Revision to the 

New Hampshire 

State Implementation Plan 

Request for 

Redesignation of the Boston-Manchester-Portsmouth (SE), NH 

8-Hour Ozone (1997 Standard) Nonattainment Area 

March 2, 2012 

~ NEW HAMPSHIRE 

DEPARTMENT OF 

Environmental 

= Services 

Air Resources Division 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page i 

TABLE OF CONTENTS 

1 . INTRODUCTION 

1 .1 Original Designation of Ozone Nonattainment Areas. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 

1 .2 Description of the Southeast New Hampshire Nonattainment Area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 

1 .3 Status of Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 

2 . ATTAINMENT OF THE STANDARD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 

2.1 Ozone Monitoring Network. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 

2.2 Summary of Ozone Monitoring Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 

2.2 .1 Annual Fourth-Highest Ozone Values. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 

2.2 .2 Ozone Design Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 

2 .2 .3 Threshold Analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 

2 .2 .4 Ozone-Related Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 

2 .2 .4 .1 Oxides of Nitrogen (NOx). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 

2 .2 .4 .2 Volatile Organic Compounds (VOC). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 

2.3 Summary of Meteorological Analyses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 

2 .3 .1 Temperature vs. Ozone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 

2 .3 .2 Wind Direction Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 

3 . STATE IMPLEMENTATION PLAN FOR NONATTAINMENT AREA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 

3 .1 Recent SIP Revisions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15 

3 .2 Reasonably Available Control Technology Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 

3 .3 1-Hour Ozone Attaimnent Demonstration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 

3 .4 Reasonable Further Progress Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 

3 .5 Clean Data Rule for 8-Hour Ozone Attainment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 

4. PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 

4.1 Emission Control Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 

4.2 Upwind Emission Reductions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23 

4.3 In-State Emission Reductions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 

5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT. . . . . . . . . . . . . . . . . . . . . 27 

5.1 Requirements of Section 110(a)(2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 

5.1 .1 Emission Reporting and Recordkeeping. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29 

5.1 .2 Periodic Testing and Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29 

5.1 .3 Transportation-Related Control Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29 

5.1 .4 Continuous Monitoring and Recording of Emissions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 

5.1 .5 Legal Authority and Emergency Powers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29 

5.2 Continuance of Existing Control Requirements after Redesignation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 

5.3 Permitting of Stationary Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32 

5 .4 Monitoring of Stationary Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32 

5 .5 Transportation Conformity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33 

5 .6 Vapor Recovery: Stage 11 and Onboard Refueling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page ii 

5 .7 Resource Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .35 

5 .8 Future Revisions to the Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .35 

6 . MAINTENANCE PLAN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36 

6.1 Attainment Inventory. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36 

6.2 Maintenance Demonstration. . . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .37 

6.2 .1 Projected 2012 and 2022 Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 

6.2 .2 Air Quality Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39 

6.2 .2 .1 EPA Modeling Analysis for the Nonroad Land-Based Diesel Engines Standards . . . . . . . . . 39 

6.2 .2 .2 EPA Modeling Analysis for the CAIR Rulemaking. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 

6.3 Air Quality Monitoring Network. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40 

6.4 Verification of Continued Attainment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41 

6.5 Contingency Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41 

6 .5 .1 ICI Boilers (at Major Point Sources) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43 

6 .5 .2 Emulsified Asphalt Paving. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43 

6 .5 .3 Consumer Products. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43 

6 .5 .4 Additional Controls on Boilers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43 

6 .5 .5 Other Contingency Measures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44 

7. ADMINISTRATIVE DOCUMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45 

8. SUMMARY AND CONCLUSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .46 

LIST OF FIGURES 

Figure 1-1 Map of New Hampshire's Former 1-Hour Ozone Nonattainment Areas . . . . . . . . . . . . . . . . . . . . . . 2 

Figure 1-2 Map of New Hampshire's Attainment Status for 1997 8-Hour Ozone NAAQS. . . . . . . . . . . . . . 3 

Figure 2-1 Ozone-Related Air Quality Monitors in New Hampshire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 

Figure 2-2 8-Hour Ozone Trends in the Southeast New Hampshire Nonattainment Area, 

1990-2011 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 

Figure 2-3 8-Hour Ozone Trends in New Hampshire Attainment Areas, 1990-2011 . . . . . . . . . . . . . . . . . . . . . 7 

Figure 2-4 8-Hour Ozone Design Value Trends in the Southeast New Hampshire 

Nonattainment Area, 1990-2011 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .8 

Figure 2-5 NOx Trends in New Hampshire, 1998-2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 

Figure 2-6 NOx Trends in Maine, 1998-2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 

Figure 2-7 NOx Trends in Massachusetts, 1998-2010. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 

Figure 2-8 Ozone-Season Average NOx Concentrations in the Ozone Transport Region, 

1998-2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 

Figure 2-9 TNMOC and PAMHC Trends in New Hampshire, Maine, and Massachusetts, 

1998-2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 

Figure 2-10 Average TNMOC and PAMHC in Nashua, New Hampshire, 2006-2010. . . . . . . . . . . . . . . . . . . . . 11 

Figure 2-11 Average TNMOC and PAMHC on Pack Monadnock in Peterborough, 

New Hampshire, 2006-2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 

Figure 2-12 Number of Days with Exceedances of the 1997 8-Hour Ozone Standard in 

New Hampshire, 1985-2011 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page iii 

Figure 2-13 Number of Days with Maximum Temperatures above 85 F and Number of Days 

with Ozone Exceedances in New Hampshire, 1985-2011 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 

Figure 2-14 New Hampshire Wind Direction Frequencies in the Months of April through 

September, 1995-2010. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14 

Figure 4-1 Ozone-Season NOx Emissions from All NOx Budget Trading Program Sources . . . . . . . . . . . . 24 

Figure 4-2 Ozone-Season NOx and VOC Emissions in the Eastern United States by 

Source Category: 1997, 2002 and 2004. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 

Figure 4-3 Ozone-Season Daily NOx Emissions in New Hampshire by Source Category: 

2002, 2005, and 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 

Figure 4-4 Ozone-Season Daily VOC Emissions in New Hampshire by Source Category: 

2002, 2005, and 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 

LIST OF TABLES 

Table 1-1 New Hampshire Designations/Classifications for 8-Hour Ozone Standard: 

Nonattainment Areas, Effective June 15, 2004. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 

Table 2-1 8-Hour Ozone Monitoring Data: 2012 Threshold Values and 2010-2011 Design Values 

Based on Fourth-Highest Annual Maxima (ppb). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 

Table 4-1 Federal Emission Control Programs for NOx and VOC in the Southeast New Hampshire 

Nonattainment Area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 9 

Table 4-2 State Emission Control Regulations for NOx and VOC in the Southeast New Hampshire 

Nonattainment Area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 

Table 4-3 NOx and VOC RACT Orders Issued in New Hampshire, 2001-Present. . . . . . . . . . . . . . . . . . . . . . . . 23 

Table 4-4 NOx and VOC Emissions in New Hampshire, 2002, 2005, and 2008 (tons/year) . . . . . . . . . . . . . 26 

Table 5-1 2008 and 2022 Motor Vehicle Emission Budgets for the Southeast New Hampshire 

Nonattainment Area (tons per summer day). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34 

Table 6-1 2008 vs. 2012 and 2022 NOx and VOC Emissions in the Southeast New Hampshire 

Nonattainment Area (pounds per day) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .38 

Table 6-2 Summary of CAIR Modeling Results for Ozone Levels in New Hampshire (ppb) . . . . . . . . . . . . . . 40 

Table 6-3 Estimated Emission Reductions from Three BOTW Control Measures . . . . . . . . . . . . . . . . . . . . . . . . 43 

Table 6-4 Potential Contingency Measures for Reducing Ozone Levels .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45 

LIST OF ATTACHMENTS 

ATTACHMENT A 

ATTACHMENT B 

ATTACHMENT C 

ATTACHMENT D 

ATTACHMENT E 

ATTACHMENT F 

ATTACHMENT G 

ATTACHMENT H 

Technical Support Document for Redesignation of the Boston-ManchesterPortsmouth (SE), NH 8-Hour Ozone (1997 Standard) Nonattainment Area 

8-Hour Ozone Data 

Chemical Analyses 

Meteorological Analyses 

Administrative Documents 

MOVES Input/Output Files for 2008 and 2022 Motor Vehicle Emissions Budgets 

Documentation for 2008 Emissions Inventory ' 

Projected 2012 and 2022 Emissions Inventories 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page iv 

This page intentionally left blank. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 1 

1 . INTRODUCTION 

The New Hampshire Department of Environmental Services (NHDES) presents this report as 

documentation for its request to the Environmental Protection Agency (EPA) to redesignate the 

Boston-Manchester-Portsmouth (SE), NH ozone nonattainment area to attainment of the 8-hour 

ozone standard of 0.08 parts per million (ppm) promulgated in 1997 . Ground-level ozone 

monitoring data from 2002-2011 show these New Hampshire counties are now in attainment for this 

standard . 

Section 107(d)(3)(E) of the Clean Air Act (CAA) establishes that, for an area to be redesignated, 

several determinations and approvals from the EPA Administrator are required. EPA provided 

guidance on redesignation in the General Preamble for the Implementation of Title I of the CAA 

Amendments of 1990, on April,16, 1992 (57 FR 13498), and supplemented this guidance on April 

28, 1992 (57 FR 18070) . EPA has provided further guidance on processing redesignation requests 

in subsequent memoranda. The following lists the determinations and approvals required from the 

EPA Administrator: 

0 

0 

A determination that the area has attained the 8-hour ozone standard, 

Approval of a State Implementation Plan (SIP) for the area under Section 110(k) of the 

Clean Air Act, 

A determination that the improvement in air quality is due to permanent and enforceable 

reductions in emissions resulting from implementation of the SIP and other federal 

requirements, 

Approval of a maintenance plan under Section 175A of the Clean Air Act, and 

A determination that the state has met all Title I, Part A, Section 110, and Part D requirements 

for the area. 

Each of these requirements is addressed within the main body of this submittal. In addition, a 

technical support document is provided in Attachment A. The technical support document is 

presented in two sections. The first provides a conceptual description of the nature of ozone 

formation and transport in the Northeast. The second describes a photochemical air quality 

modeling assessment that was undertaken in 2007 by New Hampshire and other Ozone Transport 

Region states . The results of this modeling assessment were used by states for attainment 

demonstrations and other SIP planning purposes. They are offered for review in the technical 

support document because they support the conclusions of this redesignation request. 

NHDES is also submitting as part of this redesignation request a 2022 motor vehicle emissions 

budget (MVEB) for the area. The MVEB will be used to assure that emissions from on-road mobile 

sources do not exceed levels consistent with maintenance of the 1997 8-hour ozone standard . 

1.1 Original Designation of Ozone Nonattainment Areas 

Under the 1990 Clean Air Act Amendments, all or portions of five counties in New Hampshire were 

designated as nonattainment areas for the former 1-hour National Ambient Air Quality Standard 

(NAAQS) of 0 .12 parts per million (ppm) for ground-level ozone (see Code of Federal Regulations 

40 CFR 81 .330) : 

. All of Strafford County and large portions of Hillsborough and Rockingham Counties were 

designated as "serious" nonattainment areas; 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 2 ' 

The remaining portions of Hillsborough and Rockingham counties plus all of Merrimack 

County were designated as "marginal" nonattainment areas ; and 

All of Cheshire County was designated as a nonattainment area with incomplete data. 

These former 1-hour ozone nonattainment areas are shown in Figure 1-1 . 

Figure 1-1 . Map of New Hampshire's Former 1-Hour Ozone Nonattainment Areas 

STATE OF 

NEW HAMPSHIRE 

1-Hour Ozone 

Nonattainment Areas 

0 

I I 

Seacoast Serious Area 

Nonattainmentl 

Incomplete Data 

Attainment or 

Unclassifiable 

Areas 

On July 18, 1997, EPA promulgated a new 8-hour ozone standard to replace the 1-hour standard for 

ground-level ozone (62 FR 38855) . The 8-hour ozone NAAQS, which was set at a level of 0 .08 

parts per million (ppm) and is based. on an 8-hour average of ambient ozone concentrations, more 

directly relates to ozone levels associated with adverse health effects. After the resolution of 

numerous legal challenges, on April 30, 2004, EPA published final attainment designations (69 FR 

23857) for the 1997 8-hour ozone NAAQS. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 3 

The Boston-Manchester-Portsmouth (SE), NH nonattainment area (hereinafter referred to as the 

Southeast New Hampshire Nonattainment Area) was created covering the southeastern-most portion 

of the state (see Figure 1-2). This nonattainment area, which includes portions of four counties 

(Hillsborough, Merrimack, Rockingham, and Strafford), was classified as "Subpart 2/moderate" 

nonattainment for the 8-hour ozone standard.' The area designations/classifications were based on 

2000-2002 data and the recommendations of NHDES in a letter submitted to EPA on July 15, 2003 . 

The moderate nonattainment classification was selected to be consistent with contiguous 

nonattainment areas in Massachusetts and Maine. 

Figure 1-2. Map of New Hampshire's Attainment Status for 1997 8-Hour Ozone NAAQS 

STATE OF 

NEW HAMPSHIRE 

8-Hour Ozone 

Nonattainment Area 

Southeast New Hampshire 

Moderate Area 

Attainment 

pY II .r 

1. " 

Il .p{ 

"^Y eM \ 

. 

Areas 

... .L., x 

- , 

.. ~ x . 

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eIF 

" x+ ArI~wYw 

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. Y xqr 

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.d 

' Subpart 2 refers to Subpart 2-Additional Provisions for Ozone Nonattainment Areas of Title I, Part D of the Clean Air 

Act, which supplements, and is more prescriptive than, the general requirements for nonattainment areas found in Subpart 1 . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 4 

1 .2 Description of the Southeast New Hampshire Nonattainment Area 

The Southeast New Hampshire Nonattainment Area includes 52 cities and towns in Hillsborough, 

Merrimack, Rockingham, and Strafford Counties (Table 1-1) . According to the 2010 census, these 

communities have a total population of 729,071 . Manchester is the largest municipality in the area 

with a population of 109,565, followed in order by Nashua, 86,494 ; Derry, 33,109 ; Dover, 29,987 ; 

Rochester, 29,752 ; Salem, 28,776; and Merrimack, 25,494. 

Table 1-1. New Hampshire Designations/Classifications for 8-Hour Ozone Standard: 

Nonattainment Areas, Effective June 15, 2004 (FR 69 23857) 

Designation/ 

Area County Cities and Towns Included Classification 

Boston-Manchester- Hillsborough (part) Amherst, Bedford, Brookline, Goffstown, Hollis, Hudson, Nonattainment 

Portsmouth Area Litchfield, Manchester, Menimack, Milford, Nashua, Pelham Subpart 2/Moderate 

(Southeast New Merrimack (part) Hooksett Nonattainment 

Hampshire Area) Subpart 2/Moderate 

Rockingham (part) Atkinson, Auburn, Brentwood, Candia, Chester, Danville, Nonattainment 

Deny, E. Kingston, Epping, Exeter, Fremont, Greenland, Subpart 2/Moderate 

Hampstead, Hampton, Hampton Falls, Kensington, 

Kingston, Londonderry, New Castle, Newfields, Newington, 

Newmarket, Newton, North Hampton, Plaistow, 

Portsmouth, Raymond, Rye, Salem, Sandown, Seabrook, 

South Hampton, Stratham, Windham 

Strafford (part) Dover, Durham, Rochester, Rollinsford, and Somersworth Nonattainment 

Subpart 2/Moderate 

1 .3 Status of Air Quality 

Ground-level ozone monitoring data for each three-consecutive-year monitoring period from 2002 

to 2011 show that air quality in the Southeast New Hampshire Nonattainment Area has met the 

1997 NAAQS for 8-hour ozone. (EPA reached the same conclusion after examining data for the 

2007-2009 monitoring period ; see next section). This fact, accompanied by documented decreases 

in ozone-precursor pollutant emissions from in-state and upwind sources, is the basis for requesting 

redesignation of the nonattainment area to attainment for the 1997 8-hour ozone standard, in 

accordance with Section 107(d)(3)(E) of the Clean Air Act. 

