Early Action Compact Program for 

Ground-Level Ozone: A Study 

Early Action Compact Program for
 

Ground-Level Ozone: A Study
 

By:
 

U.S. Environmental Protection Agency
 

Office of Air Quality Planning and Standards
 

Outreach and Information Division 


Research Triangle Park, North Carolina
 

U.S. Environmental Protection Agency
 

Office of Air Quality Planning and Standards
 

Outreach and Information Division 


Research Triangle Park, North Carolina
 

 EPA-456/R-09-001 

June 2009 
 

TABLE OF CONTENTS
 

EXECUTIVE SUMMARY	 6
 

INTRODUCTION 6 


BACKGROUND ON THE EAC PROGRAM 6 


INFORMATION COMPILATION APPROACH 7 


LIMITATIONS OF THIS STUDY 8 


KEY OBSERVATIONS RESULTING FROM THE STUDY 8 


HOW THIS REPORT IS ORGANIZED 11 


SECTION 1.0 BACKGROUND ON THE EARLY ACTION COMPACT
 

PROGRAM 12
 

1.1 	 Origin of the EAC Program 12 


1.2 	 What EPA Required of Compact Areas 14 


1.3 	 Areas that Participated in the EAC Program 16 


1.4 	 Action EPA Undertook To Defer the Effective Date of Nonattainment
 

Designation for the EAC Areas 17 


1.5 	 How EPA Addressed Compact Areas Attaining the 8-Hour Ozone Standard in 

April 2004 18 

1.6 	 Concerns About and Legal Challenges to the EAC Program 18 


1.7 	 Federal Emissions Control Programs that Have Helped Improve Air Quality in 


EAC Areas 20 


SECTION 2.0 INFORMATION COMPILATION APPROACH	 22
 

2.1 	 Decision to Conduct EAC Study 22 


2.2 	 Scope of the Study 22 


2.3 	 Refining the Study Scope 23 


2.3.1 	 Environmental Aspects of Study 23 


2.3.2 	 Program Design Aspects of the Study 27 


2.4 	 Information Compilation 28 


2.4.1 	 Quantitative Information Compilation 28 


2.4.2 	 Qualitative Information Compilation 32 


SECTION 3.0 INFORMATION COMPILED AND OBSERVATIONS 34
 

3.1 	 Information Compiled 34 


3.1.1 	 Quantitative Information 34 


3.1.2 	 Qualitative Information 52 


3.2 	 Observations 68 


3.2.1 	 Overall Observations Resulting from the Study 68 


3.2.2 	 Specific Observations 71 


3.2.3 	 Study Results Where Information is Insufficient or Too Ambiguous
 

to Make an Observation 75 


2 
LIST OF TABLES
 

Table ES-1: Twenty-Nine Participating EAC Program Areas 7 

Table 1-1: EAC Milestones 16 

Table 1-2: Twenty-Nine Participating EAC Program Areas 17 

Table 1-3: EPA Actions Deferring Effective Date of Nonattainment Designation 18 

Table 2-1: Population, 8-Hour DVs and Emissions Information for the 20 Areas 

Included in this Study for Which Quantitative Information was Compiled 24 

Table 2-2: EAC Program Aspects and Areas Included in the Study, Breakout of 

Information Compiled, and Whether it was Quantitative or Qualitative 29 

Table 3-1: Summary of Air Quality Study Information 39 

Table 3-2: Summary of Control Measure Emission Reduction Study Information 43 

Table 3-3: Four Nonattainment-Deferred EAC Program Areas with Five Percent or

 Greater of Quantified NOx and VOC Emissions Reductions from Eight 

Individual Local Measures 45 

Table 3-4: Two Attainment EAC Program Areas with Five Percent or Greater of

 Quantified NOx and VOC Emissions Reductions from Three Individual 

Local Measures 45 

Table 3-5: EAC Program Area Measures Not Implemented by December 2005 47 

Table 3-6: Comparison of Projected Air Quality Improvements Projected by EAC SIP

 Modeling Monitored Air Quality Measured as 8-hour Ozone Concentrations, 

 From 2001-2003 to 2005-2007, 14 Nonattainment-Deferred EAC Program

 Areas and Six Attainment EAC Program Areas 49 

Table 3-7: EPA Resource Estimates for the EAC Program versus the Traditional

 Approach 52 

Table 3-8: Conformity Program Status of Nonattainment-Deferred EAC Program

 Areas During Implementation of EAC Program 56 

LIST OF FIGURES 

Figure 1-1: Percentage Change in Seasonal 8-Hour Ozone Average Air Quality from

 2000-2002 to 2005-2007, Adjusted for Weather 21 

Figure 3-1: Map Showing Percentage Changes in Average Summertime Daily

 Maximum 8-hour Ozone Concentrations in EAC and Non-EAC Program

 Areas in the East Between 2001-2003 and 2005-2007, After Adjusting for

 Weather 36 

Figure 3-2:	 Box Plot Showing Percentage Changes in Average Summertime Daily

 Maximum 8-hour Ozone Concentrations in EAC and Non-EAC Program

 Areas in the East Between 2001-2003 and 2005-2007, After Adjusting for

 Weather 37 

Figure 3-3:	 Trends in 8-Hour Ozone (Seasonal Average Adjusted for Weather) 38 

Figure 3-4: Percentage Change in Population and VMT from 2002 to 2006 for 20 

 EAC Program Areas, the U.S. and the South and West 51 

3 
TABLE OF APPENDICIES
 

Appendix A: List of State and Local Agencies Consulted 3 

Table A-1: State Agencies Consulted 3 

Table A-2: Local Government Agencies Consulted 5 

Appendix B: Tables 6 

Table B-1: Year-to-Year Changes in 8-hour Ozone Design Values (ppm) from 

2001-2003 to 2004-2007 for 14 Nonattainment- Deferred Early Action 

Compact (EAC) Program Areas and Six Attainment EAC Program Areas, 

Not Controlling for Meteorology 6 

Table B-2: Year-to-Year Changes (and Percent Change) in 8-hour Air Quality Index 

Days from 2001 to 2007 for 14 Nonattainment-Deferred EAC Program 

Areas and 6 Attainment EAC Program Areas, Not Controlling for 

Meteorology (May to September Ozone Season) 7 

Table B-3: Changes in Seasonal Average 8-hour Daily Maximum Ozone

 Concentrations (ppm) from 2001-2003 to 2005-2007 for 14 

 Nonattainment-Deferred EAC Program Areas and 6 Attainment EAC

 Program Areas, Controlled and Uncontrolled for Meteorology 9 

Table B-4: Changes in Seasonal Average 8-hour Ozone Daily Maximum

 Concentrations (ppm) from 2001-2003 to 2005-2007 (Meteorologically­

 Controlled) for 14 Nonattainment-Deferred EAC Program Areas, 6 

 Attainment EAC Program Areas and 18 Non-EAC Program Areas 11 

Table B-5: Control Measure Emission Reductions for Berkeley and Jefferson 

 Counties, West Virginia 13 

Table B-6: Control Measure Emission Reductions for Chattanooga, 

 Tennessee-Georgia 14 

Table B-7: Control Measure Emission Reductions for Columbia, South Carolina

 (Central Midlands Area) 15 

Table B-8: Control Measure Emission Reductions for Denver-Boulder­

 Greeley-Fort Collins-Loveland, Colorado 17 

Table B-9: Control Measure Emission Reductions for Fayetteville, North Carolina

 (Cumberland County) 18 

Table B-10: Control Measure Emission Reductions for Frederick County, Virginia 19 

Table B-11: Control Measure Emission Reductions for Greensboro-Winston 

 Salem-High Point, North Carolina (Triad Area) 20 

Table B-12: Control Measure Emission Reductions for Greenville-Spartanburg­

 Anderson, South Carolina (Appalachian Area) 22 

Table B-13: Control Measure Emission Reductions for Hickory-Morganton-Lenoir, 

 North Carolina (Unifour Area) 24 

Table B-14: Control Measure Emission Reductions for Johnson City-Kingsport­

 Bristol, Tennessee 25 

Table B-15: Control Measure Emission Reductions for Nashville, Tennessee 26 

Table B-16: Control Measure Emission Reductions for Roanoke, Virginia 27 

Table B-17: Control Measure Emission Reductions for San Antonio, Texas 29 

Table B-18: Control Measure Emission Reductions for Washington County,

 Maryland (Hagerstown) 30 

Table B-19: Control Measure Emission Reductions for Austin, Texas 31 

4 
Table B-20: Control Measure Emission Reductions for Berkeley-Charleston­

 Dorchester, South Carolina 34 

Table B-21: Control Measure Emission Reductions for Mountain Area of Western 

 North Carolina (Asheville) 36 

Table B-22: Control Measure Emission Reductions for Oklahoma City, Oklahoma 37 

Table B-23: Control Measure Emission Reductions for Lower Savannah-Augusta, 

 South Carolina-Georgia 38 

Table B-24: Control Measure Emission Reductions for Tulsa, Oklahoma 40 

Table B-25: Control Measure Emission Reductions for South Carolina (Statewide) 41 

Table B-26: Comparison of EAC NOx and VOC Emissions Reductions to the 2002 

 Emissions for the 20 EAC Program Areas, Emissions for the States in 

 Which They Are Located, and the NOx SIP Call Emission Reductions

 in Those States 42 

Table B-27: Population Change from 2002 to 2006 in 14 Nonattainment-Deferred EAC 

Program Areas 44 

Table B-28: Population Change from 2002 to 2006 in 6 Attainment EAC

 Program Areas 47 

Table B-29: Vehicle Miles Traveled (VMT) Change from 2002 to 2006 In 14 

 Nonattainment-Deferred EAC Program Areas 49 

Table B-30: VMT Change From 2002 to 2006 in 6 Attainment EAC Program Areas 52 

Table B-31: EPA Resources for Traditional Approach versus EAC Program 54 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour

 Ozone Areas Compared to a Summary of Requirements for Clean 

 Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone

 Nonattainment Areas 60 

Appendix C: Approach for Calculating National (Federal) Measure Emission

 Reductions 69 

Appendix D: Brief Profile of the 14 Nonattainment-Deferred Areas and Six 

 Attainment EAC Program Areas Included in this Study 75 

Appendix E: Summary of Discussions with State and Local Agencies 79 

5 
EXECUTIVE SUMMARY 

INTRODUCTION 

The United States Environmental Protection Agency (EPA) initiated the Early Action Compact (EAC) 

Program in 2002 to make available an option of early implementation action that provided for cleaner air 

sooner than might have occurred by otherwise following the timelines in the Clean Air Act (CAA). In 

exchange for early implementation action for the 8-hour ozone standard, EPA deferred the effective dates 

of designation for those areas that would have been designated nonattainment for the 0.08 parts per 

million 8-hour ozone National Ambient Air Quality Standard (NAAQS). (The deferral of the effective 

date had the effect of also deferring the application of specific CAA requirements in these EAC areas, 

including the New Source Review (NSR) and Conformity Programs.) 

` 

The program concluded in the spring of 2008. At that time, the EPA designated as ‘attainment’ those 

EAC areas that had attained the ozone NAAQS and affirmed a nonattainment designation for the one area 

that had not attained the NAAQS for ozone. 

Following the conclusion of the EAC program, EPA’s Office of Policy Analysis and Review and EPA’s 

Office of Air Quality Planning and Standards undertook this study of the EAC program in order to learn 

what worked well and what did not with this community-based program, including whether EAC 

Program areas attained the ozone NAAQS early. EPA’s intent was then to share that knowledge with 

leaders of programs that EPA and the states create to improve air quality in communities. 

BACKGROUND ON THE EAC PROGRAM 

In July 1997, EPA promulgated a revised ozone standard, i.e., the 1997 8-hour standard. EPA designated 

areas for the 8-hour ozone standard in April 2004. After the standard was promulgated but before areas 

were designated for it, some state, local and tribal air pollution control agencies expressed a need for 

added flexibility in implementing the 8-hour ozone NAAQS. One concept was to provide incentives for 

taking early action to reduce ground-level ozone in exchange for avoiding the stigma of a CAA 

nonattainment designation and its accompanying requirements (e.g., the NSR and Conformity Programs). 

This incentive concept became the basis for the development of the EAC program. 

Certain environmental groups supported the concept of early action to improve air quality sooner, but had 

serious concerns about the approach, including, in their view, a weakening of enforcement of the CAA’s 

nonattainment area requirements. Ultimately, EPA worked with these parties to address their concerns by 

incorporating program elements to help ensure accountability and results. 

In 2002, the Texas Commission on Environmental Quality submitted an EAC protocol to EPA. EPA 

endorsed the protocol and subsequently issued guidance for compact areas. Twenty-nine areas from 12 

states submitted signed compact agreements by December 2002. Table ES-1 lists all of the participating 

areas, only one of which did not complete the program due to an air quality violation (Denver-BoulderGreeley-Fort Collins-Loveland, Colorado). Fourteen of the areas participated as nonattainment-deferred. 

This meant that their effective date of designation as nonattainment would have been June 15, 2004; 

however, EPA deferred this date because of their participation in the EAC Program. The remaining 

fifteen areas met the ozone NAAQS and were designated attainment, but were close to violating the 

standard and were looking to voluntarily adopt programs to avoid becoming nonattainment in the future. 

6 
Table ES-1: Twenty-Nine Participating EAC Program Areas
 

Nonattainment Deferred Areas (14) Attainment Areas (15) 

Berkeley and Jefferson Counties, West Virginia* Austin, Texas* 

Chattanooga, Tennessee-Georgia* Berkeley-Charleston-Dorchester, South 

Carolina* 

Columbia, South Carolina (Central Midlands Area)* Catawba, South Carolina 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado* Longview/Northeast, Texas 

Fayetteville, North Carolina (Cumberland County)* Low Country, South Carolina 

Frederick County, Virginia* Lower Savannah-Augusta, South CarolinaGeorgia* 

Greensboro-Winston Salem-High Point, North Carolina 

(Triad Area)* 

Mountain Area of Western North Carolina 

(Asheville)* 

Greenville-Spartanburg-Anderson, South Carolina 

(Appalachian Area)* 

Oklahoma City, Oklahoma* 

Hickory-Morganton-Lenoir, North Carolina (Unifour 

Area)* 

Pee Dee, South Carolina 

Johnson City-Kingsport-Bristol, Tennessee* San Juan County, NM 

Nashville, Tennessee* Santee Lynches, South Carolina 

Roanoke, Virginia* Shreveport/Bossier City, LA 

San Antonio, Texas* Tulsa, Oklahoma* 

Washington County, Maryland (Hagerstown)* Upper Savannah Abbeville-Greenwood, South 

Carolina 

Waccamaw, South Carolina 

Source: http://www.epa.gov/ttn/naaqs/ozone/eac/index.htm#EAC_Main. 

*Indicates the 20 areas included in this study. 

INFORMATION COMPILATION APPROACH 

This study examined both environmental and program design aspects of the EAC program. The 

environmental aspects of the program included: 

• Changes in air quality; 

• Estimated emissions reductions from control measures; 

• Estimates made in State Implementation Plan (SIP) air quality modeling; and 

• Growth-related issues. 

The design aspects of the study of the program included: 

• Efficiency of the EAC Program; 

• Longer term impact of the program; 

• Extent of outreach and stakeholder interaction; and 

• Other aspects of the program. 

The study examined all 14 “nonattainment deferred” and six of the 15 “attainment” EAC Program areas 

(see Table ES-1). The six attainment areas were selected based on geographic diversity and the 

availability of relevant data. As part of the study, EPA gathered information on air quality and control 

measure emissions reductions, among other data. Discussions were also held with state agencies from all 

12 states that participated in the program, as well as local agencies in six of the 14 nonattainmentdeferred areas and in three of the 15 attainment areas that also participated in the program. EPA also 

7 
consulted with representatives from two non-EAC Program areas and the states in which they are located 

to provide additional perspectives. 

The qualitative information and observations developed from discussions with state and local agencies 

reflect the views of the individuals consulted. So, in that sense, the information gained was somewhat 

subjective and should be interpreted in that light. But, to some degree, the information obtained was 

consistent enough such that it could be generalized to other EAC areas. The program design areas in 

particular were addressed in a qualitative manner because they did not lend themselves easily, if at all, to 

quantitative measurement. Ideally, for example, it would have been beneficial to be able to develop a 

questionnaire to answer some of the study’s questions. Because that was not feasible in the time 

available for the study, EPA held informal discussions, which, though not ideal, yielded useful 

information. State and local agencies provided insights, positive and negative, on the EAC Program. 

LIMITATIONS OF THIS STUDY 

This report is not a formal program evaluation and has several limitations. Specifically, the study did not: 

•	 Compare emission reductions of EAC areas versus non-EAC areas in terms of both quantities and 

implementation timeframes; 

•	 Study air quality for EAC areas past 2007; and 

•	 Rigorously compare EAC areas with non-EAC areas with respect to certain key areas, such as: 

o	 Program design-related concerns (e.g., program efficiency) 

o	 Control measure implementation. 

KEY OBSERVATIONS RESULTING FROM THE STUDY 

Because of the study’s limitations, it is difficult to draw hard findings and conclusions. However, the 

study was able to make a number of observations about emission reductions, changes in air quality, and 

issues related to program design and process. 

Overall, a number of states in the Northeast had serious concerns about the approach. The EAC program 

was generally popular with participating state and local officials. These officials indicated the EAC 

Program model provided the right combination of incentives, flexibility, and structure and was used to 

foster a collaborative environment that: 

1) Encouraged local stakeholders to take ownership of the ozone air quality issue and to develop 

and adopt local measures; 

2) Increased awareness of ozone air quality issues with key stakeholders and, to a degree, with the 

public; and 

3) Helped establish working relationships between state environmental agencies and local 

government that may prove beneficial for future implementation of air quality standards. 

Emission Reductions 

For the vast majority of the areas included in this study, the EAC Program appeared to successfully 

encourage the development and adoption of quantifiable, local emission reduction control measures by 

the December 2005 deadline. Ninety-six percent of the total 388 measures implemented for the 20 areas 

included in the study were implemented by the EAC December 2005 deadline, according to EAC 

progress reports and SIPs. Estimated emission reductions from local measures collectively constituted an 

estimated nine percent or more of quantified nitrogen oxides (NOx)and volatile organic compounds 

8 
(VOC) emissions reductions in seven of 18 EAC Program areas included in this study for which complete 

emissions reductions data were available (the remaining reductions were achieved from national and state 

measures). The local measures were “directionally correct” and should assist the areas in maintaining the 

ozone NAAQS. 

According to many state and local officials, the program also resulted in quantifiable emission coreductions of other pollutants, including particulate matter and/or air toxics. 

Air Quality 

The study analyzed the air quality improvements experienced by EAC Program areas in the eastern U.S. 

by comparing them to improvements achieved in nearby nonattainment areas that did not participate in 

the EAC program. (This could not be analyzed in the Colorado, Oklahoma and Texas EAC areas, 

because there were not ozone nonattainment areas located near enough to provide a comparison.) The 

analysis found that the changes in air quality in eastern EAC Program areas were consistent with those 

observed in non-EAC areas. Additionally, consistent with the expectation that most progress towards 

ozone attainment in the East would come generally from national measures such as vehicle standards and 

power plant controls, it appears that, based on air quality data, local EAC measures adopted and 

implemented in EAC Program areas in the East did not produce an early, demonstrable incremental 

improvement in air quality. Relative to non-EAC Program areas, the information compiled appears to 

indicate that, for EAC areas in the East, progress toward meeting the air quality standards on time was not 

adversely affected by two factors: (1) the absence of some or all of the nonattainment area requirements 

that traditional nonattainment areas face, or (2) population and vehicle miles traveled growth that most of 

the areas experienced during EAC Program implementation. Relative to non-EAC Program areas, these 

two factors also did not appear to adversely affect the ability of EAC areas in the East to attain the 

NAAQS by December 2007 (or earlier for many EAC areas). 

The fact that local measures did not produce an early, demonstrable incremental improvement in air 

quality can be explained in part by the fact that quantified NOx and VOC emissions reduction estimates 

from local EAC measures represented a small part of emissions overall: (1) in EAC Program areas; (2) in 

states in which they are located, and (3) as compared to reductions achieved in each state through the NOx 

SIP call. The best way to measure the impact on air quality of the EAC local measures – and whether 

they contributed to the areas attaining early – would be to conduct incremental air quality modeling of the 

emissions reductions from those measures. Short of that, the reductions are so small relative to the 

emission reductions from federal and state measures that their impact is indiscernible. 

All but one of the EAC areas did attain the ozone NAAQS by December 31, 2007; in fact, 15 of the 20 

EAC areas attained the 8-hour ozone NAAQS by December 31, 2004 – prior to the required 2005 

implementation date for the EAC control measures. 

This study looked at ozone air quality through 2007. And while almost all the EAC areas met the ozone 

NAAQS before 2007, it remains to be seen what will happen to ozone air quality levels in these areas as 

they grow in the next 5 to 10 years. Ozone air quality in many of the areas will continue to be influenced 

by, among other things, state and national programs to reduce NOx and VOCs. Some state and local 

officials believe that local measures should benefit air quality in the future. EAC Program areas were 

required to develop plans to demonstrate how they would address emissions growth and maintain meeting 

the ozone NAAQS for five years (to 2012). They did so, and almost all the states in the southeastern U.S 

(EPA Region 4) with EAC Program areas submitted maintenance plans for 10 years. 

9 
The study also looked at whether the air quality modeling provided insight into what degree the “local” 

EAC measures contributed to additional improvements in air quality, beyond the improvements provided 

by the state and national measures. The only reliable way to quantify the air quality improvements from 

the EAC local measures is to model the local measures independently of the state and national measures. 

But the modeling performed for the EAC SIPs did not provide such an analysis. For this study the 

information available only allows for a review of whether the actual air quality improvement achieved is 

consistent with the level of improvement predicted by the model. After making this comparison, this 

study observes that the estimates in the modeled demonstration are consistent with the air quality 

achieved. Therefore, the modeling provided reasonable information. 

It was beyond the scope of this study to analyze the improvements in short-term or long-term air quality 

that would have otherwise occurred in the affected EAC areas if they had followed the traditional 

requirements under the CAA associated with a nonattainment designation. For example, several of the 

nonattainment-deferred areas experienced new stationary source activity that may have been subject to 

permitting requirements under the CAA nonattainment NSR program had the same activities been 

undertaken while these areas had a designation of nonattainment. The proposed emissions increases for 

some of those sources were controlled under the CAA’s Prevention of Significant Deterioration Program. 

As noted above, this study did not quantify emission changes in EAC versus non-EAC areas and is, 

therefore, unable to provide information on the impact on emissions of the absence in EAC areas of some 

or all of the nonattainment area requirements that traditional nonattainment areas face, including those of 

the Nonattainment NSR Program. 

State and local agencies consulted did believe the EAC approach to be well suited for nonattainmentdeferred areas that were new to the ozone air quality issue and had ozone air quality levels relatively 

close to the standard. Those areas did not face the same degree of ozone air quality challenge faced by 

some of the nation’s largest areas and so, in that regard, their air quality problems were more manageable. 

EAC Program participants in these areas took ownership of their air quality problem in a way that was 

not likely, in the opinion of the state and local agencies consulted, to have occurred to the same degree 

under the traditional approach, absent a concerted EAC-type effort or unless the community was already 

active on environmental issues. 

Program Design and Process 

Some EAC Program areas did not experience the “collaborative environment” the EAC Program model 

fostered in other EAC Program areas. Based on the study discussions, several possible reasons emerged 

to help explain this: 

•	 Insufficient technical support for EAC Program areas from EPA and the states; 

•	 Insufficient state or local agency leadership to help start and/or shepherd the EAC Program 

process; 

•	 Lack of public interest due to insufficient information about local air quality issues; and 

•	 Ozone air quality problem believed to be solvable due to state and national measures alone so 

there was not much action perceived to be needed locally. 

The state and local agencies implementing the EAC Program reported that, in order to succeed, the EAC 

program needed (1) the threat of reinstatement of the nonattainment designation as the consequence of 

failure to meet EAC Program requirements and (2) for the EAC Program to be part of the larger SIP 

10 
program. The majority of state and local agencies consulted believed that states and local areas needed 

motivation to participate in the program for it to succeed. 

The EAC Program required as much EPA staff resources or less than the staff resources EPA estimated 

would have been needed to implement the regular program for the same areas. The question of whether 

the EAC Program saved estimated human resources varied by EPA region. The study lacked data to 

assess the resource impact of the EAC program on the participating state and local agencies. 

Details on specific quantitative and qualitative observations on environmental impacts and program 

design-related issues can be found in Section 3.0 of this report. 

HOW THIS REPORT IS ORGANIZED 

This report contains four sections. Section 1.0 provides background on the EAC Program, including 

some of its history and why some states supported and other states and environmental groups opposed the 

program. Section 2.0 describes the quantitative and qualitative information compilation approach used to 

conduct the study of the program. Section 3.0 presents a summary of the study information, as well as 

observations based on that information. The appendices include numerous data tables, lists of state and 

local agencies consulted, and a complete summary of discussions with state and local agency officials. 

11 
SECTION 1.0 BACKGROUND ON THE EARLY ACTION COMPACT 

PROGRAM 

This section provides background on the Early Action Compacts (EAC) Program, including: (1) a brief 

history; (2) why some states supported the program and other states and environmental groups opposed it; 

and (3) why the United States Environmental Protection Agency’s (EPA’s) Office of Policy Analysis and 

Review (OPAR) and Office of Air Quality Planning and Standards (OAQPS) decided to undertake this 

study. 

1.1 Origin of the EAC Program 

The Clean Air Act (CAA) establishes a process for air quality management through the National Ambient 

Air Quality Standards (NAAQS). Area designations are required after promulgation of a new or revised 

NAAQS. In 1979, EPA promulgated the 0.12 parts per million (ppm), 1-hour ozone standard. On July 

18, 1997, EPA promulgated a revised ozone standard of 0.08 ppm, measured over an 8-hour period (i.e., 

the 1997 8-hour standard.)1

 The 8-hour standard is more protective of public health and, thus, more 

stringent than the 1-hour standard. In 2008, the Agency further tightened the 8-hour ozone standard. (In 

this document, when references are made to the 8-hour standard it applies to the 0.08 ppm standard 

promulgated in 1997.) The 1997 NAAQS rule was challenged by numerous litigants and, in May 1999, 

the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued a decision remanding, 

but not vacating, the 8-hour ozone standard. The EPA sought review of two aspects of that decision in 

the U.S. Supreme Court. In February 2001, the Supreme Court upheld EPA’s authority to set the 

NAAQS and remanded the case back to the D.C. Circuit for disposition of issues the Court did not 

address in its initial decision. Whitman v. American Trucking Association, 121 S.Ct. 903, 911-914, 916­

919 (2001)(Whitman). The Supreme Court also remanded the 8-hour implementation strategy to EPA. In 

March 2002, the D.C. Circuit rejected all remaining challenges to the 8-hour ozone standard. American 

Trucking Assoc. v. EPA, 283 F.3d355 (D.C. Cir. 2002). 

The process for designations following promulgation of a NAAQS is contained in section 107(d)(1) of 

the CAA. For the 8-hour NAAQS, the Transportation Equity Act for the 21st Century (TEA-21) extended 

by one year the time for EPA to designate areas under the 8-hour NAAQS.2 Thus, EPA was required to 

designate areas for the 8-hour NAAQS by July 2000. However, House Resolution 3645 (EPA's 

appropriation bill in 2000) restricted EPA's authority to spend money to designate areas until June 2001, 

or the date of the Supreme Court ruling on the standard, whichever came first. As noted earlier, the 

Supreme Court decision was issued in February 2001. In 2003, several environmental groups filed suit in 

district court claiming EPA had not met its statutory obligation to designate areas for the 8-hour NAAQS. 

The EPA entered into a consent decree that required EPA to issue the designations by April 15, 2004.3 

During this period, in the early 2000s, some state, local and tribal air pollution control agencies expressed 

an interest in added flexibility in implementing the 8-hour ozone NAAQS, including incentives for taking 

action sooner than the CAA required for reducing ground level ozone. Some of these agencies were 

particularly interested in early planning and implementation to avoid the nonattainment designation and 

1 “National Ambient Air Quality Standards for Ozone,” 62 Federal Register 38856,
 

http://www.epa.gov/ttn/naaqs/standards/ozone/data/19970718_o3naaqs.pdf, July 18, 1997.
 2 CAA section 107(d)(1); TEA-21 section 6103(a).
 

3 “Air Quality Designations and Classifications for the 8-Hour Ozone National Ambient Air Quality Standards; Early Action
 

Compact Areas with Deferred Effective Dates,” 69 Federal Register 23858-23951,
 

http://www.epa.gov/ttn/naaqs/ozone/eac/fr_69(84)_23858.pdf, April 30, 2004.
 

12 
the various CAA requirements associated with being designated nonattainment (e.g., Conformity and 

Nonattainment New Source Review (NSR) Programs) that they were going to face in 2004 with EPA area 

designations. The concept for an EAC program required local areas to make decisions to achieve 

reductions in volatile organic compounds (VOCs) and nitrogen oxides (NOx) emissions sooner than 

otherwise mandated by the CAA. It was assumed that early planning and early implementation of control 

measures that improved air quality would provide early protection of public health. Environmental 

groups supported efforts to improve air quality sooner, but had serious concerns about the EAC Program. 

Some states, supported efforts that afforded flexibility in achieving their clean air goals but did not 

support the EAC Program per se. They believed that EPA could not relieve areas of nonattainment area 

requirements under title I, part D of the CAA when such areas were in violation of the standard at the 

time EPA designated areas. (These concerns are discussed in greater depth in Section 1.6 below.) 

In March 2002, the Texas Commission on Environmental Quality (TCEQ) encouraged EPA to consider 

incentives for early planning towards achieving the 8-hour ozone NAAQS. The TCEQ submitted to EPA 

the “Protocol for Early Action Compacts Designed to Achieve and Maintain the 8-hour Ozone Standard 

(the Protocol).”4

 The Protocol was designed to achieve NOx and VOC emissions reductions for the 8­

hour ozone NAAQS sooner than would otherwise be required under the CAA. The TCEQ recommended 

that the Protocol be formalized by ‘‘early action compact’’ agreements to be developed primarily by 

local, state and EPA officials. The principles of the compacts, as described in the Protocol, were as 

follows: 

•	 Early planning, implementation, and emissions reductions leading to expeditious attainment and 

maintenance of the 8-hour ozone standard; 

•	 Local control of the measures employed, with broad-based public input; 

•	 State support to ensure technical integrity of the early action plan; 

•	 Formal incorporation of the early action plan into the State Implementation Plan (SIP); 

•	 Designation of all areas as attainment or nonattainment in April 2004, but, for compact areas, 

deferral of the effective date of the nonattainment designation and/or designation requirements so 

long as all compact terms and milestones continue to be met; and 

•	 Safeguards to return areas to traditional SIP attainment requirements should compact areas fail to 

meet program terms (e.g., if the area fails to attain in 2007), with appropriate credit5

 given for 

reduction measures already implemented. 

In a letter dated June 19, 2002, from Gregg Cooke, Administrator, Region 6, to Robert Huston, Chairman, 

TCEQ, EPA endorsed the principles outlined in the Protocol.6 The Protocol was subsequently revised on 

December 11, 2002, based on comments from EPA. The Protocol specified certain components that 

compacts had to address, including the development of local air quality plans and the following elements: 

4 http://www.epa.gov/ttn/naaqs/ozone/eac/20020619_eac_protocol.pdf 

5 In the EAC context “credit” is discussed in a guidance Q and A that EPA issued under the heading of “SIP credit”: 

"Question: If an area implements controls under an MOA or Compact, will those reductions be able to be counted as control 

measures under a subsequent attainment SIP, if one is required? 

Response: The 8-hour “Compact” is the Memorandum of Agreement. Reductions from any control measures implemented 

under the 8-hour Early Action Compact and approved into the SIP can be credited towards a subsequent attainment SIP, if one 

is required (see memorandum from John S. Seitz, Director, Office of Air Quality Planning and Standards, to Gregg Cooke, 

Regional Administrator, Region VI, dated January 29, 2001, “Near-Term Discretionary Emission Reductions for Ozone 

NAAQS–Clarification.”)," http://www.epa.gov/oar/eac/faq.html. 6 http://www.epa.gov/ttn/naaqs/ozone/eac/20020619_eac_protocol.pdf 

13 
•	 Completion of emissions inventories and modeling (based on most recent Agency guidance) to 

support selection of local control measures; 

•	 Adoption of control strategies that demonstrate attainment and that are submitted as a revision to 

the SIP; 

•	 Completion of a maintenance component to address emissions growth at least five years beyond 

December 31, 2007, ensuring that the area will remain in attainment of the 8-hour ozone standard 

during that period; 

•	 Public involvement in all stages of planning and implementation, including public education 

programs and a process that ensures stakeholder involvement and public participation in planning 

local strategies and reviewing air quality plans; and 

•	 Semiannual reports detailing progress toward completion of compact milestones. 

1.2 What EPA Required of Compact Areas 

Based on the Protocol, EPA issued Agency guidance7

 that established parameters for entering into a 

compact. To be eligible as an EAC area, areas had to be designated attainment for the 1-hour ozone 

standard8 and be in attainment with that standard when entering into the compact. Air quality in 

qualifying EAC Program areas could approach or violate the 8-hour ozone standard9 at the time of the 

agreement, but the area would need to demonstrate that it would attain that standard by December 31, 

2007. 

EPA’s EAC guidance memorandum specified that compacts had to be completed, submitted to EPA and 

signed by local, state and EPA officials by December 31, 2002. Each EPA Regional Administrator (or 

designee) was a signatory on the compact agreement. Although these compacts alone did not constitute 

EPA-approved SIP revisions, EPA’s signature indicated the Agency’s support and willingness to honor 

the commitments established in these agreements, provided the areas met all components of the Protocol 

and acted consistently with Agency guidance and schedules. No additional areas were allowed to enter 

into compacts after December 31, 2002. 

The EPA guidance described several features of the EAC Program: 

•	 Laid out the process by which compact areas would select control strategies based on SIP quality 

modeling that showed attainment of the 8-hour ozone standard no later than December 31, 2007; 

•	 No later than December 31, 2004 states and tribes were to submit to EPA a SIP or Tribal 

Implementation Plan consisting of the local EAC plan, including all adopted control measures, 

and a demonstration that the area will attain the 8-hour ozone standard by December 31, 2007; 

7 (1) Memorandum from Jeffrey R. Holmstead, Assistant Administrator, Office of Air and Radiation, “Schedule for 8-Hour 

Ozone Designations and its Effect on Early Action Compacts,” 

http://www.epa.gov/ttn/naaqs/ozone/eac/designation_eac_20021114.pdf, November 14, 2002 and (2) Memorandum from 

Lydia N. Wegman, Director, Air Quality Strategies and Standards Division, Office of Air Quality Planning and Standards, 

‘‘Early Action Compacts (EACs): The June 16, 2003 Submission and Other Clarifications,’’ 

http://www.epa.gov/ttn/naaqs/ozone/eac/6-16-2003_eac_milestone_memo.pdf, April 4, 2003. 

8

The 1-hour ozone standard is attained when the expected number of days per calendar year with maximum hourly average 

concentrations above 0.12 parts per million is equal to or less than 1 (see 40 CFR part 50.9 and Appendix H). 

9

The 1997 8-hour ozone standard is met when the 3-year average of the annual fourth-highest daily maximum 8-hour average 

ozone concentration is less than or equal to 0.08 ppm 1 (see 40 CFR part 50.9 and Appendix I). 

14 
•	 Indicated that all compact areas were to submit a local plan by March 31, 2004 that included 

measures that were specific, quantifiable, permanent, and that, if approved into the SIP by EPA, 

would be federally enforceable 

o	 The March 31, 2004 submission had to include specific implementation dates for the local 

controls, as well as detailed documentation supporting the selection of measures 

o	 Deadline for plan submission was approximately 30 months earlier than would have 

otherwise been required by the CAA; 

•	 Local controls were to be implemented by the 2005 ozone season (or no later than December 31, 

2005). This deadline was at least 16 1⁄2 months earlier than would have otherwise been required 

by the CAA; and 

•	 Reports were to be submitted every six months to describe progress toward completion of
 

milestones. 


o	 In June 2006, compact areas were to submit a report to EPA that described the 

implementation of control measures, as well as an assessment of reductions in emissions 

and resultant improvement in air quality. 

EPA EAC guidance10 with respect to the attainment demonstrations due by December 2004 indicated that 

state and local agencies should do the following: 

•	 Follow the most recent OAQPS modeling guidance (“Draft Guidance on the Use of Models and 

Other Analyses in Attainment Demonstrations for the 8-hour Ozone NAAQS,” May 1999, EPA454/R-99-004); 

•	 Model most current emissions inventory, preferably 2002 (however, if 2002 was not available, use 

of a 1999 or later inventory for EAC modeling was acceptable); 

•	 Base 2007 projections on 1999 emissions inventory or later; 

•	 Use MOBILE6 in both the current and future inventories; 

•	 Select episodes representative of the area’s ozone problem; and 

•	 Use appropriate assumptions and emissions analysis techniques in quantifying emissions
 

reductions. 


Table 1-1 describes the milestones and submissions that compact areas were to complete to continue 

eligibility for a deferred effective date of the nonattainment designation for the 8-hour ozone standard, 

which is further described in Section 1.4 below. (The EAC milestones and requirements were issued as a 

regulation on April 30, 2004.11) 

10 (1) Memorandum from Lydia N. Wegman, Director, Air Quality Strategies and Standards Division, Office of Air Quality
 

Planning and Standards, ‘‘Early Action Compacts (EACs): The June 16, 2003 Submission and Other Clarifications,’’
 

http://www.epa.gov/ttn/naaqs/ozone/eac/6-16-2003_eac_milestone_memo.pdf, April 4, 2003; (2) “Draft Guidance on the Use
 

of Models and Other Analyses in Attainment Demonstrations for the 8-Hour Ozone NAAQS,” U.S. Environmental Protection
 

Agency, EPA-454/R-99-004, May 1999; and (3) “Frequently Asked Questions on Implementing the DRAFT 8-Hour Ozone
 

Modeling Guidance to Support Attainment Demonstrations for Early Action Compact (EAC),” U.S. Environmental Protection
 

Agency, http://www.epa.gov/scram001/guidance/guide/eac-ozone.pdf.
 11 “8-Hour Ozone National Ambient Air Quality Standards; Final Rules,” 69 Federal Register 23858-23951, 23875-76,
 

http://www.epa.gov/ttn/naaqs/ozone/eac/fr_69(84)_23858.pdf, April 30, 2004; and 40 Code of Federal Regulations 81.300(e).
 

15 
Table 1-1: EAC Milestones
 

Compact Milestone Submittal Date 

Submit Compact for EPA signature. December 31, 2002 

Submit preliminary list and description of 

potential local control measures under 

consideration. 

June 16, 2003 

Submit complete local plan to state (includes 

specific, quantified and permanent control 

measures to be adopted). 

March 31, 2004 

State submits adopted local measures to EPA 

as a SIP revision that, when approved, will be 

federally enforceable. 

December 31, 2004 

Implement SIP control measures. 2005 ozone season (or no later than December 31, 2005) 

State reports on implementation of measures 

and assessment of air quality improvement 

and reductions in NOx and VOC emissions to 

date. 

June 30, 2006 

Area attains 8-hour ozone NAAQS. December 31, 2007 

Source: “Air Quality Designations and Classifications for the 8-Hour Ozone National Ambient Air 

Quality Standards; Early Action Compact Areas with Deferred Effective Dates,” 69 Federal 

Register 23858-23951, 23865, http://www.epa.gov/ttn/naaqs/ozone/eac/fr_69(84)_23858.pdf, April 

30, 2004. 

1.3 Areas that Participated in the EAC Program 

Many areas were interested in participating in the EAC Program. Some areas that showed initial interest 

decided not to pursue participation in the program or were ineligible for different reasons such as the 

applicant could not meet the deadline (December 2002) for submitting a signed compact agreement or 

their application did not meet all of the criteria described in EPA guidance. Thirty-one areas from 12 

states submitted signed compact agreements by December 2002 and 29 of those areas ultimately 

participated fully in the program (two areas withdrew from the program prior to submitting an EAC SIP). 

Table 1-2 lists all of the participating areas at the end of the program. Fourteen of those areas were 

“nonattainment-deferred” which meant that EPA would have designated them nonattainment with an 

effective date of June 15, 2004 had they not participated in the EAC Program. Fifteen of the areas that 

participated were designated “attainment” with an effective date of June 15, 2004. The nonattainmentdeferred areas were in the mid-Atlantic and southeastern regions, except for San Antonio, Texas. Nine of 

the 15 attainment areas were in the southeast, eight of which were in South Carolina. The remaining six 

areas were spread across Texas, Oklahoma, New Mexico and Louisiana. 

16 
Table 1-2: Twenty-Nine Participating EAC Program Areas
 

Nonattainment Deferred Areas (14) Attainment Areas (15) 

Berkeley and Jefferson Counties, West Virginia Austin, Texas 

Chattanooga, Tennessee-Georgia Berkeley-Charleston-Dorchester, South Carolina 

Columbia, South Carolina (Central Midlands Area) Catawba, South Carolina 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado Longview/Northeast, Texas 

Fayetteville, North Carolina (Cumberland County) Low Country, South Carolina 

Frederick County, Virginia Lower Savannah-Augusta, South Carolina-Georgia 

Greensboro-Winston Salem-High Point, North Carolina 

(Triad Area) 

Mountain Area of Western North Carolina 

(Asheville) 

Greenville-Spartanburg-Anderson, South Carolina 

(Appalachian Area) 

Oklahoma City, Oklahoma 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) Pee Dee, South Carolina 

Johnson City-Kingsport-Bristol, Tennessee San Juan County, NM 

Nashville, Tennessee Santee Lynches, South Carolina 

Roanoke, Virginia Shreveport/Bossier City, LA 

San Antonio, Texas Tulsa, Oklahoma 

Washington County, Maryland (Hagerstown) Upper Savannah Abbeville-Greenwood, South 

Carolina 

Waccamaw, South Carolina 

Source: http://www.epa.gov/ttn/naaqs/ozone/eac/index.htm#EAC_Main. 

1.4 Action EPA Undertook To Defer the Effective Date of Nonattainment Designation for the EAC 

Areas 

At the time EPA designated areas for the 8-hour ozone standard in April 2004,12 EPA took final action 

deferring the effective date until September 30, 2005 of the nonattainment designation for the 14 

participating compact areas that were monitoring a violation of the 8-hour ozone standard. The EPA took 

action because all terms of the agreement continued to be met up to that point, including timely 

completion of all compact milestones and reports. Subsequently, through notice-and-comment 

rulemaking, EPA further deferred the effective date, based upon a determination that the areas continued 

to meet all compact milestones the time of the action. Table 1-3 provides the deferred effective date 

adopted in each of the Federal Register actions for the 14 areas. 

Table 1-3 also includes the effective dates that were specific to the Denver, Colorado EAC Program area. 

On November 29, 2006, EPA extended the deferred effective date for Denver from December 31, 2006 to 

July 1, 2007. In that final rulemaking, EPA noted that it would further extend the deferred effective date 

to as late as April 15, 2008, which was the then-applicable effective date for the other 13 areas, once 

Denver addressed certain issues with its EAC. The action extending the deferral to July 2007 was 

challenged by Rocky Mountain Clean Air Action (RMCAA), which had also challenged the August 16, 

2007 deferral as it applied to the Denver EAC Program Area. EPA issued a short further deferral to 

preserve the status quo as settlement discussion with RMCAA continued, extending the deferral date 

from July 1, 2007 to September 14, 2007. At the conclusion of settlement discussions, EPA extended the 

deferral of the effective date to November 20, 2007. Because EPA determined that the Denver area 

violated the 0.08 ppm, 8-hour ozone NAAQS based on air quality data from 2005 through the first three 

12 “8-Hour Ozone National Ambient Air Quality Standards; Final Rules,” 69 Federal Register 23858-23951, 

http://www.epa.gov/ttn/naaqs/ozone/eac/fr_69(84)_23858.pdf, April 30, 2004; and in subsequent Federal Register notices 

provided on http://www.epa.gov/ttn/naaqs/ozone/eac/index.htm#RMNotices. 

17 
quarters of 2007, the nonattainment designation for the Denver EAC was not further extended and it took 

effect on November 20, 2007. After concluding that the remaining 13 EAC Program areas had attained 

the 8-hour ozone NAAQS based on air quality data from 2005-2007, on March 27, 2008 the EPA 

Administrator signed a final action designating those 13 EAC Program areas as attainment, effective 

April 15, 2008.13 

Table 1-3: EPA Actions Deferring Effective Date of Nonattainment Designation 

Deferral Final Rule Date 

(EPA Administrator Signature) 

Deferred Effective Date 

1st April 15, 2004 September 30, 2005 

2nd August 16, 2005 December 31, 2006 

3rd November 22, 2006 April 15, 2008 

July 1, 2007 (Denver, Colorado) 

4th June 22, 2007 September 14, 2007 (Denver, 

Colorado) 

5th September 14, 2007 November 20, 2007 (Denver, Colorado) 

Source: http://www.epa.gov/ttn/naaqs/ozone/eac/index.htm#EAC_Main. 

1.5 How EPA Addressed Compact Areas Attaining the 8-Hour Ozone Standard in April 2004 

Compact areas not violating the 8-hour ozone standard based on the most recent air quality data available 

(generally data from 2001–2003) were designated unclassifiable/attainment in the April 2004 designation 

action and the unclassifiable/attainment designation became effective on June 15, 2004. EPA encouraged 

unclassifiable/attainment areas that had joined the EAC Program to continue to develop clean air plans 

and to remain committed to the compact program to ensure air quality remained clean. Seventeen such 

areas decided to participate in the program; however, two areas (Haywood County, Tennessee and 

Putnam County, Tennessee) later withdrew from the program. If an area designated 

unclassifiable/attainment in April 2004 participating in the EAC Program subsequently violated the 8­

hour ozone standard during the term of the compact, EPA had the discretion (under section 107(d)(3) of 

the CAA) to redesignate the area to nonattainment, as it does with any unclassifiable/attainment areas 

following designations. 

1.6 Concerns About and Legal Challenges to the EAC Program 

A number of environmental groups and states had significant concerns with the EAC program. This 

section describes concerns expressed by outside parties in formal comments on EPA Federal Register 

actions, EPA’s response to them and the chronology of events concerning legal challenges to the EAC 

program. 

Many commenters on EPA’s initial designations notice expressed support for the compact process, the 

goal of clean air sooner, the incentives and flexibility the program provides for encouraging early 

reductions of ozone-forming pollution, and the deferred effective date of nonattainment designation.14 

13 “Final 8-Hour Ozone National Ambient Air Quality Standards Designations for the Early Action Compact Areas,” 64
 

Federal Register 17897, http://www.epa.gov/ttn/naaqs/ozone/eac/fr20080327_eac.pdf, April 2, 2008.
 14 “Deferral of Effective Date of Nonattainment Designations for 8-Hour Ozone National Ambient Air Quality Standards for
 

Early Action Compact Areas,” 68 Federal Register 70108-70119,
 

http://www.epa.gov/ttn/naaqs/ozone/eac/fr_68(241)_70108.pdf, December 16, 2003. See “Response to Public Comments—
 

Early Action Compacts for Implementing the 8-hour Ozone National Ambient Air Quality Standards for Early Action
 

Compact Areas,” Docket No. OAR-2003-0090-0278, April 15, 2004.
 

18 
However, a number of commenters opposed the EAC program. Several of these commenters expressed 

concern about the legality of the program and primarily about the deferral of the effective date of the 

nonattainment designation for these areas. Although all of these commenters were supportive of the goal 

of addressing proactively the public health concerns associated with ozone pollution, the commenters 

stated that the EAC program was not authorized by the CAA. All of these commenters indicated that 

EPA lacked authority under the CAA to defer the effective date of a nonattainment designation. In 

addition, these commenters stated that EPA lacked the authority to enter into EACs and lacked authority 

to allow areas to be relieved of obligations under title I, part D of the CAA while these areas were 

violating the 8-hour ozone standard or were designated nonattainment for that standard. 

In response, EPA continued to believe that the compact program, as designed, will give local areas the 

flexibility to develop their own approach to meeting the 8-hour ozone standard, provided the participating 

communities are serious in their commitment to control emissions from local sources earlier than the 

CAA would otherwise require. By involving diverse stakeholders, including representatives from 

industry, local and state governments, and local environmental and citizens’ groups, a number of 

communities were discussing for the first time the need for regional cooperation in solving air quality 

problems that affect the health and welfare of its citizens. EPA stated that people living in these areas 

that realize reductions in pollution levels sooner will enjoy the health benefits of cleaner air sooner than 

might otherwise occur. In the April 2004 rule EPA codified the specific requirements in part 81 of the 

CFR to clarify what is required of compact areas to be eligible for deferral of the effective date of their 

nonattainment designation and what actions EPA intends to take in response to areas that meet the 

milestones and areas 

In addition, in response to environmental groups’ concerns, the EPA entered into discussions with those 

environmental groups. The EPA sought to address their concerns by incorporating several safeguards 

into the program to ensure the accountability of EPA and participating state and local agencies. The 

safeguards included: bi-annual progress reports; periodic milestones; and, requiring state and local 

agencies to identify measures that would produce meaningful emissions reductions. 

Several parties filed a lawsuit claiming EPA had not designated areas within the timeframe required by 

the CAA. In a March 13, 2003 consent decree between EPA and the parties who filed the challenge, the 

EPA agreed to sign a notice by April 15, 2004 promulgating the 8-hr ozone designations and to publish 

that action by April 30, 2004. In addition, the environmental groups and EPA agreed to meet periodically 

to discuss ways to encourage areas that approach or monitor minimal exceedances of the 8-hr standard to 

develop and implement early action plans offering a more expeditious time line for achieving emission 

reductions. 

