UNITED STATES ENVIRONMEN TAL PROTECTION AGENCY

REGION 2 AIR PROGRAMS BRANCH

Technical Support Document

EPA = s Notice of Proposed Rulemaking New York State Implementation Plan Revision:

New York Reasonable Further Progress Plans and Conformity Budgets

New York SIP for Ozone – Attainment Demonstration

for New York Metro Area

Final, February 8, 2008

March 20111 Table of Contents

Chapter

I. EMISSION INVENTORY

II. REASONABLY FURTHER PROGRESS PLAN

III. CONTINGENCY MEASURES2 I. EMISSION INVENTORY

1. PREFACE

This document is to support EPA's approval of a revision to the New York State Implementation Plan (SIP) which pertains to the following:

Where applicable, 2002 base year inventory an nual and summertime emissions for VOC, NOx, CO for the New York portion of the New Yo rk City-Northern New Jersey-Long Island and Poughkeepsie ozone nonattainment and attainment ar eas. This TSD contains a detailed review

of New York’s 2002 Base Year emissions invent ory submittal for the areas in question. Among the topics discussed below are the recent history and criteria for approval and EPA’s final

recommendations.

2. BACKGROUND

On November 18, 2002, EPA designated the 2002 base year inventory as the inventory for SIP planning process to address the pollutants fo r the eight hour-ozone, PM2.5 and CO national ambient air quality standard. Iden tifying the base year gives certain ty to States, and the selection

of 2002 harmonized the date for EPA’s Consolid ated Emissions Reporting rule (See 67 FR 39602) dated June 10, 2002.) that requires subm ission of the ozone, PM2.5 and CO emission inventories every three years; 2002 is one of the required ye ars for such updates. These requirements allow the EPA, based on the state’s progress in reducing emi ssions, to periodically reassess its policies and ai r quality standards and revise them as necessary. Most important, the 2002 ozone, new PM2.5 and CO invent ories will be used to de velop and assess new control strategies that the states will n eed to submit in their attainment demonstration SIPs for the new national ambient air quality standards for ozone, PM2.5 and for CO. The base year inventory may also serve as part of statewide inventorie s for purposes of regional modeling in transport areas. The base year inventory plays an importa nt role in modeling demonstrations for areas

classified as nonattainment and out side transport regions. For th e reasons stated above, ideally EPA would therefore emphasize th e importance and benefits of developing a comprehensive, current, and accurate 2002 ozone and PM2.5 emissi on inventory (similar to the 1990 base year inventory effort).

3. CRITERIA FOR APPROVAL

There are general and specific components of an acceptable emission inventory. In general, the

State must submit a revision to its SIP and th e emission inventory must meet the minimum requirements for reporting by source category. Sp ecifically, the source requi rements are detailed

below.3 The Level I and II review process is used to de termine that all components of the base year inventory are present. The review also evalua tes the level of supporting documentation provided by the State and assesses whether the emissions were developed according to current EPA or acceptable alternative guidance. The data quality is also evaluated.

The Level III review process is outlined here an d consists of 9 points th at the inventory must adequately address. For a base year emission i nventory to be acceptable it must pass all of the following acceptanc e criteria:

Adequate documentation must be provided that enabled the reviewer to determine the emission estimation procedures and the data sour ces used to develop the inventory.

1. Evidence that the inventory was qu ality assured by the state and its implementation documented.

2. The point source inventory must be complete.

3. Point source emissions must have been prepared or calculated according to the current EPA guidance.

4. The area source inventory must be complete.

5. The area source emissions must have b een prepared or calculated according to the current EPA guidance.

6. Non-road mobile emissions were prepared according to current EPA guidance for all of the source categories.

8. The method (e.g., HPMS or a network transportation planning model) used to develop VMT estimates must follow EPA guidance. The VMT development methods were adequately described and documented in the inventory report.

9. The MOBILE model must be correctly used to produce emission factors for

each of the vehicle classes.

4. DETAILED ACTION AND EVALUATION

New York submitted drafts and final versions of the Emissions Inventory SIP and comments to Region 2 for the following documents for the following program area elements:

Where applicable, 2002 base year inventory annual and summertime daily VOC, NOx, CO

emissions for the ozone nonattain ment areas and statewide. See Tables 1A-3B.

This TSD contains a detail discussion and summ ary of the review conducted by EPA for, where4 applicable, the 2002 base year inventory annua l and summertime daily emissions for VOC, NOx,

for the ozone nonattainment and attainment areas.

Table 1A

New York City-Long Island Ozone Nonattainment Area 2002 Base Year Inventory [Ozone Season VOC, NOx and CO Emissions (Tons/Day)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 10.7 445.4 283.5 236.8 976.4

NOx 171.4 77.6 186.2 327.3 762.5

CO 39.49 28.70 2,824.03 2,384.72 5,276.9

Table 1B

New York City-Long Island Ozone Nonattainment Area 2002 Base Year Inventory [VOC, NO x and CO Emissions (Tons/Year)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 3,570 152,147 60,635 81,499 297,851

NOx 45,634 54,494 55,984 124,640 280,752

CO 10,737 23,834 667,739 1,106,919 1,809,2295 Table 2A

Poughkeepsie Ozone Nonattainment Area 2002 Base Year Inventory [Ozone Season VOC, NOx and CO Emissions (Tons/Day)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 3.78 38.23 26.48 32.46 100.95

NOx 17.88 5.96 16.93 50.33 91.10

CO 2.67 5.67 199.65 410.39 618.38

Table 2B

Poughkeepsie Ozone Nonattainment Area 2002 Base Year Inventory [VOC, NO x and CO Emissions (Tons/Year)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 1,396 18,825 5,161 11,250 36,632

NOx 6,672 3,695 5,313 19,435 35,115

CO 960 10,755 42,689 189,510 243,9146 Table 3A

New York State-wide 2002 Base Year Inventory [Ozone Season VOC, NOx and CO Emissions (Tons/Day)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 41.52 855.1 749.45 546.65 2,192.72

NOx 377.25 162.4 400.78 844.22 1,784.65

CO 188.23 148.31 5,386.05 6,518.33 12,240.92

Table 3B

New York State-wide 2002 Base Year Inventory [VOC, NO x and CO Emissions (Tons/Year)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 15,034 502,797 157,892 179,731 855,454

