12/7/06

TECHNICAL SUPPORT DOCUMENT FOR

PHASE 2 OF THE FINAL RULE TO IMPLEMENT THE 8-HOUR OZONE NATIONAL 

AMBIENT AIR QUALITY STANDARD –NOTICE OF RECONSIDERATION

NOx RACT for EGUs in CAIR States-- Supplemental Technical Analysis

Analysis Data and Method

To conduct this analysis, EPA used the Integrated Planning Model (IPM)1 and National 

Electric Energy Data System (NEEDS)2 to project EGU emissions reductions that will be 

obtained in the year 2010 under two scenarios: (1) implementation of the Clean Air Interstate 

Rule (CAIR), assuming all States in the CAIR ozone region participate in the CAIR seasonal 

NOx trading program and all States in the CAIR PM2.5 region (except Delaware and New Jersey) 

participate in the CAIR annual NOx trading program3 and; (2) application, on a source-by-source 

basis, of an assumed level of RACT to all CAIR-affected EGUs in areas for which a RACT SIP, 

separate from an attainment SIP, must be prepared.

This analysis was conducted for each State in the OTR because all parts of States in the 

OTR have an obligation under sections 182(f) and 184(b) of the Clean Air Act (CAA) to meet 

the requirements, including RACT, for major sources of NOx as if the area were a moderate 

ozone nonattainment area. 42 U.S.C. section 7511a(f), 42 U.S.C. section 7511c(b); also 40 CFR 

51.916. 

 

1

IPM provides forecasts of least-cost capacity expansion, electricity dispatch, and emission 

control strategies for meeting energy demand given certain environmental, transmission, 

dispatch, and reliability constraints. IPM can be used to evaluate the cost and emissions impacts 

of proposed policies to limit emissions of sulfur dioxide (SO2), nitrogen oxides (NOx), carbon 

dioxide (CO2), and mercury (Hg) from the electric power sector. IPM is used by the EPA to 

project the impact of emissions policies on the electric power sector in the 48 contiguous States 

and the District of Columbia, and the model is able to capture detailed information regarding the 

power sector, including representations of the operating characteristics of individual electric 

boilers and generators while also considering a long-term horizon. The model is capable of 

providing detailed regional, state, and local projections, and EPA feeds emissions projections 

from IPM into air quality modeling. IPM has been used in support of Title IV of the CAA, the 

NOx SIP call, the CAIR, The Clean Air Mercury Rule (CAMR), and the Clean Air Visibility 

Rule (CAVR). Documentation for IPM may be found in the CAIR docket [EPA-HQ-OAR2003-0053-1901] and online at http://www.epa.gov/airmarkets/epa-ipm/.

2 See CAIR docket [EPA-HQ-OAR-2003-0053-1686] or http://www.epa.gov/airmarkets/epaipm/#needs.

3 The analysis, which was based on modeling conducted before March 2006, assumed that 

Delaware and New Jersey would participate in the seasonal NOx trading program but not in the 

annual NOx trading program. EPA added Delaware and New Jersey to the CAIR region for 

PM2.5 in March 2006 and, therefore, anticipates that they will also join the annual NOx trading 

program. For this reason, the modeling may underestimate the reductions to be achieved from 

the implementation of CAIR.
2

The analysis under the two scenarios described above was also conducted for each 8-hour 

ozone nonattainment area for which a RACT SIP is required separate from the attainment 

demonstration. Under 40 CFR 51.912(a), States must submit a RACT SIP separate from the 

attainment demonstration for all subpart 2 8-hour ozone nonattainment areas classified moderate 

or higher.4 In addition, 40 CFR 51.912(c)(2) requires States to submit a RACT SIP separate from 

the attainment demonstration for all subpart 1 areas with attainment dates beyond 5 years after 

their 8-hour designation. This separate RACT SIP must address major sources of NOx –

including EGUs. EPA expects that States may wish to rely on EPA’s NOx RACT determination 

for EGUs in CAIR States when submitting these RACT SIPs. 

