could be amended to provide for additional emission fees when states or regions fail to achieve rates of progress set forth in their regional or state implementation plans.

Ensuring a Successful Transition to AQMP

In designing a more comprehensive AQM system in stages, several factors should be kept in mind:

  • As noted in Recommendation One, a substantial enhancement in the resources, methods, and infrastructure used to track progress in terms of emissions and air quality will be needed to maximize the utility of the proposed review process.

  • The development of any plan, and especially a new kind of plan, can take a long time. Special care must be taken to ensure that even as this transition occurs, implementation of recognized and effective control strategies must continue so that the planning does not become a barrier to progress on AQM.

Recommendation Four

Develop an integrated program for criteria pollutants and HAPs.


The CAA uses two contrasting classification schemes for air pollutants: criteria pollutants and HAPs. As discussed in Chapter 2, there is a difference in how these two classes are defined: criteria pollutants, and not HAPs, are defined as those whose presence “in the ambient air results from numerous or diverse mobile or stationary sources.” Each is managed through a different regulatory framework: criteria pollutants through the setting of NAAQS and through the SIP process and HAPs through the promulgation of MACTs followed by a program to reduce residual risk and through separate efforts to address mobile and area sources. In the past, this two-pronged approach towards criteria pollutants and HAPs has provided a useful framework for addressing and mitigating some of the nation’s most pressing air quality problems. However, as the air quality problems of the coming decades are considered, aspects of this approach appear to be problematic.

First, the system, as currently administered, has resulted in disparate allocation of attention and resources to the different classes:

  • Criteria pollutants have received the major share of the management and enforcement priority and resources, as well as the attention directed

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