Non-Attainment Area Standards

What are Non-Attainment Area Standards?

Non-Attainment area standards apply to designated geographical regions by the US Environmental Protection Agency (EPA) that fail to meet the National Ambient Air Quality Standards (NAQQS). Under the Clean Air Act, the six pollutant criteria are regulated:

1. 1. Sulfur dioxide (SO₂)
   2. Particulate matter (PM 10 and PM 2.5)
   3. Carbon monoxide (CO)
   4. Ozone (O₃)
   5. Nitrogen dioxide (NO₂)
   6. Lead (Pb)

Each pollutant has two types of standards:

• • Primary standards – Protecting public health, with emphasis on vulnerable or sensitive groups (e.g. children, elderly, people with respiratory illnesses, etc.)
  • Secondary standards – Protecting the public welfare (e.g. environment, infrastructure, and agriculture)

For the most up-to-date non-attainment area designations by state and pollutant, refer to the EPA’s official Green Book.

Regulatory Requirements in Non-Attainment Areas

Facilities located in non-attainment areas must comply with stricter federal and state requirements aimed at reducing emissions and achieving the NAAQS. Key elements include:

1. 1. State Implementation Plans (SIPs) – States are mandated by the Clean Air Act (CAA) to develop SIPs that outline how NAAQS will be implemented, maintained, and enforced. For non-attainment areas, SIPs must include provisions for reducing air pollution and achieving attainment.
      1. Note: Facilities do not develop SIPs but must comply with all applicable requirements contained within them.
   2. Emissions Inventories – Nonattainment area SIPs must include a comprehensive emissions inventory, as required under CAA Section 172(c)(3), which quantifies pollutant emissions and evaluates progress toward attaining the NAAQS.
   3. New Source Review (NSR) – The federal preconstruction program applies to new major sources or those undergoing major modifications at existing sources. In non-attainment areas, the Non-Attainment New Source Review (NNSR) Program requires:
      1. Installation of Lowest Achievable Emission Rate (LAER) technology
      2. Securing emission offsets to compensate for new or increased emissions
      3. Opportunities for public review and involvement
   4. Control Measures – Non-attainment SIPs often mandate additional emission reduction strategies, such as Reasonably Available Control Measures, Reasonably Available Control Technology, etc.

How SEC Supports Facilities

Our SEC team supports facilities in non-attainment areas by:

• • Helping determine facility’s applicability status
  • Preparing and managing NNSR and Title V Operating Permit applications
  • Conducting LAER analyses and evaluating control technology options
  • Designing offset strategies and securing emission credits
  • Providing long-term compliance support