Bryan W. Shaw, Ph.D., P.E., Chairman Toby Baker, Commissioner

Richard A. Hyde, P.E., Executive Director 

## 15 AUG 26 PM 5: 24

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Protecting Texas by Reducing and Preventing Pollution


### August 18, 2015

Mr. Ron Curry Regional Administrator Environmental Protection Agency, Region 6 Fountain Place 12th Floor, Suite 1200 1445 Ross Avenue Dallas, Texas 75202-2733

Subject: Redesignation Substitute Reports for the Houston-Galveston-Brazoria (HGB) 1997 Eight- Hour Ozone Standard Nonattainment Area and the Dallas- Fort Worth (DFW) One-Hour and 1997 Eight-Hour Ozone Standard Nonattainment Areas

Dear Mr. Curry:

The Texas Commission on Environmental Quality (TCEQ) submits the enclosed 

### Redesignation Substitute Report for the Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Standard Nonattainment Area and the 

### Redesignation Substitute Report for the Dallas-Fort Worth OneHour and 1997 Eight-Hour Ozone Standard Nonattainment Areas for your consideration and

concurrence that the HGB area has met the requirements for the 1997 eight-hour ozone National Ambient Air Quality Standard (NAAQS) and that the DFW areas have met the requirements for both the one-hour and 1997 eight-hour ozone NAAQS.

These redesignation substitute reports include: monitoring data showing attainment of the relevant ozone NAAQS; a showing that attainment was due to permanent and enforceable emissions reductions; and, a demonstration that the areas can maintain the standards through 2028 based on emission inventory trends and projections of future emissions.

The United States Environmental Protection Agency's (EPA) 

### Implementation of the 2008 

### National Ambient Air Quality Standafds for Ozone: State Implementation Plan Requirements; Final Rule (2008 ozone standard SIP requirements rule) published in the March 6, 2015 

### Federal Register (8o FR 12264), includes a mechanism for lifting anti-backsliding obligations under a revoked ozone NAAQS. According to the rule, a state can provide a showing, termed a redesignation substitute, based on Federal Clean Air Act (FCAA), §107(d)(3)(E) redesignation criteria to demonstrate that an area qualifies for lifting anti-backsliding obligations under a revoked standard. The enclosed reports fulfill the requirements for a redesignation substitute, as described in the 2008 ozone standard SIP requirements rule, for the HGB 1997 eight-hour

ozone nonattainment area and the DFW one-hour and 1997 eight-hour ozone nonattainment

areas.

The DFW one-hour ozone nonattainment area comprises Collin, Dallas, Denton, and Tarrant Counties. The DFW four-county area monitored attainment of the one-hour ozone NAAQS based on certified monitoring data from 2004 through 2006 and has continued to monitor

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.texas.gov

How is our customer service? tceq.texas.gov /customersurvey

printed on recycled paper using vegetable-based ink

### Mr. Ron Curry Page 2 

### August 18, 2015



### attainment since that time. On October 16, 2008, 

### the EPA published final determination ( 73 

### FR 61357) 

### that the DFW four-county nonattainment area had attained the one-hour ozone standard. The DFW four-county area has continued to monitor attainment of the one-hour

ozone NAAQS since 2006.



### The DFW 1997 

### eight-hour ozone nonattainment area comprises Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties. The HGB 1997 

### eight-hour ozone nonattainment area comprises Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties. The TCEQ submitted early certification of 2014 

### ozone air monitoring data to the EPA on February 24, 2015, 

### and a request for a determination of attainment for both the DFW and HGB eight-hour ozone nonattainment areas on February 27, 2015. 

### On April 28, 2015, 

### the EPA published a proposed clean data determination for the D FW 1997 

### eight-hour ozone nonattainment area (So FR 23487). 

### On June 10, 

### 2015, 

### the EPA verified that the 2014 

### ambient ozone monitoring data for the HGB area met all data quality requirements for attaining the 1997 

### eight-hour ozone NAAQS. As 

### of August 18, 2015, 

### the DFW and HGB areas continue to monitor attainment of the 1997 

### eight-hour ozone standard.

Title 40 

### Code of Federal Regulations §51.1105(b)(2) 

### allows the EPA to remove the provisions for nonattainment new source review for the revoked one-hour and 1997 

### eight-hour ozone NAAQS
upon the EPA's approval of the 1997 

### eight-hour ozone HGB redesignation substitute and the DFW one-hour and 1997 

### eight-hour redesignation substitute. With these redesignation substitutes, the TCEQ requests that the EPA concur that the HGB and DFW areas are attaining and will continue to attain the revoked one-hour and revoked 1997 

### eight-hour ozone NAAQS, and that the relevant nonattainment NSR provisions no longer apply to the areas.



### If you have questions or need additional information, please contact David Brymer, Director of the Air Quality Division, at (512) 239-1725.

# ~fi .. .R_z_

Richard A.

# Hyde,~, Executive Director Texas Commission on Environmental Quality

RH/DB/lb/mr

Enclosures: 

### Redesignation Substitute Report for the Houston-Galveston-Brazoria 1997 EightHour Ozone Standard Nonattainment Area Redesignation Substitute Report for the f!allas-Fort Worth One-Hour and 1997 EightHour Ozone Standard Nonattainment AreasR E DESIGNATION SUBSTITU TE REPORT FOR THE DALLAS

- FORT WORTH (DFW) ONE

- HOUR AND 1997 EIGHT

- HOUR

OZONE STANDARD NONAT TAINMENT AREA S

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

P.O. BOX 13087 AUSTIN, TEXAS 78711

- 3087This page intentionally left blankPage 1

SECTION 1: G ENERAL

1.1 P urpose of this Redesignation Substitute Report This redesignation substitute (RS) report for the Dallas

- Fort Worth (DFW) One

- Hour and 1997 Eight

- Hour Ozone nonattainment areas supports the requirements described in the EPA’s Imple mentation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements; Final Rule (2008 ozone standard SIP requirements rule), published in the Federal Register (FR) on March 6, 2015 (80 12264).

The DFW one

- hour ozone nonattainment area comprises Collin, Dallas, Denton, and Tarra nt Counties. The DFW four

- county area monitored attainment of the one

- hour ozone National Ambient Air Quality Standard (NAAQS) with a design value of 124 ppb based on certified monitoring data from 2004 through 2006, and continues to demonstrate attainment with a design value of 102 ppb based on certified data through 2014. On October 16, 2008, the EPA published final determination that the DFW four

- county nonattainment area had attained the

one

- hour ozone standard (73 FR 61357).

The DFW 1997 eight

- hour ozo ne nonattainment area comprises Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties. On February 24, 2015, the TCEQ submitted early certification of 2014 ozone air monitoring data to the EPA, along with a request for a d etermination of attainment for the 1997 eight

- hour ozone standard for the nine

- county DFW area with a design value of 81 ppb based on monitoring data from 2012, 2013, and 2014. On April 28, 2015, the EPA published a proposed clean data determination for th e DFW 1997 eight

- hour ozone nonattainment area (80 FR 23487). As of August 4 , 2015, the 1997 eight

- hour ozone design value is 80 ppb.

The EPA’s 2008 ozone standard SIP requirements rule includes a mechanism for lifting anti

backsliding obligations under a revoked ozone NAAQS. According to the EPA’s 200 8 ozone standard SIP requirements rule, a state can provide a showing, termed a redesignation substitute, based on Federal Clean Air Act (FCAA), §107(d)(3)(E) redesignation

.

This DFW RS report is intended to satisfy the EPA’s requirements to lift anti

- backsliding obligations for the revoked one

- hour and the revoked 1997 eight

- hour ozone NAAQS by ensuring that specific redesignation requirements are met for the DFW four

- county one

- hour and nine

- county 1997 eigh t

- hour ozone nonattainment areas. This DFW RS report is being submitted to the EPA as provided in the 2008 ozone standard SIP requirements rule instead of a redesignation request and maintenance plan, which the FCAA require s to remove anti

backsliding obli gations under a standard that has not been revoked.

Title 40 Code of Federal Regulations ( CFR ) §51.1105(b)(2) allows the EPA to remove the provisions for nonattainment new source review ( NSR) for the revoked one

- hour and 1997 eight

- hour ozone NAAQS upon the EPA’s approval of the one

- hour and 1997 eight

- hour ozone DFW RS report . With this DFW RS report , the TCEQ requests that the EPA concur that the DFW area s are attaining and will continue to attain the revoked one

- hour and revoked 1997 eight

- hour ozone NAAQS, and that the nonattainment NSR provisions for the revoked standards no longer apply to the area s

. Certified ambient air quality monitoring data for 2004 through 2006 demonstrate that the four

county DFW area monitor ed attainment of the one

- hour ozone NAAQS starting in 2006 with a design value of 124 ppb, and continues to demonstrate attainment with a design value of 102 ppb based on certified data through 2014. The nine

- county DFW area dem onstrates attainment of the 1997 eight

- hour ozone NAAQS with a design value of 81 ppb based on certified data fromPage 2

2012 through 2014. This DFW RS report further supports the demonstration that the DFW

area s will continue to attain the one

- hour and 1997 eig ht

- hour ozone standard due to permanent and enforceable emission reductions and demonstrates continued attainment of both standards through 2028 via emission s inventory trends, 2012 attainment inventory, and projected future emissions . Since removing anti

- backsliding obligations is contingent upon the EPA’s approval, the TCEQ has set a horizon year of 2028. This 10

- year period also aligns with the EPA’s requirement of maintenance plans to demonstrate attainment for a 10

- year period following the date of red esignation.

Consistent with the EPA’s 2008 ozone standard SIP requirements rule, this DFW RS report for the one

- hour and 1997 eight

- hour ozone NAAQS includes the following elements.

Monitoring Data Showing Attainment of the Revoked One

- Hour and 1997 Eight

- Hour Ozone NAAQS
Section 2: Air Quality Data includes monitoring network and reporting requirements as well as ozone data and trend analyses. The DFW four

- county area attained the one

- hour ozone standard with a design value of 124 parts per billion ( ppb), based on certified 2004 through 2006 monitoring data. The 201 2 through 2014 certified monitoring data for the nine

- county DFW

area demonstrate that the area is monitoring attainment of the 1997 eight

- hour ozone NAAQS with a design value of 8 1 ppb. Oz one concentrations have decreased dramatically in the DFW

area s since the 1990s. Examination of the trends in one

- hour and eight

- hour ozone design values reveals substantial downward trends in monitored ozone levels.

Showing T

hat Attainment W

as D ue to Permanent and Enforceable Emissions Reductions
Section 3: Permanent and Enforceable Emissions Reductions identifies permanent and enforceable control measures that have resulted in reductions in nitrogen oxides (NO X ) and volatile organic compounds (VOC) em issions, and air quality improvements in the DFW four

county one

- hour and nine

- county 1997 eight

- hour ozone nonattainment areas. The 30 Texas Administrative Code (TAC) Chapter 115, Control of Air Pollution from Volatile Organic Compounds and 30 TAC Chapter 117, Control of Air Pollution from Nitrogen Compounds regulations have significantly reduced overall ozone precursor emissions in the DFW area s . The DFW area s have attained the one

- hour and 1997 eight

- hour ozone NAAQS as the result of implemented federal, state, and local controls. These enforceable measures will remain in place to ensure continued maintenance of the one

- hour and 1997 eight

- hour ozone NAAQS in the DFW area s

.

Demonstration That the Area s Can Maintain the Standard Over the Next 10 Years
Sect ion 4: Maintenance Demonstration provides emissions inventory trends, the 2012 attainment inventory, and projected future emissions, and demonstrate s continued attainment of the one

- hour and 1997 eight

- hour ozone standards through 2028. Analysi s of project ed ozone precursor emissions from 2012 through 2028 shows an overall projected decrease of 207.32 tons per day (tpd) in combined NO X and VOC emissions for the DFW four

- county one

- hour ozone nonattainment area. This net change for the four

- county area includes a projected 61.09 tpd decrease in VOC and a 146.23 tpd decrease in NO X . For the DFW nine

- county 1997 eight

hour ozone nonattainm ent area, the trend analysis shows an overall decrease of 257.04 tpd in combined NO X and VOC emissions. The net change for the nine

- county area includes a projected 83.86 tpd decrease in VOC and a 173.18 tpd decrease in NO X . Based on emissions projections and previous photochemical modeling analysis, continued attainment of the one

hour and 1997 eight

- hour ozone standards are shown for the four

- county and nine

- county DFW areas through 2028.Page 3

1.2 Ozone NAAQS History The following history of the one

- hour and eight

- hour ozone standards and summaries of the DFW area one

- hour and 1997 eight

- hour ozone SIP revisions are provided to give context and greater understanding of the complex issues inv olved in attaining the ozone standard in the DFW area

.

1.2.1 One

- Hour Ozone NAAQS History The EPA established the one

- hour ozone NAAQS of 0.08 parts per million (ppm) in the April 30, 1971 issue of the Federal Register (36 FR 8186). The EPA revised the one

- hour o zone standard to 0.12 ppm on February 8, 1979 (44 FR 4202). The DFW four

- c ounty one

- hour ozone nonattainment area (Collin, Dallas, Denton, and Tarrant Counties) was designated in 1991 as moderate in accordance with the 1990 FCAA Amendments (56 FR 56694). As a moderate nonattainment area, the four

- county DFW area was required to demonstrate attainment of the

one

- hour ozone standard by November 15, 1996. Ambient air monitoring data for the years 1994 through 1996, however, showed that the one

- hour ozone standard was exceeded more than one day per year over the three

- year period. As a result, the EPA reclassified the four

- county DFW area from a moderate to a serious nonattainment area (effective March 20, 1998) for failure to attain the one

- hour ozone standard by the November 1996 deadline (63 FR 8128). The EPA required the State of Texas to submit a SIP revision within one year that demonstrated attainment of the one

- hour ozone NAAQS and addressed FCAA requirements for serious ozone nonattainment areas.

1.2.1.1 March 1999 The TCEQ submitted the Attainment Demonstration (AD) for the Dallas

- Fo rt Worth Ozone Nonattainment Area SIP revision, which contained a rate

- of

- progress (ROP) demonstration, to the EPA on March 18, 1999. The photochemical modeling contained in the revision indicated that additional reductions in NO X emissions would be needed to attain the standard by November 1999. The following rules were developed and included in the SIP revision:

 reasonably available control technology (RACT) for NO X point sources;

 nonattainment new source review for NO X point sources; and

 revisions resulting from the change in the major source threshold for RACT applicability for VOC.

Additionally, the commission indicated that, due to time constraints, the ROP demonstration for the serious classification would not incorporate all rules that were ne cessary to bring the DFW nonattainment area into attainment by the November 1999 deadline and that a complete AD would be submitted in the spring of 2000. The EPA determined that the AD and ROP demonstration s were incomplete.

Additional local control strat egies were necessary for the DFW nonattainment area to reach attainment. To develop further control strategy options to augment the federal and state programs in the AD and ROP SIP revision, the DFW area established the North Texas Clean Air Steering Committee . The committee members include d local elected officials, business leaders, and other community stakeholders. This committee identified specific control strategies for review by technical subcommittee members.Page 4

1.2.1.2 April 2000 On April 19, 2000, the commission adopted a SIP revision and associated rules for the DFW

one

- hour ozone AD . The April 2000 One

- Hour Ozone AD SIP revision contained a number of control strate gies and the following elements:

 a modeling demonstration that showed air qua lity in the DFW nonattainment area was influenced at times by transport from the Houston

- Galveston

- Brazoria ( HGB ) nonattainment area (Under the EPA ’s July 16, 1998 transport policy 1 , if photochemical modeling demonstrated that emissions from an upwind area located in the same state and with a later attainment date interfered with the downwind area ’ s ability to attain, the downwind area ’ s attainment date could be extended to no later than that of the upwind area. For the DFW nonattainment area, following thi s policy would extend the attainment date to November 15, 2007, the same attainment date as the HGB area.);

 photochemical modeling of specific control measures and future state and national rules for attainment of the one

- hour ozone standard in the DFW non attainment area by the attainment deadline of November 15, 2007;

 identification of the VOC and NO X emissions reductions necessary to attain the one

- hour ozone standard by 2007. The reductions of 141 tpd NO X from federal measures and 225 tpd NO X from state measures resulted in a total of 366 tpd NO X reductions for the AD ;

 a 2007 motor vehicle emissions budget (MVEB) for transportation conformity; and

 a commitment to perform and submit a mid

- course review by May 1, 2004.

At the time it was submitted, the Apri l 2000 One

- Hour Ozone AD SIP revision allowed the EPA to determine that the DFW nonattainment area should not be reclassified from serious to severe under the conditions of the EPA ’s July 16, 1998 transport policy.

The Inspection Maintenance (I/M) program was implemented in the DFW nonattainment area on May 1, 2002 in Collin, Dallas, Denton, and Tarrant Counties and on May 1, 2003 in Ellis, Johnson, Kaufman, Parker, and Rockwall Counties. For more information on the I/M program, see Table 3

- 1: Existing Ozon e Control Measures Applicable to the DFW Nonattainment Area

.

1.2.1.3 August 2001 The next commission action was required by legislative mandate. Senate Bill (SB) 5 , passed by the 77th Texas Legislature in May 2001, required the repeal of two rules contained in the April

2000 one

- hour AD SIP revision. The first rule restricted the use of construction and industrial equipment (non

- road, heavy

- duty diesel equipment rated at 50 horsepower (hp) or greater). The second rule required the replacement of diesel

- powered cons truction, industrial, commercial, and lawn and garden equipment rated at 50 hp or greater with newer Tier 2 or Tier 3 equipment. The Texas Emissions Reduction Plan grant incentive program established by SB 5 replaced the NO X emissions reductions previously claimed for the two programs. The commission implemented the legislative mandate of SB 5 by submitting the rule repeals as part of a SIP revision adopted in August 2001.

