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## -7 PM 

## 12: 46 TEXAS COMMISSION ON ENVIRONMENTAL QuAlflIn'filVISION Bryan W. Shaw, Ph.D., Chairman BuddyGarcia, Commissioner Carlos Rubinstein, Commissioner Mark R. Vickery, P.G., Executive Director

Protecting Texas by Reducing and Preuentinq Pollution 

### April 1,2010

Docket No. 2009-0801-SIP 

### Project No. 2009-018-SIP-NR**y",·~:·** -,...r;·, .
:::**~-~!'** 

### Alfredo "AI" Armendariz, Ph.D., Regional Administrator U.S. Environmental Protection Agency

- Region6 1445 RossAvenue Dallas,Texas 75202-2733 w -**S~2** 

# c:'**~~ :"J~** **r-~·** 

### Dear Dr. Armendariz: On 

### March 10,2010, the Texas Commission on Environinental Quality (Commission) adopted a revision to the state implementation plan (SIP) for demonstration of reasonable further progress for the Houston-GalvestonBrazoria(HGB) 1997 eight-hour ozone nonattainment area. The Commission adopted the HGB Reasonable Further Progress (RFP) SIP revision, demonstrating that the RFP emissions reduction requirement will be met forthe six-year period (2003-2008) beginning January 

### 1 of the year following the yearusedfor the baseline emissions inventory (2002) and all remaining three-year periods afterthe first six-year period (2009-2011, 2012-2014, and 2015-2017) outto the area's attainment 

### date (2019). This SIPrevisionalsosetsthe nitrogen oxides (NOx) 

### and volatile organic compounds (VOC) motor vehicle emissions budgets (MVEB) for transportation conformity purposes forthe milestone years 2008, 2011, 2014, 2017,and 2018. Enclosed are the proposed revision to the SIP, a public hearing certification, a complete record of the public hearings, andthe accompanying order. I look forward to your expeditious approval ofthis SIP revision. Sincerely,

# ~~;dAtv- Bryan W. Shaw, Ph.D. Chairman BWS/ts 

### Enclosures cc: The Honorable RickPerry, Governor of Texas Mr. 

### Toby Baker, Office of Budget, Planning and Policy, Office of the Governor .Mr, 

### MarkR. Vickery, P.G., Executive Director, Texas Commission on Environmental Quality

P.O. Box 13087 Austin, Texas 78711-3087 512-239-1000 Internet address:www.tceq.state.tx.us

'.' " 'd

### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Docket No. 2009-0801-SIP Project No. 2009-018-SIP-NR

THE STATE OF TEXAS COUNTY OF TRAVIS

This is to 

### certify that the attached 

### are true and 

### correct copiesof documents for a revision to 

### the Texas State Implementation Plan, adopted on March 10.2010. 

### pursuant to 40 

### Code 

### of Federal Regulations (C.F.R) §
51.104. 

### I am the records administrator for the Air 

### Quality Division of the Texas Commission on Environmental Quality (Commission).

# <Dm~.~- '0" "Air 

### Quality Division Texas Commission on Environmental QualityTexas Commission on Environmental Quality Public Hearings October 28 and 29. 2009 Concerning Revisions 

### to the HGB Eight-Hour Ozone Reasonable Further Progress SIP ProjectNo. 2009-018-SIP-NRINTRODUCTION

The Texas Commission on Environmental Quality (commission) held public hearings in Houston on October 28, 2009, and Austin on October 29, 2009, to receive testimony regarding the HoustonGalveston-Brazoria Reasonable Further Progress (RFP) state implementation plan (SIP) revision.

The adoption demonstrates that an 18 percent emissions reduction requirement will be met for the analysis period of 2002 to 2008,9 percent between 2009 and 2011, 9 percent between 2012 and 2014, 9 percent between 2015 and 2017, 3 percent in 2018, and 3 percent for contingency
purposes. The HGB RFP SIP revision establishes baseline emission levels, calculates reduction targets, identifies control strategies to meet emission target levels, and tracks actual emission reductions against established emissions growth and control budgets.

