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Mandatory Measures in Subpart 2

Mandatory Measures in Subpart 2.

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Mandatory Measures in Subpart 2

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  1. Mandatory Measures in Subpart 2 Issue: Should prescribed requirements of Subpart 2 apply in all 8-hour nonattainment areas classified under subpart 2, or is there flexibility to apply equivalent measures, or drop some requirements altogether if in certain narrowly defined circumstances they are determined to be inappropriate?

  2. Subpart 2 Mandatory Requirements • Include e.g., NSR size cutpoints, specific ROP requirements (including 15% VOC reduction for moderate areas), size cutpoints for RACT, NOx RACT, Stage II vapor recovery, etc.)

  3. Options • Option 1.Assume no changes can be made to the statutory requirements of subpart 2. • Option 2.Identify (if possible) a legal justification to allow areas covered under subpart 2 to substitute measures that will provide equivalent ozone reductions.

  4. Options (cont’d) • Option 3. Identify (if possible) a legal justification to allow EPA to determine on a case-by-case basis which of the mandatory control measures under subpart 2 can be waived by the State in preparation of its attainment demonstration. • Option 4. Review each of the individual control requirements in subpart 2 to determine what, if any flexibility may be provided for that specific requirement

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