DEVAL L. PATRICK

Governor TIMOTHY P. MURRAY Lieutenant Governor

October 23, 2009 Mr . David Conroy U .S . Environmental Protection Agency One Congress Street Boston, MA 02114-2023 Dear Mr . Conroy : IAN A . BOWLES Secretary LAURIE BURT Commissioner

In January 2008, the Massachusetts Department of Environmental Protection (MassDEP) submitted to your office the final Massachusetts State Implementation Plan to Demonstrate Attainment ofthe National Ambient Air Quality Standard (NAAQS)for Ozone (the Ozone SIP) . We are submitting technical revisions to that submittal to incorporate minor changes in base year and projection year inventories . The Ozone SIP included a Reasonable Further Progress (RFP) demonstration, which showed that from2002 through 2008, emissions of ozone precursors were projected to decrease in Massachusetts' two nonattainment areas by a significantly greater percentage than the 15% reduction required to demonstrate RFP in accordance with EPA's rules and guidance . Your staff brought to our attention that our RFP analysis did not take into account the emission reduction credits (ERCs) issued to stationary sources pursuant to MassDEP regulation 310 CMR 7 .00, Appendix B - Emission Banking, Trading andAveraging . In response, we have made technical revisions to the 2002 base year and future year projections to account for unused ERCs in those years . The inclusion of ERCs in the RFP analysis results in only minor changes to the 2008 emissions estimates in the original RFP submittal .

This information is available in alternate format

. Call Donald M . Gomes, ADA Coordinator at 617-556-1057 . TDD# 1-866-539-7622 or 1-617-574-6868. COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON, MA 02108 617-292-5500

MassDEP on the World Wide Web : http //www

mass .gov/dep 1:"a Printed on Recycled PaperTechnical revisions to incorporate the inclusion of ERCs in the 2002 base year and projected

inventories have been made to the following sections of the Ozone SIP, which are enclosed : " Section 2: Emissions Inventories - Table El-1 and Figures 2.1 and 2 .2 " Section 4: RFP Demonstration - Tables RFP 1, 2 and 3. " New Appendix 4c - Point Source ERCs If you have any questions concerning this matter please contact Ken Santlal on my staff.

Barbara Kwetz, Dire Planning and Evaluation Divisi Bureau of Waste Prevention EnclosuresSECTION 2 EMISSIONS INVENTORIES OCTOBER 2009 REVISION 2.1 Purpose of Section The CAAand EPA regulations require that states compile estimates ofcertain air pollutants emitted fromsources within their borders. States with moderate or above ozone nonattainment areas must prepare emission inventories of VOCs, NOx and CO every three years and must include the latest inventory ofthese pollutants in their attainment demonstration SIP . The Massachusetts 2002 Base Year Emissions Inventory - September 2007 (MA 2002 Base Year Inventory, Appendix 2A to this document) satisfies the inventory requirements for the EMAand WMAozone nonattainment areas. This Section provides a brief summary of the Mass 2002 Base Year Inventory results. For the purposes of showing the overall downward trend of emissions in Massachusetts, this Section also provides a summary of the 2008 projections developed to demonstrate RFP (See Section 4, Reasonable Further Progress), the 2009 projections used in the ozone attainment modeling (See Section 5, Attainment Demonstration) and summary of projected emissions in 2012. 2.2 2002 Base Year Inventory Pollutants The MA 2002 Base Year Inventory estimates in-state emissions ofthe following pollutants as of 2002: VOCs, NOx, CO, particulate matter (PM1), ammonia (NH3) and sulfur dioxide (S02) . In addition to meeting the inventory requirements for ozone nonattainment areas, the inventory meets the requirements of EPA's 2002 Consolidated Emissions Reporting Rule (CERR) . The CERR requires that, irrespective of a state's NAAQS attainment status, every three years it must develop and update a single, statewide annual inventory of the following pollutants: VOCs, NOx, CO, PM, NH3 and S02

. The MA 2002 Base Year Inventory estimates annual emissions of pollutants from

all source sectors in the state, as required by the CERR . Because high ozone concentrations are generally associated with warmer weather and emissions may vary seasonally, the inventory also includes emissions estimates of VOCs, NOx, and COon a ton per summer day (TPSD) basis. AJune 2006 version ofthe MA 2002 Base Year Inventory was available for informal public reviewon MassDEP's website from July 2006 through October 2007. The September 2007 version (Appendix 2A) makes minor revisions to the Introduction of the June 2006 version, (Section 1), and includes methodology changes for Section 3.3-2, Surface Cleaning/Degreasing and Section 3.3-7, Cutback and Emulsified Asphalt Paving . It also adds a section estimating emissions from

