1 

 

 

 

 

Recommendations to the Clean Air Act Advisory 

Committee 

Air Quality Management Subcommittee

Phase II Recommendations

June 2007
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Air Quality Management Subcommittee Final Report 

Tribute to Gregg Cooke

Gregg Cooke served on the AQM Subcommittee until his passing on September 17, 

2006. Through all of his public life Gregg sought to forge partnerships and creatively solve 

problems. Gregg was widely recognized as an air quality policy expert, respected for his 

knowledge and insight, and trusted as a partner in working to resolve many complex problems. 

The AQM Subcommittee dedicates the AQM report to him. This dedication affirms that the 

subsequent improvements in air quality management are a product of Gregg’s seemingly tireless 

efforts, his legacy to us, and to the people he so ably served. 

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Air Quality Management Subcommittee Final Report 

AQM Subcommittee Phase II Report 

June 2007 

Table of Contents 

I. Introduction.................................................................................6 

II Air Quality Management (Phase I) Work Group....................................8 

III. Current Air Quality Management System............................................9 

IV. Challenges for Air Quality Management.............................................10 

V. Approach for Phase II AQM Subcommittee.........................................14 

VI. Recommendation for a Comprehensive Air Quality Management Planning 

Process......................................................................................17 

VII. Recommendations Related to the Comprehensive Air Quality Management 

Planning Process..........................................................................21 

Recommendation 1: Improve environmental and health data........22 

 

Recommendation 2: Improve the priority setting process.................23 

Recommendation 3: Improve accountability mechanisms..............24 

Recommendation 4: Take climate change into account................26 

Recommendation 5: Support transportation and land use scenario 

planning...........................................................................30 

Recommendation 6: Integrate air quality planning into land use, 

transportation and community development plans......................35 

Recommendation 7: Encourage pollution prevention, energy efficiency and 

renewable energy................................................................37 

Recommendation 8: Expand the use of episodic controls..............40 

Recommendation 9: Overcome potential barriers to clean energy/air quality 

integration........................................................................41 

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Air Quality Management Subcommittee Final Report 

Recommendation 10: Provide incentives for voluntary and innovative land 

use, energy, and transportation approaches..............................46 

Recommendation 11: Develop programs to reduce public demand for 

polluting activities...............................................................48 

Recommendation 12: Establish an inter-agency liaison group to coordinate 

land use, energy, transportation, climate change, and air quality goals 

......................................................................................50 

VIII. Need for Tools to Address Remaining Air Quality Problems and Planning 

Needs........................................................................................53 

IX. Unresolved Areas of Discussion.......................................................61 

X. Conclusions................................................................................71 

XI. Appendices.................................................................................72 

Appendix A: Membership and Organizational Structure of the Air Quality 

Management Subcommittee..................................................73 

Appendix B: Need for Tools to Improve Air Quality Matrix and 

Needs and Tools Paper.........................................................78 

Appendix C: Proposed Framework for an Air Quality Management 

Plan..................................................................................91 

Appendix D: Letter Transmitting Final Report to EPA.................93 

Appendix E: Commentary from stakeholders..............................96

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Air Quality Management Subcommittee Final Report 

 

I. Introduction 

In March 2005, the Clean Air Act Advisory Committee (CAAAC) formed the Air 

Quality Management (AQM) Subcommittee to continue efforts to improve the air quality 

management process in the United States. The primary charge of the AQM Subcommittee was 

to develop recommendations that would improve the air quality management system and address 

the air quality challenges in this country expected over the next 10 to 20 years. This report 

addresses those challenges and includes recommendations for the United States Environmental 

Protection Agency (EPA), states, tribes, and others to improve the planning and implementation 

of air quality protection programs. The work of the AQM Subcommittee continues air quality 

improvement efforts started by: 

• The National Research Council of the National Academies of Sciences in its 

January 2004 report entitled “Air Quality Management in the United States,” and 

• The Air Quality Management Work Group, also established by the CAAAC, and 

its January 2005 report “Recommendations to the Clean Air Act Advisory 

Committee: Phase I and Next Steps.”

From May 2005 to October 2006, the AQM Subcommittee convened to discuss changes 

to the AQM system and develop recommendations. The Subcommittee had a diverse 

membership with representatives from industry, state and tribal air agencies, regional planning 

organizations, environmental and health communities, and EPA. 

 

The AQM Subcommittee recommends in this report that EPA transition its current AQM 

paradigm from a single pollutant focus to an integrated, multiple pollutant model that: 1) 

recognizes and encourages consideration of the related and sometimes conflicting national air 

quality, land use, transportation, and energy goals and policies and 2) recognizes the range of 

benefits realized by consolidating the elements of an implementing authority’s clean air program 

into one comprehensive Air Quality Management Plan (AQMP). The proposed AQMP will 

make implementation of air quality programs more effective by realizing the co-benefits of 

control measures, and creating a one-stop shop for the public and regulated entities to understand 

all of the elements of a clean air program. The change advocated in this report will require a new 

way of thinking about air quality management by federal, state, tribal, and local officials. 

Initially, AQMPs would likely be resource intensive. However, the AQM Subcommittee’s 

recommendation comes with the expectation that an AQMP will, in the longer term, lead to 

improved air quality through more efficient air quality protection strategies that utilize fewer 

resources than the current State Implementation Plan (SIP) and Tribal Implementation Plan (TIP) 

processes. Over time, the AQMP process would also enhance coordination between federal, 

state, tribal, and local governments; provide more access and transparency to the public 

regarding what its government agencies are doing to protect public health; and, serve as a 

valuable tool that identifies gaps where more needs to be done. The proposed AQMP, through 

more coordinated revision cycles, would also deliver the regulatory certainty that industry 

requires to remain competitive. 

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Air Quality Management Subcommittee Final Report 

During its deliberations, the AQM Subcommittee considered a wide range of 

recommendations and after extensive discussion is advancing a number of those for 

consideration. Most of the recommendations made by the AQM Subcommittee in this report are 

part of the overarching comprehensive AQMP recommendation. While the AQM Subcommittee 

urges that the recommendations be considered as a whole, each of the recommendations should 

be implemented regardless of whether the comprehensive AQMP approach is undertaken by a 

particular state or tribe. 

 

The recommendations in this report, if implemented, would result in improved air quality 

management by creating a more comprehensive approach that necessitates consideration of land 

use, transportation, energy, and other related issues into the air quality planning process. The 

AQM Subcommittee believes that the recommendations in this report may be implemented under 

the current Clean Air Act (CAA). 

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Air Quality Management Subcommittee Final Report 

II. Air Quality Management (Phase I) Work Group 

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

Management Work Group to evaluate the National Research Council’s (NRC) comprehensive 

recommendations and to advise EPA on ways to improve the Air Quality Management (AQM) 

system. The Work Group included representatives from industry, state and local governments, 

tribal interests, regional organizations, environmental and public health organizations, and EPA. 

In December 2004 the CAAAC submitted the Phase I AQM report which included 38 

recommendations to EPA. The recommendations fall into the five broad categories outlined in 

the original NRC report: 

(1) Strengthening scientific and technical capacity; 

(2) Expanding national and multistate control strategies; 

(3) Transforming the SIP process; 

(4) Developing an integrated program for criteria pollutants; and 

(5) Enhancing protection of ecosystems and public welfare. 

The Work Group recommended several improvements be made to the AQM system as a 

whole that would greatly increase its effectiveness. Because of the pending SIP deadlines faced 

by states for ozone, fine particles, and regional haze, the Work Group chose to make 

recommendations that could be implemented in the nearer term. The Work Group also agreed 

that it would focus on recommendations that were responsive to the issues raised by the NRC, 

but when implemented would not require statutory changes, and in many cases would not 

involve regulatory or policy changes. The Work Group also recommended that a second phase 

focusing on additional and more comprehensive improvements be undertaken. 

The Phase I recommendations are described in full in the Work Group’s Report, 

“Recommendations to the Clean Air Act Advisory Committee: Phase 1 and Next Steps,” which 

was fully adopted by the CAAAC and submitted to EPA in January 2005. In April 2005, EPA 

conveyed to the CAAAC its agreement with the recommendations, its intent to implement the 

Phase I recommendations, and to report to the CAAAC on progress. While there was unanimous 

agreement among both EPA and the CAAAC that all of the recommendations should be pursued, 

they also recognized that resource considerations would dictate the manner and time in which 

certain recommendations could be pursued and satisfied. 

Implementation of Phase I Recommendations 

EPA has completed work on many of the Phase I recommendations and is making 

progress on addressing the vast majority of the recommendations. Longer-term projects such as 

improving information through monitoring, emissions inventories, modeling; developing a 

framework for accountability; and improving ecosystem protection are moving forward and may 

take several years to complete. The Phase I report, current EPA implementation updates, and 

additional information can be found on the CAAAC website at http://www.epa.gov/air/caaac. 

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Air Quality Management Subcommittee Final Report 

III. Current Air Quality Management System 

The CAA created a framework for authorities to manage air quality, assigning different 

roles to federal, state, tribal, and local governments. The CAA requires EPA to set standards for 

“criteria” pollutants. A criteria pollutant is one of the six pollutants that EPA has found to 

damage public health and the environment, for which EPA has set National Ambient Air Quality 

Standards (NAAQS). While other pollutants can cause such damage, there are only six for which 

EPA has set this type of standard. 

There are two types of NAAQS, primary and secondary. Primary standards are set to 

protect public health with an adequate margin of safety, including the health of "sensitive" 

populations such as asthmatics, children, and the elderly. Secondary standards are set to protect 

public welfare, including protection against visibility impairment, damage to animals, crops, 

vegetation, and buildings.1

 For the criteria pollutants, EPA and states designate those geographic areas that 

experience unhealthy levels of those pollutants. Once an area has been designated as out of 

compliance (nonattainment) for a particular NAAQS, state and local governments are 

responsible for implementing and enforcing rules that reduce air pollution. The responsible state 

or local government has three years to develop a body of rules that will lower pollution in order 

to comply with (or attain) the standard. States use computer-based modeling to show 

(demonstrate) that the body of rules (collectively called a SIP) will bring about compliance with 

the standard (attainment). Tribes may develop Tribal Implementation Plans (TIP) to address the 

NAAQS in Indian Country. In areas where tribes choose not to develop a TIP, EPA is 

responsible for implementing the program in Indian Country. Once EPA approves the SIP or 

TIP, it has the force of federal law. States and tribes retain primacy for developing and 

implementing the SIPs and TIPs, thus allowing them to tailor air quality approaches to their 

individual local or regional concerns. 

Aside from setting the standards, EPA has additional roles. EPA issues national rules that 

reduce pollution throughout the country, such as on cars and trucks. EPA also issues procedures 

and guidance to ensure consistency and certainty to states and tribes as SIPs and TIPs are 

developed and implemented. EPA then reviews SIPs and TIPs and approves them when they 

meet federal requirements, or takes action when plans are inadequate or not submitted. On 

occasion EPA must take action when mandated progress goals are not met within the required 

timeframes. EPA may also enforce state or tribal programs that are included in a SIP or TIP, if 

for some reason a state or tribe fails to do so. As required or appropriate for pollutants other than 

criteria pollutants, EPA may issue national emission control programs such as the maximum 

achievable control technology (MACT) standards for stationary sources of hazardous air 

pollutants. 

 

Air Quality Management in the 21st Century 

While much progress has been made in air quality management, the Subcommittee sees 

clear need for improvement. The NRC report identifies a number of significant challenges that 

 

1

 http://www.epa.gov/particles/standards.html 

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Air Quality Management Subcommittee Final Report 

require a more comprehensive perspective, new and improved tools, and innovative strategies. 

Addressing these challenges will help ensure future progress and keep pace with meeting current 

and future clean air goals. 

Presently, EPA, states, tribes, and local agencies are well underway in their efforts to 

achieve the NAAQS. EPA has continued efforts to routinely review the NAAQS as required 

under the CAA. In 2006, EPA revised the particulate matter (PM) standards and is currently 

reviewing the standards for ozone, lead, nitrogen oxides, and sulfur oxides. Such reviews 

underscore the need for a dynamic air quality planning strategy approach. 

The Phase I recommendations by the CAAAC along with the Phase II recommendations 

in this report are designed to assist EPA and state, tribal and local agencies to improve air 

quality, protect public health, and protect the environment. Not only will it enable agencies to 

achieve the NAAQS, but it also aims to take a more holistic multipollutant approach, including 

reducing air toxics and greenhouse gases. 

IV. Challenges for Air Quality Management – A Look Ahead 

The economic and societal activities that generate air pollution continue to grow. Despite 

this growth, air quality management programs in the United States have made significant 

progress in several key areas. Concentrations of key pollutants have improved considerably in 

much of the country. This progress has resulted in substantial public health benefits, economic 

savings, ecosystem protection, and improved aesthetics during a period of growth in the 

economy, energy production, vehicle use, and population. 

A number of serious AQM challenges persist, especially areas that continue to have 

public health and nonattainment problems with ground-level ozone and particulate matter. There 

is also a heightened awareness and concern over exposure to air toxics, increasing levels of 

pollution transported from abroad, ecosystem effects, and effects of air pollution on visibility in 

and near national parks, effects of air pollution on climate change, and the feedback effects of 

climate change on air pollution. The AQM Subcommittee believes that to be more effective, 

future air quality management should address all of these challenges in a more holistic manner. 

Nonattainment Problems: Ground-level Ozone and Particulate Matter 

Following the anticipated emissions reductions from implementing the federal SIP Call 

for Nitrogen Oxides (NOx), the Clean Air Interstate Rule (CAIR), federal mobile source rules, 

existing state and tribal air pollution control programs, and existing local initiatives, federal air 

quality modeling suggests that a number of areas, especially heavily populated areas, will 

continue to violate the current NAAQS for ground-level ozone and PM (See Figure 1). The 

number of nonattainment areas is expected to increase in light of the more protective 2006 fine 

particles (PM2.5) standard. The geographic scope and number of nonattainment areas is also 

expected to increase if a new, more protective ozone standard is promulgated. 

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Air Quality Management Subcommittee Final Report 

Area Count

3

14

8

104

Legend

Both PM and Ozone Nonattainment

PM Only Nonattainment

Ozone Only Nonattainment

Nonattainment areas projected to attain

Area Count

3

14

8

104

Legend

Both PM and Ozone Nonattainment

PM Only Nonattainment

Ozone Only Nonattainment

Nonattainment areas projected to attain

Figure 1. Areas Projected to Exceed the PM2.5 and 8-hour Ozone Standards in 2015 with 

Clean Air Interstate Rule (CAIR), Clean Air Mercury Rule (CAMR), and the Clean Air 

Visibility Rule (CAVR) Absent Additional Local Controls. 

Nonattainment areas are of particular concern, given the increased evidence linking 

ozone and PM exposure to a wide range of serious human health effects. In addition to the longrecognized effects of ozone on lung function, more recent scientific studies have linked ozone to 

increases in mortality (especially among the elderly), hospital admissions for respiratory ailments 

(particularly children), school absenteeism, and incidence of asthma. 

The most recent scientific information on the health and environmental effects of 

particles, ozone, and related precursor pollutants suggest that the NAAQS will likely remain at 

current or more restrictive levels in the foreseeable future. Developing strategies to attain and 

maintain these standards over the long term poses a significant challenge, especially in light of 

growth that is expected to continue. New and innovative strategies will likely be needed to 

achieve reductions from emissions sources that have the potential for cost-effective reductions, 

such as marine vessels, locomotives, existing legacy fleets and off-road vehicles, as well as 

under-controlled and “grandfathered” industrial facilities. It could also include instituting 

additional transportation control measures to address increased vehicle use and initiating local 

and regional planning efforts to engage in a more holistic approach to air quality management. 

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Air Quality Management Subcommittee Final Report 

Air Toxics 

Historically, the AQM system has not allocated the same level of resources to air toxics 

control and management efforts as compared to criteria pollutants. While the air toxics 

standards, ozone, and PM programs have yielded reductions of a number of toxic components 

and precursor pollutants, air toxics problems continue to exist on local, regional, and even global 

scales. The NRC report and EPA’s most recent National Air Toxics Assessment (NATA), 

suggests a background cancer risk associated with air toxics for much of the nation between 1 to 

25 in one million, with much of the risk being attributed to benzene.2

A growing body of evidence suggests a potential overlap between air toxics and PM. The 

overlap creates potential exposure and health effects concerns for populations that spend 

significant time on or near heavily-traveled roadways. This issue may be related to direct 

localized emissions of particles, organic or inorganic gaseous tailpipe emissions, or toxic 

subcomponents. While exposure to air pollution along roadways is the subject of ongoing 

research, EPA and states also need to focus on strategies to deal with “hotspots.” Air quality 

planning for localized areas will require innovative management techniques that could include 

transportation planning, city planning, and a variety of mitigating actions. 

Other Effects of Air Pollution/Interactions

Air quality management, in addition to addressing the lingering nonattainment problems 

for ozone and PM, and air toxics problems, should include consideration of the interplay between 

air quality objectives and other policies such as national land use, energy, transportation, and 

climate. These other programs are intertwined with air quality policies and programs and 

sometimes may cause increases in air emissions that make meeting air quality goals more 

difficult. Similarly, air quality policies and programs may conflict with land use, transportation, 

and energy goals. Where possible, the AQM Subcommittee recommends that these programs be 

better aligned and function more effectively. 

A similar interplay can exist between air quality and climate change. Climate change can 

influence the concentration and distribution of air pollutants through a variety of direct and 

indirect processes, including: (1) temperature increases and decreases which affect biogenic 

emissions, atmospheric water vapor content, and the reactions forming ground-level ozone and 

PM; and (2) altered weather patterns that affect wind speed and direction, vertical mixing, 

precipitation, lightning frequency, and clouds. Particulate matter emissions have direct effects 

by scattering and absorbing heat. The scattering of heat generally means that PM has a cooling 

effect. Particulate matter also interacts with clouds, thereby indirectly affecting climate. Indirect 

effects arguably represent the greatest uncertainty in our understanding of PM effects on climate. 

During the past several years, many cities and states have initiated actions to reduce 

greenhouse gases. To date, 41 states and Puerto Rico have completed greenhouse gas 

inventories and 28 states and Puerto Rico have completed, or are working on, action plans that 

identify options for reducing greenhouse gas emissions or enhancing greenhouse gas 

sequestration. Over 300 mayors representing more than 50 million Americans have signed the 

 

2

 http://www.epa.gov/ttn/atw/nata1999/natafinalfact.html 

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Air Quality Management Subcommittee Final Report 

U.S. Mayors Climate Protection Agreement that commits cities to take action to meet or exceed 

the Kyoto Protocol targets3

. The AQM Subcommittee believes that a number of cities and states 

are interested in integrating air quality planning with their climate change programs. For 

example, California has established greenhouse gas standards for passenger vehicles beginning 

with the 2009 model year. Several Northeast and Western states have also adopted these 

California measures. In addition, eight northeast states (CT, DE, ME, NH, NJ, NY, RI and MD) 

participate in the Regional Greenhouse Gas Initiative (RGGI) to reduce greenhouse gas 

emissions from the electric generating sector through a cap and trade program, and they have 

issued a model rule. Two northwest states, Oregon and Washington, are also considering similar 

greenhouse gas control initiatives. 

Environmental Effects 

Prior to the 1990 CAA Amendments, federal, state, tribal, and local air quality 

management programs focused on health-based programs. The U.S. Congress amended the CAA 

in 1990 to enhance the health-based programs, including setting a new national air toxics 

program, programs to address visibility, and reductions in pollutants that cause acid rain. The 

programs mandated by Congress in the 1990 CAA Amendments resulted in substantial 

reductions in emissions of air toxics, sulfur oxides, and nitrogen oxides. EPA has launched 

research on ecosystem health and the CAA contains requirements for secondary standards for 

certain criteria pollutants to protect public welfare, including the environment. The 2004 NRC 

report recommended establishing ecosystem protection as an AQM priority. In addition, the 

NRC suggested the need for more monitors to measure ecosystem health, improved 

meteorological and exposure models, risk assessment research, and researching the interplay of 

ecosystems with factors such as air quality, climate, and topography. 

 

3

 For more information visit http://usmayors.org/climateprotection. 

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Air Quality Management Subcommittee Final Report 

V. Approach for Phase II AQM Subcommittee 

Air Quality Management Subcommittee and Phase II Process 

In its Phase I recommendations, the CAAAC recommended that a new subcommittee be 

established to continue the assessment and development of recommendations for long-term 

changes to the air quality management system. It recommended that discussion of all remaining 

issues and options be directed towards further strengthening the U.S. air quality management 

framework over the next decade. 4 

In response to this recommendation, the CAAAC established the AQM Subcommittee in 

March 2005. The AQM Subcommittee was charged with developing Phase II recommendations 

for long-term systemic changes to the AQM system and with monitoring EPA’s implementation 

of the AQM Phase I recommendations. As with the original AQM Work Group, the 

Subcommittee’s membership was comprised of representatives from industry, state, tribal and 

local governments, regional organizations, environmental and public health organizations, and 

EPA. The list of Subcommittee members and other participants can be found in Appendix A of 

this report and is available at the CAAAC website at http://www.epa.gov/air/caaac/aqm.html. 

The AQM Subcommittee established two teams to facilitate data collection efforts and 

develop recommendations. The first team was charged with evaluating improvements to the 

AQM process. This team focused on three areas: 1) problem definition and priority setting; 2) 

the AQM planning process; and 3) strategies for improved coordination and communication. The 

second team was charged with examining and developing tools to support state, tribal, and local 

agencies to improve air quality. An organizational chart is provided on page 76 of this report. 

 

The AQM Subcommittee deliberated on recommendations developed by both teams. The 

Subcommittee reached agreement on many of the recommendations; for other recommendations, 

substantial consensus could not be reached. In addition, the Subcommittee spent considerable 

time and effort on two significant overarching areas for improvement: 1) developing a 

comprehensive AQM planning process; and 2) establishing a revised process for setting 

nonattainment boundaries. 

