HomeMy WebLinkAboutEarly Action Compact for the Augusta Area
Augusta Richmond GA
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Georgia Department of Natural Resources
Environmental Protection Division, Air Protection Branch
4244 International Parkway, Suite ~ 20, A;t:lanta, Georgia 30354
Phone: 404/363-7000; Fax: 404/363-7100
Lonice C. Barrett, Commissioner
Harold F. Reheis, Diregor
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February 18, 2003
Honorable Bob Young
Mayor, City of Augusta
530 Greene Street, Room 806
Augusta, Georgia 30911
Dear Mayor Young:
Enclosed are copies of the fully executed documents for the Early Action Compact for the
Augusta area. We appreciate your interest and participation in this.
We look forward to working and coordinating with you on this shortly.
If you have questions, please contact Dipan Shah at (404) 363-7014.
A~
Ron Methier,
Chief, Air Protection Branch
Enclosures
GEORGIA'S 8-HOUR OZONE
EARLY ACTION COMPACT
FOR AUGUSTA AREA
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Prepared for
U. S. Environmental Protection Agency
Region 4 .
Atlanta, Georgia
Prepared by
Georgia Department of Natural Resources
Environmental Protection Division
Air Protection Branch
December 17,2002
1.0
PURPOSE
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The United States Environmental Protection Agency (EPA) has provided an option for areas
currently meeting the 1-hour ozone standard, like the Augusta area, to attain the a-hour ozone
standard by December 31,2007, and obtain cleaner air sooner than federally mandated. This
option offers a more expeditious time line for achieving emissions reductions than expected
under the EPA's a-hour ozone implementation rulemaking, while providing "fail-safe" provisions
for the area to revert to the traditional State Implementation Plan (SIP) process if specific
milestones are not met. Through the development of this Early Action Compact (EAC) , local,
state, and EPA officials agree to work together to develop and implement local and state early
action plan. The plan will become a part of the state early action SIP to reduce ground-level
ozone concentrations to comply with the a-hour ozone standard by December 31 , 2007, and
maintain the standard beyond that date. Failure to meet the obligations outlined in this EAC will
result in immediate reversion to the traditional nonattainment designation process as required in
the Clean Air Act (CAA).
The South Carolina Department of Health and Environmental Control (DHEC) has expended
considerable effort planning for ozone abatement efforts in the Aiken area. An Early Action
Compact has also been finalized for that area.
Recognizing that regional airshed modeling domains for the Augusta/Aiken area would overlap
there could be significant opportunities for efficiencies in cooperation between the two areas.
There has been some initial sharing of information and informal communications have been
initiated between the two areas. EPD will endeavor to promote and support cooperation in air
quality planning efforts for the two areas.
2.0 MEMORANDUM OF AGREEMENT
This Early Action Compact (EAC) is a Memorandum of Agreement between the local
governments representing the Augusta area (Local), the Georgia Environmental Protection
Division (EPD), and the United States Environmental Protection Agency (EPA). It is for the
express purpose of developing and implementing an Early Action Plan (EAP) that will reduce
ozone levels in the Augusta area to maintain compliance with the a-hour ozone standard.
2.1 General Provisions
A. The signatory parties commit to develop, implement and maintain the local Early Action
Plan providing EPA defers the effective date of the nonattainment designation and
related requirements as long as all conditions of the EAC and key milestones are met.
B. If the potential nonattainment area fails to meet all the terms of the EAC, including
meeting agreed-upon milestones, then it will forfeit its participation and may be subject
to the full planning requirements under applicable CAA traditional SIP processes
including requirements defined as part of the EPA's a-hour ozone implementation
rulemaking.
C. If the area has had the effective date of a nonattainment designation deferred and the
area does not reach attainment of the standard by December 31,2007, then the non-
attainment designation will be effective immediately. If the EPA's implementation
schedule also requires a traditional SIP from areas on or before December 31,2007,
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then a traditional SIP revision demonstrating attainment by the new attainment date will ,?
be due for the nonattainment area no later than December 31, 2008.
