UNITED STATES ENVIRONMENTAL 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 2011
1

Table of Contents 

Chapter 

I. EMISSION INVENTORY 

II. REASONABLY FURTHER PROGRESS PLAN 

III. CONTINGENCY MEASURES
2

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 annual and summertime emissions for VOC, NOx, 

CO for the New York portion of the New York City-Northern New Jersey-Long Island and 

Poughkeepsie ozone nonattainment and attainment areas. This TSD contains a detailed review 

of New York’s 2002 Base Year emissions inventory 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 for the eight hour-ozone, PM2.5 and CO national 

ambient air quality standard. Identifying the base year gives certainty to States, and the selection 

of 2002 harmonized the date for EPA’s Consolidated Emissions Reporting rule (See 67 FR 

39602) dated June 10, 2002.) that requires submission of the ozone, PM2.5 and CO emission 

inventories every three years; 2002 is one of the required years for such updates. These 

requirements allow the EPA, based on the state’s progress in reducing emissions, to periodically 

reassess its policies and air quality standards and revise them as necessary. Most important, the 

2002 ozone, new PM2.5 and CO inventories will be used to develop and assess new control 

strategies that the states will need 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 inventories for purposes of regional modeling in transport 

areas. The base year inventory plays an important role in modeling demonstrations for areas 

classified as nonattainment and outside transport regions. For the reasons stated above, ideally 

EPA would therefore emphasize the importance and benefits of developing a comprehensive, 

current, and accurate 2002 ozone and PM2.5 emission 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 the emission inventory must meet the minimum 

requirements for reporting by source category. Specifically, the source requirements are detailed 

below. 
3

The Level I and II review process is used to determine that all components of the base year 

inventory are present. The review also evaluates 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 and consists of 9 points that the inventory must 

adequately address. For a base year emission inventory to be acceptable it must pass all of the 

following acceptance criteria: 

Adequate documentation must be provided that enabled the reviewer to determine the emission 

estimation procedures and the data sources used to develop the inventory. 

1. Evidence that the inventory was quality 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 been 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 nonattainment areas and statewide. See Tables 1A-3B. 

This TSD contains a detail discussion and summary of the review conducted by EPA for, where 
4

applicable, the 2002 base year inventory annual 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, NOx 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 1,809,229
5

 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, NOx 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 42,689 189,510 243,914
6

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, NOx 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 Criteria 1 for the Quality Assurance Plan

Quality Assurance Plan Implementation 

The Quality Assurance (QA) plan was implemented 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 relative to the inventory sources were assessed for 

completeness. QA checks were performed relative 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 performed in accordance with EPA Guidance.1,2 
7

B. Details on How New York Satisfies Criteria 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 describes how point source activity levels and their associated 

parameters are developed, and how the data are used to calculate emission estimates. The report 

references document for activity level and emission factors used and provides sample actual 

activity data and emissions factors. Information on how rule effectiveness and control 

efficiencies are applied and the associated sample calculations with numerical values are 

provided. Where applicable, annual and summertime daily point source emissions are presented 

for VOC, NOx and CO for the ozone nonattainment and attainment areas. Plant summary 

information on detailed plant, county and nonattainment 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 categories that are included in the area source inventory. Area 

source emissions are presented on a source category, 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 calculations. Referenced information for the input 

values to equations is included. Point source contributions have been correctly factored out of 

the area source category totals where appropriate. Rule effectiveness, control efficiency and rule 

penetration are correctly 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 Criteria 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 service equipment, light 

commercial equipment, lawn and garden equipment...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 summertime emissions are provided for VOC, NOx 

and CO. Nonroad mobile source emissions are presented on a source by source category basis 

and county basis. Thus, the inventory was developed in accordance with EPA Guidance.1,2 
8

Aircraft Emissions

Aircraft emissions are provided for VOC, NOx and CO and calculated based on the number of 

landing and takeoffs (LTO) cycles generated at each airport. These values are used as inputs to 

the Emissions and Dispersion Modeling System, the Federal Aviation Agency modeling tool. . 

