2007 Ozone Plan

Chapter 10 

 

Reasonable Further Progress 
2007 Ozone Plan

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San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Chapter 10: Reasonable Further Progress 

2007 Ozone Plan

10-1

CHAPTER 10: REASONABLE FURTHER PROGRESS 

10.1 INTRODUCTION 

This chapter explains and demonstrates reasonable further progress (RFP) and 

quantitative milestones that are required until the SJVAB reaches attainment of the 

federal 8-hour ozone air quality standard. The data in this chapter is based on 

information that has been provided in other chapters and appendices of this plan. The 

information and conclusions presented here are based on the best available information 

as of January 2007, but are subject to change. 

10.2 REASONABLE FURTHER PROGRESS REQUIREMENTS 

RFP requirements for 8-hour ozone are outlined in EPA’s Phase 2 rule implementing 

the 8-hour ozone standard (70 FR 71631-71652). Nonattainment areas for 8-hour 

ozone that have already met the 15% VOC emission reduction requirement for the 1-

hour ozone standard are subject to the RFP requirement1

 to obtain an average of 3% 

annual reductions of VOC and/or NOx emissions reductions for the first 6 years after the 

baseline year and every subsequent 3 years out to the attainment date. EPA approved 

the SJVAB’s 1994 Ozone Attainment Demonstration Plan and its 15% rate of progress 

(ROP) demonstration in the Federal Register on January 8, 1997, effective February 7, 

1997 (62 FR 1172). The District has submitted periodic Milestone Compliance 

Demonstrations (the most recent of which was submitted to ARB in March 2006) to 

show retrospectively that the emissions reductions required through ROP have occurred 

in the SJVAB. Therefore, the SJVAB has met the initial 15% VOC reduction 

requirement. 

The SJVAB must now obtain an average of 3% annual reductions of VOC or NOx 

emissions for the first 6 years after the baseline year and every subsequent 3-year 

period until the attainment year. The baseline year is 2002 (70 FR 71631), so the sixyear milestone is 2008. The 3-year milestone years are 2011, 2014, 2017, 2020, and 

2023. The year 2023 is also the expected actual attainment year for extreme areas. 

 

1

 In CAA section 172(2) and the final 8-hour ozone rule (70 FR 71612-71705) 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Chapter 10: Reasonable Further Progress 

2007 Ozone Plan

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10.3 REASONABLE FURTHER PROGRESS CALCULATIONS 

The CAA specifies the “baseline” from which each milestone’s emission reduction is 

calculated [Title I, Part D, Section (b)(1)(C) and (D)]. Previous requirements were 

revised by the EPA’s Final Rule to Implement the 8-Hour Ozone National Ambient Air 

Quality Standard; Final Rule. Under the new rule, RACT, I/M, and RVP adjustments to 

the RFP inventories are no longer required since each was completely in place by 1996 

and, therefore, already accounted for in the 2002 baseline. Though emissions 

eliminated by the federal motor vehicle control program (FMVCP) must be subtracted 

from the actual emissions occurring in the 2002 baseyear and in future year milestones, 

ARB’s analysis indicates that FMVCP is zero for all years. 

The RFP calculation starts with emissions inventory adjustments. Since the official 

emissions inventories developed for this plan (see Appendix B) only include District 

rules adopted through May 2005, the reductions being achieved by rules adopted 

between May 2005 and December 2006 are subtracted from the initial baseline. Also, 

the District’s control measure development process revealed source categories that 

required emissions inventory revisions. The initial baseline inventories are adjusted by 

this amount also. These source category adjustments and the adjustments for the 

District’s adopted rules are in Table B-1. 

ARB also proposed as series of adjustments for measures already adopted, and these 

are summarized in Table B-2. Table 10-1 shows the emissions inventory adjustments 

for VOC and NOx. 