1.2.1.4 March 2003 On March 5, 2003, the SIP was further revised to include the following:

1 Additional information on the EPA’s Guidance on Extension of Attainment Dates for Downwind Transport Areas is available at http://www.epa.gov/ttn/oarpg/t1/memoranda/transpor.pdf.Page 5

 th e adoption of revised 30 Texas Administrative Code (TAC) Chapter 117 NO X emission limits for cement kilns;

 the estimation of NO X reductions from energy efficiency measures, using a methodology that was to be further refined before energy efficiency credit was formally requested in the SIP revision; and

 the commitment to perform modeling with MOBILE6, the latest version of the EPA ’ s emission factor model for mobile sources at that time

. Meanwhile, the EPA ’ s July 16, 1998 transport policy, on which the extension of the DFW nonattainment area ’ s attainment date to November 15, 2007 was based, was challenged by environmental groups. A su it was filed challenging the extension of the Beaumont

- Port Arthur (BPA) area ’ s attainment date based on transport from the HGB area. On December 11, 2002, the United States Fifth Circuit Court of Appeals ruled that the EPA was not authorized to extend the BPA area’s attainment date based on transport. The EPA published a final action in the Federal Register on March 30, 2004 reclassifying the BPA area to serious with an attai nment date of November 15, 2005 and requiring a new AD to be submitted by April 30 , 2005. Although the court decision was specifically for the BPA area, the direct implication for the DFW nonattainment area was that the EPA could not approve extensions of the DFW one

- hour ozone attainment date past 1999, the date mandated by the FCAA fo r serious areas. In addition, the EPA did not approve the April 2000 One

- Hour Ozone DFW AD SIP revision.

1.2.1.5 EPA Determination of One

- Hour Ozone Attainment Since the early 1990s, when the DFW area was designated as nonattainment for the one

- hour ozone standard , much has been done to bring the area into attainment with federal air quality standards. Contributions to improved air quality in the DFW nonattainment area include: TCEQ

- implemented control strategies, local control strategies adopted by the North Centr al Texas Council of Governments (NCTCOG), and on

- road and non

- road mobile source measures implemented by the EPA. Despite the EPA’s lack of approval for multiple SIP revisions, air quality in the DFW nonattainment area continued to improve.

By 2006, certif

ied ambient monitoring data reflected attainment of the one

- hour standard. On October 16, 2008, the EPA published a final determination (73 FR 61357) that the DFW area

one

- hour ozone nonattainment counties (Collin, Dallas, Denton, and Tarrant) had attained the

one

- hour ozone standard with a design value of 124 ppb, based on certified 2004 through 2006 ambient monitoring data . The four

- county DFW area continues to demonstrate attainment of the one

- hour ozone NAAQS with certified data for 2012 through 2014.

1.2.2 1997 Eight

- Hour Ozone NAAQS History On July 18, 1997, the EPA published the revised NAAQS for ground

- level ozone in the Federal Register (62 FR 38856), and it became effective on September 16, 1997. The EPA phased out and replaced the previous one

- hour ozo ne NAAQS with an eight

- hour NAAQS set at 0.08 ppm based on the three

- year average of the annual fourth

- highest daily maximum eight

- hour average ozone concentrations measured at each monitor within an area. E ffective June 15, 2004

, the nine

- county DFW area (Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties) was designated as nonattainment with a moderate classification in the first phase of the EPA's implementation rule for the 1997 eight

- hour ozone NAAQS (69 FR 23951)

. The TCEQ was required to submit a SIP revision for the 1997 eight

- hour ozone NAAQS to the EPA by June 15, 2007, and demonstrate attainment of the standard by June 15, 2010. The EPA addressed the control obligations that apply to areas designated nonattainm ent for the 1997 eight

- hour ozone NAAQS in the second phase of the implementation rule (70 FR 71612). To satisfy the requirements of Phase I of the 1997 eight

- hour ozone standard implementation rulePage 6

(69 FR 23951), the TCEQ adopted the DFW Eight

- Hour Ozone Five Percent Increment of Progress SIP Revision on April 27, 2005 and submitted it to the EPA. The revision used a 5% increment of progress from the area’s 2002 emissions baseline beyond the reductions from federal and state measures already approved by th e EPA, and was the first DFW SIP revision submitted under the 1997 eight

- hour ozone standard.

1.2.2.1 May 23, 2007 The commission adopted the May 2007 DFW AD SIP revision and the reasonable further progress (RFP) SIP revision for the DFW nonattainment area on May 23, 2007. These SIP revisions were the first step in addressing the 1997 eight

- hour ozone standard in the DFW nonattainment area.
This eight

- hour ozone SIP revision for the DFW nonattainment area contained photochemical modeling and weight of evidence, including corroborative analysis and additional measures not included in the model. In addition to the existing control strategies in the DFW nonattainment area, the SIP revision included new rules for th e following sources:

 DFW nonattainment are a cement kilns;

 DFW nonattainment area ele ctric generating units ;

 DFW nonattainment area industrial, commercial, and institutional major sources;

 DFW nonattainment area minor sources; and

 East Texas combustion sources in 33 counties beyond the DFW nonattai nment area.

The SIP revision included additional commitments for a Voluntary Mobile Emissions Reduction Program (VMEP) and transportation control measures (TCM). The revision also contained the reasonably available control measure (RACM) analysis, RACT ana lysis, contingency measures,

em issions inventories, and MVEBs.

On July 14, 2008, the EPA proposed conditional approval ( 73 FR 40203 ) of the May 2007 DFW AD SIP Revision, providing that fin al conditional approval was contingent upon the State of Texas adopting and submitting to the EPA an approvable contingency plan SIP revision for the DF W nonattainment area. The DFW AD SIP Revision for the 1997 Eight

- Hour Ozone Standard (Contingency Measures Plan) was adopted by the commission on November 5, 2008 and submitted to the EPA on November 15, 2008. The SIP revision identifie d measures to satisf y the EPA’s 3% reduction contingency requirement for 2010 for the DFW nonattainment area, to apply in the event that the DFW nonattainment area fail ed to meet the 1997 eight

- hour ozone standard by the attainment deadline.

An additional condition stipulated by the EPA for final approval of the May 2007 DFW AD SIP Revision was that the TCEQ adopt and submit rule and SIP revisions to implement an enforceable mechanism to limit the use of discrete emission reduction credits (DERC) in the DFW nonattainment area by March 1, 2009. The DFW AD SIP Revision for the 1997 Eight

- Hour Ozone Standard DERC Program incorporated rulemaking that amend ed Chapter 101, Subchapter H, Division 4: Discrete Emission Credit Banking and Trading rules to set a limit on DERC use for the DFW nonattainment area.
On January 14, 2009, the EPA published final conditional approval of components of the 2007 AD SIP revision, including the May 2007 DFW AD SIP revision, and the April 2008 and November 2008 supplements. The approval provided conditi onal approval of the 2009 attainment MVEBs, RACM demonstration, and failure

- to

- attain contingency plan, full approval of local VMEP and TCMs, full approval of the VOC RACT demonstrations for the one

- hour andPage 7

1997 eight

- hour ozone standards, and a statement that all control measures and reductions relied upon to demonstrate attainment were approved by the EPA.

On March 10, 2010, the commission adopted the DFW RAC T Update, 30 TAC Chapter 117 Rule Revision Noninterference Demonstration, and Modified Failure

- to

- Attain Contingency Plan SIP Revision . This SIP revision incorporated several actions adopted by the commission , and supplemented the 1997 eight

- hour ozone AD by demonstrating that the revised Chapter 117 rule does not interfere with the DFW AD SIP Revision.

On August 25, 2010, the commission adopted a SIP revision to convert an environmental speed limit (ESL) control strategy to a TCM for the 1997 eight

- hour oz one standard in the DFW nonattainment area. The EPA approved this revisi on to the SIP for the DFW ozone nonattainment area to re

- categorize a l ocal ESL control measure as a TCM effective on March
10, 2014.

1.2.2.2 Reclassification to Serious for the 1997 Eight

- Hou r Ozone Standard
The nine

- county DFW 1997 eight

- hour ozone nonattainment area is currently classified as serious nonattainment. I n 2009, the monitored design value (complete ozone season prior to the attainment date) for the nine

- county DFW nonattainment a rea was 86 ppb. Effective January 19, 2011, the EPA finalized a determination that the DFW nonattainment area did not attain the 1997 eight

- hour ozone standard by June 15, 2010, the deadline set by the Phase I implementation guidance for the 1997 ozone sta ndard for areas classified as moderate (75 FR 79302). Based on that determination, the EPA reclassified the DFW nonattainment area to

ser ious and set a January 19, 2012 deadline for the state to submit an AD SIP revision that addr essed the 1997 eight

- hour ozone standard serious nonattainment area requirements, including RFP. The nine

- county DFW nonattainment area’s new attainment date for the 1 997 eight

- hour ozone standard was June 15, 2013 which required that only data through 2012 could be used to determi ne attainment under the EPA’s rules.

As required by the FCAA, the TCEQ published a notice in the Texas Register (35 TexReg 4268)

, on May 21, 2010
, implementing the area’s contingency measures for failure to attain the 1997 eight

- hour ozon e standard by the June 15, 2010 deadline.

Concurrent with the 2011 AD SIP revision, the commission adopted revised and new RACT requirements to address the following C ontrol T echniques G uid elines (CTG) documents issued by the EPA from 2006 through 2008 (Rule Project Number 2010

- 016

- 115

- EN): Flexible Package Printing; Industrial Cleaning Solvents; Large Appliance Coatings; Metal Furniture Coatings; Paper, Film, and Foil Coatings; Miscellaneou s Industrial Adhesives; Miscellaneous Metal and Plastic Parts Coatings; and Auto and Light

- Duty Truck Assembly Coatings. Concurrent with this AD SIP revision, the commission also adopted revised and new RACT requirements for VOC storage tanks (Rule Project Number 2010

- 025

- 115

- EN).

This 2011 AD SIP revision included a n MVEB for 2012 that represented the on

- road mobile source emiss ions that were modeled for the AD . The DFW area's metropolitan planning organization must demonstrate that the estimated emissions from transportation plans, programs, and projects do not exceed the MVEB. Additionally, this 2011 AD SIP revision showed that by 2012, the DFW nonattainment area would meet other serious nonattainment area requirements, including an enhanced Inspection an d Maintenance Program (which ha d already been implemented in all nine counties), Stage II vapor recovery systems at gas stations (which ha d already been implemented in Collin, Dallas, Denton, and Tarrant Counties), a Clean Fuel Fleet Program (which is not required if emissions reductions from the National Low

- EmissionsPage 8

Vehicle Program are more than what would be achieved under such a program), TCMs (which have already been implemented in all nine counties ), and enhanced monitoring

. The EPA published final a pproval of the 2011 DFW RFP SIP revision on November 12, 2014 (79 FR 67068); however, the EPA is scheduled to finalize disapproval of portions of the 2011 DFW 1997 Eight

- Hour Ozone AD SIP Revision and to finalize the clean data determination by August
31, 2015 (80 FR 23487). This redesignation substitute SIP revision is intended to satisfy the anti

- backsliding obligations for the revoked one

- hour and the revoked 1997 eight

- hour ozone NAAQS by ensuring that the EPA’s requirements for the redesignation of r evoked ozone standards are met for the DFW ozone nonattainment area. A revised attainment demonstration for the 1997 eight

- hour ozone standard will not be required with the finalization of the EPA’s clean data determination. Further, this redesignation sub stitute includes emissions inventory projections which demonstrate that the DFW area will maintain design values below the 1997 eight

- hour ozone NAAQS through 2028.

SECTION 2: AIR QUALITY DATA The ambient air quality monitoring network provides data to verify conti nued attainment of the

one

- hour and 1997 eight

- hour ozone National Ambient Air Quality Standard (NAAQS)

.

The Dallas

- Fort Worth (DFW ) nonattainment area monitoring network in 2015 consists of 17 regulatory ambient air ozone monitors located in Collin, Dalla s, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall and Tarrant Counties, Texas. The City of Dallas operates four of the monitors: Dallas Hinton (C0060/C0161/C0401/C3002), Dallas Redbird Airport (C402); Dallas North No.2 (C0063/C0679); and Rockwall Health (C0069). The City of Fort Worth operates four of the monitors: Parker County (C0076); Eagle Mountain Lake (C0075); Keller (C0017); and Arlington Municipal Airport (C0061). The Texas Commission on Environmental Quality (TCEQ) operates the remaining 9 ozone monitors: Denton Airport South (C0056/C0157/C0163); Pilot Point (C1032); Midlothian OFW (C0052/C0137); Italy (C1044); Cleburne Airport (C0077/C0682); Kaufman (C0071); Ft. Worth Northwest (C0013); Grapevine Fairway (C0070/C0182); and Frisco (C0031/C0680).

The monitors are managed in accordance with 40 Code of Federal Regulations ( CFR) Part 58 to verify the attainment status of the area. The Texas Commission on Environmental Quality ( TCEQ ) commits to keep in operation an appropriate air monitoring network in the DFW area and will continue to work with the United States Environmental Protection Agency (EPA) through the air monitoring network review process, as required by 40 CFR Part 58, to determine: the adequacy of the ozone monitoring network; if additional monitoring is needed; and when monitoring can be discontinued. Air monitoring data from these monitors will continue to be quality assured according to the requirements in the EPA’s regulations until the end of the maintenance period (2028 ) and reported t o the EPA on the schedule required by 40 CFR Part 58.

2.1 Ozone Data This section provides an analysis of air quality observational data in the DFW four

- county and nine

- county nonattainment area s . While the one

- hour and 1997 eight

- hour ozone NAAQS is expressed in units of parts per million (ppm), the familiar convention of expressing concentrations in parts per billion (ppb) is also used in this section. Data for ozone and nitrogen oxides (NO X ) were downloaded from the EPA’s Air Quality System (AQS) database, a nd volatile organic compounds (VOC) data were downloaded from TCEQ’s automated gas chromatograph (auto

- GC) database. Analyses of ozone data from federal reference method monitors and federalPage 9

equivalent method monitors, those used by the EPA to compare to t he NAAQS, are included in this section

.

2.2 Ozone Trend Analysis Trends in ozone are used to demonstrate the substantial progress the DFW area has made in improving air quality. The trend s in design values for the one

- hour and eight

- hour ozone NAAQS in the DFW nonattainment area s are seen clearly in Figure 2

- 1: One

- Hour Ozone Design Values for the DFW Area and Figure 2.2: Eight

- Hour Ozone Design Values for the DFW Area

. Regarding the one

- hour ozone NAAQS the area monitored attainment of 0.12 ppm (or 124 ppb) in 2006 and has since remained in attainment of the standard. . The one

- hour ozone design value for 2014 was 102 ppb. The design value for one

- hour ozone standard is the 4th highest value, provided that the monitor has three years of completed data. Data has to meet the validity checks of at least eighteen valid hours of data to be declared as valid days, at least 75% of days with data to be valid months, at least two months of data for valid quarters and at least three quarters of data to be declared as a valid year

. If one year out of the three year span does not meet the completeness requirements, then the design value will be the 3 rd highest value of the three year span. In 2006, the DFW area measured attainment of the one

- hour ozone NAAQS. The one

- hour ozone design value in the DFW area has shown large decrease s over the past eleven years , since 2004. T he one

- hour ozone design value in 201 4 was 102 ppb, which represents a 27 % decrease from the 1990 design value of 140 ppb

.

T he DFW nine

- county area excee ded the 1997 eight

- hour ozone NAAQS at the end of 2013, but monitored 3 ppb less than the value of the 1997 eight

- hour NAAQS of 0. 08 ppm (or 84 ppb) in
2014 . The design value for the eight

- hour ozone standard is the truncated three year average of the fourth highest value

, given three years of complete data , as discussed above . In 2014, the DFW area was in attainment of the 1997 eight

- hour ozone NAAQS. The eight

- hour ozone design value in the DFW area has decreased nearly 23 % over the past 24 years, fro m a design value of
105 ppb in 1990 to a design value of 81 ppb in 2014.Page 10

Figure 2

- 1: One

- Hour Ozone Design Values for the DFW AreaPage 11

Figure 2

- 2: Eight

- Hour Ozone Design Values for the DFW Area

The design value of a metropolitan area is the maximum design value of all of the area’s regulatory monitors’ individual design values. Because ozone varies spatially, it is also prudent to investigate trends at all monitors in an area. Table 2

- 1: One

- Hour Ozone Design Values by Monitor contain s one

- hour ozone desig n values at al l regulatory monitors in the DFW area from

2000 t hrough 20 14

. Since 2006, there have been no monitors in the DFW area that exceeded the one

- hour ozone standard. Table 2

- 2: Eight

- Hour Ozone Design Values by Monitor contain s eight

- hour ozone design values at al l regulatory monitors in the DFW area from 2000 t hrough

20 14 . More monitors than those listed in Table 2

- 1 and Table 2

- 2 operate in the DFW area, but the design values at those additional monitors are not appropriate for compliance deter minations with the DFW nonattainment area because they are not located geographically within the area. Only monitors located within the designated nonattainment area are displayed in Table 2

- 1 and Table 2

- 2. Note that the total number of monitors at the bo ttom of each table is different because there are different counties designated as nonattainment for the one

- hour ozone NAAQS and the 1997 eight

- hour ozone NAAQS. The total number of monitors also includes monitors that may not have a valid design value fo r that year.Page 12

Table 2

- 1 : One

- Hour Ozone Design Values by Monitor

Site Name 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Frisco C31 130 130 119 113 113 113 113 111 110 102 102 108 108 108 100
Anna C68 105 105 108 105 103 Dallas
Hinton St. C401/C60/C 127 125 118 125 118 115 114 114 97 87 89 98 101 101 101

Dallas North No.2
C63 128 128 118 113 118 120 117 116 101 105 105 107 106 106 99

Dallas Redbird Airport
C402 118 111 103 112 121 121 111 110 109 105 106 105 105 99 96

Sunnyvale Long Creek
C74 89 104 107 107 111 110

Denton Airport South C56 126 126 128 122 118 117 118 118 118 115 102 109 108 108 99

Pilot Point 107 104 94 97 103 103 103 97 Eagle
Mountain Lake C75 137 135 135 129 125 124 124 115 111 110 108 100 98 94

Ft. Worth Northwest
C13 131 130 126 126 123 123 117 118 109 102 106 106 101 100 100

Keller C17 128 128 128 128 126 117 115 117 111 108 107 110 108 107 95 Grapevine Fairway
C70 122 130 128 125 113 112 111 107 108 104 105 104 104 101

Arlington Municipal Airport 122 120 120 117 113 113 101 100 97 100 102 102 102

Total Number of Regulatory
M onitors 14 13 13 13 12 12 13 12 12 11 11 11 11 11 11

Total Number of
Monitors Above NAAQS 7 8 5 5 3 1 0 0 0 0 0 0 0 0 0Page 13

Table 2

- 2 : Eight

- Hour Ozone Design Values by Monitor

Site Name 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Frisco C31 101 99 93 88 89 91 92 88 83 79 77 81 83 84 78

Anna C68 76 83 80 80

Dallas
Hinton St. C401/C60/
C 93 92 91 90 89 90 87 84 74 73 82 84 78

Dallas North No.2
C63 93 89 86 87 90 89 86 80 81 78 82 81 83 77

Dallas Redbird Airport
C402 88 84 84 85 87 88 88 85 82 78 78 79 81 80 73

Sunnyvale Long Creek
C74 83 83 84

Denton Airport South C56 102 101 99 97 96 93 95 94 91 85 80 83 83 87 81

Pilot Point 81 77 78 82 82 84 79

Midlothian
Tower C94/C158 97 88 86 82 87 84 83 78

Midlothian
OFW C52/C137 75 73 72 74 76 77 71

Italy C1044 68 69 69 72 67

Cleburne Airport C77 89 90 90 89 87 85 83 83 80 79 79 79 76

Kaufman
C71 73 73 73 75 76 73 70 67 68 70 74 70

Parker County C76 86 89 86 87 88 91 84 81 75 79 78 79 74Page 14

Site Name 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Rockwall Heath C69 83 81 82 81 80 78 75 75 74 77 77 77 73

Arlington Reg. Office
C57 95 86

Eagle
Mountain Lake C75 95 96 94 95 96 95 89 86 85 83 82 81 79

Ft. Worth Northwest
C13 99 97 96 96 94 95 94 91 83 79 79 82 80 81 80

Keller C17 97 97 98 100 98 95 94 92 87 86 86 90 87 85 77

Grapevine Fairway
C70 95 100 98 93 93 92 87 84 82 86 86 86 80

Arlington Municipal Airport 87 87 87 84 79 77 79 79 83 80 75

Total Number of Regulatory
M onitors 19 18 18 18 17 17 19 19 19 17 17 17 17 17 17

Total Number of
Monitors Above NAAQS 8 8 11 11 13 12 12 10 4 3 2 2 2 3 0

Figure 2

- 3 : One

- Hour Ozone Design Value Statistics for All Monitors in the DFW Area displays the statistically summarized maximum, median, and minimum one

- hour ozone design values computed across all moni tors in the DFW area as well as how these distributions changed over time. The figure exhibits no noticeable trend until 2000 when the trend begins to fall steadily. Before 2000, only two monitors in the DFW area met t he one

- hour ozone standard; since then, the area has seen a steady increase in the number of monitors attaining the standard. By 2014, all monitors in the DFW area were below the one

- hour ozone NAAQS of 124 ppb.

