• Reform the planning and implementation process by

    • Encouraging regulatory agencies to concentrate their resources on tracking and assessing the performance of the strategies that have been implemented rather than on preparing detailed documents to justify the effectiveness of strategies in advance of their implementation.

    • Carrying out a formal and periodic process of review and reanalysis of the AQMP to identify and implement revisions to the plan when progress toward attainment of standards falls below expectations or when conditions change sufficiently to invalidate the underlying assumptions of the plan. Given the large contributions of federal and multistate measures to the success of any plan, it is essential that this review process be collaborative and include all relevant federal and state agencies.

    • Encouraging the development and testing of innovative strategies and technologies by not requiring predetermined and agreed-upon benefits for every strategy but periodically evaluating their effectiveness.

    • Retaining the federal requirement for conformity between air quality planning and transportation planning. Conformity could be improved by mandating greater consistency between the data, models, and time frames used in air quality and transportation plans.

    • Continuing to require that states implement agreed upon strategies, ensure private-sector compliance, and are held accountable for failure to meet the AQMP commitments through federally mandated sanctions.

Recommendation Four

Develop an integrated program for criteria pollutants and hazardous air pollutants.

The time has come for the nation’s AQM system to begin the transition toward an integrated, multipollutant approach that targets the most significant exposures and risks. The critical actions include

  • Develop a system to set priorities for hazardous air pollutants by expanding the approach embodied in EPA’s urban air toxics program. As proposed in Recommendation Three, a few hazardous air pollutants, because of their diverse sources, ubiquitous presence in the atmosphere, or exceptionally high risk to human health and welfare, might warrant treatment similar to criteria pollutants and be included in AQMPs.

  • Institute a dynamic review of pollutant classification, and reclassify and revise priorities for criteria pollutants and hazardous air pollutants accordingly.



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