Acknowledgements 

We would like to thank all the members of the Air Quality Management Work Group for their 

contribution to this effort, including participation in numerous calls and meetings, as well as 

countless hours spent reviewing the recommendations included in the final report. A special thank 

you to Daniel Greenbaum and Michael Bradley, representing the Committee on Air Quality 

Management in the United States, for their guidance throughout this process. 

Janet McCabe, Co-Chair 

Gregory Green, Co-Chair 

Recommendations by the Air Quality Management Work Group 

Table of Contents 

Executive Summary.......................................................................................................................v

Introduction ....................................................................................................................................3

The Air Quality Management Work Group...................................................................................7

Next Steps.....................................................................................................................................10

Air Quality Management Work Group Recommendations.......................................................11

NRC 1: Strengthen Scientific and Technical Capacity.............................................................13

1.1 Emissions Measurements and Reporting ..............................................................13

1.2 Emissions Factors and Estimation Methods .........................................................14

1.3 Uncertainty in Emissions Inventories and Modeling ............................................15

1.4 Multipollutant Monitoring.........................................................................................15

1.5 Framework for Accountability......................................................................................16

NRC 2: Expand National and Multistate Control Strategies ....................................................17

Sectors for Further Study and Possible National and Regional Regulations.................19

2.1 Industrial, Commercial, and Institutional Boilers..................................................19

2.2 Industrial Surface Coatings .....................................................................................20

2.3 Non-Industrial Solvents............................................................................................20

2.4 Architectural Coatings .............................................................................................20

2.5 Heavy-Duty Diesel Engines......................................................................................20

2.6 Emissions from Ships, Locomotives, and Aircraft, and Mobile Source Air 

Toxics...............................................................................................................................21

Evaluation of Additional Emissions Reduction Potential and Cost-Effectiveness ........22

2.7 Cement Manufacturing, Petroleum Refining, and Pulp and Paper......................22

2.8 Residential Fossil Fuel Combustion.......................................................................22

National Guidance for Local Controls.................................................................................22

2.9 Guidance for Local Control Measures in Key Sectors..........................................22

2.10 Residential Wood Smoke.......................................................................................23

2.11 Open Burning ..........................................................................................................24

2.12 High-Emitting Gasoline Vehicles ..........................................................................24

2.13 Conformity...............................................................................................................25

NRC 3: Transform the SIP Process............................................................................................25

Streamlining the SIP Process...............................................................................................26

3.1 Align SIP Submittal Dates........................................................................................26

3.2 Protocol for SIP Development .................................................................................26

3.3 Clearinghouse of Approved SIPs............................................................................27

3.4 Streamline Minor SIP Revisions..............................................................................27

3.5 Timely EPA Guidance...............................................................................................28

3.6 Avoid Unnecessary Public Hearings ......................................................................28

:: i 
Recommendations by the Air Quality Management Work Group 

3.7 Facilitate Redesignation Process for Certain Areas .............................................28

Measures to Improve Communication to the Public..........................................................29

3.8 Effective Communication with Constituencies......................................................29

3.9 Co-Benefits of Innovative Measures.......................................................................29

Steps to Increase Adoption of Innovative Measures.........................................................29

3.10 Innovative and Voluntary Measures......................................................................29

3.11 SIP Credits for Bundled Innovative Measures.....................................................29

Steps toward Transformation: Improving SIP Development and Evaluation .................30

Increasing Collaboration in SIP Planning and Control-Strategy Development....................30

3.12 Regional Approaches to SIP Planning..................................................................30

3.13 Federal and State Partnership...............................................................................30

Steps to Improve Tracking and Evaluation of Results ......................................................31

3.14 Weight-of-Evidence Demonstrations....................................................................31

3.15 Periodic Assessments to Track Progress............................................................32

3.16 Averaging, Banking, and Trading in Gasoline Sulfur Program..........................32

NRC 4: Develop Integrated Program for Criteria and Hazardous Air Pollutants...................33

4.1 SIPs to Address Multipollutant Impacts .................................................................33

4.2 Multipollutant Benefits and Disbenefits in Standards Setting .............................33

4.3 Greenhouse Gas Co-Benefits and Disbenefits......................................................33

NRC 5: Enhance Protection of Ecosystems and Public Welfare ............................................34

5.1 Program Review to Improve Ecosystem Protection .............................................34

Unresolved Issues for Further Discussion................................................................................37

Looking Forward: Long-Term Realignment of the AQM System............................................41

Long-Term AQM Vision: Core Principles ..................................................................................43

Long-Term Framework Options .................................................................................................44

Option 1: National Technology-Based Standards..............................................................44

Option 2: Meeting Environmental Goals with Emissions Caps and Trading ..................45

Option 3: Multipollutant, Performance-Based Standards .................................................46

Option 4: Continuous Improvement Program ....................................................................46

Moving Forward: Continuing the Evaluation Process.......................................................46

Conclusions..................................................................................................................................49

ii :: 
Recommendations by the Air Quality Management Work Group 

Appendix A: Air Quality Management Work Group................................................................ A-1

Organizational Structure for Response to CAAAC on NAS Report: .................................... A-3

Work Group Members: .............................................................................................................. A-4

Appendix B: Recommendations Matrix & Background Papers ............................................ B-1

Recommendations Matrix ......................................................................................................... B-3

Recommendations: Background Papers............................................................................... B-11

Appendix C: Summary of Unresolved Issues For Further Discussion ................................ C-1

Appendix D: Letter Transmitting Final Report to EPA........................................................... D-1

Appendix E: Commentaries from Clean Air Act Advisory Members.................................... E-1

:: iii 

Recommendations by the Air Quality Management Work Group 

Executive Summary

:: v 

Recommendations by the Air Quality Management Work Group 

Executive Summary 

In June 2004, the Clean Air Act Advisory Committee (CAAAC) formed the Air Quality 

Management Work Group. The Work Group’s task was to assess the recommendations made by 

the National Research Council (NRC) of the National Academies in its 2004 report, Air Quality 

Management in the United States,1

 and to advise the CAAAC on ways to improve the U.S. air 

quality management system, with an emphasis on activities that could be accomplished in the 

next one to five years. The NRC report described the dramatic improvements in air quality 

achieved in the U.S. since 1970, and the resulting improvements in human health and the 

environment. Despite these improvements, however, the NRC found that air quality challenges 

remain in many areas of the country, especially in heavily populated areas, with significant 

implications for public health. It noted a number of areas in which the air quality management 

system could be enhanced to allow progress to continue in a more effective and efficient manner. 

Recognizing this, the CAAAC charged the Work Group with outlining concrete steps that could 

promote change in the directions recommended by the NRC. 

The Work Group formed two subgroups, the Science and Technology Subgroup and the Policy 

and Planning Subgroup, to focus on the critical issues outlined in the NRC report. From June 

through December 2004, the Work Group considered many options for change. The Work Group 

included representatives from State and Local organizations, Tribal interests, regional 

organizations, environmental and public health organizations, industry, and the United States 

Environmental Protection Agency (EPA). 

In this report, the Work Group advances detailed recommendations. These recommendations 

address the five main areas of concern of the NRC: 

1) Strengthening scientific and technical capacity. 

2) Expanding national and multistate control strategies. 

3) Transforming the SIP process. 

4) Developing an integrated program for criteria and hazardous air pollutants. 

5) Enhancing protection of ecosystems and public welfare. 

The overall objective of this Work Group is for these recommendations to be implemented by EPA, 

States and others in order to make further improvements in air quality, which will result in improved 

human health and ecosystem protection. The recommendations presented in this report are designed to 

be implemented in the near term. Some of them require short-term process changes or alterations to 

existing policies that can be accomplished relatively quickly and will result in substantial 

improvements in efficiency and effectiveness of current programs. These recommendations will 

streamline processes, improve resource allocation, and enhance scientific and technical capacity. 

Other recommendations suggest initial steps that should be taken to form the basis for longer-term 

initiatives to be carried forward into the future. These recommendations focus on larger-scale efforts 

that would transform the air quality management system in more fundamental ways and further 

strengthen its scientific and technical underpinnings. These latter efforts would, of course, require 

more resources and time to implement fully. However, the Work Group regards them as critical steps 

that must be taken soon so that long-term gains can be realized. 

 

1

 http://www.nap.edu/books/0309089328/html. 

:: vii 
Recommendations by the Air Quality Management Work Group 

Over the past six months, the Work Group also considered a variety of other issues on which it is 

not prepared to make recommendations at this time. Some topics were so complex, resource 

intensive, or controversial that the Work Group was unable to reach consensus and, therefore, has 

decided not to try to resolve them at present. Additional discussion on these topics is expected in 

the future. The Work Group has also begun considering options for the air quality management 

system in the future. It evaluated the long-term challenges facing air quality management in the 

U.S. from a number of perspectives and identified several criteria that may help guide discussions 

on alternatives for reforming the current system in future years. To help begin this process, the 

Work Group outlines four approaches reflecting different views that could serve as the basis for a 

more complete transformation of the air quality management system. In addition, the Work 

Group recommends that discussion of future options and unresolved issues be continued over the 

next several months. 

The Work Group advises that the recommendations contained in this report be implemented by 

EPA, State, local, and Tribal environmental organizations, and other stakeholders in the 

immediate future. Several of the recommendations are critical because of impending 

implementation plans for ozone, PM2.5 and regional haze. The Work Group, however, is sensitive 

to the level of resources needed to implement these recommendations and understands that EPA 

should establish priorities that reflect practical constraints. All of these recommendations can be 

implemented under the current authority of the Clean Air Act (CAA). 

Specifically, the Work Group recommends: 

A new CAAAC subcommittee should be established to continue the assessment and 

development of recommendations for long-term changes to the air quality management 

system and to address the issues on which the Work Group could not reach consensus. 

Until the subcommittee is formed, the current AQM Work Group should continue 

working to further define and resolve additional issues and long-term framework options. 

•

•

•

•

The Work Group recommends that EPA carefully consider the recommendations and 

issue a response to CAAAC outlining a plan for implementation, and that EPA report 

back to the CAAAC subcommittee periodically on its implementation efforts. 

The new subcommittee, in conjunction with existing CAAAC subcommittees, should be 

assigned the responsibility for overseeing the implementation of, and any modifications 

to, the recommendations contained in this report. 

Following its establishment, the new subcommittee should develop a timeline for delivery of 

new recommendations and provide periodic progress reports to CAAAC. Discussion by the 

subcommittee on remaining issues and options should be directed towards further 

strengthening the U.S. air quality management framework over the next decade. 

viii :: 
Air Quality Management Work Group 

Report to the Clean Air Act Advisory Committee 

Recommendations by the Air Quality Management Work Group 

Introduction 

:: 3 

Recommendations by the Air Quality Management Work Group 

Introduction 

In 2004, the National Research Council (NRC) of the National Academies released a report 

entitled Air Quality Management in the United States. In this report, the NRC outlined the many 

substantial achievements of the United States air quality management (AQM) system over the 

past 30 years. Controls on air pollution enacted under the Clean Air Act have led to dramatic 

declines in emissions and air quality concentrations of a number of pollutants (Figure 1). The 

NRC concluded that these controls have been highly cost effective and have promoted the 

advancement of new technologies for pollution control. 

Figure 1. National Air Quality and Emissions Trends for selected ‘Criteria’ Pollutants.2 

A) Long-term air quality trends and, B) national emissions trends illustrate the continuing improvement achieved 

by air quality management under the Clean Air Act. 

 

2

 U.S. EPA Air Quality System (http://www.epa.gov/ttn/airs/airsaqs). 

:: 5 
Recommendations by the Air Quality Management Work Group 

Overall, the nation has achieved a 51 percent decrease in aggregate emissions of the six principal 

air pollutants and their precursors since 1970, despite significant increases in population, energy 

consumption, gross domestic product, and vehicle miles traveled (Figure 2). These successes 

demonstrate that implementation of the Clean Air Act has resulted in significant progress toward 

improving the nation’s air quality and protecting the health of its citizens. 

70 80 90 95 96 97 98 99 01 00 02 03

-50%

0%

50%

100%

150%

200%

176%

155%

45%

39%

-51%

Comparison of Growth Areas and Emissions

Gross Domestic Product

Vehicle Miles Traveled

Energy Consumption

Population

Aggregate Emissions

(Six Principal Pollutants)

Figure 2. Comparison of Growth Areas and Emissions.3 Between 1970 and 2003, gross domestic product 

increased 176 percent, vehicle miles traveled increased 155 percent, energy consumption increased 45 percent, 

and U.S. population grew by 39 percent. During the same time period, total emissions of the six principal air 

pollutants dropped by 51 percent. 

Looking to how such successes can be sustained or expanded in the future, the NRC identified 

areas where modifications to the AQM system could provide further benefits to human health and 

the environment in the most effective and efficient manner (see Figure 3). Some of the NRC’s 

recommendations involve near-term changes with immediate impact. Other NRC 

recommendations focus on more sweeping changes to the nation’s approach to air quality 

management over the mid- to long-term. Taken together, these recommendations provide the 

NRC’s vision of how AQM in the United States could be reshaped and improved to achieve 

greater benefits more rapidly and at lower cost. 

 

3

 http://www.epa.gov/air/airtrends/aqtrnd03/images/growth-and-emissions.gif. 

6 :: 
Recommendations by the Air Quality Management Work Group 

The Challenges Ahead

Meeting National Ambient Air 

Quality Standards for ozone 

and particulate matter at 2.5 μm 

in diameter and reducing 

regional haze

Designing and implementing 

controls for hazardous air 

pollutants

Protecting human health and 

welfare in the absence of a 

threshold exposure

Ensuring environmental justice

Assessing and protecting 

ecosystem health

Mitigating intercontinental and 

cross-border transport

Maintaining AQM system 

efficiency in the face of 

changing climate

To begin the evolution of AQM 

toward these objectives in the 

United States, five interrelated 

Recommendations and related 

Actions are proposed

AQM Should Strive To:

The Long-Term Objectives 

for AQM to Meet Future 

Challenges

Identify and assess most 

significant exposures, risks, and 

uncertainties

Take an integrated 

multipollutant approach to 

mitigating most significant risks

Take an airshed-based 

approach to controlling 

emissions

Emphasize results over 

process, create accountability, 

and dynamically adjust

RECOMMENDATION 1: Strengthen Scientific 

and Technical Capacity

ACTIONS: Improve emissions tracking, enhance air 

pollution monitoring, improve modeling, enhance exposure 

assessment, improve health and welfare assessment, track 

implementation costs, and invest in research and human and 

technical resources

RECOMMENDATION 2: Expand National and 

Multistate Control Strategies

ACTIONS: Expand federal emission controls, emphasize 

technology-neutral standards, use market-based approaches, 

reduce existing-sources emissions, and address multistate 

regional transport

RECOMMENDATION 3: Transform the 

SIP Process 

ACTIONS: Replace state implementation plan with 

integrated multipollutant air quality management plan and 

reform process to focus on tracking results using periodic 

reviews, encouraging innovative strategies, and retaining 

conformity and federal oversight

RECOMMENDATION 4: Develop Integrated 

Program for Criteria and Hazardous Air Pollution 

ACTIONS: Set priorities for pollutants, institute dynamic 

review of pollutant classification, list potentially dangerous but 

unregulated pollutants, address multipollutants in standardsetting process, and enhance residual assessment

RECOMMENDATION 5: Enhance Protection of 

Ecosystems and Public Welfare

ACTIONS: Conduct review of standards to protect public 

welfare, develop ecosystem monitoring networks, establish 

acceptable ecosystem exposure levels, promulgate 

secondary standards, and track progress

Figure 3. NRC Vision for an Enhanced AQM System.4 To meet the major challenges that air quality 

management efforts will face in the future, the NRC identified a set of overarching long-term objectives. 

The Air Quality Management Work Group 

Following the recommendation of the NRC to establish a stakeholder group to oversee 

implementation of its recommendations,5

 the Clean Air Act Advisory Committee (CAAAC), a 

body chartered under the Federal Advisory Committee Act, formed an Air Quality Management 

Work Group (hereafter “Work Group”). This group was charged with evaluating the NRC’s 

recommendations and advising the CAAAC on ways to improve the AQM system in the nearterm. The Work Group included representatives from State and local organizations, Tribal 

interests, regional organizations, environmental and public health organizations, industry, and the 

Environmental Protection Agency (EPA). For a list of the Work Group members, see Appendix A 

of this report. 

From June through December 2004, the Work Group considered many options to improve the 

U.S. air quality management system consistent with the NRC report. To organize its discussion, 

the Work Group formed two subgroups: one to address scientific and technological issues, and 

the other to address policy and planning issues. The Science and Technology Subgroup worked in 

 

4

 National Research Council, Air Quality Management in the United States, (Washington, D.C.; National Academies 

Press, 2004), p. 10. 5

 NRC Report, p. 314. 

:: 7 
Recommendations by the Air Quality Management Work Group 

a cross-disciplinary mode on most issues, but formed separate work teams that focused on health 

and exposure, and ecosystem issues. The Policy and Planning Subgroup also subdivided into 

teams that focused on: 1) improving the State Implementation Plan (SIP) process; 2) expanding 

the use of regional and national strategies; and 3) encouraging innovation and developing 

multipollutant approaches. A fourth team began to discuss longer-term visions of air quality 

management. Members from both the Science and Technology Subgroup and the Policy and 

Planning Subgroup, as well as outside academics, focused on developing more robust approaches 

for health and ecosystem issues. For an organizational chart showing the subgroups and work 

teams, see Appendix A. 

All of these subgroups and teams met, separately and together, on numerous occasions to develop 

a set of detailed recommendations responding to the NRC report. The teams took as their starting 

point the four long-term objectives set forth in the NRC report (see Figure 3), and the five 

overarching recommendations the NRC suggested as steps toward achieving those objectives. 

Some of the recommendations outlined by the NRC that would require statutory change are not 

feasible in the near-term and are not addressed in this report. The NRC clearly recognized that the 

more significant changes embedded in its broad vision will take time to develop, and that some 

more immediate actions are warranted to assist States as they develop new ozone (8-hour), fine 

particle (PM2.5), and regional haze SIPs in the next few years. As the NRC wrote after outlining 

its four long-term objectives, 

“Immediate attainment of these objectives is unrealistic. It would require a level of scientific 

understanding that has yet to be developed, a commitment of resources that would be difficult 

to obtain in the short term, and a rapid transformation of the AQM system that is undesirable 

in light of the system’s past successes. The committee proposes, therefore, that the AQM 

system be enhanced so that it steadily evolves toward meeting these objectives.”6

 

In the pages that follow, the Work Group provides a series of recommendations intended to begin 

this steady evolution. If implemented, these recommendations would build upon and strengthen 

the current system, starting with important modifications in the methods and technologies used to 

collect scientific data, as well as the ways those data are translated into control decisions. Though 

some of the recommendations will require further development to become wholly effective, they 

provide a necessary foundation for improving air quality programs. The Work Group agrees with 

the NRC findings that both short- and long-term changes are needed. The Work Group is, 

however, acutely aware of what is achievable within the next five years, and has, therefore, 

focused on short-term, pressing concerns such as providing support for the development of the 

upcoming SIPs. These actions include enhancing emissions inventories, redefining the role of air 

quality modeling, assisting in the development of multipollutant planning and control strategies, 

achieving reductions from mobile sources, and supporting innovative approaches to air quality 

improvement. 

As the Work Group developed recommendations, the need for three categories of 

recommendations quickly became evident: 1) recommendations upon which there was substantial 

consensus among Work Group members; 2) recommendations upon which there was not 

consensus, but on which consensus might be reached with additional discussion by the Work 

Group or a follow-on group; and 3) recommendations that relate to an overarching long-term 

vision. This report presents the Work Group’s recommendations in each of these categories. 

 

6

 NRC Report, p. 16. 

8 :: 
Recommendations by the Air Quality Management Work Group 

As a way of illustrating graphically how the system currently operates to manage and improve air 

quality and the performance of control programs, Figure 4 depicts the connections among the 

major components of the air quality management system. In this report, the Work Group first lays 

out a series of detailed recommendations that will improve how different components in the 

system are managed and enhance the feedback loops between the components. In these 38 

recommendations, the Work Group offers concrete suggestions on how to improve the scientific 

and technical foundation of the AQM process, and how to enhance the policy and planning 

activities built on the scientific and technical foundation. 

NAAQS

Acid Rain Caps

Visibility

I. Establish Goals

Emissions

Rule Effectiveness

Monitoring (air quality)

Modeling

Record Keeping

Reporting

V. Track and 

Evaluate Results

II. Determine 

Emissions 

Reductions

Monitoring

Emissions Inventories

Modeling

III. Develop 

Reduction 

Programs

National Rules

Mobile Sources

Fuels

NSPS Stationary

MACT / Residual Risks

Acid Rain Program

Regional Programs

State/Local/Tribal Plans

IV. Implement 

Reduction 

Strategies/

Enforcement

Sources Comply

Permits

Figure 4. Conceptual Diagram of the Air Quality Management Process. Air quality management should be 

an iterative process of continuous improvement: (I) National goals are established by Congress or EPA. (II) 

Scientific and technical information are key to determining what pollutants need to be reduced, by how much, 

and over what scale and time. (III) Strategies are then developed to achieve needed pollution reductions. Over 

time, the CAA Amendments have added emphasis on national controls for mobile sources and some stationary 

sources. The States (SIP process) are responsible for developing additional reduction programs as needed. (IV) 

SIPs are then adopted and enforced as sources implement reduction measures. (V) Finally, air quality and 

emissions are tracked to determine how well the measures worked to improve air quality. Depending on the 

outcome, the process may require further iterations. 

The Work Group recognizes that among the many suggestions for change outlined, virtually all 

require an expenditure of resources by EPA, States/Locals/Tribes (S/L/T), or other organizations, 

and, in some cases, may require large resource commitments over many years. Thus, either new 

resources need to be identified for implementation of the recommendations in this report, or a 

discussion needs to occur about reallocation of existing resources at the State and Federal level. 

The Work Group is very sensitive to these resource considerations and understands that priorities 

must be established which reflect the practical constraints. The Work Group lacked the time and 

information to complete prioritization during the first phase of its discussion, but would like to 

work with the CAAAC and EPA to assist them in setting priorities over the next few months. Key 

considerations should include, but are not limited to: whether the change is needed to assist the 

development of ozone, PM2.5 and regional haze SIPs; whether the action is one not currently 

underway, but could greatly improve the current process if implemented by a certain time; and 

whether the recommendation relates to critically needed improvements that will take multiple 

years to accomplish and, therefore, needs to be initiated soon. 

:: 9 
Recommendations by the Air Quality Management Work Group 

After presenting the recommendations on which the Work Group was able to reach substantial 

consensus, the report highlights a number of other crucial issues that the Work Group has 

discussed. Though the Work Group has not yet been able to reach consensus on these issues, it 

has engaged in considerable debate and is now prepared to summarize that debate and outline a 

suggested process for further discussion in the future. 

For areas requiring longer-term or more fundamental changes, the Work Group has focused on 

outlining possibilities and initial steps which could steer the AQM system in the desired direction. 

The final section of this report lays out important criteria to consider when designing new air 

quality management programs in the future, and outlines briefly four options for a revised AQM 

framework that the Work Group considered, but upon which it has not reached final conclusions. 

The Work Group recognizes, however, that even these four options do not address the universe of 

potential changes, either minor or substantial, that could be considered in a comprehensive look at 

the current AQM system. 

Next Steps 

The Work Group recommends that decisions on implementation of the recommendations in this 

report, as well as discussion of future options and unresolved issues, be continued over the next 

several months. These continuing discussions would also allow review and/or adjustment of the 

near-term recommendations if warranted. Specifically, the Work Group recommends: 

A new subcommittee of CAAAC should be established to continue the assessment and 

development of recommendations for long-term changes to the air quality management 

system and the issues on which the Work Group could not reach consensus. Until this 

subcommittee is formed, the current Work Group should continue working to resolve 

additional issues and discuss long-term framework options. Following its establishment 

under the CAAAC, the subcommittee should develop a timeline for preparing additional 

recommendations and provide periodic progress reports to CAAAC. Discussion of all 

remaining issues and options should be directed towards further strengthening the U.S. 

air quality management framework over the next decade. The Work Group recommends 

that the new subcommittee, in conjunction with existing subcommittees, also be given the 

responsibility for overseeing the implementation of, and any modifications to, the 

recommendations contained in this report. 

•

• EPA should carefully consider the recommendations presented in this report, and should 

issue a response to the CAAAC as soon as practical outlining a plan for implementing 

those recommendations to the extent possible. The CAAAC should support EPA’s 

development of this plan. EPA should report back to the newly formed CAAAC 

subcommittee periodically on its implementation efforts. 

10 :: 
Recommendations by the Air Quality Management Work Group 

Air Quality Management Work Group 

Recommendations 

:: 11 

Recommendations by the Air Quality Management Work Group 

Air Quality Management Work Group Recommendations 

In the next five sections of the report, the Work Group lays out 38 recommendations on which it 

achieved substantial consensus (see Recommendations Matrix: Appendix B). These detailed 

recommendations are organized according to the five overarching recommendations of the NRC 

(see Figure 3, above). At the top of each section, a header identifies the relevant NRC 

recommendation. The recommendations outlined in these five sections are also detailed in 

background papers found in Appendix B, with more complete information about background, 

supporting evidence, feasibility considerations, and preliminary resource estimates. For many of 

the recommendations, the Work Group has defined an appropriate time frame for implementation, 

with most starting as soon as possible. This set of recommendations, if implemented, will 

strengthen the current AQM system by streamlining processes, improving the quality of data, and 

enhancing the efficiency and effectiveness of current control efforts.

NRC 1: Strengthen Scientific and Technical Capacity 

The NRC noted that a key to improving air quality management in the United States is improving 

our knowledge concerning the sources and emissions of air pollutants and their precursors, the 

mechanisms of their fate and transport, and their impacts on human health and the environment. 

Achieving these goals will require significant efforts on many fronts. First, the Work Group 

recommends significant improvements in the collection, management, and analysis of emissions 

and ambient air quality data. This step is critical for moving the nation’s AQM system toward a 

more performance-oriented approach, and for supporting a framework to track significant healthand ecosystem-based outcomes. On the scientific and technical front, the Work Group makes the 

five recommendations below. 

The first two recommendations focus on improving the information we currently have about 

emissions of air pollutants. Recent studies have noted many deficiencies in current emissions 

inventories (e.g., NARSTO 2004), such as poorly defined emissions factors and inefficient 

emissions reporting. Improved emissions inventories are needed to provide for more effective 

planning for control strategies and to meet future air quality challenges. Therefore, the Work 

Group recommends: 

1.1 Emissions Measurements and Reporting - EPA, in conjunction with 

States/Local/Tribes (S/L/T) and affected stakeholders, should pursue improved emissions 

measurements and reporting to enhance emissions databases for more accurate air quality 

assessments and tracking of progress. A strong national effort is needed to require emissions 

measurements and reporting for as many major source categories as possible. The primary 

objective of this recommendation is to produce accurate emissions data for supporting control 

strategy planning and tracking progress (and establishing accountability mechanisms because 

they reduce uncertainty in emissions inventories), enhancing opportunities to establish viable 

emissions trading programs, supporting air quality modeling, and increasing certainty for 

compliance purposes. In 2005 and 2006, EPA, in conjunction with S/L/T and affected 

stakeholders, should: 

Conduct a study to identify relevant existing emissions measurement methodologies, 

categories for which these methodologies are necessary and appropriate, and protocols 

for conducting these measurements. 

•

:: 13 
Recommendations by the Air Quality Management Work Group 

•

•

•

•

•

 

Identify efforts needed to develop new emissions measurement methodologies and 

technologies for other source categories (e.g., continuous emissions monitors (CEMs),7

“random” stack testing for minor sources and remote sensing). 

Evaluate the need for and appropriateness of regulations to require emissions 

measurements. As necessary and appropriate, EPA should undertake rulemaking to 

establish these requirements as soon as possible. 

Evaluate the need for and appropriateness of regulations to require reporting of emissions 

measurements to a user-friendly central database, similar to EPA’s Acid Rain database 

for Electric Generating Units (EGUs). As necessary and appropriate, EPA should 

establish these requirements through rulemaking as soon as possible. 

Figure 5. Continuous 

Emissions Monitor. 

These instruments 

provide high quality 

information on air 

emissions and exhaust 

gas characteristics. See 

Recommendation 1.1. 

Photo credit: Inquest 

Environmental, Inc. 

1.2 Emissions Factors and Estimation Methods - Where emissions measurement-based 

information is impractical to obtain for air quality assessments, or where improved projections 

are needed, EPA, in conjunction with S/L/T and affected stakeholders, should improve 

emissions factors and emission estimation methods. A strong national effort is needed to 

improve emission estimation methods for major source categories, especially for sources that 

are poorly characterized or whose emissions estimates are uncertain. The primary objective of 

this recommendation is to produce better emissions inventories for supporting air quality 

modeling and tracking progress. In 2005 and 2006, EPA, in conjunction with S/L/T and 

affected stakeholders, should: 

Review existing emissions factors to identify the most significant needs, recommend and 

prioritize data collection and steps necessary for improving emissions factors, and 

develop and implement procedures for quickly disseminating new emissions factors. 

Review existing source profiles used in source-based (and receptor-based) modeling to 

identify the most significant source profile needs, and recommend and prioritize data 

7

 CEMs are already required by Title IV of the Clean Air Act for certain Electric Generating Units, by the Ozone 

Transport Commission’s (OTC) NOx Trading Program for several source categories, including industrial boilers, 

turbines, and cement kilns, or by numerous NESHAPS or NSPS. 

14 :: 
Recommendations by the Air Quality Management Work Group 

collection and steps necessary for improving or developing source profiles for poorly 

characterized sources. 

Conduct a study to reconcile current emissions inventories with ambient measurements. 

Based on the study, EPA should work with the S/L/T and affected stakeholders to 

improve emissions estimates. 

•

•

•

•

•

•

Recommendation 1.3 seeks to improve the usefulness and acceptance of technical information for 

air quality planning and decisionmaking. The Work Group recommends: 

1.3 Uncertainty in Emissions Inventories and Modeling - EPA, in conjunction with 

S/L/T and affected stakeholders, should quantify and take actions to reduce uncertainty in 

emissions inventories and air quality modeling applications, provide guidance for 

incorporating uncertainty assessments into SIP planning, and improve communication of 

uncertainty to decision-makers. Technical analyses performed to support policy development 

address complex and sometimes poorly understood problems. While serious attempts are made 

to rely on the best science available at the time, there are limitations to these analyses. In 2005 

and 2006, EPA, in conjunction with S/L/T and affected stakeholders, should conduct the 

following actions to better characterize, quantify, and reduce uncertainty in existing emissions 

inventories and modeling analyses: 

Conduct a study to evaluate sources of uncertainty in emissions inventories and modeling 

analyses for all sources; identify needed data collection activities (and associated costs) to 

reduce the most significant emissions uncertainties; and identify appropriate methods for 

incorporating uncertainty in preparing emissions inventories and conducting modeling 

analyses. Uncertainty also is present in monitoring data, but it can be better characterized. 

Provide guidance to S/L/T for incorporating uncertainty assessments in SIP and Tribal 

Implementation Plan (TIP) planning. 

Recommendation 1.4 seeks to provide more scientifically relevant and responsive data for air 

quality planning and tracking progress, and to provide a more robust and spatially complete basis 

for current and future air quality planning. Specifically, the AQM Work Group recommends: 

1.4 Multipollutant Monitoring - EPA, in conjunction with S/L/T and affected stakeholders, 

should promote and improve integrated, multipollutant monitoring. Over the past 30 years, the 

air pollution situation has changed significantly as control programs have reduced emissions of 

many pollutants and as science has identified emerging issues of concern. Accordingly, it is 

important that air monitoring efforts be more dynamic and responsive to meet the current and 

future public, regulatory, and scientific needs. To promote and improve monitoring over the 

next 3 to 4 years, EPA, in conjunction with S/L/T and affected stakeholders, should: 

Finalize its proposed national ambient monitoring strategy, and S/L/T should, as 

appropriate, work together on a regional scale to consider the need for, and, if appropriate 

develop, regional monitoring strategies. 

Establish a minimum of six Level I (research-grade) NCore sites with reasonable 

geographic coverage (e.g., one each in the Northeast, Southeast, Midwest, and South, and 

two in the West), and in conjunction with S/L/T, establish the Level II (multipollutant) 

NCore sites (see Figure 6). 

Support research and development to improve monitoring methods for several pollutants, 

including PM2.5, PM-coarse, and air toxics. 

:: 15 
Recommendations by the Air Quality Management Work Group 

• Promote policies to avoid disincentives for monitoring. 

• Promote co-location of atmospheric dry and wet deposition monitoring with long-term 

monitoring of ecological conditions whenever possible. 

Figure 6. Enhanced 

Multipollutant Monitoring 

Site. Ambient monitoring site 

operated by the Wisconsin 

Department of Natural 

Resources in Mayville, 

Wisconsin, which includes the 

multipollutant measurements 

associated with Level II NCore 

sites. 

At the core of the NRC recommendations for transforming the Air Quality Management system 

in the U.S., was a call to create accountability for the results, and dynamically adjust and correct 

the system in response to data from programs that track progress. The Work Group recognizes 

that substantial information and tools already exist for expanding the role of tracking in the SIP 

process and has made some recommendations for beginning to expand the role of tracking and 

evaluation in the process (see Recommendations 3.14 and 3.15). Nevertheless, the kind of 

comprehensive approach envisioned by the NRC will take a concerted effort that includes 

assessing the available scientific information (e.g., identifying and expanding new research and 

assessments programs). To promote understanding and characterization of the impacts of air 

quality changes on health and ecosystem outcomes, and to improve the scientific basis for more 

informed policy decisions, including the need for and nature of air quality standards, the Work 

Group recommends: 

1.5 Framework for Accountability - EPA, in conjunction with atmospheric scientists, health and 

ecosystem experts, S/L/T, and affected stakeholders, should undertake a systematic effort to track air 

quality achievements and evaluate air program results. This effort should begin by focusing on the 

progression and associations of air emissions as they interact and ultimately affect human health and 

the environment. In order to move beyond the current approach of relying predominantly on air quality 

measurements, we need to further develop and apply the capacity to monitor, assess, and report on how 

changes in emissions impact air quality, atmospheric deposition, exposure, and effects on human health 

and ecosystems. Emphasis should be placed on developing and enhancing appropriate health and 

ecosystem indicators, benchmarks, and subsequent analyses within this overarching accountability 

framework. To establish greater accountability for protecting human health and the 

environment, EPA should better track, assess, and communicate significant results of emissions 

control programs, including changes in sources and emissions, air quality and atmospheric 

deposition, exposures, and effects. Emphasis should be placed on systematically measuring 

progress and assessing benefits of air quality management through enhancing and expanding 

the suite of benchmarks and indicators of health and ecological outcomes. The Work Group 

recommends a 3-part approach involving health effects, ecosystem effects, and SIP planning 

16 :: 
Recommendations by the Air Quality Management Work Group 

for systematically ensuring that air policies and programs are achieving intended results. Over 

the next two years, the Work Group recommends: 

•

o

o

o

•

o

o

o

o

•

EPA should work with health effects experts (e.g., federal agencies under the Committee on the 

Environment and Natural Resources (CENR) Air Quality Research Subcommittee; the Clean 

Air Scientific Advisory Committee, the State/EPA/Center for Disease Control/EPA 

environmental public health tracking partners, and the Health Effects Institute) to develop 

measures to define and assess human health impacts of air pollution and ways to track and 

evaluate progress in reducing those impacts. Specific actions include: 

Facilitating communications among health research and program accountability 

efforts; 

Expanding on-going efforts into public health and air quality accountability; and 

Undertaking specific accountability efforts. 

EPA should work with others to develop benchmarks and measures to assess ecological 

impacts of air pollution and improve ways to track and evaluate progress in reducing 

those impacts. Specific actions include: 

Improving tracking and assessing the effects of multiple air pollutants on 

ecosystems; 

Conducting and facilitating integrated assessments and research to develop and 

implement an appropriate suite of measurements for detecting ecosystem 

response; 

Facilitating and pursuing collaboration on integrated assessments; and 

Examining the possibility of using critical loads and thresholds. 

EPA should work with S/L/T to determine appropriate metrics which should be used to 

more effectively track progress. 

NRC 2: Expand National and Multistate Control Strategies 

As the NRC has indicated, national and multistate approaches to pollution control have been 

particularly effective in reducing emissions and should be implemented more widely. In addition, 

national or regional approaches incorporating cap-and-trade provisions can be efficient 

mechanisms for reducing regional air emissions. While recent initiatives such as the NOx SIP 

Call, the proposed Clean Air Interstate Rule (CAIR), the Heavy-Duty Diesel Rule and the NonRoad Rule are expected to expand the use of regional and national strategies, the Work Group has 

identified a number of significant stationary and mobile source categories with substantial 

emissions which should be evaluated for potential controls. 

States face an ambitious schedule for attaining the PM2.5 and 8-hour ozone standards (in 2010 for 

PM2.5 and beginning in 2007 for ozone), and for meeting regional haze requirements. The NRC 

report clearly states that regional and national controls are an integral part of any national strategy 

for cost-effective attainment of these standards. 

The NRC also recognized, however, that continued nonattainment for ozone and PM2.5 as 

projected for 2010 (assuming implementation of currently planned emissions control measures), 

will require a multipronged approach that includes innovative, federally supported local measures 

as well as regional or national controls. The Work Group agrees that an approach combining a 

:: 17 
Recommendations by the Air Quality Management Work Group 

variety of different measures will be most effective in reducing air pollution nationwide and 

solving the worst problems in nonattainment areas. Furthermore, a combination of local, regional, 

and national approaches targeting particular sectors is likely to be the most effective in addressing 

pollutants in a comprehensive and integrated fashion (see NRC Recommendation 4 on multiple 

pollutants). Therefore, strong and timely regional and national approaches are needed to 

complement State and local controls to help the nation achieve rapid improvements in air quality. 

To help direct choices of control strategies in the next few years, the Work Group considered 

future year (2010) regional and local (nonattainment area) emissions inventories, select source 

apportionment studies, and modeling analyses. The future year regional emissions inventories 

were used initially to screen a list of more than 40 categories of mobile, stationary, and area 

sources, and to identify those with the more significant criteria pollutant emissions. The other 

information (i.e., nonattainment area emissions inventories, source apportionment studies, and 

modeling analyses) was then used to help determine whether these source categories are better 

addressed at the national/regional level or the local level. 