Figure 2

- 4 : Eight

- Hour Ozone Design Value St atistics for All Monitors in the DFW Area shows the eight

- hour ozone design value exhibited a fairly consistent downward trend since 2000. Before 2014 , the DFW area had not met the 1997 eight

- hour ozone NAAQS of 84 ppb. In 2014 however, the area monitored attainment of the standard with a design value of 81 ppb

.Page 15

Figure 2

- 3: One

- Hour Ozone Design Value Statistics for All Monitors in the DFW AreaPage 16

Figure 2

- 4: Eight

- Hour Ozone Design Value Statistics for All Monitors in the DFW Area

Other useful information regarding o zone trends can also be obtained by examini ng the number of days where the daily one

- hour ozone maximum concentration was greater than 124 ppb in a year and examini ng the number of days where the daily eight

- hou r ozone maximum concentration was greater than 84 ppb in a year. This information is an important indicator of expected future ozone attainment in an area. The number of exceedance days analysis demonstrates both that the area remains in attainment, in addition to the distribution of

exce edances over time, which provides evidence that existing control strategies for ozone are effective. Figure 2 5: Number of One

- Hour Ozone Exceedance Days by Monitor in the DFW Area shows the number of days where one

- hour ozone was greater than 12 4 ppb by y ear for each currently operating DFW monitor from 1990 t hrough 201 4. The number of days is the total number of unique days (a day with more than one monitor over 124 ppb is only counted once ) on which any monitor in the DFW area registered a daily peak one

- hour ozone concentration greater than 124 ppb. In 201 4, there were zero days that the one

- hour ozone concentration was greater than 124 ppb. Since 1990

, the number of days with ozone concentrations above 124 ppb has decreased

, which is especially pronounced from 1995 t hrough 2008. The number of days with ozone concentrations above 124 ppb occurring in the DFW area fell 100 % from seven days in 1990 to zero days in 2014 . In the last seven years, only one day had ozone concentratio ns above the 124 ppb NAAQS threshold. This means that high ozone days are not only decreasing in frequency but they are also decreasing geographically across the entire region, showing an area wide trend for the one

- hour ozone NAAQS.Page 17

Figure 2

- 6: Number of Eight

- Hour Ozone Exceedance Days by Monitor in the DFW Area shows the number of days where the eight

- hour ozone was greater than 8 4 ppb by year for each currently operating DFW monitor from 1990 t hrough 201 4. The number of days is the total numbe r of unique days on which any monitor in the DFW area registered a daily peak eight

hour ozone concentration greater than 8 4 ppb. In 201 4, there were three days that the eight

hour ozone conc entration was greater than 8 4 ppb. Since 1990

, the number of days with ozone concentrations above 84 ppb has decreased

, which is especially pronounced from 2005 t hrough 2010, then again from 2011 through 2014

. The number of days wi th ozone concentrations above 8 4 ppb occurring in the DFW area has fall en nearly 91 % from 32 days in 1990 to three days in
2014

.

Figure 2

- 5: Number of One

- H ou r Ozone Exceedance Days by Monitor in the DFW AreaPage 18

Figure 2

- 6: Number of Eight

- H ou r Ozone Exceedance Days by Monitor in the DFW Area

2.3 Trend Analysis for Ozone Precu rsors Decreases in NO X and VOC, precursors to ozone formation, demonstrate the effectiveness of control measures in reducing NO X and VOC emissions, generally support declining ozone values, and indicate that ozone reductions are due to NO X and VOC emission reductions in the DFW area; however, ozone may not always exhibit trends identical to its precursors due to other variables such as meteorological conditions.

This section evaluates trends in concentrations of NO X and VOC. Only data that met data complete ness checks are used in this section. To meet the completeness check, each day must contain at least 18 valid hours of data, each month must contain at least 75% of days with data, each quarter must have at least two months of data, and each year must cont ain at least three quarters of data. NO X emissions are a variable mixture of nitric oxide and nitrogen dioxide and are critical precursors to ozone formation. As NO X emissions decrease, ambient concentrations of these compounds should also decrease. NO X emissions are primarily created by fossil fuel combustion, lightning, biomass burning, and microbial action in soil.

Annual maxima, annual 90 th percentile

, and annual average daily peak one

- hour NO X values observed in the DFW area are plotted in Figure 2

- 7 : Annual Maxima, 90th Percentile and Average of Daily Peak NOX Values (ppb) in the DFW Area, 2000 through 2014 . The figure uses a logarithmic scale so that all three statistics are visible and a linear regression line was added toPage 19

each statistic. The linea r regression line of the yearly maximum shows a negative slope of 10.6 ppb per year with an r2 of 0.43, and the regression line of the yearly 90 th percentile shows a negative slope of 5.1 ppb per year with an r2 of 0.90. The linear regression line of the y early average shows a negative slope of 2.4 ppb per year with an r2 of 0.93. All three measures have decreased over the 2000 t hrough 201 4 period, falling 32% (maximum), 60% (90 th percentile), and 61.5% (mean). Strong downward trends in ambient NO X concentr ations depicted in the emission

- trend data are evidence of the effectiveness of emission controls implemented in the DFW area and would be expected to support declining ozone values, as observed in the DFW

area.

Figure 2

- 7: Annual Maxima, 90th Percentile and Average of Daily Peak NO X Values (ppb) in the DFW Area, 2000 through 2014

T he other major class of ozone precursors is VOC. Since the mid

- 1990s, the TCEQ has collected
40

- minute time

- integrated measurements in the DFW area , on an hourly basis, of over 4 0 VOC compounds using auto

- GC instruments. This section will focus on two prevalent VOC compounds that are associated with rapid and efficient ozone formation, ethylene and propylene. Yearly geometric means were computed from valid ambient hourly measure ments

. A geometric mean was calculated by taking the natural logarithm of each measurement, averaging these logs, and then calculating the antilog of this mean log value. The geometric mean is a preferable statistic to median or arithmetic (ordinary) mean for evaluating the central tendency of data when the data are skewed, that is, when the data are not symmetrically, or normally, distributed, but instead clustered around extreme high or low values. It is more robust than an ordinary average, meaning its v alue is not greatly influenced by one or a few very high or veryPage 20

low values. Many distributions of pollutant measurements , especially VOC, in the DFW area are skewed , thus the geometric mean was evaluated to provide an assessment of VOC emissions in the DF W area

. The annual geometric mean of ethylene concentrations in parts per billion carb on (ppbC) is shown in Figure 2

- 8 : Yearly Geometric Mean Ethylene Concentrations (ppbC) at Nine DFW Monitors, 2000 through 2014 . Prior to 2010 , only t wo of the nine monito rs had enough valid data to calculate annual geometric mean ethylene.

. Values for ethylene are fairly low; the highest geometric mean ethylene in the DFW area in 2014 was below 0.6 ppbC. While trends are generally variable from year to year, the geometric mean ethylene has decreased at the two monitors with the longest record of auto

- GC data. Ethylene at the Flower Mound Shiloh (C1007) monitor had been steadily increasing until 2013, when the geometric mean ethylene decreased in 2014 . Concentrations at the Arlington UT Campus (C1018), Eagle Mountain Lake (C0075) and Kennedale Treepoint Drive (C1062) monitors saw increases between 2013 and 2014, although the Arlington UT Campus (C1018) and Kennedale Treepoint Drive (C1062) monitors only have two years of valid data to calculate the geometric mean.

Figure 2

- 8: Yearly Geometric Mean Ethylene Concentrations (ppbC) at Nine DFW Monitors, 2000 through 2014

Figure 2

- 9 : Yearly Geometric Mean Propylene Concentrations (ppbC) at Nine DFW Monitors, 2000 through 2014 shows the annual geometric mean for propylene. Like ethylene, p rior to 2004 only three of the nine monitors had enough valid data to calculate annual geometric meanPage 21

propylene. Note that the y

- axis is the same as in Figure 2

- 8. The geometric means for prop ylene

are even lower than the geometric means for ethylene for most of the years , with the highest geometric mean propylene concentration in the DFW area in 2014 below 0.4 ppbC . All monitors have been showing a steady decrease in geometric mean propylene f rom 2000 through 2014. The Fort Worth Northwest (C0013) monitor saw a slight increase in propylene measurements between 2013 and 2014. Though decreasing at different rates , these long

- term decreases in ambient concentrations of ethylene and propylene sugge st overall industrial and automobile emissions of these compounds have decreased considerably since 2000

.

Figure 2

- 9: Yearly Geometric Mean Propylene Concentrations (ppbC) at Nine DFW Monitors, 2000 through 2014

2.4 Ozone Data Summary Ozone concentrations have decreased dramatically in the DFW area since the 1990s. In 2008, the one

- hour design value dipped below the standard of 0.12 ppm (or 124 ppb); since 2008, only one day monitored a one

- hour ozone concentration greater than 124 ppb. In 201 4 , the eight

hour ozone design value met the 1997 eight

- hour ozone NAAQS of 84 ppb. Examination of the number of days that one

- hour ozone concentrations exceeded 0. 124 ppm and that eight

- hour

ozone concentrations exceeded 0. 084 ppm reveals substantial downward trends. Evaluation of local changes of ozone precursors showed similar significant downward trends. These results suggest that the significant ozone reductions achieved in the DFW area are primarily due to NO X and VOC reduction s in the DFW area, the emission reduction control strategies are effective, and that projections fo r future attainment status are well

- founded

.Page 22

SECTION 3: PERMANENT AND ENFORC EABLE EMISSIONS REDU CTIONS

3.1 Control Measures
The Dallas

- Fort Worth (DFW) nonattainment area for the one

- hour National Ambi ent Air Quality Standard (NAAQS), which consists of Collin, Dallas, Denton, and Tarrant Counties and for the 1997 eight

- hour ozone NAAQS, which consists of Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, and Rockwall, and Tarrant Counties, include a wide variety of major and minor industrial, comme rcial, and institutional entities. The Texas Commission on Environmental Quality (TCEQ) has implemented stringent and innovative regulations that address emissions of nitrogen oxides (NO X ) and volatile organic compo unds (VOC) from these

sources.

3.2 List of Existing Control Measures Since the early 1990s, a broad range of control measures have been implemented for each emission source category for ozone planning in the DFW area. Table 3

- 1: Existing Ozone Control Measures Applicable to the DFW Nonattainment Ar ea lists the existing ozone control strategies that have been implemented for the one

- hour and 1997 eight

- hour ozone NAAQS in the DFW

area s

.
Table 3

- 1 : Existing Ozone Control Measures Applicable to the DFW Non attainment Area

Measure Description Start Date(s) DFW Industrial, Commercial, and Institutional (ICI) Major Source Rule

30 Texas Administrative Code (TAC) Chapter 117, Subchapter B, Division
4 Applies to major sources (50 tons per year (tpy) of nitrogen o xides (NO X ) or more) with affected units in Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties

Applies to major sources (100 tpy of NOx or more) with affected units in Wise County

Affected source categories included in rule: boilers; process heaters; stationary gas turbines, and duct burners used in turbine exhaust ducts; lime kilns; heat treat and reheat metallurgical furnaces; stationary internal combustion engines; incinerators; glass, fiberglass, and mineral wool mel ting furnaces; fiberglass and mineral wool curing ovens; natural

gas

- fired ovens and heaters; brick and ceramic kilns; lead smelting reverberatory and blast furnaces; natural

gas

- fired dryers used in organic solvent, printing ink, clay, brick, ceramic tile

, calcining, and vitrifying processes; and
wood

- fired boilers March 1, 2009 or March 1, 2010, depending on source category

Note: these NO X control requirements are in addition to the NO X control strategies previously implemented for ICI major sources in Co llin, Dallas, Denton, and Tarrant Counties in March 2002 for the one

- hour ozone National Ambient Air Quality Standards (NAAQS)

January 1, 2017 for Wise County and wood

- fired boilers in all ten counties of the DFW

areaPage 23 Measure Description Start Date(s)

DFW ICI Minor Source Rule

30 TAC Chap ter 117, Subchapter D, Division
2 Applies to all minor sources (less than 50 tpy of NO X ) with stationary internal combustion engines in Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties March 1, 2009 for rich

- burn

gas

- fired engines, diesel

- fired engines, and dual

- fuel engines

March 1, 2010 for lean

- burn

gas

- fired engines

Stationary Diesel Engines

30 TAC Chapter 117, Subchapter B, Division 4 and Subchapter D, Division 2 and Subchapter C, Division
4 Prohibition on operat ing stationary diesel and dual

- fuel engines for testing and maintenance purposes between 6:00 a.m. and noon in Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall,
and Tarrant Counties April 1, 2009

DFW Major Utility Electric Generation
Sou rce Rule

30 TAC Chapter 117, Subchapter C, Division
4 NO X control requirements for major source (50 tpy of NOx or more) utility electric generating facilities in Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties

NOx control requirements for major source (100 tpy of NOx or more) utility electric generating facilities in Wise County

Applies to utility boilers, auxiliary steam boilers, stationary gas turbines, and duct burners used in turbine exhaust ducts used in electr ic power generating systems

Note: these NO X control requirements are in addition to the NO X control strategies implemented for utilities in Collin, Dallas, Denton, and Tarrant Counties in 2001 through 2005 for the

one

- hour ozone NAAQS March 1, 2009 for Col lin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and
Tarrant Counties

January 1, 2017 for Wise County

Utility Electric
Generation in East and Central Texas

30 TAC Chapter 117, Subchapter E, Division
1 NO X control requirements on utility boi lers and stationary gas turbines (including duct burners used in turbine exhaust ducts) at utility electric generation sites in East and Central Texas, including Parker County May 1, 2003 through May 1,
2005Page 24 Measure Description Start Date(s)
DFW Cement Kiln Rule

30 TAC Chapter 117, Subcha pter E, Division
2 NO X control requirements for all Portland cement kilns located in Ellis County March 1, 2009

NO X Emission Standards for Nitric Acid Manufacturing

– General

30 TAC Chapter 117, Subchapter F, Division
3 NO X emission standards for nitric acid manufacturing facilities (state

- wide rule

– no nitric acid facilities in DFW) November 15, 1999

East Texas Combustion
Sources

30 TAC Chapter 117, Subchapter E, Division
4 NO X control requirements for stationary rich

- bur n, gas

- fired internal combustion engines (240 horsepower and greater)

Measure implemented to reduce ozone in DFW area although controls not applicable in DFW area March 1, 2010

Natural Gas

- Fired Small Boilers, Process Heaters, and Water
Heaters

30 TAC Cha pter 117, Subchapter E, Division
3 NO X emission limits on small

- scale residential and industrial boilers, process heaters, and water heaters equal to or less than 2.0 million British thermal units per hour May 11, 2000

Offset Lithographic Printing

30 TAC, Chapter 115, Subchapter E, Division
4 Control technology requirements for offset lithographic printing

Revision to limit Volatile Organic Compounds (VOC) content of solvents used by offset lithographic printing facilities and to include smaller sources in rule applicability December 31, 2000 for Collin, Dallas, Denton, and Tarrant Counties and March 1, 2009 in Ellis, Johnson, Kaufman, Parker, and Rockwall Counties

March 1, 2011 for major printing sources (50 tons of VOC per year or more) and March 1, 2012 for minor printing sources (less than 50 tons of VOC per year)
VOC Rules

– Degassing Operations

30 TAC, Chapter 115, Subchapter F, Division
3 VOC control requirements for degassing during, or in preparation of, cleaning any storage tanks and transport vessels May 21, 2011 for Collin, Dallas, Denton, and Tarrant CountiesPage 25 Measure Description Start Date(s)
VOC Control Measures