NOx 118,765 98,804 119,808 313,890 651,267

CO 66,157 356,287 1,206,370 2,942,730 4,571,544

A. Details on How New York Satisfies Crit eria 1 for the Quality Assurance Plan

Quality Assurance Plan Implementation

The Quality Assurance (QA) plan was implemente d for all portions of the inventory. The QA plan included a QA/Quality control (QC) program for assessing data completeness and standard range checking. Critical data elements relativ e to the inventory sources were assessed for completeness. QA checks were performed relati ve to data collection and analysis, and double counting of emissions from point, area and mobile sources. QA/QC checks were conducted to ensure accuracy of units, unit conversions, transposition of figures, and calculations. The QA plan for the inventory was performe d in accordance with EPA Guidance. 1,27 B. Details on How New York Satisfies Criter ia 2 and 3 for the Point Source Inventory

Point Source Inventory New York’s inventory includes major point sources and provides thresholds for VOC, NOx and CO. The inventory report desc ribes how point sour ce activity levels and their associated parameters are developed, and how the data are us ed to calculate emission estimates. The report references document for activity level and em ission factors used and provides sample actual activity data and emissions factors. Inform ation on how rule eff ectiveness and control efficiencies are applied and the associated sa mple calculations with numerical values are provided. Where applicable, annu al and summertime daily point source emissions are presented for VOC, NOx and CO for the oz one nonattainment and attainment areas. Plant summary information on detailed plant, county and nona ttainment area levels are included in the inventory. Thus, the point inventory was developed in accordance with section 5.3 of EPA

Guidance. 1,2

C. Details on How New York Satisfies Criteria 4 and 5 for the Area Source Inventory

Area Source Inventory The inventory lists the source ca tegories that are included in the area source inventory. Area source emissions are presented on a source categor y, county basis. Where applicable, annual and summertime daily emissions are provided for VOC, NOx and CO for the ozone nonattainment and attainment areas. Inventory documentation includes emissions factors, activity levels, seasonal adjustment factors, and sample calcul ations. Referenced information for the input values to equations is included. Point source contributions have been correctly factored out of the area source category totals wher e appropriate. Rule effectivene ss, control efficiency and rule penetration are corre ctly applied for source categories. Thus, the area source inventory was developed in accordance with EPA Guidance. 1,2

D. Details on How New York Satisfies Crit eria 6 for Non Road Mobile Source Inventory

Nonroad Mobile Source Inventory For the New York, the predominant non-road mobile source categories (i.e., agricultural equipment, construction equipment, industrial equipment, airport serv ice equipment, light commercial equipment, lawn and garden equipmen t...etc.) are developed by the Nonroad Mobile 2005 released by EPA's Office of Transportation and Air Quality (OTAQ). Where applicable,

total combined nonroad mobile annual and su mmertime emissions are provided for VOC, NOx

and CO

. Nonroad mobile source emissions are pres ented on a source by source category basis and county basis. Thus, the inventory was developed in accordance with EPA Guidance. 1,28 Aircraft Emissions Aircraft emissions are provided for VOC, NOx a nd CO and calculated based on the number of landing and takeoffs (LTO) cycles generated at each airport. Thes e values are used as inputs to the Emissions and Dispersion Modeling System, th e Federal Aviation Agency modeling tool. . Where applicable, total combined nonroad mob ile annual and summertime daily emissions are provided for VOC, NOx and CO for the ozone nona ttainment and attainment areas. Aircraft source emissions are presented on source category and county basis. The inventory was developed in accordance with EPA Guidance. 1,2

Locomotive Emissions Locomotives emissions for VOC, NOx and CO are calculated based on a report developed by the New York State Energy Research and Developm ent Authority (NYSERDA). The locomotive inventory is based upon a survey co nducted of the national, regional, and local freight railroads, as well as passenger and commuter rail lines operation in New York State. Information collected in the survey was used in development of the emissions inventory. Where applicable, annual and summertime emissions are provided for VOC, NOx and CO for total combined nonroad emissions only by county for the ozone nonattainment and attainment areas. Locomotive emissions are presented on source category and county basis. In formation on how the emissions

are calculated and the emission factors used are provided. The NYS ERDA report was provided. The inventory was developed in accordance with EPA Guidance. 1,2

Commercial Marine Vessel Emissions Commercial marine vessel (C MV) emissions for VOC, NOx and CO are prepared by Starcrest Consulting Group, LLC. The inventory report relie d on actual operational data and then used local activity parameters to extend emission estima tes to those portions of the CMV not directly inventoried. From this information, emissi on estimates are prepared based on estimated horsepower demand. Commercial marine vessel inventory for the remainder of the State (excluding NYC metro area) is based on 2002 National Emissions Inventory report.

Where applicable, annual and summertime emi ssions are provided on a county basis for VOC, NOx, and CO for total combined nonroad mobile sources for ozone nonattainment and

attainment areas. CMV source emissions are presented on a source category, county basis. The inventory was developed in accordance with EPA Guidance. 1,2

E. Details on How New York Satisfies Crit eria 8 and 9 for the Onroad Source Inventory

Onroad Mobile Source Inventory New York’s mobile source inventory was deve loped by using 2002 daily ve hicle miles traveled (DVMT) inventory constructed by the New York St ate Department of Transportation to provide DVMT estimates by county, geographic component (u rban, small urban and rural) and functional classes. The resulting VMT by county and func tional class is then multiplied by a seasonal adjustment factor to account for seasonal differe nces. The VMT mix for each of the regions in9 New York State is used to produce VMT by vehi cle type. Estimates are developed from the aforementioned sources for each roadway functi onal class, by county, in each of the ozone

attainment and nonattainment areas within the State.

Mobile 6 model for VOC, NOx and CO was used to generate emission factors for on-road vehicle emission estimates. The report also expl ains how Mobile 6 emission factors are used, in conjunction with VMT data, to estimate mobile source emissions for the inventoried areas. It provides the sources for the key inputs into th e Mobile model. Key assumptions are also

included. The methods used to determine on-road emission estimates are explained in the report. VOC, NOx, and CO annual and summertime combin ed on-road mobile emissions by county are provided. Where applicable, a nnual and summertime daily emissions are provided for VOC, NOx, and CO for the ozone nonattainment and a ttainment areas. The breakdown of VOC, NOx and CO annual and summertime daily emissions by highway vehicle classifications are included in the inventory. The inventory was developed in accordance with EPA Guidance. 1,2

Conclusion

New York has a SIP that demonstrates the re quirements for emission inventory measures and reporting are adequately met. To comply with the emission inventory requirements, the State must submit a complete inventory containing an implemented Quality Assurance Plan, point, area, on-road, and non-road mobile source data, and accompanying support documentation.

Recommendation EPA is approving this SIP submittal because it meets the essential reporting requirements for an Emission Inventory.

