UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: Coordinating 208 Planning and Air Quality
f^faintenance Area Planning
DATE:
OCT 3 0197.5
FROM-.
TO:
Piaane
Director, Water Planning Division (lvH-554)
Regional Administrators
ATTN: Water Program Directors
PROGRAM GUIDANCE MB'DRANDUM: AM-14
PURPOSE
This memorandum sets forth procedures for coordination between
air quality maintenance area planning and 208 areawide waste treatment
management planning. The Regional Offices will be responsible for
assuring the implementation of these procedures. This guidance is to
be implemented immediately.
BACKGROUND
Under the Clean Air Amendments of 1970, the states were required
to develop State Implementation Plans (SIPs) for the attainment and
maintenance of National Ambient Air Quality Standards (NAAQS) for six
pollutants: suspended particulate matter, sulfur oxides, carbon monox-
ide, hydrocarbons, nitrogen dioxide and photochemical oxidants. However,
most state regulations did not fully address the problem of maintaining
air quality and, as a result of a court case, EPA disapproved all SIPs
because they lacked effective mechanisms for maintaining standards. EPA
then required that the states identify areas that may have the potential
for exceeding any NAAQS within the subsequent 10-year period. Based
upon the information submitted by the states, EPA is publishing a list of
these potential problem areas which are termed Air Quality Maintenance
Areas or AQMAs. A detailed analysis of the impact en air quality of
projected growth in each AQMA identified by EPA must be completed by
either the state or Regional Office by April 1976. Where the analysis
indicates that an area will either not attain the NAAOS, or will not be
able to maintain them for the subsequent 10 years, the state must then
develop a plan containing measures to ensure the attainment and/or main-
tenance of the standards. Furthermore, to ensure the continued maintenance
of the NAAQSs, states must review the adequacy of the AQMA plan at l.east
every 5 years.
EPA Form 1320-6 (Rev. «-72)
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-2-
Aspects of 208 planning and AQMA planning are interrelated, both
in terms of their impact on one another and in terms of their similarities
of approach. Both are concerned with maintaining environmental quality;
both utilize an areawide approach in which areas of potential or existing
problems are identified and a unified plan is developed for the entire
area. However, when a program is designed to control pollution, in just
one medium, it can result in environmental deterioration in another. The
goal of both AQM and 208 is to improve the quality of the environment,
but by focusing on the problems within a single medium, conflict may
arise with the attainment and maintenance of standards in the other' medium.
At the same time, if care is taken to coordinate their development, the
plans produced through these two programs can be mutually supportive.
In order to facilitate coordination between 203 and AQM planning,
the Regional Offices should encourage the states to:
1, Designate, when possible, the same agency to do both 208 and
AQMA. planning;
2 . Incorporate 208 areas and AQMAs into common boundaries where
there is already an existing overlap and when such an action
appears practical;
3. Ensure that there is adequate and periodic reporting of 208
Vi'j. ciT CG i*jL*OolpOI*CijLiifc^ .i/v^i '~\ p J
4 . Review 208 plans for consistency with any corresponding AQMA
plan;
5. Resolve any conflict which iray develop during the planning stage
between an AQMA. and a 208 area if it cannot be resolved informally
by the planning agencies .
The Regional Office should also assure that the agencies responsible for
developing 208 areawide plans:
1. Develop letters of agreement with corresponding AQMA planning
agencies to cover such items as integration of work plans and
consistency of data and control strategies;
2. Specify in their work plans how coordination will occur throughout
the planning process ;
3. Integrate their data requirements with the AQMA planning effort
before gathering data so tiiat the information obtained for the
208 plan is transferable to AQMA. planning. 208 agencies should
allow the AQMA. planning agencies to utilize their population,
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land use, economic and water quality data whenever possible;
4. Have representatives from any corresponding AQMA. on their
advisory group;
5. Inform the AQMA planning agency about alternatives being considered,
and offer them an opportunity to review and comment on alternatives.
In addition, the environmental assessment associated with a 208
plan must address the impact of the alternatives and the selected
plan on air quality;
6. Report (as part of the semiannual report requirements) to the
Regional Offices on coordination efforts with AQMA planning;
7. Review completed AQMA plans as a final check for consistency and
allow the AQMA. planning agency to review 208 plans;
8. Attempt to resolve any conflicts with the AQMA planning effort
which may develop during the plroming stage.
Finally, it is the Regional Office's responsibility:
1. When reviewing the plans for 208 areas, to make sura they are
consistent with corresponding ACp-'A plans and not to approve
plans which are in conflict;
2, To resolve conflicts between the two planning efforts which cannot
be resolved by the state;
3. To resolve conflicts which involve other federal agencies.
The attached paper discusses the above points in greater detail and explains
the interrelationships between the two programs. The paper also discusses
the use of grant conditions as one mechanism to implement this guidance.
POLICY
The Regional Offices shall implement the steps described in this
guidrivice memorandum to facilitate coordi.nii.tion between 208 arenwj.de planning
and AQMA. planning.