The EGUs in subpart 1 areas with attainment dates of 5 years or less are subject to the 

NOx RACT requirement, but for these areas, the RACT requirement is satisfied by submission of 

a SIP that ensures attainment as expeditiously as practicable. Because States are not required to 

submit separate RACT SIPs for these areas, EPA does not expect States to rely on EPA’s NOx

RACT determination in SIP submissions covering these areas. In these areas the RACT 

requirement does not ensure any emissions reductions beyond those required for attainment 

purposes. As a result, the quantitative emissions reduction comparison below for the CAIR 

scenario and the source-by-source RACT scenario does not include these areas.

For these reasons, EPA’s analysis projected emission reductions for the following 8-hour 

ozone nonattainment areas, regardless of whether they are in an OTR State:

 Moderate subpart 2 areas in the CAIR region (there are currently no areas in the 

CAIR region classified higher than moderate).

 The Buffalo-Niagara Falls subpart 1 area. (Buffalo-Niagara Falls is the only subpart 

1 area in the CAIR region that is projected to remain in nonattainment in 2010 

without further control programs. Because 8-hour attainment SIPs are not yet due 

and we cannot reliably predict whether the state will submit a SIP demonstrating 

attainment for the Buffalo-Niagara Falls area within five years of designation, EPA is 

including this area in the analysis. 

In comparing the projected emissions reductions from EGUs under the CAIR and source-bysource RACT scenarios, we start from a 2010 EGU emissions baseline (See EPA-OAR-2003-

0053-1904). This baseline reflects the impact of existing controls and other controls projected to 

result from existing rules, (including the NOx SIP call, but not including CAIR implementation 

or 8-hour ozone RACT implementation). Then, we estimate the emissions reductions that CAIR 

would achieve and the emissions reductions that source-by-source RACT would achieve, relative 

to this baseline.

The analysis under the CAIR scenario relied on the IPM using the NEEDS data base, 

both described above. The emission projections for the source-by-source RACT scenario relied

on IPM modeled projections and, to simulate the assumed level of control, RACT policy rates 

based on the "NEEDS Adj." worksheet (in the supporting technical analysis) for coal units in SIP 

call States, the NEEDS database and base case annual NOx rates for other coal units, and 

 

4 To meet this requirement, a State may submit a certification that their current SIP provisions 

meet the RACT requirement. (See 70 FR 71655.)
3

assumed RACT rates of 0.20 and 0.30 lbs/MMBtu for tangential/other and wall-fired oil/gas 

steam units, respectively. All NOx rates were rounded to three significant figures for consistency.

Assumptions Used in Analysis

For purposes of this analysis, EPA used conservative assumptions about the level of 

control that EPA believes would be RACT for EGUs, resulting in a likely overstating of RACT 

emissions reductions. The level of controls we assumed for any particular unit does not imply 

that EPA has made a RACT determination for that unit. Our assumptions regarding RACT for 

EGUs are outlined below: 

For EGUs that have already installed post-combustion controls (i.e., SCR or SNCR) or state-ofthe-art combustion controls or that are projected to have such controls by 2010 under existing 

rules (e.g., NOx SIP Call and/or State rules), EPA’s analysis assumes that no further controls or 

emissions reductions would be required to meet NOx

 RACT. For purposes of this analysis, state-of-the-art combustion controls for EGUs 

are defined as: 1) low NOx burners with overfire air for wall-fired units and 2) low 

NOx coal-and-air nozzles with close-coupled and separated overfire air for 

tangentially-fired units. 

 For EGUs that have no emission controls or that are projected to have no emission 

controls by 2010, or for EGUs that will have some level of control less than state-ofthe-art combustion controls, EPA assumed “NOx RACT” to be any additional 

controls needed to achieve state-of-the-art combustion control levels (e.g., a wallfired unit with low NOx burners would need to install overfire air). 

