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**SECTION 4 REASONABLE FURTHER PROGRESS DEMONSTRATION**  **4.1 Purpose of Section**  This section demonstrates that EMA and WMA will meet the 8 - hour ozone standard requirement related to Reasonable Further Progress (RFP). EPA’s Phase 2 Rule requires that, by the e nd of 2008, emissions of ozone precursors (VOCs and NOx) in each nonattainment area decrease by at least 15% of the MA 2002 Base Year Inventory . 1 

### MassDEP has projected 2008 emissions after taking into account anticipated growth in the economy and any addit ional control measures expected to be in effect by that date. Its projections demonstrate that emissions will decrease in both areas b y a significantly greater percentage than the 15% reduction required to demonstrate RFP. **4.2 Reasonable Further Progre**  **ss Requirements and Methodology** Under the CAA, ozone nonattainment areas are required to demonstrate progress towards attaining the ozone standard prior to their attainment year. EPA’s Phase 2 Rule RFP requirements for 8 - hour ozone non - attainment areas va ry according to: 1) whether an area’s attainment y ear is more than 5 ye ars after EPA’s 2004 nonattainment designations; and 2) whether an area was previously required to submit a 15% VOC Rate of Progress 2 

### plan under the 1 - hour ozone standard. EMA and WMA have a 2010 attainment year and under the 1 - hour ozone standard they were required to submit 15% Rate of Progress SIPs. 3 

### The applicable RFP requirement, therefore, is to reduce emissions of VOCs and/or NO x by 15% within the six years after the 2002 Base Y ear I nventory - that is, by

the end of 2008. The procedures and methodology for demonstrating compliance with the 1 - hour ozone standard Rate of Progress requirements were established in a 1992 EPA guidance document; these are still applicable for purpose s of the 8 - hour ozone standard RFP. 4 

### EPA’s method for demonstrating that RFP requirements are met calls for: 1. Developing a 2002 base year inventory for a nonattainment area that takes into account certain adjustments for RFP purposes; 2. Establishing a “tar get level” of emissions for the last year of the RFP period (the “milestone” year) that reflects the required 15% reduction from the base ye ar;

1 As noted in Section 2, the MA 2002 Base Year Inventory is Appendix 2A. 2 Generally, the phrase “rate of progress” has been used in connection with 1 - hour ozone standard requirements, while EPA has described 8 - hour standard requirements as “reasonable further progress”. 3 The 15% Rate of Progr ess requirement was to demonstrate a 15% reduction in emissions of VOCs from the 1990 baseline inventory by 1996. An additional 9% reduction in VOCs, NOx or a combination of both, was required by 1999. MassDEP submitted a number of SIP revisions between 19 93 and 2002 demonstrating compliance with these 1 - hour ozone standard ROP requirements. 4 Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15 Percent Rate of Progress Plans , U.S. EPA, Office of Air Quality Planning and Standards, EPA - 452/R - 92 - 005, October 1992.

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3. Developing a projected inventory of VOC and NOx emissions for the nonattainment area in the milestone ye ar; and 4. Demonstrating that the projected milestone ye ar emissions of NOx and VOC will be less than, or equal to, the target level for that year. Consistent with EPA’s methodology , MassDEP demonstrates in the calculations below that the EMA and WMA nonattainment areas have met the RFP requirements. **4.3 2002 RFP Adjusted Base Year Inventory**  The MA 2002 Base Year Inventory estimates anthropogenic and biogenic emissions of VOC and NOx. Pursuant to EPA’s RFP methodology , for RFP purposes, MassDEP has adjusted the inventory to exclude: 1. biogenic VOC emissions; and 2. non - creditable reductions from the Federal Motor Vehicle Control Program (FMVCP). 5 

### Table RFP - 1 reflects the emissions estimates of VOC and NOx from the MA 2002 Base Year Inventory for EMA and WMA by

so urce categories, with these adjustments. The result is the 2002 RFP Adjusted Base Year Inventory .

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

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**Table RFP 1 2002 RFP Adjusted Base Year Inventory MA**  **2002 Base Year Inventory (From A**  **ppendix 2A**

**) EM**  **A VOC**  **WM A**  **VOC EM**  **A NOx**  **WM A**  **NOx** 

### ( tons per summer day) POINT 13.6 2.4 116.6 13.0 AREA 282.0 45.5 33.9 5.2 ON - ROAD 127.4 24.5 381.4 71.7 OFF - ROAD 196.2 27.7 122.1 22.4 BIOGENICS 535.7 254.6 4.4 1.1

----------------------------------------------- ----------- ---------- ------ ---- ---------- TOTAL ALL CATEGORIES 1,154.9 354.7 658.4 113.4 **Ad justments for RFP**  TOTAL ANTHROPOGENIC (after subtraction of biogenics) 619.2 100.1 654.0 112.3 FMVCP adjustment (Mobile On - Road) 6

- 15.3 - 2.9 - 45.2 - 8.5 **2002 RFP A DJU**  **STED BASE YEA R**  **INVENTORY 603.9**  **97.2 608.8**  **103.8** Note: Small discrepancies may result due to rounding 

### 4.4 **Target Level of Emissions** MassDEP must demonstrate that the 2008 projected emissions for EMA and WMA will be at least 15% below the 2002 RFP Ad justed Base Year Inventory shown in Table RFP - 1 above. The reductions can be of VOCs, NOx or any combination thereof. MassDEP is establishing its target levels based on a combined reduction of 12% NOx emissions and 3% VOC emissions in both EMA and WMA. Th e 2008 Target Levels are depicted in Table RFP 2; projected emissions in 2008 may not exceed these Target Levels. The amount of reductions of each pollutant needed to achieve the Target Levels based on the 12% NOx and 3% VOC breakdown is also shown.

