Final Section 4 - Page 1 of 7

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 end of 

2008, emissions of ozone precursors (VOCs and NOx) in each nonattainment area decrease by at 

least 15% of the MA 2002 Base Year Inventory.

1 MassDEP has projected 2008 emissions after 

taking into account anticipated growth in the economy and any additional control measures 

expected to be in effect by that date. Its projections demonstrate that emissions will decrease in 

both areas by a significantly greater percentage than the 15% reduction required to demonstrate 

RFP. 

4.2 Reasonable Further Progress Requirements and Methodology

Under the CAA, ozone nonattainment areas are required to demonstrate progress towards attaining 

the ozone standard prior to their attainment year. EPA’s Phase 2 Rule RFP requirements for 8-hour 

ozone non-attainment areas vary according to: 1) whether an area’s attainment year is more than 5 

years after EPA’s 2004 nonattainment designations; and 2) whether an area was previously required 

to submit a 15% VOC Rate of Progress2plan under the 1-hour ozone standard. EMA and WMA 

have a 2010 attainment year and under the 1-hour ozone standard they were required to submit 15% 

Rate of Progress SIPs.3 The applicable RFP requirement, therefore, is to reduce emissions of VOCs 

and/or NOx by 15% within the six years after the 2002 Base Year Inventory - that is, by the end of 

2008. 

The procedures and methodology for demonstrating compliance with the 1-hour ozone standard 

Rate of Progress requirements were established in a 1992 EPA guidance document; these are still 

applicable for purposes of the 8-hour ozone standard RFP.4 EPA’s method for demonstrating 

that RFP requirements are met calls for: 

1. Developing a 2002 base year inventory for a nonattainment area that takes into 

account certain adjustments for RFP purposes;

2. Establishing a “target level” of emissions for the last year of the RFP period (the 

“milestone” year) that reflects the required 15% reduction from the base year; 

 

1 As noted in Section 2, the MA 2002 Base Year Inventory is Appendix 2A. 

2 Generally, the phrase “rate of progress” has been used in connection with 1-hour ozone standard 

requirements, while EPA has described 8-hour standard requirements as “reasonable further progress”.

3 The 15% Rate of Progress requirement was to demonstrate a 15% reduction in emissions of VOCs 

from the 1990 baseline inventory by 1996. An additional 9% reduction in VOCs, NOx or a combination 

of both, was required by 1999. MassDEP submitted a number of SIP revisions between 1993 and 2002 

demonstrating compliance with these 1-hour ozone standard ROP requirements. 

4 Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15 Percent Rate 

of Progress Plans, U.S. EPA, Office of Air Quality Planning and Standards, EPA-452/R-92-005, October 

1992.
Final Section 4 - Page 2 of 7

3. Developing a projected inventory of VOC and NOx emissions for the nonattainment 

area in the milestone year; and

4. Demonstrating that the projected milestone year emissions of NOx and VOC will be 

less than, or equal to, the target level for that year. 

Consistent with EPA’s methodology, MassDEP demonstrates in the calculations below that the 

EMA and WMA nonattainment areas have met the RFP requirements. 

4.3 2002 RFP Adjusted Base Year Inventory

The MA 2002 Base Year Inventory estimates anthropogenic and biogenic emissions of VOC and 

NOx. Pursuant to EPA’s RFP methodology, for RFP purposes, MassDEP has adjusted the

inventory 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 source categories, with these adjustments. The result is the 

2002 RFP Adjusted Base Year Inventory. 

 

5 The CAA (Section 182(b)(1)(D)) provides that reductions from the following measures are not 

creditable toward the required reductions: (1) Federal Motor Vehicle Control Program (FMVCP) tailpipe 

and evaporative standards issued in 1990; (2) Federal regulations limiting the Reid Vapor Pressure 

(RVP) of gasoline in ozone nonattainment areas issued by June 15, 1990; (3) State regulations correcting 

deficiencies in reasonably available control technology (RACT) rules; (4) Measures required to be 

enacted immediately after passage of the 1990 CAA Amendments concerning corrections to vehicle 

inspection and maintenance (I/M) programs. Only the FMVCP continues to generate emission reductions 

through 2008 in Massachusetts.
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Table RFP 1 2002 RFP Adjusted Base Year Inventory 

MA 2002 Base Year Inventory 

(From Appendix 2A ) EMA VOC WMA VOC EMA NOx WMA 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

Adjustments 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 ADJUSTED BASE YEAR 

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 Adjusted Base Year Inventory shown in Table RFP-1 above. The 

reductions can be of VOCs, NOx or any combination thereof. MassDEP is establishing its target 

levels based on a combined reduction of 12% NOx emissions and 3% VOC emissions in both 

EMA and WMA. The 2008 Target Levels are depicted in Table RFP 2; projected emissions in 

2008 may not exceed these Target Levels. The amount of reductions of each pollutant needed to 

achieve the Target Levels based on the 12% NOx and 3% VOC breakdown is also shown. 