 For oil and gas steam EGUs, the RACT-level of control was assumed to be the level 

specified in previous EPA guidance (values are in pounds of NOx per million Btu): 

0.20 for tangentially-fired gas or oil burning;5 0.30 for wall-fired gas or oil burning.6

 For coal-fired units, we used a unit-by-unit technology requirement (rather than an 

emission rate criterion) to determine what constitutes “state-of-the-art” combustion 

controls for each EGU as described above. Thus, emission reduction rates vary by 

unit. The assumption that all uncontrolled EGUs will install state-of-the-art 

combustion controls likely overstates the number of units that would, in fact, install 

such controls because RACT is determined on a source-by-source basis, and certain 

units may have unique constraints that could lead a State to determine that 

combustion controls are not RACT for that unit. Thus, these assumptions lead to a 

more conservative estimate of emissions reductions from the application of RACT 

(i.e., these assumptions lead to predictions of greater reductions than would likely 

occur through individual State RACT programs). 

No IPM projections were available for 2009. Therefore, EPA projected emissions 

reductions for 2010 to approximate the emissions reductions expected to be achieved by 2009, 

which is both the last year for RACT compliance in moderate 8-hour nonattainment areas and 

the year the first phase of CAIR NOx reductions starts. The EPA believes the 2010 data provide

 

5 EPA also conservatively assumed a 0.20 lb/MMBtu RACT rate for oil/gas steam units for 

which it was unclear whether the unit is tangentially- or wall-fired.

6

 57 FR at 55625 ( November 15, 1992).
4

a reasonable estimation of emissions reductions that would be achieved in 2009 under the two 

scenarios because we do not expect significant changes in fuel use patterns, levels of NOx

control, or power generation between 2009 and 2010.

The EPA analysis of projected emissions reductions under the two scenarios described 

above also relied on the following assumptions: 

 As noted above, EPA interprets the CAA to allow NOx RACT to be met on an areawide basis through averaging rather than requiring every unit to meet a RACT 

minimum level of control. Consistent with EPA guidance, this approach to averaging 

ensures that actual emissions with RACT averaging are no greater than if RACT were 

applied without averaging. For simplicity, EPA applied an assumed RACT level of 

control to each uncontrolled EGU in covered areas to compute the total reductions 

that would result from RACT (EPA’s guidance also would allow these reductions to 

be achieved through averaging in which some units install beyond-RACT controls 

and others remain uncontrolled). This assumption is conservative because some of 

the uncontrolled units may be complying with previously adopted State RACT rules 

through averaging with other units. For this analysis, additional combustion controls 

would be installed under a RACT scenario for 14 units for the "Moderate nonattainment areas + Buffalo" analysis and 18 units for the "OTR States" analysis; 

however, we do not have information readily available to determine if these units 

remained uncontrolled due to area-wide RACT averaging.7

 The EPA’s existing RACT guidance for EGUs indicates that EPA considers RACT 

for utilities to be the most effective level of combustion modification reasonably 

available to an individual unit. (See 57 FR at 55626; November 25, 1992.) However, 

the EPA analysis in support of this notice of reconsideration makes the conservative 

assumption that, for uncontrolled units, a level of combustion control would be 

employed now that is more advanced than was available in 1992.8 This conservative 

assumption was made for purposes of this analysis only and does not imply that EPA 

believes in any particular case that these more advanced combustion controls are 

necessarily RACT.

 The OTR States and (former) moderate and above 1-hour ozone nonattainment areas 

were required to submit SIPs for the 1-hour standard for NOx RACT on EGUs (or 

obtain a NOx waiver under section 182(g) of the CAA). The EPA has previously 

approved all these NOx SIPs (or approved waivers). The current analysis assumes 

control of uncontrolled EGUs that were not required to install controls under the 1-

hour SIPs. This is a conservative assumption; the lack of 1-hour controls may 

indicate site-specific conditions that led to a determination that RACT was no control 

for these sources. 