6 The calculation method for the FMVCP non - creditable emissions reductions is described in Appendix 4C, July 27, 2007 MassDEP Memo, RFP Analysis; MOBILE6 input files description . The emission factors used for the 2008 Mobile 6 model runs are in Appendix 4B, Tables 4B1

– 4B6.

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**Tab le RFP 2**  **- 2008 Target Levels and Reductions Needed (TPSD)**  **1. 2002 RFP A djusted Base**  **Year Inventory (from Table RFP 1)**  **EM A**  **VOC 603.9**  **WM A** 

**VOC 97.2**  **EM A** 

**NOx 608.8**  **WM A** 

**NOx 103.8**  **2. Selected combination of reductions**  **3% 3%**  **12% 12%**  **3. Required Reductions 18.1**  **2.9 73.1**  **12.5** (line 1 x line 2) **4. 2008 Target Levels (**  line 1 – line 3) **585.8 94.3**  **535.7 91.3**  

### 4.5 **2008 Projected Emissions Inventory** The projected emissions in 2008 are calculated b y estimating anticipat ed growth in emissions between 2002 and 2008 and then adjusting for any controls that will reduce emissions during that time period. The basic methodology for growing point and area source emissions is the application of socio - economic growth factors to th e base ye ar data. For on - road and non - road sources, projected emissions are estimated using the current EPA emission models, which have built - in control factors. The NONROAD model also has built - in growth factors. Appendix 4A, MA 2008 Projections by Categories , is based on the source category list used in the MA 2002 Base Year Inventory . It shows the growth factor that was applied to each source category to project 2008 emissions. It also indicates whether post - 2002 controls have been taken into account. T he projection methodology for the different source sectors listed in Appendix 4A is discussed below. Table RFP 3 summarizes the total 2008 projected emissions for EMA and WMA for all source sectors. **4.5.1 Stationary Point Sources**  The Stationary

Point Sou

rce sector of the MA 2002 Base Year Inventory includes emissions from Electric Generating Units (EGUs) and other industrial point sources. For EGUs and certain large boilers that have been subject to the NOx Budget Program, instead of using 2002 base ye ar

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data to project 2008 emissions, 7 

### MassDEP is using 2006 actual emissions 8 

### to which it applied growth factors based on the U.S. Department of Energy Forecast 9 

### for New England. For all other point sources (non -NOx Budget Program sources), MassDEP used MA 200 2 Base Year emissions. To project 2008 emissions from this group of point sources, MassDEP interpolated from 2009 projected emissions developed for MANE - VU 10 

### for attainment demonstration modeling purposes. 11 

### MANE - VU used EPA’s Economic Growth and Anal ys is Sy stem (EGAS, version 5.0) and the Annual Energy Outlook of the U.S. Department of Energy ’s Energy Information Administration (DOE/EIA) to project 2009 emissions for the non - EGU point source sector. MassDEP did not take an y post - 2002 control measures into ac count in projecting 2008 emissions from this group of point sources. **4.5.2 Area Sources**  For most area sources, MassDEP projected 2008 emissions based on the MA 2002 Base Year Inventory combined with growth factors based on employ ment data from the Massachus etts Department of Emplo ym ent and Training (MA - DET). For the consumer products and architectural coatings (paints) categories, projections were based on population growth factors from the U.S. Census population projections. For residential, commercial and small industrial fuel use, MassDEP used the growth factors that MANE - VU developed from DOE - EIA data and EGAS. **4.5.3 On**  **- Road and Non**  **- Road Mobile Sources**  The Massachusetts Executive Office of Transportation and Public Works, Office of Transportation and Pl anning (EOT) estimated on - road mobile source emissions in 2008 for purposes of establishing the Transportation Conformity budgets required for the 2008 RFP milestone year. (Transportation Conformity budget requirements are discussed in Section 9, Transportation Conformity.) These 2008 on - road mobile source projections are used in this section as part of the RFP calculations.