In October 2006, the AQM Subcommittee reached agreement on recommendations to present 

to the CAAAC. Where there was not substantial consensus on proposed recommendations (i.e., 

reasonable performance levels, continuous improvement, and the process for setting 

nonattainment boundaries), the Subcommittee decided to document discussions where 

substantial consensus could not be reached. (see Section IX of this report). In January 2007, the 

Subcommittee presented draft Phase II recommendations to the CAAAC. 

 

4

 CAAAC, Air Quality Management Work Group. January 2005. Recommendations to the Clean Air Act 

Advisory Committee. http://www.epa.gov/air/caaac/aqm/report1-17-05.pdf 

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Air Quality Management Subcommittee Final Report 

Decision Making Process 

Prior to drafting recommendations, the AQM Subcommittee agreed to use substantial 

consensus as the means for deciding which recommendations to adopt and forward to the 

CAAAC. Using this process, the AQM Subcommittee achieved substantial consensus on the 13 

recommendations presented in this report. However, the Subcommittee found that it was unable 

to develop consensus on a few recommendations that would have substantial regulatory impact. 

Such proposals, such as the ones listed in the Unresolved Areas of Discussion section below, 

often require tradeoffs. For example, a stricter standard could be balanced with a longer period 

of repose. The Subcommittee found that this forum did not allow for such specific 

considerations. 

Recommendations on Changes to the Air Quality Management System 

The recommendations contained in this report represent the AQM Subcommittee’s vision of 

a comprehensive AQM system that can assist in meeting future air quality challenges in this 

country. 

 

As such, the AQM Subcommittee is making an overarching recommendation for taking a 

holistic approach to AQM through utilization of a more comprehensive planning process. The 

Subcommittee is making 12 additional recommendations that serve as integral components of 

this improved process. Though these recommendations work together, each should be 

considered on its specific merits and implemented regardless of the extent to which a 

comprehensive AQM plan is implemented. 

The AQM Subcommittee considered recommendations based on their merit, separate from 

consideration of whether current statutory authority supports them. Tremendous progress has 

occurred as a result of the CAA as it exists today, and the Subcommittee believes that changes to 

the CAA are unnecessary to implement the Phase II recommendations in this report. In 

particular, it is important to note that the primary recommendation – to establish a 

comprehensive AQM process – would be voluntary. This recommendation is intended to 

provide a vision for states, tribes and local governments, as well as EPA, to enhance clean air 

planning by being more proactive and comprehensive. 

Unresolved Areas of Discussion 

The Subcommittee discussed at great length three AQM system changes on which the 

members were unable to reach substantial consensus: (1) boundaries, (2) reasonable 

performance levels, and (3) continuous improvement. The areas are highlighted here and are 

discussed at greater length in Section IX of the report. 

With respect to boundaries, the AQM Subcommittee was in substantial agreement on two 

concepts related to boundary setting, and achieved consensus on a set of principles to guide the 

development of a new approach to establishing boundaries. The Subcommittee agreed on the 

need for an airshed approach to boundaries and on the need to replace the current system with an 

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Air Quality Management Subcommittee Final Report 

approach where areas that violate NAAQS and areas where controls are needed are defined 

independently based on scientific assessments. The Subcommittee also agreed that control areas 

should encompass all significant contributors to the NAAQS violation, without regard to state, 

tribal, or other geo-political boundaries, such that by controlling emissions from the sources 

included within the control area boundary, timely attainment of the NAAQS will be assured. 

The AQM Subcommittee could not, however, reach agreement on the details of how these 

concepts and the underlying principles should be implemented. 

The Subcommittee considered a concept called “reasonable performance levels” (RPL). 

It is based on the idea of treating airsheds as a finite and essential resource, and sources are not 

entitled to pollute. The RPL approach would require all categories of air pollution to take steps 

to limit their emissions. RPLs would be established and periodically updated for all air pollution 

sources and all pollutants, beginning with the sources and pollutants that pose the greatest risk to 

public health and ecosystems. The RPL approach would provide a foundation for additional 

controls that might be needed to address existing or potential area-specific problems. For 

example, due to transport issues from upwind sources implementing RPLs, an area may still 

violate a NAAQS. Under these circumstances, attainment SIPs with specific deadlines may still 

be needed to protect public health. An RPL program would likely require amendments to the 

CAA. Several Subcommittee members supported this concept as a recommendation, but several 

Subcommittee members had significant concerns that prevented substantial consensus of this 

recommendation. 

Finally, the Subcommittee discussed the concept of “continuous improvement.” The idea 

is defined as continuous improvement in emissions reductions from all stationary, mobile and 

area sources that would lead to continuous air quality improvement in all geographic regions of 

the nation. The improvements would be achieved via a combination of mechanisms, including 

voluntary programs at the local level, continued use of a national program of command and 

control emission standards, and several options for strengthening and enhancing various marketbased programs to encourage continuous improvements. The goal of Subcommittee members 

who developed the concept was to design a program that would result in more efficient and cost 

effective reductions of emissions associated with manufacturing and energy generation, while 

maintaining or improving environmental and/or public health conditions. The AQM 

Subcommittee members had a wide range of disagreement about this concept. Some 

Subcommittee members supported the concept. Others felt the proposed options lacked certainty 

and were cost prohibitive if there was no related limit. They also saw the programs as redundant 

with programs yielding reductions achieved through the NAAQS and national emission 

standards. 

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Air Quality Management Subcommittee Final Report 

VI. Recommendation for a Comprehensive Air Quality Management Planning Process 

The AQM Subcommittee makes the following overarching

recommendation for improving the current AQM system: EPA, states, 

local governments, and tribes should adopt a comprehensive AQM 

planning process and, through this process, create plans to move from a 

single pollutant approach to an integrated, multiple pollutant approach to 

managing air quality. 

The NRC report noted that an integrated, multiple pollutant approach to managing air quality 

would be more effective, efficient and timely than the current pollutant-by-pollutant approach. 

The concept of a comprehensive air quality management plan, or AQMP, is to provide a 

framework that could be used to integrate analysis, planning, and implementation of air quality 

management programs. 

The AQMP would be developed at the discretion of the state, tribal, or local government, or a 

multijurisdictional organization that is responsible for dealing with air quality issues in a 

geographic area. The plan would outline how a jurisdiction(s) intends to address air pollutants in 

an integrated manner, including, but not limited to, attainment and maintenance of the NAAQS, 

sector-based reductions of criteria pollutants and air toxics, improvements for visibility in Class I 

areas, area-wide strategies for reducing air toxics, ecosystem protection, and local environmental 

issues. The AQMP would document the critical planning process and decisions made. Because 

the AQMP would be developed on a voluntary basis at the discretion of the state, tribal, or local 

governments, or a multijurisdictional organization, only the CAA mandated components 

contained in the AQMP (e.g., the SIP) would be required to be submitted to EPA. 

Development of an AQMP is envisioned by the Subcommittee as a broad, iterative process 

that would reflect significant interaction between all stakeholders at the state, tribal, local and 

regional levels, as well as the full range of affected parties. Issues that relate to air quality, such 

as energy policy, climate change, transportation, and land use should, to the extent possible, be 

considered in a comprehensive AQMP. The goal would be to create a comprehensive plan that is 

multipollutant based, addresses all of the critical air pollution issues within the jurisdiction, 

focuses on other important air quality goals in the geographic area, sets priorities, and provides 

an overall plan for moving forward with the strategies outlined in the plan. The AQMP also 

should be revised periodically (e.g., every five to 10 years). 

At the same time that initial AQMPs are under development, EPA, and, as appropriate, the 

states should be developing multipollutant regulations. This concept affirms a recommendation 

from the NRC that EPA should address multiple-related pollutants in parallel. 

 The NRC encouraged a new approach in the steps and processes in setting the NAAQS that 

could result in better coordination of deadlines and would facilitate the development of 

multipollutant AQMPs. While the AQM Subcommittee agrees that better aligned deadlines 

between various NAAQS revisions and their subsequent SIPs/TIPs could maximize planning 

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Air Quality Management Subcommittee Final Report 

efforts, any alignment should not result in the delay of any CAA mandated deadline. Finally, the 

NRC also recommended that the hazardous air pollutants that pose the highest risk to human 

health and welfare be included in multipollutant AQMPs.5

 

Benefits of AQM Development 

The AQM Subcommittee achieved broad consensus on the concept and desirability of a 

comprehensive AQM planning process and associated AQMP. The Subcommittee proposes a 

framework for the plan which incorporates federally required elements for criteria pollutants 

(State Implementation Plan elements) and non-SIP elements (e.g., MACT standards) in addition 

to elements that are not federally required such as local planning, growth forecasts, and 

communication strategies. The framework found in Appendix C provides a proposed structure 

that a state, tribe, local government and/or multijurisdictional organization could use when 

developing an AQMP. 

 The merits of preparing an AQMP include: 

• Relationships between federal, state, tribal, and local governments would be enhanced 

through the coordinated planning effort; 

• The public would have greater access to air quality information and greater ease in 

participating in the programs to manage air quality via centralization of one easy-toaccess plan; 

• The role for local governments and multijurisdictional organizations in air quality 

planning would be facilitated; 

• The AQMP would be a valuable tool that highlights gaps where more air quality planning 

needs to occur; 

• The AQMP could initiate a process to coordinate multiple emission requirements and 

deliver regulatory certainty, enabling industry to optimize emission control decisions; and 

• The AQMP would better enable the selection of effective control strategies. More 

effective control strategies would insure that in the process of reducing a pollutant, 

increases in one or more other pollutants do not occur. 

The AQM Subcommittee agreed that states and tribes should not be required to develop an 

AQMP. Instead, the benefits of having an AQMP, coupled with new and expanded incentives for 

developing these plans, could provide sufficient motivation for a jurisdiction to prepare an 

AQMP voluntarily. The comprehensive AQMP recommendation does not contemplate changes 

to the CAA with respect to the NAAQS or air toxics standards or processes. 

Resources, Incentives, and EPA Oversight 

Two major issues were identified by the Subcommittee that would need to be addressed 

before most areas could consider developing and implementing an AQMP. First is the issue of 

resources, including staff time and funds to implement comprehensive planning. The second 

 

5

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

Press, 2004), p. 21, 310. 

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Air Quality Management Subcommittee Final Report 

issue is EPA oversight; for example, the extent to which a state that develops an AQMP would 

be required under the CAA to secure EPA approval of plan revisions. 

The AQM Subcommittee suggested that EPA consider the following incentives: 

• Offer in-kind resources from EPA staff to assist in developing the AQMP; 

• Streamline the SIP and TIP process through measures like parallel processing; 

• Provide states and tribes with flexibility to place a lower priority on administrative 

obligations that achieve little in terms of public health protection for air quality 

improvement. Instead, those resources could be devoted to activities that enhance public 

health protection, which could constitute an appropriate “trade-off.” For example, Title 

V sources are required to undergo two sets of reviews for federal and state approvals. If 

EPA were to merge its review of Title V permit actions with state Title V permit notice 

and public review processes, significant state, federal, and permittee time and resources 

could be saved; and 

• Explore CAA section 110 authorities for the purpose of providing support for the 

development of AQMPs. Such support could include expedited EPA approval of 

regulatory measures that have been adopted or are in the process of approval by a state or 

tribe outside of a nonattainment area, but would benefit the area in attaining the 

standards. 

These incentives would provide motivation for an area to commit resources to the 

development of an AQMP. The Subcommittee recommends that EPA fully assess the 

implications and options related to these incentives including, but not limited to, the legal 

implications, the impact on inter-state obligations/expectations, the basis for approval, and the 

need for consultation with various stakeholders. 

EPA has broad authority to prescribe what is included in a SIP or TIP to decide which 

proposed actions are acceptable and to determine when revisions to the SIP/TIP are consistent 

with CAA requirements. The NRC noted in its report that the current planning system has 

significant flaws. The AQM Subcommittee believes that these flaws could be minimized with 

implementation of the AQMP recommendation. Regarding EPA’s oversight, the AQM 

Subcommittee recommends that a state or tribe would need to submit only the provisions of the 

AQMP that are federally required and would include in the submission evidence that the state or 

tribe has developed a comprehensive AQMP.

The current CAA emphasizes a pollutant by pollutant approach for criteria pollutants, and a 

source sector-based approach to regulating air toxics. The AQM Subcommittee believes that a 

multi-pollutant approach to air quality management can function within the framework of the 

current CAA and it offers several advantages. These advantages may include: 

• Reaching attainment in a more cost-effective, efficient way, thus reducing public health 

and ecosystem impacts, while yielding greater overall reductions of pollutants;

• Optimizing the mix of control measures for multiple pollutants, thus avoiding control 

measures that, while beneficial in reducing one pollutant, may result in increases in 

others;

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Air Quality Management Subcommittee Final Report 

• Making better use of limited federal, state, tribal, and local resources, and those of the 

regulated community, for improving air quality;

• Providing a more proactive, predictable, and manageable air quality planning process; 

and

• Making it easier and less expensive for potentially affected sources to plan the 

installation of controls and/or the implementation of process changes, rather than having 

to install controls in a piecemeal fashion. 

In addition, the AQMP would provide a formal mechanism for providing the public with a 

comprehensive picture of air quality where they live. It would also show how state agencies, 

tribes, local governments and multijurisdictional organizations are working together and in 

coordination with EPA to protect public health and ecosystems. Moreover, the AQMP would 

help to highlight to the public and government decision-makers where there may still be 

significant air quality issues that need to be addressed and raise the profile of these issues for 

consideration for further action. 

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Air Quality Management Subcommittee Final Report 

21 

 

VII. Recommendations Related to the Comprehensive AQM Planning Process 

 In addition to the overarching recommendation related to the AQMP, the AQM 

Subcommittee is making 12 supporting recommendations to expand on the concept of the 

comprehensive air quality management process. The Subcommittee believes that these 

recommendations will lead to improvements in how information is gathered and analyzed, how 

air quality management strategies are developed, and how the strategies are implemented. The 

Subcommittee realizes that many decisions remain regarding how changes in the air quality 

management system will evolve, but that the recommendations in this report should be 

implemented regardless of whether a state, tribe, or local agency implements a comprehensive 

AQM planning process and an associated AQMP. 

A comprehensive AQM system must address three principle components: assessing current air 

quality, air quality management planning, and implementing air quality strategies. 

 

Figure 2: The Air Quality 

Management System is 

comprised of three iterative 

steps: 1) Assessing Current Air 

Quality; 2) Air Quality 

Management Planning; 3) 

Implementing Air Quality 

Strategies. 

Air Quality 

Management 

Planning 

Assessing 

Current Air 

Quality 

Implementing 

Air Quality 

Strategies 

Assessing Current Air Quality 

The AQM Subcommittee is making the following four recommendations related to assessing 

current air quality (Recommendations 1 through 4). The recommendations are based on the 

premise that a comprehensive AQM needs to include programs to assess current air quality 

impacts on public health and ecosystems and a means by which the effectiveness can be 

measured. 
Air Quality Management Subcommittee Final Report 

Recommendation 1: Improve environmental and health data - Improve the 

accuracy, robustness, and availability of environmental and health data (1) to 

enable more complete characterization of air quality, emissions, and 

environmental and health outcomes and (2) to facilitate the assessment and 

characterization of relative risks. 

Background/Explanation: 

To meet future air quality management needs and to help air quality planning agencies 

prioritize those needs, the supporting data must be continuously improved. Scientific 

advancements continue to improve our understanding of air pollution and its impacts on 

public health and the environment. Several of the following recommended actions are 

expansions of recommendations that were made in the Phase I AQM report, 

“Recommendations to the Clean Air Act Advisory Committee: Phase 1 and Next Steps” 

(January 2005) and will improve the quality of the data that help inform air quality 

management decisions. 

Recommended Actions: 

A. EPA, states, tribes, and others should work to improve air quality data by continually 

improving air quality monitoring networks to collect data on pollutants of concern, in 

areas of concern. 

B. Fill in the information gaps and continually improve emissions inventories and air quality 

modeling. 

C. EPA should improve the information on health endpoints and on the relative risk of 

exposure to single and multiple pollutants, at both the population and individual level. 

D. Air quality planning agencies should improve the coordination and communication 

between environmental groups, governmental agencies and external stakeholders, 

including health agencies, academic institutions, and the medical community. 

E. EPA should improve the collection of control and cost data to facilitate analysis of 

projected and actual implementation costs for major regulations. 

 

Benefits: 

• Improved air quality data and information will improve decisions related to control 

strategies. 

• Better environmental and health data will enhance the ability of governmental agencies to 

evaluate the results of implemented strategies and to make changes as needed to improve 

air quality resulting in improvements to public health and the environment. 

• Improved communication between multiple parties will help ensure that information is 

shared and used to enhance program results. 

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Air Quality Management Subcommittee Final Report 

Recommendation 2: Improve the priority setting process - Improve the priority 

setting process by creating mechanisms to systematically realign resources and 

regulatory focus toward areas of greatest health and environmental risk. 

Background/Explanation: 

To address current and future air quality issues, the AQM system should be realigned to 

more effectively address the interaction of multiple pollutants. While some progress has 

been made in addressing some multi-state transport of air pollution, transport issues still 

need to be identified and proactively addressed. In addition, urban areas have a mix of 

emissions that may be more appropriately addressed in a multipollutant fashion than on an 

individual pollutant by pollutant basis. 

Problem/Challenges Addressed: 

• Ability to address new priorities promptly. 

• Identification and assessment of most significant exposures and problems. 

• Integration of a multipollutant approach. 

Recommended Actions: 

A. EPA should use the updated information provided by the state, tribal, and local air 

agencies in AQM planning to develop national regulatory priorities. EPA should also, 

through modeling and monitoring, help define problems that occur on a national scale 

that can be used to support state and tribal plans. 

B. EPA should start discussions with the Centers for Disease Control (CDC) and state health 

agencies to determine if it is feasible to produce an air quality health trends report. The 

report would attempt to link changes in ambient air quality to health data on a five-year 

cycle, using the best available information while recognizing the limitations of those data. 

C. EPA, the Federal Land Managers, and other agencies, working with the states, tribes, and 

local agencies should report on links between ambient air quality and the health of 

ecosystems on a five year cycle, using the best available information while recognizing 

the limitations of that information. 

D. EPA and other stakeholders should strengthen the link between improved science and 

improved policy by developing new mechanisms to encourage more rapid adjustment of 

policy priorities in the face of new scientific information. EPA should investigate 

mechanisms (incentives and hammers) to encourage the realignment of regulatory 

priorities and implementation efforts to deal with the highest priority problems, both 

within the Agency and among implementing authorities.

Benefits: 

• The additional consideration given to pollutant interactions will produce a more 

comprehensive approach to improving air quality than the current process. 

• Using updated information to develop national priorities will allow state, tribal, and local 

agencies to better align and shift resources to areas of higher priority.

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Air Quality Management Subcommittee Final Report 

• An air quality health trends report will lead to improved communication with the public 

on public health impacts from poor air quality.

• New regulatory programs can be adapted that improve the linkages between emissions 

and public health and ecosystem impacts.

Recommendation 3: Improve accountability mechanisms - Improve 

accountability by systematically monitoring progress and evaluating results, by 

ensuring that data collection is meaningful and that feedback loops exist so actual 

environmental results inform the future allocation of resources and the 

establishment of priorities. 

Background/Explanation: 

The AQM system must include an ongoing process for accountability, evaluating progress 

and developing ways to make adjustments in activities and resource allocations based on the 

success or failure of existing programs. Part of this process involves continuing investments 

in technical tools, such as modeling, monitoring, and emissions inventory capabilities, to 

ensure decisions are informed by the best possible information. AQM Phase I focused on 

needs in this area. In addition, it is important to evaluate program performance relative to air 

quality and cost-benefit goals, and to adjust program efforts and priorities accordingly. 

In the past, EPA has had difficulty shifting resources and establishing programmatic 

momentum in the face of new problems. For example, EPA first promulgated a fine particle 

national ambient air quality standard in 1997 after evaluating available health data that 

indicated fine particles posed a significant health risk. However, attainment and 

nonattainment designations were not effective until April 2005, the SIPs are not due until 

2008, and the first attainment deadlines are due in 2010. States have little discretion in how 

they devote SIP development resources. States and tribal air agencies are trying to integrate 

planning and reduction programs in a multipollutant framework. However, the rigid statutory 

structure and unaligned deadlines make it difficult. 

Even when targeted programs are developed to tackle a specific problem, measuring 

progress accurately and assuring that the programs are actually reducing the targeted 

pollutants and improving public and ecosystem health can be difficult. Current ways of 

measuring progress are slow and, in some cases, not very accurate. 

The current system is extremely cumbersome when faced with new information about health 

and air pollution priorities, no matter how compelling the evidence. 

Problems/Challenges Addressed: 

• The need to be able to address new priorities promptly. 

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Air Quality Management Subcommittee Final Report 

• Lack of confidence in the effectiveness of pollution reduction programs because of weak 

accountability systems (and therefore potential lack of support for continuing or future 

programs). 

• Evaluation of the effectiveness of controls and adjustment as necessary. 

Recommended Actions: 

A. EPA should make information available to the Clean Air Science Advisory Committee 

(CASAC)6, state, tribal, and local agencies, and the public on an ongoing basis about 

significant new research and studies on the health, welfare and ecosystem impacts of air 

pollution. Provide a summary of significant new studies annually to the CASAC and to 

the CAAAC. Provide notice in the Federal Register as to the availability of this summary 

and prominently display the summary on EPA’s website. 

