Final Section 8 - Page 1 of 3

SECTION 8 CONTINGENCY MEASURES

8.1 Purpose of Section 

This section demonstrates that EMA and WMA meet the requirements for SIP 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 (discussed in 

Section 5). Contingency measures ensure that if EMA or WMA fail to achieve the 15% required 

RFP reductions by the 2008 RFP milestone year, or fail to attain the ozone standard by 20101, 

additional reductions will occur without further state or federal 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 SIPs. 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 SIP by the milestone year (2008 for EMA and WMA), or has failed to 

attain the standard by the attainment date (June 2010 for EMA and WMA), the area must be able 

to implement contingency measures within one year 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 reductions 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 emissions 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 in NOx and a 3% 

reduction in VOCs by 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 year 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 attainment 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 year – 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-of-Progress Plans, August 23, 1993. 
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demonstrated reductions significantly 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 will assess whether EMA and WMA have attained the standard by June 2010, presumably 

based on monitored ozone readings for 2007 – 2009. If either area is not meeting the standard 

based on readings for the 3-year period, EPA may issue a notification of failure to attain. The 

notification will trigger a requirement for MassDEP to implement contingency reductions within 

one year of the notification. For purposes of this contingency analysis, MassDEP is assuming 

that EPA would issue the notice in June 2010, and that the contingency measures would need to 

be in place by 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 any 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 The 

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 by 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-Way” On-Road Mobile 

Source Measures (Fuel Standards and Heavy-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 NOx emission reductions through 2011 

(and beyond) 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, NOx 

reductions can be used as a direct substitute for up to 90% of the required reductions of 3% of VOCs 

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.
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date and before the 2011 ozone season -- are shown 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 reductions5

Combined On-Road VOC & NOx 

reductions compared to 

required contingency

VOC

2009

VOC 2011VOC 

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 by 2008 are significantly 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 already 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 

described in Appendix 8A