Air quality data summaries describing improvements in local ambient ozone concentrations are 

included in the next section, 2. ATTAINMENT OF THE STANDARD. Emission reductions contributing 

to the improved ozone levels are described in 4. PERMANENT AND ENFORCEABLE EMISSION 

REDUCTIONS. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 5 

2. ATTAINMENT OF THE STANDARD 

The determination of New Hampshire's 1997 8-hour ozone attainment status is based on extensive 

analysis of real-time ozone and photochemical data collected from monitoring stations installed and 

maintained by NHDES at strategic locations across the state. Using quality-assured, certified data 

for the monitoring period 2007-2009, EPA determined that air quality in the Southeast New 

Hampshire Nonattainment Area (moderate) had attained the 1997 8-hour ozone NAAQS (76 FR 

14805, March 18, 2011) . This determination is consistent with EPA's Clean Data Rule (40 CFR 

51 .918); see 3.5 Clean Data Rule for 8-Hour Ozone Attainment. [In a separate but related action, 

EPA issued a proposed rule determining that the Boston-Lawrence-Worcester MA-NH serious onehour ozone nonattainment area met the November 15, 2007, deadline for attaining the one-hour 

NAAQS for ozone, based on quality-assured, certified data for the 2005-2007 monitoring period (76 

FR 77739, December 14,2011).] 

2.1 Ozone Monitoring Network 

New Hampshire's current ozone monitoring network has a total of 14 sites, located as shown in 

Figure 2-1 . Eleven of these ozone monitors are operated by NHDES and three are operated by partner 

agencies . Included in the ozone monitoring network are three ozone-related monitors that measure for 

oxides of nitrogen (NOx) and two sites that measure for Photochemical Assessment Monitoring 

Stations (PAMS) pollutants . 

Figure 2-1. Ozone-Related Air Quality Monitors in New Hampshire 

State of 

New Hampshire 

Ozone Related Monitor Network 

2011 

DES Monitor Key 

0 Ozone 

" NOx/NOy 

o PAMs 

M Ozone Monitors Operated by the Hubbard Brook Research Foundation 

® Ozone Monitors Operated by the University of New Hampshire 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 6 

All 11 NHDES stations operate throughout the ozone season from April 1 through September 30. 

Four of the ozone monitors - those at Londonderry, Nashua, Portsmouth, and Rye (Odiorne) - are 

located within the Southeast New Hampshire Nonattainment Area. Although the Portsmouth and 

Rye monitors are only a few miles apart, they represent different airsheds : continental population 

(Portsmouth), and coastal-oceanic (Rye) . Also situated within the nonattainment area are two NOx 

monitors (Nashua and Londonderry) and one PAMS installation (Nashua). 

2.2 Summary of Ozone Monitoring Data 

Real-time ozone data collected from the monitoring network are used in a variety of analyses to 

determine whether monitored areas are meeting the 1997 NAAQS for 8-hour ozone . The following 

definitions are instrumental to assessing attainment status : 

0 

Annual fourth-highest value : the fourth-highest 8-hour ozone concentration for a given 

ozone season at a monitored location . 

Design value: the 3-year average of the annual fourth-highest 8-hour ozone concentration at 

a monitored location. 

Threshold value: the fourth-highest monitored 8-hour ozone concentration for a given ozone 

season that would cause that year's design value at a monitored location to exceed the 8-hour 

ozone NAAQS. 

A description of 8-hour ozone data handling conventions is provided in Attachment B; also included 

is a table of the annual fourth-highest values, annual design values, and 2012 threshold values for 

each of the Manchester, Nashua, Portsmouth, and Rye monitor sites. Ozone concentrations at these 

locations represent ozone levels for the entire Southeast New Hampshire Nonattainment Area. 

2.2 .1 Annual Fourth-Highest Ozone Values 

Figure 2-2 displays annual fourth-highest 8-hour ozone values in parts per billion (ppb) since 1990 

for monitoring locations in the nonattainment region . (In addition to ozone values for the four 

named locations, the chart includes values for monitor sites in Brentwood and Rochester that 

operated for shorter periods) . Figure 2-3 shows corresponding values for ozone monitors in the 

remainder of the state. While meteorological conditions contribute to yearly variations, it is clear 

that ambient ozone concentrations in both attainment and nonattainment areas are trending 

downward. It is important to note that all ozone data through September 30, 2011, have passed all 

quality assurance requirements and have been entered into EPA's Air Quality System (AQS) 

database . 

2.2 .2 Ozone Design Values 

Trends in the 8-hour ozone design values for monitoring locations in the Southeast New Hampshire 

Nonattainment Area are illustrated in Figure 2-4. As the graph shows, design values have been 

declining since 1990, and all stations have demonstrated attainment since 2003 ; i .e ., design values 

for the four Southeast New Hampshire Nonattainment Area monitors have remained below the level 

of the 8-hour NAAQS during each of the periods 2002-2004, 2003-2005, 2004-2006, 2005-2007, 

2006-2008, 2007-2009, 2008-2010, and 2009-2011 . (There are some gaps in the data plots due to 

relocation of monitor sites.) To be valid, design values require three years of quality-assured data 

collected at the same location. Based on quality-assured data through the 2011 ozone season, 8-hour 

ozone design values for the period 2009-2011 were no greater than 70 ppb at all locations, with most 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 7 

sites in the southern part of the state displaying values in the low- to mid-60's ppb range. See 

Attachment B for a technical discussion of data handling conventions and design value calculations . 

Figure 2-2. 8-Hour Ozone Trends in the Southeast New Hampshire Nonattainment Area, 

1990-2011 

Ozone Trends in New Hampshire's Nonattainment Area 

(Annual 8-Hour Ozone 4th High Values) 

120 

110 

100 

m 

a 

a 

e 0 

r A 

r 

c 

m 

u 

e 

0 

v 

90 

80 

70 

60 

40 

50 

~ QrIV 915 0` 0 0 k 0 0 o~ O^ 

KIP y0oa ob 0o~° ~OoA o% o°~ ~yo ,yo ,y0 , ,y0 ,y ,y0 ,y~ ,y0 ,y0 ,y0 

Year 

°-o--- Brentwood 

Manchester 

-*--Nashua 

s°~° Rochester 

t Rye 

-+- Portsmouth 

- -1997 NAAQS 

Figure 2-3. 8-Hour Ozone Trends in New Hampshire Attainment Areas, 1990-2011 

Ozone Trends in Attainment Areas of New Hampshire 

(Annual 8-Hour Ozone 4th High Values) 

100 

m 

a 

a 

c 

0 

A 

c 

m 

u 

c 

0 

v 

90 

120 

110 

,°'ooe^~.oo~~.'N ~.o9N~o0~"9°'6~°~9A N°~°'0~.°~9otioootioo~tioo~tioo~tiooatioob tioobti°°A ti°°otioootioN otio,,~ 

80 

70 

60 

50 

40 

--Camp Dodge 

tClaremont 

-f-Concord 

Conway 

-#-Haverhill 

-~- Keene 

-~- Laconia 

-~-Lebanon 

Pittsburg 

- -1997 NAAQS 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 8 

Figure 2-4. 8-Hour Ozone Design Value Trends in the Southeast New Hampshire 

Nonattainment Area, 1990-2011 

Ozone Trends in New Hampshire's Nonattainment Area 

(Annual 8-Hour Ozone Design Values) 

120 

110 

100 

m 

n. 

a 

c 

. 0 

.. 

e 

m 

u 

e 

0 

90 

80 

70 

60 

50 

40 

At, 9~ or~' q1b Q b` Ah O r° OA or0 9°~ 

'01,01,101 

0 ^ ~' O~ Op' & O~° O~ 00 O°~ ~ 

,1.0 ,y0 ,y0 ,~.0 ,y0 4 ,y0 ,~,0 'p2.2 .3 Threshold Analysis 

-0 ° Brentwood 

t Manchester 

tNashua 

Rochester 

-+-Rye 

-+-Portsmouth 

- -1997 NAAQS 

The threshold analysis presented in Table 2-1, based on supporting data in Table B-1 of Attachment 

B, further demonstrates that the Southeast New Hampshire Nonattainment Area is likely to remain 

in attainment once redesignated . While two of the four monitor sites represented in the table have 

had at least one value over the threshold, this value would not influence the design value unless it 

accounted for the season's fourth-highest concentration. In fact, not one of these sites has had a 

fourth-highest value above its 2012 threshold at any time in its monitoring history. Therefore, it is 

highly probable that the Southeast New Hampshire Nonattainment Area will continue to achieve 

attainment . This prospect is supported by the previous introduction of large-scale emission control 

measures that have reduced NOx emissions across the region - particularly the NOx SIP call and the 

phase-in of mobile source controls. 

Table 2-1 . 8-Hour Ozone Monitoring Data: 2012 Threshold Values and 2010-2011 Design 

Values Based on Fourth-Highest Annual Maxima (ppb) 

Monitor AQS 4a' Highest Value Design Value* 2012 

Threshold 

Most Recent Year at 

or above Threshold 

Location Number 2008 : 2009 : 2010 ; 2011 2010 2011 Value** 1" Highest ; 4"' Highest 

Manchester 330110020 64 60 63 *** 62 *** *** None None 

Nashua 330111011 67 66 67 65 66 66 123 None None 

Portsmouth 330150014 69 70 66 64 68 66 125 1988 None 

Rye 330150016 75 68 66 66 69 66 123 1991 None 

* Example : The 2010 design value is the 3-year average of the annual fourth-highest 8-hour ozone concentration for the period 2008-2010 . 

** The 2012 threshold value is the fourth-highest monitored daily maximum 8-hour ozone value during the 2012 ozone season that would 

cause the 2012 design value to exceed the 8-hour ozone NAAQS. 

*** No data; monitor was moved to Londonderry in 2011 . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 9 

2.2 .4 Ozone-Related Parameters 

The PAMS stations are set up to monitor ozone, NOx, speciated volatile organic compounds (VOC, 

mainly hydrocarbons and carbonyl compounds), and meteorological parameters. New Hampshire's 

current PAMS monitors are located in Nashua (Gilson Road) and on the summit of Pack Monadnock 

Mountain (Miller State Park), in Peterborough. For its investigation of ozone trends in the Southeast 

New Hampshire Nonattainment Area and surrounding region, NHDES analyzed data from the two 

PAMS sites in New Hampshire and nine PAMS sites in Maine and Massachusetts. The analyses 

confirm that the many efforts to control NOx and VOC emissions in recent years have resulted in 

lower ambient concentrations of NOx and TNMOC during the ozone season . Background 

information, descriptions of the analyses performed, and graphs of the chemical data are presented 

in Attachment C. The meteorological portion of the analyses is included in Attachment D. 

2.2 .4 .1 Oxides of Nitrogen (NOx) 

Figures 2.5 through 2.7 depict average NOx concentrations in New Hampshire, Maine, and 

Massachusetts during the PAMS reporting season of June 1 to September 30 for the period 1998-

2010. Because of monitor site changes in New Hampshire, there are only a few years of data for 

each PAMS location in the state. Nevertheless, average NOx concentrations at each of the New 

Hampshire sites either decreased or held nearly constant over the respective measurement period . 

The more complete data sets from PAMS sites in Maine and Massachusetts demonstrate a clear 

decline in NOx concentrations over the last decade, indicative of a regional downward trend in the 

Northeast. 

Figure 2-5. NOx Trends in New Hampshire, 1998-2010 

New Hampshire Average NOx (June-Septernber) 

a 

e 

0 

c 

am fJ 

c 

O 

V 

10 

8 

6 

4 

2 

0 

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 

" Brentwood 

" Portsmou ' 

p Gilson 

o Miller 

Figure 2-6. NOx Trends in Maine, 1998-2010 

Maine Average NOx (June-September) 

35 

30 

25 

0 20 

15 * . 

c 

10 

c 

V 5 

0 

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 

" Portland 

m Kittery 

0 Cadillac 
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Figure 2-7. NOx Trends in Massachusetts, 1998-2010 

Massachusetts Average NOx (Jurie-September) 

c0 

.. 

c 0 

». 

c 

c 

70 

60 

50 

40 

30 

20 

10 

0 

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 

" Boston 

m Springfield 

0 Worcester 

o Lynn 

m Newbury 

" Blue Hill 

The observed decline in NOx concentrations in the three-state area is reflective of the general trend 

across the Ozone Transport Region (OTR)2. Since 1998, ozone-season average NOx levels in the 

OTR have fallen steadily by more than 40 percent (Figure 2-8). 

Figure 2-8. Ozone-Season Average NOx Concentrations 

in the Ozone Transport Region, 1998-2010 

25 

20 

m 

a 

a 

c 

0 

c d 

u 

e 0 

U 

15 

10 

5 

0 

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 

2.2 .4 .2 Volatile Organic Compounds (VOC) 

Figure 2-9 exhibits seasonal averages of total nonmethane organic carbon (TNMOC) and total 

PAMS-measured hydrocarbons (PAMHC) for the combined data sets of New Hampshire, Maine, 

and Massachusetts. Both categories of VOCs have decreased in concentration significantly since 

1998. In particular, despite year-to-year variations, average concentrations since 2003 have been 

consistently lower than those in the five preceding years: the average PAMHC concentration was 18 

ppbC in 2003-2009 versus 28 ppbC in 1998-2002. 

2 The OTR consists of eleven states in the northeastern U.S . plus the District of Columbia. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 11 

Figure 2-9. TNMOC and PAMHC Trends in New Hampshire, 

Maine, and Massachusetts, 1998-2010 

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 

" TNMOC 

" PAMHC 

Note : 2010 data were not 

yet available for all states 

as of this publication . 

The most recent VOC data from New Hampshire's PAMS sites (Nashua and Pack Monadnock) are 

graphed in Figures 2-10 and 2-11 . For the period from 2006 to 2010, TNMOC and PAMHC 

seasonal average concentrations at both sites were relatively stable . The seasonal averages at Pack 

Monadnock reached their lowest values in 2010. 

Figure 2-10. Average TNMOC and PAMHC in Nashua, New Hampshire, 2006-2010 

TNMOC and PAMHC Seasonal Averages 

Gilson Road, Nashua 

V 

m 

a 

c. 

e 

0 

R 

c 

m u 

c 

0 

V 

2006 2007 2008 2009 2010 

sTNMOC 

" PAMHC 

Figure 2-11 . Average TNMOC and PAMHC on Pack Monadnock in 

Peterborough, New Hampshire, 2006-2010 

TNMOC and PAMHC Seasonal Averages 

Pack Monadnock Summit, Peterborough 

60 

m 50 

a 

a 40 

v 0 

ar 

0 10 

c 

30 

c 20 

s TNMOC 

m PAMHC 

2006 2007 2008 2009 2010 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 12 

For Nashua, the 2009 seasonal averages were higher than in 2006-2008; but this phenomenon was 

due to contamination by local emissions. Extensive paving near the Nashua monitoring site began 

on July 16, 2009, and continued during the rest of the summer. This activity caused elevated values 

of certain unknown hydrocarbons as well as those on the target list, including 1,2,3-

Trimethlybenzene and 1,2,4-Trimethylbenzene, through the end of the PAMS season in September. 

This local influence resulted in higher averages of PAMHC and TNMOC for the entire 2009 season . 

PAMHC and TNMOC dropped to more historically consistent levels in 2010. In fact, the 2010 

seasonal averages are lower than those of any preceding year. 

Conclusion: Given the relatively stable or declining pattern in recorded ozone and ozone-precursor 

levels at New Hampshire monitors over the last 5 to 6 years, and observed longer-term regional 

decreases in both NOx and VOC emissions (see 4. PERMANENT AND ENFORCEABLE EMISSION 

REDUCTIONS), it is expected that ozone concentrations in New Hampshire will remain at 

attainment levels in the future . 

2.3 Summary of Meteorological Analyses 

Meteorology is a major factor in the formation and transport of ozone and its precursors. High 

ozone concentrations in southern New Hampshire occur most often when low-pressure systems 

approach from the Great Lakes or southern Canada while high pressure is situated just off the 

eastern seaboard. When such a scenario is in place, it provides warm temperatures, clear skies, and 

southwesterly winds to allow the transport of ozone and its precursors into the Northeast. 

Upwind states have successfully begun to address the problem of regional transport and made it 

possible for New Hampshire to reach attainment of the 8-hour ozone standard . This fact is reflected 

by the recent decline in the number of days, year to year, in which New Hampshire's ozone levels 

have exceeded the NAAQS (see Figure 2-12). 