– Storage Tanks

30 TAC Chapter 115, Subchapter B, Division
1 Applies to major source storage tanks (50 tpy of VOC or more) in Collin, Dallas, Denton, Ellis, Johnson , Kaufman, Parker, Rockwall, and Tarrant Counties

Applies to major source storage tanks (100 tpy of VOC or more) in Wise County

Requires controls for slotted guidepoles and more stringent controls for other fittings on floating roof tanks, and control

requ irements or operational limitations on landing floating roof tanks

Eliminates exemption for storage tanks for crude oil or natural gas condensate and regulates flash emissions from these tanks

New inspection requirements to control flashed gases from stora ge tanks and corresponding recordkeeping requirements for fixed roof storage tanks March 1, 2013

January 1, 2017 for major source storage tanks in Wise County and for new inspection requirements to control flashed gases from storage tanks and corresponding recordkeeping requirements for fixed roof storage tanks in Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall,
Tarrant and Wise Counties

VOC Control Measures

– Solvent

- Using
Processes

30 TAC Chapter 115, Subchapter E Revised rules to implement RACT requirements per Control Techniques Guidelines issued by the United States Environmental Protection Agency (EPA) including new control, testing, monitoring and recordkeeping requirements for eight emission source categories in the DFW area: paper, film, and foil coatings; large appliance coatings; metal furniture coatings; miscellaneous metal and plastic parts coatings; automobile and light

- duty truck coating; industrial cleaning solvents; miscellaneous industrial adhesives; and flexible pack age printing (see DFW AD SIP Revision for the 1997 Eight

- Hour Ozone Standard Nonattainment Area (2010

- 022

- SIP

- NR)) March 1, 2013 for Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and
Tarrant Counties

January 1, 2017 for Wise CountyPage 26 Measure Description Start Date(s)

Re fueling

– Stage I

30 TAC, Chapter 115, Subchapter C, Division
2 Captures gasoline vapors that are released when gasoline is delivered to a storage tank

Vapors returned to tank truck as storage tank is filled with fuel, rather than released into ambient air 1990 for Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties

January 1, 2017 for Wise County

A SIP revision related to Stage I regulations was approved by the EPA, effective June 29,
2015 Refueling

– Stage II

30 TAC, C hapter 115, Subchapter C, Division
4 Captures gasoline vapors when vehicle is fueled at pump

Vapors returned through pump hose to petroleum storage tank, rather than released into ambient air 1992 (Collin, Dallas, Denton, and Tarrant Counties)

A SIP revision authorizing the decommissioning of Stage II vapor control equipment was approved by the EPA on March 17, 2014. Facilities may continue operating Stage II until August 31, 2018
VOC Control Measures

30 TAC Chapter 115 Control technology requireme nts for VOC sources for reasonably available control technology (RACT) and other SIP planning purposes including: storage, general vent gas, industrial wastewater, loading and unloading operations, general VOC leak detection and repair, solvent using

proce sses, etc. December 31, 2002 and earlier for Collin, Dallas, Denton, and
Tarrant Counties

June 15, 2007 or March 1, 2009 for Ellis, Johnson, Kaufman, Parker, and Rockwall Counties

January 1, 2017 for Wise CountyPage 27 Measure Description Start Date(s)

Texas Emissions Reduction Plan (TERP)

30 T AC Chapter 114, Subchapter K Provides grant funds for on

- road and

non

- road heavy

- duty diesel engine replacement/retrofit. The first emissions reduction incentive grant projects funded under TERP were for fiscal years 2002

- 2003 (September 1, 2001, through August 31, 2003). To focus the emissions reduction benefits for the areas that needed them the most, applications were accepted only for projects in the
Houston

- Galveston

- Brazoria (HGB) and DFW nonattainment areas for fiscal years 2002 through 2003. An ap plication period limited to the DFW, HGB, and
Beaumont

- Port Arthur areas was done in 2006 and 2007. The allocation approach established by the commission for TERP included several grant programs for reducing emissions from mobile sources and encouraging th e use of cleaner alternative fuels for transportation, including the Diesel Emissions Reduction Incentive Program providing grants to replace or upgrade heavy

- duty on

- road vehicles, non

- road equipment, locomotives, marine vessels, and some stationary engin es. January 2002

Texas Low Emission Diesel

30 TAC Chapter 114, Subchapter H, Division
2 Requires all diesel fuel for both on

- road and non

- road use to have a lower aromatic content and a higher cetane number Phased in from October 31, 2005 through January 31, 2006

Texas Low Reid Vapor Pressure (RVP)
Gasoline

30 TAC Chapter 114, Subchapter H, Division
1 Requires all gasoline for both on

- road and non

- road use to have RVP of 7.8 pounds per square inch or less from May 1 through October 1 each year April 2000 in Ellis, Johnson, Kaufman, Parker, Rockwall, and
Wise CountiesPage 28 Measure Description Start Date(s) Vehicle Inspection/ Maintenance (I/M)

30 TAC Chapter 114, Subchapter C Yearly treadmill

- type testing for pre

- 1996 vehicles and computer checks for 1996 and newer vehicles May 1, 2002 in Collin, Dallas, Denton, and Tarrant Counties

May 1, 2003 in Ellis, Johnson, Kaufman, Parker, and Rockwall
Counties

The DFW area meets the FCAA, §182(b)(4) requirements to implement an Inspection and Maintenance (I/M) program , and according to 40 CFR §51.3 50(b)(2), an I/M program is required to cover the entire urbanized area based on the 1990 census. The current I/M program in the DFW ozone nonattainment area sufficiently covers a population equal to the DFW urbanized area, thus expansion of the I/M progra m to include Wise County is not required.
California Gasoline Engines California standards for non

- road gasoline engines 25 horsepower and larger May 1, 2004

Transportation Control
Measures Various measures in North Central Texas Council of Governments’ (NCTCOG) long

range transportation plans 2007

Voluntary Energy Efficiency/Renewable Energy (EE/RE) See Chapter 3.3.3: Energy Efficiency and Renewable Energy Measures See Chapter 3.3.3

Voluntary Mobile Emissions Reduction Program Various pedestrian, bicycle, traffic, and mass transit voluntary measures administered by NCTCOG 2007

Federal On

- Road
Measures Series of emissions limits implemented by the EPA for on

- road vehicles

Included in measures: Tier 1, Tier 2, and
Tier 3 light

- duty and medium

- duty passenger vehicle standards, heavy

- duty vehicle standards, low sulfur diesel standards, National Low Emission Vehicle standards, and reformulated gasoline Phase in through 2010

Tier 3 phase in from 2017 through 2025Page 29 Measure Description Start Date(s)
Federal Area /Non

Road Measures Series of emissions limits implemented by the EPA for area and non

- road sources

Examples: diesel and gasoline engine standards for locomotives and leaf

blowers Phase in through 2018

3.2.1 Tier 3 Motor Vehicle Emission and Gasoline Sulfur Stan dards On April 28, 2014, the United States Environmental Protection Agency (EPA) finalized the Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards (79 Federal Register 23413). Starting in 2017, Tier 3 sets new veh icle emissions standards and lowers the sulfur content of gasoline, considering the vehicle and its fuel as an integrated system.

Tier 3 motor vehicle emission standards of Tier 3 will reduce both tailpipe and evaporative emissions from passenger cars, li ght

- duty trucks, medium

- duty passenger vehicles, and some heavy

- duty vehicles beginning model year 2017 and will be fully phased in by model year 2025. The Tier 3 motor vehicle emission standards also extend the regulatory useful life period during which t he standards apply from 120,000 miles to 150,000 miles.

When fully implemented, the Tier 3 motor vehicle exhaust emission standards for light

- duty vehicles will provide approximately an 80% reduction in non

- methane organic gases (NMOG) and NO X (NMOG+NO X ) s tandards and a 70% reduction in per

- vehicle particulate matter (PM) standards when compared to the current fleet average. The Tier 3 motor vehicle exhaust standards for heavy

- duty vehicles provide about a 60% reduction in both fleet average NMOG+NO X vehicl e emissions standards and per

- vehicle PM standards when compared to the current vehicle emissions standards.

The Tier 3 gasoline sulfur standards will limit gasoline sulfur to no more than 10 parts per million (ppm) of sulfur on an annual average basis beg inning January 1, 2017, a reduction of approximately 66% when compared to the current standard. The current gasoline sulfur standards specifying an 80 ppm refinery gate cap and 95 ppm downstream cap are maintained under the new Tier 3 gasoline sulfur standards. Removing sulfur from gasoline allows a vehicle’s catalyst to work more efficiently. The Tier 3 fuel standards will make emission control systems more effective for both existing and new vehicles, and will enable automobile manufacturers to meet the Tier 3 motor vehicle emissions standards.

3.3 Additional Measures

3.3.1 SmartWay Transport Partnership and Blue Skyways Collaborative Among its various efforts to improve air quality in Texas, the TCEQ continues to promote two voluntary programs in cooperation with the EPA: SmartWay Transport Partnership and Blue Skyways Collaborative.

The SmartWay Transport Partnership is a market

- driven partnership aimed at helping businesses move goods in the cleanest most efficient way possible. This is a voluntary EPA program primarily for the freight transport industry that promotes strategies and technologies to help improve fleet efficiency while also reducing air emissions.Page 30

There are over 3,000 SmartWay partners in the United States (U.S.), including most of the nation’s largest truck carriers, all the Class 1 rail companies, and many of the top Fortune 500 companies. Since its founding, SmartWay has reduced oil consumption by 120.7 million barrels and pr evented the release of 738,000 tons of NO X and 37,000 tons of PM into the atmosphere 2

. Approximately 170 Texas companies are SmartWay partners. The SmartWay Transport Partnership will continue to benefit the DFW area by reducing emissions as more companies and affiliates join, and additional idle reduction, trailer aerodynamic kits, low

- rolling resistance tire, and retrofit technologies are incorporated into SmartWay

- verified technologies.

The Blue Skyways Collaborative was created to encourage voluntary ai r emission reductions by planning or implementing projects that use innovations in diesel engines, alternative fuels, and renewable energy technologies applicable to on

- road and non

- road sources. The Blue Skyways Collaborative partnerships include internat ional, federal, state, and local governments, non

profit organizations, environmental groups, and private industries.

3.3.2 Cement Kiln Consent Decree Cement kilns located in Ellis County are subject to the requirements of Chapter 117, Subchapter E, Division 2. Ash Grove Cement Company operated three kilns in Ellis County, with an established source cap under §117.3123 of 4.4 tons per day (tpd).

However, a 2013 consent decree between Ash Grove and the EPA required by September 10, 2014 shutdown of two kilns and r econstruction of kiln #3 with selective noncatalytic reduction (SNCR) with an emission limit of 1.5 pounds of NOx per ton of clinker (lbs NO X /ton) and a 12

- month rolling tonnage limit for NOx of 975 tpy. The reconstructed kiln is a dry kiln with year

round SNCR operation. The redesign allows 949,000 tpy of clinker, or 1.95 tpd of NO X , which is well below the 4.4 tpd source cap

. Any modifications or new construction would be required to meet nonattainment new source review with best available control technol ogy requirements, and would be subject to the same 1.5 lbs NO X /ton of clinker emission limit in the New Source Performance Standards for Portland Cement Plants.

3.3.3 Energy Efficiency and Renewable Ener gy Measures Energy efficiency (EE) measures are typically p rograms that reduce the amount of electricity and natural gas consumed by residential, commercial, industrial, and municipal energy consumers. Examples of EE measures include increasing insulation in homes, installing compact fluorescent light bulbs, and r eplacing motors and pumps with high efficiency units. Renewable energy (RE) measures include programs that generate energy from resources that are replenished or are otherwise not consumed as with traditional fuel

- based energy production. Examples of renew able energy include wind energy and solar energy projects.

Texas leads the nation in RE generation from wind. As of December 2014, Texas has 14,098 megawatts (MW) of installed wind generation capacity 3 ; more than double that of California, the state with t he next highest amount of installed wind generation capacity. Texas’ total net electrical generation from renewable wind generators for 2014 is estimated to be approximately

2 EPA, 2014. SmartWay Program Highlights 201 4 , EPA

- 420

- F

- 14

- 003, February 2014

, http://www.epa.gov/smartway/about /documents/basics/420f14003.pdf

3 U.S. Department of Energy, National Renewable Energy Laboratory, http://apps2.eere.energy.gov/wind/windexchange/wind_installed_capa city.aspPage 31

39 million megawatt

- hours (MWh) 4 , approximately 22% of the total wind net electric al generation for the U.S.

While EE/RE measures are beneficial and do result in lower overall emissions from fossil fuel

fired power plants in Texas, emission reductions resulting from these programs are not explicitly included in photochemical modeling fo r state implementation plan (SIP) purposes because local efficiency efforts may not result in local emissions reductions or may be offset by increased demand in electricity. The complex nature of the electrical grid makes accurately quantifying emission re ductions from EE/RE measures difficult. At any given time, it is impossible to determine exactly where a specific user’s electricity was produced. The electricity for users in a nonattainment area may not necessarily be generated solely within that
nonatta inment area. For example, some of the electricity used within a nonattainment area in East Texas could be generated by a power plant in a nearby attainment county or even in West Texas. If electrical demand is reduced in a nonattainment area due to local e fficiency measures, the resulting emission reductions from power generation facilities may occur in any number of locations around the state. Similarly, increased RE generation may not necessarily replace electrical generation from local fossil fuel

- fired power plants within a particular nonattainment

area.
The Texas Legislature has enacted a number of EE/RE measures and programs. The following is a summary of Texas EE/RE legislation since 1999.

 76th Texas Legislature, 1999

o Senate Bill (SB) 7

o House Bill (HB ) 2492

o HB 2960

 77th Texas Legislature, 2001

o SB 5

o HB 2277

o HB 2278

o HB 2845

 78th Texas Legislature, 2003

o HB1365 (Regular Session)

 79th Texas Legislature, 2005

o SB 20 (1st Called Session)

o HB 2129 (Regular Session)

o HB 2481 (Regular Session)

 80th Texas Legislature, 2007

o SB 12

o HB 66

o HB 3070

o HB 3693

 81st Texas Legislature, 2009

o None

 82nd Texas Legislature, 2011

o SB 898 (Regular Session)

o SB 924 (Regular Session)

o SB 981 ( Regular Session )

4 U.S. Department of Energy, Energy Information Administration, Form EIA

- 923 data, http://www.eia.gov/electricity/data/eia923/Page 32

o SB 1125 (Regular Session)

o SB 1150 (Regular Session)

o HB 51 ( Regular Sessi on )

o HB 362 (Regular Session)

 83rd Texas Legislature, 2013

o None

 84th Texas Legislature, 2015

o SB 1626

o HB 1736

3.3.3.1 Renewable Energy SB 5, 77th Texas Legislature, 2001, set goals for political subdivisions in affected counties to implement measures to reduce energy consumption from existing facilities by 5% each year for five years from January 1, 2002 through January 1, 2006. In 2007, the 80th Texas Legislature passed SB 12, which extended the timeline set in SB 5 through 2007 and made the annual 5% reduction a goal instead of a requirement. The State Energy Conservation Office (SECO) is charged with tracking the implementation of SB 5 and SB 12. Also during the 77th Texas Legislature, 2001, the Energy Systems Laboratory (ESL), part of the Texas Engineering Ex periment Station, Texas A&M University System, was mandated to provide an annual report on EE/RE efforts in the state as part of TERP under Texas Health and Safety Code (THSC), §388.003(e).

The 79th Texas Legislature, 2005, Regular and 1st Called Sessions, amended SB 5 through SB 20, HB 2129, and HB 2481 to add, among other initiatives, renewable energy initiatives which require: 5,880 MW of generating capacity from renewable energy by 2015; the TCEQ to develop a methodology for calculating emission reducti ons from renewable energy initiatives and associated credits; the ESL to assist the TCEQ in quantifying emissions reductions from EE/RE programs; and the Public Utility Commission of Texas (PUCT) to establish a target of 10,000 MW of installed renewable te chnologies by 2025.

Wind power producers in Texas exceeded the renewable energy generation target by installing over 10,000 MW of wind electric generating capacity by 2010.

HB 2129, 79th Texas Legislature, 2005, Regular Session, directed the ESL to collabo rate with the TCEQ to develop a methodology for computing emission reductions attributable to use of renewable energy and for the ESL to annually quantify such emission reductions. HB 2129 directed the Texas Environmental Research Consortium to use the Tex as Engineering Experiment Station to develop this methodology. With the TCEQ’s guidance, the ESL produces an annual report, Statewide Air Emissions Calculations from Energy Efficiency, Wind and Renewables , detailing these efforts.

In addition to the programs discussed and analyzed in the ESL report, local governments may have enacted measures beyond what has been reported to SECO and the PUCT. The TCEQ encourages local political subdivisions to promote EE/RE measures in their respective communities an d to ensure these measures are fully reported to SECO and the PUCT.

SB 981, 82nd Texas Legislature, 2011, Regular Session, allows a retail electric customer to contract with a third party to finance, install, or maintain a distributed renewable generation system on the customer's side of the electric meter, regardless of whether the customer owns the installed system. SB 981 also prohibits the PUCT from requiring registration of the system as an electric utility if the system is not projected to send power to the grid.Page 33

HB 362, 82 nd Texas Legislature, 2011, Regular Session, helps property owners install solar energy devices such as electric generating solar panels by establishing requirements for property owners associations’ approval of installation of solar energy devices. HB 362 specifies the conditions that property owners associations may and may not deny approval of installing solar energy devices.

SB 1626, 84th Texas Legislature, 2015, modifies the provisions established by HB 362 from the 82nd Texas Le gislature, 2011, Regular Session, regarding property owners associations’ authority to approve and deny installations of solar energy devices such as electric generating solar panels. HB 362 included an exception that allowed developers to prohibit install ation of solar energy devices during the development period. SB 1626 limits the exception during the development period to developments with 50 or fewer units.

3.3.3.2 Residential and Commercial Building Codes and Programs THSC, Chapter 388, Texas Building Energy Performance Standards, as adopted in SB 5 of the 77th Texas Legislature, 2001, states in §388.003(a) that single

- family residential construction must meet the energy efficiency performance standards established in the energy efficiency chapter of the Inter national Residential Code. The Furnace Pilot Light Program includes energy savings accomplished by retrofitting existing furnaces. Also included is a January 2006 federal mandate raising the minimum Seasonal Energy Efficiency Ratio for air conditioners in single

family and multi

- family buildings from 10 to 13.

