General Conformity Training Module 3.6: Proactive Role for Federal Agencies

The conformity process works best when a federal agency coordinates with the State air agency, Tribal government, or local air quality agency to include in the applicable implementation plan budget the future projected emissions from sources already existing within a nonattainment or maintenance area and the possible additional projected emissions that may be caused by approval or implementation of the agency's future Federal actions. The federal agencies' environmental compliance officials need to know the process for developing an implementation plan for application within areas that could be affected by possible new Federal actions, which would also be subject to General Conformity.

A federal agency’s ability to coordinate and consult effectively with the State, Tribe, or local air quality agencies is based on the agency's knowledge of its own future foreseeable sources of emissions. State air agencies, Tribal governments, and local air agencies can more effectively accommodate future projected emissions within their nonattainment and maintenance areas if the agency provides information about the possible future foreseeable emissions sources while the implementation plan is still under development and before it is finalized.

A federal agency's development of a comprehensive inventory of emissions from existing sources within a nonattainment or maintenance area, along with a projection of future emissions from its planned future Federal actions, provides the State, Tribe, or local air agency with the information they need to effectively manage emissions from all sources accounted for in the nonattainment or maintenance area's implementation plan. An inventory of existing and future projected emissions, and their sources, can help identify possible mitigation measures or offsets, including future Early Emissions Reduction Credits (EERCs) that can be used or developed for future General Conformity evaluations.