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__ D_E_P A_R_T_M_ E_N_T_O_F_E_N_V_IR_O_N_M_E_N_T_A_L_M_A_N_A_G_E_M_E_N_T_ 

CJ 235 Promenade Street, Providence, RI 02908-5767 

June 23, 2015 

David Conroy 

EPA- New England, Region I 

5 Post Office Square, Suite 100 

Boston, MA 02109-3912 

Dear Mr. Conroy: 

TOO 401-831-5508 

The Rhode Island Department of Environmental Management (RI DEM), Office of Air 

Resources is hereby submitting revisions to the Rhode Island State Implementation Plan (SIP) to 

address Clean Air Act Sections 11 O(a)(2)(D)(i)(I) requirements for the 2008 National Ambient 

Air Quality Standard (NAAQS) for ozone. This SIP, commonly referred to as a "transport" or 

"good neighbor" SIP, addresses the contribution of pollutants emitted in Rhode Island on 

nonattainment or maintenance of the ozone standard in downwind states. Note that a SIP revision 

addressing all other infrastructure requirements in Sections 11 O(a) (1) and (2) of the Clean Air 

Act for the 2008 ozone NAAQS was submitted to the EPA on January 2, 2013. 

A notice of a public comment period and the opportunity to request a public hearing on the 

proposed "Section 11 O(a)(2)(D)(i)(I) Transport Certification for the 2008 Ozone National 

Ambient Air Quality Standard," was posted on RI DEM's web site and sent electronically to the 

RI DEM Office of Air Resource's mailing list on May 22, 2015. The comment period remained 

open through June 22,2015. Since the only comment received during that period was a June 11 , 

2015 letter from EPA Region 1 in support of the proposed SIP, the SIP was not modified in 

response to comments. 

The following documents are included in this submittal package: 

1. The Notice of Public Comment Period, and 

2. The final proposed "Section 11 O(a)(2)(D)(i)(I) Transport Certification for the 2008 

Ozone National Ambient Air Quality Standard." 

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If you have any questions about this submittal, please contact Barbara Morin of my staff at ( 40 I) 

222-4700 ext. 7012. 

Very truly yours, 

' 

cf27:!111r 

Office of Air Resources 
Notice of Public Comment Period 

Sections llO(a) (1) and (2) of the Clean Air Act (CAA) require states to submit revisions 

to their State Implementation Plans (SIPs) within three years after the promulgation of a 

new or revised National Ambient Air Quality Standard (NAAQS) to demonstrate that the 

state meets the procedural, timing and infrastructure requirements necessary for 

implementing the NAAQS. In January 2013, the Rhode Island Department of 

Environmental Management submitted a SIP amendment that fulfilled all but two of the 

requirements of those sections for the revised ozone NAAQS, which was promulgated in 

2008. 

The 2013 SIP submittal did not fulfill the requirements of Section 11 O(a)(2)(D)(i)(I) of 

the CAA, which address the effect of emissions in one state on nonattainment and 

maintenance of attainment of the NAAQS in downwind states (interstate transport). The 

Rhode Island Department of Environmental Management, Office of Air Resources, is 

now accepting public comments on the proposed "Section 11 O(a)(2)(D)(i)(I) Transport 

Certification for the 2008 Ozone National Ambient Air Quality Standard," which will 

fulfill that requirement. 

The SIP revisions are available on the Office of Air Resources' web page at: 

http://www.dem.ri.gov/programslbenviron/air/pdf/siprev15.pdf 

Comments on these documents will be accepted until4:00 PM on June 22, 2015 and can 

be submitted electronically or in hard copy to: 

Barbara M01in, Supervising Environmental Scientist 

Rhode Island Department of Environmental Management 

Office of Air Resources 

235 Promenade Street 

Providence, RI 02908 

(401) 222-4700, ext. 7012 

(401) 222-2017 (fax) 

barbara.morin@dem.ri.gov 
Section 110(a)(2)(D)(i)(l) Transport Certification for the 

2008 Ozone National Ambient Air Quality Standard 

Rhode Island Department of Environmental Management 

Office of Air Resources 

Posted for Public Comment: May 22, 2015 

Submitted as a SIP Revision: June 23, 2015 
Section 11 0( a)(2)(D)(i)(I) Transport Certification for the 

2008 Ozone National Ambient Air Quality Standard 

Sections 110(a)(l) and (2) ofthe Clean Air Act (CAA) require states to submit a State 

Implementation Plan (SIP) amendment that addresses the procedural, timing and infrastructure 

elements identified in those sections within three years of promulgation of a new National 

Ambient Air Quality Standard (NAAQS). On March 12, 2008, the United States Environmental 

Protection Agency (EPA) promulgated a new NAAQS for ozone, 75 ppb as an 8-hour average. 

