ductions are achieved, and ambient monitoring to establish that the program does not inadvertently result in geographic and temporal disparities in results.

  • Reduce emissions from existing facilities and vehicles, to the extent practical by promulgating standards for sources regardless of their age, status, or fuel. Older stationary sources and mobile nonroad sources are of particular concern.

  • Address multistate transport problems by providing EPA with greater statutory responsibility to assess multistate air quality issues on an ongoing basis and the regulatory authority to deal with them in a regional context. Constitutionally, interstate environmental rules and regulations must be based on federal authority, but EPA has not been given sufficient tools under the CAA to address the multistate aspects of most air quality problems.

Recommendation Three

Transform the SIP process.

Implementation planning at the state and local levels should be changed to place greater emphasis on performance and results and to facilitate development of multipollutant strategies. Critical actions include

  • Transform the SIP into an AQM plan. Each state should be required to prepare an air quality management plan (AQMP) that integrates the relevant air quality measures and activities into a single, internally consistent plan. An evolution of the SIP process to an AQMP approach should involve the following:

    • Given the similarity of sources, precursors, and control strategies, the AQMP should encompass all criteria pollutants in an integrated multipollutant plan.

    • EPA should identify key hazardous air pollutants that have diverse sources or substantial public health impacts. These pollutants should be included in an integrated multipollutant control strategy and addressed in each state’s AQMP.

    • The scope of the AQMP should explicitly identify and propose control strategies for air pollution hot spots and situations where disadvantaged groups may be disproportionately exposed and should provide incentives to implement the strategies.

    • Given the current statutory requirements and rules associated with the SIP, it might be necessary to implement this recommendation in stages and provide incentives to facilitate the transition to an AQMP approach.



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