Figure 2-12. Number of Days with Exceedances of the 1997 8-Hour Ozone Standard 

in New Hampshire, 1985-2011 

Oh b~° 01 00 O°~ 00 9N 9~' O~ O~` 9~ 9~° 01 00 9°~ 00 O~ O~' O~ O~` O~ O~° O~ SP O°~ -1,14 NN 

.O ~y0 ~10 " ~y0 ,y0 ,y0 ,y0 ,y0 e~,0 ey0 ,~,0 r~,0 

As required by EPA guidance for the redesignation process, New Hampshire must show evidence that 

unusual weather conditions would not have been the essential cause of the area's newly acquired 

attainment status . NHDES has prepared two types of graphical analyses for this purpose - temperature 

vs. ozone and wind direction frequency - presented in detail as Attachment D and summarized below: 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 13 

2.3.1 Temperature vs. Ozone 

Because warm weather is a principal condition for ozone formation, hotter summers tend to 

experience greater frequency of ozone exceedances. Figure 2-13 contains a bar graph depicting the 

number of days each year between 1985 arid 2011 in which the National Weather Service recorded a 

maximum daily temperature above 85 F in Concord, New Hampshire . These data are sorted in 

ascending order by temperature (rather than by chronological order) . Summers have varied from the 

relatively cool summer of 1996, with 20 days having maxima above 85 F, to the very hot summer of 

2010, with 63 days having maxima above 85 F. 

Also included in Figure 2-13 is a blue line graph showing the number of days with 8-hour ozone 

values exceeding 85 ppb. The upward-sloping trend line of exceedance days against the plotted 

temperature profile illustrates the expected correlation of ozone exceedances and higher temperatures . 

The light blue ovals on the line graph identify data points for 2003-2011, a period in which the 

frequency of exceedances was markedly below the expected frequency based on temperature 

patterns. Note that the number of exceedances was well below the linear trend line in each year 

since 2003, despite some very warm summers in 2005, 2007, and 2010 . In fact, 2010 had the 

highest number of days with a maximum temperature over 85 F, but no ozone exceedances. These 

findings indicate that the decline in ozone levels since 2003 is not solely or primarily due to a 

decrease in summer temperatures . 

Figure 2-13 . Number of Days with Maximum Temperatures above 85 F and Number of Days 

with Ozone Exceedances in New Hampshire, 1985-2011 

70 

2010 

11M Max Temperature >85 F 

N 

T to 

0 

O 

d 

E 

Z 

~r° ~r°O~ Ot ~~'O&O~`~~ 06~~ 1 ~~0~~°~ ~~`R>~~~~~ O~ 4~O~ O~'A~0~9~ 4O 

~.°~ ~.°~ ~. .~ ~.°~~.~ ~y~ ~.°~~.~ ~.~ ~.°~ ~.% ~.~~.~ ~ .~ ~.°~ ~.°~ ~.°~ ~.°~ ~y~ ; .~ ; .~ ; .~ ~.~~P kq ;p 

2.3 .2 Wind Direction Frequency 

-"-Ozone Exceedances 

-Linear (Ozone 

Exceedances) 

Notes: 

Temperatures are National 

Weather Service data from 

Concord Airport. 

Data are sorted by number 

of days with maximum 

temperature >85 F 

(therefore, years are not in 

chronological order) . 

Because transport of ozone and its precursors from outside state borders plays a critical role in 

elevated ozone levels in New Hampshire, another significant factor to consider is wind direction. 

Surface winds from the southwest are conducive to transport along the Northeast Corridor from 

metropolitan areas upwind. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 14 

Figure 2-14 presents composite wind roses for the months of April-September for the period from 

1995 to 2010. To provide the most consistent basis for comparison, data were taken from the longterm databases of the National Weather Service for airport sites in Concord and Portsmouth, New 

Hampshire. The data were separated into two periods, 1995-2002 and 2003-2010, to distinguish 

between the wind direction patterns of the earlier period and those of the more recent period 

characterized by fewer exceedances. The wind roses are based on hourly wind observations for the 

entire summer season, without regard to ozone concentration. 

The Concord and Portsmouth wind roses display very different, site-specific wind patterns; but for 

each location, the wind direction frequencies were consistent over time. While the number of 

exceedances was declining, the wind direction patterns for 2003-2010 were remarkably similar to 

the wind direction patterns for 1995-2002. Therefore, the observed decline in the number of ozone 

exceedances since 2003 is not merely a consequence of shifts in wind direction. 

Figure 2-14. New Hampshire Wind Direction Frequencies in the Months of 

April through September, 1995-2010 

Wind Direction Frequencies at Concord Airport Wind Direction Frequencies at Pease Airport, Portsmouth 

National Weather Service Data National Weather Service Data 

1995-2010 1995-2010 

-+-1995-2002 ~-1995-2002 

-a-2003-2010 -2003-2010 

S S 

Conclusion: As the graphical analyses show, the reduced number of ozone exceedances in recent 

years has occurred despite normal variations in temperature and consistent wind direction patterns. 

Thus, monitored attainment of the Southeast New Hampshire Nonattainment Area is not primarily 

due to unusual meteorological conditions. Should meteorological conditions during future summers 

favor transport of pollutants into New Hampshire, ozone levels in the Southeast New Hampshire 

Nonattainment Area are not expected to exceed the NAAQS because large-scale NOx emission 

reductions that began with the NOx SIP Call in 2003 will continue to mitigate upwind contributions. 

Furthermore, the upwind source regions impacting New Hampshire (i .e ., southern New England and 

the New York metropolitan area) have higher and more frequent ozone exceedances than New 

Hampshire and are taking additional steps to control emissions contributing to this situation. These 

steps will further reduce the amounts of ozone and its precursors available for transport to New 

Hampshire. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 15 

3. STATE IMPLEMENTATION PLAN FOR NONATTAINMENT AREA 

New Hampshire's original state implementation plan (SIP) was submitted to EPA on January 27, 

1972, and approved on May 31, 1972 (37 FR 10842) . It has undergone many revisions since then to 

meet new federal requirements as they occurred. New Hampshire's approved SIP is published in 

the Code of Federal Regulations at 40 CFR 52 Subpart EE. 

3.1 Recent SIP Revisions 

Recent revisions to New Hampshire's state implementation plan, all of which are effective for the 

Southeast New Hampshire Nonattainment Area, include the following : 

RACT Certification. Pursuant to 40 CFR 51 .912 and Clean Air Act Sections 172(c)(1), 

182(b)(2), and 184(b)(1), this plan revision was submitted to certify reasonably available 

control technology (RACT) requirements . The submission certified that New Hampshire's 

RACT regulations for the former 1-hour ozone National Ambient Air Quality Standard 

(NAAQS), combined with all RACT orders issued by NHDES, satisfied RACT requirements 

under the 1997 revised 8-hour ozone NAAQS of 0.08 ppm. NHDES submitted the RACT SIP 

revision to EPA on January 28, 2008. 

Interstate Transport Provisions . In 2005, EPA entered into a consent decree with Earth 

Justice that obligated EPA to determine whether states had made SIP submissions to meet the 

requirements of the Clean Air Act, Sections 110(a)(1) and (2). On April 25, 2005, EPA published 

a finding that all states had failed to submit SIP revisions addressing interstate transport for 

the 1997 8-hour ozone and PM2_5 NAAQS (70 FR 21147). Accordingly, on March 11, 2008, 

NHDES submitted a SIP revision to EPA to fulfill the requirements of the Finding of Failure 

and section 110(a)(2)(D)(i) relating to interstate transport of those pollutants . 

8-Hour Ozone Certification. The consent decree with Earth Justice also obligated EPA to 

determine whether states had made submissions meeting the remaining "infrastructure" 

requirements of CAA Sections 110(a)(1) and (2) for 8-hour ozone and fine particulate matter. 

To the extent that existing SIPs already satisfied these requirements, states needed only to 

certify that fact to EPA. NHDES submitted New Hampshire's certification of adequacy for 

8-hour ozone on December 14, 2007. EPA approved this SIP revision in a final rule 

published on July 8, 2011 (76 FR 40248) . 

PM2,5 Certifications . In similar fashion, NHDES submitted New Hampshire's certification of 

adequacy for the 1997 24-hour and average annual PM2.5 standards on April 3, 2008. EPA 

published a completeness finding for this submission on October 22, 2008 (73 FR 62902). 

NHDES followed this, on September 18, 2009, with submittal of a certification of adequacy 

for the 2006 revised 24-hour PM2.5 standard . 

Regional Haze Plan. In 1999, the Environmental Protection Agency (EPA) issued 

regulations to improve visibility in 156 national parks and wilderness areas (Federal Class I 

areas) across the United States . The Regional Haze Rule applies to any state having a federal 

Class I area as well as any state that contributes to visibility impairment at any (downwind) 

Class I area. Each state's plan for regional haze takes the form of a SIP revision and must 

include reasonable progress goals for visibility improvement and a long-term strategy with 

enforceable emission reductions to meet those goals. On January 29, 2010, NHDES 

submitted New Hampshire's regional haze plan to EPA and provided copies to the Federal 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 16 s 

Land Managers. Following receipt of agency comments, NHDES made adjustments to the 

plan, adopted Env-A 2300 Mitigation of Regional Haze, and resubmitted the package as a 

final SIP revision on January 14, 2011 . In response to additional EPA comments, NHDES 

submitted further amendments on August 26, 2011 . On February 15, 2012, the Regional 

Administrator signed a proposed rule, approving the Regional Haze SIP revision. 

3.2 Reasonably Available Control Technology Requirements 

For areas of New Hampshire previously designated as 1-hour serious ozone nonattainment areas, 

Section 182(b) and (c) of the Clean Air Act required the state to adopt RACT rules for VOC sources 

covered by Control Technique Guidelines (CTGs) issued before and after enactment of the 1990 

Clean Air Act Amendments. These sections also required the state to implement RACT requirements 

for all other major sources of VOCs in the classified nonattainment areas. Note, however, that 

because New Hampshire is part of the Ozone Transport Region, Section 184(b) requires 

implementation of VOC RACT for all areas of the state regardless of attainment classification . New 

Hampshire met these requirements through the adoption of various VOC regulations and individual 

VOC RACT determinations for all major VOC sources not covered by the CTGs. New 

Hampshire's VOC RACT rule, codified at Env-A 1204 Stationary Sources of Volatile Organic 

Compounds (VOCs), applies to facilities in designated source categories that have the potential to 

emit as little as 10 tons/year of VOCs, depending on the category. This rule expired in 2010 and 

was readopted with amendments, effective June 1, 2011 . The rule, renumbered as Chapter Env-A 

1200, was amended to address the CTGs issued by EPA in 2006, 2007, and 2008 for Group 11, III, and 

IV source categories, respectively; and the applicability threshold for sources in those categories was 

set at 3 tons/year of actual VOC emissions, prior to controls. The readopted rule was submitted to 

EPA as a SIP revision on July 26, 2011 . 

Section 182(f) required states to make similar provisions for major stationary sources of NOx. 

Accordingly, New Hampshire established NOx RACT regulations covering major NOx sources in 

all areas of the state and issued NOx RACT determinations for several such sources. New 

Hampshire's NOx RACT rule, codified at Env-A 1211 Nitrogen Oxides (NOx), applies to facilities 

that have the potential to emit 50 tons/year of nitrogen oxides or that meet specific size thresholds 

based on heat input capacity or other measure. This rule expired in 2010 and was amended, 

renamed, renumbered, and readopted as Env-A 1300 Nitrogen Oxides (NOx) Reasonably Available 

Control Technology (RACT), effective October 31, 2010. The readopted rule was submitted to EPA 

as a SIP revision on March 31, 2011 . 

3.3 1-Hour Ozone Attainment Demonstration 

Section 182(c) of the Clean Air Act required any state with a serious nonattainment area for ozone 

to submit by November 15, 1994, a SIP revision demonstrating how the state would attain the 1-

hour ozone standard . Notwithstanding significant efforts by the states, in 1995 EPA recognized that 

many states in the eastern half of the United States could not meet this deadline because of ozone 

transport related to NOx and VOC emissions in upwind states . EPA subsequently allowed the states 

more time for study and planning. On June 30, 1998, NHDES submitted an attainment 

demonstration (SIP revision), for New Hampshire's 1-hour ozone nonattainment area. In a final 

rule published on December 6, 2002 (67 FR 72574), EPA approved New Hampshire's attainment 

demonstration and its attainment-level motor vehicle emissions budget for the New Hampshire 

portion of the Boston-Lawrence-Worcester, MA-NH serious ozone nonattainment area. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 17 

3.4 Reasonable Further Progress Requirements 

Section 182(c) also required any state with a serious nonattainment area for ozone to prepare a plan 

for reasonable further progress (RFP) to reduce VOC emissions by at least 15 percent from 1990 

base year levels by November 15, 1996, and to achieve an additional 9 percent reduction in VOC 

emissions by November 15, 1999. NHDES submitted New Hampshire's 15% RFP plan to EPA on 

February 2, 1994 (subsequently revised May 10, 1994,; October 11, 1994; and August 29, 1996), 

followed by New Hampshire's 9% RFP plan on September 27, 1996. These plans were specific to 

the Portsmouth-Dover-Rochester 1-hour ozone nonattainment area and the New Hampshire portion 

of the Boston-Lawrence-Worcester 1-hour ozone nonattainment area. EPA published final rules 

approving SIP revisions for the 15% RFP plan on December 7, 1998 (63 FR 67405), and April 16, 

2002 (67 FR 18493). 

With respect to the 8-hour ozone standard, EPA's clean data determination (see next paragraph) 

suspended the requirements for a reasonable further progress plan and other SIP elements for the 

southern New Hampshire area. 

3.5 Clean Data Rule for 8-Hour Ozone Attainment 

From an analysis of monitoring data for the period 2007-2009, EPA determined that the Southeast 

New Hampshire Nonattainment Area (moderate) had reached attainment of the 8-hour ozone 

NAAQS. A final rule published on March 18, 2011 (76 FR 14805), effective on April 18, 2011, 

suspended the requirements for this area to submit an attainment demonstration, an RFP plan, 

contingency measures, and other State Implementation Plan elements related to attainment of the 8-

hour ozone NAAQS. This determination is consistent with EPA's Clean Data Rule (40 CFR 

51 .918), which exempts the state from certain SIP requirements if the area has three consecutive 

years of air quality data showing it meets the NAAQS, for as long as the area continues to attain the 

standard . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 18 

4. PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS 

Recent air quality improvements in the Southeast New Hampshire Nonattainment Area, evidenced 

by the decline in 8-hour ozone design values, are the result of fewer emissions of NOx and VOC 

from a broad spectrum of sources: stationary point, area, and mobile . Most of the improvement 

over 2000-2002 baseline values is attributable to implementation of federally mandated emission 

control programs - in particular, the NOx SIP Call and the Federal Motor Vehicle Emission Control 

Program (FMVCP). Various New Hampshire programs have also reduced in-state emissions during 

the same period . 

More than 90 percent of all pollutants responsible for the formation and presence of high 

concentrations of ground-level ozone in New Hampshire's nonattainment area originate from 

emission sources in upwind states .3 However, the transported pollutants from upwind states have 

shown steady declines since the early 1990s as a result of federal emission control programs and 

control measures adopted into the SIPs of upwind states . Air quality improvements associated with 

the remaining 10 percent of pollutants (i .e ., in-state emissions) can be attributed to permanent and 

enforceable emission reduction measures adopted by New Hampshire. 

4.1 Emission Control Programs 

Regional and state strategies to control ozone have focused on reducing emissions of NOx and VOC 

as the major photochemical precursors of ground-level ozone formation. In urban areas, the 

relatively high density of local emission sources can lead to elevated concentrations of ozone . At 

the same time, ozone concentrations in both urban and rural areas are influenced by regional 

transport - the movement of ozone and its precursors by the wind. Controlling both NOx and VOC 

emissions can be effective for reducing local ozone levels in urban locations, while controlling NOx 

is typically more effective for reducing regional impacts, especially in New Hampshire, where 

biogenic sources dominate VOC emissions. As a consequence, ground-level ozone in New 

Hampshire may be addressed most successfully through a combination of regional programs 

focused on controlling NOx emissions and local programs controlling both ozone-precursor types. 

Some emission control programs for NOx and VOC were implemented and began to yield 

demonstrable emission reductions within the region prior to the 2000-2002 baseline period. That is, 

these programs were already reducing ozone-causing emissions before the official designation of 

New Hampshire's 8-hour ozone nonattainment area, but continued thereafter to provide real and 

permanent decreases in emissions from the affected source categories, especially where source 

turnover/replacement is an important element of rule penetration (e.g., nonroad engines) . On the 

other hand, some emission control measures implemented since 2000-2002 may not have had 

sufficient time yet to reach maximum rule penetration and full effectiveness. Thus, the downward 

trend in emissions attributable to control measures already in place is expected to continue. 

It should be emphasized that the decline in ozone concentrations from nonattainment to attainment 

levels in New Hampshire is due to implemented control measures rather than special circumstances 

such as the shutdown of a major emission source . In the future, New Hampshire intends to maintain 

existing emission control programs or replace them with equivalent or more stringent control 

measures as necessary to comply with all applicable laws and regulations . 