As a result of its deliberations over the past six months, the Work Group advances several 

specific recommendations about particular sectors or strategies. Some of these recommendations 

suggest regulations at the regional and/or national level as appropriate, while others concern 

national guidance for potential application at the local level. Some of the recommendations apply 

to mobile sources, while others focus on stationary or area sources. 

Air emissions from the recommended categories are projected to continue to be substantial (see 

Figure 7). However, a variety of factors must be considered in determining whether and how a 

sector can be effectively regulated, including pollutant type, geographic location, dispersion 

patterns, multipollutant interactions, control strategy availability, emissions reduction potential, 

and cost-effectiveness. Some Work Group participants believe that adequate information exists to 

begin the regulatory process now for certain source categories, while others believe that 

additional data and data analyses are necessary. After extensive deliberations, the Work Group 

recommends that each of the sectors listed below be addressed in some fashion by EPA. This 

action may include, but should not be limited to, development of national and/or regional rules, 

control technique guidelines, other guidance, and/or further study. 

18 :: 
Recommendations by the Air Quality Management Work Group 

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

7,000,000

8,000,000

Ind/Com/Ins Boilers

Industrial Surface Coatings

Non-Industrial Solvents

Architectural Coatings 

Heavy-Duty Diesel Engines 

Ships, Locomotives, Aircraft

Cement Manufacturing

Petroleum Refining

Pulp & Paper

Residential Fossil Fuel Combustion

Residential Wood Smoke

Open Burning

Emissions (tons)

PM2.5 SO2 NOX VOC CO

Figure 7. Projected 2010 National Emissions for Key Source Categories. In developing recommendations 

relating to the source categories shown here, Work Group analysts examined projected emissions of five key 

criteria pollutants to 2010 for 40 stationary and mobile categories. Excluding electricity generating units (EGUs) 

and natural emission sources, the categories shown comprise over 70 percent of the national SOx and NOx 

emissions and about 30% of the direct PM2.5 and VOC emissions. These projections include recognized 

uncertainties in the current inventory and the forecast. Due to data limitations, the assessment did not include 

estimates of air toxics emissions or ammonia. 

In each case, EPA should review the contributions from these categories, assess the technical and 

economic feasibility of further controls, and conclude this review process as soon as possible, 

given the urgency of achieving effective air quality improvements. EPA should initiate 

appropriate actions regarding the category consistent with the results of its analysis as soon as 

possible. Because cost-effectiveness and technical feasibility are important considerations, EPA 

should also consider whether market mechanisms or program design elements, such as cap-andtrade provisions, can be employed to improve environmental results while maximizing flexibility 

and efficiency. 

Sectors for Further Study and Possible National and Regional Regulations 

The Work Group recommends that EPA consider developing national and/or regional rules for 

sectors identified as key contributors to nonattainment from a national or multistate perspective. 

The Work Group acknowledges the importance of working more directly with these industry 

sectors to further evaluate the emissions contributions from the respective categories. 

Stationary and Area Source Categories 

2.1 Industrial, Commercial, and Institutional Boilers - EPA should complete as soon 

as possible a review of the contributions from this category and the technical and economic

:: 19 
Recommendations by the Air Quality Management Work Group 

feasibility of further controls, given the high priority assigned to this sector. EPA should then 

initiate development of a regional or national emissions control regulation for the category, or 

take alternative action consistent with the results of its analysis.

2.2 Industrial Surface Coatings - EPA should complete as soon as possible a review of the 

contributions from this category and the technical and economic feasibility of further controls. 

EPA should then initiate development of a regional or national emissions control regulation 

for the category, or take alternative action consistent with the results of its analysis. 

2.3 Non-Industrial Solvents - EPA should initiate rulemaking efforts to establish minimum 

performance standards (i.e., national rules) for this category using the volatile organic 

compound (VOC) content limitations contained in, and regulating the products covered by, the 

model rule developed by the Ozone Transport Commission.

2.4 Architectural Coatings - EPA should initiate rulemaking efforts to establish minimum 

performance standards (i.e., national rules) for this category using the VOC content limitations 

contained in, and regulating the products covered by, the model rule developed by the Ozone 

Transport Commission. 

Mobile Source Categories 

In the mobile source area, the Work Group endorses the following recommendations made by the 

Mobile Source Technical Review Subcommittee of the CAAAC: 

2.5 Heavy-Duty Diesel Engines - EPA should reduce emissions from the existing fleet of 

heavy-duty diesel engines by employing a multi-pronged approach. Over the last decade, EPA 

has moved aggressively to strengthen federal emissions standards for a wide range of diesel 

engines. While these standards will serve to dramatically lower emissions when fully 

implemented, the full human health benefits will not be realized for 20 years or more. The 

delay in achieving emissions reductions is attributable to two factors: the fact that emissions 

standards do not take effect for new engines until 2004-2007, and the long lifespan of the 

existing fleet of diesel engines. The Work Group recommends that EPA employ a variety of 

strategies to monitor and reduce emissions from the in-use fleet. This is a high priority for 

action within the next 3-4 years. Recommended actions include: 

Continue working with manufacturers to ensure heavy-duty compliance and supporting 

initiatives such as heavy-duty inspection and maintenance programs, harmonized 

nationwide on-board diagnostics requirements for heavy-duty vehicles, and development 

of portable emissions measurement capabilities for diesel PM. 

•

• Encourage voluntary programs for diesel retrofits, idling reductions, and other emissions 

control strategies, concentrating on the construction, port, freight, and school bus sectors. 

Some members of the Mobile Source Technical Review Subcommittee believe EPA should consider 

expanding current federal programs through a mandatory program of accelerated retirements, retrofits, 

repowering, replacement and anti-idling measures. These stakeholders believe EPA should encourage 

retrofits for all heavy-duty diesel engines by 2012 by: (a) establishing mandatory measures to cut 

pollution from existing diesel engines; and (b) seeking Congressional appropriations to expand 

funding for programs aimed at reducing emissions from heavy-duty engines. 

20 :: 
Recommendations by the Air Quality Management Work Group 

2.6 Emissions from Ships, Locomotives, and Aircraft, and Mobile Source Air 

Toxics - EPA should address emissions from ships, locomotives, and aircraft, and mobile 

source air toxics through national emissions standards. While emissions from most categories 

of mobile sources have stabilized or decreased over the past two decades, emissions from 

ships, aircraft, and locomotives have increased and are forecast to continue to increase (Figure 

8). Nationally, these sectors produce substantial emissions of both criteria pollutants and air 

toxics, and they represent major sources of pollution at the local level. EPA should control 

criteria and toxic pollutant emissions from ships, aircraft and locomotives, and other mobile 

source air toxics by: 

Promulgating technology-forcing emissions standards for all new marine diesel engines, 

all new and rebuilt locomotive engines, and all aircraft engines. 

•

•

•

Developing national rules to control mobile source air toxics and criteria pollutants 

through fuel reformulation (e.g., national benzene cap, lower sulfur fuels). 

Developing strategies for reducing emissions at airports, seaports and rail yards that can 

be employed at the S/L/T level, such as reducing engine idling and taxiing, imposing 

differential landing fees, using gate-powered electricity, or reducing emissions from 

ground service equipment. 

EPA has already begun action for some of the source categories outlined above. Current plans 

call for a Notice of Proposed Rulemaking (NPRM) on gasoline outboard, sterndrive, inboard and 

personal watercraft engines in the Spring of 2005; an NPRM on locomotive and marine diesel 

standards in mid-2005; an NPRM on air toxics in mid-2005; a final rule adopting the existing 

International Civil Aviation Organization NOx standards for aircraft engines in 2005; and a final 

rule on ocean-going marine diesel engines by mid-2007. EPA should give high priority to 

continuing the development of these standards and adopting additional control strategies, as 

necessary. 

0

2,000,000

4,000,000

6,000,000

8,000,000

10,000,000

12,000,000

14,000,000

1996 2030

on-highway

nonroad-diesel

other nonroad

aircraft

locomotives

marine

Planes

Trains

Ships

Figure 8. Mobile Source NOx Emissions Projections. Over the next 30 years, highway emissions are projected 

to decrease greatly, with the result that categories with limited controls – ships, locomotives, and aircraft – will 

become of increasing relative importance for air pollution control strategies. See Recommendation 2.6. 

:: 21 
Recommendations by the Air Quality Management Work Group 

Evaluation of Additional Emissions Reduction Potential and CostEffectiveness 

For some sectors, the Work Group did not reach consensus on whether there are sufficient data to 

recommend that EPA consider national and/or regional strategies at this time. The Work Group 

determined that additional research and consultation was necessary to clarify the timing and 

levels of national or regional pollution-reduction measures that would be appropriate for the 

following potentially important sectors: 

2.7 Cement Manufacturing, Petroleum Refining, and Pulp and Paper - The cement 

manufacturing, petroleum refining, and pulp and paper industrial source categories are 

already under substantial regulation, but continue to be significant sources of pollutants and 

warrant further consideration by EPA. EPA should evaluate potential national or regional 

emissions reduction strategies for criteria pollutants and air toxics in these categories. This 

should include improving emissions inventories if necessary and assessing their impacts on 

nonattainment areas or other sensitive areas. EPA should carefully consider the costeffectiveness of imposing additional controls as it determines whether additional emissions 

reductions are justified and should take action consistent with the results of this analysis. 

2.8 Residential Fossil Fuel Combustion - EPA should evaluate the potential for 

expanding the Energy Star voluntary program to gain additional criteria pollutant emissions 

reductions (as well as improve energy efficiency) from the residential fossil fuel sector. As part 

of this effort, EPA should continue to gather information on the characteristics of residential 

fossil fuel emissions and their contributions to nonattainment, and the magnitude and cost of 

potential emissions reductions under a voluntary program and/or expanded use of low-sulfur 

fuel. EPA should also coordinate with Regional Planning Organizations (RPOs) and 

companies that produce lower-emitting appliances to assess the potential for programs that 

promote the installation of such technologies. 

National Guidance for Local Controls 

National rules are complex and take several years, at minimum, to develop for any industrial 

sector. Recognizing that many of the most severe air quality problems in the nation demand more 

immediate action to assist S/L/T in developing their Implementation Plans for ozone, PM2.5, and 

regional haze, the Work Group recommends that, in addition to developing national or regional 

rules for the sectors discussed above, EPA should issue guidance as soon as possible for use at the 

local level or offer additional federal support for existing local-level programs. Specifically: 

2.9 Guidance for Local Control Measures in Key Sectors - EPA, in conjunction with 

S/L/T and affected stakeholders, should prepare federal guidance for local (urban-scale) 

control measures to support the upcoming round of ozone and PM2.5 SIPs, and, if possible, 

optimize multipollutant control benefits and opportunities for reducing criteria and toxic air 

pollutants. Federal guidance is needed by October 2005 to assist States in preparing SIPs to 

address ozone and PM2.5 nonattainment and regional haze milestones. Based on a preliminary 

review of available ambient monitoring data, source apportionment studies (see Figure 9), 

modeling analyses, and emissions inventories, the Work Group recommends that EPA, in 

conjunction with S/L/T and affected stakeholders, should issue guidance as soon as possible for 

the following source sectors: 

• Residential wood stoves and fireplaces; 

• Open burning; 

22 :: 
Recommendations by the Air Quality Management Work Group 

• Mobile sources (high-emitting vehicles and diesel retrofit programs); and 

• Industrial operations (e.g. cement manufacturing, petroleum refineries, pulp and paper, 

metals, and surface coating). 

In prioritizing development of the guidance, EPA should consider factors such as emissions 

reduction potential, timeliness, cost effectiveness, completeness of existing guidance, and 

reactivity. Additionally, EPA, in conjunction with S/L/T and affected stakeholders, should 

continue to assess other source categories that would benefit from local (urban-scale) 

strategies. The identification of these categories should be based on the same factors cited 

above (e.g. evaluation of ambient monitoring data, source apportionment studies, modeling 

analyses, and future year emissions inventories). As appropriate, EPA should issue technical 

guidance for other source categories.

At this time, the Work Group is advancing more detailed recommendations for three of the listed 

sectors. In keeping with the NRC’s recommendation to focus on areas with the highest risk, the Work 

Group recommends the highest priority be placed on implementing local controls for these sectors in 

areas that do not attain the ozone or PM2.5 standards, or that have air quality close to the standards: 

Secondary sulfate

Secondary nitrate

Mobile

Diesel

Industrial

Woodsmoke

Soil

3%

 

3%

18%

5%

22%

13%

36%

Figure 9. Fine Particle Source Apportionment. 8 Estimated source contributions (%) to annual average PM2.5 

concentrations in St. Louis, Missouri (2000-2003). Secondary ammonium sulfates and nitrates are formed from 

reactions of SO2, NOx, and NH3 emissions from a variety of sources over large scales. The relative fraction of 

source contributions can vary significantly among different urban areas. The apportionment results also may vary 

with analysis methodology uncertainties and monitoring. 

2.10 Residential Wood Smoke - EPA should further develop the Residential Wood Smoke 

Reduction Initiative that includes working with S/L/T, industry, non-governmental 

organizations and others to support and facilitate the changeout of dirty, inefficient, 

“conventional” (pre-New Source Performance Standard or NSPS) woodstoves with new, 

cleaner, and more efficient heating appliances (e.g., EPA certified woodstoves). Concurrent 

with the development and implementation of changeout programs, EPA should commence 

efforts to revise the NSPS. Residential wood smoke contains various types of toxic air 

pollutants (e.g., polycyclic organic matter) and contributes 420,000 tons of direct PM2.5

emissions annually. Almost 80 percent of these emissions come from about 10 million 

8

 Center for Air Resources Engineering and Science, Analysis of Midwest PM-Related Measurements (draft), Philip K. 

Hopke, Jong Hoon Lee, Clarkson University.

:: 23 
Recommendations by the Air Quality Management Work Group 

woodstoves currently in use, 80 to 90 percent of which are pre-NSPS stoves. Many Tribes are 

affected by wood smoke from dirty stoves causing serious health problems in Indian 

communities. The voluntary residential wood smoke reduction initiative EPA began in 2004 

should be expanded, with substantial increases in grants to States and Tribes to retrofit or 

replace existing woodstoves. In parallel, on the national level, EPA should update the NSPS to 

ensure that all woodstoves reflect the kind of clean technology available today (see Figure 10). 

In addition, EPA should consider emission control opportunities for fireplaces and outdoor 

wood boilers. While many of the aspects associated with this entire effort are local in nature, 

some are national in scope and require a national effort. 

a) b) 

Photo credit: Wood Heat Organization, Inc. 

Figure 10. Woodstoves. The change out of a) an old, dirty, inefficient “conventional” woodstove with b) a new, 

cleaner burning EPA-certified woodstove could potentially reduce emissions by 60 to 80 percent. 

2.11 Open Burning - EPA should work with S/L/T to encourage more vigorous control of 

open burning, especially in, and adjacent to, counties with Class I areas and counties 

classified as nonattainment for fine particles or ozone. Open burning releases substantial 

emissions of PM2.5, VOCs, carbon monoxide, and other pollutants of concern. Emissions from 

open burning, released near the ground and most often in relative proximity to inhabited areas, 

contribute to urban smog, regional haze, ozone, and elevated PM2.5 readings, and cause 

periodic localized exposures in excess of acceptable risks. To encourage controls on open 

burning, EPA and S/L/T should work cooperatively to develop guidance, model rules, and 

communication strategies for deployment at the local level. In addition, EPA should develop 

methods for crediting open burning control strategies in SIPs/TIPs. Open burning is of critical 

interest to Tribes near or in urban areas, as well as rural areas. Agricultural concerns also need 

to be considered. 

2.12 High-Emitting Gasoline Vehicles - EPA and S/L/T should reduce emissions from 

high-emitting gasoline vehicles that are believed to contribute a high fraction of mobile source 

emissions. Increasingly stringent regulation of new vehicle emissions has had a large positive 

24 :: 
Recommendations by the Air Quality Management Work Group 

effect on overall fleet emissions reductions. As a result, an increasing portion of uncontrolled 

mobile source emissions are produced by a relatively small fraction of high-emitting vehicles 

(such as poorly maintained vehicles or older vehicles). Future emissions reductions in this 

sector depend on identifying and controlling such vehicles. In the next 3-4 years, EPA should: 

Determine the impact of high-emitters on today’s mobile source inventory, using new 

data sources and improved analytical techniques. 

•

•

•

•

•

Encourage the continued development of on-road vehicle remote sensing or other 

technologies to enhance high-emitter identification programs for pre-1996 vehicles. 

Continue to evaluate the effectiveness of on-board diagnostic systems, tailpipe emissions 

testing, and new technologies to identify post-1996 high-emitting vehicles. 

Make use of new technology as it becomes available to improve detection of highemitters. 

Continue to support State and local inspection and maintenance programs and initiatives 

designed to repair high-emitting vehicles or remove them from the road. 

Implementing these recommendations will have significant, but variable, impacts on air quality 

throughout the nation, depending on the proportion of high-emitters in local inventories. 

2.13 Conformity - Conformity should be retained as part of the nation’s AQM system. The 

Work Group and the Mobile Source Technical Review Subcommittee wish to emphasize that, 

in addition to other mobile source initiatives in local nonattainment areas, the overall 

transportation planning approach embedded in the conformity program should continue to 

receive substantial federal support. The NRC found that the transportation conformity program 

has significantly reduced pollution levels in cities around the country, with the greatest impact 

in nonattainment areas experiencing rapid growth. Furthermore, the program has “fostered 

greater interaction” between transportation planning and air quality regulatory authorities, 

resulting in knowledge transfer and mutual respect. Therefore, conformity’s current key 

requirements and schedules must be retained and effectively enforced. Additionally, future 

administrative action should consider: (1) protecting sensitive populations from localized, 

elevated particle pollution levels; and (2) expanding emissions budgets under the general 

conformity program to limit emissions from other significant transportation sectors (e.g., 

marine ports, rails, airports and freight). 

Even with the application of these complementary strategies at the national, regional and local 

levels, the Work Group recognizes the possibility that certain nonattainment and emissionstransport problems may not be resolved. Further analysis of nonattainment problems projected to 

persist after implementation of these recommendations may suggest additional controls on certain 

sectors, and/or alternative or supplementary approaches to improving air quality. 

NRC 3: Transform the SIP Process 

Among the most immediate and critical areas in which the NRC and the Work Group advocate 

change is the way SIPs are developed, processed and evaluated. Recognizing that the SIP/TIP 

process can be cumbersome and time-consuming for S/L/T, the Work Group proposes a number 

of steps that would improve the SIP process and facilitate more integrated, comprehensive air 

quality management. These recommendations fall into two categories: 1) immediate changes that 

will provide incremental improvements by streamlining the SIP process; and 2) additional steps 

:: 25 
Recommendations by the Air Quality Management Work Group 

that begin the longer-term task of transforming the SIP process in more substantial ways. Taken 

together, these recommendations will improve accountability, promote innovative approaches to 

air pollution problems, and help integrate key programs and approaches. 

Streamlining the SIP Process 

The Work Group recognizes that the SIP process itself (see Figure 11)—the procedures by which 

the SIP is managed by S/L/T; the timing of key steps; and the way stakeholders are included in 

the process—could be improved significantly in the near term. Part of creating accountability 

mechanisms is ensuring that necessary procedural steps are carried out with maximum efficiency 

and transparency. Here, the Work Group offers several recommendations for immediate actions 

that could help expedite the SIP process, encourage innovation, and improve communication with 

stakeholders. 

Near-Term Procedural Changes to Expedite SIP Development and Processing 

3.1 Align SIP Submittal Dates - Because ozone, PM2.5, and regional haze SIPs have 

similar elements and are likely to contain similar control strategies, EPA, S/L/T and other 

stakeholders should strive to align the submittal dates of the three SIPs. This recommendation 

is not intended to suggest changes to any deadlines for attainment or implementation of control 

strategies, or to imply that a single SIP should be required for ozone, PM2.5, and regional haze. 

It is further recommended that, in the future, EPA should align designation dates as 

appropriate to promote multipollutant SIP development. For many States, there is likely to be 

overlap between the efforts necessary to address 8-hour ozone, PM2.5 and regional haze 

problems. The resources saved from a holistic analysis and the development of a single 

strategy as opposed to several incremental adjustments within a few months’ time may be 

significant. It is difficult for States to accelerate adoption of the PM2.5 and regional haze SIPs 

(due in 2008) to coincide with the schedule for 8-hour ozone SIPs (due in 2007). Therefore, 

EPA should identify incentives (e.g. modeling assistance) it could provide to States to 

accelerate the preparation of regional haze and PM2.5 SIPs. It is critical that EPA take rapid 

action—within the next 6 months—to provide guidance to States in time to impact the current 

round of SIPs. 

3.2 Protocol for SIP Development - Each State should work with the appropriate EPA 

Regional Office to develop and implement a protocol for SIP development and processing that 

would lay out responsibilities, expectations, and timelines for all parties. While a model 

protocol should be developed, the EPA Regional Office and each State should have the 

flexibility to design a protocol tailored to their specific needs. The lack of effective and 

consistent communication between States and EPA historically has been an impediment to 

development and processing of SIPs. To avoid delays in the SIP approval process and to limit 

the insertion of new demands by EPA late in the process (after public hearings and legislative 

action are well underway at the State level), EPA and the States should jointly foster the 

development of a model protocol within the next six to nine months outlining the SIP process. 

While the protocol can be tailored to fit each particular situation, it should generally: 

• Be flexible enough to address all types of SIP submittals; 

•

•

Incorporate regular mechanisms for communication, expected turnaround for EPA review 

of State materials, and more streamlined processes for simpler SIPs; and 

Include accountability mechanisms. 

26 :: 
Recommendations by the Air Quality Management Work Group 

Figure 11. Major Steps in the 

SIP Process. The Work Group 

recommends a number of steps to 

streamline aspects of SIP 

processing to expedite procedures 

and save significant resources 

without sacrificing the benefits of 

public participation and comment. 

State prepares draft SIP and rules

CAA or court case mandates plan submittal, 

or State/Local decides to revise its own SIP

Public hearing on SIP and rules

State makes appropriate revisions and adopts SIP

State submits SIP to EPA Regional office

If complete SIP ... EPA proposes approval/disapproval in CFR

EPA considers public comments on SIP ... approves/disapproves plan**

After SIP approval, the plan becomes Federally enforceable

** If mandated SIP is disapproved or a complete SIP never submitted, 

then EPA must promulgate a Federal Implementation Plan (FIP)

incomplete

Return to State

EPA reviews SIP for completeness**

3.3 Clearinghouse of Approved SIPs - EPA should develop a website, similar to the Best 

Available Control Technology (BACT)/Lowest Achievable Emission Rate (LAER) 

clearinghouse, containing interpretations of rules and other SIP/TIP approval-related issues. 

This website could contain both policy and/or technical information depending on how it is 

developed. Each EPA Regional Office should develop a website, to be updated every 12 months 

on or about October 1, that identifies and provides links to all statutory and regulatory 

requirements in the federally approved SIP, including associated State and federal legal 

citations and effective dates. Because there is no central repository for information about 

SIP/TIP approvability, the process for finding answers can be very time- and resourceintensive. EPA should give medium priority to developing a clearinghouse that is accessible to 

States and the public. Additionally, EPA regional offices should standardize the content and 

quality of websites containing statutory and regulatory requirements for applicable SIPs. This 

includes providing: (a) a citation of and link to every State statute and regulation; (b) the State 

effective date; (c) the federal publication date; (d) the federal effective date; and (e) the 

applicable federal register citation. 

3.4 Streamline Minor SIP Revisions - For the SIP approval/disapproval phase of the air 

quality management process, EPA should establish a de minimis level for SIP revisions and 

streamline the processing of these revisions by the use of “letter approvals” or similar 

expedited procedures signed by the Regional Administrator. EPA should, in consultation with 

S/L/T and other stakeholders, develop a listing of the types of SIP actions that are eligible for 

streamlined processing. Many SIP revisions submitted by States are minimal in their scope or 

impact, yet such submittals must still undergo the full administrative process that is required of 

:: 27 
Recommendations by the Air Quality Management Work Group 

all Federal rulemaking actions. To streamline the revisions approval process and save 

significant resources, EPA is advised to take action within the next 12-18 months to: 

Develop guidance defining what would be considered de minimis, in terms of subject 

matter, emissions limits, and the process by which such actions would be approved. 

•

• Group in one rulemaking action a series of SIP submittals which meet the de minimis

criteria. 

3.5 Timely EPA Guidance - EPA guidance should be issued in sufficient time for States to 

meet their SIP development deadlines. EPA should involve S/L/T and other appropriate parties 

in its guidance development process. In cases where guidance is delayed, EPA should take into 

consideration States’ efforts to meet deadlines without the benefit of the appropriate policy 

guidance. Frequently, States must prepare SIPs under a specific deadline, but are dependent on 

EPA to develop guidance for the SIP. Delay by EPA in preparing guidance can cause States to 

be rushed or late in meeting their deadlines, or to develop SIPs which have to be revised later. 

This can lead to strained relationships between EPA and the States, public criticism of the 

States, and possibly sanctions against the States. Furthermore, greater communication between 

EPA and other stakeholders in the development of guidance can help reduce implementation 

problems, resource expenditures, and litigation. Therefore, within the next six months, EPA 

should institute a new, collaborative process for developing guidance in a more timely fashion. 

In any Federal Register notice for a final rulemaking, EPA should clarify if and when any 

additional guidance will be forthcoming. The Work Group hopes that this notice would serve 

as a deadline to prompt EPA action. 

3.6 Avoid Unnecessary Public Hearings - EPA should work with the States and Tribes to 

develop a model regulation that would require a public hearing for SIP revisions only if one is 

requested after public notice. This recommendation is not intended to restrict public comment 

in any way; it is meant only to eliminate those hearings that no one attends. The CAA has long 

been interpreted to require that a public hearing be held by States for all SIPs and SIP revisions 

prior to their submittal to EPA. Holding public hearings is resource-intensive, and while the 

use of State resources is completely justifiable when interested parties testify at the hearing, in 

many instances no comments or testimony are offered. A work group comprised of members of 

EPA’s Office of General Counsel, EPA Regional Counsels, States’ Attorneys General, and 

Tribal attorneys should undertake a review to determine whether holding a public hearing only 

upon request could satisfy CAA requirements for SIP revisions. If so, the work group should 

also develop a model regulation for States to adopt for SIP approval that provides the 

circumstances and procedures for holding SIP revision hearings only upon request. 

3.7 Facilitate Redesignation Process for Certain Areas - For those areas that have not 

pursued and been granted redesignation when initially eligible, and have continued to 

demonstrate violation-free ambient air quality data for several years, EPA should expedite the 

redesignation process. EPA should ensure that all Regions and States are aware of the 

simplified procedures. This recommendation is not intended to change the requirements for 

redesignation under the CAA. All EPA Regional Offices should disseminate and provide any 

needed assistance on the implementation of both the May 10, 1995 Clean Data Policy (CDP) 

and the “Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas,” 

commonly referred to as the Limited Maintenance Plan Policy (LMPP). The CDP allows the 

Part D SIP requirements of an approved attainment demonstration, rate of progress plan and 

their associated contingency measures to be waived in areas with three or more years of 

violation free data. Similarly, the LMPP can exempt an area from modeled maintenance 

28 :: 
Recommendations by the Air Quality Management Work Group 

demonstration. These policies change and simplify the technical requirements for 

redesignation, not the legal requirements. 

Measures to Improve Communication to the Public 

3.8 Effective Communication with Constituencies - EPA, along with S/L/T, should 

develop a menu of options for effective communication to build support with a wide variety of 

constituencies for clean air plans at the S/L/T level. The SIP/TIP planning process is 

cumbersome, lengthy and difficult for the public to comprehend, which hinders plan 

development and air quality improvements. Successfully engaging the public early in the 

SIP/TIP development process builds general understanding and support. Some States and 

Tribes have done this successfully, but other States could improve their outreach efforts, 

particularly by fostering collaboration at the local level. EPA should also develop outreach 

materials for diverse audiences explaining the SIP/TIP process and the health effects of air 

pollution. 

3.9 Co-Benefits of Innovative Measures - EPA and S/L/T should work collectively to 

communicate the co-benefits associated with innovative measures. In keeping with the previous 

recommendation, it is important for S/L/T to tailor their communication strategies to the 

concerns of their audience(s). The public is concerned with basic goals, such as improving 

public health and increasing economic and environmental benefits, when considering pollution 

control alternatives. Overemphasis on receiving SIP credit for new and innovative types of 

pollution control initiatives limits public understanding and support for such initiatives. 

Therefore, EPA and S/L/T should communicate how proposed strategies and innovations 

would improve quality of life more generally.

Steps to Increase Adoption of Innovative Measures 

3.10 Innovative and Voluntary Measures - EPA should encourage States’ and Tribes’ 

efforts to implement innovative measures by providing enhanced flexibility, SIP/TIP credit 

guidance, technical support, and funding for innovative and voluntary programs. Some areas 

have implemented most of the readily available traditional emissions control strategies, but still 

have not met air quality goals. As areas consider new strategies to attain the NAAQS, EPA 

should continue to develop policy and technical guidance to provide States with the flexibility 

to utilize innovative emission reduction strategies in their SIPs. The Work Group recommends 

that within 6 to 9 months EPA should: 1) clarify and expand the channels through which States 

may gain SIP/TIP credit for innovative measures by issuing additional enabling guidance and 

by balancing the level of effort required for approval (recordkeeping, reporting, etc.) with the 

level of environmental benefits; 2) create a clearinghouse for information on new technologies, 

innovative approaches, mentoring resources, and “off-the-shelf” measures, pilot projects, and 

quantification techniques; 3) develop sector-based guidance that would synthesize and clarify 

innovative technological approaches to reducing pollution in key sectors; and 4) continue to 

offer targeted funding to promote innovation. 

3.11 SIP Credits for Bundled Innovative Measures - EPA should incentivize innovative 

pollution control strategies by offering SIP/TIP credit for “bundled and discounted” measures.

States and Tribes are often discouraged from adopting innovative measures because those 

measures are typically too small scale to result in significant SIP/TIP credit. In addition, results 

of those measures may be hard to quantify or verify individually. In the aggregate, however, 

such measures can provide significant air quality benefits. EPA has recently increased the 

:: 29 
Recommendations by the Air Quality Management Work Group 

amount of presumptive SIP credit States can earn for stationary-source innovative measures to 

6 percent through its guidance on Incorporating Emerging and Voluntary Measures in a SIP 

(September 2004). The Work Group recommends that EPA build upon this initiative by 

granting States and Tribes SIP/TIP credit upfront for a “bundle” of small, innovative measures, 

with an appropriate discount to deal with the uncertainty embedded in these untested measures. 

The impact of the bundled measures on air quality should be evaluated in the aggregate. Each 

approval of “bundled” measures in a SIP will need to be conducted through full notice-andcomment rulemaking in the context of a particular State SIP revision. 

Steps toward Transformation: Improving SIP Development and Evaluation 

In addition to the near-term steps for streamlining SIPs outlined above, the Work Group 

recommends a number of other changes regarding the development of SIPs that should be 

initiated now and pursued over the course of the next several years. These more fundamental 

changes can only be accomplished over a longer time period. These recommendations focus on 

the nature of the federal/State/Tribal partnership, and on increasing the role of tracking progress 

and mid-course corrections. Specifically, the Work Group recommends that the current SIP 

process can be transformed in the following ways: 

Increasing Collaboration in SIP Planning and Control-Strategy Development 

3.12 Regional Approaches to SIP Planning - For many areas, planning for new SIPs or 

major revisions to existing SIPs for two or more separate nonattainment areas that are both 

part of the same regional-scale air quality problem should be coordinated. If requested by a 

State, EPA should work with the different nonattainment areas, Tribes and combinations of 

multistate organizations and other stakeholders, as appropriate, to assist in the development of 

regional approaches to planning. This could include technical assistance such as modeling, 

national or regional control strategies, model SIPs, and model rules as templates for S/L/T 

adoption. State-by-State planning without proper coordination can result in a patchwork of 

regulations and numerous stakeholder conflicts. As discussed in the previous section of this 

report, the nature of many areas’ 8-hour ozone and PM2.5 problems increasingly calls for the 

development and implementation of regional control strategies. In several areas, Regional 

Planning Organizations (RPOs) and Multi-Jurisdictional Organizations (MJOs) are being used 

successfully to develop model SIPs for regional haze (e.g. the Western Regional Air 

Partnership) or ozone (e.g. the Ozone Transport Commission). The Work Group recommends 

expanding such efforts within the next year to aid States in developing their ozone and PM2.5

SIPs. Specifically, RPOs and MJOs can assist with developing model rules and SIPs, and 

developing standardized technical support documents. EPA should encourage flexibility in the 

use of grant funds allocated to RPOs and MJOs so they address multiple ambient air pollution 

problems under the “one atmosphere” approach, ensuring that the most scientifically valid and 

cost-effective approaches are evaluated and implemented. 

3.13 Federal and State Partnership - EPA should participate with S/L/T in the SIP/TIP 

development process to identify and pursue emissions reductions from important source 

categories, especially those that only the federal government has the ability to address, such as 

federal and international sources. The level of control sought from these sources should be 

commensurate with their impact on the nonattainment area. As warranted by the nature of the 

source, control strategy development should be carried out by S/L/T working either directly 

with EPA or with EPA and other federal agencies. For attainment demonstration purposes, 

States should be able to take appropriate credit for anticipated reductions from these sources 

30 :: 
Recommendations by the Air Quality Management Work Group 

(whether the reductions are from regulatory or incentive programs) so long as the control 

strategy and its anticipated impact are found to be consistent with EPA regulation and 

guidance. States and Tribes often struggle to control existing sources, such as mobile sources, 

federal sources, or international sources, over which they have limited regulatory authority. 

The Work Group suggests that EPA and S/L/T could collaborate more successfully to control 

such sources so that the 8-hour ozone and PM2.5 standards can be met. Specifically, within each 

nonattainment area, EPA should work with S/L/T to: 

•

•

•

•

•

o

o

o

Identify and reduce emissions from national and international sources, in part by 

cooperating with international standards-setting bodies and participating in international 

agreements with neighboring countries; 

Reduce relevant emissions from federal sources, cooperating with other federal agencies 

as necessary; 

Expedite the approval of new technologies that can be applied to existing local mobile 

source fleets; and 

Develop new strategies, including multijurisdictional strategies, targeting sources that are 

difficult to control at the State or Tribal level in order to help local areas achieve 

attainment. 

Steps to Improve Tracking and Evaluation of Results 

As the NRC report stressed, it is important to push the current AQM system towards a more 

performance-oriented approach, one that measures both outputs and outcomes and ties them 

together in meaningful ways. While the comprehensive vision outlined by the NRC will require 

the kinds of assessment and research outlined in Recommendation 1.5, the Work Group believes 

that there are important steps that can be taken to improve methods and metrics for tracking 

pollution outputs, translating them into impacts, and creating feedback loops to adjust policies 

and programs to make them more effective in improving public health and welfare. Specifically, 

the Work Group recommends:

3.14 Weight-of-Evidence Demonstrations - In order to move beyond the current 

approach of relying on air quality modeling, EPA, in conjunction with S/L/T and affected 

stakeholders, should modify its guidance to promote weight-of-evidence (WOE) demonstrations 

for both planning and implementation efforts. In particular, these demonstrations should 

reduce reliance on modeling data as the centerpiece for SIP/TIP planning, and should increase 

use of monitoring data and analyses of monitoring data, especially for tracking progress. The 

current system is top-heavy on modeling for planning purposes, especially during the 

preparation of an attainment demonstration, and light on tracking progress. Enhanced tracking 

and ambient monitoring data is a better use of available resources than intensive local 

modeling. As such, EPA, in conjunction with S/L/T, should:

Incorporate a WOE approach in planning efforts to provide the most technically 

defensible basis for a control plan and to satisfy any statutory requirement for a 

demonstration of attainment. The WOE approach should include three elements: 

A prospective modeling analysis to identify the appropriate control path; 

Analyses of air quality data; and 

Summaries of current actual and expected future year emissions. 

:: 31 
Recommendations by the Air Quality Management Work Group 

Consider WOE elements such as retrospective modeling analysis (as necessary), analyses 

of air quality data, and summaries of actual emissions in implementation efforts (i.e., 

periodic progress assessments, as discussed in Recommendation 3.15). 

•

•

•

•

•

•

Issue WOE guidance, which clarifies the proper role of modeling for SIP planning, 

establishes standard WOE procedures, and identifies appropriate data analysis methods 

(e.g., estimating statistically significant trends). 

3.15 Periodic Assessments to Track Progress - S/L/T and EPA should conduct periodic 

assessments to ensure that areas are on track to meet NAAQS, air toxics, and visibility goals, 

and make mid-course adjustments, as necessary. To lay the foundation for a performanceoriented approach, and to help build a stronger framework for accountability, over the next two 

years: 

States, Tribes, and EPA should work together on tracking progress, including a review of 

changes in actual emissions and air quality concentrations, as described in 

Recommendation 3.14. 

If actual progress differs “substantially” from the expected trend for a given metric, then 

S/L/T should reexamine effectiveness of that attainment measure. If attainment will be 

later than the statutory attainment date, then the S/L/T authorities should determine 

whether it is necessary to modify the SIP. 

EPA should report annually on health and ecosystem impacts (i.e., indicators and 

benchmarks established pursuant to Recommendation 1.5). 

EPA should report annually on major control programs that it is coordinating (e.g., Title 

IV and NOx SIP Call). 

In accordance with this recommendation to improve program evaluation, the Mobile Source 

Technical Review Subcommittee recommended the Work Group highlight one particular program 

for detailed evaluation: 

3.16 Averaging, Banking, and Trading in Gasoline Sulfur Program - EPA should 

evaluate the averaging, banking, and trading (ABT) provisions included in the Tier II gasoline 

sulfur regulation to see if they are effective. Averaging, banking, and trading (ABT) provisions 

have been widely used by EPA to provide flexibility to industry while aggressively addressing 

environmental problems. EPA should evaluate the effectiveness of these provisions in the 

gasoline sulfur program as that program develops over the next few years. The evaluation 

should consider the distribution of credits; the volume and nature of trading; the impact of 

trading on firm-level performance; and the overall administrative performance of the program. 

