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Christopher W. Hayes

Christopher W. Hayes, An Evaluation of Tennessee’s Early Action Compacts to Achieve Compliance With New Ozone Standards: A Dynamic Analysis of Reduction Strategies to Decrease Tropospheric Ozone Formation
Faculty Chair:  Dr. John Tucker

On June 19, 2002, the U.S Environmental Protection Agency (EPA) endorsed the Early Action Compact (EAC), a mechanism designed to aid potential nonattainment areas throughout the United States to comply with the new 8-hour National Ambient Air Quality Standards (NAAQS) set for ground-level ozone. Under the Compact, local areas will have the flexibility to design and implement ozone reduction control measures specific to the area's needs. The EAC will also defer nonattainment designation from April 15, 2004 to a date no later than December 31, 2007. A nonattainment designation carries with it negative repercussions that affect the local economy and inhibit growth.

Five major Tennessee metropolitan areas have chosen to enter into the EAC with state officials and the EPA. An examination of the EAC's various components was performed at both the local and regional level. Seven potential reduction control strategies proposed by the selected five metropolitan areas were chosen for comparison. A comparative analysis was performed based on cost effectiveness, feasibility of implementation, effectiveness in reducing ozone precursor compounds, and identification of population groups targeted by each strategy.

Results indicate that each strategy has the potential to offer considerable benefits depending on the local area's needs, capabilities, and primary emission sources of ozone precursor compounds. Due to variability in the types of sources that emit ozone precursor compounds, fluctuations in local meteorological conditions, and scientific uncertainty associated with ozone formation, it is suggested that multiple reduction strategies be implemented to reduce ground-level ozone formation. Thus far, data reporting protocols and reduction model estimates have been inconsistent and highly variable, placing doubt on the effectiveness of any single control strategy.

The EPA needs to establish a uniform system of data reporting to allow actual source sub-category emissions to be compared to past modeling projections. A uniform system would enable researchers to determine whether a single reduction strategy is capable of reducing an area's actual ozone concentration to a level predicted by future modeling techniques. Officials can then better protect local communities from the negative health effects associated with ozone exposure, as required by NAAQS. Through compromise, the EAC allows local areas to avoid economic and growth restrictions while allowing local stakeholders the ability to design and implement feasible reduction strategies. The EAC is a beneficial tool that facilitates this compromise between an immediate nonattainment designation and local area compliance with federal ground-level ozone NAAQS. Ultimate success of the EAC, however, will not be determined until December 2007, at which time all compact areas are scheduled to be in compliance with the 8-hour NAAQS set for ground-level ozone. If this goal is not achieved, the EAC has merely prolonged the implementation of federal control measures and delayed the enforcement of corrective actions, including Transportation Conformity and New Source Review.