THSC, Chapter 388, as adopted in SB 5 of the 77th Texas Legislature, 2001, states in §388.003(b) that non

- single

- family residential, commercial, and industrial construction must meet the energy effici ency performance standards established in the energy efficiency chapter of the International Energy Conservation Code.

HB 51, 82nd Legislature, 2011, Regular Session, requires municipalities to report implementation of residential and commercial building c odes to SECO.

HB 1736, 84th Texas Legislature, 2015, update THSC §388.003 to adopt, effective September 1, 2016, the energy efficiency chapter of the International Residential Code as it existed on May 1, 2015. HB 1736 also established a schedule by which SECO could adopt updated editions of the International Residential Code in the future, not more often than once every six years.

3.3.3.3 Federal Facility EE/RE Projects Federal facilities are required to reduce energy use by Presidential Executive Order 13123 and the Energy Policy Act of 2005 (Public Law 109

- 58 EPACT20065). The ESL compiled energy reductions data for the federal EE/RE projects in Texas.

3.3.3.4 Political Subdivisions Projects SECO funds loans for energy efficiency projects for state agencies, institutions of higher education, school districts, county hospitals, and local governments. Political subdivisions in nonattainment and affected counties are required by SB 5, 77th Texas Legislature, 2001, to report EE/RE projects to SECO. These projects are typically building systems retrofits, non

building lighting projects, and other mechanical and electrical systems retrofits such as municipal water and waste water treatment systems.

3.3.3.5 Electric Utility Sponsored Programs Utilities are required by SB 7, 76th Texas Leg islature, 1999, and SB 5, 77th Texas Legislature, 2001, to report demand

- reducing energy efficiency projects to the PUCT (see THSC, §386.205Page 34

and Texas Utilities Code (TUC), §39.905). These projects are typically air conditioner replacements, ventilation du ct tightening, and commercial and industrial equipment replacement.

SB 1125, 82nd Texas Legislature, 2011, Regular Session, amended the TUC, §39.905 to require energy efficiency goals to be at least 30% of annual growth beginning in 2013. The metric for th e energy efficiency goal remains at 0.4% of peak summer demand when a utility program accrues that amount of energy efficiency. SB 1150, 82nd Texas Legislature, 2011, extended the energy efficiency goal requirements to utilities outside the Electric Reliab ility Council of Texas area.

3.3.3.6 State Energy Efficiency Programs HB 3693, 80th Texas Legislature, 2007, amended the Texas Education Code, Texas Government Code, THSC, and TUC. The bill:

 requires state agencies, universities and local governments to adopt ener gy efficiency
programs;

 provides additional incentives for electric utilities to expand energy conservation and efficiency programs;

 includes municipal

- owned utilities and cooperatives in efficiency programs;

 increases incentives and provides consumer educ ation to improve efficiency programs; and

 supports other programs such as revision of building codes and research into alternative technology and renewable energy.

HB 51, 82nd Texas Legislature, 2011, Regular Session, requires new state buildings and major renovations to be constructed to achieve certification under an approved high

- performance design evaluation system. HB 51 also requires, if practical, that certain new and renovated state

funded university buildings comply with approved high

- performance b uilding standards.

SB 898, 82nd Texas Legislature, 2011, Regular Session, extended the existing requirement for state agencies, state

- funded universities, local governments, and school districts to adopt energy efficiency programs with a goal of reducing e nergy consumption by at least 5% per state fiscal year (FY) for 10 state FYs from September 1, 2011 through August 31, 2021.

SB 924, 82nd Texas Legislature, 2011, Regular Session, requires all municipally

- owned utilities and electric cooperatives that had retail sales of more than 500,000 MWh in 2005 to report each year to SECO information regarding the combined effects of the energy efficiency activities of the utility from the previous calendar year, including the utility's annual goals, programs enacted to achieve those goals, and any achieved energy demand or savings goals.

3.3.4 Clean Air Interstate Rule and Cross

- State Air Pollution Rule In March 2005, the EPA issued the Clean Air Interstate Rule (CAIR) to address electric generating unit ( EGU ) emissions th at transport from one state to another. The rule incorporates the use of three cap and trade programs to reduce sulfur dioxide (SO 2 ) and NO X : the ozone

season NO X trading program, the annual NO X trading program, and the annual SO 2 trading
program.

For CAIR , Texas was not included in the ozone season NO X program but was included for the annual NO X and SO 2 programs. As such, Texas must make necessary reductions in annual SO 2 and NO X emissions from new and existing EGUs to demonstrate that emissions from Texas do not contribute to nonattainment or interfere with maintenance of the 1997 particulate matter with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM 2.5 ) NAAQSPage 35

in another state. CAIR consists of two phases for implementing neces sary NO X and SO 2 reductions. Phase I addresses required reductions from 2009 through 2014. Phase II addresses reductions in 2015 and thereafter.

In July 2006, the commission adopted a SIP revision to address how the state would meet emissions allowance all ocation budgets for NO X and SO 2 established by the EPA to meet the federal obligations under CAIR. The commission adopted a second CAIR

- related SIP revision in February 2010. This revision incorporated various federal rule revisions that the EPA had promul gated since the TCEQ’s initial submittal. It also incorporated revisions to 30 TAC Chapter 101 resulting from legislation during the 80th Texas Legislature, 2007, Regular Session.

A December 2008 court decision found flaws in CAIR but kept CAIR requirement s in place temporarily while directing the EPA to issue a replacement rule. In July 2011, the EPA finalized the Cross

- State Air Pollution Rule (CSAPR) to meet FCAA requirements and respond to the court’s order to issue a replacement program. Texas was incl uded in CSAPR for ozone season NO X , annual NO X , and annual SO 2 due to the EPA’s determination that Texas significantly contributes to nonattainment or interferes with maintenance of the 1997 eight

- hour ozone NAAQS and the 1997 PM 2.5 NAAQS in other states. As a result of numerous EGU emission reduction strategies already in place in Texas, the annual and ozone season NO X reduction requirements from CSAPR were relatively small but still significant. CSAPR required an approximate 7% reduction in annual NO X emissions and less than 5% reduction in ozone season NO X emissions.

On August 21, 2012, the U.S. Court of Appeals for the District of Columbia (D.C.) Circuit vacated the CSAPR. Under the D.C. Circuit Court’s ruling, CAIR would remain in place until the EP A develops a valid replacement. On October 5, 2012, the EPA filed a petition seeking an en banc rehearing of the U.S. Court of Appeals’ decision regarding CSAPR, but the appeal was denied.

The EPA and various environmental groups petitioned the Supreme Cou rt of the United States to review the D.C. Circuit Court's decision on CSAPR. On June 24, 2013, the Supreme Court granted the petitions and heard oral arguments on December 10, 2013. On April 29, 2014, a decision by the Supreme Court reversed the D.C. Circ uit Court’s decision and remanded the

case. On June 26, 2014 , the EPA filed a motion with the U.S. Court of Appeals for the D.C. Circuit to lift the stay of C S APR
, which was granted on October 23, 2014. On November 21,
2014 , the EPA issued rulemaking, whic h shifted the effective dates of CSAPR requirements to account for the time that had passed after the rule was stayed in 2011. As a result, the EPA is implementing the CSAPR federal implementation plan for Texas. Phase 1 of CSAPR took effect January 1, 201 5 and Phase 2 is scheduled to begin January 1, 2017. Oral arguments on the remanded case were held on February 25, 2015

. On July 28, 2015, the D.C. Circuit Court ruled that the 2014 annual SO2 budgets and the 2014 ozone season NOX budgets for Texas were in valid because they required overcontrol of Texas emissions, and remanded these budgets back to the EPA without vacatur.

3.3.5 Clean School Bus Program HB 3469 , 79th Texas Legislature, 2005, Regular Session, established the Clean School Bus Program , which provid e s monetary incentives for school districts in the state for reducing emissions of di esel exhaust from school buses

. As of May 201 5 , the TCEQ Clean School Bus Program has reimbursed approximately $2 8

. 5 million in grants for over 7,2 00 school buses across the state, with $4.5 million being used for 833 school buses in the DFW area.Page 36

3.3.6 Texas Emission Reduction Plan
The Texas Emissions Reduction Plan ( TERP ) was created in 2001 by the 77th Texas Legislature

, Regular Session, to provide grants to of fset the incremental costs associated with reducing NO X emissions from high

- emitting heavy

- duty internal combustion engines on heavy

- duty vehicles,

non

- road equipment, marine vessels, locomotives, and some stationary equipment.

The primary emissions reduct ion incentives are awarded under the Diesel Emissions Reduction Incentive Program (DERI). DERI incentives are awarded to projects to replace, repower, or retrofit eligible vehicles and equipment to achieve NO X emission reductions in Texas ozone nonattainme nt areas and other counties identified as affected counties under the TERP program where ground

- level ozone is a concern.

From 2001 through August 2014 , $905 million in DERI grants were awarded for projects estimated to help reduce 160,836 tons of NO X . Ove r $313 million in DERI grants were awarded to projects in the DFW area, with a projected 57,052 tons of NO X reduced. These projects were estimated to reduce up to 18.3 tons per day of NO X in the DFW area in 2015

. The emissions reduction estimates will chan ge yearly as older projects reach the end of the project life and new projects begin achieving emissions reductions. Also, of that $313 million awarded in the DFW

area , $22 million were awarded to North Central Texas Council of Governments through third

pa rty grants to admini ster subgrants in the DFW area.

An additional 666 DERI grants were selected for funding in FY 2015 for $80.6 million. Ninety

one of these projects were in the DFW area and totaled approximately $9.1 million. Subject to final contracting , these projects are estimated to reduce approximately 986 tons of NO X in the DFW area, representing almost 0.6 tons per day of NO X reduced beginning in 2017.

Three other incentive programs under the TERP program will result in the reduction in NO X emissions in the DFW area as discussed below

. A new Drayage Truck Incentive Program was established in 2013 to provide grants for the replacement of drayage trucks operating in and from seaports and rail yards located in the nonattainment areas. The progr am has awarded grants to nine projects totaling $3.95 million. These projects are estimated to reduce 233 tons of NO X , including 25 tons in the DFW area. This represents an additional 0.02 tpd of NO X projected to be reduced in the DFW area beginning in

201 7.

The Texas Clean Fleet Program (TCFP) was established in 2009 to provide grants for the replacement of light

- duty and heavy

- duty diesel vehicles with vehicles powered by alternative fuels, including: natural gas, liquefied petroleum gas, hydrogen, methan ol (85% by volume), or electricity. This program is for larger fleets ; applicants must commit to replacing at least 20 eligible diesel

- powered vehicles with qualifying alternative fuel or hybrid vehicles over a 12

- month period. From 2009 through August 201 4, almost $23.6 million in TCFP grants were awarded for projects to help reduce a projected 314.5 tons of NO X . Over $3.3 million in TCFP grants were awarded to projects in the DFW area, with a projected 89.4 tons of NO X reduced. The projects are estimated to reduce over 0.07 tpd of NO X in the DFW area starting in 2015. The latest TCFP grant application period ended October 3, 2014, with five projects totaling $8.85 million selected for funding. Subject to final contracting, t hese projects are estimated to r esult in an additional 124 tons of NO X reduced, including 94 tons in the DFW area. This represents an additional 0.076 tpd of NO X projected to be reduced in the DFW area beginning in 2017.Page 37

The Texas Natural Gas Vehicle Grant Program (TNGVGP) was establishe d in 2011 to provide grants for the replacement of medium

- duty and heavy

- duty diesel vehicles with vehicles powered by natural gas. This program may include grants for individual vehicles or multiple vehicles. The majority of the vehicle’s operation must o ccur in the Texas nonattainment areas, other counties designated as affected counties under the TERP, and the counties in and between the triangular area between Houston, San Antonio, and Dallas

- Fort Worth. From 2011 through August 2014, over $36.4 million in TNGVGP grants were awarded for projects to help reduce a projected 1,137 tons of NO X . Over $13.2 million in TNGVGP grants were awarded to projects where the applicant indicated the primary operation of the vehicle would occur in and around the DFW area , with a projected 452 tons of NO X reductions . These projects are estimated to reduce up to 0.36 tpd of NO X in the DFW area starting in 2015.

An additional 53 projects for approximately $15.8 million were selected for funding in FY 2015. Twenty

- four of these grants totaling $7.1 million are for projects with primary operation in the DFW area. The estimated emissions reductions from the FY 2015 projects will be available once final contracts are completed and calculations are performed. HB 1, General Appr opriations Bill, 84th Texas Legislature, 2015, appropriated $118.1 million per year for implementation of the TERP in FYs 2016 and 2017. This represents an increase of $40.5 million per year over the appropriation amount in FYs 2014 and 2015. This addition al funding will be available for future grant projects that should result in NO X reductions in the eligible TERP areas, including the DFW area.

3.3.7 Low Income Vehicle Repair Assistance, Retrofit, and Accelerated Vehicle Retirement Program The TCEQ established a financial assistance program for qualified owners of vehicles that fail the emissions test. The purpose of this voluntary program is to repair or remove older, higer emitting vehicles from use in certain counties with high ozone . The Low Income Vehicle R epair Assistance, Retrofit, and Accelerated Vehicle Retirement Program (LIRAP) provisions of HB 2134, 77th Texas Legislature , 2001, Regular Session, created the program. In 2005, HB 1611, 79th Texas Legislature , Regular Session, modified the program to app ly only to counties that implement a vehicle inspection and maintenance program and have elected to implement LIRAP fee provisions. The counties currently participating in the LIRAP are Brazoria, Fort Bend, Galveston, Harris, Montgomery, Collin, Dallas, De nton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, Travis, and Williamson Counties

. SB 12, 80th Texas Legislature 2007, Regular Session, expanded the LIRAP participation criteria by increasing the income eligibility to 300% of the federal poverty ra te and increasing the amount of assistance toward the replacement of a retired vehicle. HB 3272, 82nd Texas Legislature 2011, Regular Session, expanded the class of vehicles eligible for a $3,500 voucher to include hybrid, electric, natural gas, and federa l Tier 2, Bin 3 or cleaner Bin certification vehicles. The program provides $3,500 for a replacement hybrid, electric, natural gas, and federal Tier 2, Bin 3 or cleaner Bin certification vehicle of the current model year or the previous three model years; $3,000 for cars of the current or three model years; and $3,000 for trucks of the current or previous two model years. The retired vehicle must be 10 years old or older or
must have failed an emissions test. From December 12, 2007 through May 31 , 2015 , the program has retired and replaced 28,604 vehicles in the DFW area at a cost of $ 85,903,000

. During the same period, an additional 16,635 vehicles in the DFW area have had emissions

related repairs at a cost of $ 8,318,866 . The total retirement/replacement a nd repair expenditure for the DFW area from December 12, 2007 through May 31 , 2015 is $ 94,221,866

.Page 38

HB 1, G eneral Appropriations Bill, 84th Texas Legislature, 2015 , Regular Session, a ppropriated $43.5 million per year for FYs 2016 and 2017 to continue this clean air strategy in the 16 participating counties . The nine counties that participate in the program in the DFW area, Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant, were allocated approximately $21.6 mil lion per year for the LIRAP for FYs 2016 and 2017. This is an increase of approximately $18.8 million per year over the previous biennium.

3.3.8 Local Initiative Projects Funds are provided to counties participating in the LIRAP for implementation of air quality improvement strategies through local projects and initiatives. In the DFW area, Local Initiative Projects (LIP) funding is available to the nine counties currently participating in the LIRAP: Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant. HB 1, General Appropriations Bill, 84th Texas Legislature 2015, Regular Session, appropriated $4.8 million per year for FY s 2016 and 2017 to continue this clean air strategy. The nine DFW area counties were allocated approximately $ 2.4 million per year for FYs 2016 and 2017. This is an increase of approximately $2.1 million per year over the previous biennium.

Dallas County used LIP funds in 2008 to establish the Dallas County Clean Air Emissions Task Force. For its first seven years , the task force targeted high

- emitting vehicles, smoking vehicles, and suspicious vehicles to verify that the state safety and emissions inspection windshield certificates on these vehicles were legitimate and in compliance with air quality standards. The task force’s objective is to reduce the number of fraudulent, fictitious, or improperly issued safety and emissions inspection windshield certificates.

Following the success of Dallas County’s emissions enforcement project, Denton (2009

- 2015), Ellis (2008

- 2014), Johnson (2010

- 2014), Kaufman (2012

- 2015), and Tarrant (2010

- 2015) Counties established similar task forces. Beginning in March 2015, the emission enforcement task forces adjusted their objectives to concentrate on the identification of vehicles wit h counterfeit registration insignia and the reduction of fraudulent vehicle inspection reports. These programs have partnered with local and state agencies to enforce state laws, codes, rules, and regulations regarding air quality and mobile emissions in t he DFW area. The citizens of the entire north Texas region benefit from these programs as a result of the reduction in NO X emissions from each vehicle brought into emissions compliance.

The City of Plano, through Interlocal Agreements with Collin County, u sed LIP funding in 2012 and 2014 for Local Initiative Projects. In 2012, LIP funding was used by the City of Plano to install auxiliary power units in police department vehicles to reduce vehicle emissions during the daily activities of traffic enforcement . This idle reduction technology powers equipment such as lights, radio, and computers so that law enforcement officers can shut

- off their vehicles to perform traffic control, traffic accident investigations, lunch breaks, and other activities where the en forcement officer is outside their vehicle. In 2014, the City of Plano used LIP funding to install wireless communications technology at 20 intersections and additional pan/tilt cameras at 19 of those intersections. The project allows signal management fro m a traffic management center to reduce traffic congestion and idling in an effort to reduce emissions. The project reduces idling by improving traffic flow and decreasing the number of times vehicles must stop at traffic lights. The exhaust phase of an en gine emits the most emissions during starting, idling, and breaking stationary inertia. The project increases the emissions reduction benefits by allowing real

- time traffic management instead of a stagnate model to better manage peak

- hour congestion, while minimizing cross

- traffic congestion, and reducing emissions.Page 39

3.3.9 84th Texas Legislature Bills passed during the 84th Texas Legislature, 2015, that have the potential to impact the DFW area are discussed in Section 3.3.3: Energy Efficiency and Renewable Energ y Measures and Section 3.3.7: Low Income Vehicle Repair Assistance, Retrofit, and Accelerated Vehicle Retirement Program . As discussed in Section 3.3.7, HB1 appropriated $43.5 million per year for FYs 2016 and 2017 to continue this clean air strategy in th e 16 participating counties. The nine counties that participate in the program in the DFW area, Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant, were allocated approximately $21.6 million per year for the LIRAP for FYs 2016 a nd 2017. This is an increase of approximately $18.8 million per year over the previous biennium.