B. EPA and other regulators should include metrics and schedules for tracking progress 

within programs and rules at the time they are initiated. Using these metrics, EPA and 

state, tribal, and local agencies should evaluate the progress that is being made under 

various regulatory control programs by assessing compliance rates, actual reductions 

achieved, and cost-benefit analysis. EPA and other stakeholders should improve the 

collection of control and cost data to facilitate analyses of projected and actual 

implementation costs for major regulations, as follows: 

a. EPA should develop an improved means of assessing control and compliance 

measures and actual costs of these measures. Prospective modeling to estimate 

costs and benefits in advance of new rules should be matched with retrospective 

analyses of actual implementation costs, so that results and impacts can be 

assessed more accurately. 

b. EPA and state, tribal, and local agencies should invest jointly in a complete, upto-date system to catalog available pollution control technologies and reduction 

strategies and their associated costs and benefits. 

c. EPA and other stakeholders, including the CDC, should improve the assessment 

of the prospective and retrospective benefits associated with avoiding air 

pollution-related health impacts and premature mortality, ecosystem damage, 

agricultural impacts and other public welfare impacts. 

d. Pollution control information and cost-benefit calculations should be combined 

with the information in EPA’s Trends Reports to produce a more comprehensive 

“accountability” assessment that tracks program progress in a transparent and 

publicly accessible way. 

e. Initial accountability efforts should focus on major rules such as the Clean Air 

Interstate Rule (CAIR), the Clean Air Mercury Rule (CAMR), and mobile source 

rules. Accountability metrics should ultimately be incorporated into all types of 

programs. 

Benefits: 

• The public will benefit if regulators are focusing on the more important public health 

issues and have more flexibility to respond to newly developed information. 

 

6

 For more information about the Clean Air Science Committee visit the EPA Science Advisory Board website at 

http://www.epa.gov/sab/about.htm. 

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Air Quality Management Subcommittee Final Report 

• Publicizing significant new health and ecosystem studies on a regular basis will 

increase focus on public health and environmental goals. 

• Publicizing these studies should help streamline the review/revision of primary 

standards and facilitate the development of meaningful secondary standards that will 

protect ecosystems. 

• Furthermore, ongoing efforts to track effectiveness and cost/benefit of programs 

should enhance program design and effectiveness in the future. Accountability is 

always necessary to ensure public and private resources are being used to the greatest 

purpose, and to assure confidence in the effectiveness of current and future programs.

Recommendation 4: Take climate change into account - Take climate change 

into account in air quality management strategies. 

Background/Explanation: 

The NRC report includes the following discussion on climate change: 

The earth’s climate is warming. Although uncertainties remain, the 

general consensus among the scientific community is that this warming 

trend will continue or even accelerate in the coming decades. The AQM 

system will need to ensure that pollution reduction strategies remain 

effective as the climate changes, because some forms of air pollution, such 

as ground-level ozone, might be exacerbated. In addition, emissions that 

contribute to air pollution and climate change are fostered by similar 

anthropogenic activities, that is, fossil fuel burning. Multipollutant 

approaches that include reducing emissions contributing to climate 

warming as well as air pollution may prove to be desirable. 

Air Quality Management in the United States, National Research Council 

(January 2004) p. 16.

During the past several years, many cities and states have initiated actions to inventory 

and/or reduce greenhouse gases. For instance, according to EPA, 41 states and Puerto Rico 

have completed greenhouse gas inventories and 28 states and Puerto Rico have completed, 

or are working on, action plans that identify options for reducing greenhouse gas emissions 

or enhancing greenhouse gas sequestration. Many cities and states are interested in 

integrating air quality planning with their climate change programs. 

California has established greenhouse gas standards for passenger vehicles beginning with 

the 2009 model year, a move several northeast and west coast states have also adopted. 

Eight northeast states (CT, DE, ME, NH, NJ, NY, RI and MD) participate in the Regional 

Greenhouse Gas Initiative (RGGI) to reduce CO2 emissions from the electric generating 

sector through the application of a cap and trade program. A draft model rule was issued in 

2006. California, Oregon and Washington are currently considering similar greenhouse gas 

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Air Quality Management Subcommittee Final Report 

control initiatives. The AQM Subcommittee discussions and recommendations preceded the 

Massachusetts v. EPA Supreme Court decision. The AQM Subcommittee recognizes 

ongoing discussions on climate change will occur outside of the AQM process. 

Problems/Challenges Addressed: 

In the January 2005 AQM Phase I Report, a recommendation was made that “EPA should 

assist states and localities in quantifying the potential increases or decreases in greenhouse 

gas (GHG) emissions from reduction measures primarily designed to address ozone, fine 

particles, regional haze, and air toxics.” This recommendation was made in the Phase I 

report in the context of the NRC core recommendation titled, “Develop an integrated 

program for criteria pollutants.” 

Many AQM Subcommittee (Phase II) members felt that with the recommendation made in 

the Phase I report that the scope of the AQM in Phase II should be further expanded on the 

topic of climate change. Most Subcommittee members agreed that climate change was an 

important issue worthy of further discussion as it relates to air quality. However, some 

members believed that climate change was being expanded beyond the intended scope of the 

AQM Subcommittee and should not be the forum for this topic as more qualified experts, not 

present in this process, should be a part of a broader national debate. Therefore, the AQM 

Subcommittee agreed to narrow discussion to certain aspects of three air quality related 

linkages to climate change: 

• Maintenance of AQM efficiency in the face of changing climate; 

• Consideration of the effects of climate change in air quality decision making; 

and, 

• Coordination of air quality and urban planning strategies. 

Recommended Actions: 

A. EPA should continue to pursue Recommendation 4.3 from the AQM Phase I Report: 

“Greenhouse Gas Co-Benefits and Disbenefits” – EPA should assist states and localities, 

in quantifying the potential greenhouse gas co-benefits and disbenefits of emissions 

reduction measures primarily designed to address ozone, PM2.5, regional haze and air 

toxics. In evaluating control measures, EPA should assist states and localities in 

quantifying potential greenhouse gas emissions increases and decreases. Many states and 

localities have adopted policies to assess and/or reduce greenhouse gas emissions. Under 

this recommendation, where requested, EPA should support state, tribal, or local efforts 

to determine how pollution reduction alternatives might also impact greenhouse gas 

emissions. 

B. EPA should undertake a comprehensive assessment of the implications climate change 

will have on future air quality objectives and include other federal agencies and climate 

change scientists in that endeavor.7

 The assessment should include estimation of the 

 

7

 Aspects of the activities described under “B” are being carried out by EPA. For example, the EPA Office of 

Research and Development (ORD) initiated a large program in 2001 to assess the impact of climate change on US 

regional air quality. The EPA STAR Grant program funded 25 climate change-related projects; ORD and the 

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Air Quality Management Subcommittee Final Report 

potential increases in the average and high temperatures during ozone season and the 

impacts of such increases on ozone formation. An estimate of the air quality impact of 

secondary effects of temperature increases, such as wildfires, heat island effects, 

increased electric use, decreased hydroelectric generation, etc. should also be provided. 

The assessment should include an estimation of costs and savings associated with 

mitigation strategies to address impacts of climate change or temperature increases 

associated with these potential secondary impacts. 

C. EPA should assist states in the development of annual greenhouse gas emission 

inventories.8 The Emission Inventory Improvement Program quantification guidance 

should be finalized and made available to states to promote comparability between state 

inventories.9

 These enhanced inventories should be reflected in the assessment 

conducted under recommended action B and should enable states to better evaluate the 

air quality benefits associated with various control strategies. Coordination with 

greenhouse gas emissions inventories collected by other governmental entities, such as 

the U.S. Department of Energy (DOE), should be pursued to avoid duplication of efforts 

and to ensure integrity of the data. EPA, at the request of state, tribal, or local 

governments, should also provide additional technical assistance to states so they may 

effectively evaluate greenhouse gas reduction strategies in conjunction with the 

development of their air quality management plans. 

Implementation: 

• For recommended actions A and C, EPA should work with states, local agencies and 

tribes to provide technical assistance to assess greenhouse gas emission co-benefits and 

disbenefits, and associated air pollution reduction strategies, as well as provide states, 

tribes, and local agencies with the improved emission inventory information called for in 

recommendation C. 

• For recommended action B, EPA should conduct the comprehensive assessment of the air 

quality implications associated with climate change in a manner that utilizes the best 

information available, and provides for stakeholder input. 

 

National Exposure Research Laboratory (NERL) began a large project involving global and regional simulations, in 

conjunction with DOE through a cooperative agreement. In addition, ORD’s National Risk Management Research 

Laboratory (NRMRL) began development of data resources and tools for emissions projections. These activities 

will yield results that will be summarized in two assessment reports due in 2007 and 2010, to be produced by ORD’s 

National Center for Environmental Assessment (NCEA) in collaboration with EPA’s Office of Air and Radiation 

and key stakeholders. 

8

 Aspects of the activities described under “C” are being (or have been) carried out by EPA. For example, 42 states 

and Puerto Rico have completed their own greenhouse gas emission inventories in partnership with EPA. EPA's 

draft guidance and draft State Inventory Tool have been instrumental in the progress to date. 

9

 See http://www.epa.gov/ttn/chief/eiip/techreport/volume08/index.html for more information regarding the 

Emission Inventory Improvement Program. 

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Air Quality Management Subcommittee Final Report 

Benefits: 

• These three initiatives will provide critical information to states, tribes, and local agencies 

to use in any air quality and climate change program assessment or development they 

may be pursuing. 

• Recommended action C will provide essential guidance on potential adjustments to be 

considered in the air quality planning process as a result of climate change.

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Air Quality Management Subcommittee Final Report 

AQM Management Planning 

The three recommendations the AQM Subcommittee is making regarding air quality 

management (AQM) planning (Recommendations 5 through 7) represent an expansion of 

traditional air quality management where the states play the lead role and the focus is on 

point and mobile sources. The proposed comprehensive AQM planning process 

recommends an enhanced role for tribal, local governments, and multijurisdictional 

organizations, including the utilization of scenario planning and other tools. The AQM 

Subcommittee also recommends an increased effort to encourage pollution prevention, 

energy efficiency, and renewable energy as a means to reduce emissions. 

Recommendation 5: Support transportation and land use scenario planning - 

The AQM Process should support transportation and land use scenario planning 

at the multijurisdictional, state, tribal, and local levels and other means to identify 

emissions reduction opportunities and improve tribal and local engagement.10

Background/Explanation: 

Tribal and local governments have critical control and approval authority over land use 

choices that significantly impact air pollution, transportation systems (which some would 

argue is the most critical driver of locally controlled development), air pollution, energy 

use and greenhouse gas emissions. Multi-jurisdictional planning organizations are also 

significantly involved in local land use and transportation planning in several ways, such 

as providing technical planning support to local governments. For example, tribes, local 

governments, and multi-jurisdictional planning organizations have the power to 

determine or influence the way in which land is developed, how vehicle use and 

transportation patterns evolve, which land is opened to development, and whether local 

funds and land use are used to support mass transit, rather than discourage it. Some may 

also influence whether energy efficiency or demand side management techniques are 

required or implemented (e.g., in residential and commercial development). There is no 

single federal requirement for coordination among transportation, land use and air 

quality. Metropolitan and statewide transportation planning must address land use, air 

quality factors, and transportation conformity. The conformity process seeks to integrate 

transportation planning to the SIP’s purpose of reducing violations and contributing to 

attainment of the NAAQS. By virtue of their role in these multiple areas, multijurisdictional planning organizations, tribal and local governments have a unique 

opportunity to coordinate air quality, land use, energy, transportation, and climate 

programs. For these and other reasons, the AQM Subcommittee recommends that 

 

10 For purposes of Recommendation 5, “multi-jurisdictional planning organizations” include, but are not limited to, 

multi-state organizations such as state transportation departments, multijurisdictional and regional planning 

organizations (MJOs and RPOs), council of governments (COGs), nonprofit planning organizations and independent 

system organizations. 

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Air Quality Management Subcommittee Final Report 

multijurisdictional planning organizations, including all governments and planning 

organizations be an integral part of the AQM process. 

The AQM Subcommittee recognizes that considerations such as quality of life are 

frequently the drivers for planning organizations (often with the support of 

multijurisdictional planning organizations) to recommend and adopt land use restrictions 

and other practices that are also good for air quality. EPA can play a constructive role in 

supporting such practices by providing tools and resources to assess the air quality 

benefits of alternative land use scenarios. 

Problems/Challenges Addressed: 

• Attaining and maintaining the NAAQS for ozone and PM2.5 and reducing 

regional haze. 

• Addressing air quality on the appropriate geographic scale (locally, regionally and 

globally). 

• Addressing remaining pollution problems, including unregulated and smaller 

“area sources”. 

• Coordinating air quality, energy, transportation and urban planning strategies. 

Recommended Actions: 

To achieve enhanced multijurisdictional planning organization, state, tribal, and local 

governments involvement in the AQM process and better coordination of AQM, land use, 

energy, transportation and climate programs, the AQM process should be modified so 

that multijurisdictional planning organizations including local planning choices are better 

integrated with, and have meaningful input into, federal, state, and tribal AQM processes. 

To accomplish this objective: 

A. EPA should encourage states and tribes to coordinate with multijurisdictional planning 

organizations and tribal and local governments by aligning planning schedules. EPA 

should provide resources to multijurisdictional planning organizations, and tribal and 

local governments so they can better understand the impact that land use, energy, and 

transportation decisions in their areas will have on air quality and greenhouse gas 

emissions. EPA (in consultation and coordination with DOT, states, and tribes) should 

assist, where appropriate, in linking multijurisdictional planning organizations and tribal 

and local governments that are actively implementing integrated planning approaches 

(e.g., Sacramento, Portland, Chicago, Minneapolis) with those that are considering, but 

not yet implementing, such approaches (e.g., Atlanta). 

EPA, drawing on outside expertise), should also develop a clearinghouse of planning 

related resources and tools, as proposed in the 2005 AQM Phase I report. Over the 

longer term, multijurisdictional planning organizations, including governmental and other 

planning organizations, need more sophisticated transportation and land use models that 

adequately capture local land design issues, bicycle and pedestrian travel, and reduced 

demand. These models will need to be supported by high quality, sufficiently 

disaggregated land use, and travel data. In the nearer-term, regions, communities and 

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Air Quality Management Subcommittee Final Report 

tribal entities need scenario analyses and visioning tools that allow them to understand, 

visualize and quantify the opportunity costs of business-as-usual development trends and 

the benefits of more efficient transportation and land use scenarios. Local land use and 

transportation infrastructure decisions are typically driven more by the quality of life and 

economic concerns than by air quality and environmental issues. Thus, it is critical that 

scenario analysis tools address multiple factors (such as emissions, mobility, consumer 

fuel costs, water quality, infrastructure costs, etc.) of concern to the public and the private 

sector. 

B. EPA, in partnership with states, tribes, and DOT in consultation with other interested 

stakeholders, should encourage multijurisdictional planning organizations, tribal, and 

local governments to conduct a visioning and scenario planning process in which the area 

in question decides where it wants to be in the future with regard to land use, 

transportation, and energy; and, the area in question adopts a plan to incorporate the 

necessary policies and requirements/mandates that further its vision. These efforts should 

be coordinated with and supported by the transportation planning process. This could 

produce an “integrated” strategy that addresses land use, energy, and transportation in a 

manner that is directionally correct for air quality or explicitly tied to attainment. As part 

of their visioning and scenario planning process, multijurisdictional planning 

organizations, tribal, and local governments should be encouraged to work with state 

and/or tribal planning organizations to identify strategically located communities that are 

appropriate for new fuel and energy generation, storage, transportation technologies, 

facilities, and infrastructure requiring changes to the existing land and built environment. 

C. EPA, in partnership with states, tribes, and DOT and in consultation with other interested 

stakeholders, should explore the advantages and disadvantages of mandatory and 

voluntary visioning and scenario planning that, among other things, identifies the 

environmental benefits and detriments of various land use choices. Such a program could 

be conducted as part of the multijurisdictional planning organizations or tribal or local 

government’s transportation planning and air quality planning process.11 If a mandatory 

program is appropriate, significant changes would be required not just to the AQM 

system, but to the transportation planning and conformity processes and underlying 

statutes. 

D. EPA should allow SIP/TIP credit and make available other forms of recognition or 

alternative “credit” for multijurisdictional planning organizations, tribal, and local 

governments that revise their land use laws consistent with EPA’s model goals and 

ordinances, or that implement quantifiable land use, energy or transportation technologies 

or approaches that benefit air quality. 

 

11 A recommendation to mandate scenario planning for Transportation Improvement Plans and Long Range 

Transportation Plans was initially developed by a group of transportation, land use and air quality experts convened 

by the Center for Clean Air Policy and the local Government Commission in December 2004. See 

http://www.ccap.org/transportation/smart_two.htm for more information. 

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Air Quality Management Subcommittee Final Report 

Implementation: 

• For recommended action A, EPA should develop a plan in consultation with states, tribes, 

DOT, and the various associations that represent municipalities (e.g., National 

Association of Regional Councils). The plan should include a mechanism for facilitating 

communication and scheduling between and among multijurisdictional planning 

organizations, tribal, and local governments, as well as issuing guidance on integrated 

planning approaches. 

• Further, with respect to the clearinghouse of planning resources and tools, EPA (drawing 

on outside expertise) should gather items that will help multijurisdictional planning 

organizations and tribal and local governments achieve planning and development 

practices that benefit air quality. The clearinghouse of resources and tools should 

include, without limitation: 

1) Software that enables multijurisdictional planning organizations and tribal and local 

governments to model current and alternative land use patterns, energy trends and 

transportation options so that they can study how different land use, energy and 

transportation scenarios would impact future emissions; 

2) Modeling software that enables multijurisdictional planning organizations and tribal and 

local governments to quantify the emission reductions associated with certain land use, 

energy and transportation technologies or approaches; 

3) On-line tutorials and manuals for use of modeling software; 

4) Model codes and ordinances that benefit air quality (e.g., model codes and ordinances 

that promote increased urban density, multiuse clustering, energy efficiency and public 

transportation); 

5) Guidance that identifies land use, energy and transportation technologies or approaches 

that benefit air quality and establish certain minimum steps that multijurisdictional 

planning organizations and tribal and local governments should take to obtain SIP or TIP 

credit when pursuing such technologies and approaches; 

6) Model educational and citizen involvement practices; and, 

7) Guidebooks that identify funding opportunities for innovative land use, energy and 

transportation approaches. 

• In assembling this clearinghouse, EPA should determine what tools have been developed 

and what items need to be enhanced or developed. EPA and the Federal Highway 

Administration (FHWA) currently provide some technical assistance and guidance on 

scenario planning tools and integrating transportation and land use planning. Increasing 

awareness of these existing tools would be straightforward and low cost. For tools 

needing to be enhanced or developed, EPA should decide which ones to develop first 

based on stakeholders’ needs. 

• To help ensure these tools are readily accessible to multijurisdictional planning 

organizations and tribal and local governments, EPA should make the clearinghouse 

available in a central place on the web. EPA should also consider featuring the tools at a 

conference with a particular emphasis on creating champions or advocates such as local 

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Air Quality Management Subcommittee Final Report 

politicians and land planners who can utilize the information to promote beneficial landuse practices in their communities. 

The clearinghouse and the other recommendations in this proposal are intended to deepen 

current support and systematize it so these tools and approaches can be implemented more 

broadly. The clearinghouse would require additional staff and financial resources for 

implementation, especially for new tool development. 

For recommended actions B and C to improve the effectiveness of scenario planning, EPA 

should partner with states, tribes, local governments, and DOT to support pilot transportation 

and land use scenario analyses in a few metropolitan regions across the U.S. These pilot 

efforts would test the premise that scenario analyses can identify cost-effective emissions 

reduction options that would otherwise be missed in the current system that does not 

explicitly consider land use as a policy variable. The pilots would assess whether scenario 

analyses yield persistent emission reduction strategies that will help maintain air quality and 

aid in meeting future SIP/TIP objectives. These pilot efforts should be designed to fully 

understand what is involved in making scenario analysis requirement a mandatory feature of 

AQM and inform how it would be structured and implemented. Another goal of the pilots 

should be identifying next steps to make use of scenario planning more widespread, 

including consideration of whether making such analyses should be mandatory. 

For recommended action D, EPA should give states and tribes the option to include the 

visioning and scenario planning process as an input into their SIPs or TIPs in one of three 

ways: 1) as a measure in the baseline; 2) a measure warranting credit; and/or, 3) a growth 

assumption. EPA has developed several useful guidelines for calculating SIP and TIP credit. 

For example, EPA has provided guidance on SIP credit for emission reductions from electric 

sector energy efficiency and renewable energy projects and plans to provide guidance on SIP 

credit for emission reductions from highway and off-road diesel vehicles and retrofits. EPA 

should continue developing guidelines for calculating SIP and TIP credit associated with 

other land use, energy and transportation technologies and approaches and should work with 

EPA regional offices and in consultation with states and tribes to follow such guidelines for 

SIP and TIP planning and development. EPA should develop guidance that explains how 

areas can get SIP/TIP credit for well documented land use measures that multijurisdictional 

planning organizations and tribal and local governments adopt that yield emission reductions. 

EPA should also develop new guidance to allow some amount of SIP/TIP credit where the 

total reductions for innovative strategies would exceed the three percent for mobile voluntary 

measures and six percent for stationary source related VOC measures under current 

guidance. Recommendation 10 details measures that EPA could pursue to further credit and 

other recognition programs outside the SIP/TIP process. 

Benefits: 

• Current land use and transportation decisions will impact emissions over many decades. 

Providing multijurisdictional planning organizations, tribal, and local governments with 

tools and resources to better understand the interaction among land use, transportation, 

energy, and greenhouse gas emissions, will empower them to make better decisions over 

the short- and long-term. 

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Air Quality Management Subcommittee Final Report 

• Alternative transportation and land use scenario analyses have been used to identify costeffective emissions reduction options that would otherwise be missed in the current 

system that does not explicitly consider land use as a policy variable. 

• In addition to emissions benefits, smart growth policies can yield multiple benefits on 

issues of significant public and private sector concern including: energy security, traffic 

congestion, ecosystem preservation, reduced infrastructure costs, and protection of water 

resources. 