Upon promulgation of the 8-hour area designations, several environmental groups and some of the 

Northeastern states filed suit challenging EPA’s deferral of the effective date of designation for the EAC 

areas. American Lung Assoc., et al., v. EPA (D.C. Cir. No. 04-1275). These same parties challenged 

each of the subsequent actions further deferring the effective date of designation and those subsequent 

cases were consolidated with the first. In addition to these actions by national environmental groups and 

Northeastern states noted above, RMCAA sued EPA specifically on the deferral for Denver, Colorado 

from November 29, 2006 to July 1, 2007. RMCAA v. EPA (D.C. Cir. 07-1012). As noted above, on 

November 29, 2006, EPA deferred designations for 13 EAC areas until April 15, 2008. EPA deferred the 

designation for Denver only until July 1, 2007, as it had not yet completed all of the necessary 

rulemaking. Subsequently, the measures were adopted. EPA settled the suit with RMCAA in 2007, by 

19 
which time Denver had measured a violation that ultimately resulted in the nonattainment designation 

taking effect on November 20, 2007. RMCAA had several comments15 on EPA’s proposed deferral of 

Denver’s nonattainment designation, including: 

•	 2006 ozone levels have risen to unhealthy levels; 

•	 Denver EAC has fallen short of achieving reductions in ozone precursors; 

•	 Nowhere does the CAA allow deferrals of nonattainment designations; and 

•	 If Denver violates the 8-hour ozone NAAQS in 2007, there is nothing that triggers an automatic 

nonattainment designation. 

1.7 Federal Emissions Control Programs that Have Helped Improve Air Quality in EAC Areas 

Amid the concerns and challenges discussed in the prior section, the EAC Program moved forward and 

was implemented with all but one of the 29 participating areas attaining the 1997 ozone NAAQS by the 

December 2007 deadline. The EAC areas were aided in reducing their ozone levels to a significant 

degree, as is true for many other ozone areas in the country, by implementation of several Federal 

programs to reduce emissions of NOx, and to some degree VOCs. These programs include: 

•	 NOx SIP Call16 

o	 Compliance dates 2004-2007, depending on the state 

o	 Set NOx budgets for electrical generation units, large industrial boilers, cement kilns and 

turbines in 20 Eastern states and Washington, D.C. 

o	 NOx reductions of 880,000 tons per ozone season by 2007; 

•	 Tier 2 Vehicle and Gasoline Sulfur Program17 

o	 Compliance dates 2004 for gasoline sulfur content and 2004–2009 for phase-in of new 

vehicle standards by model year 

o	 Covered gasoline sold nationwide and cars, light-duty trucks, and certain size sport utility 

vehicles sold outside California 

o	 Reduces NOx and VOC emissions; and 

•	 New Source Performance Standard and Emission Guidelines for Waste Combustion18 

o	 Compliance date 2005 

o	 Covered certain incinerators and municipal waste combustors nationwide 

o	 Reduced NOx emissions by 16,283 tons per year in 2006. 

These and other Federal programs helped to reduce ozone in the EAC Program areas – both locallyformed and transported ozone. Figure 1-1 provides a visual display of the benefit to ozone air quality for 

15 “Final Extension of the Deferred Effective Date for 8-Hour Ozone National Ambient Air Quality Standards for the Denver
 

Early Action Compact: Proposed Rule,”
 

http://www.epa.gov/ttn/naaqs/ozone/eac/fr_20070301_72(40)_9285_eac_4extend_deferred_date.pdf , March 1, 2007; Docket
 

No. EPA–HQ–OAR–2003–0090, comment submitted by Jeremy Nichols, Director, Rocky Mountain Clean Air Action, April
 

2, 2007.
 

16 “Finding of Significant Contribution and Rulemaking for Certain States in the Ozone Transport Assessment Group Region
 

for Purposes of Reducing Regional Transport of Ozone,” 63 Federal Register 57356,
 

http://www.epa.gov/ttn/naaqs/ozone/rto/sip/index.html, October 27, 1998.
 17 “Control of Air Pollution From New Motor Vehicles: Tier 2 Motor Vehicle Emissions Standards and Gasoline
 

Sulfur Control Requirements,” 65 Federal Register 6698-6870, http://www.epa.gov/tier2/finalrule.htm, February 10, 2000.
 18 “Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Other Solid Waste
 

Incineration Units; Final Rule,” 70 Federal Register 74870-74924,
 

http://www.epa.gov/ttn/oarpg/t3/fr_notices/30600oswi_fr_note.pdf, December 16, 2005.
 

20 
-

-1

areas in the Eastern U.S. due, in part, to these control programs, particularly the NOx SIP Call. The figure 

shows the change in seasonal 8-hour ozone averages adjusted for weather19 from 2000-2002 to 2005­

2007. The map shows the wide range of change across the East. The range spans a one percent 

deterioration in the seasonal 8-hour ozone average to a 17 percent improvement in the seasonal 8-hour 

ozone average. The impacts of NOx reductions in the East have been assessed in three NOx Budget 

Trading Reports that have been issued from 2003 to 2006.20 See also Figure 3-1, which compares ozone 

reductions in EAC and non-EAC areas. 

Figure 1-1: Percentage Change in Seasonal 8-Hour Ozone Average Air Quality - from 2000-2002 to 2005-2007, Adjusted for Weather 

-15 -8 -11 

-7 -9 

-16 

13 

-5 

-9 

-10 

1 

-8 

-7 

-5 

-6 

-9 

-8 -16 

-5 

-5 -8

-4 

-3 

-10 

-8 

-5 

-12 

-12 

-9 

-7 

-17 

-12 

-9-10 

-4 

-2 

-10 

-8 

-11 

-11 

-7 

-4 

-11 

-11 

-2 

-16 

-10 

-8 

-7 -5

0 

-9 

-5 

-69 

-8 

-13 

-9 

-4 

-10 

-12 

-8 

-8 

-13 

-9 

-7 

-13 -11 

-12 

-8 -8 

-7 

-8 

-11 

-10 -10 

-8 

-9 

1 

-9 

-7 

-5 

-2 

-6 

-5 

-4 

-6 

-6 

-2 

-10 

-7 

-7 

-8 

1 

-7 

Source: Analysis by the Air Quality Assessment Group, OAQPS, using the method described in 

Camalier, L., Cox, W., Dolwick, P., 2007. The effects of meteorology on ozone in urban areas 

and their use in assessing ozone trends. Atmospheric Environment 41, 7127-7137. 

19 The methodology used to adjust for weather is explained in section 3.1.1. 20 http://www.epa.gov/airmarkets/progress/progress-reports.html. 

21 
SECTION 2.0 INFORMATION COMPILATION APPROACH 

This section describes the study’s information compilation approach, both quantitative and qualitative. It 

is important to note that the information compilation approach has several limitations because this report 

is not a formal program evaluation. Specifically, the study did not: 

•	 Compare emission reductions of EAC areas versus non-EAC areas in terms of both quantities and 

implementation timeframes; 

•	 Study air quality for EAC areas past 2007; and 

•	 Rigorously compare EAC areas with non-EAC areas with respect to certain key areas, such as: 

o	 Program design-related concerns (e.g., program efficiency) 

o	 Control measure implementation. 

2.1 Decision to Conduct EAC Study 

Following the conclusion of the EAC program, EPA’s OPAR and EPA’s OAQPS undertook this study of 

the EAC program in order to learn what worked well and what did not with this community-based 

program, including whether EAC Program areas attained the ozone NAAQS early. EPA’s intent was to 

then share that knowledge with leaders of programs that EPA and the states create to improve air quality 

in communities. 

2.2 Scope of the Study 

EPA staff, consulting with EPA management, determined that the quantitative component of the study 

should address all 14 of the “nonattainment deferred” and six of the 15 “attainment” EAC areas. The six 

attainment EAC Program areas were selected based on geographic diversity and availability of 

meteorological data. The attainment EAC Program areas were located in the Southeast and Southwest – 

EPA Regions 4 and 6 – so areas were selected from these two parts of the country for which 

meteorological data were available. (The availability of meteorological data was important for the air 

quality information compilation because it was needed in order to be able to remove the effects of 

weather when examining changes in seasonal 8-hour ozone air quality. Section 2.3.1 below provides a 

description of how the meteorological adjustments were made.) Qualitatively, the study addressed all 29 

areas primarily by consulting state and local agencies from all 12 states that participated in the program, 

as well as six of the 14 nonattainment-deferred areas and three of the 15 attainment areas that also 

participated in the program. Information and observations from these discussions have been generalized 

and extrapolated to all EAC Program areas. To provide a qualitative comparison for these areas, two 

non-EAC Program areas and the states in which they are located were also consulted. 

Table 2-1 provides a list of the 20 areas that were included in the study, along with their 2001-2003 8­

hour ozone design values (DVs), 2001 population and vehicle miles traveled (VMT) and a breakout of 

NOx and VOC emissions. (Appendix D also provides a brief profile of the 20 areas. More detailed 

information on population and VMT for the states in which these 20 areas are located can be found in 

Appendix B, Tables B-27 to B-30.) 

Of the 14 nonattainment-deferred areas, some are rural with lower populations, such as Frederick County, 

Virginia, while others are medium sized – Chattanooga, Tennessee – and yet others are larger – Denver, 

Colorado and San Antonio, Texas. Eight-hour ozone DVs for 2001-2003 for the 14 areas were relatively 

close to the level of the 1997 standard with only one area above 0.090 ppm: Greensboro, North Carolina 

at 0.093 ppm. The mix of NOx and VOC emissions varies from area to area. 

22 
Of the six attainment areas, one is rural with lower populations – Mountain Area of Western North 

Carolina (Asheville) – while three others are medium sized – Lower Savannah-Augusta, South CarolinaGeorgia – and yet two others are larger – Austin, Texas and Oklahoma City, Oklahoma. Eight-hour 

ozone DVs for 2001-2003 for the six areas were at or below the level of the 1997 standard with two areas 

at 0.072 ppm or less. The balance among NOx emissions sources and among VOC emission source types 

varies from area to area. 

2.3 Refining the Study Scope 

As the study scope was determined, EPA staff, consulting with EPA management, refined it by 

identifying the key areas the study would address. The following two subsections capture the essential 

issues that the study included. 

2.3.1 Environmental Aspects of Study 

Changes in Air Quality 

The study analyzed changes in air quality in EAC Program areas (improvements or deteriorations), both 

not controlling and controlling for meteorology. One of the purposes of the study was to determine 

whether those changes were more, less, or the same as neighboring areas. The study also sought to 

determine what accounted for the changes. 

Estimated Emissions Reductions from Control Measures 

This study looked at to what degree “local” EAC measures contributed to any improvements in air quality 

in EAC Program areas. In addition, the following issues were investigated: 

•	 What control measures (and how many of the total) had emissions reductions associated with 

them (and which did not) and how large were they; 

•	 Which measures provided the greatest or least for overall emission reductions and the modeled 

attainment demonstration; 

•	 Were all control measures actually implemented as required of the states; 

•	 Were there environmental benefits as a direct result of the EAC activities for pollutants other than 

ozone; and 

•	 Did areas implement temporary control measures that were later discontinued. 

23 
Table 2-1: Population, 8-Hour DVs and Emissions Information for the 20 Areas
 

Included in this Study for Which Quantitative Information was Compiled
 

EAC Program Area 2002 

Population* 

2002 

VMT* 

2001-2003 

DV (ppm) 

2002 Emissions 

NOx VOC Source Type 

Nonattainment Deferred Areas 

Berkeley and Jefferson 

Counties, West Virginia 

126,357 1,279 0.086 30% 3% Point 

7% 52% Area 

37% 33% Highway 

Vehicles 

27% 12% Off Highway 

Vehicles 

Chattanooga, TennesseeGeorgia 466,775 4,976 0.088 9% 6% Point 

6% 44% Area 

63% 37% Highway 

Vehicles 

22% 13% Off Highway 

Vehicles 

Columbia, South Carolina 

(Central Midlands Area) 

611,932 7,208 0.089 35% 9% Point 

6% 50% Area 

46% 27% Highway 

Vehicles 

13% 13% Off Highway 

Vehicles 

Denver-Boulder-GreeleyFort Collins-Loveland, 

Colorado 

2,970,672 24,081 0.087 28% 37% Point 

5% 26% Area 

49% 26% Highway 

Vehicles 

18% 12% Off Highway 

Vehicles 

Fayetteville, North 

Carolina (Cumberland 

County) 

304,094 2,780 0.087 7% 9% Point 

5% 40% Area 

73% 42% Highway 

Vehicles 

15% 9% Off Highway 

Vehicles 

Frederick County, Virginia 87,282 1,136 0.085 4% 16% Point 

17% 40% Area 

63% 23% Highway 

Vehicles 

16% 21% Off Highway 

Vehicles 

Greensboro-Winston 

Salem-High Point, North 

Carolina (Triad Area) 

1,471,869 16,351 0.093 47% 14% Point 

3% 50% Area 

40% 27% Highway 

Vehicles 

10% 9% Off Highway 

Vehicles 

24 
Table 2-1: Population, 8-Hour DVs and Emissions Information for the 20 Areas
 

Included in this Study for Which Quantitative Information was Compiled
 

EAC Program Area 2002 2002 2001-2003 2002 Emissions 

Population* VMT* DV (ppm) NOx VOC Source Type 

Greenville-Spartanburg­ 1,053,490 10,887 0.087 13% 8% Point 

Anderson, South Carolina 10% 58% Area 

(Appalachian Area) 59% 23% Highway 

Vehicles 

18% 11% Off Highway 

Vehicles 

Hickory-Morganton­ 348,968 3,003 0.088 60% 37% Point 

Lenoir, North Carolina 3% 31% Area 

(Unifour Area) 27% 23% Highway 

Vehicles 

9% 9% Off Highway 

Vehicles 

Johnson City-Kingsport­ 408,857 3,887 0.086 67% 33% Point 

Bristol, Tennessee 3% 36% Area 

23% 24% Highway 

Vehicles 

8% 7% Off Highway 

Vehicles 

Nashville, Tennessee 1,269,605 15,876 0.086 21% 13% Point 

4% 36% Area 

58% 35% Highway 

Vehicles 

18% 16% Off Highway 

Vehicles 

Roanoke, Virginia 235,494 2,487 0.085 14% 6% Point 

14% 53% Area 

58% 34% Highway 

Vehicles 

14% 7% Off Highway 

Vehicles 

San Antonio, Texas 1,654,839 14,967 0.089 28% 2% Point 

8% 50% Area 

49% 34% Highway 

Vehicles 

15% 14% Off Highway 

Vehicles 

Washington County, 134,700 1,886 0.086 30% 5% Point 

Maryland (Hagerstown) 7% 51% Area 

48% 33% Highway 

Vehicles 

15% 12% Off Highway 

Vehicles 

25 
Table 2-1: Population, 8-Hour DVs and Emissions Information for the 20 Areas
 

Included in this Study for Which Quantitative Information was Compiled
 

EAC Program Area 2002 

Population* 

2002 

VMT* 

2001-2003 

DV (ppm) 

2002 Emissions 

NOx VOC Source Type 

Attainment EAC Program Areas 

Austin, Texas 1,347,464 13,088 0.084 14% 2% Point 

7% 48% Area 

57% 34% 

Highway 

Vehicles 

22% 17% 

Off Highway 

Vehicles 

Berkeley-CharlestonDorchester, South Carolina 

562,579 5,649 0.072 48% 10% Point 

3% 46% Area 

20% 23% Highway 

Vehicles 

29% 21% Off Highway 

Vehicles 

Mountain Area of Western 

North Carolina (Asheville) 

285,431 3,115 0.083 44% 12% Point 

3% 38% Area 

43% 35% 

Highway 

Vehicles 

9% 15% 

Off Highway 

Vehicles 

Oklahoma City, Oklahoma 1,107,167 13,793 0.080 13% 4% Point 

12% 45% Area 

59% 39% 

Highway 

Vehicles 

15% 11% 

Off Highway 

Vehicles 

Lower Savannah-Augusta, 

South Carolina-Georgia 

594,875 6,790 0.067 46% 11% Point 

6% 55% Area 

37% 26% 

Highway 

Vehicles 

11% 9% 

Off Highway 

Vehicles 

Tulsa, Oklahoma 819,321 10,639 0.083 43% 4% Point 

10% 52% Area 

35% 30% 

Highway 

Vehicles 

12% 13% 

Off Highway 

Vehicles 

Source: U.S. Census, 2002 National Emissions Inventory, and Air Quality System 

*For four areas the population and VMT estimates are for whole counties even though only a 

partial county was part of the EAC Program: Mountain Area of Western North Carolina 

(Asheville); Columbia, South Carolina (Central Midlands Area); Denver-Boulder-Greeley-Fort 

Collins-Loveland, Colorado; and Hickory-Morganton-Lenoir, North Carolina (Unifour Area). 

26 
Air Quality Modeling for EAC SIPs 

The study addressed three issues with respect to the air quality modeling work states performed as part of 

their EAC SIPs: 

•	 Whether the modeling could provide any insight into what degree “local” EAC measures
 

contributed to any improvements in air quality in EAC Program areas;
 

•	 Did the air quality modeling predict attainment with or without the local EAC measures; and 

•	 Were the air quality improvements projected in the state’s EAC modeling achieved or did the 

observed air quality improvements exceed the air quality improvements projected in the state’s 

EAC modeling. 

Growth-Related Aspects of the Study 

There was interest in studying the impact on EAC Program areas of not requiring the Nonattainment NSR 

and Conformity Programs in EAC areas, both of which address growth in emissions. However, because 

of the complexity of the programs, it was decided such an analysis was beyond the scope of this effort 

and that it would require a separate study. So, instead, the study focused on a limited scope: 

•	 Determining whether the extent of new source activity that occurred in the 14 nonattainmentdeferred EAC Program areas that may have been subject to the Nonattainment NSR Program had 

the areas been designated nonattainment; 

•	 Determining which of the 14 nonattainment-deferred EAC Program areas were subject to the 

Conformity Program for other reasons even though they were participating in the EAC Program 

for ozone; and 

•	 Displaying changes in estimated population and VMT during EAC Program implementation. 

2.3.2 Program Design Aspects of the Study 

Efficiency of EAC Program 

The study addressed the issue of whether the EAC model is just as efficient at producing clean air as the 

traditional nonattainment designation approach. This issue was approached by: (1) studying the resource 

aspect of this question for EPA regions and headquarters, and for state and local agencies; and, (2) asking 

whether all states and areas met their process-related goals and requirements. This study also addresses 

whether the compact agreements gave local areas flexibility to develop their own approach to meeting the 

8-hour ozone standard. Additionally, the study asks whether the program would have succeeded without 

the threat of nonattainment designation for those areas with deferred nonattainment designations. 

Longer Term Impact 

The study addressed whether EAC activities: (1) will result in longer-term emission reductions or 

continued reductions in ozone and air quality improvement activities and policies into the future; and, (2) 

provide for or create a local "infrastructure" for further or continued action in the future through, for 

example, the creation of an organizational entity in the local area. 

Outreach and Stakeholder Interaction 

The study addressed whether the compacts were successful at engaging and involving stakeholders at the 

local level. In addition, the study addressed whether there were any intangible information from 

27 
stakeholder engagement. It was also important to gain an understanding of how successful the outreach 

programs were in EAC Program areas. 

Other Aspects of the Program 

The study also addressed how the requirements for the EAC Program areas compare to the requirements 

the areas would have faced as traditional nonattainment areas. 

2.4 Information Compilation 

Table 2-2 provides a breakout of the EAC Program aspects and areas included in the study and whether it 

was quantitative or qualitative. To understand the table, it is important to note that the study’s 

quantitative information focused on 20 areas (of the 29 total EAC areas), while the qualitative 

information addressed all 29 areas. The qualitative study was conducted through discussions with all 12 

states in the program and nine of the 29 EAC Program areas. The information from those discussions 

was generalized to all 29 areas. 

The following two subsections provide an overview of how the study was conducted for the 14 

nonattainment-deferred EAC Program areas and the six attainment EAC Program areas that were 

included. 

2.4.1 Quantitative Information Compilation 

For environmental aspects of the study, the quantitative information addressed: 

• Changes in air quality; 

• Estimated emissions reductions from control measures; 

• Air quality modeling for EAC SIPs; and 

• Growth-related aspects of the study. 

For design aspects of the study, the information compiled addressed the efficiency of the EAC Program. 

Changes in Air Quality 

The air quality information gathered came from EPA’s Air Quality System submitted by the states to 

EPA. The study looked at changes in air quality from 2001-2003 to 2005-2007 on three bases: 8-hour 

ozone DV; Air Quality Index (AQI) days above 100; and seasonal averages of daily maximum 8-hour 

ozone (not controlling and controlling for meteorology) (see Appendix B, Tables B-1 to B-4). Seasonal 

averages for meteorology were “controlled” or adjusted. The study performed meteorological 

adjustments for the 15 EAC Program areas that are located in the East (except for a few cases where data 

were not available), and, for comparative purposes, for 18 non-EAC metropolitan areas that are generally 

in the same region as these EAC Program areas. The non-EAC Program areas are a mix of attainment 

and nonattainment areas. In the Southwest, air quality comparisons were difficult to make because of a 

28 
Table 2-2: EAC Program Aspects and Areas Included in the Study, Breakout
 

of Information Compiled, and Whether it was Quantitative or Qualitative
 

Program Aspect Quantitative 

Information 

Compiled 

Qualitative 

Information 

Compiled 

Areas 

EAC Program Environmental Aspects of Study 

Changes in air 

quality 

Yes No • Quantitative information: all 20 areas (except 

for cases where meteorological data were not 

available) 

Estimated emissions 

reductions from 

control measures 

Yes Yes • Quantitative information: all 20 areas 

• Qualitative information: all 29 areas (able to 

generalize information to all areas by consulting 

all 12 states in the program and nine of the 29 

EAC Program areas) 

Air quality modeling 

for EAC SIPs 

Yes No • Quantitative information: all 20 areas 

Growth-related 

aspects of the study 

Yes Yes • Quantitative information: all 20 areas 

• Qualitative information: 14 of the 20 areas 

EAC Program Design Aspects of the Study 

Efficiency of EAC 

Program 

Yes Yes • Qualitative information: all 29 areas (for 

estimation of EPA resources for EAC Program 

versus traditional approach) 

• Qualitative information: all 29 areas (able to 

generalize information to all areas by consulting 

all 12 states in the program and nine of the 29 

EAC Program areas) 

Longer term impact No Yes • Qualitative information: all 29 areas (able to 

generalize information to all areas by consulting 

all 12 states in the program and nine of the 29 

EAC Program areas) 

Outreach and 

stakeholder 

interaction 

No Yes • Qualitative information: all 29 areas (able to 

generalize information to all areas by consulting 

all 12 states in the program and nine of the 29 

EAC Program areas) 

Other aspects of the 

program 

No Yes • Qualitative information: all 29 areas (able to 

generalize information to all areas by consulting 

all 12 states in the program and nine of the 29 

EAC Program areas) 

29 
lack of monitoring sites with meteorologically controlled air quality data that were close enough to the 

EAC Program areas. Therefore, the study was not able provide a review of how those air quality gains in 

that region compare to other non-EAC ozone areas in the same region. The study did not compare two 

individual cities because it is very difficult to determine if they are comparable. Comparing the range of 

reductions between two groups is more reasonable, as the study did for areas in the East. 

Meteorological adjustments of the data pertain to how weather differences from day-to-day and across 

years can cause substantial differences in monitored ozone concentrations, even when emissions are not 

changing. This can obscure the changes in ozone that are rightly attributable to emissions reductions 

achieved by control strategies like those included in the EAC and standard ozone SIPs. Therefore, it is 

useful to adjust monitored ozone concentrations for meteorological effects. The methodology uses a 

generalized linear model is used to describe the relationship between daily ozone and several 

meteorological parameters. The model also accounts for the variation in seasonal ozone across different 

years by correcting for meteorological fluctuations between those years. The most important 

meteorological parameters considered in this model are daily maximum 1-hour temperature and midday 

(10 a.m. to 4 p.m.) relative humidity. This model is estimated or fitted for individual metropolitan areas 

of interest, where the necessary ozone and meteorological data sets were both available. Once the 

parameters (i.e., coefficients) have been estimated using daily data, the model produces an estimate of 

what the seasonal average daily 8-hour maximum would have been in a given year if that year had had 

typical weather conditions combined with its actual emissions. This methodology and the subsequent 

ozone estimates are provided by EPA’s OAQPS, Air Quality Assessment Division.21 

Estimated Emissions Reductions from Control Measures 

The emission reductions information compilation had two features: 

First, information was gathered from the EAC SIPs in several areas to compile a complete list of 

measures, including any prospective emission reduction estimates provided by the states in their SIPs for 

local, state and national (Federal) measures (see Tables B-6 to B-26). For this part of the study, local 

measures were defined as measures adopted locally by a local body or authority, as well as measures 

adopted by the state that applied specifically to that area. (State measures were measures adopted by 

states that apply in more than one area in a state and national (Federal) measures were measures adopted 

by EPA that apply nationally or in a sub-region of the country.) In addition, where possible, the 

quantified emission reduction from each EAC SIP measure was compared as a percentage to the total 

reductions for all such measures in the same SIP, as well as to the total 2002 NOx and VOC emissions in 

the EAC Program areas from the 2002 National Emissions Inventory. This was done in an attempt to 

convey the relative air quality importance of the various measures. 

There are at least two important limitations to what can be discerned from the estimates in Tables B-6 to 

B-26: 

1) Estimating emissions reductions is inherently uncertain. 

21 The method used is described in: “The effects of meteorology on ozone in urban areas and their use in assessing ozone 

trends,” Atmospheric Environment 41, 7127-7137, Camalier, L., Cox, W., Dolwick, P., 2007. See additional resources on 

meteorological adjustment of ozone air quality on: http://www.epa.gov/air/airtrends/weather.html. 

30 
o	 For the local measures, the limitations include the inherent uncertainty of estimating 

emissions reductions from non-traditional sources and strategies on which the EAC 

Program areas relied for local measures. 

2)	 The percentages must be studied carefully when comparing the reductions for each measure (or 

groups of measures) to total reductions for all the measures. In some of the EAC SIPs, the 

denominator for the percentages (total quantified emissions reductions from listed EAC SIP 

measures) may not be a completely consistent benchmark because it may not reflect every state 

and national measure that contributed to air quality improvement. 

o	 For the Federal measures, the study calculated a rough estimate of the emissions 

reductions from Federal measures. This is reflected in Tables B-6 to B-26 (or “other” 

Federal measure emission reductions in the case of the two areas where some Federal 

measures were quantified). 

�	 The study employed an approach for developing the estimates that is described in 

Appendix C. 

o	 The approach was to calculate the total emissions reductions assumed in the modeled 

attainment demonstration and to subtract from that the quantified state and local measures 

in the attainment demonstration (as well as some national measures that were quantified in 

two areas). 

o	 Providing the estimates of Federal measure emission reductions helps to address the 

concern with respect to the percentages by making the denominators more reflective of all 

the measures that benefited the areas. 

o	 Having as accurate a denominator as possible is important to avoid overstating or 

understating the percentage contributions of local, state and national measures. 

o	 In an extreme case, a hypothetical SIP that explicitly listed only one small local measure 

would calculate that measure’s percentage as 100 percent of total quantified emissions, 

possibly giving the impression that the measure was important to air quality progress in 

the area when it may not have been. 

o	 Another example of the misimpression that can be taken from these percentages is the 

hypothetical case of a SIP that contains 100 local measures each with equal and large 

emissions reductions; those measures would each only score 1 percent. 

Second, the study also put the magnitude of the emission reductions in the EAC Program areas’ SIPs into 

perspective by comparing the total quantified NOx and VOC emission reductions estimates in the EAC 

SIPs to: 

•	 Total 2002 NOx and VOC emissions in the EAC Program areas; 

•	 Total 2002 NOx and VOC emissions in the state in which the area is located; and 

•	 Total NOx reductions from the NOx SIP call within the state in which the area is located (for states 

that were part of that program). 

The 2002 NOx and VOC emissions estimates for the EAC Program areas and for the state in which the 

area is located come from the 2002 National Emissions Inventory. The quantified NOx and VOC 

emissions estimates in the EAC SIPs used for comparative purposes are for local measures, state/national 

measures, and the two combined. 

31 
Air Quality Modeling for EAC SIPs 

To answer the questions posed with respect to air quality modeling, the study addressed the modeling 

information from EAC SIPs and then compared the information to observed air quality values. 

Growth-Related Aspects of the Study 

The study also reviewed information concerning estimates of population and VMT change from 2001 to 

2006. The population estimates came from the U.S. Census. The VMT numbers come from the National 

Emission Inventory’s VMT estimates, which are derived from the Highway Performance Monitoring 

System (HPMS). It is important to note that they are subject to significant uncertainty that can cause over 

or underestimates. HPMS was designed to collect statewide data to populate a national database that 

would be used to: (1) assess the performance and condition of the nationwide transportation system; and, 

(2) help guide national investment priorities. The sampling techniques were designed for these purposes. 

They may not be appropriate for estimating small changes in VMT in smaller geographic areas such as 

the areas included in this study. While the margin of error at the statewide and national level is acceptable 

for the purposes that HPMS was designed for, it is unclear whether the margin of error at the 

nonattainment areas scale would render the study inconclusive.22 

Other Aspects of the EAC Program 

For design aspects of the study, the quantitative information addressed the efficiency of the EAC Program 

by estimating the resources expended by EPA headquarters and regional offices for the EAC Program. 

This was compared to the level of estimated resources that would have been necessary had the EAC 

Program areas not participated in the EAC Program but instead pursued a traditional approach after being 

designated nonattainment or attainment (estimates do not include state and local agency resources). The 

resource estimates encompassed Full Time Equivalent (FTE) and the number of Federal Register actions 

and pages (including costs). Federal Register costs were calculated using the current rates due to the 

difficulty of determining historical Federal Register costs and of determining what costs apply to which 

Federal Register actions. Table B-31 provides the methodology used to develop them. The resource 

estimates for the traditional approach assume that: (1) the 14 nonattainment-deferred areas would have 

been Subpart 1 areas; and (2) the resource estimates vary depending on the size of the area. Because the 

regional resource estimates varied for the traditional approach, a range of numbers is presented. 

2.4.2 Qualitative Information Compilation 

For environmental aspects of the study, the qualitative information compiled addressed qualitative aspects 

of (1) control measure emissions reductions and (2) growth-related aspects of the study (i.e., new source 

activity, and Conformity Program applicability in the 14 nonattainment-deferred EAC Program areas 

during the implementation of the EAC Program). 

For design aspects of the study, the compilation of qualitative information addressed: 

• Efficiency of EAC Program; 

• Longer term impact; 

• Outreach and stakeholder interaction; and 

• Other aspects of the program. 

22 For more information about HPMS, visit: http://www.fhwa.dot.gov/policy/ohpi/hpms/abouthpms.htm. 

32 
 

These four program design areas were addressed in a qualitative manner because they did not lend 

themselves easily, if at all, to quantitative measurement. Ideally, for example, it would have been 

beneficial to measure the impact of the EAC Program on state and local resources by developing a 

questionnaire that measured the impact on state and local agency FTE and budgetary outlays. However, 

that was not feasible in the time given for the study, so an alternative informal discussion method was 

employed, which, nonetheless, yielded useful information. 

Information for the qualitative part of the study came from four sources: 

• The progress reports and SIPs submitted by the states and local agencies; 

• EPA and state permitting databases containing information on new source activity; 

• The four EPA regional offices that implemented the program; and 

• Discussions with staff and managers at the state and local agencies that implemented the program. 

The discussions were held with all of the air planning agencies for the 12 states involved in the EAC 

Program and with local agencies for six of the 14 areas involved in the nonattainment-deferred EAC 

Program. Appendix A provides a list of the individuals consulted. In addition, two non-EAC ozone 8­

hour nonattainment areas – Rocky Mount, North Carolina and Knoxville, Tennessee – and the air 

agencies for the states in which they are located were consulted to provide a comparison to the responses 

received with respect to the EAC Program areas. Appendix E provides a complete summary of the 

discussions that can reasonably be generalized to other EAC areas. The discussions reflect people’s 

views so, in that sense, the information gained is the view of the respective local or state agency. 

Because the state and local agency names are included in Appendix E, the individual discussion notes 

were shared with the individuals consulted as a courtesy and to provide an opportunity for any 

corrections. The discussions provided useful insights, both positive and negative, on the EAC Program. 

33 
SECTION 3.0 INFORMATION COMPILED AND OBSERVATIONS 

In this section the information compiled as part of the study is described and observations stemming from 

the information are provided. 

3.1 Information Compiled 

3.1.1 Quantitative Information 

The study produced quantitative information for both the environmental and program design aspects of 

the study. 

Environmental Aspects of the Study 

The study produced information in four areas: 

• Changes in air quality; 

• Estimated emissions reductions from control measures; 

• Air quality modeling for EAC SIPs; and 

• Growth-related aspects of the study. 

Changes in Air Quality 

Ten of the 14 nonattainment-deferred areas attained the 8-hour ozone NAAQS by December 31, 2004, 

prior to the required 2005 implementation date for the EAC control measures. All of the 14 

nonattainment-deferred areas, except Denver, Colorado, attained the 8-hour ozone NAAQS by December 

31, 2007. Five of the areas had 2005-2007 8-hour DVs at or below 0.079 ppm, while 11 were at or below 

0.083 ppm. All of the areas showed an improvement in ozone air quality from 2001-2003 to 2005-2007 

and five areas showed a 10 percent or greater improvement in their DVs. All of the areas reduced the 

number of AQI days above 100 from 2001-2003 to 2005-2007, while 10 showed a greater than 60 percent 

improvement on an AQI day basis. Thirteen of the 14 nonattainment-deferred areas showed an 

improvement in air quality from 2001-2003 to 2005-2007 on an 8-hour, meteorologically controlled 

seasonal average basis (Denver was excluded due to a lack of meteorological data). Eight of the 14 areas 

showed a 10 percent or greater improvement on that basis. (For a summary, see Table 3-1 and, for more 

details, see Tables B-1 to B-3 in Appendix B.) 

Five of the six attainment areas attained the 8-hour ozone NAAQS by December 31, 2004, prior to the 

required 2005 implementation date for the EAC control measures. All six attainment areas included in 

the study attained the 8-hour NAAQS as of December 31, 2007 and all had 2005-2007 8-hour DVs at or 

below 0.080 ppm. Three attainment areas showed an improvement in ozone air quality from 2001-2003 

to 2005-2007 on an 8-hour DV basis. One of the six attainment areas showed deterioration in air quality 

from 2001-2003 to 2005-2007 on the same basis, while two of the six showed no change. When areas 

were studied on an AQI day basis, four of the six areas showed an improvement from 2001-2003 to 2005­

2007. Two of these areas showed a greater than 80 percent improvement. One area showed an increase, 

while another showed no change. Four of the six attainment areas show an improvement in air quality 

from 2001-2003 to 2005-2007 on an 8-hour, meteorologically controlled seasonal 8-hour average basis. 

One area showed an increase, while another showed no change. (For a summary, see Table 3-1 and, for 

more details, see Tables B-1 to B-3 in Appendix B.) 

34 
For the 12 nonattainment-deferred areas in the East, the improvement in ozone air quality on a 

meteorologically controlled seasonal 8-hour average basis from 2001-2003 to 2005-2007 ranges from 4 

percent to 12 percent, with an average 9 percent improvement. For the three attainment areas in the East, 

the change in ozone air quality on a meteorologically-controlled, seasonal 8-hour average basis from 

2001-2003 to 2005-2007 ranges from a 6 percent improvement to a 3 percent deterioration, with an 

average 1 percent improvement. The air quality deteriorated in Lower Savannah-Augusta, South 

Carolina-Georgia. Savannah is located on the perimeter of the NOx SIP call region (due to its location on 

the border between Georgia and South Carolina, a state that was part of the NOx SIP Call). It is also not 

located in the normal downwind area in the East that would benefit from NOx reductions in the Midwest 

and Southeast. Overall, the average improvement in air quality was 8 percent for the 15 nonattainmentdeferred and attainment areas in the East. 

For comparative purposes, the range of improvement in ozone air quality on a meteorologically 

controlled seasonal 8-hour average basis for 18 non-EAC, 8-hour ozone nonattainment areas in the East 

from 2001-2003 to 2005-2007 was from 5 percent to 14 percent. Overall, for the 18 non-EAC Program 

areas in the East the average improvement in air quality was 8 percent. 

Figure 3-1 is a map that shows the 15 EAC Program areas in the East that were included in the study and 

the 18 non-EAC, 8-hour ozone nonattainment areas in the East that were used for comparison. The map 

indicates the percentage reduction in ozone from 2001-2003 to 2005-2007. Figure 3-2 is a box-plot of the 

same areas that illustrates the means, medians and the 90th and 100th percentiles of the percentage 

reductions. (As indicated in Figure 3-2, the dots represent the means of the areas represented, the line 

inside the box represents the median, the ends of box represent the 10th percentiles and the ends of the 

“whiskers” represent the 90th percentiles. The length of the “whiskers” represents the spread of the data.) 

The means and the medians are close, while the 90th and 100th percentiles are farther apart, particularly 

at the deterioration end of the range. However, the percentiles are within the 2 percent margin of error. 

The meteorological adjustment analyst considers this difference to be within the range of uncertainty (or 

close to it), with the exception of the 100 percentile where the EAC air quality change is greater at the 

deterioration end of the range. Table B-4 in Appendix B contains the air quality data and percentage 

changes from 2001-2003 to 2005-2007 for the 15 and 18 areas. 

In addition to these figures and tables, Figure 3-3 shows the difference in ozone air quality (seasonal 

average adjusted for weather) over time from 2001 to 2007 for the 15 EAC Program areas in the East that 

were included in the study and the 18 non-EAC, 8-hour ozone nonattainment areas in the East that were 

used for comparison. While the graph shows consistently better air quality in the EAC areas versus the 

non-EAC areas, the difference is within the margin of error and, thus, not significant. In addition, the 

degree to which the two trend lines track so closely indicates the degree to which air quality levels 

recorded at monitors across the East are uniformly influenced by regional air pollution emissions 

reductions from programs such as the NOx SIP call. 

35 
Figure 3-1: Map Showing Percentage Changes in Average Summertime Daily Maximum 8-hour
 

Ozone Concentrations in EAC and Non-EAC Program Areas in the East Between 2001-2003 and
 

2005-2007, After Adjusting for Weather
 

Source: Analysis by the Air Quality Assessment Group, OAQPS, using the method described 

in Camalier, L., Cox, W., Dolwick, P., 2007. The effects of meteorology on ozone in urban 

areas and their use in assessing ozone trends. Atmospheric Environment 41, 7127-7137. 

36 
Figure 3-2: Box Plot Showing Percentage Changes in Average Summertime Daily Maximum 8­

hour Ozone Concentrations in EAC and Non-EAC Program Areas in the East Between 2001-2003 


and 2005-2007, After Adjusting for Weather
 

Percent
 

Change
 

5 

4 

3 

2 

1 

0 

-1 

-2 

-3 

-4 

-5 

-6 

-7 

-8 

-9 

-10 

-11 

-12 

-13 

-14 

-15 

90th Percentile 

10th Percentile 

Mean 

Median 

EAC Areas NON-EAC Areas 

Source: Analysis by the Air Quality Assessment Group, OAQPS, using the method 

described in Camalier, L., Cox, W., Dolwick, P., 2007. The effects of meteorology on 

ozone in urban areas and their use in assessing ozone trends. Atmospheric Environment 

41, 7127-7137. 

37 
-

0 

10 

20 

30 

40 

50 

60 

70 

2001 2002 2003 2004 2005 2006 2007 

Year 

Concentrations (ppb) 

Non-EAC Areas (18) EAC Areas (15) 

 Figure 3-3: Trends in 8-Hour Ozone (Seasonal Average Adjusted for Weather) 

Source: Analysis by the Air Quality Assessment Group, OAQPS, using the method described in 

Camalier, L., Cox, W., Dolwick, P., 2007. The effects of meteorology on ozone in urban areas and 

their use in assessing ozone trends. Atmospheric Environment 41, 7127-7137.

38 
Table 3-1: Summary of Air Quality Study Information
 

Percent 

Improvement In 

8-Hour DV 

(2001-2003 to 

2005-2007) 

Percent 

Improvement In 

AQI Days (2001­

2003 to 2005-2007) 

Change In Number 

of Average AQI 

Days (2001-2003 to 

2005-2007) 

Percent Improvement 

In Seasonal Ozone 

Average, 

Meteorologically 

Controlled (2001-2003 

to 2005-2007) 

Nonattainment-Deferred EAC Program Areas 

Berkeley and 

Jefferson Counties, 

West Virginia 

-13% -77% -3.3 -12% 

Chattanooga, 

Tennessee-Georgia -5% -72% 

-9.3 

-9% 

Columbia, South 

Carolina (Central 

Midlands Area) 

-8% -48% 

-3.7 

-6% 

Denver-BoulderGreeley-Fort CollinsLoveland, Colorado 

-2% -47% 

-5.0 

NA 

Fayetteville, North 

Carolina 

(Cumberland County) 

-6% -62% 

-5.3 

-4% 

Frederick County, 

Virginia -14% -93% -4.7 -12% 

Greensboro-Winston 

Salem-High Point, 

North Carolina (Triad 

Area) 

-11% -76% 

-14.7 

-10% 

GreenvilleSpartanburgAnderson, South 

Carolina 

(Appalachian Area) 

-5% -77% 

-11.0 

-10% 

Hickory-MorgantonLenoir, North 

Carolina (Unifour 

Area) 

-11% -100% 

-5.0 

-11% 

Johnson CityKingsport-Bristol, 

Tennessee 

-3% -45% 

-3.3 

-5% 

Nashville, Tennessee -2% -24% -2.7 -11% 

Roanoke, Virginia -11% -91% -3.3 -8% 

San Antonio, Texas -8% -64% -5.3 -13% 

Washington County, 

Maryland 

(Hagerstown) 

-8% -84% 

-7.0 

-10% 

39 
Table 3-1: Summary of Air Quality Study Information
 

Percent 

Improvement In 

8-Hour DV 

(2001-2003 to 

2005-2007) 

Percent 

Improvement In 

AQI Days (2001­

2003 to 2005-2007) 

Change In Number 

of Average AQI 

Days (2001-2003 to 

2005-2007) 

Percent Improvement 

In Seasonal Ozone 

Average, 

Meteorologically 

Controlled (2001-2003 

to 2005-2007) 

Attainment EAC Program Areas 

Austin, Texas -5% -11% -0.3 0% 

Berkeley-CharlestonDorchester, South 

Carolina 

3% 0% 0.0 -1% 

Mountain Area of 

Western North 

Carolina (Asheville) 

-5% -81% -4.3 -6% 

Oklahoma City, 

Oklahoma 0% 143% 3.3 -6% 

Lower SavannahAugusta, South 

Carolina-Georgia 

0% -100% -0.3 3% 

Tulsa, Oklahoma -4% -22% -1.3 -6% 

Source: AQS and meteorological analysis by the Air Quality Assessment Group, OAQPS, using the 

method described in Camalier, L., Cox, W., Dolwick, P., 2007. The effects of meteorology on 

ozone in urban areas and their use in assessing ozone trends. Atmospheric Environment 41, 7127­

7137. 

40 
 

Estimated Emissions Reductions from Control Measures
 

This section provides information for EAC areas on the estimated emission reductions from 

state and local EAC measures and overall from Federal measures. Federal measures include 

programs such as EPA rules for motor vehicle standards (i.e., Tier 2 and non-road diesel 

engines). State measures include programs such as inspection and maintenance (I/M), lower 

Reid vapor pressure, and Reasonably Available Control Technology (RACT) controls for 

VOCs. It is important to keep in mind that many EAC local measures were implemented that 

could not be easily quantified, if at all. They were implemented with the goal of effecting 

lifestyle and other changes that could, in turn, help reduce emissions contributing to ozone 

levels. Examples of these measures are: 

• Bike racks and trails at work sites (Chattanooga, Tennessee-Georgia); 

• Encouragement of carpooling (Columbia, South Carolina (Midlands Area)); 

• Energy efficient buildings (Fayetteville, NC); 

• Timing of refueling vehicles (Roanoke, Virginia); and 

• Truck stop anti-idling program (San Antonio, Texas). 

This subsection discusses five areas relating to control measures: 

• Measures Implemented in Nonattainment-Deferred EAC Program Areas; 

• Measures Implemented in Attainment EAC Program Areas; 

• Control Measure Emissions Reductions in Perspective; 

• Control Measure Implementation; and 

• Non-Ozone Air Quality Benefits. 

Measures Implemented in Nonattainment-Deferred EAC Program Areas 

The 14 nonattainment-deferred areas implemented a range of state and local measures, spanning from 

as few as four in Denver, Colorado23 to as many as 35 in Greenville-Spartanburg-Anderson, South 

Carolina (Appalachian Area). In the 14 areas, the number of local measures that were implemented 

ranged from zero in Denver, Colorado to as many as 35 in the Greenville-Spartanburg-Anderson, South 

Carolina (Appalachian Area). Across all 14 nonattainment-deferred EAC Program areas, 258 state and 

local measures were implemented. (See Table 3-2 and Appendix B, Tables B-5 to B-25.) 

All 14 of the nonattainment-deferred areas implemented state and local measures that had estimated 

emissions reductions associated with them. Of the local measures, the percentage that had quantified 

emissions reductions associated with them ranged from zero percent in Denver-Boulder-Greeley-Fort 

Collins-Loveland, Colorado that had no local measures to 100 percent in Berkeley and Jefferson 

Counties, West Virginia. Five of the 14 areas had one percent or less of quantified NOx and VOC 

emissions from local measures. Four of the 14 nonattainment-deferred areas had 10 percent or greater 

of their quantified NOx and VOC emissions from local measures. Six areas had 10 percent or greater 

of their quantified NOx and VOC emissions from state measures. All 14 areas had 35 percent or more 

of their quantified NOx and VOC emissions from Federal measures, while twelve areas had 50 percent 

or more and 8 areas had 80 percent or more. The 14 nonattainment-deferred areas relied largely on 

state and national measures for their modeled attainment demonstrations. 

23 These were State of Colorado, federally-enforceable measures adopted as rule revisions, resulting in permanent emissions 

reductions of 58,765 tons per year of VOC and 6,935 tons per year of NOx (see Appendix B, Table B-8). 

41 
Table 3-3 contains a list of the eight local EAC measures in the four of the 14 nonattainment-deferred 

area SIPs that individually contributed 5 percent or greater of their quantified NOx and VOC emissions 

reductions to their respective SIPs. 

Measures Implemented in Attainment EAC Program Areas 

The six attainment areas included in the study implemented a range of state and local measures, 

spanning from as few as one in Tulsa, Oklahoma to as many as 44 in Lower Savannah-Augusta, South 

Carolina-Georgia. In four of the six areas, the number of local measures that were implemented ranged 

from zero in Mountain Area of Western North Carolina (Asheville) to 42 in Lower Savannah-Augusta, 

South Carolina-Georgia. Across all six attainment EAC Program areas, 130 state and local measures 

were implemented. (See Table 3-2 and Appendix B, Tables B-5 to B-25.) 

Four of the six attainment areas included in the study implemented measures that had emission 

reductions associated with them. Of the local measures, the percentage that had quantified emissions 

reductions associated with them ranged from zero percent for Berkeley-Charleston-Dorchester, South 

Carolina and Mountain Area of Western North Carolina (Asheville) to 100 percent for Tulsa, 

Oklahoma. One of five of the six attainment areas included in the study had 21 percent of its quantified 

NOx and VOC emission reductions from local measures, while the remainder had two percent or less. 

These five had 4 percent or less of their quantified NOx and VOC emission reductions from state 

measures. Of four of the six attainment areas included in the study, one had 78 percent of its quantified 

NOx and VOC emission reductions from national measures, while the remainder had 96 percent or 

more. The six attainment areas included in the study relied largely on estimated NOx and VOC 

emissions reductions from state and national measures for their modeled attainment demonstrations. 

Table 3-4 contains a list of the three local EAC measures in two of the six attainment EAC area SIPs 

that individually contributed five percent or greater of their quantified NOx and VOC emissions 

reductions to their respective SIPs. 

