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Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation

Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation. Public Meeting April 3, 2002 Tempe, Arizona. Annie Nikbakht US EPA OAQPS/AQSSD Ozone Policy and Strategies Group (919) 541-5246 nikbakht.annie@epa.gov. David Sanders US EPA OAQPS/AQSSD

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Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation

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  1. Reasonable Further Progress Under8-hr Ozone NAAQS Implementation Public Meeting April 3, 2002 Tempe, Arizona

  2. Annie Nikbakht US EPA OAQPS/AQSSD Ozone Policy and Strategies Group (919) 541-5246 nikbakht.annie@epa.gov David Sanders US EPA OAQPS/AQSSD Ozone Policy and Strategies Group (919) 541-3356 sanders.dave@epa.gov Reasonable Further Progress Under8-hr Ozone NAAQS Implementation

  3. Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation Issue Question: What should be the requirements for reasonable further progress under the 8-hour ozone standard?

  4. Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation • Assumptions • Use same baseline year to both address growth and to calculate the RFP target level • Handle contingency measures as under 1-hr std • Allow emission reductions outside nonattainment area • 100km for VOC • 200km for NOx • Apply anti-backsliding across 1-hr nonattainment area

  5. Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation • ISSUE 1: VOC and 15% - Only VOC required for the initial 15% progress period? • Option 1 • Assume status quo - continue to require 15% VOC reductions • Option 2 • No repeats for areas already having completed the 1-hr 15% reduction plans • Option 3 • Use only the 9% mixed VOC/NOx reduction (18% over 6 yrs) – CAA already provided for 15% in 1990

  6. Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation • ISSUE 2: EI Baseline Year - What year should be used for the baseline inventory? • Option 1 • Use closest year to designations (most likely 2002) • Option 2 • Use the CAA required year of 1990 or best choice

  7. Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation • ISSUE 3: Creditability - How should CAA restrictions on creditable measures be interpreted? What should be the baseline year for credit for national measures? • Option 1 • Status quo as per CAA(i.e., use 1990 baseline) • Option 2 • Same baseline year used to calculate rate of progress (most likely 2002)

  8. Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation • ISSUE 4: RFP Under Subpart 1 -If an area is subject to Subpart 1 instead of Subpart 2, how should the RFP requirement be structured? • Option 1 • (See next slide) straight-line reductions from base year to attainment year • Option 2 • use the Subpart 2 structure for RFP under Subpart 1

  9. Reasonable Further Progress Under 8-hr Ozone NAAQS Implementation • 4. Option 1: Straight-line reductions from base year to attainmentyear • Implications: • less than 6 years to attainment, then get all reductions in enough time to ensure attainment by the attainment date. • greater than or equal to 6 years to attainment, then get ½ reductions in ½ the time • greater than 9 years to attain, then get 1/3 reductions in 3 equal intervals

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