Attachment
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Procedures for Coordination Between Air Quality
SUBJECT: Maintenance Planning and 208 Areawide Waste Treatment DATE: §£p 3 2
Management Planning
FROM: John R. Quarles, Or.
Deputy Administrator
TO: Regional Administrators
He are keenly aware of the importance of coordinating related
EPA programs to ensure that they are mutually supportive and that
they neither conflict nor duplicate effort. The 208 Areawide Waste
Treatment Management Program and the Air Quality Maintenance Program
are intsrrelated programs which ara regional in scope and which will
be developed concurrently in many areas. In many cases, the plans
resulting from these programs will be addressing similar environmental
problems in related madia and will employ similar management alterna-
tives.
T'ne attached procedures were developed by the Office of Water
and Hazardous Materials and the Office of Air and Waste Management
to provide guidance on coordinating the 208 and AQMA programs. This
guidance was distributed in draft form to all the Regions in May for
comment and review. This final version incorporates those comments
received and reflects the new proposed regulations for Air Quality
Maintenance.
Copies of this guidance should be provided to all the stats
offices responsible for air and water quality and, in addition,
be given to all designated 203 planning agencies and AQMA planning
agencies.
Attachment
EPA Form 1320-6 (R«v. 6-72)
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PROCEDURES FOR COOfWilATSOH BETWEEN AIR QUALITY MAINTENANCE PLAKM1NG
AiiD ?.08 AREAWlDli WASTE TREATMENT MANAGEMENT PLANNING
I . Introduction :
A . Rationale for the Programs
Air Qual ity
Under Ihs Clean Air Atonements of 1970, the states were required
to develop State iMplomentation Flans (SlPs) Tor the attainment and
:n,?. iiite nance of National Ambient Air Quality Standards (MAAQS) for six
pollutants: suspended participate matter, sulfur oxides, carbon monoxide,
hydrocarbons, nitrogen dioxide and photochemical oxidants. Mowever, most
stats regulations ccuccrv'irated on the attainment of standards through
em ir, si en controls ana did not fully address the problem oi" ir.ainr.aining air
qual ity.
As a result of a court case won by the Nacural Resources Dev'ense
f i C> tl I '„ ,j Li I V U I U Vv U U i U <,t O V. 11V ' * Vj> VI l[~ . 1U i_ v-' I U I i vxj ,j v " 1 I U C -> v> «,., I U i 1 O C.
Council, EPA disapproved all SIPs because tiuiy lacked effective mechanisms
for n:aint.3iniM'.j stai;dard3. EPA then required th-it the states identify
------ f t ^ i
are termed Air finality Maintenance Areas or AQi-iAs.
By July 1, 1976, EPA will determine which areas need ruiintenance
plans, and as discussed further below, by this sa;ne date the Regional Adniini-
ctv'ators will have to decide which Air Quality Control Regions (AQCPvs) need
plan re-visions for both attainment and n:aintenance. An analysis performed
by cither the State or EPA is due by April 1 , 1976 (RAs n>ay modify this date),
to determine v.-hich areas would need attainment and/or maintenance plan revisions.
The Regional Administrators will specify a submittal date for the AQMA plan and
the time period the plan must cover. To ensure the continued maintenance of
the NAAQS, states must review the adequacy of the AQMA plan at least every 5
years or more frequently if the plan itself covers less than 5 years.
2. 208 Planning, . '
Section 203 of the Federal Hater Pollution Control Act Ansendnients
of 1972 allows the state or local governments to designate certain areas
v.'hich have substantial water quality control problems for areawide waste
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treatment management planning. The states are responsible for developing
plans in areas not designated. The plans developed under 203 must, among
other things, identify the facilities necessary for meeting and maintaining
water quality standards for the next 20 years and regulate their location,
modification, and construction. The plans must also include procedures
designed to control nonpoint sources of pollution, pretrcatment of industrial
wastes, and the disposal of wcistcwater residues. The management agency
or agencies necessary for implementing the plan must also be identified.
One large difference between the two programs is that monies have
been appropriated especially for 20S areawide planning while' AQ.MA planning
is part of the SIP and is funded out of existing grants . The money allocated
to the state through Program. Support Grants (Section 105 of the Clean Air
Act), together with the matched state or local funds, must be apportioned
among a number of other air quality programs wliich are part of the SIP (e.g.
Stationary Source Review, New Source Performance Standards, Transportation
Control Measures), along with other general functions (^nforcement, engineer-
;irsn3 technical services, and uiuiiagement) ,
ol TV
their impact on one another end in terms of their similarities or approach.
Both an.- concerned with maintaining environmental quality; both utilize
an areawide approach in ivhich a was of potential or existing problems
are identified and a unified plan is developed for the entire area. However,
when a program is designed to control pollution in just one medium, it can
result in environmental deterioration in another. Win"!: the goal of both
AQM and 208 is to improve the quality of the environment, the single
medium focus of separate prograns may result in conflict with the attain-
ment and maintenance of standards in the other medium. At tho same time,
if care is taken to coordinate their development, the plans produced
through these two programs can be mutually supportive.