 

7 Note that a source that met the RACT requirement under the 1-hour NAAQS cannot be 

automatically assumed to meet RACT under the 8-hour NAAQS; see discussion in the Phase 2 

8-hour ozone implementation rule at 70 FR 71654 and 71655 (November 29, 2005).

8 For instance, the November 25, 1992 notice provided RACT-equivalent values for EGUs for 

coal-fired utility boilers in the range of 0.45 to 0.50 lb NOx/MMBtu (57 FR at 55625). However, 

the combustion controls assumed in this analysis as RACT for coal-fired units would yield NOx

rates in the 0.2 to 0.4 lb NOx/MMBtu range.
5

As noted in the Federal Register reconsideration notice, the CAIR is implemented on an 

annual and (for ozone) a seasonal basis. Connecticut and Massachusetts are covered by the 

CAIR for ozone only and thus only have a summer season NOx cap. The other States with 

relevant ozone nonattainment areas in the CAIR region are covered by both an annual and a 

summer season NOx cap under the CAIR. Therefore, the analysis comparing reductions from the 

CAIR and reductions from EGU-by-EGU application of RACT is also done on an annual and a 

seasonal basis. We believe that these averaging periods on which RACT is being implemented 

under the Phase 2 Rule are not in conflict with existing EPA policy. In general, the RACT 

requirement is applied on a short-term basis up to 24 hours.9 However, EPA guidance permits 

averaging times longer than 24 hours under certain conditions.10 Although these earlier EPA 

guidance documents were directed at VOC, the NOx Supplement to the General Preamble11 

provides, “While this guidance has been largely directed at application within the VOC program, 

much of the guidance is also applicable to RACT for stationary sources of NOx.” Section 4.6 

(“RACT for Certain Electric Utility Boilers”) of the NOx Supplement provides generally 

applicable NOx RACT emission rates for certain utility boilers on a pounds of NOx per million 

Btu basis and indicates, “Compliance with these limits may be determined on a continuous basis 

through the use of a 30 day rolling average emission rate, calculated each operating day as the 

average of all hourly data for the pr[e]ceeding 30 operating days.”

Other EPA guidance and policy allow for longer averaging times in certain 

circumstances. The EPA’s “Economic Incentive Policy”12 (EIP) provides guidance on use of 

long-term averages for RACT and generally provides for averaging times of no greater than 30 

days. However, that guidance also states, “For NOx sources that are required to comply with the 

[Ozone Transport Region] NOx MOU regulation or the NOx SIP call, the averaging time of an 

emission limit must not exceed a compliance period of an area’s ozone season. Sources involved 

with EIP trades must meet all requirements applicable to the program.” The EPA interprets this 

policy as applying to all trading programs and providing that the averaging time may not exceed 

the period for determining compliance with the trading program (e.g., one year for the CAIR 

annual trading programs –and the ozone season for the CAIR ozone season trading program). 

There is additional discussion on this matter in the Federal Register reconsideration notice.

As noted, several of these assumptions are conservative. As a result, the projections of 

emissions reductions under the source-by-source RACT scenario would likely exceed the 

emissions reductions that would actually occur.

 

9

 See, e.g., 52 FR at 45108 col. 2, “Compliance Periods” (November 24, 1987). “VOC rules 

should describe explicitly the compliance timeframe associated with each emission limit (e.g., 

instantaneous or daily). However, where the rules are silent on compliance time, EPA will 

interpret it as instantaneous.

10 Memorandum from John O’Connor, Acting Director of the Office of Air Quality Planning and 

Standards, January 20, 1984, “Averaging Times for Compliance with VOC Emission Limits—

SIP Revision Policy.”

11 57 FR at 55625, col. 1 sec. 4.5 “Relation to VOC RACT Policies” (November 25, 1992).

12 Improving Air Quality with Economic Incentive Programs, January 2001, available at 

http://www.epa.gov/region07/programs/artd/air/policy/search.htm.
6

The spreadsheet that provides the data for the analysis is available in the docket.