Adhesives and Sealants. The complete MA 2002 Base Year Inventory - September 1 The inventory includes estimates of both PM1o and PM2.5. PM,o refers to particles equal to or smaller than 10 micrometers in diameter. PMZ_5 refers to particles equal to or smaller than 2.5 micrometers in diameter. Final Section 2 - Page 1 of 5 - October 2009 Revision2007 is part ofthis Massachusetts 8-Hour Ozone Attainment Demonstration SIP ; it is available on MassDEP's web site at : http://mass ~,,ov/dep/air/priorities/aqdata.htm . It contains extensive narrative explaining the methodology for development of the inventory and the extensive data files supporting the emission estimates . 2.3 2008 and 2009 Projected Inventories In addition to calculating emissions in the base year, nonattainment areas must also estimate emissions in future milestone years . For purposes of demonstrating RFP towards attainment, areas must project emissions for the RFP milestone year - 2008 for EMA and WMA . EPA's Phase 2 Rule established 2002 as the base year for demonstrating compliance with the 8-hour ozone standard RFP requirements . For purposes of RFP, areas may take credit for reductions that occur subsequent to 2002, but before their RFP milestone year. (The methodology for developing the 2008 projections is discussed in Section 4, Reasonable Further Progress) To demonstrate attainment, areas must project emissions in the attainment year for use in their modeled attainment demonstration . For attainment demonstration purposes, EPA recommended, but did not require, that states use 2002 as the baseline year for their attainment demonstration modeling. MassDEP is using 2002 as its base year for the 2009 regional attainment modeling, as discussed in Section 5, Attainment Demonstration . (The methodology for developing the 2009 projections is also discussed in Section 5 .) 2.4 2012 Projected Inventory Massachusetts is not required to estimate emissions in years subsequent to its 2009 attainment year for 8-hour ozone purposes. However, to comply with the requirements of an EPA rule related to Regional Haze,

2, the Mid-Atlantic/Northeast Visibility Union (MANE-VU)3 developed emissions estimates for 2012 for all states in the MANE-VU region, including Massachusetts. Because these 2012 estimates4 are available, MassDEP has included themin Table 2.1 below in order to demonstrate the continued downward trend in Massachusetts' emissions. 2.5 Emissions Inventory Trends Table El -1 provides the statewide ozone season 2002 MA Base Year Inventory emissions ofVOC and NOx by source sector and the projected emissions for each sector in 2008, 2009 and 2012. Figures 2-1 and 2-2 illustrate the reductions ofVOCs and NOx that are projected to take place in 2 EPA's Regional Haze Rule requires that states address regional haze and visibility impairment in Class 1 Federal areas (certain parks and wilderness areas) . This is a separate EPA rule unrelated to ozone attainment. 3 The Mid-Atlantic and Northeastern states, tribes, and federal agencies formed MANE-VU to coordinate regional haze planning activities for the region. 4 Mid-Atlantic Regional Air Management Association, Development ofEmission Projections for 2009, 2012 and 2018for NonEGUPoint, Area, and Nonroad Sources in the MANE-VURegion, Final Report, February 2007. www

marama orF-,/visibility/Inventory%20Summary/FutureEmissionslnventory .htm Final Section 2 - Page 2 of 5 - October 2009 RevisionMassachusetts by the 2008 milestone year for RFP, by the 2009 attainment demonstration milestone

year, and by 2012. Note that because ofdifferent methods use to project emissions fromthe various sectors in the three projection years, estimates are only roughly comparable. As noted above, the methods used to develop the 2008 and 2009 projections are discussed in Sections 4 and 5. Table EI -1 MA 2002 Emissions and Projections for 2008,2009* and 2012* 2002 Voc Voc Voc STATEWIDE Base 2008 2009 2012 2002 Base NOx 2008 NOx 2009 NOx 2012 Year Tons per VOC Proiected Proiected Proiected Year NOx Proiected Proiected Proiected summer day Point EGU* 1 .5 1 .4 1 .4 1 .5 82.8 37 .3 56.0 56.0 Point non-EGU 14.5 15.0 15.2 16.5 46.8 48.4 47 .7 49.5 Total Point 16.0 16.4 16.6 18.0 129.6 85.7 103.7 105.5 Area 327.6 332 .4 277 .9 268.3 39.1 44.0 44.5 45.3 On-Road"* 151 .9 80.1 74.2 56.2 453.1 222.6 202.7 132.4 Off-Road 223.8 178.9 171 .6 159.8 _ 144.6 128.4 124.3 105.8 Unadiusted TOTAL 719 .3 607.8 540 .3 502.2 - 766 .3 480