The evaluation should include annual analysis of available information and a complete report 

when the program has been fully implemented and patterns of credit usage are well established. 

EPA should consider conducting a similar analysis for ABT when it implements the diesel 

sulfur program. 

In addition to the specific example of program evaluation noted above, the detailed text of 

Recommendation 1.5 in Appendix B notes several other programs that EPA should consider for 

evaluation, such as the NOx SIP call and the Clean Air Interstate Rule (CAIR). 

All of the above recommendations on SIP processing, SIP development, planning, 

communications, innovations, and tracking will help improve the current SIP process by making 

it more efficient and more effective. These changes should all be implemented in the near term, 

32 :: 
Recommendations by the Air Quality Management Work Group 

some because they are designed to help S/L/T with the upcoming round of SIPs for ozone, PM2.5 

and regional haze, and others because they represent initial steps that will form the basis for 

longer-term initiatives necessary to transform the SIP process as the NRC recommended. 

NRC 4: Develop Integrated Program for Criteria and Hazardous Air 

Pollutants 

The Work Group believes it is also possible to take immediate steps toward controlling criteria 

and toxic air pollutants (also known as hazardous air pollutants or HAPs) in a more integrated 

fashion. The Work Group agrees with the NRC that this is a critical task in the air quality 

management arena, and one that has often been neglected in the past. While fully integrated 

pollution control is a difficult task that will take many years and substantial reorganization of the 

entire air quality management framework to accomplish fully, the earlier recommendations for 

sector-based approaches and multipollutant control strategies (2.1 – 2.13) represent some of these 

steps. The following additional steps will also promote greater integration of programs designed 

to control criteria and toxic air pollutants: 

4.1 SIPs to Address Multipollutant Impacts - For the SIPs States are required to submit 

over the next several years, EPA and S/L/T should promote the consideration of multipollutant 

impacts, including the impacts of air toxics, and where there is discretion, select regulatory 

approaches that maximize benefits from controlling key air toxics, as well as ozone, PM2.5, and 

regional haze. The SIP process provides an opportunity for many urban areas to include key 

toxic air pollutants in a comprehensive, multipollutant air quality plan. While in no way 

reducing federal responsibilities for air toxics, this recommendation envisions SIPs/TIPs as 

providing an opportunity to see how S/L/T efforts are also reducing key air toxics, to identify 

what actions could be taken at the S/L/T level to supplement current federal efforts, and to help 

identify priorities for federal action. EPA should focus on developing a “short list” of critical 

toxic air pollutants and other widespread pollutants that pose the highest risk to human health 

in urban areas. In developing this list, EPA should consider including benzene, acrolein and 

diesel PM, and other widespread pollutants. EPA should encourage S/L/T in developing their 

SIPs/TIPs for PM2.5, regional haze and ozone, to evaluate opportunities for achieving cobenefits through simultaneous reduction of these key “urban risk driver” air toxics and any 

other air toxics which are of high risk in their area. Because of the urgency of this task, EPA 

should work with stakeholders to develop and test a model integrated SIP as a pilot project by 

the end of 2005. 

4.2 Multipollutant Benefits and Disbenefits in Standards Setting - EPA should 

explicitly outline and quantify multipollutant benefits and disbenefits when setting emissions 

standards. As part of its attempts to encourage integrated air quality planning, EPA should 

utilize the ongoing air toxics standards-setting process (e.g., remaining Maximum Achievable 

Control Technology (MACT), residual risk, and area source standards) to explicitly consider 

multipollutant effects of proposed control strategies in selecting options. Specifically, when 

conducting engineering reviews to support emissions standards efforts, EPA should assess how 

options identified for controlling air toxics reduce and/or increase direct PM2.5 emissions, and 

emissions of PM and ozone precursors such as VOC, NOx and SO2. Furthermore, engineering 

reviews for air toxic standards should catalog available control options that would reduce direct 

PM, SO2, VOC and NOx emissions even if those options would not reduce air toxics. 

4.3 Greenhouse Gas Co-Benefits and Disbenefits – EPA should assist States, and 

localities, in quantifying the potential greenhouse gas co-benefits and disbenefits of emissions 

:: 33 
Recommendations by the Air Quality Management Work Group 

reduction measures primarily designed to address ozone, PM2.5, regional haze and air toxics. 

In evaluating control measures, EPA should assist States and localities in quantifying potential 

greenhouse gas emissions increases and decreases. Many States and localities have adopted 

policies to assess and/or reduce greenhouse gas emissions. Under this recommendation, where 

requested, EPA should support a State’s or localities efforts to determine how pollution 

reduction alternatives might also impact greenhouse gas emissions. 

These multipollutant measures are very important to advancing the core goals outlined at the 

beginning of this report. These recommendations promote integration of air quality programs and 

approaches, thus addressing one of the main points of the NRC report. They also enhance 

accountability by providing more meaningful data about emissions and their likely impact on 

health and the environment. Combined with some of the measures discussed earlier about 

improving tracking, monitoring, and health/ecosystem indicators, these recommendations will 

help us measure progress toward desirable outcomes and design more effective and efficient 

pollution control strategies. 

NRC 5: Enhance Protection of Ecosystems and Public Welfare 

Finally, the Work Group agrees with the NRC that a great deal of work remains to be done in the 

areas of ecosystem protection and public welfare improvements. These are, in essence, the most 

fundamental goals of the air quality management system, and while substantial progress has been 

made on both fronts in the past thirty years, there are important gaps which require new 

approaches and new resources to address. The Work Group has focused on identifying a list of 

critical needs that could serve as the foundation for long-term progress in the protection of 

ecosystems and public welfare. 

5.1 Program Review to Improve Ecosystem Protection - EPA should, in parallel with 

recommended scientific and technical work, begin now to examine current and alternative 

clean air related policies and programs to develop approaches that would advance the 

protection of ecosystems from the adverse effects of air pollution. Alternatives that should be 

evaluated include a regional cap-and-trade program, protection of ecosystems based on 

critical loads, and a State-wide planning program for protecting and enhancing air quality in 

areas that attain the NAAQS (including National Parks and Wilderness Areas). The NRC 

stated that the system of air quality management in the United States does not go far enough in 

protecting ecosystems and other aspects of public welfare from the impacts of air pollution. 

The NRC noted specific policy-related deficiencies in secondary NAAQS, tracking of 

ecosystem outcomes from air quality changes, and accounting for ecosystem effects in costbenefit analyses. The Work Group agrees with this assessment, and recommends that, in 

addition to developing innovative benchmarks and measures to assess the ecological impacts of 

air pollution and improving ways to track and evaluate progress (see Recommendation 1.5), 

EPA should also assess the current and potential effectiveness of major clean air programs in 

providing ecosystem protection. In its assessment, EPA should consider a number of features 

of each program: 

a) policy mandates, objectives, goals, definitions of ecosystem protection, and 

historic/legal interpretation; 

b) characteristics of the air pollutant(s) regulated, and potential magnitudes of impact; 

c) existing measures for reporting program progress and ecosystem impacts; 

34 :: 
Recommendations by the Air Quality Management Work Group 

d) desirable modifications to existing tracking efforts to support their application to 

different regulatory programs; 

e) current and future opportunities or impediments to expanding the use of ecological 

science in the policy context; and 

f) policy innovations or revisions that would help translate ecosystem science into 

effective ecosystem protection policies. 

EPA should also assess the impact of non-regulatory programs, such as the Sustainable 

Environment for Quality of Life (SEQL) project in Charlotte, NC, on the protection of 

ecosystems. This project involves innovative efforts to integrate air pollution effects with other 

ecological concerns, and may serve as a model for future regulatory approaches. 

Figure 12. Wetland 

Ecosystem in NY.

Regional air deposition is 

a significant source of 

pollution to aquatic and 

terrestrial ecosystems in 

some areas of the U.S. 

Photo credit: 

K. Mirza/S.Olson 

:: 35 

Recommendations by the Air Quality Management Work Group 

Unresolved Issues 

for Further Discussion 

:: 37 

Recommendations by the Air Quality Management Work Group 

Unresolved Issues for Further Discussion 

Given sufficient resources, most of the recommendations outlined in this report so far could be 

implemented within the next 1 to 5 years under the current statutory framework. Such short-term 

changes are desirable, even critical, for helping S/L/T meet the air quality challenges they 

currently face. In addition to these recommendations, the Work Group also discussed a number of 

other changes to the AQM system that might be beneficial. While some of these issues provoked 

controversy within the Work Group, and no consensus was reached on how to handle them, they 

represent opportunities for further improvements in the near- or long-term and deserve mention 

here. The Work Group expects discussion of these issues to continue, and hopes to make 

additional recommendations over the next several months. 

Included in this group of topics for future discussion were scientific and technical issues such as: 

increasing the number and distribution of air quality monitors; implementing more short-term 

monitoring programs; improving the process through which emissions inventories are developed; 

and promoting the use of multipollutant and multimedia technical tools. 

In the policy and planning arena, the Work Group also had a number of unresolved issues. 

Among them were: improving the transparency and consistency of the SIP process; the possible 

role of geographically dispersed emissions reductions and whether they should be counted in SIPs 

for nonattainment areas; improving the communication of technical information to policymakers; 

integrating programs for criteria pollutants and toxic air pollutants more fully; and accounting for 

pollutant tradeoffs from different emissions control technologies during permitting at individual 

facilities. Many of these issues were considered medium or low priority compared to the 

recommendations listed in this report, or were so complex that the Work Group believed that it 

was premature to attempt to make recommendations at this time. Pending further discussion, 

additional recommendations may be forthcoming in these areas at a future date. 

The Work Group discussed at length the electricity generating unit (EGU) sector because of the 

large contribution that this sector makes to multiple air quality problems, but was unable to reach 

consensus. Many on the Work Group believed that the active rulemaking underway on the Clear 

Air Interstate Rule (CAIR) provided the proper forum for considering what this sector ought to do 

for the next 15 years or more; others did not. Since no agreement could be reached on a 

recommendation regarding this sector, the Work Group recommends that discussions continue by 

the new CAAAC subcommittee. Regardless of the outcome of any future discussions, many of 

the stakeholders involved saw value in S/L/T and utilities consulting with each other after final 

promulgation of the CAIR (or new legislation) to share compliance plans, evaluate likely 

emissions reductions and their geographic distribution, and apply that information to further 

planning activities. 

All of these issues deserve further consideration and remain on the Work Group’s agenda for the 

future. While some of them may involve irreconcilable conflicts among stakeholders, it is the 

Work Group’s hope that gathering additional evidence and continuing deliberations may produce 

a number of follow-up recommendations that would accompany those outlined in this report. 

:: 39 

Recommendations by the Air Quality Management Work Group 

Looking Forward: 

Long-Term Realignment 

of the AQM System 

:: 41 

Recommendations by the Air Quality Management Work Group 

Looking Forward: Long-Term Realignment of the 

AQM System 

Among its many tasks, the Work Group also considered more sweeping changes to the AQM 

framework in the United States. Such a broad-scale endeavor is necessarily a long-term project, 

requiring a great deal of discussion and negotiation among stakeholders. Still, the Work Group 

believes it is possible to outline some aspects of a new long-term vision. These aspects must be 

taken up in greater detail in the upcoming months as the reevaluation of AQM in the United 

States moves forward. 

In its discussions about long-term issues, the Work Group focused on identifying core principles 

around which future air quality programs should be organized. These core principles offer the 

opportunity to build highly effective programs to address emerging and future air quality 

problems by capturing past successes and incorporating new approaches. On top of these core 

principles, the Work Group drafted a series of Framework Options: approaches to air quality 

management that implement the core principles in different ways. Below, the core principles are 

described, followed by a brief description of four possible Framework Options. These options 

need further evaluation and discussion before any recommendations can be made by the Work 

Group to the CAAAC. 

Long-Term AQM Vision: Core Principles 

Members of the Work Group identified ten major principles that should be further considered in 

future deliberations of the long-term vision. 

1. Expand application of and develop national and/or regional measures for all source 

sectors (stationary, area, and mobile) to address air pollution in a nationally and/or 

regionally consistent manner. 

2. Integrate multipollutant considerations when addressing emissions reduction 

requirements and developing control programs. 

3. Include emissions reductions approaches from “non-traditional” sources and “nontraditional” (i.e., innovative) approaches (as well as from traditional sources and 

approaches) when developing plans and programs to achieve clean air goals. 

4. Make the SIP process simpler, more effective and more efficient. 

5. Ensure periodic review of progress to determine whether public health and environmental 

protection goals are being achieved. 

6. Ensure that innovative and market-based programs yield the desired levels of public 

health and environmental protection, as well as being economically efficient. 

7. Incorporate land use and transportation planning in clean air planning efforts. 

8. To the extent feasible, integrate health risk during control strategy program design. 

9. Maintain and protect States' and Tribes’ authority to reduce emissions in order to protect 

public health and the environment, and meet and maintain air quality standards. 

10. Integrate air quality management with national energy policy to ensure coordination and 

mutual support between energy policy and air quality policy. 

:: 43 
Recommendations by the Air Quality Management Work Group 

The Work Group did not presume that the CAA would necessarily need to be changed in order to 

move in the direction of these principles, although some approaches would likely not be 

achievable without statutory change. The NRC report recognized that the current AQM system 

has been and continues to be effective in many aspects. The current system provides a firm 

foundation to address present challenges and flexibility to adapt to developments in science and 

changes in policy. Consideration of changes to the current system warrant serious and thoughtful 

discussion in light of the goals to be achieved and the ultimate goal of continued progress towards 

clean air.9

The Work Group envisions that future AQM efforts will involve a heightened role for the federal 

government to issue national or regional programs covering multiple source sectors. These 

programs and this approach will be necessary to support State, local and Tribal governments as 

they address their nonattainment problems by assisting them in addressing multipollutant 

interactions and pollution transport. Under the CAA, the federal government has largely an 

oversight role. State, local, and Tribal governments are responsible for nearly all air quality 

implementation tasks. Furthermore, the current system does not currently implement mechanisms 

and processes adequate to address the significant impact of sources outside nonattainment 

boundaries. The mechanisms provided by the CAA to address pollution transport to date (SIP 

calls and petitions) can result in individual progress. Federal technology-based controls targeting 

various industrial sectors could achieve more integrated planning and address multipollutant 

interactions. 

Even with a greater federal presence, S/L/T will still have considerable work ahead in order to 

meet their air quality challenges and responsibilities—they hold ultimate authority and 

responsibility for attaining and maintaining the NAAQS and protecting public health. By 

streamlining the currently burdensome SIP process, incorporating innovative and multipollutant 

solutions, developing better ways to track progress, enhancing States’ and Tribes’ ability to 

address transported pollution, and crafting new controls on sources that only the federal 

government can regulate, the AQM system can promote cleaner air across the nation. 

Long-Term Framework Options 

The Work Group has developed four options for a new long-term AQM framework. These 

options share some of the core principles discussed above; in this sense, there is some overlap in 

the approaches described. However, in other respects the options are quite distinctive, both from 

the current AQM approach and from one another. These options are all in their infancy: while 

they have been subject to much discussion within the Work Group, that discussion served to 

highlight the complexity of the decision the nation faces in altering the current AQM system in 

any significant way. Therefore, rather than attempting to flesh out any “favored” option and 

recommend its adoption, the Work Group chose only to outline the four options. By presenting 

the options in this manner, the Work Group hopes to carry forward its internal discussions into 

the wider public sphere where these and other options will be given more considered attention. 

Option 1: National Technology-Based Standards 

Under this option, all stationary sources nationwide that emit above a specified threshold of a 

criteria pollutant or HAP would be required to reduce emissions of the full set of pollutants. New 

sources would be required to install state-of-the-art controls equivalent to LAER, while emissions 

 

9

 NRC Report, p. 22. 

44 :: 
Recommendations by the Air Quality Management Work Group 

from existing sources would be capped at a level that reflects the nationwide installation of 

technology no less stringent than BACT with existing sources required to meet a specified 

minimum level of control. 

Individual States would not need to go through the standard-setting process, but would retain 

their authority to adopt more stringent standards as necessary. To enhance flexibility, the option 

would incorporate emissions trading for some pollutants and would offer the possibility of 

reduced NSR obligations. A similar, national performance standard approach would be used for 

area sources. For mobile sources, EPA would expand its existing mobile source programs by 

regulating all HAPs from mobile sources and their fuels, and establish new national standards for 

remaining source categories, such as locomotives, marine engines and aircraft. Further reductions 

could come from a national mandatory diesel retrofit program and other restrictions on mobile 

sources and fuels. 

States and localities would be responsible for conducting ambient monitoring of criteria 

pollutants and HAPs to identify where unacceptable pollution levels persist after the application 

of national performance standards, and for ultimate attainment and maintenance of the air quality 

standards. In fulfilling these responsibilities, they would be subject to a “SIP lite” requirement, 

whereby they would develop local plans to address remaining air pollution problems. 

Option 2: Meeting Environmental Goals with Emissions Caps and Trading 

Modeled after the successful CAA Title IV acid rain trading program, a second option would be 

to set caps for emissions from certain source categories and allow trading. As in Option 1, the 

federal government would take the lead in controlling sources, with States responsible for 

addressing hotspots, residual risk, and transportation and land use planning measures. This 

approach is probably most amenable to large and medium stationary sources, but could also be 

applicable to some smaller stationary and area sources, if minimum criteria for participation in a 

trading program could be met. 

This approach’s coverage would be national and involve all major air pollutants, but could be 

regional for a given pollutant if certain demonstrations were made. In general, control programs 

should cover most sources within a source category, controlling 90 percent of emissions of each 

major pollutant from the category. Most sources would have an emissions control obligation, but 

would not necessarily need to make reductions on-site. Individual emitting sources would not be 

able to opt out of regulation altogether, but could receive compliance flexibility in a sector that is 

not regulated with emissions trading. 

Trading would be allowed across participating stationary and area sources for criteria pollutants. 

Trading might be restricted for air toxics to prevent hotspots, and trading between mobile and 

stationary sources would not be permitted. Initial caps/reduction targets would be set quickly 

(within five years) based on cost-effective control levels and adjusted periodically (every eight to 

ten years) considering emissions reductions needed to meet environmental goals. This would 

provide long lead times for technology advancement and a high degree of certainty to industry 

while providing a mechanism for continuous improvement towards environmental goals. 

Allowance allocations would also be used to encourage technology advancement. All new 

sources would be required to meet state-of-the-art controls. 

:: 45 
Recommendations by the Air Quality Management Work Group 

Option 3: Multipollutant, Performance-Based Standards 

A third option would establish innovative technology-promoting programs and national or 

regional multipollutant performance standards. The program would be national or regional, 

depending upon the sector and the air quality objective, and would cover criteria pollutants and 

toxic air contaminants. The multipollutant performance standards would be designed to achieve 

attainment and other appropriate air quality objectives (e.g., visibility, risk reduction) in most 

parts of the country. The States would be responsible for addressing residual nonattainment. 

The program would apply to most sectors, including stationary, mobile and area sources. New 

sources would be required to install “best integrated control technology,” which EPA would 

establish on a sector-by-sector and multipollutant basis after consideration of several factors, 

including the technology’s impact on criteria pollutant and toxic air pollutant emissions, and any 

adverse macroeconomic impacts. Most existing sources would be required to comply with a 

multipollutant emissions reduction obligation set by EPA based on various sector-specific 

considerations, including public health, ecosystem, energy, technical, economic, and market 

considerations. 

The program would also include demand-side and incentive-based strategies to encourage the 

development and use of clean technologies. These strategies include a pre-certified credit 

program; a clean air investment fund; and retail choice, transportation mode choice and energy 

choice programs. This option would also include measures to ensure that trading does not 

interfere with risk-reduction or public health benefits. 

Option 4: Continuous Improvement Program 

A fourth option, based on the Toxics Release Inventory, would set reporting standards for all 

major stationary sources and require an annual report of all relevant air emissions (HAPs, criteria 

pollutants, and criteria precursors). The reporting could be done by source category or on a 

national basis. The program would provide a metric to determine the relative pollution efficiency 

of the facility (pollution per unit of production). 

A threshold would be set above which facilities would be required to control emissions within a 

three- to five-year period. Emissions trading would be permitted and sources that went beyond 

compliance could bank the credits in accordance with national rules. The program would be 

adjusted on a cycle set forth in the rule (three to five years). Annual reports would serve as a 

benchmark to let everyone know how a facility ranks, thus creating a reduction incentive. New 

major sources would be required to install state-of-the-art control equipment. Because of the 

continuous improvement features of the program, NSR requirements could be lessened or 

removed. Program safeguards for attainment demonstrations and increased risk to the public from 

HAPs would have to be established. 

Certain area sources (e.g., consumer products and solvents) could be controlled by this approach, 

while others would be controlled using traditional CAA programs. Innovative programs could be 

implemented at the national and local levels to effectively address these sources. Area sources 

that represented a large portion of the national inventory may require rule making at a regional or 

national level. 

Moving Forward: Continuing the Evaluation Process 

These options represent four models out of many that could be developed as alternative futures 

for air quality management efforts in the United States. Though each option has some strong 

46 :: 
Recommendations by the Air Quality Management Work Group 

features, in each case many questions about a new AQM framework remain unanswered, 

including: 

1. How the federal and S/L/T governments would interact under a scheme that envisions 

sharing the responsibilities previously reserved for S/L/T governments, and how 

jurisdictional responsibilities would be defined; 

2. How risk and economics would be factored into the decision-making process; 

3. What is the role of energy, land use and transportation planning under the new paradigm; 

4. How innovative solutions (including pollution prevention) are incorporated into the 

approach; 

5. How the responsibility of various sources/sectors is determined under this process; and 

6. How the various pollutants relate to each other and the environment in a multipollutant 

program. 

These challenging questions should be addressed in any future discussions on recommendations 

for a long-term course of reform. Answering these questions and properly evaluating all of the 

nuances and implications of the options described above, as well as other possible options, will 

require detailed consideration by the CAAAC and an extensive dialogue between stakeholders. 

The Work Group recommends that this process of evaluation be carried forward during the next 

year, along with the implementation of the near-term recommendations outlined in this report. 

:: 47 

Recommendations by the Air Quality Management Work Group 

Conclusions 

:: 49 

Recommendations by the Air Quality Management Work Group 

Conclusions 

The Clean Air Act has been one of the most successful and cost-effective environmental statutes 

enacted since 1970. As described at the outset of this report, over the last three decades the nation 

has achieved major reductions in air pollution while population, energy consumption, gross 

domestic product, and vehicle miles traveled have expanded. The Clean Air Act provides a strong 

foundation for the protection of public health and the environment, offering powerful control 

mechanisms to combat serious pollution problems while also remaining flexible enough to 

accommodate advances in scientific knowledge and new policy priorities. 

Despite the substantial improvements in air quality over the past 30 years, however, there are 

important challenges ahead. As the most obvious pollution problems have been solved, other 

problems have moved into the spotlight. Advancing scientific research indicates that human 

health is threatened at very low levels of pollutant exposure, and toxic hotspots continue to affect 

localized populations. The impact of air pollution on ecosystems also needs further scientific 

study and policy action. 

In order to address these challenges, we must adopt new approaches to air pollution control. In 

addition, we must acknowledge that traditional approaches to controlling air pollution, while 

effective, have not always been efficient. Recent experience with cap-and-trade mechanisms and 

other market-based approaches has shown that there is room to improve the efficiency with which 

pollution reductions are achieved. As we move forward with air quality management efforts, we 

must look for additional opportunities to streamline processes and enhance program efficiency. 

The recommendations presented in this report offer concrete opportunities to improve the 

efficiency and effectiveness of current air quality programs. These recommendations build on the 

existing Clean Air Act and help enhance the current framework. They also serve as building 

blocks for potential long-term change. The report only begins to describe some of the possibilities 

before us as we move into a new era in air quality management. With the success of the past 

thirty years behind us, we should carefully consider the opportunities for improving air quality in 

the future, and move forward deliberately and enthusiastically to address new challenges. 

:: 51 

Recommendations by the Air Quality Management Work Group 

Appendix A:

Air Quality Management 

Work Group 

:: A-1 

Recommendations by the Air Quality Management Work Group 

Appendix A: Organizational Structure for Response 

to CAAAC on NAS Report: 

Clean Air Act Advisory Committee (CAAAC) EPA

Air Quality Management 

Work Group

Co-Chair: Janet McCabe (IN)

Co-Chair: Greg Green (EPA/OAQPS)

Policy & Planning Subgroup

Co-Chair: David Shaw (NY)

Co-Chair: Lydia Wegman (EPA-OAQPS)

Work Teams

Short-Term SIP Process

Co-chairs: Janet McCabe (IN) and Bill Baker (EPA)

Regional/National Strategies

Co-chairs: John Hornback (Metro 4/SESARM/VISTAS) 

and Sam Napolitano (EPA)

Innovative and Multi-pollutant Approaches

Co-chairs: Patrick Cummins (WGA), Penny Lassiter 

(EPA)

Long-term AQM Framework

Co-chairs: Bill Becker (STAPPA/ALAPCO), Dave Shaw 

(NYSDEC)

Work Teams

Emissions, Monitoring & Modeling

All Subgroup members are providing input on these 

three topics

Ecosystems

Co-chairs: Paul Stacey (CT/DEP) and Rona Birnbaum 

(EPA)

Health and Exposure

Co-chairs: Dr. Elaine Barron (JAC PDN AQ), John 

Bachmann (EPA)

Science & Technology Subgroup

Co-Chair: Mike Koerber (LADCO)

Co-Chair: Peter Tsirigotis (EPA/OAQPS)

:: A-3 
Recommendations by the Air Quality Management Work Group 

Air Quality Management Work Group 

Janet McCabe, Co-Chair

Indiana Dept of Environmental Management 

Greg Green, Co-Chair

U.S. Environmental Protection Agency 

Members: 

Tad Aburn

Maryland Department of the Environment 

Praveen Amar

Northeast States for Coordinated Air Use Management (NESCAUM) 

William M. Auberle, P.E. (CAAAC)

Northern Arizona University 

Robert V. Avant, Jr., P.E. (CAAAC)

Texas Food & Fibers Commission 

John Bachmann 

U.S. Environmental Protection Agency 

William Baker

U.S. Environmental Protection Agency, Region 2 

Elaine Barron, M.D. (CAAAC)

Joint Advisory Committee Paso Del Norte Air Quality 

S. William (Bill) Becker (CAAAC) 

Amy Royden-Bloom 

State and Territorial Air Pollution Program Administrators 

Association of Local Air Pollution Control Officials (STAPPA/ALAPCO) 

Don R. Clay (CAAAC)

Koch Industries Inc. 

Jeanette Clute 

Jerry Roussel 

Ford Motor Company 

Kenneth A. Colburn (CAAAC) 

Leah Weiss

Northeast States for Coordinated Air Use Management 

A-4 :: 
Recommendations by the Air Quality Management Work Group 

Patrick Cummins

Western Governor's Association 

Pamela M. Giblin (CAAAC)

Baker & Botts L.L.P 

Eric Ginsburg 

U.S. Environmental Protection Agency 

Lisa P. Gomez (CAAAC)

Sempra Energy 

Charles H. Goodman (CAAAC)

Southern Company Generation 

Ned Helme (CAAAC) 

Stacey Davis

Center for Clean Air Policy 

Jim Hendricks (CAAAC)

Duke Energy 

Ben G. Henneke, Jr. (CAAAC)

Clean Air Action Corporation 

John E. Hornback

Metro 4, Inc./Southeastern States Air Resource Managers, Inc. 

Carter Keithley (CAAAC) 

John Crouch

Hearth, Patio & Barbecue Association 

Mike Koerber

Lake Michigan Air Directors Consortium 

Douglas A. Lempke (CAAAC)

Colorado Department of Public Health and Environment 

Mark MacLeod 

Vickie L. Patton (CAAAC)

Environmental Defense 

Patricia Mariella (CAAAC)

Gila River Indian Community 

Dennis McLerran 

Jim Nolan

Puget Sound Clean Air Agency 

Jeffrey M. Mears

Oneida Tribe of Indians of Wisconsin 

:: A-5 
Recommendations by the Air Quality Management Work Group 

J. Mark Morford

Stoel Rives LLP 

Chuck Mueller (CAAAC)

Texas Commission on Environmental Quality 

Jeff Muffat (CAAAC)

3M Corporation 

Sam Napolitano 

U.S. Environmental Protection Agency 

Brock Nicholson

North Carolina Division of Air Quality 

Janice E. Nolen 

American Lung Association® 

John A. Paul (CAAAC)

Regional Air Pollution Control Agency 

Margie Perkins

Colorado Department of Public Health and Environment 

Kimber Scavo 

U.S. Environmental Protection Agency 

Jim Scherer 

Lorie Schmidt 

U.S. Environmental Protection Agency 

Mary Gade (CAAAC) 

John Seitz

Sonnenschein, Nath & Rosenthal 

David Shaw

New York State Dept. of Environmental Conservation 

Paul Stacey

Connecticut Department of Environmental Protection 

Eugene M. Trisko, Esq. (CAAAC)

Attorney at Law 

Peter Tsirigotis

U.S. Environmental Protection Agency 

Jeff Underhill 

New Hampshire 

James Vickery

U.S. Environmental Protection Agency 

A-6 :: 
Recommendations by the Air Quality Management Work Group 

Phillip J. Wakelyn

National Cotton Council 

Lydia Wegman

U.S. Environmental Protection Agency 

Roger Westman, Manager

Allegheny County Health Department 

Richard D. (Dick) Wilson (CAAAC)

National Environmental Strategies 

Catherine Witherspoon (CAAAC) 

Lynn Terry

CA Air Resources Board 

Robert A. Wyman, Esq. (CAAAC)

Latham and Watkins 

:: A-7 

Recommendations by the Air Quality Management Work Group 

Appendix B:

Recommendations Matrix & 

Background Papers 

:: B-1 

Recommendations by the Air Quality Management Work Group 

Appendix B: Recommendations Matrix 

& Background Papers 

Recommendations Matrix 

NRC 1: Strengthen scientific and technical capacity 

Number Recommendation Priority 

1.1 

Emissions Measurements and Reporting - EPA, in conjunction with 

S/L/T and affected stakeholders, should pursue improved emissions 

measurements and reporting to enhance emissions databases for more 

accurate air quality assessments and tracking of progress.

High 

1.2 

Emissions Factors and Estimation Methods - Where emissions 

measurement-based information is impractical to obtain for air 

quality assessments, or where improved projections are needed, 

EPA, in conjunction with S/L/T and affected stakeholders, should 

improve emissions factors and emission estimation methods.

High 

1.3 

Uncertainty in Emissions Inventories and Modeling - EPA, in 

conjunction with S/L/T and affected stakeholders, should quantify and 

take actions to reduce uncertainty in emissions inventories and air 

quality modeling applications, provide guidance for incorporating 

uncertainty assessments into SIP planning, and improve communication 

of uncertainty to decision-makers.

High 

1.4 

Multipollutant Monitoring - EPA, in conjunction with S/L/T and 

affected stakeholders, should promote and improve integrated, 

multipollutant monitoring.

High 

:: B-3 
Recommendations by the Air Quality Management Work Group 

1.5 

Framework for Accountability - EPA, in conjunction with atmospheric 

scientists, health and ecosystem experts, S/L/Ts, and affected 

stakeholders, should undertake a systematic effort to track air quality 

achievements and evaluate air program results. This effort should begin 

by focusing on the progression and associations of air emissions as they 

interact and ultimately affect human health and the environment. In order 

to move beyond the current approach of relying predominantly on air 

quality measurements, we need to further develop and apply the capacity 

to monitor, assess, and report on how changes in emissions impact air 

quality, atmospheric deposition, exposure, and effects on human health 

and ecosystems. Emphasis should be placed on developing and 

enhancing appropriate health and ecosystem indicators, benchmarks, and 

subsequent analyses within this overarching accountability framework. 

High 

NRC 2: Expand national and multistate control strategies 

Number Recommendation Priority 

2.1 

Industrial, Commercial, and Institutional Boilers - EPA should 

complete as soon as possible a review of the contributions from this 

category and the technical and economic feasibility of further 

controls, given the high priority assigned to this sector. EPA should 

then initiate development of a regional or national emissions control 

regulation for the category, or take alternative action consistent with 

the results of its analysis. 

High 

2.2 

Industrial Surface Coatings - EPA should complete as soon as 

possible a review of the contributions from this category and the 

technical and economic feasibility of further controls. EPA should 

then initiate development of a regional or national emissions control 

regulation for the category, or take alternative action consistent with 

the results of its analysis. 

Medium 

2.3 

Non-Industrial Solvents - EPA should initiate rulemaking efforts to 

establish minimum performance standards (i.e., national rules) for 

this category using the volatile organic compound (VOC) content 

limitations contained in, and regulating the products covered by, the 

model rule developed by the Ozone Transport Commission. 

Medium 

B-4 :: 
Recommendations by the Air Quality Management Work Group 

2.4 

Architectural Coatings - EPA should initiate rulemaking efforts to 

establish minimum performance standards (i.e., national rules) for 

this category using the VOC content limitations contained in, and 

regulating the products covered by, the model rule developed by the 

Ozone Transport Commission. 

Medium 

2.5 

Heavy-Duty Diesel Engines - EPA should reduce emissions from 

the existing fleet of heavy-duty diesel engines by employing a multipronged approach. 

High 

2.6 

Emissions from Ships, Locomotives, and Aircraft, and Mobile 

Source Air Toxics - EPA should address emissions from ships, 

locomotives, and aircraft, and mobile source air toxics through 

national emissions standards. 

High 

2.7 

Cement Manufacturing, Petroleum Refining, and Pulp and Paper - 

The cement manufacturing, petroleum refining, and pulp and paper 

industrial source categories are already under substantial regulation, but 

continue to be significant sources of pollutants and warrant further 

consideration by EPA. EPA should evaluate potential national or 

regional emissions reduction strategies for criteria pollutants and air 

toxics in these categories. This should include improving emissions 

inventories if necessary and assessing their impacts on nonattainment 

areas or other sensitive areas. EPA should carefully consider the costeffectiveness of imposing additional controls as it determines whether 

additional emissions reductions are justified and should take action 

consistent with the results of this analysis.

Medium 

2.8 

Residential Fossil Fuel Combustion - EPA should evaluate the 

potential for expanding the Energy Star voluntary program to gain 

additional criteria pollutant emissions reductions (as well as improve 

energy efficiency) from the residential fossil fuel sector. As part of 

this effort, EPA should continue to gather information on the 

characteristics of residential fossil fuel emissions and their 

contributions to nonattainment, and the magnitude and cost of 

potential emissions reductions under a voluntary program and/or 

expanded use of low-sulfur fuel. EPA should also coordinate with 

Regional Planning Organizations (RPOs) and companies that 

produce lower-emitting appliances to assess the potential for 

programs that promote the installation of such technologies. 

Medium 

:: B-5 
Recommendations by the Air Quality Management Work Group 

2.9 

Guidance for Local Control Measures in Key Sectors - EPA, in 

conjunction with S/L/T and affected stakeholders, should prepare 

guidance for local (urban-scale) control measures to support the 

upcoming round of ozone and PM2.5 SIPs, and, if possible, optimize 

multipollutant control benefits and opportunities for reducing criteria 

and toxic air pollutants.

High 

2.10 

Residential Wood Smoke - EPA should further develop the 

Residential Wood Smoke Reduction Initiative that includes working 

with S/L/T, industry, non-governmental organizations and others to 

support and facilitate the changeout of dirty, inefficient, 

“conventional” (pre-New Source Performance Standard or NSPS) 

woodstoves with new, cleaner, and more efficient heating appliances 

(e.g., EPA certified woodstoves). Concurrent with the development 

and implementation of changeout programs, EPA should commence 

efforts to revise the NSPS. 

High 

2.11 

Open Burning - EPA should work S/L/T to encourage more 

vigorous control of open burning, especially in, and adjacent to, 

counties with Class I areas and counties classified as nonattainment 

for fine particles or ozone. 

Medium 

2.12 

High-Emitting Gasoline Vehicles - EPA and S/L/T should reduce 

emissions from high-emitting gasoline vehicles that are believed to 

contribute a high fraction of mobile source emissions. 

Variable 

2.13 Conformity - Conformity should be retained as part of the nation’s 

AQM system. Low 

NRC 3: Transform the SIP process 

Number Recommendation Priority 

3.1 

Align SIP Submittal Dates - Because ozone, PM2.5, and regional haze 

SIPs have similar elements and are likely to contain similar control 

strategies, EPA, S/L/T and other stakeholders should strive to align the 

submittal dates of the three SIPs. This recommendation is not intended to 

suggest changes to any deadlines for attainment or implementation of 

control strategies, or to imply that a single SIP should be required for 

ozone, PM2.5, and regional haze. It is further recommended that, in the 

future, EPA should align designation dates as appropriate to promote 

multipollutant SIP development. 

High 

B-6 :: 
Recommendations by the Air Quality Management Work Group 

3.2 

Protocol for SIP Development - Each State should work with the 

appropriate EPA Regional Office to develop and implement a 

protocol for SIP development and processing that would lay out 

responsibilities, expectations, and timelines for all parties. While a 

model protocol should be developed, the EPA Regional Office and 

each State should have the flexibility to design a protocol tailored to 

their specific needs. 

High 

3.3 

Clearinghouse of Approved SIPs - EPA should develop a website, 

similar to the Best Available Control Technology (BACT)/Lowest 

Achievable Emission Rate (LAER) clearinghouse, containing 

interpretations of rules and other SIP/TIP approval-related issues. 

This website could contain both policy and/or technical information 

depending on how it is developed. Each EPA Regional Office 

should develop a website, to be updated every 12 months on or 

about October 1, that identifies and provides links to all statutory 

and regulatory requirements in the federally approved SIP, including 

associated State and federal legal citations and effective dates. 

Medium 

3.4 

Streamline Minor SIP Revisions - For the SIP 

approval/disapproval phase of the air quality management process, 

EPA should establish a de minimis level for SIP revisions and 

streamline the processing of these revisions by the use of “letter 

approvals” or similar expedited procedures signed by the Regional 

Administrator. EPA should, in consultation with S/L/T and other 

stakeholders, develop a listing of the types of SIP actions that are 

eligible for streamlined processing.