Where applicable, total combined nonroad mobile annual and summertime daily emissions are 

provided for VOC, NOx and CO for the ozone nonattainment 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 Development Authority (NYSERDA). The locomotive 

inventory is based upon a survey conducted 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. Information on how the emissions 

are calculated and the emission factors used are provided. The NYSERDA report was provided. 

The inventory was developed in accordance with EPA Guidance.1,2 

Commercial Marine Vessel Emissions

Commercial marine vessel (CMV) emissions for VOC, NOx and CO are prepared by Starcrest 

Consulting Group, LLC. The inventory report relied on actual operational data and then used 

local activity parameters to extend emission estimates to those portions of the CMV not directly 

inventoried. From this information, emission 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 emissions 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 Criteria 8 and 9 for the Onroad Source 

Inventory

Onroad Mobile Source Inventory

New York’s mobile source inventory was developed by using 2002 daily vehicle miles traveled 

(DVMT) inventory constructed by the New York State Department of Transportation to provide 

DVMT estimates by county, geographic component (urban, small urban and rural) and functional 

classes. The resulting VMT by county and functional class is then multiplied by a seasonal 

adjustment factor to account for seasonal differences. The VMT mix for each of the regions in 
9

New York State is used to produce VMT by vehicle type. Estimates are developed from the 

aforementioned sources for each roadway functional 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 explains 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 the 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 combined on-road mobile emissions by county are 

provided. Where applicable, annual and summertime daily emissions are provided for VOC, 

NOx, and CO for the ozone nonattainment and attainment 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 requirements 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 Implementation 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 1992 
10

II. REASONABLE FURTHER PROGRESS PLAN 

1. PREFACE 

This document is to support EPA's evaluation 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 York 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 emissions inventory is also an integral part of the plan. 

However, detailed evaluation of the 2002 inventory will not be addressed in this document. 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 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 the 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 regulations (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 reductions 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 area. The emissions inventory for an ozone 

nonattainment area contains VOC and NOx emissions as these pollutants are precursors to ozone 

formation. In this case, the baseline emissions inventory is for the year 2002. 

The 15 Percent Reasonable Further Progress 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 serious area which contains a portion of an area 
11

with an approved 15% VOC “Rate of Progress” plan under the 1-hour ozone standard, States are 

allowed to treat the area as two parts each with a separate RFP target. For the part with an 

approved 15% VOC "Rate of Progress" plan under 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, States must obtain VOC reductions. These VOC reductions can be 

obtained from the part of the area with an approved 1-hour VOC Rate 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 developed in accordance with the 

procedures outlined EPA’s latest guidance 1,3,4,6,7? 

2. Was the 15 Percent Plan developed in accordance 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 Strategies 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 discussion 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 Nonattainment Areas and Attainment Areas, dated November 18, 

2010 for details on the proposed approval of New York’s 2002 base year inventory. New York 
12

submitted it’s proposed 2002 base year emission inventories and final 2002 base year emission 

inventories. 

Table 1A below shows the revised 2002 base year volatile organic compounds (VOC) and 

oxides of nitrogen (NOx ) emission inventories for the New York Portion of the New York CityNorthern New Jersey-Long Island ozone nonattainment area.

Table 1A

New York City-Long Island Ozone Nonattainment Area 

2002 Base Year Inventory [Ozone Season VOC and NOx 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

Section 2: Calculation of 2008 Projection Year Emission Inventories 

A projection of 2002 VOC anthropogenic emissions 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 determine 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 base 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, the total growth from 2002 to 2008 four VOC source categories 

(point, area, non-road and on-road mobile) for the New York portion of the New York CityNorthern New Jersey-Long Island ozone nonattainment area is estimated at 52.6, -37.4, -68.4 and 

-72.7 tons per day (tpd), respectively. The total 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 were first calculated by 

estimating growth in each source category. As appropriate, the 2002 actual 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 facility 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 were first calculated by 

estimating growth in each source category. As appropriate, the 2002 actual 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 inventory to 2008. The 2008 inventory was constrained as a more 

conservative approach because emissions from 2005-2008 are more likely to decrease due to the 

Clean Air Interstate Rule (CAIR) or CAIR reduction 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 Demonstration for New York Metro Area, dated February 2008. 