3 New Hampshire Department of Environmental Services, "Air Pollution Transport and How It Affects New Hampshire," 

May 2004. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 19 

Tables 4-1 and 4-2 list federal and state enforceable emission control requirements that have 

contributed to the documented improvements in 8-hour ozone levels in the nonattainment area. 

Table 4-3 lists all NOx and VOC RACT orders for individual sources issued by NHDES since 2001 . 

Table 4-1 . Federal Emission Control Measures for NOx and VOC 

in the Southeast New Hampshire Nonattainment Area 

Federal Control Measure Citation NH SIP Revision 

National VOC Emission Standards for Consumer and Commercial Products 40 CFR 59 -- 

Standards of Performance for New Stationary Sources 40 CFR 60 -- 

Acid Rain Nitrogen Oxides Emission Reduction Program 40 CFR .76 -- 

Control of Air Pollution from Mobile Sources 40 CFR 85 -- 

Control of Emissions from New and in-Use Highway Vehicles and Engines 40 CFR 86 -- 

Control of Air Pollution from Aircraft and Aircraft Engines 40 CFR 87 -- 

Control of Emissions from New and in-Use Nonroad Compression-Ignition Engines 40 CFR 89 -- 

Control of Emissions from Nonroad Spark-Ignition Engines 40 CFR 90 -- 

Control of Emissions from Marine Spark-Ignition Engines 40 CFR 91 -- 

Control of Air Pollution from Locomotives and Locomotive Engines 40 CFR 92 -- 

Control of Air Pollution from Marine Compression-Ignition Engines 40 CFR 94 -- 

NOx Budget Trading Program for State Implementation Plans 40 CFR 96 -- 

Reasonable Further Progress CAA Section 182(b)(1) and 

CAA Section 182(c)(2)(B) 

63 FR 67405 and 

67 FR 18493 

VOC Reasonably Available Control Technology (RACT) CAA Section 182(b)(2) and 

CAA Section 182(c) 

63 FR 11600 and 

67 FR 48036 

NOx Reasonably Available Control Technology (RACT) CAA Section 182(f) 62 FR 17092 

Gasoline Vapor Recovery: Stage II Vapor Recovery CAA Section 182(b)(3) and 

CAA Section 182(c) 63 FR 67405 

Motor Vehicle Inspection and Maintenance CAA Section 182(b)(4) and 

CAA Section 182(c) 67 FR 65710 

Enhanced Vehicle Inspection and Maintenance (Alternative Program) CAA Section 182(c)(3) 66 FR 1868 

Attainment Demonstration: 1-Hour Ozone CAA Section 182(c)(2xA) 67 FR 72574 

Onboard Vapor Recovery (ORVR) CAA Section 202(a)(6) -- 

Emissions Control Diagnostics: Onboard Diagnostic (OBD) Systems CAA Section 202(m) -- 

Reid Vapor Pressure Requirements CAA Section 211(h) -- 

Reformulated Gasoline for Conventional Vehicles CAA Section 211(k) -- 

Conformity CAA Section 176(c) 64 FR 44417 

Motor Vehicle Emissions Budget (MVEB) l CAA Section 1 82(c)(5) ~ 74 FR 8863 

Note: The above list is not necessarily inclusive of all federal measures to control NOx and VOC that contributed to air quality 

improvements in the Southeast New Hampshire Nonattainment Area prior to the 2007-2009 attainment period. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 20 ~ 

Table 4-2. State Emission Control Regulations for NOx and VOC 

in the Southeast New Hampshire Nonattainment Area 

(SIP-approved rules in black, other State rules in blue) 

NH Administrative Rule Effective Submitted for EPA Description Date(s) EPA Approval Approval 

Env-A 622 Additional Requirements in Non- 01-30-1999 07-02-99 07-27-2001 Provisions applicable to 

Attainment Areas and the New Hampshire Portion of 66 FR 39100 new major stationary 

the Northeast Ozone Transport Region sources and major 

Env-A 618 (formerly 622) Additional Requirements 10-28-2002 Not Submitted modifications to existing 

in Non-Attainment Areas and the New Hampshire sources. 

Portion of the Northeast Ozone Transport Region 

Env-A 623 Prevention of Significant Deterioration 07-27-2001 08-06-2001 10-28-2002 Preconstruction review 

(PSD) ofAir Quality Permit Requirements 67 FR 65710 procedures for new major 

stationary sources and 

Env-619 (formerly 623) Prevention of Significant 04-26-2003 Not Submitted major modifications to 

Deterioration (PSD) ofAir Quality Permit existing sources in areas 

Requirements where existing air quality 

meets the NAAQS. 

Env-A 1204 Stationary Sources of Volatile Organic 08-31-1995 06-28-96 03-10-98 Provisions for 

Compounds (VOCs) 10-24-96 63 FR 11600 implementation of 

............ ............ .. ............. .... ....... ... . . .. . .... . 

Env-A 1204.09 (Metal Cans) reasonably available 

_.. . .... .. . . ... .. ..... ........ .. control technology 

Env-A 1204.10 (Paper, Fabrics, Film and Foil (RACT) on certain 

Substrates) VOC-emitting sources. 

Env-A 1204.12 (Metal Furniture Coating) 

Env-A 1204.13 (Magnetic Wire Insulation Coating) 

. .... ............. ... ............ .. . ....... ....... .... . .. .. . ..... . ..... . . 

(Note: Env-A 1204 was 

readopted as Env-A 1200 , 

Env-A 1204.14 (Coating of Metal Coils) effective 06-01-2011, and 

. ............ ............. .... .............. . ................ .... .... . .. ...... . 

Env-A 1204.15 (Miscellaneous Metal Parts and submitted for SIP 

Products) approval on 07-26- 

... .... ... .... . ............ . .... ........... . ....... ............. .. 2011 .) 

Env-A 1204.17 (Coating of Wood Furniture, Burial 

Caskets, and Gunstock) 

Env-A 1204.18 (Rotogravure and Flexographic 

Printing) 

............... . .................. .... ........ ... . . . . . . . 

Env-A 1204.19 (Offset Lithographic Printing) 

. ............ ........... ...... . ." . ... . ... . ...... ... . ... . . . . . ..... . . . ...... .... ............ .. ............ . .. 

Env-A 1204.20 (Fixed Roof Tank VOL Storage) 

Env-A 1204.21 (External Floating Roof Tanks) 

............ .................. .. ....... .. . . ... .. . .... ..... . 

Env-A 1204.22 (Bulk Gasoline Loading Terminals) 

..... .............. ... ..... .. ...... .. . ....... ...... . .... ........ . . ............. . .. 

Env-A 1204.23 (Bulk Gasoline Plant) 

Env-A 1204.25 (Cutback and Emulsified Asphalt) 

. .. . . ....... . . ............ .. ........ ....... .. 

Env-A 1204.26 (Solvent Metal Cleaning) 

Env-A 1204.27 (Misc. and Multicategory Station 08-31-1995 06-28-96 07-23-2002 

VOC Sources) 10-24-96 67 FR 48033 

Env-A 1204 Stationary Sources of Volatile Organic 12-31-2002 03-17-2003 Approval not yet 

Compounds (VOCs) acquired 

Env-A 1204.09 (Metal Cans) 

Env-A 1204.10 (Paper, Fabrics, Film and Foil 

Substrates) 

........ ..... ............. ... .................. .. . ........... ............ .. ......... ....... .. 

Env-A 1204.12 (Metal Furniture Coating) 

Env-A 1204.13 (Magnetic Wire Insulation Coating) 

Env-A 1204.14 (Coating of Metal Coils) 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 21 

NH Administrative Rule Effective Submitted for EPA Description Date(s) EPA Approval Approval 

Env-A 1204 .15 (Miscellaneous Metal Parts and 

Products) 

Env-A 1204 .17 (Coating Plastic Components of 

Automotive Interiors) 

Env-A 1204.18 (Coating Plastic Components of 

Automotive Exteriors 

Env-A 1204.19 (Specialty Coatings on Automotive 

Components) 

Env-A 1204.25 (Coating of Wood Furniture, Burial 

Caskets and Gunstock) 

Env-A 1204.36 (Rotogravure and Flexographic 

Printing) 

Env-A 1204.37 (Offset Lithographic Printing) 

Env-A 1204.38 (Fixed Roof Tank VOL Storage) 

Env-A 1204 .39 (External Floating Roof Tanks) 

Env-A 1204 .40 (Bulk Gasoline Loading Terminals 

Env-A 1204 .41 (Bulk Gasoline Plants) 

Env-A 1204.42 (Cutback and Emulsified Asphalt 

Env-A 1204 .43 - 1204.47 (Solvent Metal Cleaning) 

Env-A 1204 .48 (Misc. And Muilticategory 

Stationary VOC Sources) 

Env-A 1204 Stationary Sources of Volatile 02-26-2005 07-09-07 Approval not yet 

Organic Compounds (VOCs) acquired 

Env-A 1204 .02 Scope 

Env-A 1204 .03 Definitions 

Env-A 1204.43 (Solvent Metal Cleaning) 

Env-A 1204.44 (Cold Cleaning) 

Env-A 1205 VOC: Gasoline Dispensing Facilities 08-17-1992 12-07-98 Requirements for 

and Gasoline Tank Trucks 63 FR 67405 underground storage tank . ... . ... .... .. ...... . .... ... ... . . ... .. .. 

Env-Wm 1404 (formerly Env-A 1205) Gasoline 

.. . . . ..... ........ . .... . . . . . 

02-25-2004 

...... . .. ....... . . . . .. . 

Not Submitted facilites to prevent and 

Dispensing Facilities, Bulk Gasoline Plants, and 08-21-2004 minimize the 

Cargo Trucks contamination of the land 

and water of the state. 

Env-A 1211 Nitrogen Oxides (NOx) 08-31-1995 04-09-1997 Provisions for 

Env-A 1211 .03 (Utility Boilers) 62 FR 17087 implementation of 

reasonably available 

Env-A 1211 .05 (Industrial Boilers) control technology 

......... ... ............ ... .................. . .......... . . ... ..... . 

Env-A 1211 .06 (Combustion Turbines) (RACT) on certain NOxemitting sources. 

Env-A 1211 .07 (Stationary Internal Combustion 

Engines) (Note: Env-A 1211 was 

Env-A 1211 .08 (Asphalt Plant Dryers) readopted as Env-A 1300, 

.............. ... ............ . ... ..... .. ........ .......... ... . .. . 

Env-A 1211 .09 (Incinerators) 

............ ............ . . . ............ . ...... ........ . . ... ..... ... . ... . .. . . . . .... . . . . ...... . . 

effective 10-31-2010, and 

submitted for SIP 

Env-A 1211 .10 (Wallboard Manufacturing) 

_. ............ . .... ............ .................. . ........... ... . ... .... .... . . . . . . . . . 

approval on 03-31-2011 .) 

. . .. .. . . .. .. 

Env-A 1211 .11 (Emergency Generators) 

, . ............ ..... .................. . . . . .. . 

Env-A 1211 .12 (Auxilliary Boilers) 

Env-A 1211 .13 (Load Shaving Units) 

Env-A 1211 .14 (Miscellaneous Stationary Sources) 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 22 

NH Administrative Rule Effective 

Date(s) 

Submitted for 

EPA Approval 

EPA 

Approval Description 

Env-A 1211 Nitrogen Oxides (NOx) 10-31-2002 03-17-2003 Approval not yet 

12-22-2004 07-09-07 acquired 

Env-1211 .03 (Utility Boilers) 

Env-A 1211 .05 (Industrial Boilers) 

Env-A 1211 .06 (Combustion Turbines) 

Env-A 1211 .07 (Stationary Internal Combustion 

Engines) 

_. ..... .. ........ ...:. ...... ......... . ...... ......... . . ...... . 

Env-A 1211 .08 (Asphalt Plant Dryers) 

Env-A 1211 .09 (Incinerators) 

Env-A 1211 .10 (Wallboard Manufacturing) 

.... . 

Env-A 1211 .11 (Emergency Generators) 

Env-A 1211 .12 (Auxilliary Boilers) 12-22-2004 07-09-07 

Env-A 1211 .13 (Load Shaving Units) 

Env-A 1211 .14 (Miscellaneous Stationary Sources) 

Env-A 1500 Conformity 04-19-1996 08-16-1999 Provisions related to the 

Env-A 1502 Conformity of General Federal Actions 04-25-1996 07-10-1996 08-16-1999 nformi of federal 

co actions to New 

_............ . ....... ...... . ......... 

64 FR 44417 .. ., 

.... .. .. .... . .. . Hampshire's SIP. 

Env-A 1500 Conformity 

............. .... ... . .... . . .. . ...... 

Env-A 1501 Transformation Conformity 10-27-1995 12-1-1998 Approval not yet 

8-27-1998 acquired 

10-14-2003 

06-22-2005 

...... ...... .... . . . ... ........ ... . 

Env-A 1502 Conformily ofGeneral Federal 10-14-2003 

Actions 06-22-2005 

Env-A 3200 NOx Budget Trading Program 07-27-1998 11-14-2000 Provisions to implement 

65 FR 68078 New Hampshire's NOx 

Env-A 3200 NOx Budget Trading Program 08-25-1999 Not Submitted Budget Program to help 

02-01-2000 achieve attainment of the 

05-24-2003 ozone NAAQS. 

02-28-2004 

08-25-2007 

11-02-2007 

02-21-2008 

Saf-C 3200 Official Motor Vehicle Inspection 11-17-1998 01-10-2001 Provisions related to 

Requirements 

. ........ ... .............. . . .......... ...... . .... .......... ... ... .. 

66 FR 1868 control of motor vehicles 

. .................. ........... .... . . . 

Saf-C 3221A Emissions Requirements emissions. 

Saf-C 3200 Offzcial Motor Vehicle Inspection 

Requirements . ... .... .......... ....... ... ....... ...... . .......... 

Saf-C 3220 Emissions Requirements 06-22-2007 

Saf-C 3222 On-board Diagnostic System 07-26-2002 

06-20-2008 

Saf-C 5 800 Roadside Diesel Opacity Inspection 11-17-1998 01-10-2001 Provisions implementing 

66 FR 1868 a roadside heavy-duty 

Saf-C 5800 Roadside Diesel Opacity Inspection 01-01-1999 diesel emissions testing I 

program. ! 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 23 

Table 4-3. NOx and VOC RACT Orders Issued in New Hampshire, 2001-Present 

Order No. Company Name Pollutant Effective Date 

96-001 Textile Tapes Corp. VOC 04-19-02, rev . 08-10-07 

99-001 Kalwall Corp. - Manchester VOC 11-20-01 

00-001 Anheuser Busch, Inc . VOC 04-15-02 

01-001 Waste Management of NH, Inc . - Turnkey NOx 08-26-02, rev . 08-11-11 

01-002 Hutchinson Sealing Systems, Inc. VOC 08-08-02 

02-001 Hitchiner Manufacturing Co., Inc . - Milford VOC 06-20-02 

02-003 Newington Energy, LLC NOx 09-09-02 

03-001 * Parker Hannifin Corporation, Chomerics VOC 07-17-02 

03-001 * Sturm, Ruger & Company, Inc . VOC 10-13-03, rev . 12-01-03 & 03-02-10 

03-002 Gates Mectrol Inc .** VOC 06-16-03 

04-001 Newington Energy, LLC NOx 06-20-07 

05-001 * Anheuser Busch, Inc . NOx 05-09-05 

05-001 * Metal Works, Inc . VOC 12-22-04 

06-001 PSNH Schiller Station - Unit #5 NOx 08-04-06 

07-001 Webster Valve, Inc . VOC 04-20-07, rev . 04-20-07 

07-002 TFX Medical, Inc . VOC 08-07-07 

07-003 Concord Litho Group, Inc . VOC 09-17-07 

07-004 Polyonics, Inc. ~ VOC I 12-28-07 

* duplicate numbers issued ** facility shut down; letter to cancel RACT order sent to EPA on 07-02-09 

4.2 Upwind Emission Reductions 

As mentioned above, a broad array of NOx and VOC emission controls in upwind states has largely 

made possible the attainment of the 1997 8-hour ozone standard in the Southeast New Hampshire 

Nonattainment Area. The observed improvement in air quality would not have occurred without the 

concerted efforts of EPA and the Ozone Transport Commission (OTC) to reduce the emitted 

amounts of both pollutants across the region . 

In September 1994, the OTC member states4 adopted a memorandum of understanding to achieve 

regional NOx emission reductions . Phase I began with the installation of RACT, followed in Phases 

11 and III by the development and implementation of regulations to achieve further reductions in 

ozone-season NOx emissions by 1999 and 2003, respectively . The second and third phases were 

modeled on the cap-and-trade principle and resulted in the creation of the OTC NOx Budget 

Program. s This program established a de facto NOx emission rate of 0 .15 lbs/MMBtu for 

4 The OTC includes the states of Maine, New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island, New 

York, New Jersey, Pennsylvania, Maryland, Delaware, and the District of Columbia. 