High 

3.5 

Timely EPA Guidance - EPA guidance should be issued in 

sufficient time for States to meet their SIP development deadlines. 

EPA should involve S/L/T and other appropriate parties in its 

guidance development process. In cases where guidance is delayed, 

EPA should take into consideration States’ efforts to meet deadlines 

without the benefit of the appropriate policy guidance.

High 

3.6 

Avoid Unnecessary Public Hearings - EPA should work with 

States and Tribes to develop a model regulation that would require a 

public hearing for SIP revisions only if one is requested after public 

notice. This recommendation is not to restrict public comment in any 

way; it is meant only to eliminate those hearings that no one attends. 

High 

:: B-7 
Recommendations by the Air Quality Management Work Group 

3.7 

Facilitate Redesignation Process for Certain Areas - For those 

areas that have not pursued and been granted redesignation when 

initially eligible, and have continued to demonstrate violation-free 

ambient air quality data for several years, EPA should expedite the 

redesignation process. EPA should ensure that all Regions and 

States are aware of the simplified procedures. This recommendation 

is not intended to change the requirements for redesignation under 

the CAA.

Low 

3.8 

Effective Communication with Constituencies - EPA, along with 

S/L/T should develop a menu of options for effective 

communication to build support with a wide variety of 

constituencies for clean air plans at the S/L/T level.

Medium 

3.9 

Co-Benefits of Innovative Measures - EPA and S/L/T should work 

collectively to communicate the co-benefits associated with 

innovative measures. 

High 

3.10 

Innovative and Voluntary Measures - EPA should encourage 

States’ and Tribes’ efforts to implement innovative measures by 

providing enhanced flexibility, SIP/TIP credit guidance, technical 

support, and funding for innovative and voluntary programs.

High 

3.11 

SIP Credits for Bundled Innovative Measures - EPA should 

incentivize innovative pollution control strategies by offering 

SIP/TIP credit for “bundled and discounted” measures.

High 

3.12 

Regional Approaches to SIP Planning - For many areas, planning 

for new SIPs or major revisions to existing SIPs for two or more 

separate nonattainment areas that are both part of the same regionalscale air quality problem should be coordinated. If requested by a 

State, EPA should work with the different nonattainment areas, 

Tribes and combinations of multistate organizations and other 

stakeholders, as appropriate, to assist in the development of regional 

approaches to planning. This could include technical assistance such 

as modeling, national or regional control strategies, model SIPs, and 

model rules as templates for S/L/T adoption.

High 

B-8 :: 
Recommendations by the Air Quality Management Work Group 

3.13 

Federal and State Partnership - EPA should participate with S/L/T 

in the SIP/TIP development process to identify and pursue emissions 

reductions from important source categories, especially those that 

only the federal government has the ability to address, such as 

federal and international sources. The level of control sought from 

these sources should be commensurate with their impact on the 

nonattainment area. As warranted by the nature of the source, 

control strategy development should be carried out by S/L/T 

working either directly with EPA or with EPA and other federal 

agencies. For attainment demonstration purposes, States should be 

able to take appropriate credit for anticipated reductions from these 

sources (whether the reductions are from regulatory or incentive 

programs) so long as the control strategy and its anticipated impact 

are found to be consistent with EPA regulation and guidance. 

High 

3.14 

Weight-of-Evidence Demonstrations - In order to move beyond the 

current approach of relying on air quality modeling, EPA, in conjunction 

with S/L/T and affected stakeholders, should modify its guidance to 

promote weight-of-evidence (WOE) demonstrations for both planning 

and implementation efforts. In particular, these demonstrations should 

reduce reliance on modeling data as the centerpiece for SIP/TIP planning, 

and should increase use of monitoring data and analyses of monitoring 

data, especially for tracking progress. 

High 

3.15 

Periodic Assessments to Track Progress - S/L/T and EPA should 

conduct periodic assessments to ensure that areas are on track to 

meet NAAQS, air toxics, and visibility goals, and make mid-course 

adjustments, as necessary.

High 

3.16 

Averaging, Banking and Trading in Gasoline Sulfur Program - EPA 

should evaluate the averaging, banking, and trading (ABT) provisions 

included in the Tier II gasoline sulfur regulation to see if they are effective. 

Low 

NRC 4: Develop an integrated program for criteria pollutants 

and hazardous air pollutants 

Number Recommendation Priority 

4.1 

SIPs to Address Multipollutant Impacts - For the SIPs States are 

required to submit over the next several years, EPA and S/L/T 

should promote the consideration of multipollutant impacts, 

including the impacts of air toxics, and where there is discretion, 

select regulatory approaches that maximize benefits from controlling 

key air toxics, as well as ozone, PM2.5, and regional haze. 

High 

:: B-9 
Recommendations by the Air Quality Management Work Group 

4.2 

Multipollutant Benefits and Disbenefits in Standards Setting - 

EPA should explicitly outline and quantify multipollutant benefits 

and disbenefits when setting emissions standards.

High 

4.3 

Greenhouse Gas Co-benefits and Disbenefits - EPA should assist 

States and localities in quantifying the potential for greenhouse gas 

co-benefits and disbenefits of emissions reduction measures 

primarily designed to address ozone, PM2.5, regional haze and air 

toxics. 

High 

NRC 5: Enhance protection of ecosystems and public welfare 

Number Recommendation Priority 

5.1 

Program Review to Improve Ecosystem Protection - EPA 

should, in parallel with recommended scientific and technical 

work, begin now to examine current and alternative clean air 

related policies and programs to develop approaches that would 

advance protection of ecosystems from the adverse effects of air 

pollution. Alternatives that should be evaluated include a 

regional cap-and-trade program, protection of ecosystems based 

on critical loads, a State-wide planning program for protecting 

and enhancing air quality in areas that attain the NAAQS 

(including National Parks and Wilderness Areas).

High 

B-10 :: 
Recommendations by the Air Quality Management Work Group 

Recommendations: Background Papers

1.1 Emissions Measurements and Reporting: EPA, in conjunction with S/L/T and 

affected stakeholders, should pursue improved emissions measurements and reporting to enhance 

emissions databases for more accurate air quality assessments and tracking of progress.

Background/Explanation: Recent studies have noted many deficiencies with current emissions 

inventories (e.g., “Improving Emission Inventories for Effective Air Quality Management Across 

North America: A NARSTO Assessment,” September 30, 2004). The NARSTO report, as well as 

the NRC recommendations, notes the benefits of collecting actual emissions data using emissions 

measurement techniques, such as the continuous emissions monitors (CEMS) for electrical 

generating units (EGUs) mandated by Title IV of the Clean Air Act. Improved emissions 

inventories are needed to provide for more effective control strategy planning and to meet future 

air quality management challenges.

Recommended Actions: A strong national effort is needed to require emissions measurements 

and reporting for as many major source categories as possible. The primary objective of these 

measurements is to produce accurate emissions data for supporting control strategy planning and 

tracking progress. The Work Group recommends that this can best be accomplished by the 

following actions: 

1) EPA should conduct a study to identify: 

a) relevant existing emission measurement methodologies for criteria pollutants (and 

their precursors) and hazardous air pollutants (HAPs), source categories for which 

these methodologies can be applied, and protocols for conducting these 

measurements, 

b) efforts needed to develop new emission measurement methodologies and 

technologies for other source categories (especially, those for which current emission 

estimates are highly uncertainty), and 

c) costs to conduct emission measurements. 

Emissions measurement methodologies that should be considered include CEMs (which, 

as noted above, are already required by Title IV for EGUs, by the OTC’s NOx Trading 

Program for several source categories, including industrial boilers, turbines, and cement 

kilns, and by numerous NESHAPS and NSPS); “random” stack testing (which may be 

appropriate for minor sources); and remote sensing. 

2) EPA should evaluate the need for and appropriateness of regulations to require emissions 

measurements for as many source categories as possible. As necessary, EPA should 

undertake rulemaking as soon as possible. 

3) EPA should evaluate the need for and appropriateness of regulations to require reporting 

of emissions measurements to a user-friendly central data base, similar to EPA’s Acid 

Rain database for EGUs. This would satisfy the compliance reporting requirements of 

Title V and place the information in a location where all entities could have access to it 

promptly. As necessary, EPA should undertake rulemaking as soon as possible. 

:: B-11 
Recommendations by the Air Quality Management Work Group 

Benefits: Collecting actual emissions data will reduce uncertainty in emissions inventories, 

enhance ability to participate in emissions trading programs, support air quality modeling, and 

increase certainty for compliance purposes. These data are also important to the success of most 

of the other Work Group recommendations. Making these data available through a central 

database will allow easier and more widespread access to the data. 

Feasibility: This recommendation has a medium feasibility for implementation because it can be 

completed under existing statutory authority, but will require a study to identify the source 

categories and will take some time to implement. 

Timing: The study can be performed in the next 6 – 9 months. The timeframe for establishing 

emissions monitoring requirements and for implementing these requirements could take several 

years. 

Resources: The identification of source categories can be performed by EPA technical staff (or 

by a contractor for less than $50K). The costs to conduct the emissions measurements (and report 

the data), however, are unknown, but are likely to be substantial. 

Priority Level: High 

B-12 :: 
Recommendations by the Air Quality Management Work Group 

1.2 Emissions Factors and Estimation Methods: Where emissions measurementbased information is impractical to obtain for air quality assessments, or where improved 

projections are needed, EPA, in conjunction with S/L/T and affected stakeholders, should 

improve emissions factors and emission estimation methods.

Background/Explanation: Recent studies have noted many deficiencies with current emissions 

inventories (e.g., “Improving Emission Inventories for Effective Air Quality Management Across 

North America: A NARSTO Assessment,” September 30, 2004). The NARSTO report, as well as 

the NRC recommendations, note numerous weaknesses with current emission estimates. 

Improved emissions inventories are needed to provide for more effective control strategy 

planning and to meet future air quality management challenges.

Recommended Actions: A strong, systematic national effort is needed to improve emission 

estimation methods for all major source categories, especially poorly characterized sources or 

those for which there is uncertainty in current emission estimates. The primary objective of these 

improvements is to produce better emissions inventories for supporting control strategy planning 

and tracking progress. The Work Group recommends that this can best be accomplished by the 

following actions: 

1) EPA, in conjunction with S/L/T and affected stakeholders, should review existing 

emissions factors and consider the results of EPA’s recent emissions factor workshop 

(“Revamping the Emissions Factor Program – A Workshop,” August 25-26, 2004) to: 

a) identify the most significant emissions factor needs, 

b) recommend and prioritize data collection and steps necessary for improving 

emissions factors. 

EPA should develop and implement procedures for quickly disseminating new emissions 

factors. 

2) EPA, in conjunction with S/L/T and affected stakeholders, should review existing source 

profiles used in source-based (and receptor-based) modeling to: 

a) identify the most significant source profile needs, 

b) recommend and prioritize data collection and steps necessary for improving or 

developing source profiles for poorly characterized sources. 

3) EPA, in conjunction with S/L/T and affected stakeholders, should conduct a study to 

reconcile current emissions inventories with ambient measurements. The study should 

build-upon the “top-down” evaluations summarized in the NARSTO emissions inventory 

assessment. Based on the study, EPA should work with S/L/T and affected stakeholders 

to improve emission estimates. Examples of emission estimation improvements include 

methods for mobile sources, ammonia sources (especially livestock operations, fertilizer 

applications, soil, and urban sources), and unusual or infrequent events (e.g., forest fires, 

dust storms, chemical spillage or upsets, unusually hot days). 

Benefits: Developing improved emission estimation methods will allow States and local agencies 

with interest and resources to apply those methods to create inventories that are more accurate 

and hence more useful for purposes of air quality modeling platform development and validation, 

attainment planning, and progress tracking. The improved State and local inventories would also 

be incorporated into the National Emissions Inventory used by EPA in developing effective 

national or regional strategies. Some of the listed improvements in methods – those dealing with 

:: B-13 
Recommendations by the Air Quality Management Work Group 

non-point source categories – could also be applied directly by EPA in developing the National 

Emissions Inventory. 

Feasibility: These recommendations have medium to high feasibility for implementation because 

they can be completed under existing regulatory authority. For some of the recommended actions, 

specific steps towards have already been taken and EPA is currently making further progress. 

However, later steps will require substantial resources above current efforts.

Timing: Most of the desired methods, models, and guidance documents will take several years to 

complete, even assuming resources are available. 

Resources: The needed funding for this work is uncertain, but in the aggregate may likely exceed 

a few million dollars per year over several years. 

Priority Level: High 

B-14 :: 
Recommendations by the Air Quality Management Work Group 

1.3 Uncertainty in Emissions Inventories and Modeling: EPA, in conjunction with 

S/L/T and affected stakeholders, should quantify and take actions to reduce uncertainty in 

emissions inventories and air quality modeling applications, provide guidance for incorporating 

uncertainty assessments into SIP planning, and improve communication of uncertainty to 

decision-makers. 

Background/Explanation: Technical analyses performed to support policy-making need to 

address complex and sometimes poorly understood problems. While serious attempts are made to 

rely on the best science available at the time, there are, generally, limitations with these analyses. 

For example, emissions inventories for some source categories are developed using emissions 

factors of variable quality. Another issue with these analyses is that they may reflect 

simplifications to facilitate communication with policy makers. For example, modeling analyses 

of a given control scenario will generate a single, best estimate, rather than dealing with the actual 

probability of success. An effort should be made to deal with the associated uncertainty in the 

technical analyses, especially with regard to emissions inventories and modeling applications. 

There is also uncertainty with monitoring data, but it can be better characterized. 

Recommended Actions: The Work Group recommends the following actions to address 

uncertainty in existing emissions inventories and modeling analyses: 

1) EPA, in conjunction with S/L/T and affected stakeholders, should conduct a study to: 

a) evaluate sources of uncertainty in emissions inventories and modeling analyses for all 

sources, 

b) identify needed data collection activities (and associated costs) to reduce the most 

significant emissions uncertainties, 

c) identify appropriate methods for incorporating uncertainty in preparing emissions 

inventories, and 

d) identify appropriate methods for incorporating uncertainty in conducting modeling 

analyses. Particular attention should be paid to probabilistic approaches in evaluating 

the likelihood of “success” (i.e., meeting the NAAQS) as part of the attainment 

demonstration. 

2) EPA should provide guidance to S/L/T for incorporating uncertainty assessments in SIP 

planning. In addition, EPA, in conjunction with S/L/T and affected stakeholders, should 

improve communication of uncertainty to decision makers and the general public. 

Benefits: Air quality management decisions are more likely to achieve intended goals at least 

cost if the decisionmakers have some information on the uncertainties in emissions estimates – 

and on the uncertainty in other estimates derived from them such as pollutant concentration 

estimates-versus having no such information. Public and industry acceptance may also be greater 

if it is known that uncertainties have been responsibly addressed. Also, knowledge of 

uncertainties can help target resources towards information collection that will have the largest 

payoff in terms of reducing bias and uncertainty in the emissions estimates, leading again to 

better air quality management decisions. Because real world experiences in using explicit 

uncertainty characterizations to make air quality management decisions are at best rare and 

narrow in scope, it is not yet possible to say by how much or in what specific areas the air quality 

management process is most likely to be affected. 

:: B-15 
Recommendations by the Air Quality Management Work Group 

Feasibility: Implementation of these recommended actions in the near term (i.e., next five years) 

will be difficult, given that there is so much source-by-source uncertainty characterization work 

to be done. The recommendations can be considered to have medium feasibility for the longer 

term, if resources are present, because they can be completed within existing statutory authorities. 

Resources: Resource needs are uncertain, but may be high, if all important sources of uncertainty 

are to be characterized objectively, especially if this is attempted retroactively (e.g., to 

characterize the uncertainty of a “legacy” emission factor). Resources needs would be lower if 

well informed, but subjective expert opinion is considered sufficient. Also, resource needs will be 

less, if the need to characterize uncertainty is part of the original data objectives for development 

of new emissions factors, models, etc. 

Priority Level: High 

B-16 :: 
Recommendations by the Air Quality Management Work Group 

1.4 Multipollutant Monitoring: EPA, in conjunction with S/L/T and affected stakeholders, 

should promote and improve integrated, multipollutant monitoring.

Background/Explanation: Ambient monitoring data are an essential part of the nation’s air 

quality program. Monitoring objectives include determining compliance with federal air quality 

standards, developing emission control plans, tracking effectiveness of these plans, and providing 

information for the public, regulators, and affected stakeholders on the quality of the air. Over the 

past 30 years, the air pollution situation has changed significantly, as control programs have 

reduced emissions of many pollutants and as science has identified emerging issues of concern. 

Accordingly, it is important that air monitoring efforts be dynamic and responsive to meet the 

current and future public, regulatory, and scientific needs. 

Recommended Actions: The Work Group recommends the following actions to promote and 

improve monitoring: 

1) EPA should finalize its proposed national ambient monitoring strategy, and S/L/T should, 

as appropriate, work together on a regional-scale to consider the need for, and, if 

appropriate develop, regional monitoring strategies. The existing monitoring networks 

are top-heavy on determining attainment/nonattainment and light on addressing other 

monitoring objectives, especially control strategy development and tracking progress. An 

assessment of the existing networks, either through a national or regional monitoring 

strategy, is needed to support redistribution of monitoring resources to address current 

policy- and program-relevant objectives. In the longer term, EPA should consider 

adopting a more inclusive and holistic national monitoring strategy which considers all 

types of monitoring pursuant to health and non-health (e.g., ecosystem) objectives. 

2) As initial efforts in implementing the national monitoring strategy, EPA should: 

a) Establish six Level I (research-grade) NCore sites with reasonable geographic 

coverage (e.g., one each in the NE, SE, MW, and S, and two in the W). Additionally, 

EPA should work with the Level I researchers to prepare and implement a data 

management and analysis plan. Funding for the operation and maintenance of these 

sites, and the data management and analysis work, should be provided by EPA 

(ORD). EPA should also sponsor a workshop every three years to report on the 

lessons learned and to promote technology transfer from the Level I sites. 

b) Establish, in conjunction with S/L/T, the Level II (multipollutant) NCore sites. (The 

appropriate number and location of these sites should be determined by the S/L/T and 

the respective EPA Regional Offices.) Additionally, EPA should work with the 

S/L/T, to prepare and implement a data management and analysis plan. Any resource 

savings from network changes provided by a regional monitoring strategy should be 

directed to help pay for the operation and maintenance of these sites, and the data 

management and analysis work. 

3) EPA should support research and development (for example, through the Level I NCore 

sites) to improve monitoring methods for: 

a) PM2.5-mass: Establish a continuous federal equivalent method for PM2.5-mass (i.e., 

resolve difference between current filter-based FRM for PM2.5-mass and continuous 

PM2.5-mass methods). 

b) PM2.5-species: Establish a consistent filter-based method for measuring and reporting 

OC and EC (i.e., adopt the IMPROVE methodology for both rural and urban 

:: B-17 
Recommendations by the Air Quality Management Work Group 

measurements), identify appropriate measurement methods for supporting source 

apportionment studies for OC, and establish reliable continuous methods for 

individual PM2.5 species. EPA should recognize and report the uncertainty in these 

measurements. 

c) PM2.5 & PM10: Investigate the potential for over-sampling with the PM10 and PM2.5

FRM samplers in areas where the mass median diameter (MMD) of the PM is larger 

than the size of interest (10 or 2.5 AED) and determine whether additional research, 

altered inlets, or implementation guidance should be provided. 

d) PM-coarse (PMc): Establish a federal reference method for PMc. Using the 

difference between PM10 and PM2.5 as measured with PM10 and PM2.5 FRM samplers 

is not acceptable. The method should be capable of determining the amount of crustal 

material. 

e) Air Toxics: Need reliable methods for acrolein, hexavalent chromium, and other 

species. A portion (e.g., 10 percent) of federal funding for the national air toxics 

monitoring program should be used for methods development. 

f) Dry deposition measurements, particularly for mercury species (see Recommendation 

1.5). 

4) EPA should promote policies to avoid disincentives for monitoring. The necessary 

changes in ambient monitoring networks, as called for by the national and regional 

monitoring strategies, should proceed without any negative ramifications. Specific 

actions include: 

a) Support concept of performance-based measurement systems (PBMS) in EPA’s 

national monitoring strategy (i.e., monitoring intended for investigative, not 

compliance, purposes). Although these measurements should meet minimum data 

quality requirements (developed through the Data Quality Objectives process), these 

data will not be used to assess attainment or nonattainment with the NAAQS. Note, 

this concept is similar to the FACA recommendation to “decouple the use of research 

data for regulatory purposes for a period of several years.” Prior to deploying PBMS 

(including untested, research-grade monitors), states and the EPA regional office 

should document in writing the non-compliance monitoring objectives and the 

appropriate response to any measured values in excess of the level of the NAAQS 

(e.g., deployment of an FRM monitor). 

b) Acknowledge EPA’s Exceptional Events policy, which avoids counting (for 

compliance purposes) high pollution events due to certain unusual or extreme 

conditions. 

c) Avoid monitors taking “root” by having state and local agencies specify monitoring 

objectives for their existing networks (including the expected period of sampling to 

meet these objectives) in their regional monitoring strategy. For any new monitoring, 

encourage identification of the monitoring objectives up-front (including expected 

period of sampling to meet objectives). Provide the agencies with discretion in 

moving monitors upon completion of the intended sampling period. 

d) Promote the concept of sharing monitoring data in a timely manner with potential 

sources as a means to help identify and minimize pollution problems rather than a 

strict enforcement tool. This would require the expansion of real-time monitoring and 

data transfer capabilities at existing and new monitoring sites. This effort and the 

B-18 :: 
Recommendations by the Air Quality Management Work Group 

resulting data could be utilized, with appropriate input on potential pollution 

emission activities and sources, for targeting more cost-effective control strategies. 

5) EPA should, whenever possible, promote co-location of atmospheric dry and wet 

deposition monitoring with long-term monitoring of ecological conditions (see 

Recommendation 1.5). 

Benefits: Implementation of the national monitoring strategy will demonstrate EPA’s 

commitment to a multipollutant air quality management framework, given that the developing a 

measurements infrastructure is a critical component upon which further technical and program 

adjustments can be based. From a strict technical perspective, the national monitoring strategy 

will broaden the scope of monitoring services beyond the historical regulatory emphasis and 

allow for more credible program accountability assessments, air quality model evaluation, 

support to forecasting venues such as AIRNow, and enhanced support to the research community, 

especially in the health effects area. Support for Level I sites would demonstrate EPA leadership 

in bridging the gap between research and applications and engaging the nation’s scientific 

expertise directly into its air program infrastructure. 

Feasibility: Implementation of the national monitoring strategy is underway and most 

components of the Level II NCore sites should be implemented within current resource 

allocations. There are no currently identified resources for the Level I sites. Failure to fund these 

sites will jeopardize successful implementation of the strategy. 

Timing: EPA could finalize the national monitoring strategy, and S/L/T could work together and 

prepare regional monitoring strategies during CY2005. Assuming the availability of funding, 

EPA could establish these sites in CY2006. EPA’s national strategy implementation plan targets a 

phased implementation of the NCore Level II sites in 2007. 

Resources: A minimum base of $3M per year would be needed to fund basic operations for six 

Level I sites. EPA’s national strategy implementation plan recommends an outlay of $10M per 

year (OAR or ORD) to support these sites. Internal OAQPS funding of approximately 

$150K/year for FY05 and FY06 is estimated to be needed to support training needs associated 

with implementing the strategy. 

Priority Level: High 

:: B-19 
Recommendations by the Air Quality Management Work Group 

1.5 Framework for Accountability: EPA, in conjunction with atmospheric scientists, 

health and ecosystem experts, S/L/T, and affected stakeholders, should undertake a systematic 

effort to track air quality achievements and evaluate air program results. This effort should begin 

by focusing on the progression and associations of air emissions as they interact and ultimately 

affect human health and the environment. In order to move beyond the current approach of 

relying predominately on air quality measurements, we need to further develop and apply the 

capacity to monitor, assess, and report on how changes in emissions impact air quality, 

atmospheric deposition, exposure, and effects on human health and ecosystems. Emphasis should 

be placed on developing and enhancing appropriate health and ecosystem indicators, 

benchmarks, and subsequent analyses within this overarching accountability framework. 

Background/Explanation: To guide future improvement of the air quality management system, 

the NRC identified as a longer-term objective the need for a results-oriented approach which 

emphasizes “performance rather than the process” in determining the efficacy of air policies and 

programs. Building on the current paradigm of accountability, EPA could better track, assess, and 

communicate significant results of emission control programs, including changes in 

source/emissions, air quality/atmospheric deposition, exposures, and effects. Emphasis is placed 

on systematically measuring progress and assessing benefits of air quality management through 

enhancing and expanding the suite of benchmarks and indicators of health and ecological 

outcomes. It is important to recognize that public health and ecosystem responses to emissions 

reductions occur over time and not always in the same time context as program assessments. The 

plan would, in a very general fashion, be based on the framework described above. That is, 

ideally accountability efforts would follow the “source/emissions – to air quality – to exposure – 

to dose – to effect” paradigm producing an improved understanding of cause/effect associations 

and input for meaningful program changes (or mid-course adjustments). It may be impossible to 

establish these links for health or ecosystem effects following strictly this linear progression. 

Plans for accountability will need to grapple with the difficult issue of tracking what are often 

small changes in health effects, on a relative basis, in large populations. 

Recommended Actions: The Work Group recommends a 3-part approach involving health 

effects, ecosystem effects, and SIP planning for systematically ensuring that air policies and 

programs are achieving intended results. 

For public health, the Work Group recommends that EPA work with health effects experts (e.g., 

federal agencies under the CENR Air Quality Research Subcommittee, CASAC/NAS, 

State/CDC/EPA environmental public health tracking partners, and HEI) to develop measures to 

define and assess human health impacts of air pollution and by developing ways to track and 

evaluate progress in reducing those impacts. Specific actions include: 

1) Strengthen the partnership among atmospheric science, health research, and program 

accountability efforts. 

a) Produce a summary report on air quality and health accountability as a first 

assessment of findings/capability 

b) Sponsor a collaborative workshop to promote involvement in developing the 

overarching framework. 

2) Expand on-going efforts into public health and air quality accountability. 

a) Assign a specific group to focus on public health and air quality accountability. 

B-20 :: 
Recommendations by the Air Quality Management Work Group 

b) Study effects of AQI advisories on exposure-reduction behaviors and whether 

behaviors lead to health benefits. 

c) Fund grants to State/local health departments in collaboration with State/local 

environmental agencies to assess health impact of specific environmental 

regulations/actions and whether they align with projected health impacts. 

d) Develop methodologies to detect changes in human health indicators/responses, as a 

result of changing from meeting 1-hr ozone standard to meeting a more stringent 8-hr 

ozone standard. 

e) Develop methods and collect data to better assess population exposure to air 

pollutants of ambient origin, considering indoor exposure and variables impacting 

personal exposure (time spent indoors, exercising, etc.). 

f) Enhance exposure assessment activities through expanded collection of air pollution 

biomarker data and development of additional biomarker detection methods for 

priority air pollutants. 

g) Develop further epidemiological and biostatistical approaches in assessment of 

exposure and dose, selection of health outcomes, and study design and data analysis. 

h) Review/critique the PHASE project (this winter), learn from PHASE and expand 

indicators work, and consider expanding PHASE into a functional air quality-public 

health tracking program. 

i) Identify additional projects, additional research, and explore further: building tools 

and develop methods for making air quality-public health linkage, expanding the 

NATA connection to criteria pollutant analyses, building on NATA and Criteria 

Document preparation to develop indicators and protocols, and ensuring 

appropriateness of ambient and health monitoring systems for public health tracking. 

3) Undertake specific accountability efforts. 

a) Undertake “intervention” studies for cities with largest expected, overall air quality 

improvements. 

b) Examine the usefulness and implementation of accountability measures in the context 

of “natural” experiments. 

c) Design and implement a study of accountability measures for changes in multiple air 

compositions. 

d) Study health indicators for ozone and particle air quality in areas with contemporary 

improvements. 

e) Study particle and CO effects in areas with winter time programs to reduce pollution 

from wood stoves. 

f) Develop processes to identify and implement accountability research for health 

effects resulting from long term air quality improvement trends. Methodologies may 

need to be developed to account for life-style and other interferences. 

g) Develop/improve biological indicators or biomarkers of early effects for long-term 

and acute exposures. 

For ecosystems, the Work Group recommends that EPA work with others to develop benchmarks 

and measures to assess ecological impacts of air pollution, and improve ways to track and 

evaluate progress in reducing those impacts. Specific actions include: 

:: B-21 
Recommendations by the Air Quality Management Work Group 

4) Improve tracking and evaluation of the effects of multiple air pollutants on aquatic and 

terrestrial ecosystems to assess the response to air pollution control policies. 

a) Identify a comprehensive suite of air quality—ecosystem indicators or measurements 

for tracking status and trends in exposure and condition consistently across broad 

regions of the U.S. 

b) Increase the density and spatial coverage of long-term ambient air quality and 

atmospheric deposition monitoring stations in rural, remote forest, agricultural, and 

coastal areas. 

c) Co-locate long-term measurements of ambient air quality and atmospheric deposition 

with long-term ecological research studies to answer key policy questions over time 

and a range of scales. 

5) Conduct and/or facilitate integrated assessments and research to develop and implement 

an appropriate suite of measurements for detecting ecosystem response to air pollution 

control programs within a long-term monitoring and assessment framework. 

a) Improve methods for monitoring atmospheric inputs to ecosystems and ecosystem 

response. Consider developing routine methods for measuring ammonia, organic 

nitrogen, dry deposition of mercury, and various dry measurements in a network 

mode (e.g., NADP, CASTNET), including in under-represented areas, such as coastal 

and western ecosystems. 

b) Improve methods to evaluate the status, trends, and response to air pollution control 

over regional scales, such as total nitrogen deposition rates and loadings, delivery of 

atmospheric loads to ecosystems relative to other sources, and simple, effective 

indicators of ecological condition. 

c) Improve models for characterizing the transfer of air pollutants through water, soil, 

and food chains over time. 

6) Collaborate with federal and State agencies, and the academic research community to 

pursue focused, integrated assessments and the integration of ecologically-relevant 

monitoring networks. 

a) Identify and develop institutional arrangements to initiate focused air qualityecosystem, integrated environmental assessments. 

b) Identify and leverage existing models of successful collaboration in atmospheric, 

aquatic, and terrestrial environmental monitoring and assessment. 

c) Standardize data collection activities across agencies, where possible, and look for 

ways to offer air-quality ecosystem datasets in centralized locations. 

7) Examine the possibility of using critical loads and thresholds, and other environmental 

benchmarks to quantify impacts on ecosystems. 

a) Initiate a series of focused technical workshops with stakeholder groups on the stateof-the-science to inform the development of environmental benchmarks or measures 

which define and assess the impacts of air pollution on ecosystems, and the expected 

time scales of recovery. 

b) Synthesize the results of the workshops for possible EPA policy development 

consideration; begin to develop a framework or strategy for applying the scientific 

assessment information. 

B-22 :: 
Recommendations by the Air Quality Management Work Group 

c) Conduct air quality-ecosystem benchmark assessments (e.g. critical loads) to better 

characterize air to ecosystem effects. 

Finally, the Work Group recommends that EPA work with S/L/T to determine appropriate 

metrics which should be used to more effectively track progress. Specific actions include: 

8) For the major control programs in a given SIP, determine quantifiable metrics for 

characterizing the program (e.g., for the NOx SIP Call, the change in monthly or seasonal 

average NOx concentrations from rural/regional ambient monitors, and the monthly or 

seasonal average NOx emissions from power plants). 

9) Determine emissions or ambient measurement methods (and measurement plan) for each 

metric (e.g., for the NOx SIP Call, a regional network of ambient NOx monitors and 

CEMs on power plants). Note, this may require enhancing or expanding emissions or 

ambient measurement activities, such as rural measurements for total reactive nitrogen 

(NOy), nitric acid and ammonia, and PM2.5 speciation to better detect measurable progress 

of ozone and PM precursors in support of major national rules and in concert with 

Recommendation #1.4. 

Benefits: A science-based framework to track and evaluate air quality achievements will enable 

EPA to allocate resources effectively. Shared data/information and joint prioritization of 

cooperative projects with other agencies allow resources to be used more effectively. Partnerships 

among the air quality community can support agency planning efforts, facilitate coordination 

activities, help to resolve issues between agencies, and improve involvement of non-federal 

organizations. 

Feasibility: This recommendation is considered to be feasible given that models already exist for 

tracking program outcomes used throughout EPA, states, and by health and ecosystem experts. 

The likelihood this recommendation can be successfully implemented is enhanced by building on 

the existing “accountability” infrastructure under the current CAA authority, including health and 

ecosystem monitoring and assessment, and leveraging known effective models of collaboration. 

Timing: Develop multi-year, high intensity indicators in years 1-3 that track effectiveness and 

progress of emission control programs in concert with the established framework. Indicator 

application is a complex process that will require additional time to further define ecosystem and 

health changes and expected time-scales of recovery. 

Resources: EPA has a number of projects underway that support tracking and assessing the 

results of emission control programs. Several activities can build on these efforts and begin 

immediately with relatively little additional resources. Some of the recommended health and 

ecosystem actions entailing developing new metrics and performing integrated assessments, in 

particular, would necessitate additional staff resources and funds in OAR. Additional resources 

may be available and leveraged through collaboration with other EPA programs and non-EPA 

partners, such as states, non-governmental organizations, and industry. 

Priority Level: High 

:: B-23 
Recommendations by the Air Quality Management Work Group 

2.1 Industrial, Commercial, and Institutional Boilers: EPA should complete as soon 

as possible a review of the contributions from this category and the technical and economic 

feasibility of further controls, given the high priority assigned to this sector. EPA should then 

initiate development of a regional or national emissions control regulation for the category, or 

take alternative action consistent with the results of its analysis.

Background/Explanation: Industrial, commercial, and institutional (ICI) boilers combust coal, 

oil or gas to produce heat and process steam in numerous sectors, including chemical 

manufacturing, petroleum refining, commercial buildings, hospitals, and universities. ICI boilers 

should be evaluated by EPA for possible regulation due to: 1) their significant contribution to 

projected 2010 criteria pollutant emissions; 2) the availability of cost-effective control measures; 

and 3) the likely contributions to nonattainment of the national ozone and fine particle standards 

as well as the other environmental impacts associated with boiler emissions. 

Recommended Actions: To determine whether regulation of ICI boilers is warranted and to 

improve existing ICI boiler inventories and data, EPA should: 

1) Evaluate the ICI boiler sector in detail using the agency’s existing authorities under the 

Clean Air Act. EPA should identify which measures are likely to be cost-effective for 

specific boiler sizes and types and identify the total emissions reductions this would 

imply for the sector. 

2) Close data gaps pertaining to characterization of the ICI boiler population and emissions, 

potentially by hiring a technical consultant to improve the quality and completeness of 

the ICI boiler inventory and to develop a realistic emissions baseline. The consultant 

would seek to integrate data from available data sources, including data in the NEI, data 

reported as a result of the Consolidated Emissions Reporting Rule, and data pulled 

together to support MACT regulation and the OTAG effort. The goal would be to create a 

comprehensive and systematic database listing key unit-level data for all states that is 

properly maintained and updated over time. 

3) Support a mechanism for reporting emissions from ICI boilers, potentially by maintaining 

and fully implementing the Consolidated Emissions Reporting Rule or developing a new 

Information Collection Request. 

4) Demonstrate the effect of reductions from ICI boilers on attainment (through air quality 

modeling or other means deemed appropriate) to ensure that any action proposed for this 

sector will help meet the desired air quality objective. 

5) Develop improved, peer-reviewed estimates of the cost-effectiveness of the various 

emission reduction measures that might be used with ICI boilers. This effort should 

include estimates for a range of sizes and should reflect recent experiences with NOx and 

SO2 control technologies in the ICI boiler and similar sectors (e.g., electric power sector). 

6) Make a final determination regarding whether and/or how to regulate ICI boilers that 

includes consideration of the potential penetration of cost-effective control measures. 

7) Issue regulations, if warranted, that are national or regional in scope due to the broadbased distribution of ICI boilers and the potential for emissions transport. Emissions 

trading should be utilized where appropriate due to the successes in using this approach 

in the NOx SIP Call and the ability of this source to use continuous emissions monitors 

(CEMs). Any regulation of this sector should include requirements for CEMs or other 

reliable emissions monitoring methods. EPA could also consider alternative regulatory 

B-24 :: 
Recommendations by the Air Quality Management Work Group 

approaches for smaller ICI boilers, considering administrative and emissions 

measurement costs and other factors. 

Benefits: Emissions reductions from the ICI boiler sector have the potential to achieve significant 

reductions in criteria pollutants nationwide. In 2010, ICI boilers are projected to account for over 

16 percent (2.7 million tons) of total NOx, 16 percent (2.4 million tons) of total SO2, and 5 

percent (0.3 million tons) of total PM2.5 emissions nationwide.10 The projected 2010 SO2 and NOx

emissions from ICI boilers are second only to the projected emissions from the power sector 

(without CAIR). Emissions of NOx, SO2 and PM2.5 contribute to an array of environmental 

problems, including ground level ozone, acid rain, fine particle pollution, eutrophication and 

regional haze. Reducing emissions from ICI boilers could therefore contribute to reducing the 

impacts of these emissions on human health. A comparison of projected emissions from ICI 

boilers and nonattainment areas also suggests a potential relationship between regulation of ICI 

boilers and improving local air quality. In fact, ICI boilers are expected to represent a sizeable 

share of emissions in many States that are projected to have one or more counties in 

nonattainment for the 8-hour ozone and fine particle standards in 2010. 