1 . In termed la Tradeoffs
An obvious example of the intermedia conflict is the use of control
technologies and equipment which are employed to reduce omissions to one
medium while transferring the pollution problem to another medium. Lime/
limestone scrubbers, one means for reducing S02 emissions, produce a
liquid sludge which must be disposed of. Conversely, sewage treatment
plants may try to dispose of sludge through incineration, thus increasing
air quality problems. Such problems can also affect energy production
considerations. A fossil-fueled electric generator may be undesirable
because of air quality limitations, but an alternative nuclear generating
plant may be unable to meet thermal pollution standards.
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2, Communi ty Growth
Potential conflicts are also apparent when examining the issue
of community grov;th -- v.'hcre should it occur, how should it be
distributed and how niiic'h should be allowed? The two programs will
view these questions from different perspectives, which in some cases
may result in different ^nswers. Tor example, the location of waste
treatment plants and sewer interceptors can act as an inducement to
growth and guide growth toward the serviced areas. These areas plan-
ned for expanded sewersge service niay have existing air quality problems
which increased growth would simply exacerbate. In Ocean County, few Jersey,
for instance, the combination of the expansion of the Gar-den State Parkway
ar.c! a proposed new large treatment plant would have pormi i-.tsd a rapidly
accelerating growth rate and resulting »ir pollution problems rrom increased
coiiinniting. Citizen objections finally resulted in a reduction in the
scale oi" the plant. I;i t!>o Wash ing ton, D.C. f-'etropol i tan Area, a large
interceptor wan run out to serve tne Dulles International Airport through
lend wirkJi was laryoly undeveloped. Th:; combined attract ion of both
the air;;ort ar,u the available sewer service has put: scv/ero pressure on
the local communi ties to accommodate greater deyalc;;rt:o;it :ind thus more
pol lution.
In addition to conflicts over the amount of growth, the two programs
nicy censcicucly attempt to guide growth toward different, d istriunLioriS.
Tn designing an AQMA plan, fjr exiinple, the planning aqoncy uiay -..'ani; to
utilize the option of emission density /:oning to establish oi-iisoion li-nr.s
for different aj'e-as. An industrial zone might have a limit or 3 tons of
total suspended participates per square r:-i 1 e while the limit fur a commer-
cial zone would be considerably less. However, wasteload ;i 11 orations
consistent with maintaining water quality may necessitate a different
land use configuration which would not correspond to the air quali.ty zones.
For example, the location of additional heavy industry within a particular
area may lower the quality of the receiving water below standards, though
due to favorable meteorological conditions, it is a desirable location in
terms of air quality maintenance.
On a larger scale., the two programs may favcr different general-
growth patterns. In one area, for example, substantial iii-migration
and a concommitant demand for housing may result from ino-easing job
opportunities. !*!
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best suited to meet the requirements of a water quality plan may conflict
with the needs for Air Quality Maintenance Planning.
3. Reinforcement
Thus far, only possible conflicts between the two programs have
been mentioned, However, they should be designed to be consistent with
one another so tivit their policies can be reinforcing, thus providing
further inducement, for corni.ni ties to take regulatory action. Haste-
water treatment and collection facilities, for example, can be designed •
to serve those areas lacking significant air quality attainment and
maintenance problems, thus directing grov.'th away from problem areas. In
doing so, however, con .si dorr, t ion must be givon to preventing da ten' oral; ion
of air and water quality. If land use policies and controls are consistent,
growth can be regulated so that it does not result in violations of either
water or air quality standards. Therefore, it is important that agencies
developiny plans under the two programs coordinate closely with each other
to assure that their plans v/ill achieve national objectives for both media
and that th-jy are compatible and complementary . The plans v/ill thus more
likely reinforce each other as they arc implemented.
! I . DG;:icmation and Timing
A . (a tion of Plamy-nn Agencies
Under the 208 regulations, an agency must be designated to do
th/3 planning at the same time the 203 area is designated. There can
only be one agency responsible for planning in each 203 area, and often
:he designated c.g.-ancy is •"» regional pi aiming council or a COG, If
th;ire is no existing regional planning organization, one must be
created, and it must include representation from all the jurisdictions
within the 208 areas. As part of the planning process, an implementa-
tion program must be developed and the implementing agency or agencies
must be identi fied.
The situation in AQMAs is somewhat different. The state has the
initial responsibility for developing the AQMA analysis and plans,
although it may delegate this responsibility to a lower level of govern-
ment. For example, the state might decide to do the planning itself,
or it might decide to co it in conjunction with local or regional. •
cigenices. If this is the case, more than one local or regional agency
might be involved for each AQMA, It is recommended that one agency
have lead responsibility, but this is not a requirement. Implementation
can be the responsibility of one or more agencies as in 203. Because
many air pollution control agencies may not have adequate expertise
in developiny and implementing the kinds of measures that may be needed
for air quality maintenance such as land use and transportation measures,
they are required by the regulations to consult with other agencies, such
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as the EPA 208 agencies, HUO 701 agencies, DOT 3-C agencies, Coastal
Zone Management agencies and OMB A-95 clearinghouses, if they develop .
the AQMA plan. Furthermore, the State would have tofforward the AQMA •
plan to the appropriate A-95 clearinghouse for comment prior to submission
to EPA.
