As part of the  Federal Clean Air Act Amendments (CAAA) of 1977, states and local governments were required to develop State Implementation Plan (SIP) revisions for all areas that were not attaining the NAAQS. Subsequent to these amendments, the EPA developed a list of "nonattainment" areas on a pollutant-by-pollutant basis. The list, which constituted formal notification, was published in the September 12, 1978, Federal Register.

The counties of Broward, Miami-Dade and Palm Beach were among those listed as being non-attainment for photochemical oxidants; i.e., ozone. The CAAA of 1977 also set specific steps for attainment and deadline dates that had to be met by the designated areas.

Although designated areas across the country attempted to meet the NAAQS by their respective deadlines, the realization surfaced that the target deadlines specified were unattainable as originally envisioned. In addition, it appeared that the CAAA of 1977 did not provide the most effective means to handle the problems associated with ozone nonattainment areas. The Clean Air Act Amendments required modification to facilitate reaching the goals in a more expeditious manner.