This revision also includes motor vehicle emission budqets (MVEBs) for the milestone years 2008, 2011,2014,2017, and 2018. No new on-road mobile source controls have been adopted as part of the plan. However, on-road mobile source emissions inventories have been updated using the latest available data and the United States Environmental Protection Agency's MOBILES inventory development tool. As a result of the required mobile source emission inventory updates, the MVEBs

are updated as part of this SIP revision.

The comment period closed on November 9, 2009. All testimony and comments have been reviewed and seriously considered. This hearing record contains a complete record of the public hearings and is divided into the following four sections:o Public Notification and Proposal

o Written and Oral Testimony

o Evaluation of Testimony

o Staff Recommendations/Order

Additional copies of this hearing record are maintained in the TCEQ central office at 12100 Park 35 Circle, Austin, Texas 78753. For further information, please contact Walker Williamson at (512) 239-3181.

# PUBLIC NOTIFICATION AND PROPOSALPUBLIC NOTIFICATION

Notification to the public of the proposed revision was conducted by the following procedures:

1. Publication of notice of public hearings in the following newspapers on the date listed: Austin American-Statesman, September 28, 2009 Houston Chronicle, September 28, 2009

2. Publication of the Notice of Public Hearings in the October 9,2009, issue of the Texas Register (34 TexReg 7132)

3. Correspondence forwarding the notice of public hearing to the following officials and agencies: Speaker of the House Lieutenant Governor Alamo Area Council of Governments Capital Area Planning Council City of Austin, Mayor's Office City of EI Paso City of Houston, Mayor's Office City of Victoria Planning Department Dallas Department of Environmental and Health Services Dallas Department of Aviation East Texas Council of Governments EI Paso Metropolitan Planning Organization Federal Highway Administration Fort Worth Environmental Management DepartmentGalveston County Health District Houston Department of Health and Human Services Harris County Public Health and Environmental Services Houston-Galveston Area Council North Central Texas Council of Governments South East Texas Regional Planning Commission Texas Department of Transportation Texas Transportation Institute Travis County Judge Arkansas Department of Pollution Control and Ecology Louisiana Department of Environmental Quality New Mexico Environmental Department Oklahoma Department of Environmental Quality U. S. Environmental Protection Agency

### Example of Newspaper Classified Ad Houston Chronicle, September 28, 2009(TCEQ) for proposed Registratio No. 40243, to construct and operate a Type V municipal solid waste fer station. The proposed facility, River City Recycles, will be I d 8000 Daffan Lane, Austin, Texas 78724, in Travis County. This f ility is requesting authorization to recycle and transfer municipal sol d waste which includes construction and demolition waste. The . 'on application is available for viewing and copying at the TCE Region II Office, 2800 S. IH 35, Suite 100, Austin, Travis County, TX 78704-5712. PUBLIC COMMENTIPUBLIC ETING. Written public comments or written requests for a public m . must be submitted to the Office of Chief Clerk at the address incl d in the information section below. Comments may also be received' a public meeting is held on the facility. A public meeting will be held y the executive director ifrequested by a member of the legislature represents the general area where the development is to be located, r if there is a substantial public interest in the proposed developmen The purpose ofthe public meeting is for the public to provide input r consideration by the commission, and for the applicant and the co . ion staff to provide information to the public. A public meeting i not a contested case hearing. The executive director will review and nsider public comments and written requests for a public meeting ubmitted prior to the notice offinal determination. The executive' r is not required to file a response to comments. EXECUTIVE DIRECTOR ACn N. The executive director shall, after review of an application for 'on, determine if the application will be approved or denied' whole or in part. If the executive director acts on an application, th chief clerk shall mail or otherwise transmit notice of the action and explanation of the opportunity to file a motion to reconsider the exe utive director's decision. The chief cleric shall mail this notice to the 0 and operator, the public interest counsel, to adjacent landowners shown on the required land ownership map and landowners list, an to other persons who timely filed public comment in response to p lie notice. Not all persons on the mailing list for this notice will re ive the notice letter from the Office of the Chief Cleric. IJIWORMAllON. Written public mments or requests to be placed on the permanent mailing list fi r this application should be submitted to the Office of the Chief Clerk, MC 105, TCEQ, P.O. Box 13087, Austin, TX 78711·308 or electronically submitted to http://wwwS.tceq.state.tx.uslecmnindex.cfin. Individual members of the general public may con the Office of Public Assistance at 1-800-687-4040. General info 'on regarding the TCEQ can be found at our web site at www..state.tx.us. Further information may also be obtained from Ms. Rodewald at the address stated above or by calling (512) 832-83 TRD-2oo904422 LaDonna Castaftuela Chief CIer1t TexasCommissionon Environmen Filed: September 30. 2009 