Recommendation 6: Integrate air quality planning into land use, 

transportation and community development plans - Local planning 

organizations should integrate air quality planning into their land use, 

transportation and community development plans when high population growth is 

occurring in order to prevent significant deterioration of air quality. 

Background/Explanation 

As America grows, it is particularly important that land use, transportation, and air quality 

linkages be established in a manner that educates, provides incentives, and flexibility for 

local officials and governing boards or commissions. Local forums have great power to 

design and manage growth in ways that stimulate creative, cost effective solutions that 

maintain clean air. 

During the history of the CAA, air quality planning by local governments has primarily 

occurred when a nonattainment problem had to be solved. Local governments, elected 

officials, and the business community can react quickly to bring about cost-effective 

solutions to air quality problems when they understand the possible adverse impacts of 

inaction. Opportunities for flexibility and inventiveness should be encouraged early in the 

AQM process to avoid a nonattainment designation and the prescriptive programs that 

would accompany those designations. 

 Preservation of clean air is no longer solely focused on large industrial and mobile source 

challenges. Local governments and leaders have a growing appreciation of the value of 

clean air as a health, quality of life, and economic resource. Chronic erosion of air quality 

that gradually builds to violations of the NAAQS is an outcome Congress foresaw in 1977. 

While Prevention of Significant Deterioration (PSD) increment standards and baseline dates 

set the foundation for preserving clean air, they are no longer sufficient to address the 

challenge of urban expansion, where air quality is often eroded by small point, area, and 

mobile source air pollution. 

 Comprehensive state-wide or regional airshed planning could potentially be developed from 

a mosaic of local plans. However, if all areas were required to undertake local planning, it 

could become a significant and unnecessary burden for local governments. This planning 

requirement would need to be accompanied by new planning tools and educational 

components to aid local governments. 

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Air Quality Management Subcommittee Final Report 

Problems/Challenges Addressed: 

• A new local planning paradigm is needed if states, tribes, and local governments are going 

to preserve clean air below the NAAQS level while also promoting population and 

economic growth. 

 

Recommended Actions: 

A. Engage local leaders early in the AQM process by encouraging flexibility and customized 

solutions that would spur preemptive action. This could help avoid a nonattainment 

designation and the more prescriptive programs that would accompany nonattainment. 

Local governments and the business community can react quickly to bring about costeffective solutions to air quality problems when they understand the possible adverse 

economic impacts of inaction. 

B. Selected local areas, particularly those with high population growth, should be required to 

develop local air quality plans. This planning requirement would need to be 

accompanied by new planning tools to aid the selected tribal and local governments. 

Benefits: 

• This recommendation fills a gap in the existing AQM system to manage chronic pollution 

increases in high population growth areas of the country in order to preserve existing 

clean air areas. Some recent examples have shown this can be achieved in a way to 

stimulate local leaders’ protection of air resources, promoting health, quality of life, and 

the economic vitality of our cities and communities. 

• This recommendation also relates to ecosystem protection and creates stronger 

opportunities for local government air quality management that may also assist 

environmental justice goals. 

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Air Quality Management Subcommittee Final Report 

Recommendation 7: Encourage pollution prevention, energy efficiency and 

renewable energy - Analyze existing laws to determine the extent to which they 

can be used to encourage pollution prevention, energy efficiency, and renewable 

energy as they may be effective in reducing emissions.

Background/Explanation: 

Tremendous progress has been made in the U.S. over the past 30 years in reducing air pollution 

using primarily command and control approaches under the CAA. In addition, several 

environmental and energy statutes directly or indirectly address energy efficiency, cleaner 

energy, and renewable energy and may present another means of achieving CAA air quality 

objectives. These statutes are potentially amenable to a number of legally permissible 

interpretations and the regulations implementing them are amenable to a number of legally 

permissible regulatory frameworks. 

For example, the CAA Amendments of 1990 establish prevention as “a primary goal” of 

the Act (see Title 1, Part A, section 101 (a) (3) and section 101 (c)). The Act also 

addresses concerns related to multi-media transfer of pollutants. 

The Pollution Prevention Act establishes as national policy: 

“...that pollution should be prevented or reduced at the source whenever feasible; 

pollution that cannot be prevented should be recycled in an environmentally safe 

manner, whenever feasible; pollution that cannot be prevented or recycled should 

be treated in an environmentally safe manner whenever feasible; and that disposal 

or other release into the environment should be employed only as a last resort and 

should be conducted in an environmentally safe manner.” 

Similarly, the Energy Policy Act in Section 2108 (a) (titled Energy Efficient 

Environmental Program) states: 

“(a) PROGRAM DIRECTION- The Secretary, in consultation with the Administrator 

of the Environmental Protection Agency, is authorized to continue to carry out a five 

year program to improve the energy efficiency and cost effectiveness of pollution 

prevention technologies and processes, including source reduction and waste 

minimization technologies and processes. The purposes of this section shall be to 

(1) apply a systems approach to minimizing adverse environmental effects of 

industrial production in the most cost effective and energy efficient manner; and

(2) incorporate consideration of the entire materials and energy cycle with the 

goal of minimizing adverse environmental impacts.” 

A clean air strategy that takes full advantage of opportunities to use pollution prevention, 

energy efficiency and renewable energy measures may offer three advantages. First, such 

an approach could, with a single investment, reduce multiple emissions and reduce and/or 

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Air Quality Management Subcommittee Final Report 

eliminate pollutants and emissions to other media, as well as emissions that are currently 

unregulated but which may be in the future. Second, viewed from a systems perspective 

(as the Energy Policy Act dictates) pollution prevention, energy efficiency and renewable 

energy measures may be more cost effective than command and control strategies. Third,

such measures may help the U.S. accomplish important public policy goals outside the 

environmental and clean air arena, such as energy security, national security, and 

homeland security. Many states have established pollution prevention programs that have 

garnered tremendous successes. 

Problems/Challenges Addressed: 

• Coordinating air quality and energy strategies;

• Meeting the NAAQS for ozone and PM2.5 and reducing regional haze; and

• Addressing impacts on specific communities (environmental justice).

Recommended Actions: 

A. EPA should examine the scope and extent of pollution prevention-based strategies 

permissible under the CAA, Pollution Prevention Act and Energy Policy Act; assess the 

cost effectiveness of such strategies as compared to current regulatory strategies; and 

identify opportunities for taking advantage of pollution prevention-based approaches that 

may exist in the current legal framework. In addition, EPA should examine the potential 

for new enforceable regulatory requirements which allow for use of pollution prevention 

strategies where they prove to be more effective from cost- and performance-based 

perspectives. 

B. Existing and prospective prevention-based strategies should be identified and 

implemented, particularly where they offer the opportunity to achieve national goals such 

as greater energy independence and energy security, and/or where they allow the nation 

to accomplish reductions in greenhouse gas emissions as an ancillary benefit that imposes 

low net costs. 

Implementation: 

• For recommended action A, EPA should convene a team including state and local 

officials, the Environmental Law Institute, Energy and Environmental Analysis, Inc., the 

National Association of Clean Air Agencies (NACAA), National Association of State 

Energy Officials (NASEO), American Council for an Energy Efficient Economy 

(ACEEE), DOE’s energy laboratories, Electric Power Research Institute, Environmental 

Council of States (ECOS), and representatives from tribes, industry, and environmental 

advocacy groups, to thoroughly examine the scope and extent of pollution preventionbased strategies permissible under the CAA, the Pollution Prevention Act and the Energy 

Policy Act, including pertinent rules, regulations, and other policy documents. The 

review and analysis should include examples of where pollution prevention strategies that 

have been tried, used, and where opportunities exist to further the use of these strategies. 

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Air Quality Management Subcommittee Final Report 

• Second, for recommended actions A and B, EPA should convene an analytical team 

including state and local officials, DOE, National Renewable Energy Laboratory 

(NREL), NACAA, NASEO, ECOS, and representatives from tribes, industry, and 

environmental advocacy groups, to gather all information and data on the pollution 

prevention provisions of all pertinent statutes, rules, guidance, and policies. In addition, 

the team should gather and analyze performance and cost data on energy efficiency and 

renewable energy technologies to examine their performance and cost-effectiveness as 

compared to current regulatory strategies in achieving air quality objectives and 

providing other ancillary benefits. 

• The above two teams should be asked to merge their findings and any proposed 

recommendations into a single document and to present that document to EPA and DOE 

for consideration. 

Benefits: 

• This recommendation promotes meeting air quality objectives in the most cost-effective 

manner, with lower compliance and administrative costs, conservation of fuels and 

resources, enhanced national and energy security, and reductions of greenhouse gases at 

little or no additional expense while providing new and clean sources of electricity 

generation, and enhanced local and regional economic development. 

Implementing Air Quality Strategies

 The Subcommittee recommends an integrated approach for implementation that calls for air 

quality goals, strategies, and plans to be implemented in coordination with a range of related 

issues. EPA should work with state air and energy organizations, tribal governments, and 

regional air quality planning organizations to overcome potential barriers to clean energy/air 

quality integration. Incentives (including, but not limited to, more flexible forms of credit, 

regulatory incentives and economic incentives) for voluntary and innovative land use, energy, 

and transportation technologies or approaches need to be developed and promoted. In addition a 

federal inter-agency liaison group should be established with EPA and other federal agencies to 

coordinate land use, energy, transportation, greenhouse gas, and air quality goals.

The AQM Subcommittee is making five recommendations related to implementation of a 

comprehensive AQM system (Recommendations 8 through 12). 

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Air Quality Management Subcommittee Final Report 

Recommendation 8: Expand the use of episodic controls - Expand the use of 

episodic control measures to help attain and maintain national ambient air quality 

standards in areas where all reasonable continuous and seasonal control 

measures have already been required. 

Background/Explanation: 

The U.S. AQM system relies on the use of continuous (i.e., year-round) and seasonal 

control measures. A number of communities have supplemented the use of continuous 

and seasonal control measures with public information campaigns and voluntary 

programs designed to reduce emissions on specific days when high ozone or PM 

concentrations are expected. In 1977, Congress rejected the use of “intermittent” controls 

as part of a SIP for achieving the NAAQS. Since that time, EPA has concluded that the 

CAA does not restrict SIP approval (or credit) for peak day (i.e., episodic) reduction 

measures that apply to: (1) consumer products or services (2) certain consumer actions, 

(3) episodic transportation control measures, and (4) certain other mobile source 

measures that may be approved for SIP credit. EPA maintains, however, that the CAA 

limits the use of intermittent controls at stationary sources as part of an approvable SIP. 

Recommended Actions: 

A. Expand federal research and technical assistance to communities regarding the design, 

implementation and evaluation of successful programs to reduce peak day emissions 

from non-stationary sources 

B. Expand the use of stationary source episodic control measures as a backup insurance 

mechanism (i.e., outside the scope of an approved SIP) for areas struggling to attain or 

maintain the short-term ambient standards. 

Implementation

If the use of episodic control measures is to be expanded, a number of implementation issues 

must be addressed, including: 

• How the results of such programs are measured; 

• How well high pollution days are predicted and how best episodic measures can be called 

into effect in a timely manner; and, 

• What types of episodic control measures will be practical, enforceable, and cost 

effective? 

Benefits 

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Air Quality Management Subcommittee Final Report 

• Episodic control measures can provide an expanded set of cost-effective control 

opportunities for states and local communities that are capable of yielding emission 

reductions. 

• A variety of measures that could not be implemented on a continuous or seasonal basis 

could prove to be suitable and cost effective for episodic use. 

• For areas that are working to attain or maintain a NAAQS, episodic control measures can 

serve as a backup insurance mechanism by preventing air quality violations on days when 

meteorological conditions might otherwise cause a violation. 

• By reducing peak concentrations on the highest pollution days, episodic control measures 

may provide considerable health and environmental benefits to all affected populations. 

Recommendation 9: Overcome potential barriers to clean energy/air quality 

integration - EPA should work with state, tribal, and local air agencies, energy 

organizations, and regional air quality planning organizations to overcome 

potential barriers to clean energy/air quality integration.

Background/Explanation: 

Many states and tribes have developed programs to implement energy 

efficiency/renewable energy measures. Several states and tribes have expressed interest 

in implementing these energy related measures to help achieve their air quality 

objectives. Toward that end, EPA has established the Clean Energy-Environment State 

Partnership Program, a voluntary state-federal partnership to support state efforts to 

increase the use of clean energy to achieve environmental, energy and economic benefits. 

To support state, tribal, and local clean energy programs, EPA has issued three key 

documents: 

1. “Guidance on State Implementation Plan Credits for Emission Reduction 

Measures from Electric-sector Energy Efficiency and Renewable Energy 

Measures,” August 2004 (hereinafter, EPA SIP Energy Guidance); 

2. "A Toolkit for States: Using Supplemental Environmental Projects (SEPs) To 

Promote Energy Efficiency (EE) and Renewable Energy (RE)," January 2005; 

and, 

3. “Clean Energy-Environment Guide to Action: Policies, Best Practices and Action 

Steps for States,” February 2006. 

The requirement for SIP and TIP revisions to meet the new 8-hour ozone standard and 

the PM 2.5 standard provides an opportunity for clean energy and air quality integration. 

This integration can be achieved through the inclusion of energy efficiency and 

renewable energy measures into SIPs/TIPs utilizing state and EPA programs and 

resources like the ones cited above. 

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Air Quality Management Subcommittee Final Report 

There is limited precedent for adoption of energy efficiency and renewable energy 

measures within SIPs and TIPs. States must submit ozone and PM2.5 SIPs over the next 

two years, leaving little time to accommodate the lengthy process required for 

incorporating energy efficiency and renewable energy measures into the plans. 

Notwithstanding, EPA should lead the way now to overcome real and perceived obstacles 

to including energy efficiency and renewable energy measure adoption and inclusion in 

SIPs and TIPs. 

Barriers to clean energy/air quality integration: 

• Some states have indicated that they are unlikely to pursue energy efficiency and 

renewable energy measures as part of their SIPs to meet the ozone and PM standards 

because they believe that an insignificant amount of SIP credit may be obtained or that 

EPA requirements (including inconsistent application of requirements across the regions) 

for documenting the benefits within the SIP will be too burdensome. For example, the 

EPA SIP Energy Guidance is unclear as to what extent states and local governments can 

rely on existing modeling under the Clean Air Interstate Rule (CAIR) to document 

upwind areas, thereby avoiding the need for extensive new modeling. 

• EPA is currently working with the states, tribes, and local governments on incorporating 

energy efficiency and renewable energy measures into SIPs and TIPs. The effort is not 

sufficient to provide many governments with the necessary assurances that EPA will 

approve their proposals for inclusion of energy efficiency and renewable energy 

measures into SIPs when they are submitted to the Agency. For example, some 

interpretations of the applicable guidance are more restrictive than EPA intended. For 

example, the extent of documentation necessary to obtain SIP credit for renewable energy 

and energy efficiency measures undertaken as part of a Renewable Portfolio Standard or 

Alternative Portfolio Standard is unclear.

• Some states, tribes, and local governments do not realize the extent of the opportunities 

they have for incorporating energy efficiency and renewable energy measures into 

SIPs/TIPs, and do not realize they can work with EPA and its regional offices on 

proposals during early SIP planning discussions. 

• When a Best Available Control Technology (BACT) determination in the context of New 

Source Review (NSR) involves the use of an add-on control device, it appears that some 

EPA regional offices and some states believe that the determination requires that the 

permittee must always use that control device to achieve the related emission limit. This 

should not always be the case. If, after the permit is issued, the permittee is able to 

achieve the required emission limit without using the control device (e.g., through 

pollution prevention by replacing a solvent-borne coating with a water-borne coating 

containing much less VOCs), the permittee should be allowed to discontinue using that 

control device and thus eliminate the associated energy use, assuming the reformulation 

of the coating is consistent with the air toxic requirements of the state. For example, a 

permittee with a coating line is initially subject to a BACT determination based on the 

use of an oxidizer to meet a volatile organic compound (VOC) emission limit. The 

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Air Quality Management Subcommittee Final Report 

permittee subsequently reformulates its coating material to use a water-borne coating 

with an inherently lower VOC content and can now meet the VOC limit without using 

the oxidizer. Assuming the reformulation of the coating is consistent with the air toxic 

requirements of the state, the permittee should be allowed to turn off the oxidizer thereby 

saving energy and eliminating the emissions associated with the oxidizer while at the 

same time continuing to ensure compliance with the VOC emissions and/or performance 

limit. 

• In addition, new permit applicants should not be required to install control devices if they 

are able to comply with a comparable or equivalent BACT limit using other means. For 

example, if a permittee is able to use a more advanced low NOx burner that has 

emissions that are comparable to or better than BACT limits, the permittee should not be 

required to install an add-on control device, such as Selective Catalytic Reduction. 

• Incorporation of energy efficiency and renewable energy measures into SIPs/TIPs raises 

significant national policy issues that require time to resolve. For example, in some 

locations, due to the nature of the electric grid, it can be challenging to determine how the 

emissions benefits will occur in locations that are relevant to the nonattainment area in 

question. Some states are uncertain how to interpret EPA guidance on determining where 

net emissions reductions need to occur for clean energy measures with respect to a 

nonattainment area for that area to be able to take credit. There are also unrealized 

opportunities for regional cooperation to credit the dispersed emissions reductions. 

• The relationship between cap and trade programs and SIP credits for energy efficiency 

and renewable energy actions can be complex. Some state, tribal, and regional air 

agencies may not realize that they need to retire allowances to receive SIP credit for NOx 

emission reductions if the state is subject to CAIR. Some state air agencies may not 

realize that they must create energy efficiency and renewable energy set-aside or other 

allocation mechanism under their CAIR implementation rules to obtain SIP credits for 

energy efficiency and renewable energy measures for the period from 2009 forward. 

• State, tribal and local governments are often unaware of existing resources, including the 

timing, and amount of DOE, EPA, and DOT funding of clean energy/air quality 

integration measures. Interest by government and tribal entities in energy efficiency and 

renewable energy measures will be greatly enhanced if they are provided with readily 

accessible information on funding sources. 

• State, tribal, and local governments are facing budgetary constraints that may limit their 

ability to adopt energy efficiency and renewable energy measures. Increased provision of 

information on creative financing approaches (e.g., performance contracting for 

solar/efficiency in schools) that overcome the financial barriers posed by high upfront 

capital costs can greatly spur the adoption of energy efficiency and renewable energy 

measures. 

Problems/Challenges Addressed: 

• Meeting the NAAQS for ozone and PM2.5 and reducing regional haze.

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Air Quality Management Subcommittee Final Report 

• Coordinating air quality and energy planning strategies.

Recommended Actions: 

EPA should expedite actions to overcome the barriers to clean energy/air quality 

integration. All relevant EPA regional and headquarters offices should work with state, 

tribal, and local air permitting authorities and air planning organizations to: 

A. Communicate with state air agencies, tribal governments, local planning organizations, 

and related non-profit organizations (ECOS, NACAA, NASEO, NARUC) using different 

formats such as conference calls and webcasts to determine actual and perceived barriers 

to clean energy/air quality integration and to resolve policy issues on including energy 

efficiency and renewable energy measures in SIPs/TIPs. 

B. Serve as a facilitator and mediator to ensure a consistent approach encouraging use and 

incorporation of clean energy measures and to help resolve policy issues and encourage 

the inclusion of energy efficiency and renewable energy measures into SIPs/TIPs. 

C. Engage with state, tribal, and local air planning organizations in early discussions 

regarding energy efficiency and renewable energy measures being considered for 

inclusion in SIP/TIP submittals. This will help resolve any issues of interpretation or 

other technical concerns, including reconciliation of the anticipated locations of the clean 

energy measure emissions reductions with any SIP requirements in EPA guidance and 

rules. 

D. Issue guidance confirming that energy-consuming control devices may be shut down if, 

through pollution prevention, a permittee is able to meet the associated emission limits 

without using controls. 

E. Clarify that, a permit applicant is not required to the add-on BACT control if they 

demonstrate a pollution prevention measure is a substitute to BACT through a “topdown” BACT analysis. 

F. Clarify that, a permit applicant is not required to install an additional add-on control 

devices if they use pollution prevention approaches to meet an emission limit as long as it 

is comparable/equivalent to the limit that would be achieved by the add-on control 

device. 

G. Provide outreach to EPA regional officials, state officials, and state, tribal, and local 

governments on the interface between the CAIR regulations and energy efficiency and 

renewable energy measures in SIPs/TIPs. 

H. Define a sample of energy efficiency and renewable energy control measures currently 

under consideration by state, tribal, and local governments to meet the ozone and PM 

standards and anticipate and proactively work through the issues that will arise during the 

SIP/TIP review process. For example, the Control Measures Work Group of the 

Technical Advisory Committee of the Metropolitan Washington Air Quality Committee 

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Air Quality Management Subcommittee Final Report 

would be one good candidate for such a proactive review since this Work group already 

has developed a number of potential energy efficiency and renewable energy measures. 

I. Increase awareness among state, tribal, and local governments of existing funding 

opportunities made available by DOE, EPA, and DOT relating to clean energy/air 

quality, including eligibility, funding levels, and amount of awards. This includes 

making these governments aware of such information sources as the Clean Energy 

Environment State Partnership online funding guide provided by EPA. EPA should also 

make funding information available on the EPA Air Innovations web site and other high 

visibility EPA websites. This suggestion was presented to EPA at the 2005 Air 

Innovations Conference and EPA implementation would help overcome a major 

information barrier. 

J. Identify innovative financing strategies (e.g., state performance contracting laws) to assist 

state, tribal, and local governments in implementing clean energy/air quality integration 

measures. For example, EPA should make information available on the development of 

financing strategies, such as performance contracting and effective use of tax incentives 

provided in the Energy Policy Act of 2005, to spur cash-strapped municipalities to adopt 

energy efficiency and renewable energy measures. 