.7 475.2 389 .0 October 2009 Revision : Add Unused Banked ERCs*** 2 .5 2 .2 2.2 2.2 31 .4 26.7 26.7 26.7 October 2009 Revision Adjusted TOTAL 721 .8 610.0 542.5 504 .4 797.7 507 .4 501 .9 415.7

File inv2002-sip-rfp / MA-RFP-base-targets-proj-revised-Oct-21 /2009 * As discussed in Section 5, Attainment Demonstration, 2009 projections used in attainment modeling are based on: 1) Appendix 5L - Development ofEmission Projectionsfor NonEGU Point, Area and NonroadSources in the MANE-VURegion, prepared by MACTEC Federal Programs, Inc., February 2007; 2) Mobile Source emissions developed by NESCAUM, with Mobile 6 .2 inputs provided by the states ; and 3) Integrated Planning Model (IPM) runs for EGU emissions (see List of References - Reference #8 re: IPM runs) . 2012 EGU projections are also based on IPM runs . IPM projections are for the May - September ozone season. MassDEP has derived a tons per summer day estimate from the IPM ozone season estimate (ozone season emissions/153 days .) ** On-Road Mobile projections are based on the estimates developed for the 2008 and 2009 Conformity Budgets (described in Section 9, Transportation Conformity) . For 2012, MassDEP extrapolated fromthe 2009 projections. ***Unused point source banked emission reduction credits (ERCs) were added to the 2002 base year emissions . The remaining unused banked ERC values were added to the 2008, 2009 and 2012 projections. By 2008, MassDEP estimates that statewide emissions of VOCs during the summer ozone season (May -September) will decrease from2002 levels by 16% and of NOx by 36%

. As discussed in Section 4, Reasonable Further Progress, EMAand WMA are able to demonstrate that reductions of VOCand NOx by 2008 in each area will substantially exceed the required 15% reduction needed to Final Section 2 - Page 3 of 5 - October 2009 Revisiondemonstrate RFPtoward attainment .

By 2009, MassDEP estimates that statewide emissions ofVOCs during the summer ozone season will decrease from2002 levels by 25% and of NOx by 37%

. These reductions are the result of both existing and new

Massachusetts and federal control measures . As discussed in Section 3, Control Measures, and Section 5, Attainment Demonstration, the 2009 projected emissions inventorys used in the OTCmodeling process incorporates these anticipated reductions in Massachusetts. By 2012, MassDEP estimates that statewide emissions ofVOCs will decrease from2002 levels by 30%and of NOx by 48% . These reductions will result from state and federal control measures already in effect and taken into account in the 2009 attainment demonstration. Additional reductions will continue to accrue fromthese measures and ensure that ozone concentrations will continue to decrease in years subsequent to the 2009 attainment demonstration year.

Figure 2.1 Projected Anthropogenic VOC Emission

Trends for MA 2002 to 2012
S T u o m n m s e r P e D r a 

### I 800,,

700 600 500- 400 300- 200 100 

### 0 2002 2008 2009 2012 Actual -16% -25% -30% Projected %

VOC Reductions from2002 0 Off-Road 0 On-Road NArea I I " Point <

5 It should be noted that the inventory data used in the attainment modeling is based on annual emissions (as discussed in Section 5), rather than summer ozone season emissions . Therefore, percentage reductions that are cited in Section 5 may differ fromthe estimates provided in this Section.

