Gilbert Stroud Merritt

“ Models can be used to predict pollution from a single source, after factoring in an assumption about the amount of background pollution, or they can be used to predict the spread of pollution from each of a number of sources. The model must be supplied with a "data base" consisting of information about variables such as the capacity of the power plants, the sulfur content of the fuel used, the height and diameter of the smoke stacks, the geographical characteristics of the surrounding terrain, and at least one year's monitored weather conditions. ”

“ In 1978, the utility company requested that EPA relax the emissions standard on the Eastlake and Avon Lake plants. In support of its request the company submitted studies showing that the Urban RAM model's predictions of sulfur dioxide concentrations in the air were significantly higher than actual empirically tested or monitored concentrations. These "validation studies" convinced EPA that the Urban RAM model overpredicted sulfur dioxide concentrations and that that model was not an appropriate tool for setting emissions limits at the plants. ”

“ In order to bring into compliance a region of dirty air, a so-called "nonattainment area," the plan must establish a maximum emission level for a pollutant by individual large-scale producers. The maximum level is called an "emissions limit" and a large-scale producer a "major stationary source."
The Cleveland, Ohio region is a nonattainment area for sulfur dioxide; the region includes areas where the concentration of sulfur dioxide in the ambient air exceeds the national standard. ”