42 
Table 3-2: Summary of Control Measure Emission Reduction Study Information
 

Geographic Area 

Number of 

Measures 

Implemented 

Emission Reductions 

Local State 

Percentage of 

Local Measures 

Quantified 

Percentage of Estimated Quantified NOx and VOC 

Emissions From: 

Of th

Perc

Nat

Local Measures State Measures National (Federal) Measures 

Nonattainment-Deferred EAC Program Areas Berkeley and Jefferson Counties, West Virginia 7 0 100% 65% 0% 35% 

Chattanooga, Tennessee-Georgia 14 6 57% 9% 18% 73%* 

Columbia, South Carolina (Central Midlands Area) 27 2 37% 13% 0% 87% 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 0 4 0% 0% 54% 46%* 

Fayetteville, North Carolina (Cumberland County) 24 2 17% 4% 8% 88% 

Frederick County, Virginia 7 3 57% 10% 7% 83% 

Greensboro-Winston SalemHigh Point, North Carolina (Triad Area) 

27 2 41% 1% 2% 97% 

Greenville-SpartanburgAnderson, South Carolina (Appalachian Area) 

35 0 20% 24% 0% 77% 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 12 3 33% 0% 5% 95% 

Johnson City-Kingsport-Bristol, Tennessee 2 5 50% 1% 10% 89% 

Nashville, Tennessee 11 4 100% 4% 3% 93%* 

Roanoke, Virginia 24 5 46% 3% 16% 81% 

San Antonio, Texas 10 3 70% 9% 38% 52% 

Washington County, Maryland (Hagerstown) 12 7 83% 1% 32% 66% 
Table 3-2: Summary of Control Measure Emission Reduction Study Information
 

Geographic Area 

Number of 

Measures 

Implemented 

Emission Reductions 

Local State 

Percentage of 

Local Measures 

Quantified 

Percentage of Estimated Quantified NOx and VOC 

Emissions From: 

Of th

Perc

Nat

Local Measures State Measures National (Federal) Measures 

Attainment EAC Program Areas Austin, Texas 39 2 21% 21% 1% 78% 

Berkeley-Charleston-Dorchester, South Carolina 39 0 0% 0% 0% Insufficient data 

Mountain Area of Western North Carolina (Asheville) 0 2 0% 0% 4% 96% 

Oklahoma City, Oklahoma 3 0 66% 0% 0% 100% 

Lower Savannah-Augusta, South Carolina-Georgia 42 2 2% Insufficient data Tulsa, Oklahoma 1 0 100% 4% 0% 96% 

*The estimates of the percentage contributions of national (Federal) measures are higher than they should be because temissions reductions for one state measure for each area that the study was unable to subtract out due to insufficient inAppendix C for more details. 
Table 3-3: Four Nonattainment-Deferred EAC Program Areas with Five 

Percent or Greater of Quantified NOx and VOC Emissions Reductions 

from Eight Individual Local Measures 

Nonattainment-Deferred 

EAC Program Area 

Local Measure Percent of Quantified 

NOx and VOC 

Emissions Reductions 

Ozone action day program 17% 

Berkeley and Jefferson 

Counties, West Virginia 

Public awareness program 26% 

Bicycle/pedestrian measures 5% 

Voluntary -ground freight industry 14% 

Columbia, South Carolina 

(Central Midlands Area) 

Reduce NOx emissions from South Carolina 

Electric and Gas - 2 coal fired boilers 11% 

Greenville-SpartanburgAnderson, South Carolina 

(Appalachian Area) 

Develop stakeholder group - regulatory 

development 14% 

Transco (gas pipeline company) - early 

implementation of Phase 2 emission 

reductions 

5% 

San Antonio, Texas Reduced Stage I vapor recovery exemption 

level from 125k gal/mo to 25k gal/mo 6% 

Table 3-4: Two Attainment EAC Program Areas with Five Percent or Greater of
 

Quantified NOx and VOC Emissions Reductions from Three Individual Local Measures
 

NonattainmentDeferred EAC 

Program Area 

Local Measure Percent of Quantified NOx 

and VOC Emissions 

Reductions 

Austin, Texas I/M Onboard Diagnostics & Low Income 

Repair Program 

6% 

Degreasing controls 5% 

Lower SavannahAugusta, South CarolinaGeorgia 

Open burning ban -ozone season (Georgia) Insufficient data* 

*Using the data the study had available, this percentage is 48 percent. However, due to 

insufficient data for this area, the study could not include a complete quantification of 

the emission reductions benefitting the area in this report. Therefore, the 48 percent 

overstates the measure’s contribution and would be lower if we had more complete 

information on emission reductions. 

Control Measure Emissions Reductions in Perspective 

For the 20 EAC Program areas included in the study, the study compared quantified NOx emissions 

reduction estimates for local measures to (1) 2002 NOx emissions in the area, (2) 2002 NOx emissions 

in the state in which the area is located, and (3) the emission reduction achieved in that state through the 

NOx SIP call. For 17 of the 20 areas the ratio of the emissions for all three of these comparisons 

represented five percent or less (See Table B-26, Appendix B). The three areas for which one or more 

of the ratios is above five percent are: 

45 
• Berkeley and Jefferson Counties, West Virginia; 

• Columbia, South Carolina (Central Midlands Area); and 

• Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area). 

For 15 of the 20 areas the NOx emissions reductions for local measures represent 2.5 percent or less 

than the respective point of comparison. The two areas with one or more comparisons between 2.5 and 

5 percent are: 

• Austin, Texas and 

• Frederick County, Virginia. 

The study also compared quantified VOC emissions reduction estimates for local measures to 2002 

VOC emissions in the area and in the state in which the area is located. For 18 of the 20 areas the ratio 

of the emissions for the two comparisons represented five percent or less. The two areas for which one 

or both of the ratios is above five percent are: 

• Austin, Texas and 

• Berkeley and Jefferson Counties, West Virginia. 

For 15 of the 20 areas, the VOC emission reductions for local measures represented two and a half 

percent or less. The three areas with one or more comparisons between 2.5 and 5 percent are: 

• Chattanooga, Tennessee-Georgia; 

• Frederick County, Virginia; and 

• San Antonio, Texas. 

Control Measure Implementation 

According to the EAC progress reports and SIPs, all measures committed to by the states in the 20 areas 

included in the study but 14 were implemented by December 2005.24 The 14 measures not 

implemented by December 2005 are listed in Table 3-5 and are also included in Appendix B, Tables B5 to B-25. The 14 measures represent 4 percent of the total 388 state and local measures implemented 

for the 20 areas included in the study with seven in nonattainment-deferred areas and seven in 

attainment areas. As Table 3-5 indicates, seven of the 14 measures were implemented after 2005. Only 

one of the measures was modeled in an area attainment demonstration. 

24 For purposes of EAC measures, implementation meant that areas committed, at a minimum, to begin implementing 

measures no later than December 2005. Considering the variety of programs and technologies adopted into the SIPs, EPA 

recognized that certain measures required phased implementation on a specific schedule and that all of those activities were 

not expected to occur by December 2005. 

46 
Table 3-5: EAC Program Area Measures Not Implemented by December 2005 


EAC Program 

Area 

Control Measure State or 

National 

Measure? 

Implementation 

Date 

Emissions 

Reductions 

Quantified 

Measure 

Modeled? 

Nonattainment-Deferred EAC Program Areas 

Chattanooga, TNGeorgia Accelerated 

replacement of onroad vehicles 

No 2006* No No 

Denver, Colorado 

Reduce flash VOC 

emissions from 

condensate 

collection at various 

natural gas facilities 

Yes December 31, 

2007 

Yes Yes 

GreenvilleSpartanburgAnderson, South 

Carolina 

(Appalachian Area) 

Encourage 

community schools 

No Insufficient 

information to 

determine date 

No No 

Improve landscape 

at county facilities 

No Insufficient 

information to 

determine date 

No No 

School bus retrofits No 2006 Yes No 

Roanoke, Virginia Ethanol alternative 

fuel vehicles 

No 2007 No No 

Biodiesel ready 

trucks 

No 2007 No No 

Attainment EAC Program Areas 

Austin, Texas Power Plant 

Reductions-­

enforceable 

commitments by 

area power plants 

No December 31, 

2006 

No No 

BerkeleyCharlestonDorchester, South 

Carolina 

Educational 

programs 

No Insufficient 

information to 

determine date 

No No 

Schools-add 

sidewalks, increase 

bus usage; restrict 

vehicle idle times 

No Insufficient 

information to 

determine date 

No No 

Educate public ­

festivals, lecturer, 

brochure 

No Insufficient 

information to 

determine date 

No No 

Lower SavannahAugusta, South 

Carolina-Georgia 

Seek information on 

alternative fuels 

No Insufficient 

information to 

determine date 

No No 

Replace vehicles 

with latest emission 

reduction vehicles 

No Insufficient 

information to 

determine date 

No No 

Install Intelligent 

Transportation 

Systems equipment 

along major routes 

No Post 2007** No No 

47 
*While this measure was implemented in 2006, as approved by the SIP, procedures were in place in 

2005 to accelerate replacement of non-road vehicles. Actual replacement occurred in 2006. 

**A master plan for this area was completed in May 2002 that contained plans to install Intelligent 

Transportation Systems equipment along major routes. When EPA approved the SIP in 2004, the 

equipment installations were not expected until post 2007. 

Non-Ozone Air Quality Benefits 

The study lacked data regarding non-ozone air quality benefits so these benefits were not quantified. 

However, according to 12 of the individuals consulted EAC Program activities directly generated 

environmental benefits in addition to ozone reduction. Seven of the individuals consulted stated that 

the EAC Program has reduced PM2.5 (generally referring to particles less than or equal to 2.5 

micrometers) through such programs as alternative fuels, open burning bans, freight partnership, diesel 

and school bus retrofits, and idling reduction. The EAC Program has also led to efforts to reduce PM2.5 

that are underway in three additional areas. In addition, EAC Program activities are also responsible 

for generating reductions in air toxics, NOx, and VOCs. 

Air Quality Modeling for EAC SIPs 

The study reviewed the SIP modeling demonstrations to determine whether the air quality modeling 

predicted attainment with or without the local EAC measures. The attainment demonstrations did rely 

largely on state and national measures for their attainment demonstrations and not local measures. 

The study addressed whether the modeling could provide any insight into what degree “local” EAC 

measures contributed to any improvements in air quality in EAC Program areas. Because the states for 

the most part did not include local measures in their modeling, the study determined that the only 

reliable way to quantify the air quality impacts of EAC local measures would be to model the 

incremental contribution of those measures. The study did not possess the resources to perform that 

modeling and, thus, could not reliably answer that question. 

For the question of how the air quality improvements projected in the state’s EAC modeling compare to 

the observed air quality improvements, actual 2007 air quality data (on an 8-hour DV basis) was 

compared to predicted 2007 air quality data, based on air quality modeling in the EAC SIPs. Eightyfive percent of the EAC Program areas that were included in the study predicted better or the same air 

quality for 2007 as was observed, as shown in Table 3-6. In projecting from their base years to 2007, 

the state-submitted EAC modeling projections had an average error of about 0.003 ppm. Where the 

model projections deviated from what was observed, the eventual air quality tended to be cleaner than 

what was predicted; that is, the modeling projections tended to be conservative (average projection bias 

was 0.0014 ppm). Where the model projections overestimated the amount of air quality improvement, 

the areas still came into attainment in 2005-2007, although in some cases only by very small amounts 

(e.g., Nashville predicted 0.082 ppm, actual was 0.084 ppm). Overall, the level of ozone improvement 

anticipated was achieved. 

48 
Table 3-6: Comparison of Projected Air Quality Improvements Projected by EAC SIP Modeling 

to Monitored Air Quality Measured as 8-hour Ozone Concentrations, 

From 2001-2003 to 2005-2007, 14 Nonattainment-Deferred EAC Program Areas 

and Six Attainment EAC Program Areas 

EAC Program Area 2007 SIP 

Predicted 

DV (ppm) 

Observed 2005­

2007 

DV (ppm) 

Observed Air 

Quality Cleaner 

Than Predicted?* 

Nonattainment-Deferred EAC Program Areas 

Berkeley and Jefferson Counties, 

West Virginia 0.082 0.075 Yes 

Chattanooga, Tennessee-Georgia 0.084 0.084 Same 

Columbia, South Carolina 

(Central Midlands Area) 0.080 0.082 Same 

Denver-Boulder-Greeley-Fort 

Collins-Loveland, Colorado 0.085 0.085 Same 

Fayetteville, North Carolina 

(Cumberland County) 0.078 0.082 No 

Frederick County, Virginia 0.082 0.073 Yes 

Greensboro-Winston SalemHigh Point, North Carolina 

(Triad Area) 

0.084 0.083 Same 

Greenville-SpartanburgAnderson, South Carolina 

(Appalachian Area) 

0.084 0.083 Same 

Hickory-Morganton-Lenoir, 

North Carolina (Unifour Area) 0.075 0.078 No 

Johnson City-Kingsport-Bristol, 

Tennessee 0.084 0.083 Same 

Nashville, Tennessee 0.082 0.084 Same 

Roanoke, Virginia 0.080 0.076 Yes 

San Antonio, Texas 0.084 0.082 Same 

Washington County, Maryland 

(Hagerstown) 0.081 0.079 Same 

Attainment EAC Program Areas 

Austin, Texas 0.083 0.080 Yes 

Berkeley-Charleston-Dorchester, 

South Carolina 0.071 0.074 No 

Mountain Area of Western 

North Carolina (Asheville) 0.077 0.079 Same 

Oklahoma City, Oklahoma 0.080 0.080 Same 

Lower Savannah-Augusta, South 

Carolina-Georgia 0.077 0.067 Yes 

Tulsa, Oklahoma 0.084 0.080 Yes 

Source: AQS and EAC SIPs 

*Assume “same” if observed and predicted values are within 0.002 ppm or “yes” or “no” if 

difference is greater than 0.002 ppm. 

49 
Growth-Related Aspects of the Study 

All but one of the 14 nonattainment-deferred areas – Fayetteville, North Carolina (Cumberland County) 

– had population growth from 2002 to 2006 during EAC Program implementation. Two of the 

nonattainment-deferred areas experienced a greater than 10 percent increase. Seven of the 14 areas 

experienced estimated growth for the period equal to or greater than the rest of the state in which the 

area is located, the region in which it is located, and the U.S. as a whole. All of the six attainment areas 

experienced population growth from 2002 to 2006. Four of the attainment areas experienced a five 

percent or greater increase. Two of the areas experienced estimated population growth for the period 

equal to or greater than the rest of the state in which the area is located, the region in which it is located, 

and the U.S. as a whole. 

All but two of the 14 nonattainment-deferred areas – Berkeley and Jefferson Counties, West Virginia 

and Frederick County, Virginia – were estimated to have experienced VMT growth from 2002 to 2006 

during EAC Program implementation. Three of the areas experienced a greater than 10 percent 

increase. Three of the 14 areas experienced estimated growth for the period equal to or greater than the 

rest of the state in which the area is located, the region in which it is located and the U.S. as a whole. 

All of the six attainment areas experienced VMT growth from 2002 to 2006. Three experienced a nine 

percent or greater increase. Three of the areas experienced estimated VMT growth for the period equal 

to or greater than the rest of the state in which the area is located, the region in which it is located and 

the U.S. as a whole. (See Figure 3-3 and Appendix B, Tables B-27 to B-30.) 

The percentage changes in Figure 3-3 for the South and the West consist of the following states: 

Western States 

• Alaska; • Nevada; 

• Arizona; • New Mexico; 

• California; • Oregon; 

• Colorado; • Utah; 

• Idaho; • Washington; and 

• Montana; • Wyoming. 

Southern States 

• Alabama; • Louisiana; 

• Arkansas; • Maryland; 

• Delaware; • Mississippi; 

• District of Columbia; • North Carolina; 

• Florida; • Oklahoma; 

• Georgia; • South Carolina; and 

• Kentucky; • Tennessee. 

• Texas; 

• Virginia; 

• West Virginia; 

50 
Washington Co (Hagerstown), MD 

Tulsa, OK 

Savannah SC/GA 

San Antonio, TX 

Roanoke, VA 

Oklahoma City, OK 

Nashville, TN 

Mountain Area of Western NC (Asheville) 

Johnson City-Kingsport-Bristol, TN 

Hickory-Morganton-Lenoir, NC (Unifour Area) 

Greenville-Spartanburg-Anderson, SC (Appalachian Area) 

Greensboro-Winston Salem-High Point, NC (Triad Area) 

Frederick Co, VA 

Fayetteville, NC (Cumberland County) 

Denver-Boulder-Greeley-Fort Collins-Love., CO 

Columbia, South Carolina (Central Midlands Area) 

Chattanooga, TN-GA 

Berkeley-Charleston-Dorchester, SC 

Berkeley and Jefferson Counties, WV 

Austin, TX 

United States 

West 

South 

Percentage Change VMT Percentage Change Popu

Figure 3-4: Percentage Change in Population and VMT from 2002 to 2006 for 

20 EAC Program Areas, the U.S. and the South and West 

-15% -10% -5% 0% 5% 10% 15% 20% 
Program Design Aspects of the Study 

The study produced quantitative information in one area regarding program design: other aspects of the 

EAC Program related to EPA resources. The methodology and information from the study of the EPA 

resource estimates for the EAC Program versus the traditional approach are summarized in Table 3-7 

(and described in detail in Table B-31). These are estimates made after completion of the EAC 

program, as resources expended on the program were not specifically tracked during its 

implementation. 

Table 3-7 indicates that the study estimate for FTE to implement the EAC Program is 23.8. Table 3-7 

also indicates that the study estimate for FTE to implement the traditional approach for the EAC areas 

is 24.6 to 57.3. The FTE estimates for implementation of a hypothetical traditional approach vary 

because of the differences across the regions in the FTE estimates for implementation of such an 

approach. Based on these estimates, since 23.8 and 24.6 are roughly comparable and 57.3 is well above 

those two numbers, the study information indicate that the EAC Program is as resource intensive (or 

less, depending on the EPA region) as a hypothetical traditional program for FTE. 

Table 3-7 indicates that the study estimate for Federal Register actions to implement the EAC Program 

is 55. Table 3-7 also indicates that the study estimate for Federal Register actions to implement the 

traditional approach for the EAC areas is 28 to 46. The reason for the variability in the Federal Register 

actions for implementation of a hypothetical traditional approach is because of the variability across the 

regions in the estimates of the implementation of such an approach. According to these estimates, 

because 55 exceeds 46, the EAC Program is more resource intensive for Federal Register actions than 

the hypothetical traditional program. This is due partly to the fact that the EAC Program necessitated 

that EPA headquarters issue a number of Federal Register notices. 

The estimates in Table 3-7 also indicate that the EAC Program is less resource intensive for Federal 

Register cost than the traditional program. This is due to the fact that the EAC Program’s Federal 

Register actions were shorter than those of the traditional approach, despite being more numerous. 

Table 3-7: EPA Resource Estimates for the EAC Program versus the Traditional Approach 

Resource Traditional Approach EAC Program 

FTE 24.6 to 57.3 23.8 

Number of EPA Federal Register 

Actions (pages) 

28 actions (715 pages) to 46 

actions (1,085 pages) 

55 actions (561 pages) 

Federal Register Cost* $349,635 to $530,565 $274,329 

Source: EPA headquarters and regional office Staff estimates made retrospectively after the
 

EAC Program ended, not during the EAC Program. 


*Assumes current Federal Register of $489/page. 


3.1.2 Qualitative Information 

The study produced qualitative information for both the environmental and program design aspects of 

the study. 

52 
Qualitative Information for Environmental Aspects of the Study 

The study produced information in one area: growth-related aspects of the study. Specifically, the 

discussion of study information in this area covers NSR Program activity and Conformity Program 

applicability. 

NSR Program Activity 

There are fundamental limitations to the ability to do a full quantitative analysis of the environmental 

benefits, or loss of opportunity for benefits, from Nonattainment NSR Program requirements due to 

implementing an EAC versus a traditional program. An analysis of this type would rely upon the 

ability to estimate the effects that the Nonattainment NSR Program would be expected to have on 

emissions over time, and compare that to the effects that occur absent the Nonattainment NSR Program. 

Although the study had available some limited information about some permit actions in some EAC 

areas, it cannot quantify, with a reasonable level of specificity, the differences in emissions for a given 

pollutant or pollutants, if any, that result from Nonattainment NSR Program requirements not being in 

place for EAC areas since it is not known: 

•	 Whether a given project that went forward in the EAC area would have gone forward in the 

nonattainment area; 

•	 If the Nonattainment NSR Program would create incentives for sources to relocate outside the 

nonattainment area, or to redesign or resize projects to avoid the Nonattainment NSR Program; 

and 

•	 What the outcome of a nonattainment permitting process would have been (i.e., would the 

control technology determination have been different under Lowest Achievable Emission Rate 

(LAER) than under Best Available Control Technology (BACT), and from where would the 

offsets have come). 

Because of these and other difficulties, it is very difficult to model the likely changes in emissions or air 

quality that could have occurred as a result of Nonattainment NSR Program requirements being in 

place. Therefore, the study considered qualitative observations more appropriate when looking at EAC 

programs and the potential emissions that may have been averted if Nonattainment NSR Program 

requirements had been in place in these areas. Nonetheless, specific permit information can provide a 

useful supplement to these conclusions when data is available. For that reason, the study provides the 

information below. However, the study is not able to make a quantitative estimate based on this 

information. While the Nonattainment NSR Program requirements have more stringent requirements in 

many cases, EPA cannot assume a direct comparison between hypothetical Nonattainment NSR 

Program and what actually occurred (i.e., between hypothetical LAER and actual BACT, or 

hypothetical major NSR Program and actual minor NSR Program) for these individual sources is valid. 

The study identified two categories of NSR Program permitting activity in the 14 nonattainment 

deferred areas: 

•	 Projects where the Prevention of Significant Deterioration (PSD) Program applied (projected 

emissions greater than either 250 tons per year or a PSD emissions significance rate) and the 

Nonattainment NSR Program may have applied because the projected emissions exceeded 100 

tons per year (Category 1); and 

53 
•	 Projects that were not subject to the PSD Program (projected emissions less than 250 tons per 

year) but the Nonattainment NSR Program may have applied because either the projected 

emissions exceeded 100 tons per year or met another Nonattainment NSR Program emissions 

applicability test (Category 2). 

The study addressed permitting activity from June 15, 2004 until April 15, 2008 by consulting with 

EPA regional and, where appropriate, state permitting staff. In five of the 14 areas the study found that 

there was no new source activity that triggered the PSD program requirements or that would have 

triggered the CAA’s Nonattainment NSR Program requirements had the areas been designated 

nonattainment. The areas are: 

•	 Berkeley and Jefferson Counties, West Virginia; 

•	 Denver-Boulder-Greeley-Fort Collins-Love, Colorado; 

•	 Frederick County, Virginia; 

•	 Nashville, Tennessee; and 

•	 Roanoke, Virginia. 

Four of the 14 areas had eight new source permitting actions under Category One (plus one application 

submitted) in which the applicant was subject to the PSD Program but may have been subject to the 

Nonattainment NSR Program instead had the areas been designated nonattainment. The areas (and the 

associated activity) are: 

•	 Columbia, South Carolina (Central Midlands Area) 

o	 Lexington County 

�	 Permit issued in 2007 – Michelin Corporation - major PSD Program source for 

VOC – increased VOC emissions by 110.9 tons per year, exceeding the PSD 

Program significance rates for VOCs of 40 tons per year; 

•	 Greensboro-Winston Salem-High Point, North Carolina (Triad Area); 

o	 Forsyth County 

�	 Permit issued in 2005 – R.J. Reynolds - major PSD Program source for VOC – 

increased VOC emissions by 3,495 tons per year, exceeding the PSD Program 

significance rates for NOx of 40 tons per year; 

•	 Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 

o	 Anderson County 

�	 Permit issued in 2005 – Santee Cooper - major PSD Program source for NOx – 

increased NOx emissions by 217.2 tons per year, exceeding the PSD Program 

significance rates for NOx of 40 tons per year 

�	 Permit issued in 2006 – Duke Energy Corporation - major PSD Program source 

for NOx – increased NOx emissions by 84.1 tons per year, exceeding the PSD 

Program significance rates for NOx of 40 tons per year 

o	 Greenville County 

�	 Permit issued in 2007 – Michelin Corporation - major PSD Program source for 

VOC – increased VOC emissions by 260 tons per year, exceeding the PSD 

Program significance rates for VOCs of 40 tons per year; and 

54 
•	 San Antonio, Texas 

o	 Bexar County 

�	 2004 permit issued - Toyota Motor Manufacturing of Texas - major PSD 

Program source of VOC – increased VOC emissions by 75.6 tons per year, 

exceeding PSD Program significant rates for VOC of 40 tons per year 

�	 2005 permit issued - City Public Service Spruce Power Unit No. 2- new major 

PSD Program source – increased NOx emissions by 1,752 tons per year, 

exceeding PSD Program major source threshold for NOx of 250 tons per year 

o	 Comal County 

�	 2006 application submitted - Chemical Lime No. 1 – proposed NOx increase of 

711 tons per year - permit not issued to date 

�	 2007 permit issued - TXI Operations, Hunter Plant - new major PSD Program 

source – increased NOx emissions by 1,224 tons per year, exceeding PSD 

Program major source threshold for NOx of 250 tons per year. 

Two of the 14 areas had three new source permitting actions under Category Two in which the 

applicant was not subject to the PSD Program but may have been subject to the Nonattainment NSR 

Program had the areas been designated nonattainment. The areas are: 

•	 Chattanooga, Tennessee-Georgia 

o	 Hamilton County 

�	 2005 permit issued - Caraustar Mill Group, Inc. (d/b/a Chattanooga 

Paperboard) - major Nonattainment NSR Program source of NOx – increased 

NO2 by 145.69 tons per year, which would have exceeded Nonattainment 

NSR Program major source threshold for NOx of 100 tons per year 

�	 2005 permit issued - Aerisyn LLC - major Nonattainment NSR Program 

source of VOC – increased VOC emissions by 120 tons per year, which 

would have exceeded Nonattainment NSR Program major source threshold 

for NOx of 100 tons per year; and 

•	 Johnson City-Kingsport-Bristol, Tennessee 

o	 Sullivan County 

�	 2005 permit issued - Aurora Hardwoods, Inc. - major Nonattainment NSR 

Program source of VOC – increased VOC emissions by 249.9 tons per year, 

exceeding Nonattainment NSR Program major source threshold for VOCs of 

100 tons per year. 

For six of the 14 areas the study lacked sufficient information to determine whether there was any 

activity under Category Two: 

•	 Columbia, South Carolina (Central Midlands Area); 

•	 Fayetteville, North Carolina (Cumberland County); 

•	 Greensboro-Winston Salem-High Point, North Carolina (Triad Area); 

•	 Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area); 

•	 Hickory-Morganton-Lenoir, North Carolina (Unifour Area); and 

•	 San Antonio, Texas. 

55 
For Washington County, Maryland (Hagerstown), no activity in Categories 1 and 2 were identified as 

they would have not been subject to the Nonattainment NSR Program because Maryland is in the 

Ozone Transport Commission and would have had to meet NSR Program requirements regardless of 

participation in the EAC Program because it is treated as a moderate nonattainment area for NSR 

Program purposes. 

Conformity Program Applicability 

Although they were participating in the EAC Program, six of the 14 nonattainment-deferred EAC 

Program areas were subject to the CAA Conformity Program requirement during the EAC Program 

(from June 14 2004 to April 15, 2008) for pollutants other than the 8-hour ozone NAAQS. Those 

pollutants were: the 1-hour ozone NAAQS, the PM10 NAAQS, the PM2.5 NAAQS and the carbon 

monoxide NAAQS. Table 3-8 provides information on each area’s Conformity Program status. 

Federal actions in these areas may also have been subject to the environmental review process under the 

National Environmental Policy Act (NEPA), which has some overlap with the Conformity Program for 

certain analyses. The NEPA requires Federal agencies to integrate environmental values into their 

decision making processes by considering the environmental impacts of their proposed actions and 

reasonable alternatives to those actions.25 

Table 3-8: Conformity Program Status of Nonattainment-Deferred EAC
 

Program Areas during Implementation of EAC Program
 

Nonattainment-Deferred EAC 

Program Areas 

Was the Conformity 

Program in Effect for 

At Least Part of EAC 

Program 

Implementation? 

What NAAQS Pollutant(s)? 

Berkeley and Jefferson Counties, 

West Virginia 

No • Not applicable 

Chattanooga, Tennessee-Georgia Yes • PM2.5 NAAQS because area designated nonattainment for 

PM2.5 (effective April 5, 2005) 

Columbia, South Carolina 

(Central Midlands Area) 

No • Not applicable 

Denver-Boulder-Greeley-Fort 

Collins-Loveland, Colorado 

Yes • 1-hour ozone NAAQS (approved maintenance plan in place 

with budgets for NOx and VOCs) 

• PM10 NAAQS (approved maintenance plan in place with 

budgets for PM10 and NOx) 

• Carbon Monoxide NAAQS (approved maintenance plan in 

place with budget for Colorado) 

Fayetteville, North Carolina 

(Cumberland County) 

No • Not applicable 

Frederick County, Virginia No • Not applicable 

Greensboro-Winston Salem-High 

Point, North Carolina (Triad Area) 

Yes • 1-hour ozone NAAQS (to be revoked after April 15, 2009) 

• PM2.5 NAAQS because area designated nonattainment for 

PM2.5 (effective April 5, 2005) 

Greenville-Spartanburg-Anderson, 

South Carolina (Appalachian 

Area) 

No • Not applicable 

25 http://www.epa.gov/compliance/nepa/index.html 

56 
 

Nonattainment-Deferred EAC 

Program Areas 

Was the Conformity 

Program in Effect for 

At Least Part of EAC 

Program 

Implementation? 

What NAAQS Pollutant(s)? 

Hickory-Morganton-Lenoir, North 

Carolina (Unifour Area) 

Yes • PM2.5 NAAQS because area designated nonattainment for 

PM2.5 (effective April 5, 2005) 

Johnson City-Kingsport-Bristol, 

Tennessee 

No • Not applicable 

Nashville, Tennessee Yes • 1-hour ozone NAAQS (will be revoked after April 15, 

2009) 

Roanoke, Virginia No • Not applicable 

San Antonio, Texas No • Not applicable 

Washington County, Maryland 

(Hagerstown) 

Yes • PM2.5 NAAQS because area designated nonattainment for 

PM2.5 (effective April 5, 2005) 

Source: EPA regional office Conformity Program staff. 

Qualitative Information for Program Design Aspects of the Study 

The study produced information in four areas: 

• Efficiency of EAC Program; 

• Longer term impact; 

• Outreach and stakeholder interaction; and 

• Other aspects of the program. 

Efficiency of EAC Program 

Ten of the state and local agency officials consulted believe the EAC Program model is a more efficient 

way to deliver clean air than the traditional nonattainment designation approach. The EAC Program is 

considered by the individuals consulted to be more efficient because it is thought to generate cleaner air 

quicker than the traditional approach. EAC Program areas are perceived to have an incentive to address 

air quality issues earlier than they would otherwise. Individuals consulted believe that is why 

participants preferred to take a proactive approach rather than a retroactive response to air quality 

problems in their areas. 

In addition, the individuals consulted believe the traditional nonattainment approach can create 

resentment between states and localities. States bear criticism for administering the mandatory 

measures required under nonattainment designation. The individuals consulted observed that local 

stakeholders preferred to have some control over the types of measures that would be applied in their 

areas. Also, localities are not believed to make an effort to improve air quality if they think that the 

area will be designated nonattainment anyway. 

Most importantly, the individuals consulted expressed the view that the EAC Program establishes better 

working relationships between states and local stakeholders than occur in the traditional approach. As a 

result, stakeholders appeared to focus better on developing and implementing control measures. They 

also developed ownership of the air quality issues in their community. These factors contributed to the 

perceived efficiency of the program. 

The majority of the individuals consulted would like EPA to establish an EAC-type program for the 

2008 ozone standard. The reasons for wanting to participate in another EAC Program, include: 

57 
• Strong incentives to come into attainment; 

• Ability to build on lessons learned during the first EAC experience; 

• Positive collaboration with educated stakeholders; and 

• Need to obtain emissions reductions from local measures. 

Five of the individuals consulted believed that the efficiency of the EAC Program model depends on 

the circumstances of individual programs. First, they regard the EAC Program to be a more efficient 

method for improving air quality for areas that are relatively close to the standard. In these situations, a 

few local measures, coupled with state, regional, and national programs, are all that is needed to bring 

the area into attainment. But, the EAC Program is not considered to be the right approach for areas 

further from the standard that need more measures to reach attainment. Second, the individuals 

consulted stated that the efficiency of the EAC Program model must be studied on an area-by area 

basis. They found that the extent of local involvement in a program has a major influence on the 

efficiency of an EAC Program. Local measures may be more efficient in concept but will not work if 

stakeholders are not engaged in the process. 

One local agency could not determine whether the EAC Program is more efficient because it had never 

participated in the traditional approach. However, it believed the EAC Program did speed up the pace 

of emissions reductions in the area. Local stakeholders attempted to clean up the air as quickly as 

possible. 

One individual consulted stated that the EAC Program is not more or less efficient than the traditional 

approach. Even so, the agency believed the EAC Program did produce benefits. The EAC Program’s 

collaborative approach did make the program effective. The public also became aware that it could 

play a role in improving air quality. 

One state agency noted that the EAC Program produced positive and negative impacts. The EAC 

generated the following positive impacts: additional funding for ozone modeling; better outreach on 

ozone action days; and, greater public air quality awareness. On the negative side, the agency became 

frustrated with the procrastination of local areas in submitting required data for the state to complete 

EAC progress reports to EPA. 

A state agency implementing the traditional approach did not believe it was a more efficient approach 

in a nonattainment area. The traditional approach did not generate support for environmental measures. 

Conversely, the agency believed the EAC approach would have helped to change attitudes and generate 

local support in the area. The CAA is considered to be punitive because the agency had to obtain 

unnecessary VOC reductions under the traditional approach. 

A local agency participating in the traditional approach in this state could not compare the two 

approaches because it is not familiar with the EAC process. But, it noted that the redesignation process 

takes a very long time under the traditional approach. The agency believed that shortening this time 

period would greatly benefit local areas. 

Rather than follow the traditional approach, five areas in another state decided to pursue voluntary 

EAC-type activities. The state agency administering this program believed the traditional model is a 

less efficient method of improving air quality. This is due to the restrictive nature of the traditional 

58 
program. The agency believed that the EAC Program provided areas with the opportunity to utilize 

control measures that work best for local conditions without imposing the regulatory burden. The 

collaborative dialogue among participants provided for a more efficient method of reaching attainment 

status. In addition, the agency believed that the selection criteria made the EAC a more efficient 

approach than the traditional model because only areas that are likely to succeed are accepted into the 

program. 

EAC Program Resources versus Traditional Approach 

Six of the individuals consulted believed that local areas spent more resources in the EAC Program than 

they would have in the traditional program. This is because local stakeholders would not have been as 

involved in the traditional method. The individuals consulted noted that industry would likely have 

been the only stakeholder involved in the traditional process. 

Four of the individuals consulted stated that the EAC Program did cost more time and resources 

initially. However, they believed that the benefits from the EAC Program outweighed the costs by: 

• Saving resources in the long run; 

• Developing control measures that accommodate economic growth; 

• Developing good will among stakeholders; 

• Providing local control over program activities; and 

• Avoiding nonattainment status. 

One of these individuals consulted did comment, however, that comparing resource expenditures is not 

an appropriate method to study the EAC Program. The benefits of participating in the EAC were 

considered to have outweighed the costs. 

Five of the individuals consulted found it difficult to compare resource allocations under the two 

different approaches. One state agency reportedly saved money and staff time while planning the EAC 

Program but still had to allocate resources to SIP development. Another state agency believed that the 

EAC Program approach required fewer resources at the state level than would be needed to conduct 

rulemaking for a traditional SIP. However, it noted that the EAC Program required more resources at 

the local level to engage stakeholders. 

An agency in a different state noted that its EAC effort required more work and resource allocation up 

front. However, it believed that the traditional approach would have required more state resources over 

time. This is because local areas were more willing to contribute resources in the EAC approach 

because they had greater responsibility for the program. In comparison, nonattainment areas had to rely 

more heavily on the state for resources. So, the agency found it difficult to say whether one approach 

was more costly overall than the other. 

An agency in another state reported that staff responsibilities were redirected from technical SIP work 

to working with local EAC Program areas. No additional state resources were committed to the EAC 

program. In one respect, though, the agency believed that the EAC Program reduced the resource 

burden. In its experience, more people became involved in “bureaucratic exercises” in the traditional 

nonattainment process. Because the EAC Program did not contain comparable requirements, the 

agency found that EAC participants were able to focus resources on implementing “air quality 

improvement efforts”. The agency considered this a more efficient use of limited resources. 

59 
Instead of hiring any additional staff for the EAC Program, one County agency also added air quality 

duties to the workload of existing staff. It also found that the EAC Program approach did make more 

resources available than would have been available through the traditional approach. Local 

stakeholders stepped up, took ownership of the program, and tried to implement control measures. 

Three of the individuals consulted stated that the EAC Program did not save money or resources over 

the traditional approach. One state agency noted that it had to allocate more staff time for the EAC 

Program approach. An agency in another state said that additional resources were needed to complete 

the EAC requirement for ongoing progress reports. It considered the reporting requirement 

burdensome and very similar to the SIP approach. 

Two of the individuals consulted stated that EPA needed to provide additional technical assistance and 

education for participants to fulfill EAC Program requirements. Three of the individuals consulted 

reported that they did not have the funding and/or technical expertise needed to complete modeling 

requirements or implement local measures. One state agency pointed out that it could not have 

performed the ozone modeling needed for the EAC areas without funding from their State Department 

of Transportation. EPA Section 105 funding enabled the state to develop a modeling capability but it 

did not provide the capacity to refine the system for the EAC Program Areas. The agency believed that 

funding limitations, particularly for technical assistance, may have prevented interested parties from 

participating in the EAC Program. 

One local agency participating in the traditional approach found the process to be time consuming but a 

great learning experience as well. Although it found that more staff time is required in the traditional 

approach, the resource burden was not overtaxing. The state agency administrating the traditional 

approach noted that this approach required fewer state resources initially to deal with a local 

nonattainment area. In contrast, it found that the EAC process required a lot of resources up front but 

has long-term benefits. 

The local agency participating in a voluntary program rather than the traditional approach stated that the 

voluntary measures cost the same as the traditional approach. The resource cost was sizeable but 

unavoidable. In general, however, it considered that more local resources would be required for a 

locally-driven, EAC-type approach than in the traditional approach. The state agency administering 

this voluntary program believed that the resource allocation was burdensome but required by law. 

Since modeling would have been required under the traditional approach, the modeling aspect of the 

voluntary program was not considered to be more or less burdensome than the traditional model. 

Although the voluntary EAC approach cost a little bit more upfront, however, the agency thought it 

produced a greater yield of benefits. 

EAC Program Flexibility 

Fifteen of the individuals consulted believed the EAC Program gave local areas the flexibility to 

develop their own approach. According to one state agency, the EAC Program’s flexibility created an 

intergovernmental dynamic that would not likely have occurred under the traditional approach. This 

dynamic is credited with bringing a more willing and receptive response from the local area to the 

program. A County agency stated that local flexibility was a strong selling point for bringing a 

skeptical community showing resistance to an unknown program. Another state agency believed that 

60 
the opportunity for flexibility in local decision making was critical for obtaining support for the 

program. 

The EAC Program areas in two states would have come into attainment through national measures 

alone. By participating in the EAC Program, however, the states believed they had the flexibility to 

develop control measures that were appropriate for their own areas. For example, an area may have 

been interested in pursuing an anti-idling program originally to save fuel. Because the anti-idling 

program would also provide air quality benefits, it may have made it easier politically for the area to 

implement the program in the context of the EAC Program. In addition, the flexibility of the EAC 

Program was considered to have provided an opportunity for local programs to include controversial 

measures such as lowering the speed limits for truckers. 

One local agency commented that the EAC Program’s flexibility allowed localities to focus on specific 

industries of interest. As a result, it did not have to spend resources on all sources in the area. A local 

agency in another EAC Program area noted that the flexibility provided an opportunity to develop 

measures that would be best for each individual source or sources. It believed that the local control 

measures adopted in EAC Program areas could not have been mandated by states. 

Three of the individuals consulted believe it is possible that the EAC Program may have provided 

flexibility to local areas. Although more flexibility may have been available, one state agency 

maintained that its EAC Program areas did not take advantage of the added flexibility. A local agency 

stated that there was not much it could do at the local level. It believed that whatever emissions 

reductions it generated would be a drop in the bucket compared to those coming from all the federal 

and state programs. 

The local agency and state agency that followed the traditional approach agreed that it does not give 

local areas flexibility to develop their own approach. However, the local agency stated that it is 

difficult for local areas to develop alternative approaches to complex issues when state government 

already has a good approach. 

A local agency participating in a voluntary program rather than the traditional approach believed that 

the traditional approach does not provide flexibility to local areas. The state agency that administered 

this approach noted that the CAA does not provide local flexibility in the traditional approach. 

Threat of Nonattainment Designation as Incentive 

Sixteen of the individuals consulted stated that the EAC Program would not have succeeded without the 

threat of nonattainment designation or without the program being part of the larger SIP effort. They 

believed that states and local areas needed motivation to participate in the program. Moreover, EAC 

Program participants indicated that they entered the program to avoid the NSR and Conformity 

Program requirements of nonattainment designation. They were also concerned about the impact of a 

nonattainment designation on economic development. In addition, the individuals consulted thought it 

would be difficult to get local stakeholders to participate in the program without the threat of 

nonattainment. 

Four of the individuals consulted were not certain whether the EAC Program would have succeeded 

without the threat of nonattainment. They believed that some areas might have participated under the 

right circumstances. 

61 
One state agency commented that one of its EAC Program Areas would have participated without the 

threat of nonattainment because it is a very environmentally-motivated area. The local agency agreed 

that it would have participated in the EAC without the threat of nonattainment. 

EAC Program Process-Related Goals and Requirements 

Based on information contained in the bi-annual progress reports from the 14 nonattainment-deferred 

and six attainment areas, all of the areas studied met their progress-related requirements. However, one 

attainment area was late with some of their bi-annual progress reports. 

Six of the individuals consulted stated that EPA should streamline the EAC biannual reporting process. 

They believe that less frequent reporting would have the same or greater value than a biannual exercise. 

In addition, EPA is encouraged to develop a simplified reporting process such as: a more quantitative 

approach; a standard checklist; or a standard electronic form. However, six other individuals consulted 

felt that the reporting requirements were not more burdensome than the traditional approach. 

Longer Term Impact 

EAC Provision for Longer Term Emission Reductions or Continued Action In The Future 

Based on information contained in the progress reports from the 14 nonattainment-deferred and six 

attainment areas, these areas have entities that will continue the EAC Program activities beyond April 

2008.26 

Nineteen of the individuals consulted stated that the EAC Program activities did provide for longer term 

emission reductions or create a local “infrastructure” for further or continued action in the future. 

Several of the individuals consulted noted that the EAC control measures would remain in place for the 

foreseeable future. There are several reasons for this. They include the following: 

•	 EAC control measures may have been adopted without expiration dates or are intended to be 

permanent; 

•	 Control measures that are included in SIPs will remain in effect as long as necessary; 

•	 Local areas may value the benefits of air quality measures put in place during the EAC
 

Program; and 


•	 Due to the anti-backsliding provision, it may be necessary to retain EAC Program control 

measures to comply with the SIP. 

The EAC is credited with creating an infrastructure for continued action in the future. One state agency 

reported that air quality is among the elements in the smart growth principles adopted by planning 

districts during the EAC Program. These measures have and will continue to remain in place after the 

EAC Program. The agency believed it was important that the program was being implemented by 

government entities that will remain in place long term. 

An agency in another state noted that an EAC Program task force created during the EAC Program’s 

development and implementation formed a successor group after the program ended. About 80 

members attend the regularly scheduled meetings. The new task force has already developed a 

26 To clarify, the EAC control measures are part of the SIP and are, therefore, Federally enforceable and are to continue to be 

implemented in the future regardless of whether an entity has been designated to continue EAC Program activities. 

62 
document of control measures for planning agencies in the state. The agency stated that this document 

prepared the groundwork for the next ozone standard. 

Local areas in another state have indicated they are committed to keeping air quality programs going. 

Financial support and the new standard will help keep those commitments alive. One local area, for 

example, wants to expand air quality measures beyond ozone to address PM2.5 and greenhouse gases 

(GHG). Another community has inquired about funding for woodstove changeout programs. A 

different area has developed a website, conducted significant outreach, and committed to funding an air 

quality coordinator. 

An agency in another state believed that the EAC Program did provide a learning experience. It also is 

credited with facilitating inter-state collaboration on air quality issues, particularly PM2.5 emissions. 

However, the local EAC Program activities did not provide much capacity for continued action in the 

future. 

One local agency participating in the traditional approach believed that this approach created a close 

working relationship between local stakeholders and the state. The relationship has proven to be 

beneficial. In addition, local stakeholders learned from the experience. The state agency administering 

this program believed that the EAC approach provided these benefits to a greater extent. It believed the 

traditional approach is more short sighted and does not get local long-term emissions reductions. 

According to a local agency participating in a voluntary program rather than the traditional approach, 

the public received a great deal of information about air quality. This generated an awareness of air 

quality issues. The EAC-type activities are credited with generating advocacy for increased bus routes, 

especially to outlying areas. The state agency administering this voluntary EAC program noted that 

the traditional approach locks in control measures and contingency measures for an extended period of 

time. The traditional approach also provides for continued and more concrete control measures. Under 

the voluntary approach, however, the agency notes that it created a Clean Air Coalition of regional 

stakeholders that continues to function. 

EAC Activities and Continued Reductions in Ozone 

Sixteen of the individuals consulted believed that EAC Program activities resulted in continued 

reductions in ozone and air quality improvement activities/policies that were not foreseen initially as 

the EAC Program was implemented. Two of the individuals consulted could not determine at this time 

whether unforeseen reductions would continue. Two other individuals consulted reported that EAC 

Program activities did not lead to continuing unforeseen air quality benefits. 

Four states maintained that the EAC Programs led to the development of policies and projects that 

yielded continuing benefits that would not have occurred otherwise. These included: 

• A school bus anti-idling program; 

• Increased use of biodiesel; 

• Alternative modes of transportation; 

• Carpooling; 

• Expanded bus routes; 

• Policies requiring sidewalks and green-spaces; 

• Local capacity building; 

63 
• Cement kiln voluntary reductions; 

• Airport reductions; 

• Lawn mower trade-in programs; 

• Retrofits for compressor engines; and 

• A green building program. 

In another state, the EAC Program established an atmosphere that helped create alliances to push the oil 

and gas industry for emissions reductions. As a result, the EAC Program is credited with generating 

large emissions reductions than would not have occurred without the program. The state agency 

continues to ask for additional reductions from the oil and gas industry. It plans to ask for more 

reductions from the industry in the future as well. 

Three local areas reported that the EAC Program provided ongoing unforeseen air quality benefits such 

as: a regional ride share website for twenty-two participating counties; an ozone watch/warning system; 

greater use of greenways, bikeways and similar measures; closer and more trusting inter-governmental 

relationships; and greater public awareness of air quality issues. 

A local agency participating in the traditional approach stated that the traditional approach increased 

public awareness of air quality issues. It believed that the growing awareness may lead to vehicle 

emissions reductions if the public changes personal behavior patterns by driving less or filling up at 

appropriate times. The state agency administering this traditional program did not think that there 

would be any additional unforeseen reductions. 

A local agency participating in a voluntary program rather than the traditional approach did not think 

there would be additional unforeseen reductions. Most of the voluntary activities have already 

concluded. The agency reported that one criticism of the voluntary approach is that it keeps initial 

momentum going but falters once the initial catalyst has been removed. According to the state agency 

administering the voluntary EAC program, desulfurization will result in mercury reductions that were 

not foreseen. This will help improve mercury-impaired waters. 

Outreach and Stakeholder Interaction 

EAC Air Quality Task Forces 

Based on information contained in the bi-annual progress reports, the 20 areas included in the study did 

have air quality task forces except for three of the attainment areas: Mountain Area of Western North 

Carolina (Asheville); Oklahoma City, Oklahoma; and Tulsa, Oklahoma. The Mountain Area had a 

group but it included only government representation. For the areas that had task forces, all had diverse 

representation from at least three sectors except for Chattanooga, Tennessee-Georgia and Nashville, 

Tennessee. Chattanooga addressed their task force needs through the public transportation planning 

organization, which did not have representation from least three sectors. 

Ozone Awareness Outreach 

Based on information contained in the bi-annual progress reports from the 14 nonattainment-deferred 

and six attainment areas, the 20 areas included in the study did conduct ozone awareness and all but one 

– Chattanooga, Tennessee-Georgia – had a coordinator. 

64 
Stakeholder Engagement 

Seventeen of the individuals consulted stated that the EAC Program did engage local stakeholders in 

the program. The diverse range of local stakeholders included local governments, elected officials, the 

media, councils of governments, industry, local businesses, utilities, chambers of commerce, 

environmentalists, and other organizations. One state agency noted that it had to reach out to 

stakeholder groups, which are not customarily involved in air quality issues. Another state agency 

maintained that public engagement in the process was the largest benefit of the EAC Program. A local 

agency stated that the program generated a greater level of engagement from a wider range of local 

stakeholders than found in other issues. Another local agency summarized the importance of engaging 

local stakeholders in the process. It stated that, in general, suggestions from local stakeholders are 

better received than ideas from government. The EAC is credited with improving the working 

relationships between states and local stakeholders. It is believed that the improved relationships and 

the flexibility given to local areas provided opportunities to consider measures that would not have been 

discussed outside of the EAC Program. 

The individuals consulted believed that the EAC Program produced the following additional benefits. 

1.	 Prior to the EAC Program, local stakeholders were considered to have a limited awareness of air 

quality issues. Because of the EAC Program, however, elected officials, citizens, and other 

local stakeholders became more aware of air quality issues. The increased level of public 

awareness may not have occurred under the traditional approach. One state agency noted that 

local stakeholders are now discussing air quality issues amongst themselves. It also credited the 

EAC Program for creating clean air advocates at the local level. 

The EAC also is credited with increasing the involvement of local stakeholders in air quality 

issues. Stakeholders had to take part in the initial stages of the program to meet the EAC 

schedule. Besides getting involved more quickly, stakeholders also participated in air quality 

issues to a greater extent than they would have under the traditional approach. 

A local agency noted that citizens now discuss aspects of air quality that they would not have 

known about prior to the EAC Program. At stakeholder meetings, for example, citizens are 

aware of particulates, the new standards, and other air quality issues. In addition, the public is 

aware that personal actions, such as exchanging gas cans and lawn mowers, can improve air 

quality. 

2.	 The EAC Program process is credited with strengthening the relationship between states and 

local stakeholders. One state agency maintained that its relationship and communication with 

local stakeholders was not nearly as strong prior to the EAC Program. Another state agency 

acknowledged that it had an outreach program to local areas prior to the EAC Program. 

However, the EAC Program enhanced its outreach effort. The EAC generated broad 

stakeholder representation in each of the participating areas. As a result, the agency believed 

the state’s outreach efforts are better now. 

One state agency believed that its enhanced relationship with stakeholders has already provided 

important benefits. The state legislature must approve all proposed regulations. Before 

receiving legislative approval, however, the state has to demonstrate stakeholder support for a 

regulation. The agency was able to tighten the open burning ban and NOx reduction regulations. 

65 
But, the agency stated that it would have not have been able to obtain the stakeholder support 

needed to get the regulations passed without the improved relationships from the EAC Program. 

3.	 The EAC Program is credited with creating an infrastructure for stakeholder involvement in 

future air quality issues. Seven of the individuals consulted noted that stakeholder groups 

remain involved in air quality issues. Three of the stakeholder groups are working with states 

on implementation of the PM2.5 standard. One local agency stated that its entire metropolitan 

area has been working proactively on PM2.5 issues for the past year. Many of the same people 

who were involved in the EAC are now working on PM2.5. The relationships established during 

the EAC Program are credited with making collaboration on PM2.5 much easier. 