Emission Inventory Guidance Documents

1 Emission Inventory Guidance for Implementati on of ozone and Particulate Matter NAAQS and Regional Haze Regulation , September 2005

2 Example Documentation Report for 1990 Base Year Ozone and Carbon Monoxide State Implementation Plan Emission Inventories , March 199210 II. REASONABLE FURTHER PROGRESS PLAN

1. PREFACE

This document is to support EPA's evaluati on of the 2008 projection inventory Reasonable Further Progress (RFP) Plans included in New York’s 8-Hour Ozone Attainment Demonstration State Implementation Plan (SIP) for the New Yo rk portion of the New York City-Northern New Jersey-Long Island serious ozone nonattainment area. The intended effect of this action is to evaluate inventory components required by the Clean Air Act (Act) which result in emission reductions that will help achieve attainment of the National Ambient Air Quality Standard for

ozone. The 2002 ozone Base Year em issions inventory is also an integral part of the plan. However, detailed evaluation of the 2002 inventor y will not be addressed in this document. The reader is referred to Region 2’s document entitled New York State 2002 Ba se Year Inventory

SIP for the New York Portion of the New York City-Northern New Jersey-Long Island, Poughkeepsie Ozone Nonattainment Areas and Attainment Areas, dated November 18, 2010 for details on the approval of New York’s portion of the New York City-Northern New Jersey-Long

Island ozone nonattainment area.

This document contains a detailed review of th e New York’s 15 percent plan RFP submittal. Among the topics discussed below are: background and criteria for approval and EPA’s final

recommendation.

2. BACKGROUND

REASONABLY FURTHER PROGRESS ELEMENTS

2002 Base Year Emissions Inventory

Section 182 of the Clean Air Act (CAA) and EPA’s 8-hour ozone regu lations (40 CFR 51.910) require each moderate and above 8-hour ozone nonattainment area to submit an emissions inventory and Reasonably Further Progress (RFP) SIP revision, which describes, how the area

will achieve actual emissions re ductions of volatile organic compounds (VOC) and nitrogen oxides (NOx) from a baseline emissions inventory. An emissions inventory is an estimation of actual emissions of air pollutants in an ar ea. The emissions inventory for an ozone

nonattainment area contains VOC and NOx emissions as these pollutants ar e precursors to ozone formation. In this case, the baseline em issions inventory is for the year 2002.

The 15 Percent Reasonable Further Progre ss Plans and Attainment Demonstration

15 Percent Reasonable Further Progress Plans

For serious 8-hour ozone nonattainment area, a 15% reduction in ozone precursor emissions is required within six years (2002 to 2008). For a se rious area which contains a portion of an area11 with an approved 15% VOC “Rate of Progress” pl an under the 1-hour ozone standard, States are

allowed to treat the area as tw o parts each with a separate RFP target. For the part with an approved 15% VOC "Rate of Progress" plan unde r the 1-hour ozone standard States can use reductions from VOC or NOx or a combination of either. For the part without an approved 15% VOC Rate of Progress plan, St ates must obtain VOC reductions. These VOC reductions can be obtained from the part of the area with an approved 1-hour VOC Ra te of Progress plan.

3. CRITERIA FOR APPROVAL

Projection, RFP and Attainment Demonstration

There are several points that the projection inventories, RFP and Attainment Plans must adequately address. For the projection inventories and RFP and Attainment Plans to be acceptable they must pass the following acceptance criteria:

1. Were the 2008 projection inventories de veloped in accordance with the procedures outlined EPA’s latest guidance 1,3,4,6,7 ?

2. Was the 15 Percent Plan developed in acco rdance with the procedures outline in EPA’s latest guidance for the Adjusted Base Year Emissions Inventory and the Target for the 15 Percent Plans 2,3,6 ?

3. Were the Plans developed in accordance with EPA’s latest guidance for Growth Factors, Projections, and Control Strategi es for the 15 Percent Rate of Progress,

Post-1996 and Attainment Demonstration Plans 1,3,4,6,7 ?

4. DETAILED ACTION AND EVALUATION

This portion of the report contains a discus sion and summary of the review conducted by EPA for the 2008 projection inventories and the 15 Percent RFP Plan for the New York Portion of the New York City-Northern New Jersey-Long Island ozone nonattainment area.

Section 1: 2002 BASE YEAR INVENTORY

Calculation of 2002 Base Year Emission Inventory

The reader is referred to Region 2’s document entitled New York State 2002 Base Year Inventory SIP for the New York Portion of the New York City-Northern New Jersey-Long Island, Poughkeepsie Ozone Nonattainme nt Areas and Attainment Areas, dated November 18, 2010 for details on the proposed approval of New York’s 2002 base year inventory. New York12 submitted it’s proposed 2002 base year emission i nventories and final 2002 base year emission

inventories.

Table 1A below shows the revised 2002 base year volatile organic compounds (VOC) and oxides of nitrogen (NO

x ) emission inventories for the New York Portion of the New York CityNorthern New Jersey-Long Is land ozone nonattainment area.

Table 1A

New York City-Long Island Ozone Nonattainment Area 2002 Base Year Inventory [Ozone Season VOC and NOx Emi ssions (Tons/Day)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 10.7 445.4 283.5 236.8 976.4

NOx 171.4 77.6 186.2 327.3 762.5

Section 2: Calculation of 2008 Proj ection Year Emission Inventories

A projection of 2002 VOC anthropogenic emission s to 2008 is required to determine the VOC reductions needed for the 15 percent plan. In addition, projection of the 2002 VOC and NOx anthropogenic emissions to 2008 is required to dete rmine the reductions needed for plans. The 2008 projection year emission inventories are calculated by multiplying the 2002 base year inventory by factors which estimate growth from 2002 to 2008. A specific growth factor for each source type in the inventory is required since sources typically grow at different rates.

The difference between the 2002 ba se year inventory and the 2008 projection inventories are the emissions growth estimates. Based on the difference between the 2002 inventory and the 2008 projection year inventories, th e total growth from 2002 to 2008 four VOC source categories (point, area, non-road and on-ro ad mobile) for the New York portion of the New York CityNorthern New Jersey-Long Island ozone nonattai nment area is estimated at 52.6, -37.4, -68.4 and -72.7 tons per day (tpd), respectively. The to tal growth from 2002 to 2008 for the four NOx sources categories in the New York portion of the New York City-Northern New Jersey-Long

Island ozone nonattainment area is estimated at 27.6, 6.9, -11.8 and -53.8 tpd, respectively.13 Projection Methodology

Major Point Sources

Non-EGU For the major point source category, the projected emissions inventories we re first calculated by estimating growth in each source category. As appropriate, the 2002 actua l emissions inventory was used as the base for applying factors to account for inventory growth. The point source inventory was grown from the 2002 inventory to 2008 for each fac ility using growth factors by

source classification codes utilized in EPA’ s Economic Growth Analysis System (EGAS) version 5.0 and the United States Department of Energy’s (USDOE) Annual Energy Outlook 2005 (AOE 2005) Projections.