Table 10-1 Adjusted Emissions Inventory (in tons per day) 

Description 2002 2008 2011 2014 2017 2020 2023 

VOC 

O3SIP Inventory (Table B-4) 419.6 381.5 370.6 361.7 357.7 358.1 363.1

 Subtract District Adjustments (Table B-1)1 -55.1 -51.5 -42.6 -48.2 -48.7 -50.1 -51.6

Subtract ARB Adjustments (Table B-2) 0.8 2.4 2.5 2.6 2.6 2.7 2.7

Adjusted VOC Inventory Before Plan 

Control Strategy 474 431 411 407 404 406 412

NOx

O3SIP Inventory (Table B-3) 638.3 597.8 531.4 458.2 396.9 351.9 322.1

Subtract District Adjustments (Table B-1) -5.5 6.7 14.8 17.1 15.7 13.1 10.4

Subtract ARB Adjustments (Table B-2) 1.5 23.3 23.1 21.6 19.2 17.1 16.7

Adjusted Inventory Before Plan Control 

Strategy 642 568 494 420 362 322 295

1

 Note that subtracting a negative value is equivalent to adding. For example, the District has determined that 55.1 tpd of VOC

emissions should be added to the 2002 baseline. 

Adjusted inventories are then used to determine whether RFP has been met. For each 

milestone year, the percent reduction from the 2002 adjusted baseyear emissions 

inventory is calculated for both VOC and NOx. If the sum of these percents is greater 

than or equal to the RFP requirement, then RFP has been met for that milestone. Table 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Chapter 10: Reasonable Further Progress 

2007 Ozone Plan

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10-2 shows the percent calculations (based on the adjusted inventories from Table 10-

1). The data is shown graphically in Figure 10-1. Since the combined percent reduction 

surpasses the RFP requirement, the SJVAB meets RFP. 

Table 10-2 RFP Demonstration: Percent of Emissions Reductions from Base Year 

VOC NOx 

Year 

Adjusted 

Emissions 

(tpd) 

before 

Strategy a

Adjusted 

Emissions 

(tpd) 

before 

Strategy a

2002 474 

Percent 

reductions 

from 2002 

642 

Percent 

reductions 

from 2002 

VOC % 

Reduced + 

NOx % 

Reduced 

Required 

RFP% 

RFP 

met? 

2008 431 9% 568 12% 21% 18% Yes 

2011 411 13% 495 23% 36% 27% Yes 

2014 407 14% 421 35% 49% 36% Yes 

2017 404 15% 363 44% 59% 45% Yes 

2020 406 14% 322 50% 64% 54% Yes 

2023 412 13% 295 54% 67% 63% Yes 

a

 From Table 10-1 

Figure 10-1 Reductions Surpassing RFP Milestone Requirements 

0%

10%

20%

30%

40%

50%

60%

70%

80%

2008 2011 2014 2017 2020 2023

Year

VOC Reductions

NOx Reductions

RFP Requirement
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Chapter 10: Reasonable Further Progress 

2007 Ozone Plan

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10.4 REDUCTIONS BEYOND RFP FOR CONTINGENCY 

As discussed further in Chapter 11, EPA suggests that attainment plans provide the 

equivalent of one year of reasonable further progress reductions, which is 3% of the 

baseyear for ozone plans, to be set aside each year to satisfy the contingency measure 

requirement. Table 10-3 shows that sufficient emissions reductions are being achieved 

in the baseline to satisfy both RFP and the 3% contingency requirement. 

Table 10-3 Contingency Measure Demonstration 

Column 1: 

VOC % Reduced + 

NOx % Reduced 

(Table 10-2) 

Column 2:

Required 

RFP% 

Percent beyond RFP 

available as 

Contingency 

reductions 

(Column 1-Column 2)

3% 

Contingency 

met? 

21% 18% 3% Yes 

36% 27% 9% Yes 

49% 36% 13% Yes 

59% 45% 14% Yes 

64% 54% 10% Yes 

67% 63% 4% Yes