3.4 Control Strategies Summary The permanent and enforceable VOC and NO X control measures contained in Section 3.2: List of Existing Control Measures have resulted in air quality improvement in the DFW area. These enforceable measures will remain in place to ensure continued maintenance of the one

- hour and the 1997 eight

- hour ozone NAAQS in the DFW area s . In addition, Section 3.3: Additional Measures lists control m easures that may not meet all of the EPA’s standard tests of SIP creditability (permanent, enforceable, surplus, and quantifiable) but are crucial to the success of the air quality plan in the DFW area. Implementation of these control measures will contrib ute to the continued maintenance of the one

- hour and the 1997 eight

- hour ozone NAAQS. The TCEQ continues to seek innovative air quality improvement measures and technologies to implement in the DFW area.

SECTION 4: MAINTENANCE DEMONSTR ATION

4.1 General This redesignation substitute (RS) state implementation plan (SIP) revision is intended to demonstrate that the Dallas

- Fort Worth (DFW) area will remain in attainment of the one

- hour and 1997 eight

- hour ozone National Ambient Air Quality Standards (NAAQS) for the 10

- year period following the date that anti

- backsliding obligations under the revoked standard would be lifted. Since removing anti

- backsliding obligations is contingent upon the United States Environmental Protection Agency’s (EPA) approval, the T exas Commission on Environmental Quality (TCEQ) has set a horizon year of 2028. This 10

- year period also aligns with the EPA’s requirement of maintenance plans to demonstrate attainment for a 10

- year period following the date of redesignation.

The most cur rent emissions inventory (EI) data were analyzed as part of this maintenance demonstration. The year 2012 was chosen as the base year for the analyses presented in this section because it is one of the three years (2012, 2013, and 2014) used to determine t he design value for the 201 4 attainment year and due to periodic inventory data availability. At the time of this RS SIP revision proposal, the TCEQ was developing the 2014 periodic emissions inventory for the DFW area in accordance with the EPA’s Air Emis sions Reporting Requirements (40 Code of Federal Regulations Part 51, Subpart A). The calendar year 2011 periodic inventory was the most recent periodic inventory available to develop this RS SIP revision inventory. Since 2011 was not one of three years us ed to determine the design value for the 2014 attainment year, the TCEQ developed a 2012 base year inventory from available data for area and mobile sources, and used the reported calendar year 2012 data for point sources. Additionally, the 10 years prior to the 2012 base year (2002 through 2011) were analyzed to develop historical trend data. During this time, the EI for the DFW four

- county one

- hour and nine

- county 1997 eight

- hour ozone nonattainment areas showed a significant decrease in ozone precursor e missions from all source categories as detailed in Section 4.2 : Historical Emissions Inventory Trends , which contributed to the attainment of the one

- hour and 1997 eight

- hour ozone NAAQS. ThesePage 40

reductions were accomplished through a variety of federal, sta te, and local regulations and programs as detailed below.

4.2 Historical Emissions Inventory Trends For the historical period prior to the 2012 base year, 2002 through 2011, overall anthropogenic ozone precursor emissions in the DFW four

- county and nine

- county nonattainment areas declined substantially as a result of regulations implemented at the federal, state, and local levels and innovative programs implemented by the TCEQ. In the DFW four

- county one

- hour ozone nonattainment area from 2002 through 2011, ant hropogenic volatile organic compounds (VOC) emissions have decreased 12 % , and anthropogenic nitrogen oxides (NO X ) emissions have decreased 36%. In the DFW nine

- county 1997 eight

- hour ozone nonattainment area from 2002
to 2011 , anthropogenic VOC emissions h ave decreased 8 %, and anthropogenic NO X emissions have decreased 37 %. These trends are detailed in:

 Figure 4

- 1: DFW Four

- County Nonattainment Area Historical NO X Emissions Trends

,

 Figure 4

- 2: DFW Nine

- County Nonattainment Area Historical NO X Emissions Trends

,

 Figure 4

- 3: DFW Four

- County Nonattainment Area Historical VOC Emissions Trends , and

 Figure 4

- 4 : DFW Nine

- County Nonattainment Area Historical VOC Emissions Trends

. Both 30 Texas Administrative Code (TAC) Chapter 115 : Control of Air Pollu tion from Volatile Organic Compounds and 30 TAC Chapter 117: Control of Air Pollution from Nitrogen Compounds regulations have significantly reduced overall ozone precursor emissions at both major and minor (point and area) industrial, commercial, and inst itutional sources in the DFW ozone nonattainment area. Innovative emissions reduction programs such as the Texas Emissions Reduction Plan and the AirCheckTexas Drive a Clean Machine program in 30 TAC Chapter 114: Control of Air Pollution from Motor Vehicle s have also reduced mobile source emissions, the primary source of NO X emissions in the DFW area.Page 41

Figure 4
- 1 : DFW Four

- County Nonattainment Area Historical NO X Emissions Trends

Figure 4
- 2 : DFW Nine

- County Nonattainment Area Historical NO X Emissions Trends 34.57

7.94 10.4 8.38

22.44 36.60 74.81

31.06 345.10

313.70

225.53

191.55

104.08 110.58 115.19

93.26

0 50 100 150 200 250 300 350 400

2002 2005 2008 2011 Point

Area

On-Road

Non-road Emissions in Tons Per Day

79.23

56.93
49.12

31.34 118.97 130.03 141.87

112.40

23.69 47.52 147.25

37.69 428.49

385.57

270.60 230.09

0 100 200 300 400 500

0 20 40 60 80 100 120 140 160 180 200

2002 2005 2008 2011 Point

Nonroad
Area

OnRoad Emissions in Tons Per DayPage 4 2

Figure 4
- 3 : DFW Four

- County Nonattainment Area Historical VOC Emissions Trends

Figure 4
- 4 : DFW Nine

- County Nonattainment Area Historical VOC Emissions Trends 18.76 21.42 19.01 16.15

197.27 202.36 250.92

216.47

118.39
102.95 91.73

76.71 70.11 59.57 62.11

47.54

0 50 100 150 200 250 300

2002 2005 2008 2011 Point

Area

On-Road

Non-road Emissions in Tons Per Day

26.44 29.58 31.27 27.65 228.97 235.16 304.67

262.35

136.86
117.76 103.83 87.43 78.62 67.19 70.23
53.76

0 50 100 150 200 250 300 350

2002 2005 2008 2011 Point

Area

On-Road

Non-road Emissions in Tons Per DayPage 43

4.3 Attainment Inventory Base Year The 1990 Federal Clean Air Act Amendments require that EIs be prepared for ozone nonattainment areas. Because ozone is photochemically produced in the atmosphere when VOC mix es with NO X in the presence of sunlight, the TCEQ must compile information on the sources of these precursor pollutant emissions. The EI must identify the source types present in an area, the amount of each pollutant emitted, and the types of processes and control devices employed at stationary sources or other source categories. The EI provides data for a variety of air quality planning tasks, including establishing baseline emission levels, calculating reduction targets, control strategy development for a chieving the required emission reductions, emission inputs into air quality simulation models, and tracking actual emission reductions against the established emissions growth and control budgets.

The 2012 base year inventory for the DFW area is based on t he VOC and NO X emissions that occur on a typical summer weekday. Consistent with a September 4, 1992 EPA memorandum entitled Procedures for Processing Requests to Redesignate Areas to Attainment , the attainment EI base year may be any one of the three year s used to determine the design value for the attainment year. For this DFW one

- hour and 1997 eight

- hour ozone nonattainment area s RS report , the attainment EI base year is 2012 and it is one of the three years used to determine the design value for the 201 4 attainment year. The total VOC and NO X EIs for the four one

- hour and nine 1997 eight

- hour ozone nonattainment counties in the DFW area are summarized from the estimates developed for four general categories of anthropogenic emissions sources, which

are e ach explained in Section 4.4.1: Area Sources , Section 4.4.2: On

- Road Mobile Sources

, Section 4.4.3: Non

- Road Mobile Sources , and Section 4.4.4: Stationary Point Sources

. Summaries of the 2012 VOC and NO X emissions by source type are provided in Section 4.5 : Emissions Summary

.

4.4 Future Emissions and Verification of Continued Attainment To track progress of the DFW area toward continued attainment of the one

- hour and 1997 eight

hour ozone NAAQS, the TCEQ will continue to develop and submit periodic EIs (PEI) to the EPA every three years as required by the federal Air Emissions Reporting Requirements (AERR) rule. The 2011 inventory was the first PEI submitted under the AERR. As required by the AERR, the 2011 PEI was reported to the EPA’s National Emissions Invent ory (NEI) as a comprehensive and detailed estimate of air emissions, including ozone precursors (NO X and VOC). As directed by the AERR, the 2011 Texas PEI includes annual emissions for the entire state and summer weekday emissions for the 2008 eight

- hour o zone nonattainment areas in Texas, including the DFW area. Per the EPA’s Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Imp lementation Plan Requirements; Final Rule (2008 ozone standard SIP requirements rule), published in the March 6, 2015 Federal Register (80 Federal Register 12264), s tates can rely on periodic AERR EI submittals to satisfy ongoing SIP EI submission requirements every three years.

Because the EPA has not made guidance available for how to demonstrate co ntinued attainment in a redesignation substitute , the TCEQ is using the method outlined in the EPA’s redesignation guidance 5 . Future emissions for the DFW area were projected from the base year inventory (2012) to a future year (horizon year) of 2028. Proj ecting emissions to 2028 aligns with the EPA’s requirement of maintenance plans to demonstrate attainment for a 10

- year period following the date of redesignation. The requirement for demonstration of continued attainment

5 Memorandum from John Calcagni, Director of Air Quality Man agement Division, September 4, 1992, Procedures for Processing Requests to Redesignate Areas to Attainment

. EPA Office of Air Quality Planning and Standards

.Page 44

is satisfied when the state demons trates that future VOC and NO X emissions levels are not expected to result in exceedances of the one

- hour and the 1997 eight

- hour ozone NAAQS.

Future emissions were projected to the horizon year 2028 using two

- and three

- year intervals to align milestone years with periodic AERR EI years as appropriate. A summary of the base year inventory and the future year inventories for ozone precursor emissions is presented in Section
4.5 : Emissions Summary

.

4.4.1 Area Sources Stationary source emissions data from sites an d processes that do not meet the reporting requirements for point sources are classified as area sources. Area sources are small

- scale industrial, commercial, and residential sources that generate emissions

. Emissions are calculated and reported at the cou nty level. Examples of area sources include: printing operations

, industrial coatings

, degreasing solvents

, architectural coatings, gasoline service station underground tank filling

, vehicle refueling operations

, stationary source fossil fuel combustion

, o utdoor refuse burning

, and structural fires. With some exceptions, area source emissions are calculated by multiplying an established emissions factor (emissions per unit of activity) by the appropriate activity or activity surrogate responsible for genera ting emissions. Population is one of the more commonly used activity surrogates for area sources. Other activity data include the amount of gasoline sold in an area, employment by industry type, and crude oil and natural gas production.

4.4.1.1 Updated 201 2 Base Y ear Inventories The updated 2012 base year inventory was formed using the 2011 periodic AERR EI. The periodic 20 11 inventory was developed per the AERR reporting requirements and was creat ed using a combination of methodologies and data: EPA

- generated EIs; TCEQ

- contract ed projects ; TCEQ staff projects ; and categories grown from the 200 8 EI using factors derived from study data compiled by Eastern Research Group (ERG), the Economic and Consumer Credit Analytics website ( http://www.economy.com/default.asp ), and the United States Energy Information Administration’s (EIA) a nnual e nergy o utlook publication. The documentation for the development of the ERG study factors can be found in Attachment A: Projecti on Factors for Point and Area Sources

. The EPA developed EIs for states to use for many source categories as part of the NEI. The states access these individual inventories through the EPA’s NEI w ebsite ( ftp://ftp.epa.gov/EmisInventory/2011nei/doc/ ). These source categories include but are not limited to: industrial coatings; degreasing; residential, commercial/institutional, and industrial fuel use; commercial cooking; aviation fuel use; and consu mer products . For some source categories, the TCEQ developed state

- specific emissions estimates by acquiring current state

specific activity data and applying appropriate emissions factors. These source categories include but are not limited to : storage ta nks

, structural fires

, dry cleaners

, and automobile fires

. The 2012 base year inventory was grown from the 2011 periodic AERR EI using factors derived from Attachment A: Projection Factors for Point and Area Sources

. In particular, the TCEQ focused on refining oil and gas area source inventory production categories for the EI . The improvements included the development and refinement of a state

specific oil and gas area source emissions calculator. This oil and gas area source emissions calculator uses c ounty

- level production and local equipment activity data with local emissions requirements to estimate emissions from individual production categories including compressor engines, condensate and oil storage tanks, loading operations, mud degassing, pump e ngines, heaters, and dehydrators. The documentation for the development of the oil and gas emissionsPage 45

calculator can be found in Attachment B : Characterization of Oil and Gas Production Equipment and Develop a Methodology to Estimate Statewide Emissions

. A significant improvement made to the oil and gas calculator was the development of refined emission s factors for VOC emissions from condensate storage tanks. The documentation for the refined emission s factors can be found in Attachment C : Condensate Tank O il and Gas Activities

. In addition, further improvements were made to the oil and gas calculator through the development of region

- specific emissions factors for mud degassing, updated region

- specific equipment profiles, and year specific engine emissions factors for hydraulic pump engines. The documentation for these refined factors can be found in Attachment D: Specified Oil and Gas Well Activities Emissions Inventory Update . The 2012 base year inventory for oil and gas area sources was developed using 20 12 activity data and production information from the Railroad Commission of Texas (RRC).

For those area source categories affected by TCEQ rules, rule effectiveness factors are applied to the baseline or uncontrolled emissions to estimate controlled emissi ons . These factors address the efficiency of the controls and the percentage of the category’s population affected by the rule. Quality assurance of area source emissions involves ensuring that the activity data used for each separate category is current a nd valid. Data such as current population figures, fuel usage, and material usage were updated and the EPA guidance on emissions factors was used. Other routine efforts such as checking calculations for errors and conducting completeness and reasonableness checks were implemented.

4.4.1.2 Updated Milestone Years Inventories The updated base year (2012), milestone years (2014, 2017, 2020, 2023, and 2026) and horizon year (2028) EIs for most area source categories were developed using factors derived from Attachment A: Projection Factors for Point and Areas Sources , the Economic and Consumer Credit Analytics website ( http://www.economy.com/default.asp ), and the EIA’s annual energy outlook publication . The ERG

- derived factors contain individual growth factors for each category and for each forecasting year. This projection method is the EPA standard and accepted method for developing future year EIs.

F or DFW counties with oil and gas production that reside in the Barnett Shale area , specifically Dallas, Denton, Ellis, Johnson, Parker, and Tarrant Counties, growth factors from the report in Attachment E : Forecasting Oil and Gas Activities , were used. These ERG

- derived factors deal specifically with oil and gas sourc es in the Barnett Shale area and employ category

- oriented growth factors for each forecasting year.

The updated milestone year area source emissions inventories were developed by applying the selected growth factors to the baseline emissions for each area source category to account for any growth in emissions. Rules controlling emissions from industrial coatings, portable fuel containers, 30 TAC Chapter 117 Subchapter D controls on minor sources in ozone nonattainment areas, and gasoline station underground tank filling (Stage I) and vehicle refueling (Stage II) were accounted for in the base year inventory.

In addition, New Source Performance Standard (NSPS) OOOO controls on upstream oil and gas sources became fully applicable after the 2012 base year. Ther efore, these controls were not incorporated in the base year inventory. Additionally, the NSPS OOOO controls were not incorporated into the milestone year inventories because they are not needed to demonstrate maintenance.Page 46

4.4.1.3 Area Source Emissions Inventorie s The DFW area source base year (2012), milestone years (2014, 2017, 2020, 2023, and 2026) and horizon year (2028) EIs for NO X and VOC for the two DFW ozone nonattainment areas are summarized in the following tables:

 Table 4

- 1: DFW Area Source Four

- County One

- Hour Ozone Nonattainment Area NO X and VOC Emissions (tons per day) , and

 Table 4

- 2: DFW Area Source Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area NO X and VOC Emissions (tons per day)

.

Table 4
- 1 : DFW Area Source Four

- County One

- Hour Ozone Nonattainment Area NO X and VOC Emissions (tons per day)

Pollutant 201 2 2014 2017 2020 2023 2026 2028

NO X 28.54 29.41 27.79 25.96 24.90 24.68 24.68

VOC 218.90 224.51 218.56 211.43 209.81 210.69 211.77

Table 4
- 2 : DFW Area Source Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area NO X and VOC Emissions (tons per day)

Pollutant 201 2 2014 2017 2020 2023 2026 2028

NO X 33.60 34.77 32.01 28.98 27.37 26.97 26.93

VOC 265.43 273.08 260.19 245.76 241.13 241.19 242.15

4.4.2 On

- Road Mobile Sources
On

- road mobile emission sources consist of automobiles, trucks, motorcycles, and other motor vehicles traveling on public roadways. On

- road mobile source emissions are usually categorized as either combustion

- related emissions or evaporative hydrocarbon emissions. Combustion

related emissions are estimated for vehicle engine exhaust. Evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative

- leak sou rces on the vehicle. To calculate emissions, both the rate of emissions per unit of activity (emissions factors) and the number of units of activity must be determined. The emissions factors for on

- road mobile sources are determined using models developed and approved by the EPA. The models allow for input of local conditions and vehicle characteristics. The activity information corresponding to the emissions factors is obtained using local travel demand models (TDM) , the output from the highway performance monitoring system, and speed models.

In March 2010, the EPA released the Motor Vehicle Emissions Simulator (MOVES) model as the official emissions factor model for developing on

- road mobile source category EIs . Although MOVES represented a new approach to assessing on

- road emissions, the sources are the same, and the opportunity to use local inputs for meteorological conditions, control programs, and fleet characteristics remains. When using MOVES in emission

- rates mode, emission rates are produced for sub sets of the on

- road fleet, and the emission rates are multiplied by the activity level of each vehicle type or source

- use type to calculate emissions.