One County agency stated that it could not have afforded to pay for the technical expertise provided by 

stakeholders participating in the EAC Program. Technical experts from industry and the state continue 

to help the County with EPA guidance, other air quality issues, and community events. 

One state agency maintained that the infrastructure developed through the EAC Program will help it 

meet the new ozone standard quicker. It plans to do more of the same activities developed during the 

EAC Program to meet the new standard. Moreover, the state is very interested in developing the EAC 

Program concept. It is exploring whether states and localities can build upon previous programs to 

continue the EAC. 

Two of the individuals consulted found it difficult to determine whether the EAC Program increased 

stakeholder involvement. According to one individual consulted, local stakeholders participated 

extensively in the EAC Program. However, air quality issues were already important to stakeholders 

before the areas became involved in the EAC Program. The other individual consulted did not track 

stakeholder involvement. 

Due to the rural nature of the region, one EAC Program area did not have much stakeholder 

participation. The local agency stated that air quality issues were not that important to the general 

public. 

One local agency in one area participating in the traditional approach stated that it engaged local 

stakeholders. Participants included metropolitan planning organization committees, local government, 

and business. However, there was not much public participation. The state agency administering the 

traditional program noted that the approach did not engage stakeholders in the same area but not in 

another. The lack of stakeholder engagement in that area was thought to be due to the lower level of 

resources spent by the state in the area. 

A local agency that participated in an EAC-type voluntary approach rather than the traditional approach 

stated that the voluntary approach brought together elected officials and various other stakeholders. The 

state agency that administered the voluntary EAC-type approach agreed that local stakeholders were 

engaged in the process. 

Other Aspects of the Program 

EAC Requirements versus CAA Nonattainment Area Requirements 

Table B-32 lays out in detail the requirements for EAC Program areas alongside the requirements the 

14 nonattainment-deferred areas could have faced had they not pursued the EAC Program and instead 

66 
were designated nonattainment. Specifically, the table presents an outline of the general Subparts 1 and 

2 requirements of the CAA. The presentation of the requirements in the table and the discussion here 

serves historical purposes only. Following the April 2004 area designations, the implementation 

program for the 8-hour standard had to be revised in light of a court decision that affected how areas 

were classified. This may have affected some of the EAC Program Areas if they had been designated 

nonattainment in April 2004 instead of participating in the EAC Program. Most of the Subpart 1 

requirements in Table B-32 no longer apply to the areas that were originally placed under Subpart 1. 

EPA is currently developing rulemaking to address the requirements for the areas that were originally 

placed under Subpart 1. However, for historical purposes only the study performed a comparison of 

Subpart 1 nonattainment area requirements versus EAC area requirements, which is presented here. 

(The Marginal Subpart 2 areas are not included in the comparison here but can be found in Table B-32.) 

In some respects, the EAC Program required more stringent requirements than a Subpart 1 

nonattainment program. In other respects, however, the Subpart 1 program required more stringent 

requirements. And, in yet other ways, the requirements for the two types of areas were comparable. 

Here are the major differences in requirements: 

In a few respects, the EAC Program required more stringent requirements than a Subpart 1 

nonattainment program: 

•	 Earlier date for submission of an attainment demonstration SIP; 

•	 Earlier attainment date; 

•	 Earlier date for compliance with emission reductions needed for attainment; and 

•	 Planning milestones such as progress reports for planning, which, if not met, would have caused 

the termination of the EAC deferral of the nonattainment designation. 

In many respects, the Subpart 1 nonattainment program required more stringent requirements than the 

EAC Program: 

•	 Nonattainment area NSR; 

•	 General Conformity Program; 

•	 Transportation Conformity Program including, but not limited to, the following requirements: 

o	 Consultation between air quality and transportation agencies on both the SIP and the 

transportation plan and Transportation Improvement Program 

o	 Transportation and emissions modeling requirement 

o	 Build/no build test 

o	 Hot spot test 

o	 Emission budget tests 

o	 “Freezes” if certain requirements are not me; 

•	 RACT; 

•	 Attainment had to be achieved as “expeditiously as practicable”; 

•	 Failure to submit a SIP would ultimately result in sanctions and Federal Implementation Plans; 

and 

•	 Longer period (10 years) for showing of maintenance with the standard if state/area requested 

redesignation to attainment. 

67 
o	 EAC Program areas only required to demonstrate maintenance of the standard for 

five years (although states for almost all of the EAC Program areas in the Southeast 

(EPA Region 4) submitted maintenance plans for 10 years).27 

In two respects, the requirements for Subpart 1 and EAC Programs were comparable: 

•	 An attainment demonstration using photochemical grid modeling, although the EAC modeling 

required that fewer episodes are modeled and 

•	 Preparation of a revised SIP if the area failed to attain by its attainment date. 

In addition, the Subpart 2 nonattainment classification would have been more stringent than the EAC 

Program in the case where an area (such as a marginal area) failed to attain by its attainment date. In 

that instance, it would have been reclassified to at least the next highest classification. The area would 

then have been subject to additional mandatory source control measures and planning requirements. 

However, a marginal area would not have been required to submit an attainment demonstration or to 

have satisfied other planning requirements. 

Finally, it is worth noting that, pursuant to authority under Section 110 of the CAA, EPA has long 

required states to submit emission inventories to EPA as part of their SIP. The inventories have to 

contain information regarding the emissions of criteria pollutants and their precursors (e.g., VOCs). 

This applies to EAC and non-EAC Program areas in states. In 2002 EPA simplified and consolidated 

emission inventory reporting requirements, established new reporting requirements related to PM2.5 and 

regional haze, and established new requirements for the statewide reporting of area source and mobile 

source emissions.28 

3.2 Observations 

3.2.1 Overall Observations Resulting from the Study 

Because of the study’s limitations, it is difficult to draw hard findings and conclusions. However, the 

study was able to make a number of observations about emission reductions, changes in air quality, and 

issues related to program design and process. 

Overall, a number of states in the Northeast had serious concerns about the approach. The EAC 

program was generally popular with participating state and local officials. These officials indicated the 

EAC Program model provided the right combination of incentives, flexibility, and structure and was 

used to foster a collaborative environment that: 

1) Encouraged local stakeholders to take ownership of the ozone air quality issue and to develop 

and adopt local measures; 

2) Increased awareness of ozone air quality issues with key stakeholders and, to a degree, with the 

public; and 

27 EPA Region 4 worked with almost all of the participating EAC states in the Southeast – North Carolina, South Carolina,
 

and Tennessee but not Georgia – to voluntarily agree to develop and submit maintenance plans that extended to 2017, 5
 

years past the year 2012 minimum date for EAC areas.
 

28“Consolidated Emissions Reporting Rule,” 67 Federal Register 39602-39616,
 

http://www.epa.gov/ttn/chief/cerr/cerr.pdf, June 10, 2002. 

68 
3)	 Helped establish working relationships between state environmental agencies and local 

government that may prove beneficial for future implementation of air quality standards. 

Emission Reductions 

For the vast majority of the areas included in this study, the EAC Program appeared to successfully 

encourage the development and adoption of quantifiable, local emission reduction control measures by 

the December 2005 deadline. Ninety-six percent of the total 388 measures implemented for the 20 

areas included in the study were implemented by the EAC December 2005 deadline, according to EAC 

progress reports and SIPs. Estimated emission reductions from local measures collectively constituted 

an estimated nine percent or more of quantified NOx and VOC emissions reductions in seven of 18 

EAC Program areas included in this study for which complete emissions reductions data were available 

(the remaining reductions were achieved from national and state measures). The local measures were 

“directionally correct” and should assist the areas in maintaining the ozone NAAQS. 

According to many state and local officials, the program also resulted in quantifiable emission coreductions of other pollutants, including particulate matter and/or air toxics. 

Air Quality 

The study analyzed the air quality improvements experienced by EAC Program areas in the eastern 

U.S. by comparing them to improvements achieved in nearby nonattainment areas that did not 

participate in the EAC program. (This could not be analyzed in the Colorado, Oklahoma and Texas 

EAC areas, because there were not ozone nonattainment areas located near enough to provide a 

comparison.) The analysis found that the changes in air quality in eastern EAC Program areas were 

consistent with those observed in non-EAC areas. Additionally, consistent with the expectation that 

most progress towards ozone attainment in the East would come generally from national measures such 

as vehicle standards and power plant controls, it appears that, based on air quality data, local EAC 

measures adopted and implemented in EAC Program areas in the East did not produce an early, 

demonstrable incremental improvement in air quality. Relative to non-EAC Program areas, the 

information compiled appears to indicate that, for EAC areas in the East, progress toward meeting the 

air quality standards on time was not adversely affected by two factors: (1) the absence of some or all 

of the nonattainment area requirements that traditional nonattainment areas face, or (2) population and 

vehicle miles traveled growth that most of the areas experienced during EAC Program implementation. 

Relative to non-EAC Program areas, these two factors also did not appear to adversely affect the ability 

of EAC areas in the East to attain the NAAQS by December 2007 (or earlier for many EAC areas). 

The fact that local measures did not produce an early, demonstrable incremental improvement in air 

quality can be explained in part by the fact that quantified NOx and VOC emissions reduction estimates 

from local EAC measures represented a small part of emissions overall: (1) in EAC Program areas; (2) 

in states in which they are located, and (3) as compared to reductions achieved in each state through the 

NOx SIP call. The best way to measure the impact on air quality of the EAC local measures – and 

whether they contributed to the areas attaining early – would be to conduct incremental air quality 

modeling of the emissions reductions from those measures. Short of that, the reductions are so small 

relative to the emission reductions from federal and state measures that their impact is indiscernible. 

All but one of the EAC areas did attain the ozone NAAQS by December 31, 2007; in fact, 15 of the 20 

EAC areas attained the 8-hour ozone NAAQS by December 31, 2004 – prior to the required 2005 

implementation date for the EAC control measures. 

69 
This study looked at ozone air quality through 2007. And while almost all the EAC areas met the 

ozone NAAQS before 2007, it remains to be seen what will happen to ozone air quality levels in these 

areas as they grow in the next 5 to 10 years. Ozone air quality in many of the areas will continue to be 

influenced by, among other things, state and national programs to reduce NOx and VOCs. Some state 

and local officials believe that local measures should benefit air quality in the future. EAC Program 

areas were required to develop plans to demonstrate how they would address emissions growth and 

maintain meeting the ozone NAAQS for five years (to 2012). They did so, and almost all the states in 

the southeastern U.S (EPA Region 4) with EAC Program areas submitted maintenance plans for 10 

years. 

The study also looked at whether the air quality modeling provided insight into what degree the “local” 

EAC measures contributed to additional improvements in air quality, beyond the improvements 

provided by the state and national measures. The only reliable way to quantify the air quality 

improvements from the EAC local measures is to model the local measures independently of the state 

and national measures. But the modeling performed for the EAC SIPs did not provide such an analysis. 

For this study the information available only allows for a review of whether the actual air quality 

improvement achieved is consistent with the level of improvement predicted by the model. After 

making this comparison, this study observes that the estimates in the modeled demonstration are 

consistent with the air quality achieved. Therefore, the modeling provided reasonable information. 

It was beyond the scope of this study to analyze the improvements in short-term or long-term air quality 

that would have otherwise occurred in the affected EAC areas if they had followed the traditional 

requirements under the CAA associated with a nonattainment designation. For example, several of the 

nonattainment-deferred areas experienced new stationary source activity that may have been subject to 

permitting requirements under the CAA nonattainment NSR program had the same activities been 

undertaken while these areas had a designation of nonattainment. The proposed emissions increases for 

some of those sources were controlled under the CAA’s PSD Program. As noted above, this study did 

not quantify emission changes in EAC versus non-EAC areas and is, therefore, unable to provide 

information on the impact on emissions of the absence in EAC areas of some or all of the 

nonattainment area requirements that traditional nonattainment areas face, including those of the 

Nonattainment NSR Program. 

State and local agencies consulted did believe the EAC approach to be well suited for nonattainmentdeferred areas that were new to the ozone air quality issue and had ozone air quality levels relatively 

close to the standard. Those areas did not face the same degree of ozone air quality challenge faced by 

some of the nation’s largest areas and so, in that regard, their air quality problems were more 

manageable. EAC Program participants in these areas took ownership of their air quality problem in a 

way that was not likely, in the opinion of the state and local agencies consulted, to have occurred to the 

same degree under the traditional approach, absent a concerted EAC-type effort or unless the 

community was already active on environmental issues. 

Program Design and Process 

Some EAC Program areas did not experience the “collaborative environment” the EAC Program model 

fostered in other EAC Program areas. Based on the study discussions, several possible reasons 

emerged to help explain this: 

70 
•	 Insufficient technical support for EAC Program areas from EPA and the states; 

•	 Insufficient state or local agency leadership to help start and/or shepherd the EAC Program 

process; 

•	 Lack of public interest due to insufficient information about local air quality issues; and 

•	 Ozone air quality problem believed to be solvable due to state and national measures alone so 

there was not much action perceived to be needed locally. 

The state and local agencies implementing the EAC Program reported that, in order to succeed, the 

EAC program needed (1) the threat of reinstatement of the nonattainment designation as the 

consequence of failure to meet EAC Program requirements and (2) for the EAC Program to be part of 

the larger SIP program. The majority of state and local agencies consulted believed that states and local 

areas needed motivation to participate in the program for it to succeed. 

The EAC Program required as much EPA staff resources or less than the staff resources EPA estimated 

would have been needed to implement the regular program for the same areas. The question of whether 

the EAC Program saved estimated human resources varied by EPA region. The study lacked data to 

assess the resource impact of the EAC program on the participating state and local agencies. 

3.2.2 Specific Observations 

Quantitative Observations 

Environmental Aspects 

The following seven quantitative observations relate to environmental aspects of the EAC Program 

study. They are based on a quantitative information gathered for 20 EAC Program areas – 14 

nonattainment-deferred and 6 designated unclassifiable/attainment – and, thus, pertain to those areas. 

Observation 1: In the East air quality changes in EAC Program areas were consistent with air 

quality changes in non-EAC 8-hour ozone nonattainment areas in the same region. Based on a 

study of meteorologically-controlled air quality data from 2001-2003 to 2005-2007, air quality changes 

in EAC Program areas in the East are consistent with changes in non-EAC Program areas in the East. 

Any pre-program concern that ozone air quality in EAC Program areas would suffer as compared to 

non-EAC Program areas does not appear in retrospect to have been justified, at least with respect to air 

quality measured through 2007. (The study did not quantify emission changes in EAC versus non-EAC 

areas and is, therefore, unable to comment on the impact on emissions of the absence in EAC areas of 

some or all of the nonattainment area requirements that traditional nonattainment areas face.) The 

study lacked adequate sites with meteorologically-controlled ozone air quality data to enable us to make 

comparisons for areas in the Central Southwest. Therefore, the study cannot comment on how those air 

quality gains in that region compare to other non-EAC ozone areas there. The study did not compare 

two individual cities because it is very difficult to determine if they are comparable. Comparing the 

range of reductions between two groups is more reasonable, as the study did for areas in the East. 

Observation 2: States relied largely on state and national measures for their attainment 

demonstrations. Despite having quantified local measures, and, thus, satisfying one of the criteria 

necessary for a measure to be included in the attainment demonstration, states chose for the most part 

not to include those measures as part of the attainment demonstration. The study did not explore why 

states chose to include some measures in the attainment demonstration but not others. 

71 
Observation 3: The overwhelming majority of the EAC Program areas included in the study 

attained the 8-hour ozone NAAQS despite growth in population and VMT. Nineteen of the 20 

EAC Program areas included in the study that attained the 8-hour ozone NAAQS by December 2007 

did so despite most of them experiencing estimated growth in either VMT or population or both during 

implementation of the EAC Program (in several cases these growth rates met or exceeded national and 

regional growth rates). In fact, 15 of the 20 EAC areas attained the 8-hour ozone NAAQS by 

December 31, 2004, prior to the required 2005 implementation date for the EAC control measures. (It 

is also important to note that the remaining 9 attainment areas for which the study did not compile 

quantitative information also maintained their attainment status with respect to the 8-hour NAAQS 

through December 2007.) 

Observation 4: The EAC Program successfully encouraged local areas in the adoption and 

development of meaningful, local control measures in the majority of the EAC Program areas 

included in the study, representing a significant percentage of quantified NOx and VOC emissions 

in several of the areas included in the study. Despite the uncertainty inherent in emission reduction 

estimates, the estimated individual and collective emissions reductions from these local measures 

constituted significant percentages of quantified NOx and VOC emissions in those areas. These 

measures are what the study terms “directionally correct”. While they should help the areas maintain 

their ozone air quality levels, these measures did not produce a discernible, incremental change in 

ozone air quality levels that helped the areas meet the EAC requirement of attaining early by December 

2007 (a requirement every area except Denver met). Twelve of nineteen nonattainment-deferred and 

attainment EAC Program areas included in the study that had complete emission reductions data had 

less than nine percent of their quantified emission reductions from local measures. This is likely due to 

one or more factors: 

•	 Local measures were not adopted, which was the case for two areas; 

•	 Attainment was demonstrated without including local measures; 

•	 Certain measures did not lend themselves to quantification; and 

•	 State determined that the potential emissions reductions were not great enough to justify the 

effort EPA requires to document those projected emissions reductions. 

Observation 5: Ninety-six percent of the total 388 measures implemented for the 20 areas 

included in the study were implemented by the EAC December 2005 deadline, according to the 

EAC progress reports and SIPs. Conversely, four percent (i.e., 14 measures) of the 388 measures 

were not implemented by the EAC December 2005 deadline. Of the 14 measures not implemented by 

December 2005, one had quantified NOx and/or VOC emissions reductions associated with them and 

seven were implemented after 2005 -- in 2006 or 2007. Only one of the measures was modeled in an 

area’s EAC SIP attainment demonstration. 

Observation 6: For the majority of EAC Program areas, quantified NOx and VOC emissions 

reduction estimates from local measures represented a small fraction of 2002 emissions overall in 

the respective EAC Program area, in the state in which the EAC area is located, and as compared 

to reductions achieved in that state through the NOx SIP call. Comparing emissions reductions 

from local EAC measures to these other emissions values helps to explain, at least partly, why the 

improvements in air quality in EAC Program areas in the East are consistent with changes in air quality 

in non-EAC Program areas. The comparison helps to put the relative value of those estimated 

reductions into perspective against all emissions contributing to ozone formation. There arguably were 

72 
EAC measures adopted and implemented in EAC Program areas that might not have been considered 

had the areas been designated traditional nonattainment. But, in relative terms, the measures did not 

reduce total emissions very much and, thus, did not produce measurable incremental improvements in 

air quality. 

Observation 7: Air quality modeling contained in the SIPs for the 20 EAC areas included in the 

study predicted improvements in air quality that were generally consistent with the eventual 

observations. The study addressed whether the modeling provided insight into what degree the “local” 

EAC measures contributed to additional improvements in air quality, beyond the improvements 

provided by the state and national measures. The only reliable way to quantify the air quality 

improvements from the EAC local measures is to model the local measures independently of the state 

and national measures. But the modeling performed for the EAC SIPs did not provide such an analysis. 

For this study the only assessment that could be performed was to determine whether the actual air 

quality improvement achieved is consistent with the level of improvement predicted by the model. 

After making this comparison, the study observes that the estimates in the modeled demonstration are 

consistent with the air quality achieved. 

Program Design Aspects 

The observation is related to the quantitative, programmatic aspects of the EAC Program study. It is 

based on a quantitative study of EPA resources expended relative to the whole EAC Program consisting 

of 29 areas – 14 nonattainment-deferred and 15 designated unclassifiable/attainment – and, thus, pertain 

to those areas. 

Observation 8: The EAC Program required as much EPA human resources or less than a 

hypothetical traditional approach depending on the EPA region implementing the program. For 

EPA, the answer to the question of whether the EAC Program saved estimated human resources varied 

by EPA region. The study lacked data to quantitatively assess the resource impact of the EAC program 

on the state and local agencies. 

Qualitative Observations 

Environmental Aspects 

The following two observations are related to the qualitative review of the environmental aspects of the 

EAC Program study. Observation 9 is based on information from EPA regional office and state agency 

permitting databases. Observation 10 is derived from information gathered though consultations with 

state and local agency officials. 

Observation 9: Less than half of the nonattainment-deferred areas experienced new stationary 

source activity that may have been subject to permitting under the CAA nonattainment NSR 

program had the same activities been undertaken while these areas had a designation of 

nonattainment. Six of the 14 nonattainment-deferred areas experienced new stationary source activity 

that may have been subject to permitting under the CAA nonattainment NSR program had the same 

activities been undertaken while these areas had a designation of nonattainment, (this could be an 

underestimate given the lack of compete information on permitting activity). The proposed emissions 

increases from the new and modified sources in four of the six areas were controlled under the CAA’s 

PSD program. (The study did not quantify emission changes in EAC versus non-EAC areas and is, 

therefore, unable to comment on the impact on emissions of the absence in EAC areas of some or all of 

73 
the nonattainment area requirements that traditional nonattainment areas face, including nonattainment 

NSR.) 

Observation 10: The state and local agencies implementing the EAC Program believe that the 

EAC activities generated direct environmental benefits other than ozone reduction. A majority of 

the individuals consulted reported that EAC activities directly generated environmental benefits other 

than ozone reduction. The largest benefit came from reductions of PM2.5 through such programs as 

alternative fuels, open burning bans, freight partnership, diesel and school bus retrofits, and idling 

reduction. EAC activities also generated reductions in GHG, air toxics, NOx, and VOCs. However, 

several individuals consulted stated that no additional environmental benefits were generated directly 

from the EAC activities. This is partly because EAC control measures were selected from a list of 

existing state rules. In these cases, no local measures were developed for the EAC. 

Program Design Aspects 

The following four qualitative observations are based on a qualitative review of the program design 

aspects of the EAC Program study. The observations draw on information gathered through 

consultations with state and local agency officials. 

Observation 11: The state and local agencies implementing the EAC Program believe that the 

EAC Program, in order to succeed, needed (1) the threat of reinstatement of the nonattainment 

designation as the consequence of failure to meet EAC Program requirements and (2) for the 

EAC Program to be part of the larger SIP program. The majority of the individuals consulted 

believed that states and local areas needed motivation to participate in the program for it to succeed. 

For many states and local areas, EAC participants were motivated to enter the program as 

nonattainment-deferred areas specifically to avoid the NSR and Conformity Program requirements for 

their 8-hour ozone areas. Those areas were also concerned about the impact of a nonattainment 

designation on economic development. 

Observation 12: The state and local agencies implementing the EAC Program believe the EAC 

Program gave local areas the flexibility to develop their own approach to meeting the 8-hour 

ozone standard that might not otherwise have been present under the traditional approach. The 

majority of the individuals consulted stated that the EAC Program gave local areas the flexibility to 

develop their own approach. They believed that the opportunity for flexibility in local decision-making 

was critical to obtaining support for the program. 

Observation 13: The state and local agencies implementing the EAC Program believe the EAC 

Program effectively engaged and involved local stakeholders in the program and created positive 

working relationships. The majority of the individuals consulted supported this statement. The 

diverse range of local stakeholders engaged in the EAC Program areas included local governments, 

elected officials, the media, councils of governments, industry, local businesses, utilities, chambers of 

commerce, environmentalists, and other organizations. According to the individuals consulted, the 

EAC Program model produced numerous intangible benefits, such as a greater public awareness of air 

quality issues and local stakeholder participation in air quality improvement than would have occurred 

under the traditional approach. The EAC Program is also credited with: (1) improving the working 

relationships between states and local stakeholders, and (2) helping create an infrastructure for 

stakeholder involvement in future air quality issues. The improved relationships and flexibility are 

74 
believed to have created an environment for local areas to consider measures that would not have been 

discussed outside of the EAC Program. 

Observation 14: The state and local agencies implementing the EAC Program believe that it is 

expected to result in continued reductions in ozone and air quality improvement activities and 

policies that were not foreseen, initially, as the EAC Program was implemented. The majority of 

the individuals consulted believed that: (1) EAC efforts would lead to continued reductions in ozone 

and air quality improvement activities and policies that were not originally foreseen; and (2) programs 

adopted by the EAC would continue providing additional reductions beyond those already achieved or 

create a local “infrastructure” for further or continued action in the future. It is believed that some of 

the policies, projects and activities would not have occurred without the EAC Program. Several of the 

individuals consulted noted that the EAC control measures would remain in place for the foreseeable 

future. In addition, local organizations that did not address air quality issues prior to the EAC Program 

are now considering air quality issues in their areas. 

3.2.3	 Study Results Where Information is Insufficient or Too Ambiguous to Make an 

Observation 

Observations did not emerge from information in three areas where the study lacked sufficient 

information or the information was too ambiguous: 

• Program design aspects 

o EAC program efficiency; 

• Environmental aspects 

o EAC program requirements versus Subpart 1 requirements; and 

o Conformity Program. 

Program Design Aspects 

EAC Program Efficiency 

Based on the consultations with state and local officials, the EAC model is believed to be a more 

efficient way to deliver clean air quicker than the traditional nonattainment designation approach. 

However, the impact of the EAC Program on state and local resources is unclear, including whether the 

EAC approach saved money and resources for state and local agencies over the traditional approach. 

The majority of the individuals consulted believe the EAC model is a more efficient way to deliver 

clean air quicker than the traditional approach. Several of the individuals consulted believe that the 

EAC is a more efficient method for areas that: (1) are relatively close to the standard, and/or (2) have 

significant local stakeholder involvement. 

Several of the individuals consulted believe that local areas spent more resources in the EAC Program 

than they would have in the traditional program. This is because local stakeholders are not as involved 

in the traditional method. However, these individuals consulted believed that the EAC benefits 

overshadowed the costs by: 

• Saving resources in the long run; 

• Developing control measures that accommodate economic growth; 

• Developing good will between stakeholders; 

• Providing local control over program activities; and, 

• Avoiding nonattainment status. 

75 
Several other individuals consulted found it difficult to determine the impact of the EAC on state and 

local resources. They were divided on whether the EAC approach saved money and resources over the 

traditional approach. A few individuals consulted found that the EAC Program did not save money or 

resources over the traditional approach. 

Environmental Aspects 

EAC Program Requirements versus Subpart 1 Requirements 

In comparing the differences between the EAC program and Subpart 1 area CAA requirements, the 

study did not arrive at a observation as to which approach would have produced the greater emission 

reductions and air quality improvement. As the qualitative information indicates, some requirements 

were more stringent for EAC Program areas and some more stringent for Subpart 1 areas. Relative to 

non-EAC Program areas, air quality in EAC areas in the East was not adversely affected by two factors: 

(1) the absence of some or all of the nonattainment area requirements that traditional nonattainment 

areas face or (2) by the fact that most of the areas experienced population and VMT growth during 

EAC Program implementation. Relative to non-EAC Program areas, these two factors also did not 

adversely affect the ability of EAC areas in the East to attain the NAAQS by December 2007 (or earlier 

for many EAC areas). However, it remains to be seen what will happen to ozone air quality levels in 

these areas as they grow in the next five to 10 years. Ozone air quality in many of the areas will 

continue to be influenced by, among other things, state and National programs to reduce NOx and 

VOCs. Moreover, EAC Program areas were required to demonstrate maintenance of the standard for 

five years (to 2012), although almost all the states in the Southeast (EPA Region 4) with EAC Program 

areas submitted maintenance plans for 10 years. These plans are in place to address emissions growth 

to ensure attainment of the ozone standard. 

With respect to the relative burden of the CAA requirements, the individuals consulted clearly viewed 

not having to implement the Nonattainment NSR and Conformity Programs as a burden reduction. 

However, several state and local agencies consulted felt that reducing EAC Program’s reporting 

requirements could have eased the resource burden of the EAC Program further. Other individuals 

consulted felt the benefits of the EAC Program outweighed the burden. 

Conformity Program 

The study lacked sufficient information on which to base a Conformity Program-specific observation as 

to the emissions and/or air quality impacts of not requiring the Conformity Program in EAC areas. 

Such an analysis was beyond the scope of this study. The study did find information that the 

Conformity Program applied in about one-half of the 14 EAC nonattainment-deferred areas for at least 

one criteria pollutant other than the 8-hour ozone standard. Six of the 14 nonattainment-deferred EAC 

Program areas were subject to the CAA Conformity Program requirement during the EAC Program 

(from June 14 2004 to April 15, 2008) for pollutants other than the 8-hour ozone NAAQS: the 1-hour 

ozone NAAQS, the PM10 NAAQS, the PM2.5 NAAQS and the carbon monoxide NAAQS. 

76 
TABLE OF APPENDICIES 

Appendix A: List of State and Local Agencies Consulted 3 

Table A-1: State Agencies Consulted 3 

Table A-2: Local Government Agencies Consulted 5 

Appendix B: Tables 6 

Table B-1: Year-to-Year Changes in 8-hour Ozone Design Values (ppm) from 

2001-2003 to 2004-2007 for 14 Nonattainment- Deferred Early Action 

Compact (EAC) Program Areas and Six Attainment EAC Program Areas, 

Not Controlling for Meteorology 6 

Table B-2: Year-to-Year Changes (and Percent Change) in 8-hour Air Quality Index 

Days from 2001 to 2007 for 14 Nonattainment-Deferred EAC Program 

Areas and 6 Attainment EAC Program Areas, Not Controlling for 

Meteorology (May to September Ozone Season) 7 

Table B-3: Changes in Seasonal Average 8-hour Daily Maximum Ozone

 Concentrations (ppm) from 2001-2003 to 2005-2007 for 14 

 Nonattainment-Deferred EAC Program Areas and 6 Attainment EAC

 Program Areas, Controlled and Uncontrolled for Meteorology 9 

Table B-4: Changes in Seasonal Average 8-hour Ozone Daily Maximum

 Concentrations (ppm) from 2001-2003 to 2005-2007 (Meteorologically­

 Controlled) for 14 Nonattainment-Deferred EAC Program Areas, 6 

 Attainment EAC Program Areas and 18 Non-EAC Program Areas 11 

Table B-5: Control Measure Emission Reductions for Berkeley and Jefferson 

 Counties, West Virginia 13 

Table B-6: Control Measure Emission Reductions for Chattanooga, 

 Tennessee-Georgia 14 

Table B-7: Control Measure Emission Reductions for Columbia, South Carolina

 (Central Midlands Area) 15 

Table B-8: Control Measure Emission Reductions for Denver-Boulder­

 Greeley-Fort Collins-Loveland, Colorado 17 

Table B-9: Control Measure Emission Reductions for Fayetteville, North Carolina

 (Cumberland County) 18 

Table B-10: Control Measure Emission Reductions for Frederick County, Virginia 19 

Table B-11: Control Measure Emission Reductions for Greensboro-Winston 

 Salem-High Point, North Carolina (Triad Area) 20 

Table B-12: Control Measure Emission Reductions for Greenville-Spartanburg­

 Anderson, South Carolina (Appalachian Area) 22 

Table B-13: Control Measure Emission Reductions for Hickory-Morganton-Lenoir, 

 North Carolina (Unifour Area) 24 

Table B-14: Control Measure Emission Reductions for Johnson City-Kingsport­

 Bristol, Tennessee 25 

Table B-15: Control Measure Emission Reductions for Nashville, Tennessee 26 

Table B-16: Control Measure Emission Reductions for Roanoke, Virginia 27 

Table B-17: Control Measure Emission Reductions for San Antonio, Texas 29 

Table B-18: Control Measure Emission Reductions for Washington County,

 Maryland (Hagerstown) 30 

Table B-19: Control Measure Emission Reductions for Austin, Texas 31 
________________________________________________________________________________ 

____ 

Table B-20: Control Measure Emission Reductions for Berkeley-Charleston­

 Dorchester, South Carolina 34 

Table B-21: Control Measure Emission Reductions for Mountain Area of Western 

 North Carolina (Asheville) 36 

Table B-22: Control Measure Emission Reductions for Oklahoma City, Oklahoma 37 

Table B-23: Control Measure Emission Reductions for Lower Savannah-Augusta, 

 South Carolina-Georgia 38 

Table B-24: Control Measure Emission Reductions for Tulsa, Oklahoma 40 

Table B-25: Control Measure Emission Reductions for South Carolina (Statewide) 41 

Table B-26: Comparison of EAC NOx and VOC Emissions Reductions to the 2002 

 Emissions for the 20 EAC Program Areas, Emissions for the States in 

 Which They Are Located, and the NOx SIP Call Emission Reductions

 in Those States 42 

Table B-27: Population Change from 2002 to 2006 in 14 Nonattainment-Deferred EAC 

Program Areas 44 

Table B-28: Population Change from 2002 to 2006 in 6 Attainment EAC

 Program Areas 47 

Table B-29: Vehicle Miles Traveled (VMT) Change from 2002 to 2006 In 14 

 Nonattainment-Deferred EAC Program Areas 49 

Table B-30: VMT Change From 2002 to 2006 in 6 Attainment EAC Program Areas 52 

Table B-31: EPA Resources for Traditional Approach versus EAC Program 54 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour

 Ozone Areas Compared to a Summary of Requirements for Clean 

 Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone

 Nonattainment Areas 60 

Appendix C: Approach for Calculating National (Federal) Measure Emission

 Reductions 69 

Appendix D: Brief Profile of the 14 Nonattainment-Deferred Areas and Six 

 Attainment EAC Program Areas Included in this Study 75 

Appendix E: Summary of Discussions with State and Local Agencies 79 

2 
____________________________________________________________________________________ 

APPENDICES 

Appendix A: List of State and Local Agencies Consulted 

Table A-1: State Agencies Consulted 

State Contact 

Colorado • Mike Silverstein, Colorado Department of Public Health and Environment 

Georgia • Jimmy Johnston, Program Manager, Air Quality, Georgia Department of Natural Resourc

• Elizabeth Muncey, Environmental Engineer, Georgia DNR 

Louisiana • Jim Orgeron, Acting Program Manager, SIP Group, Louisiana Department of EnvironmenMaryland • Brian Hug, Deputy Manager, Air Quality Program Planning, Maryland Department of Nat

(MDDNR) 

• Randy Mosier, MDDNR 

North Carolina 

• Laura Boothe, Attainment Planning Branch Supervisor, North Carolina Department of En

Natural Resources (NCDENR) Division of Air Quality (DAQ) 

• Sheila Holman, NCDENR DAQ 

New Mexico 

• Andy Berger, Control Strategies Section Chief, New Mexico Environment Department (N• Mark Jones, Environmental Analyst, Farmington Field Office, NMED 

Oklahoma • Leon Ashford, Environmental Programs Specialist, Oklahoma Department of Environmen

South Carolina 

• Renee Shealy, South Carolina Department of Health and Environmental Control (South C

• Melinda Mathias, South Carolina DHEC • Robbie Brown, South Carolina DHEC • Michael Monroe, South Carolina DHEC • Adam Page, South Carolina DHEC • Nelson Roberts, South Carolina DHEC 

Tennessee • Barry Stephens, Director, Air Pollution Control Division (APCD), Tennessee Department 

and Conservation (TDEC) 

• Quincy Styke, Deputy Director, APCD, TDEC 

Texas • Kelly Keel, Team Leader, Texas Commission on Environmental Quality (TCEQ) 

• Theresa Pella, SIP Section Manager, TCEQ • Kim Herndon, TCEQ 
____________________________________________________________________________________ 

Table A-1: State Agencies Consulted
 

State Contact 

Virginia • Tom Ballou, Director, Air Data Analysis and Planning Division, Virginia Department of E

Quality 

West Virginia 

• Fred Durham, Deputy Director, Division of Air Quality, West Virginia Department of Env

Protection and Assistant Director for Planning, West Virginia Department of Environmen
____________________________________________________________________________________ 

Table A-2: Local Government Agencies Consulted
 

Area Contact 

Nonattainment Deferred EAC Program Areas 

Chattanooga, Tennessee/Georgia • Bob Colby, Director, Chattanooga-Hamilton County A

Tennessee 

Denver-Boulder-Greeley-Fort. CollinsLoveland, Colorado 

• Ken Lloyd, Denver Regional Air Quality Council 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 

• Sandra Yundice, Assistant County Administrator, Gree• Kevin Robinson, Associate Planner, Planning Departm• John Owings, Manager of Air Planning, Greenville Co• Dan Powell, Planning Department, Greenville County 

Northern Shenandoah Valley, Virginia • Patrick Barker, Executive Director, Winchester-Freder

Development Commission 

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 

• Virginia G. Booker, Assistant Director, Piedmont Tria

Washington County, Maryland • Jill Baker, Senior Planner, Washington County Depart

Attainment EAC Program Areas 

Austin, Texas • Cathy Stephens, Capital Area Metropolitan Planning OOklahoma City, Oklahoma • Darla Hugaboom, Associate Planner, Transportation D

Central Oklahoma Governments 

Lower Savannah-Augusta, South Carolina-Georgia 

• Stephen Strohminger, Development Official, Aiken Co

Other Ozone Nonattainment Areas (Control Cases) 

Knoxville, Tennessee • Lynne A. Liddington, Director, Knox County, Air Qua

Department of Public Health 

Rocky Mount, North Carolina • Bob League, Transportation Planner, Rocky Mount Ur

Planning Organization 

• John Gessaman, President and Chief Executive Office

Partnership 
____________________________________________________________________________________ 

Appendix B: Tables 

Table B-1: Year-to-Year Changes in 8-hour Ozone Design Values (ppm) from 2001-2003 to 2004-20

Deferred Early Action Compact (EAC) Program Areas and Six Attainment EAC Prog

Not Controlling for Meteorology 


EAC Program Areas 2001­

2003 

Design 

Value 

2002­

2004 

Design 

Value 

2003­

2005 

Design 

Value 

2004­

2006 

Design 

Value 

2005­

2007 

Design 

Value 

Nonattainment-Deferred EAC Program Areas Berkeley and Jefferson Counties, West Virginia 0.086 0.08 0.076 0.074 0.075 

Chattanooga, Tennessee-Georgia 0.088 0.086 0.08 0.08 0.084 

Columbia, South Carolina (Central Midlands Area) 0.089 0.086 0.083 0.082 0.082 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 0.087 0.084 0.084 0.081 0.085 

Fayetteville, North Carolina (Cumberland County) 0.087 0.084 0.083 0.08 0.082 

Frederick Co, Virginia 0.085 0.078 0.073 0.071 0.073 

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 0.093 0.087 0.082 0.08 0.083 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 0.087 0.084 0.081 0.083 0.083 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 0.088 0.082 0.077 0.075 0.078 

Johnson City-Kingsport-Bristol, Tennessee 0.086 0.084 0.079 0.079 0.083 

Nashville, Tennessee 0.086 0.083 0.082 0.083 0.084 

Roanoke, Virginia 0.085 0.079 0.074 0.074 0.076 

San Antonio, Texas 0.089 0.091 0.086 0.087 0.082 

Washington Co (Hagerstown), Maryland 0.086 0.083 0.078 0.078 0.079 

Attainment EAC Program Areas Austin, Texas 0.084 0.085 0.082 0.082 0.08 

Berkeley-Charleston-Dorchester, South Carolina 0.072 0.072 0.073 0.075 0.074 

Mountain Area of Western North Carolina (Asheville) 0.083 0.081 0.078 0.078 0.079 

Oklahoma City, Oklahoma 0.080 0.079 0.079 0.081 0.080 

Lower Savannah-Augusta, South Carolina-Georgia 0.067 0.068 0.069 0.069 0.067 

Tulsa, Oklahoma 0.083 0.079 0.079 0.079 0.080 

Source: Air Quality System, U.S. Environmental Protection Agency (EPA). 
____________________________________________________________________________________ 

Table B-2: Year-to-Year Changes (and Percent Change) in 8-hour Air Quality Index Days from 

Nonattainment-Deferred EAC Program Areas and 6 Attainment EAC Program Areas, Not Contro

 (May to September Ozone Season)
 

EAC Program Area 2001 2002 2003 2001-2003 

Average 

2004 2005 2006 2007 2005-2007 

Average 

C

2

Nonattainment-Deferred EAC Program Areas Berkeley and Jefferson Counties, West Virginia 5.0 6.0 2.0 4.3 1.0 1.0 1.0 1.0 1.0 

Chattanooga, Tennessee-Georgia 5.0 31.0 3.0 13.0 1.0 1.0 6.0 4.0 3.7 

Columbia, South Carolina (Central Midlands Area) 3.0 18.0 2.0 7.7 3.0 7.0 2.0 3.0 4.0 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 2.0 9.0 21.0 10.7 0.0 2.0 7.0 8.0 5.7 

Fayetteville, North Carolina (Cumberland County) 4.0 18.0 4.0 8.7 0.0 8.0 0.0 2.0 3.3 

Frederick Co, Virginia 5.0 9.0 1.0 5.0 1.0 0.0 1.0 0.0 0.3 

Greensboro-Winston-SalemHigh Point, North Carolina (Triad Area) 20.0 31.0 7.0 19.3 0.0 3.0 5.0 6.0 4.7 

Greenville-SpartanburgAnderson, South Carolina (Appalachian Area) 12.0 27.0 4.0 14.3 2.0 3.0 4.0 3.0 3.3 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 2.0 10.0 3.0 5.0 0.0 0.0 0.0 0.0 0.0 Johnson City-Kingsport-Bristol, Tennessee 6.0 13.0 3.0 7.3 0.0 3.0 4.0 5.0 4.0 

Nashville, Tennessee 7.0 21.0 6.0 11.3 1.0 4.0 7.0 15.0 8.7 

Roanoke, Virginia 5.0 5.0 1.0 3.7 0.0 0.0 0.0 1.0 0.3 

San Antonio, Texas 1.0 17.0 7.0 8.3 7.0 4.0 4.0 1.0 3.0 

Washington Co (Hagerstown), Maryland 5.0 17.0 3.0 8.3 1.0 2.0 1.0 1.0 1.3 

Attainment EAC Program Areas Austin, Texas 1.0 5.0 3.0 3.0 2.0 3.0 4.0 1.0 2.7 

Berkeley-Charleston-Dorchester, South Carolina 0.0 1.0 0.0 0.3 1.0 0.0 1.0 0.0 0.3 
____________________________________________________________________________________ 

Table B-2: Year-to-Year Changes (and Percent Change) in 8-hour Air Quality Index Days from 

Nonattainment-Deferred EAC Program Areas and 6 Attainment EAC Program Areas, Not Contro

 (May to September Ozone Season)
 

EAC Program Area 2001 2002 2003 2001-2003 

Average 

2004 2005 2006 2007 2005-2007 

Average 

C

2

Mountain Area of Western North Carolina (Asheville) 2.0 14.0 0.0 5.3 0.0 1.0 1.0 1.0 1.0 

Oklahoma City, Oklahoma 2.0 3.0 2.0 2.3 0.0 4.0 11.0 2.0 5.7 

Lower Savannah-Augusta, South Carolina-Georgia 0.0 1.0 0.0 0.3 0.0 0.0 0.0 0.0 0.0 

Tulsa, Oklahoma 4.0 5.0 9.0 6.0 0.0 6.0 6.0 2.0 4.7 

Source: Air Quality System, EPA. 
____________________________________________________________________________________ 

Table B-3: Changes in Seasonal Average 8-hour Daily Maximum Ozone Concentrations (ppm) 

2007 for 14 Nonattainment-Deferred EAC Program Areas and 6 Attainment EAC Program 

Uncontrolled for Meteorology 


EAC Program Area Changes in Changes in Seasonal Average 8-hour Ozone Concentrations 

Uncontrolled for Meteorology Contro

2001-2003 Average 2005-2007 

Average 

Percent Change 

2001-2003 Avera

Nonattainment Deferred EAC Program Areas Berkeley and Jefferson Counties, West Virginia 0.052 0.051 -3% 0

Chattanooga, Tennessee-Georgia 0.061 0.059 -2% 0

Columbia, South Carolina (Central Midlands Area) 0.056 0.056 -1% 0

Denver-Boulder-Greeley-Fort CollinsLoveland, Colorado NA NA NA NA 

Fayetteville, North Carolina (Cumberland County) 0.059 0.055 -6% 0

Frederick Co, Virginia 0.053 0.050 -4% 0

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 0.063 0.061 -3% 0

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 0.058 0.058 0% 0Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 0.057 0.055 -4% 0

Johnson City-Kingsport-Bristol, Tennessee 0.058 0.059 1% 0Nashville, Tennessee 0.061 0.062 2% 0Roanoke, Virginia 0.054 0.053 -3% 0

San Antonio, Texas 0.053 0.048 -10% 0

Washington Co, Maryland (Hagerstown) 0.055 0.054 -3% 0

Attainment EAC Program Areas Austin, Texas 0.049 0.049 -1% 0

Berkeley-Charleston-Dorchester, South Carolina 0.045 0.047 3% 0Mountain Area of Western North Carolina (Asheville) 0.060 0.059 -2% 0

Oklahoma City, Oklahoma 0.059 0.057 -3% 0
____________________________________________________________________________________ 

Table B-3: Changes in Seasonal Average 8-hour Daily Maximum Ozone Concentrations (ppm) 

2007 for 14 Nonattainment-Deferred EAC Program Areas and 6 Attainment EAC Program 

Uncontrolled for Meteorology 


EAC Program Area Changes in Changes in Seasonal Average 8-hour Ozone Concentrations 

Uncontrolled for Meteorology Contro

2001-2003 Average 2005-2007 

Average 

Percent Change 

2001-2003 Avera

Lower Savannah-Augusta, South CarolinaGeorgia 0.037 0.042 12% 0Tulsa, Oklahoma 0.060 0.058 -3% 0

Source: Air Quality System. EPA and meteorological analysis by the Air Quality Assessment Group, Office of Air Quality Planusing the method described in Camalier, L., Cox, W., Dolwick, P., 2007. The effects of meteorology on ozone in urban areas and trends. Atmospheric Environment 41, 7127-7137. 
____________________________________________________________________________________ 

Table B-4: Changes in Seasonal Average 8-hour Ozone Daily Maximum Concentrations 

2005-2007 (Meteorologically-Controlled) for 14 Nonattainment-Deferred EAC 

6 Attainment EAC Program Areas and 18 Non-EAC Program Areas 

EAC Program Area 2001-2003 Average 2005-2007 Av

Nonattainment Deferred EAC Program Areas Berkeley and Jefferson Counties, West Virginia 0.055 

Chattanooga, Tennessee-Georgia 0.062 

Columbia, South Carolina (Central Midlands Area) 0.058 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado NA NA 

Fayetteville, North Carolina (Cumberland County) 0.059 

Frederick Co, Virginia 0.055 

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 0.064 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 0.061 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 0.059 

Johnson City-Kingsport-Bristol, Tennessee 0.059 

Nashville, Tennessee 0.065 

Roanoke, Virginia 0.055 

San Antonio, Texas 0.054 

Washington County , Maryland (Hagerstown) 0.057 

Attainment EAC Program Areas Austin, Texas 0.049 

Berkeley-Charleston-Dorchester, South Carolina 0.047 

Mountain Area of Western North Carolina (Asheville) 0.061 

Oklahoma City, Oklahoma 0.059 

Lower Savannah-Augusta, South Carolina-Georgia 0.040 

Tulsa, Oklahoma 0.060 

Non-EAC Program Areas in the EAC Region in the East Atlanta, Georgia 0.067 

Baltimore, Maryland 0.066 

Birmingham, Alabama 0.062 

Charlotte, North Carolina 0.064 

Charleston, West Virginia 0.055 

Cincinnati, Ohio 0.064 

Huntington, West Virginia 0.063 

Knoxville, Tennessee 0.068 

Lexington, Kentucky 0.055 
____________________________________________________________________________________ 

Table B-4: Changes in Seasonal Average 8-hour Ozone Daily Maximum Concentrations 

2005-2007 (Meteorologically-Controlled) for 14 Nonattainment-Deferred EAC 

6 Attainment EAC Program Areas and 18 Non-EAC Program Areas 

EAC Program Area 2001-2003 Average 2005-2007 Av

Louisville, Kentucky 0.063 

Memphis, Tennessee 0.064 

Montgomery, Alabama 0.052 

Philadelphia, Pennsylvania 0.064 

Pittsburgh, Pennsylvania 0.063 

Raleigh, North Carolina 0.062 

Richmond, Virginia 0.062 

Virginia Beach, Virginia 0.056 

Washington, District of Columbia 0.065 

Source: Air Quality System. EPA and meteorological analysis by the Air Quality Assessment Group, OAQPS, using the meCox, W., Dolwick, P., 2007. The effects of meteorology on ozone in urban areas and their use in assessing ozone trends. A7127-7137. 
____________________________________________________________________________________ 

Table B-5: Control Measure Emission Reductions for Berkeley and Jefferson Counties, W

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

362.9 kg/d 2.091% 1,723.7 kg/d 5.964% 35.13% 

Ozone action day program N Y July 1, 2004 907.2 kg/d 5.228% 81.6 kg/d 0.283% 16.65% 

Public awareness program N Y July 1, 2004 731.6 kg/d 4.216% 798.3 kg/d 2.762% 25.76% Bicycle/pedestrian measures N Y Sep. 1, 2005 203.2 kg/d 1.171% 108.9 kg/d 0.377% 5.25% 

Reduce engine idling N Y July 1, 2004 10.2 kg/d 0.059% 154.2 kg/d 0.534% 2.77% 

School bus engine retrofit N Y Jan. 1, 2005 1.0 kg/d 0.006% 18.1 kg/d 0.063% 0.32% 

Voluntary -ground freight industry N Y July 1, 2005 71.1 kg/d 0.410% 762.0 kg/d 2.637% 14.03% Open burning-increase compliance N Y July 1, 2004 5.5 kg/d 0.032% 0.5 kg/d 0.002% 0.10% 

TOTALS Y = 1 of 8 CM 

N = 7 of 8 CM 

Y = 8 of 8 CM 

N = 0 of 8 CM 

2,292.6 kg/d 

922.4 t/yr 

13.211% 3,647.3 kg/d 

1,467.5 t/yr 

12.621% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-6: Control Measure Emission Reductions for Chattanooga, Tennessee-Ge

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

14,455.1 kg/d 17.281% 21,386.0 kg/d 27.922% 72.72% 

Light Duty Motor Vehicle I & M Y Y April 2005 1,905.1 kg/d 2.278% 1,079.5 kg/d 1.409% 6.06% 

Anti Motor Vehicle Tampering Y Y Dec. 2004 NQ NQ 

Volatile Organic Compounds Reductions Y Y Dec. 2004 

Stage 1 Vapor Recovery (Tennessee) Y Y May 2005 2,731.5 kg/d 3.266% 5.54% 

Seasonal Open Burning Ban (Tennessee) N Y May 2005 1,458.8 kg/d 1.744% 526.2 kg/d 0.687% 4.03% Vehicle I & M plan Y Y April 2005 1,905.1 kg/d 2.278% 1,079.5 kg/d 1.409% 6.06% 

Ozone Action Days Program: Spare the Air (Tennessee) 

N Y May 2004 178.7 kg/d 0.214% 137.0 kg/d 0.179% 0.64% 

Ozone Action Days Program: Spare the Air (GA) N Y May 2004 47.2 kg/d 0.056% 36.3 kg/d 0.047% 0.17% 

Stage 1 Vapor Recovery (GA) Y Y 2005 293.0 kg/d 0.350% 0.59% 

Seasonal Open burning ban-ozone season (GA) N Y 2005 Ozone 

season 

1,415.2 kg/d 1.692% 429.1 kg/d 0.560% 3.74% 

Municipal Buses - Increased ridership (Tennessee) 

N Y On-going 3.6 kg/d 0.004% 2.7 kg/d 0.004% 0.01% 

Intelligent Transportation System: Smartway N Y Early 2005 NQ NQ 

HELP Trucks N Y June 2000 NQ NQ 

Diesel Retrofits (Tennessee) N Y May 2004 8.2 kg/d 0.010% 56.2 kg/d 0.073% 0.13% 

Diesel Retrofits (GA) N Y May 2004 1.8 kg/d 0.002% 16.3 kg/d 0.021% 0.04% 

Bike Trails and Bike Racks at Work Sites N Y Implemented NQ NQ Pedestrian Greenways N Y April 2004, March 

2009 

NQ NQ 

Accelerated Replacement of On-Road Vehicles N N 2006 NQ NQ 

Bio-diesel and Alternative Fuel Vehicles (Tennessee) 

N Y Dec. 2004 135.2 kg/d 0.176% 0.27% 

Replacement of on- and off-road diesel vehicles N Y 2005 NQ NQ 

TOTALS Y = 7 of 21 CM 

N = 14 of 21 

CM 

Y = 20 of 21 

CM 

N = 1 of 21 CM 

24,403.3 kg/d 

9,818.5 t/yr 

29.175% 24,884.1 kg/d 

10,012.0 t/yr 

32.489% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-7: Control Measure Emission Reductions for Columbia, South Carolina (Central M

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Federal control measures Y Y Before Dec 31, 

2005 

22,316.7 kg/d 17.526% 65,317.3 kg/d 57.270% 86.72% 

Air Quality Contact N Y March 2003 Gas can exchange plan N Y June 2004 Promote land-use planning to promote air quality 

N Y Jan. 2003 

Participate in Clean Cities N Y July 2003 Industry Advisory Panel N Y Summer 2004 Purchase electric instead of golf carts N Y On-going Purchase 15 CNG vehicles N Y Late 2004 Educate public; increase media alerts N Y June 2003 Speak to municipalities in County N Y Spring 2003 Flex/compress schedule- County employees N Y On-going Encourage carpooling N Y On-going Develop city and county energy plan N Y On-going Encourage mass transit N Y On-going Assign staff - air quality expert N Y On-going Encourage not overfilling fuel tank N Y June 2003 County employees-restrict mowing during ozone action days 

N Y On-going 

Land Development Code/Tree ordinances N Y Jan. 2005 / TBD Reduce NOx, VOC emissions at International Paper 

N Y On-going 2,485.4 kg/d 2.179% 2.46% 

Reduce NOx emissions from SCE&G - 2 coal fired boilers 

N Y On-going 10,928.6 kg/d 9.582% 10.81% 

School Bus Retrofits N Y Dec. 2005 1.0 kg/d 0.001% 0.00% Gas Can Exchange Events - 250 cans were distributed 

N Y June 2004 & Oct. 