EGU For the major point source category, the projected emissions inventories we re first calculated by estimating growth in each source category. As appropriate, the 2002 actua l emissions inventory was used as the base for applying factors to account for inventory growth. The actual 2005 inventory was also calculated. For a more realistic projection, the point source inventory was kept constant from 2005 invent ory to 2008. The 2008 inventory was constrained as a more conservative approach because emissions from 20 05-2008 are more likely to decrease due to the Clean Air Interstate Rule (CAIR) or CAIR re duction equivalent regulations which establishes NOx and SO2 emission caps.

The reader is referred to Section 4.4.1 of the New York State Implementation Plan for Ozone (8- Hour NAAQS) Attainment Demonstr ation for New York Metro Area, dated February 2008. This document provides further details and references on how pr ojections were performed. These growth indicators are some of the preferred growth indicators to use as outlined in EPA Guidance, 1,3,4,6,7

EPA finds New York’s methodology for projec ting point sources to be acceptable.

Area Sources For the area source category, New York proj ected emissions from 2002 to 2008 using state population projections, USDOE’s AOE2005 fuel consumption projections and employment projections and EGAS 5.0. This is in accordan ce with EPA’s recommended growth indicators for projecting emissions for area source cat egories as outlined in EPA Guidance. 1,3,4,6,7

The reader is referred to Section 4.4.1 of the New York State Implementation Plan for Ozone (8- Hour NAAQS) Attainment Demonstr ation for New York Metro Area, dated February 2008. This document provides furthe r details and references on ho w projections were performed.

EPA finds New York’s methodology for projecting area sources to be acceptable.14 Non-Road Mobile Sources Non-road vehicle equipment emissions were projected from 2002 to 2008 and 2009 using the

NONROAD 2005. The NONROAD 2005 model contains growth factors, which are based on the historical trends in nonroad equipment activ ity. This model was used to calculate past and

future emission inventories for all nonroad e quipment categories except commercial marine vessels, locomotives and aircrafts. EPA fina lized nonroad mobile model regulations are built

into the current version of the model. The nonr oad mobile projection inventories automatically reflect any regulations th at will occur in the future. The model does not allow for estimation of projection inventories without futu re regulations in place for comp arison purposes. As a result, uncontrolled projected 2008 nonroad mobile emi ssions are less than the 2002 base year

emissions.

Aircrafts, Locomotives and Commercial Marine Vessels Aircraft, Locomotive and Commercial Marine Vessel emissions were projected from 2002-2008 based on future growth projections developed for emission projections from US EPA’s CAIR

Rule.

The reader is referred to Chapter 4.4.3 of the New York State Implementation Plan for Ozone (8- Hour NAAQS) Attainment Demonstr ation for New York Metro Area, dated February 2008. This document provides further details and references on how projections were performed.

EPA finds New York’s methodology for proj ecting non-road mobile sources to be acceptable.

Onroad Mobile Sources For the onroad mobile source category, the primar y indicator and tool for developing on-road mobile growth and expected emissions are vehicle miles traveled (VMT) and US EPA’s

Mobile6.2 model. The 2008 VOC and NOx emissi on factors were generated by Mobile6.2 and applied to the daily VMT (DVMT) projections provided by the New York State Department of Transportation.

The reader is referred to Chapter 4.4.2 of the New York State Implementation Plan for Ozone (8- Hour NAAQS) Attainment Demonstr ation for New York Metro Area, dated February 2008. This document provides further details and references on how pr ojections were performed. These growth indicators are some of the preferred gr owth indicators to use, as outlined in EPA Guidance, 1,3,4,6,7 Uncontrolled 2008 projected onroad mobile inventory were developed by using projection emission factors that assume 2002 controls and account for fleet turnover for to the given projection year and multiplied by the a ssociated VMT. As a result, 2008 uncontrolled projection year emissions are less than 2002 base year emissions.

EPA finds New York’s methodology for projecting on-road mobile sources to be acceptable.15 Tables 2A show 2008 VOC and NOx projection emissi on inventories (uncontrolled after 2002 using the aforementioned growth indicators/met hodologies for the New York portion of the New York City-Northern New Jersey-Long Island ozone nonattainment area.

Tables 2B show 2008 VOC and NOx projection emission inventories controlled after 2002 using the aforementioned growth indicators/methodologies for the New York portion of the New York City-Northern New Jersey-Long Is land ozone nonattainment area.

Table 2A

New York Portion of the New York Ci ty-Northern New Jersey-Long Island

Ozone Nonattainment Area 2008 Projection Year Inventory (Uncontrolled) [Ozone Season VOC and NO

x Emissions (Tons/Day)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 63.3 408 215.1 164.1 927.5

NO

x 199 84.5 174.4 273.5 731.416 Table 2B

New York Portion of the New York Ci ty-Northern New Jersey-Long Island

Ozone Nonattainment Area 2008 Projection Year Inventory (Controlled) [Ozone Season VOC and NO

x Emissions (Tons/Day)]

Pollutant Major

Point

Sources Area

Sources Nonroad

Mobile

Sources Onroad

Mobile

Sources Total

VOC 19.8 413.6 215.1 148.8 798.4

NO

x 178.9 84.4 174.4 211.8 649.5

Section 3: 2008 RFP Demonstration

Section 3A: 15% VOC RFP Pl an or 2008 RFP Demonstration

Steps involved in calculati ng the 2002 Percent RFP Plan:

1. Preparation of 2002 Anthropogenic Base Y ear Ozone Season Emission Inventory

2. Calculation of a 2002 Rate-of-Progress VOC (Baseline) Emission Inventory

3. Calculation of a 2002 Adjusted Ba seline Emission Inventory for 2008

4. Calculation of the 2008 Reduction Requirement

5. Calculation of the non-credit able emission reductions

6. Calculation of Total Expected Reductions

7. Calculation of the 2008 Target Inventory

8. Calculation of Emission Reductions Requi re to Meet the 2008 Target Level

9. Calculation of 2008 Projec tion Year Inventory17 Preparation of 2002 VOC Base Year Ozone Se ason Anthropogenic Emission Inventory

The reader is referred to S ection 1 of this document.