T he on

- road mobile source category EIs for this DFW one

- hour and 1997 eight

- hour ozone RS report were dev eloped using the latest version of the MOVES model that is available, MOVES 2014. The EPA made MOVES2014 available on July 31, 2014; officially released the MOVES2014 version of the model as a replacement to MOVES2010b for SIP applications onPage 47

October 7, 201 4 (70 FR 60343); and released an update to the model on October 27, 2014. The TCEQ
, working with the North Central Texas Council of Governments ( NCTCOG )

, recently completed MOVES2014

- based 201 2 , 2014, 2017, 2020, 2023, 2026, and 202 8 on

- road emission inven tories for the DFW area. The planning assumptions, fleet characteristics, and vehicle miles traveled (VMT) estimates were updated to incorporate the latest available information at the time the inventories are developed.

To estimate on

- road mobile source emissions, emissions rates calculated by the MOVES model are multiplied by the level of vehicle activity. On

- road mobile source emissions factors are expressed in units of grams per mile, grams per vehicles (evaporative), and grams per hour (extended idle mode) ; therefore, the activity data required to complete the inventory calculation are VMT in units of miles per day , vehicle populations, and source hours idling . The level of vehicle travel activity is developed using a TDM run by the Texas Department of Transportation or by the local metropolitan planning organization. The TDMs are validated against a large number of ground counts, i.e., traffic passing over counters placed in various locations throughout a county or area. For SIP and reporting inventori es, VMT estimates are calibrated against outputs from the federal highway performance monitoring system, a model built from a different set of traffic counters. Vehicle populations by source type are derived from the Texas Department of Motor Vehicle regis tration database and, as needed, national estimates for vehicle source type population.

In addition to the number of miles traveled on each roadway link, the speed on each roadway type or segment is also needed to complete an on

- road EI. Roadway speeds, re quired inputs for the MOVES model, are calculated by using the activity volumes from the TDM and a post

processor speed model.

4.4.2.1 On

- R oad Mobile Source Emissions Inventories
The 201 2 , 2014, 2017, 2020, 2023, 2026, and 202 8 on

- road mobile source EI s for th is D FW

one

- hour and 1997 eight

- hour ozone RS report were developed by the NCTCOG using the latest available data, current emissions factors and models, and the most current planning assumptions. The inventories include the four DFW

- area counties designated as nonattainment for the one

- hour ozone NAAQS and the nine DFW

- area counties designated as nonattainment for the 1997 eight

- h our o zone NAAQS.

Consistent with on

- road inventory development procedures for reporting requirements and reasonable further progress demonstration state implementation plans , the on

- road inventories for each of these calendar years are based on VMT estimates and emission rates for an average summer weekday. MOVES2014 , which is the latest available version of the EPA’s MOVES model, was u sed to estimate the summer weekday emission rates in units of grams per mile for NO X and VOC.

The roadway link

- level VMT estimates were obtained from travel demand modeling for each of the DFW count ies for each analysis year. Two me thods are used to estab lish VMT: a federal system, the Highway Perform ance Monitoring System (HPMS); and a local system, a travel demand model (TDM) . For historical years, the HPMS data constitutes the official measurement of highway performance, including VMT. The TDM represents the best method for distributing VMT to the roadway links within the local travel network and for predicting future year VMT. To provide consistency between the estimates for the two systems, the TDM

- forecasted VMT estimates are adjusted using a VMT ratio based on an historical year for which the TDM was validated and the HPMS data has been made available. A summary of the on

- road mobile source VMT used to develop the various NO X and VOC emission s estimates for the four

- county one

-Page 48

hour and the ni ne

- county 1997 eight

- hour ozone nonattainment areas are presented separately in the following tables:

 Table 4

- 3 : DFW Four

- County One

- Hour Ozone Nonattainment Area VMT (miles per average summer day) , and

 Table 4

- 4 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area VMT (miles per average summer day )

.
Table 4
- 3 : DFW Four

- County One

- Hour Ozone Nonattainment Area VMT (miles per average summer day)

Table 4
- 4 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area VMT (miles per average summer day)

Year Vehicle Miles Traveled

2012 183,855,804

2014 193,671,709

2017 212,516,292

2020 226,113,715

2023 238,584,779

2026 251,758,922

2028 265,309,733

The on

- road mobile source 201 2 , 2014, 2017, 2020, 2023, 2026, and 202 8 EI s for NO X and VOC for the DFW nonattainment areas are summarized in the following tables:

 Table 4

- 5 : DFW Four

- County One

- Hour Ozone Nonattainment Area Average Summer Weekday NO X and VOC Emissions for On

- Road Mobile Sources (tons per day) , and

 Table 4

- 6 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Average Summer Weekday NO X and VOC Emissions for On

- Road Mobile Sources (tons per day)

. For complete documentation of the development of the on

- road mobile source EI s for th e DFW

one

- hour and 1997 eight

- hour ozone nonattainment areas RS SIP revision, including the inventory development methods, MOVES inputs, and the results

, refer to Appendix F : Development of DFW On

- Road Emission Inventories for the Years 2012, 2014, 2017, 2020, 2023, 2026
, and 2028

. The complete s et of input and output files are available from the Emissions Assessment Section of the TCEQ Air Quality Division upon request. Year Vehicle Miles Traveled

2012 158,968,136

2014 166,904,345

2017 182,658,562

2020 193,804,121

2023 203,852,679

2026 214,346,979

2028 225,718,496Page 49

Table 4
- 5 : DFW Four

- County One

- Hour Ozone Nonattainment Area Average Summer Weekday NO X and VOC Emissions for On

- R oad Mobile Sources (tons per day)
Pollutant 201 2 2014 2017 2020 2023 2026 2028

NO X 1 7 1

. 2 0 1 4 7

. 4 2 96

. 7 4 69

. 6 7 54

. 4 4 43

. 3 3 38

. 8 3

VOC 78

. 5 6 71

. 2 0 55

. 5 9 46

. 8 1 41

. 5 3 35

. 8 5 32

. 9 4

Table 4
- 6 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Average Summer Weekday NO X and VOC Emissions for On

- R oad Mobile Sources (tons per day)
Pollutant 201 2 2014 2017 2020 2023 2026 2028

NO X 2 1 6

. 7 4 1 8 8

. 6 5 1 2 9

. 1 9 95

. 9 5 77

. 8 7 64

. 6 2 59

. 7 5

VOC 92

. 1 7 83

. 7 5 65

. 6 2 55

. 3 6 49

. 2 1 42

. 7 0 39

. 4 9

4.4.2.2 On

- R oad Mobile Source Control Strategies

The on

- road mobile EIs for each analysis year were developed using MOVES2014 emission s factors that reflect all control strategies used to demonstrate maintenance of the one

- hour and 1997 eight

- hour ozone NAAQS. The controls that were modeled include: pre

- 1990 Federal Motor Vehicle Control Program ( FMVCP ) , fleet turnover to Tier 1 of the FMVCP, fleet turnover to Tier 2 of the FMVCP, the 2007 heavy duty diesel FMVCP, fleet turnover to Tier 3 of the FMVCP, the lower sulfur gasoline associated with Tier 3 FMVCP, the Nation al Low Emission Vehicle (NLEV) p rogra m , summer reformulated gasoline ( RFG )

, the Texas Regional Low RVP, the DFW vehicle inspection and maintenance ( I/M ) program, the DFW anti

- tampering program, and Texas Low Emission Diesel (TxLED). The federal RFG program was implemented in the four DFW one

- hour counties. The Texas Regional Low RVP Program does not include RFG counties and is modeled only for Ellis, Johnson, Kaufman, Parker

, and Rockwall Counties

. The DFW I/M program began in 1990 in Dallas and Tarrant counties; was expanded in 2002 and 2003 to include additional counties; and now includes all nine DFW one

- hour and 1997 eight

- hour ozone nonattainment counties. A summary of the DFW on

- road mobile source control strategies used for th is DFW one

- hour and 1997 eight

- hour ozone RS report are presen ted in Table 4

- 7 : DFW On

- Road Mobile Control Strategies Summary

.

Table 4
- 7 : DFW On

- Road Mobile Control Strategies Summary
Control Program Description Year Control

Program Started Control Scenario Notes

Pre

- 1990 FMVCP Pre

- 1990 Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028

Anti

- Tampering Program 1986 Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028
1992 Federal Controls on Gasoline Volatility 1992 Maximum Reid Vapor Pressure of 7.8 pounds per square inch (psi)

Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028

Tier 1 FMVCP 1994 Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028Page 50

Control Program Description Year Control

Program Started Control Scenario Notes

RFG Phase 1 1995 for Phase 1 Collin, Dallas, Denton, and Tarrant Counties

Superseded by RF G Phase 2 I/M Program 1990 thru 2003 Dallas and Tarrant Counties (1990); Collin and Denton Counties added (2002); Ellis, Johnson, Kaufman, Parker

, and Rockwall Counties added (2003)
RFG Phase 2 2000 for Phase 2 Collin, Dallas, Denton

, and Tarrant Counties

Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028 Texas Regional Low RVP 2000 Ellis, Johnson, Kaufman, Parker

, and Rockwall
Counties

Max imum summertime RVP of 7.8 psi NLEV Program 2001 Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028

Tier 2 FMVCP 2004 Phase d in from 2004 to 2009

Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028

TxLED 2006 Low aromatic hydrocarbon and high cetane number to control NO X

Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028
Federal Low Sulfur Highway Diesel 2006 15 ppm maximum sulfur content

Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028 2007 Heavy Duty FMVCP 2007 Phase d in from 2007 to 2010

Included for 2012 , 2014, 2017, 2020, 2023

, 2026, and 2028

Tier 3 FMVCP 2017 Will be phased in from 2017 to 2025 Lower sulfur gasoline associated with Tier 3
FMVCP 2017 10 ppm maximum gasoline sulfur

4.4.2.3 On

- Road Mobile Source Control Strategy Reductions

Due to the on

- road mobile source control programs in place for each analysis year, the on

- road NO X and VOC emiss ions are steadily decreasing fro m the base year of 201 2 to each milestone year and the 202 8 horizon year despite projected growth in VMT for all milestone years , for both the one

- hour and 1997 eight

- hour ozone nonattainment county groups . A summary of thePage 51

tons per day (tpd) change from the 201 2 base year to each milestone year and the horizo n year are summarized in the following tables:

 Table 4

- 8 : DFW Four

- County One

- Hour Ozone Nonattainment Area Estimated On

- road Mobile Sources Reduction s from 2012 Baseline Due to FMVCP, I/M, RFG, and TxLED (tons per day ), and

 Table 4

- 9: DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Estimated On

road Mobile Sources Reductions from 2012 Baseline Due to FMVCP, I/M, RFG, and TxLED (tons per day)

A summary of the percent change in NO X and VOC from the 201 2 base year to each milestone year and the horizo n year are summarized in the following tables:

 Table 4

- 10: DFW Four

- County One

- Hour Ozone Nonattainment Area Estimated Percent On

- road Mobile Sources Reductions from 2012 Baseline Due to FMVCP, I/M, RFG, and TxLED , and

 Table 4

- 11: DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Estimated Percent On

- road Mobile Sources Reductions from 2012 Baseline Due to FMVCP, I/M, RFG, and TxLED

.

Table 4
- 8 : DFW Four

- County One

- Hour Ozone Nonattainment Area Estimated On

- road Mobile Sources Reductions from 2012 Ba seline 1 Due to FMVCP, I/M, RFG, and TxLED (tons per day)

Inventory Year NO X (tons per day) VOC (tons per day)

201 2 0 0

2014

- 23.78

- 7.36

2017

- 74.46

- 22.97

2020

- 101.53

- 31.75

2023

- 116.76

- 37.03

2026

- 127.87

- 42.71

2028

- 132.37

- 45.62 Note 1: The four county 2012 on

- road emissions levels from which the reductions are taken are: 171.20 tpd NO X and 78.56 tpd VOC (see Table 4

- 5)Page 52

Table 4
- 9 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Estimated On

- road Mobile Sources Reductions from 2012 Ba seline 2 Due to FMVCP, I/M, RFG, and TxLED (tons per day)

Inventory Year NO X (tons per day) VOC (tons per day)

201 2 0 0

2014

- 28.09

- 8.42

2017

- 87.55

- 26.55

2020

- 120.79

- 36.81

2023

- 138.87

- 42.96

2026

- 152.12

- 49.47

2028

- 156.99

- 52.68 Note 2: The nine county 2012 on

- road emissions levels from which the reductions are taken are: 216.74 tpd NO X and 92.17 tpd VOC (see Table 4

- 6)

Table 4
- 10 : DFW Four

- County One

- Hour Ozone Nonattainment Area Estimated Percent On

- road Mobile Sources Reductions fro m 2012 Ba seline 3 Due to FMVCP, I/M, RFG, and TxLED
Inventory Year NO X % Reductions VOC % Reductions

201 2 0 0

2014

- 13.9

- 9.4

2017

- 43.5

- 29.2

2020

- 59.3

- 40.4

2023

- 68.2

- 47.1

2026

- 74.7

- 54.4

2028

- 77.3

- 58.1 Note 3: The four county 2012 on

- road emissions levels from which the percent reductions are taken are: 171.20 tpd NO X and 78.56 tpd VOC (see Table 4

- 5)

Table 4
- 11 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Estimated Percent On

- road Mobile Sources Reductions from 2012 Ba seline 4 Due to FMVCP, I/M, RFG, and TxLED
Inventory Year NO X % Reductions VOC % Reductions

201 2 0 0

2014

- 13

- 9.1

2017

- 40.4

- 28.8

2020

- 55.7

- 39.9

2023

- 64.1

- 46.6

2026

- 70.2

- 53.7

2028

- 72.4

- 57.2
Note 4 : The nine county 2012 on

- road emissions levels from which the percent reductions are taken are: 216.74 tpd NO X and 92.17 tpd VOC (see Table 4

- 6)Page 53

4.4.3 Non

- Road Mobile Sources

Non

- road vehicles do not typically operate on roads or highways and are often referred to as off

road or off

- highway vehicles. The non

- road source category is composed of a diverse collection of equipment. Non

- road emissions sources include but are not limited to: agricultural equipment, construction and mining equipment, lawn and g arden equipment, aircraft and airport equipment, locomotives, commercial marine vessels (CMV), and drilling rigs. EIs for

non

- road sources developed as subcategories include: NONROAD model categories, airports, CMVs, drilling rigs, and locomotives. Note CM V activities do not apply to the DFW area; therefore all counties in the DFW area will indicate zero emissions for CMV activities. The following sections describe the emissions calculation methods used for the non

- road mobile source subcategories.

4.4.3.1 Updated 2012 Base Year Inventories
A Texas

- specific version of the EPA’s latest NONROAD 2008a model, called the Texas NONROAD (TexN) model, was used to calculate emissions for all non

- road mobile source equipment and recreational vehicles, with the exception of ai rports, locomotives, and drilling rigs. Several equipment survey studies have been conducted that focused on various equipment categories operating in different areas in Texas. The resulting survey data are used as inputs to the TexN model to more accurate ly estimate non

- road emissions for the State of Texas instead of using the national default values in the EPA’s NONROAD2008a model. Documentation of methods and procedures used in developing NONROAD model category EIs can be found in Attachment G : Developm ent of Air Emissions Inventories for NONROAD Model Category Mobile Sources (Task 3)

. The United States Federal Aviation Administration’s Emissions and Dispersion Modeling System, Version 5.1.3 (EDMS) was used with updated activity data to calculate airport source emissions. These airport emissions sources include aircraft engines, auxiliary power units, and ground support equipment. To estimate the emissions from the airport sources, a survey was conducted by ERG under contract with the TCEQ to collect upda ted information on aircraft activity, fleet mix, and other EDMS model input parameters. Documentation of methods and procedures used in developing DFW area airport EIs can be found in Attachment H : Airport Emissions Inventories for Houston

- Galveston

- Brazor ia and Dallas

- Fort Worth Areas for Select Years 2012, 2014, 2017, 2020, 2023, 2026, and 2028

.

The 2012 Texas l ocomotive EI includes Class I, II, and III locomotive activity and emissions by rail segment for all counties within Texas. Locomotive line

- haul and yard activity data were compiled from companies operating in Texas and from additional resources identified by contractor ERG to create a county

- level Class I line

- haul inventory. Data developed by Eastern Regional Technical Advisory Committee in collaboration with the Federal Railroad Administration, the American Short Line and Regional Railroad Association (ASLRRA), and members of the Class II and III railroad communities used 2008 activity and emissions profiles for Class II and Class III railro ads. To calculate annual gallons of fuel used by railroads, data compiled by ASLRRA from the Class II and III railroads, including total industry fuel use in 2008 for locomotives and total Class II/III route miles, were used. Based on the EIA’s latest

annu al energy outlook publication, 2008 fuel usage values were grown to estimate 2012 emissions. Documentation of methods and procedures used in developing the l ocomotive EIs can be found in Attachment I : Controlled and Uncontrolled Average Summer Weekday Loco motive Inventories for Houston

- Galveston

- Brazoria and Dallas

- Fort Worth Areas for Select Years 2012, 2014, 2017, 2020, 2023, 2026, and 2028

.Page 54

The 2012 inventory for the drilling rig diesel engines was developed based on a statewide EI improvement study and updated with 2012 activity data. A survey of oil and gas exploration and production companies was used to develop improved drilling rig emissions characterization profiles. Documentation of methods and procedures used in developing the drilling rig diesel engine EIs can be found in Attachment J : Development of Texas Statewide Drilling Rigs Emissions Inventories for the Years 1990, 1993, 1996, and 1999 through 2040 . The drilling rig emissions characterization profiles from this study were combined with 2012 drilling activity data obtained from the RRC to develop the 2012 inventory.

