If an area implements controls under an MOA or Compact, will those reductions be able to be counted as control measures under a subsequent attainment SIP, if one is required?
RESPONSE: The 8-hour “Compact” is the Memorandum of Agreement. Reductions from any control measures implemented under the 8-hour Early Action Compact and approved into the SIP can be credited towards a subsequent attainment SIP, if one is required (see memorandum from John S. Seitz, Director, Office of Air Quality Planning and Standards, to Gregg Cooke, Regional Administrator, Region VI, dated January 29, 2001, “Near-Term Discretionary Emission Reductions for Ozone NAAQS — Clarification.”) Top of page Early Reductions for PM-2.5 Standard 13. What are EPA’s thoughts about how an 8-hour Ozone Early Action Compact would relate to States’ efforts to meet the fine particulate standard? There may be overlap in control strategies to address the two pollutants. Is EPA considering a similar program for areas likely to be nonattainment for PM-2.5? What benefits exist for communities opting into the Ozone Flex Program if the possibility for designation as nonattainment for PM-2.5 is likely? RESP
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