# • • Notice of Public Hearings on oposed Revisions to 30 TAC Chapter 101 and to the State plementation Plan The Texas Commission on Enviro ental QuaIity (commission) will conduct concurrent public he' to receive testimony regarding proposed revisions to 30 TAC C ter 101, General Air Quality Rules, Subchapter A, Definitions, and Su hapter II, Emissions Banking and Trading, Division 6, Highly- ive Volatile Organic Compound Emissions Cap and Trade Pro and corresponding revisions to the state implementation plan (S ) under the requirements of Texas



### 34 TexReg 7132 

### October 9, 

### 2009 Texas Register Health and Safety Code, §382.017; Texas Government Code, Chapter 2001, Subchapter B; and 40 Code fFederal Regulations §51.102, of the United States Environmental P tection Agency (EPA) concerning SIPs. The proposed amendments to C r 101, Subchapter A, §IOl.1, Definitions, would update the ition of volatile organic compound to link the 30 TAC de . on with the current definition in 40 Code of Federal Regulations d correct the reportable quantity for 1,I,I,2,3,3,3-heptafluoropro . The proposed amendment to Chapter 101, Subchapter II, Div ion 6, Highly-Reactive Volatile Organic Compound Emissions C and Trade Program, would also reduce the total cap amount of all wances and revise the allocation methodology of allowances for icipants in the Highly-Reactive Volatile Organic Compound Emissi ns Cap and Trade Program. (Rule Project No. 2009-006-101-EN) Public hearings for this proposed emaking and corresponding SIP revision are scheduled in conjuncti n with the proposed amendments to Chapter 101, Subchapter II, Di ision 3, Mass Emissions Cap and Trade (MECn program; and C 115, Subchapter E, Division 4, Offset Lithographic Printing at the ollowing times and locations: October 28, 2009, 2:00 p.m. and 6:00 .m., in Conference Room A at the Houston-Galveston Area Council, 555 Tunmons Lane, Houston; and in Austin on October 29, 2009, I: p.m. and 3:00 p.m., at the Texas Commission on Environmental 'ty complex, Building E, Room 20lS, 12100 Parle 35 Circle. The earings will be structured for the receipt of oral or written comments interested persons. Registration will begin 30 minutes prior to e hearing. Individuals may present oral statements when called upon' order of registration. There will be no open discussion during the aring; however, commission staff members will be available to disc the proposals 30 minutes before each hearing and will answer q ons before and after the hearing. Persons planning to attend the he' who have special communication or other accommodation n should contact Charlotte Horn, Texas Register Team (512) 239-07 9. Requests should be made as far in advance as possible. Comments may be submitted to essica Rawlings, Texas Register Team, Office of Legal Services, Te Commission on Environmental Quality, MC 205, P.O. Box 130 ,Austin, Texas 78711-3087, or faxed to (512) 239-4808. Electro c comments may be submitted at www5.tceq.state.tx.us/ruIes/ecom ntsl. File size restrictions may apply to comments being submitted . the eComments system. Copies ofthe proposed rules can be 0 • d from the commission's Web site at http://www.tceq.state.tx.us/nav/iles/propose_adopt.html. Copies of the proposed SIP revisions an all appendices can be obtained from the commission's Web site http://www.tceq.state.tx.us/implemenuuion/air/sip/Hottop.html. Fo further information regarding the proposed rules and SIP revisions, please contact Ray Schubert, Air Quality Planning Section, at (512) 39-661S. TRD-200904274 Robert Martinez Director, Environmental Law Divisi Texas Commission on Environmen Filed: September 25.2009 