D. Before formal adoption into the Georgia SIP, this agreement may be modified or
terminated by mutual consent of all signatory parties, or any party may withdraw from
the agreement by notifying other parties in writing. If a party's withdrawal from the
agreement prevents remaining signatories from satisfying any of the terms and
milestones of the original agreement, the agreement will be void, any deferred effective
date of the nonattainment designation would be withdrawn and the area's nonattainment
designation would become effective soon after. Upon termination or withdrawal from the
EAC, the area will be subject to the full planning requirements under applicable CAA
traditional processes including requirements defined as part of the EPA's 8-hour ozone
implementation rulemaking. The local government signatories will approve the local
Early Action Plan before EPD includes it in the Early Action SIP. Once the local early
action plan is incorporated irrto the early action SIP, any modifications will be treated as
SIP revisions.
E. Execution of this EAC by each Party shall be. by signature of each Party's authorized
representative. This agreement remains in effect until December 31,2007.
2.2 Early Action Plan
EPD agrees to develop and implement an Early Action Plan that will demonstrate attainment of
the 8-hour ozone standard by December 31, 2007, and maintenance until at least 2012. EPD
will develop this plan in coordination with local governments, EPA, stakeholders, and the
general public. The EAP will include a process monitor and maintain long-term compliance with
the standard. The EAP will be finalized for inclusion in the Georgia SIP by December 31, 2004.
If a development or issue arises that may impact performance or progress toward milestones,
EPD will immediately notify all other signatories.
The Early Action Plan will address the following major elements.
2.2.1 Milestones and Reporting
EPD and locals will assess progress towards developing and implementing the early action SIP
and make a report available to EPA and the public every six months beginning in June 2003.
As per EPA guidance, the key milestones for participation in the EAC are identified in the
following table (see Table 1 below).
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December 31, 2002
June 16, 2003
March 31, 2004
December 31, 2004
September 30, 2005
December 31, 2005
June 30, 2006
December 31, 2007
'?
EAC signed by all parties and submitted to EPA
Potential local emission reduction strategies
identified and described
Final local Early Action Plan drafted for public
participation; copy to EPA
Early Action Plan submitted to EPA for
incorporation into SIP
EPA takes final action on SIP submitted
December 31, 2004
LocaVState control strategies implemented no
later than this date
State submits progress report to EPA
Attainment of the a-hour ozone standard
Local/State/EP A
Local/State
State/local
State
EPA
Local/State
State
Local/State
2.2.2 Emission Inventories
EPD will be responsible for developing all the emission inventories. Base year emissions
inventory is scheduled to be developed by May 31, 2003. The base case inventory is scheduled
to be developed for 1999 or later episode(s). Selection of specific episode inventories will be
partiaHy determined by the conceptual model, which reflects an analysis of meteorological
conditions typical of high ozone events. These inventories will be used for SIP-quality regional
air quality modeling. The inventories will include:
· Point source emissions - employing EPD Emission Inventory System data.
· Onroad mobile source emissions - employing Mobile 6 emission modeling.
· Nonroad sources - model data adjusted for local equipment usage.
· Area sources - data based, where possible, on local surveys.
· Biogenic sources - inventory developed employing methods acceptable to EPA.
A Mure year (2007) emissions inventory is scheduled to be developed by June 30, 2003. This
inventory will sufficiently account for projected Mure growth in ozone precursor emissions
through 2007, particularly from stationary, non-road and on-road mobile sources.
Where practicable, trends in emissions from the various source categories will be analyzed to
provide a better understanding of emissions trends in the Augusta area and to facilitate
verification of accuracy of the inventories.
2.2.3 Modeling
EPD will be responsible for conducting the meteorological and air quality modeling analysis.
EPD will conduct the modeling analysis based on the "Draft Guidance on the use of Models and
Other Analyses in Attainment Demonstrations for the a-Hour Ozone NAAOS" (EPA-454/R-99-
Page 3
004, May 1999). The modeling will follow the guidance as facilitated by the EPA Regional
Office. Modeling protocol development, episode selection, model input preparation, and actual
model simulations will involve close collaboration and agreement of the Augusta area
representatives, EPD, and EPA. As mentioned previously, there may also be opportunity to
coordinate with South Carolina for efficiency and consistency in regional modeling efforts.