Results of Analysis

The EPA used these projections to examine whether the NOx emissions reductions

achieved as a result of the CAIR will equal or exceed those that would be achieved by 

application of EGU source-by-source RACT in each OTR State and each nonattainment area for 

which a separate RACT SIP is required. This analysis illustrates that the CAIR achieves greater 

overall emissions reductions across the CAIR region than would be achieved through the 

application of EGU source-by-source RACT controls. The results of the projections are 

summarized in Table A; detailed results appear in Tables B, C, D, and E.

The analysis results in Tables D (for annual emissions) and E (for summer season 

emissions) for Poughkeepsie need an explanation. The initial RACT projection for the 

Poughkeepsie, NY nonattainment area does not take into account the recent installation of low 

NOx burners on two coal-fired units. These controls were installed after the control data for 

these units was finalized in the IPM. Because these controls were not accounted for, we assume 

in our projection of emissions reductions attributable to RACT in the Poughkeepsie, NY area 

that these units would install state-of-the-art combustion controls. The total reductions attributed 

to these sources are 1,260 tons annually and 560 tons over the summer season. As stated 

previously, in this analysis, NOx RACT is assumed to be existing control for sources with 

controls already in place. When the recently installed controls are considered, our analysis does 

not project any additional emission reductions due to application of RACT to these sources. For 

this reason, the combustion controls and NOx rates under the CAIR program and under sourceby-source RACT for these units would be the same, and the CAIR and RACT policies would get 

nearly identical levels of reductions for the Poughkeepsie nonattainment area (from the 2010 preCAIR baseline).13

Similarly, the analysis results in Tables B (for annual emissions) and C (for summer season 

emissions) for the State of Connecticut need further explanation. In the 2010 baseline analysis,

the IPM projects that one coal-fired EGU in Connecticut, Bridgeport Harbor, will install SCR by 

2010 as a result of Connecticut’s participation in the NOx SIP call trading program. Therefore, 

there is no additional reduction attributable to the RACT scenario.14 However, in the CAIR 

scenario, the IPM projects that this unit will not install SCR by 2010 due to projected changes in 

the price of NOx allowances due to the CAIR15 Thus, the RACT scenario shows greater 

 

13 While changing the assumed level of controls on these two relatively small units to slightly 

more advanced controls may have minor impacts on dispatch and generation patterns, such 

changes would be negligible in calculating emission patterns for the areas under consideration. 

14 If this unit chooses not to install the SCR, it would still have in place its existing NOx controls 

(low NOx burners and overfire air), which are the level of control assumed to be RACT for this 

analysis. Thus, the corrected total emissions reductions attributable to the unit's compliance with 

the RACT requirement are 0.

15 This difference in projected NOx control is due to the expected decrease in value of ozone 

season NOx allowances resulting from the implementation of the CAIR program. Connecticut is 
7

emissions reductions than the CAIR scenario at this source, but the reduction differential is 

attributable to the NOx SIP call rather than the application of RACT. When the 930 ton annual 

(410 tons summer season) reduction resulting from the installation of the SCR is eliminated from 

the projected emissions reductions under the RACT scenario, the projections show that the total 

new annual or summer seasonal reductions in the State of Connecticut from the application of 

RACT are approximately 100 tons (in Table B, 1030 minus 930; in Table C, 520 minus 410). 

The remaining approximate 100 tons difference between the RACT and CAIR scenarios (for 

both annual and ozone season NOx) is due to a slight shift in generation pattern and utilization of 

a gas turbine unit.

With regard to the areas and States showing negative reductions with CAIR compared to 

RACT in Tables B – E, except Connecticut and Poughkeepsie (which are discussed above), (e.g., 

DC, MA, DE, NJ, NY, Boston, Springfield, Baltimore, Buffalo, and Chicago), the lower 

emissions under RACT are chiefly due to differences in utilization patterns of gas-fired units. 