5 The NOx Budget Program involves an allowance trading system which harnesses free market forces to reduce 

pollution, similar to the U.S . EPA's Acid Rain Program. Under this program, budget sources were allocated allowances 

by their state governments. Each allowance permits a source to emit one ton of NOx during the control period (May 

through September) for which it is allocated or any later control period. Allowances may be bought, sold, or banked. 

Any person may acquire allowances and participate in the trading system. Each budget source must comply with the 

program by demonstrating at the end of each control period that actual emissions do not exceed the amount of 

allowances held for that period . However, regardless of the number of allowances a source holds, it cannot emit at 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 24 " 

participating electric generating units and large industrial boilers. Rules for New Hampshire's 

participation in the OTC NOx Budget Program are codified at Chapter Env-A 3200. 

In the midst of these efforts, in 1998, EPA issued a final rule aimed at reducing the regional 

transport of NOx and ozone. This rule, commonly known as the NOx SIP Call, required 22 eastern 

states and the District of Columbia (not including New Hampshire) to reduce ozone-season NOx 

emissions. Compliance with the NOx SIP call began on May 1, 2003, for the participating OTC 

states 6 and on May 31, 2004, for states outside the Ozone Transport Region. Although the NOx SIP 

Call provided states with the flexibility to design their own programs to meet the NOx reduction 

requirements, all affected states chose to participate in a regional cap-and-trade program.7 

The NOx SIP Call and the NOx Budget Trading Program (NBP) have had a major effect on 

reducing regional transport of this pollutant. EPA data presented in Figure 4-1 show that total 

ozone-season NOx emissions from all NBP sources fell from 1,256,000 tons in 2000 to 481,000 

tons in 2008.8 

Figure 4-1. Ozone-Season NOx Emissions from All NOx Budget Trading Program Sources 

2,200 

2,000 

0 1,800 

1,600 

1,400 

1,200 

0 1,00(1 

800 

w 600 

x 

400 

200 

0 

1990 2000 2003 2004 2005 2006 2007 

Ozone Season 

" Ozone Season N0, Emassions (thousend tons) 

" Total State Trading Budgets 

Notes: 

" Data reflect full ozone season emissions in all years for all states. 

The year 2000 baseline value has been adjusted to correct a misprint in Figure 5 of the 2007 NB P report. 

" The 2008 total state trading budgets include opt-in allowances, 

where applicable (New York, Ohio, and West Virginia). 

Source : EPA, 2009 

2008 

levels that would violate other federal or state limits (e .g ., NSPS, Title IV, NOx RACT). 

6 The NOx SIP Call superseded Phase III of the OTC NOx Budget Program. Maine, New Hampshire, and Vermont 

were not participating states . 

' The NOx Budget Trading Program established under the NOx SIP Call is separate and distinct from the OTC NOx 

Budget Program. 

8 USEPA, The NOx Budget Trading Program: 2008 Highlights, December 2008; available at 

http ://www .epa .gov/airmarkt/progress/NBP 4.html. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 25 

On March 10, 2005, EPA issued the Clean Air Interstate Rule (CAIR) to further reduce air pollution 

that moves across state boundaries. CAIR established permanent emission caps for nitrogen oxides 

(and sulfur dioxide) emanating from major sources in eastern states - representing a 60 percent cut 

in NOx emissions from 2003 levels . On July 6, 2011, following a round of legal challenges to the 

original rule, EPA replaced CAIR with the Cross-State Air Pollution Rule, which corrected certain 

deficiencies in the original. Although not fully implemented before its withdrawal, CAIR yielded 

significant reductions in NOx emissions and transport; these realized air quality benefits will 

continue largely in effect under the replacement rule . 

At the same time it was addressing NOx emissions, EPA was developing programs to reduce VOC 

emissions on a broad scale. Since the 1990's, EPA has mandated numerous mobile and area source 

controls for VOC (see Table 4-1), all of which have contributed to improved air quality in New 

Hampshire and the other downwind states . 

As a complement to these federal efforts, the OTC developed model rules to be implemented by the 

individual member states for a number of VOC and NOx source categories. The OTC model rules 

were developed in three series : 2001/2002, 2006, and 2009/2010 . (Note: Some of the 2009/2010 

model rules exist in draft form.) Adoption of these rules (or their equivalent) in a number of upwind 

states has helped to reduce the transport of ozone and its precursors into New Hampshire. 9 

As illustrated in Figure 4-2, both NOx and VOC emissions in the eastern United States declined 

steadily between 1997 and 2004 for all major source categories. 

Figure 4-2. Ozone-Season NOx and VOC Emissions in the Eastern United States 

by Source Category: 1997, 2002 and 2004 

n 

C 

m 

S& 

w 

m 

c 

.(~ 

tu 

Source: EPA 

4.3 In-State Emission Reductions 

Note: Other Includes emissions from nonroad, pourer industry, and nonsolvent 

industrial processes. 

Aggregated reductions in NOx and VOC emissions from all sources in New Hampshire are partly 

responsible for New Hampshire's attainment of the 8-hour ozone standard . Table 4-4 summarizes 

statewide emissions by source category for the inventory years of 2002, 2005, and 2008. 

9 Status reports on states' adoption of the OTC model rules may be viewed by clicking on links to the model rule 

adoption matrices available at http ://www .otcair.oreJinterest.asp?Fview=stationary_. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 26 

Table 4-4. NOx and VOC Emissions in New Hampshire, 2002, 2005, and 2008 (tons/year) 

S C 

2002 Emissions 2005 Emissions 2008 Emissions 

ource ategory NOx VOC NOx VOC NOx VOC 

Point 9,938 2,010 12,583 1,404 6,734 962 

Area 10,681 56,054 11,482 59,263 4,678 19,510 

Non-Road Mobile 9,108 22,099 8,746 21,485 8,877 18,916 

On-Road Mobile 30,755 16,895 26,874 14,151 21,450 9,431 

I Total ~ 60,482 97,058 59,685 96,303 41,739 48,819 

Note: A revised methodology (EPA's residential wood combustion tool) was used in the 2008 inventory for 

residential wood combustion; this resulted in substantially lower estimates of NOx and VOC for area sources. 

Ozone-season daily NOx and VOC emissions in New Hampshire by source category are represented 

graphically in Figures 4-3 and 4-4. 

Figure 4-3. Ozone-Season Daily NOx Emissions in New Hampshire 

by Source Category: 2002, 2005, and 2008 

~ 450,000 

R 

'a 400,000 

a 350,000 

300,000 

3 

a 250,000 

m 200,000 

e 

y 150,000 

£ 100,000 

W K 50,000 

z 0 

Point Area Non-Road On-Road Total 

Mobile Mobile 

I 0 2002 0 2005 0 20081 

Figure 4-4. Ozone-Season Daily VOC Emissions in New Hampshire 

by Source Category: 2002, 2005, and 2008 

; 450,000 

~ 400,000 

c. 350,000 

N 

300,000 

3 

a 250,000 

200,000 

~°G 150,000 

~ 100,000 

W 

v 50,000 

O 

> 0 

Point Area Non-Road On-Road Total 

Mobile Mobile 

I " 2002 " 2005 0 200 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 27 

5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT 

Pursuant to Section 107(d)(3) of the Clean Air Act, state implementation plan submittals requesting 

redesignation of any area or portion thereof must meet all requirements applicable to the area under 

Title 1, Part A, Section 110 - Implementation Plans, and Title 1, Part D - Plan Requirements for 

Nonattainment Areas. 

According to EPA's interpretation1°, to qualify for redesignation, a state requesting redesignation to 

attainment must meet the relevant CAA requirements that come due prior to the submittal of a 

complete redesignation request. Applicable requirements of the CAA that come due subsequent to 

the area's submittal of a complete redesignation request remain applicable until a redesignation is 

approved, but are not required as a prerequisite to redesignation. The Section 110 and part D 

requirements which are linked with a particular area's designation and classification are the relevant 

measures to evaluate in reviewing a redesignation request. 

Part D, Sections 172-176 of the CAA set forth the basic requirements for all nonattainment areas. 

General provisions for nonattainment plans appear in Section 172(c) . Section 182 establishes 

additional specific requirements depending on the area's nonattainment classification . Section 

182(b) prescribes specific measures for a moderate nonattainment area such as the Southeast New 

Hampshire Nonattainment Area. Section 184 establishes additional requirements applicable to the 

area because of its location within the Ozone Transport Region. 

Previous EPA statements" indicate that conformity, new source review requirements, and OTR 

requirements are not applicable to considerations of redesignation as they are not directly linked 

with an area's designation and classification. In particular, 

0 

0 

It is reasonable to interpret the conformity SIP requirements as not applying for purposes of 

evaluating the redesignation request under Section 107(d) because state conformity rules are 

still required after redesignation and federal conformity rules apply where state rules have 

not been approved. 

It is reasonable to interpret the Section 184 OTR requirements, including New Source 

Review (NSR), as not being applicable for purposes of redesignation based on two factors. 

First, the requirement to submit SIP revisions for the Section 184 requirements continues to 

apply to areas in the OTR after redesignation to attainment . Therefore, the state remains 

obligated to have New Source Review (as well as RACT and Vehicle Inspection and 

Maintenance (I/M) programs) even after redesignation. Second, the Section 184 control 

measures are region-wide requirements and do not apply to the area by virtue of its 

designation and classification . 

Once an area has been redesignated to attainment status, NSR requirements for nonattainment areas 

under Part D will be replaced by program requirements for Prevention of Significant Deterioration 

(PSD) under Part C of Title I. NHDES submitted a New Source Review equivalency demonstration 

to EPA on January 3, 2006, detailing how New Hampshire's current and proposed programs are at 

least as stringent as the federal NSR and PSD programs. 

lo EPA memorandum from John Calcagni, Director, Air Quality Management Division, "Procedures for Processing 

Requests to Redesignate Areas to Attainment," September 4, 1992. 

11 EPA, Approval and Promulgation of Implementation Plans and Designation of Areas for Air Quality Planning 

Purposes; Maine; Redesignation of the Portland, ME and the Hancock, Knox, Lincoln and Waldo Counties, Maine 

8-Hour Ozone Nonattainment Areas to Attainment for Ozone; Proposed Rule, October 17, 2006 (71FR 60937) . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 28 

For redesignation, a major consideration is the adequacy of maintenance provisions to assure 

continued attainment of the standard . In the present redesignation request, the maintenance plan 

presented in 6. MAINTENANCE PLAN meets the requirements set forth in Section 175A of the 

CAA. The emissions inventory requirements of Section 172(c)(3) are satisfied by the inventory 

developed for the maintenance plan as described in 6.1 Attainment Inventory. The requirements of 

Section 172(c)(9) for contingency measures are fulfilled in 6.5 Contingency Plan . 

NHDES asserts that New Hampshire's implementation plan meets the requirements of Section 110 

and Part D for the state, in general, and for the Southeast New Hampshire Nonattainment Area, in 

particular . The required rulemaking authority, powers of the Commissioner, provisions for permits 

and enforcement, and other provisions necessary to meet the state's obligations under the Clean Air 

Act are established in New Hampshire's Revised Statutes Annotated (RSA), Chapter 125-C Air 

Pollution Control. Regulations implementing New Hampshire's air program are established in the 

Rules Governing the Control of Air Pollution, New Hampshire Code of Administrative Rules 

Env-A 100 through 4800. (Note: Many New Hampshire air rules have received SIP approval; see 

relevant titles listed in Table 4-2). Additional requirements for controlling mobile source emissions 

are found in rules issued by the Department of Safety at Saf-C 3200 and Saf-C 5800. Provisions for 

compliance with the specific elements of Section 110 are described in more detail below. 

5.1 Requirements of Section 110(a)(2) 

Section 110(a)(2) of the Clean Air Act and EPA regulations at 40 CFR 51, Subparts K and L, 

require that New Hampshire's state implementation plan: 

0 

. 

Provide for legally enforceable emission reporting and recordkeeping; 

Provide for periodic testing and inspection of emission sources and for enforcement and 

investigation of complaints; 

Include procedures for implementing transportation-related emission control measures; 

Contain legally enforceable procedures to require stationary sources to install, calibrate, 

maintain, and operate equipment for continuously monitoring and recording emissions; 

Demonstrate that the state has legal authority to adopt emission standards and limitations 

and any other measures necessary for attainment and maintenance of national standards; 

Demonstrate that the state has the legal authority to enforce applicable laws, regulations, and 

standards and to seek injunctive relief; 

Provide the state with the legal authority to abate pollutant emissions on an emergency basis 

to prevent substantial endangerment to the health of persons; 

Demonstrate that the state has the legal authority to prevent the construction, modification, 

or operation of a facility which directly or indirectly results or may result in emissions of any 

air pollutant at any location that will prevent the attainment or maintenance of a national 

standard ; 

Demonstrate that the state has the legal authority to obtain information necessary to 

determine whether air pollution sources are in compliance with applicable laws, regulations 

and standards and that the state has the legal authority to make inspections and conduct tests 

of air pollution sources. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 29 

New Hampshire meets these requirements by having adopted and implemented the following state 

laws and regulations that are at least as stringent as the applicable federal requirements established 

for the protection of air quality: 

5.1 .1 Emission Reporting and Recordkeeping 

Env-A 900 Owner or Operator Recordkeeping and Reporting Obligations requires that records be 

kept at sources that discharge air pollutants so that the emissions of such pollutants can be readily 

calculated or estimated and reported to NHDES for the purposes of demonstrating compliance, 

compiling emission inventories, and developing air-related strategic plans. The statutory authority 

for this regulation is provided in RSA 125-C:4,1 . 

5.1 .2 Periodic Testing and Inspection 

Env-A 800 Testing and Monitoring Procedures establishes minimum testing and monitoring 

procedures, calculation procedures, and standards for any owner or operator of a stationary source, 

area source, or device, required to perform testing or monitoring to determine compliance with RSA 

125-C, any permit issued by the division, or the requirements of other provisions of Env-A 300 et 

seq. The statutory authority for this regulation is contained in RSA 125-C:6, XI, XII. Statutory 

provisions for investigations and enforcement are established in RSA 125-C :6 and RSA 125-C :15. 

5.1 .3 Transportation-Related Control Measures 

Env-A 1501 Transportation Conformity implements Section 176 of the Clean Air Act and 40 CFR 

93, Subpart A, with respect to transportation plans, programs, and projects developed, funded, or 

approved by the federal government or that are deemed regionally significant. Conformity 

determinations made under this rule ensure that the metropolitan planning organization (MPO) and 

state transportation plans, programs, and projects in the non-attainment areas adhere to New 

Hampshire's SIP. The statutory authority for these regulations is provided in RSA 125-C :4 . (See 

expanded description under 5.4 Transportation Conformity.) Additional regulations for 

controlling mobile source emissions are presented at Saf-C 3200 Official Motor Vehicle Inspection 

Requirements and Saf-C 5800 Roadside Diesel Opacity Inspection . 

5.1 .4 Continuous Monitoring and Recording of Emissions 

Env-A 808 Continuous Emission Monitoring requires the owner or operator of a stationary source 

meeting certain conditions to install, operate, and maintain a CEM system and to perform quality 

assurance testing on that system . The statutory authority for this regulation is provided in RSA 125-

C:6, XI, XII. 

5.1 .5 Legal Authority and Emergency Powers 

Legal authority to carry out New Hampshire's implementation plan is vested in the Commissioner 

of the New Hampshire Department of Environmental Services under New Hampshire statutes RSA 

125-C:4 Rulemaking Authority; Subpoena Power and RSA 125C:6 Powers and Duties of the 

Commissioner (see Attachment E). The Commissioner has delegated to the Director of the Air 

Resources Division major responsibilities for carrying out New Hampshire's air programs. (Note: 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 30 

Under RSA 125-C :8 Administration of Chapter; Delegation of Duties, the Commissioner cannot 

delegate rulemaking authority.) 

Permit conditions, orders, or directives issued by the Commissioner may be enforced by NHDES 

or by the New Hampshire Attorney General. NHDES may resolve a violation through an 

administrative consent agreement, schedule and hold an enforcement hearing, or refer the violation 

to the Attorney General to initiate a civil or criminal action. 

The Governor has appointed the Director of the Air Resources Division, acting under the authority 

of the Commissioner, as his designee for requesting EPA's approval of revisions to New 

Hampshire's State Implementation Plan (see Attachment E). 