B. Geographic Doundari es
Most AQr'iAs consist of urban and urbanizing areas, and many
overlay Standard Metropolitan Statistical Areas. Because of this, the
initial boundaries arc often defined as coincident v;i th county boundaries,
though in sorr.e. cases boundaries divide counties. Other AQMAs cover
areas whore resource exploitation or industrial df've! orient, create,
or inay potentially create, an air quality problem. Oesigr.ations
arc; po-Uitant ipecific; that is, an AQMA -lay be designated for a
potential violation of any cno or several of the pollutants for which
standards exist.
Fo! lowinci to-r initial dui; irjna ticn. sUtai; cr £?A niust -!o an in-depth
analysis of ti-s p>~obU-:iiis ;-ooc;.'! by each rullutaiit Per v;hich an area
is designated. This v/oulu ircluJc an ass'.^snient ;;f -jrcv.'th ;'ictors
and dr/slopjnont patterns an-j a projection of future air quality for
at lc:.>;t 10 y?ars. It is possible that b,i:od on this analysis, the?
boundaries would L^ revised to correspond rr.ore closely to the air shad
vdthin v/hich the objectionsie po!i:;i:anos are a pr«?Jie«i.
2C-3 aroav/ide plcinninc: is not pollutant specific, It is i^yrforir.O'J
'whenever the governor of the state (or in suine cases, local officials)
del errnir.es tiui: an area will hc\ve subst^iici A! problc::is in controlling
'•/ater c;.ia!ity due to hi';h coricentrat'ions of population and iiKh:;try or
other conditions. The state is responsible for planning in ail other
areas through the State U'atsr Quality Management Plan. Boundaries, for
203 areas are coincident v/ith governmental boundaries in most cases, though
hydrological boundaries also n:ay influence boundary '.leteniiination. The
designations are proposed either by the state (or states if it is an
interstate area), or by the local jurisdictions th
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In other areas, the first problem may be to attain air quality
standards before considering maintenance measures. In any case, by
July 1, 1976 the Regional Administrators must identify all attainment
and maintenance SIP revisions that will be necessary as well as just
maintenance revisions, It is the RA's responsibility to set a
submittal date for the AQMA plan which will be contingent upon the
lead ti;iie neetiod for effective maintenance. For example, if the
first 10 year oir quality analysis reveals maintenance problems, and
to solve the problem requires an action 7 years in advance, then the
necessary action must be in the first maintenance revision. It does
not Matter how many years the revision covers, the necessary lead time
from action i.o prevention of air quality standards violation must be
considered. The shortest time period a revision cculd cover, however,
would probably be three years since less would be impractical.
Plans that provide for the maintenance of tils ilAAQS for loss
than 10 years :iust provide a discussion of problems in nwip.taining
the NAAQS for the remainder of the 10-year period. In addition,
AQMA analyses ond plans n>ust address the sarno periods as other
. federal ly-sponr.ored plans in AQMAs where such plans account for
periods of longer than 10 years. These plans include the Department
of TVonsporf-.j.t ion's 3-C pUns, trie !.\v-arL;;:ont of Housing and Urban
Developer's 701 comprehensive plans, .;rc! ilPA's Section ?Q3 areavmie
v;?ste t r ::•;?,<::.•;: rii; :nanaa£;,:-Mu: plans. If the AQMA plan does not maintain stan-
dards over the full period cover ad by other fcuernlly-sponscred plan', then
i:he AQMA plan wou'd have fo clis'".u:;' '.he ;r:ui:V:c::a;io>; prouieiHS expected
over the remainder of the period. The1 Administrator, at his discretion,
could pervni t the States to perform a less detailed ACr!A Analysis for
the period beyond the initial IQ-year period than for the initial VO-year
period.
From 'chc i'!ats of designation, according to the Act, 1:08 planning
agencies havy one year to develop a work plan and Lv;o years to develop
a plan, However, in order to qualify for IOC?.; fedora 1 funding, the
work plan had to be submitted to EPA before the ond of FY 75. Thus,
for most designated areas the deadline for the romp Is ted nloti will bs
around June 1977, but the exact da to for each 208 area depends on when
it ro.cciveci its grant. Proposed changes in the grant regulations would
allow the RAs some discretion in detorniining when 203 plans would be
due from those agencies receiving grants in FY 74 and FY 76. The RA
would be allowed to grant the planning agencies more time based on his
determination of when they had sufficient staff to begin plan development
and had initiated major work elements. Under die proposed changes new
grantees would have two years to develop the plan from the date the
detailed work plan was approved by EPA. The agencies could receive
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up to 5 percent of their grant award to prepare the work plan.