2004 

1.0 kg/d 0.001% 0.00% 

Improvements to Park and Ride lot at Highway 378 and I-20 

N Y 2003 - ongoing 1.1 kg/d 0.001% 0.6 kg/d 0.001% 0.00% 

Conversion of Commercial Vehicle Fleet to Propane 

N Y 2005 1.6 kg/d 0.001% 2.0 kg/d 0.002% 0.00% 

Biodiesel Buses, University of South Carolina. N Y 2002 0.0 kg/d 0.000% 0.0 kg/d 0.000% 0.00% University of South Carolina Ethanol Project N Y On-going 0.0 kg/d 0.000% 0.0 kg/d 0.000% 0.00% 
____________________________________________________________________________________ 

Table B-7: Control Measure Emission Reductions for Columbia, South Carolina (Central M

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Take a Break from the Exhaust program Y Y On-going 0.7 kg/d 0.001% 0.5 kg/d 0.000% 0.00% 

SC DHEC has a number of flex fuel vehicles that run almost exclusively on E85. 

N Y FY 2005 / FY 2006 0.1 kg/d 0.000% 0.1 kg/d 0.000% 0.00% 

Smart Ride – Mass Transit Program Y Y On-going 0.2 kg/d 0.000% 0.3 kg/d 0.000% 0.00% 

Ethanol (E85) refueling station for public N Y Oct. 2004 0.2 kg/d 0.000% 0.8 kg/d 0.001% 0.00% 

TOTALS Y = 3 of 30 CM 

N = 27 of 30 

CM 

Y = 30 of 30 

CM 

N = 0 of 30 CM 

22,322.8 kg/d 

8,981.5 t/yr 

17.531% 78,735.7 kg/d 

31,678.8 t/yr 

69.035% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-8: Control Measure Emission Reductions for Denver-Boulder-Greeley-Fort Collins-Lo

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

32,023.6 kg/d 6.730% 36,287.4 9.894% 45.55% 

Lower Reid vapor pressure Y Y Mar. 25, 2004 9,071.8 kg/d 1.907% 6.05% 

Reduce flash VOC emissions from condensate collection at various natural gas facilities 

Y N by Dec. 31, 2007 49,895.2 kg/d 10.486% 0.0 kg/d 0.000% 33.27% 

Control IC engines>500 HP Y Y Dec. 31, 2005 4,989.5 kg/d 1.049% 17,236.5 kg/d 4.700% 14.82% 

Control dehydration units Y Y Dec. 31, 2005 453.6 kg/d 0.095% 0.0 kg/d 0.000% 0.30% 

TOTALS Y = 5 of 5 CM 

N = 0 of 5 CM 

Y = 4 of 5 CM 

N = 1 of 5 CM 

96,433.7 kg/d 

38,799.5 t/yr 

20.266% 53,523.9 kg/d 

21,535.0 t/yr 

14.594% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-9: Control Measure Emission Reductions for Fayetteville, North Carolina (Cumbe

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Federal control measures Y Y Before Dec 31, 2005 6,350.3 kg/d 18.006% 8,527.5 kg/d 30.543% 87.70% Landscape ordinance - nonresidential N Y Dec. 2005 Smart growth audit N Y Dec. 2005 Pedestrian trails N Y Dec. 2005 Brownfield development N Y On-going Shared parking facilities N Y Dec. 2005 Green space inventory N Y March 2004 185 vehicles converted to biodiesel N Y Dec. 2005 4.5 kg/d 0.013% 2.7 kg/d 0.010% 0.04% Electrical outlets- reduce truck idling N Y Oct. 2005 Retrofit school buses N Y by Summer 2005 381.0 kg/d 1.080% 2.25% Using ITS and dynamic message N Y Dec. 2005 Enhance mass transit N Y Dec. 2005 226.8 kg/d 0.643% 7.3 kg/d 0.026% 1.38% Develop database-carpool N Y June 2004 Increase rural paratransit N Y Dec. 2005 Encourage Park and Ride for events N Y On-going Use landfill gas; support NC Green Power N Y On-going; Spring 

2004 

12.7 kg/d 0.045% 0.07% 

Energy efficient buildings N Y On-going Energy reduction - LNB; water based paints N Y On-going Air Quality Coordinator N Y May 2003 Student outreach N Y On-going Public education outreach N Y On-going Speakers bureau N Y On-going Air quality web page N Y On-going Promote bus youth riders N Y On-going Education – libraries N Y On-going Open burning ban -ozone action days Y Y June 2004 181.4 kg/d 0.514% 90.7 kg/d 0.325% 1.60% Expand vehicle I & M Y Y July 2003 544.3 kg/d 1.543% 635.0 kg/d 2.274% 6.95% 

Y = 3 of 27 CM 

Y = 27 of 27 

CM 7,688.4 kg/d 9,276.0 kg/d 

TOTALS 

N = 24 of 27 

CM 

N = 0 of 27 CM 3,093.4 t/yr 

21.800% 

3,732.1 t/yr 

33.224% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-10: Control Measure Emission Reductions for Frederick County, Virgi

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Architectural and Industrial Paints Y Y Implemented 121.6 kg/d 0.468% 1.11% Consumer Products Y Y Implemented 50.8 kg/d 0.196% 0.46% Metal Cleaning Y Y Implemented 50.8 kg/d 0.196% 0.46% Motor Vehicle Refinishing Paint Y Y Implemented 2.7 kg/d 0.010% 0.02% Small Gasoline Engine Standards Y Y Implemented 736.6 kg/d 2.838% 24.5 kg/d 0.127% 6.95% Non-road Diesel Engine Standards Y Y Implemented 42.6 kg/d 0.164% 250.4 kg/d 1.296% 2.68% Locomotive Engine Standards Y Y Implemented 18.1 kg/d 0.094% 0.17% Large Gasoline Engine Standards Y Y Implemented 61.7 kg/d 0.238% 225.0 kg/d 1.165% 2.62% Spark Ignition Marine Engine Standards Y Y Implemented 3.6 kg/d 0.014% 0.03% On-road Motor Vehicle Standards Y Y Implemented 2,821.3 kg/d 10.871% 4,662.9 kg/d 24.136% 68.37% Ozone action days/public awareness -multiple activities 

N Y Spring 2005 272.2 kg/d 1.049% 18.1 kg/d 0.094% 2.65% 

VMT Reduction programs - multiple activities N Y Spring 2005 136.1 kg/d 0.524% 272.2 kg/d 1.409% 3.73% Open burning restrictions N Y Spring 2005 254.0 kg/d 0.979% 108.9 kg/d 0.563% 3.31% Engine idling restrictions - trucks and school buses 

N Y Spring 2005 90.7 kg/d 0.470% 0.83% 

School bus/heavy duty diesel retrofit N Y Spring 2005 1.8 kg/d 0.007% 0.9 kg/d 0.005% 0.02% Voluntary industrial reductions N Y Spring 2005 Regional Reduction of NOx Emissions Y Y May 31, 2004 RACT Controls -- VOC only, no NOx reductions Y Y Nov. 15, 2005 718.5 kg/d 2.769% 0.0 kg/d 0.000% 6.56% Enhanced Ozone Forecasting tool N Y 2005 State Cutback Asphalt Regulation Y Y Nov. 2005 0.9 kg/d 0.003% 0.0 kg/d 0.000% 0.01% 

Y = 13 of 20 

CM 

Y = 20 of 20 

CM 5,275.3 kg/d 5,671.7 kg/d 

TOTALS 

N = 7 of 20 CM N = 0 of 20 CM 2,122.5 t/yr 

20.327% 

2,282.0 t/yr 

29.358% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-11: Control Measure Emission Reductions for Greensboro-Winston Salem-High Point, Nort

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implement 

ed by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Federal control measures Y Y Before Dec 31, 2005 36,287.4 kg/d 14.012% 362,951.2 kg/d 118.488% 97.34% Open burning ban -ozone action days Y Y June 2004 1,905.1 kg/d 0.736% 1,360.8 kg/d 0.444% 0.80% Expand vehicle I & M Y Y July 2002; July 2004 1,542.2 kg/d 0.596% 3,628.7 kg/d 1.185% 1.26% Purchase newer, less polluting vehicles N Y Jan. 2004 2.7 kg/d 0.001% 2.2 kg/d 0.001% 0.00% Convert to biodiesel for all vehicles N Y Spring 2003 Contract incentives for low emission vehicles N Y Possible Tax to support PART regional work program N Y 2003 Add 20 Park and Ride lots N Y 2004-2007 4.5 kg/d 0.002% 8.0 kg/d 0.003% 0.00% Add 5 vans/yr to ridesharing N Y Jan. 2004 1.7 kg/d 0.001% 1.7 kg/d 0.001% 0.00% Increase ridership on regional bus service N Y On-going 22.1 kg/d 0.009% 18.1 kg/d 0.006% 0.01% Expand carpooling - PART N Y Jan. 2004 57.7 kg/d 0.022% 47.2 kg/d 0.015% 0.03% RJ Reynolds-Monaco-Ville - eliminate use of coal fired boilers during ozone season 

N Y 2004 13.4 kg/d 0.004% 0.00% 

Energizer-reduce vehicle fleet; 90% of forkliftsbattery N Y June 2004 Duke-reduce mobile reading-56 trucks N Y 2003 2.8 kg/d* 0.001% 0.00% Duke-idling reduction guidelines N Y Summer 2004 Diesel retrofits-50-100school buses N Y 2004 42.3 kg/d 0.016% 57.2 kg/d 0.019% 0.02% No idling-all school buses N Y 2003 Energy efficient public buildings N Y 2003 & ongoing Flex, compress work schedule; telecommuting N Y On-going 469.7 kg/d 0.181% 385.2 kg/d 0.126% 0.21% ITS N Y On-going Encourage non-motorized transportation N Y On-going 693.4 kg/d 0.268% 569.2 kg/d 0.186% 0.31% Smart growth policies N Y On-going Truck stop electrification N Y July 2004; July 2005 4.5 kg/d 0.002% 87.0 kg/d 0.028% 0.02% Reduce fleet emissions N Y Oct. 2004 Emission reduction clearinghouse N Y April 2005 Hospital transportation shuttle N Y April 2004 Enhance mass transit facilities N Y 2004 & ongoing 
____________________________________________________________________________________ 

Table B-11: Control Measure Emission Reductions for Greensboro-Winston Salem-High Point, Nort

Control Measure Implementation Emission Reductions 

State or 

National 

Implement 

ed by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Mass transit incentives N Y Dec. 2005 Commuter/intercity rail N Y Fall 2004 Feasibility of HOV/HOT lanes - I-40 N Y Summer 2005 

TOTALS 

Y = 3 of 30 

CM 

N = 27 of 

30 CM 

Y = 30 of 30 

CM 

N = 0 of 30 

CM 

41,033.3 kg/d 16,509.5 t/yr 

15.845% 369,132.7 kg/d 

148,518.2 t/yr 

120.506% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-12: Control Measure Emission Reductions for Greenville-Spartanburg-Anderson, South Caro

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Federal control measures Y Y Before Dec 31, 

2005 37,920.3 kg/d 16.998% 60,962.8 kg/d 45.767% 76.509% 

Develop stakeholder group-regulatory development N Y On-going 17,895.2 kg/d 13.434% 13.846% Ozone Action coordinator N Y March 2003 Low S fuels – ASAP N Y On-going ITS-design and implement N Y 2003 / On-going Encourage use of hybrid vehicles N Y 2004-2005 School buses-higher efficiency engines N Y ASAP Promote bike paths N Y 2004 Park & Ride to plants N Y 2004 Downtown shuttles; rapid transit bus N Y 2004 Free or reduced public transportation faresozone action days N Y 2004 Integrate transportation planning with land use planning N Y 2004 Review & update air emission inventory N Y Fall 2003 Seek reductions from major sources N Y 2005 1,242.7 kg/d 0.933% 0.962% Develop program to purchase or repair smoking vehicles N Y 2005 Ban open burning of on-site commercial N Y 2004 Incentives for purchasing high efficiency, low emissions vehicles 

N Y 2005 

Land use/transportation planning N Y 2004 Encourage use of green power; capture landfill emissions 

N Y 2004 

Promote route efficiency for delivery vehicles and garbage trucks N Y 2004 Encourage alternate work schedules N Y 2004 Establish Park and Ride lots N Y 2004 Encourage carpooling; telecommuting N Y 2004 Establish active public awareness N Y 2004 Promote research in energy efficiency - local universities 

N Y 2005 

Encourage use of alternate fuels N Y On-going Evaluate use of HOV on 3 interstates N Y 2005 Modify speed limits for optimum fuel efficiency N Y 2005 or 2006 
____________________________________________________________________________________ 

Table B-12: Control Measure Emission Reductions for Greenville-Spartanburg-Anderson, South Caro

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Develop process for minimizing impact of major building projects 

N Y 2004 

Encourage community schools N N 

Improve landscape at county facilities N N 

Transco-early implementation of Phase 2 N Y Dec. 2005 6,365.2 kg/d 4.779% 4.925% 

Duke Power- install advanced low NOx burners N Y Oct. 2005 4,761.1 kg/d 3.574% 3.684% 

School Bus Retrofits N N 2006 1.9 kg/d 0.001% 0.001% 

Gas Can Exchange Event - 115 cans were distributed N Y June 2003 0.9 kg/d 0.000% 0.001% 

Truck Stop Electrification Project N Y 2004 4.6 kg/d 0.002% 90.0 kg/d 0.068% 0.073% 

TOTALS Y = 1 of 36 CM 

N = 35 of 36 

CM 

Y = 33 of 36 

CM 

N = 3 of 36 CM 

37,927.7 kg/d 15,260.0 t/yr 

17.001% 91,317.0 kg/d 

36,740.8 t/yr 

68.554% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-13: Control Measure Emission Reductions for Hickory-Morganton-Lenoir, North Caro

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Federal control measures Y Y Before Dec 31, 

2005 

11,430.5 kg/d 18.424% 120,791.6 kg/d 147.007% 94.94% 

Open burning ban-ozone action days Y Y June 2004 635.0 kg/d 1.024% 453.6 kg/d 0.552% 0.78% Local governments join NC Air Awareness Program 

N Y 2004 

Enhanced awareness; outreach; educate N Y 2003 / On-going Energy conservation plan N Y 2005 1.2 kg/d 0.002% 1.0 kg/d 0.001% 0.00% Staff person-air quality contact N Y 2004 Adopt local clean air policy N Y 2005 Landscape/tree ordinances N Y 2003 / 2005 Implement Smart Growth N Y 2003 / 2005 Encourage bicycle and pedestrian usage N Y 2003 / 2005 5.0 kg/d 0.008% 4.0 kg/d 0.005% 0.01% Support coordination of planning organizations N Y 2003 Encourage compressed/flexible work N Y 2004 3.7 kg/d 0.006% 3.2 kg/d 0.004% 0.00% Expand transit and ridesharing N Y 2004 1.2 kg/d 0.002% 1.0 kg/d 0.001% 0.00% More efficient trafficking systems N Y 2005 Expand vehicle I& M Y Y July 2003 - July 

2005 

725.7 kg/d 1.170% 725.7 kg/d 0.883% 1.04% 

Clean Smokestacks Act Y Y June 2005 4,490.6 kg/d 5.465% 3.22% 

Y = 4 of 16 CM 

Y = 16 of 16 

CM 12,802.5 kg/d 126,470.7 kg/d 

TOTALS 

N = 12 of 16 

CM 

N = 0 of 16 CM 5,151.0 t/yr 

20.636% 

50,884.7 t/yr 

153.919% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-14: Control Measure Emission Reductions for Johnson City-Kingsport-Bristol, 

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

16,604.2 kg/d 15.049% 10,462.6 kg/d 8.051% 89.41% 

Light Duty Motor Vehicle I & M Y Y April 2005 

Anti Motor Vehicle Tampering Y Y Dec. 2004 NQ NQ 

Volatile Organic Compounds Reductions Y Y Dec. 2004 Ozone Action Day Program N Y 2001 73.5 kg/d 0.067% 233.1 kg/d 0.179% 1.01% 

Open burning ban during Ozone Action Days Y Y Implemented 2,137.3 kg/d 1.937% 762.0 kg/d 0.586% 9.58% 

Transportation Emission Reduction Control Measures 

N Y 2005-2007 NQ NQ 

Stage I Vapor Recovery Y Y Dec. 2004 NQ NQ 

TOTALS Y = 6 of 8 CM 

N = 2 of 8 CM 

Y = 8 of 8 CM 

N = 0 of 8 CM 

18,815.0 kg/d 

7,570.1 t/yr 

17.053% 11,457.7 kg/d 

4,610.0 t/yr 

8.816% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-15: Control Measure Emission Reductions for Nashville, Tennessee
 

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Federal control measures Y Y Before Dec 31, 

2005 

37,227.2 kg/d 21.738% 46,357.1 kg/d 21.074% 93.19% 

Light Duty Motor Vehicle I & M Y Y April 2005 2,330.6 kg/d 1.361% 67.1 kg/d 0.031% 2.67% Anti Motor Vehicle Tampering Y Y Dec. 2004 NQ NQ Volatile Organic Compounds Reductions Y Y Dec. 2004 Traffic signal synchronization N Y 2004-2006 235.9 kg/d 0.138% 190.5 kg/d 0.087% 0.48% New infrastructure-rideshare program N Y 2004-2006 9.1 kg/d 0.005% 7.3 kg/d 0.003% 0.02% Trip reduction N Y 2004-2006 61.7 kg/d 0.036% 48.1 kg/d 0.022% 0.12% Roadside assistance program N Y Implemented 28.1 kg/d 0.016% 28.1 kg/d 0.013% 0.06% Addition of HDGV2B Weigh Class Vehicles to existing IM program 

N Y April 2005 40.8 kg/d 0.024% 20.9 kg/d 0.009% 0.07% 

New pedestrian facilities; bikeways N Y 2004-2006 72.6 kg/d 0.042% 55.3 kg/d 0.025% 0.14% HOV lanes - I-24,40 N Y 2004-2007 19.1 kg/d 0.011% 15.4 kg/d 0.007% 0.04% Ban open burning-ozone action days Y Y March 2004 99.8 kg/d 0.058% 383.7 kg/d 0.174% 0.54% Improve bus ridership N Y 2004-2006 9.1 kg/d 0.005% 9.1 kg/d 0.004% 0.02% New Rail Service (Nashville-Lebanon corridor) N Y 2005-2006 54.4 kg/d 0.032% 27.2 kg/d 0.012% 0.09% Land use controls-reduce VMT N Y 2004 and Beyond 226.8 kg/d 0.132% 553.4 kg/d 0.252% 0.87% Air Quality Action Days N Y Implemented 426.4 kg/d 0.249% 1,088.6 kg/d 0.495% 1.69% 

Y = 5 of 16 CM 

Y = 16 of 16 

CM 40,841.5 kg/d 48,851.9 kg/d 

TOTALS 

N = 11 of 16 

CM 

N = 0 of 16 CM 16,432.3 t/yr 

23.848% 

19,655.3 t/yr 

22.209% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-16: Control Measure Emission Reductions for Roanoke, Virginia 


Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Architectural and Industrial Paints Y Y Implemented 337.5 kg/d 0.799% 1.24% Consumer Products Y Y Implemented 161.5 kg/d 0.383% 0.59% Metal Cleaning Y Y Implemented 147.9 kg/d 0.350% 0.54% Motor Vehicle Refinishing Paint Y Y Implemented 143.3 kg/d 0.340% 0.53% Small Gasoline Engine Standards Y Y Implemented 1,525.0 kg/d 3.612% 53.5 kg/d 0.128% 5.79% Non-road Diesel Engine Standards Y Y Implemented 143.3 kg/d 0.340% 879.1 kg/d 2.094% 3.75% Locomotive Engine Standards Y Y Implemented 1,008.8 kg/d 2.403% 3.70% Large Gasoline Engine Standards Y Y Implemented 132.4 kg/d 0.314% 495.3 kg/d 1.180% 2.30% Recreational Engine Standards Y Y Implemented 13.6 kg/d 0.032% 0.0 kg/d 0.000% 0.05% On-road Motor Vehicle Standards Y Y Implemented 6,586.2 kg/d 15.602% 10,523.3 kg/d 25.069% 62.74% Reduce locomotive idling N Y Implemented 0.0 kg/d 0.000% 138.8 kg/d 0.331% 0.51% Limit idling-school buses N Y Implemented 0.0 kg/d 0.000% 2.7 kg/d 0.006% 0.01% Retrofit 100 school buses- oxidation catalyst N Y Summer 2005 2.7 kg/d 0.006% 8.2 kg/d 0.019% 0.04% Retrofit 102 school buses - oxidation catalyst N Y End of 2005 Bio-diesel solid waste trucks-purchased N Y Implemented 0.0 kg/d 0.000% 0.9 kg/d 0.002% 0.00% Ethanol alternative fuel vehicles N N 2007 Biodiesel ready trucks N N 2007 Hybrid vehicles N Y Implemented 0.9 kg/d 0.002% 0.9 kg/d 0.002% 0.01% Alternative fuel vehicles N Y Implemented 0.9 kg/d 0.002% 0.9 kg/d 0.002% 0.01% Implement effective environmental driving N Y Implemented Public education: Air Quality Action Day N Y Implemented Timing of refueling vehicles N Y Implemented Promote alternative fuel vehicles N Y Implemented 

& on-going 

Media/public relations program N Y Implemented Public transit incentives N Y Implemented Bike Infrastructure and Amenities N Y Urban 

implemented; Rural in progress 

Expand public education program N Y Implemented 

& on-going 

Tree planting program N Y On-going Mass transit to Blacksburg N Y Implemented 8.2 kg/d 0.019% 3.6 kg/d 0.009% 0.04% Replace gas golf carts w/electric N Y End of 2005 0.9 kg/d 0.002% 0.00% Replace gas mowers w/electric N Y End of 2005 15.4 kg/d 0.037% 0.9 kg/d 0.002% 0.06% Open burning ban -expanded N Y Implemented 0.0 kg/d 0.000% 215.9 kg/d 0.514% 0.79% 
____________________________________________________________________________________ 

Table B-16: Control Measure Emission Reductions for Roanoke, Virginia 


Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Mandatory Restriction lawn equipment usage during ozone action days 

Y Y Implemented 712.6 kg/d 1.688% 472.9 kg/d 1.127% 4.35% 

Voluntary Private Sector Restriction lawn equipment usage during ozone action days 

N Y End of 2005 140.2 kg/d 0.332% 80.5 kg/d 0.192% 0.81% 

Cradle to Cradle Design Competition N Y End of 2005 

Regional Reduction in NOx emissions Y Y May 31, 2004 National Low Emission Vehicle Program Y Y April 14, 1999 Stage1 Vapor Recovery Y Y Implemented 1,593.0 kg/d 3.774% 0.0 kg/d 0.000% 5.84% 

CTG RACT -- CTG VOC RACT and NOx RACT Y Y Initiated 2005 996.1 kg/d 2.360% 716.7 kg/d 1.707% 6.28% 

State Cutback Asphalt Regulation Y Y Initiated 2005 4.5 kg/d 0.011% 0.02% 

Enhanced Ozone Forecasting tool Y Y 2005 

TOTALS 

Y = 17 of 41 

CM 

N = 24 of 41 

CM 

Y = 39 of 41 

CM 

N = 2 of 41 CM 

12,665.2 kg/d 

5,095.8 t/yr 

30.002% 14,603.9 kg/d 

5,875.8 t/yr 

34.789% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-17: Control Measure Emission Reductions for San Antonio, Texas
 

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

ORVR, on-road and non-road federal measures Y Y Implemented 28,667.0 kg/d 15.644% 21,309.8 kg/d 10.495% 52.34% 

Point source emission reductions from power plants 

Y Y Implemented 961.6 kg/d 0.525% 35,842.9 kg/d 17.652% 38.54% 

Degreasing controls N Y by Dec. 2005 85 % 

Reduced Stage I vapor recovery exemption level from 125k gal/mo to 25k gal/mo 

N Y by Dec. 2005 5,270.7 kg/d 2.876% 0.0 kg/d 0.000% 5.52% 

Energy efficiency / Renewable energy projects-­TCEQ 

N Y On-going 0.0 kg/d 0.000% 54.4 kg/d 0.027% 0.06% 

Transportation emission reduction measures (TERMs) 

N Y by Dec. 2005 834.6 kg/d 0.455% 290.3 kg/d 0.143% 1.18% 

Transportation Demand Management (TDM) N Y by Dec. 2005 27.2 kg/d 0.015% 23.6 kg/d 0.012% 0.05% 

Alternative Fuel Vehicles N Y On-going 28.1 kg/d 0.015% 312.5 kg/d 0.154% 0.36% 

Lawnmower Recycling Program N Y by Dec. 31, 2005 51.8 kg/d 0.028% 2.2 kg/d 0.001% 0.06% 

Texas Emission Reduction Program (TERP)-­upgrade on and nonroad mobile source diesel engines with cleaner equipment 

N Y by Dec. 31, 2005 0.0 kg/d 0.000% 1,814.4 kg/d 0.894% 1.90% 

Portable Fuel Container Rule Y Y by Dec. 31, 2005 45 % 

Truck Stop Anti-idling program N Y by Dec. 31, 2005 Windshield Wiper Fluid Y Y by Dec. 31, 2005 

Public education program N Y by Dec. 31, 2005 

TOTALS Y = 4 of 14 CM 

N = 10 of 14 

CM 

Y = 14 of 14 

CM 

N = 0 of 14 CM 

35,841.2 kg/d 14,420.5 t/yr 

19.559% 59,650.0 kg/d 

23,999.8 t/yr 

29.377% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-18: Control Measure Emission Reductions for Washington County, Maryland (H

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Other federal control measures Y Y Before Dec 31, 

2005 

108.3 kg/d 0.449% 1369.8 kg/d 4.776% 18.06% 

On-road Motor Vehicle Standards Y Y Implemented 861.8 kg/d 3.573% 3093.5 kg/d 10.786% 48.33% Small Gasoline Engine Standards Y Y Implemented Gasoline Marine Engine Standards Y Y Implemented Large gasoline Engine Standards Y Y Implemented Ride sharing/commuter connections N Y Implemented 0.3 kg/d 0.001% 0.3 kg/d 0.001% 0.01% Transit programs N Y Implemented 7.4 kg/d 0.031% 6.4 kg/d 0.022% 0.17% Park and Ride lots N Y Implemented 1.8 kg/d 0.007% 1.8 kg/d 0.006% 0.04% Telecommuting N Y Implemented 3.1 kg/d 0.013% 3.3 kg/d 0.012% 0.08% Ozone action days N Y by July 2005 Public education outreach N Y by June 2005 E-gov/e-commerce enhancement N Y by Dec. 2005 1.6 kg/d 0.007% 0.3 kg/d 0.001% 0.02% New jobs tax credit N Y Implemented 1.6 kg/d 0.007% 1.9 kg/d 0.006% 0.04% Growth management program N Y Implemented 13.2 kg/d 0.055% 15.4 kg/d 0.054% 0.35% Signal system enhancements N Y FY 2004 10.2 kg/d 0.042% 3.1 kg/d 0.011% 0.16% Incident Management/Intelligent Transportation System 

N Y Implemented 17.6 kg/d 0.073% 8.0 kg/d 0.028% 0.31% 

On-road vehicle replacement N Y End of 2005 1.5 kg/d 0.006% 13.7 kg/d 0.048% 0.19% Vehicle Emissions Inspection Program Y Y Implemented 480.8 kg/d 1.993% 562.5 kg/d 1.961% 12.75% OTC- consumer products Y Y Implemented 108.9 kg/d 0.451% 0.0 kg/d 0.000% 1.33% OTC-architectural and industrial maintenance Y Y Implemented 92.2 kg/d 0.382% 0.0 kg/d 0.000% 1.13% OTC-portable fuel containers Y Y Implemented 54.4 kg/d 0.226% 0.0 kg/d 0.000% 0.67% OTC-low emissions paint Y Y Implemented 26.3 kg/d 0.109% 0.0 kg/d 0.000% 0.32% Off-road vehicle replacements Y Y Feb. 2002; Jan. 

2004 

RACT Controls -- Post 1999 inventory RACT Y Y Implemented 0.0 kg/d 0.000% 1,312.3 kg/d 4.576% 16.04% 

Y = 12 of 24 

CM 

Y = 24 of 24 

CM 1,791.0 kg/d 6,392.3 kg/d 

TOTALS 

N = 12 of 24 

CM 

N = 0 of 24 CM 720.6 t/yr 

7.425% 

2,571.9 t/yr 

22.287% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-19: Control Measure Emission Reductions for Austin, Texas
 

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

1,787.2 kg/d 1.302% 76,865.8 kg/d 58.181% 78.43% 

I & M Onboard Diagnostics & Low Income Repair Program 

N Y by Dec. 31, 2005 3,474.5 kg/d 2.531% 2,921.1 kg/d 2.211% 6.38% 

Heavy-duty diesel Idling restrictions (April 1 to October 31). 

N Y by Dec. 31, 2005 0.0 kg/d 0.000% 607.8 kg/d 0.460% 0.61% 

Portable Fuel Container Rule Y Y by Dec. 31, 2004 807.4 kg/d 0.588% 0.0 kg/d 0.000% 0.81% 

Reduced Stage I vapor recovery exemption level from 125k gal/mo to 25k gal/mo 

N Y by Dec. 31, 2005 4,427.1 kg/d 3.225% 0.0 kg/d 0.000% 4.41% 

Emission Reduction Program-- financial incentives to retrofit or replace on & nonroad diesel engines 

N Y by Dec. 31, 2005 0.0 kg/d 0.000% 1,814.4 kg/d 1.373% 1.81% 

Degreasing controls N Y by Dec. 31, 2005 5,034.9 kg/d 3.668% 0.0 kg/d 0.000% 5.02% 

Cutback Asphalt N Y by Dec. 31, 2005 934.4 kg/d 0.681% 0.0 kg/d 0.000% 0.93% 

Energy efficiency / Renewable energy projects-­TCEQ 

N Y On-going 

Power Plant Reductions--enforceable commitments by area power plants 

N N by Dec. 31, 2006 

Low emission diesel for fleets Y Y On-going 

Transportation emission reduction measures (TERMs) 

N Y On-going 753.0 kg/d 0.549% 653.2 kg/d 0.494% 1.40% 

Clean Air Partners Program (CLEAN AIR Force of Central TX) the area. 

N Y Ongoing 

Access management regulations or guidelines for new or re-development emissions. 

N Y On-going 

Alternate commute infrastructure requirements N Y On-going 

Reduce use of drive-through lanes on ozone action days 

N Y On-going 

Expedited permitting for mixed use, transitoriented or in-fill-development N Y On-going 

Airport Clean Air Plan--electric or alternative fuels for airport ground service equipment and shuttle buses 

N Y On-going 

Low VOC striping material--require use of reformulated striping material products 

N Y On-going 

Open burning restrictions during peak ozone season. 

N Y On-going 

Tree planting program using low VOC-emitting trees 

N Y On-going 
____________________________________________________________________________________ 

Table B-19: Control Measure Emission Reductions for Austin, Texas
 

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Local commitment to State's 5% per year energy usage reduction program 

N Y On-going 

Shift electric load profile to nighttime period N Y On-going 

Environmental dispatch of power plants N Y On-going 

Incentives for purchase of low emission vehicles N Y On-going 

Adopt a school bus replacement program N Y On-going 198.8 kg/d 0.151% 0.20% Increased enforcement of speed limits and smoking vehicle restrictions. 

N Y On-going 

Business evaluation of fleet usage N Y On-going 

Commute solutions programs-compressed work week; carpool/alternative transportation incentives; flexible work schedule; transit pass subsidized by employer, teleworking, etc 

N Y On-going 

Offer employees direct deposit to reduce vehicle 

use 

N Y On-going 

Provide e-Government services to reduce VMT N Y On-going 

Fueling vehicles in evening N Y On-going 

Urban Heat Island/Cool cities program N Y On-going 

Expand and quantify ongoing resource conservation programs 

N Y On-going 

Electric utilities develop customer incentives for installation of energy efficient appliances / technologies. 

N Y On-going 

Construction-related emissions on ozone action days clauses in public contracts 

N Y On-going 

Ensure emission reductions in SEPs, BEPs, and 

similar agreements 

N Y On-going 

Ozone action day education program N Y On-going 
____________________________________________________________________________________ 

Table B-19: Control Measure Emission Reductions for Austin, Texas
 

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Ozone Action Day specific reduction measures program 

N Y On-going 

Education program to delay landscaping work on high ozone days. 

N Y On-going 

Residential electric lawnmower exchange program 

N Y 1997, 2002 & 2003 

State Agency Voluntary Commute Reduction Projects commuting. 

N Y Voluntary 

TOTALS Y = 3 of 42 CM 

N = 39 of 42 

CM 

Y = 41 of 42 

CM 

N = 1 of 42 CM 

17,218.4 kg/d 

6,927.7 t/yr 

12.543% 83,061.1 kg/d 

33,419.1 t/yr 

62.871% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-20: Control Measure Emission Reductions for Berkeley-Charleston-Dorchester, S

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Appoint Ozone Action Coordinator N Y 2003 Add ozone alert to county website N Y 2003 Expand electronic transactions N Y On-going Develop, implement ozone public education plan N Y Begin FY 2004 Expand use of hybrid cars N Y FY 2005 Use right size - county fleet N Y FY 2005 Include fuel efficiency/emission ratings N Y FY 2005 Purchase vehicles/light trucks to meet new standards 

N Y On-going 

Purchase heavy duty diesel trucks to meet new standards 

N Y On-going 

Convert to use of low-sulfur gasoline N Y On-going Consider pilot test for county fleets N Y FY 2005 Best practices for fueling N Y FY 2004 Land use plan-develop mass transit N Y On-going Limit emissions from counties small engines N Y Over 5 yrs Ask garages to limit idling N Y FY 2004 Energy conservation at county bldgs N Y FY 2004 Expand flexible hrs-county employees N Y FY 2004 Encourage walking, biking, car pooling N Y FY 2005 Form regional stakeholders group N Y FY 2004 Remain current w/stakeholders N Y On-going Support programs to reduce ozone for SCDOT N Y On-going Set the example-telecommuting; carpooling; flex schedules; alternate fuel vehicles 

N Y On-going 

Educational programs N N TBD Schools-add sidewalks, increase bus usage; restrict vehicle idle times 

N N TBD 

Ozone conditions-TV N Y May 2004 Educate public - festivals, lecturer, brochure N N TBD Planning for future green spaces N Y On-going Cluster development, Smart Growth, mass transit 

N Y On-going 

Conserve energy in county property N Y June 2003 Designate Ozone Action Coordinator N Y March 2003 Zoning ordinance-landscape buffers N Y Sep. 2000 Implement Greenspace initiative N Y Sep. 2000 
____________________________________________________________________________________ 

Table B-20: Control Measure Emission Reductions for Berkeley-Charleston-Dorchester, S

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Encourage development of non-polluting industries 

N Y On-going 

Encourage recycling goods N Y On-going 

Increase focus-composting N Y On-going 

Install passive gas vents-landfill N Y Prior to 2004 

Purchase 2 alternative fuel vehicles for Sheriff Dept 

N Y February 2004 

Best management practices-engines N Y On-going 

Staggered work schedule N Y On-going 

TOTALS Y = 0 of 39 CM 

N = 39 of 39 

CM 

Y = 36 of 39 

CM 

N = 3 of 39 CM 

0.0 kg/d 0.0 t/yr 

0.000% 0.0 kg/d 

0.0 t/yr 

0.000% 0.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-21: Control Measure Emission Reductions for Mountain Area of Western North Car

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

5,443.1 kg/d 13.564% 42,909.8 kg/d 69.295% 96.04% 

Open burning ban -ozone action days Y Y June 2004 453.6 kg/d 1.130% 362.9 kg/d 0.586% 1.62% 

Expand vehicle I & M Y Y July 2005 544.3 kg/d 1.356% 635.0 kg/d 1.026% 2.34% 

TOTALS Y = 3 of 3 CM 

N = 0 of 3 CM 

Y = 3 of 3 CM 

N = 0 of 3 CM 

6,441.0 kg/d 

2,591.5 t/yr 

16.050% 43,907.7 kg/d 

17,666.0 t/yr 

70.906% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-22: Control Measure Emission Reductions for Oklahoma City, Oklahom

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

4,753.7 kg/d 2.779% 21,918.3 kg/d 13.917% 99.60% 

Transportation system improvements ­intersection improvement, signal 

modification/interconnection, continuous left turn 

lanes 

N Y 2004-2005 54.4 kg/d 0.032% 35.6 kg/d 0.023% 0.34% 

Bike/pedestrian facilities N Y 2005 NQ NQ 

Intelligent Transportation Systems Projects N Y 2004-2005 16.1 kg/d 0.009% 0.06% 

TOTALS Y = 1 of 4 CM 

N = 3 of 4 CM 

Y = 4 of 4 CM 

N = 0 of 4 CM 

4,824.2 kg/d 

1,941.0 t/yr 

2.821% 21,953.9 kg/d 

8,833.0 t/yr 

13.940% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-23: Control Measure Emission Reductions for Lower Savannah-Augusta, South Ca

Control Measure Implementation Emission Reductions 

VOC Reduction NOx Reduction 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

% of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Air Quality Contact-ozone education/outreach N Y March 2003 Stage I Vapor Recovery (GA) Y Y Dec. 2005 1,460.6 kg/d 1.139% 31.20% Delay/reschedule mowing on ozone action days N Y July 2003 Delay/reschedule landscaping activities on ozone action days 

N Y July 2003 

Don't top off fuel tanks N Y July 2003 Turn off lights/computers N Y July 2003 Restrict painting-ozone action days N Y July 2003 Promote employee awareness of ozone issues N Y July 2003 Change work schedule N Y July 2003 Seek information on alternative fuels N N TBD Reduce idling especially during high ozone days N Y 2003 Stricter controls on illegal burning N Y 2003 Replace vehicles with latest emission reduction vehicles 

N N TBD 

Community education N Y 2003 / On-going Switch vehicles to bio-diesel N Y 2002 Low-sulfur Type II fuels in all vehicles N Y July 2003 Promote Early Action Plan N Y July 2003 Commuter Choice Program N Y May 2003 Install Intelligent Transportation System equipment along major routes 

N N Post 2007 

Revise ordinances to promote bike/pedestrian N Y June 2003 Establish minimum tree planting requirements N Y June 2003 Ban or limit open burning (SC local) N Y Implemented Encourage carpool to lunch N Y 2003 Install workplace occupancy sensors -reduce energy 

N Y 2003-2004 

Use reflective paint to reduce energy consumption 

N Y 2003-2004 

Purchase Energy Star products N Y 2003 Stakeholder development N Y June 2003 Public education program N Y July 2003 Purchase test alt fuel vehicles N Y June 2004 Monitor/reduce engine idling N Y June 2004 Open burning ban -ozone season (GA) N Y May 2005 1,587.6 kg/d 1.238% 644.1 kg/d 0.513% 47.67% Voluntary smog alerts N Y July 2004 
____________________________________________________________________________________ 

Table B-23: Control Measure Emission Reductions for Lower Savannah-Augusta, South Ca

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Stage I Vapor Recovery (SC) Y Y Dec. 2005 988.8 kg/d 0.771% 21.12% 

Maintain vehicles at peak efficiency and replaced with more efficient 

N Y On-going 

Reinforce prohibit idling when not in use N Y On-going 

Promote use of alternative fuel vehicles N Y Dec. 2004 

Protect natural areas; minimize use of motorized vehicles; pesticides 

N Y On-going 

Enforce existing Tree Ordinance-developments N Y On-going 

Increase bike and pedestrian routes N Y On-going 

Community education N Y On-going 

Enforce existing open burning restrictions (GA local) 

N Y On-going 

Support Long Range Transportation Plan N Y On-going 

Support initiatives-rural public transportation N Y On-going 

Incorporate Early Action Plan-municipal plans N Y On-going 

TOTALS Y = 2 of 44 CM 

N = 42 of 44 

CM 

Y = 40 of 44 

CM 

N = 4 of 44 CM 

4,037.0 kg/d 1,624.3 t/yr 

3.149% 644.1 kg/d 

259.2 t/yr 

0.513% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-24: Control Measure Emission Reductions for Tulsa, Oklahoma 


Control Measure Implementation Emission Reductions 

Control Measure Description 

State or 

National 

Measure 

(Y/N) 

Implemented 

by 

December 

2005 

(Y/N) 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Federal control measures Y Y Before Dec 31, 

2005 

9,870.2 kg/d 5.951% 50,784.2 kg/d 26.209% 96.20% 

Transportation Emission Reduction Strategy ­roadway expansion and intersection improvement projects 

TOTALS 

N 

Y = 1 of 2 CM 

N = 1 of 2 CM 

Y 

Y = 2 of 2 CM 

N = 0 of 2 CM 

Dec. 31, 2005 18.1 kg/d 

9,888.3 kg/d 

3,978.5 t/yr 

0.011% 5.962% 

2,376.8 kg/d 

53,161.0 kg/d 

21,389.0 t/yr 

1.227% 

27.435% 

3.80% 

100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-25: Control Measure Emission Reductions for South Carolina 

(Statewide) 

Control Measure Implementation Emission Reductions 

State or 

National 

Implemented 

by 

Implementation 

Date 

VOC Reduction NOx Reduction % of Total 

Quantified 

Emissions 

Reductions 

(NOx & VOC) 

Control Measure Description 

Measure 

(Y/N) 

December 

2005 

(Y/N) 

Amount 

of 

Reduction 

% of 

EAC Area 

Total VOC 

Emissions 

Amount 

of 

Reduction 

% of 

EAC Area 

Total NOx 

Emissions 

Ozone forecast/outreach, education N N 

Open Burning-ban household trash burning Y Y 2005 1,734.8 kg/d 0.314% 365.4 kg/d 0.068% 0.76% 

SC NOx Control Regulation - new sources Y Y 2005 7,240.1 kg/d 1.356% 2.63% 

Assist local areas in determining emission reductions 

Y N 

Clean Air Initiatives for Governmental Entities Y Y April 2005 

Smart highways Y Y 2005 NOx reduction-large facilities Y Y April 2005 31,068.0 kg/d 5.821% 11.28% 

Appalachian Area Local Control Measure Reductions 

N Y By Dec 31, 2005 37,927.7 kg/d 6.864% 91,317.0 kg/d 17.109% 46.93% 

Central Midlands Local Control Measure Reductions 

N Y By Dec 31, 2005 22,322.8 kg/d 4.040% 78,735.7 kg/d 14.751% 36.70% 

Charleston Area Local Control Measure Reductions 

N Y By Dec 31, 2005 0.0 kg/d 0.000% 0.0 kg/d 0.000% 0.00% 

Lower Savannah Local Control Measure Reductions 

N Y By Dec 31, 2005 4,037.0 kg/d 0.731% 644.1 kg/d 0.121% 1.70% 

TOTALS Y = 6 of 11 CM 

N = 5 of 11 CM 

Y = 9 of 11 CM 

N = 2 of 11 CM 

66,022.3 kg/d 26,563.7 t/yr 

11.948% 209,370.1 kg/d 

84,238.7 t/yr 

39.226% 100.00% 

Definition assumptions for measures: 

• State measure: measure adopted by states that applies in more than area in a state • National measure: measure adopted by EPA that applies nationally or in a sub region • Local measure: measures adopted by a local unit of government for the area or by the state for the specific area 
____________________________________________________________________________________ 

Table B-26: Comparison of EAC NOx and VOC Emissions Reductions to the 2002 Emissions for the 2

Emissions for the States in Which They Are Located, and the NOx SIP Call Emission Reduction

EAC Area Description 

NOx Emissions Reductions and Base Year Inventory (tons/year) VOC Emissions Reductions a

EAC Area Emission Reductions 2002 NOx Emissions Inventory 

2000-2006 NOx SIP Call 

Reductions 

EAC Area Emission Reductions 

National & State 

Measures 

Local 

Measures 

Total 

National & State 

Measures 

Local 

Measures 

Total State-wide Emissions EAC Area Emissions 

Nonattainment-Deferred EAC Program Areas Berkeley and Jefferson Counties, WV (Eastern Panhandle EAC) 

694 774 1,467 

382,514 

0.2% 0.2% 0.4% 

11,627 

6.0% 6.7% 12.6% 

80,346 

0.9% 1.0% 1.8% 

146 776 922 

0

Chattanooga, TN-GA (Chattanooga Area EAC) 9,473 539 10,012 1,221,179 0.8% 0.0% 0.8% 30,816 30.7% 1.7% 32.5% 45,717 20.7% 1.2% 21.9% 8,566 1,253 9,819 

0

Columbia, SC (Central Midlands EAC) 26,280 5,398 31,679 355,640 7.4% 1.5% 8.9% 45,888 57.3% 11.8% 69.0% 21,298 123.4% 25.3% 148.7% 8,979 2 8,981 

2

Denver-Boulder-Greeley-Ft Collins-Love, CO (Denver Area EAC) 21,535 0 21,535 

319,555 

6.7% 0.0% 6.7% 

147,563 

14.6% 0.0% 14.6% 

NA 

38,800 0 38,800 

7

Fayetteville, NC (Fayetteville Area EAC) 3,723 9 3,732 608,616 0.6% 0.0% 0.6% 11,233 33.1% 0.1% 33.2% 42,695 8.7% 0.0% 8.7% 2,847 246 3,093 

0

Frederick County, VA 

(Northern Shenandoah Valley 

EAC) 

2,085 197 2,282 

513,247 

0.4% 0.0% 0.4% 

7,773 

26.8% 2.5% 29.4% 

19,552 

10.7% 1.0% 11.7% 

1,855 267 2,122 

0

Greensboro-Winston Salem-High Point, NC (Triad Area EAC) 148,039 480 148,518 

608,616 

24.3% 0.1% 24.4% 

123,245 

120.1% 0.4% 120.5% 

42,695 

346.7% 1.1% 347.9% 

15,987 523 16,510 

2

Greenville-SpartanburgAnderson, SC (Appalachian Area EAC) 24,528 12,213 36,741 

355,640 

6.9% 3.4% 10.3% 

53,594 

45.8% 22.8% 68.6% 

21,298 

115.2% 57.3% 172.5% 

15,257 2 15,259 

3

Hickory-Morganton-Lenoir, NC (Unifour Area EAC) 50,881 4 50,885 

608,616 

8.4% 0.0% 8.4% 

33,059 

153.9% 0.0% 153.9% 

42,695 

119.2% 0.0% 119.2% 

5,147 5 5,151 

3

Johnson City-KingsportBristol, TN (Tri-Cities Area EAC) 

4,516 94 4,610 

570,102 

0.8% 0.0% 0.8% 

52,289 

8.6% 0.2% 8.8% 

45,717 

9.9% 0.2% 10.1% 

7,541 30 7,570 

1

Nashville, TN (Nashville Area EAC) 18,833 822 19,655 570,102 3.3% 0.1% 3.4% 88,503 21.3% 0.9% 22.2% 45,717 41.2% 1.8% 43.0% 15,956 476 16,432 

3

Roanoke, VA (Roanoke Area EAC) 5,693 183 5,876 513,247 1.1% 0.0% 1.1% 16,890 33.7% 1.1% 34.8% 19,552 29.1% 0.9% 30.1% 5,028 68 5,096 

1
____________________________________________________________________________________ 

Table B-26: Comparison of EAC NOx and VOC Emissions Reductions to the 2002 Emissions for the 2

Emissions for the States in Which They Are Located, and the NOx SIP Call Emission Reduction

NOx Emissions Reductions and Base Year Inventory (tons/year) VOC Emissions Reductions a

EAC Area Emission Reductions 2002 NOx Emissions Inventory EAC Area Emission Reductions 

EAC Area Description 

National & State 

Measures 

Local 

Measures 

Total State-wide Emissions EAC Area Emissions 2000-2006 NOx SIP Call Reductions National & State Measures Local Measures Total 

1,894,105 81,696 NA 

San Antonio, TX (San Antonio Area EAC) 22,995 1,005 24,000 

1.2% 0.1% 1.3% 28.1% 1.2% 29.4% 

11,921 2,500 14,420 

0

Washington County , MD 297,586 11,540 10,474 (Hagerstown) (Washington Co. EAC) 

2,550 22 2,572 

0.9% 0.0% 0.9% 22.1% 0.2% 22.3% 24.3% 0.2% 24.6% 

697 23 721 

0

Attainment EAC Program Areas Austin, TX 1,894,105 53,155 NA (Austin Area EAC) 30,926 2,493 33,419 1.6% 0.1% 1.8% 58.2% 4.7% 62.9% 1,044 5,884 6,928 0Berkeley-Charleston- 355,640 81,670 21,298 Dorchester, SC (Charleston Area EAC) 0 0 0 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0 0 0 0Asheville, NC 608,616 24,915 42,695 (Mountain Area of Western NC EAC) 17,666 0 17,666 2.9% 0.0% 2.9% 70.9% 0.0% 70.9% 41.4% 0.0% 41.4% 2,592 0 2,592 0Oklahoma City, OK 448,240 63,365 NA (Central Area EAC) 8,819 14 2.0% 0.0% 2.0% 13.9% 0.0% 13.9% 1,913 28 0

1,006,717 50,488 21,298 

Savannah-Augusta, SC-GA (Lower Savannah-Augusta Area EAC) 

0 259 

0.0% 0.0% 0.0% 0.0% 0.5% 0.5% 0.0% 1.2% 1.2% 

986 639 

0

Tulsa, OK 448,240 77,961 NA (Tulsa Area EAC) 20,433 956 4.6% 0.2% 4.8% 26.2% 1.2% 27.4% 3,971 7 1South Carolina 355,640 214,751 21,298 (Statewide) 15,560 68,679 4.4% 19.3% 23.7% 7.2% 32.0% 39.2% 73.1% 322.5% 395.5% 698 25,866 0

Sources: 2002 National Emissions Inventory, EAC SIPs, Table 3 of http://www.epa.gov/airmarkt/progress/docs/2006-NBP-Report.