The authority of the Commissioner to undertake specific actions is established in the following 

sections of state law: 

0 

RSA 125-C :4 Rulemaking Authority; Subpoena Power provides the Commissioner with the 

legal authority to adopt emission standards and limitations and any other measures necessary 

for attainment and maintenance of national standards. 

RSA 125-C:6 Powers and Duties of the Commissioner provides the Commissioner with the 

legal authority to prevent the construction, modification, or operation of a facility which 

directly or indirectly results or may result in emissions of any air pollutant at any location 

that will prevent the attainment or maintenance of a national standard; to obtain information 

necessary to determine whether air pollution sources are in compliance with applicable laws, 

regulations and standards; and to make inspections and conduct tests of air pollution sources. 

RSA 125-C:9 Authority of the Commissioner in Cases of Emergency provides the 

Commissioner with the legal authority to abate pollutant emissions on an emergency basis to 

prevent substantial endangerment to the health of persons. 

RSA 125-C:15 Enforcement provides the Commissioner with the legal authority to enforce 

applicable laws, regulations, and standards and to seek injunctive relief. 

5.2 Continuance of Existing Control Requirements after Redesignation 

New Hampshire's implementation plan incorporates federal requirements for demonstrating that the 

ozone standard can be maintained in future years in the Southeast New Hampshire Nonattainment 

Area. Continued attainment of the standard is supported by adherence to anti-backsliding provisions 

established in Section 173(e) of the CAA and by maintenance provisions developed specifically for 

this area redesignation to meet the requirements of Section 175A (see 6. MAINTENANCE PLAN). 

Note that, in compliance with federal anti-backsliding requirements, existing NOx and VOC RACT 

control measures (as well as other control measures) implemented within the ozone nonattainment 

area will remain in effect after redesignation to attainment. 

Under EPA's anti-backsliding rules, areas designated nonattainment for the 1-hour ozone standard at 

the time of the 8-hour ozone designations remained subject to certain control measures that applied 

by virtue of the area's classification for the 1-hour NAAQS (40 CFR 51 .900 et seq.) . 40 CFR 

51 .905(a)(1) prescribes the 1-hour NAAQS requirements that continue to apply to former 1-hour 

ozone nonattainment areas after revocation of the 1-hour NAAQS: "The area remains subject to the 

obligation to adopt and implement the applicable requirements as defined in section 51 .900(f), . . ." 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 31 

40 CFR 51 .900(f) reads : "Applicable requirements means . . .the following requirements to the extent 

such requirements apply or applied to the area for the area's classification under section 181(a)(1) of 

the CAA for the I -hour NAAQS at designation for the 8-hour NAAQS: . . ." 

For New Hampshire's former 1-hour marginal nonattainment area, the applicable requirements are 

as follows: 

" RACT; 

" I/M programs ; 

For New Hampshire's former 1-hour serious nonattainment areas (Seacoast and Southern), the 

applicable requirements are as follows: 

" RACT; 

" I/M programs; 

" Major source applicability cut-offs for purposes of RACT; 

" ROP reductions ; 

" Stage II vapor recovery; 

" Clean fuels fleet program under Section 182(c)(4) of the CAA; 

" Enhanced (ambient) monitoring under Section 182(c)(1) of the CAA; 

" Transportation controls under Section 182(c)(5) of the CAA; 

" NOx requirements under Section 182(f) of the CAA; and 

" Attainment demonstration or an alternative as provided under 40 CFR 51 .905(a)(1)(ii) . 

New Hampshire asserts that all required control provisions shall remain in place to prevent 

backsliding and assure maintenance of the 1997 8-hour ozone NAAQS after redesignation of the 

area to attainment. The 1-hour ozone attainment demonstration was submitted and approved, as 

previously described in 3.3 1-Hour Ozone Attainment Demonstration. Provisions for NOx and 

VOC RACT are as described in 3.2 Reasonably Available Control Technology Requirements. Rate 

of Progress (ROP) reductions are as described in 3.4 Rate-of-Progress Requirements. 

New Hampshire notes that it recently revoked the requirement that new gasoline dispensing 

facilities shall be equipped with Stage II vapor recovery control equipment and simultaneously 

adopted a requirement that owners of existing gasoline dispensing facilities equipped with Stage II 

controls shall decommission such equipment by . December 22, 2015. This rulemaking was 

necessary to prevent a situation - forecast to occur in the next few years - whereby the Stage II 

equipment, because of incompatability with ORVR equipment, would cause more VOC emissions 

than it would prevent. New Hampshire is preparing a separate SIP submittal demonstrating that 

these rule changes will not violate the anti-backsliding requirements of section 110(1) of the Clean 

Air Act. The demonstration would have been included with this SIP revision, but has been delayed 

as NHDES resolves discrepancies in motor vehicle emission estimates after conversion to the new 

MOVES model. 

New Hampshire has a motor vehicle I/M program requiring annual inspections of all motor vehicles . 

Pre-model year 1996 vehicles that are less than 20 years old undergo a visual anti-tampering 

inspection. Model year 1996 and newer gasoline and 1997 and newer diesel vehicles up to 8,500 

pounds Gross Vehicle Weight Rating (GVWR) are subject to an annual onboard diagnostics (OBD) 

inspection as specified in 40 CFR Parts 51 and 85 . In addition, heavy duty diesel vehicles (GVWR 

>10,000 Ibs) are also subject to random roadside opacity testing (see NH statute RSA 266 :59-b and 

New Hampshire Department of Safety Administrative Rules Saf-C 3200 and Saf-C 5800). 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 32 

NHDES operates two enhanced ambient air monitoring stations as required by Section 182(c)(1) of 

the CAA for serious nonattainment areas for the 1-hour ozone standard . These Photochemical 

Assessment Monitoring Stations (PAMS) were originally configured to track NOx and VOC 

emissions up- and downwind of the Portsmouth, New Hampshire, metropolitan area. With EPA 

approval, this network has since been modified to reflect updated science and to track high- and 

low-elevation ozone precursor emissions entering the state from the southwest. Because of the 

revocation of the 1-hour ozone standard, the PAMS monitors operate in an 8-hour ozone 

nonattainment area currently classified as moderate. 

New Hampshire meets Section 182(c)(5) requirements through compliance with the transportation 

conformity requirements found at 40 CFR Part 93. Using a consultative process set forth in Env-A 

1500, New Hampshire ensures that transportation-related emissions remain consistent with emission 

levels projected in the state's attainment demonstration and established in the motor vehicle 

emissions budgets. 

5.3 Permitting of Stationary Sources 

Under Chapter Env-A 600 Statewide Permit System, all new, modified, and existing stationary 

emission sources of specified sizes and types are required to obtain permits; operate in compliance 

with applicable laws and regulations ; maintain and test emission control equipment; and keep 

detailed records of emissions, fuel use, and related parameters . In addition, NHDES has the 

authority to conduct periodic inspections and surveillance of emission sources, to enter property at 

any reasonable time for such purposes, to require the submission of detailed plans and other data 

from permit applicants, and to require the submission of information regarding actual or suspected 

violations . 

New Hampshire's process for permit application and review includes consideration of air quality 

impact analysis (modeling), emission control technology, operational limitations, public 

participation, and other procedural requirements for both existing sources seeking operating permits 

(renewals) and new or modified sources seeking temporary (initial construction) permits prior to 

operation. The permit process also includes consideration of federal New Source Review 

requirements applicable to all major sources of NOx, VOC, and other regulated pollutants . State 

rules designed to protect air quality in existing attainment areas are found at Part Env-A 619 

Prevention of Significant Deterioration (PSD) Air Quality Permit Requirements. These rules meet 

requirements of the Clean Air Act pertaining to PSD and visibility protection as established in 

Section 110(a)(2) of Title I, Part A and Sections 160-169 of Title I, Part C. These rules also are at 

least as stringent as EPA requirements published at 40 CFR 51 .166 and 40 CFR 52 .21 . 

All information submitted to NHDES in permit applications is available for public disclosure. Any 

exceptions to this general statement are determined by the provisions of RSA 125-C:6, VII, and 

Env-A 103 Claims of Confidentiality. 

5.4 Monitoring of Stationary Sources 

NHDES requires qualifying facilities to install, maintain, and use emission monitoring devices and 

to make periodic submittals to NHDES on the nature and quantity of emissions. Air program rules 

at Chapter Env-A 800 Testing and Monitoring Procedures establish minimum testing and 

monitoring procedures, calculation methods, standards, and other requirements to determine 

compliance with applicable state/federal laws and rules. Part Env-A 808 Continuous Emission 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 33 

Monitoring establishes the requirements for CEMs at major emission sources. Chapter Env-A 900 

Owner or Operator Recordkeeping and Reporting Obligations identifies requirements for keeping 

records of and reporting actual emissions to NHDES and EPA. All permitted emission sources are 

required to file annual emission statements by April 15 for the previous calendar year. NHDES is 

required to make all information on emissions available for public inspection, including any reports 

correlating source emission data with applicable emission standards and limitations. 

5.5 Transportation Conformity 

In addition to requirements for the control of NOx and VOC emissions, the 1990 Clean Air Act 

Amendments established specific provisions regarding the conformity of transportation actions. 

Transportation conformity ("conformity"), as established in Section 176(c)(4) of the Act, is a way to 

ensure that Federal funding and approval goes to those transportation activities that are consistent 

with air quality goals as outlined in a SIP . Conformity applies to transportation plans, transportation 

improvement programs (TIPs), and projects funded or approved by the Federal Highway 

Administration (FHWA) or the Federal Transit Administration (FTA) in areas that do not meet or 

previously have not met air quality standards for ozone, carbon monoxide, particulate matter, or 

nitrogen dioxide. These areas are known as "nonattainment areas" or "maintenance areas," 

respectively . Regulations governing transportation conformity are found in 40 CFR Parts 51 and 93 . 

EPA regulations for transportation conformity (40 CFR Parts 51 and 93) require MPOs and the U.S. 

Department of Transportation (US DOT) to make conformity determinations on metropolitan 

transportation plans and TIPs before they are adopted, approved or accepted. In addition, highway 

or transit projects which are funded or approved by the Federal Highway Administration or the 

Federal Transit Administration must also receive a conformity determination before they can be 

approved or funded by US DOT or an MPO. Regionally significant projects, regardless of their 

funding source, must also undergo a conformity finding. The federal rule applies in all 

nonattainment areas, or areas with maintenance plans for ozone, carbon monoxide, nitrogen oxides 

or particulate matter . 

EPA's transportation conformity regulations, first promulgated November 24, 1993, have been 

amended several times, including on July 1, 2004, when EPA issued a final rule to implement 

conformity for the 8-hour ozone NAAQS, and on May 6, 2005, March 10, 2006, and January 24, 

2008. 

Conformity determinations are made by demonstrating consistency with adequate or EPA-approved 

motor vehicle emissions budgets (MVEBs) established by rate-of-progress plans, attainment 

demonstrations, or other control strategy implementation plans. Section 176(c)(2)(A) specifically 

requires conformity demonstrations to show that emissions from transportation plans and TIPs are 

consistent with estimates of emissions from motor vehicles and necessary emission reductions as 

established by reasonable further progress, attainment demonstrations, and maintenance 

demonstrations contained in the SIP. MVEBs are the explicit or implicit identification of the motorvehicle-related portions of the projection inventory used to demonstrate reasonable further progress 

milestones, attainment, or maintenance for a particular year identified in the SIP. The MVEBs 

establish a cap on emissions which cannot be exceeded by predicted highway and transit vehicle 

emissions . 

On July 28, 2008, EPA deemed adequate for purposes of conformity New Hampshire's SIP revision 

establishing MVEBs for the Southeast New Hampshire Nonattainment Area. On February 27, 2009, 

EPA proposed final approval of the budgets, effective April 29, 2009. NHDES developed these 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 34 

budgets using the MOBILE6.2 modeling platform . Subsequently, NHDES prepared new MVEBs 

using EPA's MOVES2010a model to be consistent with the agency's latest policy on modeling 

emissions from mobile sources. As part of this redesignation request, NHDES is requesting that EPA 

withdraw the approved MOBILE6.2 2009 MVEBs and replace them with the new MOVES 2008 

MVEBs (summarized in Table 5-1). Electronic input/output files for MOVES are provided as 

Attachment F. 

Simultaneously, NHDES is submitting 2022 MVEBs for NOx and VOC for use in determining 

transportation conformity (see Table 5-1 and Attachment F). NHDES used MOVES to calculate onroad emissions of NOx and VOC for the 52 cities and towns in Hillsborough, Merrimack, 

Rockingham, and Strafford Counties comprising the Southeast New Hampshire Nonattainment 

Area. In this submittal, New Hampshire is proposing MVEBs for the last year of the 8-hour ozone 

maintenance planning period (2022) at 8 .9 tons per summer day (tpsd) of VOC and 11 .8 tpsd of 

NOx. These on-road mobile source emissions, when added to emissions from all other inventory 

sources - stationary, area, and other mobile sources (i .e ., non-road, marine vessels, airplanes, and 

locomotives) - result in a year 2022 emissions inventory lower than the year 2008 attainment 

inventory .(see NOx and VOC emissions summary in Table 6-1). These emissions budgets, once 

approved or deemed adequate by EPA, must be used for future transportation conformity 

determinations. 

Table 5-1. 2008 and 2022 Motor Vehicle Emission Budgets for the Southeast New Hampshire 

Nonattainment Area (tons per summer day) 

2008 2022 

Category 

NOx VOC NOx VOC 

Onroad 37 .2 17 .8 11 .8 8.9 I 

5.6 Vapor Recovery: Stage II and Onboard Refueling 

EPA established the federal Stage II vapor recovery program, a VOC emissions reduction control 

measure, in Section 182(b)(3) of the CAA. This section of the CAA directs state or local air pollution 

control agencies with moderate or worse ozone nonattainment areas to require Stage II vapor 

recovery systems (VRS) at gasoline dispensing facilities (GDF) . However, Section 202(a)(6) of the 

CAA, states that the Section 182(b)(3) Stage Il requirement shall not apply in moderate areas after 

new motor vehicle onboard refueling vapor recovery (ORVR) requirements are promulgated. 

For the Ozone Transport Region, there is an additional requirement, in Section 184(b)(2) of the CAA, 

for 1) EPA to "complete a study identifying control measures capable of achieving emission 

reductions comparable to those achievable through vehicle refueling controls contained in section 

7511 a (b)(3) of this title, and such measures or such vehicle refueling controls shall be implemented 

in accordance with the provisions of this section" (referred to as comparable measures); and 2) OTR 

states to revise their state implementation plans to require Stage 11 controls or comparable measures 

in OTR areas (statewide in New Hampshire) . 

12 This requirement is not affected by EPA's 

promulgation of ORVR rules, or by any future widespread use determination under CAA Section 

202(a)(6). 

lZ See U.S . EPA, Stage II Comparability Study for the Northeast Ozone Transport Region, EPA Publication No. EPA452/R-94-O11, January 1995. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 35 

Portions of New Hampshire's four-county nonattainment area (the Southern and Seacoast Serious 

areas) were assigned a higher than moderate classification for the 1997 ozone NAAQS, and the 

entire state is located in the OTR. Therefore, NHDES has required Stage II controls as an element 

of the state's federally enforceable implementation plan in the four-county nonattainment area since 

1992. The Stage 11 requirements were codified in New Hampshire rule Env-A 1205 Volatile 

Organic Compounds (VOC): Gasoline Dispensing Facilities and Gasoline Tank Trucks and 

subsequently approved into the SIP.13 (Note that New Hampshire identified comparable measures 

to avoid the OTR statewide Stage II requirement.) 

The CAA required EPA to develop standards for ORVR controls on new light-duty vehicles, which 

were phased in between 1998 and 2002 . However, there is a technology mismatch: vacuum assist 

Stage 11 control systems are not fully compatible with ORVR-equipped vehicles . ORVR diminishes 

the effectiveness of the vacuum assist Stage II vapor recovery systems, resulting in an increase in 

emissions compared to the levels expected during refueling of non-ORVR-equipped vehicles . 

Consistent with these findings, NHDES has determined that Stage II vapor recovery controls are 

providing a diminished emissions reduction benefit due to the predominance of ORVR-equipped 

vehicles in the New Hampshire fleet. This benefit will disappear altogether over the next several 

years as more ORVR-equipped vehicles enter the fleet. 

Because of the conflicting technology and its potential to increase refueling emissions as ORVR 

achieves "widespread use," 14 NHDES, with guidance from EPA, is removing the Stage II 

requirement for existing and future gasoline dispensing facilities . Note, however, that NHDES is 

not submitting the phase-out of Stage II as a formal component of this SIP revision to redesignate 

the 1997 8-hour ozone nonattainment area, but will submit a separate request to remove Stage II 

requirements from the SIP in the near future . 