Implementation: 

• For recommended actions A, B, C, and F, EPA should convene an implementation group 

to convene on a regular basis. This group should discuss the interface between cap and 

trade programs, such as the CAIR regulations, and energy efficiency and renewable 

energy measures, identify actual and perceived barriers to clean energy/air integration and 

develop recommendations for addressing such perceived barriers. The group should 

focus on facilitating the implementation of energy efficiency/renewable energy measures 

across the country and incorporating such measures in SIPs/TIPs, including set-asides 

under CAIR. Membership on the group should include EPA headquarters and regional 

offices, DOE/NREL, NACAA, NASEO, ACEEE, tribal governments, environmental 

advocacy groups, industry, and others. 

• For recommended actions D and E, EPA should issue clarifying guidance. 

• For recommended actions F, G, H, and I, EPA should consult NASEO, DOT, 

DOE/NREL, ACEEE, states and others to obtain information, consolidate it, and then 

make it available on an EPA website dedicated to energy efficiency and renewable 

energy. 

Benefits: 

• Reducing demand for energy reduces emissions associated with energy production and 

combustion, which benefits air quality. Renewable energy projects can help improve air 

quality today by offsetting fossil fuel-fired generation, especially during peak demand. 

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Air Quality Management Subcommittee Final Report 

Recommendation 10: Provide incentives for voluntary and innovative land 

use, energy, and transportation approaches - The AQM process should include 

incentives (including, but not limited to, more flexible forms of credit, regulatory 

incentives and economic incentives) for innovative and voluntary land use, energy, 

and transportation technologies or approaches that provide air quality benefits. 

Background/Explanation: 

The AQM process should include incentives for voluntary and innovative land use, energy, 

and transportation technologies or approaches that benefit air quality in nonattainment and 

other areas. Encouragement should particularly be given to low emission technologies, smart 

growth, energy efficiency measures, cogeneration, demand-side management and renewable 

resources. The AQM process should better integrate incentives that incorporate these 

technologies and approaches into the NAAQS implementation process. Incentives could 

include, but are not limited to: 

• More flexible forms of SIP and TIP credit; 

• Regulatory incentives (such as streamlined or expedited permitting opportunities) and 

economic incentives (such as tax incentives, public benefits programs); 

• State and utility funding programs for energy efficiency projects, where appropriate and 

properly structured; and, 

• Recognition programs or forms of alternative “credit” for communities that implement 

voluntary and/or innovative land use, energy or transportation policies, programs or 

practices that benefit air quality. 

While EPA has already developed incentives for voluntary and innovative measures that 

address the above objectives (e.g., 2001 Improving Air Quality with Economic Incentive 

Programs12), many stakeholders are unaware of these programs. 

Problems/Challenges Addressed: 

• Meeting the NAAQS for ozone and PM2.5, and reducing regional haze; 

• Addressing air quality on the appropriate geographic scale (locally, regionally, and 

globally); 

• Addressing remaining pollution problems, including unregulated and smaller “area” 

sources; and, 

• Coordinating air quality, energy, transportation, and urban planning strategies. 

 

12 United States Environmental Protection Agency, Improving Air Quality with Economic Incentive Programs, 

available at http://epa.gov/ttn/caaa/t1/memoranda/eipfin.pdf. 

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Air Quality Management Subcommittee Final Report 

Recommended Actions: 

A. EPA should develop a communication strategy to inform interested stakeholders about 

land use, energy and transportation-related programs that already exist. 

B. EPA should continue to develop new programs that motivate the implementation of 

voluntary and innovative measures. Appropriate and properly structured incentive 

programs such as expedited and streamlined permitting opportunities, the Texas 

Emissions Reduction Plan (TERP) program, EPA’s Performance Track Program, and 

innovative measures such as voluntary mobile emissions reduction programs (VMEP) 

and projects funded by Congestion Mitigation and Air Quality (CMAQ) funds can, in the 

aggregate, make greater overall contributions to future SIPs and TIPs than they have in 

the past. 

C. Current SIP/TIP approval requirements have recently been made more flexible in 

crediting such measures, but they still require a ton-denominated precursor reduction 

applied to each such measure. The AQM process should allow for additional alternative 

forms of credit for such measures. EPA should assist in determining and allowing SIP 

and TIP credits for energy efficiency and renewable energy programs. 

D. With respect to community recognition programs, EPA should compile a list of existing 

recognition programs (e.g., Indiana CLEAN Community Challenge), their strengths and 

weaknesses, and what the recognizing entity offers as an incentive to areas that 

implement environmentally beneficial measures (e.g., technical assistance, public 

recognition, and cash awards). Drawing from this research, in partnership with other 

organizations that work with local governments, EPA should develop a community 

recognition or other alternative “credit” program for nonattainment and other areas that 

adopt voluntary and/or innovative land use, energy or transportation policies, programs or 

practices that benefit air quality. EPA should develop clear criteria for how an area 

would qualify for this recognition or alternative “credit.” 

Implementation: 

• For recommended action C, EPA should consider the predicted effects of a package of 

measures presented in a SIP or TIP, potentially over a longer time horizon than the 

SIP/TIP review period. Specifically, EPA should identify or develop model land use, 

transportation and energy planning documents that address SIP/TIP credit issues 

applicable to each voluntary and innovative measure that is identified under 

recommended action B. Among other things, the documents should demonstrate how to 

quantify emission reductions expected from each identified measure in a manner where 

they can be considered for SIP/TIP credit. 

• EPA should also encourage adaptive plan revisions as indirect effects of innovative 

measures become better understood, which is consistent with current SIP requirements for 

reasonable emission reduction progress checks. The implementation challenge for this 

recommendation will be identifying appropriate targets for emission reduction initiatives 

and quantifying the air quality benefits expected or actually achieved as a result of any 

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Air Quality Management Subcommittee Final Report 

one initiative.

Benefits: 

• This recommendation shifts the focus for new programs away from traditional command 

and control strategies to strategies that are more likely to be effective in achieving 

additional air pollution gains in the areas of land use, transportation and energy planning. 

Recommendation 11: Develop programs to reduce public demand for 

polluting activities - Develop programs that focus on reducing public demand for 

polluting activities. Such programs could include incentive programs for 

encouraging use of lower-polluting activities, reduction programs, and tax and use 

restrictions. 

Background/Explanation: 

Much of air quality management has been directed at large scale sources of pollution, from 

all sectors of the inventory. While additional reductions from such sources are possible, 

further reductions may also be achieved by encouraging the public to reduce activities that 

produce pollution or to pursue less polluting alternatives. 

Problems/Challenges Addressed: 

• Meeting the NAAQS for ozone, PM2.5, and reducing regional haze. 

• Addressing air quality on the appropriate geographic scale (locally, regionally, and 

globally). 

• Addressing remaining pollution problems, including unregulated and smaller “area” 

sources. 

• Coordinating air quality, energy, transportation and urban planning strategies. 

Recommended Actions 

A. EPA should develop a social marketing and outreach strategy that includes, but is not 

limited to, helping the public make environmentally beneficial choices and understand 

the impact their decisions have on air quality. This marketing and outreach strategy 

should include approaches such as California’s 3-star recreational watercraft labeling 

program and DOT/EPA’s “Best Workplaces for Commuters” and “It All Adds Up to 

Cleaner Air” programs. EPA efforts should discourage activities that create more air 

pollution and encourage alternative activities that minimize environmental harm. As 

appropriate, EPA should consult with other federal agencies and stakeholders in 

developing the strategies. 

B. EPA should evaluate options for discouraging higher polluting activities (e.g., education, 

taxes, fees imposed on federal lands, and use restrictions) and encouraging less polluting 

activities (e.g., economic incentives, education, and expedited or streamlined permitting 

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Air Quality Management Subcommittee Final Report 

opportunities). For example, energy demand might be reduced through programs that 

educate the public about energy efficient practices or provide funding for energy 

efficiency and renewable energy projects. 

Implementation: 

• One implementation challenge will be possible resistance from industries that serve the 

demand for polluting activities. This resistance may be reduced by shaping programs to 

create opportunities for such industries to serve demand for activities with less air 

pollution impact. 

Benefits: 

• This recommendation would reduce air pollution at its source, which is the demand for 

activities that cause it. It also would involve the public directly in the decisions 

individuals make that affect air pollution. 

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Recommendation 12: Establish an inter-agency liaison group to coordinate 

land use, energy, transportation, climate change, and air quality goals - An 

inter-agency liaison group should be established with EPA and other federal 

agencies (e.g., FAA, HUD, DOE, NRC, FERC, USDA, CDC, DOI, and DOT) to 

explore issues and opportunities for coordinating land use, energy, transportation, 

climate change, and air quality goals. 

Background/Explanation: 

Land use, transportation, energy, and climate-related policies and programs are 

inextricably intertwined with air quality. Such policies and programs can conflict with 

attaining national air quality goals. Conversely, air quality policies and programs can 

conflict with or frustrate national transportation and energy goals. 

Federal agencies already coordinate their activities to some extent. For example, when 

EPA undertakes a major rulemaking, the Office of Management and Budget’s (OMB) 

Office of Information and Regulatory Affairs (OIRA) facilitates an inter-agency review 

process to ensure other federal agencies have an opportunity to review and provide 

comment on EPA rulemakings. Moreover, Executive Orders 13211 (May 18, 2001) and 

12866 (September 30, 1993) require federal agencies to prepare a Statement of Energy 

Effects when undertaking certain rulemaking actions that are likely to have a significant 

adverse effect on the supply, distribution or use of energy. A Statement of Energy 

Effects must include, among other things, detailed information regarding any adverse 

effects the agency action will have on energy supply, distribution, or use (including a 

shortfall in supply, price increases and increased use of foreign supplies). OIRA uses the 

Statements of Energy Effects to ensure that one federal agency’s proposed actions do not 

conflict with another agency’s policies or actions. Federal agencies must also publish 

their Statements of Energy Effects, or a summary in each notice of proposed rulemaking 

and in any resulting final rule. 

With the objective of enhancing the above efforts and facilitating earlier and more 

meaningful coordination between federal agencies and national programs and objectives, 

an Inter-agency Liaison Group should be established based on the guiding principle that 

our nation's land use, transportation, energy, climate change, and air quality programs 

and objectives must be aligned to serve consistent goals. The Liaison Group should 

include EPA and several other federal agencies such as FAA, HUD, DOE, NRC, FERC, 

USDA, CDC, DOI, and DOT. 

The creation of a federal coordination group has precedent. In the late 1970s EPA 

participated in the Interagency Regulatory Liaison Group or “IRLG.” This group brought 

together high-level officials from EPA and other federal agencies to discuss policies and 

issues of common concern. At least two current AQM Subcommittee members recall 

participating in the effort and believe it was highly effective. 

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Air Quality Management Subcommittee Final Report 

Problems/Challenges Addressed: 

• Coordination of air quality, energy, transportation and urban planning strategies.

• Maintenance of AQM efficiency in the face of changing climate.

Recommended Actions: 

A. EPA should proactively work with its federal partners (e.g., FAA, HUD, DOE, NRC, 

FERC, USDA, CDC, DOI, and DOT) to establish an Inter-agency Liaison Group to 

explore issues and opportunities for coordinating and aligning federal agency goals and 

objectives on energy, land use, transportation, climate change, and air quality. The 

purpose of the group would be to help ensure federal agencies work together in achieving 

coordinated and integrated solutions to these issues. 

B. In addition to periodically meeting, sharing information and working to align national 

programs and objectives, the group should work with OMB, CEQ and other interested 

stakeholders to develop a protocol under which federal agencies would (a) formally 

analyze major proposed federal rulemakings that are likely to have significant impacts on 

national land use, energy, transportation, climate change, and/or air quality programs or 

objectives; (b) for those proposed major regulations that are likely to have such 

significant impacts, prepare a Statements of Effects similar in content to the Statements 

of Energy Effects that Executive Orders 13211 (May 18, 2001) and 12866 (September 

30, 1993) currently require; and (c) subject such Statements of Effects to public review 

and comment. 

Implementation: 

• The Inter-agency Liaison Group should be established at the political or senior career 

level. It should include representatives from EPA’s air office and from other federal 

agencies. EPA should also create a lower-level working group to implement future 

recommendations of the group. The liaison group should use a Memorandum of 

Understanding (MOU) or other vehicle to establish a common understanding of its 

purpose and activities. The group should meet at least quarterly to share information and 

coordinate policies and programs. 

• In exploring and developing a protocol for analyzing and disseminating information 

regarding major proposed federal rulemakings, the liaison group (working with OMB, 

CEQ and other interested stakeholders) should consider and address several issues, 

including what proposed federal regulations are covered and the appropriate scope and 

extent of analysis and public participation. In addition, to avoid duplicative analyses, to 

the extent that a federal agency is required to prepare an impacts analysis pursuant to 

another statutory or regulatory requirement (e.g., the National Environmental Policy Act) 

that is substantially similar to the analysis that the protocol requires, the protocol should 

allow the federal agency to use that analysis in lieu of preparing a new duplicative 

impacts analysis. 

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Air Quality Management Subcommittee Final Report 

Benefits: 

• This recommendation encourages policy makers to better coordinate national air quality, 

energy, transportation and greenhouse gas programs and objectives. The rulemaking 

protocol would provide information on significant impacts proposed major federal 

rulemakings may have. It would allow policy makers and interested stakeholders to 

understand the degree to which proposed major federal rulemakings would further or 

undermine national air quality, energy, transportation, and greenhouse gas programs and 

objectives, including identifying opportunities to reduce the potential for adverse air 

quality impacts.

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Air Quality Management Subcommittee Final Report 

VIII. Need for Tools to Improve Air Quality 

 Today’s air quality problems pose difficult and in many ways different challenges to 

EPA, states, and tribes than the challenges of the past. While traditional air quality management 

has focused on reducing emissions from large stationary sources, fuels, and new car and truck 

engines, such strategies alone may no longer ensure attainment and maintenance of the nation’s 

air quality and public health goals. To meet the air quality challenges, EPA, states, and tribes 

must utilize and enhance existing tools, while simultaneously developing new and innovative 

tools to address emissions from a variety of sources such as existing cars and trucks (so-called 

“legacy fleets”), a wider range of engine and vehicle types (e.g., marine vessels), and many types 

of small and mid-size emission sources. Furthermore, although new engine emission standards 

promise to reduce dramatically (sometimes to near zero) the emissions from new cars, trucks, 

and from off-road vehicles and products such as lawn mowers, boats, and all-terrain vehicles, the 

continued growth in travel and the delivery of goods spurred by increasing population and 

personal income will likely make it necessary to go beyond technology-focused air pollution 

control strategies to address transportation, land use and energy efficiency concerns in major 

metropolitan areas. Although the nation now boasts some of the world’s cleanest products, fuels 

and vehicles, much can still be done to accelerate the turnover of existing fleets and to increase 

penetration of the cleanest products by implementing demand-side strategies to a greater extent 

than in the past. 

 The Subcommittee focused on several types of sources whose relatively uncontrolled or 

undercontrolled emissions contribute significantly to ozone or fine particle nonattainment in 

several areas of the country. The specific categories identified are legacy vehicle and engine 

fleets, ports and goods movement-related sources (e.g., trucks, ships and rail), airports, 

agricultural emissions, small sources (e.g., bakeries, restaurants, dry cleaners), consumer 

products, and industrial boilers. 

 The AQM Subcommittee also discussed a range of measurement-related tools needed. 

For criteria pollutants, these include the need for improved baseline emissions inventory data and 

ambient air quality data (e.g., due to existing gaps in monitoring). Measurement tool needs for 

toxic air pollutants are considered even more pressing. There is a need for data in many areas, 

including ambient concentrations, better risk assessment and speciation data improvements, 

significance levels, and potential impacts of air toxics on sensitive populations. The 

Subcommittee identified other measurement challenges, including consideration of the cobenefits and impacts of various control strategies, and potential local impacts associated with 

emissions trading. 

 The AQM Subcommittee discussed a number of other air quality planning challenges 

related to tools, including how to ensure SIP or TIP credit for non-traditional strategies, such as 

diesel reduction programs or innovative and voluntary incentive programs. The Subcommittee 

recognized resource limitations faced by many state, tribal, and local agencies. The AQM 

Subcommittee also recognized the lack of incentives available for attainment and nonattainment 

areas to encourage air quality problems from developing or worsening. For example, the 

Subcommittee discussed the need to encourage conservation on both the user and supplier side in 

several priority areas, including energy efficiency and consumer travel and purchasing choices. 

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Air Quality Management Subcommittee Final Report 

Potential Tools to Address Air Quality Challenges and Planning Needs 

 The AQM Subcommittee evaluated a variety of tools that could be used to address these 

challenges. Current tools, such as emissions limits, add-on controls, and emissions cap and trade 

programs, have been and will continue to be successful in improving air quality. The purpose of 

this evaluation was to identify and characterize additional tools that air pollution control officials 

could use in their efforts to manage air quality. The Subcommittee believes that a few of these 

tools are likely to prove valuable in areas of the country where, for example, there is a shared 

need to address older, higher-emitting vehicles or to address relatively uncontrolled or 

undercontrolled large stationary sources. Other tools may be appropriate for use in areas that 

face unique difficulties, such as ports and large airports. At large regional ports, for example, the 

existing and anticipated high density of engines requires that engine turnover or retrofits be 

accelerated. In these cases, strategies are needed to promote rapid and large-scale investment in 

clean fuels and technologies to help attain and maintain the ozone or PM 2.5 standards and 

thereby, protect public health. The use of tools such as emissions trading, pricing, or other 

financial strategies may raise novel or significant public policy questions (e.g., the use of 

acceptable risk benchmarks, inter-pollutant trading, emissions banking and borrowing, “in lieu” 

compliance strategies) that would need to be carefully considered at local, regional, and national 

levels. 

The AQM Subcommittee selected four areas to be given additional priority and review 

for developing tools for improving air quality. Examples of these programs include: 

(1) Financial tools for fleet turnover and diesel retrofits; 

(2) Financial tools for land use and transportation planning; 

(3) Information programs for land use and transportation planning; and, 

(4) Emission limits for industrial, commercial, residential boilers and heaters, and legacy 

equipment and sources. 

The AQM Subcommittee has prepared a matrix of potential tools which is presented in 

the appendix B to this report. The matrix focuses on specific newer tools that could be effective 

at reducing emissions for various sources or sectors. An outline of the needs and tools that have 

been identified can also be found in appendix B. 

(1) Financial Tools for Fleet Turnover and Diesel Retrofits

Financial tools and financial demand-side strategies that encourage fleet turnover and diesel 

retrofits include tax strategies, loans, equity strategies, and targeted rebates. 

Carl Moyer Program 

California’s Carl Moyer Memorial Air Quality Standards Attainment Program is a state 

and local partnership that provides incentive grants to cover the incremental costs of cleaning up 

heavy-duty engines more than is required by air pollution regulations. The program, established 

in 1998, was recently expanded and given a 2015 sunset date. Heavy-duty on-road and off-road 

equipment may qualify for grants, including farm and construction equipment, marine vessels, 

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Air Quality Management Subcommittee Final Report 

locomotives, and airport ground support equipment. Projects are diverse and range from the 

purchase of new alternative-fuel heavy-duty vehicles, such as transit buses, to engine 

replacements for construction equipment and marine vessels. 

Grants are issued and monitored locally by air pollution control districts and air quality 

management districts, following guidelines developed by the California Air Resources Board. 

The program achieves near-term reductions in emissions of NOx, PM, and reactive organic gas. 

The California Air Resources Board and local air districts fund the program jointly. 

Sources of revenue include smog check fees and tire fees. Local districts can also use vehicle 

registration fees. Districts match $1 in local funds for every $2 in Moyer funds. In recent years, 

about $140 million of incentive funding has been available annually through the Carl Moyer 

Program. Demand for the program is expected to remain high, given that the cost of cleaning up 

the state’s existing diesel engine fleet is estimated to be at least ten times the available Carl 

Moyer Program funds. 

Each California district is eligible to receive a minimum funding allocation. More 

populous districts in nonattainment areas are eligible for additional funding. In districts with 

populations over one million, at least 50 percent of Carl Moyer Program funds must benefit low 

income communities. 

In its first six years, the Carl Moyer Program provided over $140 million to clean up 

more than 6,300 heavy-duty engines, reducing NOx emissions by over 18 tons per day at a cost 

of about $2,600 per ton of NOx reduced. It is estimated that the program reduced lost workdays 

by about 17,000, prevented 2,800 asthma attacks and 100 premature deaths. 

TERP 

Another example of the use of incentive grants to encourage fleet turnover and diesel 

retrofits is the Texas Emissions Reduction Plan (TERP), established in 2001 and administered 

primarily by the Texas Commission on Environmental Quality (TCEQ). TERP includes a 

number of financial incentive and other assistance programs to help improve air quality. The 

main financial incentive programs are the Emissions Reduction Incentive Grants Program and 

the New Technology Research and Development Program. 

The Emissions Reduction Incentive Grants Program provides funds to eligible projects in 

nonattainment and near-nonattainment areas to offset incremental costs associated with reducing 

NOx emissions from high-emitting internal combustion engines. The Rebate Grants Program is 

a simplified application process available only for diesel on-road and off-road replacement and 

repower projects. Funds are also set aside for small business. 

The New Technology Research and Development Program offers grants to encourage 

research, development, and commercialization of pollution-reducing technologies. 

Other TERP programs include the Clean School Bus Program, which funds projects 

including diesel oxidation catalysts, diesel particulate filters, and add-on equipment to reduce 

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exposure to diesel exhaust from school buses; the Small Business Grants Program, which helps 

small businesses participate in TCEQ incentive programs; the Heavy-Duty Motor Vehicle 

Purchase or Lease Incentive Program, which can reimburse the purchaser or lessee of a new onroad heavy-duty vehicle for incremental costs of purchasing or leasing the vehicle in lieu of a 

higher-emitting diesel powered vehicle; and the Light-Duty Motor Vehicle Purchase or Lease 

Incentive Program, which provides rebates for the purchase or lease of an eligible new car or 

light truck. 