8,833 1,941 

259 1,624 

21,389 3,979 84,239 26,564 
____________________________________________________________________________________ 

Table B-27: Population Change from 2002 to 2006 in 14 Nonattainment-Deferred EAC Progr

Geographic Area Population Estimates Percent 

July 1, 2002 July 1, 2006 

United States 287,888,021 298,754,819 South 103,188,427 108,894,582 West 65,476,021 69,141,582 

West Virginia 1,804,146 1,818,470 

West Virginia (rest of state) 1,677,789 1,670,493 

Berkeley and Jefferson Counties, West Virginia 126,357 147,977 

Georgia 8,597,927 9,363,941 

Georgia (rest of state) 8,479,304 9,237,319 

Tennessee 5,788,333 6,038,803 

Tennessee (rest of state) 5,440,181 5,686,258 

Chattanooga, Tennessee-Georgia (Georgia portion) 118,623 126,622 

Chattanooga, Tennessee-Georgia (Tennessee portion) 348,152 352,545 

Chattanooga, Tennessee-Georgia 466,775 479,167 

South Carolina 4,101,122 4,321,249 

South Carolina (rest of state) 3,489,190 3,671,291 

Columbia, South Carolina (Central Midlands Area) 611,932 649,958 

Colorado 4,500,122 4,753,377 

Colorado (rest of state) 1,529,450 1,603,723 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 

2,970,672 3,149,654 

North Carolina 8,313,494 8,856,505 

North Carolina (rest of state) 8,009,400 8,557,445 

Fayetteville, North Carolina (Cumberland County) 304,094 299,060 Virginia 7,285,707 7,642,884 
____________________________________________________________________________________ 

Table B-27: Population Change from 2002 to 2006 in 14 Nonattainment-Deferred EAC Progr

Geographic Area Population Estimates Percent 

July 1, 2002 July 1, 2006 

Virginia (rest of state) 7,198,425 7,546,432 

Frederick Co, Virginia 87,282 96,452 

North Carolina 8,313,494 8,856,505 

North Carolina (rest of state) 6,841,625 7,319,383 

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 

1,471,869 1,537,122 

South Carolina 4,101,122 4,321,249 

South Carolina (rest of state) 3,047,632 3,216,134 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 

1,053,490 1,105,115 

North Carolina 8,313,494 8,856,505 

North Carolina (rest of state) 7,964,526 8,496,649 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 

348,968 359,856 

Tennessee 5,788,333 6,038,803 

Tennessee (rest of state) 5,379,476 5,619,535 

Johnson City-Kingsport-Bristol, Tennessee 408,857 419,268 Tennessee 5,788,333 6,038,803 

Tennessee (rest of state) 4,518,728 4,669,256 

Nashville, Tennessee 1,269,605 1,369,547 

Virginia 7,285,707 7,642,884 

Virginia (rest of state) 7,050,213 7,403,797 

Roanoke, Virginia 235,494 239,087 

Texas 21,762,430 23,507,783 
____________________________________________________________________________________ 

Table B-27: Population Change from 2002 to 2006 in 14 Nonattainment-Deferred EAC Progr

Geographic Area Population Estimates Percent 

July 1, 2002 July 1, 2006 

Texas (rest of state) 20,107,591 21,703,771 

San Antonio, Texas 1,654,839 1,804,012 

Maryland 5,441,349 5,615,727 

Maryland (rest of state) 5,306,649 5,471,979 

Washington Co (Hagerstown), Maryland 134,700 143,748 

Source: U.S.Census Bureau, Green Book For partial counties, the population estimates are for the entire county, while the EAC Program Area includes only part of the county. This includes the Columbia, South Carolina (Central Midlands Area); Denver-Boulder-GreeleyFort Collins-Loveland, Colorado; and Hickory-Morganton-Lenoir, North Carolina (Unifour Area) areas. 
____________________________________________________________________________________ 

Table B-28: Population Change from 2002 to 2006 in 6 Attainment EAC Program A

Geographic Area Population Estimates Percent 

July 1, 2002 July 1, 2006 

United States 287,888,021 298,754,819 

South 103,188,427 108,894,582 

West 65,476,021 69,141,582 

Texas 21,762,430 23,507,783 

Texas (rest of state) 20,414,966 21,994,218 

Austin, Texas 1,347,464 1,513,565 

South Carolina 4,101,122 4,321,249 

South Carolina (rest of state) 3,538,543 3,718,071 

Berkeley-Charleston-Dorchester, South Carolina 562,579 603,178 

North Carolina 8,313,494 8,856,505 

North Carolina (rest of state) 8,028,063 8,557,529 

Mountain Area of Western North Carolina (Asheville) 285,431 298,976 

Oklahoma 4,101,122 4,321,249 

Oklahoma (rest of state) 2,993,955 3,163,407 

Oklahoma City, Oklahoma 1,107,167 1,157,842 

Georgia 8,597,927 9,363,941 

Georgia (rest of state) 8,305,429 9,062,656 

South Carolina 4,101,122 4,321,249 

South Carolina (rest of state) 3,798,745 4,013,887 

Lower Savannah-Augusta, South Carolina-Georgia (Georgia portion) 302,377 307,362 

Lower Savannah-Augusta, South Carolina-Georgia (South Carolina portion) 

292,498 301,285 

Lower Savannah-Augusta, South Carolina-Georgia 594,875 608,647 

Oklahoma 4,101,122 4,321,249 
____________________________________________________________________________________ 

Table B-28: Population Change from 2002 to 2006 in 6 Attainment EAC Program A

Geographic Area Population Estimates Percent 

July 1, 2002 July 1, 2006 

Oklahoma (rest of state) 3,281,801 3,480,011 

Tulsa, Oklahoma 819,321 841,238 

Source: U.S.Census Bureau, Green Book For partial counties, the population estimates are for the entire county, while the EAC Program Area includes only part of the counWestern North Carolina (Asheville) area. 
____________________________________________________________________________________ 

Table B-29: Vehicle Miles Traveled (VMT) Change from 2002 to 2006 


In 14 Nonattainment-Deferred EAC Program Areas
 

Geographic Areas VMT Estimates Percent Cha

2002 2006 

United States 2,822,279 3,014,116 

South 1,120,903 1,225,953 

West 585,246 645,007 

West Virginia 19,544 20,885 

West Virginia (rest of state) 18,264 19,637 

Berkeley and Jefferson Counties, West Virginia 1,279 1,248 

Georgia 106,727 113,532 

Georgia (rest of state) 106,159 112,927 

Tennessee 68,315 70,596 

Tennessee (rest of state) 63,907 66,131 

Chattanooga, Tennessee-Georgia (Georgia portion) 569 605 

Chattanooga, Tennessee-Georgia (Tennessee portion) 4,408 4,465 

Chattanooga, Tennessee-Georgia 4,976 5,070 

South Carolina 47,074 50,199 

South Carolina (rest of state) 39,866 42,397 

Columbia, South Carolina (Central Midlands Area) 7,208 7,802 

Colorado 43,539 48,641 

Colorado (rest of state) 19,458 21,669 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 24,081 26,972 

North Carolina 80,200 101,515 

North Carolina (rest of state) 77,420 98,539 

Fayetteville, North Carolina (Cumberland County) 2,780 2,976 
____________________________________________________________________________________ 

Table B-29: Vehicle Miles Traveled (VMT) Change from 2002 to 2006 


In 14 Nonattainment-Deferred EAC Program Areas
 

Geographic Areas VMT Estimates Percent Cha

2002 2006 

Virginia 77,396 81,095 

West Virginia (rest of state) 76,260 80,084 

Frederick Co, Virginia 1,136 1,011 

North Carolina 80,200 101,515 

North Carolina (rest of state) 63,849 83,865 

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 

16,351 17,650 

South Carolina 47,074 50,199 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 

10,887 11,535 

South Carolina (rest of state) 36,187 38,664 

North Carolina 80,200 101,515 

North Carolina (rest of state) 77,197 97,785 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 3,003 3,730 

Tennessee 68,315 70,596 

Tennessee (rest of state) 64,428 66,508 

Johnson City-Kingsport-Bristol, Tennessee 3,887 4,088 

Tennessee 68,315 70,596 

Tennessee (rest of state) 52,439 51,493 

Nashville, Tennessee 15,876 19,103 

Virginia 77,396 81,095 

Virginia (rest of state) 74,909 78,510 

Roanoke, Virginia 2,487 2,585 

Texas 217,820 238,256 
____________________________________________________________________________________ 

Table B-29: Vehicle Miles Traveled (VMT) Change from 2002 to 2006 


In 14 Nonattainment-Deferred EAC Program Areas
 

Geographic Areas VMT Estimates Percent Cha

2002 2006 

Texas (rest of state) 202,853 221,891 

San Antonio, Texas 14,967 16,365 

Maryland 53,758 56,302 

Maryland (rest of state) 51,872 54,266 

Washington Co (Hagerstown), Maryland 1,886 2,036 

Source: The VMT numbers come from the National Emissions Inventory’s VMT estimates, which are derived from the Highway PerMonitoring System (HPMS). It is important to note that they are subject to significant uncertainty that can cause over or underestimadesigned to collect statewide data to populate a national database that would be used to: (1) assess the performance and condition of ttransportation system; and, (2) help guide national investment priorities. The sampling techniques were designed for these purposes. appropriate for estimating small changes in VMT in smaller geographic areas such as the areas included in this study. While the margstatewide and national level is acceptable for the purposes that HPMS was designed for, it is unclear whether the margin of error at thareas scale would render the study inconclusive (see http://www.fhwa.dot.gov/policy/ohpi/hpms/abouthpms.htm). 

For partial counties, the VMT estimates are for the entire county, while the EAC Program Area includes only part of the county. This Columbia, South Carolina (Central Midlands Area); Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado and Hickory-MorgantCarolina (Unifour Area) areas. 
____________________________________________________________________________________ 

Table B-30: VMT Change From 2002 to 2006 in 6 Attainment EAC Program Areas
 

Geographic Area VMT Estimates Percent Cha

2002 2006 

United States 2,822,279 3,014,116 

South 1,120,903 1,225,953 

West 585,246 645,007 Texas 217,820 238,256 Texas (rest of state) 204,732 223,931 Austin, Texas 13,088 14,325 South Carolina 47,074 50,199 South Carolina (rest of state) 41,425 43,947 Berkeley-Charleston-Dorchester, South Carolina 5,649 6,252 North Carolina 80,200 101,515 North Carolina (rest of state) 77,085 97,509 Mountain Area of Western North Carolina (Asheville) 3,115 4,006 Oklahoma 45,732 48,689 Oklahoma (rest of state) 31,938 34,493 Oklahoma City, Oklahoma 13,793 14,196 Georgia 106,727 113,532 Georgia (rest of state) 103,992 110,483 South Carolina 47,074 50,199 South Carolina (rest of state) 43,020 46,179 Lower Savannah-Augusta, South Carolina-Georgia (Georgia portion) 2,736 3,049 Lower Savannah-Augusta, South Carolina-Georgia (South Carolina portion) 4,054 4,020 

Lower Savannah-Augusta, South Carolina-Georgia 6,790 7,069 Oklahoma 45,732 48,689 
____________________________________________________________________________________ 

Table B-30: VMT Change From 2002 to 2006 in 6 Attainment EAC Program Areas
 

Geographic Area VMT Estimates Percent Cha

2002 2006 

Oklahoma (rest of state) 35,093 37,215 

Tulsa, Oklahoma 10,639 11,474 

Source: The VMT numbers come from the National Emissions Inventory’s VMT estimates, which are derived from the Highway PerMonitoring System (HPMS). It is important to note that they are subject to significant uncertainty that can cause over or underestimadesigned to collect statewide data to populate a national database that would be used to: (1) assess the performance and condition of ttransportation system; and, (2) help guide national investment priorities. The sampling techniques were designed for these purposes. appropriate for estimating small changes in VMT in smaller geographic areas such as the areas included in this study. While the margstatewide and national level is acceptable for the purposes that HPMS was designed for, it is unclear whether the margin of error at thareas scale would render the study inconclusive (see http://www.fhwa.dot.gov/policy/ohpi/hpms/abouthpms.htm). 

For partial counties, the VMT estimates are for the entire county, while the EAC Program Area includes only part of the county. This Area of Western North Carolina (Asheville) area. 
____________________________________________________________________________________ 

Table B-31: EPA Resources for Traditional Approach versus EAC Progr

EPA Full Time Equivalent 

(FTE) Number of EPA Federal Register 

Actions (pages) 

Regional 

Offices Headquarters 

Hypothetical Areas – Traditional Approach Estimate for resources required for a typical nonattainment area from State Implementation Plan (SIP) development through red4.5 years). 

Headquarters NA 13.05 0 $0 

Regions 11.5 to 44.2 NA 28 (715 pages) actions to 

46 actions (1,085 pages) 

$349,

Subtotal 11.5 to 44.2 13.05 28 (715 pages) actions to 

46 actions (1,085 pages) 

$349,

Resources required for a typical attainment area 

Headquarters 0 0 0 $0 

Regions 0 0 0 $0 

Subtotal 0 0 0 $0 

Total estimate for hypothetical nonattainment and 

attainment areas 

11.5 to 44.2 13.05 28 (715 pages) actions to 

46 actions (1,085 pages) 

$349,

EAC Program** Estimate for resources includes program startup (about 6 years). 

Headquarters NA 7.174 11 actions (326 pages) $159,

Regions 16.66 NA 44 actions (235 pages) $114,

Total for all EAC Program Areas 16.66 7.174 55 actions (561 pages) $274,

 Source: EPA Headquarters and Regional Office Staff 

*Assumes current Federal Register of $489 per page. **EPA resources expended on the EAC Program were not tracked during EAC Program implementation. T numbers presented here for the EAC Program are “after the fact” estimates. 

Steps for Completing Resource Estimates for Table: Note: For the traditional approach, assume no resources expended on SIP program for attainment areas. Step 1: Determine the year 2000 population and classification for the 14 nonattainment-deferred areas that thhad not become EAC Program areas but instead became traditional nonattainment areas Step 2: Sort the areas by year 2000 population. 
____________________________________________________________________________________ 

Nonattainment-Deferred EAC Program Area 2000 Population 8-Ho

Nonattain

Classifica

Small (<250,000) Frederick Co, Virginia 82,794 Subpart 1 Berkeley and Jefferson Counties, West Virginia 118,095 Subpart 1 Washington County, Maryland (Hagerstown) 131,923 Subpart 1 Johnson City-Kingsport-Bristol, Tennessee 206,611 Subpart 1 Roanoke, Virginia 235,932 Subpart 1 Mid size (250,000 to 800,000) Fayetteville, North Carolina (Cumberland County) 302,963 Subpart 1 Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 309,512 Subpart 1 Chattanooga, Tennessee-Georgia 372,264 Subpart 1 Columbia, South Carolina (Central Midlands Area) 494,518 Subpart 1 Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 799,147 Subpart 1 Large (> 800,000) Nashville, Tennessee 1,097,810 Subpart 1 Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 1,285,879 Marginal San Antonio, Texas 1,559,975 Subpart 1 Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 2,811,580 Subpart 1 

*The classification the areas would have had, at least initially, had they not become EAC Program areas and instead purtraditional route. 
____________________________________________________________________________________ 

Step 3: Determine what size and classification of traditional area resource estimate needed and list the areas h

•	 Small Subpart 1 nonattainment area; •	 Mid size Subpart 1 nonattainment area; and •	 Large Subpart 1 nonattainment area. 

Step 4: Regions 3, 4, 6, and 8 develop estimates of “average” resources (e.g., FTE and Federal Register actionthe three types of areas listed in step 3 based on regional experience with other Subpart 1 areas. 

•	 Estimate should encompass SIP development through redesignation to attainment (about 4.5 years); •	 Estimate should include all regional resources (e.g., technical and policy/planning staff, regional couns•	 Estimate should be averages based on regional experience with one or more examples of each type of a•	 If a region lacks an example to use for one or two of the area types, then no estimate should be submitt

that: 

o	 Region 6 should use examples of marginal or moderate areas to develop their estimates. 

Step 5: Calculate “average,” per area resource estimate (of the regional estimates) for each area type for each following: 

Area Type “Average” Regional Resource Estimates Across The Areas In 

Region That Would Have Had Subpart 1 Areas 

Small Subpart 1 nonattainment areas Region 3: 

• FTE: 1.9 

• Federal Register Actions: 2 • Federal Register Pages: 59 • Federal Register Cost*: $28,851 

Mid size Subpart 1 nonattainment areas Region 3: 

• FTE: 1.9 

• Federal Register Actions: 2 • Federal Register Pages: 60 • Federal Register Cost*: $29,340 

Region 4: 

• FTE: 0.25 • Federal Register Actions: 4 • Federal Register Pages: 130 • Federal Register Cost*: $63,570 
____________________________________________________________________________________ 

Area Type “Average” Regional Resource Estimates Across The Areas In 

Region That Would Have Had Subpart 1 Areas 

Large Subpart 1 nonattainment areas Region 4: 

• FTE: 0.18 

• Federal Register Actions: 2 • Federal Register Pages: 30 • Cost*: $14,670 

Region 8: 

• FTE: 6.3 • Federal Register Actions: 4 • Federal Register Pages: 35 • Cost*: $17,115 

*Federal Register costs are assumed to be current: $163/column or $489/page at 3 columns per 

Step 6: Multiply the range of “average” resource estimate for each area type by the number of areas in that ty

• Small Subpart 1 nonattainment area 

o Average FTE resource estimate * 5 nonattainment deferred EAC Program areas = 9.5 o Average Federal Register action resource estimate * 5 nonattainment deferred EAC Program aro Average Federal Register pages resource estimate * 5 nonattainment deferred EAC Program aro Average Federal Register cost estimate * 5 nonattainment deferred EAC Program areas = $144

• Mid size Subpart 1 nonattainment area 

o Average FTE resource estimate * 5 nonattainment deferred EAC Program areas = 1.25 to 9.5 o Average Federal Register action resource estimate * 5 nonattainment deferred EAC Program aro Average Federal Register pages resource estimate * 5 nonattainment deferred EAC Program aro Average Federal Register cost estimate * 5 nonattainment deferred EAC Program areas = $146

• Large Subpart 1 nonattainment area 

o Average FTE resource estimate * 4 nonattainment deferred EAC Program areas = 0.72 to 25.2 o Average Federal Register action resource estimate * 4 nonattainment deferred EAC Program aro Average Federal Register pages resource estimate * 4 nonattainment deferred EAC Program aro Average Federal Register cost estimate * 4 nonattainment deferred EAC Program areas = $58,6
____________________________________________________________________________________ 

Step 7: Estimate the total EPA regional resources that would have been required had the 14 EAC Program arenonattainment areas as follows: 

•	 Total FTE resources: 11.5 to 44.2 = 9.5 (total for small Subpart 1 nonattainment areas) + 1.25 to 9.5 (t

nonattainment areas) + 0.72 to 25.2 (total large Subpart 1 nonattainment area); 

•	 Total Federal Register actions: 28 to 46 = 10 (total for small Subpart 1 nonattainment areas) + 10 to 20 

1 nonattainment areas) + 8 to 16 (total for large Subpart 1 nonattainment area); 

•	 Total Federal Register pages: 715 to 1,085 = 295 (total for small Subpart 1 nonattainment areas) + 300 

Subpart 1 nonattainment areas) + 120 to 140 (total for large Subpart 1 nonattainment area); and 

•	 Total Federal Register cost: $349,635 to $530,565 = $144,255 (total for small Subpart 1 nonattainment 

$317,850 (total for mid size Subpart 1 nonattainment areas) + $58,680 to 68,460 (total for large Subpar

Step 8: Estimate the total EPA headquarters resources that would have been required had the 14 EAC Program nonattainment areas as follows: 

•	 2.9 FTE per year to support SIP development (primarily responding to issues from Regions; does not i

policy and guidance), including Office of Air Quality Planning and Standards (2.5/year), Office of Tra(0.2/year) and Office of General Counsel (0.2/year); 

•	 Total FTE resources: 13.05 = 2.9 FTE per year * 4.5 years; and •	 No resources required for SIP area-specific Federal Register actions since those are all issued by the re

Step 9: Estimate the total EPA resources that would have been required had the 14 EAC Program areas been areas as follows: 

•	 Total FTE resources 24.5 to 57.2 = 13.05 (total headquarters FTE resources) + 11.5 to 44.2 (total regio•	 Total Federal Register actions 28 to 46 = 0 (total headquarters Federal Register actions) + 28 to 46 (tot

actions); 

•	 Total Federal Register pages 715 to 1,085 = 0 (total headquarters Federal Register pages) + 715 to 1,08

Register pages); and 

•	 Total Federal Register cost: $349,635 to $530,565 = $0 (total headquarters Federal Register cost) + $3

regional Federal Register cost). 
____________________________________________________________________________________ 

Step 10: Estimate the total EPA resources that were devoted to the EAC Program from the program’s start thryears; excluding this study): 

•	 Total FTE resources 23.8 = 7.174 (total headquarters FTE resources: OAQPS -- 6.244 FTE, OTAQ -- 0

+ 16.66 (total regional FTE resources: Region 3 -- 5 FTE; Region 4 – 1.36 FTE; Region 6 -- 3.6 FTE; 

•	 Total Federal Register actions 55 = 11 (total headquarters Federal Register actions: OAQPS -- 11 Fede

(total regional Federal Register actions: Region 3 -- 11 Federal Register actions; Region 4 -- 6 Federal -- 25 Federal Register actions; Region 8 -- 2 Federal Register actions); 

•	 Total Federal Register pages 561 = 326 (total headquarters Federal Register pages: OAQPS-- 326 page

regional Federal Register pages: Region 3 -- 136 pages; Region 4 -- 37 pages; Region 6 -- 45 pages; Re

•	 Total Federal Register Cost $274,329 = 561 pages * $489/page (Federal Register costs are assumed to 

or $489/page at 3 columns per page. This is to ensure that the comparison with EAC costs is on a cons
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

IMPORTANT NOTE: The subpart 1 and 2 requirements presented here are the requirements that EPA interprets as applying to the 14 EAhad they not become EAC Program areas but had instead become designated nonattainment areas under the CAA. The list below constituterequirements of the CAA. It should not be relied on for regulatory purposes but serves for historical information purposes only. In DecembAppeals for the DC Circuit issued an opinion that vacated EPA’s rule that placed certain 8-hr ozone nonattainment areas under subpart 1 of issued on August 29, 2007). All but one of the EAC areas had design values consistent with the marginal classification under subpart 2 had under subpart 2. Most of the subpart 1 requirements in the 3rd column of this table no longer apply to the areas that were originally placed u

developing rulemaking to address the requirements for the areas that were originally placed under subpart 1. Attainment Dates Attainment not later than December 31, 2007. Failure to attain by this date will result in 

the nonattainment designation becoming effective. But if an area failed to achieve milestones, including attaining the 8-hour ozone standard on or before December 31, 2007, the area will have been deemed in violation of the Compact and will have been subject to the full planning requirements under applicable CAA standard SIP processes including requirements defined as part of the EPA’s 8-hour implementation rulemaking. Such an area would have been subject to the same requirements and deadlines which would have been effective under the CAA and the EPA’s 8-hour designation rulemaking had it not participated in this program, with no preferential delays or exemptions from the EPA. 

Attainment is as expeditas practicable, but no lat5 years after nonattainmdesignation: June 15, 20(may extend up to 10 yebased on specified considerations) 

Reasonable Further Requirement 

None AAnnual incremental em

reductions@
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

Milestone Must include clearly measurable milestones for the development and implementation of Not required as such; Compliance the plan. Local areas will assess and report their progress against milestones in a regular, contingency measures Determination public process, at least every six months starting June 2003 and ending December 2007. 

Milestones will include, at a minimum: - Completion of emissions inventories and modeling; - Adoption of control strategies that demonstrate attainment; - Completion and adoption of the early action SIP revision; - Attainment not later than December 31, 2007; and - Post-attainment demonstration and plan updates. By June 30, 2006, compact areas must certify progress toward attainment since previous milestone, e. g., continued implementation and progress toward improvement in air quality and emissions reductions. 

supposed to be implemeupon failure to meet Reasonable Further Prog(RFP) 
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

Attainment Emission inventories will be used to develop SIP quality modeling episodes that perform Attainment demonstratiodemonstration within the EPA’s accepted margin of accuracy, including a base case and future case on required. EPA sets date 

submission or before December 31, 2007. Therefore, inventories must sufficiently account for 

projected future growth in ozone precursor emissions, particularly from stationary, nonroad, and on-road mobile sources. Local area must carefully document modeling approach, and work will be supported and reviewed by the state and concurrently reviewed by the EPA. Quantifiable emission reduction measures will be integrated into the future case to produce one or more control cases. These control cases will be used to indicate the relative effectiveness of different measures and aid in selecting appropriate measures. Prior to plan implementation the control strategies should be determined based on model results from a control case episode that shows achievement of the 8-hour ozone standard on or before December 31, 2007 through implementation of the control strategies. Communities will continue to develop other episodes as necessary to fully represent the variety of situations that typically contribute to ozone production in the area and to support the plan with the most current information and tools. Other episodes may also indicate necessary revisions to ensure that sufficient emission reduction measures are selected and implemented to continue to achieve target ozone concentration levels. By December 31, 2004, states must submit a SIP consisting of the local plan, including all adopted control measures that demonstrate attainment of the 8-hour ozone National Ambient Air Quality Standard (NAAQS) by December 31, 2007. 

can be no later than 3 yeafter designation (due Ju2007). 

Nonattainment New Source Review (NSR) and Reasonably Available Control Technology 

Not required. 100 tons per year (any n

SIP revision due June 15
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

(RACT) major source applicability Nonattainment NSR offsets 

Not required. New/modified source 

emissions must be offset least on a 1 to 1 basis (anrevision due June 15, 20

Nonattainment NSR permits 

Not required. Permits required (any SI

revision due June 15, 20

Reclassification to higher classification 

No reclassification requirement. NA 

RACT control for nitrogen oxides (NOx) 

Not required. None specified 

NOx control for 

NSR 

Not required. None specified 
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

Emission inventory Required using the most current tools available for at least one recent episode in order to 

support the early action plan. Emission inventories must include: - 1999 or later episode reflective of a typical ozone season exceedance that meets the EPA episode selection guidance to ensure that representative meteorological regimes are considered; - MOBILE6 data with link based Travel Demand Model mobile data in urban areas; - NONROAD model data adjusted for local equipment populations and usage rates; - Area source entered into database when possible on local survey data. Further episode inventories will also be developed over time to fully represent the variety of situations that typically contribute to ozone production in the area and to include the most recent developments. Emission inventories will be compared and analyzed for trends in emission sources over time. By December 31, 2004, states must submit a SIP consisting of the local plan, including all adopted control measures that demonstrate attainment of the 8-hour ozone NAAQS by December 31, 2007. 

Required in nonattainmearea; no express requiremfor updates or emission statements (due by June 2007) 

Reasonably Available Control Measures (RACM)/RACT 

Not required per se but, after all adopted federal and state or tribal controls that have been or will be implemented by the attainment date of December 31, 2007 are accounted for in the modeling, the local area will adopt additional local controls, as necessary, to demonstrate attainment of the 8-hour standard by December 31, 2007. As an initial matter, by June 16, 2003, the local area will identify and describe the local control measures that will be considered during the local planning process. The June 16, 2003 deadline for describing the control measures under consideration must be met to maintain eligibility in the program. While failure to list a measure at this stage would not preclude its adoption later, it is important to develop a reasonably complete initial list of measures. This will provide the public with clear information on the measures under consideration, will help ensure that interested parties are fully aware of the level of effort and local 

General requirement for RACM, including RACT by June 15, 2007)* 
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

commitment that is necessary, and will demonstrate that the local area is making progress toward meeting the critical March 31, 2004 deadline for adoption of local measures. The resulting local plan must be completed and submitted to the state or tribal leader by March 31, 2004 for inclusion in the SIP. The local plan shall include measures that are specific, quantified, and permanent, and that if approved by EPA, will be federally enforceable SIP revisions. The March 31, 2004 submission also will include specific implementation dates for the adopted local controls, as well as detailed documentation and reporting processes. Controls will be implemented as soon as practicable, but not later than December 31, 2005. Controls will be designed and implemented by the community with full stakeholder participation. All control measures will be incorporated by the state into the SIP and submitted to the EPA for review and approval. In the event that areas wish to add or substitute measures after SIP submittal, plan modifications will be treated as SIP revisions and facilitated by the state. By June 16, 2003, compact areas were required to identify/describe local control measures that are being considered during the planning process and the control measures must be met to maintain program eligibility. By March 31, 2004, the resulting local plan, including control measures, must be completed and submitted to the state by this date for inclusion in the SIP. By December 31, 2005, compact areas must implement the local control measures that have been incorporated into the SIP. 
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

Inspection and Not required. Nothing specified maintenance program Conformity (transportation and general) 

Not required. Required (also required 

subpart 2 areas) (conforapplies 1 year after the effective date of designatransportation conformitrequirements for metropareas must be in place bthen); conformity determinations for new papprovals that occur aftealso due 

Consequences of failure to attain 

See entry for “Reclassification to higher classification” EPA to specify additiona

requirements; up to 10 myears to attain 
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

Maintenance The plan must include a component to address emissions growth at least 5 years beyond December 31, 2007, ensuring that the area will remain in attainment of the 8-hour 

standard during that period. This future attainment maintenance analysis may employ one or more of the following or any other appropriate techniques necessary to make such a demonstration: - Modeling analysis showing ozone levels below the 8-hour standard in 2012; - An annual review of growth (especially mobile and stationary source) to ensure control measures and growth assumptions are adequate; - Identification and quantification of federal, state, and/or local measures indicating sufficient reductions to offset growth estimates. The plan must also detail a continuing planning process that includes modeling updates and modeling assumption verification (particularly growth assumptions). Modeling updates and planning processes must consider and evaluate: - all relevant actual new point sources; - impacts from potential new source growth; and - future transportation patterns and their impact on air quality in a manner that is consistent with the most current adopted Long Term Transportation Plan and most current trend and projections of local motor vehicle emissions. If the review of growth demonstrates that adopted control measures are inadequate to address growth in emissions, additional measures will be added to the plan. Local planning processes should prepare for this possibility. 

Requirement for maintenplans (with 2 consecutivyear demonstrations of maintenance) for areas requesting redesignation nonattainment to attainm

Contingency measures 

See entry for “Reclassification to higher classification” Required for failure to m

RFP or attainment 
____________________________________________________________________________________ 

Table B-32: Summary of Requirements for Nonattainment-Deferred EAC 8-Hour Ozone Areas Compa

Requirements for Clean Air Act (CAA) Subpart 1 and Subpart 2 Marginal 8-hour Ozone Nonatta

Element Early Action Compacts Subpart 1 Area Requirements 

Public Involvement Public involvement will be conducted in all stages of the planning and 

implementation process. Public education programs will be used to raise awareness regarding issues, opportunities for involvement in the planning process, implementation of control strategies, and any other issues important to the area. Interested stakeholders will be involved in the planning process as early as possible. Planning meetings will be open to the public, with posted meeting times and locations. Plan drafts will be publicly available, and the drafts process will have sufficient opportunities for comment from all interested stakeholders. Public comment on the proposed final plan will follow the normal SIP revision process as implemented by the state. Semi-annual reports detailing, at a minimum, progress toward milestones, will be publicly presented and publicly available. 

Required 

*EPA’s Phase 2 implementation rule had a two-tier approach for RACT for subpart 1 areas. If an area demonstrated a

after designation, the attainment demonstration was deemed to have met the RACT requirement (i.e., no separate reqor major source non-CTG RACT). If the area demonstrated attainment beyond 5 years after designation, then the arrequirements similar to a subpart 2 moderate area, which would have meant CTG RACT and major source non-CTG Circuit Court vacated our placing any area under subpart 1, so that provision of the rule is now on hold pending EPAaddresses the former subpart 1 areas. 

Sources: 

1.	 For EAC requirements: “Protocol For Early Action Compacts Designed To Achieve and Maintain the 8-Hour 

2002, http://www.epa.gov/ttn/naaqs/ozone/eac/20020619_eac_protocol.pdf. 

2.	 For subpart 1 and marginal area requirements: June 2, 2003 NPRM 68 Federal Register 32864. 
Appendix C: Approach for Calculating National (Federal) Measure Emission Redu

Introduction
 This appendix provides the approach for developing estimates of emission reductions from national (federal) mfor which quantitative information was compiled for this study, four areas quantified the emissions reductions federal measures that contributed to emission reductions towards attainment: Austin, Texas; Frederick Countyand San Antonio, Texas. One other area partially estimated emissions reductions from federal measures: Was(Hagerstown), Maryland. To provide as complete as possible an accounting of the federal emissions reductions, the study developed an estimates of the emission reductions from federal measures. The study performed the calculation for followinone area with partial federal measure estimates but excluding two areas that did not provide sufficient informaestimates and the four areas that developed their own estimates): Nonattainment-Deferred Areas 

• Berkeley and Jefferson Counties, West Virginia; • Chattanooga, Tennessee-Georgia; • Columbia, South Carolina (Central Midlands Area); • Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado; • Fayetteville, North Carolina (Cumberland County); • Greensboro-Winston Salem-High Point, North Carolina (Triad Area); • Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area); • Hickory-Morganton-Lenoir, North Carolina (Unifour Area); • Johnson City-Kingsport-Bristol, Tennessee; • Nashville, Tennessee; and • Washington County (Hagerstown), Maryland. 

Attainment Areas 

• Mountain Area of Western North Carolina (Asheville); • Oklahoma City, Oklahoma; and • Tulsa, Oklahoma, 
Three-Step Process 

Generally, the approach consisted of three steps: 

•	 Step 1: The first step is to calculate the difference in emissions in the base year (typically, a year betw

emissions in the 2007 control case. The emissions studied were the emissions that served as inputs into to demonstrate attainment. The number represents the total of state, local and federal emissions reductincreases resulting from population and industrial growth. Documentation for the emission inventory nthe state and federal technical support documents developed to support the EAC Program SIPs (http://www.epa.gov/ttn/naaqs/ozone/eac/index.htm#EAC_Main). 

•	 Step 2: Next, the emissions numbers in Tables B-5 to B-25, Appendix B for state and local measures t

modeled for each area were subtracted from the number derived in Step 1. For the one area with partianational measures, the emissions numbers subtracted from the number derived in Step 1 included emisbut not all, national measures. The resulting number for each area represents a reasonable estimate of federal measures in 13 of the 14 EAC areas. For the area with a partial estimate, the resulting number reasonable estimate of other emission reductions from federal measures. It is also important to note thnumbers for three areas derived in this step also include emission reductions from some state measuresGeorgia; Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado; and Nashville, Tennessee. 

•	 Step 3: Finally, a new “Federal Measures” (or “Other Federal Measures”) entry was created in each o

for the 14 areas to provide the number developed in Step 2. 

Step One: Calculating Overall Emission Reduction Number This table contains the calculations described in Step 1 above. The calculations are based on emissions informstates’ EAC SIP submittals. 

EAC Areas Total Modeled NOx 

Reductions in Tons/Day from 

Base Year to 2007 

Total Modeled VOC 

Reductions in Tons/Day from 

Base Year to 2007 

Nonattainment-Deferred EAC Program Areas Berkeley and Jefferson Counties, West Virginia 

1.9 0.4 

Chattanooga, Tennessee-Georgia 27.43 26.9 Columbia, South Carolina (Central Midlands Area) 

72 24.6 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 

59 106.3 

Fayetteville, North Carolina (Cumberland County) 

10.2 7.8 
EAC Areas Total Modeled NOx 

Reductions in Tons/Day from 

Base Year to 2007 

Total Modeled VOC 

Reductions in Tons/Day from 

Base Year to 2007 

Frederick County, Virginia N/A N/A Greensboro-Winston Salem-High Point, North Carolina (Triad Area)1 

405.6 43.8 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 

67.2 41.8 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area)2 

138.9 13.4 

Johnson City-Kingsport-Bristol, Tennessee 

12.63 20.74 

Nashville, Tennessee 51.62 43.76 Roanoke, Virginia N/A N/A San Antonio, Texas N/A N/A Washington County (Hagerstown), Maryland 

5.54 1.85 

Attainment EAC Program Areas Austin, Texas N/A N/A Berkeley-Charleston-Dorchester, South Carolina 

N/A N/A 

Mountain Area of Western North Carolina (Asheville) 

48.4 7.1 

Oklahoma City, Oklahoma 24.2 5.3 Lower Savannah-Augusta, South Carolina-Georgia 

N/A N/A 

Tulsa, Oklahoma 58.6 10.9 

1 The Greensboro estimate includes substantial NOx reductions from a local electric generating unit. 2 The Hickory estimate includes NOx reductions from a local electric generating unit. 
Steps Two and Three: Deriving an Estimate of Emission Reductions from Federal Measures and Creat

Appendix B Tables This table indicates which types of measures that were quantified and modeled were subtracted from the numbderive an estimate of emission reductions from federal measures. It also indicates whether federal measures exin the Appendix B table or whether specific federal measures are listed. 

EAC Areas Calculation to Create “Federal Measure” Entry 

in Appendix B Tables 

Nonattainment-Deferred EAC Program Areas Berkeley and Jefferson Counties, West Virginia 

For this area, the state of West Virginia modeled only national measures. The SIP did not provide any specific estimates for individual state and national measures. Therefore, Table B-5 contains an entry for national measures that is the number in Step 1 above. 

Chattanooga, Tennessee-Georgia Tennessee modeled state and national control measures, as well as 

several local measures. The Table B-6 contains an entry for national measures that was calculated by subtracting estimates for the modeled state and local measures contained in Table B-6 from the number in Step 1 above. The Chattanooga reduction estimate also includes estimates of the VOC emission reductions attributed to implementation of the statewide VOC reductions rule. 

Columbia, South Carolina (Central Midlands Area) 

South Carolina modeled only federal control measures. Table B-7 contains an entry for national measures that is the number in Step 1 above. 

Denver-Boulder-Greeley-Fort Colorado modeled state and national control measures. The Table Collins-Loveland, Colorado B-8 contains an entry that includes national measures that was 

calculated by subtracting estimates for the modeled state measures contained in Table B-8 from the number in Step 1 above. The Denver reduction estimate for federal measures also includes estimates of the NOx and VOC emission reductions attributed to 

implementation of the state's motor vehicle I/M program.3 

3 The estimates of the NOx and VOC emission reductions attributed to implementation of the state's motor vehicle I/M program are e

emissions modeling work. The MOBILE6.2 model is used to project emission reductions from vehicle fleets from Federal tailpipe returnover with newer, less-polluting vehicles replacing older vehicles. When states run the MOBILE6.2 model, flags can be tripped iI/M program being implemented for that year. The MOBILE6.2 model then uses all these data inputs to calculate predicted future yfrom a 2002 fleet to a 2007 fleet). 
EAC Areas Calculation to Create “Federal Measure” Entry 

in Appendix B Tables 

Fayetteville, North Carolina (Cumberland County) 

North Carolina modeled state and national control measures. The Table B-9 contains an entry for national measures that was calculated by subtracting estimates for the modeled state measures contained in Table B-9 from the number in Step 1 above. 

Frederick County, Virginia Table B-10 contains estimates the state provided of emissions 

reductions from federal measures. 

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 

North Carolina modeled state and national control measures, as well as a local measure. The Table B-11 contains an entry for national measures that was calculated by subtracting estimates for the modeled state and local measures contained in Table B-11 from the number in Step 1 above. 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 

South Carolina modeled only federal control measures. Table B-12 contains an entry for national measures that is the number in Step 1 above. 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 

North Carolina modeled state and national control measures. The Table B-13 contains an entry for national measures that was calculated by subtracting estimates for the modeled state measures contained in Table B-13 from the number in Step 1 above. 

Johnson City-Kingsport-Bristol, Tennessee 

Tennessee modeled state and national control measures, as well as a local measure. The Table B-14 contains an entry for national measures that was calculated by subtracting estimates for the modeled state and local measures contained in Table B-14 from the number in Step 1 above. 

Nashville, Tennessee Tennessee modeled state and national control measures, as well as a 

local measure. The Table B-15 contains an entry for national measures that was calculated by subtracting estimates for the modeled state and local measures contained in Table B-15 from the number in Step 1 above. The Chattanooga reduction estimate also includes estimates of the VOC emission reductions attributed to implementation of the statewide VOC reductions rule. 

Roanoke, Virginia Table B-16 contains estimates the state provided of emissions 

reductions from federal measures. 

San Antonio, Texas Table B-17 contains estimates the state provided of emissions 

reductions from federal measures. 

Washington County (Hagerstown), Maryland 

Maryland modeled state and national control measures. The Table B-18 contains an entry for other national measures that was calculated by subtracting estimates for the state and national measures contained in Table B-18 from the number in Step 1 above. 
EAC Areas Calculation to Create “Federal Measure” Entry 

in Appendix B Tables 

Attainment EAC Program Areas Austin, Texas Table B-19 contains estimates that the state provided of emissions 

reductions from federal measures as a whole. 

Berkeley-Charleston-Dorchester, South Carolina 

N/A 

Mountain Area of Western North Carolina (Asheville) 

North Carolina modeled state and national control measures. The Table B-21 contains an entry for national measures that was calculated by subtracting estimates for the modeled state measures contained in Table B-21 from the number in Step 1 above. 

Oklahoma City, Oklahoma Oklahoma modeled local and national control measures. The Table 

B-22 contains an entry for national measures that was calculated by subtracting the estimate for the modeled local measure contained in Table B-22 from the number in Step 1 above. 

Lower Savannah-Augusta, South Carolina-Georgia 

N/A 

Tulsa, Oklahoma Oklahoma modeled local and national control measures. The Table 

B-24 contains an entry for national measures that was calculated by subtracting the estimate for the modeled local measure contained in Table B-24 from the number in Step 1 above. 
Appendix D: Brief Profile of the 14 Nonattainment-Deferred Areas and Six Attainment EAC
 

Program Areas Included in this Study 

14 Nonattainment-Deferred Areas: 

Berkeley and Jefferson Counties, West Virginia 

The Eastern Panhandle Region Early Action Compact (EAC) Program Area in West Virginia includes 

both Berkeley and Jefferson Counties. Both counties are relatively rural in character. Berkeley County 

covers 321 square miles and includes the City of Martinsburg, a city of roughly 15,000 people. The 

entire population of Berkeley County is approximately 76,000. Jefferson County is smaller, covering 

212.4 square miles with a population of approximately 42,190. The three largest towns in Jefferson 

County are Charles Town (2,907), Ranson (2,951) and Bolivar (1,045). Historically, there had been 

little reason to site an air pollution monitor in the area due to its relatively low population and largely 

rural nature. More recently, growth in Berkeley and Jefferson Counties has largely been residential in 

character with few new large air pollution sources. Nevertheless, an ozone monitor was set up in 

Martinsburg, West Virginia that began operating in 2000 with complete quality assured ozone season 

data becoming available starting in 2001. 

Chattanooga, Tennessee-Georgia 

The Chattanooga, Tennessee-Georgia EAC Program Area is located on the southeastern side of 

Tennessee at the Tennessee-Georgia border. It consists of the unclassifiable/attainment counties of 

Marion County, Tennessee and Walker County, Georgia and the nonattainment-deferred counties of 

Hamilton and Meigs County, Tennessee and Catoosa County, Georgia. The population of the area is 

372,264. 

Columbia, South Carolina (Central Midlands Area) 

The Columbia EAC Program Area consists of two nonattainment-deferred counties, Richland and 

Lexington and two unclassifiable/attainment counties, Newberry and Fairfield. It is located in the 

center of the state surrounding the City of Columbia, the capitol of South Carolina. The population is 

494,518. 

Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado 

The Denver-Boulder-Greeley-Fort Collins-Loveland, Colorado EAC area is located on the plains 

directly adjacent and east of the Front Range Mountains of the Colorado section of the Rocky 

Mountains. Metro-Denver is located in a slight depression area or shallow bowl (at 5,280 feet) with 

slightly rolling prairie areas to the north, east, and south. At the southern extend, a ridge called the 

Palmer Divide extends perpendicular to the Front Range and to the west of the entire area are the 

foothills (typically 9,000 feet) of the Front Range Mountains. The population of the Denver-BoulderGreeley-Fort Collins-Loveland, Colorado area is approximately 2.5 million and contains the major 

cities of Denver, Aurora, Fort Collins, Boulder, Longmont, Loveland, Golden, and Greeley. 

Fayetteville, North Carolina (Cumberland County) 

The Fayetteville EAC Program Area consists of Cumberland County and is located in southeastern 

North Carolina. Cumberland County was nonattainment-deferred. It is a mixture of urban and rural 

lands. The 2000 census population for Cumberland County was 302,963, some of which is rural -­

20,540 -- and most of which lies within the Urbanized Area Boundary -- 282,423. Population density is 

also varied. Because of the difference in land use and densities, care was exercised when proposing and 

75 
selecting strategies to be implemented by such diverse jurisdictions. The Cantonment Area of Fort 

Bragg Military Reservation and Pope Air Force Base are also located within Cumberland County. 

Frederick County, Virginia 

The Northern Shenandoah Valley EAC Area consists of the City of Winchester and Frederick County 

and is located in the Valley and Ridge Region of Virginia that includes the Northern Shenandoah 

Valley and the Appalachian Ridge. The major urban center of the area is the City of Winchester that is 

surrounded by the suburban/rural Frederick County. Much of the western portion of Frederick County 

is mountainous and forested rural area associated with the Appalachian Ridge. The majority of the 

area’s population (82,794 in 2000) and industry is centered in and around Winchester, Virginia. The 

area’s monitor is located in Northeastern Frederick County just south of the West Virginia border. 

Greensboro-Winston Salem-High Point, North Carolina (Triad Area) 

The Triad EAC Program Area is located in the northern central portion of North Carolina. The 

nonattainment-deferred counties in the EAC Program Area were Rockingham, Caswell, Forsyth, 

Guilford, Alamance, Davie, Davidson and Randolph. The unclassifiable/attainment counties in the 

EAC Program Area were Surry, Yadkin and Stokes. Population of the Triad EAC Program Area is 

1,285,879. 

Greenville-Spartanburg-Anderson, South Carolina (Appalachian Area) 

The Appalachian (Greenville-Spartanburg-Anderson), North Carolina EAC Program Area is in the 

northwest section of South Carolina. It consists of the nonattainment-deferred counties of Spartanburg, 

Greenville and Anderson and the unclassifiable/attainment counties of Cherokee, Pickens and Oconee. 