Because tho regulations for AQM do not specify due dates for the
subiaittal cf maintenance plans, but leave this to the discretion of the
RA> it is difficult to generalize on the timing of coordination between
208 and AQ;';A plaining . -Soi.ic CPA "scions will keep their AQMAs to the
time schedule developed earlier, which overlaps greatly v/ilh the schedule
for 203 pl'ans. ..'here this is not possible, it is important to remember
that tha plans which am developed are not one time efforts but must
u?2 period ically updated in order to ir.airitain them as effective irar.u'joment
uools. Section £Qo requires an annual certification of the plan by the
novernor or his dosinnco as being consistent with applicable basin plans.
The 203 grant regulations state that if in thn judgment of the Regional
Administrator, State Govenior(s) or 203 agency, substantial changes have
occurred v;hich warrant revision or amendment of the approved plan, the
plan shall be revised or c^ndod and submitted for review in ^he same
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i',i. rroccG'jres ror Loorainanon
Thjro are o number of procedures, wiiich if iirpleri'^iif'.ecl, would
facilitfito coordination b-'tv-^en 2OS and AQ?} during the plaijni-'Hj ;;e/-iod.
The purposa of this section is to outline tiic;;e ar^d to describe how
thay v/cuui c?. integrdted ir.to tho planning process.
It should also be noted that the state is responsible for water
quality nisnacement planning in those areas of the state not designated
for 203 arcawide planning. Thus it is only logical that the state
;uvency >"-Jipc-nsible for water quality ;"anacje!;;o;it cco:-c.h'n.-ito with the
s-jency responsible for the St.ite Implementation Plnn. Mnny of the pro-
cedures discussed herein pertain to state planning efforts and chcind be
carried out whc:n a;)plicab!e. The State Vwter Qua! i l\> Ma:i'Kje.;:c-iit Plans
include many of the same elements that 203 plans in designated areas
will contain. The State is already responsible for the SIP of which
/"\QMA plans are a part. The agencies responsible for 203 or AQMA planning
in areas where there is no co'-responding areav/ido planning effort for
the other medium should coordinate with the state agencies responsible
for air or water quality management.
A. Planning Agency Designation
In most cases, the 208 planning agencies will have been designated
prior to the AQMA designations, and often the designated agency will be
a COG or regional planning council. Given this fact, coordination would
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8
be facilitated if the states delegated responsibility for AQN plan-
ning to the same agency designated for 203 planning, provided that
agency has rer-ponsibi 1 i ty for comprehensive planning and is capable of
preparing such a plan. Tlv:; development of AQMA plans in many areas
involve measures, such as land use controls, which many'air pollution
control agencies have neither the expertise to develop nor the authority
to implement. Thus, in addition to facilitating coordination, it may
be more politically acceptable to have an agency responsible for general
comprehensive planning develop the AQi-'A plan. Of course, the feasibility
of having the sanie agency develop both plans would depend on the boundaries
of the two areas. If th?re is little overlap, the designated 208 agency
may not have the authority to conduct fanning in the AQMA.
IF the saii'.-j agency i;; not designa ted, cocrci'ination '.-ould still
have to occur, and to assure thai: it does, the responsible planning
agencies should draw up letters of agreement between them to cover
such items as integration of work plans, and consistency of date and
control strategies.
3 • Goooraplric J'.oundari e_s_
Frcn1 the <\srlicr discussion, it .--hoi.;Id be* apparent oh?.t in many
en sos 203 a:i'.i Af'-MA dusigrn tions u i'M not coincide, Sonio i;:e!;ropol i Cnn
ar'xr; may be design?.UK! In part for 208, vmile ufiOt'ner part is included
in AM AQMA. nOx-..>'v'.-irj if there is a considerable overlap between the two
bouii'.'iorins, it would bft ;-;roforabS>? if they could be the sai:;c. During
the ACy'A analysis, v;hc-n ti;-? boundaries are refir.cd, the s;:-ates or those
cielep.-iVed by th.s-.in should consider incorporating existing 203 areas into
the A^MA when this appeals to ba a prnctical alternative, Coiiversely,
if dssiynatlons for 203 ar;.:-j.s are made after KY 7fj, consideration should
be given to refining the boundaries prior to designation to increase .
consistency with AQMA.
C. Ifork ProqraiTis
The 208 and AQMA plans have a slightly-different planning sequence
but essentially follow a similar process.
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The follov/inq generalized planning tasks apply to either
AQMA or 203 planning:
1. Inventory of existing and potential emissions or
discharcier, and characterization of possible problems.
2. Data collection and projection of population, employment,
and 1-ind use over the planning period.
3. Projection of waste loads or emissions over the planning
period.
4. Deter;;,i nation of effects on air or v/ater Duality.
'j. Determination of necessary elusion or \vaste load
5. Devourment of a 1 torrviU ve s :.r;'. tecio:; of .^ste l:c\d or
emission redaction to oc!;icvo o:id ::":': i is £:>."'n s-^'^hrds.
tivo.