Implementation of that NAAQS was suspended by the EPA on January 6, 2010 pending further 

review and was reinitiated on September 2, 2011. 

On January 2, 2013, the Rhode Island Department of Environmental Management (RI DEM) 

submitted an " Infrastructure Certification for the 2008 Ozone National Ambient Air Quality 

Standard" to the EPA as a SIP amendment to address the 110(a)(1) and (2) requirements for that 

NAAQS. The EPA has determined that Rhode Island's January 2013 submittal is complete for 

all but two of the elements specified in Sections 110(a)(1) and (2) for the 2008 ozone NAAQS. 1 

Those elements not fulfilled by the January 2013 submittal, Prongs 1 and 2 of Section 

11 O(a)(2)(D)(i)(I), address the effect of emissions in one state on nonattainment and maintenance 

of attainment, respectively, in downwind states (interstate transport). Although Rhode Island did 

not comprehensively address interstate transport in the 2013 submittal, that document noted that 

"analyses in support ofEPA's 2005 Clean Air Interstate Rule (CAIR) determined that emissions 

in Rhode Island do not significantly impact downwind nonattainment areas. In addition, all areas 

downwind of Rhode Island are currently designated as attainment areas for the 2008 ozone 

NAAQS." 

In a November 19,2012 memo

2

, the EPA stated that it did not intend to issue deficiency findings 

for those elements, the so-called "Good Neighbor" Provision, until litigation related to the 

vacatur of the Cross-State Air Pollution Rule (CSAPR) was resolved. This litigation has since 

been resolved and, on January 22, 2015, the EPA issued a memo3 

and preliminary air quality 

modeling data4 to assist states in developing SIPs to fulfill the interstate transport requirements 

in Section 11 O(a)(2)(D)(i)(I) for the 2008 ozone NAAQS. In that memo, the EPA identified a 

methodology, similar to that used in the development of the CSAPR rule, to identify states that 

1 USEPA, Status of SIP Infrastructure Requirements, Rhode Island Infrastructure Requirements by Pollutant, 

Rhode Island: 110(a)(2) Ozone (2008) Infrastructure Requirements, 

http://www.epa.gov/oar/urbanair/sipstatus/reports/ri infrabypoll.html#x110 a 2 ozone 2008 

2 Memo from Gina McCarthy, Assistant Administrator, EPA, to Air Division Directors, "Next Steps for Pending 

Redesignation Requests and State Implementation Plan Actions Affected by the Recent Court Decision Vacating the 

2011 Cross-State Air Pollution Rule, November 19, 1012. 

http://www.epa.gov/airtransport/pdfs/CSAPR Memo to Regions.pdf 

3 Memo from Stephen D Page, Director, EPA Office of Air Quality of Planning and Standards ()AQPS), to Regional 

Air Division Directors, " Information on the Interstate Transport "Good Neighbor" Provision for the 2008 Ozone 

National Ambient Air Quality Standard (NAAQS) under Clean Air Act (CAA) Section 110(a)(2)(D)i)(l)," January 

22, 2015. http://www.epa. gov/airtransport/GoodNeighborProvision2008NAAQS.pdf 

4 EPA OAQPS, "Air Quality Modeling Technical Support Document for the 2008 Ozone NAAQS Transport 

Assessment," January 201 5. http://www.epa.gov/airtransport/03TransportAOModelingTSD.pdf 
may significantly impact downwind nonattainment or maintenance areas. Specifically, the 

memo states: 

CSAPR used a screening threshold (1 percent of the NAAQS) to identify contributing 

upwind states warranting further review and analysis. States whose air quality impact to 

a least one downwind problem receptor was greater than or equal to the threshold were 

identified as needing further evaluation for actions to address transport. States whose air 

quality impacts to all downwind problem receptors were below this threshold were 

identified as states not requiring further evaluation for actions to address transport- that 

is, those states had no emissions reduction obligation under the "Good Neighbor" 

Provision. 

EPA's January 2015 preliminary modeling analysis used the CSAPR modeling approach to 

assess the effects of interstate transport on attainment and maintenance of the 2008 ozone 

NAAQS. In that analysis, 2011 base year and 2018 projected emissions were modeled with the 

Comprehensive Air Quality Model with Extensions (CAMx), version 6.10 and a relative 

response factor (RRF), which is the fractional change in the modeled 8-hour daily maximum 

ozone levels between 2011 and 2018, was calculated for each ozone monitoring site from the 

results of those modeling runs. 

EPA then used a methodology described in its draft guidance for attainment demonstration 

modeling5 to identify ozone monitoring sites that it projected would be in nonattainment or 

would have maintenance issues with the 2008 ozone NAAQS in 2018. That approach entails 

calculating the maximum and average of the monitored ozone design values for the five years 

centered on the 2011 base year (2009 - 20 13) for each ozone monitor. Those values were 

multiplied by the corresponding RRFs to project average and maximum 2018 design values. 

