The comments raise the following issues:

• EPA cannot approve a reasonable further progress (“RFP”) plan without an approved attainment demonstration.
• The plan substitutes nitrogen oxide (“NOx”) emission reductions for volatile organic compound (“VOC”) emission reductions but does not demonstrate that this results in equivalent reductions in ozone concentrations.
• EPA cannot approve already-implemented measures as contingency measures.
• EPA cannot approve the motor vehicle emission budgets (“MVEBs”) without approving an RFP plan.