This document provides further details and references on how projections 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 projecting point sources to be acceptable. 

Area Sources

For the area source category, New York projected 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 accordance with EPA’s recommended growth indicators 

for projecting emissions for area source categories 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 Demonstration 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 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 activity. This model was used to calculate past and 

future emission inventories for all nonroad equipment categories except commercial marine 

vessels, locomotives and aircrafts. EPA finalized nonroad mobile model regulations are built 

into the current version of the model. The nonroad mobile projection inventories automatically 

reflect any regulations that will occur in the future. The model does not allow for estimation of 

projection inventories without future regulations in place for comparison purposes. As a result, 

uncontrolled projected 2008 nonroad mobile emissions 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 Demonstration 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 projecting non-road mobile sources to be 

acceptable. 

Onroad Mobile Sources

For the onroad mobile source category, the primary 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 emission 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 Demonstration for New York Metro Area, dated February 2008. 

This document provides further details and references on how projections were performed. These 

growth indicators are some of the preferred growth 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 associated 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 emission inventories (uncontrolled after 2002 

using the aforementioned growth indicators/methodologies 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 Island ozone nonattainment area. 

Table 2A

New York Portion of the New York City-Northern New Jersey-Long Island 

Ozone Nonattainment Area 

2008 Projection Year Inventory (Uncontrolled) 

 [Ozone Season VOC and NOx 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

NOx 199 84.5 174.4 273.5 731.4
16

Table 2B

New York Portion of the New York City-Northern New Jersey-Long Island 

Ozone Nonattainment Area 

2008 Projection Year Inventory (Controlled) 

[Ozone Season VOC and NOx 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 

NOx 178.9 84.4 174.4 211.8 649.5 

Section 3: 2008 RFP Demonstration 

Section 3A: 15% VOC RFP Plan or 2008 RFP Demonstration 

Steps involved in calculating the 2002 Percent RFP Plan: 

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

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

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

4. Calculation of the 2008 Reduction Requirement 

5. Calculation of the non-creditable emission reductions 

6. Calculation of Total Expected Reductions 

7. Calculation of the 2008 Target Inventory 

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

9. Calculation of 2008 Projection Year Inventory 
17

Preparation of 2002 VOC Base Year Ozone Season Anthropogenic Emission Inventory

The reader is referred to Section 1 of this document. 

Calculation of a 2002 VOC Rate-of-Progress (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 inventory the emission benefits from the pre-1990 Clean Air Act 

Federal Motor Vehicle Control Program (FMVCP). 

The pre-1990 FMVCP reductions were determined by taking the difference between the 2002 

highway mobile source emission inventory and the 2002 adjusted baseline 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 Adjusted Baseline Highway Inventory. This was 

done in accordance with the procedures outlined in EPA Guidance.2,3,6 

New York calculated the 2002 Adjusted Base 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 procedures outlined in EPA Guidance.2,3,6

New York calculated the 2008 percent reduction requirement in accordance with EPA 

guidance. 

Calculation of the non-creditable emission reductions
18

The 15 percent RFP Plan non-creditable reduction 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 reductions 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 target inventory by subtracting the required Percent 

reductions for 2008 and the non-creditable emission reductions from the 2002 baseline 

emission inventory. The reader 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 inventory in accordance with EPA guidance. 

Calculation of Total Emission Reductions Needed to Reach 2008 Target Levels 

New York calculated the total emission reductions needed to reach 2008 target levels by 

taking the difference between the 2008 projected emission inventory (with no additional 

post-2002 control measures) and the 2008 target inventory. The reader is referred to Table 

3A for the calculations. 

New York has calculated the 2008 total emission reductions needed to reach the 2008 

target levels in accordance with EPA guidance. 

Calculation of the 2008 Projection 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 calculating the 2008 projection year emission 

inventory. 
19 

Table 3A provides a summary of the emission inventories calculated above. 

