The Model Clearinghouse is a focal point for interpretation of modeling guidance in specific regulatory applications. The Model Clearinghouse is the mechanism by which an EPA Regional Office can obtain EPA Headquarters concurrence on resolving implementation issues and non-regulatory applications related to regulatory air quality modeling. Archival of Model Clearinghouse decisions are located in the Model Clearinghouse Information Storage and Retrieval System (MCHISRS). In addition to MCHISRS, EPA issues formal "Clarification Memos" for general issues related to permit modeling under Appendix W, as appropriate.
The statutory authority of the Model Clearinghouse is provided within 40 CFR, Part 51, Appendix W, Section 3.3(b). This section states that "The Regional Office should always be consulted for information and guidance concerning modeling methods and interpretations of modeling guidance, and to ensure that the air quality model user has available the latest most up-to-date policy and procedures. As appropriate, the Regional Office may request assistance from the Model Clearinghouse after an initial evaluation and decision has been reached concerning the application of a model, analytical technique or data base in a particular regulatory action."
Public access to policy-related memoranda are available from the "Title V, NSR/PSD Policy and Guidance Database", courtesy of EPA Region 7. This policy-oriented database provides an excellent compliment to the technical-oriented information within MCHISRS.
Model Clearinghouse Process
The need for a Model Clearinghouse action begins when there is an unresolved regulatory modeling issue that arises at a State or local office in a particular permitting action that is then forwarded to the Regional Office (RO) for resolution. After the State/local agency contacts the RO, the Model Clearinghouse (MC) process is initiated to resolve the issue and involves the following steps:
1. Regional Office makes a determination that the issue is a precedent-setting decision or may have national implications.
2. Regional Office submits a formal memorandum (on RO letterhead) detailing issue and proposed solution for concurrence to MC Director (via email), along with supporting technical and related documentation.
3. MC facilitates review across the Regional Office and EPA Headquarters to determine appropriateness of proposed solution.
4. After review, MC generates a formal memorandum of findings (on EPA letterhead) and submits to Regional Office.
5. MC Director sends formal MC memo via email to all ROs and archives in MCHISRS for public access and reference.
Questions about the Model Clearinghouse should be provided to George Bridgers, the MC Director.
Model Clearinghouse Memorandum Requirements
The following elements are required as part of a MC request from the ROs:
1. Background and explanation of issue
2. Technical proposal of solution
3. Defensibility of solution, including Appendix W or technical evaluation references
4. Language which isolates this solution to this particular application
An example of such a MC request is provided HERE.
The formal MC memorandum from EPA Headquarters will contain the following elements:
1. Brief acknowledgement of receipt of Model Clearinghouse request
2. Background and explanation of issue
3. Overview of proposed solution
4. MC concurrence of proposal solution, with technically defensible rationale
5. Language indicating that this solution is for the specific application; similar applications must be approved on a case-by-case basis
An example of such a MC action memo is provided HERE.
Model Clearinghouse Annual Reports
The Model Clearinghouse will also issue an annual report summarizing the actions and highlight common issues for further review and discussion across the modeling community. As precedent and consensus builds over time, then EPA Headquarters may develop appropriate guidance on the use of models in regulatory applications. The following are past Annual Clearinghouse Reports.
Annual Clearinghouse Reports
ACR-1 1989 FY89 Model C/H Report
ACR-2 1990 FY90 Model C/H Report
ACR-3 1991 FY91 Model C/H Report
ACR-4 1992 FY92 Model C/H Report
ACR-5 1993 FY93 Model C/H Report
ACR-6 1994 FY94 Model C/H Report
ACR-7 1995 FY95 Model C/H Report (17K,ZIP)
ACR-8 1996 FY96 Model C/H Report (20K,ZIP)
ACR-9 1997 FY97 Model C/H Report (27K,ZIP)