Final Section 2 - Page 4 of 5 - October 2009 RevisionFigure 2.2 Projected Anthropogenic NOx Emission Trends for MA 2002 to 2012
S T u o m n m s e r p e D r a Y 800 700- 600 500- 400 300 200 100 0 2002 2008 2009 2012 Actual -36% -37% -48% Projected % NOx Reductions from2002 OOff-Road D On-Road " Area ~ " Point

-----

Final Section 2 - Page 5 of5 - October 2009 RevisionSECTION 4 REASONABLE FURTHER PROGRESS DEMONSTRATION OCTOBER 2009 REVISION 4 .1 Purpose of Section This section demonstrates that EMAand WMAwill meet the 8-hour ozone standard requirement related to Reasonable Further Progress (RFP) . EPA's Phase 2 Rule requires that, by the end of 2008, emissions of ozone precursors (VOCs and NOx) in each nonattainment area decrease by at least 15%

of the MA 2002 Base Year Inventory.' MassDEP has projected 2008 emissions after taking into account anticipated growth in the economy and any additional control measures expected to be in effect by that date. Its projections demonstrate that emissions will decrease in both areas by a significantly greater percentage than the 15% reduction required to demonstrate RFP . 4.2 Reasonable Further Progress Requirements and Methodology Under the CAA, ozone nonattainment areas are required to demonstrate progress towards attaining the ozone standard prior to their attainment year . EPA's Phase 2 Rule RFP requirements for 8-hour ozone non-attainment areas vary according to: 1) whether an area's attainment year is more than 5 years after EPA's 2004 nonattainment designations ; and 2) whether an area was previously required to submit a 15%

VOC Rate of Progress2 plan under the 1-hour ozone standard. EMAand WMA have a 2010 attainment year and under the 1-hour ozone standard they were required to submit 15% Rate of Progress SIPs.3 The applicable RFP requirement, therefore, is to reduce emissions of VOCs and/or NOx by 15%

within the six years after the 2002 Base Year Inventory - that is, by the end of 2008. The procedures and methodology for demonstrating compliance with the 1-hour ozone standard Rate of Progress requirements were established in a 1992 EPAguidance document ; these are still applicable for purposes of the 8-hour ozone standard RFP .4 EPA's method for demonstrating that RFP requirements are met calls for : 1 . Developing a 2002 base year inventory for a nonattainment area that takes into account certain adjustments for RFP purposes ; 2 . Establishing a "target level" of emissions for the last year ofthe RFP period (the "milestone" year) that reflects the required 15% reduction fromthe base year ;

1 As noted in Section 2, the MA 2002 Base Year Inventory is Appendix 2A. 2 Generally, the phrase "rate of progress" has been used in connection with 1-hour ozone standard requirements, while EPA has described 8-hour standard requirements as "reasonable further progress" . 3 The 15%Rate of Progress requirement was to demonstrate a 15%reduction in emissions of VOCs from the 1990 baseline inventory by 1996. An additional 9% reduction in VOCs, NOx or a combination of both, was required by 1999. MassDEP submitted a number of SIP revisions between 1993 and 2002 demonstrating compliance with these 1-hour ozone standard ROP requirements. 4 Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Targetfor the 15 Percent Rate of Progress Plans, U.S . EPA, Office of Air Quality Planning and Standards, EPA-452/R-92-005, October 1992. Final Section 4 - Page 1 of 7 - Revised October 20093. Developing a projected inventory of VOC and NOx emissions for the nonattainment area in the milestone year ; and 4 . Demonstrating that the projected milestone year emissions of NOx and VOCwill be less than, or equal to, the target level for that year. Consistent with EPA's methodology, MassDEP demonstrates in the calculations below that the EMAand WMAnonattainment areas have met the RFP requirements . 4.3 2002 RFPAdjusted Base Year Inventory The MA 2002 Base Year Inventory estimates anthropogenic and biogenic emissions of VOC and NOx. Pursuant to EPA's RFP methodology, for RFP purposes, MassDEP has adjusted the inventory as follows: 1 . excluded biogenic VOCemissions; and 2. excluded non-creditable reductions fromthe Federal Motor Vehicle Control Program (FMVCP) .5 3. included unused point source banked emission reduction credits (ERCs) in 2002. Table RFP-1 reflects the emissions estimates of VOC and NOx fromthe MA 2002 Base Year Inventory for EMAand WMAby source categories, with these adjustments. The result is the 2002 RFPAdjusted Base Year Inventory.

5 The CAA (Section 182(b)(1)(D)) provides that reductions fromthe following measures are not creditable toward the required reductions: (1) Federal Motor Vehicle Control Program(FMVCP) tailpipe and evaporative standards issued in 1990 ; (2) Federal regulations limiting the Reid Vapor Pressure (RVP) of gasoline in ozone nonattainment areas issued by June 15, 1990 ; (3) State regulations correcting deficiencies in reasonably available control technology (RACT) rules; (4) Measures required to be enacted immediately after passage of the 1990 CAA Amendments concerning corrections to vehicle inspection and maintenance (I/M) programs. Only the FMVCP continues to generate emission reductions through 2008 in Massachusetts .