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Base and Mure case (2007) modeling are scheduled to be completed by September 30, 2003.
Control strategy modeling (e.g. sensitivity analysis) is scheduled to be completed by November
30, 2003, with final revisions completed by January 31, 2004.
Modeling efforts will be carefully documented. Model performance will be assessed to assure
conformance with EPA's accepted model accuracy criteria, and will sufficiently account for
projected growth in ozone precursor emissions. A technical support document describing the
modeling effort and attainment demonstration will be part of the Early Action Plan submittal.
2.2.4 Control StrategIes
All adopted Federal and State emission reduction strategies that have been or will be
implemented by the December 31, 2007 attainment date will be included in base, future and
control case modeling.
Local measures being considered for the Early Action Plan will be identified and described by
June 16, 2003. Following research of various emission reduction strategies and, with guidance
provided by testing of various strategies with the developed regional air quality modeling, EPD
will select and adopt local emission reduction measures necessary to support demonstration of
attainment of the a-hour ozone standard by December 31 , 2007. These local emission
reduction strategies will be designed and implemented by the community with stakeholder
participation. The selected local emission reduction measures will be specific, quantified, and
enforceable. Specific implementation dates, as well as detailed documentation and reporting
processes will be provided for each. The local and state control strategies selected will be
implemented as soon as practical, but no later than December 31, 2005.
Voluntary strategies can playa supporting role in the Early Action Plan. If emission reductions
from voluntary strategies are quantified and credit is taken for them in the EAP, those emission
reductions will be enforceable. Additional strategies must be implemented to meet those
quantified reduction requirements if quantified voluntary strategies fail. This is true for all
quantified emission reductions.
The local emission reduction measures will be incorporated by the EPD into the SIP and
submitted to EPA for review and approval. In the event the area desires to add, delete or
substitute measures after SIP promulgation, the area will request a modification of the EAP.
Such modification will be treated as a SIP revision and facilitated by the EPD. .
2.2.5 MaIntenance for Growth
The EAP will include a component to address emissions growth at least 5 years beyond
December 31,2007, ensuring that the Augusta area will remain in attainment of the a-hour
standard during that period. The attainment maintenance analysis will be completed by March
31, 2004. The Mure attainment maintenance analysis will employ one or more of the following
or any other appropriate techniques necessary to make such a demonstration:
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Modeling analysis showing ozone levels below the a-hour standard in 2012;
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· An annual review of growth (especially stationary and mobile sources) to ensure control
measures and growth assumptions are adequate;
· Identification and quantification of federal, state, and/or local measures indicating
sufficient reductions to offset growth estimates; or
· Any other appropriate techniques necessary to make such a determination.
The EAP will also detail a continuing planning process that includes modeling updates and
modeling assumption verification (particularly growth assumptions) where changes in emissions
inventories and growth assumptions warrant. The continuing planning process will consider and
evaluate:
· All relevant actual new point sources and major modifications of existing sources;
· Impacts from increased emissions from potential new source growth; and
· Future transportation patterns and their impact on air quality in a manner that is
consistent with the most current adopted Long Term Transportation Plan and most
current trend and projections of local motor vehicle emissions.
If the review of growth with the continuing planning process demonstrates that adopted
emission reduction measures are inadequate to address growth in emissions, additional
measures will be added to the EAP through the SIP revision process. Local planning processes
should prepare for this possibility.
In the event that the continuing planning process identifies the need to add, delete, or substitute
control strategies after the local early action plan has been incorporated into the early action
SIP, the local area will initiate, and EPD will facilitate a SIP revision to accommodate changes.
2.2.6 Public Involvement
Public involvement has been and will continue to be strongly encouraged during the planning
and implementation process. Public awareness programs will be used to provide opportunities
for involvement in the planning process, implementation of control strategies, and any other
issues important to the Augusta area. Interested stakeholders (Le., local, state, and federal
government, citizens, public interest groups, and the business community) have been involved
in the FAQS and will continue to be involved in the planning process for EAP as early as
possible. Planning meetings will be open to the public, with posted meeting times and locations.