Calculation of a 2002 VOC Rate-of-Prog ress (Baseline) Emission Inventory

The reader is referred to procedure outlined in Section 2 this document. The reader is

referred to Table 3A for the calculation.

Calculation of a 2002 VOC Adjusted Baseline Emission Inventory for 2008

The 2002 adjusted baseline emission inventory for 2002 is calculated by subtracting from the

2002 baseline emission inventor y the emission benefits from the pre-1990 Clean Air Act Federal Motor Vehicle Control Program (FMVCP).

The pre-1990 FMVCP reductions were determin ed by taking the difference between the 2002 highway mobile source emission inventory a nd the 2002 adjusted base line highway mobile source emission inventory for 2008.

To estimate the expected reductions from FMVCP standards, the State prepared an additional mobile source emission inventory using the Mobile6.2 emission factor model, and changed the certain input variables to disable the modeling of 1990 Clean Air Act effects. The resulting inventory is referred to as the Ad justed Baseline Highway Inventory. This was done in accordance with the procedures outlined in EPA Guidance. 2,3,6

New York calculated the 2002 Adjusted Ba se Year Inventory for 2008 in accordance with EPA guidance.

Calculation of the 2008 Reduction Requirements

New York calculated the required reductions by multiplying the 2002 adjusted baseline emission inventory for 2008 by 0.15. The reader is referred to Table 3A for the calculations. This was done in accordance with the pr ocedures outlined in EPA Guidance. 2,3,6

New York calculated the 2008 percent reducti on requirement in accordance with EPA guidance.

Calculation of the non-creditable emission reductions18 The 15 percent RFP Plan non-creditable re duction category (FMVCP ) applies for the 2008 Percent RFP plans. The reader is referred to Table 3A for the calculation. This was done in accordance with the procedures outlined in EPA Guidance. 2,3,6

New York has calculated the non-creditable emission reductions in accordance with EPA guidance.

Calculation of Total Expected Reductions for 2008

New York calculated the total expected reductio ns for the year 2008 by taking the sum of the

non-creditable emission reductions and the 15 Percent RFP reduction requirements, respectively. The reader is referred to Table 3A for the calculation. This was done in accordance with the procedures outlined in EPA Guidance. 2,3,6

Calculation of the 2008 Target Inventory

New York calculated the 2008 ta rget inventory by subtrac ting the required Percent

reductions for 2008 and the non-creditable em ission reductions from the 2002 baseline emission inventory. The r eader is referred to Table 3A for the calculations. This was done in accordance with the procedures outlined in EPA Guidance. 2,3,6

New York has calculated the 2008 target in ventory in accordance with EPA guidance.

Calculation of Total Emission Reduction s Needed to Reach 2008 Target Levels

New York calculated the total emission reducti ons needed to reach 2008 target levels by taking the difference between the 2008 projec ted emission inventory (with no additional post-2002 control measures) and the 2008 target inventory. The read er is referred to Table

3A for the calculations.

New York has calculated the 2008 total emis sion reductions needed to reach the 2008 target levels in accordance with EPA guidance.

Calculation of the 2008 Pr ojection Year Inventory

The reader is referred to Section 2 of this document for more details. This was done in accordance with the procedures outlined EPA guidance. 1,3,4,6,7

New York has followed EPA guidance in calc ulating the 2008 projection year emission inventory.19 Table 3A provides a summary of the emissi on inventories calculated above.

Table 3A

------------------------------------ ----------------- ------------------ ------------ 2008 VOC Emissions (Tons/Day) for the

New York Portion of the New York Ci ty-Northern New Jersey-Long Island

Ozone Nonattainment Area

------------------------------------ ----------------- ------------------------------ ------------- A. 2002 Anthropogenic Base Y ear Emissions Inventory .................................................976.40 B. 2002 Rate-of-Progress Inventory .................................................................................976.40 C. Emission Reds. from the Pre-1990 FMVCP and Phase II RVP Expected by 2002 .......32.50 D. 2002 Adjusted Base Year Inventory(B-C) .................................................................. 943.90 E. 15% Percent Reduction Requirement (D x 0.15) ........................................................ 141.56 F. Total Expected Reductions (E + C) ............................................................................ 174.06 G. 2008 Target Level of Emissions (B - F) ......................................................................802.34 H. 2008 Projection Year Inventory (B + growth & offsets) ........................................927.50

I. Total Emission reductions needed to reach 2008 Target Level (H - G) .................125.16

------------------------------------ ----------------- --------------------------------- --------------20 Section 3B: 2008 or 15% RFP Control Measures

Table 3B

VOC Emission Reduction Measures Include d in the New York 2008 (15%) RFP Plan

VOC CONTROL MEASURES NY Portion of the NYC-NJ-LI
Ozone NAA (Tons Per Day)

REQUIRED REDUCTION IN VOC TO

MEET 2008 MILESTONE 125.16

POINT SOURCE CONTROL MEASURES

CAIR RULE 0

REMAINING POINT SOURCES *43.5

ERCS -1.1

NON-ROAD MOBILE SOURCE

CONTROL MEASURES 0

ON-ROAD MOBILE SOURCE CONTROL

MEASURES

LEV 2 2.5

NYVIP 4.0

FUELS 8.7

HEAVY DUTY DIESEL .1

STATIONARY AREA SOURDE CONTOL

MEASURES

CONSUMER PRODUCTS 17.1

PORTABLE FUEL CO NTAINERS 13.9

AIMS COATING 22.5 MOBILE EQUIPMENT REPAIR 12.6

SOVENT METAL CLEANING 5.3

TOTAL VOC BENEFITS FROM ALL

SOURCES 129.1 VOC SHORTFALL = (VOC REDUCTIONS NEEDED TO MEET TARGET LEVEL) – (VOC BENEFITS FROM ALL SOURCES)

125.16-129.1 = -3.94

VOC PLAN PRESULTS IN 3.94 TPD SURPLUS21 *Includes a summation of all emissions reducti on from regulations that were effective prior to 2002.

Based on Table 3B, New York’s VOC control plan m eets the 15 Percent Plan reduction requirements. It result s in 3.94 tpd surplus.

In addition, the New York’s plan also controls NOx sources. Since there is a surplus in the VOC control plan all NOx emissions except thos e due to the pre-1990 FMVCP reductions and

correction of deficiencies in RACT rules are consider as surplus emissions from 2002-2008. See

Tables 3C and 3D

.