5.7 Resource Commitments 

Section 110(a)(2)(E) of the CAA requires assurances that the state will have adequate personnel, 

funding, and authority under state law to carry out the State Implementation Plan. Funding for New 

Hampshire's air programs is appropriated by the New Hampshire General Court on a biannual 

budget cycle. EPA provides significant financial support for the administration of federal programs 

in New Hampshire . The majority of funding is derived through the Air Resource Division's permit 

fee structure. NHDES is committed to providing continued funding and staffing levels adequate to 

maintain New Hampshire's implementation plan. 

5.8 Future Revisions to the Plan 

NHDES will revise the maintenance plan for the redesignated area, as necessary, to meet revisions 

to the NAAQS for ozone, to fulfill other requirements of the Clean Air Act, or take advantage of 

improved methods for maintaining the standard . More specifically, in compliance with Section 

175A of the Act, NHDES will revise the maintenance plan eight years after redesignation of the 

area, or at any such time that EPA deems the maintenance plan inadequate to meet the NAAQS. 

'3 See 63 FR 67405, December 7, 1998, at http ://www .epa.gov/reQionl/topics/air/sips/sips nh.html. 

'4 See U. S. EPA, Stage 11 Vapor Recovery Systems Issues Paper, Office of Air Quality Planning and Standards (D243-02), 

August 12, 2004, at http ://www.epa .gov/ttn/naaqs/ozone/ozonetech/sta eg 2/isspaper081204 pdf. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 36 

6. MAINTENANCE PLAN 

Section 175A of the Clean Air Act sets forth the elements of a maintenance plan for areas seeking 

redesignation from nonattainment to attainment . The plan must demonstrate continued attainment 

of the applicable NAAQS for 10 years after the area is redesignated . Section 175A(b) requires that, 

eight years after formal redesignation, the state submit a SIP revision for maintenance of the 

standard for an additional 10 years following the first 10-year period . To provide for appropriate 

response to the possibility of future NAAQS violations, the maintenance plan must contain 

contingency measures adequate to assure prompt correction of any air quality problems, including a 

schedule for implementation. 

EPA guidance15 recommends that states seeking redesignation of a nonattainment area consider the 

following provisions to ensure maintenance of the NAAQS: 

An attainment emissions inventory to identify the level of emissions in the area that is 

sufficient to attain the NAAQS. 

A maintenance demonstration showing that future emissions of a pollutant or its precursors 

will not exceed the level of the attainment inventory over the 10-year period following 

redesignation. 

Continued operation of an appropriate air quality monitoring network to verify the area's 

attainment status . 

Verification of continued attainment and evidence that the state has the legal authority to 

implement and enforce all measures necessary to attain and maintain the NAAQS. 

Available contingency measures to promptly correct any NAAQS violation, including a 

schedule for implementation. 

6.1 Attainment Inventory 

The attainment emissions inventory should identify the level of emissions sufficient to achieve the 

NAAQS. This inventory should be consistent with EPA's most recent guidance on emission 

inventories for nonattainment areas available at the time and should include emissions during the 

time period associated with the monitoring data showing attainment of the ozone NAAQS. Where 

the state has made an adequate demonstration that air quality has improved as a result of the SIP, the 

attainment inventory will generally be the actual inventory during the time period the area attained 

the standard . The inventory must be based on "typical summer day" emissions of VOCs and NOx 

during the attainment year. 

NHDES has developed an attainment inventory for 2008, representing the three-year period (2007-

2009) in which New Hampshire's ozone monitoring data showed attainment of the 8-hour ozone 

standard . (Note that the monitoring data have met this standard since the 2002-2004 monitoring 

period). The 2008 attainment inventory and projected future inventories (see 6.2 .1 Projected 2012 

and 2022 Emissions Inventories) are subdivided into the following general emissions categories : 

Point Sources, which represent discrete facilities . These sources usually must meet certain 

emission criteria to be included as point sources and generally represent larger facilities . 

Area Sources, which represent facilities and activities too numerous and widespread to be 

inventoried individually but which collectively may account for significant emissions . 

'5 See footnote 10. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 37 

Non-Road Mobile Sources, including aircraft, locomotives, commercial marine vessels, 

construction vehicles, lawn & garden equipment, and other mobile vehicles and equipment 

that are not meant to be operated on roadways. 

On-Road Mobile Sources, including cars, trucks, buses, motorcycles, and other vehicles that 

operate on public roadways. 

The 2008 attainment inventory and the projected 2012 interim-year and 2022 maintenance 

inventories represent all NOx and VOC,emissions originating within the specific cities and towns of 

the 8-hour ozone nonattainment area (see Table 1-1 for list). These inventories were developed in 

accordance with EPA guidance. Because the 2008 emissions inventory serves as the attainment 

inventory for this redesignation request, it is being formally adopted into the New Hampshire SIP . 

The 2008 emissions inventory is also being submitted to EPA for inclusion in the 2008 National 

Emissions Inventory. Detailed documentation for New Hampshire's 2008 emissions inventory is 

presented for SIP approval as Attachment G. The methodologies used in preparing the 2008 

emissions estimates are summarized in the following paragraphs . 

For point sources, affected facilities in New Hampshire are required to report their emissions on an 

annual basis . The reporting requirements for these facilities are provided under New Hampshire's 

air regulations, its state air permitting program, and the CERR. Data submitted by these facilities are 

extensively cross-checked and quality assured by NHDES staff before eventual submittal to EPA. 

The point source data contained in New Hampshire's 2008 attainment inventory originated from the 

quality-assured 2008 data from all reporting point sources in the 8-hour nonattainment area. 

The methodologies used to estimate emissions for area source categories come primarily from EPA's 

Emissions Inventory Improvement Program (EIIP) . Calculations for many area source categories are 

based on variables such as population, employment, and fuel consumption data. Descriptions of the 

methodologies for specific area source categories can be found in EIIP Volume 3, Area Sources, 

which is available at EPA's Clearinghouse for Inventories and Emissions Factors website at 

http ://www.epa .gov/ttn/chief/eiip/techreport/volume03/index.html. 

For the non-road mobile category, NHDES used EPA's NONROAD2008a model to estimate 2008 

emissions for those equipment types that are included in the model. For commercial aircraft and 

airport ground service equipment, NHDES used the Federal Aviation Agency's (FAA's) Emissions 

& Dispersion Modeling System (EDMS). Standardized methodologies and references were 

employed for equipment types not included in the EDMS or NONROAD models, e .g ., locomotives 

and commercial marine vessels. 

For on-road mobile sources, NHDES used MOVES2010a with VMT and other road related data 

provided by the relevant MPOs within the state's nonattainment area. Results represent emissions 

originating in cities and towns in the non-attainment area only, not whole counties as had been 

reported previously . 

Estimated emissions for the 2008 attainment inventory are shown in Table 6-1 . 

6.2 Maintenance Demonstration 

EPA guidance on redesignation provides for demonstrating maintenance of the NAAQS through the 

use of either an emissions inventory approach (where a state demonstrates that future emissions of a 

pollutant or its precursors will not exceed the level of the attainment inventory), or by air quality 

modeling to show that future emission rates from all sources will not cause a violation of the NAAQS. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 38 

The maintenance demonstration should be for a period of 10 years following the redesignation and 

should consider future growth, including population and industry, be consistent with the attainment 

inventory, and provide documentation of data inputs and assumptions. All elements of the 

demonstration should be consistent with current EPA guidance. Enforceability through regulations 

must also be demonstrated . 

Any assumptions concerning emission rates must reflect permanent, enforceable measures. A state 

generally cannot take credit for reductions unless there are regulations in place requiring those 

reductions or the reductions are otherwise shown to be permanent. Therefore, the state is expected 

to maintain its implemented control strategy despite redesignation to attainment, unless such 

measures are shown to be unnecessary for maintenance or are replaced with measures that achieve 

equivalent reductions . Emission reductions from source shutdowns can be considered permanent 

and enforceable to the extent that those shutdowns have been reflected in the State Implementation 

Plan and all applicable permits have been modified accordingly. 

6.2 .1 Projected 2012 and 2022 Emissions Inventories 

New Hampshire has chosen to utilize the emissions inventory approach to demonstrate that its 

future emissions of ozone precursors will not exceed the level of the 2008 attainment inventory, and 

has projected emissions for 2012 and 2022.16 Table 6-1 shows that future emissions of NOx and 

VOC will remain below the level of New Hampshire's 2008 attainment inventory through the 10-

year planning period following redesignation - the result of a continuing decline in total emissions. 

The projected emissions reflect the expected summertime emissions based on enforceable emission 

limits and typical production rates. The methodologies used to estimate projected 2012 and 2022 

emissions are discussed in the following paragraphs . 

Table 6-1 . 2008 vs. 2012 and 2022 NOx and VOC Emissions in the 

Southeast New Hampshire Nonattainment Area (pounds per day) 

NOx VOC 

Source Category 2008 2012 2022 2008 2012 2022 

Point 24,289 21,655 22,742 5,762 5,288 6,605 

Area 6,528 6,243 6,432 55,871 57,885 70,195 

Non-Road Mobile 31,364 26,121 17,670 33,512 26,863 19,152 

On-Road Mobile 74,352 51,204 23,558 35,666 26,985 17,839 

Total 136,533 105,223 70,402 130,811 117,021 113,791 

Except as noted below, New Hampshire used EPA's Economic Growth Analysis System (EGAS) 

Version 5 .0 to develop the applicable growth factors for estimating projected 2012 and 2022 

emissions. Growth factors were matched to the appropriate point, area, and mobile source 

categories using Source Classification Codes (SCC). With respect to area sources, New Hampshire 

has adopted or is evaluating various control measures for a number of VOC source categories such as 

solvent cleaning, architectural surface coating, etc. For those measures that are not yet SIPapproved, the attendant emission reductions benefits are omitted from the 2012 and 2022 

inventories. As a consequence of this conservative approach, it is anticipated that actual future-year 

emissions will be lower than the projected emissions presented in Table 6-1 . 

'6 The maintenance plan must show that emissions 10 years after the date on which EPA approves the redesignation 

request (expected to be in 2012) will be lower than they were in the base year (2008) of the maintenance plan . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 39 

Because analysis year is an inherent input into the NONROAD model, projected 2012 and 2022 

non-road mobile emissions were estimated directly for those non-road equipment categories that are 

included in the model. For other non-road mobile categories such as aircraft, locomotives, and 

CMVs, the appropriate EGAS growth factors were used. For commercial aircraft and airport ground 

service equipment, the EGAS growth factors were applied to the specific activities (e .g ., aircraft 

landing and takeoff operations) ; and the growth-adjusted values were then input into the EDMS 

model . (Note: The EDMS model uses the analysis year to select the appropriate emission factors.) 

For on-road mobile sources, VMT data were provided by the relevant Metropolitan Planning 

Organizations (MPOs) via their transportation demand models that use population, employment and 

other economic factors as inputs to growth-adjust to 2012 and 2022 . These values were subsequently 

used as inputs to the MOVES model. Vehicle population data were adjusted for subsequent years 

using the growth factors from Table 3-14 of MOVES2010 Highway Vehicle Population and 

Activity Data, EPA-420-R-10-026, November 2010. 

In addition to growth factors and future control measures, another consideration in making emission 

projections is that sources in New Hampshire hold a certain quantity of banked emissions under the 

state's open market trading program. As of 2011, these sources held 68 tons of ozone-season 

Discrete Emissions Reductions (DERs) and 254 tons per season of ozone-season Emissions 

Reductions Credits (ERCs) for VOC. Similarly, New Hampshire sources held 1,882 tons of ozoneseason DERs and 198 tons of ozone-season ERCs for NOx. It is expected that these credits will 

remain banked and not be used. However, it was conservatively assumed that all available 

emissions credits would be used. Therefore, they have been included in the project point source 

emissions estimates shown in Table 6-1 . 

All of the technical data files related to the projected 2012 and 2022 emissions inventories are 

enclosed on CD-ROM as Attachment H. 

6.2 .2 Air Quality Modeling 

Although EPA's redesignation guidance does not require air quality modeling for ozone 

nonattainment areas seeking redesignation, extensive modeling has been performed to determine the 

effect of national and regional emission control strategies on ozone air quality in New Hampshire 

and throughout the eastern United States . These modeling analyses have demonstrated that the 

Southeast New Hampshire Nonattainment Area is significantly impacted by transported ozone and 

ozone precursors and that regional NOx reductions will provide significant ozone air quality 

improvements in this area. 

6.2 .2 .1 EPA Modeling Analysis for the Nonroad Land-Based Diesel Engines Standards 

In 2003, EPA conducted modeling to support the rulemaking for the Nonroad Land-based Diesel 

Engines Standards.' 7 In its analysis, EPA used the Comprehensive Air Quality Model with 

Extensions (CAMx) to evaluate the impacts of the proposed emission reductions on future air 

quality levels . Three meteorological episodes (June 12-24, 1995; July 5-15, 1995 ; and August 7-21, 

1995) were used for the modeling simulations . Ambient monitoring showed that ozone 

concentrations over the eastern United States were relatively elevated during these time periods. 

'7 "Technical Support Document for the Nonroad Land-based Diesel Engines Standards Air Quality Modeling 

Analyses", U.S . EPA Office of Air Quality Planning and Standards, April 2003 . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 40 

Using the relative reduction factor method, EPA applied CAMx to predict ozone values under 

several emissions scenarios: the 1996 base year, the 2021 baseline case, the 2021 control case, the 

2030 baseline case, and the 2030 control case. Results of this modeling show that under both the 

base case (without new rules on nonroad land-based diesel engines) and under the control scenario 

(with these new rules), there would be no counties in New Hampshire with predicted future design 

values that exceed (or come within 10 percent of) the 8-hour ozone standard . 

6.2 .2 .2 EPA Modeling Analysis for the CAIR Rulemaking 

More recently, EPA conducted a similar modeling analysis as part of the Clean Air Interstate Rule 

(CAIR) rulemaking'g . In this analysis, EPA used CAMx version 3.10 to model the 1995 ozone episode 

meteorology described above (i .e ., June 12-24, July 5-15, and August 7-21, 1995). The analysis 

years and emissions scenarios that were assessed included: 

" 2001 Base Year " 2010 Base Case 

" 2010 CAIR Controls 

" 2015 Base Case 

" 2015 CAIR Controls 

" 2015 CAIR + BART 

" 2015 BART Only 

The 2010 and 2015 base cases reflect expected economic growth and the anticipated benefits 

associated with existing emissions control programs. 

As with the modeling done for the non-road diesel rulemaking, the CAMx model predictions for the 

CAIR analysis were used in a relative manner. Weighted-average 1999-2003 design values were 

used as the basis of the observed 8-hour ozone concentrations . EPA then estimated maximum 8-

hour ozone design values for each future-year scenario for each county in the modeling domain with 

an ozone monitor. Table 6-2 shows the maximum estimated future 8-hour design values for New 

Hampshire. These results show that, even without the emissions benefits associated with CAIR, all 

New Hampshire counties were predicted to be in attainment for 8-hour ozone for the 2010 and 2015 

analysis years. 

Table 6-2. Summary of CAIR Modeling Results for Ozone Levels in New Hampshire (ppb) 

C t 

1999-2003 

A D i n 

Estimated Maximum 8-hour Future Design Values 

oun y verage es g 

Value 2010 Base 2010 CAIR 2015 Base 2015 CAIR 

Belknap 78 .0 68 .5 68.2 65.8 65 .0 

Carroll 66 .5 60 .3 60.0 58.6 58 .0 

Cheshire 73 .7 65 .2 64.9 63 .1 62 .0 

Hillsborough 85 .0 76 .7 76.6 74.1 73 .9 

Merrimack 73 .0 64 .8 64.6 62.3 61 .8 

Rockingham 82.7 75 .2 75.1 73 .3 72.9 

Strafford 77.3 69.2 69.1 I 66.8 I 66.5 

Note: Data taken from Appendix E of EPA's Technical Support Document for the Final Clean Air Interstate Rule, 

Air Quality Modeling, March 2005. 

18 "Technical Support Document for the Final Clean Air Interstate Rule, Air Quality Modeling", U.S . EPA Office of Air 

Quality Planning and Standards, March 2005 . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 41 

6.3 Air Quality Monitoring Network 

Once an area has been redesignated, the state must continue to operate an appropriate air quality 

monitoring network in accordance with 40 CFR Part 58, to verify the area's attainment status . In 

cases where measured mobile source parameters (for example, vehicle miles traveled) have changed 

over time, the state may also need to perform a saturation monitoring study to determine the need 

for and location of additional permanent monitors. NHDES is committed to the continued operation 

and maintenance of an appropriate air quality monitoring network for the Southeast New Hampshire 

Nonattainment Area, contingent on future EPA funding sufficient to sustain the network at the 

required operational levels . 