7 The NOx Budget Program is discussed in Section 3 ,Control Measures. Because the program began in 2003, 2002 base year data does not provide a good basis from which to project future year emissions from sources covered by the program. 8 EPA Clean Air Markets Division 2006 NOx Budget Program Emissions Report for Massachusetts. Available at: http://camddataandmaps.epa.gov/ gdm/index.cfm 

### . 9 U.S. Department of Energy, Energy Information Administration (DOE/EIA), Forecasts and Analysis, Table 1 - Energy Consumption by Sector and Source -New England

– 01 http://www.eia.doe.gov/oiaf/forecasting.html 10 The Mid - Atlantic and Northeastern states, tribes, and federal agencies formed The Mid Atlantic/Northeast Visibility Union (MANE - VU) to coordinate regional haze planning acti vities for the region. MANE - VU and the OTC coordinated the development of combined inventories for purposes of regional ozone and PM2.5 attainment planning and regional haze planning. 11 See Appendix 5K, “Development of Emission Projections for 2009, 2012 a nd 2018 for NonEGU Point, Area and Nonroad Sources in the MANE
- VU Region, Prepared by MACTEC Federal Programs, Inc., Feb. 28, 2007.

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EOT used the latest version of its Travel Demand Model to project 2008 vehicle miles traveled (VMT). EPA’s MOBILE 6.2 model generated emission factors based on MassDEP inputs to the model that reflect state and federal mobile source control programs that will be in place in 2008. EOT combined the emission factors generated from MOBILE 6.2 with VMT to estimate on - road mobile emissions in 2008. 12 

### The MassDEP on - road mobile control programs that were adopted under the 1 - hour ozone standard and that are reflected in the 2002 and 2008 input files include: MA Enhanced Inspection and Maintenance (I/M) program, the California Low Emission V ehicle (LEV) program, Stage II vehicle refueling control and reformulated gasoline (RFG). MassDEP does not anticipate changing the parameters of an y state mobile source control program after 2002 and prior to the end of 2008. Therefore, the inputs for the 2002 base year and the 2008 projection year are the same. 13 

### (MassDEP expects to implement program revisions for the I/M program beginning in late 2008.) For non - road mobile emissions, MassDEP used EPA’s NONROAD Model (version 2005a, Feb.2006) to project 2008 emissions from this sector. The model has built - in state and county growth factors and factors for the federal control measures for non - road engines that will be in effect in 2008. (See Section 3, Control Measures ) For the non - road category of airport emissions, MassDEP applied growth factors for Logan Airport to develop Suffolk County (EMA) projected emissions. The growth factors for other airports in each county in EMA and WMA were derived from MANE - VU projections. Growth factors for Commercial Marin e Vessels and Locomotives were also derived from MANE - VU. **4.6 Summary**  The 2008 projections are summarized in Table RFP 3 below. Reductions anticipated by 2008 are compared to the reductions required to meet RFP. As shown, both areas have demonstrated reduc tions significantl y greater than the 15% reduction needed to meet RFP requirements.

12 Section 9, Transportation Conformity , includes additional discussion of the planning assumptions used to estimate mobi le source emissions for the 2008 and 2009 Transportation Conformity Budgets. 13 Non - road input and output data and non - road emissions by county are contained in Appendix 4b, Tables 4B - 7 and 4B - 8.

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- Page 7 of 7 **TA BLE RFP 3**  **2002 RFP A djusted Base Year, 2008 Projected Emissions & Target Level Comparison**  Tons per Summer Day ks /inv2002 - sip - rfp/ rfp - 2002 - 8 - target /jan - 8 - 2008 **EM A**  **2002 EM**  **A 2008**  **WM A**  **2002 WM**  **A 2008**  **EM A**  **2002 EM**  **A 2008**  **WM A**  **2002 WM**  **A 2008**  **RFP A DJ**  **PROJECT RFP A**  **DJ PROJECT**  **RFP A DJ**  **PROJECT RFP A** **DJ PROJECT**  **SOURCE SECTOR VOC**  **VOC VOC**  **VOC NOx**  **NOx NOx**  **NOx** Point 13.6 13.9 2.4 2.4 116.6 77.2 13.0 8.6 Area 282.0 286.0 45.5 46.3 33.9 38.1 5.2 5.9 On - Road (Adjusted) 112.1 68.3 21.6 11.8 336.2 191.3 63.2 31.3 Off - Road 196.2 155.3 27.7 23.6 122.1 108.1 22.4 20.3 1. 2002 RFP A djusted Base Year Emissions (Table RFP 1) **603.9 97.2**  **608.8 103.8**  2. Total 2008 Projected Emissions **523.5 84.1**  **414.7 66.1**  3. Required VOC/NOx Reductions (must total 15%) **3% 3%**  **12% 12%**  4. **15% Reductions in tons**  (to calculate 2008 Target Levels = Line 1* line 3) **18.1 2.9**  **73.1 12.5**  5. **2008 RFP Target Levels (Table RFP 2)**  Line 1 - line 4 **585.8 94.3**  **535.7 91.3**  6. **Projected reductions by 2008**  Line 1 - line 2 **80.4 13.1**  **194.1 37.7**  7. **Tons (and % )**  **by**

**which 2008 projected emissions exceed**  **required reductions** Line 6 - line 4, (Line 7 / line 5) **62.3 (10.6%)**  **10.2**

**(10.8%) 121.0** 

**(22.6%) 25.2** 

**(27.6%)**