Section 3C: NOx Substitution Requi rements to Satisfy the 0% Shortfall

Steps involved in calculating the NOx Reductions Needed to Satisfy the 0% Percent shortfall:

1. Preparation of 2002 NOx Base Year Ozone Season Emission Inventory

2. Calculation of a 2002 Rate-of-Progress NOx (Baseline) Emission Inventory

3. Calculation of a 2002 NOx Adjusted Baseline Emission Inventory for 2008

4. Calculation of the 0% Reduction Requirement

5. Calculation of the non-credit able emission reductions

6. Calculation of Total Expected Reductions

7. Calculation of the NOx 2008 Target Inventory

8. Calculation of Emission Reductions Requi re to Meet the 2008 Target Level

9. Calculation of 2008 Projec tion Year Inventory

Preparation of 2002 NOx Base Year Ozone Season Emission Inventory

The reader is referred to S ection 1 of this document.

Calculation of a 2002 NOx Rate-of-Progress (Baseline) Emission Inventory22 The reader is referred to Section 2 (same proce dure as VOC is applied here) is applied this

document. The reader is referred to Table 3C for the calculation.

Calculation of a 2002 NOx Adjusted Baseline Emission Inventory for 2008

The 2002 adjusted baseline emission inventory for 2002 is calculated by subtracting from the

2002 baseline emission inventor y the emission benefits from the pre-1990 Clean Air Act

FMVCP.

The pre-1990 FMVCP reductions were determin ed by taking the difference between the 2002 highway mobile source emission inventory a nd the 2002 adjusted base line highway mobile source emission inventory for 2008.

To estimate the expected reductions from FMVCP standards, the State prepared an additional mobile source emission inventory using the Mob ile^ emission factor model, and changed the input variables to disable the modeling of 1990 Clean Air Act effects. The resulting inventory is referred to as the Adjusted Baseline Highway I nventory. This was done in accordance with the procedures outlined in EPA Guidance. 2,3,6

New York calculated the 2002 NOx Adjusted Base Year Inventory in accordance with EPA guidance.

Calculation of the 0% Reduction Requirement

New York calculated the required 0 percent reduc tions by multiplying the 2002 adjusted baseline emission inventory for 2008 by 0. The reader is referred to Table 3C for the calculation. This was done in accordance with the procedures in EPA Guidance. 2,3,6

New York calculated the 0 percen t reduction requirement in accord ance with EPA guidance.

Calculation of the non-creditable emission reductions

The same 15 percent RFP non-creditable reducti on category (FMVCP) applies as for the NOx RFP plan. The reader is referred to Table 3C for the calculation. This was done in accordance with the procedures in EPA Guidance. 2,3,6

New York has calculated the non-creditable em ission reductions in accordance with EPA guidance.23 Calculation of Total Expected NOx Reductions for 2008

New York calculated the total expected reduc tions by taking the sum of the non-creditable

emission reductions and the 0 Percent reduction requirement. The reader is referred to Table 3C

for the calculation. This was done in accordan ce with the procedures in EPA Guidance. 2,3,6

Calculation of the 2008 Target Inventory

New York calculated the 2008 target inventory by subtracting the re quired Percent reductions for

2008 and the non-creditable emission reductions from the 2002 baseline emission inventory. The

reader is referred to Table 3C for the calculation. This was done in accordance with the procedures in EPA Guidance. 2,3,6

New York has calculated the 2008 target in ventory in accordance with EPA guidance.

Calculation of Total Emission Reducti ons Needed to Reach 2008 Target Level

New York calculated the total emission reducti ons needed to reach 2008 NOx target level by taking the difference between the 2008 projected emission inventory (with no additional control measures and including any pre-1990 banked emission reduction cred its) and the 2008 NOx target inventory. The reader is referred to Table 3C for the calculation.

New York has calculated the 2008 total emission reductions needed to reach the 2008 target levels in accordance with EPA guidance. 2,3,6

Calculation of the 2008 Pr ojection Year Inventory

The reader is referred to Section 2 of this document for more details.

This was done in accordance with the procedures in EPA Guidance. 1,3,4,6,7 New York has followed EPA guidance in calculating its 2008 projection year emission inventory.

Table 3C provides a summary of the emissi on inventories calculated above.

Table 3C

------------------------------------ ----------------- ------------------------------------------------ ------------- 2008 NOx Emissions (Tons/Day) Northern-New Jersey NAA

------------------------------------ ----------------- ------------------------------------------------ ------------- A. 2002 Anthropogenic Base Y ear Emissions Inventory ........................................................................... ....762.50 B. 2002 Rate-of-Progress Inventory ...............................................................................................................762.50

C. Emission Reductions from the Pre-1990 FM VCP and Phase II RVP Expected by 2008 ........................... 30.70 D. 2002 Adjusted Base Year Inventory(B-C) ..................................................................................... ........... 731.80 E. 0% Percent Reduction Requirement (D x 0.00) ................................................................................ ............ 0.0024 F. Total Expected Reductions (E + C) ......................................................................................... ....................30.70 G. 2008 Target Level of Emissions (B - F) ..................................................................................... ...............731.80 H. 2008 Projection Year Inventor y (B + growth & offsets) ...................................................................... .....731.30 I. Total Emission reductions needed to reach 2008 NOx Target Level (H - G) ................................................. -0.5

------------------------------------ ----------------- ------------------------------------------------ -------------

The 2008 projection inventory is 0.5 tpd below th e 2008 Target level, therefore no NOx emission reduction are necessary to meet the 2008 target level.Section 3D: NOx Control Measures to Satisfy the 0% Shortfall

Table 3D

2008 NOx Emission Reduction Measures Included in the New York Plan

NOx CONTROL MEASURES NY Portion of the NYC-NJ-LI
Ozone NAA (Tons Per Day) REQUIRED REDUCTION IN NOx TO

MEET 2008 MILESTONE 0

POINT SOURCE CONTROL MEASURES

CAIR RULE 8.7

REMAINING POINT SOURCES *16.1

ERCS -4.7

NON-ROAD MOBILE SOURCE

CONTROL MEASURES 0

ON-ROAD MOBILE SOURCE CONTROL

MEASURES

LEV 2 18.9

NYVIP 5.3

FUELS 33.8

HEAVY DUTY DIESEL 3.6

REFLASH .1

STATIONARY AREA SOURDE CONTOL

MEASURES

CONSUMER PRODUCTS 0

PORTABLE FUEL CONTAINERS 0

AIMS COATING 0 MOBILE EQUIPMENT REPAIR 0

SOVENT METAL CLEANING 0

TOTAL NOx BENEFITS FROM ALL

SOURCES 81.8 NOx SHORTFALL = (NOx REDUCTIONS NEEDED TO MEET TARGET LEVEL) – (NOx BENEFITS FROM ALL SOURCES) 0.0-81.8 = -81.8

NOx PLAN PRESULTS IN 81.8 TPD SURPLUS

*Includes a summation of all emissi ons reduction from regulations that were effective prior to

2002.