Final Section 4 - Page 2 of 7 - Revised October 2009Table RFP 1 2002 VOC and NOx Adjusted Base Year Inventory

MA2002 Base Year Inventarv WMA STATE (From Appendix 2A) VOC yOC yOC EMA NOx NOx NOx (tons per summer day) POINT 13 .6 2.4 16.0 116.6 13.0 129.6 AREA 282.0 45.5 327.5 33.9 5.2 39.1 ON-ROAD 127.4 24.5 151 .9 381 .4 71 .7 453.1 OFF-ROAD 196.2 27.7 223 .9 `'= 122.1 22.4 144.5 BIOGENICS 535.7 254.6 790.3 4.4 1 .1 5 .5 TOTAL ALL CATEGORIES 1154.9 354.7 1509.6 658.4 113.4 771 .8 Adjustments for RFP EMA/WMA: TOTAL ANTHROPOGENIC (after subtraction of biogenics) 619.2 100.1 719.3 654 .0 112.3 766.3 FMVCP adjustment (Mobile On-Road) -15.3 -2 .9 -45.2 -8.5 UNUSED BANKED POINT ERCs 2002 2.4 0.1 30.6 0.8 2002 RFP ADJUSTED BASE YEAR INVENTORY EMA 8 WMA 606.3 97.3 639:4 11}4.6 Note: Small discrepancies may be due to rounding ksi2.inventory-2002-SIP-RFP File: MA-RFP-base-targets-proj -revised- Oct-14-2009 4.4 Target Level of Emissions MassDEP must demonstrate that the 2008 projected emissions for EMA and WMAwill be at least 15%

below the 2002 RFP Adjusted Base Year Inventory shown in Table RFP-1 above. The reductions can be of VOCs, NOx or any combination thereof . MassDEP is establishing its target levels based on a combined reduction of 12% NOx emissions and 3% VOCemissions in both EMA and WMA

. The 2008 Target Levels are depicted in Table RFP 2; projected emissions in 2008 may not exceed these Target Levels. The amount of reductions of each pollutant needed to achieve the Target Levels based on the 12% NOx and 3%VOCbreakdown is also shown.

Final Section 4 - Page 3 of 7 - Revised October 2009Table RFP 2 - 2008 Target Levels and Reductions Needed (TPSD) EMA WMA EMA WMA 1 . 2002 RFP Adjusted Base VOc VOc NOx NOx Year Inventory (from Table RFP 1) 606.3 97.3 639.4 104.6 2. Selected combination of reductions 3% 3% 12% 12% 3. Required Reductions 18.2 2.9 76.7 12.6 (line 1 x line 2) 4. 2008 Target Levels jl ine 1 - line 3) 588.1 94.4 562.7 0 ksi2.inventory-2002-SIP-RFP File: MA-RFP-base-targets-proj -revised- Oct-14-2009 4.5 2008 Projected Emissions Inventory The projected emissions in 2008 are calculated by estimating anticipated growth in emissions between 2002 and 2008 and then adjusting for any controls that will reduce emissions during that time period. The basic methodology for growing point and area source emissions is the application of socio-economic growth factors to the base year data. For on-road and non-road sources, projected emissions are estimated using the current EPA emission models, which have built-in control factors. The NONROAD model also has built-in growth factors. Appendix 4A, MA 2008 Projections by Categories, is based on the source category list used in the MA 2002 Base Year Inventory. It shows the growth factor that was applied to each source category to project 2008 emissions . It also indicates whether post-2002 controls have been taken into account . The projection methodology for the different source sectors listed in Appendix 4A is discussed below

