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Appendix A PROTOCOL FOR EARLY ACTION COMPACTS DESIGNED TO ACHIEVE AND MA1NTAIN THE 8-HoUR OZONE STANDARD Purpose of Compact Early voluntary 8-hour air quality plans can be developed through a Compact between Local, State and the Environmental Protection Agency (EP A) officials for areas that are in attainment (including no monitored violations) of the I-hour ozone standard but approach or monitor exceedances ofthe 8-hour standard. These early action plans will include all necessary elements of a comprehensive air quality plan, but will be tailored to local needs and driven by local decisions. The Early Action Compact is designed to develop and implement control strategies, account for growth, and achieve and maintain the 8- hour ozone standard. This approach will offer a more expeditious time line for achieving emission reductions than the EPA's expected 8-hour implementation mlemaking, while providing "fail-safe" provisions for the area to revert to the traditional State Implementation Plan (SIP) process if speciiic milestones are not met. Early Action Compacts should complement any existing Ozone Flex Agreements. The principles of the tri- party Early Action Compact to be executed by Local, State and the EP A officials are: Early planning, implementation, and emission reductions leading to expeditious attainment and maintenance of the 8- hour ozone standard; Local control of the measures to be employed, with broad based public input; State support to ensure technical integrity of the early action plan; Formal incorporation of the early action plan into the SIP; Deferral of the effective date of non attainment designation and related requirements so long as all Compact terms and milestones are met; and Safeguards to return areas to traditional SIP requirements should Compact terms and/or milestones be unfulfilled, with appropriate credit given for emission reduction measures implemented. Compact Requirements The Compact will address the following components: A. Milestones and Reporting o In order to facilitate self-evaluation and communication with the EP A, TNRCC and stakeholders, the Early Action Compact must include clearly measurable milestones for the development and implementation of the plan. Local areas will assess and report their progress against milestones in a regular, public process, at least every six months. NIilestones will include, at a minimum: Completion of emissions inventories and modeling; Adoption of control strategies that demonstrate attainment; Completion and adoption of the early action SIP revision;