TERP grants are allocated through an annual or bi-annual application process. Sources of 

funding for TERP include a surcharge on some registration fees, a surcharge on the sale, lease or 

rental of off-road heavy-duty equipment, a surcharge on the sale or lease of diesel on-road 

vehicles, and a fee on commercial vehicle inspections. Revenues have been predicted to average 

about $150 million per year. About $130 million is allocated to the Emissions Reduction 

Incentive Grants Program, including about $2 million for small business incentive grants. About 

$14 million is allocated for the New Technology Research and Development Program. 

More information on financial incentives and other strategies to encourage fleet turnover 

and diesel retrofits may be found in the April 2006 report to the CAAAC from the Mobile 

Sources Technical Review Subcommittee, Recommendations for Reducing Emissions from the 

Legacy Diesel Fleet, at http://www.epa.gov/cleandiesel/publications.htm#caaac-apr06. 

(2) Financial Tools for Land Use and Transportation Planning

Financial tools and financial demand-side strategies used as incentives to encourage land use and 

transportation planning include differential pricing and tax strategies. 

Differential Pricing 

One innovative example of the use of differential pricing to reduce sprawl and emissions 

as part of a land use and transportation plan is occurring in Madison, Wisconsin. Beginning in 

2001, Dane County and the University of Wisconsin encouraged public transit through more 

accurate price signals. The introduction of marginal cost pricing for parking at the University 

was linked to the expansion of fixed price universal transit passes. According to initial 

estimates, participation by 500 employees who curtail driving by one day per week can reduce 

vehicle miles traveled by 350,000 per year, resulting in hydrocarbon reductions of four tons. 

Another example of differential pricing that has controlled sprawl and reduced emissions 

is occurring in Portland, Oregon. A plan was designed in the mid 1970s to increase transit use 

by eliminating free parking, reducing the number of parking spaces, encouraging dense 

development around transit stations, and providing free transit service for workers and shoppers 

within the central business district, called the Fareless Square. In the last ten years, the 

economically depressed Lloyd district on the edge of downtown has become Portland’s fastest 

growing economic district. That growth prompted transportation planners to focus on reducing 

use of cars for trips between downtown and the Lloyd district, to increase shopping and 

recreational opportunities through an extended downtown, and to increase the potential for new 

development downtown and in the Lloyd district. To meet these goals, the Fareless Square was 

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Air Quality Management Subcommittee Final Report 

extended to include the Lloyd district, and new parking meters and regulations were 

implemented to decrease car use. Development and zoning codes have been put in place to 

encourage high density, mixed use development along transit corridors. Ride sharing programs, 

guaranteed rides home, and reserved parking places for carpools and vanpools in the Lloyd 

district have contributed to Portland’s commitment to smart growth through innovative 

transportation and planning tools. 

Tax Strategies 

In 2007, the federal tax code allows tax-free transportation fringe benefits of up to $110 

per month per employee for transit or vanpool expenses. Unlike ordinary wage payments, 

employers do not have to pay their share of federal payroll taxes on tax-free transit benefits, and 

the cost of providing tax-free transit benefits can be deducted as a normal business expense. 

These benefits can be deducted from corporate gross income for purposes of taxation when paid 

by an employer. Employees pay no federal income tax on commuter benefits. This benefit 

encourages transit ridership and van or carpooling, both of which reduce vehicle miles traveled 

and thus reduce emissions that form ozone. Several states have also implemented tax incentive 

programs to encourage commuter benefits, including Connecticut, Delaware, Georgia, Maryland, 

Minnesota, New Jersey, and Oregon. 

An example of the innovative use of tax strategies is the Eco Pass, an annual photo ID 

transit pass developed by the Denver Area Regional Transportation District that is distributed to 

participating employers at significant discounts. The Eco Pass is tax deductible to employers 

and is a tax-free benefit for employees. If an employee has an unexpected change of schedule or 

emergency, the Eco Pass will guarantee a free taxi ride home. Pass holders can use all regular 

transit services seven days per week. The mayor has offered Eco Passes to all City of Denver 

employees, and expects over 35 percent of them to take advantage of the program. 

More information on these examples of financial tools used as incentives to encourage 

land use and transportation planning, and additional examples, may be found in the 2005 report 

of the National Association of Local Government Environmental Professionals, “Clean 

Communities on the Move”. See http://www.nalgep.org. 

(3) Information Programs for Land Use and Transportation Planning

Information programs, reward programs, and non-financial demand-side strategies (collectively 

referred to in this section as “information programs) for land use and transportation planning 

include clearinghouses, labeling, performance benchmarking, community “Green Action” lists, 

surveys, frequent flyer-type programs, and web tools that educate and influence decisions. 

Information programs can be targeted to a specific audience or designed for general 

consumption. Here are some examples of successful information programs. 

 

Clearinghouses and Web Tools 

The Smart Growth Network operates a web-based clearinghouse aimed at land use and 

transportation planning. The clearinghouse promotes economic development that simultaneously 

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fosters healthy communities, strong neighborhoods, and transportation choices by providing 

tools, resources, and information sharing. For more information, visit 

http://www.smartgrowth.org. 

Web-based tools to assist in land use and transportation planning are also available. For 

example, the Smart Growth INDEX model simulates alternative land use and transportation 

scenarios using GIS sketch models to incorporate smart growth principles into planning 

processes. See http://www.epa.gov/smartgrowth/topics/sg_index.htm. 

Similarly, EPA Region 3’s Green Communities Program has a web-based clearinghouse 

that provides access to tools, technical assistance, and training to integrate environmental goals 

applicable to urban, suburban, and rural communities. For more information, see 

http://www.epa.gov/greenkit. 

Information and Reward Programs 

As part of a program to address air pollution and congestion challenges in Tulsa, the 

Indian Nations Council of Governments sponsored an innovative information program called 

Driving Toward Clean Air. The program targeted high school students, providing teen drivers 

with information about “green” vehicles, carpooling, air pollution, and alternative transportation 

methods. The Tulsa Air Quality Enhancement and Education Project sponsored a competition 

where students pledged to carpool, ride the bus, or walk to school during a six-week period. The 

high school with the most participation received a new Toyota Prius hybrid as a reward. This 

program was recognized by EPA with a 2004 Clean Air Excellence Award. See 

http://www.epa.gov/air/caaac/2004awar.html. 

(4) Emission Limits for Industrial, Commercial, Residential Boilers and Heaters and 

Legacy Equipment and Sources

Several examples of efforts addressing this source category are worth highlighting, some 

of which have been completed and some of which are underway. The examples range from 

traditional emission limits to voluntary-based approaches and a hybrid of the two. 

Hazardous Air Pollutants

In September 2004, EPA promulgated a national emission standards specifying 

application of MACT to address HAPs from industrial, commercial, and institutional boilers and 

process heaters. EPA identified this source category as a major source of HAP emissions 

Implementation of the standard is expected to reduce HAP emissions by 50,600 to 58,000 tons 

per year. The air toxics emitted by facilities in the boiler and process heater source category 

include arsenic, cadmium, chromium, hydrogen chloride, hydrogen fluoride, lead, manganese, 

mercury, nickel, and various organic air toxics. For more information, visit: 

http://www.epa.gov/ttn/atw/boiler/boilerpg.html. 

Criteria Air Pollutants 

As part of Phase I, the AQM Work Group recommended to EPA that it complete as soon 

as possible a review of the contributions from the industrial, commercial, and institutional boiler 

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category and the technical and economic feasibility of further controls, given the high priority 

assigned to this sector (Recommendation 2.1). It indicated that EPA should then initiate 

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

alternative action consistent with the results of its analysis. To respond, in coordination with 

EPA, the Regional Planning Organizations will collect and analyze data concerning industrial, 

commercial, and institutional boilers to effectively characterize these sources and their 

environmental impacts. EPA plans to include the National Association of Clean Air Agencies 

(NACAA) and other organizations in this comprehensive approach. 

In March 2006, NACAA released a report, “Controlling Fine Particulate Matter under the 

Clean Air Act: A Menu of Options.” Chapter 6 presents control options for industrial and 

commercial boilers. The report is available at: http://www.4cleanair.org/PM25Menu-Final.pdf . 

Residential Units

 Voluntary Approaches 

In January 2007, EPA launched a voluntary partnership program to reduce emissions 

from outdoor wood-fired hydronic heaters (OWHH), also called outdoor wood boilers or outdoor 

wood-fired furnaces. The voluntary program will bring significantly cleaner outdoor wood-fired 

hydronic heaters (OWHH) to market beginning in 2007. OWHH burn wood to heat water, 

which is generally piped underground to provide heat for homes. A typical OWHH looks like a 

small shed with a smokestack, and is usually located next to the building to be heated. 

Sixteen OWHH manufacturers have signed a memorandum of understanding with EPA 

that commits them to use their best efforts to develop, manufacture, and market one or more 

cleaner models. Under this agreement, the new models must emit no more than 0.6 pounds of 

particle pollution per million BTUs of heat input (i.e., wood burned). The models must be tested 

by an accredited third-party laboratory to verify that they meet these levels. The cleaner heaters 

made available through the voluntary program will be about 70 percent less polluting than 

current models. Consumers interested in the new, cleaner models should look for an orange 

hangtag that will show how a specific model compares to EPA’s performance specifications. A 

list of program partners can be found at http://www.epa.gov/woodheaters/partners.htm

 In addition to the effort for OWHHs, EPA and many states, tribal and local agencies are 

continuing the effort begun as far back as the 1980s to change out old and dirty residential 

woodstoves with EPA certified wood-burning appliances that burn more cleanly and efficiently. 

EPA has developed a how-to guide for areas to use to determine whether it is feasible for a 

jurisdiction to develop and implement a Woodstove Changeout program. The how-to guide can 

be found on EPA’s Clean Wood Burning Stoves and Fireplaces website at 

http://www.epa.gov/woodstoves/. 

Regulatory Approaches 

In addition to the voluntary OWHH and woodstove programs, EPA has provided technical 

assistance to the Northeast States for Coordinated Air Use Management (NESCAUM), an 

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association of eight northeastern states, to develop a model rule that states, tribes and local 

governments may use if they choose to regulate OWHH. The rule can be tailored to address 

specific local situations. The model rule establishes emission limits and labeling requirements 

for new units. It also contains the following components for both new and existing OWHH: 

 

• Setback requirements from property lines, structures and residences, 

• Stack height requirements, and, 

• Distributor and buyer notification requirements. 

The model rule can be found at: http://www.nescaum.org/topics/outdoor-hydronic-heaters 

The State of Vermont recently promulgated regulations for OWHH based on the 

NESCAUM model rule. Under the new regulation, all new boilers sold/installed in Vermont 

must certify a particulate emissions limit of 0.44 lb/mmBTU by March 2008. Other states are 

also developing regulations to address OWHH emissions. 

In addition, EPA is assessing other non-regulatory options including labeling to 

differentiate between regulated and non-regulated units and emission limits. 

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Air Quality Management Subcommittee Final Report 

IX. Unresolved Areas of Discussion 

The AQM Subcommittee was unable to reach substantial consensus with regard to a few 

proposed recommendations. This section summarizes the key areas where this occurred and the 

nature of the differences of opinion that arose. 

Unresolved Recommendation 1: Implement the use of “regional airsheds” to approximate the 

boundaries of emission source areas most likely to contribute to nonattainment areas. 

Background 

Historically, nonattainment area boundaries have been established to focus primarily on 

local scale (i.e., state- or area-specific) control measures, though some also included 

control measures for which agreement on regional application was reached outside of the 

SIP process. The more traditional local-problem and local-control approach that proved 

successful in the past for many of the criteria pollutants, has more recently had limited 

success in remedying ozone and fine particle NAAQS nonattainment issues, as well as 

regional haze problems. 

For two important reasons, the current approach to boundaries with respect to 

nonattainment area designations warrants review. First, the designation process has been 

based on geo-political boundaries, which causes some difficulties in dealing with 

problems that transcend such boundaries. Second, many states feel that there is a stigma 

associated with the label of “nonattainment.” This is largely due to the mandatory 

requirements that take effect in nonattainment areas. As a result, in some areas, there 

has been a tendency to define nonattainment boundaries as small as possible. 

Goals 

The AQM Subcommittee discussions regarding boundaries were initiated with the 

following desired endpoints on the need to: 

• Address situations where emissions in upwind areas contribute significantly to violations 

elsewhere; 

• Provide a mechanism that can address interstate transport during the SIP/TIP 

development process and ensures that areas with contributing sources are involved in the 

initial SIP/TIP planning process; 

• Minimize disincentives for monitoring; 

• Reduce the desire/incentive to define areas of violation as small as possible; 

• Not punish areas where air quality is poor if they have taken all reasonable steps to 

reduce local emissions; 

• Better define sources that actually contribute to NAAQS violations and have a system 

that naturally includes those sources in the area subject to control requirements; 

• Set boundaries based more on science and less on geo-political boundaries; 

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Air Quality Management Subcommittee Final Report 

• Recognize the increasing necessity for regional programs within which states must work 

cooperatively and ensure accountability; 

• Respect state/tribal rights and balance local and regional control programs with 

complimentary national control programs; and, 

• Recognize the increasing need for national control programs in which the federal 

government takes the lead and ensures accountability. 

Recommendations 

The AQM Subcommittee was in substantial agreement on two important concepts related 

to setting boundaries, and achieved consensus on a set of principles that should guide the 

development of a new approach to establishing boundaries. The Subcommittee could not, 

however, reach agreement on the details of how the concept should be implemented. 

Instead, the Subcommittee substantially agreed on the need for an airshed approach to 

boundaries (regional, as appropriate) and the following concepts: 

A. The current approach to establishing nonattainment area boundaries that define 

both the area that violates a NAAQS as well as the area within which emissions 

must be reduced to achieve attainment should be replaced. The new approach 

should include areas that violate NAAQS and areas where controls are needed and 

should be defined independently based on scientific assessments. 

B. Control areas should encompass all significant contributors to the NAAQS 

violation, without regard to state/tribal or other geo-political boundaries. By 

controlling emissions from the sources included within the control area boundary, 

timely attainment of the NAAQS will be assured. 

Consensus was also reached on the following guiding principles: 

C. Revisions to the current nonattainment area boundary approach should improve 

upon the current system, resulting in one or more of the following: 

• More timely emissions reductions; 

• More effective emissions reductions; 

• Less dispute; 

• More flexibility to choose appropriate controls; and, 

• Facilitation of an airshed-based approach to managing air quality. 

D. When a NAAQS is violated, people exposed to unhealthful air quality must be 

informed. 

E. When a NAAQS is violated, prompt steps must be taken to restrict emission 

growth that might aggravate the problem. 

F. Defining the area within which air quality is unhealthful, and the area within 

which emission sources need to be controlled, should be based on scientific 

factors. 

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Air Quality Management Subcommittee Final Report 

G. Any new boundary-setting approach should facilitate, or at least not further 

complicate, efforts to address air quality on a multipollutant basis, as 

recommended in the NRC report. 

The AQM Subcommittee agreed that significantly more in-depth discussion would be 

needed before a specific recommendation could achieve substantial consensus. Because 

such a recommendation would need to discuss trade-offs between currently mandated 

CAA requirements and other (presumably more effective) emission control requirements, 

further discussions would need to include a broad array of stakeholders potentially 

affected by the changes. 

Summary of Boundaries Discussion 

The AQM Subcommittee formed a work group to advise it on recommendations related 

to boundaries. Based on consensus of the above concepts and principles, and building 

from the Federal Advisory Committee (FACA) work in the early 1990s on Areas of 

Violation and Influence (AOV and AOI), the boundaries work group recommended to the 

AQM Subcommittee that EPA expand its conventional application of nonattainment area 

boundaries through a concept of “control regions.” The work group thought that broader 

application could maximize effectiveness and establish equity in implementing air 

pollution controls needed to bring areas that violate the NAAQS into attainment. The 

concept of “airsheds” was accepted by consensus of the AQM Subcommittee. However, 

questions regarding the details of its implementation arose during subsequent 

conversations of the Subcommittee. 

The boundaries work group recommended separating areas with NAAQS violations from 

areas that contribute emissions to those areas. For purposes of the discussion, the 

boundaries work group referred to areas where air quality does not meet the NAAQS as 

“areas of violation” and areas where emissions contribute to those violations as “control 

regions.” As envisioned, the area of violation would usually be contained within the 

control region, though there would be situations in which there is partial or even no 

overlap. 

The basic components of the proposal made by the boundaries work group to the AQM 

Subcommittee on implementation include: 

• An area of violation defined by air quality monitoring data where public education 

and health advisories are emphasized; 

• A control region based on existing scientific information (from the states and EPA) 

about which types of sources in which geographic areas are contributing to the 

violations of NAAQS (which in most cases, but not always, will encompass the area 

of violation); 

• A stationary source program for the control region that involves: 

• state of the art controls for entirely new significant sources and significant 

modifications at existing sources; 

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Air Quality Management Subcommittee Final Report 

• reasonable retrofit controls (and continuation of existing requirements) for 

significant existing sources; and, 

• reasonable retrofit controls for small sources once their actual emissions 

exceed a significance threshold; 

• An emissions offset requirement that targets the emissions reductions needed to offset 

growth (with a default to the stationary source offset program); 

• Local mobile sources programs in the control region to complement the basic federal 

programs as the state/tribe deems appropriate as part of its SIP/TIP (programs 

currently required by the Act would remain); and, 

• Mechanisms to assure multi-state control programs are implemented when the 

pollution problems are regional (interstate). 

Under this proposal, EPA and regional and state modeling centers would work together to 

understand meteorology and transport of all NAAQS pollutants, and once an air quality 

violation was found, they would work to establish preliminary control regions. These 

preliminary control regions could be refined into more scientifically defined regions 

through an exercise conducted in a state, multi-state, and tribal collaboration that could 

be moderated by multi-state organizations with the assistance of EPA. Once such 

geographic regions are finalized, regional control strategies (through Air Quality 

Management Plans) could be developed and incorporated in individual enforceable 

SIPs/TIPs. The value of using SIP calls by EPA under the CAA section 110 at the time of 

designation was also discussed. The SIP calls would provide the needed forcing function 

for each state identified in the preliminary analysis to develop enforceable plans that 

contain all appropriate measures needed for attainment in the affected areas of violation, 

both in state and out of state. The appropriateness of area of violation and control region 

boundaries should be periodically reviewed with a technical analysis to ensure 

appropriate coverage and progress toward attainment. 

Reactions to Boundaries Proposal 

The Subcommittee focused its discussion on the specifics of mandated levels of controls 

and the details of how to apply the control region boundaries. Some believed that the 

control regions should be very large to be highly inclusive of all contributing sources, 

while others wanted to limit their size to minimize impacts on more remote businesses. 

One member was concerned about the ability of states to be able to transcend political 

issues and geo-political consideration, and base boundaries solely on scientific evidence. 

There was concern that, as a result, boundaries would be smaller, not larger. After 

considerable discussion, the AQM Subcommittee asked the work group to provide further 

clarifications on levels of specified controls and their applicability. One member 

requested that the work group develop a boundary proposal based on existing political 

boundaries. 

After considerable deliberations, the boundaries work group developed a two-option 

recommendation. The first option built upon and clarified the previously proposed 

airshed-control region proposal, which would be multi-state, as appropriate. The second 

option presented a “no-boundary” approach that allows states/tribes to remedy their own 

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Air Quality Management Subcommittee Final Report 

problems without defining boundaries. It would allow states and tribes to use appropriate 

flexibility in pollution control requirements to meet attainment while being clearly 

required to comply with CAA transport provisions. Under this two-option proposal, 

states/tribes capable of remedying their own attainment problems would be granted 

greater flexibility in control levels and those controls would be specified without needing 

to formally define a control region, while states/tribes dealing with regionalized air 

pollution would be required to work together to develop an acceptable area to control 

assuming a certain base-level of mandated controls and supplemented by other, more 

flexible control measures. Both types of nonattainment areas would need to demonstrate 

that their plan could meet attainment as expeditiously as possible, as required under the 

CAA. Some members believed that multiple states/tribes needed a formal mechanism to 

require them to work together upfront in some areas of the country where interstate 

transport is a factor. Some Subcommittee members also believed that some prescribed 

control measures are needed to supplement more flexible measures to meet attainment. 

Others supported a full no boundary approach for all states/tribes where they would be 

free to use approaches they deemed appropriate and necessary to fix their own problems. 

Some members were optimistic that revising the boundary setting process would be 

sufficient to address interstate transport so that all states could attain the NAAQS. Others 

thought that another mechanism, not yet deliberated or developed, would be needed to 

address interstate transport. 

Following much discussion, the Subcommittee agreed that the boundaries issues could 

not be resolved within the AQM Subcommittee. For this reason, the Subcommittee 

agreed to describe the proposed boundaries approaches in this report and provide a 

summary of views made by Subcommittee participants in hopes that it be useful to any 

future forum on the boundaries topic. 

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Air Quality Management Subcommittee Final Report 

Unresolved Recommendation 2: Over a period of time, all sources of air pollution should 

be required to demonstrate that they are achieving reasonable performance levels (RPLs) 

to control emissions. The form and substance of this concept should be developed with 

consideration of applicable emission control regulations, technical feasibility, and costs as 

well as all fuel, operational, and emission control options. 

Background 

The Subcommittee considered a concept called “reasonable performance levels” (RPL). 