 

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. 
Final Section 4 - Page 4 of 7

Table RFP 2 - 2008 Target Levels and Reductions Needed (TPSD)

1. 2002 RFP Adjusted Base 

Year Inventory 

(from Table RFP 1) 

EMA 

VOC

603.9

WMA

VOC

97.2

EMA 

NOx 

608.8

WMA 

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 by estimating anticipated growth in emissions 

between 2002 and 2008 and then adjusting for any controls that will reduce emissions during that 

time period. The basic methodology for growing point and area source emissions is the 

application of socio-economic growth factors to the base year data. For on-road and non-road 

sources, projected emissions are estimated using the current EPA emission models, which have 

built-in control factors. The NONROAD model also has built-in growth factors.

Appendix 4A, MA 2008 Projections by Categories, is based on the source category list used in 

the MA 2002 Base Year Inventory. It shows the growth factor that was applied to each source 

category to project 2008 emissions. It also indicates whether post-2002 controls have been taken 

into account. The projection methodology for the different source sectors listed in Appendix 4A 

is discussed below. Table RFP 3 summarizes the total 2008 projected emissions for EMA and 

WMA for all source sectors.

4.5.1 Stationary Point Sources

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

from Electric Generating Units (EGUs) and other industrial point sources. For EGUs and certain 

large boilers that have been subject to the NOx Budget Program, instead of using 2002 base year 
Final Section 4 - Page 5 of 7

data to project 2008 emissions,7 MassDEP is using 2006 actual emissions8to which it applied 

growth factors based on the U.S. Department of Energy Forecast9for New England.

For all other point sources (non-NOx Budget Program sources), MassDEP used MA 2002 Base 

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

interpolated from 2009 projected emissions developed for MANE-VU10 for attainment 

demonstration modeling purposes.11 MANE-VU used EPA’s Economic Growth and Analysis 

System (EGAS, version 5.0) and the Annual Energy Outlook of the U.S. Department of Energy’s 

Energy Information Administration (DOE/EIA) to project 2009 emissions for the non-EGU point 

source sector. MassDEP did not take any post-2002 control measures into account in projecting 

2008 emissions from this group of point sources. 

4.5.2 Area Sources

For most area sources, MassDEP projected 2008 emissions based on the MA 2002 Base Year 

Inventory combined with growth factors based on employment data from the Massachusetts 

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

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

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

fuel use, MassDEP used the growth factors that MANE-VU developed from DOE-EIA data and 

EGAS.

4.5.3 On-Road and Non-Road Mobile Sources

The Massachusetts Executive Office of Transportation and Public Works, Office of 

Transportation and Planning (EOT) estimated on-road mobile source emissions in 2008 for 

purposes of establishing the Transportation Conformity budgets required for the 2008 RFP 

milestone year. (Transportation Conformity budget requirements are discussed in Section 9, 

Transportation Conformity.) These 2008 on-road mobile source projections are used in this 

section as part of the RFP calculations. 

 

7 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 MidAtlantic/Northeast Visibility Union (MANE-VU) to coordinate regional haze planning activities for the 

region. MANE-VU and the OTC coordinated the development of combined inventories for purposes of 

regional ozone and PM2.5 attainment planning and regional haze planning. 

11 See Appendix 5K,“Development of Emission Projections for 2009, 2012 and 2018 for NonEGU Point, 

Area and Nonroad Sources in the MANE-VU Region, Prepared by MACTEC Federal Programs, Inc., Feb. 

28, 2007. 
Final Section 4 - Page 6 of 7

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 Vehicle (LEV) program, Stage II 

vehicle refueling control and reformulated gasoline (RFG). MassDEP does not anticipate 

changing the parameters of any state mobile source control program after 2002 and prior to the 

end of 2008. Therefore, the inputs for the 2002 base year and the 2008 projection year are the 

same.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 Marine 

Vessels and Locomotives were also derived from MANE-VU.

4.6 Summary 

The 2008 projections are summarized in Table RFP 3 below. Reductions anticipated by 2008 are 

compared to the reductions required to meet RFP. As shown, both areas have demonstrated 

reductions significantly greater than the 15% reduction needed to meet RFP requirements. 

 

12 Section 9, Transportation Conformity, includes additional discussion of the planning assumptions 

used to estimate mobile source emissions for the 2008 and 2009 Transportation Conformity Budgets. 

13 Non-road input and output data and non-road emissions by county are contained in Appendix 4b, 

Tables 4B-7 and 4B-8. 
Final Section 4 - Page 7 of 7

TABLE RFP 3 

 2002 RFP Adjusted Base Year, 2008 Projected Emissions & Target Level Comparison 

 Tons per Summer Day

ks/inv2002-sip-rfp/ rfp-2002-8-target /jan-8-2008

EMA 2002 EMA 2008 WMA 2002 WMA 2008 EMA 2002 EMA 2008 WMA 2002 WMA 2008

RFP ADJ PROJECT RFP ADJ PROJECT RFP ADJ PROJECT RFP ADJ 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 Adjusted 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%)