. Table RFP 3 summarizes the total 2008 projected emissions for EMA and WMAfor all source sectors. 4.5.1 Stationary Point Sources The Stationary Point Source sector of the MA 2002 Base Year Inventory includes emissions fromElectric Generating Units (EGUs) and other industrial point sources. For EGUs and certain large boilers that have been subbject to the NOx Budget Program, instead of using 2002 base year data to project 2008 emissions, MassDEP is using 2006 actual emissions7 to which it applied growth factors based on the U .S . Department of Energy Forecastg for New England.
6 The NOx Budget Programis discussed in Section 3,Control Measures. Because the programbegan in 2003, 2002 base year data does not provide a good basis from which to project future year emissions from sources covered by the program . Final Section 4 - Page 4 of 7 - Revised October 2009For all other point sources (non-NOx Budget Program sources), MassDEP used MA 2002 Base Year emissions. To project 2008 emissions fromthis group of point sources, MassDEP interpolated from2009 projected emissions developed for MANE-VU9 for attainment demonstration modeling purposes. 10 MANE-VU used EPA's Economic Growth and Analysis System (EGAS, version 5.0) and the Annual Energy Outlook ofthe U .S. Department of Energy's Energy Information Administration (DOE/EIA) to project 2009 emissions for the non-EGU point source sector . MassDEP did not take any post-2002 control measures into account in projecting 2008 emissions fromthis group of point sources. Banked emission reduction credits (ERCs) unused as of 2008 are included in the 2008 projections. (See Table RFP 3 and Appendix 4c.) 4.5.2 Area Sources For most area sources, MassDEP projected 2008 emissions based on the MA 2002 Base Year Inventory combined with growth factors based on employment data fromthe Massachusetts Department of Employment and Training (MA-DET) . For the consumer products and architectural coatings (paints) categories, projections were based on population growth factors fromthe U

.S . Census population projections. For residential, commercial and small industrial fuel use, MassDEP used the growth factors that MANE-VU developed fromDOE-EIA data and EGAS. 4 .5.3 On-Road and Non-Road Mobile Sources The Massachusetts Executive Office of Transportation and Public Works, Office of Transportation and Planning (EOT) estimated on-road mobile source emissions in 2008 for purposes of establishing the Transportation Conformity budgets required for the 2008 RFP milestone year . (Transportation Conformity budget requirements are discussed in Section 9, Transportation Conformity.) These 2008 on-road mobile source projections are used in this section as part of the RFP calculations.

7 EPA Clean Air Markets Division 2006 NOx Budget ProgramEmissions Report for Massachusetts . Available at : http://camddataandmaps .epa .gov/gdm/index.cfm . 8 U .S. Department of Energy, Energy Information Administration (DOE/EIA), Forecasts and Analysis, Table 1 - Energy Consumption by Sector and Source -New England -O1 http ://www

.eia.doe.gov/oiaf/forecasting .html 9 The Mid-Atlantic and Northeastern states, tribes, and federal agencies formed The MidAtlantic/Northeast Visibility Union (MANE-VU) to coordinate regional haze planning activities for the region. MANE-VU and the OTC coordinated the development of combined inventories for purposes of regional ozone and PM2.5 attainment planning and regional haze planning. 10 See Appendix 5K, "Development ofEmission Projections for 2009, 2012 and 2018 for NonEGUPoint, Area and Nonroad Sources in the MANE-VURegion, Prepared by MACTEC Federal Programs, Inc., Feb. 28, 2007. Final Section 4 - Page 5 of 7 - Revised October 2009EOT used the latest version of its Travel Demand Model to project 2008 vehicle miles traveled

(VMT) . EPA's MOBILE 6 .2 model generated emission factors based on MassDEP inputs to the model that reflect state and federal mobile source control programs that will be in place in 2008. EOT combined the emission factors generated from MOBILE 6 .2 with VMT to estimate on-road mobile emissions in 2008.11 The MassDEP on-road mobile control programs that were adopted under the 1-hour ozone standard and that are reflected in the 2002 and 2008 input files include: MA Enhanced Inspection and Maintenance (I/M) program, the California Low Emission Vehicle (LEV) program, Stage 11 vehicle refueling control and reformulated gasoline (RFG) . MassDEP does not anticipate changing the parameters of any state mobile source control program after 2002 and prior to the end of 2008

. Therefore, the inputs for the 2002 base year and the 2008 projection year are the same . 12 (MassDEP expects to implement program revisions for the I/M

programbeginning in late 2008.) For non-road mobile emissions, MassDEP used EPA's NONROAD Model (version 2005a, Feb.2006) to project 2008 emissions fromthis sector . The model has built-in state and county growth factors and factors for the federal control measures for non-road engines that will be in effect in 2008. (See Section 3, Control Measures) For the non-road category of airport emissions, MassDEP applied growth factors for Logan Airport to develop Suffolk County (EMA) projected emissions. The growth factors for other airports in each county in EMAand WMAwere derived fromMANE-VUprojections . Growth factors for Commercial Marine Vessels and Locomotives were also derived fromMANE-VU . 4 .6 Summary The 2008 projections are summarized in Table RFP 3 below . Reductions anticipated by 2008 are compared to the reductions required to meet RFP. As shown, both areas have demonstrated reductions significantly greater than the 15% reduction needed to meet RFP requirements .