The larger cities in the area include Greenville and Spartanburg. The population of the Appalachian 

EAC Program Area is 310,000. 

Hickory-Morganton-Lenoir, North Carolina (Unifour Area) 

The Unifour area includes Alexander, Burke, Caldwell, and Catawba Counties. All of these counties 

were nonattainment-deferred. It is located in the central eastern portion of the state. The population for 

the EAC Program Area is 1,300,000. The City of Hickory noted a period of unprecedented growth in 

the 1990s. This was accompanied by an increased reliance on non-public transportation. The increase 

in vehicles miles traveled that resulted contributed to such challenges as congestion and air pollution. 

Thus, beginning in the summer of 1998, the City of Hickory has been very active in trying to reduce air 

pollution in the Unifour area. Caldwell County and Catawba County have been very active as well. 

There are two ozone monitors in Unifour EAC Program Area. One is located in Lenoir, Caldwell 

County and the other in Taylorsville, Alexander County. 

Johnson City-Kingsport-Bristol, Tennessee 

The Johnson City-Kingsport-Bristol, Tennessee EAC Program Area is located in the far Northeast 

corner of the state. It consists of two nonattainment-deferred counties, Sullivan and Hawkins and four 

unclassifiable/attainment counties, Washington, Unicoi, Carter and Johnson. The population of the area 

is 207,000. Hawkins and Sullivan Counties are located in the ridge and valley section of the East 

Grand Division of the state bordering Virginia. 

Nashville, Tennessee 

The Nashville, Tennessee EAC Program Area is located in the north central portion of the state and 

consists of eight counties. Five of the counties are nonattainment-deferred. These include Davidson, 

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Rutherford, Williamson, Wilson and Sumner Counties. The attainment counties are Robertson, 

Cheathan and Dickson Counties. The population of the area is 1,098,000. 

Roanoke, Virginia 

The Roanoke EAC Program Area is located within the Blue Ridge Mountain area of Virginia and has 

typical topographic characteristics of such a mountain and valley area. The major urbanized center area 

is located in a valley and made up of the Cities of Roanoke and Salem, along with the Town of Vinton, 

where the ozone monitor for the area is located. The more suburban and rural Roanoke County, with 

Botetourt, surrounds this core urban area to the North. The major commercial transportation corridor of 

Interstate 81 runs through the entire area from north to south, which is just to the west of the urban core. 

A significant portion of Northwestern Botetourt County is rural and part of the Jefferson National 

Forest. 

The total land area of the Roanoke EAC Program Area is 851 square miles. According to the 2000 

Census, the population was 235, 932, with a population density of 277 per square mile. The projected 

population growth in the Roanoke Area by expected by 2010 is 244,499 persons. 

San Antonio, Texas 

San Antonio is located in south central Texas, SSW of Austin. The San Antonio EAC Program Area 

consisted of four counties -- Bexar, Comal, Guadalupe and Wilson – with a population of 1,559,975 in 

2000. The area has always been in attainment with the 1-hour ozone standard, but was not consistently 

able to maintain the 8-hr standard. In 2004, the San Antonio area was designated as nonattainment for 

the 8-hr ozone standard, but achieved the standard in 2007. The Alamo Area Council of Governments 

was the local lead for the EAC. 

Washington County (Hagerstown), Maryland 

Washington County is located in west-central Maryland, bounded by Pennsylvania, Virginia, and West 

Virginia. The county extends east to South Mountain, south to the merging of the Shenandoah and 

Potomac Rivers, north to the Pennsylvania border, and west to Sideling Hill Creek. It is bordered by 

the Appalachian Highlands, and situated at the center of the Cumberland Valley with low rolling hills, 

cultivated valleys, woodlands, and moderate elevations of 500-800 feet above sea level. Hagerstown, 

the county seat, is located in the center of the county and approximately 75 miles west of Washington, 

DC, and Baltimore. 

Washington County enjoys a high employment rate and moderate incomes, with a lower cost of living 

than nearby metropolitan areas. According to the 2000 Census and the Maryland Department of Labor, 

Washington County had a population of 131,923 people, as well as 49,726 households and a workforce 

of 70,857 people. Projected population growth in Washington County is expected to increase from the 

2000 levels, but not at the same rate from 1990 to 2000. The total land area in the county is 485 square 

miles. The population density is relatively small compared to the counties in the Baltimore and 

Washington, DC areas, which have a population density over 1,000 people per square mile. 

Six Attainment EAC Program Areas: 

Austin, Texas 

Austin is located in south central Texas, NNE of San Antonio. The Austin EAC Program Area 

consisted of five counties – Bastrop, Caldwell, Hays, Travis and Williamson – with a population of 

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1,249,763 in 2000. The area has always been in attainment with the 1-hour ozone standard, but was not 

consistently able to maintain the 8-hr standard. 

Berkeley-Charleston-Dorchester, South Carolina 

The Berkeley-Charleston-Dorchester, South Carolina EAC Program Area consists of Dorchester, 

Berkeley and Charleston Counties. It is located around the Charleston area on and around the Atlantic 

Coast. Charleston is the largest city in the area. The ozone monitor is located in Berkeley County. 

Mountain Area of Western North Carolina (Asheville) 

The Mountain Area Compact is a diverse region of five Western North Carolina counties comprising 

more than 2400 square miles. According to 2002 estimates, County populations range from 212,907 in 

Buncombe to 20,192 in Madison. Henderson (93,033), Haywood (55,299) and Transylvania (29,997) 

fall within those extremes. Population density, total workforce and infrastructure development exhibit 

similar county-to-county variation. Services and retail trade are strong factors in each local economy, 

reflecting the area’s popularity for retirement living and for travel and tourism. All of the Mountain 

Area EAC counties were designated unclassifiable/attainment. 

Oklahoma City, Oklahoma 

Oklahoma City is located in central Oklahoma. The Oklahoma City or Central Oklahoma EAC 

Program Area consisted of seven counties: Canadian, Cleveland, Grady, Lincoln, Logan, McClain, and 

Oklahoma. In 2000 the area had a population of 1,083,346. The area has always been in attainment 

with the 1-hour ozone standard, but was not consistently able to maintain the 8-hr standard. 

Lower Savannah-Augusta, South Carolina-Georgia 

The Lower Savannah-Augusta, South Carolina-Georgia EAC Program Area is located in the southern 

central portion of South Carolina just south and west of Columbia. The area includes the AikenAugusta Area. The EAC Program Area consists of Aiken, Orangeburg, Barnwell, Calhoun, Allendale 

and Bamberg Counties in South Carolina and Richmond and Columbia Counties in Georgia. There are 

monitors each located in Barnwell and Aiken Counties in South Carolina. There are also ozone 

monitors in Richmond and Columbia Counties in Georgia. 

Tulsa, Oklahoma 

Tulsa is located in northwestern Oklahoma. The Tulsa EAC Program Area consisted of five counties: 

Tulsa county and portions of Creek, Osage, Rogers, and Wagoner. In 2000 the area had a population of 

803,235. The area has been in attainment with the 1-hour standard, but has not consistently maintained 

the 8-hr standard. 

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Appendix E: Summary of Discussions with State and Local Agencies
 

This appendix contains a complete summary of the discussions held with state and local officials as part 

of this study. It is organized into two parts. The first part contains the discussions held with state and 

local officials involved in the Early Action Compact (EAC) Program. The second part contains the 

discussions held with state and local officials with respect to the traditional State Implementation Plan 

(SIP) program. Each part is organized by study question with the responses under headings for each 

respondent. 

EAC PROGRAM AREA DISCUSSIONS 

1)	 Is the EAC model a more efficient way to deliver clean air to citizens in these areas (versus the 

traditional nonattainment designation approach)? If so, how? If not, why? 

STATE ENVIRONMENTAL AGENCIES 

Colorado Department of Public Health and Environment (CDPHE) 

The CDPHE believed that the EAC was a good program. By not having to address standard 

nonattainment requirements, the EAC Program made it easier to bring industry and other parties into 

the stakeholder process. The program design worked well for the CDPHE. It contained good 

incentives to succeed. First, Denver had the motivation to sign up for and implement the program in 

order to gain relief from the Transportation Conformity and Nonattainment New Source Review (NSR) 

Program requirements. Second, Denver had the flexibility to pick and choose control measures. 

Although Denver fell short of its goal and violated the standard at one monitor, the controls helped the 

city offset significant growth. 

Georgia DNR Department of Natural Resources (Georgia DNR) 

Georgia DNR believed that the EAC Program is more efficient for areas that are very close to the 

standard. Areas that are well above the standard, such as Atlanta, are not appropriate to participate in 

the program. The EAC helps states by deferring the Nonattainment NSR and Transportation 

Conformity Program requirements. States do not have to use as many resources on areas that do not 

need to meet these requirements. The EAC Program in Georgia did not go well but the state learned 

how to work with similar programs. 

Louisiana Department of Environmental Quality (LDEQ) 

LDEQ stated that the EAC Program is a more efficient approach. The state considered it important to 

avoid nonattainment status because of the resources needed to meet the requirements of the 

Nonattainment NSR and Conformity Programs. In addition, Louisiana DEQ believed that the EAC 

approach required a little less outreach than needed for the traditional approach. 

Maryland DNR Department of Natural Resources (MDDNR) 

MDDNR believed that the EAC approach is a more efficient method for areas that are relatively close 

to the standard. In these situations, a few local measures, coupled with state, regional, and national 

programs, are all that is needed to bring the area into attainment. The EAC Program is not the right 

model for areas further from the standard that need more measures to reach attainment. 

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New Mexico Environment Department (NMED) 

The EAC approach has some advantages over the traditional approach. The EAC approach is more 

collaborative. The San Juan County EAC enjoyed wide stakeholder representation, including the oil 

and gas industry, utilities, and local governments. The EAC Program was much better received than a 

nonattainment designation would have been by stakeholders. The process produced a healthy, 

productive dialogue among stakeholders. It also provided them with an opportunity for networking and 

an understanding of the challenges facing the area. 

North Carolina Department of Environment and Natural Resources (NCDENR) 

NCDENR found it difficult to say which approach is more efficient. It is possible that the EAC 

Program areas reached attainment earlier than they would have otherwise. The EAC Programs were 

proactive in fostering partnerships. This led to new ideas, local ownership, and may have resulted in 

greater efficiency. Overall, the EAC generated a more positive working situation between the state and 

participating areas than would have occurred under the traditional approach. 

In the North Carolina EAC Program areas, local stakeholders appeared to be willing to do anything 

feasible to obtain better air quality. As awareness of the issue increased, local governments and 

business looked for more things to do to improve air quality. Businesses in the EAC Program areas 

were willing to participate in the idle reduction strategy. Local stakeholders stepped forward to become 

part of the effort to reach a common goal. 

Awareness of air quality issues, and local activity, was greater in EAC Program areas than in other 

areas of state where the state did not place as much emphasis on local measures. Without the EAC 

approach, the areas participating in the program most likely would not have implemented so many 

activities, due primarily to the fact that the EAC Program areas were projected to attain with federal and 

state measures alone. 

Oklahoma Department of Environmental Quality (OKDEQ) 

Oklahoma DEQ believed the EAC was more efficient. The EAC Program provided an incentive for 

Tulsa and Oklahoma City to proactively address air quality issues earlier than they would have 

otherwise. The threat of receiving a nonattainment designation was a critical factor in their decisions. 

South Carolina Department of Health and Environmental Control (South Carolina DHEC) 

The EAC Program was more efficient because it obtained cleaner air sooner than would have otherwise 

occurred. The EAC Program made more sense than the traditional route for areas that were close to the 

standard. The education that occurred in these areas was extremely important. Stakeholders realized 

that the decisions they make everyday have an impact on air quality. 

In addition, local stakeholders would not have been as involved without the EAC Program. The 

traditional method creates more of an adversarial relationship. The EAC Program created better 

relationships with all parties involved in the process. Through the EAC Program, the state established 

better working relationships with local governments than they ever had in the past. 

Tennessee Department of Environment and Conservation (TDEC) 

The EAC is more efficient. The traditional approach creates a lot of resentment. Under the traditional 

approach, the Tennessee DEC becomes an extension of EPA. As a result, the state bears criticism for 

administering the mandatory measures required under nonattainment designation. In addition, localities 

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are not inclined to make an effort to improve air quality if they think that the area will be designated 

nonattainment anyway. The areas are not motivated to do anything locally. 

During the EAC, the state created partnerships with stakeholders that it never would have had to 

otherwise. Transportation conformity is supposed to drive conversations with localities. Importantly, 

however, the EAC Program attracted the attention and involvement of local elected officials. At the 

local level, action starts to happen when local elected officials become involved in an issue. 

In addition, the EAC changed the dynamic of addressing air quality issues. Citizens and industry 

become involved voluntarily in the program. By getting involved, citizens develop ownership of the air 

quality in their community. This offers the public an opportunity to solve a problem with “good old 

American knowledge and hard work”. It gives people hope that they can do something about the 

quality of life in their area. That is very important. Public involvement also brings about changes in 

personal lifestyles to keep the air clean. In addition, the public also develops a better understanding of 

the connection between air quality and health during air quality action days. 

At first, all of the areas in Tennessee tried to get into the EAC Program. The prospect of becoming an 

EAC Program had everyone working hard initially. Knoxville and Memphis did not become EAC 

Program areas but they still moved forward with measures. For example, both locations lowered the 

speed limits in their counties. 

Tennessee will see a lot of Code Orange days with the new standard. The state will draw upon the EAC 

coalitions to continue their work to address the new standard. 

Texas Commission on Environmental Quality (TCEQ) 

It depends on the circumstances. The EAC Program is not necessarily more efficient than the 

traditional method. 

Virginia Department of Environmental Quality (VADEQ) 

The EAC was more efficient and a less burdensome process. Because they had never been out of 

compliance, the two areas in Virginia were new to air quality issues. The EAC process allowed them to 

design a plan to address their problems without getting bogged down in the requirements of 

nonattainment areas. Both areas felt they had more control through the EAC process. 

There were some initial problems as the state educated local elected officials and others on the need to 

address air quality. Once the process was underway, the participants developed a plan rather quickly. 

Virginia felt that the local areas were much more involved in EAC Program areas than they would have 

been otherwise. 

The EAC Program reduces demand on state resources but increases demand for local resources. If the 

areas had not been in attainment, however, local officials and the Virginia DEQ and the Virginia 

Department of Transportation would have had to do more work to meet the Conformity and 

Nonattainment NSR Program requirements. Neither community would have been able to meet 

conformity standards without assistance 

81 
West Virginia DEP 

It partly depends on what an area has to do in the program. Local measures may be more efficient in 

concept but will not work if local stakeholders are not engaged in the process. It really depends on a 

case-by-case basis. 

West Virginia is a small state with large power plants and the remnants of a manufacturing base. 

Berkeley and Jefferson Counties were likely to come into attainment through national and regional 

measures alone. The EAC addressed maintenance in the area until 2012. A traditional SIP would have 

addressed maintenance in the area until 2018. Due to high growth in Berkeley and Jefferson Counties, 

the area was perhaps better suited to the EAC concept that encouraged the incorporation of local 

measures to address growth. 

LOCAL GOVERNMENT AGENCIES 

Capital Area Metropolitan Planning Organization (CAMPO, Austin, Texas) 

CAMPO (Austin, Texas) could not definitively answer whether the EAC is more efficient because it 

had never participated in the traditional approach. But, the EAC Program did speed up the timing of 

emissions reductions. It normally takes five years (from nonattainment designation to SIP submittal) to 

get emissions reductions. The desire of EAC participants to clean up the air as quickly as possible did 

generate quicker results. The program’s flexibility and a desire to avoid nonattainment lead to a greater 

local investment in air quality issues. 

Chattanooga-Hamilton County APCD Air Pollution Control Board (CHCAPCD) 

The EAC model is more efficient. The EAC Program generated local support by pointing out that 

Chattanooga would receive clean air sooner by participating in the voluntary program. If the area had 

gone through the traditional approach, the response from stakeholders would not have been as positive. 

For example, the area volunteered to do an inspection and maintenance program. The program has 

been successful. Not everyone likes the program but stakeholders accept it. If EPA had proposed the 

inspection and maintenance program, however, there would have been more opposition from the 

community. In general, the community needs jobs and economic growth. So, it made a difference not 

having to address the Nonattainment NSR Program with economic development prospects. Due in part 

to the early action compact and its success, Volkswagen selected the Chattanooga area in July 2008 as 

the site for its new U.S. manufacturing facility and headquarters. 

Denver Regional Air Quality Council (RAQC) 

The EAC is generally more efficient than the traditional approach. Deferral of a nonattainment 

designation provided an incentive for Denver to do things much sooner than it would have through the 

traditional approach. In that sense, the EAC Program achieved its desired result. By requiring a SIP, 

however, the process is still pretty inflexible. It is not much more flexible than the traditional process. 

If Denver had taken the traditional route, the area would have been designated as “marginal” 

nonattainment. The City would have had to conduct an inventory but the not air quality modeling that 

the EAC Program required. This would have required a rather minimal paperwork exercise. No new 

measures would have been required. 

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Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The EAC process is more efficient and equitable than the traditional process. Although some 

regulatory requirements were non-negotiable, Frederick County had more influence in deciding how 

and what to control throughout the program. The traditional approach would not have recognized the 

measures already undertaken by point sources in the area. 

Greenville County, South Carolina Government 

The EAC is a very valuable tool. The main value of the program is that it lets local areas come into 

compliance through their own methods. This approach works better than EPA telling an area to do 

specific measures. Although the command and control method may have achieved the same results, it 

certainly would not have created the same dynamic and strong partnerships at the local level. 

The traditional approach would have generated resistance from industry. Under this approach, 

Greenville County would have been repeating EPA requirements. The EAC process brought in 

stakeholders from the planning sector, chamber of commerce, business, local governments (three 

counties in Upstate South Carolina), and industry. Government did not tell private or nonprofit entities 

what to do to improve air quality. Instead, the EAC Program enabled a consensus-based approach that 

encouraged sharing the expertise, thoughts, and ideas of all stakeholders. This approach allowed 

stakeholders to develop and implement their own strategies. 

The EAC Program did not take less effort by Greenville County. Because the County would have 

encountered resistance from the private sector if it had gone through traditional approach, the EAC 

Program was more efficient from that standpoint. 

Aiken County, South Carolina Government (Lower Savannah) 

Initially, the EAC Program was better than the nonattainment route. Public participation was good at 

the first set of meetings. For example, thirty or forty people came to the meetings when the Lower 

Savannah area first started the program. But, attendance dropped off after the area produced three years 

of clean air quality data. Local governments had the perception that the problem had been solved. 

Representatives of small municipalities, Aiken County public schools, public works, and other public 

entities stopped coming to the meetings. However, representatives of large companies kept 

participating. 

Georgia and South Carolina handled their own portions of the EAC Program Area. In general, more 

proactive measures were conducted to improve air quality through the EAC Program. 

ACOG (Oklahoma City) 

The EAC was a more efficient model for Oklahoma City. The program provided an opportunity to get 

the message out and capture the attention of local stakeholders. People paid attention to the issue 

because it involved a tangible situation. No one would have listened otherwise. 

Piedmont Triad Council of Governments (PTCOG) 

The EAC Program was definitely more efficient than the traditional approach. The EPA set the 

standard that participants had to meet. The program required accountability and local government 

commitment from participating areas. In return, EPA provided participants with the flexibility to 

develop local strategies without having to do a lot of peripheral activities. 

83 
Washington County Government 

The EAC is not more or less efficient than the traditional approach. But, the approach made the EAC 

Program effective. It provided participants with a “gentle” introduction to air quality issues. This 

allowed the state time to educate local officials. Washington County had the opportunity to become 

more engaged in the program. The County also had the opportunity to educate the public about air 

quality issues. Citizens also became aware they could play a role in improving air quality. 

a) What has been the impact of EACs on State and local resources? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

It is difficult to quantify the resource impact of the program. The Colorado DPHE saved money and 

staff time in the EAC planning process. The state did not have to involve all stakeholders in the 

process. For example, the EAC reduced the number of meetings because the state only had to address 

affected industry groups. It did not have to work with all industries located in the area. The EAC 

Program also reduced travel time by the state. However, the state still had to develop and meet all 

requirements of a SIP. 

Georgia DNR 

Local stakeholders spent more resources in the EAC Program than they would have in the traditional 

program. This is because local stakeholders would not have been as involved in the traditional method. 

Under the traditional approach, industry would pretty much have been the only stakeholder involved in 

the process. 

Louisiana DEQ 

Participation by the Mayor’s office in Shreveport and local government made the EAC process a lot 

easier. 

Maryland DNR 

For Maryland DNR’s response to this question, see question 1.b. below. 

New Mexico ED 

The state expended a little less resources for the EAC compared to what it would have under the 

traditional approach. It is difficult to estimate the impact on local areas. 

North Carolina DENR 

More state and local resources were expended in the participating areas than would have been used 

without the EAC Program. But, it has been a positive investment. Local measures will become even 

more critical with the upcoming standard. The EAC is a good model to follow. 

Oklahoma DEQ 

The use of state resources in an EAC Program is more intensive up front than it would be with a waitand-see approach. The state provided technical support to the EAC Program areas. The council of 

governments managed the local programs. The outreach activities included many meetings to engage 

stakeholders and to develop advertising campaigns that involved public service announcements (PSAs). 

84 
In the long run, however, participation in the EAC may save resources by avoiding nonattainment 

designation. Participation is certainly worth the “insurance” policy that areas receive by avoiding 

nonattainment status. 

South Carolina DHEC 

It is not clear whether more state resources were used in the EAC Program than would have been 

expended in a traditional approach. In a traditional nonattainment area, more people are involved in 

“bureaucratic exercises” dealing with the Transportation Conformity and Nonattainment NSR 

Programs. Conversely, in EAC Program areas, the resources are used more efficiently on implementing 

“air quality improvement efforts”. 

Tennessee DEC 

It took the state a lot of time to convince areas to participate in the EAC Program. The resources 

expended in the EAC Program have been a worthwhile investment. Results are always greater when 

local areas embrace a program. 

Texas CEQ 

Even though awareness was already raised in Texas’ EAC Program areas, state resources were still 

required as there was a lot of back and forth time spent with the local EAC participants and EPA on 

several issues. 

Virginia DEQ 

In general, the EAC process reduced the amount of resources required by the state to address air quality 

in the participating areas. There were fewer resource and administrative requirements such as the 

conformity process, nonattainment permits, and offset requirements. 

At the local level, it is likely that slightly more resources were required to set up local programs, 

websites, and provide outreach. But, the state believes that both EAC Program areas saw this as a 

worthwhile investment. 

West Virginia Department of Environmental Protection (West Virginia DEP) 

For West Virginia DEP’s response to this question, see question 1.b. below. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

A regional committee of local and regional governmental entity staff handled the planning work for the 

EAC Program. The state contributed by passing legislation that funds air quality planning and 

implementation in near nonattainment areas in Texas and adopting several state rules that reduced 

emissions in the Austin area. 

Chattanooga-Hamilton County APCD 

The EAC activities did raise public awareness in Chattanooga-Hamilton County APCD more than 

would have occurred under the traditional approach. This required more local resources than would 

have been used in the traditional approach. For example, Chattanooga-Hamilton County APCD 

decided to claim credit for its voluntary action day program. The County now regrets this decision. It 

spent a “huge” amount of money (between $30,000 to 35,000 per year) to meet EPA requirements for 

85 
documenting the effectiveness of the program. The County had to conduct random telephone sampling 

to estimate participation and associated emissions reductions. This resulted in a lot of effort and 

expenditure for an insignificant environmental benefit. The County would not seek to claim credit for 

such activities again. The county, instead, now puts the same amount of money into other actions, such 

as radio and television advertisements. 

Greenville County, South Carolina Government 

The EAC approach made more resources available to Greenville County than would have been 

available through the traditional approach. Local stakeholders stepped up, took ownership of the 

program, and tried to implement control measures. For example, the Sierra Club suggested offering tax 

incentives to purchase low emission vehicles and they worked with the state legislature on the bill until 

it passed in June 2006. 

Note: Greenville County began exploring the generation of green power as a result of one strategy 

conceived through the EAC process and included in the report. As a result Greenville County entered 

into an agreement with a company to produce green power. This project will begin in fall 2008. 

Greenville County, South Carolina Government did not add any additional staff for the EAC. But, the 

County did add air quality duties to the work of existing staff. 

Denver RAQC 

The EAC had a significant impact on resources. Modeling and processing requirements took resources 

to complete. Denver received assistance from different areas, including the EPA ($100,000) the Denver 

Area Metropolitan Planning Organization (MPO), and the Colorado Department of Transportation. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The Virginia DEQ and the EDC worked together to sell the EAC Program to local elected officials in 

the City of Winchester and Frederick County. Consultants developed and implemented parts of a 

follow-on EAP. Overall, the EAC cost the County more upfront than the traditional approach. But, the 

program was worth the expense to avoid nonattainment status. 

Aiken County, South Carolina Government (Lower Savannah) 

Aiken County, South Carolina Government (Lower Savannah) did not hire new staff to work on the 

EAC. Aiken County primarily had one staff person working on the EAC. Other counties also used core 

staff for the EAC Program. The main expenses were for newspaper advertisements and public meeting 

handouts. 

ACOG (Oklahoma City) 

Oklahoma City definitely spent more resources on the EAC than it would have in the traditional 

approach. 

Piedmont Triad COG 

For Piedmont Triad COG’s response to this question, see question 1.b. below. 

Washington County Government 

For Washington County Government’s response to this question, see question 1.b. below. 

86 
b) Did the EAC approach save money and resources over the traditional approach? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

It is difficult to compare the resource allocations under the two different approaches. However, the 

state did save money and staff time in the planning process. Although it saved some resources by not 

having to involve all stakeholders, the state still had to allocate resources to SIP development. 

Georgia DNR 

The program was resource intensive for Georgia in the short term because the EAC Program areas were 

not familiar with air quality issues. The state had to spend resources and time traveling to teach 

participants about air quality issues. In the long run, the EAC Program saved the state resources. But, 

the Chattanooga Tennessee-Georgia EAC Program areas lost some of the gains when designated 

nonattainment for PM2.5. 

Louisiana DEQ 

Louisiana DEQ made several visits to Shreveport to assist in development of the EAC there. 

Maryland DNR 

Maryland DNR expended more resources through the EAC approach than would have been required in 

the traditional SIP approach. The additional resources were needed to complete the requirement for 

ongoing progress reports. The administrative requirements were burdensome and felt very similar to 

the SIP approach. 

New Mexico ED 

For New Mexico ED’s response to this question, see question 1.a. above. 

North Carolina DENR Department of Environment and Natural Resources (NCDENR) 

Overall, the EAC cost North Carolina DENR more in resources than the traditional approach. The state 

had to attend more meetings and do more modeling runs than would have necessary under traditional 

approaches. However, North Carolina DENR does not believe that comparing resource expenditures is 

an appropriate method for an EAC Program study. The benefits of EACs outweigh the costs. 

Oklahoma DEQ 

Oklahoma DEQ expended more resources initially on the EAC Program than it would have by waiting 

to see whether the areas became nonattainment. In the long run, however, the EAC Program may save 

the state resources. The EAC approach is certainly worth the “insurance” policy that the areas receive 

by avoiding nonattainment designation. 

South Carolina DHEC 

It is difficult to determine whether the EAC approach saved resources for South Carolina DHEC. 

The state did not hire additional staff or spend additional money on the program. Instead, staff shifted 

focus from technical SIP work to working with local EAC Program areas. Under the traditional 

approach, the state would not have conducted as much outreach to local areas. The EAC Program areas 

would have attained with federal and state measures alone. Consequently, there was more local activity 

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under the EAC approach. If new modeling had been required, however, the EAC approach would have 

required additional resources from the state. 

Tennessee DEC 

Overall, the EAC process may have cost Tennessee DEC more in resources. But, the EAC Program 

Area benefited by having measures tailored to local conditions that still provided for economic growth. 

The EAC Program did cost Tennessee DEC more time and resources initially. The state had to work 

with the local area to develop consensus and ownership of the project. Once the EAC Program was in 

place, however, the state did not have the battles with elected officials it has had in the past under the 

traditional approach. The EAC Program allowed stakeholders to develop local measures instead of 

spending time arguing over issues. It is hard to put a price on building good will. However, the 

enormous good will built through the EAC Program has been priceless. 

Texas CEQ 

Overall, Texas CEQ had to allocate more staff time for the EAC approach. The amount of local 

resources spent on the program depends on the individual area. The Austin, Texas area is zealous in its 

approach to the environment. It wanted to do everything. So, it devoted a lot of time and resources to 

the EAC Program. 

San Antonio saved money and resources by participating in the EAC. The City did not have to do the 

work or develop the measures that would be required for a traditional nonattainment SIP. So, the City 

had less work to do than it would have if designated nonattainment. 

North East Texas conducted an outreach and education campaign. The level of effort was not more 

intensive than it would have been without the EAC Program. 

Virginia DEQ 

Virginia did not see a big cost difference between the EAC and traditional approaches. The EAC effort 

required more initial work and resources from the state. But, the traditional approach would have 

required more state resources over time. 

Under the EAC approach, local areas are more willing to contribute resources because they have greater 

responsibility for the program. Areas that are designated nonattainment rely more on the state for 

resources. So, it is difficult to say whether one approach is more costly than the other. 

West Virginia Department of Environmental Protection (West Virginia DEP) 

In West Virginia, the EAC approach required fewer resources at the state level than needed to conduct 

rulemaking for a traditional SIP. Virginia conducted the modeling. However, the EAC Program 

required more resources at the local level to engage stakeholders. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

It is difficult to compare because CAMPO (Austin, Texas) has never done the traditional approach. A 

regional committee of local and regional governmental entity staff conducted the planning work. The 

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state contributed funding for air quality planning and implementation in near-nonattainment areas and 

adopting several state rules that reduced emissions in the Austin area. 

Chattanooga-Hamilton County APCD 

Chattanooga-Hamilton County APCD could not think of instances in which the EAC Program saved 

money and resources. 

Greenville County, South Carolina Government 

For Greenville County, South Carolina Government’s response to this question, see question 1.a. above. 

Denver RAQC 

For Denver RAQC’s response to this question, see question 1.a. above. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The EAC cost Frederick County more initially but it was worth the expense to avoid nonattainment 

status. It did save other affected community stakeholders (businesses and citizens). 

Aiken County, South Carolina Government (Lower Savannah) 

It is difficult to say whether the EAC saved money and resources. The same outreach activities would 

have been conducted with the traditional approach. However, Aiken County, South Carolina 

Government (Lower Savannah) would also have had to deal with conformity under the traditional 

approach. So, the EAC Program may have saved some resources. 

ACOG (Oklahoma City) 

The EAC Program did not save Oklahoma City money or resources. 

Piedmont Triad COG 

Without the EAC Program, air quality activities would have occurred in Greensboro and WinstonSalem but not in the rural areas and smaller towns as those areas were not equipped to take on the issue. 

Washington County Government 

2)	 What have been other impacts, intended or not, if any, of EACs on local communities and 

State air agencies? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

Overall, the EAC Program had a positive impact. The EAC brought a considerable number of elected 

officials onboard quickly to think about air quality issues. Many local officials, especially at the county 

level, became involved in the process because they had to sign the EAC memorandum of understanding 

(MOU). This level of participation does not usually occur with the traditional approach. However, 

there was a feeling of failure when the area became nonattainment. In particular, the oil and gas 

industry felt that all the emission reductions they did might not have affected the outcome. 

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Georgia DNR 

Local stakeholders did develop an improved awareness of air quality issues. But, the improvements are 

due to the “PM2.5 focus area” program, an EAC-type effort to avoid nonattainment designation, and not 

the EAC Program. 

Louisiana DEQ 

There is more local participation under the EAC approach. 

Maryland DNR 

Local stakeholders participated more quickly and to a greater degree than they would have under the 

traditional approach. The EAC schedule made it necessary for stakeholders to become involved in the 

initial stages of the program. Washington County developed a working relationship with stakeholders 

early in the process. The County also had to obtain much-needed assistance with air quality modeling. 

North Carolina DENR 

The EAC Program led to the adoption of local measures that could not have been mandated by the state. 

The measures would not have been discussed without the flexibility of the EAC Program. The outreach 

activities also led to a greater awareness and continued enthusiasm for air quality issues. Local areas 

have asked the state whether another EAC Program can be done for the 2008 ozone standard. 

The Hickory, EAC Program Area continues to hold monthly meetings. In June 2008, Hickory will hold 

a 2nd annual conference in June to discuss air quality issues with industry and the public. The 

Fayetteville and Triad EAC Program areas have hired air quality coordinators. Fayetteville changed 

their roads and bus routes to improve air quality. In addition, Fayetteville established more dialogue 

with Fort Bragg on air quality issues. These types of activities will continue in the future. 

New Mexico ED 

The EAC has had a snowball effect on awareness of air quality issues. The state established a task 

force to work on the EAC. After the EAC Program ended, the state created a successor group. The 

new task force attracts approximately 80 attendees from federal, state, local, and tribal governments to 

regularly scheduled meetings. In addition to other issues, the task force is preparing the groundwork to 

meet the next standard. 

Oklahoma DEQ 

The EAC Program produced positive and negative impacts. On the positive side, the Department of 

Environmental Quality received $500,000 from the state Department of Transportation for ozone 

modeling. The program enhanced air quality awareness among elected officials and the public in EAC 

Program areas. The Tulsa and Oklahoma City Councils of Governments made greater efforts to get the 

word out on ozone action days. Overall, the cost/benefit analysis came out favorably, although the 

benefits were fuzzy. 

On the negative side, the state became frustrated with the pace of required data submittal from local 

areas. However, Oklahoma DEQ viewed the biannual reporting requirement as worth the effort to 

avoid nonattainment designation. 

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South Carolina DHEC 

South Carolina DHEC conducted a statewide EAC Program. Consequently, the state found it difficult 

to compare the impacts among local areas. The EAC Program generated substantial support in local 

areas. For example, Charleston did not have a problem with the 1997 8-hour National Ambient Air 

Quality Standard (NAAQS). Although it did not, therefore, have to participate, Charleston still became 

very engaged in the EAC Program. Darlington and Florence were in a similar position but were also 

very engaged in the process. 

The EAC Program helped communication between the state and local areas. When the PM2.5 NAAQS 

changed, the state already had a direct line of contact with the local areas. In addition, coalitions are 

being formed and partnerships expanded to develop a multi-pollutant approach now that the new ozone 

NAAQS is final. 

Tennessee DEC 

As a result of the EAC Program, the public pays more attention and understands the air quality index 

much better. The public is also more aware of personal actions they can take to improve air quality. In 

Williamson County, local officials host a weekly program on the community access channel. The area 

never had anything like that before the EAC Program. 

Texas CEQ 

The EAC generated a range of benefits in Texas. Texas CEQ made a commitment to provide Texas 

Emission Reduction Plan funds to each EAC Program Area. These local programs would not have 

been funded without the EAC Program. 

Local governments developed an increased awareness of air quality issues that would not have taken 

place without the EAC Program. The EAC also led to cooperation among local stakeholders. Austin, 

Texas voluntarily adopted an inspection and maintenance program. After state permits were issued, the 

city obtained voluntary emissions reductions from industry. In San Antonio and North East Texas, the 

EAC Programs established a level of cooperation between industry and other local stakeholders. San 

Antonio provided information to industry seeking a permit to retrofit equipment that would reduce 

emissions. The City also obtained voluntary agreements to reduce emissions after permits were in 

place. 

Virginia DEQ 

The EAC increased the involvement of local stakeholders in air quality issues. Elected officials and 

citizens became more aware of air quality issues. 

West Virginia DEP 

The EAC fosters local engagement in air quality issues. Local stakeholders have to become involved if 

the program is to work. However, West Virginia DEP is not sure how much time local governments 

still spend on EAC activities. There were no real downsides to the EAC Program other than the 

reporting requirements. 

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LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

The EAC has produced only positive impacts in Austin, Texas. The program raised awareness and 

acceptance by local elected officials and stakeholders of the need to improve air quality. The EAC 

provided local flexibility to solve the local air quality problem. This made it easier for the five 

participating counties, including two rural areas, to make hard decisions and develop emission 

reduction strategies that consider the varied issues and circumstances of the jurisdictions in the region. 

The EAC also led to better coordination between state and local officials. 

Chattanooga-Hamilton County APCD 

Public awareness of air quality issues increased in Chattanooga-Hamilton County APCD as a result of 

the EAC. People began thinking about air quality and how to improve it. 

Denver RAQC 

The EAC process led to more outreach, awareness and voluntary action than would have occurred 

otherwise. Local stakeholders completed a lot of work related to air quality in a short period of time. 

Heightened awareness of the ozone situation was the greatest impact of the program. Without the 

increased awareness, Denver would not have received funding from the transportation planning 

process. The heightened awareness also generated support from industry. In particular, the oil and gas 

industry would not have been as involved in finding emissions reductions. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The EAC Program raised awareness and educated the public on air quality issues. A wide range of 

stakeholders participated in the process. The process went very smoothly. Control measures were 

selected through a consensus-building process that bridged a lot of gaps among stakeholders. As a 

result, implementation occurred much smoother than if outstanding differences had still remained 

among stakeholders. This helped unite the community. It also brought organizations together that are 

now working on projects beyond the EAC Program. In addition, the program led to a shift in lifestyle 

activities among residents. Virginia DEQ gained a lot of credibility among local communities as a 

result of the EAC Program. 

Greenville County, South Carolina Government 

The EAC has had a good impact on Greenville County. The County was designated attainment for the 

1997 standard. The EAC Program also provided another benefit for Greenville County. It provided an 

opportunity for the County to collaborate with Upstate Forever, Save Our Saluda, Sierra Club, and 

other organizations working to improve air quality. The organizations worked together on all twentythree strategies and some subsets as well, such as Breathe Better Air at School (B2

@School) program at 

Fountain Inn Elementary School. Now the B2@School program is being expanded to Sevier Middle 

School. 

In addition, the Sierra Club suggested offering tax incentives for low emission vehicles. The 

organization went before the legislature to get funding for this measure. The Duke Power - Leed Steam 

Plant, the largest emitter of nitrogen oxides (NOx) in the upstate area, brought together a number of its 

constituents. They decided to convert the boilers at the plants to low NOx emitting boilers. This was a 

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$15 million commitment. The second largest NOx emitter in the upstate area, Transco, had thirteen 

compressors that had no controls at all. Transco installed low NOx boilers early because of its 

involvement with the EAC. 

Aiken County, South Carolina Government (Lower Savannah) 

The EAC increased awareness of air quality issues in the Lower Savannah area. For example, the EAC 

was a factor in the prominence of the air quality outreach at the local Earth Day event. Small 

municipalities learned a lot about air quality through the EAC Program. Recently, local environmental 

organizations have spurred on a lot of improvements. However, the EAC was ahead of this recent 

movement in bringing about local improvements. 

ACOG (Oklahoma City) 

The EAC Program raised awareness of air quality issues. 

Piedmont Triad (COG) 

The EAC generated positive impacts in the area. The Triad had been facing a lot of pressure to make 

significant changes, such as becoming more energy efficient. The pressure came from a number of 

factors including: MPO requirements, conformity, nonattainment avoidance, and sound economic 

development. 

The EAC Program linked air quality issues to smart growth initiatives and the planning process. This 

complemented the work of the MPOs in the area. The EAC accelerated the emphasis on greenways, 

bikeways, pedestrian planning, and other smart growth-type initiatives. The public supported these 

measures because of the linkage to air quality issues. The impetus for these activities was greatly 

strengthened by the EAC. 

Washington County Government 

The biggest impact of the EAC was raising public awareness of air quality issues. People became 

aware that air quality is not just a “city” issue and that rural areas also play a role in maintaining air 

quality. 

3)	 Would the program have succeeded without the threat of nonattainment designation or 

without the program being part of the larger SIP effort? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

No, it would not have succeeded without the threat of nonattainment. Local areas needed a “driver” to 

motivate them to participate in the program. The threat of being designated nonattainment compelled 

areas to participate in the EAC. 

Georgia DNR

 The local communities would not have participated at all without the threat of nonattainment. 

Louisiana DEQ 

Louisiana DEQ probably would not have participated. The threat of nonattainment designation 

motivated Louisiana DEQ to participate. 

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Maryland DNR 

Maryland DNR would not have participated without the threat of nonattainment. It wanted to minimize 

the Nonattainment NSR and Conformity Program requirements. 

North Carolina DENR 

Some areas might participate without the threat under the right circumstances. Initially, the threat of 

nonattainment designation motivated the Mountain Area EAC to participate in the EAC. However, the 

local stakeholders decided to continue participating in the EAC Program even though the area was in 

attainment. 

New Mexico ED 

There is not much rationale for an area to join the EAC Program without the threat of nonattainment. 

The EAC Program encourages areas to take a proactive approach to avoid nonattainment status. 

Oklahoma DEQ 

It is doubtful that there would be willingness to participate in the EAC without the threat of 

nonattainment. 

South Carolina DHEC 

It is not clear if the threat of nonattainment needs to be a factor. South Carolina DHEC hoped it would 

have participated without being concerned about nonattainment designation. The possibility of 

nonattainment status was considered an incentive to take actions earlier to improve air quality. South 

Carolina DHEC’s continued “early action” effort demonstrates the desire to meet national standards 

before nonattainment designations occur. 

Tennessee DEC 

States and localities need a driver to motivate participation in the EAC. The concern over 

nonattainment designation led Tennessee DEC to participate. The state did not want to have to deal 

with the Transportation Conformity Program or the economic development issues associated with the 

Nonattainment NSR Program. 

Texas CEQ 

San Antonio would not have participated without the concern of nonattainment designation. The other 

two areas might have participated. However, Austin, Texas probably would not have adopted the 

inspection and maintenance program. 

Virginia DEQ 

Initially, Winchester, Virginia (as part of the Frederick County, Virginia area) probably would not have 

participated without the threat of nonattainment. Virginia DEQ spent a lot of time in Winchester 

convincing them to join the EAC. Winchester selected the EAC as the lesser of two evils. However, 

local attitudes have changed after participating in the program. Communities now see the value of 

addressing air quality issues and participating in the EAC Program. 

West Virginia DEP 

West Virginia DEP stated emphatically that it would not have participated without the threat of 

nonattainment. The state was concerned about the economic consequences of nonattainment. The 

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EAC created a local dynamic to participate in the program. Originally, Winchester, Virginia was 

motivated to participate. This spurred the Berkeley and Jefferson Counties to approach the state with 

interest in the program. Afterwards, Hagerstown, Maryland became interested in participating. 

Berkeley and Jefferson Counties put together $200,000 for emissions inventory and control strategy 

development. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

Austin, Texas would have participated without the threat of nonattainment. It is a very motivated area. 

However, the state would not have been as involved without the concern over nonattainment 

designation. Due to that concern, the state committed to emission reductions in the Austin area that 

they probably would not have otherwise. 

Chattanooga-Hamilton County APCD 

The EAC Program absolutely would not have succeeded without the threat of nonattainment 

designation. Chattanooga-Hamilton County APCD participated in the program out of concern over the 

impact of a nonattainment designation on economic development. 

Denver RAQC 

The EAC Program probably would not have had as much participation without the threat of 

nonattainment. Denver entered the program while designated attainment but became nonattainment 

afterwards. However, the City joined the program to avoid nonattainment designation. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The County would not have been able to get local business involved in the process without the threat of 

nonattainment. It would have been much harder to persuade businesses to join the program. Moreover, 

the program’s methods would not have been as balanced because stakeholder involvement would have 

suffered. 

Greenville County, South Carolina Government 

No, the program would not have succeeded in Greenville County without an incentive. It took the 

threat of nonattainment to nudge the elected officials to move forward with the efforts. Greenville 

County, South Carolina Government had to spend some time to educate the public officials. 

Public officials tend to think of air quality problems as a regional problem and not a local problem. The 

opportunity to take control of developing solutions to the problem appealed to them. Local officials 

appreciated having the opportunity to develop solutions instead of having EPA devise solutions for 

them. 

Aiken County, South Carolina Government (Lower Savannah) 

It is doubtful that anyone would have participated without the threat of nonattainment. However, it is 

possible that some larger corporations, such as Kimberly-Clark, Bridgestone, and Pepperidge Farm, 

might have participated because they have had “green” outreach programs since 2000. 

ACOG (Oklahoma City) 

The EAC Program would not have succeeded without the threat of nonattainment. 

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Piedmont Triad (COG) 

The EAC Program would have been much less efficient without the threat of nonattainment. Concern 

over nonattainment designation makes local governments and elected officials become more aware of 

air quality issues. The program’s deadlines provide the motivating force to reduce emissions. If EPA 

does another program, two factors will motivate participation in the program. Increased awareness of 

air quality issues will be one factor, while the desire to avoid nonattainment will be the other. 

Washington County Government 

The EAC Program would not work without the threat of nonattainment. Localities do not know what to 

do about air quality issues. They need the prodding of a nonattainment designation to become involved 

in the process. 

4) Were the Compacts successful at engaging and involving stakeholders at the local level? 

Were there intangible outcomes from stakeholder engagement such as increasing local 

awareness that may provide for air quality benefits and better decisions in the future? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

The EAC did succeed in engaging local stakeholders. The EAC Program compelled the state to go 

beyond working with the “usual” stakeholder groups. The state contacted county commissioners it had 

not worked with before to sign the EAC MOU. Public interest in the EAC Program was about the same 

level as with other issues. But, environmentalists may have been more involved in this issue. The 

media took a real interest in the program. This proved to be helpful in obtaining the support of local 

elected officials. 

Georgia DNR 

Georgia learned a lot from the early stages of the EAC process. It is important to have local investment 

in the program. However, it was the process for the PM2.5 focus area that successfully engaged local 

stakeholders. The increased involvement of stakeholders occurred in most areas of the state with the 

exception of the Chattanooga area. 

Louisiana DEQ 

It is unclear whether stakeholder involvement increased. The progress reports did not require an 

appraisal of stakeholder involvement. 

Maryland DNR 

There was a fair degree of stakeholder engagement. Businesses did not participate much initially. The 

program did produce benefits. Air quality forecasting now covers Washington County. Additionally, 

local businesses and governments now participate in ozone action day programs. 

New Mexico ED 

The EAC absolutely increased the level of stakeholder involvement. Public engagement in the process 

was the largest benefit of the program. The state also developed good relationships and had good 

outcomes with the press and local television. 

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San Juan County, New Mexico created an ozone task force to study the impacts of ozone in area. In 

April 2002, the group started talking to the public about ozone, its sources, and its health effects. 

Public interest and awareness of air quality increased in response to the outreach. When the EAC 

Program was announced, local governments were asked if they wanted to participate. San Juan County 

and three localities within the county decided to participate in the program. 

North Carolina DENR 

The EAC Program increased local stakeholder participation and produced intangible results. North 

Carolina DENR has had an outreach program since 1997. The EAC Program helped enhance those 

efforts. As a result, the state’s outreach efforts are better now. The outreach generated broad 

stakeholder representation in all of the North Carolina EAC Program areas. Local people now talk to 

other local people about air quality issues. The state’s efforts also created clean air advocates at the 

local level. 

The EAC Program also helped develop relationships that are being used to address other issues. For 

example, the EAC Program paid off in Hickory. When Hickory became nonattainment for PM2.5, it 

already had an air quality effort underway through the EAC Program. 

Oklahoma DEQ 

The EAC did increase stakeholder engagement and produce intangible benefits. Because of the EAC 

Program, political leaders are aware of the ozone problem. The general public is aware of air quality 

issues. The business community also shows willingness to participate in improving air quality. The 

state sees evidence that this level of involvement will continue. For example, the state has submitted 

voluntary “maintenance” flex-plans for Tulsa and Oklahoma City with additional emissions reductions 

included in those plans. 

South Carolina DHEC 

The EAC Programs engaged local governments, environmentalists, councils of governments, industry, 

and state agencies. The state focused most of its efforts on the nonattainment-deferred areas of 

Columbia and Greenville. Consequently, stakeholder involvement was greater in those areas. But, the 

Aiken area and Charleston area also had a good level of local involvement. Rural areas that did not 

have as much to do still maintained good contact with stakeholders 

There is no comparison to the way things were before the EAC Program. The relationship and 

communication between the state and local stakeholders was not nearly as strong prior to the EAC 

Program. These stakeholders have expressed an interest in participating again if given the opportunity. 

The EAC Program enhanced the state’s relationship with stakeholders. This has already proved to be 

important. The South Carolina legislature must approve all proposed regulations. The state has to 

demonstrate stakeholder support for a regulation before the legislature will approve it. The state was 

able to tighten the open burning ban and NOx reduction regulations. But, the state would have not been 

able to obtain the stakeholder support needed to get the regulations passed without the improved 

relationships from the EAC Program. 

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Tennessee DEC 

The EAC Program enhanced stakeholder support and produced intangible benefits. Bigger results 

always occur when local areas are fully invested in a program. The EAC built good will partnerships 

with stakeholders. 

The Tennessee Environmental Board has a member who represents counties and another member 

representing cities. The state is very interested in the EAC concept. It is exploring whether states and 

localities can build on previous programs to continue the EAC concept. Because of the EAC Program, 

Tennessee now has the infrastructure in place to meet the new standard quicker. It will continue doing 

more of the same thing to meet the new standard. The state would like to have the opportunity to 

participate in another EAC Program. 

Texas CEQ 

The three EAC Program areas in Texas already had an increased level of awareness of air quality issues 

prior to the start of the EAC Program. During the EAC, there was extensive local involvement to 

develop and agree on control measures. Those groups are still active. However, stakeholder 

participation in environmental issues had already been high before Austin, Texas became an EAC 

Program Area. 

Virginia DEQ 

The EAC generates much more grass roots involvement than traditional programs. This is due to the 

small size of the areas. It is also due to the fact that participants are involved in the process from the 

very beginning. The task forces in both EAC Program areas had a very diverse mix of people. 