 

in the CAIR ozone region and is, therefore, expected to participate only in the CAIR ozone 

season NOx trading program. When both the CAIR annual and ozone season NOx trading 

programs are implemented, ozone season NOx allowances are projected to become relatively 

inexpensive. Thus, the economic benefit of installing certain controls in states participating only 

in the CAIR ozone season trading program may be lower than the economic benefit of installing 

those same controls under the NOx SIP call. 
8

TABLE A

OZONE TRANSPORT REGION STATES --

ANNUAL EMISSIONS

2010 CAIR 

Annual 

Reductions* 

(tons)

2010 RACT 

Annual 

Reductions* 

(tons)

Difference between 

CAIR Ann'l Reductions 

and RACT Ann'l 

Reductions (tons)

170,660 7,160 163,500

OZONE TRANSPORT REGION STATES --

SUMMER EMISSIONS

2010 CAIR 

Summer 

Reductions* 

(tons)

2010 RACT 

Summer 

Reductions* 

(tons)

Difference between 

CAIR Summer 

Reductions and RACT 

Summer Reductions 

(tons)

20,410 2,440 17,970

MODERATE AND ABOVE 8-HOUR 

OZONE NONATTAINMENT AREAS AND 

BUFFALO-NIAGARA FALLS 

NONATTAINMENT AREA--ANNUAL 

EMISSIONS

2010 CAIR 

Annual 

Reductions* 

(tons)

2010 RACT 

Annual 

Reductions* 

(tons)

Difference between 

CAIR Ann'l Reductions 

and RACT Ann'l 

Reductions (tons)

94,140 5,980 88,150

MODERATE AND ABOVE 8-HOUR 

OZONE NONATTAINMENT AREAS AND 

BUFFALO-NIAGARA FALLS 

NONATTAINMENT AREA--SUMMER 

EMISSIONS

2010 CAIR 

Summer 

Reductions* 

(tons)

2010 RACT 

Summer 

Reductions* 

(tons)

Difference between 

CAIR Summer 

Reductions and RACT 

Summer Reductions 

(tons)

6,020 2,150 3,870

* “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT 

Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NOx SIP 

Call and State rules) (as well as installation of state-of-the art combustion controls on currently 

uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the 

RACT-level of control was assumed to be the level specified in previous EPA guidance (see text 

for details).
9

TABLE B: OZONE TRANSPORT REGION STATES -- ANNUAL EMISSIONS

OTR State Name

2010 CAIR 

Annual 

Reductions*

(tons)

2010 RACT 

Annual 

Reductions*

(tons)

Difference between 

CAIR Ann'l 

Reductions and 

RACT Ann'l 

Reductions (tons)

Connecticut -1,030 0 -1,030

Delaware 920 0 920

District Of Columbia -40 0 -40

Maryland 43,220 730 42,480

Massachusetts -150 0 -150

New Jersey 4,720 0 4,720

New York 9,070 5,110 3,960

Pennsylvania 111,830 1,320 110,510

Virginia (Alexandria and Prince 

William Counties 2,130 0 2,130

Grand Total 170,660 7,160 163,500

* “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT 

Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NOx SIP 

Call and State rules) (as well as installation of state-of-the art combustion controls on currently 

uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the 

RACT-level of control was assumed to be the level specified in previous EPA guidance (see text 

for details).
10

TABLE C: OZONE TRANSPORT REGION STATES -- SUMMER EMISSIONS

OTR State Name

2010 CAIR 

Summer 

Reductions*

(tons)

2010 RACT 

Summer 

Reductions*

(tons)

Difference between 

CAIR Summer 

Reductions and 

RACT Summer 

Reductions (tons)