25Based on Table 3D, New York’s NOx plan satisf ies the 0 percent shortfall . It results in 81.8 tpd surplus in NOx reductions.

Measures Included In New York’s RFP Plan

Gasoline Measures

Part 225-3: Fuel Consumption and Use - Gasoline

New York State adopted Subpart 225-3 of T itle 6 of the New York Codes, Rules and Regulations (6 NYCRR) to limit th e volatility, or Reid Vapor Pre ssure (RVP), of motor fuel statewide as a strategy for cont rolling VOC emissions from moto r vehicles. Specifically, this regulation established a maximum RVP of 9.0 pounds per square inch (psi) for all gasoline sold or supplied to retailers and w holesale purchaser-consumers anywhe re in New York State from May 1 through September 15 of each year.

Part 230: Gasoline Dispensing Sites and Transport Vehicles

This rule contains requirements for Stage I a nd Stage II gasoline dispensing site regulations. Stage I systems are required state- wide, while Stage II systems are mand ated only in the New York Metropolitan Area (NYMA) and lower Or ange County. Part 230 affects those gasolinedispensing sites whose annual throughput exceeds 120,000 gallons. (This minimum throughput level is waived for NYMA.)

A Stage I vapor collection system captures gasoline vapors which are displaced from underground gasoline storage tanks when those tanks are filled. These vapors are forced into a vapor-tight gasoline transport vehi cle or vapor control system th rough direct displacement by the gasoline being loaded. A Stage II vapor collection system captures at least 90 percent, by weight, of the gasoline vapors that are displaced or drawn from a vehicle fu el tank during refueling; these vapors are then captured and either retained in the storage tanks or destroyed in an emission

control device.

Federal Reformulated Gasoline - Phase I and II

Section 211(k) of the CAA deemed that reformulat ed gasoline must be sold in certain ozone nonattainment areas. Federal reformulated gasoline allows for a maximum of 1 percent benzene by

volume. Phase I of the rule took effect Janua ry 1, 1995 with preliminary VOC and air toxics standards. These reformulated gasoline standa rds were replaced with Phase II standards, effective January 1, 2000, which called for broade r emissions controls, requiring 25%-29% VOC

emission reductions and 20%-22% air toxics reductions. Retail distribution of reformulated gasoline is required in NYMA and Orange C ounty. Dutchess County and a portion of Essex County have voluntarily opted to use reformulated gasoline.

26NY Motor Vehicle Hardware Measures

Part 217: Motor Vehicle Emissions

To help limit ozone precursor emissions from mo tor vehicles, New York State has implemented 6 NYCRR Part 217, which contains em issions standards for in-use vehicles and applies to all

non-electric and non-diesel automob iles in the state. This rule al so requires that all affected

vehicles have an on-board dia gnostic system which functions co rrectly and meets certain design

standards.

Part 218: Emission Standards for Moto r Vehicles and Motor Vehicle Engines

In this rule, New York State requires that ne w light-duty vehicles sold in New York meet

California emissions standards.

Part 231: New Source Review in Non-Atta inment Areas and Ozone Transport Region

New Source Review (NSR) in non-attainment areas has been regulated by 6 NYCRR Part 231 of the New York State air pollution control regulations since 1979. Pa rt 231 was written to conform to federal guidelines and requirements on new s ources and modifications at major facilities in

non-attainment areas which would cause emissi on increases exceeding de minimus levels set forth in the regulation. The base requirements for applicable sources were that Lowest Achievable Emission Rate (LAER) be applie d and that emission offsets be provided.

VOC RACT EPA has approved regulations for prior SIP commitments for reducing emissions from nonmobile sources. Descriptions of these regulations are summarized in the following sections.

Part 212: General Process Emission Sources

This rule, which applies to both VOC and NOx em issions, requires the application of Reasonably Available Control Technology (RACT) for each emission point which emits NOx for major NOx facilities or VOCs for major VOC facilities. Its requirements are mostly generic, with specific requirements only for coating opera tions not subject to Part 228.

Part 226: Solvent Meta l Cleaning Processes

Part 226 puts forth guidelines for the cleaning of metal surfaces by VOC-containing substances. Listed in this regulation are specifications limitin g the vapor pressure solvents as well as those for control equipment and proper operating practi ces for a variety of degreasing operations, as well as general requirements for storage and recordkeeping. The Department may accept a lesser degree of control upon submission of satisfactory evidence that the person engaging in solvent

27metal cleaning is applying RACT and has a plan to develop the techno logies necessary to comply with the aforementioned sections.

Part 228: Surface Coating Pro cesses (Including Autobody Shops)

Part 228 limits the VOC content for each gallon of coating and sets minimum efficiency for VOC incinerators used as control equipment for VOC emissions from coating processes. It also provides for the use of source-specific analyses of control requirements where the requirements

of the rules cannot be met. Addi tionally, Part 228 contains requi rements for paints and coatings used in autobody refinishing and repairing, including spray equipment and housekeeping.

Part 229: Petroleum and Volatile Or ganic Liquid Storage and Transfer

This rule limits VOC emissions from applicable gasoline bulk plants, gasoline loading terminals, marine loading vessels, petroleum liquid storage tanks or organic liquid storage tanks. There are lower applicability thresholds for each process for NYMA than those for the Lower Orange County metropolitan area, upstate ozone non- atta inment areas, and areas not included above.

Part 233: Pharmaceutical and Cosm etic Manufacturing Processes

This rule limits VOC emissions from synthe sized pharmaceutical or cosmetic manufacturing processes at a major source faci lity located in NYMA. Compliance requires the installation of control devices, along with monitori ng, recordkeeping, and leak repair.

Part 234: Graphic Arts

This rule sets control requirements and limits VOC emissions from packaging rotogravure, publication rotogravure, flexographi c, offset lithographic or screen printing processes at a major source facility located in NYMA.

MACT

Under section 112 of the 1990 CAA Amendments, hazardous air pollutants (HAPs) are required to be controlled by technology determined to be the Maximum Achievable Control Technology (MACT). Since many organic HAPs are also VOCs, the use of MACT results in the reduction of

VOC and NOx emissions. New York has been ad opting MACT control requirements as they have been developed by EPA and has therefore been realizing the reducti ons resulting from the MACT program. These federal regulations are incorporated by reference in 6 NYCRR 200.10 (Tables 2, 3 and 4).