# • 

# • Notice of Public Hearings on Proposed Revisions to 30 TAC Chapters 101 and 115 and to the State Implementation Plan The Texas Commission on Environmental Quality (commission) will conduct public hearings to receive testimony regarding proposed revisions to 30 TAC Chapter 101, General Air Quality Rules, and 30 TAC Chapter 115, Control of Air Pollution from Volatile Organic

# • Compounds and corresponding revisions to the state implementation plan (SIP) under the requirements of TexasHealth and Safety Code, §382.017;Texas Government Code, Chapter 2001,SubchapterB; and 40 Code of Federal Regulations §51.102, and the United States Environmental Protection Agency (EPA) concerning SIPs. Additionally, the commission will also receive testimony regarding the proposed eight-hour ozone attainment demonstration and reasonable further progress (RFP) demonstration for the Houston-Galveston-Brazoria (HOB) area. The proposedamendmentto Chapter 101, Subchapter H, Division3, Mass Emissions Cap and Trade (MEeT) Program. would revise the definitionof "Uncontrolled design capacity" to provideadditionalflexibilityfor certain stationarydieselenginesand clarifyboth site and facility applicability. In addition, the proposed amendment would maintain the integrity of the nitrogenoxides (N0x) cap in the HOB ozone nonattainment area andminimize increases in the NO x cap by discontinuing the acceptance of late ECT-3 forms, Level of Activity Certification, from major sourcesof NO x submitted after March 30,2010. (Rule Project No.**2~19-101-EN)** The proposed amendment to Chapter 101, Subchapter H, Division 6, Highly-Reactive Volatile Orgp"ic Compound Emissions Cap and Trade Program. wouldreducethe total cap amount of allowances and revisethe allocation methodology of allowances forparticipantsin the Highly-Reactive Volatile Organic Compound (HRVOC) Emissions Cap and TradeProgram.A proposed amendment to § I 01.1wouldalso update the definition of volatileorganiccompound(VOC)to link. the 30 TAC definition with the current definition in 40 Code of Federal Regulationsand correct the reportable quantityfor l,l,l,2,3,3,3-heptaftuoropropane. (Rule Project No. 2009-006-101-EN) The proposed amendments to Chapter 115, Subchapter E, Division4, Offset Lithographic Printing, wouldreduce the VOCcontentlimitson fountainsolutionsused by sourcesthat are subjecttothe existingChapter 115 rules. The proposed rulemaking would also limit the VOC content of fountain and cleaningsolutionsused by certainsourcesthat are exempt from the existing Chapter 115 rules. (Rule Project No.**2~19-115-EN)** The proposedHOB Attainment Demonstration SIP revision contains Federal Clean Air Act-required SIP elements, includinga photochemical modeling analysis, a weight of evidence analysis, a reasonable available control technology (RACT)analysis,a reasonably availablecontrol measures (RACM) analysis, a motor vehicle emissions budget (MVEB)for 2018,and a contingency plan. In addition,the Houston-Galveston Area Council has committed to emissions reductions through the Voluntary Mobile EmissionReduction Program and implementation of transportation control measures. The proposed revision also describes the concurrently proposedrule revisions in Chapters 101 and 115. The commission is also soliciting comments on whetherit is appropriate to performa 1997eight-hourozone standard mid-coursereviewanalysis,and, if so, what elementsshould be contained in the analysis. The commission is also seeking input on the appropriate date to submitthe mid-course review. (Rule Project No. 2009-G17-SIP-NR) The proposedHOB Eight-Hour Ozone Nonattainment Area RFP SIP revision demonstrates thatthe 18percentozoneprecursoremissions reduction requirement will be metforthe analysis period of2002 to 2008, 9 percentbetween2009 and 2011,9 percent between2012 and 2014, 9 percent between 2015 and 2017,3 percent in 2018, and 3 percent for contingency purposes. Thisrevision also includesa revisedMVEB for the milestoneyears 2008, 2011, 2014, 2017, and 2018. No new on-roadmobile source controlshave been adoptedas part of the plan. However,on-roadmobilesourceemissionsinventorieshave been updatedusing the latest available data and the EPA'sMOBILE6inventory development tool. As a result of the required mobile source emission inventory updates, theMVEBs are updated as part of thisSIP revision. (Rule Project No. 2009-018-SIP-NR) Public hearingson these proposals will be held at the following times and locations: October 28,2009,2:00 p.m. and 6:00 p.m., in ConferenceRoomA at the Houston-Galveston Area Council, 3555Tunmons Lane, Houston; and in Austin on October 29, 2009, 3:00 p.m., at the Texas Commission on Environmental Quality complex, Building E, Room201S, 12100 Pad 35 Circle. Thehearingswillbe structuredfor the receipt of oral or written comments by interested persons. Registrationwill begin 30 minutesprior to each hearing. Individuals may presentoralstatementswhencalleduponinorderof registration. There will be no open discussionduringthe hearing; however, commissionstaffmemberswillbe availableto discussthe proposals30 minutesbefore each hearingand will answer questionsbeforeand afterthe hearing. Persons planningto attend the hearing, who have special communicationor other accommodation needs, should contactCharlotteHorn, TexasRegisterTeam(512)239-0779.Requestsshouldbe made as far in advanceas possible. Comments may be submitted to Jessica Rawlings, Texas Register Team, Office of Legal Services, Texas Commission on Environmental Quality, MC 205, P.O. Box 13087, Austin, Texas 78711-3087, or faxed to (512) 239-4808. Electroniccommentsmay be submittedat www5.tceq.state.tx.uslruJesiecommenJsI. File size restrictions may apply to commentsbeing submittedvia the eComments system. AU commeats should reference the rule or SIP project number that the comment pertains to: Rule Project No. 2009-019-101-EN for the proposed MECf rule amendments, Rule Project. No. 2009-006-101-EN for the proposed HRVOC rule amendments, Rule Project No.**2~19-115-EN** for the proposed VOC rule amendmeats, SIP Project No. 2009-817-SIP-NR for the proposed HGB Attainment Demonstration SIP revision and SIP Project No. 2009-G18-SIP-NR for the proposed HGB RFP SIP revisioa. Comments must be received by November 9, 2009. Copies of the proposed rules can be obtained from the commission's Web site at hJtp://www.tceq.state.tx.uslnav/rulesipropose