4.4.3.2 Updated Milestone Years Inventories The updated milestone year inventories for the NONROAD model categories were developed using the most recent version of the TexN 2008a model (ve rsion 1.7). The TexN model runs were performed by ERG for the analyses years 2012, 2014, 2017, 2020, 2023, 2026, and 2028 to estimate the average summer weekday emissions for the NONROAD model categories. For more details, please see Attachment G: Developm ent of Air Emissions Inventories for Non

- Road Model Category Mobile Sources (Task3)

. The TexN model contains unique population files for all 254 Texas counties that have been developed for every possible analysis year (1970 to 2050) within the TexN model, using county and source category classification

- specific growth factors. Due to fluctuations in engine activity and their associated surrogates, the TexN population files

are periodically updated with new growth factors such as those available on the Economic and Consumer Credit Analytics website ( https://www.economy.com ) to support more accurate forecasting and back

- casting of emissions

. The updated milestone year inventories for the following source categories were developed based on studies found in the appendices listed below.

 NONROAD model category mobile sources inventories were based on the ERG study found in Attachment G: Development of Air Emissions Inventories for Non

- Road Model Category Mobile Sources (Task3 )

,

 airport source inventories were based on the ERG study found in Attachment H: Airport Emissions Inventories for Houston

- Galveston

- Brazoria and Dallas

- Fort Worth Areas for Select Years 2012, 2014, 2017, 2020, 2023, 2026, and 2028,

 l ocomotive inventories were based on the ERG study found in Attachment I : Controlled and Uncontrolled Average Summer Weekday Locomotive Inventories for Houston

- Galveston

Brazoria and Dallas

- Fort Worth Areas for Select Years 2012, 2014, 2017, 2020, 2023, 2026, and 2028 , and

 drilling rig inventories were based on the ERG study found in Attachment J: Development of Texas Statewide Drilling Rigs Emission Inventories for the Years 1990, 1993, 1996, and 1999 through 2040

.

The updated milestone year inventories for drilling rigs we re based on the 2012 inventory developed using the drilling rig emissions characterization profiles from the ERG report in Attachment J : Development of Texas Statewide Drilling Rigs Emission Inventories for the Years 1990, 1993, 1996, and 1999 through 2040 combined with 2012 drilling rig activity data from the RRC. The 2012 inventory was then projected to future years using growth factors. Documentation on the development of growth factors can be found in Attachment A : Projection Factors for Point and Area Sources

.Page 55

4.4.3.3 Non

- Road Mobile Source Emissions Inventories
The non

- road mobile source NO X and VOC emissions for the 2012 through 2028 milestone
years for the DFW area are presented in :

 Table 4

- 12 : DFW Four

- County One

- Hour Ozone Nonattainment Area NO X Emissions for Non

- Road EI Categories (tons per day)

,

 Table 4

- 13: DFW Four

- County One

- Hour Ozone Nonattainment Area VOC Emissions for Non

- Road EI Categories (tons per day)

,

 Table 4

- 1 4 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area NO X Emissions for Non

- Road EI Categories (tons per day)

, and

 Table 4

- 1 5 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area VOC Emissions for Non

- Road EI Categories (tons per day)

. Please note that although drilling rig VOC emissions for 2026 and 2028 are shown as 0.00 tons per day in Tables 4

- 13 and 4

- 15, there are actually small amounts of drilling rig VOC emissions forecasted for these two years. These emissions are below 0.005 tons per day for each of the forecasted years, so the values round downwards to zero.

Table 4
- 12 : DFW Four

- County One

- Hour Ozone Nonattainment Area NO X Emissions for Non

- R oad EI Categories (tons per day)
Category 201 2 2014 2017 2020 2023 2026 2028 Airport 10.12 11.28 12.34 13.31 14.19 15.24 16.07

Commercial Marine Vessels 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Drilling Rigs 3.75 4.08 2.56 1.00 0.32 0.10 0.04

Locomotive 10.33 10.12 8.89 8.21 7.45 6.33 5.71 NONROAD Model Categories 52.75 46.81 37.77 30.79 26.91 24.69 23.84

Non

- road Total 76.95 72.29 61.56 53.31 48.87 46.36 45.66

Table 4
- 13 : DFW Four

- County One

- Hour Ozone Nonattainment Area VOC Emissions for Non

- Road EI Categories (tons per day)

Category 201 2 2014 2017 2020 2023 2026 2028 Airport 2.95 3.14 3.41 3.64 3.85 4.09 4.28

Commercial Marine Vessels 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Drilling Rigs 0.18 0.19 0.12 0.05 0.02 0.00 0.00

Locomotive 0.60 0.56 0.46 0.40 0.36 0.30 0.27

NONROAD Model Categories 37.66 32.59 28.6 26.99 26.81 27.13 27.53

Non

- road Total 41.39 36.48 32.59 31.08 31.04 31.52 32.08Page 56

Table 4
- 14 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area NO X Emissions for Non

- R oad EI Categories (tons per day)
Category 201 2 2014 2017 2020 2023 2026 2028 Airport 10.1 5 11. 31 12. 37 13. 34 14. 22 15. 28 16. 11

Commercial Marine Vessels 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Drilling Rigs 4.97 5.40 3.40 1.33 0.43 0.13 0.06

Locomotive 14.36 14.04 12.24 11.25 10.16 8.61 7.74 NONROAD Model Categories 63.50 56.08 44.82 36.18 31.40 28.69 27.64

Non

- road Total 92.98 86.83 72.83 62.10 56.21 52.71 51.55

Table 4
- 15 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area VOC Emissions for Non

- Road EI Categories (tons per day)

Category 201 2 2014 2017 2020 2023 2026 2028 Airport 3. 02 3. 22 3. 49 3 .72 3. 92 4. 17 4. 36

Commercial Marine Vessels 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Drilling Rigs 0.24 0.26 0.16 0.06 0.02 0.01 0.00

Locomotive 0.83 0.76 0.61 0.53 0.47 0.40 0.35

NONROAD Model Categories 42.78 37.10 32.47 30.47 30.14 30.42 30.82

Non

- road Total 46.87 41.34 36.73 34.78 34.55 35.00 35. 53

4.4.4 Stationary Point Sources

4.4.4.1 Emissions Inventory Development Stationary point source emissions data are collected annually from sites that meet the reporting requirements of 30 TAC §101.10. This rule, referred to as the TCEQ emissions inventory reporting rule, establishes EI reporting thresholds in ozone nonattainme nt areas that are currently at or less than major source thresholds in the DFW ozone nonattainment area. Therefore, some minor sources in the DFW ozone nonattainment area report to the point source EI

. To collect the data, the TCEQ sends notices to sites i dentified as potentially meeting the reporting requirements. Companies are required to report emissions data and to provide sample calculations used to determine the emissions. Information characterizing the process equipment, the abatement units, and the emission points is also required.

All data submitted in the emissions inventory questionnaire ( EIQ ) are reviewed for quality

assurance purposes and then stored in the State of Texas Air Reporting System (STARS) database. EIQ guidance documents and historic al point source emissions of major pollutants are available on the TCEQ’s Point Source Emissions Inventory Web page (https://www.tceq.texas.gov/airquality/point

- source

- ei/psei. html). Additional information is available upon request from the TCEQ’s Air Quality Division.

4.4.4.2 Updated 2012 Base Year Inventory The TCEQ extracted the 201 2 point source inventory data from STARS on June 5 , 2014. The extracted data included reported annual a nd ozone season daily emissions of NO X and VOC forPage 57

each site in the DFW area for which a 201 2 E IQ was submitted and reflected revisions made on or before the extract date.

4.4.4.3 Updated Milestone Year Inventories The TCEQ designated the 2013 EI as the starting p oint for emissions inventory projections for each of the milestone years because it was the most recent point source EI data available. Using the most recent point source EI data captures the most recent economic conditions and any recent applicable contro ls, which can improve the accuracy of emissions projections. The TCEQ extracted the 2013 point source inventory data from STARS on March 4, 2015. The extracted data included reported annual and ozone season daily emissions of NO X and VOC for each site in
t he DFW area that submitted a 2013 EIQ and reflected revisions made on or before the extract date.

In the development of the milestone year inventories for each ozone precursor (NO X and VOC), the TCEQ projected future emissions from major and minor sources separately when appropriate and then added unused emissions reductions credits to the inventories. Further details are explained below. Title V operating permit data were reviewed to identify sites that were major for NO X or VOC.

NO X emissions from electri c generating units (EGU) and cement kilns were projected separately from other sources. EGU emissions were projected using Cross State Air Pollution Rule (CSAPR) allocations

. Ozone season allocations were averaged over the 153 day season to obtain milestone year projections for 2017 and beyond. No CSAPR allocations were available for 2014 so EGU emissions for 2014 were projected using growth factors; the projected values for NO X emissions were within 0.01 tons per day (tpd) of NO X emissions reported to the EPA’s Clean Air Markets Division under the Acid Rain Program. Emissions from other non

- CSAPR units at EGU sites were projected using growth factors. Cement kiln emissions for 2017 and beyond were projected using the 30 TAC Chapter 117 cap, which li mits future emissions growth to the cap levels. The 30 TAC Chapter 117 cap provides a conservative estimate of emissions growth

. Other major source emissions were projected by adding emissions growth allowed under the major modification thresholds. Specifi cally, NO X emissions from non

- EGU and non

- cement sites identified as major sources of NO X emissions and VOC emissions from sites identified as major sources of VOC emissions were projected using the moderate nonattainment major modification threshold of 40 tons per year

. The moderate nonattainment threshold was selected based upon the DFW area’s classification for the 2008 ozone NAAQS. Title V operating permit data from 201 4 were reviewed to identify major sources of NO X and VOC emissions. For each site ide ntified

, a daily average of this growth was calculated by prorating the annual 40

- ton major modification threshold by the site

- wide ratio of ozone season to annual emissions to provide a one

- time growth limit added to the site’s 201 3 emissions. To maintain a conservative approach, all growth was taken into account for the 2017 milestone year inventory.

For minor sources, NO X and VOC emissions were projected using emission s trend data and growth factors for each milestone year . Emission s trends for each site were established using 2009 through 201 3 annual emissions data. For sites with decreasing emission trends, milestone year inventories were set equal to the 201 3 baseline inventory. For sites with increasing emission trends, milestone year inventories were determined by applying growth factors to the

201 3 baseline inventory. The growth factor information can be found in Attachment A. To maintain a conservative approach, any growth factors that projected a decrease in future emissions we re modified so that emissions for these source categories remained equal to the 2013 baseline inventory through future years

.Page 58

Finally, each of the milestone year inventories were adjusted to account for available (unused) emissions credits. Emissions credi ts are banked emissions reductions that may return to the air shed in the future through the use of these emissions credits either to modify existing facilities, construct new facilities, or by facilities to demonstrate compliance with emissions limit obli gations where provided for in commission rules . To account for the possible use of the banked NO X and VOC emissions, available Emissions Reduction Credit (ERC) and Discrete Emissions Reduction Credit (DERC) data for DFW were added to the inventories as discussed below

. Projected ERC use was determined by assuming that banked ERCs would be used for offsets in permitting new or modified sources. In ozone nonattainment areas, ERCs used to permit new or modified sources must be reduced by a factor called the ‘offset ratio’ to assist with ensuring progress towards attaining air quality standards. Therefore, available ERCs were reduced by 15% (i.e., divided by 1.15 to account) for the Nonattainment New Source Review permitting offset ratio for moderate ozon e nonattainment areas since the area would be classified as moderate nonattainment upon redesignation. Applying the moderate ozone nonattainment offset ratio (1.15 to 1) instead of the serious ozone nonattainment offset ratio (1,2 to 1) to unused credits

c onservatively estimates growth: since less credits are needed to offset emissions from new or modified sources, the amount of credits available to return to the airshed increases.

All available ERCs listed in the emissions banking and trading database as o f January 15, 2015 were added to each milestone year starting with 2017. This includes transactions with available information for the period 2008 to 2014 to account for credits taken from the bank and applied to projects that may not have been completed i n time for the 2013 inventory.

Projected VOC DERC use was determined by assuming that all available credits would be used over the 2017 to 2028 timespan. The credits were averaged over the 2017 to 2028 projected timespan to obtain a yearly amount

. The year ly amount was averaged over the DFW ozone season to obtain a daily contribution and added to the projected inventories. The DERC transactions between 2008 and 2014 were not applied as they were used for one

- time compliance projects applicable to, and refle cted in, emissions for those years only.

Projected NO X DERC use was determined by using the flow control value of 17.0 tons per day as listed in 30 TAC § 101.379 adopted June 3, 2015. This approach is conservative and simplified; historical use has been co nsiderably less. The flow control value of 17.0 tpd is added to each of the 2017 through 2028 milestone year NO X emissions.

A summary of the point source inventories is presented in the following tables:

 Table 4

- 16 : DFW Four

- County One

- Hour Ozone Nonattain ment Area Point Source NO X and VOC Emissions (tons per day)

 Table 4

- 1 7 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Point Source NO X and VOC Emissions (tons per day)

Table 4
- 16 : DFW Four

- County On e - Hour Ozone Nonattainment Area Point Source NO X and VOC Emissions (tons per day)

Pollutant 2012 2014 2017 2020 2023 2026 2028

NO X 8.47 8.79 29.47 29.57 29.65 29.71 29.76

VOC 11.11 11.02 11.52 11.71 11.86 11.99 12.08Page 59

Table 4
- 17 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area Point Source NO X and VOC Emissions (tons per day)

Pollutant 2012 2014 2017 2020 2023 2026 2028

NO X 30.80 31.25 62.38 62.49 62.57 62.64 62.71

VOC 27.66 28.61 29.46 29.97 30.41 30.82 31.10

4.5 E missions S ummary The 2012 base year and the 2014, 2017, 2020, 2023, 2026, and 2028 future year EI summaries by source categories for the DFW four one

- hour and nine 1997 eight

- hour ozone n onattainment areas are shown in:

 Table 4

- 18: DFW Four

- County One

- Hour Ozone Nonattainment Area NO X Emissions by Source Category (tons per day)

,

 Table 4

- 19 : DFW Four

- County One

- Hour Ozone Nonattainment Area VOC Emissions by Source Category (tons per day)

,

 Table 4

- 20 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area NO X Emissions by Source Category (tons per day) , and

 Table 4

- 21 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area VOC Emissions by Source Category (tons per day).

These tables illustrate that in the horizon year of 2028, mobile sources (on

- road and non

- road) contribute the most NO X emissions and area sources contribute the most VOC emissions for both the DFW four one

- hour and nine 1997 eight

- hour ozone nonattainment counties. Contributions from biogenic emissions are not included in the summary because this analysis is limited to anthropogenic sources.

Table 4
- 18 : DFW Four

- County One

- Hour Ozone Nonattainment Area NO X Emissions by Source Category (tons per day)

Category 201 2 2014 2017 2020 2023 2026 2028

Point Sources 8.47 8.79 29.47 29.57 29.65 29.71 29.76

Area Sources 28.54 29.41 27.79 25.96 24.90 24.68 24.68

On

- Road Mobile Sources (MOVES 2014 ) 171.20 147.42 96.74 69.67 54.44 43.33 38.83

Non

- Road Mobile Sources 76.9 5 72. 29 61.5 6 53.3 1 48. 87 46. 36 45. 66

Total 285.16 257.91 215.56 178.51 157.86 144.08 138.93

Table 4
- 19 : DFW Four

- County One

- Hour Ozone Nonattainment Area VOC Emissions by Source Category (tons per day)

Category 201 2 2014 2017 2020 2023 2026 2028

Point Sources 11.11 11.02 11.52 11.71 11.86 11.99 12.08

Area Sources 218.90 224.51 218.56 211.43 209.81 210.69 211.77

On

- Road Mobile Sources (MOVES 2014 ) 78.56 71.20 55.59 46.81 41.53 35.85 32.94Page 60 Category 201 2 2014 2017 2020 2023 2026 2028

Non

- Road Mobile Sources 41.39 36.48 32.59 31.08 31.04 31.52 32.08

Total 349.96 343.21 318.26 301.03 294.24 290.05 288.87

Table 4
- 20 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area NO X Emissions by Source Category (tons per day)

Category 201 2 2014 2017 2020 2023 2026 2028

Point Sources 30.80 31.25 62.38 62.49 62.57 62.64 62.71

Area Sources 33.60 34.77 32.01 28.98 27.37 26.97 26.93

On

- Road Mobile Sources (MOVES 2014 ) 216.74 188.65 129.19 95.95 77.87 64.62 59.75

Non

- Road Mobile Sources 92.98 86.83 72.83 62.10 56.21 52.71 51.55

Total 374.12 341.50 296.41 249.52 224.02 206.94 200.94

Table 4
- 21 : DFW Nine

- County 1997 Eight

- Hour Ozone Nonattainment Area VOC Emissions by Source Category (tons per day)

Category 201 2 2014 2017 2020 2023 2026 2028

Point Sources 27.66 28.61 29.46 29.97 30.41 30.82 31.10

Area Sources 265.43 273.08 260.19 245.76 241.13 241.19 242.15

On

- Road Mobile Sources (MOVES 2014 ) 92.17 83.75 65.62 55.36 49.21 42.70 39.49

Non

- Road Mobile Sources 46.87 41.34 36.73 34.78 34.55 35.00 35.53

Total 432.13 426.78 392.00 365.87 355.30 349.71 348.27

4.6 M aintenance Demonstration Conclusion Future year trends were analyzed using the 2012 base year and the 2028 projected emissions above for the DFW four

- county one

- hour and the nine

- county 1997 eight

- hour ozone nonattainment areas. T rend analysi s using the 2028 future year emissions shows an overall decrease of 207.32 tpd in combined NO X and VOC emissions for the DFW four

- county one

- hour ozone nonattainment area . This net change for the four

- county area includes a projected 61.09 tpd de crease in VOC and a 146.23 tpd decrease in NO X .

For the DFW nine

- county 1997 eight

- hour ozon e nonattainment area, the trend analysi s shows an overall decrease of 257.04 tpd in combined NO X and VOC emissions. The net change for the nine

- count y area includes a projected 83.86 tpd decrease in VOC and a 173.18 tpd decrease in NO X .

Previous photochemical modeling analysis for the DFW area shows that reducing NO X emissions is expected to be more effective in reducing the one

- hour and the 1997 eight

- hour ozone design value s than VOC reductions. Therefore, the projected 146.23 tpd and 173.18 tpd decrease s of NO X are expected to reduce one

- hour and 1997 eight

- hour ozone design values

more effectively than the smaller 61.09 tpd and 83.86 tpd de crease s in VOC emissions . Based onPage 61

future expected trends and previous photochemical analysis, the DFW are a is projected to show continued attainment of the one

- hour and 1997 eight

- hour ozone NAAQS through 2028

.