It is based on the idea of treating airsheds as a finite and essential resource, and sources 

are not entitled to pollute that no source would be left uncontrolled. The RPL approach 

would require all categories of air pollution to take steps to limit their emissions. RPLs 

would be established and periodically updated for all air pollution sources and all 

pollutants, beginning with the sources and pollutants that pose the greatest risk to public 

health and ecosystems. New and expanding sources not otherwise subject to emission 

control mandates would be required to demonstrate that reasonable performance levels 

have been achieved at start-up. The RPL approach would provide a foundation for 

additional controls that might be needed to address existing or potential area-specific 

problems. For example, due to transport issues from upwind sources implementing RPLs, 

an area may still violate a NAAQS. Under these circumstances, attainment SIPs with 

specific deadlines may still be needed to protect public health. An RPL program would 

likely require amendments to the CAA. 

Discussion 

Reasonable performance levels could address many of the challenges defined in the NRC 

report, such as taking an integrated multi-pollutant approach and utilizing performancebased control strategies for under-regulated sources. Criticisms of the recommendation 

focused on: 

• How to define “reasonable control.” The discussion centered on two aspects, i.e. 

would reasonable controls be decided on a case-by-case basis, and what nature 

and level of cost-effectiveness criteria would apply? 

• Whether a regulatory review and control action would be imposed on all sources 

(without regard to location, age, size or existing regulatory status) or whether the 

review should be imposed on a subset with the greatest potential for cost-effective 

and significant emissions reductions. The concern was for the trade 6off between 

the administrative and control cost and the air quality benefit. 

• Whether this would be a one-time review to address “grandfathered” uncontrolled 

sources or whether this would be a measure imposed at certain time intervals. 

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Air Quality Management Subcommittee Final Report 

A few alternative approaches were offered to improve the recommendation, such as 

applying it only to sources that emit 100 tons per year but that have never undergone a 

Prevention of Significant Deterioration (PSD) permit review. Some Subcommittee 

members also felt that the recommendation did not do enough to control emissions from 

under-regulated sources. Based on the varying viewpoints, the Subcommittee decided 

that substantial consensus on this issue was not possible. 

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Air Quality Management Subcommittee Final Report 

Unresolved Recommendation 3: “Continuous improvement” should be achieved via a 

combination of mechanisms to achieve continuous emission improvements nationwide. 

Mechanisms discussed included voluntary programs at the local level, continuing a 

national program of command and control emission standards, and several options for 

strengthening and enhancing various market-based programs to encourage continuous 

improvements. 

Background 

The AQM Subcommittee considered mechanisms to achieve continuous emission 

reductions from all stationary, mobile and area sources that would lead to continuous air 

quality improvement in all geographic regions of the nation with the improvements going 

beyond attainment of the NAAQS. Continuous improvement could occur via a flexible 

system that would accommodate changes in science and air quality planning needs. A 

work group was convened by the Subcommittee to inform it on the subject of continuous 

improvement. The work group realized that to be successful, a combination of 

continuous improvement approaches would be needed to address all appropriate source 

sectors and provide options to reduce emissions at reasonable cost. 

Several options were considered such that, when used in combination, they could 

provide a new approach to managing air quality. Different geographic or political areas 

would utilize different combinations of options to custom design an air quality approach 

that would work best for that area. Two forms of continuous improvement were 

considered: 

The first concept focused on maintaining existing air quality by offsetting 

emissions increases associated with growth in demand for goods and services. The goal 

was to improve operational efficiencies to generate more electricity, produce more 

products, provide more services, and accommodate more vehicles on the road without 

increasing air pollution emissions. This concept currently exists in components of many 

SIPs (e.g., reasonable further progress requirements, requirements to maintain the 

NAAQS), conformity regulations, cap and trade programs (e.g., where industries must 

accommodate increased production under a fixed cap), and in prescribed offset ratio 

requirements for certain nonattainment areas. While market-based programs have helped 

address improvements for large point sources, improvements in certain mobile and area 

source sectors have been more difficult to achieve. 

The second concept focused on health and environmental improvements that 

would be achieved by gradually reduce ambient air pollution levels over time to lower 

levels than currently foreseen under the current NAAQS. The concept was intended to 

realize public health and environmental benefits through a program that would result in 

continuous improvement in emission rates and ambient air pollution concentrations. 

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Air Quality Management Subcommittee Final Report 

Recommendations and Options 

The continuous improvement work group recommended that a combination of 

options be considered and implemented to achieve continuous emission improvements 

across multiple source sectors (i.e., mobile, stationary, and area). Recommendations 

included voluntary and incentive-based programs at the national, state, tribal, and local 

levels. This included options for strengthening and enhancing various market-based 

programs to encourage continuous improvements. The work group agreed that a onesize-fits-all requirement could not be justified and that multiple programs should be 

pursued simultaneously. It agreed that there should be an emphasis placed on demandside or end-use efficiencies, as well as on mobile and less regulated emission sources. 

Based on historical successes with market-based systems and the general 

preference of businesses and individuals to control their own decisions, the work group 

supported, where appropriate, the use of market-based incentive programs as a 

component of continuous improvement. Examples of such programs include: 

• Public emissions reporting/product use emission information (all source types) 

similar to the Toxic Release Inventory (TRI) program to apply public pressure for 

“cleaner” products; 

• Emission fees (all source types) with revenues used to pay for other 

environmental initiatives; and, 

• Emission fee system based on an industry average performance. 

The work group also acknowledged that there might be advantages to greater use of 

cap and trade approaches to continuous improvement where SIP/TIP strategies require 

specific source sector emissions reductions. These might include: 

• Traditional emissions cap and trade, especially for high growth industries; and, 

• Emissions cap and trade with a continuously declining cap or allowance 

retirement. 

The work group first reviewed a wide range of continuous improvement options 

ranging from doing nothing to mandated controls to achieve ongoing improvements. 

Many options were eliminated quickly because they were unattractive to industry in that 

the concept of continually improving emission controls introduces uncertainty that could 

hamper long-term investments, and that could possibly cause them to be outdated before 

being paid off. 

Reactions to the Continuous Improvement Proposal 

There was a wide range of reaction within the AQM Subcommittee to the 

continuous improvement concept that ultimately led to the conclusion that substantial 

consensus would not be possible. Some Subcommittee members supported the concept. 

Other members stated that the proposed options lacked certainty, and would constrain the 

business activities at affected facilities. Some believed cost-effectiveness criteria would 

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Air Quality Management Subcommittee Final Report 

be needed to limit such a program and those criteria would be redundant with the 

emissions reductions achieved through the NAAQS and national emission standards. 

Some members advocated a voluntary program and suggested that a voluntary emission 

reporting program similar to mandatory Toxics Release Inventory (TRI) reporting would 

produce the needed improvements. Others stated that mandatory programs would be 

necessary to drive needed improvements and push technology development. 

General concerns expressed: 

• Proposal was targeted at stationary sources and did not focus enough on emissions 

from other sources; 

• Proposal could be costly and the role of cost effectiveness was not defined; 

• Programs incorporating a fixed glide slope forces technology development that 

may be beyond source’s ability to produce and/or may be too expensive; 

• Voluntary programs will not work without a mandatory backstop and a reasonable 

amount of time to produce results; and, 

• Continuous improvements set unreasonable expectations, left open the question of 

“when is enough continuous improvement enough?” and creates too much 

uncertainty for the business and industry constituents. 

Again, following much debate on this issue, the AQM Subcommittee decided to 

include continuous improvement as an area worthy of future discussions. The intent here 

is to document the discussions and viewpoints to help inform those future discussions. 

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Air Quality Management Subcommittee Final Report 

X. Conclusions 

 The Clean Air Act continues to deliver significant benefits both in terms of protection of 

public health and the environment. As described in the report for the first phase of this AQM 

review (January 200 Phase I Report) and in the 2004 NRC report that spawned this process, the 

nation has made enormous strides since 1970 at improving air quality during a period of 

economic prosperity and population growth. 

 The future of air quality management offers tremendous opportunities to continue the 

Clean Air Act’s record of progress toward protecting public health and the environment. With 

these opportunities come unique challenges. New scientific information indicates an ongoing 

need to address significant threats to public health and the environment from air pollution. 

Climate change and improved understanding of the risk posed by hazardous air pollutants will 

also challenge air quality management planners by highlighting the need for new approaches and 

strategies. 

 The AQM Subcommittee strongly believes that moving from the pollutant by pollutant 

approach of the current air quality management system to the comprehensive multipollutant 

approach outlined in this report will substantially help meet the air quality challenges of the 21st

century. This more holistic approach calls for collective efforts of governmental organizations, 

including states, tribes, local communities, EPA, DOE, DOT, and others to develop and 

implement this comprehensive planning approach. The AQM Subcommittee recommends that 

the concept for a comprehensive air quality management system be implemented in its entirety. 

The Subcommittee also believes that the 12 recommendations contained in this report stand on 

their own merits and can, therefore, be implemented separately to improve the current approach 

to air quality management in this country. Continuing to protect and preserve clean air is a duty 

and responsibility that this Subcommittee has taken seriously and these recommendations have 

been considered with the goals of protecting public health and the environment. 

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Air Quality Management Subcommittee Final Report 

XI. Appendices 

 

Additional documentation of the work completed by the Air Quality Management 

Subcommittee can be found at the Clean Air Act Advisory website at 

http://www.epa.gov/air/caaac.html. The additional documentation includes meeting 

summaries, draft ideas considered by the work groups not adopted by the Subcommittee, 

and presentations from the Subcommittee meetings. 

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Air Quality Management Subcommittee Final Report 

Appendix A: Membership and Organizational Structure of the 

Air Quality Management Subcommittee 

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Air Quality Management Subcommittee Final Report 

74 

 

AQM Subcommittee Chairs 

Gregory A. Green 

US EPA 

Patrick Cummins 

Western Governors’ Association 

AQM Subcommittee Members 

Michael Bradley (CAAAC) 

M.J. Bradley Associates Inc. 

Don Clay (CAAAC) 

Koch Industries, Inc. 

Gregg Cooke (CAAAC) 

Guida, Slavich, and Flores, PLLC 

Greg Dana (CAAAC) 

Alliance of Automobile Manufacturers 

Anna Garcia 

Ozone Transport Commission 

Carolyn Green (CAAAC) 

Sunoco Inc. 

Lisa Gomez (CAAAC) 

Sempra Energy 

Stephen Hartsfield 

National Tribal Air Association 

Jim Hendricks (CAAAC) 

Duke Energy 

Christopher Hessler (CAAAC) 

AJW, Inc. 

John Hornback 

SESARM/Metro 4, Inc. 

Sharon Kneiss (CAAAC) 

American Chemistry Council 
Air Quality Management Subcommittee Final Report 

Mark MacLeod 

Environmental Defense 

J. Mark Morford 

 Stoel Rives LLP 

Janet McCabe (CAAAC) 

Improving Kids Environment 

Brock Nicholson 

State of North Carolina 

Janice Nolen (CAAAC) 

American Lung Association 

Margie Perkins 

State of Colorado 

David Shaw 

State of New York 

John Seitz 

ES&P, LLC 

Lynn Terry 

State of California 

Leah Weiss 

Northeast States for Coordinated Air Use Management (NESCAUM) 

Robert Wyman, Esq. (CAAAC) 

Latham and Watkins LLP 

Significant Contributors to the AQM Subcommittee

Tom Chapple 

State of Alaska 

Pamela Giblin (CAAAC) 

Baker Botts, LLP 

Tim Hunt 

American Forest and Paper Association 

Dan Johnson 

Western States Air Resources Council (WESTAR) 

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Air Quality Management Subcommittee Final Report 

Chuck Mueller 

State of Georgia 

Michael Sheehan 

State of New York 

Patty Strabbing 

DaimlerChrysler 

Jeff Underhill 

State of New Hampshire 

Larry Greene 

Sacramento Air Quality 

Jerry Kotas 

US Dept of Energy 

Steve Winkelman 

Center for Clean Air Policy 

Camille Mittleholz 

US Dept of Transportation 

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Air Quality Management Subcommittee Final Report 

77 

 

Air Quality 

Management 

Subcommittee 

Co-Chairs

Gregory Green, EPA 

Patrick Cummins, Western 

Governors’ Association 

Air Quality 

Planning 

Workgroup 

Co-Chairs

Don Clay 

Janet McCabe 

Lydia Wegman

Air Quality 

Management 

Tool Workgroup 

Co-Chairs

Anna Garcia 

Deborah Wood 

Robert Wyman 

Defining and 

Setting 

Priorities 

Lead: Janet McCabe 

AQM Planning 

Process 

Lead: Brock Nicholson 

Coordination with 

Land Use, 

 Energy, 

and Transportation 

Lead: Lisa Gomez 

Boundaries 

Workgroup 

Reasonable 

Performance Levels 

Workgroup

Continuous 

Improvement 

Workgroup 
Air Quality Management Subcommittee Final Report 

Appendix B: Matrix of Tools to Improve Air Quality 

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Air Quality Management Subcommittee Final Report 

Matrix of Potential Tools to Address Air Quality Challenges and Planning Needs 

Sources or 

Sectors (not 

in priority 

order) 

Recommended 

Tool Type 

Specific Tool Options Pollutant 

Targeted 

(1) Fleet 

turnover & 

diesel retrofits 

A. Financial tools 

and financial 

demand-side 

strategies 

B. Emissions 

Trading 

C. Information 

programs, reward 

programs and nonfinancial demandside strategies 

D. Planning tools 

E. Retrofit 

strategies 

F. Enforcement 

enhancements 

I. Emission limits 

A. Tax strategies, loans, equity strategies, and targeted rebates are 

financing strategies that may encourage fleet turnover (e.g., TERP, DERA, 

Moyer). 

 

B. Emissions trading may offer an appropriate private sector source of 

financing to accelerate turnover. Approaches that might work best for 

fleet turnover purposes include inter-sector trading strategies as well as 

fleet averaging programs. 

C. Clearinghouses can disseminate information on technology and 

incentives to educate and promote the use of technologies that have a 

positive impact on air quality. Labeling can be used to inform the general 

public of the relative benefits of choices they are making and to promote 

the use of new and innovative technologies and resources. Performance 

benchmarking can be used to highlight the positive characteristics of new 

and innovative technologies through comparison of these technologies 

against standard market practices and/or the continued use of existing 

products. Surveys can be used to gauge the effectiveness of the programs 

and to inform federal, state, tribal and local entities of program results and 

market changes. Frequent flyer-type programs can be used to provide 

incentives for entities that make frequent purchases by offering discounts, 

rebates, credits or other offerings to promote repeated use of the product(s) 

being promoted. Web tools can be used to move product information. 

This information can be targeted to a specific audience or for general 

consumption to inform, promote, educate and influence decisions. 

D. Modeling to estimate the emission reduction benefits of fleet turnover 

and retrofit is recommended. An inventory of the number of diesel 

engines that could benefit from retrofit is recommended. 

E. Retrofit strategies include converting existing engines to an alternative 

fuel, engine recalibration, adding additional emission controls, 

replacement with a new, cleaner engine, anti-idling, and other changes in 

operating strategies that reduce emissions. 

F. Use Supplemental Environmental Projects (SEP) funding to encourage 

fleet turnover and retrofits. Use remote sensing to measure reductions. 

I. Require mandatory diesel retrofit. Require scrapage programs. Use 

green contract conditions in government contracts. Use state and federal 

leadership programs. 

PM, NOx, 

VOCs, CO 

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Air Quality Management Subcommittee Final Report 

80 

 

Sources or 

Sectors (not 

in priority 

order) 

Recommended 

Tool Type 

Specific Tool Options Pollutant 

Targeted 

(2) Land use 

& 

transportation 

planning 

(including 

road 

exposures) 

A. Financial tools 

and financial 

demand-side 

strategies 

C. Information 

programs, reward 

programs and nonfinancial demandside strategies 

D. Planning tools 

H. Targeted 

strategies 

A. Financial demand-side strategies like differential pricing and tax 

strategies can be used as an incentive. 

C. Clearinghouses can disseminate information on technology and 

incentives to educate and promote the use of technologies that have a 

positive impact on air quality. Labeling can be used to inform the general 

public of the choices they are making and to promote the use of new and 

innovative technologies and resources. Performance benchmarking can be 

used to highlight the positive characteristics of new and innovative 

technologies through comparison of these technologies against standard 

market practices and/or the continued use of existing products. 

Community “Green Action” lists can be utilized to provide access to tools 

and information that will help promote the use of more sustainable “Green 

Community” concepts, including on line tutorials in the use of modeling 

software, model codes and ordinances, sample plans, community 

involvement practices and funding opportunities. Surveys can be used to 

gauge effectiveness of the programs and to inform federal, state, tribal, and 

local entities of program results and market changes. Frequent flyer-type 

programs can be used to provide incentives for entities that make frequent 

purchases by offering discounts, rebates, credits or other offerings to 

promote repeated use of the product(s) being promoted. Web tools can be 

used to move product information. This information can be targeted to a 

specific audience or for general consumption to inform, promote, educate, 

and influence decisions. 

D. Provide modeling software for scenario envisioning and to quantify 

emission reductions. Modeling to project VMT for transportation 

planning is recommended. 

H. Non-measured VOC sources can be detected by thermal IR camera 

(e.g., floating roof storage tanks, VOC loading racks, pipeline operations, 

marine vessels, and marine loading operations). 

PM, NOx, 

VOCs, CO 
Air Quality Management Subcommittee Final Report 

(3) Ships 

and ports, 

airports, 

and rail 

systems 

A. Financial tools 

and financial 

demand-side 

strategies 

B. Emission trading 

C. Information 

programs, reward 

programs and nonfinancial demandside strategies 

D. Planning tools 

E. Retrofit strategies 

F. Enforcement 

enhancements 

H. Targeted 

strategies 

I. Emission limits 

J. Work practice 

standards 

A. Tax strategies, loans, equity strategies, and targeted rebates are 

strategies that provide financial incentives to reduce emissions. FAA 

grants through the VALE program are available. 

B. Emissions trading can work together with appropriate emissions 

performance standards to provide private sector financing and to 

accelerate engine turnover. Depending upon the overall compliance 

program, the emissions trading element could consist of one or some 

combination of a performance averaging program (e.g., by a terminal 

operator or among fleets), inter-sector trading, banking, and a cap and 

trade program. 

C. Clearinghouses can disseminate information on technology and 

incentives to educate and promote the use of technologies that have a 

positive impact on air quality. Performance benchmarking can be used to 

highlight the positive characteristics of new and innovative technologies 

through comparison of these technologies against standard market 

practices and/or the continued use of existing products. Web tools can be 

used to move product information. This information can be targeted to a 

specific audience or for general consumption to inform, promote, educate, 

and influence decisions. 

D. Modeling to estimate emission reduction benefits of various strategies 

is recommended. 

E. Retrofit strategies include converting existing engines to an alternative 

fuel, engine recalibration, adding additional emission controls, 

replacement with a new and cleaner engine, and anti-idling and other 

changes in operating strategies that reduce emissions. 

F. Use SEP funding to accelerate emission reductions through 

electrification. 

H. Non-measured VOC sources can be detected by thermal IR camera 

(e.g., floating roof storage tanks, VOC loading racks, pipeline operations, 

marine vessels and marine loading operations). 

I. Use green contract conditions when facilities are enlarged or rebuilt, or 

when leases are up. Emission limits would be effective for any source 

with discrete, measurable points of emissions. 

J. Imposing work practice restrictions on intermittent sources can be 

effective to address high ozone levels (like taxiing on one engine). 

PM, 

NOx, 

VOCs, 

SO2, air 

toxics 

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Air Quality Management Subcommittee Final Report 

(4) Rural Sources

(a) Agriculture 

(including potential 

effect on PM 

formation and acid 

deposition) 

A. Financial tools 

and financial 

demand-side 

strategies 

C. Information 

programs, reward 

programs and nonfinancial demandside strategies 

D. Planning tools 

E. Retrofit strategies 

J. Work practice 

standards 

A. Predicate approval of loans on agreement to implement 

best management practices (BMPs). 

C. Clearinghouses can disseminate information on 

technology and incentives to educate and promote the use of 

technologies that have a positive impact on air quality. 

Performance benchmarking can be used to highlight the 

positive characteristics of new and innovative technologies 

through comparison of these technologies against standard 

market practices and/or the continued use of existing 

products. Web tools can be used to move product 

information. This information can be targeted to a specific 

audience or for general consumption to inform, promote, 

educate, and influence decisions. 

D. Permit streamlining replaces redundant and unnecessary 

requirements in favor of practically enforceable limits that 

can reduce administrative costs, reduce timing, and improve 

enforcement. Modeling to estimate emission reduction 

benefits of various strategies is recommended. 

E. Retrofit strategies include converting existing engines to 

an alternative fuel, engine recalibration, adding additional 

emission controls, replacement with a new and cleaner 

engine, anti-idling, and other changes in operating strategies 

that reduce emissions. 

J. Work practice standards (referred to as BMPs) are 

currently in use and effectively controlling emissions from 

many agricultural sources. 

PM, VOCs, 

ammonia 

(b) Dust A. Financial tools 

and financial 

demand-side 

strategies 

C. Information 

programs, reward 

programs and nonfinancial demandside strategies 

J. Work practice 

standards 

A. Predicate approval of loans on green clauses in 

development contracts. 

C. Clearinghouses can disseminate information on 

technology and incentives to educate and promote the use of 

technologies that have a positive impact on air quality. Web 

tools can be used to move product information. This 

information can be targeted to a specific audience or for 

general consumption to inform, promote, educate and 

Influence decisions. 

J. Work practice standards are effective tools for dealing 

with “area” type sources such as dust. 

PM 

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Air Quality Management Subcommittee Final Report 

83 

 

(5) Small Emitters 

(e.g., dry cleaners, 

bakeries, 

restaurants)

C. Information 

programs, reward 

programs, and nonfinancial demandside strategies 

D. Planning tools 

H. Targeted 

strategies 

I. Emission limits 

J. Work practice 

standards 

C. Clearinghouses can disseminate information on 

technology and incentives to educate and promote the use of 

technologies that have a positive impact on air quality. 