ICI boilers are a potentially cost-effective source for additional emission reductions. Preliminary 

data indicate that control technologies for industrial boilers can achieve emissions reductions 

cost-effectively—often well below current allowance prices for NOx and SO2, and in many cases, 

below the levels deemed to be “highly cost-effective” under the proposed CAIR rule for the 

electric power sector ($1,300 per ton of NOx and $700 per ton of SO2 in 2010).11 

Feasibility: There do not appear to be any major technical or legal barriers to the proposed 

analyses or other measures to close information gaps. In addition, if regulation of ICI boilers is 

deemed appropriate, we do not see any barriers because authorities exist under Sections 110, 111, 

and potentially other sections of the Clean Air Act. The main hurdle is anticipated to be the 

likelihood of industry lobbying and legal action. This can be mitigated in part by providing a 

reasonable horizon within the framework of the fine particle and ozone attainment deadlines and 

by offering as much compliance flexibility as possible through emissions trading or other means. 

Timing: Implementation of an emissions reduction program would need to take place no later 

than the 2010 to 2012 timeframe to help States meet attainment for ozone and fine particle 

national ambient air quality standards.12 Consequently, the suggested improvements to the data 

and rule development should begin as soon as possible to give the industry a long lead time for 

compliance, if regulation is deemed appropriate. 

Resources: EPA staff time would be required to develop peer-reviewed cost-effectiveness 

estimates, study the effects of ICI boiler control on attainment, and oversee the database 

development consultant. Funds would also need to be set aside to compensate the consultant. If 

 

10 Note that these percentages assume only existing regulations—they do not assume implementation of the proposed 

Clean Air Interstate Rule (CAIR) that would control emissions from the power sector. If implementation of CAIR 

were assumed, industrial, commercial and institutional boilers would constitute an even greater share of 2010 

emissions. For example, with implementation of CAIR, the ICI boiler share of 2010 SO2 emissions would be 

expected to increase to 22%. 11 It should be noted that EPA did not assume reductions from ICI boilers in the CAIR because they did not believe 

there was sufficient information to determine that controls met the highly cost effective criteria. 12 Attainment deadlines are as early as 2007 in some cases. In most cases, the NAAQS compliance deadline is April 15, 

2009. However, extensions may be granted through April 15, 2014 or even April 15, 2016, if the required showings 

are made. The limited number of areas designated “severe” for the 8-hour ozone standard have even longer to meet 

attainment. States will need to know whether national/regional measures are going to be successful several years 

before the final deadlines so that they can ramp up additional programs of their own, where needed. 

:: B-25 
Recommendations by the Air Quality Management Work Group 

national or regional regulation is deemed to be appropriate, EPA staff time would be needed to 

develop proposed and final rules and design the trading program infrastructure or other regulatory 

approach. The State role would be limited to monitoring and source permitting. 

The cost of implementation would depend on the type of regulation used and the number of 

sources covered. For example, the cost of administering an emissions trading program would be 

generally lower than a command-and-control approach. In addition, costs would be expected to 

increase somewhat if all ICI boilers are included versus those accounting for the majority of 

pollutants or those exceeding a boiler size or throughput threshold. 

Priority Level: High 

B-26 :: 
Recommendations by the Air Quality Management Work Group 

2.2 Industrial Surface Coatings: EPA should complete as soon as possible a review of the 

contributions from this category and the technical and economic feasibility of further controls. 

EPA should then initiate development of a regional or national emissions control regulation for 

the category, or take alternative action consistent with the results of its analysis.

Background/Explanation: VOCs from industrial surface coating represent about 11% of 

national VOC emissions. Reductions beyond current Control Techniques Guidelines (CTG) 

recommendations and New Source Performance Standards have been demonstrated and achieved 

by sources in all previously regulated industrial surface coating categories. While scheduled area 

source, residual risk rules, and 112(d)(6) review may result in further emissions reductions in this 

sector, there may still be significant emissions from facility maintenance operations and surface 

coating of miscellaneous wood products that have not been regulated previously. There exist two 

primary approaches for addressing these emissions – the use of low-VOC/low-HAP coatings, and 

the use of capture and control equipment. 

Recommended Actions: EPA should: (1) review nonattainment contributions from this category; 

(2) assess the technical and economic feasibility of a more stringent performance standard and 

revised CTGs; and (3) proceed with the appropriate action(s) based on this review and analysis. 

Feasibility: It would probably require 2 to 3 years to develop a new standard for this category. 

Resources would be devoted to review and analysis, necessary data collection and rule 

development. 

Timing: Any regulatory effort would take 2 to 3 years at a minimum. However, updates to 

existing CTGs could be completed in shorter timeframe. 

Resources: EPA resources would be required to undertake the required research and possible 

promulgation of a new NSPS, and also for the development of relevant CTGs. At the local level, 

resources associated with the adoption and enforcement of CTGs would potentially be required.

Priority Level: Medium 

:: B-27 
Recommendations by the Air Quality Management Work Group 

2.3 Non-industrial Solvents: EPA should initiate rulemaking efforts to establish minimum 

performance standards (i.e., a national rule) for this category using the VOC content limitations 

contained in, and regulating the products covered by, the model rule developed by the Ozone 

Transport Commission.

Background/Explanation: Non-industrial solvents are projected to be responsible for 16% of 

nationwide VOC emissions in 2010. NIS/CCP are specifically subject to Section 183(e) with 

regard to VOC emissions. There is an existing national rule (40 CFR 59 subpart C) that regulates 

24 categories of household consumer products. In addition, there are Control Techniques 

Guidelines (CTG) and alternative control techniques documents pertaining to categories such as 

cutback asphalt paving and agricultural pesticide application. The non-industrial nature of the 

products generally removes many of them from the authority of sections 111 and 112. There is no 

known authority to directly regulate HAP emissions from the use of consumer products. 

The existing federal consumer products rule regulates only 25 categories of products. This rule is 

estimated to have reduced VOC emissions from these categories of household and institutional 

products by approximately 20 percent, or 90.000 tons per year nationwide, from a 1990 baseline. 

These reductions were achieved at a cost effectiveness of about $250/ton. California and several 

other States have regulated, or are in the process of regulating, many more categories of products, 

and at lower VOC limits than the federal rule requires. As discussed above, several northeast 

States have been developing rules based on an Ozone Transport Commission (OTC) model rule 

for consumer products. The basis for the OTC model rule was the existing California rule. 

It is possible that further regulation might not result in appreciable reductions. The reason for this 

is that most consumer products are manufactured and distributed nationwide, and that the major 

manufacturers formulate their products to be distributed nationwide. Accordingly, nationally 

distributed products must meet the most stringent requirements. This results in “compliant” 

products being distributed and used nationwide, even in areas with no regulations. However, 

smaller, regionally distributed products should be affected by further federal action. In proceeding 

with this recommendation, EPA should quantify the potential achievable emissions reductions 

associated with tightening VOC content limitations. 

Recommended Actions: EPA should research the potential to gain additional VOC reductions 

from non-industrial solvents, focusing on: 

potential gains from regulation of additional product categories at the federal level and 

the of updating current standards; 

•

•

•

potential reductions from updating existing CTGs to reflect tighter State limits; and 

the extent to which regionally distributed products (from areas with no additional 

standards) contribute to total national VOC emissions and the magnitude of potential 

reductions from this group of products 

Following its review, EPA should take regulatory action consistent with its analysis. 

Feasibility: Further regulation of consumer products beyond the existing federal rule is possible 

and has been pursued by California and by some of the northeast States using an Ozone Transport 

Commission model rule based on California’s rule. 

Timing: Any regulatory effort would take 2 to 3 years at a minimum. However, updates to 

existing CTGs could be completed in shorter timeframe. 

B-28 :: 
Recommendations by the Air Quality Management Work Group 

Resources: Either a regulatory action or a revised CTG would probably require less than 1 FTE 

and $25K to $100K per year per category on EPA’s part, depending on how much work was 

performed in-house. At the local level, resources associated with the adoption and enforcement of 

CTGs will be required. 

Priority Level: Medium

:: B-29 
Recommendations by the Air Quality Management Work Group 

2.4 Architectural Coatings: EPA should initiate rulemaking efforts to establish minimum 

performance standards (i.e., a national rule) for this category using the VOC content limitations 

contained in, and regulating the products covered by, the model rule developed by the Ozone 

Transport Commission. 

Background/Explanation: VOCs from architectural surface coating represent about 4% of 

national VOC emissions. While this sector is already regulated under the national VOC rule 

(183(e)), California has adopted a more stringent standard for VOC content and OTC States are 

adopting rules based on the California rules. These standards could be extended nationwide. 

There currently exist near-zero VOC content materials for some content categories (e.g., flat 

interior wall coatings). 

Recommended Actions: Research the magnitude of potential reductions that could be gained 

beyond existing rules, and if significant reductions could be achieved cost-effectively, adopt a 

more stringent national VOC content standard for this sector. 

Feasibility: Implementation of additional controls for this industrial sector is a realistic 

expectation. It would require revisiting the current VOC content standard in place under section 

183(e). The existence of State standards that are well below the national standard and the 

development of extremely low-VOC content materials, suggest that this activity would be 

worthwhile. 

Timing: It would probably require 1-2 years to develop a new standard for this category. 

Resources would be devoted to necessary data collection and rule development. 

Resources: EPA resources would be required to undertake the required research and rule 

development for further regulatory action. 

Priority Level: Medium 

B-30 :: 
Recommendations by the Air Quality Management Work Group 

2.5 Heavy-Duty Diesel Engines: EPA should reduce emissions from the existing fleet of 

heavy-duty diesel engines by employing a multi-pronged approach.

Background/Explanation: Over the last decade, EPA has moved aggressively to strengthen 

federal emission standards for a wide range of diesel engines. While these standards will serve to 

dramatically lower emissions when fully implemented, the full human health benefits will not be 

realized for 20 years or more. The figure below graphically shows the national particulate 

pollution under the phase-in of the federal emission standards for diesel trucks and buses, and 

nonroad engines. 

Figure 1. National PM2.5

emissions under phase-in of 

federal standards for on road 

diesel trucks and buses, and 

nonroad diesel equipment. 

(Estimated from EPA, 2000 

and EPA, 2004a) 

0

50000

100000

150000

200000

250000

300000

350000

400000

2000 2005 2010 2015 2020 2025 2030

Year

Emissions 

(tons/year)

Particulate Pollution Under

Phase-in of Federal Standards for

Diesel Trucks, Buses and Machinery 

The delay in achieving emissions reductions is attributable to two factors. The first factor is the 

lapse in time before the emissions standards take effect for new engines. The standards finalized 

in 2001 for highway engines take effect in 2007, while the new standards for nonroad diesel 

engines are phased in based on engine size, beginning in 2008 with engines smaller than 25 hp. 

Final standards for nonroad engines greater than 750 hp will not be effective until 2015. The 

second factor that contributes to the lag in effectiveness of the diesel rules is the long lifespan of 

diesel engines. Under typical operating loads and levels of use, large diesel engines can last for 

more than one million miles and/or decades. 

The ultimate consequence of the time lag in emissions reductions for diesel engines is a 

corresponding lag in achieving the projected health benefits. EPA has estimated that by 2030, the 

highway diesel rule will avoid 8,300 premature deaths per year, which otherwise would have 

been caused by exposure to particulate pollution from diesel emissions (EPA, 2000, Table VII19). The rule is also projected to prevent more than 7,000 hospital admissions, 360,000 asthma 

attacks and more than 1.5 million lost work days in 2030 (EPA, 2000, Table VII-19). The 

nonroad rule similarly projects tremendous health benefits in 2030, including the avoidance of 

12,000 premature deaths and 8,900 hospital admissions per year from particulate pollution 

exposure (EPA, 2004a, Table 9-11). The nonroad rule is also projected to avoid 200,000 cases of 

exacerbated asthma in children in 2030 (EPA, 2004a, Table 9-11). These projected health 

benefits in 2030 are extremely important. However, the fact is that the same kinds of health 

impacts that will be avoided in 2030 are occurring now, and will continue to occur until today’s 

high-polluting diesel engines and equipment are replaced or cleaned up. 

:: B-31 
Recommendations by the Air Quality Management Work Group 

Policy action is needed to accelerate the transition to cleaner diesel engines and realize more 

immediate public health protection. In principle, emissions from these existing engines can be 

reduced either by incentivizing their early retirement, by improving their current emissions 

performance (e.g., by add-on emissions control system, changes in the engines themselves, repair 

of high-emitting engines or improved fuels), or by limiting the time that these engines operate 

(e.g., through idling reduction programs and/or otherwise). Each approach has merit under certain 

conditions and programs, and should be part of an implementation strategy. For example, 

centrally operated and fueled fleets (e.g., school and transit buses and refuse trucks) are good 

candidates for retrofit technologies or engine repowers. Some of these fleets can be excellent 

candidates for replacement with advanced technologies (e.g., hybrids) or alternative fuels. In 

addition, some mid-1990s engines can achieve lower emissions limits by reprogramming of 

engine control systems. Finally, programs aimed at reducing idling time can lower pollution, 

achieve substantial ancillary benefits from reduction of fuel consumption and greenhouse gas 

emissions, and lower operating costs. 

Recommended Actions: EPA will continue to employ a variety of strategies to monitor and 

reduce emissions from the in-use fleet and enforce its emissions standards. These strategies are 

outlined below: 

Heavy-Duty Compliance Programs 

Continue to work with manufacturers to ensure compliance with existing and new 

emissions standards through manufacturer testing of new and in-use engines and effective 

EPA enforcement. 

•

•

•

•

•

•

•

•

•

•

Ensure that manufacturers of consent decree engines reprogram control systems to reduce 

NOx emissions. 

Develop, evaluate and provide guidance to the States on a heavy-duty vehicle testing 

approach that will be appropriate for use in heavy-duty vehicle inspection and 

maintenance (I/M) programs as a replacement for the existing snap-idle (smoke) test. 

Work closely with California Air Resources Board (CARB) to develop a harmonized, 

nationwide set of requirements for Heavy Duty On-Board Diagnostics (HD OBD) in the 

US for gas and diesel vehicles for implementation in 2010.

Investigate the development of portable emission measuring equipment to quickly and 

accurately measure diesel particulate matter (PM) emissions. 

Voluntary Programs 

Develop a national initiative, building upon the success of EPA’s voluntary programs, to 

provide federally funded incentives for diesel emissions reductions using California’s 

Carl Moyer Program and Texas’s Emissions Reduction Plan as models. 

Investigate low-interest loan programs and other creative financial methods to help 

private fleets retrofit or rebuild existing engines to reduce emissions. 

Work toward the goal of reducing the emissions of the existing 11 million engines in the 

fleet today by concentrating on the construction, port, freight and school bus sectors. 

Meet with States and engine manufacturers to develop a voluntary program that educates 

owners on ECM reflash strategies (to achieve NOx reductions) and urge their 

participation. 

Continue building industry support through voluntary, market-based approaches. 

B-32 :: 
Recommendations by the Air Quality Management Work Group 

Work with General Services Administration (GSA) and Department of Defense (DOD) to 

establish, by January 2006, government-wide procurement and contracting guidelines on 

emissions performance standards for existing diesel engines. 

•

•

•

Work with private and public fleets to develop operational strategies to reduce in-use 

emissions, such as idling reduction programs. 

EPA should also consider a mandatory program that would: 

Dramatically expand current federal programs to cut pollution from existing diesel 

engines through accelerated retirements, retrofits, repowering, replacement and antiidling measures. EPA should pursue a dual, complementary strategy to achieve the goal 

of retrofitting all heavy-duty diesel engines by 2012 by: (a) establishing mandatory 

measures to cut pollution from existing diesel engines and (b) considerably multiplying, 

through expanded congressional appropriations, the funding for both mandatory and 

voluntary programs with funding contributions from other federal agencies as well. 

Feasibility: Continuation of the existing program is feasible; the compliance programs are 

operating under existing statutory authority and the voluntary efforts are currently partnering with 

States and fleet operators across the country. Legislation to secure expanded federal funding to 

sustain and enlarge voluntary programs to clean up existing diesel engines is also feasible, but 

would present a substantial challenge. The cost to retrofit all diesel engines would be high. 

Timing: Several specific actions recommended here are currently a part of EPA’s ongoing 

efforts. As noted above, EPA and CARB are working toward implementation of national HD 

OBD requirements in 2010. It is anticipated that other actions can be implemented in 3-4 years as 

current studies are completed and new testing technologies are established. 

Resources: Continue existing efforts. Redirection of existing efforts/personnel may be required. 

Priority Level: High 

References: 

EPA. 2000. Regulatory Impact Analysis: Heavy Duty Engine and Vehicle Standards and 

Highway Diesel Fuel Sulfur Control Requirements, EPA420-R-00-026, December.

EPA. 2004a. Final Regulatory Analysis: Control of Emissions from Nonroad Diesel Engines, 

EPA420-R-04-007, May. 

EPA. 2004b. Median Life, Annual Activity and Load Factor Values for Nonroad Engine 

Emissions Modeling, EPA420-P-04-005, April. 

:: B-33 
Recommendations by the Air Quality Management Work Group 

2.6 Emissions from Ships, Locomotives, and Aircraft, and Mobile Source Air 

Toxics: EPA should address emissions from ships, locomotives, and aircraft, and mobile source 

air toxics through national emissions standards. 

Background/Explanation: Over the past decade, EPA has adopted several groundbreaking rules 

that will dramatically reduce emissions from the nation’s passenger vehicles, trucks and buses, 

and nonroad equipment. Collectively, these rules will eliminate tens of thousands of premature 

deaths and create tens of billions of dollars of health and other social benefits. Indeed, new 

engines covered by these regulations will be more than 90 percent cleaner than their predecessors. 

As these vehicle sectors get progressively cleaner, thanks to vehicle turnover and an increased 

emphasis on retrofit and other strategies to reduce emissions from the existing fleets, EPA should 

address the growing percentage of emissions from engines outside the scope of these rulemakings 

i.e., from ships, locomotives and aircraft. Moreover, EPA should address mobile source air toxic 

emissions that have not been addressed by these rulemakings. 

Regulating Additional Mobile Sources: Aircraft, Locomotive 

and Marine Diesel Engines 

While emissions from most categories of mobile and industrial sources have stabilized or 

decreased over the past two decades, emissions from locomotives, marine diesel engines and 

aircraft have increased, and are forecast to continue growing. For example, airplanes at U.S. 

airports emitted 350 million pounds of smog-forming pollutants in 1993, more than twice their 

1970 total. The FAA estimates that aircraft-related NOx emissions will double by 2030. At the 

local level, an airport’s arriving and departing planes can emit as much smog-forming pollution 

as many power plants and other large industrial sources.1

 

The situation at our nation’s ports and rail yards is no different. Ships are projected to be the 

second largest source of mobile source PM emissions in 2020, emitting roughly one-fifth of the 

nation’s soot particles,2

 thanks to the clean-up of highway and other nonroad diesel engines and 

the sharp projected growth in port activities. Locally, this growth will be even more 

significantCthe Port of Los Angeles expects its trade-related traffic to triple by 2020. 

Although these emissions can be significant local emission sources, States are largely preempted 

from regulating them through their SIP process or otherwise. Moreover, exhaust emission 

standards do not effectively address aggregate aircraft, ship or locomotive emissions on any given 

airport runway, at a crowded port or in a busy rail yard. Many of these sites are near residential 

neighborhoods, increasing the need for meaningful emission reduction strategies. 

Regulating Additional Emissions: Mobile Source Air Toxics 

Mobile source air toxics (MSATs) are among the most pervasive and hazardous pollutants 

regulated by EPA. Indeed, EPA’s National Air Toxics Assessment data show that MSATs exceed 

cancer health benchmarks in all areas of the country and are up to 10 times higher in urban areas. 

Mobile source programs such as Tier 2, highway diesel and nonroad diesel will significantly 

reduce mobile source air toxics. However, an analysis conducted by the Northeast States shows 

that nationwide, even with the full implementation of all mobile source programs, benzene, 1,3 

butadiene, formaldehyde and other potent toxins will continue to exceed health risk benchmarks. 

EPA is required by CAA section 202(l) to reduce the threat posed by MSATs. 

 

1

 NRDC, Flying Off Course: Environmental Impacts of America’s Airports, 1996, pp. 36-37. 2

 EPA, Nonroad Diesel Rule, Draft Regulatory Impact Analysis, EPA 420-R-03-008, April 2003, Section 3.2. 

B-34 :: 
Recommendations by the Air Quality Management Work Group 

 

Recommended Actions: EPA should: 

1) Promulgate technology-forcing Tier 2 emission standards for all new marine diesel 

engines, including compression-ignition marine engines at or above 30 liters per cylinder 

(Category 3 engines), that are more stringent than the international MARPOL Annex VI 

NOx limits. Section 213 of the Clean Air Act Amendments directs EPA to set nonroad 

standards that “achieve the greatest degree of emission reduction achievable through the 

application of technology which the Administrator determines will be available for the 

engines or vehicles to which such standards apply.” Such standards should achieve 

emission reductions comparable to those required of other mobile source categories under 

EPA’s recent highway and nonroad diesel rules. These regulations should apply to all 

ships in U.S. ports, whether U.S. or foreign flagged. 

2) Promulgate technology-forcing emission standards for new and rebuilt locomotive 

engines. Again, Section 213 of the Clean Air Act Amendments clearly authorizes EPA to 

do so. Such standards should achieve emission reductions comparable to those required 

of other mobile source categories under EPA’s recent highway and nonroad diesel rules. 

3) Promulgate technology-forcing emission regulations for aircraft that are comparable in 

stringency to other mobile source emissions standards, while maintaining the aviation 

industry’s outstanding safety record. As with marine diesel engines, EPA is not limited 

by the ICAO process, and is authorized by Section 213 of the Clean Air Act to adopt such 

technology-forcing emission standards. 

4) Develop strategies (including, to the extent permissible, permitting requirements and SIP 

control strategies) for reducing aviation, ship and locomotive emissions at airports, 

seaports and rail yards that can be employed at the State and/or Local level. 

5) With respect to controlling ground-level aviation emissions within their SIP processes, 

EPA should encourage States and airport operators to consider strategies such as reduced 

engine idling and taxiing, differential landing fees, using gate-powered electricity rather 

than auxiliary power units, among others. 

6) Provide guidance to States and airport operators so they consider emissions reduction 

strategies for ground service equipment as part of their SIP strategies. Such strategies 

could include accelerated retirement, engine repowers, emission control retrofits, reduced 

idling measures and replacements with the cleanest available engines and fuels, including 

alternative fuels. 

7) Study toxic aircraft, ship and locomotive emissions and develop a strategy for reducing 

them. Studies have shown that these sources generate significant hazardous air pollutants, 

yet they are exempt from the Toxic Release Inventory (TRI) program.3 

8) Dramatically expand the agency's programs to cut diesel PM from existing engines 

including both voluntary and mandatory measures. 

9) Promulgate a protective national benzene cap. Expanding low-RVP gasoline 

requirements beyond ozone nonattainment areas would also lower benzene and other 

toxic VOCs and secondary toxics like formaldehyde and acetaldehyde. 

10) Consider regulations to reduce other mobile source air toxics such as formaldehyde, 

acetaldehyde, acrolein and 1,3-butadiene. 

 

3 See, e.g., http://www.arb.ca.gov/diesel/documents/rrstudy/rcexecsum.pdf. 

:: B-35 
Recommendations by the Air Quality Management Work Group 

11) Consider national gasoline standards that further reduce sulfur and also address other fuel 

parameters. 

12) Address the high sulfur content in the distillate/bunker fuel used in Category 3 oceangoing marine vessels. 

13) Consider requiring catalysts on nonroad gasoline engines such as forklifts. 

Feasibility: High. 

Timing: Current plans call for an NPRM on gasoline outboard, sterndrive, inboard and personal 

watercraft engines in the Spring of 2005; an NPRM on locomotive and marine diesel standards in 

mid-2005; an NPRM on air toxics in mid-2005; a final rule adopting the existing International 

Civil Aviation Organization NOx standards for aircraft engines in 2005; and a final rule on oceangoing marine diesel engines by mid-2007. 

Resources: Several of the recommended actions have already been funded and staffed. 

Priority Level: High 

B-36 :: 
Recommendations by the Air Quality Management Work Group 

2.7 Cement Manufacturing, Petroleum Refining, and Pulp and Paper: The 

cement manufacturing, petroleum refining, and pulp and paper industrial source categories are 

already under substantial regulation, but continue to be significant sources of pollutants and 

warrant further consideration by EPA. EPA should evaluate potential national or regional 

emissions reduction strategies for criteria pollutants and air toxics in these categories. This 

should include improving emissions inventories if necessary and assessing their impacts on 

nonattainment areas or other sensitive areas. EPA should carefully consider the costeffectiveness of imposing additional controls as it determines whether additional emissions 

reductions are justified and should take action consistent with the results of this analysis. 

Background/Explanation: Cement plants, petroleum refineries, and pulp and paper mills are 

major emitters of criteria pollutants and hazardous air pollutants (HAPs). While boilers from 

refineries and pulp and paper mills would be considered under the ICI boiler recommendation, 

process sources associated with these two sectors present an additional challenge. It is much more 

difficult and costly to monitor and report emissions from process sources, such as catalytic 

cracking units, flares, and sources of fugitive emissions. 

Petroleum refineries are major sources of HAPs and emit large quantities of criteria pollutants. 

There are 146 petroleum refineries located in 33 States. However, fifty-five percent of the U.S. 

production capacity is located in three States - Texas, Louisiana, and California. 

Based on EPA’s projections for 2010, the cement industry in the U.S. will emit approximately 5 

and 2 percent of the overall NOx and SO2 emissions, respectively, excluding the emissions from 

EGUs. The sources of these emissions are about 200 active cement kilns in this country. Since 

cement industry was included under the NOx SIP Call rule, some of these kilns have already been 

retrofitted with NOx controls. 

Pulp and paper mills are projected to be responsible for 2 percent of both nationwide PM2.5

emissions and organic carbon emissions in 2010. The recent air toxics rules included a PM limit 

as a surrogate for metal HAPs, but PM2.5 has not been specifically addressed. 

Recommended Actions: 

1) EPA should evaluate further potential national or regional emissions reduction strategies 

for criteria pollutants and HAPs in these categories. This should include improving 

emissions inventories and assessing their impacts on nonattainment areas or other 

sensitive areas. 

2) EPA should carefully consider the cost-effectiveness of imposing additional controls as it 

determines whether additional emission reductions are justified. 

3) EPA should and take action consistent with the results of its analysis of these sectors. 

Feasibility: High, given apparent lack of technical or legal barriers to analysis and/or rule 

development. 

Timing: This recommendation should be implemented in a timeframe that would allow for at 

least some emissions reductions to be achieved by 2010. 

Resources: EPA staff time would be required to develop peer-reviewed cost-effectiveness 

estimates and study the effects of further control on these sectors on attainment. If national or 

:: B-37 
Recommendations by the Air Quality Management Work Group 

regional regulation is deemed to be appropriate, EPA staff time would be needed to develop 

proposed and final rules. 

The cost of implementation will depend on the type of regulation used and the number of sources 

covered. For example, the cost of administering an emissions trading program is generally lower 

than a command-and-control approach. 

Priority Level: Medium 

B-38 :: 
Recommendations by the Air Quality Management Work Group 

2.8 Residential Fossil Fuel Combustion: EPA should evaluate the potential for 

expanding the Energy Star voluntary program to gain additional criteria pollutant emissions 

reductions (as well as improve energy efficiency) from the residential fossil fuel sector. As part of 

this effort, EPA should continue to gather information on the characteristics of residential fossil 

fuel emissions and their contributions to non-attainment, and the magnitude and cost of potential 

emissions reductions under a voluntary program and/or expanded use of low-sulfur fuel. EPA 

should also coordinate with Regional Planning Organizations (RPOs) and companies that 

produce lower-emitting appliances to assess the potential for programs that promote the 

installation of such technologies.

Background/Explanation: Residential fossil fuel use generally comprises natural gas, fuel oil, 

LPG and kerosene combustion for space heating, water heating, and cooking. This source releases 

emissions of several criteria pollutants, most significantly SO2 and NOx. Geographically, 

emissions are more significant in the Northeast and Midwest. Opportunities for emissions 

reduction generally include actions or technologies that improve energy efficiency, such as high 

efficiency boilers, furnaces and water heaters, and insulation and air sealing, or energyconserving behaviors (e.g., heating only rooms being used). Other emissions control opportunities 

include low-NOx space and water heaters, or the use lower sulfur fuel oil. Because residential 

sources are numerous and small, implementation of a strict cap or rate requirement would be 

impracticable. However, a voluntary program could be an effective means of reducing emissions. 

Energy Star is a national voluntary program (jointly run by EPA and the Department of Energy 

(DOE)) that focuses on reducing CO2 emissions through energy efficiency measures. Many of the 

energy efficiency measures promoted for reducing residential CO2 emissions also reduce 

emissions of criteria pollutants. In addition, DOE issues energy efficiency standards for 

appliances. Considering the significant amounts of emissions from residential fossil use, the 

availability of control measures, and the potential for collaboration with the existing Energy Star 

program, this is a potential area for further Federal action. 

Because many of the actions to reduce criteria pollutants from residential fossil use are measures 

that improve energy efficiency, these actions can generate cost savings for homeowners. Energy 

Star has a program to promote whole house retrofits, which is estimated to save homes an average 

of 30 percent of the total energy bill. DOE has a program that provides air sealing and insulation 

to qualifying homeowners, and the Department estimates the cost at $2,672 per home with energy 

savings paying for costs within a few years. Energy Star programmable thermostats can save a 

home about $100 per year. Note that not all actions that improve home energy efficiency will 

reduce criteria pollutants from residential fossil use, so not all of the cost savings from these 

programs would be attributed to reducing criteria pollutants. 

An EPA analysis estimated the costs of a rule that would require low-NOx residential water 

heaters, and found that such a rule would not increase the cost of natural gas water heaters, 

implying a cost effectiveness of $0 per ton NOx removed. 

DOE research indicated that low-sulfur fuel oil might cost up to two cents more per gallon than 

conventional fuel oil. The reduced sulfur levels may lead to net savings for consumers, due to 

reduced maintenance and cleaning costs. 

Recommended Actions: EPA should: 

1) Work toward establishing low sulfur fuel alternatives for residential fossil fuel heating 

systems, and possible regulation of sulfur content of home heating fuels. 

:: B-39 
Recommendations by the Air Quality Management Work Group 

2) Talk with its Energy Star staff about the potential for an expanded voluntary program to 

promote actions that both improve energy efficiency and reduce criteria pollutants. 

3) Talk with NESCAUM and other regional organizations to raise awareness of the extent to 

which residential fossil fuel emissions are a regional concern, and to ascertain their 

thoughts on voluntary programs promoted at the regional level. 

4) Talk with companies that currently produce and/or market high efficiency appliances that 

reduce emissions, to assess their interest in engaging in programs to promote the 

installation of emissions-reducing technologies (e.g., by offering rebates). 

5) Continue to gather information about the characteristics of residential fossil fuel 

emissions and their contributions to nonattainment. Also gather information about the 

extent to which further action would gain meaningful emissions reduction beyond what 

has been achieved under Energy Star and what is projected to be achieved under DOE’s 

forthcoming revised energy efficiency standards. 

Feasibility: This recommendation has a high feasibility for implementation. A Federal voluntary 

program implemented in collaboration with the existing Energy Star program presumably would 

be implemented under the same statutory authority as Energy Star. This recommendation does not 

establish any proscriptive mandates that would require regulatory action. No major obstacles have 

been identified. Regulation of sulfur-content of home heating fuel would require a longer 

timeframe. 

Timing: It is anticipated that discussions with Energy Star staff, NESCAUM and other regional 

organizations, as well as further information gathering, can be completed in 6 months. Once 

decisions are made to pursue Federal and/or regional voluntary programs, full implementation 

can be achieved within a year to a year and a half. Regulation of sulfur-content of home heating 

fuel would require a longer timeframe. 

Resources: Collaboration with Energy Star will provide significant savings in resources, drawing 

on existing expertise and experience. Some additional personnel at the Federal level would be 

required to accommodate the expanded scope beyond CO2 reductions. If regional programs are 

implemented then some additional resources will be required at that level.

Priority Level: Medium 

B-40 :: 
Recommendations by the Air Quality Management Work Group 

2.9 Guidance for Local Control Measures in Key Sectors: EPA, in conjunction with 

S/L/T and affected stakeholders, should prepare guidance for local (urban-scale) control 

measures to support the upcoming round of ozone and PM2.5 SIPs, and, if possible, optimize 

multipollutant control benefits and opportunities for reducing criteria and toxic air pollutants.

Background/Explanation: Many states are starting to prepare State Implementation Plans (SIPs) 

to address nonattainment requirements for ozone (8-hour) and PM2.5, and reasonable progress 

requirements for regional haze. These nonattainment (and regional haze) problems are due to 

impacts from nearby (local) and more distant (regional) sources. The NRC recognized that 

additional federal emission control measures and guidance would be useful in assisting states to 

effectively attain air quality standards for ozone and PM2.5. This recommendation will focus on 

providing guidance for local (urban-scale), multi-pollutant control measures, which are most 

properly dealt with by States in their SIPs. Specifically, this recommendation will focus on the 

current round of SIP development for ozone, PM2.5, and regional haze (i.e., SIPs which are due in 

2007/2008 and address attainment in the 2010 timeframe). (It should be noted that absolute and 

relative amounts of emissions by source sector is expected to change beyond 2010, with 

significant reductions expected for at least mobile sources and EGUs.) Other recommendations 

address regional/national control measures for certain source categories, which are most 

effectively dealt with by EPA as part of federal rulemaking. 

Recommended Actions: Federal guidance is needed now to assist states in preparing SIPs to 

address nonattainment requirements for ozone (8-hour) and PM2.5 (i.e., attain ambient standards 

by 2010), and visibility/regional haze requirements (i.e., satisfy first reasonable progress 

milestone in 2018). The Work Group recommends that EPA, in conjunction with S/L/T and 

affected stakeholder, undertake the following actions: 

1) Issue technical guidance for source categories that would benefit from local (urbanscale), multi-pollutant strategies and technologies. The identification of these source 

categories should be based on an evaluation of existing ambient monitoring data, source 

apportionment studies, modeling analyses, and future year emissions inventories. 

Consideration should also be given to emission reduction potential (and uncertainty in 

emission estimates), timeliness, cost effectiveness, completeness of existing guidance 

(e.g., STAPPA/ALAPCO’s forthcoming “Menu of Options for Control Fine Particulate 

Matter”), and reactivity (if relevant). Additional studies and analyses may be necessary to 

provide a comprehensive list of local strategies and technologies. 

2) Given that ozone (8-hour) and PM2.5 (and haze) SIPs are due in mid-2007 and early 2008, 

respectively, EPA should issue guidance now for those source categories considered to be 

associated with residual nonattainment problems (in the 2010 timeframe). Based on a 

preliminary review of available ambient monitoring data, source apportionment studies, 

modeling analyses, and emissions inventories, it is suggested that guidance should be 

prepared now for the following source categories: 

• Residential woodstoves and fireplaces; 

•

•

•

Mobile sources (e.g., high emitting vehicles and diesel retrofit programs); 

Open burning; and 

Industrial operations (e.g., cement manufacturing, petroleum refineries, pulp and 

paper, metals, and surface coating); 

:: B-41 
Recommendations by the Air Quality Management Work Group 

Note, the other factors identified above (e.g., emission reduction potential, timeliness, cost 

effectiveness, completeness of existing guidance, and reactivity) were not considered in 

identifying this list of source categories, but should be considered by EPA in prioritizing 

development of the guidance, and by S/L/T in implementing the guidance. It should also be noted 

that some of the source categories addressed by this local-scale guidance may also be appropriate 

to address at the national/regional level through federal rulemaking. 

Benefits: This recommendation would result in guidance to help S/L/T meet the demands of 

preparing SIPs for ozone, PM2.5, and haze over the next couple of years. In addition, it should 

help support integrated, multi-pollutant emission reduction strategies, which should allow S/L/T 

to develop control plans more effectively (e.g., targeting source categories considered to be 

associated with residual nonattainment problems) and efficiently (e.g., less the time and resources 

compared to develop SIPs on a pollutant-by-pollutant basis). 

Feasibility: There do not appear to be barriers associated with developing guidance for local 

control measures. The statutory authority for integrating area source standards into the guidance 

might include sections 111(d), 112(d)(4) and (5), 112(l) or 112(k)(3) and (4) of the Clean Air Act. 

Timing: The development of the initial round of guidance would require immediate attention in 

order to be useful for the first round of ozone (8-hour) and PM2.5 (and haze) SIPs, which are due 

in mid-2007 and early 2008, respectively. As such, the first round of the guidance should be 

issued by October 2005 and, as such, will likely be able to a few source categories. 

Resources: The guidance can be prepared by EPA contractors and is estimated to cost around 

$75K per source category. 

Priority Level: High 

B-42 :: 
Recommendations by the Air Quality Management Work Group 

2.10 Residential Wood Smoke: EPA should further develop the Residential Wood Smoke 

Reduction initiative that includes working with S/L/T, industry, non-governmental organizations 

and others to support and facilitate the changeout of dirty, inefficient “conventional” (pre-New 

Source Performance Standard or NSPS) woodstoves with new, cleaner and more efficient heating 

appliances (e.g., EPA certified woodstoves). Concurrent with the development and 

implementation of changeout programs, EPA should commence efforts to revise the NSPS. 

Background/Explanation: Residential wood smoke contains PM2.5 and various types of 

hazardous air pollutants (e.g., polycyclic organic matter). Wood smoke emissions occur in 

neighborhoods where people live. Wood burning is done throughout the United States, in varying 

degrees depending on the location. Large emissions reduction potential (60%-80%) exists and 

there are programs that have been successfully implemented. Residential wood smoke makes up 

420,000 tons of total direct PM2.5 emissions, with 80 percent of the total coming from 

woodstoves. Nationally residential wood smoke contributes approximately 22 percent of all 

seven of the carcinogenic PAHs identified in the EPA’s National Emissions Inventory. There are 

approximately 10 million wood stoves in use at this time, and 80 - 90 % of those are pre-NSPS 

stoves. 

Recommended Actions: Build on and implement EPA’s Office of Air Quality Planning and 

Standards (OAQPS) voluntary residential wood smoke reduction initiative started earlier this 

year. Currently, EPA plans to pilot test the concept of wood stove changeouts in three locations in 

FY 05, and then three to six more in FY 06. In FY 06-07 EPA would work to grow the 

woodstove change out initiative into a grant program like the diesel retrofit program. 

Concurrently with the development and implementation of the voluntary initiative, EPA should 

commence efforts to revise the NSPS.