Al tMoi'tj!", U'ey may be cm so:nr:v.'!'.^i: -ji f f::rr.,-!t \.~.:.";: sclied:., lr:s , it is
on i.iie d-:velci':;":;i~ of ;:''eir v:or!-; 'r.1 •
uc jointly, ;v.;/ivtp-; --:.-:'.:;: iivj ..',;-.; •; '-„:• ;' f r-vy; Ire •,,f,-ni..-:; f ; .• t!;e ;:i;;^:-
.. ;;5:ng n.^t^ro of i'/cii ; ' • c •:: r .' r.is . >': .'1:0' ca;;-::, i:;;e v,or!s :. •.••-;;•:!!! r':J'~t
:-<;';.;:: i fy iiov: cvO'";1 !na h io-i '..'iil occur c-i'-;.:^!'n;ji; :,;•,.; pi in-r^-'j ;:. :i'jcoss .
";•,.": Sol lov.'ii!!j -ecticns --! •.:.!] -.;!-.!: :;,•:.-. ;oi;;-e:; fn;- !:-.y-:-:-.;vi:. > ; -,;i •;,•; ;.j;o
'!•.:•••/':'! ;:-.;; nr; rit of ;'r:)jecti.;:':i ; e'/alu^". iv;;i of altern^';;^e 3 tv.-Kojies , ^.;v'i
.•"C.-itol i\ivil v:. i°> , roporting, and rapr-:;Siiii.-,ctic%n. T;ie exact i;;e".(is or
i implementing I'w-:.? pi'ocedures must be developed in the work plan.
0. Gr-in'; Ccnd i Uoninq
G?\-nt conditions can !.e used to ii)eciry and nivi:! ar-sur-vice that
"i:ff Icient attention vnll Ls eiven to cO'ji'din^Lion needs, "i.^i'-e :-•:•:-uj,~:-i
for ;i.!:;;isisteri;i'j the ACM pi•-.•;;;;ram v.'ii'.irin the !le
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10
Air and Hater Quality Planrnng Coordination
The Project Control Program shall, at a minimum, establish
procedures to integrate the air quality maintenance planing (AQMP)
and Aroavnde t.'nste Treatment Management Planning (AV.'VfR-iP) activities
for the designated area by written agreement(s). These agreements
shall insure that: •
A, The designated air quality maintenance planning agcncy(s) has
rovicv;2'J and coinT.Gntcd en the project control program prior
to i i;s subciHtal to EPA.
0. ?•.-:.•• I ex! ic reporting and output review procedures for both the
/',Qi'-;P snci A'J'.nH? progr:;!;vj are estaM inh.-yJ betv.'cen cho desijnatecl
air quality na in/:nnano:} n! arming •::•;; 2.:vv-'{s) ar*ci the a reawide v.'ast
troa '-.ir,cnt ;:UiU^e:rent pUmning aacncy.
C. The design?, cati air qua! icy '.^inten^nco planning agc^cyfs) nas'tic
~\3 "C":ber(s/ oi: ;:he Ai'fjav.-J!"ie Plonnir-g Advisory Co;;^ii ttee, ejcabli
pursuant to 40 CFR 35 .lo:-4-^(d).
;s .'--I C'y.r!v.:; lent -^''C^ or ;..••.•.;•.. ..-•< ^:i
-3 aii- c-i;:! ! !-.y :;:ain :;;;';;,;-;^ \> \-\-.\-:, I
iVj l'io ••;:•-; .'•^nsio-i air qvalit/ -•;>.>::v
o.j^'iciss) cr ':.;:•? ox is tin-;.! or.r-rci'iic , ••!.:•;. ;••'; ;j ra p i1 •> c , I-: .id vise, ."..:d -^'
b'':;li:ie tlf.t;; a:vi daLa "c:-:--.'.t:; is .'i;::cnp : 'shad r;riO!' b;; L';o •.! •••ol
n^tvc of the d.it/i Lv~;se for ti--i A--:V;Ti'-'P 5'vl ACMP p> ••Hrr'.nis.
Oyvrr'cpii'.or,!: or i>ov: ocoi'.oir.'i'; , '!;i;i:ogr^;;;i1c 3 land uso and uti'.er Lv'el
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11
E. Data
Both programs require the projection of future pollution levels.
To do this, they must correlate predictions of the concentrations anc}-
components of growth to the resulting emissions. 203 covers a 20 year
planning period, ACMA plans must address the same time period as other
Federally-sponsored plans in the AQMA, so in areas where 203 planning
is being done, A^'A plc.r,s must discuss at least a 20 year period. If
the two plans aro to be consistent, they must develop consistent pro-
jections for democjraphic factors such as population and household type,
and for economic growth and land use. To insure such consistency, a
common classification system is needed for land use and 3conoi;i.ic factors
so that data will be compiled using a similar format. The planning agencies
should integrate their data requirements before gathering data, so that
the information obtained for the ore plan is transferable to the other,
AQ'-'.A pla.is can use Uvo fota already collected by 203 in areas v.here 203
p'rV'.niiig is alrouciy underway. In other cross, the two programs should
divide Lhe effort of obtaining data, which, when collected, car, ba integrated
into .1 common data base.