Early action SIP drafts will be publicly available, and the drafting process will have sufficient
opportunities for comment from all interested stakeholders. Opportunities for public comment
on the proposed early action SIP will be provided and will follow the traditional SIP revision
process as implemented by EPD. Semi-annual reports detailing, at a minimum, progress
toward key milestones, will be made available to the public.
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2.3
Local, State, and EPA Commitments
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2.3.1 Local Government (Local) Commitments
The local governments agree to assist EPD in the development and implementation of a local
early action plan that will promote the area's attainment by December 31,2007, of the a-hour
ozone standard and maintenance until at least 2012. The local governments will provide
support to EPD throughout the planning and implementation process. Areas of support will
include:
· Assisting EPD in completing and adopting the early action plan as part of the SIP no
later than December 31 , 2004;
· Notifying parties as soon as possible of issues and developments, which may impact
performance and progress toward milestones;
· Notifying parties as soon as possible if Compact milestones will be missed or have been
missed;
· Notifying parties as soon as possible if Compact modification/termination is to be
requested;
· Third party review of emissions inventory, modeling, and self-evaluation work;
· Strategic assistance, as appropriate, in the selection and implementation of emission
reduction strategies;
· Planning assistance in developing and implementing processes to address the impact of
emissions growth beyond the attainment date; and
· Support for public education efforts.
2.3.2 State Government (EPD) Commitments
EPD agrees to hold the primary responsibility for the development and implementation of an
Early Action SIP that will demonstrate Augusta area's attainment by December 31,2007, of the
a-hour 'Ozone standard and maintenance until at least 2012. EPD will develop this plan in
coordination with the local governments, EPA, stakeholders and the public. The state early
action SIP will include a process to monitor and maintain long-term compliance with the
standard.
It is the responsibility of each state under the CAA to ensure attainment with all National
Ambient Air Quality Standards. At any such time that an area is deemed nonattainment, the
state will be required to develop a plan to return the area(s) to attainment in accordance with the
CAA. If applicable, Georgia is committed to working with adjacent states to assure mutual
attainment of national standards.
I n the event a development or issue arises that may impact performance or progress toward key
milestones (including if a key milestone will be or has been missed and/or if a termination or
Page 6
modification has been requested}, EPD will notify all other signatories in writing as soon as
possible.
EPD will provide support throughout the planning and implementation process by:
""
· Developing emission inventories, modeling, trends analysis, and quantification and
comparison of control measures.
· Providing necessary information on all federal and state adopted emission reduction
measures, which affect the area.
· Providing technical and strategic assistance, as appropriate, in the selection and
implementation of control strategies.
· Providing technical and planning assistance in developing and implementing processes
to address the impact of emissions growth beyond the attainment date.
· Maintaining monitors and reporting and analysis of monitoring data.
· Promoting public awareness efforts.
· Coordinating communication between local areas and the EPA to facilitate continuing
the EPA review of local work.
· Ensuring expeditious review of local early action plan, and if deemed adequate,
proposing modification of the early action SIP to adopt the early action plan.
· Adopting control measures into the early action SIP as expeditiously as possible. The
final complete early action SIP revision must be completed, adopted, and submitted by
the state to the EPA by December 31,2004.
· Tracking progress. If any milestone is missed and EPAwithdraws the deferred effective
date, thereby triggering a nonattainment designation and applicable statutory
requirements, the state will strive to submit a traditional nonattainment SIP within one
year.
2.3.3 Federal Government (EPA) Commitments
EPA will recognize Augusta area's and EPD's commitment to voluntarily adopt an early,
substantive, scientifically-based and enforceable attainment plan with early implementation of
control measures by becoming a party to the Early Action Compact developed in conformance
with the EPA's EAC Protocol. EPA responsibilities include:
· If monitors in the Augusta area reflect nonattainment when EPA's a-hour ozone
implementation guidelines call for designations or at any time during the area's
participation in the Early Action Compact, EPA will defer the effective date of
nonattainment designation and related requirements for the area as long as all terms
and milestones of the Compact are being met, including submission of the early action
SIP revision by 2004.
