# Presentation: 924001

## Reasonable Further Progress Policyand Mid-Course Reviews

- John Summerhays
- EPA Region 5
- June 20, 2007

## RFP Policy

- Applicability of planning requirement
- “Generally linear emission reductions”
- Inventory area
- Pollutants included

## Who Must Do an RFP Plan?

- Area attaining by 2010:
- Congratulations!  No additional plan needed
- Area needing extension beyond 2010:
- Must show “generally linear progress” from base year to attainment year
- Purpose:  Steady progress in implementing controls

## Dates

- RFP plan is due in April 2008
- RFP plan must have controls early enough to project adequate interim progress by the “milestone dates”
- Milestone dates:
- If attaining by 2010:  None
- If attainment date is 2011 - 2013:  2009
- If attainment date is 2014 or 2015:  2009, 2012

## Generally Linear Reductions

- Based on emissions
- Example 1:  Base year: 2002, Clean air starts 2012:
- About 7/10 of 2012 emission reductions must be achieved by 2009
- Example 2:  Base year:  2002, Clean air starts 2014:
- About 7/12 of 2014 emission reductions by 2009
- About 10/12 of 2014 emission reductions by 2012

## Generally Linear Reductions (cont’d)

- Two options:
- Option 1: all regulated pollutants reduced in generally linear faction
- Option 2: Some reductions sooner, others later, to obtain same air quality improvement by milestone date
- Reflects all controls (federal and state) and all other influences on emissions
- No backloading of emission controls

## Example Calculation

- Suppose Kleenare City will have clean air in 2012 as a result of 20% reduction of SO2, 20% reduction of NOx, and 10% reduction of organic particles (direct PM)
- Reductions from 2002 to 2009 must be about 7/10 of reductions from 2012
- Thus, “generally linear reductions” would be:   SO2: 14%; NOx: 14%; organic particles: 7%
- Alternatively, other combinations with same air quality benefit (modeling not required)

## Area to be Included

- Nonattainment area, plus:
- Optionally, for SO2 & NOx, sources to 200 km
- Also, optionally, for VOC, ammonia, in special cases
- For directly emitted PM, nonattainment area only
- State must provide justification for any area outside the nonattainment area

## Area to be Included(continued)

- Inventories must include all sources in applicable area
- Unlike ozone policy
- Area cannot go outside state or states in nonattainment area
- For transportation conformity purposes, states must submit a budget that includes on-road emissions only from the nonattainment area

## Pollutants

- Include all regulated pollutants
- Must include pollutants controlled in attainment plan
- Therefore we expect RFP plans to include direct PM2.5, SO2, and NOx
- EPA requires a proper fraction of the plan’s controls to be implemented by 2009 and in some cases 2012

## Multi-state Areas

- In multi-state areas, RFP must be achieved on a multi-state basis
- Must include at least entire nonattainment area
- All states must demonstrate RFP on the basis of a common multi-state inventory

## Mid-course Review

- Applicability:
- Areas needing attainment date extension to 2014 or 2015
- Due Date:
- April 2011
- Purpose:
- Assure progress toward attainment in problem areas using updated information
- In lieu of formal milestone review

## Elements of Midcourse Review

- Review of emission reductions
- Review of air quality progress
- Updated attainment demonstration
- Any new or revised controls needed to attain by the planned attainment date