 Table 3A 

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

2008 VOC Emissions (Tons/Day) for the 

New York Portion of the New York City-Northern New Jersey-Long Island 

Ozone Nonattainment Area 

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

A. 2002 Anthropogenic Base Year 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 Included 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 CONTAINERS 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 SURPLUS 
21 

*Includes a summation of all emissions reduction from regulations that were effective 

prior to 2002. 

Based on Table 3B, New York’s VOC control plan meets the 15 Percent Plan reduction 

requirements. It results 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 those 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 Requirements 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-creditable emission reductions 

6. Calculation of Total Expected Reductions 

7. Calculation of the NOx 2008 Target Inventory 

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

9. Calculation of 2008 Projection Year Inventory 

Preparation of 2002 NOx Base Year Ozone Season Emission Inventory

The reader is referred to Section 1 of this document. 

Calculation of a 2002 NOx Rate-of-Progress (Baseline) Emission Inventory
22 

The reader is referred to Section 2 (same procedure 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 inventory the emission benefits from the pre-1990 Clean Air Act 

FMVCP. 

The pre-1990 FMVCP reductions were determined by taking the difference between the 2002 

highway mobile source emission inventory and the 2002 adjusted baseline 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 Mobile^ 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 Inventory. 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 reductions 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 percent reduction requirement in accordance with EPA guidance. 

Calculation of the non-creditable emission reductions

The same 15 percent RFP non-creditable reduction 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 emission reductions in accordance with EPA 

guidance. 
23 

Calculation of Total Expected NOx Reductions for 2008 

New York calculated the total expected reductions 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 accordance 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 required 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 inventory in accordance with EPA guidance. 

Calculation of Total Emission Reductions Needed to Reach 2008 Target Level 

New York calculated the total emission reductions 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 credits) 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 Projection 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 emission inventories calculated above. 

Table 3C

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

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

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

A. 2002 Anthropogenic Base Year Emissions Inventory ...............................................................................762.50

B. 2002 Rate-of-Progress Inventory ...............................................................................................................762.50

C. Emission Reductions from the Pre-1990 FMVCP 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) ............................................................................................ 0.00
24 

F. Total Expected Reductions (E + C) .............................................................................................................30.70

G. 2008 Target Level of Emissions (B - F) ....................................................................................................731.80

H. 2008 Projection Year Inventory (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 the 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 emissions reduction from regulations that were effective prior to 

2002. 

25 
Based on Table 3D, New York’s NOx plan satisfies 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 Title 6 of the New York Codes, Rules and 

Regulations (6 NYCRR) to limit the volatility, or Reid Vapor Pressure (RVP), of motor fuel 

statewide as a strategy for controlling VOC emissions from motor 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 wholesale purchaser-consumers anywhere 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 and Stage II gasoline dispensing site regulations. 

Stage I systems are required state- wide, while Stage II systems are mandated only in the New 

York Metropolitan Area (NYMA) and lower Orange 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 vehicle or vapor control system through 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 fuel 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 reformulated 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 January 1, 1995 with preliminary VOC and air toxics 

standards. These reformulated gasoline standards were replaced with Phase II standards, 

effective January 1, 2000, which called for broader 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 County. Dutchess County and a portion of Essex 

County have voluntarily opted to use reformulated gasoline. 

26 
NY Motor Vehicle Hardware Measures

Part 217: Motor Vehicle Emissions 

To help limit ozone precursor emissions from motor vehicles, New York State has implemented 

6 NYCRR Part 217, which contains emissions standards for in-use vehicles and applies to all 

non-electric and non-diesel automobiles in the state. This rule also requires that all affected 

vehicles have an on-board diagnostic system which functions correctly and meets certain design 

standards. 

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

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

California emissions standards. 

Part 231: New Source Review in Non-Attainment 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. Part 231 was written to conform 

to federal guidelines and requirements on new sources and modifications at major facilities in 

non-attainment areas which would cause emission increases exceeding de minimus levels set 

forth in the regulation. The base requirements for applicable sources were that Lowest 

Achievable Emission Rate (LAER) be applied 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 emissions, 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 operations not subject to Part 228. 