6.4 Verification of Continued Attainment 

Verification of continued attainment can be accomplished through the acquisition of air quality data 

and source emission data. Air quality data will directly show whether the ozone NAAQS is being 

met in real time and over specified averaging periods. The gathering of source emission data 

enables the construction of periodic updates to emissions inventories for tracking progress in 

emission control measures or supplying inputs for revised air quality modeling projections. 

Emission inventory updates could be based, in part, on the annual update of EPA's national 

emissions inventory (NEI) database and could indicate new source growth and other changes from 

the attainment inventory (such as changes in vehicle miles traveled or in traffic patterns). 

New Hampshire will track the progress of attainment maintenance by making periodic updates to 

the state emissions inventory. NHDES ordinarily revises the emissions inventory on a 3-year cycle; 

the latest one, the 2008 inventory, was completed in 2010. Subsequent updates will be prepared for 

2011 and 2014 . NHDES will report the results of this tracking program to EPA on the same 3-year 

cycle, when the emissions inventory data become available. 

6.5 Contingency Plan 

Section 175A(d) of the Clean Air Act requires that a maintenance plan include contingency 

provisions to promptly correct any violation of the NAAQS that occurs after redesignation of a 

nonattainment area to attainment status . As an enforceable part of the SIP, the contingency plan 

should be implemented expediently if and when the need arises . According to EPA guidance 19, the 

contingency plan should clearly identify the measures to be adopted, a schedule and procedure for 

adoption and implementation, and a specific time limit for action by the state. The plan should also 

identify specific indicators, or triggers, that the state will use to determine when the contingency 

measures are needed. Action-level indicators might be based on ambient ozone concentrations (e.g., 

monitored violations of the NAAQS) or on updated emission inventory values (e .g ., tonnages of 

specific ozone-precursor pollutants). 

EPA points out that air quality levels above the NAAQS will not automatically necessitate a 

revision of the SIP where implementation of contingency measures is adequate to address the cause 

of the violation. The need for a SIP revision is subject to the EPA Administrator's discretion . EPA 

states in its guidance that the agency will review what constitutes a contingency plan on a case-bycase basis. At a minimum, it is required that the state implement all measures contained in the SIP 

for the nonattainment area prior to its redesignation to attainment . 

'9 See footnote 10 . 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 42 

Despite New Hampshire's best efforts to maintain compliance with air quality standards, the 

possibility exists that ambient ozone concentrations might at some future date exceed the NAAQS. 

Therefore, in accordance with the requirements of Section 175A(d), New Hampshire has identified 

various contingency measures that could be taken following an ozone "trigger" event and is 

committed to pursuing the following protocol : 

1 . At the conclusion of each ozone season, NHDES will evaluate whether the 8-hour ozone 

design value for any ozone monitor in the redesignated planning area is above or below the 

1997 8-hour ozone standard (the "trig ~er") . The design value, in the case of this standard, is 

defined as the average of the annual 4' highest daily maximum 8-hour average concentration 

for the preceding 3-year period . 

2. If the design value is above the standard for any ozone monitor, NHDES will investigate the 

cause and determine whether the exceedance is due to : 

. 

an increase in emissions from local, in-state sources; 

an increase in emissions from upwind, out-of-state sources; or 

exceptional event as defined in 40 CFR 50.1 . 

3 . If an increase in in-state emissions is determined to be a contributing factor to the 

exceedance, NHDES will evaluate the projected in-state emissions for the next ozone 

season . If the projected in-state emissions are not expected to decrease enough in the next 

ozone season to mitigate the violation, New Hampshire will implement one or more of the 

contingency measures listed below or will substitute other VOC or NOx control measures as 

necessary to achieve additional in-state emission reductions . 

4. The contingency measures(s) will be selected by the Governor or the Governor's designee 

within six months of the end of the ozone season for which contingency measures have been 

determined to be needed. New Hampshire will then initiate a course of action to implement 

enforceable control measure(s) to rectify the problem. New rulemaking can typically be 

adopted and implemented within a 12-month timeframe . NHDES will update the 

maintenance plan as necessary and develop and implement required regulations as soon as 

practicable within the guidelines established in the New Hampshire Administrative Procedures 

Act, but no later than 18 months after selection of the appropriate measure. 

New Hampshire is studying an array of possible contingency measures that would achieve further 

reductions in NOx and VOC emissions, including the following emission controls previously 

proposed by the Northeast states : 

. 

NOx controls for industrial, commercial, and institutional (ICI) boilers; 

VOC controls for emulsified and cutback asphalt paving; and 

VOC controls for consumer products. 

These contingency measures are among several OTC control measures" exceeding current on-thebooks/on-the-way (OTB/OTW) emission controls and serving as a subset of potential additional 

controls measures called beyond-on-the-way (BOTW). Details on BOTW control measures may be 

found in MACTEC's report "Development of Emission Projections for 2009, 2012 and 2018 for 

NonEGU Point, Area and Nonroad Source in the MANE-VU Region," Final Report, February 2007 . 

20 MACTEC Federal Programs, "Identification and Evaluation of Candidate Control Measures," Final Technical Support 

Document, Ozone Transport Commission, February 28, 2007. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 43 

Estimated emission reductions for New Hampshire from the three named control measures are given 

in Table 6-3. 

Table 6-3. Estimated Emission Reductions from Three BOTW Control Measures 

Control Measure Pollutant 2009 Estimated Emission 

Reductions (tons per day) 

ICI Boilers (OTC 2006 Model Rule) NOx 1 .9 ' 

Emulsified Asphalt Paving (OTC guidelines) VOC 4.4 

Consumer Products (OTC 2006 Model Rule) VOC 0.3 

Source: MACTEC, 2007 

These potential contingency measures are further described in subparts 6.5 .1 through 6.5 .3, below. 

6.5 .1 ICI Boilers (at Major Point Sources) 

In 2006, the OTC commissioners recommended that the OTC member states pursue "as necessary 

and appropriate" state-specific rulemakings to establish required emission reduction percentages, 

emission rate performance standards, or control technologies to reduce emissions from industrial, 

commercial, and institutional boilers (OTC Resolution 06-02) . The approximately 2-ton-per-day 

reduction in NOx emissions from ICI boilers reported in Table 6.3 was based on implementation of 

OTC's recommended control levels on boilers of 25-250 MMBtu/hr heat input capacity at major 

point sources in New Hampshire. 

6.5 .2 Emulsified Asphalt Paving 

NHDES is currently evaluating the proposed contingency measure for emulsified asphalt paving. 

OTC's guideline would limit the VOC content of emulsified asphalt to 2 percent or less . The VOC 

content of emulsified asphalt in New Hampshire is assumed to be 2 .5 percent at present. Thus, the 

estimated VOC emission reduction from this source category would be approximately 20 percent 

during the ozone season . 

6.5 .3 Consumer Products 

The contingency measure for consumer products included in Table 6-3 would replace the OTC 2001 

VOC model rules with the OTC 2006 model rules, which provide amendments adopted by the 

California Air Resources Board (CARB) in July 2005 . The amendments revise the existing VOC 

limit for contact adhesives and create VOC limits for nine new source categories (adhesive 

removers, electrical cleaner, electronic cleaner, fabric refresher, footwear or leather care, graffiti 

remover, hairstyling products, toilet care, and wood cleaner). Based on estimates developed by 

CARB for 2009, these amendments would reduce VOC emissions by about 2 percent. 

6.5.4 Additional Controls on Boilers 

New Hampshire and the other OTC states have continued to investigate the possibility of additional 

controls on ICI boilers and utility boilers as stationary sources with the highest potential for NOx 

emission reductions . The additional controls would cover a wider range of boilers and would be 

more stringent than those described in the MACTEC report for non-EGU point sources and area 

sources in New Hampshire. More specifically, recent OTC proposals being considered by NHDES 

would provide additional NOx controls on the following boiler categories : 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 44 

as-fired boilers servin 

. 

OTC 2010 Model Rule : This proposed rule would 

impose the following NOx emission limitations on oil- and gas-fired utility boilers with a 

nameplate capacity of 25 MW or greater : for gas only, 0 .08 lb/MMBtu; for oil or oil/gas, 

0.15 lb/MMBtu. 

New small natural-gas-fired boilers and water heaters (OTC 2010 Model Rule): This proposed 

rule would establish NOx emission standards for various devices ranging in size from 75,000 

to 5,000,000 Btu/hr . 

. ICI boilers: Stricter NOx emission standards would be extended to any ICI boiler above a 

certain size threshold, e.g ., 25 MMBtu/hr. 

Since 2006, OTC and the Lake Michigan Air Directors Consortium (LADCO) have worked 

collaboratively to assess the technical and economic feasibility of enhanced emission controls on ICI 

boilers of all sizes.21 A NESCAUM study2z from the same time period examined a variety of 

technologies available to reduce NOx emissions from ICI boilers with heat input ratings from as low 

as 10 MMBtu/hr to as high as 1,000 MMBtu/hr. It was determined that emission reductions of 5 to 

90 percent are achievable, depending on boiler size, fuel type, and chosen technology. Generally, 

the higher control efficiencies are applicable to larger ICI boilers, of which New Hampshire has 

relatively few. 

NHDES is gathering data on New Hampshire's current stock of ICI boilers by size, fuel type, and 

existing control level. Preliminary data indicate that approximately 80 percent of ICI boilers in the 

state have heat input ratings less than 25 MMBtu/hr and lack NOx controls. Another 13 percent 

have heat input ratings less than 50 MMBtu/hr and lack NOx controls. These units - most of them 

burning fuel oil - account for more than half of all NOx emissions from ICI boilers in the state. 

Boilers with heat input ratings above 100 MMBtu/hr, while far fewer in number, would generally 

have some existing level of NOx controls. Given all of these facts, NHDES anticipates that any 

reasonable control program for ICI boilers in New Hampshire would be capable of reducing overall 

NOx emissions from this sector by 25 percent or more. 

Ongoing state and regional initiatives to control boiler emissions are overlain by EPA's proposed or 

final rules pertaining to National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

industrial, commercial, and institutional (ICI) boilers at major sources and area sources; NESHAP 

for coal- and oil-fired electrical generating units; and New Source Performance Standards (NSPS) for 

fossil-fuel-fired electric utility and ICI boilers. Under these rules, affected sources would be subject 

to mandatory new emission limits and/or periodic boiler tune-ups that would yield direct emission 

reductions or indirect co-benefits with respect to NOx and VOC control. 

6.5 .5 Other Contingency Measures 

NHDES is evaluating other potential NOx and VOC control measures that could be applied, if 

necessary, to further reduce ozone levels in the maintenance area. These control measures are listed 

in Table 6-4 along with the previously mentioned contingency measures for boilers, asphalt paving, 

and consumer products . 

Z' OTC and LADCO, "Evaluation of Control Options for Industrial, Commercial and Institutional (ICI) Boilers," 

Technical Support Document, Final, May 14, 2010. 

ZZ NESCAUM, Applicability and Feasibility of NOx, SO2, and PM Emission Control Technologies for Industrial, 

Commercial, and Institutional (ICI) Boilers, November 2008. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 45 

Table 6-4. Potential Contingency Measures for Reducing Ozone Levels 

Control Measure Source Category 

NOx Control Measures 

Oil and Gas Boilers Serving EGUs (OTC 2010 Model Rule) Major Point 

New Small Natural-Gas-Fired Boilers and Water Heaters (OTC 2010 Model Rule) Area* 

ICI Boilers Area or Major Point 

Stationary Generators (OTC 2010 Model Rule) Area 

Motor Vehicle Anti-Idling (mandatory, not voluntary) Onroad Mobile 

California Low-Emission Vehicles (CALEV) Standards Onroad Mobile 

Low-Carbon Fuel Standard (regional) Onroad Mobile / Nonroad 

VOC Control Measures 

Large above-Ground Storage Tanks (OTC 2010 Model Rule) Major Point 

Emulsified and Cutback Asphalt Paving (OTC guidelines) Area 

Adhesives and Sealants Application (OTC 2006 Model Rule) Area 

Architectural and Industrial Maintenance Coatings (OTC 2009 Model Rule) Area 

Solvent Cleaning (OTC 2009 Model Rule) Area 

Consumer Products (OTC 2006 Model Rule) Area 

Consumer Products (OTC 2010 Model Rule) Area 

Motor Vehicle and Mobile Equipment Non-Assembly Line Coatings Operations 

(OTC 2009 Model Rule) Area 

*Area sources include minor emission sources, typically large in number and widely distributed. 

7. ADMINISTRATIVE DOCUMENTS 

In accordance with the requirements for SIP submissions established in 40 CFR 51 .103, the following 

documentation is herewith provided as integral to this redesignation request: 

A formal letter of submittal from the Governor or his designee, requesting EPA approval of 

this SIP revision; 

Evidence that NHDES has the necessary legal authority under state law to adopt and 

implement the plan. 

Evidence that public notice was given of the proposed change consistent with procedures 

approved by EPA, including the date of publication of such notice . 

Certification that public hearing(s) were held in accordance with the information provided in 

the public notice and the state's laws and constitution, if applicable and consistent with the 

public hearing requirements in 40 CFR 51 .102 . 

Compilation of public comments and the state's response thereto. 

Documentation of legal authority, public notice, certification of the public process, and public 

comments and responses are provided in Attachment E. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 46 

8. SUMMARY AND CONCLUSIONS 

NHDES is requesting redesignation of the Southeast New Hampshire Nonattainment Area from 

moderate nonattainment to attainment for the 1997 National Ambient Air Quality Standard for 8-

hour ozone. Section 107(d)(3)(E) of the Clean Air Act establishes the requirements that an area 

must meet in order to be considered for redesignation. The following summarizes how the 

nonattainment area meets the essential criteria for redesignation: 

The area has attained the 8-hour ozone standard. All four ozone monitoring sites within the 

nonattainment area have had ozone design values below the 1997 8-hour ozone standard for 

each year since 2006 (see Figure 2-4 and Attachment B) . In addition, all other ozone 

monitoring sites throughout the state have shown levels below this standard . 

The state has an approvedlapprovable State Implementation Plan under CAA Section 110(k) . 

New Hampshire's approved SIP is published in the Code of Federal Regulations at 40 CFR 

52 Subpart EE. The implementation plan includes revisions to demonstrate attainment of 

the former 1-hour ozone NAAQS (67 FR 72574, December 6, 2002) and to meet reasonable 

further progress requirements for the former standard (3 FR 67405, December 7, 1998, and 

67 FR 18493, April 16, 2002). Consistent with EPA's Clean Data Rule, certain SIP 

elements related to attainment of the 8-hour ozone NAAQS, including an attainment 

demonstration, a reasonable further progress plan, contingency measures, and other plan 

elements, have been suspended (73 FR 14387, March 18, 2008). The approved SIP 

incorporates rules implementing NOx and VOC RACT requirements (see Table 4-2). 

The improvement in air quality is due to permanent and enforceable emission reductions 

resulting from implementation of the SIP and other federal requirements. The vast majority 

of ozone-causing air pollutants in New Hampshire originate from sources in upwind states . 

Federally mandated programs such as the NOx SIP Call have made it possible for groundlevel ozone concentrations in the nonattainment area to reach attainment levels . Also 

contributing to local air quality improvements are New Hampshire regulations to control 

NOx and VOC emissions from diverse sources . Tables 4-1, 4-2, and 4-3 identify permanent 

and enforceable emission control measures that have resulted in statewide attainment for 

ozone. Table 4-4 shows the substantial decline in both NOx and VOC emissions from instate sources between 2002 and 2008 . 

The state has prepared an approved/approvable maintenance plan under Section 175A. 

NHDES has prepared the requisite attainment inventory, maintenance demonstration, and 

contingency plan, and will continue to operate an appropriate air quality monitoring network 

to assure that the area stays in attainment of the 8-hour ozone standard after redesignation 

(see 6. MAINTENANCE PLAN). A comparison of NOx and VOC emission inventories for 

2008, 2012, and 2022 (Table 6-1) indicates continuing, substantial emission reductions for 

both types of ozone precursors in the next decade. 

The state has met all Title I, Part A, Section 110, and Part D requirements for the area. 

New Hampshire has satisfied the requirements of Section 110 related to emission reporting 

and recordkeeping, periodic testing and inspection of emission sources, transportationrelated emission control measures, continuous monitoring and recording, and legal authority 

and emergency powers. The state has also met Part D requirements for nonattainment areas, 

providing assurance of future attainment through continued implementation of appropriate 

emission control and monitoring measures and attention to anti-backsliding requirements . 

(See 5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT.)