28Part 235: Consumer Products

The Consumer Products rule regulates the VOC content of consumer and commercial products that are sold to retail customers for persona l, household, or automotive use, along with the products marketed by wholesale distributors for us e in commercial or institutional settings such as beauty shops, schools and hospitals. The rule also includes labeling, re porting and compliance requirements that apply to ma nufacturers of these products.

Part 205: Architectural and Indus trial Maintenance (AIM) Coatings

This regulation limits the content of VOCs in AIM coatings by setting minimum VOC limits for AIM coatings. Part 205 also contains labeling and reporting requirements, compliance provisions

and test methods.

Part 208: Landfill Gas Collection and Control Systems for Certain Municipal Solid Waste

Landfills

This rule applies to the operation of munici pal solid waste (MSW) landfills exceeding stated capacities. For landfills whos e non-methane hydrocarbon emissions exceed 50 megagrams per year, the operator must submit a collection a nd control system design and permit application, along with operating standards for the control systems. The rule additionally contains requirements for monitoring, testi ng, recordkeepi ng and reporting.

Part 227: Stationary Combustion Installations

Subpart 227-2: Reasonably Available Control Technology (RACT) for Oxides of Nitrogen (NOx)

Subpart 227-2 sets NOx control limits for major source stationary combusti on installations. NOx RACT requirements applicable to particular appl icable combustion sources fall into one of two categories: presumptive RACT limits (which are of ten set as emission limits but also take other forms) or case-by-case RACT determinations . Presumptive RACT limits are category-wide requirements. However, for some sources, presumptive RACT limits may not be attainable. Case-by-case RACT determinati ons consider the technological and economic circumstances of

the source in these circumstances. Each case- by-case determination which establishes RACT requirements in a source's permit must be subm itted to the administrator as a separate SIP

revision.

Other NOx RACT Provisions

Additional RACT provisions include Part 220 whic h limits particulate and NOx emissions from portland cement plants, and Part 212, which app lies to general process sources. For the purpose of RACT analyses related to th e 8-hour ozone standard, RACT c onsists of technically feasible NOx control strategies to minimize NOx formation.

29Part 204: NOx Budget Trading Program

Part 204 sets requirements for how New York me ets the emissions budget for NOx established in

EPA's final rule entitled "Findi ng of Significant Contribution and Rulemaking for Certain States in the Ozone Transport Assessment Group Region for Purposes of Reducing Regional Transport of Ozone," otherwise known as the "NOx SI P Call." This rulemaking set a NOx emissions budget for New York for the five month summer season. New York is meeting this budget through control programs already in place and by limiting the NOx emissions of certain major stationary sources through the NOx budget trading program established under 6 NYCRR 204. Part 204 applies to the followi ng source categories: Electric Generating Units (EGUs) with nameplate capacities equal to or greater than 15 megawatts; non-EGUs with maximum design heat inputs equal to or greater than 250 m illion British thermal units (mmBTU) per hour; and portland cement kilns with maximum design heat inputs equal to or gr eater than 250 mmBTU per hour. The Department allocates the budget to sources within the above categories. Sources may hold or transfer allowances, but, at the end of each year's reconciliation period, must have enough allowances in its compliance accounts to cover emissions during the control period.

Conclusion New York has a SIP that fully demonstrates that 2008 projection inve ntory reporting and RFP requirements have been adequately met. To comply with requirements, the State submitted a complete 2008 projection inventory including point, area, on-road, and non-road mobile source data, and RFP

demonstration with th e support documentation.

Recommendation EPA is approving this SIP submitta l because it meets the essential reporting requirements for an Emission Inventory and adequate RFP demonstration.

Emission Inventory Guidance Documents

1 Emission Inventory Improvement Program guidance document titled Volume X, Emission Projections

, dated December 1999

2 Guidance on the Adjusted Base Year Emissions I nventory and the 1996 Target for the 15 Percent Rate of Progress Plans , dated October 1992

3 Guidance for Growth Factors, Projections, and Contro l Strategies for the 15 Percent Rate of Progress

Plans , dated March 1993

4 Guidance on the Post-1996 Rate of Progre ss Plan and Attainment Demonstration , dated January 1994

305 Emission Inventory Guidance for Implementati on of ozone and Particulate Matter NAAQS and Regional Haze Regulation , dated September 2005

6 EPA’s follow-up memo “8-Hour Ozone National Ambient Air Quality Standards ImplementationReasonable Further Progress (RFP) , dated August 2006

7 Guidance on the Use of Models and Other Analyses for Demonstration Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze , dated April 2007

3132 III. CONTINGENCY MEASURES

Contingency Measures for the 2008 RFP Demonstration

EPA requires that the contingency measures account for one year of RFP reductions, or 3 percent of the adjusted baseline VOC emissions i nventory for the particular projection year. 1 Thus, the contingency measures for the 2008 RFP must total 3 percent of the 2002 adjusted base year VOC emissions inventory. EPA also allows for subs titution of NOx reductions for VOC reductions in the contingency measure plans on a percentage basis. 2 However, the EPA requires that at least 0.3 percent of the total 3 percent reduction be VOC emission reductions. 3 Furthermore, the EPA allows the use of emission reductions from the early implementation of strategies to be used for contingency measure reduction. 4

.

EPA evaluation:

New York determined the required emission reducti ons for its RFP contingency plans consistent with the Act, as interpreted in EPA’s regula tions, guidance and policie s and identified the specific measures needed to achieve them. All the emission reductions included in the RFP contingency plans are from adopted measures and ha ve not been used in the SIP to meet some other requirement. EPA is satisfied that th e State’s RFP contingency plans meet agency requirements.

Contingency measures are also required for the atta inment plan, that is, additional reductions in

case a state does not attain in the year it is suppose to. New York provided contingency measures for its attainment year, but EPA is deferring action on the attainment contingency measures. EPA will act on these measures when it acts on an approvable attainment

demonstration.

1 57 FR 13498 (April 16, 1992).

2 USEPA. NOx Substitution Guidance. United Stat es Environmental Protection Agency, Office of Air Quality Planning and Standards, Re search Triangle Park, NC, December 1993.

3 USEPA Memorandum from Michael H. Shapiro to Region Air Directors, “Guidance on Issues

Related to 15 Percent Rate-of- Progress Plans,” August 23, 1993.

4 USEPA Memorandum from Gary T. Helms, Ch ief, Ozone/Carbon Monoxide Branch, “Early Implementation of Contingency Measures for Ozone and Carbon Monoxide (CO) Nonattainment Areas,” August 13, 1993.