Labeling can be used to inform the general public of the 

choices they are making and to promote the use of new and 

innovative technologies and resources. Performance 

benchmarking can be used to highlight the positive 

characteristics of new and innovative technologies through 

comparison of these technologies against standard market 

practices and/or the continued use of existing products. 

Community “Green Action” lists can be utilized to provide 

access to tools and information that will help promote the use 

of more sustainable “Green Community” concepts. Surveys 

can be used to gauge effectiveness of the programs and to 

inform federal, state, tribal and local entities of program 

results and market changes. Frequent flyer-type programs 

can be used to provide incentives for entities that make 

frequent purchases by offering discounts, rebates, credits or 

other offerings to promote repeated use of the product(s) 

being promoted. Web tools can be used to move product 

information. This information can be targeted to a specific 

audience or for general consumption to inform, promote, 

educate, and influence decisions. 

D. Permit streamlining replaces redundant and unnecessary 

requirements in favor of practically enforceable limits that 

can reduce administrative costs, reduce timing, and improve 

enforcement. Assessing inventory and population density is 

recommended. 

H. Non-measured VOC sources can be detected by thermal 

IR camera (e.g., floating roof storage tanks, VOC loading 

racks, pipeline operations, marine vessels, and marine 

loading operations). 

I. Emission limits would be effective for any source with 

discrete, measurable points of emissions. With very small 

sources, it may not be cost effective to conduct routine or 

continuous source sampling. 

J. Work practice standards would be an effective alternative 

to emission limits for most of these sources. 

PM, NOx, 

VOCs, air 

toxics 
Air Quality Management Subcommittee Final Report 

(6) Consumer 

Products (e.g., 

VOC-containing 

consumer products)

A. Financial tools 

and financial 

demand-side 

strategies 

B. Emissions trading 

C. Information 

programs, reward 

programs, and nonfinancial demandside strategies 

I. Emission limits 

A. Financial strategies such as targeted rebates have proven 

successful. 

B. One or more emissions trading tools may be effective in 

this area, including averaging and banking. 

C. Clearinghouses can disseminate information on 

technology and incentives to educate and promote the use of 

technologies that have a positive impact on air quality. 

Labeling can be used to inform the general public of the 

choices they are making and to promote the use of new and 

innovative technologies and resources. Performance 

benchmarking can be used to highlight the positive 

characteristics of new and innovative technologies through 

comparison of these technologies against standard market 

practices and/or the continued use of existing products. 

Community “Green Action” lists can be utilized to provide 

access to tools and information that will help promote the use 

of more sustainable “Green Community” concepts. Surveys 

can be used to gauge effectiveness of the programs and to 

inform federal, state, tribal and local entities of program 

results and market changes. Frequent flyer-type programs 

can be used to provide incentives for entities that make 

frequent purchases by offering discounts, rebates, credits, or 

other offerings to promote repeated use of the product(s) 

being promoted. Web tools can be used to move product 

information. This information can be targeted to a specific 

audience or for general consumption to inform, promote, 

educate, and influence decisions. 

I. Emission limits would be effective for any source with 

discrete, measurable points of emissions. With certain types 

of sources, it will not be cost effective to conduct routine or 

continuous source sampling. 

PM, NOx, 

VOCs, SO2, 

air toxics 

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Air Quality Management Subcommittee Final Report 

(7) Industrial, 

Commercial and 

Residential Boilers 

and Heaters, and 

Legacy Equipment 

and Sources 

B. Emissions trading 

C. Information 

programs, reward 

programs, and nonfinancial demandside strategies 

D. Planning tools 

I. Emission limits 

J. Work practice 

standards 

B. Emissions trading tools such as plant-wide applicability 

limits may be effective. 

C. Clearinghouses can disseminate information on 

technology and incentives to educate and promote the use of 

technologies that have a positive impact on air quality. 

Labeling can be used to inform the general public of the 

choices they are making and to promote the use of new and 

innovative technologies and resources. Performance 

benchmarking can be used to highlight the positive 

characteristics of new and innovative technologies through 

comparison of these technologies against standard market 

practices and/or the continued use of existing products. 

Surveys can be used to gauge effectiveness of the programs 

and to inform federal, state, tribal and local entities of 

program results and market changes. Web tools can be used 

to move product information. This information can be 

targeted to a specific audience or for general consumption to 

inform, promote, educate, and influence decisions. 

D. Permit streamlining replaces redundant and unnecessary 

requirements in favor of practically enforceable limits that 

can reduce administrative costs, reduce timing, and improve 

enforcement. Modeling to estimate emission reduction 

benefits of various strategies is recommended. Inventory 

assessment is recommended. 

I. Emission limits can be an effective tool to address these 

types of sources. 

J. Work practice standards might be an effective alternative 

to emission limits for some of these sources. 

PM, NOx, 

VOCs, SO2 

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Air Quality Management Subcommittee Final Report 

 Needs, Tools, and Attributes 

1. List of “Needs” or Problems: 

 A. Priority Emission Reduction Areas 

 (1) Vehicles and Engines: 

 (a) Issues related to vehicle and engine emissions: 

 i. Insufficient turnover of existing fleets 

ii. Need to encourage higher market penetration of clean engines 

and fuels 

iii. Need for greater implementation of retrofits 

(b) Issues related to vehicle and engine use (i.e., vehicle miles traveled 

(VMT)): 

 i. lack of land use planning to reduce VMT 

 ii. lack of transportation planning to reduce VMT 

 (2) Special Under-Managed Problem Areas: 

(a) ports and goods movement (including some related on-road engines, 

e.g., trucks) 

(b) airports 

 (c) other federally preempted sources (e.g., railroads, ships, etc.) 

(d) agricultural emissions (including both their potential effect on PM 

formation and on acid deposition; includes, e.g., ammonia, dust from 

tillage, land clearing burning) 

(e) dust emissions 

 (3) Small Emitters (e.g., dry cleaners, bakeries, restaurants) 

 (4) Consumer Products (e.g., VOC-containing consumer products) 

 (5) Industrial Boilers and Other Under-Regulated Stationary Sources 

B. Problems and Needs Related to Measurements (of Problem or Actions Taken) 

and Performance Tracking 

 (1) Baseline Air Quality Data 

(a) Current Disincentives - Current program discourages data development 

and other efforts to update the technical underpinning of attainment 

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Air Quality Management Subcommittee Final Report 

SIPs. Currently, areas are penalized for discovering that their problem 

is worse than previously understood. 

(b) Need for More Refined Data – we need more information regarding 

speciation of fine particulates if we are to identify the most appropriate 

sources to target for controls. 

(c) Inventory Gaps – we have not yet adequately estimated emissions from 

many source categories, including: 

 - marine emissions 

 - locomotive emissions 

 - off-road diesel emissions 

(d) Insufficient ambient air quality monitoring networks- lack of ambient 

data 

 (2) Hazardous Air Pollutants 

 (a) Limited or non-existent monitoring data. 

 (b) Need better risk assessment methodology that incorporates both 

 scientific and traditional knowledge. 

 (c) Lack of understanding regarding levels of significance 

 (d) Lack of ambient thresholds. 

(e) Need more understanding of potential impact of hazardous air 

pollutants on sensitive populations. 

 (3) Planning Challenges 

(a) Co-benefit evaluations – we lack the tools or metrics to account 

properly for co-benefits of various strategies. 

(b) Difficulty of evaluating local impacts of trading programs. 

C. Problems or Needs Related to Authority or Jurisdiction 

(1) Preemption – states and tribes are preempted from regulating many source 

 Categories. 

(2) Limitations – e.g., many states and tribes can’t go beyond federal measures or 

can’t regulate minor sources. 

(3) International and Border Emissions. 

(4) Authority and jurisdictional regulatory “patchwork” of state/local regulations 

versus national regulations. 

D. Other SIP Challenges 

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Air Quality Management Subcommittee Final Report 

(1) SIP Credit – how should credit for non-traditional strategies be allocated, 

including: 

 - Mobile source strategies (e.g., diesel reduction programs). 

 - Voluntary/incentive programs. 

E. Resources – many state, tribal and local agencies lack sufficient resources 

F. Other Needs 

 (1) Lack of incentives to prevent air quality problems (e.g., in attainment areas) 

 (2) Conservation, both user and supplier side, including: 

 - Energy efficiency. 

 - User side behavior/choices. 

 - Purchasing/consumption. 

 - Mass transit. 

2. List of Potential “Tools:” 

A. Financial Tools and Financial Demand-Side Strategies 

 Tax strategies (e.g., deductions, credits, accelerated depreciation, etc.) 

 Loans 

 Equity strategies 

 Clean air investment funds 

 Emission fees 

 Fees in lieu of offsets 

 Targeted rebates 

 Differential pricing 

B. Emissions Trading Tools 

 Cap and trade 

 Open market strategies 

 Bubbles (e.g., by category of equipment, facility, industry, port or airport) 

 Plant-wide applicability limits 

 Mobile to stationary trading 

 Interpollutant trading 

 Risk-based trading 

 Reactivity-based trading 

C. Information Programs, Reward Programs and Non-Financial Demand-Side 

Strategies 

 Clearinghouses for Technology, Regulations, Incentives 

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Air Quality Management Subcommittee Final Report 

 Labeling (e.g., star programs, nutrition label model) 

 Performance Benchmarking 

 Community “green” action lists 

 Surveys (e.g., impacts of personal choices) 

 Frequent flyer-type programs (e.g., points for personal clean air actions) 

 Web tools (e.g., info availability, personal clean air web account) 

D. Planning Tools 

 Permit streamlining 

 Model local ordinances and guidance 

 Quantification models to project impacts of land use choices 

 Federal agency ombudsman for assisting local governments to identify available 

 funds, good land use models, etc. 

 Memoranda of understanding 

 Remote sensing 

 Monitoring tools for dealing with inventory uncertainties 

E. Retrofit Strategies (other than financial incentives, which are listed separately 

above) 

 Useful life limits on equipment 

 Retrofit requirements (Super RACT) 

 Minimum technology standards based on pollutant focus 

Fuel type and usage 

Operational protocol 

Compliance flexibility 

Direct regulations requiring retrofits 

F. Enforcement Enhancements 

 Incentives for self certification 

 Source specific emission limit agreements 

Privatization Strategies 

G. Targeted Strategies 

 Sensitive zones 

 Sensitive receptors 

 Time of day restrictions 

 Seasonal restrictions 

H. Emission Limits 

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Air Quality Management Subcommittee Final Report 

3. Attributes – for evaluating and comparing tools: 

DIRECT: 

A. Environmental benefits and dis-benefits (e.g., emission reductions, air quality 

benefits, public health benefits, cultural benefits, ecological benefits, aesthetic 

benefits), including a statement of which “need” is being addressed. 

B. Economic impacts (e.g., cost and cost effectiveness). 

C. Time (e.g., lead time, duration in years, continuity of benefit during day and week). 

D. Ease of monitoring and accountability. 

AUTHORITY, JURISDICTION AND MECHANISMS: 

E. Jurisdictional attributes (e.g., do states and tribes have necessary authority, are there 

limits, who would implement – business, local, state, tribe, federal, international). 

F. Would the strategy require CAA amendment? 

G. Replicability. 

INDIRECT: 

H. Impact on personal choice and quality of life. 

I. Benefits and dis-benefits of energy efficiency and greenhouse gas reductions. 

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Air Quality Management Subcommittee Final Report 

Appendix C: Proposed Framework for an Air Quality Management 

Plan 

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Air Quality Management Subcommittee Final Report 

Proposed Framework for an Air Quality Management Plan 

The following framework for an AQMP is based, in part, on the South Coast Air Quality 

Management District (AQMD) 2003 air quality management plan 

(http://www.aqmd.gov/aqmp/AQMD03AQMP.htm). 

Elements of an AQMP and a Proposed Framework 

1) Executive Summary 

a) Presents philosophy and direction 

b) Summarizes key components and discusses how they will be implemented 

2) Overview 

a) Explains concept of AQMP and provides context for current plan versus the past 

b) Discusses how the plan developed, who is involved in the process 

c) Discusses benefits and impacts of an AQMP 

3) Air Quality Requirements and Goals 

a) Purpose – why are we doing an AQMP? 

b) Challenges 

c) Current requirements and goals addressed by the AQMP (both federal and state, tribal, 

or local) 

4) Air Quality, Health, and Ecosystem Effects 

a) Explains current air quality issues in the area covered by the plan – what are the 

problems in the area? 

b) Includes both criteria and non-criteria pollutants 

c) Discusses health effects and other issues for all pollutants covered by the plan 

5) Air Emissions Assessment 

a) Provides a picture of where the area is and may be in terms of its current and future 

emissions inventories from all sources – what does it look like now and in the future? 

b) Discusses how emissions will be monitored, what modeling has been done, and 

what/how information is being provided to stakeholders and the public 

6) Strategy for Managing Emissions from New and Existing Sources 

a) Outlines the various control strategies and other measures the planning agency is 

undertaking in the stationary, area and mobile sectors – what are we doing about it? 

b) Covers all pollutants addressed by the AQMP 

7) Future Air Quality 

a) Provides the future air quality picture based on implementation of the strategies and 

measures in the AQMP – where do these actions get us? 

8) Implementation 

a) Explains how the organizations involved in the AQMP will execute the programs and 

strategies outlined in the AQMP – how would we get this done? 

9) Looking Beyond Current Requirements 

a) Provides a forward look at air quality problems and requirements on the horizon and 

how the area is approaching those issues 

10) Glossary and Appendices 

a) Provides detailed technical support documents and information

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Air Quality Management Subcommittee Final Report 

Appendix D: Letter Transmitting Final Report to EPA 

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Air Quality Management Subcommittee Final Report 

Honorable Stephen L. Johnson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

Dear Administrator Johnson: 

On behalf of the Clean Air Act Advisory Committee (CAAAC), we are pleased to 

present to you a report and recommendations from the Committee for your consideration. The 

CAAAC is a senior-level policy committee consisting of managers and experts representing 

State and local government, environmental and public interest groups, academic institutions, 

unions, trade associations, utilities, industry, and others. The Committee provides advice and 

counsel to EPA on a variety of important air quality policy issues. 

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

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

the many substantial achievements of the U.S. Air Quality Management (AQM) system over the 

past 30 years. The NRC also identified areas where additional changes in the AQM system 

would provide further benefits to human health and the environment. The NRC advanced 

recommendations for change in the AQM system on a number of levels. Some of the NRC’s 

recommendations involve short-term changes of limited scope and immediate impact. Other 

NRC recommendations involve sweeping changes to the Nation’s approach to AQM over the 

mid- to long-term. 

 For the past 2 years, a CAAAC Subcommittee has examined the latter category of the 

NRC recommendations and has developed this report detailing options for long-term, systemic 

ways to improve the AQM system in this country. The Subcommittee’s findings support a shift 

from the current pollutant-by-pollutant AQM system to a fully integrated multipollutant, 

comprehensive AQM system that functions in coordination with energy, land use, and 

transportation plans. The AQM Subcommittee included representatives from State and local 

organizations, Tribes, regional organizations, environmental and public health organizations, 

industry, and the EPA. 

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Air Quality Management Subcommittee Final Report 

 On behalf of the Committee, we thank you for the opportunity to provide advice on 

developing air quality management strategies for the future. 

 Sincerely, 

 Gregory A. Green, Co-Chair 

 Air Quality Management Subcommittee 

 Patrick Cummins, Co-Chair 

 Air Quality Management Subcommittee 

 Robert J. Meyers, Chair 

 Clean Air Act Advisory Committee 

Enclosure 

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Air Quality Management Subcommittee Final Report 

Appendix E: Commentary from Stakeholders 

96 

 
June 8, 2007 

Patrick Cummins and Gregory Green, Co-Chairs 

Air Quality Management Subcommittee of the Clean Air Act Advisory Committee 

U.S. Environmental Protection Agency 

Mail Code C304-01 

Research Triangle Park, NC 27711 

Dear Mr. Cummins and Mr. Green: 

As participants in the Clean Air Act Advisory Committee’s Air Quality Management (AQM) 

Subcommittee’s deliberations over the past few years and on behalf of the NESCAUM states, we 

submit these comments to you in response to the May 2, 2007 draft report of the AQM 

Subcommittee, entitled Recommendations to the Clean Air Act Committee; Air Quality 

Management Subcommittee Recommendations, Phase II, June 2007. The NESCAUM states are 

Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and 

Vermont. 

With regard to the statement in the report that the recommendations in the report are “the AQM 

Subcommittee’s vision of a comprehensive AQM system that can assist in meeting future air 

quality challenges in this country” (see page 15), we can only agree in part. Without opportunity 

for in-depth discussion of climate change, it proved impossible to develop what constitutes, in 

our minds, a truly comprehensive AQM system. As such, the recommendations represent some 

good initial steps toward a more comprehensive paradigm of integrated multi-pollutant planning 

and management that is yet to be achieved. 

Contextualizing the Phase II Recommendations - Process Observations 

Phase II of the AQM deliberations proved to be more challenging than Phase I for several 

reasons, including process dynamics. We feel it important to describe some of these process 

dynamics in order to place the report in context for readers who may wish to pursue future 

discussions on new approaches to air quality management with this report in hand. 

First, the group was charged to look broadly at longer term, possibly more large-scale changes to 

the air quality management system. While brainstorming on new ideas sounds like a stimulating 

and uncomplicated task, the policy context in which the Subcommittee was operating compelled 

many participants to consider the potential and substantial regulatory impacts of such innovative 

ideas, particularly with respect to impacts on their constituencies. As mentioned in the AQM 

Subcommittee report, coming to consensus on more groundbreaking proposals such as the ones 

listed in the Unresolved Areas of Discussion section (i.e., airshed-based boundaries, reasonable

performance levels, and continuous improvements) would have required deliberating on and 

conceding to regulatory and policy tradeoffs. Many Subcommittee members found that this 

forum did not allow -- and may not have been the place -- for such specific considerations. As a 
Air Quality Management Subcommittee Report June 8, 2007 

NESCAUM Page 2

result, there was discomfort among participants, particularly in engaging in conversations on 

how an innovative concept might be envisioned or implemented. 

Second, in the context of brainstorming new approaches, we observed a concern on the part of 

many Subcommittee members that formally endorsing a new concept could be erroneously 

interpreted to imply that the corresponding concept currently in place was no longer supported or 

deemed adequate. This further affected the Subcommittee’s ability to explore new approaches as 

a group with rigor. 

Third, early on in the deliberations, it became clear that the Subcommittee could not reach 

consensus as to whether or not to discuss climate change as part of the AQM process. 

Participants on both sides of the issue felt strongly about their positions. Rather than expending 

time and resources further debating the issue, a compromise position was reached that climate 

change would only be discussed within a very narrowly defined context, i.e., as presented in the 

three action items contained in Recommendation #4: Take climate change into account in air 

quality management strategies. We believe that such a narrow bounding of the topic of climate 

change significantly disadvantaged the deliberations. Our specific thoughts on this are 

elucidated below. 

Fourth, while Subcommittee and workgroup deliberations were at times engaging and truly 

exploratory, the open-ended nature of the Subcommittee’s charge, coupled with the process 

concerns, ultimately resulted in constrained dialogue. We suggest that, for future CAAAC 

subcommittee deliberations, specified goals or endpoints accompany the charge so that ideas and 

draft recommendations can be more easily compared to and assessed with respect to those goals. 

Such an approach could greatly enhance that group’s overall deliberative process. 

Multi-Pollutant Planning without Climate Change - Scratching the Surface 

From the NESCAUM states’ perspective, the Subcommittee’s inability to discuss climate change 

in the context of criteria pollutant planning and management was disappointing. During the time 

period coinciding with the AQM Subcommittee’s deliberations, the NESCAUM states were 

actively working together and with states across the nation on several key climate initiatives, 

including the Regional Greenhouse Gas Initiative (RGGI) and The Climate Registry, as well as 

developing State Implementation Plans for ozone, particulate matter, and regional haze. The 

NESCAUM states have started to confront some critical policy challenges concerning climate, 

criteria pollutant, and air toxics integration, and would have welcomed an opportunity to discuss 

them with a larger constituency. Some of the key issues specifically involve climate-criteria 

pollutant tradeoffs, and include: (1) science and analytical assessment needs for assessing multipollutant interactions and tradeoffs; (2) policy challenges and needs for addressing multipollutant interactions and tradeoffs; (3) institutional barriers that need to be addressed in order to

move to more integrated multi-pollutant planning and management; (4) local, state, tribal, and 

federal roles in integrating climate change into multi-pollutant planning; and (5) building 
Air Quality Management Subcommittee Report June 8, 2007 

NESCAUM Page 3

capacity at the state, tribal, and federal levels to successfully implement multi-pollutant planning 

and management. 

Moving Forward 

We are pleased that the U.S. Environmental Protection Agency (EPA) has initiated steps to 

launch a pilot program, in response to the Subcommittee’s recommendation, for developing 

statewide Air Quality Management Plans over the next few years. We agree that federally 

sponsored pilots aimed at building capacity at the state level to conduct multi-pollutant analyses, 

as well as identifying policy, regulatory, and institutional challenges and ways to address them 

during the integration process, will prove beneficial. We recommend that a series of pilots be 

launched and subsequently documented, evaluated, and made publicly available so that we can 

learn from those experiences. We hope to work with EPA in the near future on such efforts. 

We greatly appreciated the work of the EPA staff in convening the AQM Subcommittee 

meetings and writing and producing the final report. We thank you for your efforts in 

shepherding this process to its conclusion. If you have any questions on our comments, do not 

hesitate to contact us. 

Sincerely, 

David Shaw, Director Jeffrey Underhill, Chief Scientist 

Division of Air Resources Air Resources Division 

NY DEC NH DES 

Michael Sheehan, Chief Leah Weiss, Senior Policy Advisor 

Mobile Source Planning Section NESCAUM 

Division of Air Resources, NY DEC 

cc: NESCAUM Directors 

 Arthur Marin, NESCAUM