Woodstove Changeout Campaign 

a) Build strong partnerships with States, communities, hearth trade association, nonprofits and others; 

b) Implement 3 pilot woodstove changeout demonstration projects in FY 05; 

c) Develop education and outreach materials, including website; 

d) Evaluate and document FY05 successes and lessons learned; 

e) Develop model woodstove changeout program template; 

f) Distribute template and encourage States/Locals/Tribes to implement at local level; 

and 

g) Issue guidance on how to quantify the emission reductions from the wood stove 

change outs for SIP purposes. 

Fireplaces 

a) Support development of ASTM consensus test method; and 

b) Use the EPA website to educate consumers on more efficient and less polluting 

options. 

Outdoor Wood Boilers 

a) Gather information on the nature and magnitude of air quality impacts; 

b) Support development of ASTM consensus test method; and 

:: B-43 
Recommendations by the Air Quality Management Work Group 

c) Determine whether a regulatory or non-regulatory approach is warranted. 

There are several examples (e.g., Crested Butte, CO) in various sizes of communities where 

voluntary residential wood burning programs have been effectively implemented, particularly in 

the western part of the U.S. to address PM10. 

Feasibility: This recommendation is technically feasible because the cleaner technologies (50-

70% fewer PM emissions) are available and woodstove changeout programs have been successful 

in the past. The idea is to greatly expand the effort and find creative ways to fund the woodstove 

change outs, particularly for low income families. There are no federal standards that require 

wood stove owners to replace their old dirty wood stoves (that owners often believe are “working 

just fine” and appear to last forever) with a cleaner technology. Although changeout programs in 

the past have depended heavily on manufacturer rebates and tax incentives, many of the people 

who depend on wood as a primary heating source are low income and are not in a situation such 

that they can take advantage of these incentives. Addressing this need will be a challenge. 

Timing: The initiative would be gradually ramped up from demonstration projects to a program 

between now and 2008 in those areas where wood smoke is a significant contributor to 

nonattainment for PM2.5 and for those areas that may be close to nonattainment for PM2.5. If 

communities could identify foundations, businesses or other sources to obtain funding to 

purchase stoves for low income families, the program could be especially effective and 

woodstoves could be changed out by 2008, the likely attainment dates. 

Resources: The estimated costs to EPA for FY ’05 and FY ’06 are $300,000 and 3-4 FTE for 

each year. If the pilots are sufficiently successful, the cost to EPA could grow to $1M in FY 07. 

The cost to State/Local/Tribal areas could be up to .5 FTE per location selected to assist in EPA’s 

pilots. If States/Locals or Tribes elect to conduct change out programs on their own using EPA’s 

model program developed, the cost per location would likely be up to 1 FTE. If communities are 

successful in identifying sources of funding to purchase stoves for low income families, the 

amounts they would need in FY ’05 would be as little as $1-2M, and would grow in the out years 

to $50M or more across the country. Manufacturers and retailers of woodstoves have historically 

provided rebates of 10% to 20% per stove. Regardless of whether communities are successful in 

securing funding to purchase stoves for low income people, some emission reductions will occur 

from the outreach activities that EPA and the State/Local air pollution control agencies conduct 

and the economic incentives provided by the manufacturers and retailers, however the magnitude 

of the reductions would be significantly lower. Additional funds would be needed for EPA to 

revise the NSPS. 

Priority Level: High 

B-44 :: 
Recommendations by the Air Quality Management Work Group 

2.11 Open Burning: EPA should work with S/L/T to encourage more vigorous control of 

open burning, especially in, and adjacent to, counties with Class I areas and counties classified 

as nonattainment for fine particles or ozone.

Background/Explanation: Open burning has been a difficult source of emissions to control due 

to the complexities of alternative waste disposal methods, associated costs, and the mindsets of 

many Americans who view open burning as acceptable and of little consequence to their health. 

Yet open burning releases substantial emissions of fine particles, volatile organic compounds, and 

carbon monoxide and lesser amounts of organic carbon, oxides of nitrogen, and other pollutants 

of concern. Emissions from open burning, released near the ground and most often in relative 

proximity to inhabited areas, contribute to urban smog, regional haze, and elevated fine 

particulate and ozone readings and cause periodic localized exposures in excess of acceptable 

risks. 

Recommended Actions: EPA should: 

1) Survey State and Local agencies and Tribes, identify current levels of control of open 

burning nationwide, and update open burning emissions and control information. 

2) Develop SIP guidance for States, Locals, and Tribes to outline procedures and calculation 

methodologies for determining emissions reductions credit for more stringent regulation 

of open burning activities. 

3) Consolidate information on open burning emissions and health impacts into updated 

informational documents, brochures, and flyers. 

4) Develop an outreach strategy designed to inform States, Locals, and Tribes of the impacts 

of open burning on air quality and to encourage tighter controls in areas with inadequate 

regulation of open burning. 

5) Encourage States, Locals, and Tribes to include bans or more stringent restrictions on 

open burning in counties with a nonattainment area or a Class I area and in counties 

adjacent to, or impacting, those areas. 

6) Consider making open burning control strategies a component of nonattainment SIPs. 

7) Develop a model open burning rule for use by States, Locals, and Tribes. 

8) Work with EPA’s Office of Solid Waste to determine if a national open burning rule is 

worthwhile and, to the extent that such a determination is made, pursue development and 

implementation of such a rule. 

States, Local agencies, and Tribes should: 

1) Review available data on emissions from open burning. 

2) Seek tighter controls on open burning within their jurisdictions and especially so in the 

vicinity of nonattainment and Class I areas. 

3) Mount substantial public education campaigns to advise citizens of the impacts of open 

burning and disposal alternatives. 

4) Develop comprehensive waste management and disposal methods that reduce the 

inclination of citizens to burn waste materials. 

:: B-45 
Recommendations by the Air Quality Management Work Group 

Benefits: Implementation of this recommendation would benefit public health by reducing 

exposure to fine particles, ozone, NOx, VOCs, carbon monoxide, and toxic air pollutants. 

Improvements in visibility would also be achieved which would help address the aesthetic goals 

of the regional haze program. The nation’s air pollution control agencies would benefit through 

the resultant additional emission reductions that would contribute to meeting national ambient air 

quality standards and aid in meeting reasonable further progress goals of the criteria pollutant and 

regional haze programs. 

Feasibility: This recommendation has a high feasibility for implementation because it can be 

completed under existing statutory authority. It does not establish any proscriptive mandates that 

would require regulatory action, with the exception of the recommendation to consider making 

open burning control strategies a required component of nonattainment SIPs and to review the 

possibility of creating a national open burning rule. Concerns include additional staff time to 

conduct research and prepare informational documents, local reluctance to impose additional 

regulatory controls on citizens, and inadequate regulatory agency staffing to enforce the 

requirements at the Local, State, and Tribal level. 

Timing: It is anticipated that the bulk of this recommendation could be implemented within one 

year because only research and informational brochure development must be competed. The 

exceptions are development of implementation guidance requiring open burning controls in SIPs 

and possible development of a national open burning rule. 

Resources: Redirection of existing efforts and personnel would be required. No significant 

additional EPA resources are anticipated to implement this recommendation because the protocol 

is non-regulatory and does not have to go through a formal public process. At the State, Local, 

and Tribal level, enforcement of open burning requirements would place additional demands on 

compliance staff, only some of which could be absorbed with current resource levels. 

Priority Level: Medium 

B-46 :: 
Recommendations by the Air Quality Management Work Group 

2.12 High-Emitting Gasoline Vehicles: EPA and S/L/T should reduce emissions from 

high-emitting gasoline vehicles that are believed to contribute a high fraction of mobile source 

emissions. 

Background/Explanation: Most people are aware that increasingly stringent regulations on new 

vehicle tailpipe emissions and improved durability of emissions controls have had a large and 

positive effect on reducing overall fleet emissions. What is less well known is that an increasing 

portion of the remaining emissions result from a relatively small fraction of high-emitting 

vehicles, and that future emissions reduction will depend to an increasing degree on developing 

an effective and politically acceptable means of identifying and dealing with these vehicles. 

To date, the primary program for identifying high-emitting vehicles has been periodic tailpipe 

testing within vehicle inspection and maintenance (I/M) programs. Some I/M programs have 

begun to phase out tailpipe testing for more recent (1996 and later) vehicles in favor of using the 

onboard diagnostic (OBD-II) systems included in these vehicles. While other methods, especially 

on-road vehicle remote sensing, have proven effective, in some cases, at evaluating fleet 

emissions and, in a more limited role, in “clean screening” and “high-emitter identification” 

programs, existing systems and methods have not yet been demonstrated to be sufficiently 

effective to serve as the basis for a large scale high-emitter identification program. 

California is considering a catalyst replacement program for model year 1984 to 1994 vehicles. 

The replacement would be an OBD-compliant aftermarket converter. Preliminary testing has 

shown significant, cost effective emission benefits. Incentives may be required to encourage 

replacement when a vehicle is still meeting the required standards. 

Recommended Actions: EPA and States/Locals/Tribes should: 

1) Determine the aggregate impact of high-emitters on today’s mobile source vehicle 

inventory. Identify those areas where emissions from high-emitters contribute 

significantly to the mobile source inventory. Analyze available data and develop new 

data sources such as EPA’s Kansas City study. Use untapped existing or new data 

sources such as I/M databases and new manufacturer-run in-use data as it becomes 

available. 

2) Develop better means for analyzing EPA and manufacturer in-use testing data and 

vehicle I/M records to identify patterns of vehicle emissions failures both as an aid in 

repairing these vehicles and to provide feedback to manufacturers for improvements in 

the durability of emissions control systems. 

3) Encourage the continued development of on-road vehicle remote sensing or other 

technologies that show promise for serving as the basis for future high-emitter 

identification programs for pre-1996 vehicles. Until an effective and appropriate 

alternative is available, encourage States to maintain their I/M infrastructure and to 

continue testing pre-1996 vehicles. 

4) Continue to evaluate the effectiveness of OBD systems, tailpipe emissions testing, and 

new technologies to identify post-1996 high-emitting vehicles. 

5) Make use of new technology as it becomes available in remote sensing and OBD to 

improve detection. 

6) Continue to work with State and Local I/M programs to provide technical information to 

assist repair technicians regarding emissions-related failures and appropriate corrective 

:: B-47 
Recommendations by the Air Quality Management Work Group 

actions and, where appropriate, to advocate and support programs that remove from 

service and scrap high-emitting vehicles, especially those not OBD-II equipped, for 

which cost-effective repairs cannot be made. 

7) Continue outreach on OBD to increase public response to repair high-emitters after they 

are detected. 

Feasibility: High. Some programs to gather needed data are already underway, such as the OBD 

high-mileage study and the Kansas City study. EPA (or other stakeholders) would need to devote 

additional resources to collect additional data to accurately determine the impact of high-emitters. 

Other steps depend on development of new technology by others. 

Timing: It is anticipated that these recommendations can be implemented in 3 to 4 years as 

current studies are completed, new data becomes available for I/M and manufacturer in-use data, 

and additional studies are initiated and completed. 

Resources: Redirection of existing efforts and personnel would be required for new work while 

existing resources would be used for work already underway.

Priority Level: Variable (depends on the impact of high-emitters on inventory) 

B-48 :: 
Recommendations by the Air Quality Management Work Group 

2.13 Conformity: Conformity should be retained as part of the nation’s AQM system. 

Background/Explanation: The NRC found that “although individual vehicle emissions have 

been reduced substantially over the past 30 years, those improvements have been offset at least 

partially by continued increases in vehicle miles traveled (VMT)” (Air Quality Management in 

the United States, p. 139). The technology-based emissions standards under Title II of the Clean 

Air Act limit pollution levels from each vehicle but not the total pollution from in-use motor 

vehicles. Conformity is the key Clean Air Act program designed to manage cumulative 

emissions. Transportation conformity requires that the overall air pollution levels from motor 

vehicles on highway segments and in a metropolitan area, including emissions due to planned 

transportation projects, will be consistent with emissions levels necessary to assure the timely 

attainment and maintenance of the health-based national ambient air quality standards. 

The NRC found that the transportation conformity program has “fostered greater interaction” 

between transportation planning and air quality regulatory agencies (p. 141). As a result, these 

agencies have gained “more knowledge about and a greater appreciation for one another’s 

missions, responsibilities and procedures”; furthermore, “most transportation officials also seem 

to accept the legitimacy and high priority of environmental values in transportation decisionmaking” (141). 

The NRC also determined that “the conformity requirement has had the largest impact on 

NAAQS nonattainment areas experiencing rapid growth” (141). A pivotal prospective question, 

in the NRC’s judgment, is how “the conflicts between transportation and air quality goals in such 

areas will be resolved and whether the federal government will remain firm in enforcing the 

regulation” (142). 

Recommended Actions: 

1) Transportation conformity must be retained. 

2) Conformity’s current key requirements and schedules must be retained and effectively 

enforced as an important measure to help achieve and maintain compliance with the 

national ambient air quality standards. The current planning timetable requiring 

transportation plans to have a 20-year horizon is consonant with the long-term planning 

and investment in new highway projects as well as central Clean Air Act timetables for 

nonattainment and maintenance plans. To ensure durability and integrity in the air quality 

planning and management process, EPA must continue to require conformity to 

attainment emissions budgets after the year of attainment has passed. The requirement to 

revise transportation conformity analyses every three years is necessary to ensure 

conformity is based on current data and is consistent with EPA’s recently adopted State 

requirement for triennial emissions inventory reporting. 

3) Future administrative action should consider: (1) protection of sensitive populations from 

localized, elevated particle pollution concentrations due to vehicle emissions near 

highways, interchanges, terminals, and schools; and (2) expansion of emissions budgets 

under the general conformity program to limit emissions from other significant 

transportation sectors including, for example, marine ports, rails, airports and freight. 

Feasibility: Maintaining the current requirements and schedules is highly feasible. It is uncertain 

whether legislation supported by the administration, that would shorten the period of time 

covered by conformity determinations, will be adopted. 

:: B-49 
Recommendations by the Air Quality Management Work Group 

Timing: No program disruption will occur if the current requirements and schedules are 

maintained. If legislation to shorten the time period covered by conformity becomes law, it would 

take effect immediately. 

Resources: Maintaining the current requirements and schedules requires no additional resources. 

Legislation shortening the time period covered by conformity determinations would not require 

any significant resources and might reduce the conformity-related burden in some areas. 

However, long-term air quality impacts of on road emissions will no longer be evaluated. EPA 

headquarters would be required to revise the conformity regulation to account for this. 

Priority Level: Low 

(Note: Priority is low because there is an effective program in place. At this time, areas are not 

having significant problems demonstrating conformity for the final year of their transportation 

plan. This is most likely due to emission reductions attributable to the Tier 2 and heavy-duty 

diesel rules.) 

B-50 :: 
Recommendations by the Air Quality Management Work Group 

3.1 Align SIP Submittal Dates: Because ozone, PM2.5, and regional haze SIPs have 

similar elements and are likely to contain similar control strategies, EPA, the States / Locals / 

Tribes, and other stakeholders should strive to align the submittal dates of the three SIPs. This 

recommendation is not intended to suggest changes to any deadlines for attainment or 

implementation of control strategies, or to imply that a single SIP should be required for ozone, 

PM2.5, and regional haze. It is further recommended that, in the future, EPA should align 

designation dates, as appropriate, to promote multipollutant SIP development. 

Background/Explanation: Finding a way to combine all of these SIPs would provide immense 

efficiencies for the States, regional planning organizations, the public and EPA. The deadlines are 

close enough in time that a way should be found for States to be able to develop the three SIPs 

together. 

For many States there is likely to be overlap between the technical basis for, and the ultimate 

development of, control strategies necessary to address the 8-hour ozone, PM2.5 and regional haze 

SIPs. For example, regional NOx reductions from the same source categories will likely be a 

necessary element for all three plans. The resources saved from a holistic analysis and the 

development of a single strategy as opposed to incremental adjustments within a few months time 

has the potential of being significant. Similarly, whether the State develops a single SIP or 

separate SIPs, the logistical resources associated with the processing of SIPs and the public 

participation process has the potential to be reduced if multiple hearings, analyses and responses 

to comments are not necessary due to the disparate deadlines. 

Recommended Actions: Because PM2.5, ozone and regional haze share some of the same 

precursors and because the timelines are similar, EPA, the States / Locals / Tribes, and other 

stakeholders should strive to align the submittal dates of these three SIPs. However, recognizing 

that it is difficult for States to accelerate adoption of the PM2.5 and regional haze SIPs to coincide 

with the schedule for 8-hour ozone SIPs, EPA should identify incentives (modeling assistance, 

other technical assistance, resources, detailing of personnel, etc.) it could provide States in order 

to assist them in accelerating the States' preparation of regional haze and PM2.5 SIPs. 

Feasibility: The time frames for regional haze and PM2.5 are aligned; however, the time frames 

for ozone and PM2.5 are offset by 6 to 8 months. Aligning all three SIPs or developing a 

multipollutant SIP will require an acceleration of planning for PM2.5 and regional haze. 

There are also technical issues with multipollutant modeling (discussed below). However, 

traditional modeling could still be used to develop a multipolluant SIP. States’ unfamiliarity with 

multipollutant modeling is a challenge for accelerating schedules. CAMx and CMAQ are 

photochemical grid models that are being used to assess 8-hour ozone, PM2.5 and regional haze. 

These models are currently being used by States and EPA for various purposes but experience is 

still limited. In addition, the modeling episodes for different pollutants will be different as ozone 

is a summertime problem and PM is a year-round problem. This may reduce the resource savings 

that can be obtained by developing these SIPs together. 

Timing: For this option to be meaningful for the next round of SIPs, States would need 

guidance/ability to develop such SIPs in the immediate future as SIPs will be due in the 2007 

(ozone) to 2008 (PM2.5/regional haze) time frame. Even if developed within a year, guidance may 

not be timely enough for States to use, particularly those that have long rule making time frames. 

Resources: Whether States develop these SIPs together or separately, States and EPA will need 

to develop the resources to implement these SIPs. Implementation of a multipollutant approach 

:: B-51 
Recommendations by the Air Quality Management Work Group 

may require increased resource commitment in the beginning in order to achieve resources 

savings in the long term. 

Priority Level: High 

B-52 :: 
Recommendations by the Air Quality Management Work Group 

3.2 Protocol for SIP Development: Each State should work with the appropriate EPA 

Regional Office to develop and implement a protocol for SIP development and processing that 

would lay out responsibilities, expectations, and timelines for all parties. While a model protocol 

should be developed, the EPA Regional Office and each State should have the flexibility to design 

a protocol tailored to their specific needs.

Background/Explanation: The lack of effective and consistent communication between States 

and EPA historically has been an impediment to development and processing of SIPs. EPA does 

not always provide assistance to State, Local and Tribal agencies early enough in their planning 

processes to address issues such as inventories, modeling, quantification of reductions from 

particular control strategies, and regulation review. Likewise States and Local agencies do not 

consistently provide EPA with draft versions of SIPs to review and comment upon prior to the 

formal public comment period and hearing. This lack of coordination has resulted in difficulties 

in meeting Clean Air Act deadlines for submittal of required SIPs. 

Many States will face the difficult challenge of having to develop three major SIPs, for ozone, 

PM2.5 and regional haze, within the next three years. There will be many issues requiring EPA 

input and approval which must be accomplished in a methodical way. Consequently, some States 

and Regions may wish to take advantage of this protocol concept to ensure the timely 

development, submittal and approval of these SIPs. 

Recommended Actions: To avoid delays in the SIP approval process and to limit the insertion of 

new demands by EPA late in the process (after public hearings and legislative action are well 

underway at the State level): 

1) EPA should develop a model protocol that, if desired, could be used by its Regional 

Offices in negotiating specific protocols with their States. 

2) EPA Regional Offices and their States should jointly foster the development of a protocol 

outlining the SIP process. This protocol should: 

a) Include enough flexibility to address all types of SIP submittals, though more 

complex control strategy SIPs may need an expanded version of the basic protocol to 

include emission inventory development, model selection, etc. For example: 

attainment demonstrations, and rate of progress (ROP) plans for PM2.5, ozone and 

regional haze. 

b) Lay out responsibilities and expectations of all parties as they move through the 

entire process. 

c) Include input from not only the State and the EPA Regional Office, but also the 

Office of Air and Radiation and the EPA Offices of Regional and General Counsel as 

appropriate. 

d) Be signed by the Regional Administrator and the State Secretary (may be delegated 

to the EPA Regional Air Division Director and State Air Director). 

e) Identify the role of any Regional Planning Organizations (RPOs) or MultiJurisdictional Organizations (MJOs) in process. 

f) Incorporate regular mechanisms for communication (e.g., monthly State-EPA calls); 

expected turnaround for EPA review of State materials (e.g., interim approval steps); 

and more streamlined processes for simpler SIPs. 

:: B-53 
Recommendations by the Air Quality Management Work Group 

g) Include accountability mechanisms such as a computer-based system which tracks 

the scheduled dates and actual dates of completion of each step of the protocol to 

ensure that EPA and the States follow the agreements. An analysis of both State and 

EPA performance should be conducted annually and any corrective actions 

identified. 

h) Identify the role of any MJO or RPO in process. 

i) Recognize that under EPA’s formal Delegation Manual, SIP approvals have been 

delegated to the RAs. 

j) Include a process whereby a State consults with Tribal governments potentially 

affected by the SIP. 

k) Include a process whereby a Tribe, especially one in a nonattainment area, may work 

with the State in developing a SIP for that area. 

Feasibility: This recommendation is certainly legally feasible to implement because it may be 

completed under existing statutory authority and only requires that a State and Regional Office 

develop and sign a protocol. 

Issues/Obstacles may include: 

The model protocol may suggest timelines; however, each State and Region must have 

the flexibility to negotiate the timelines in a specific protocol recognizing such issues as 

the differences from State to State in the length of their adoption processes. Realistic 

timelines will aid in long-term accountability. 

•

•

•

Some EPA Regional Offices have multiple SIPs being developed in as many as six to 

eight States simultaneously. Therefore, any model protocol will recognize that work load 

and be realistically tailored to fit the needs of a given State and Region. 

Not all States and Regions feel that such a protocol is a high priority dependent upon the 

current State/Regional relationship and whether or not a significant SIP backlog exists in 

the Regional Office. 

Timing: It is anticipated that this recommendation can be implemented in 6-9 months for the 

protocol itself to be developed. To be most useful, should be completed within that time frame. 

Additional time will be needed for signature agreements and to establish a tracking mechanism or 

to modify each Region’s current tracking system to reflect the timelines of the protocol. 

Resources: Redirection of existing effort and personnel. No significant additional resources are 

anticipated to implement this recommendation because the protocol is non-regulatory and does 

not have to go through a formal public process. The cost associated with this recommendation is 

the time of the EPA Regional and State personnel charged with the development of the protocol. 

It is strongly recommended that personnel with experience in both SIP development and 

SIP processing undertake the development of the protocol. 

Priority Level: High 

B-54 :: 
Recommendations by the Air Quality Management Work Group 

3.3 Clearinghouse of Approved SIPs: EPA should develop a website, similar to the Best 

Available Control Technology (BACT)/Lowest Achievable Emission Rate (LAER) clearinghouse, 

containing interpretations of rules and other SIP/TIP approval-related issues. This website could 

contain both policy and/or technical information depending on how it is developed. Each EPA 

Regional Office should develop a website, to be updated every 12 months on or about October 1, 

that identifies and provides links to all statutory and regulatory requirements in the federally 

approved SIP, including associated State and federal legal citations and effective dates. 

Background/Explanation: Questions regarding general SIP/TIP approvability arise with some 

frequency. Many times these questions have been already been raised and answered. Because 

there is no central repository for this information, the process for finding answers, or even 

creating an entirely new process to arrive at the same or different answers, can be very time and 

resource consuming. 

An October 1st update for the Regional Office website is important because the term "updated 

annually" could result in updates occurring, for example, on January 1, 2005, and December 31, 

2006, which meet the "annual test" but would be in actuality a 2-year span. 

Recommended Actions: EPA should develop this clearinghouse. This would probably be on the 

Technology Transfer Network portion of EPA’s website but could be developed by a Region or 

Regions and/or OAQPS. It is important that information is easily accessed on the website or it 

will have defeated its original intent.

Additionally, each EPA regional office should develop a website containing all of the statutory 

and regulatory content of the applicable SIPs over which it has jurisdiction. For each statutory 

and regulatory requirement in the applicable SIP, this website should contain at least the 

following information: (a) a citation of (including title) and link to every State statute and 

regulation that is included in the applicable SIP; (b) the State effective date; (c) the federal 

publication date; (d) the federal effective date; and (e) the applicable federal register citation. 

Each of the above websites should be updated no less frequently than by October 1 of each year. 

Benefits: A centralized and publicly available database of SIP approval issues, responses to 

comments, and other types of decisions would assist EPA staff, States and the public to 

understand what issues have arisen previously and how they were decided. This would improve 

efficiency and consistency of Federal, State, Tribal and Local agencies. 

Feasibility: Feasibility is high. This would not require any legal, statutory or regulatory changes. 

Possible hurdles include lack of resources. 

Timing: Timing on this project is not critical as there are no deadlines that would render this 

project obsolete. It could, however, be helpful in developing the upcoming ozone, PM2.5 and 

regional haze SIPs if it was done sooner. 

Resources: There may be direct monetary costs associated with this project if contractors are 

used. Otherwise it will require personnel hours which would be spent finding information, 

designing this website, actually building the website, filling in the database, etc. 

Priority Level: Medium 

:: B-55 
Recommendations by the Air Quality Management Work Group 

3.4 Streamline Minor SIP Revisions: For the SIP approval/disapproval phase of the air 

quality management process, EPA should establish a de minimis level for SIP revisions and 

streamline the processing of these revisions by the use of “letter approvals” or similar expedited 

procedures signed by the Regional Administrator. EPA should, in consultation with S/L/T and 

other stakeholders, develop a listing of the types of SIP actions that are eligible for streamlined 

processing.

Background/Explanation: There are certain SIP revisions submitted by States which revise only 

administrative State requirements, apply to a very narrow and often specified group of sources in 

a small geographic area, and/ or have quantifiable emissions changes (increases or reductions) 

which have minimal (i.e., de minimis) impact on overall emissions levels or PSD increment 

consumption in a given geographic area (especially designated attainment areas). Yet, such 

official State submittals must still undergo the full administrative process that is required of all 

Federal rulemaking actions. A survey of SIP revisions that are currently undergoing review in the 

Regional offices is likely to reveal that a significant number (perhaps 25% to 35%) of all formal 

SIP submittals consist of State provisions which would result in a de minimis impact. Because of 

the sheer volume of these revisions, the processing by EPA is often slow, and becomes a source 

of frictions between States and the Regional Offices. This process includes a separate review by 

the Office of Management and Budget (OMB) of all final rulemaking actions where EPA 

announces full disapproval of a SIP revision request. 

Recommended Actions: 

1) EPA, with input from States and Tribes (both program offices and attorneys) should 

institute a process for developing guidance which defines what could be considered de 

minimis with respect to SIP revisions, both in terms of subject matter and emissions limit. 

Regulatory change which could increase emissions on a nonattainment area or an OTClike area or which would result in consumption of a PSD increment might not be 

candidates for the de minimis process. However, some source-specific emission limit 

changes might be considered de minimis. Also, recodification actions which involve no 

substantive revisions to a State’s regulatory text could be considered de minimis, as might 

be revisions where State incorporates by reference an existing Federal requirement. 

2) EPA should revisit and update the January 30, 1989 policy memo on letter notices, and 

see whether such actions could still be used for the processing of de minimis actions. 

Also, if a SIP revision is processed through a letter notice, then we need clear guidance 

from OGC as to what the effective SIP date would be. 

3) As an alternative, EPA could “bundle” in one rulemaking action (direct final, whenever 

possible) a series of separate formal SIP submittals which meet the de minimis criteria. 

4) EPA should work with the Office of Management and Budget (OMB) to explain the 

concept of de minimis actions and request an exemption to the OMB review process in 

the event of a full disapproval of a de minimis SIP action. 

5) EPA should apply, as often as possible, the de minimis review process to other low-key 

Federal plan actions such as Section 111(d)/129 plan revisions. 

6) EPA should work with States to ensure that certain State administrative provisions 

governing the State regulatory and enforcement process are not submitted as SIP 

revisions, not even under a streamlined de minimis process. Section 110 only requires 

that States have a public hearing process and an enforcement program. The State 

procedures, by which public hearings are announced, held and recorded or how search 

B-56 :: 
Recommendations by the Air Quality Management Work Group 

warrants are obtained and executed need not be in the SIP. The exemption of such State 

administrative provisions from SIP review would prevent the tying-up of EPA resources 

to process SIP revisions that have virtually no environmental impact. 

Feasibility: The feasibility of this process depends on certain legal decisions: 

1) Whether EPA, States, and Tribes can come to consensus as to what constitutes a de 

minimis revision. 

2) Whether the issuance of an approval letter notice can set the effective date of the SIP or 

other plan revision. If the attorneys determine that only a Federal Register notice action 

can set the effective date, then the use of letter notice procedures may not produce the 

desired outcome of expeditious SIP processing. However, if the attorneys come to a 

consensus that making SIP actions effective through the issuance of letter notices meets 

the requirements of the APA, and results in expedited Federal effective dates, then the 

use of Letter Notices for de minimis actions should be utilized to the fullest extent. 

3) Whether OMB is likely to grant an exemption for its review of a full disapproval action, 

if such action is taken for a revision that EPA has determined to be de minimis. 

4) Whether further streamlining of the Direct Final Rule process could be considered. 

Examples would be a 15-day comment period or an effective date of 45 days after 

publication of the Direct Final rule notices. 

5) How the RME Docket system, which enhances the public’s ability to review and 

comment on EPA decisions, would need to be modified to accommodate EPA decisions 

made through a letter notice or similar expedited processes. 

6) Whether EPA would have to develop and publish a blanket rulemaking action to explain 

to the public how the rulemaking process of di minimis actions would be handled. EPA 

followed this step to explain: 1) the use of the direct final rulemaking process; and 2) the 

rule process which allowed Regional Administrators to sign final rulemaking actions. 

Such a formal action on the process of handling de minimis actions may assure the 

legality of the use of the expedited process for individual de minimis actions. 

Timing: This recommendation could be implemented in 12 to 18 months since 1) processes and 

procedures need to be developed; and 2) EPA would have to prepare a Federal Register notice 

signed by the EPA Administrator, announcing to interested parties the streamlined rulemaking 

process for de minimis SIP [and other plan] actions. 

Resources: EPA could utilize the standing National SIP Processing Work Group, comprise of 

representatives from all 10 Regions, OAQPS and OGC. The Work Group also interacts with 

EPA’s Federal Register liaison as well as legal staff from the Office of the Federal Register. If so 

determined, the Work Group could work with a committee of State and Tribal representatives to 

help implement the process to define the scope of de minimis SIP [and other plan] actions and a 

process for providing expedited Federal Review. 

Priority Level: High 

:: B-57 
Recommendations by the Air Quality Management Work Group 

3.5 Timely EPA Guidance: EPA guidance should be issued in sufficient time for States to 

meet their SIP development deadlines. EPA should involve S/L/T and other appropriate parties in 

its guidance development process. In cases where guidance is delayed, EPA should take into 

consideration States’ efforts to meet deadlines without the benefit of the appropriate policy 

guidance.

Background/Explanation: States cannot develop SIPs without guidance. Frequently, States are 

placed in the position of having to prepare SIPs under a specific deadline, but are dependent on 

EPA to develop guidance for the SIP. Delay by EPA in preparing guidance can cause: 1) States to 

be rushed in meeting their deadlines; 2) States to miss deadlines for submittal; and 3) States to 

develop SIPs which may later have to be revised in order to be accepted. This can lead to 

criticism of EPA due to lack of timely performance and blame of EPA for failure to make timely 

SIP submittals. Missing deadlines can cause States embarrassment and criticism from the public, 

at a minimum, and can cause sanctions, at worst. EPA is also criticized for not involving 

stakeholders (States/Tribes and others) in development of guidance. Not involving stakeholders 

usually results in guidance that is difficult to implement, requires excessive resources by the 

States and invites litigation by the excluded stakeholders. This paper focuses on SIP actions; 

however, if there are non-SIP actions where EPA guidance is critical and timing is of the essence 

in order to avoid an adverse reaction, such as sanction clocks, then the product of this effort 

should be implemented in those situations as well. 

Recommended Actions: 

1) EPA should institute a process for developing guidance which: 

a) Recognizes the timeline the States are under to implement the SIP involved. 

b) Establishes a priority and plan which will ensure that the guidance is published in 

time for State’s use to meet deadlines. 

c) Includes stakeholders in developing the guidance, guidance review and setting the 

priority for guidance. The Clean Air Act Advisory Committee (CAAAC) could serve 

this role, as could STAPPA. The chosen organization should also evaluate a 

restatement by EPA of what the agency is doing now and determining if 

modifications to our stakeholder process are necessary. 

d) Ensures that adequate EPA resources are applied to the guidance. 

e) Delegates decisions within EPA to facilitate more timely guidance. 

2) This process should be accomplished as a pilot. The pilot should explore what 

regulation/guidance development within EPA is felt by States and stakeholders to be 

working well. In the short term, the best aspects of process(es) determined to be working 

well should be identified and instituted into this process for developing guidance. 

3) EPA responds best when under a deadline. This is especially true for actions under court 

deadlines or consent decree deadlines. In order to set deadlines, EPA should indicate in 

the final Federal Register notice if any guidance is still needed after a rule is finalized. 

The Federal Register should identify the target date for completion of such guidance. 

Feasibility: The recommendation is feasible in that it only requires the establishment of a process 

to ensure the timely development of guidance. One obstacle to accomplishing this may include 

established organizational bureaucracies which have review and concurrence authority and do not 

have responsibility for meeting deadlines in guidance development. In other words, there should 

B-58 :: 
Recommendations by the Air Quality Management Work Group 

be as much urgency in developing guidance as there is in developing rules. Another obstacle may 

be lack of staff resources necessary to develop the guidance in the necessary time frame. Staff are 

often working on multiple projects at any given time and cannot always devote the time needed to 

develop the guidance and follow it through the review and concurrence process. 

Timing: This recommendation should be implemented in six months. Since it would not be tied 

to any one specific SIP schedule, it is difficult to specify a due date, other than as quickly as 

possible. 

Resources: Resources should be a small project team made up of staff with experience in 

guidance document preparation, and process and procedures development. Guidance is 

nonregulatory and will not have to go through a formal public process; therefore, no resources 

required for public process. 

Priority Level: High 

:: B-59 
Recommendations by the Air Quality Management Work Group 

3.6 Avoid Unnecessary Public Hearings: EPA should work with States and Tribes to 

develop a model regulation that would require a public hearing for SIP revisions only if one is 

requested after public notice. This recommendation is not intended to restrict public comment in 

any way; it is meant only to eliminate those hearings that no one attends.

Background/Explanation: The CAA has long been interpreted to require a public hearing be 

held by States for all SIPs and SIP revisions prior to their submittal to EPA. Holding public 

hearings is resource-intensive in terms of time and expense to the State. The use of State 

resources is justifiable when interested parties testify at the hearing. However, those resources are 

wasted in many instances where no comments or testimony are offered at the public hearing. 

Section 110(a)(2) of the CAA requires that States hold a public hearing for any prospective SIP 

revision. This requirement is repeated in regulations at 40 CFR 51.102. However, 40 CFR 

51.102(g)(2) provides that “Procedures different from this part may be approved if they (i) ensure 

public participation in matters for which hearings are required; and (ii) provide adequate public 

notification of the opportunity to participate.” Minimal case law exists to judge what EPA might 

be able to approve as a de minimis deviation from holding a public hearing for every prospective 

SIP revision. It is certainly possible, however, that revisions that do not involve rule revisions, de 

minimis rule revisions that involve no changes to what the regulated community is required to do, 

most maintenance plan revisions, and many source-specific revisions may be defensible 

candidates for EPA approval based upon a process whereby the State offers the public the 

opportunity to request a hearing but holds such hearing only upon request. 

Recommended Actions: A workgroup comprised of members of EPA’s Office of General 

Counsel, EPA Regional Counsels and States Attorneys General, and Tribal attorneys13 should 

undertake a review of the CAA to determine whether a holding a public hearing only upon 

request could satisfy section 110(a) for SIPs/SIP revisions. The workgroup should address the 

following questions: 

•

•

•

 

Is a statutory change to the CAA is required? 

If not appropriate for all SIPs, can a subset of SIP revisions be identified where a holding 

a public hearing only upon request would be sufficient to satisfy the CAA? 

Are there Tribal laws or considerations that would impact the issue differently for TIPs? 

If no statutory changes to the CAA are required, the workgroup should develop a model 

regulation for States adopt for SIP approval that provides the circumstances and procedures for 

holding SIP revision hearings only upon request to satisfy section 110(a). If statutory changes to 

the CAA are required, the workgroup should identify what provisions of section 110(a) must be 

revised and recommend language for such changes. This recommendation is not intended to 

address issues of who has standing to request a public hearing; the recommendation assumes that 

if anyone requests a hearing, then a hearing will be held. 

Feasibility: Some subset of SIP revisions may be able to be identified for which the State could 

provide the opportunity for a public hearing and hold one only upon request to satisfy section 

13 EPA and an interested State should pursue a pilot project to explore specific procedures to use for specified types of 

prospective SIP revisions and to explore the legal issues of instituting and implementing such procedures. The State 

of Minnesota has commenced this process with EPA Region 5. They should participate in and advise the 

recommended workgroup of their efforts. 

B-60 :: 
Recommendations by the Air Quality Management Work Group 

110(a). To make the opportunity for hearing only upon request sufficient for all SIP revisions 

may require a statutory change to section 110(a). 

Timing: The legal workgroup could be convened by EPA, ECOs/STAPPA/ALAPCO, NTC and 

charged with completing the recommended actions by a given date. The Recommended Actions 

should be implemented as soon as possible and completed well before the next round of SIPs 

revisions are required for 8-hour ozone, PM2.5 and regional haze. 

Resources: The cost to EPA/States/Tribes would the time of their attorneys. 

