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# CJ 235 Prom en ade Street , Pro vid en ce , 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: T OO 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 li st 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 1 1 O(a)(2)(D)(i)(I) Transport Certification for the 2008 Ozone Natio nal Ambient Air Quality Standard."



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**\,~** 30% p ost-consume r fiberIf you have any questions about this submittal, please contact Barbara Morin of my staff at ( 40 I) 222

-4700 ext. 7012

. Very truly yours, ' 

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Office of Air ResourcesNotice of Public Comment Period
Sections llO(a) (1) and (2) of the Clean Air Act (CAA) require states to submit re v isions 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 th at 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 emis sions 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: //w ww.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 , Supervi sing 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, 2015Section 1 1 0(a)(2)(D)(i)(I) Tran sport Certificati on for the 2008 Ozone National Ambient Air Quality Standard

Sections 110(a)(l) an d (2) oft he C l ean Air Act (CAA) require states to submit a State Implementation Plan (SIP) amendment that addresses the procedural , timing and infrastructure elements identified in tho se section s within three years ofpromulgation 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 s u spended b y the EPA on Janu ary 6, 2010 pending further review and was reinitiated on September 2, 2011. On J anuary 2, 2 013 , the Rh ode Island Department of Environmental Management (RI D EM) submitted an " Infrastructure Certification for the 2008 O zone National Ambient Air Quality Standard " to the EPA as a SIP amendment to ad dress the 110(a) (1) and (2) requirements for th at NAAQS. The EPA has determined that Rho de I s land 's Janu ary 2013 sub mi ttal is complete for all but two of the elements s pecified in Sections 110(a)(1) and (2) for the 2008 ozone NAA QS. 1 Tho se elements not fulfilled by the Janu ary 20 13 submittal , Prong s 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, respect ivel y, in downw ind state s (interstate transport). Although Rhode I sland did not compreh ens ively address interst at e tran sport in the 2013 submi ttal , th at document noted that "a

n alyses in support ofEPA's 2 00 5 C l ean Air Inte r state Rul e (CAIR) det ermin ed that e mi ssions in Rhod e Isl and do not significan tl y impact do wnwi nd nonattainm ent areas . In addi tion , all areas downwind of Rhod e Island are currently des i gnated as attainment areas for the 2008 ozone NAAQS

. " In a November 19 ,2 012 memo 2
, the EPA s tated that it did not intend to issue deficiency findings for those e lements , the so-call e d " Goo d Ne ig hb or " Provi s ion , until litiga tion related to the vacatur ofthe Cross-State Air Pollution Rul e (CSAPR) was resol ved. Thi s litigation ha s si n ce been re so lve d and, on Janu ary 22, 20 15, the EPA i ss ued a memo 3 and preliminary air qu ali ty modeling data4 to assis t states in developing SIPs to fu l fill the interstate transport requirements in Section 11 O(a)(2)(D)(i)(I) for th e 2008 oz one NAAQS. In that memo, the EPA i dent ifi ed a methodo lo gy, simi l ar to that used in the development of t he CSAPR rule , to id enti fy states that

1 USEPA , Status of SIP Infrastructure Requireme nts , Rhode Is l and Infras tru cture Requirements by Pollutant, Rhode I sland : 1 10(a)(2) Ozo ne (2008 ) Infra s tru cture Requirements, http: / /www.epa.gov / oar /urbanair /s ipstatus/reports / ri infrabyp o ll.html #x 1 10 a 2 ozone 2008 2 Memo from Gina McCarthy, A ss i stant Admin i strator, EPA , to Air Divis i on Director s, "Next Steps for P endin g Redesignat ion Reque sts and Stat e Implementation Plan Actio n s Affected by the Recent Court Decision Vacating the 2011 Cross-State Air Pollution Rule, No vember 1 9 , 101 2. http :/ /www.epa.gov/air transport /pdfs/CSAPR Memo to Regions.pdf 3 Memo from S t ephen D Page, Director, EPA Offi ce of Air Quality of Pl anning and Standards ()AQPS), to Regional Air Divis i o n Direc tor s, " Information on th e Interstate Transport " Good N ei ghbor" Pro visi on for the 200 8 Ozon e National Ambi ent Air Quality Standard (NAAQS) under Clean Air Act (CAA) Section 110(a)(2)(D)i)(l)," J anu ary 22 , 20 15. ht tp: //www.epa. gov/airtransport/GoodNei ghborProvision2008NAAQS.pdf
4 EPA OAQPS , "Air Quality Mod e ling Technica l Support Documen t for the 2008 Ozone NAAQS Transport Assessment ," J anuary 2 01 5. h ttp: //www.epa.gov /a irtransport/03TransportAOModelingTSD

. pdfmay 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 analy sis

. State s 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 addre ss transport. States whose air quality impacts to all downwind problem receptors were below this thre shold were identified as states not requiring further evaluation for actions to addre ss 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 anal y sis , 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 dai ly maximum ozone levels between 2011 and 2018, was calculated for each ozone monitoring s ite from the results of those modeling run s. EPA then used a methodology described in its draft guidance for attainment demon s tration modeling 5 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 value s 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 a s 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 h a lf of the U nited 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, tw o 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 u s ing CAMx with the Anthropogenic Precursor Culpability Analysis (APCA) version of the Ozone Source Apportionment Technology (OSAT) apportioning schemes to quantify the contribution of 2018 emissions of oxides of nitrogen (NOx) and volatile organic compound s (V OC) 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 clas sified 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 E PA, "Modeling Guidance for Demonstrating Attainment of Air Quality Goal s for Ozone, PM2 .5 , and Regional Haze- Dec ember 2014 DRAFT

.. " http: / /www.epa . gov / scramOOllguidance/guide /Draft 03-PMRH Modeling Guidance-2014.pdfRhode Island 's highest contribution was 0.04 ppb (0.05% of the N AAQS ) 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" Provi sio n. Questions have been raised about some aspects of the EPA methodology , e.g. the selection of 2018 as the target attainment year and the u s e 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 recep tors , 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 I sland's emissions do not contribute s ignificantly 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 Massachusett s, is clas s ified as a marginal nonattainment area for the 2008 ozone NAA QS ; 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 emi ss ions 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 i ss ued with that memorandum , RI D EM certifies that air emi ss ions from sources in Rhode Island do not contribute significa ntly 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 thi s document to the EPA as an amendment to the Rhode Island SIP fulfill s the "Goo d Nei ghbor" Provision requirements in Section 11 0(a)(2)(D)(i) (I) of the CAA and completes Rhode Island's fulfillment ofthe elements specified in Sections 11 O(a) 

### (1) and (2) of the CAA for the 2008 ozone NAAQS. A notice of a publi c 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 Qualit y Standard was posted on the web site of the Rhode I slan d Dep artment of Environmental Management (RI D EM) and sent electronically to the RI DEM Office of Air Resource's mailing list on May 22, 2015. Comments were accepted t hrough June 22,2015.