11 Section 9, Transportation Conformity, includes additional discussion of the planning assumptions used to estimate mobile source emissions for the 2008 and 2009 Transportation Conformity Budgets. 12 Non-road input and output data and non-road emissions by county are contained in Appendix 4b, Tables 4B-7 and 4B-8

. Final Section 4 - Page 6 of 7 - Revised October 2009TABLE RFP 3

2002 RFP Adjusted Base Year, 2008 Projected Emissions &Target Level Comparison Tons per Summer Day 

### NOC NOX EMA EMA WMA WMA EMA EMA WMA WMA 2002 2008 2002 2008 2002 2008 2002 2008 BASE PROJECT BASE PROJECT ' - BASE PROJECT BASE PROJECT YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR SOURCE SECTOR (Anthropoqenic) VOc VOC VOC VOC NOx NOx NOx NOx POINT 13.6 13.9 2.4 2.4 ; 116.6 77.2 13.0 8 .6 AREA 282.0 286.0 45.5 46.3 ` 33 .9 38.1 5.2 5 .9 ON-ROAD 127.4 68.3 24.5 11 .8 ' 381 .4 191 .3 71 .7 31 .3 OFF-ROAD 196.2 155.3 27.7 23.6 122 .1 108.1 22.4 20.3 TOTAL EMISSIONS unadjusted 619.2 523.5 100.1 84.1 654.0 414.7 112.3 66.1 UNUSED BANKED POINT ERCs 2-4 2-2 0-1 0-1 30.6 25.9 0-8 0-8 TOTAL EMISSIONS WITH ERCs 621 .6 525.7 100.2 84.2 ' 684.6 440.6 113 .1 66.9 FMVCP A

DJUSTMENT (ON-ROAD) -15.3 -2 .9 -45.2 -8 .5 - 1 . 2002 RFPAdjusted Base Year Emissions (Table RFP 1) 606.3 97.3 639.4 104.6 - 2 . 2008 Projected Emissions (with unused banked ERCs in 2008) 525.7 84.2 440.6 66.9 3. Required VOC/NOx Reductions (must total 15%) 3% 3% 12% 12% 4.15% Reductions in tons (to calculate 2008 Target Levels = Line 1 *fine 3) 18.2 2 .9 76.7 12.6 5 . 2008 RFPTarget Levels (Table RFP 2) Line 1 - line 4 588.1 94.4 562.7 92.0 6 . Projected 2002 to 2008 reductions Line 1- line 2 80.6 13.1 198.8 37.7 7. Tons (and %) by which 2008 projected emissions are below RFP Target Levels Line 6- line 4 62.4 10.2 122 .1 25.1 Line 7 / line 5 10.6% 10 .8% 21 .7% 27 .3% * Unused banked ERCs in 2002 and 2008 were added to 2002 base year and 2008 projection year, respectively . ks/2.inventory-2002-SIP-RFP File: MA-RFP-base-targets-proj -revised- ERCs-Oct--2009

Final Section 4 - Page 7 of 7 - Revised October 2009] APPENDIX 4c - October 2009 REVISION

POINT SO

URCE EMISSION REDUC i

__ TION CREDITS (ERCs) --- ~ ~

--- - -- ------ - - - ----- - --- - I (Emissions in tons per year (TPY), tons per ozone season (TP0_S), and to ns per su m mer day (TPSD) i, ~ -1 ------- ------------- - -T-- ------- - ----- _ i -- ~

f -- ---- ------------ ~ file: erc sum-Oct-09-2009-sort-EW-MA TOTAL UNUSED ERCs IN 2002 BASE YEAR (From Shee 1 .Gen 12-31-01) ---heet -- . _ - , - - ~ -

_ --, --

------ I RATE BASED ' TOTAL ~ MASS BASED RATE BASED

! , UNUSED ERCs i

, MASS BASED ' UNUSED ERCsI UNUSED UNUSED ERCs !, IN 2002 TPSD , ' UNUSED ERCs IN 2002 TPSD ; ERCs in 2002 -' - ---

IN 2002 TPY (/365 Days) ~-- i-- .- IN 2002 TPOS -- - ------------ /153 Davs j TPSD -- - -~--- -- ----- NOx JE Ma -------- 1284.3~- 3.52 ~ 4138.5 - --- 27 .05 30.57