Priority Level: High

:: B-61 
Recommendations by the Air Quality Management Work Group 

3.7 Facilitate Redesignation Process for Certain Areas: For those areas that have 

not pursued and been granted redesignation when initially eligible, and have continued to 

demonstrate violation-free ambient air quality data for several years, EPA should expedite the 

redesignation process. EPA should ensure that all Regions and States are aware of the simplified 

procedures. This recommendation is not intended to change the requirements for redesignation 

under the CAA.

Background/Explanation: States should not be required to meet needlessly complex and 

resource-intensive requirements to redesignate nonattainment areas that have five or more years 

of violation free ambient air quality data that has been quality assured/quality controlled and 

entered into the national Air Quality Systems database. This is particularly true of areas with slow 

or no projected growth in emissions over a ten-year maintenance period. 

Recommended Actions: All EPA Regional Offices should disseminate and provide any needed 

assistance on the implementation of both the May 10, 1995 Clean Data Policy (CDP) and the 

“Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas, commonly referred 

to as the Limited Maintenance Plan Policy (LMPP). The CDP allows the Part D SIP requirements 

of an approved attainment demonstration, rate of progress (ROP) plan and their associated 

contingency measures to be waived in areas with three or more years of violation free data. 

Similarly, the Limited Maintenance Plan Policy (LMPP) can exempt an area from modeled 

maintenance demonstration. These policies change and simplify the technical requirements for 

redesignation, not the legal requirements. 

Feasibility: This recommendation is feasible. It has already been implemented on a limited basis 

by EPA Regions 3 and 4 during the processing of several state redesignation requests (and 

associated maintenance plans) for ozone and PM10. The use of the CDP and LMPP has not yet 

faced a legal challenge but, properly implemented, both policies are considered defensible by 

EPA's Office of General Counsel. 

Currently, there are issues restricting the use of the CDP and LMPP for SO2 and CO 

nonattainment areas. These issues are addressed in the September 4, 1992 memorandum entitled, 

“Procedures for Processing Requests to Redesignate Areas to Attainment.” 

Many States choose not to redesignate because there are no regulatory drivers encouraging 

redesignation; plus States may find advantages to retaining nonattainment status. 

Timing: Can be implemented immediately. 

Resources: The only resources necessary would be those in educating the EPA Regions, 

State/Local/Tribal entities that are unfamiliar with these policies. 

Priority Level: Low 

B-62 :: 
Recommendations by the Air Quality Management Work Group 

3.8 Effective Communication with Constituencies: EPA, along with S/L/T should 

develop a menu of options for effective communication to build support with a wide variety of 

constituencies for clean air plans at the S/L/T level.

Background/Explanation: The NRC report concluded that the SIP process is overly 

bureaucratic, drawing attention and resources away from the relevant issues of tracking progress 

and assessing performance. Both State officials and the regulated community complain that the 

planning process is cumbersome, lengthy and difficult for the public to comprehend, which 

encumbers the goal of developing and adopting air quality control plans, and attaining and 

maintaining national ambient air standards. 

Recommended Actions: Elements of these plans are frequently the subject of public lawsuits. 

Yet successfully engaging the public early in the SIP development process builds general 

understanding and support. Although some States and local air agencies achieve this through their 

current outreach programs, some do not. These discussions are timely as States prepare to 

develop SIPs for new federal ambient air quality standards for 8-hour ozone and PM2.5. 

A more aggressive marketing approach can help educate the public about the need to clean up 

local air pollution; getting the public involved in the SIP process is much more difficult. Often air 

agencies only hear from those members of the public who have 1) time and resources to send 

representatives to meetings; or 2) financial interests at stake, which make the expenditure of time 

and resources worthwhile. Even the environmental community often cannot participate fully due 

to limited staff and financial resources. 

Influencing community opinion leaders is a tested means of shaping public opinion, particularly 

in the short-term. However, all too often State and federal agencies do not use these techniques 

because of staff and resource limitations or department policies which constrain outreach. 

Although transmitting a message to the people who help shape public opinion is critical, merely 

sending press releases or letters of invitation to a community meeting is not effective. States and 

local air agencies must engage them directly. 

Building support for newer pollutant programs requires public education about the direct health 

risks associated with ozone and PM Fine. Effective outreach is most often achieved at the local 

level, where communities can relate to specifics and risks that may effect them and motivate 

behavioral change. Some methods to collaborate with States and engage the public locally could 

include the following actions: 

Target key opinion leaders. States and local air offices should initiate or expand the use 

of editorial board meetings to reach key media opinion leaders. 

•

•

•

•

•

•

States and locals should develop relationships with local reporters covering the issue. 

All States and locals should be sure that the Air Quality Index is forecast and reported in 

weather reports in their communities. 

States and locals should meet with local leaders in the Chambers of Commerce in their 

areas. 

States and locals should make presentations to key civic groups in the community. 

States and locals should meet with leaders in the religious community and work with 

them to reach out to their membership. 

:: B-63 
Recommendations by the Air Quality Management Work Group 

States and locals should meet with leaders in neighborhood associations and work with 

them to reach out to their membership. 

•

•

•

•

•

•

•

•

•

States and locals should meet with local and State environmental and public health 

groups to enlist their involvement in the process and their partnership in outreach efforts. 

States and locals should meet with key elected officials early and often in the process to 

keep them and their key staff informed. 

EPA should host focus group meetings to identify messages that build support for these 

issues. 

EPA should develop outreach materials targeted to diverse communities that explain the 

SIP process and the health effects of air pollution. 

EPA should offer training on efficient web content development for local government 

sites, incorporating AIR NOW real-time ozone and PM projections. 

STAPPA/ALAPCO and EPA should identify and catalog existing resources and develop 

additional appropriate tools based on targeted audiences. 

EPA should schedule State public meetings/workshops during SIP/rule development. 

STAPPA/ALAPCO and EPA should identify additional financial and staff resources to 

help agencies develop, produce and disseminate appropriate tools that reach targeted 

audiences, with the goal of garnering public support for the SIP process. 

Feasibility: It is likely that these recommendations will be implemented if expertise between 

federal, State and local agencies are shared. The STAPPA/ALAPCO Public Education and 

Communications Committee may be an appropriate group to coordinate this effort. EPA’s role 

can include development and dissemination of outreach materials that are nationally applicable, 

as well as improving how information may be made available on its website. 

Timing: As SIP development progresses, public involvement should be actively encouraged 

throughout the process. 

Resources: Redirection of existing effort and personnel; additional resources should be 

considered as outreach planning intensifies. 

Priority Level: Medium 

B-64 :: 
Recommendations by the Air Quality Management Work Group 

3.9 Co-Benefits of Innovative Measures: EPA and S/L/T should work collectively to 

communicate the co-benefits associated with innovative measures. 

Background/Explanation: The public is concerned with basic goals, such as improving public 

health and increasing economic and environmental benefits. When considering pollution control 

alternatives, broader support of a measure can be realized by determining and articulating the 

range of co-benefits provided by the measure. Overemphasis on receiving SIP credit for new and 

innovative types of pollution control initiatives limits public understanding and support for such 

initiatives. 

Recommended Actions: In evaluating an innovative measure, or bundle of measures: 

EPA and States should communicate how proposed strategies and innovations would 

improve quality of life more generally. 

•

Feasibility: This recommendation has a high feasibility for implementation because in August 

2004, the EPA committed to continue to bring stakeholders from federal, State, local, and tribal 

agencies, the public, and the regulated community together for an annual Air Innovations 

Conference. The conference will highlight the benefits of new and innovative air quality projects 

going on around the United States and encourage dialogue among stakeholders. 

Timing: It is anticipated that this recommendation can be implemented in 6-9 months as EPA has 

already committed to hold an annual Air Innovations Conference for the purpose of improving 

the dialogue among stakeholders. 

Resources: Only minor redirection of existing efforts and personnel would be required. 

Priority Level: High

:: B-65 
Recommendations by the Air Quality Management Work Group 

3.10 Innovative and Voluntary Measures: EPA should encourage States’ and Tribes’ 

efforts to implement innovative measures by providing enhanced flexibility, SIP/TIP credit 

guidance, technical support, and funding for innovative and voluntary programs.

Background/Explanation: As areas continue to experience challenges in meeting air quality 

standards many still have to adopt and implement additional measures to meet the SIP 

requirements for attainment, reasonable further progress (RFP), rate of progress (ROP) or 

maintenance requirements. Some areas have implemented most available traditional emission 

control strategies and want to try new types of pollutant reduction strategies to attain or maintain 

the NAAQS. The EPA needs to continue to develop policy and technical guidance for the purpose 

of providing States and Tribes with the flexibility to test and use new and innovative emission 

reduction strategies in their SIPs/TIPs. 

Recommended Actions: To continue to encourage, foster and support innovative and voluntary 

programs and measures in SIPs/TIPs, EPA should take the following actions: 

1) EPA should clarify and expand the channels through which States and Tribes may gain 

SIP/TIP credit for innovative measures by issuing additional enabling guidance and by 

balancing the level of effort required for approval (recordkeeping, reporting, etc.) with 

the level of environmental benefits anticipated. EPA has begun this process by issuing 

new policy and guidance covering: 

• SIP credit for voluntary and emerging measures 

•

•

SIP credit for energy efficiency and renewable energy initiatives 

SIP credit for reductions in truck and locomotive idling emissions 

2) EPA should create a clearinghouse for information on new technologies, innovative 

approaches, mentoring resources, and “off-the-shelf” measures, pilot projects, and 

quantification techniques. As an initial step, EPA is creating an interactive Innovations 

website to assist State/local/tribal governments in their efforts to implement innovative 

and voluntary programs. 

3) Building off successful pilot studies, EPA should develop sector-based guidance that 

would synthesize and clarify innovative technological approaches to reducing pollution in 

the key sectors. 

4) EPA should offer targeted funding to promote innovation. EPA has begun this process by 

providing funding for the following specific innovative projects: 1) Pollution Control 

Strategy Rapid Assessment & Optimization Tool (Response Surface Model) to provide 

state/local agencies accurate and economical tools for quickly determining the most costeffective local strategies for meeting air quality standards; 2) Residential Wood Smoke 

Reduction Initiative; 3) grants for State/Local Innovative Approaches to Reducing Air 

Pollution; and 4) grant(s) for stationary diesel retrofit project. 

Feasibility: This recommendation has a high feasibility for implementation because it can be 

completed under existing statutory authority and only requires that EPA continue to focus on 

providing responsive and timely guidance and technical support. 

Timing: It is anticipated that this recommendation can be implemented in 6-9 months as many of 

the action items are already under development or consideration by the EPA. 

B-66 :: 
Recommendations by the Air Quality Management Work Group 

Resources: Only minor redirection of existing efforts and personnel would be required as many 

of the action items are already under development or consideration by the EPA. 

Priority Level: High 

:: B-67 
Recommendations by the Air Quality Management Work Group 

3.11 SIP Credits for Bundled Innovative Measures: EPA should incentivize 

innovative pollution control strategies by offering SIP/TIP credit for “bundled and discounted” 

measures.

Background/Explanation: States and Tribes are often discouraged from adopting innovative 

measures because those measures are typically too small-scale to result in significant SIP/TIP 

credit. In addition, results of those measures may be hard to quantify or verify individually. In the 

aggregate, however, such measures can significantly impact air quality. Currently, EPA has 

increased the amount of SIP credit States can earn for stationary voluntary and emerging 

(innovative) measures to a presumptive 6 percent through its latest guidance document on 

Incorporating Emerging and Voluntary Measures in a SIP (September 2004).

Recommended Actions: EPA should encourage States to experiment with new and innovative 

approaches to air pollution. Specifically, EPA should: 

Grant States and Tribes SIP/TIP credit upfront for a “bundle” of small, innovative 

measures and evaluate the measures in the aggregate by looking at air quality 

improvements after implementation. An appropriate discount factor should be applied to 

the credit, considering the amount of credit claimed and the level of uncertainty 

associated with quantifying the actual air quality benefits of the bundled measures. 

•

Feasibility: This recommendation has a high feasibility for implementation because of EPA’s 

recent policy on “Incorporating Emerging and Voluntary Measures in a SIP” which enables a 

State to receive SIP credit for emission reduction or pollutant reduction measures which are more 

difficult to accurately quantify or enforce than traditional SIP emission reduction measures. 

However, any approval of “bundled” measures in a SIP will need to be conducted through full 

notice-and-comment rulemaking in the context of a particular state SIP revision. 

Timing: It is anticipated that this recommendation can be implemented in 6-9 months as the 

overall enabling policy framework is now in place in the form of EPA’s recently issued guidance 

on “Incorporating Emerging and Voluntary Measures in a SIP.” 

Resources: Only minor redirection of existing efforts and personnel would be required as a 

policy and guidance framework is already in place. 

Priority Level: High 

B-68 :: 
Recommendations by the Air Quality Management Work Group 

3.12 Regional Approaches to SIP Planning: For many areas, planning for new SIPs or 

major revisions to existing SIPs for two or more separate nonattainment areas that are both part 

of the same regional scale air quality problem should be coordinated. If requested by a State, 

EPA should work with the different nonattainment areas, Tribes and combinations of multistate 

organizations and other stakeholders, as appropriate, to assist in the development of regional 

approaches to planning. This could include technical assistance such as modeling, national or 

regional control strategies, model SIPs, and model rules as templates for S/L/T adoption.

Background/Explanation: The interstate transport of criteria pollutants and criteria pollutant 

precursors make State-by-State planning both impractical and ineffective. Moreover, even the 

appearance that neighboring States are developing SIPs regulating the same industrial sectors for 

the same pollutant(s) with differing levels of stringency quickly brings delays to the SIP/TIP 

development and adoption processes. The nature of many areas’ 8-hour ozone and PM2.5

problems increasingly call for the development and implementation of regional control strategies. 

Recommended Actions: 

1) Groups of States/Locals should redefine the role of existing Regional Planning 

Organizations (RPOs) and Multi-Jurisdictional Organizations (MJOs) to include 

supporting planning for all regional air pollution problems (e.g., 8-hour ozone, PM2.5, 

regional haze). 

2) These organizations should amend their charters and by-laws as necessary for clarity of 

purpose and eligibility for additional grants. 

3) These organizations should continue their established stakeholder involvement 

procedures in the development of model rules and model SIPs. 

4) EPA personnel from multiple Regional Offices and OAR should review and comment 

upon model rules and model SIPs with an eye to their eventual adoption by 

State/Locals/Tribes such that any potential approval concerns are addressed up front. 

5) In addition to model rules, RPOs/MJOs should develop standardized Technical 

Support/Analysis Documents for SIPs/TIPs being adopted by their member States/Tribes. 

6) RPOs/MJOs should develop procedures for inter-RPO/MJO coordination to ensure 

consistency, as needed, in their air quality planning processes and comparability in their 

work products. 

7) EPA should pursue discussions with OMB to ensure the flexibility of the use of grant 

funds allocated to RPOs/MJOs so they address multiple ambient air pollution problems as 

“one atmosphere” under a single grant such that the most scientifically valid and cost 

effective approaches can be studied and implemented. 

8) The technical activities of RPOs/MJOs should be closely coordinated with the technical 

support activities and R&D programs of EPA. 

Pilot Studies: Examine the benefits of the STAPPA/ALAPCO, OTC and WRAP model rules 

along with other model rules and SIPs developed by NESCAUM, LADCO, SESARM, VISTAs, 

CENSARA, CENWRAP, MARAMA, MANE-VU. 

Feasibility: No statutory changes are necessary. Ease of feasibility is dependent upon the 

State/Local/Tribal desire to redefine/expand the role of RPOs/MJOs and to get charters and bylaws amended, as necessary. 

:: B-69 
Recommendations by the Air Quality Management Work Group 

Large neighboring groups of States/Locals/Tribes are already using RPOs to develop model SIPs 

and rules for regional haze. The successful efforts of the Western Regional Air Partnership 

(WRAP) for the regional haze SIPs under section 309 in the West and the Ozone Transport 

Commission for ozone SIPs in the Northeast are evident. 

Timing: Should be implemented within one year to be effective for 8-hour ozone and PM2.5. EPA 

needs to work with OMB in the next budget cycle to pursue flexibility in the use of federal grants 

to RPOs/MJOs to work on multipollutant approaches to solving ambient air pollution problems. 

Resources: The MJOs/ RPOs are already established. While negotiations and coordination 

between States/Locals/Tribes, Federal Land Managers and multiple EPA Regional Offices may 

initially take longer than each State only having to develop its own SIP internally, once 

procedures are established and schedules set, the time savings will be significant. The cost 

savings, particularly in the areas of emission factor and emission inventory development and 

modeling will be substantial. The regulated and environmental community and interested citizens 

would save resources by participating in the RPO/MJO stakeholder processes rather than having 

to spread themselves over each State’s SIP development process. 

Priority Level: High 

B-70 :: 
Recommendations by the Air Quality Management Work Group 

3.13 Federal and State Partnerships: EPA should participate with S/L/T in the SIP/TIP 

development process to identify and pursue emissions reductions from important source 

categories, especially those that only the federal government has the ability to address, such as 

federal and international sources. The level of control sought from these sources should be 

commensurate with their impact in the nonattainment area. As warranted by the nature of the 

source, control strategy development should be carried out by S/L/T working either directly with 

EPA or with EPA and other federal agencies. For attainment demonstration purposes, States 

should be able to take appropriate credit for anticipated reductions from these sources (whether 

the reductions from regulatory or incentive programs) so long as the control strategy and its 

anticipated impact are found to be consistent with EPA regulation and guidance.

Background: States are generally unable to regulate emissions from sources under federal or 

international jurisdiction, and have limited ability to regulate other on-road and non-road sources. 

Such sources can be major contributors to the air quality problem in many nonattainment areas. 

Under the Clean Air Act, EPA is given authority to regulate new mobile sources and their fuels 

and is able to assist State and local agencies and Tribes in regulating existing mobile sources and 

in achieving the desired control from federal sources either through direct EPA regulation or by 

working with other federal agencies. Similarly, EPA has the ability to work with other parts of the 

federal government in seeking the control of international sources. Such emission controls can, as 

appropriate, take the form of the direct regulation of emitting sources, incentive programs to 

reduce emissions, international agreements and other forms. Under existing EPA guidelines all of 

these forms of emission reduction can be credited in SIPs. 

Recommended Actions: 

1) EPA should participate with State and local agencies and Tribes in the process of 

identifying and pursuing measures to achieve the emission reductions from national and 

international sources needed to attain the 8-hour ozone and PM2.5 standards by the 

attainment dates in each nonattainment area. 

2) Early in the SIP development process, EPA should consult with State and local agencies 

on preliminary emission targets for each federal sector, help develop options to achieve 

those reductions, and aid in providing estimated benefits for State use in draft SIPs for 

public review. 

3) EPA should expedite the approval of new technologies such as retrofits and alternative 

fuel formulations that can be applied to existing fleets within a nonattainment area. 

4) When assessing controls, EPA should consider cost-effective technologies proven to 

control similar sources not under direct federal authority. 

5) In those cases where States have limited ability to control a category of sources, where 

such sources are a key part of the problem and where national programs are not feasible, 

EPA, working with State and local agencies and Tribes, should develop targeted 

strategies for affected nonattainment areas, including multistate or regional strategies. 

6) For federal sources that EPA does not have the authority to control directly, EPA should 

work with other federal agencies (such as the Federal Aviation Administration) to secure 

significant near-term and long-term reductions. 

7) EPA should negotiate with international standards-setting entities on actions to achieve 

the reductions necessary to meet the attainment targets for these sectors (i.e., the 

International Civil Aviation Organization (ICAO) and the International Maritime 

Organization (IMO)). 

:: B-71 
Recommendations by the Air Quality Management Work Group 

8) EPA should pursue international agreements with neighboring countries to address 

international emissions outside States’ jurisdiction. 

Benefits: Identifying and pursuing the necessary emission reductions from national and 

international sources will help ensure that the public health benefits of national air quality 

standards are achieved and that States do not suffer the economically from sanctions due to 

failure to comply with SIP requirements. 

Feasibility: This recommendation calls on EPA to more directly address the attainment needs of 

each area by becoming a fuller partner early in the planning process. Implementing some 

potential strategies would require actions or funding by other federal agencies or Congress, 

international organizations, and other countries. 

Timing: Because States are already in the development process for 8-hour ozone and PM2.5 SIPs, 

this activity needs to be initiated immediately. 

Resources: EPA could use existing resources. EPA staff is already familiar with federal 

emissions sectors that could provide additional emission reductions. Additionally, States have 

established incentive programs that could serve as models for federal incentive programs. 

Priority Level: High 

B-72 :: 
Recommendations by the Air Quality Management Work Group 

3.14 Weight-of-Evidence Demonstrations: In order to move beyond the current 

approach of relying on air quality modeling, EPA, in conjunction with S/L/T and affected 

stakeholders, should modify its guidance to promote weight-of-evidence (WOE) demonstrations 

for both planning and implementation efforts. In particular, these demonstrations should reduce 

reliance on modeling data as the centerpiece for SIP/TIP planning, and should increase use of 

monitoring data and analyses of monitoring data, especially for tracking progress.

Background/Explanation: The current system is top-heavy on modeling for planning purposes 

(especially, the preparation of an attainment demonstration) and light on tracking progress. The 

NRC recommended that “a more useful approach would be to retain the attainment demonstration 

as a planning tool but to place greater emphasis on follow-up measures to track compliance and 

progress and on actions to be taken if compliance and progress are not satisfactory.” This 

recommendation will focus on defining a more effective use of technical tools for a performanceoriented air quality management approach, and recognizes that S/L/T need to accomplish this 

work with available resources. Enhanced tracking and ambient monitoring (to track progress) is a 

better use of resources than intensive local modeling. 

Recommended Actions: To move beyond the current approach of relying on air quality 

modeling, the Work Group recommends the following actions 

1) Planning efforts should incorporate a weight-of-evidence (WOE) approach to provide the 

most technically defensible basis for a control plan and to satisfy any statutory 

requirement for a demonstration of attainment. A WOE approach is especially important 

when the modeling shows that the area is projected to be either just above or just below 

the ambient standard. (It should be noted that the WOE demonstration, including the 

modeling, must be subject to public review as part of the SIP process.) The WOE 

approach should include the following three elements: 

a) A prospective modeling analysis, performed in accordance with an EPA-approved 

modeling protocol. Modeling should be used to identify the appropriate control path. 

Unfortunately, over-reliance on modeling can produce unnecessary debates over 

technical details, which can hinder efforts in getting emission reductions and 

cleaning-up the air. EPA should work with S/L/T and affected stakeholders to modify 

its guidance to clarify the proper use of modeling and WOE for SIP planning. 

b) Analyses of air quality data, including preparation of a conceptual/qualitative 

description of the area's nonattainment problem, examination of historical air quality 

and emissions trends, assessment of (incoming and outgoing) transport (e.g., 

trajectory analyses), and use of observation-based methods (e.g., receptor models, 

and indicator species and ratios). 

c) Summaries of current actual and expected future year emissions by species (primary 

and secondary), by year (base year, attainment years, and appropriate interim years), 

and by source sector. Assumptions used in projecting emissions growth must be well 

documented. 

2) Implementation efforts (i.e., periodic progress assessments) should consider similar WOE 

elements, including: 

a) A retrospective modeling analysis (as necessary) to assess progress in meeting air 

quality standards and visibility goals. 

b) Analyses of air quality data, including examination of recent (meteorologically 

adjusted) air quality trends and emissions trends. 

:: B-73 
Recommendations by the Air Quality Management Work Group 

c) Summaries of actual emissions by species (primary and secondary species), by year 

(base year, attainment years, and appropriate interim years), and by source sector. 

Assumptions used in projecting emissions growth must be well documented. 

3) To assist S/L/T with these planning and implementation efforts, EPA should issue WOE 

guidance, which clarifies the proper role of modeling for SIP planning, establishes 

standard WOE procedures (e.g., when WOE considerations are appropriate, how to 

ensure that use of WOE is a symmetric process, and how to determine what additional 

evidence should be considered and how it should be used), and identifies appropriate data 

analysis methods (e.g., methods for estimating statistically significant trends which 

account for meteorological effects). 

Benefits: Better use of modeling and monitoring data can provide a sounder basis for control 

strategy development, and allow better tracking of compliance and progress. 

Feasibility: All the technical tools are available for performing the necessary modeling and data 

analysis activities, including work being performed by the RPOs and MJOs. The bigger issues are 

likely to be the availability of sufficient air quality measurements, and the staffing/resources 

needed to conduct these analyses. The EPA guidance should address the tools/methods, as well 

as the data requirements and personnel needs. 

Timing: Given the potentially large scope of this recommendation, it is important to break the 

analyses into pieces and assess the time required to complete each of them. A workshop with all 

interested parties should be held to develop further this recommendation. Once there is a general 

framework of what is to be done and the data needed to support that framework, the guidance for 

addressing the other activities can be prepared. 

Resources: To conduct such extensive analyses, a wide variety of experts will be required (e.g., 

statisticians, meteorologists, air quality data analysts, emissions inventory experts). In addition, 

someone with the ability to put the analyses into concise wording will be needed to communicate 

the findings. Up to 4-5 FTEs that have the skills outlined above, as well as contract funds (e.g., 

$50K for workshop and follow-up actions) is estimated to develop appropriate guidance. 

Resources for training for S/L/T personnel are also needed. 

Priority Level: High 

B-74 :: 
Recommendations by the Air Quality Management Work Group 

3.15 Periodic Assessments to Track Progress: S/L/T and EPA should conduct periodic 

assessments to ensure that areas are on track to meet NAAQS, air toxics, and visibility goals, and 

make mid-course adjustments, as necessary. 

Background/Explanation: One of the long-term objectives identified by the NRC is to guide 

future improvement of the air quality management system is to take a performance-oriented 

approach. This approach would emphasize “performance rather than the process” and would 

“create accountability for achieving results.” The NRC recommended that “a more useful 

approach would be to retain the attainment demonstration as a planning tool but to place greater 

emphasis on follow-up measures to track compliance and progress and on actions to be taken if 

compliance and progress are not satisfactory.” This recommendation will focus on tracking 

progress and what to do if areas are not on track to meet NAAQS, HAP, and visibility goals. The 

previous recommendation (3.14) addressed the definition of a more effective use of technical 

tools for a performance-oriented air quality management approach. 

Recommended Actions: To begin to lay the foundation for a performance-oriented approach, the 

Work Group recommends the following actions: 

1) States and EPA should work together on tracking progress, including a review of changes 

in actual emissions and air quality concentration, as described in Recommendation 3.14. 

In particular, a comprehensive progress report should be prepared, which compares actual 

progress with expected emissions and air quality trends for each metric (see 

Recommendation 1.5). Further discussion is needed to determine the appropriate 

frequency for this report. 

2) If actual progress differs “substantially” from the expected trend for a given metric, then 

States should reexamine effectiveness of that attainment measure. If attainment will be 

later than the statutory attainment date, then the State should determine whether it is 

necessary to modify the SIP. Note, this determination should consider the influence of 

weather conditions (e.g., very hot/cold, or very wet/dry conditions). 

3) EPA should report annually on health and ecosystem impacts (i.e., indicators and 

benchmarks established pursuant to Recommendation 1.5). Also, EPA should report 

annually on major control programs that they are coordinating (e.g., Title IV and NOx 

SIP Call). 

Benefits: On-going progress assessments will ensure that the correct and most cost effective 

control strategies are in use. Joint State-EPA efforts should allow more effective use of available 

resources and eliminate any redundancy in current efforts. Such comprehensive analyses can also 

highlight limitations in existing data systems which would facilitate appropriate data quality 

improvements (emissions, modeling, and monitoring). 

Feasibility: This activity is a logical extension of EPA’s annual Trends Report, and State RFP 

and air quality assessments. Additional EPA and State staffing may be needed to ensure proper 

interagency coordination. Refinements to existing tools will be needed (such as improved 

adjustments for meteorology) some of which are already in development by EPA. 

Timing: Initial products could be expected within 1-2 years. A fully integrated State-EPA 

analysis and report system may take several years. 

:: B-75 
Recommendations by the Air Quality Management Work Group 

Resources: EPA should bear the primary responsibility. Approximately 2-3 new FTE’s and 

$300K per year may be needed. 

Priority Level: High 

B-76 :: 
Recommendations by the Air Quality Management Work Group 

3.16 Averaging, Banking and Trading in Gasoline Sulfur Program: EPA should 

evaluate the averaging, banking, and trading (ABT) provisions included in the Tier II gasoline 

sulfur regulation to see if they are effective. 

Background: Averaging, banking, and trading (ABT) provisions have been widely used in EPA 

regulatory programs to provide flexibility to industry while aggressively attacking environmental 

problems. The effectiveness of these provisions for fuels programs should be evaluated, since 

ABT concepts are being built into new regulatory programs. 

Recommended Actions: EPA should evaluate the ABT provisions in the gasoline sulfur program 

as the program rolls out over the next few years. The evaluation should be phased to include 

annual analysis of available information and a complete report when the program has been fully 

implemented and patterns of credit usage are well-established. Below is a list of topics that would 

be covered by the evaluation: 

Credit accumulation: Did the credit generation opportunity result in substantially lower 

sulfur levels in 2002 and 2003? What volume of credits were generated and how much 

flexibility did this make possible to refineries? How was credit generation distributed 

across the industry? 

•

•

•

•

•

•

Allotment accumulation: Did facilities and companies take advantage of the allotment 

generation opportunity in 2003–2005? What volume of allotments was created, and how 

much flexibility is thus available to refining companies? 

Trading and markets: (Separately for credits and allotments) How much trading took 

place relative to the total volume of credits/allotments? How efficiently did the 

credit/allotment markets function? Were credits and allotments readily available for 

purchase by challenged facilities and companies? How much trading of credits was intercompany (as opposed to trading between facilities within the same company)? How did 

the price of credits/allotments vary over the course of the program? How was the trading 

system perceived by refiners? 

Role of allotments in compliance with Corporate Average Standard (CAS): To what 

extent did active trading of allotments contribute to companies’ ability to comply (use of 

purchased versus self-generated allotments)? How did CAS compliance strategies vary 

across the industry (uniform reductions across facilities versus planned unevenness in 

facility reductions)? How many allotments were retired? 

Role of credits in compliance with Refinery Annual Average Standard (RAAS): To what 

extent did facilities use credits to come into compliance with the RAAS? What 

proportion of the credits used in compliance were purchased rather than self-generated? 

How many credits were retired? 

Reporting system’s accuracy: Does accuracy of reporting indicate industry understanding 

of ABT program? Do most reports of credit/allotment trades match up without EPA 

intervention or troubleshooting? Do refiners perceive the ABT system as logical and 

workable in practice? 

EPA should consider conducting a similar analysis for ABT when it implements the diesel sulfur 

program. 

Feasibility: This recommendation is generally very feasible. Existing EPA staff can perform 

these analyses and write the final report. Possible obstacles include difficulties in enlisting 

:: B-77 
Recommendations by the Air Quality Management Work Group 

cooperation from industry sources, and the need to work around confidentiality concerns with 

both reporting data and information obtained from confidential conversations. 

Timing: Some aspects of the evaluation can be addressed in annual analyses beginning in mid-tolate 2005. The more complete report on this effort cannot be developed until late 2007 at the 

earliest, the first time data on a fully-implemented program will be available. 

Resources: This evaluation will require less than one FTE for each report. Some contractor time 

will be required to program certain analyses. 

Priority Level: Low 

B-78 :: 
Recommendations by the Air Quality Management Work Group 

4.1 SIPs to Address Multipollutant Impacts: For the SIPs States are required to 

submit over the next several years, EPA and S/L/T should promote the consideration of 

multipollutant impacts, including the impacts of air toxics, and where there is discretion, select 

regulatory approaches that maximize benefits from controlling key air toxics, as well as ozone, 

PM2.5 and regional haze.

Background: The SIP process provides an opportunity for many urban areas to include key 

HAPs in a comprehensive multipollutant approach to air quality management, consistent with the 

NRC recommendations. The NRC recommends (on p. 298 of Air Quality Management in the 

United States) that: 

EPA, States and local agencies should identify key HAPs that have diverse sources or 

substantial public health impacts or both, which would merit their inclusion in an integrated 

multipollutant control strategy (for example, benzene). 

Activities have been taken at the State/Local/Tribal and federal level to reduce emissions from 

key HAPs. It is important to clarify that this NRC recommendation should not be interpreted as 

deferring federal responsibilities (e.g., mobile source air toxics program, 112(k) area source 

program, etc) to State and local agencies. Rather, this recommendation means that the air quality 

management process being undertaken for SIPs/TIPs provides an opportunity to see how 

State/Local/Tribal and federal efforts are working to reduce key HAPs, to identify what actions 

could be taken at the State and local level to supplement current efforts, and to help identify 

priorities for federal actions. 

Recommended Actions: EPA, in consultation with states and stakeholders, should develop a 

“short list” of critical HAPs that pose the highest risk to human health in urban areas. Likely 

compounds for consideration on the short list would include: 

benzene and acrolein: these are national risk drivers in EPA’s 1999 national air toxics 

assessment (NATA). 

•

diesel PM: although not a “HAP” listed specifically in the Clean Air Act, the workgroup 

recommends it for consideration on the short list. 

•

The following additional steps should be taken to finalize the short list: 

1) EPA and States/Locals/Tribes should identify additional HAPs which are likely due to 

ubiquitous sources for inclusion into the list of “key HAP”. For example, the following 

were identified in the 1999 NATA as contributing to more than 90% of the cancer risks in 

531 proposed or final nonattainment counties: 

• Ethylene dibromide 

•

•

•

•

•

•

Butadiene 

Acetaldehyde 

Bis 2 ethylhexyl pthalate (DEHP) 

1,1,2,2, tetrachloroethane 

Chromium VI 

PAHs 

:: B-79 
Recommendations by the Air Quality Management Work Group 

• Napthalene 

•

•

Tetrachlorethylene 

Ethylene dichloride 

2) EPA and States/Locals/Tribes should review HAP monitoring results to identify any 

high-risk pollutants which may be underpredicted by the NATA. 

3) States/Locals/Tribes should include on the list any additional HAPs which are high risk 

in their area. 

For the “short list,” EPA should encourage States and Tribes, in developing their SIPs/TIPs for 

PM2.5, regional haze and ozone, to evaluate opportunities for achieving co-benefits through 

simultaneous reduction of these key “urban risk driver” HAPs. 

EPA, working with one State and a short list of HAPs, should develop and test a model integrated 

SIP as a pilot project before expanding to other States/Tribes. Possibly good candidates for such a 

pilot, areas which are both ozone and PM nonattainment, and which are part of the national air 

toxics trends sites (NATTS) network include: Detroit, St. Louis, Atlanta, and Chicago. 

Feasibility: Including a short list of HAPs in modeling and control strategy analyses for 

SIPs/TIPs should not add substantially to the resource burden. Results for the HAP “short list” 

could readily be derived from existing ozone or PM modeling. Control strategy analysis would be 

somewhat more complex, but would benefit from a more thorough evaluation of multi-pollutant 

interactions. 

Timing: In order to extend this approach to the additional areas that will be submitting PM and 

/or ozone SIPs, the pilot effort would need to be complete by the end of calendar year 2005. 

Resources: For EPA, this effort could be completed with redirection of existing personnel 

without a substantial additional financial commitment. For States, this might add perhaps 10-20% 

to the cost of the SIP analytical effort. 

Priority Level: High 

B-80 :: 
Recommendations by the Air Quality Management Work Group 

4.2 Multipollutant Benefits and Disbenefits in Standards Setting: EPA should 

explicitly outline and quantify multipollutant benefits and disbenefits when setting emissions 

standards.

Background: The current statutory, regulatory, and policy framework does not explicitly provide 

an integrated approach for the consideration of criteria and air toxics. An opportunity exists in the 

ongoing air toxic standards-setting processes (e.g., remaining MACT standards, residual risk, and 

area source standards) to explicitly consider multi-pollutant effects of proposed control strategies 

in selecting options. 

Recommended Actions: 

EPA, in conducting engineering reviews to support emissions standards efforts, should 

assess how identified options for Hazardous Air Pollutants (otherwise known as HAPs or 

air toxics) reduce and/or increase direct PM2.5 emissions, and emissions of PM and ozone 

precursors such as VOC, NOx and SO2. 

•

• Engineering reviews for HAP standards should catalog available control options that 

would reduce direct PM, SO2, VOC and NOx emissions even if those options would not 

reduce air toxics. 

Feasibility: The recommendation to quantify the benefits and disbenefits has a high feasibility 

for implementation, although the degree to which they can be considered is not clear under 

existing statutory authority. Section 112 (d)(2) of the Clean Air Act explicitly states that emission 

standards for HAP should consider non-air quality health and environmental impacts, but it 

doesn’t appear to preclude consideration of other air quality impacts. Regardless of a change in 

statutory requirements, quantifying criteria pollutant benefits will result in better decision-making 

and will boost overall acceptance of future MACT requirements. 

Timing: It is anticipated that this recommendation to quantify the multi-pollutant benefits and 

disbenefits can be implemented immediately in ongoing development of remaining MACT 

standards, MACT residual risk 112(d)(6) standards, and 112 (k) area source standards. 

Resources: This effort will require some additional analyses in the MACT development process, 

but we would not expect substantial additional financial commitments. 

Priority Level: High 

:: B-81 
Recommendations by the Air Quality Management Work Group 

4.3 Greenhouse Gas Emissions: EPA should assist States and localities in quantifying the 

potential increases or decreases in greenhouse gas (GHG) emissions from reduction measures 

primarily designed to address ozone, fine particles, regional haze, and air toxics.

Background/Explanation: A number of States and localities have adopted policies to assess 

and/or reduce GHG emissions from certain source categories under their jurisdiction. A number 

of these source categories emit criteria and toxic air pollutants. To assist those States and 

localities wishing to consider multiple emissions implications of alternative strategies, EPA 

should help determine how pollution control alternatives that are being examined to address 

ozone, fine particles, regional haze, and air toxics might either increase or decrease emissions of 

GHG emissions. States would then have the option to consider multiple emissions impacts in 

assessing a list of proposed alternative measures. Tools for evaluating impacts are available, 

including STAPPA and ALAPCO’s Clean Air and Climate Protection Software (CACPS). 

Recommended Actions: In evaluating emissions control measures, EPA should assist States and 

localities in the quantification of potential increases and decreases in GHG emissions. 

