1. Determining Attainment Dates for Different Types of Nonattainment Areas Rich Damberg EPA Office of Air Quality and Standards June 20, 2007

2. 2 Types of Nonattainment Areas Requirements under the implementation rule, such as the RACT/RACM analysis and RFP, vary depending on the date for which an area can demonstrate attainment Types of areas: –Clean data before April 2008 SIP submittal date –Attainment by April 2010 with no new local measures –Attainment by April 2010 with local measures –Extension needed - attainment between April 2010- 2013 –Extension needed – attainment in 2014 or 2015

3. 3 Clean Data Achieved Before SIP is Due The requirements for an attainment demonstration and related elements, reasonable further progress, and contingency measures are suspended for an area that demonstrates clean air quality data prior to the SIP submittal date The area would be required to implement the NSR program and continue implementation of the transportation & general conformity programs The suspended requirements would come back into force in the event the area falls back into nonattainment

4. 4 Terminology “Attainment date” vs. “emissions year for modeling” Designations were finalized in April 2005 The attainment date should be within 5 years, by April 2010 To show attainment by April 2010, 2009 needs to have clean data. Thus, conduct modeling for the emissions year of 2009 to show attainment by April 2010.

5. How Do You Set Your Attainment Date? Area can attain by April 2010 with no new measures Attain NAAQS by April 2010? Yes No Reach attainment one year earlier (by April 2009) based on candidate measures through 2008? Yes Attainment date = April 2010 Need analysis to determine if area can attain one year earlier (by April 2009) based on measures that can be implemented through 2008. Can be qualitative. Candidate measures to consider for most expeditious attainment date = all technically and economically feasible reductions available from sources in the nonattainment area (RACT/RACM) plus other intrastate measures. Need to analyze 2009 with additional measures Go to next chart Attainment date = April 2009 Model 2009 Base Case (Only controls on the books such as CAIR, mobile source rules, State programs)

6. Model 2009 with all candidate measures that can be implemented through 2009 No Yes Need an extension Go to next chart No Yes How Do You Set Your Attainment Date? Area can attain by April 2010 with additional measures Attain NAAQS by April 2010? Reach attainment one year earlier (by April 2009) based on candidate measures through 2008? Attainment date = April 2010 Attainment date = April 2009 Analytical burden is less if can show attainment by 2010. An area with a 2009 base case modeled design value just over the standard may be able to show expeditious attainment here with a limited set of additional measures Candidate measures to consider for most expeditious attainment date = all technically and economically feasible reductions available from sources in the nonattainment area (RACT/RACM) plus other intrastate measures.

7. 7 Areas Needing An Extension 2015 attainment date is NOT automatic Need rigorous analysis of available measures and when they could be implemented Future years to model may vary from area to area. –If modest reductions needed, no later than 2012 –If very large reductions needed, may be ok to start with 2014-2015

8. Model 2012 with all candidate measures that can be implemented through 2012 No Attain NAAQS by April 2013? YesNo Yes Need extension to 2014 or 2015 Go to next chart How Do You Set Your Attainment Date? Extension needed - attainment in 2011 - 2013 RFP Plan for 2009 Emissions Year Analyze 2009 and 2012 model output and emissions. Can area reach attainment in 2011 or 2012 based on all candidate measures? Attainment date = April 2011 or 2012 Attainment date = April 2013 Candidate measures to consider for most expeditious attainment date = all technically and economically feasible reductions available from sources in the nonattainment area (RACT/RACM) plus other intrastate measures.

9. Model 2014 with all candidate measures that can be implemented through 2014 No Attain NAAQS by April 2015? YesNo Yes CAA requires attainment no later than 2015. Need approvable plan. How Do You Set Your Attainment Date? Extension needed - attainment in 2014 - 2015 RFP Plan for 2009 and 2012 Emissions Years Analyze 2009, 2012, and 2014 model output and emissions. Can area reach attainment by April 2014 based on all candidate measures? Attainment date = April 2014 Attainment date = April 2015 Candidate measures to consider for most expeditious attainment date = all technically and economically feasible reductions available from sources in the nonattainment area (RACT/RACM) plus other intrastate measures.