Sites with average projected 2018 design value that exceeded 75 ppb, the 2008 ozone NAAQS, 

were identified as projected 2018 nonattainment monitors. Monitoring sites with 2018 average 

projected design values below the NAAQS but with 2018 maximum projected design values that 

exceed the NAAQS were identified as projected 2018 maintenance areas. 

Using that analysis, the EPA projected that a total of 11 monitors in the eastern half of the United 

States would be in nonattainment of the 2008 ozone NAAQS in 2018. Two of those areas are in 

Connecticut, seven in Texas, and one each in Maryland and New York. 18 eastern monitors 

were identified as projected 2018 maintenance areas: 8 in Texas, two each in Connecticut and 

New Jersey and one each in Kentucky, Michigan, Missouri, New Jersey, New York, 

Pennsylvania and Wisconsin. 

The EPA then performed nationwide state-level ozone source apportionment modeling using 

CAMx with the Anthropogenic Precursor Culpability Analysis (APCA) version of the Ozone 

Source Apportionment Technology (OSA T) apportioning schemes to quantify the contribution of 

2018 emissions of oxides of nitrogen (NOx) and volatile organic compounds (VOC) from all 

sources in each state to projected 2018 ozone concentrations at the identified nonattainment and 

maintenance monitoring sites. A state's interstate transport impact was classified as significant if 

the emissions from that state were associated with ozone levels of at least 1% of the NAAQS 

(0.75 ppb) at a nonattainment or maintenance site in another state. 

5

EPA, "Modeling Guidance for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional 

Haze- December 2014 DRAFT .. " http://www.epa.gov/scramOOllguidance/guide/Draft 03-PMRH Modeling Guidance-2014.pdf 
Rhode Island's highest contribution was 0.04 ppb (0.05% of the NAAQS) to a nonattainment site 

and 0.03 ppb (0.04% of the NAAQS) to a maintenance site. These values are substantially 

below the 1% significance levels established by the EPA and, therefore, according to the January 

EPA guidance memo discussed above, no further evaluation or emission reductions are required 

for Rhode Island to satisfy its interstate transport obligations under the "Good Neighbor" 

Provision. 

Questions have been raised about some aspects of the EPA methodology, e.g. the selection of 

2018 as the target attainment year and the use of2011 meteorology in the CAMx modeling. RI 

DEM is also aware that the EPA modeling results used for this analysis are preliminary. 

However, since Rhode Island's maximum impact on problem receptors, as calculated by the 

EPA, was approximately 1/20th ofEPA's significance threshold, it is unlikely that a modification 

in the modeling methodology would change the conclusion that Rhode Island's emissions do not 

contribute significantly to nonattainment or maintenance at the downwind receptors identified. 

Modeling conducted in support of the CSAPR rule showed that the most substantial impact of 

Rhode Island emissions on ozone concentrations in other states were at receptors in eastern 

Massachusetts, New Hampshire and Maine. One county in those states, Dukes County in 

Massachusetts, is classified as a marginal nonattainment area for the 2008 ozone NAAQS; 

however, the 2013 and 2014 monitored design values for the monitor in that nonattainment area 

are substantially below the NAAQS. There are no other nonattainment areas in those states and 

monitored 2014 design values for all monitors were well below the NAAQS. This evidence 

provides further support to the conclusion that Rhode Island's emissions do not interfere with 

attainment or maintenance of the 2008 ozone NAAQS in other states. 

In summary, based on the methodology specified in EPA's January 2015 memorandum and the 

results of the preliminary CAMx modeling that was issued with that memorandum, RI DEM 

certifies that air emissions from sources in Rhode Island do not contribute significantly to 

nonattainment or maintenance of the 2008 ozone NAAQS in other states. Monitored ozone 

concentrations at sites that are often downwind of Rhode Island further support this assertion. 

The submittal of this document to the EPA as an amendment to the Rhode Island SIP fulfills the 

"Good Neighbor" Provision requirements in Section 11 0( a)(2)(D)(i)(I) of the CAA and 

completes Rhode Island's fulfillment of the elements specified in Sections 11 O(a) (1) and (2) of 

the CAA for the 2008 ozone NAAQS. A notice of a public comment period and the opportunity 

to request a public hearing on the Section 110(a)(2)(D)(i)(I) Transport Certification for the 2008 

Ozone National Ambient Air Quality Standard was posted on the web site of the Rhode Island 

Department of Environmental Management (RI DEM) and sent electronically to the RI DEM 

Office of Air Resource's mailing list on May 22, 2015. Comments were accepted through June 

22,2015.