Feasibility: Quantifying the impacts of control strategies on GHG emissions is feasible; a 

number of existing tools (i.e., CACPS) already do this. If “co-benefits” were to mean modeling 

of the impacts of such increases and decreases on climate change, this would be far less feasible. 

Timing: Implement over the next few years. 

Resources: Implementation would require a relatively small increase in resources for EPA to 

support the existing toolkit (CACPS) that STAPPA/ALAPCO already has developed. State/local 

resources would be affected only for States/localities choosing to use this information. 

Priority Level: High 

B-82 :: 
Recommendations by the Air Quality Management Work Group 

5.1 Program Review to Improve Ecosystem Protection: EPA should, in parallel 

with recommended scientific and technical work, begin now to examine current and alternative 

clean air related policies and programs to develop approaches that would advance protection of 

ecosystems from the adverse effects of air pollution. Alternatives that should be evaluated include 

a regional cap-and-trade program, protection of ecosystems based on critical loads, and a Statewide planning program for protecting and enhancing air quality in areas that attain the NAAQS 

(including National Parks and Wilderness Areas).

Background/Explanation: The NRC stated that the system of air quality management in the 

United States does not go far enough in protecting ecosystems and other aspects of public welfare 

from the impacts of air pollution. The NRC noted specific policy-related deficiencies in 

secondary standards, tracking of ecosystem outcomes from air quality changes, and accounting 

for ecosystem effects in cost-benefit analyses. 

Recommended Actions: To advance and support future policy decisions, it is important to 

implement the recommendations of the science and technology subgroup regarding developing 

innovative benchmarks and measures to assess ecological impacts of air pollution and improving 

ways to track and evaluate progress in reducing those impacts. The examination of potential 

policy alternatives does not, however, need to be delayed while these advances are being 

developed. We have substantial information on direct and indirect effects of some air pollutants 

on the environment amassed in criteria documents, and assessments such as that of the National 

Acid Precipitation Assessment program. This information can assist in framing policy questions 

and approaches in an exploration of how current and future information might be used to increase 

environmental protection. This effort should be interactive with those groups who are working on 

the scientific and technical recommendations. 

Specifically, EPA should, in conjunction with other interested parties, begin with an assessment 

of the relative effectiveness of major clean air programs under the CAA in terms of their potential 

to provide additional ecosystem protection. 

Recognizing that regulatory programs are in different stages of implementation and offer different 

options, EPA should consider the following in the review of each program: 

a) policy mandates, objectives, goals, definitions of ecosystem protection, historic/legal 

interpretation 

b) characteristics of air pollutant(s) regulated (e.g., toxics, criteria, mobile), may have 

different potential magnitudes of impact (e.g., different temporal/spatial scales) 

c) existing reporting measures of program/ecosystem protection progress (e.g., trends 

report, acid deposition goals under GPRA and PART, NAPAP Report to Congress, 

EPA’s Report on the Environment, water quality measures, inclusion in regulatory 

impact analyses etc.) 

d) whether existing tracking efforts need modifications to specifically support their use 

in different regulatory programs (i.e., networks needed to support secondary 

standards vs. other CAA mechanisms, national vs. critical ecosystem coverage, etc.) 

e) current and future opportunities or impediments to expand use of ecological science 

in the policy context, given additional ecological research, indicator/ model/monitor 

development, consistent longer-term measurements/monitoring. 

:: B-83 
Recommendations by the Air Quality Management Work Group 

f) what policy innovations/revisions would be required to better translate ecosystem 

science into effective ecosystem protection policies. 

The policy assessment of air pollution and ecosystem protection should also consider nonregulatory programs, including ongoing innovative approaches that examine multi-media 

approaches to integrating air pollution effects with other ecological concerns, as is done in the 

Sustainable Environment for Quality of Life (SEQL) project in Charlotte. 

Benefits: This recommendation will accelerate consideration of ecosystem protection in clean air 

programs as well as ensuring faster application of recommended enhancements to EPA’s 

scientific and technical assessment capabilities as they are developed 

Feasibility: This recommendation is highly feasible and the work can be completed under current 

Clean Air Act authority. The exercise could, however, identify impediments or desirable policy 

approaches that are not currently available. 

Timing: The recommended policy assessment of current programs could begin immediately. The 

potential for developing new policy approaches would depend on the results of the activity. If the 

scientific and technical recommendations are adopted, improved tracking could begin in the near 

future. Longer-term consideration would be needed to determine whether current and/or 

additional technical information/tools under development could be applied more formally under 

the Clean Air Act. 

Resources: Additional staff resources in the Office of Air and Radiation would be needed. 

Priority Level: High 

B-84 :: 
Recommendations by the Air Quality Management Work Group 

Appendix C: 

Summary of Unresolved Issues 

For Further Discussion 

:: C-1 

Recommendations by the Air Quality Management Work Group 

Appendix C: Unresolved Issues for Further Discussion 

Listed below, with brief descriptions, are several recommendations that the AQM Work Group 

considered but decided against advancing in final form at this time. There were various reasons 

why these recommendations were deferred for further discussion: some recommendations were 

added to the discussions late in the Work Group’s process; others are so complex that they require 

additional data and evaluation before they can be finalized; others are controversial and require 

further discussion among stakeholders. This list does not include every issue considered by the 

Work Group, but contains the issues that were considered most important to advance for further 

discussion. 

1) Emissions Inventories: EPA should improve the process for developing national, 

State, and local emissions inventories. 

Currently, States are required to prepare a comprehensive statewide inventory every three 

years, pursuant to EPA’s Consolidated Emissions Reporting Rule (CERR). EPA prepares 

its National Emissions Inventory (NEI) using these State inventories and other 

information. The timeliness and quality of these State and national inventories should be 

improved. For example, EPA should consult with States to determine which source 

categories can be inventoried more frequently (ideally, annually), such as EGUs, and 

EPA should work with a few States on a pilot project to develop more efficient ways to 

prepare the NEI (e.g., examination of top-down (national-level) and bottom-up (statelevel) approaches, and streamline the reporting of State data and EPA’s processing and 

compilation of these data). 

2) Monitoring Networks: EPA and States should work together to increase the number 

of air quality monitoring stations and improve their distribution.

To improve spatial coverage and comprehensiveness in existing State and federal 

monitoring networks, additional monitoring sites and additional measurements are 

desired. The first step in making improvements is to conduct spatial analyses of existing 

monitoring networks and identify “gaps” in coverage. Based on results of the spatial 

analyses, EPA Regional Offices and States should work together to establish appropriate 

monitoring sites. Possible enhancements include increased sampling in rural areas (to 

promote ecosystem goals) and reallocation of PAMS monitoring to ensure a Type II site 

in as many 8-hour ozone nonattainment areas as possible (to promote tracking progress). 

To ensure that monitoring networks are providing usable data, States should conduct a 

thorough assessment of their monitoring networks every five years. 

3) Short-Term Monitoring: States should consider conducting short-term monitoring 

programs.

To complement on-going monitoring efforts (especially, to address particular air quality 

problems and issues), special (short-term) field programs should be considered. Examples 

of such field programs include summertime ozone field programs (e.g., SCAQS, LMOS, 

and NARSTO-Northeast) and investigative studies (e.g., MRPO’s urban organics study). 

4) Evaluation of Models: EPA should support the evaluation of air quality models.

:: C-3 
Recommendations by the Air Quality Management Work Group 

To develop confidence in using models for regulatory purposes, it is important first to 

evaluate the models by comparing model estimates and ambient measurements. EPA 

should publish a report every three years on the state-of-the-science for ozone, fine 

particle, and haze modeling. The report should include any current model-evaluation 

studies, and assessments of special issues (e.g., model predictive capability of changes in 

air quality concentrations due to changes in emissions, predictive capability of models at 

very low concentrations, effect of model grid resolution on predicted concentrations, and 

suitability of using point measurements for comparison with modeled concentrations). On 

a larger scale, a measurement plan should be prepared for a regional (or sub-regional) 

field program in the eastern half of the U.S. to support ozone, fine particle, and haze 

models. Note, resources for a meaningful field study may approach a million dollars. 

Further discussion is needed to address the scope, cost, and funding options for such a 

major study. 

5) Evaluation of Control Measures: EPA should conduct retrospective evaluations of 

control measures.

The NRC recommendations note that programs to systematically collect information on 

what has worked (and how well or not so well) have been inconsistently funded and have 

been limited in ability to independently validate user’s estimates of compliance costs. 

Even though NRC’s emphasis above is only on costs (evaluated retrospectively), it seems 

equally important to evaluate technical experience/feasibility with various technologies. 

As such, it is recommended that EPA undertake written case studies in consultation with 

the affected industries of cost and technology experience of representative stationary 

source and mobile source categories (e.g., EGU NOx and SOx control, non-EGU NOx 

controls, motor vehicles fuels and emission standards, and mobile source retrofit 

programs). 

6) Communication of Technical Information to Policymakers: The scientific 

community, both within EPA and outside the agency, should work to improve the 

communication of technical information to policymakers. 

Technical analysts often generate complex, highly scientific information to address air 

quality problems. Communicating this information to policymakers and others who may 

not have the same technical background is a challenge. As such, it is necessary for 

technical analysts to be clear, objective, and relevant in presenting this information to 

policymakers, and for policymakers to be willing to receptive to technical information. 

7) Multipollutant Modeling: EPA should promote the use of multipollutant models.

EPA and States should use air quality models capable of addressing ozone, fine particles, 

regional haze, and air toxics (e.g., mercury) in the upcoming round of SIP development. 

Viable candidate multi-pollutant models include CMAQ (developed by EPA’s Office of 

Research and Development (ORD)), CAMx, and REMSAD. Although no endorsement of 

these models is offered, it should be noted that CMAQ and CAMx appear to reflect the 

most up-to-date science. As these models advance, the transition from research to 

application needs to be improved. For example, EPA’s ORD and Office of Air Quality 

Planning and Standards should make sure that CMAQ is usable (in-house) by 

RPOs/states for SIP modeling. 

C-4 :: 
Recommendations by the Air Quality Management Work Group 

8) Integration of Programs for Criteria Pollutants and Air Toxics: EPA should 

investigate technical considerations associated with the potential integration of programs 

to control criteria pollutants and air toxics.

The NRC, recognizing the long standing difference in the way criteria pollutants and 

toxic air pollutants are regulated under the Clean Air Act, while also recognizing that in 

the air they mix to form one atmosphere, recommended an evolution toward a common 

risk based approach to regulating emissions of air pollutants and providing clean air. 

Setting aside the policy and program issues, there are fundamental science hurdles that 

must be overcome to weigh the options and alternative approaches in moving toward 

such a “one-atmosphere” approach to providing clean air (e.g., dealing with large 

differences in the amount and quality of data on emissions, ambient levels, personal 

exposures and environmental deposition, health and ecosystem effects, thresholds, and 

risk factors for these many chemicals). What is needed initially is a first order relative 

risk assessment and gap analysis based on currently available information using existing 

practices. Ultimately gaps would be filled and protocols. 

9) Integrated Criteria/Toxics Controls at Individual Sources: Consistent with the 

goal of controlling more air pollutants in a holistic fashion, States/Locals/Tribes should 

be encouraged to address emissions from criteria pollutants and air toxics concurrently 

during permitting or regulatory actions at individual sources. 

The group believed that this recommendation had possible merit. However, the 

recommendation was drafted late in the process and the group did not have adequate time 

to consider it in detail.

10) SIP Consistency Process: EPA should better document its internal processes to ensure 

transparency in evaluating S/L/T or regional requests for a variance from published 

policies.

The Group believed that this was an important recommendation. However, there was a 

general lack of understanding outside of EPA as to how EPA’s internal process works to 

ensure consistency in decisions across the different Regions. EPA agreed that such 

policies need to be better documented and explained. However, there was insufficient 

time to do so, so the recommendation was deferred for further discussion. 

11) Electric Generating Units: The electricity generating unit (EGU) sector makes a 

large contribution to multiple air quality problems. Many believed that the active 

rulemaking underway on the Clear Air Interstate Rule (CAIR) provided the proper forum 

for considering what this sector ought to do for the next 15 years or more; others did not. 

Since no agreement could be reached on a recommendation regarding this sector, the 

Work Group recommends that discussions continue by the new CAAAC subcommittee. 

Regardless of the outcome of any future discussions, many of the stakeholders involved 

saw considerable value in State and Local agencies and utilities consulting with each 

other after final promulgation of the CAIR (or new legislation) to share compliance plans, 

evaluate likely emissions reductions and their geographic distribution, and apply that 

information to further planning activities.

:: C-5 

Recommendations by the Air Quality Management Work Group 

Appendix D: 

Letter Transmitting 

Final Report to EPA

:: D-1 

Recommendations by the Air Quality Management Work Group 

Appendix D: Letter Transmitting Final Report to EPA 

Honorable Michael O. Leavitt 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Ave N.W. 

Washington, DC 20460 

Dear Administrator Leavitt: 

On behalf of the Clean Air Act Advisory Committee (CAAAC), we are pleased to present to you 

a report and list of recommendations from the Committee for your consideration. CAAAC is a 

senior-level committee consisting of senior managers and experts representing state and local 

government, environmental and public interest groups, academic institutions, unions, trade 

associations, utilities, manufacturing industries and others. The Committee provides advice and 

counsel to EPA on a variety of important air quality issues. 

In 2004, the National Research Council (NRC) of the National Academies released a report 

entitled Air Quality Management in the United States. In this report, the NRC outlined the many 

substantial achievements of the U.S. air quality management system over the past 30 years. The 

NRC also identified areas where changes in the air quality management (AQM) system would 

provide further benefits to human health and the environment. The NRC advanced 

recommendations for change in the AQM system on a number of levels. Some of the NRC’s 

recommendations involve short-term changes of limited scope and immediate impact. Other 

NRC recommendations focus on more sweeping changes to the nation’s approach to AQM over 

the mid- to long-term. 

For the past six months a CAAAC Work Group has evaluated ways to improve the current air 

quality management system in this country. The recommendations of the NRC helped guide this 

Work Group. On December 16 the Work Group advised the CAAAC about the desirability and 

feasibility of implementing a number of near-term recommendations to improve the current 

system. The AQM Work Group included representatives from State and local organizations, 

Tribes, regional organizations, environmental and public health organizations, industry and EPA. 

This report outlines near term recommendations for improvements in air quality management in 

the United States and also proposes a continuing process for discussion of longer term changes. 

It focuses on translating the relatively broad NRC recommendations into specific and concrete 

steps that can be taken quickly by EPA and others to realize improvements in science, 

technology, policy, and planning that will lead to improved air quality and public health 

protection 

While the CAAAC reached consensus on forwarding the recommendations for further 

examination by EPA, individual members were also given an opportunity to submit additional 

comments on the recommendations. Comments submitted in writing by CAAAC members are 

included as an appendix of this report. CAAAC does recognize that there are potential resource 

implications associated with some of these recommendations for EPA and its partners in air 

:: D-3 
Recommendations by the Air Quality Management Work Group 

quality management. The CAAAC hopes that resources can be made available to implement 

these recommendations appropriately. 

On behalf of the Committee, we thank you for the opportunity to participate in EPA’s activities 

and hope our advice is useful in developing air quality management strategies. 

Sincerely, 

Janet McCabe, Co-Chair Gregory Green, Co-Chair 

Air Quality Management Work Group Air Quality Management Work Group 

Jeff Holmstead, Chair 

Clean Air Act Advisory Committee 

D-4 :: 
Recommendations by the Air Quality Management Work Group 

Appendix E: 

Commentaries from 

Clean Air Act Advisory Members

 

:: E-1 

Recommendations by the Air Quality Management Work Group 

Appendix E: Commentaries from Clean Air Act Advisory Members 

At a meeting of the Clean Air Act Advisory Committee on December 16, 2004, the Air Quality 

Management Work Group presented results of its efforts to assess the recommendations made by 

the NRC on air quality management in the United States. The Work Group presented 37 

recommendations for the CAAAC’s consideration. The CAAAC agreed to forward those 37 

recommendations and requested the Work Group to include the recommendation on green-house 

gases for future consideration by EPA. At the request of the CAAAC, the Work Group has 

modified the report to include the greenhouse gas recommendation (see Recommendation 4.3) 

and has added language to the report to emphasize the goal of public health and ecosystem 

protection. In addition, the CAAAC emphasized the need to label the Work Group’s initial effort 

and this report as “Phase 1” since there are remaining issues to be resolved and discussions 

needed on the longer-term vision and air quality management framework of the future. The 

CAAAC conferred and as a group agreed to deliver the final report to EPA for its consideration. 

Following the December 16, 2004 meeting, members of the CAAAC were asked to submit any 

comments in writing to the Work Group on the individual recommendations. Contained in this 

appendix are the comments received from seven organizations. Many of these comments are 

directed at future issues and will be discussed as part of Phase 2 follow-on efforts. 

Comments are included from the following: 

William W. Goldsmith, Cornell University 

Ralph Marquez, Texas Commission on Environmental Quality 

Steve Winkelmann and Ned Helm, Center for Clean Air Policy 

Kenneth Coburn, Northeast States for Coordinated Air Use Management 

Charles Collett, National Association of Home Builders 

Christopher Recchia, Ozone Transport Commission 

J. Stephen Hartsfield, National Tribal Air Association 

 

:: E-3 
Recommendations by the Air Quality Management Work Group 

December 17, 2004 

Dear Greg, Janet, Rob, et al: 

To begin, thanks again especially to Greg and Janet and members of the AQM sub-committee for 

the very high quality – if perhaps timid or incremental – report on AQM. Although I offered my 

suggestions at the CAAAC meetings Wednesday and Thursday, with general agreement from the 

committee, I will repeat them below in writing, as friendly amendments to the report. 

Respectfully, 

William W. Goldsmith 

1. The report needs to state prominently – in its Executive Summary (ES) and Introduction – that 

it proposes air quality management (AQM) improvements in pursuit of lower emissions and 

better air quality (AQ) for improved protection of human health and national and regional 

ecosystems.

The draft Executive Summary (ES) and Introduction that you presented to the CAAAC, do not

provide this emphasis. Instead, they emphasize “the dramatic improvements in AQ . . . since 

1970.” The wording of the ES and Intro might lead an uninitiated reader to conclude that AQ has 

been sufficiently improved already, so that to fix the its machinery EPA need only to tighten 

some screws, adjust some valves, and oil some joints – to make “improvements in efficiency and 

effectiveness of current programs,” as the ES says (p. vi). 

Presentations by the report’s authors and many spoken comments from CAAAC members were 

much more forthright about the remaining need for improvements in AQ, in spite of the dramatic 

improvements we’ve had since 1970. Reports on details of the sub-committee discussions, 

comments from CAAAC members, and responses from sub-committee and EPA leaders left no 

doubt – the objective of the report is to make management more efficient and effective so as to 

further reduce emissions and therefore further improve AQ, in pursuit of improved human health 

and ecosystem quality. 

As it stands in the draft, the ES emphasizes “transformation of the AQM system,” calls for EPA 

to “improve the US AQM system,” wants changes “to allow progress to continue in a more 

effective and efficient manner,” and calls for EPA to “streamline processes, improve resource 

allocation, and enhance scientific and technical capacity.” 

The Introduction, after documenting “dramatic declines in emissions and ... pollutants,” focuses 

again on efficiency and effectiveness,. The Intro does say AQ improvements can “be ... 

expanded,” and that “the AQM system could ... provide further benefits, but it imbeds these goal 

statements in discussion of management efficiency and effectiveness, rather than stating them as 

independent goals. 

2. The report should strengthen its comments on conformity.

E-4 :: 
Recommendations by the Air Quality Management Work Group 

The report should call for intensified effort to analyze relationships connecting human health and 

ecosystem quality with the metropolitan nexus of AQ, transportation, and land use. Problems in 

this area – now so frequently discussed in the public arena under such rubrics as sprawl and smart 

growth – are getting worse, not better. AQ damages are “transported” beyond the metro areas, to 

include, e.g., tribal areas. Conformity provisions are badly needed and must be retained, as the 

report says, but they have not yet worked adequately, so the report should call for them to be 

improved and strengthened. 

3. Changes are required in reporting three of the issues that have been placed in the so-called 

Bin Two (i.e., left to be considered for future recommendations from this or other subcommittees 

of the CAAAC).

a) Long-term principle #7 (p. 34) should be changed to read: Further incorporate land 

use and transportation planning in clean air planning efforts.

b) The discussion in Section 2.1.3 (p. 21 and Appendix p. 48) must include language 

indicating that transportation plans can achieve adequate AQ improvements only if

they are integrated adequately with improved land use plans. Thus, a fourth 

Recommended Action should be added (Appendix, 2.1.3, p. 48,) as follows: 

c) 4) EPA should work with COGs, MPOs, and other involved agencies of S/L/T 

governments to facilitate better AQ results through reduction of urban sprawl and 

consequent reductions in VMT and energy use. EPA should work with DOT, HUD, 

and other federal agencies to seek improved land use and transportation plans and 

enhanced coordination among highly interdependent jurisdictions. 

d) The listing of deferred “Issues” (Appendix C, p. 86 ff.) should be amended to include 

all the issues listed as “Core Principles” (Report, p. 34). 

The Report’s “Long-Term Core Principles” and Appendix C’s “Summary of Deferred Issues” 

leave the reader confused. The section on Long-Term Framework Options,” at the end of the 

Report, adds to this confusion. The general idea, made clear in the discussion, is that a number of 

items/issues were left for the future, either because they were added too late, are too complex, or 

are too controversial. The two lists should be made compatible. 

In particular, whether or not other changes are made, Core Principle #7 (on land use and 

transportation planning) needs also to be listed as a separate item in Appendix C.

:: E-5 
Recommendations by the Air Quality Management Work Group 

January 4, 2005 

Comments from: 

Ralph Marquez, Commissioner, 

Texas Commission on Environmental Quality 

The primary points Commissioner Marquez would like to reiterate are: 

1) The report’s recommendations mention in a number of places the need for increased 

regional approaches to addressing the air quality needs. However, the report does not 

adequately address the tension which currently exists between EPA’s desire for national 

consistency and the flexibility needed to adequately craft the necessary regional 

approaches. EPA needs to recognize this tension and take the appropriate steps to 

mitigate it. 

2) There are a couple of recommendations which refer to the need for EPA to issue timely 

guidance. However, the report does not adequately address the disincentives, associated 

with draft and evolving guidance, which currently preclude S/L/T’s from developing 

unique approaches to address their particular issues. EPA should stop the bureaucratic 

terrorism and not hold up innovative and unique approaches solely because they may not 

be consistent with future guidance. 

3) The report is very weak on the need for increased accountability associated with EPA’s 

role in the process. Specifically, there is too much focus on the need to evaluate 

additional controls on source categories which State’s currently have a significant amount 

of authority to regulate. EPA needs to focus those resources on what should or could be 

done to address those categories where State’s have little to no authority. For example, 

EPA should focus on getting new technologies approved and into the market, especially 

for mobile sources, in a timely enough manner that they will be available for this next 

round of SIPs. EPA should also consider stepping up and assuming a federal assignment 

up front in the planning process, for achieving reductions from these categories. 

There are over 37 recommendations included in the report, with a number of subrecommendations. If EPA were to attempt to implement them all, other important programs and 

initiatives could suffer. EPA needs to step back and conduct a holistic evaluation of all of its 

current efforts, and identify those activities which could be delayed or eliminated, to ensure 

adequate resources are available for the timely implementation of these initial recommendations.

E-6 :: 
Recommendations by the Air Quality Management Work Group 

To: Air Quality Management Work Group 

From: Steve Winkelman and Ned Helme 

 Center for Clean Air Policy 

Re: CCAP Comments on the AQM Work Group Final Report 

Date: January 6, 2005 

These comments are intended to respond to and expand upon three components of the AQM 

Work Group Final Report: 

• 2.13 Conformity 

•

•

3.9 Co-Benefits 

Long-Term Vision Core Principle #7, land use and transportation planning. 

The comments arise from the Clean Air and Smart Growth Forum organized by the Center for 

Clean Air Policy and the Local Government Commission in Sacramento, CA on December 1-2, 

2004. The forum brought together some 50 experts from a variety of disciplines and jurisdictions 

to provide recommendations on how to improve clean air programs, policies and processes in a 

way that will support both sustainable land use and emission reduction goals. 

Better integration of land use and transportation planning is critical to slowing growth in vehicle 

miles traveled (VMT) and is therefore an important element in developing conforming

transportation programs and plans. A key finding from the CCAP/LGC forum is that 

implementing integrated land use and transportation policies requires quantification 

communication of the broader co-benefits of smart growth polices (quality of life, congestion, 

infrastructure cost savings, etc.). 

Rapid growth in VMT poses perhaps the most serious challenge to reducing transportation sector 

emissions and achieving air quality goals. Land use patterns have a strong influence on the 

amount of driving based on the availability of transportation choices and distances between 

origins and destinations. More integrated land use and transportation policies such as smart 

growth, transit-oriented development, and infill development hold significant promise for 

reducing transportation emissions.14 

The forum recommendations were grouped into three categories: A. Clean Air Act, B. Modeling, 

and C. Implementation. Below we include highlights of those recommendations that are pertinent 

to the AQM Work Group report and have provided key recommendations in italics. 

 

14 See, for example: 

• Center for Clean Air Policy, Smart Growth and Air Quality Primer, December 2004. 

• Ewing, R., Pendall, R., and D. Chen. Measuring Sprawl And Its Impact Volume I. October 2002. 

• L. Frank, “Land Use Impacts on Travel Choice and Vehicle Emissions in the Central Puget Sound: 

Methodology and Findings,” Transportation Research - Part D., March 2000. 

• Holtzclaw, J., Clear, R., Dittmar, H., Goldstein, D, and P. Haas, “Location Efficiency: Neighborhood and 

Socioeconomic Characteristics Determine Auto Ownership and Use – Studies In Chicago, Los Angeles And 

San Francisco,” Transportation Planning and Technology, 2002, Vol. 25, pp. 1–27. 

:: E-7 
Recommendations by the Air Quality Management Work Group 

A. Clean Air Act 

1. Require Alternative Scenario Analyses for Transportation Improvement Plans (TIPs) 

and Long Range Transportation Plans (LRTPs) 

The TIP and LRTP planning process require alternatives analyses only for specific large projects 

but not for the full Program or Plan. At the local project scale the likelihood of detecting any 

discernible land-use impact is small − thus lower-cost, more efficient alternatives may be missed. 

A change that could fix this, and in turn strengthen the current conformity process, would be a 

requirement that MPOs include regional alternative transportation and land use scenarios in their 

TIP and LRTP updates. This could include, for example, increased transit service, infill and 

mixed-use development. If MPOs were required to generate such alternative scenarios at the 

regional scale, it would help officials consider various planning factors and opportunities to avoid 

or minimize various adverse impacts of project and plan investments. This would maximize the 

satisfaction of regional and federal objectives and make the benefits of comprehensive smart 

growth planning readily apparent. 

EPA (with FHWA/FTA) could prepare guidance on how to conduct alternative transportation and 

land use scenario analyses. This might require working with Congress on legislative changes. It 

would likely require financial support from the federal government so that it does not become an 

“un-funded mandate.” EPA could work with regions that have already done such analyses (e.g., 

Sacramento) as a starting point for piloting such an effort.

2. Ensure Emissions Baseline Integrity 

Baseline land use assumptions have a big impact on the level of travel demand and available 

travel choices. Too often, the assumptions are not subject to rigorous review in terms of quality or 

how realistic they are. While, alternative scenario analyses can help improve the quality of input 

assumptions, more is needed to ensure that assumptions are reasonable. In some cases, the 

conformity process is iterative in nature, where, for example modelers increase transit ridership or 

land use densities until conformity is met (in conjunction with other measures). While fine in 

principle, there appears to be little in the way of follow up to ensure that those assumptions are 

realistic and realized. If a plan conforms due, in part, to unrealistic assumptions then it will fail to 

achieve required emissions levels and will not sufficiently protect public health. We note that 

there is a higher level of scrutiny for individual control measures even if they may impact fewer 

tons than key baseline assumptions. 

Thus, we recommend increased scrutiny by federal officials to improve the quality and reliability 

of baseline assumptions, and enhanced tracking and enforcement to ensure that assumptions 

reflect reality. This is not intended to discourage progressive land use assumptions in 

transportation plans, but should be done in conjunction with incentives and opportunities to 

improve input data and to assist with implementation follow through. Land use development is a 

complex undertaking that involves many parties external to the planning and modeling processes. 

Therefore, it may be unfair and unrealistic to require literal fulfillment of baseline land use 

assumptions, but it does seem appropriate to require demonstration of progress toward policy 

goals embedded in baselines. For example, if the baseline assumes infill development, then local 

governments or regional bodies should be able to demonstrate new initiatives, funding or 

incentives to encourage infill development. 

EPA (and FHWA) should provide guidance on appropriate land use and transportation baseline 

assumptions as well as guidance on appropriate level of demonstration. They should explore 

E-8 :: 
Recommendations by the Air Quality Management Work Group 

potential incentives and efforts for improving input data and for assisting with implementation 

follow through. EPA should also develop parameters for demonstration of progress toward 

baseline goals, including guidance on appropriate contingency efforts if baseline assumptions fall 

short. 

3. Encourage Greater Use of Land Use Measures in SIPs 

In 2001, the US EPA issued guidance titled, Improving Air Quality through Land Use Activities, 

to assist states in formally obtaining SIP credit for sustainable land use policies including 

brownfields and infill development.15 Only two states (Maryland and Texas) have taken 

advantage of this guidance. Barriers to participation include modeling complexities, 

implementation uncertainties and low emission benefits for small-scale projects. 

EPA should consider developing less stringent standards for evaluating land use measures. EPA 

could consider increasing the 3% cap through voluntary guidance coupled with specific 

requirements for demonstrating implementation (e.g., region commits funding, zoning 

modifications passed). Another approach would be to develop a mechanism to allow land use 

projects as enforceable measures with no percent cap. In either case, it will be important to 

require a contingency plan, which could include innovative approaches such as including source 

shut-downs in a community bank. 

B. Modeling 

The quality of land use and transportation modeling is often poor due to MPO staff and resource 

limitations, and a lack of incentives to improve models. 

EPA, FHWA, and FTA should develop joint guidance on improving travel models with minimum 

acceptable practices, routine audits of modeling used for SIPs/TIPs/RTPs/NEPA to evaluate 

adequacy of inputs, outputs, sensitivity performance. 

EPA should pursue a pilot initiative for regions incorporating the following elements: 

•

•

•

•

•

 

Interagency cooperation 

Performance-based measures: air quality, public health, equity, energy conservation, 

quality of life 

Uses Best Practice measurement tools 

A transparent public process including regional/local visioning 

Auditing progress 

 

15 US EPA, Final Policy Guidance: Improving Air Quality through Land Use Activities. EPA420-R-01-001 

Transportation and Regional Programs Division, Office of Transportation and Air Quality January 2001 

U.S. EPA , January 2001. Please also see, 

. 

http://www.epa.gov/otaq/transp/conform/policy.htm#landuse

www.epa.gov/otaq/transp/landguid.htm

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C. Implementation 

It is critical to ensure that land use policies are actually implemented if we are to reap their air 

quality benefits. The forum identified a number of areas where EPA could help. 

1. Promote Education and Foster Leadership 

The multiple benefits of smart growth policies are insufficiently understood by many policy 

makers. There is need for more federal coordination to ensure that policies and funding decisions 

do not contribute to unsustainable land use patterns and increased transportation emissions. 

EPA should coordinate with other federal agencies (FHWA, FTA, HUD, Fish and Wildlife) at the 

federal and regional levels on promoting sustainable land use policies that benefit air quality, 

water quality and quality of life. At the federal level, agency heads, could recommend a 

Presidential Executive Order, that recommends funding priorities to improve the natural and 

community environment. At the regional level EPA could help identify a champion in each 

region (e.g., regional EPA and FHWA offices, elected officials, business leaders) to lead 

comprehensive smart growth efforts. 

EPA should work with governors and mayors to foster leadership on dealing with land use, 

transportation and air quality in an integrated way. This could include expansion of existing 

efforts, and high-level briefings with elected officials and key staff. It will be important to 

emphasize health and financial benefits of smart growth policies. 

EPA, FHWA and FTA should fund indicator development to help promote and track the multiple 

benefits of smart growth policies. Indicators could include per-capita VMT, exposure to 

congestion, availability of alternative travel choices, health impacts and infrastructure costs. 

2. Ensure that Federal Transportation and Infrastructure Funding Advances Sustainable 

Land Use and Transportation 

EPA and DOT should fund regional visioning exercises that elicit public input on alternative 

transportation and land use scenarios. Efforts such as Envision Utah and the BluePrint project in 

Sacramento can increase public understanding of and support for efficient, integrated policies. 

EPA should work with other federal agencies, state and local governments to coordinate 

infrastructure funding in such as way as to encourage efficient land use patterns and slow growth 

in VMT. For example, if EPA is promoting brownfield development in a region, it is important to 

ensure that there are not other incentives that make greenfield development relatively more 

attractive. 

EPA should work with Congress to allow transportation funds to be used for updating general 

plans in ways that can slow growth in VMT. 

EPA should work with other federal agencies to develop performance-based funding mechanisms 

and incentives. For example EPA could develop a scorecard to measure local plans against 

livable community measures such as efficient land use, provision of affordable housing, energy 

use, CO2 emissions, etc. Funding would be adjusted based on the scoring. 

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Additional Comments from the Ozone Transport Commission 

Excerpts from AQMWG Report for Comment 

Executive Summary, pg viii 

Over the past six months, the Work Group also considered a variety of other issues on which it is 

not prepared to make recommendations at this time, some of which are short term and others long 

term. Some topics were so complex, resource intensive, or controversial that the Work Group 

was unable to reach consensus and, therefore, has decided not to carry them forward. Additional 

discussion on these topics is expected in the future, with some resolution about the deferred short 

term issues within the next three to six months by a new subcommittee of the CAAAC . 

The Work Group has also begun considering options for the air quality management system in the 

future. It evaluated the long-term challenges facing air quality management in the U.S. from a 

number of perspectives and identified several criteria that may help guide discussions on 

alternatives for reforming the current system in future years. To help begin this process, the 

Work Group outlines four approaches reflecting different views that could serve as the basis for a 

more complete transformation of the air quality management system. In addition, the Work 

Group recommends that discussion of future options and unresolved issues be continued over the 

next several months. 

Pg 6 

Next Steps 

The Work Group recommends that decisions on implementation of the recommendations in this 

report, as well as discussion of future options and unresolved issues, be continued over the next 

several months. These continuing discussions would also allow review and/or adjustment of the 

near-term recommendations if warranted. Specifically, the Work Group recommends: 

A new subcommittee of CAAAC should be established to continue the assessment and 

development of recommendations for long-term changes to the air quality management 

system and the short-term issues on which the Work Group could not reach consensus. 

Until this subcommittee is formed, the current Work Group should continue working to 

resolve additional short-term issues and continue discussion of long-term framework 

options. Following its establishment under the CAAAC, the subcommittee should 

develop a prioritization and timeline for preparing additional recommendations and 

provide periodic progress reports to CAAAC. Discussion of all remaining issues and 

options should be directed towards further strengthening the U.S. air quality management 

framework over the next decade. The Work Group recommends that the new 

subcommittee, in conjunction with existing subcommittees, also be given the 

responsibility for overseeing the implementation of, and any modifications to, the 

recommendations contained in this report. 

•

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Air emissions from the recommended categories are projected to continue to be substantial (see 

Figure 7). However, a variety of factors must be considered in determining whether and how a 

sector can be effectively regulated, including pollutant type, geographic location, dispersion 

patterns, multipollutant interactions, control strategy availability, emissions reduction potential, 

and cost-effectiveness. Some Work Group participants believe that adequate information exists 

to begin the regulatory process now for certain source categories, while others believe that 

additional data and data analyses are necessary. After extensive deliberations, the Work Group 

recommends that each of the sectors listed below be addressed in some fashion by EPA. This 

action may include, but should not be limited to, development of national and/or regional rules, 

control technique guidelines, other guidance, and/or further study. 

Figure 7. Projected 2010 National Emissions for Key Source Categories. In developing 

recommendations relating to the source categories shown here, Workgroup analysts examined 

projected emissions of five key criteria pollutants to 2010 for a list of 40 stationary and mobile 

categories. Excluding natural emission sources, the categories shown comprise over XX percent 

of the national SOx and NOx emissions and about XX percent of the direct PM2.5 and VOC 

emissions. These projections include recognized uncertainties in the current inventory and the 

forecast. Due to data limitations, the assessment did not include estimates of air toxics emissions 

or ammonia. (Add a bar for the EGU sector to this chart, and include a second chart that displays 

all the same sectors for current air emissions.) 

Unresolved Issues for Further Discussions

Pg 33 

A second potential recommendation discussed at length by the Work Group was the electricity 

generating unit (EGU) sector because of the large contribution that this sector makes to multiple 

air quality problems. Many on the Work Group believed that the active rulemaking underway on 

the Clear Air Interstate Rule (CAIR) provided the proper forum for considering what this sector 

ought to do for the next 15 years or more; others did not. Since no agreement could be reached 

on a recommendation regarding this sector, the Work Group recommends that discussions 

continue by the new CAAAC subcommittee. Regardless of the outcome of any future 

discussions, many of the stakeholders involved saw value in S/L/T and utilities consulting with 

each other after final promulgation of the CAIR (or new legislation) to share compliance plans, 

evaluate likely emissions reductions and their geographic distribution, and apply that information 

to further planning activities. (This section needs to be rewritten since CAIR will not be 

promulgated. It is important that the EGU sector be given highest priority in terms of the issues 

being addressed by the new subcommittee. Consideration of additional regulatory action in this 

sector is critical for states, localities and tries in meeting their air quality requirements.) 

Pg. 88 – Appendix C Summary of Deferred Issues 

1) Electric Generating Units: Consistent with the comments we made regarding page 33 of the 

report, on the priority of addressing this sector through additional national/regional regulations, 

this should appear as the first item in a prioritized list of the issues and potential 

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recommendations for future discussion. The AQMWG should prioritize the other 11 issues and 

recommendations according to their valueto states, localities and tribe in meeting the immediately 

upcoming SIP and air quality requirements. 

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