Page 7
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EPA will provide technical assistance to EPD and the Augusta area in the development
of the early action plan.
.'"
· EPA will move quickly to review and approve completed plans by no later than
September 30, 2005.
· Provided that the area has progressed from nonattainment to attainment status by
December 31,2007, EPA will move expeditiously to designate the area as attainment
and impose no additional requirements.
· If at any time the area does not meet all the terms of this compact, including meeting
agreed-upon milestones, then it will forfeit its participation and be designated (or re-
designated if necessary) according to EPA's 8-hour ozone implementation guidelines.
EPA will offer such an area no delays, exemptions or other favorable treatment because
of its previous participation in this program. .
· If the Augusta area violates the standard after December 31,2007, the area will be
designated nonattainment. EPD will then submit a revised attainment demonstration
SIP revision according to the CAA and EPA's 8-hour implementation rule, unless the 8-
hour implementation schedule requires SIPs from 8-hour nonattainment areas before
December 31 ,2008. In that event, a revised attainment demonstration SIP revision for
the participating area will be due as soon as possible but no later than December 31,
2008. In no event will EPA extend the attainment date for the area beyond that required
by the CAA and/or EPA's 8-hour implementation rule.
· The region will not be allowed to renew this EAC after December 31 , 2007; or to initiate
a new compact if it has previously forfeited its participation.
2.3 Signatures
~~~~.
Mr. Jimmy P , Jr.
Administrator, U.S. Environmental Protection Agency, Region 4
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Date
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Mr. Harold Reheis
Director, Georgia Environmental Protection Division
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The Honorable Bob Young
Mayor, City of Augusta
Page 8
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BOARD OF COMMISSIONERS
December 20, 2002
United States Environmental Protection Agency
Atlanta, Georgia
Georgia Environmental Protection Division
Department of Natural Resources
Atlanta, Georgia
Gentlemen:
- A request was made of Columbia County to join in "Georgia's Eight Hour Ozone
Early Action Compact for Augusta Area" (the "Early Action Compact") along with
Richmond County and yourselves. While Columbia County has chosen not to be a
signatory to the EAC, it is vitally interested in clean high quality air. The purpose of this
letter is to express to you Columbia County's support for activities to improve the quality
of the air in the Greater Augusta Area of which Columbia County is a part.
Columbia County supports the action provided for in the Early Action Compact
because it will obtain cleaner air sooner, helping the entire region. For the reasons stated
above, Columbia County will continue to be an active participant in the Fall Line Air
Quality Work and will continue to work with Richmond County on the development of
an early action plan. We understand that Georgia EPD has recommended Richmond
County only to be designated as an Eight Hour Ozone non-attainment area, and we
support that recommendation. Columbia County feels strongly that it should not be
designated as a non-attainment area. By continuing to participate in the local planning
process, Columbia County is not suggesting in any way that Columbia County should be
included in the boundaries of any non-attainment area that is designated for the Augusta
area.
Georgia Tech and the Columbia County Engineering and Environmental Services
Division have jointly operated an air quality monitoring station since early 2001.
Columbia County has provided a number of in-kind services to assist in that project,
including the construction of a new shelter to house the equipment. The Columbia
County staff is readily available to monitor the equipment, conduct various tests, notify
Georgia tech personnel of on-sight problems and provide lightning protection and other
security measures at the facility. Columbia County has been a cooperative partner in the
P.O. Box 498 · Evans, GA 30809 0 Phone: (706) 868-3379 0 Fax: (706) 868-3348
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BOARD OF COMMISSIONERS
Page 2
project since its inception. The County will continue to assist Georgia Tech in
monitoring this project.
We trust that this adequately explains Columbia County's position in support of
action to improve air quality even though it has not joined in the Early Action Compact.
If you have any questions concerning this, please contact Mr. Steve Szablewski, the .
Columbia County Administrator.
Very truly yours,
Columbia County, Georgia
P.O. Box 498 · Evans, GA 30809 · Phone: (706) 868-3379 · Fax: (706) 868-3348