Since most AQi-'A planning Agencies have limited resources, primary
reliance should ho placed on 2Gr. agencies for population, l,;nd use,
£.:ynr.:ric ;u:d water ouelHy data •-.-hen this is compatible with the time
schedule for Ai^.'-'A planning, The i dune much
earlier than the other, n-ira 'recent or cc:-[/rehens ive ciala .:'.\y '.)i.-cc:r,e
av^'i;'iblc by the timo the s-'/cond planniiv.] effort \", u.v.'erway. if this
'Is the ca;e, there i^ay be aciiciuate re.VJOi1. for r'ocifyirig projeoLi-ons.
!iowf:vcr, if it Ccirnot he demonstrated thr-t th.e oif^oronco in pro.jectioiiS
"is cuo to the
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F . Representation
Periodic consultation between AQM and 203 planning agencies will r
help ensure tint both plans arc consistent. It is important, therefore ,
that representatives of tho planning agencies roponsible for each program
should ba included in any Advisory group which might be created, to
ensure periodic consultation between tho two agencies. AOMA planning
guidelines discuss the necer.sary involvement and interrelationship of
various governmental crcan izations in the development of an AQMA plan.
They assume t!i-it, in most cases, a number of aconcios will he intimately
, ,
involved in tho plan's development, and several possible modes
cion are discussed. l-!ho L'-r:vot- method is chosen, a representativ
of coorcliikv
ve of tho
203 planning
shoul
ide for coordi nation by moans of
included in such efforts. 2Gr. y..: ids lines
Areawido
an Ai\'T\ agency sho
he s"':.?. iTi; of the
Advisory Con^ii ttns and representatives
incited in its r;,r:-bership. In additi, .. ..
ayfrncies should develop a close working relationship. For example, each
planning agency c.c;uld designate' one person to sor-t: as liaison betv;ecn
thorn, to help oribure that necessary coord i nation
'
nning
ld be
-.'o planning
h
fashion. This w^u'id also help in identify ng possible conflicts
carried cue in a
U;K! rosolving c!io;:i inforiuaHy as they arise.
3 !' •'•'"!
'i Z •"•;
case-
in >"•
<" .-~i j ' •-
Many
o r a
SpC:',: 1 &
of Ai
ontro'i
Tnr '• '' r
of tho
" ^ , i J
i iy •»,
r 0-jnl
Strat
i\ .'! <; 1
control •;:;!'
.1 r: • Oi L',.; <,;
i ty i-'aic: ;;,r,
,::<,\ a '_:jv) i o^, ! -j 1 a
nee, nine of che 1
- ill of i:!-.a AQMA
i;vpc ""•!•;' -- c-i .-in •! 1
•'or use
rNn ,•>.•-'...-,
• * 1-
.•I/) to
"; r;:;\ic.r
:ji:i.-!ol in
| .«.-;. : - ^ . <
in oi Lher
i i ...
land us-:.
cs 'lire1.:;-
s s:-vrii-:s)
i->.-ni-.-. - !:
an
r
f
SGd
, a
- Q
In the
,or
Instancs, \vouid li-iiit tho cc'ir;:;ion of oollutants L-'.sed on the ^ijicnal
lend trie/trsnspoi-taf ion plan. The mo.-imun eivrissions al lov,:;;jle, con-
sistent v/ith standards, v;ould be allocated to planning s'.'ivir^as, and.
"'and use and transporttion plans would be revised so that these pre-
scribed emissions limits would not be exceeded. Emission c'
zonir'.g limits euiissions of a pollutant to prescribed levels v,
defined so?tial areas. The limit is established i:> terms of
of emission.? per area, per v.isr.fi period, snch as pounds cf pa:
per .-ere, per year. The allocation can correspord to the t:yr;
use so that, for example, heavy industrial ."ones art; allowed
limits thon residential r.onos. Tranr-portation controls help rcdnce
emission'; from no Lor vehicles by either roducinq t.ho pollutant omission'
rate per vehicle mile of travel (VMT) or by rechjcing the total number
of VJ-ir. Measin'cs to reduce VMT liave the greatest impact on land use,
and can include such things as street closings or traffic free zones,
parking bans, parking supply management, restricted road building,
improved mass transit, and control of urban development. Other control
i tv
Un'n
of land
igiior
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13
strategies which affect lend use include transfer of enn'sson source
location, indirect source review, emission charges, and .regional
development planning.
All of these control stratgies affect water quality and planning
for iirc-cU-ndc waste treatment manager.ont. Emission limits set for various
suhe.reas would effectively control certain types of development producing
tho;;e emissions, while possibly encouraging then to locate elsewhere.'
An optimum location decision in terms of maintaining air quality may
not be desirable in terns of handling water pollution discharges.
Restricting the development of road networks in one area may lead to
development wlvi-re tiv* troimportation in!"ras'cruc euro was already in
existence - thus causing higher pollution loads in already developed
areas.