Connecticut -520 0 -520

Delaware -600 0 -600

District Of Columbia -40 0 -40

Maryland 980 0 980

Massachusetts -290 0 -290

New Jersey -770 0 -770

New York 1,910 2,090 -190

Pennsylvania 19,620 350 19,280

Virginia (Alexandria and Prince 

William Counties 120 0 120

Grand Total 20,410 2,440 17,970

* “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT 

Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NOx SIP 

Call and State rules) (as well as installation of state-of-the art combustion controls on currently 

uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the 

RACT-level of control was assumed to be the level specified in previous EPA guidance (see text 

for details).
11

TABLE D: MODERATE AND ABOVE 8-HOUR OZONE NONATTAINMENT AREAS 

AND BUFFALO-NIAGARA FALLS NONATTAINMENT AREA--ANNUAL EMISSIONS

Nonattainment Area Name

2010 CAIR 

Annual 

Reductions*

(tons)

2010 RACT 

Annual 

Reductions*

(tons)

Difference 

between CAIR 

Ann'l 

Reductions and 

RACT Ann'l 

Reductions 

(tons)

Baltimore, MD 19,740 250 19,490

Boston-Lawrence-Worcester (E. MA), MA -140 0 -140

Buffalo-Niagara Falls, NY (Subpart 1) 4,290 710 3,580

Charlotte-Gastonia-Rock Hill, NC-SC 120 0 120

Chicago-Gary-Lake County, IL-IN 13,220 540 12,680

Cleveland-Akron-Lorain, OH 7,710 2,160 5,550

Dallas-Fort Worth, TX 500 0 500

Greater Connecticut, CT 0 0 0

Houston-Galveston-Brazoria, TX 20 0 20

Jefferson Co, NY 0 0 0

Milwaukee-Racine, WI 20 0 20

New York-N. New Jersey-Long Island,NY-NJ-CT 790 0 790

Philadelphia-Wilmin-Atlantic Ci,PA-NJ-MD-DE 11,550 0 11,550

Poughkeepsie, NY 0 1,260 -1,260

Sheboygan, WI 5,400 530 4,870

Springfield (Western MA), MA -20 0 -20

St. Louis, MO-IL 7,140 50 7,090

Washington, DC-MD-VA 23,790 490 23,300

Grand Total 94,140 5,980 88,150

* “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT 

Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NOx SIP 

Call and State rules) (as well as installation of state-of-the art combustion controls on currently 

uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the 

RACT-level of control was assumed to be the level specified in previous EPA guidance (see text 

for details).
12

TABLE E: MODERATE AND ABOVE 8-HOUR OZONE NONATTAINMENT AREAS AND 

BUFFALO-NIAGARA FALLS NONATTAINMENT AREA--SUMMER EMISSIONS

Nonattainment Area Name

2010 CAIR 

Summer 

Reductions* 

(tons)

2010 RACT 

Summer 

Reductions* 

(tons)

Difference 

between CAIR 

Summer 

Reductions and 

RACT Summer 

Reductions (tons)

Baltimore, MD -220 0 -220

Boston-Lawrence-Worcester (E. MA), MA -300 0 -300

Buffalo-Niagara Falls, NY (Subpart 1) 0 310 -320

Charlotte-Gastonia-Rock Hill, NC-SC 60 0 60

Chicago-Gary-Lake County, IL-IN 160 220 -60

Cleveland-Akron-Lorain, OH 1,980 770 1,210

Dallas-Fort Worth, TX 0 0 0

Greater Connecticut, CT 0 0 0

Houston-Galveston-Brazoria, TX 10 0 10

Jefferson Co, NY 0 0 0

Milwaukee-Racine, WI 20 0 20

New York-N. New Jersey-Long Island,NY-NJCT 170 30 140

Philadelphia-Wilmin-Atlantic Ci,PA-NJ-MD-DE 880 0 880

Poughkeepsie, NY 0 560 -560

Sheboygan, WI 2,390 230 2,160

Springfield (Western MA), MA 0 0 0

St. Louis, MO-IL 170 20 150

Washington, DC-MD-VA 690 0 690

Grand Total 6,020 2,150 3,870

* “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT 

Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NOx SIP 

Call and State rules) (as well as installation of state-of-the art combustion controls on currently 

uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the 

RACT-level of control was assumed to be the level specified in previous EPA guidance (see text 

for details).