- ---,_- -- I --_ W .Ma -- 48.0 0.13 _- 100.0 - -~--------- - -- -- 0.65 0.79 - - -- - ----- State _ 1332.3 3 .65 4238.5 - --~ ~ - ---- ----- 27 .70 31 .35 --- '

__.- - - --- i -- - . . ---- ---- - ~ - ----- -~ VOC I,E .Ma 383.9 1 .05 1 211 .51: ---- - ---- --~_-- 1 .38 2.43 - -- - - - ---------i - - --- W M 12 0 0 03 4 0 I -- . . -- -- ------ ----- - --- - 0 03 - ~

-

. . _ . I . a I-

- ---- - -- -i -------- --- - ---- - . --- 0.06 - ~ ~--_ .-- ----- --_

-- State 395.9 215. 51 ~=~8 I 1 .41 2.49 - - -- -----

- - - - L- -- - - I - - ---- -- --- -I-- - - -- - -- ~ 1 ,- -

-- -lr---- I Y-- - L - I TOTAL USED ERCs 2002-2008'` SUBTRACTED FROMUNUSE D 2002 ERCs ABOVE (Used _E_R_Cs_fro_m Sheet 2.T&U 12-31 -01) --- - - - --T r , ~ RATE BASE Q ~ ~ I . USED ER(s I MASS BASED MASS BASED RATE BASED POST 2002 USED ERCs USED ERCs TOTAL USED USED ERCs TPSD/365 POST 2002 I OS D TPOS' POST 2002 ERCs POST, TPSD /1 D i P T 2002 TPY ays 53 avsi 2002 in TPSD --- - -- --- , '

--- ----- -- ~ ----- ---- - ----- -- ' - --- , f---------- - NOx 2.03 -

I E.Ma 742.3 -- 1 '----
~- 40 2.64 4.67I ---------- --- -- --------------- - - --- , - - - - ~ I W . Ma 0.0 0.00 0.0 i - - --- - --- --- - ----- - --- - ---------- -

- --- ---- .00 0.0_0; - ~ --- -- - - 742.3 State 2.03 404.0~ __ '- 4.671 2.64` - - , ,---- -- -- , - ----- -- --

- - --- -- r - VOC E .Ma 90.1 0.251 0.0 - -----------------------~- ---- -- - 0.00 , 0.25, I 

# W .Ma _0.0 0.00~ _0.0 - - I

I _ _0.00 _ _O.OO ` O.OI State ' -- 90.1-,I 0.25

- - ---- --- I --------- ----- --- - ~ --- - - 0.25 O.OOt--- -- -- ' -- . - - -- - -- ' ERCs tha

t were generated after the 2002 ba se year and any of their usage were not counted. I I

----- -- ~ - -

----------- II --------' ------------
~ 

# ------i-------I ---~-----

--------- ------ --- - --- i - -- -- - - --- ------ - ------ TOTAL UNUSED ERCs IN 2008 (diff erence between tw

o tables above) j 

# ~- i----------I- I - ----T 

# -------------

I RATE BASED

!, I ' MASS BASED TOTAL I RATE BASED UNUSED ERCs 'i MASS BASED I UNUSED UNUSED ERCs UNUSED ERCs IN 2008+ TPSD UNUSED ERCsI IN 2008+ TPSD ' ERCs in IN 2008+ TIDY

]. (/365 Days) ; i IN 2008+ TPOSI /153 Days ~ ~ 2008+ TPSD , NOx E .Ma 542.0 1 5 3734.5 24 .4 25.89

W .Ma _ i ' 100.0 ' --- - --- - - -48.0

_--- ----- ----------

0.-1 ----- - -- - - -- - ---- .State 590.0 1 .6 3834.5 ;

-------- - - ~------------ - 0-71_ - ' 0.79 -- -------- 25 .1 26.68 I I

_ -- - - - --- --- r-- - --- ---- -- - ---- I - - --l -- ------~- VOC - - IE .Ma % 293.8 0.8 211 .5

! -- - -- -- ~ L - -- -- I------ - -- - - -- -------- -- 1 .4 I 2.18i ~ -------- ;---- --- -- W - Ma f - - ----

12

- .0' O- --- + ------- ------- 4- .0 6 ~ - . . 0-0 I' 0 I State 305.8 1 0.8 ; 215.5, 1 .4, 2.24'