Part 226: Solvent Metal Cleaning Processes 

Part 226 puts forth guidelines for the cleaning of metal surfaces by VOC-containing substances. 

Listed in this regulation are specifications limiting the vapor pressure solvents as well as those 

for control equipment and proper operating practices 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 

27 
metal cleaning is applying RACT and has a plan to develop the technologies necessary to 

comply with the aforementioned sections. 

Part 228: Surface Coating Processes (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. Additionally, Part 228 contains requirements for paints and coatings 

used in autobody refinishing and repairing, including spray equipment and housekeeping. 

Part 229: Petroleum and Volatile Organic 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- attainment areas, and areas not included above. 

Part 233: Pharmaceutical and Cosmetic Manufacturing Processes 

This rule limits VOC emissions from synthesized pharmaceutical or cosmetic manufacturing 

processes at a major source facility located in NYMA. Compliance requires the installation of 

control devices, along with monitoring, recordkeeping, and leak repair. 

Part 234: Graphic Arts 

This rule sets control requirements and limits VOC emissions from packaging rotogravure, 

publication rotogravure, flexographic, 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 adopting MACT control requirements as they 

have been developed by EPA and has therefore been realizing the reductions resulting from the 

MACT program. These federal regulations are incorporated by reference in 6 NYCRR 200.10 

(Tables 2, 3 and 4). 

28 
Part 235: Consumer Products

The Consumer Products rule regulates the VOC content of consumer and commercial products 

that are sold to retail customers for personal, household, or automotive use, along with the 

products marketed by wholesale distributors for use in commercial or institutional settings such 

as beauty shops, schools and hospitals. The rule also includes labeling, reporting and compliance 

requirements that apply to manufacturers of these products. 

Part 205: Architectural and Industrial 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 municipal solid waste (MSW) landfills exceeding stated 

capacities. For landfills whose non-methane hydrocarbon emissions exceed 50 megagrams per 

year, the operator must submit a collection and control system design and permit application, 

along with operating standards for the control systems. The rule additionally contains 

requirements for monitoring, testing, recordkeeping 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 combustion installations. NOx 

RACT requirements applicable to particular applicable combustion sources fall into one of two 

categories: presumptive RACT limits (which are often 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 determinations 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 submitted to the administrator as a separate SIP 

revision. 

Other NOx RACT Provisions 

Additional RACT provisions include Part 220 which limits particulate and NOx emissions from 

portland cement plants, and Part 212, which applies to general process sources. For the purpose 

of RACT analyses related to the 8-hour ozone standard, RACT consists of technically feasible 

NOx control strategies to minimize NOx formation. 

29 
Part 204: NOx Budget Trading Program 

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

EPA's final rule entitled "Finding 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 SIP 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 following 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 million British thermal units (mmBTU) per hour; and 

portland cement kilns with maximum design heat inputs equal to or greater 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 inventory 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 the support documentation. 

Recommendation 

EPA is approving this SIP submittal 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 Inventory and the 1996 Target for the 15 Percent Rate 

of Progress Plans, dated October 1992 

3

Guidance for Growth Factors, Projections, and Control Strategies for the 15 Percent Rate of Progress 

Plans, dated March 1993 

4

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

30 
5Emission Inventory Guidance for Implementation 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 

31 
32 

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 inventory 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 substitution 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 reductions for its RFP contingency plans consistent 

with the Act, as interpreted in EPA’s regulations, guidance and policies and identified the 

specific measures needed to achieve them. All the emission reductions included in the RFP 

contingency plans are from adopted measures and have not been used in the SIP to meet some 

other requirement. EPA is satisfied that the State’s RFP contingency plans meet agency 

requirements. 

Contingency measures are also required for the attainment 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 States Environmental Protection Agency, Office 

of Air Quality Planning and Standards, Research 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, Chief, Ozone/Carbon Monoxide Branch, “Early 

Implementation of Contingency Measures for Ozone and Carbon Monoxide (CO) Nonattainment 

Areas,” August 13, 1993.