Final Section 8

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**SECTION 8 CONTINGENCY MEASURES 8.1**  **Purpose of Section** This section demonstrates that EMA and WMA meet the requirements for SI P contingency measures related to both Reasonable Further Progress (RFP) and to the attainment of the ozone standard. If implemented, the contingency measures discussed in this section would result in reductions in addition to those required to demonstrate RFP (discussed in Section 4) and in addition to those that have been taken into account in the attainment demonstration (discuss ed in Section 5). Contingency

measures ensure that if EMA or WMA fail to achieve the 15% required RFP reductions b y the 2008 RFP milestone year, or fail to attain the ozone standard b y 2010 1 , additional reductions will occur without further state or federa l action. **8.2 Contingency Requirements**  Section 172(c)(9) of the CAA and EPA’s Phase 2 Rule require that nonattainment areas include contingency

measures in their RFP and attainment SI Ps. If a state receives a notification from EPA that a nonattainment area within its borders has failed to achieve the level of reductions demonstrated in the RFP SI P by the milestone y ear (2008 for EMA and WMA), or has failed to attain the standard b y the attainment date (June 2010 for EMA and WMA), the area must be able to imp lement contingency measures within one ye ar after EPA’s notice. The RFP contingency

and the attainment contingency must each provide for reductions equivalent to at least 3% of the 2002 RFP Adjusted Base Year VOC emissions inventory

. 2 The contingency

red uctions are in addition to the 15% reduction required to demonstrate RFP and in addition to the reductions taken into account in the attainment demonstration. **8.3 RFP Contingency**  As discussed in Section 4, MassDEP is meeting the requirement to reduce emiss ions by 15% in the 2008 RFP milestone year through a combination of reductions of NOx (12%) and VOCs (3%) in both EMA and WMA. To satisfy the contingency

requirement, MassDEP must be able to demonstrate that if EMA or WMA fails to achieve a 12% reduction i n NOx and a 3% reduction in VOCs b y 2008, without further state or federal action, an additional 3% reduction could be achieved from control measures not already taken in account in calculation of the 15% RFP reduction. According to EPA’s interpretation of this requirement, the RFP contingency may be met by showing reductions in the 2008 RFP milestone y ear of at least 18% by 2008 (15% RFP + 3% RFP contingency). 3 As demonstrated in Section 4 Table RFP 3, both EMA and WMA have

1 The attai nm ent date for moderate nonattainment areas is June 15, 2010. For attainment contingency purposes, this is the milestone year. This is in contrast to the milestone year for the attainment demonstration, which is the ozone season prior to the attainment y ear
– 2009. 2 The RFP Adjusted Base Year Inventory is based on the MA 2002 Base Year Inventory adjusted for RFP purposes, as discussed in detail in Section 4. 3 U.S. EPA Memorandum from Michael H. Shapiro to Region 1 through 10 Air Directors, Guidance on Issues Related to 15% Rate

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-Progress Plans, August 23, 1993.Final Section 8

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demonstrated reductions signi ficantl y greater than the 15% reductions needed to meet RFP requirements and the additional 3% reductions needed to meet the contingency requirements. Therefore, EMA and WMA have both met the RFP contingency requirement. **8.4 Attainment Contingency**  EPA wil l assess whether EMA and WMA have attained the standard b y June 2010, presumabl y based on monitored ozone readings for 2007

– 2009. If either area is not meeting the standard based on readings for the 3

- ye ar period, EPA may issue a notification of failure to attain. The notification will trigger a requirement for MassDEP to implement contingency reductions within one y ear of the notification. For purposes of this contingency analy sis, MassDEP is assuming that EPA would issue the notice in June 2010, and that the contingency measures would need to be in place b y June 2011. Therefore, to meet the attainment contingency requirement, MassDEP must identify

control measures that will achieve additional reductions in emissions after 2009 and by June 2011 from control measures that will be effective without an y further state or federal action. The amount of additional reductions that must be achieved in order to meet the attainment contingency

requirement is 3% of the 2002 RFP Adjusted Base Year VOC emissions. 4 T he amount of reductions is shown below. **Table CGM 1 Required Attainment Contingency** 

**2002 RFP Adjusted Base Year Inventory (TPSD)**  **3% of 2002 VOCs = Required Contingency**  **Reduction VOC**  **NOx EMA**  603.9 608.8 **18.1 WMA**  97.2 103.8 **2.9** STATE 701.1 712.6 21.0 MassDEP will meet this attainment contingency requirement b y taking credit for emission reductions that will be achieved from the existing federal on

- road mobile source control measures described in Section 3, Control Measures, Federal “On

- the

- Wa y ” On

-Road Mobile Source Measures (Fuel Standards and Heav y - Duty Engine Standards) and from the Massachusetts Low

- Emission Vehicle (LEV) Program (also discussed in Section 3). These measures will continue to provide substantial VOC and NO x emission reductio ns through 2011 (and bey ond) as newer, less

- polluting vehicles replace the older fleet. The projected reductions from the on

- road mobile sector during the contingency period

– after the June 2009 attainment

4 While the required reductions are calculated as a percentage of the 2002 VOC emissions, NO x reductions can be used as a direct substitute for up to 90% of the required reductions of 3% of V OCs Therefore, only 0.3% of the reductions achieved by the contingency measures must be VOCs; this equates to 0.05 TPSD in EMA and 0.01 TPSD in WMA.Final Section 8

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date and before the 2011 ozone season

-- are show n in Table CGM 2. The estimated reductions during this time period exceed the required attainment contingency reduction. **Table CGM 2 Comparison: 2011 Projections and Contingency Requirement**

(TPSD) **On -**  **Road Mobile 2009 & 2011**

**Projected emissions and reductions**  **5 Combined On**  **- Road VOC & NOx**  **reductions compared to required contingency** 
VOC 2009 VOC 2011 VOC Reduction 2009 to 2011 NOx

2009 NOx

2011 NOx

Reduction 2009 to 2011 Combined

VOC/NOx Reductions Required

attainment contingency reductions (from Table CGM 1)

**EMA** 63.5 52.5 **11.0** 175.0 132.1 **42.9 53.9**  **18.1 WMA**  10.7 8.9 **1.9** 27.7 20.9 **6.8 8.7**  **2.9** STATE 74.2 61.4 12.9 202.7 153.0 49.7 62.6 21.0

**8.5 Conclusions**  EMA and WMA have met the RFP contingency by demonstrating that the reductions of VOC and NOx projected b y 2008 are significantl y greater than the 18% reduction that is required (15% for RFP and 3% for RFP contingency). For the attainment contingency , the reductions of VOC and NOx that will be achieved during the 2009

- 2011 period from the on

- road mobile source control measures alread y in effect are significantly greater than reductions needed to meet the 3% attainment contingency requirement. Therefore, EMA and WMA meet the attainment contingency

requirement.

5 The methodology and calculations used to develop the 2011 projected emissions shown in Table CGM 2 are d escribed in Appendix 8A