2007 Ozone Plan 

# Chapter 10

Reasonable Further Progress2007 Ozone Plan 

### This page intentionally blank.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 requirement 1 

### 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 FR71631), 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 

### 10-2 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. TableSan Joaquin Valley Unified Air Pollution Control District April 30, 2007

Chapter 10: Reasonable Further Progress
2007 Ozone Plan 

### 10-3 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 RequirementSan Joaquin Valley Unified Air Pollution Control District April 30, 2007

Chapter 10: Reasonable Further Progress
2007 Ozone Plan 

### 10-4 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