West Virginia DEP 

There was extensive stakeholder involvement in the EAC. All participants appeared to want to find 

workable control strategies. The state is already involved with stakeholders on the PM2.5 standard. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

The EAC Program generated stakeholder involvement and intangible benefits. The regional 

stakeholder workgroups developed lists of control measures to help ensure acceptance by stakeholders. 

They also received commitments from stakeholders for future action 

Chattanooga-Hamilton County APCD 

The EAC did bring stakeholders together in Chattanooga-Hamilton County APCD. Through 

discussions, local stakeholders identified about twelve measures for the program. In general, 

suggestions from local stakeholders are better received than ideas from government. 

Denver RAQC 

The EAC Program generated a greater level of engagement from a wider range of local stakeholders 

than found in other issues. Stakeholders are now much more aware of air quality issues. The oil and 

gas industry, refining industry, and transportation community all became involved in the process. The 

EAC Program also helped lead to an expansion in the outreach program from $50,000 to $2.5 million. 

The area was expanded while it was part of the EAC Program and brought in 2 new counties that had 

never before addressed ozone. 

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Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The EAC Program did generate stakeholder involvement and intangible benefits. The business 

community was recognized for the proactive measures done prior to EAC. The SHENAIR program is 

an example of the benefits associated with the EAC Program. 

Greenville County, South Carolina Government 

The EAC has been successful in raising stakeholder involvement. Local stakeholders had limited 

awareness of air quality issues before Greenville County, South Carolina Government started the EAC 

Program. The County’s outreach focused on reaching one community or school at a time. This 

approach took more time but did raise awareness. The control measures also raised public awareness. 

The car care, gas can and lawn mower exchange events as well as public presentations and setting up 

booth are community wide events helped spread the message to citizens that they could take personal 

actions to improve air quality. Citizens now discuss aspects of air quality that they would not have 

known about prior to the EAC. At stakeholder meetings, for example, citizens are aware of 

particulates, the new standards, and other air quality issues. In early 2007, newspaper articles about air 

quality began to regularly appear and local TV stations made air quality forecast a regular part of the 

weather forecast. 

The EAC process created partnerships and relationships that will come in handy in the future. 

Mitsubishi, Michelin, BMW, Milliken, and other private organizations joined the stakeholders’ 

committee. Greenville County, South Carolina Government could not have paid the hourly rate 

necessary to bring these people in to get their technical expertise. Instead, these very knowledgeable 

technical experts participated in the EAC free of charge. They, and South Carolina DHEC, have helped 

county staff interpret EPA guidance and are continuing to help Greenville County with air quality 

issues. In addition, businesses helped sponsor community events. 

Aiken County, South Carolina Government (Lower Savannah) 

The EAC did engage local stakeholders in the Lower Savannah area during the early stages of the 

process. During the past year, the entire metropolitan area has been working proactively on PM2.5. 

Many of the same people involved in the EAC are working on PM2.5. The relationships established 

during the EAC Program made the collaboration on PM2.5 much easier. 

Association of Central Oklahoma Governments (ACOG) 

The Oklahoma City EAC definitely did engage local stakeholders. There has not been a lot of spin-off 

progress yet. However, the community is better prepared because of EAC involvement. In addition, 

the EAC laid the groundwork for future outcomes. 

Piedmont Triad (COG) 

The EAC Program generated stakeholder involvement and intangible benefits. The EAC stakeholder 

group continues to meet quarterly. It consists of Duke Power, RJ Reynolds, local officials, 

environmentalists, and chambers of commerce. 

Washington County Government 

Due to rural nature of the region, Washington County did not have much stakeholder participation. 

There is not much industry in the county. The issues were not that important to the general public. 

99 
However, there may have been indirect benefits from the outreach program. People now understand 

what they can do to improve air quality. 

5)	 Did the compact agreements give local areas the flexibility to develop their own approach to 

meeting the 8-hour ozone standard that the program touted? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

EAC may possibly have provided flexibility to local areas. The RAQC is the lead planning 

organization for SIP development for Denver. However, the state and Air Quality Control Commission 

retain regulatory authority. The state adopts rules that apply statewide or in a geographic subset. 

RAQC and the state did have more flexibility designing the EAC than available in other programs. 

RAQC did a lot of outreach with local governments. In return, RAQC received input and help from 

affected cities and counties. Local governments do not usually adopt ozone control measures. Under 

the EAC, however, local governments did conduct more ozone outreach programs. 

Georgia DNR 

The EAC Program may have given local areas greater flexibility. But, the EAC Program areas in 

Georgia did not take advantage of the added flexibility. 

Louisiana DEQ 

The EAC did provide local flexibility. The EAC Program Area had the opportunity to develop a list of 

potential measures appropriate for the individual characteristics of the community. In addition, the 

EAC Program did create a different dynamic between the state and the locality. This dynamic probably 

led to a willing and receptive response to the program from the local area. 

Maryland DNR 

The traditional SIP approach affords some flexibility to local areas. While the EAC offered a little 

more flexibility, Maryland DNR believed that the program felt very much like a SIP exercise. 

New Mexico ED 

Yes, the flexibility was key for buy in and gave the local participants the ability to make their own 

decisions. 

North Carolina DENR 

The EAC emphatically did provide flexibility to local areas. North Carolina DENR presented the EAC 

Program areas with a list of state and federal control measures that would improve air quality. The 

EAC Program areas had the flexibility to select measures from the list that would work with the 

individual characteristics of their own communities. 

For example, in the Triad EAC, local businesses joined in to help the area reach attainment on time. 

Duke Power installed a Selective Catalytic Reduction control system a year early. Duke Power also 

installed remote reading of meters in the area to reduce vehicle idling. RJ Reynolds agreed to switch 

fuel in the summertime from coal to natural gas to reduce their NOx emissions. 

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Oklahoma DEQ 

The opportunity for flexibility in local decision-making was critical in obtaining support for the 

program. 

South Carolina DHEC 

The EAC provided programmatic and local flexibility. Air quality models indicated that the areas 

would come into attainment through existing federal programs. This provided flexibility to the state 

and local areas. Each of the EAC Program areas adopted control measures that made sense for their 

own areas. For example, an area might be interested in pursuing an anti-idling program to save fuel. 

The area would find it easier to implement the program after being informed of the air quality benefits 

by the state. 

Tennessee DEC 

The EAC Program provided flexibility to local areas. National measures were primarily responsible for 

bringing the areas into attainment. However, the EAC allowed local areas to contribute to the effort to 

improve air quality. At times, the local programs included controversial measures such as lowering the 

speed limits for truckers. In order to be in the EAC Program, Chattanooga-Hamilton County APCD 

asked for an inspection and maintenance program, which was a controversial move. 

Texas CEQ 

Local areas, in conjunction with state approval, did receive flexibility in selecting control measures. 

The EAC Program areas implemented area-specific state rules and measures that were included in the 

air quality modeling performed for the areas’ plans. In addition, some local measures were included in 

EAC Programs but which did not model. 

Virginia DEQ 

Virginia DEQ stated that EAC Program provided flexibility. 

West Virginia DEP 

West Virginia DEP stated that EAC Program provided a lot of flexibility. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

The EAC Program did provide local flexibility. After looked at the emissions for each of the five 

participating counties, the EAC workgroup set a target emissions reduction commitment level for each 

county and seven cities in the region (the largest city in each county plus two additional cities). In 

addition, multi-county measures such as inspection and maintenance programs were implemented in 

two urban counties and several measures were implemented through state rule (at the request of the 

local governments) in all five counties. 

Chattanooga-Hamilton County APCD 

In general, the EAC gave local areas greater flexibility. 

Denver RAQC 

The EAC gave Denver the flexibility to focus on specific industries of interest. 

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Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The EAC clearly gave areas the opportunity to develop a flexible approach. This was a strong selling 

point for obtaining the support of a skeptical community that was showing resistance to an unknown 

program. 

Greenville County, South Carolina Government 

The EAC Program did provide local flexibility. 

Aiken County, South Carolina Government (Lower Savannah) 

The EAC did provide local flexibility in the Lower Savannah area. Local stakeholders developed a list 

of voluntary and industrial measures that produced noticeable improvements. The local areas 

developed what they thought would be best for each individual source or sources. 

Association of Central Oklahoma Governments (ACOG) 

Yes, but the EAC Program did not have the strength to get areas to choose measures. Instead, they 

waited for designation before they would do anything. Having a percent reduction target would have 

changed things. 

Piedmont Triad (COG) 

The EAC did provide for a more flexible approach. A local stakeholder group put together an initial list 

of more than one hundred measures. After meeting monthly for one year, the group winnowed the list 

down to thirty measures. Afterwards, the group submitted and received approval for the measures from 

the participating local governments. 

Washington County Government 

The EAC may have provided local flexibility. However, there was not much Washington County could 

do at the local level. Whatever emissions reductions the County generated would be a drop in the 

bucket compared to those coming from all the federal and state programs. Washington County’s 

activities focused primarily on educational outreach. 

6)	 Are there environmental benefits as a direct result of the EAC activities regarding pollutants 

other than ozone? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

There have been additional environmental benefits from the EAC. Air toxics have been lowered by the 

reduced VOC emissions from lower Reid vapor pressure gasoline. In addition, reductions in NOx 

emissions improved visibility and regional haze. 

Georgia DNR 

There were no other benefits directly resulting from EAC activities. The EAC Program areas selected 

control measures from a list of state rules. The EAC Program areas developed no local measures. For 

example, Augusta selected open burning as a local control measure. However, the state rules for open 

burning were used for Augusta rather than Augusta creating a local regulation. 

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Louisiana DEQ 

Generally, the EAC Program Area did not get a lot of emissions reductions. 

Maryland DNR 

There were little environmental co-benefits as a direct result of the EAC activities regarding pollutants 

other than ozone. 

New Mexico ED 

There were no new local or state measures as a result of the EAC; those are a “work in progress.” The 

area, though, did add a third air quality monitor. The EAC Program paved the way for a larger task 

force. 

North Carolina DENR 

The EAC Program produced additional direct benefits. The idling reduction and biofuel programs 

adopted by EAC Program areas reduced particulate matter (PM) emissions. The open burning ban also 

contributes to PM reductions but it was a state rule already in place prior to the EAC Program. 

Additionally, local ordinances reduced vehicle miles traveled by promoting walkable communities. 

This will reduce PM and carbon dioxide (CO2) emissions as well. 

Oklahoma DEQ 

The EAC Program did produce additional direct benefits. As a result of the EAC Program, Oklahoma 

DEQ added a third air quality monitor. In addition, the very successful EAC Program paved the way 

for a larger taskforce. 

South Carolina DHEC 

The EAC Program generated additional direct benefits. South Carolina DHEC is building upon its 

ozone EAC Program to develop PM2.5 and greenhouse gas (GHG) emission reductions programs. 

Tennessee DEC 

The EAC Program did produce additional direct benefits. The state promoted alternate fuels in the 

EAC Program. By reducing NOx emissions, alternative fuels help lower PM as well. The open burning 

ban has also helped reduce PM, carbon dioxide, air toxics and volatile organic compounds (VOCs). 

Texas CEQ 

Texas CEQ did not measure per se, but other pollutants benefits were possible. For example inspection 

and maintenance could benefit Colorado and PM. 

Virginia DEQ 

The EAC Program provided multiple direct environmental benefits. Roanoke is now looking at 

reducing PM2.5 and GHG. As a result of the EAC Program, Winchester is much more interested in air 

quality issues of all types. Its residents are more educated and involved in air quality issues than before 

the EAC Program. Most importantly, the EAC Program spawned the SHENAIR project with NOAA to 

address air quality in the Northern Shenandoah Valley. 

West Virginia DEP 

EAC Programs, such as the reduced idling and freight partnership programs, have reduced NOx, PM, 

and air toxics. 

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LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

Control measures adopted during the EAC Program have led to additional environmental benefits. 

Several measures reduce CO2. The inspection and maintenance program reduces air toxics and PM. 

The school bus retrofits reduce PM and air toxics. 

Chattanooga-Hamilton County APCD 

The EAC activities have led to other environmental benefits. The inspection and maintenance program 

reduces combustion. The burn bans reduces PM, air toxics, and greenhouse gases. 

Denver RAQC 

The EAC Program has primarily generated VOC reductions. The reductions from the oil and gas 

industry have reduced some air toxics, but not by very much. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

Not sure of any non-ozone environmental benefits. 

Greenville County, South Carolina Government 

The EAC Program did produce additional direct benefits. EPA Region 4 and South Carolina DHEC 

have been working with Greenville County, South Carolina Government on the PM2.5 issue. 

Note: A new PM2.5 monitor was placed at a location that all agreed met EPA siting guidelines. County 

officials continue working with DHEC to site an additional PM2.5 monitor in Spartanburg. The 

cooperative spirit the EAC has provided also allowed us to collectively site two new ozone monitors 

that all agreed met EPA siting guidelines. 

Aiken County, South Carolina Government (Lower Savannah) 

EAC measures to reduce ozone have also helped lower PM2.5. The measures include diesel retrofits and 

the recent popularity of biodiesel in the area. One biodiesel plant is already in the area and another is 

being built. Lower Savannah is just under the limit for the PM2.5 air quality standard. The area might 

have exceeded the PM2.5 standard if not for the EAC activities. 

ACOG (Oklahoma City) 

Oklahoma City did not experience any other benefits from the EAC activities. 

Piedmont Triad (COG) 

The EAC Program did generate additional direct benefits. The North Carolina DENR Clean 

Smokestacks program continues to reduce PM and sulfates. Additional emissions reductions have 

occurred through the biodiesel and diesel retrofit programs. 

Washington County Government 

The EAC Program may have helped reduce PM emissions. 

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7)	 To what extent did the EAC activities provide for longer-term emission reductions or create a 

local “infrastructure” for further or continued action in the future? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

The Colorado DPHE adopted regulations without expiration dates for the EAC Program. As a result, 

the regulations will provide long-term environmental benefits. In addition, the planning capacity 

developed by the Fort Collins area during the EAC Program will be valuable because the area is now 

designated nonattainment for the 8-hour ozone standard. The RAQC has also become successful at 

securing grant dollars to conduct outreach work. 

Georgia DNR 

Aside from the learning experience, the local EAC activities did not provide much capacity for 

continued action in the future. For example, Walker and Catoosa County commissioners, two local 

EAC Program Area stakeholders, have not carried EAC efforts forward. 

The EAC Program did facilitate inter-state collaboration. Prior to the EAC Program, Georgia and 

South Carolina had little, if any, coordination on emission control measures. Since the EAC Program, 

the two states have been working together on reducing PM2.5 emissions. 

Louisiana DEQ 

The control measures enacted for the EAC are permanent. 

Maryland DNR 

Air quality forecasting now covers Washington County. In addition, local businesses and governments 

participate in ozone action day programs 

New Mexico ED 

After the program ended, the EAC task force formed a successor group. The new task force attracts 

about 80 attendees to the regularly scheduled meetings. There is an oversight group composed of 

representatives from tribal, federal, state, and local governments. The task force developed a document 

with control measures for planning agencies in the state. This prepared the groundwork for the next 

standard. 

North Carolina DENR 

Local stakeholders developed an awareness of air quality issues through the EAC Program. Because of 

this, air quality issues will continue to be raised by the activities initiated during the EAC that involve 

metropolitan planning. For example, air quality is an element in the smart growth principles adopted in 

planning districts during the EAC. These activities will continue. It is important that the parties 

implementing the program are government entities that will remain in place long term. Additionally, 

several of the EAC Program areas established Air Awareness outreach positions to promote public 

education and outreach. These activities are expected to continue. 

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Oklahoma DEQ 

The participating communities developed an understanding of air quality issues through the EAC 

activities. As a result, the communities now understand regional haze and mercury issues. This will pay 

dividends for the new standard. 

South Carolina DHEC 

The EAC Program areas are continuing their air improvement efforts. As a result of the EAC Program, 

the state and local stakeholders have established an ongoing dialogue. The participants discuss the new 

ozone standard and the need for continued efforts to improve air quality. 

Tennessee DEC 

Due to the anti-backsliding measure, the state and locals have pledged to do everything necessary to 

stay within the SIP. The EAC activities developed an infrastructure that remains in place for further or 

continued action in the future. 

Texas CEQ 

Each of the EAC Program areas has made a commitment to implement the programs through 2012. In 

addition, public awareness of air quality has influenced local planning activities, particularly in Austin, 

Texas. 

Virginia DEQ 

Both of the EAC Program areas are committed to keeping the programs going. Financial support and 

the new standard will help keep that commitment alive. Roanoke, for example, wants to expand air 

quality measures beyond ozone to address PM2.5 and GHG. In addition, Roanoke has inquired about 

funding for woodstove changeout programs. Winchester has developed a website, conducted 

significant outreach, and committed to funding an air quality coordinator. 

West Virginia DEP 

West Virginia DEP created the position of a regional economic development coordinator to coordinate 

the EAC activities. This position will likely continue to be funded in the future. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

A regional group of elected officials and staff will continue to work on air quality issues. (This group 

just developed an 8-hour Ozone Flex Program that has been approved at the state and local level and is 

awaiting EPA approval). The EAC control measures in the SIP will continue to be implemented for the 

foreseeable future. In addition, there is no talk of stopping the local measures used in the EAC 

Program. 

Chattanooga-Hamilton County APCD 

The burn ban and inspection and maintenance program in Chattanooga-Hamilton County APCD are in 

the SIP and will remain in effect as long as necessary. 

Denver RAQC 

The EAC Program has helped the City to deal with future air quality issues. In addition, the emissions 

reductions from the oil and gas industry will continue into the future 

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Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The County will need to stay involved in air quality issues because the ozone problem can return. All 

the relevant stakeholders are more willing to work together since the EAC Program. 

Greenville County, South Carolina Government 

The “local ‘infrastructure’” is the strong partnership created during the process with public and private 

organizations. 

Several activities will help continue emissions reductions: 

• The B2@School program is planned for all of the Elementary Schools in the County. 

• Reducing lawn mowing and having a student patrol encouraging buses and parents not to idle. 

• Safe route to school to encourage walking. 

Unfortunately, HOV lanes were not implemented but they will continue with community awareness 

campaign. 

Aiken County, South Carolina Government (Lower Savannah) 

There is a framework in place for continued action. In addition, South Carolina Electric and Gas added 

gas turbines and switched to a wood pellet fuel as a permanent measure. 

ACOG (Oklahoma City) 

The EAC activities did provide assistance for longer-term emission reductions. Oklahoma City is now 

aware of the type of projects to look for in the future. In addition, the ACOG will likely devote 1⁄2 FTE 

to air quality issues. Hopefully, in the future, the ACOG will have 1 FTE working on air quality issues. 

Piedmont Triad (COG) 

The EAC created an infrastructure to address air quality issues in the future. PTCOG will continue to 

take the lead in the effort to improve air quality in the area. The EAC is the platform they will build on 

for future activities. 

As a result of the EAC, a number of regional organizations and programs (PTCOG, regional 

transportation authority, Triad Air Quality Program, and North Carolina Solar Center) have formed an 

effective network/infrastructure that continues to work on regional air quality issues. 

Washington County Government 

The awareness of air quality issues developed through the EAC Program has established a foundation 

for future action. 

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8)	 Will EAC activities result in continued reductions in ozone and air quality improvement 

activities/policies that were not foreseen at the time the EACs were developed? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

The EAC established an atmosphere that helped create alliances to push the oil and gas industry for 

emissions reductions. As a result, the state obtained large emissions reductions earlier than would have 

occurred without the program. The state continues to ask for additional reductions and plans to do so in 

the future as well. The EAC Program also provided the stimulus for the state to pursue statewide 

controls on oil and gas facilities to help with ozone air quality in the Front Range area of Colorado. 

Georgia DNR 

No activities were identified. 

Louisiana DEQ 

Yes, but no activities were identified. 

Maryland DNR 

Due to the EAC Program, air quality forecasting now covers Washington County. Local businesses and 

governments now participate in ozone action day programs. 

North Carolina DENR 

The EAC led to the development of policies and projects that would not have been implemented 

otherwise. These include: a school bus anti-idling program, increased use of biodiesel, alternative 

modes of transportation, expanded bus routes, and policies requiring sidewalks and green-spaces. 

South Carolina DHEC 

Some measures in South Carolina were in the planning process prior to the new ozone NAAQS, such as 

a lawn mower exchange. However, stakeholders became interested in the initiatives because of the 

EAC Programs. 

“Capacity building”, described in the air quality context as the increased capacity of a local area to 

continue the air quality improvement effort, continues to take place in South Carolina’s EAC Program 

areas. This is beneficial because local efforts will be important to meet the new standard. 

Transportation related efforts will also be important. In this regard, South Carolina DHEC is “leading 

by example” through carpooling and other measures. These efforts are offshoots of the EAC Program. 

Tennessee DEC 

The EAC Program began with a core group of individuals. However, public participation in the 

program grew as larger numbers of people began taking voluntary efforts to improve air quality. 

Texas CEQ 

The EAC led to a range of programs that would not have otherwise occurred. These include: an 

inspection and maintenance program in Austin, Texas; cement kiln and CPS voluntary reductions in 

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San Antonio; airport emissions reductions; lawn mower trade-in programs; and retrofits with natural 

gas for compressor engines in North East Texas. 

Virginia DEQ 

The EAC stimulated offshoots such as a green building program in Roanoke. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas)

 The EAC control measures will be continued and will continue to reduce ozone. Two new regional 

activities have been implemented, a region-wide ride share website for twenty-two participating 

counties and an ozone watch/warning system implemented in conjunction with the state. 

Chattanooga-Hamilton County APCD 

The EAC activities will lead to continued reductions. The EAC led the local Air Pollution Control 

Board to collaborate more with the Health Department. This relationship will continue in the future. 

The EAC Program also helped promote greater use of greenways, bikeways and similar measures. 

Chattanooga-Hamilton County APCD continues to pursue extended bikeways. 

Denver RAQC 

The EAC Program created an awareness of ozone that will continue. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The EAC Program has created an infrastructure for further action. The EAC fostered a closer working 

relationship between state and local governments. By working together on the EAC Program, the 

different levels of government developed a level of trust that will make it easier to work together on 

future air quality issues. In addition, public awareness of air quality issues that began during the EAC 

Program continues to grow. The EAC Program also led to the creation of the SHENAIR project with 

NOAA to address air quality in the Northern Shenandoah Valley (http://www.isat.jmu.edu/shenair/). 

Greenville County, South Carolina Government 

Activities will continue because there is still a lot of room for growth. The County would like to get 

high school and college students to do PSAs. It would like to get some grant money to do a pilot 

program for PSAs and to do a statewide PSA. 

Greenville County, South Carolina Government has discussed continuing the EAC strategies. Although 

there is no longer any requirement to submit EAC reports, the County sends copies of progress reports 

to the state and US EPA under a grant requirement. The County also continues working with and 

record information from Trees Greenville and Garden Clubs on the B2

@School program. 

Aiken County, South Carolina Government (Lower Savannah) 

Lower Savannah continues to do public outreach. 

ACOG (Oklahoma City) 

Nothing yet has happened in Oklahoma City. 

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Piedmont Triad (COG) 

PTCOG believes the rate of air quality progress will continue. 

Washington County Government 

No activities were cited. 

9)	 What improvements could be made to the program to make it better? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

The resources needed to implement the EAC Program were about the same as would be required to 

reach attainment through the traditional SIP process. It is important that the EAC Program remain part 

of SIP process. The Colorado DPHE also felt that the 6-month progress reports were appropriate and 

not burdensome. 

Georgia DNR 

Georgia DNR believes that the two EAC Program areas were given too much latitude without any 

technical assistance. In retrospect, the state would have given local areas more guidance on what they 

needed to do. Georgia would have also stressed that measures adopted by EAC Program areas need to 

be local measures accompanied by local responsibility. 

Georgia DNR believes EPA needs to provide initial assistance to EAC Program areas by suggesting 

control measures to help local stakeholders get started. Georgia DNR believes EPA must also provide 

technical assistance to the EAC Program areas throughout the duration of the program. 

It is critical that the right elected officials are involved and provide leadership in the process. Georgia 

DNR believes EPA also needs to be certain that elected officials provide an authentic commitment to 

participate in the program. Even so, the turnover of elected officials provides a challenge to continuity 

of the process. The stakeholders who will be impacted by the control measures also need to be 

involved in the process. 

Georgia DNR believes the following elements have been important to the success of Georgia’s PM2.5 

focus areas: 

�	 Educate areas about the problem; 

�	 Provide areas with appropriate local control measures; 

�	 Involve all stakeholders impacted by the measures; and 

�	 Provide technical assistance and help areas stay focused on control measures that will make a 

difference. 

Georgia DNR believes the EAC Program is too resource intensive. For example, the requirements for 

the formal EAC submittal to EPA for approval were overly burdensome. In this instance, Georgia had 

to submit the following information: 1) a conceptual description of the ozone problem; 2) an emissions 

inventory; and; 3) an atmospheric modeling and attainment demonstration. The effort needed to 

compile this information took about the same amount of resources needed for an attainment SIP. 

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Georgia believes that these elements are unnecessary for a voluntary program and should not be 

required in future programs. 

Louisiana DEQ 

The EAC requirements should be eased. Due to resource constraints, less stringent modeling should be 

required. 

Maryland DNR 

The program was too heavy on process. The biannual reporting requirement was overly burdensome 

for states and localities. It added another level of pressure to state agencies. Maryland DNR submitted 

fresh reports each time rather than presenting a pro forma response. As a result, the state had to submit 

a large amount of paperwork each time. Maryland DNR emphasized that the biannual reporting 

requirement added another level of pressure to state agencies. 

EPA expectations are unclear. The state received little feedback from EPA on the progress reports. 

Although the air quality staff knew the situation was okay, other state departments and localities 

expected some type of approval or acknowledgement from EPA. To improve the reporting process, 

Maryland DNR recommends that EPA require that states complete a checklist that would be followed 

by an EPA recognition/response letter. 

The EAC Program created an uneven playing field. When the EAC Program was conceived, Maryland 

DNR already had a program in place to control emissions at the state level. However, the state did not 

get credit for it in the EAC Program as part of their base statewide control program. 

New Mexico ED 

EPA should ensure continued funding for EAC Program areas. A functioning partnership with EPA 

Regional Offices is important to a successful program. New Mexico ED also believed that the semiannual reporting was appropriate but more frequent reporting would be burdensome. 

North Carolina DENR 

More time needs to be built into the timetable to make it a more realistic schedule. One of the state’s 

biggest concerns was having enough time to have the Compact signed. In addition, the EAC Program 

works much better in smaller areas. 

North Carolina DENR made several concessions to environmentalists. The state extended its modeling 

time to cover a full 10-year period to 2017. There had been concern that the EAC Program did not 

cover a maintenance program. Although the state was required to do 5 years of modeling, it agreed to 

model for an additional 5-year period. In addition, North Carolina DENR agreed to conduct annual 

reviews for new source and VMT growth. 

Oklahoma DEQ 

EPA must provide funds for participating areas through a grant system. The grant program could 

require matching funding from recipients. Oklahoma DEQ could not have performed the ozone 

modeling needed for the EACs without funding from the state Department of Transportation. EPA 105 

funding enabled the state to develop a modeling capability but did not provide the capacity to refine the 

system for the EAC Program areas. 

111 
 

The biannual reporting requirement was worth the effort to avoid nonattainment designation. 

South Carolina DHEC 

The reporting requirement was burdensome and time consuming. In addition, the reporting procedures 

were confusing. EPA needs to develop a clearer reporting format. 

South Carolina DHEC also had problems calculating emissions reductions. It would be very helpful to 

have a computer program that conducted the calculations. With such a program in place, the state 

would not have to take so much time to develop an extensive narrative description. The program 

should be available to local stakeholders to assist with calculating emissions. This might assist them in 

their decision making as well. 

Tennessee DEC 

EPA should consider offering incentives to participate in the program. If the Clean Air Act (CAA) is 

reopened, an EAC Program should be included in the Act. In the meantime, EPA should consider 

announcing another EAC Program before or coinciding with issuance of a new nonattainment area 

boundary memo. 

Texas CEQ 

The EAC Program should be confined to just demonstrating attainment. The state felt that it was bonus 

on resources not having to do RFP or transportation conformity. With respect to timing, the EAC 

process did not match traditional or required attainment dates. In fact, the EAC process was not earlier, 

it was later. Finally, the EAC Program provided local areas more say in their “destinies.” 

Virginia DEQ 

The reporting requirements were burdensome and redundant. The need to produce bi-annual reports 

was counterproductive and took resources away from the program. Less frequent reporting would have 

the same or more value. 

Virginia had limited resources to devote to the program. EPA Region 3 did allow Supplemental 

Environmental Project money to be used for diesel retrofits. An EPA grant or loan program would help 

EAC Program areas implement local measures. For example, Roanoke is looking for grant for a 

woodstove changeout program. 

West Virginia DEP 

There were no real downsides to the EAC Program other than the reporting requirements. The biannual reporting requirement was overly burdensome for EPA regions and states. Less frequent 

reporting would accomplish the same purpose. 

EPA should provide assistance for the technical work needed to fulfill EAC requirements. The 

assistance could come through a matching grant or by providing technical resources. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

The EAC needs to remain part of a SIP to have credibility. states and local areas need an incentive to 

participate in an EAC Program. It is important that local areas retain the flexibility to develop their 

112 
own control measures. In addition, a minimum emission reduction target requirement should be 

considered to address environmental concerns. Progress reports are important but the EAC 

requirements were somewhat burdensome. An annual progress report would be preferable to the semiannual reports required by the EAC. 

Chattanooga-Hamilton County APCD 

Chattanooga-Hamilton County APCD could not think of anything that should be done to change the 

program. The County did not believe the reporting requirement was burdensome. Instead, it kept them 

focused on the program. The County did the reports cumulatively so information only had to be added 

periodically. 

Denver RAQC 

One year is too short of a time frame for SIP development. In addition, the legal issues need greater 

clarity. They are difficult for local areas to comprehend. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

The reporting requirements of the EAC Program were repetitious. A new program should have a more 

simplified reporting process. The new process should be more quantitative. A checklist may be an 

appropriate method of reporting progress. In addition, education needs to be a critical component in the 

initial stages of the program. 

Greenville County, South Carolina Government 

The reporting requirement takes a lot of paperwork and meetings to keep up with but it is not onerous. 

However, EPA should adopt a standard electronic form for the progress report for local governments to 

submit to South Carolina DHEC and from South Carolina DHEC to EPA. 

Aiken County, South Carolina Government (Lower Savannah) 

Aiken County, South Carolina Government (Lower Savannah) did not have any outstanding concerns. 

The main concern had been the difficulty EAC organizers had keeping people involved after 

improvements had been made in local air quality. However, SCDHEC sent out a letter to EAC 

stakeholders requesting their participation in PM2.5 discussions. In the letter, stakeholders became 

aware of state and federal support for the meetings and programs. It also let them know that PM2.5 is a 

regional, not just local, problem. There was a great response to the invitation. The Lower Savannah 

group is working again. There is a bigger response when SCDHEC is involved. 

ACOG (Oklahoma City) 

The EAC Program did not have the strength to get areas to choose measures. The program would be 

stronger by incorporating a percentage reduction target. This would have improved the local program. 

The Ozone Flex program is much stronger than the EAC. The EPA’s Ozone Flex Program forced 

ACOG to do much more public participation. Local businesses were more involved in the Ozone Flex 

Program. 

Piedmont Triad (COG) 

Money should be provided to local areas for administrative costs. PTCOG did not believe that the EAC 

reporting requirements were burdensome. The EAC Program had fewer reporting requirements than in 

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other situations that include EPA funding. Those situations require additional paperwork. For example, 

the EAC reporting requirements were much easier than the requirements for water quality grants. 

Washington County Government 

No areas for improvement were cited. 

10) Would you do it again? 

STATE ENVIRONMENTAL AGENCIES 

Colorado DPHE 

Colorado DPHE would participate in the EAC Program again because of the strong incentives to come 

into attainment. For example, the EAC process in the Four Corners area helped bring many 

stakeholders together, including representatives from the oil and gas industry. 

Georgia DNR 

Georgia would do the program again. The state learned a lot from this first experience and its 

collaboration with South Carolina DHEC. Georgia would like EPA to allow states to do an EAC 

Program for the 2008 ozone standard. However, in order to do the EAC Program again, the state would 

need to find a way to stretch its resources. At present, Georgia does not know how it would fund 

participation again. 

Louisiana DEQ 

Louisiana DEQ would join the program again. The state would like an EAC Program for the new 

standard to start soon so that areas can get started right away. 

Maryland DNR 

Maryland DNR’s participation would depend upon the area under consideration. Washington County 

would not participate because it became nonattainment for PM2.5. Maryland DNR would enter a rural 

area on the Eastern Shore if it received credit for its existing program to control emissions at the state 

level. 

New Mexico ED 

New Mexico ED would consider participating if the EAC Program provided funding. 

North Carolina DENR 

North Carolina DENR would join the program again because of the need to obtain emissions reductions 

from local measures. Because of the commitment to clean air in the EAC Program areas, less outreach 

will be needed to educate stakeholders for the 2008 ozone standard. 

Local areas appreciate being able to take action to fix air quality problem before being designate 

nonattainment. The EAC communities were very proactive and progressive in developing activities. 

The EAC approach elicits a more positive response from stakeholders than does the traditional 

approach. 

The state received negative reactions to the traditional process. Local areas expressed much frustration 

when the PM2.5 nonattainment designations were announced. The EPA/state simply labeled an area 

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nonattainment rather than offering to develop a collaborative approach to solving the air quality 

problem. Being designated nonattainment for PM2.5 took away the benefits that had been obtained by 

participating in the EAC. This produced a negative reaction to the EAC concept. 

West Virginia DEP 

West Virginia DEP would support another EAC in Martinsburg because the local stakeholders were 

engaged in the process. However, it may not support an EAC in other areas because of uncertainty over 

the level of local participation. 

LOCAL GOVERNMENT AGENCIES 

CAMPO (Austin, Texas) 

CAMPO (Austin, Texas) said they would absolutely participate again. 

Denver RAQC 

Denver would do the program again. 

Chattanooga-Hamilton County APCD 

Chattanooga-Hamilton County APCD would absolutely do the program again. 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah 

Valley, Virginia) 

Winchester-Frederick County Economic Development Commission (Northern Shenandoah Valley, 

Virginia) would definitely participate again. 

Greenville County, South Carolina Government 

Greenville County would participate again. The County will continue to write and distribute progress 

even if there is not another EAC Program. 

Aiken County, South Carolina Government (Lower Savannah) 

Yes, Aiken County, South Carolina Government (Lower Savannah) would participate again. 

ACOG (Oklahoma City) 

Oklahoma City would definitely participate in the EAC again. It just signed an Ozone Flex agreement. 

Piedmont Triad (COG) 

The PTCOG area would enthusiastically participate in another EAC Program. Another EAC Program 

would reflect positively on EPA’s understanding of motivation and management. 

Washington County Government 

Washington County is a rural area that never had to think about air quality. The County did not 

understand the problem or what to do because it had never been designated nonattainment for any 

pollutant. Maryland DNR encouraged Washington County to become an EAC Program Area. The 

County wanted to be proactive in addressing the problem. It also wanted to avoid transportation 

conformity. The County relied heavily on the state for technical assistance because it lacked the ability 

and necessary resources. Midway through the EAC process, however, Washington County learned it 

would have to do transportation conformity for the PM2.5 standard. 

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Washington County appreciated the EAC concept and “gentler” approach to air quality issues. The 

County did not fully understand what it was getting into before agreeing to participate in the program. 

It did not realize that the EAC would be such a labor intensive process that required more work than 

just doing conformity. If the area had been designated nonattainment, the County’s involvement would 

have been limited to attending MPO meetings to deal with conformity issues. Consequently, 

Washington County would not likely participate in an EAC Program again. It would take less effort to 

go through the traditional process. 

TRADITIONAL AREA PROGRAM DISCUSSIONS 

1)	 Is the traditional model a more or less efficient way to deliver clean air to citizens in these 

areas (versus the EAC approach)? If so, how? If not, why? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

The Rocky Mount area felt that it was unfairly designated nonattainment when EPA made designations 

for the 8-hour ozone standard. Seventy-five percent of the emissions causing the problem in Rocky 

Mount came from the Raleigh-Durham-Chapel Hill, North Carolina area. The remaining twenty-five 

percent of the emissions came from Fayetteville, NC. 

The traditional approach was not more efficient in Rocky Mount. It did not generate support for 

environmental measures in the local area. The EAC Program approach would have helped to change 

attitudes and generate local support for the program in Rocky Mount. 

Tennessee DEC 

Due to the restrictive nature of the process, the traditional model is a less efficient method of improving 

air quality. The EAC Program provides areas with the opportunity to utilize control measures that work 

best for local conditions without imposing the regulatory burden. This allows participants to buy into 

the program instead of feeling that they are being told what they must do. The collaborative dialog 

among participants provides for a more efficient method of reaching attainment status. 

Instead of following the traditional approach, five areas in Tennessee adopted voluntary EAC-type 

activities. The Chattanooga EAC developed an inspection and maintenance (I/M) program that brought 

the area into attainment. Due to the overwhelming benefits from the EAC Program, the American Lung 

Association withdrew its opposition and supported the program. The traditional route would not have 

provided an opportunity for Chattanooga to implement an I/M program. 

The selection criteria used by the EAC Program also contributes to the efficiency of the program. 

Modeling is a central part of the EAC Program process. The EAC Program only selects locations that 

demonstrate through modeling that they have the capability to come into attainment through voluntary 

measures. As a result, local areas were selected for the EAC Program if they had an opportunity for 

success. Since it would have been required under the traditional approach, the modeling aspect of the 

EAC Program is neither more nor less of a burden. The selection criteria made the EAC Program a 

more efficient approach than the traditional model. 

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LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

Rocky Mount officials could not compare the two approaches because they are not familiar with the 

EAC Program process. 

Nonetheless, it is important for a local area to have personal contact with state and federal agencies. 

Rocky Mount had good pre-existing working relationships with North Carolina Department of 

Transportation and the Federal Highway Administration. The agencies were very cooperative in 

providing needed assistance. This enabled Rocky Mount to comply with program requirements without 

difficulty. In comparison, larger urban areas may have more difficulty meeting program requirements 

under the traditional approach. 

The redesignation process takes a very long time under the traditional approach. It would be beneficial 

to local areas if the time period could be shortened. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

Knoxville went through much of the EAC Program process. At the air quality summit in 2003, the 

EAC Program process brought leaders together at an early stage to think about the consequences of 

nonattainment designation. It was very much in favor of the EAC Program from a political standpoint. 

However, the modeling came up a little short for participation in the program. Knoxville started out 

with an 8-hour ozone design value of 91 parts per billion (ppb), but the amount of voluntary reductions 

needed was too immense. If not for a severe summer with higher ozone levels, the area would have 

come into attainment. Knoxville responded by carrying through with many of the voluntary measures 

initially formulated during the EAC Program process. Consequently, it can be viewed as an area that 

went through an EAC-type process but within a traditional framework. 

The opportunity to do an EAC would be helpful but it is not known whether it would be more efficient. 

The cost of Knoxville’s program was just as much due to needed modeling and staff resources as 

required by the traditional approach. 

2) What has been the impact of the traditional approach on State and local resources? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

Rocky Mount was close to the standard and relied on existing federal and state measures to attain. 

Tennessee DEC 

The resource allocation for Tennessee’s voluntary programs was a burden but required by law. 

Modeling is a central component in the EAC Program process. The state agency paid the University of 

Tennessee $300,000 a year to conduct required modeling. However, modeling would have been 

required under the traditional approach as well. So, the modeling aspect of Tennessee’s voluntary 

program was not considered to be more or less burdensome. 

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The EAC Program process required more effort in the early stages as opposed to the heavy back 

loading of the traditional program. Although the voluntary EAC Program approach cost a little bit 

more upfront, it produced a greater yield of benefits. 

LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

The process is time consuming but it is also a great learning experience. As a result of going through 

the traditional approach, Rocky Mount officials are more sympathetic to making improvements to 

enhance air quality. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

Four local areas worked with Tennessee DEC, and independently as well, to try to create a unified SIP. 

As noted, Knoxville’s program cost the same as the traditional approach. The resource cost was 

sizeable but unavoidable. 

Because of its larger resource base, Knox County was able to do more voluntary measures. This was 

due to the large size of the metropolitan area and to the accompanying tax base that is associated with 

such a population base. 

3) Did the traditional approach require more money and resources over the EAC approach? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

In the short term, it took the state fewer resources to work with Rocky Mount under the traditional 

approach. The EAC Program process requires a lot of resources up front but has long-term benefits that 

are not realized by the traditional approach. 

Tennessee DEC 

More local resources would be required for a locally-driven EAC-type approach than for the traditional 

approach. 

LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

Rocky Mount used about five full time equivalents during the process. Officials believe that more staff 

time is required in the traditional approach. However, the resource burden was not overtaxing for the 

City. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

More local resources would be required for a locally-driven EAC-type approach than for the traditional 

approach. 

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4)	 What have been other impacts, intended or not, if any, of the traditional approach on local 

communities and State air agencies? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

Rocky Mount is an economically depressed area that is losing population and jobs. It felt stung by the 

nonattainment designation. Conversely, the EAC Program process does help areas that accept the need 

to improve air quality. 

Tennessee DEC 

The traditional approach can breed resentment. Conversely, the EAC Program motivates people by 

getting stakeholders to buy into the process. 

LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

State agencies and EPA required substantial work products. Rocky Mount conducted public hearings. 

Rocky Mount came out of nonattainment quickly. Officials felt that Rocky Mount came out of 

nonattainment more quickly than the EAC Program areas. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

Programs are easier to justify to the general public under the traditional approach. Politics are removed 

from programs when they are backed up by regulatory requirements. Under the traditional approach, 

local areas can point out that they are required by EPA (or another agency) to implement certain 

measures. It was much harder politically to implement some measures that were adopted voluntarily by 

a local area (e.g., reduced speed limits for trucks). So, it is easier to implement programs under the 

traditional approach. 

5)	 Was the traditional approach successful at engaging and involving stakeholders at the local 

level? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

The traditional approach engaged stakeholders in the Raleigh-Durham-Chapel Hill, North Carolina area 

but did not engage stakeholders in Rocky Mount. However, the state did not focus too many resources 

in Rocky Mount since it had an 8-hour ozone design value of 85 ppb when designated nonattainment. 

Tennessee DEC 

The voluntary EAC-type approach adopted by Tennessee and implemented by the Clean Air Coalition 

definitely engaged local stakeholders in areas that were required to do the traditional process. The 

voluntary approach provides incentives to local areas to participate. For example, stakeholders in the 

Knoxville and Memphis areas became involved in the hope of getting an EAC. 

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LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

Yes, the traditional approach successfully engaged and involved stakeholders at the local level. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

Knoxville did not follow the traditional approach. But, the voluntary program used by Knoxville did 

bring together county mayors, local congressmen, and various other stakeholders. 

6)	 Were there intangible outcomes from stakeholder engagement such as increasing local 

awareness that may provide for air quality benefits and better decisions in the future? 

STATE ENVIRONMENTAL AGENCIES 

Tennessee DEC 

Tennessee DEC’s voluntary program increased public awareness, built alliances, and provided for a 

dialog between stakeholders. The program also promoted behavioral changes in the public. 

LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

Industry, MPO committees on technical coordination and transportation advising, and local government 

were well engaged in the process. There was not much public participation. 

The Long Range Transportation Plan produced many benefits. Rocky Mount intends to follow the 

plan. 

The situation encouraged adjacent areas to work together by taking a multi-region approach. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

Knoxville is considered to be a college town that has many progressive-minded people. There were a 

lot of complaints that not enough had been done to improve the natural environment in the community. 

This may provide the foundation for future activities. Also, the pathway of communication between 

stakeholders is now much more open. The improved communication contributed to the formation of 

the regional clean air coalition. 

7)	 Did the traditional approach give local areas the flexibility to develop their own approach to 

meeting the 8-hour ozone standard? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

The traditional approach provides less opportunity and less incentive for local areas to develop their 

own approach. There is also less interaction between government and business in the traditional 

approach. On the other hand, the EAC Program’s powerful incentives encourage government and 

business to act more like partners. 

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Tennessee DEC 

Under the CAA there is no local flexibility in the traditional approach. In particular, section 182 of the 

CAA does not provide any flexibility. Memphis applied for and received a reclassification of its ozone 

classification but did not reach attainment. As a result, Memphis is ineligible to receive an extension. 

Knoxville is in limbo because of the uncertainty for subpart 1 ozone nonattainment areas as a result of a 

court vacature of EPA’s implementation rulemaking. 

LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

No, Rocky Mount followed the lead of North Carolina DENR, Federal Highway Administration, and 

transportation groups. Rocky Mount representatives are satisfied with this approach. Local areas 

would not know how to do it differently. It is difficult for local areas to develop alternative approaches 

to complex issues when the state already has a good approach. It is hard to have expertise at local level. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

No, but the EAC Program does. 

8)	 Are there environmental benefits as a direct result of traditional approach activities regarding 

pollutants other than ozone? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

No, the focus is on reducing ozone precursors. In the traditional approach, there are a lot more 

requirements that need to be met. The goal is to meet those minimum requirements. Conversely, the 

EAC Program is an open-minded process. There is a fundamental difference between the two 

approaches. Under the traditional approach, the state has to solve the problem. Under the EAC 

Program model, the group works to solve the problem. This leads to more innovative solutions. 

Tennessee DEC 

Under the traditional approach, the Stage I vapor recovery provided for an alleviation of air toxics. 

However, this applied to the EAC Program process as well. 

Chattanooga voluntarily asked for an I/M program that was politically unpopular but resulted in a 

Volkswagen plant coming into the area. This would not have been allowed under the traditional 

program. In addition, speed limit reductions were powerful measures but would not have been done if 

an area relied upon the traditional approach. 

The state responded to an increased interest in environmental issues by making the AQI available to the 

public. 

LOCAL GOVERNMENT AGENCIES
 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount)
 

There may be benefits for other pollutants but Rocky Mount representatives are not aware of what 

them. 

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Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

Many of the measures implemented under the voluntary approach were done for ozone but had an 

effect on PM2.5 and regional haze. 

9)	 To what extent did traditional approach activities provide for longer term emission reductions 

or create a local "infrastructure" for further or continued action in the future? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

The EAC Program approach provided these benefits to a greater extent. The traditional approach is 

more short sighted and does not get local, long-term emissions reductions. Neither Rocky Mount nor 

Raleigh-Durham-Chapel Hill, North Carolina has hired an AQ coordinator. Also, neither area has an 

AQ-focused central task force 

Tennessee DEC 

The traditional approach locks in control measures and contingency measures for an extended period of 

time. This approach also provides for continued and more concrete control measures. 

Under the voluntary approach, the state of Tennessee created a regional Clean Air Coalition to bring 

together county mayors and other influential individuals to develop a cohesive clean air plan. The 

Coalition continues to operate. It illustrates the ongoing gains from the EAC Program. 

Tennessee DEC would not have to conduct the same level of stakeholder outreach in another EAC-type 

program. Much of the groundwork has already been established. Tennessee believes that behavioral 

changes are going to be the factor that decides whether an area will be able to reach attainment in the 

future. Because lifestyle changes will be voluntary by design, the best way to encourage them is 

through an EAC-type program. 

LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

The traditional approach created a close working relationship between parties within the Metropolitan 

Statistical Area and the state. The relationship has proven to be beneficial. In addition, Rocky Mount 

learned from the experience. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

A great deal of information went out to the public during the voluntary program. This generated an 

awareness of air quality issues. Incentives were given to Knox County and Knoxville employees to 

participate in the smart trips program. The program also generated advocacy for increased bus routes, 

especially to outlying areas. In general, the process helped to lay the groundwork for programs such as 

I/M. 

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10) Will traditional approach activities result in continued reductions in ozone and air quality 

improvement activities/policies that were not foreseen at the time of designation? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

No, traditional approach activities are not expected to produce unforeseen reductions. 

Tennessee DEC 

Desulfurization will result in mercury reductions that were not foreseen. This will help out mercuryimpaired waters. 

LOCAL GOVERNMENT AGENCIES
 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount)
 

In general, public awareness of air quality issues increased. The growing awareness may lead to 

vehicle emissions reductions if the public changes personal behavior patterns by driving less or filling 

up at appropriate times. Otherwise, it may be too early to tell if unforeseen reductions will emerge. All 

measures may not be in place yet. 

Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

Most of the voluntary activities ran their course. Additional reductions will be seen with 

accompanying growth to the area. One criticism of the voluntary approach is that it keeps initial 

momentum going but falters once the initial catalyst has been removed. For example, rising gas prices 

had an initial effect but have since leveled off. Programs are permanent under the traditional approach. 

These programs generate more long-term reductions. 

11) What improvements could be made to the traditional approach to make it better? 

STATE ENVIRONMENTAL AGENCIES 

North Carolina DENR 

Before designations occur, the state should be given an opportunity to address air quality issues to see if 

problems can be solved through control measures, both at the state and local level. Those data should 

be used as the basis for designations. In addition, the CAA is punitive. The state was forced to obtain 

VOC reductions when they are unnecessary. 

Tennessee DEC 

EPA needs to write rules that will not get vacated. The heavy reliance on EPA rules that have been 

vacated has put the state in a bad situation. 

LOCAL GOVERNMENT AGENCIES 

Rocky Mount Urban Area MPO and Carolinas Gateway Partnership (Rocky Mount) 

Anything to speed up the conformity process would be beneficial. Rocky Mount representatives did 

not know how to improve the process. 

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Knox County, Air Quality Management, Department of Public Health (Knoxville, Tennessee) 

A Knoxville representative believes that politics at the federal level are immense. The traditional 

approach cannot really be changed without some major reform (e.g., Clean Air Interstate Rule and 

Clean Air Mercury Rule). Either way, local areas would find it helpful to receive guidance on how to 

implement programs under the traditional approach. 

For the EAC Program, a local area must be close to the standard to participate in the program. That is 

the key to the program. By being close to the standard, the area is predisposed to succeed. It is the only 

way to realistically expect the EAC Program to work in an area. 

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United States Office of Air Quality Planning and Standards Publicat

Environmental Protection Outreach and Information Division 

Agency Research Triangle Park, NC