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 of the 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 

from 2002 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 and Averaging. 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 Paper 
Technical 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 

Enclosures 
SECTION 2 EMISSIONS INVENTORIES 

OCTOBER 2009 REVISION 

2.1 Purpose of Section 

The CAA and EPA regulations require that states compile estimates of certain air pollutants 

emitted from sources 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 of these 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 EMA and 

WMA ozone 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 of the 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 CO on 

a ton per summer day (TPSD) basis. 

A June 2006 version of the MA 2002 Base Year Inventory was available for informal public 

review on 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 Revision 
2007 is part of this 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 them in 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 of VOC 

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 of VOCs 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 of Emission Projections for 2009, 

2012 and 2018 for 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 Revision 
Massachusetts by the 2008 milestone year for RFP, by the 2009 attainment demonstration milestone 

year, and by 2012. Note that because of different methods use to project emissions from the 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 of Emission Projections for NonEGU Point, Area and Nonroad Sources in the MANE-VU Region, 

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 from the 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 from 2002 levels by 16% and of NOx by 36%. As discussed in 

Section 4, Reasonable Further Progress, EMA and WMA are able to demonstrate that reductions of 

VOC and NOx by 2008 in each area will substantially exceed the required 15% reduction needed to 

Final Section 2 - Page 3 of 5 - October 2009 Revision 
demonstrate RFP toward attainment. 

By 2009, MassDEP estimates that statewide emissions of VOCs during the summer ozone season 

will decrease from 2002 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 inventory s used 

in the OTC modeling process incorporates these anticipated reductions in Massachusetts. 

By 2012, MassDEP estimates that statewide emissions of VOCs will decrease from 2002 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 from these 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 from 2002 

0 Off-Road 

0 On-Road 

N Area 

I " Point I 

< 

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 from the estimates provided in this Section. 

Final Section 2 - Page 4 of 5 - October 2009 Revision 
Figure 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 from 2002 

O Off-Road 

D On-Road 

" A rea 

~ " Point 

----- 

Final Section 2 - Page 5 of 5 - October 2009 Revision 
SECTION 4 REASONABLE FURTHER PROGRESS DEMONSTRATION 

OCTOBER 2009 REVISION 

4.1 Purpose of Section 

This section demonstrates that EMA and WMA will 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 Progress 2 plan under the 1-hour ozone standard . EMA and 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 EPA guidance 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 of the RFP period (the 

"milestone" year) that reflects the required 15% reduction from the 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 Target for 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 2009 
3 . 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 VOC will 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 

EMA and WMA nonattainment areas have met the RFP requirements . 

4.3 2002 RFP Adjusted 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 VOC emissions; and 

2 . excluded non-creditable reductions from the 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 from the MA 2002 Base Year 

Inventory for EMA and WMA by source categories, with these adjustments. The result is the 

2002 RFP Adjusted Base Year Inventory. 

5 The CAA (Section 182(b)(1)(D)) provides that reductions from the 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 2009 
Table RFP 1 2002 VOC and NOx Adjusted Base Year Inventory 

MA 2002 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 WMA will 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% VOC emissions 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% VOC breakdown is also shown. 

Final Section 4 - Page 3 of 7 - Revised October 2009 
Table 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 

WMA for all source sectors. 

4.5 .1 Stationary Point Sources 

The Stationary Point Source sector of the MA 2002 Base Year Inventory includes emissions 

from Electric 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 emissions 7 to which it applied 

growth factors based on the U.S . Department of Energy Forecastg for New England. 

6 The NOx Budget Program is discussed in Section 3, Control Measures. Because the program began 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 2009 
For all other point sources (non-NOx Budget Program sources), MassDEP used MA 2002 Base 

Year emissions. To project 2008 emissions from this group of point sources, MassDEP 

interpolated from 2009 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 of the 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 from this 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 from the Massachusetts 

Department of Employment and Training (MA-DET) . For the consumer products and 

architectural coatings (paints) categories, projections were based on population growth factors 

from the U.S . Census population projections. For residential, commercial and small industrial 

fuel use, MassDEP used the growth factors that MANE-VU developed from DOE-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 Program Emissions 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 of Emission 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 2009 
EOT 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 program beginning in 

late 2008.) 

For non-road mobile emissions, MassDEP used EPA's NONROAD Model (version 2005a, 

Feb.2006) to project 2008 emissions from this 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 EMA and 

WMA were derived from MANE-VU projections . Growth factors for Commercial Marine 

Vessels and Locomotives were also derived from MANE-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 2009 
TABLE 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 ADJUSTMENT (ON-ROAD) -15.3 -2 .9 -45.2 -8 .5 - 

1 . 2002 RFP Adjusted 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 RFP Target 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 SOURCE EMISSION REDUC 

i __ 

--- 

TION CREDITS (ERCs) 

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

_ f -- -- ~ ---- ------------ 

file: erc sum-Oct-09-2009-sort-EW-MA ~ 

TOTAL UNUSED ERCs IN 2002 BASE YEAR (From ---heet Shee1 .Gen 12-31-01) -- . _ 

- , - - 

~ 

- 

_ --, -- 

------ 

RATE BASED ' MASS BASED I TOTAL~ 

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 Davsj TPSD 

-- - -~--- -- ----- 

NOx JE Ma -------- 1284.3~- 3.52 ~ 4138.5 

- --- 

27.05 30.57 - ---,_- 

-- 

--_W

I .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 

- - ~ 

. a 

I- 

. _ . 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 FROM UNUSED 2002 ERCs ABOVE (Used _E_R_Cs_fro_m Sheet 2.T&U 12-31 -01) 

r --- - - - --T 

, ~ RATE BASE Q ~ 

~ I 

. 

USED ER(sI 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, 

P T 2002 TPY ays TPSD /1 53 D avsi i 2002 in TPSD 

----- -- --- - -- -- --- ----- ---, , ' ~ ----- ---- ' f---------- - - - --- 

NOx 2.03 - 

I 

E.Ma 742.3 

-- 

1 

'---- 

~- 40 

2.64 ---------- 4.67I --- 

~ -- --------------- - - --- , - - - - 

I W. Ma i 0.0 0.00 - - --- 0.0 

- - --- --- - --- ---- - ----- - --- ---------- - 

.00 0.0_0 ; - 

~ 

State 742.3 2.03 404.0~ --- -- - - 

__ 

, - , ,---- -- -- - - ----- 2.64` -- -- '- 4.671 

- - --- -- r - 

VOC E .Ma 90.1 0.251 0.0 

- -----------------------~- ---- -- - 

0.00 , 0.25, I W.Ma _0 .0 0 .00~ - - _0 .0 _O .OO I I _ _0 .00 _ 

` State O.O I ' 

-- 

90.1-,I 0.25 

- I --------- ----- --- - - - ---- --- ~--- - 

O.OOt--- 0.25 

-- -- ' -- . - - -- - -- 

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

I 

----- -- ~ - - 

----------- II --------' ------------ 

--------- 

TOTAL UNUSED 

------ --- - --- 

ERCs 

i - -- -- 

IN 2008 

- - 

(diff

--- 

erence 

------ 

between tw

~ 

o tables 

- 

above) 

------ 

j 

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

RATE BASED

~- I 

!, 

i 

I 

---- ------ I 

' 

- --- 

MASS 

-- ------- 

BASED 

- 

TOTAL 

RATE BASED UNUSED ERCs'i MASS BASEDI UNUSED ERCs I UNUSED 

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-- - --- --l -- ------~- I ---- 

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'