Ar, pointed out earlier, it is not only the control strategies
which directly affect land use arid thus water quality, but also the
'technological ly and opera i.ioral ly crisnt^u str'u-^i^s , that is, omission
control measures. Thesa include such thir.cjf, as now source performance
s !.'r.r.d;;rds, t\.;ol conversion, combination of '-inn •, "on sources, stac!; hc-viht
rc1^! latiens and control or" fugitive dust sources. Combination of emission
sources may cause a concer.'Li-.ition of v.'atcr pollution dischart.j;!1;. Tiie 'jse
uf U"i i i stacks may reduce ground level concertra ti')n- but could result
in coiitaniina tec! precipi tatio;' .r/.;ch as t!;e "acici veins'1 observed in
Sw2r!'.:.i. One control strategy for fugitive d:jst consists of v.;.tiring
which cuijid cause runoff problems.
Int::-riiiedin prohlenis i:iay also arise frc'ii water quality rvr.Mr:c'n;ent.
strategies. Many of the measures incorcor'ted into •?. 203 plan to control
point o;vl nonpoint sources affect land use which could affect AC/'A plans.
Sev.'or interceptor and facilities location, restricting tha Ic-cation of
industrial devolopmont to arcar, where the receiving v/atei's
capacity, and restricting development in arr.as wh^ro siyni
polli.nii.in would result, ore decisions which cculd arfect a
iiovre'-'or, not all interaction between 2CG ancl AQM i-ecd re
Both plans should favor bettor ^an-Kifciuant of conn trucl; ion
exa:up!e, liieasur^s such as minimal exposure periods for active
areas, or utilisation of staged grading, seeding and sodding procedures •
would reduce both runoff and fugitive dust problems. More generally, the
objectives of both programs wnuld be served by limited urban development
in certain areas or controlled density. Transportation control plans
which restrict road construction to such areas, and facility planning
which avoids routing an interceptor to undeveloped areas could both be
used as reinforcing strategies.
It is thus critical for the successful•implementation of the 203
and AQMA plans to take advantage of complementary strategies by evaluating
the effectiveness of various alternatives to determine their impact on
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14
each medium.
The planning agencies responsible for the tv/o programs must
make sure that they inform one another about alternatives being
considered and offer one another an opportunity to review and comment
on alternatives. Such COT-MIts should bo considered during the evaluation
process so that alternatives for one medium could not be selected that
would conflict vm.h i ir.pl encnUti on of the plans for the other r.edium.
This review and co;;;:::ent should be undertaken by the planning staffs and
the advisory groups to the planning agencies.
208 agencies will have an additional opportunity in preparing
the environmental a^sessnant to assure thai ;-o conflict exists with
AQMA strategies. L-;;h alternative 208 plr-n v.'ili bo evaluated ro assess
its impact on air quality. u~>-: only the direct impact on air quality
should bs assessed but also the indirect effects on grov/th inducement
or distribution.
l!> Reporting
In order to keep the pi-,-win;) o.gijr.oies pasted on tho ciirr-.:'.-. t •-.kr-.'o'iop-
;?!.?n'; of both plans, there :i:C-!.''!u be sci;^ ty;.:™ of periodic or ;.:iloposL
ry.;orting i'Otv.'ssn thsnt. The st.vt* shoi:id bo veGpfu;:.iblo for ensuring
tna :; the reporting is carried out. fhis c-^.iici take ;-!ace quartorly or at
jactions, analysis of v/atcr and air qujlity, ntc.). Ii-f.vr-al contacts
v-.-oulJ, of course, b<:nt to the !-"Y\ rn-rional
office. The report should describe how respr^en^atives of eac i program
are involved in an advisory capacity, any meetings ':h;c:h .have; l.-j-'.-n ';eid
between t!iG two programs, what information has hcc-n provided to o:ic'n pro-
gram, how consistency in data and projections is 'being achieved, and any
i/otantial conflicts which may be developed. This sh'iuld DO done at a
minimum of L-very 6 njonths in the format of the stami-annual reports required
of coth i:!;=; AQM and 203 planning agencies.
I. Progra:n Approval
After completion, the planning agency for each nrogron sliculd review
the other's plan to ensure there are no conflicts, and as a final
check, the plans should also be reviewed at the state K:vel by those
responsible for administering the tv/o programs, and by the EPA regional
office.
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15
If potential conflicts develop during the puintnng stage, it is
expected that the planning agencies responsible will attempt to
resolve them informally. If this is not possible, the conflict should
be referred v.p to the state level where the agencies responsible for
administering these t'.-.o programs v.'ould resolve it. As a final resort,
it would be referred to the Regional Administrator for mediation.
In the case that other federal agencies v/ere involved in a dispute,
then EPA should meet with representatives of the .-if fee ted agency to review
the situation and v;henevcr possible to fonr.ulate recommendations for
resolving th eiL'ner
Hir'.'.iiL'ni. Thus, 2'^ i!M..1 A'y! agopci'rjS arc encouraged i:o ror.olve conflicts
early c>r-i.! nol: v.'Ai i: unLM the plans arc so far alon~ l\\:\i ciionn^s v.'ould
Environmental Protection
Region V8 Library
230 South Vezz-bctm Streo
Chicago, Illinois 6060«f
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