_adopt.htmL Copies of the proposed SIP revisions and all appendices can be obtained from the commission's Web site at hJtp://www.tceq.state.tx.uslimplementationla;"/sip!Hottop.html. For further information regarding the proposed rules and SIP revisions, please contact Ray Schubert, Air Quality Planning Section,at (512) 239-6615. TRD-200904267 Robert Martinez Director, Environmental Law DMsion Texas Commission on Environmental Quality Filed: september 25, 2009 

# • Notice of Public Hearings on Chapter 115 and to the State I plementation Plan The Texas Commission on Enviro ental Quality (commission) will conduct public hearings to rece e testimony regarding proposed revisions to 30 TAC Chapter 10 , General Air Quality Rules, and 30 TAC Chapter 115,Control of ir Pollutionfrom Volatile Otganic Compounds and corresponding re isions to the state implementation plan (SIP) under the requiremen of TexasHealth and Safety Code, §382.0l7; Texas Government C ,Chapter 2001, Subchapter B; and 40 Code of Federal Regulati ns §51.l02, and the United States Environmental Protection Agen (EPA) concerning SIPs. Additionally, the commission will receive testimony regarding the



### INADDITION October 9, 

### 2009 34 

### TexReg 7133Bryan W. Shaw, Ph.D., Chairman Buddy Garcia, Commissioner Carlos Rubinstein, Commissioner Mark R. Vickery, P.G. Executive Director 

# TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas by Reducing andPreventing Pollution NOTICE OF PUBLIC HEARINGS BY THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY ON PROPOSED REvISIONS TO 30 TAC CHAPTERS 101 AND 115, AND TO THE STATE IMPLEMENTATION PLAN
The Texas Commission on Environmental Quality (commission) will conduct public hearings to receive testimony regarding proposed revisions to 30 TAC Chapter 101, 

### General Air Quality Rules, and 30 TAC Chapter 115, Control of Air Pollution from Volatile Organic Compounds and corresponding revisions to the state implementation plan (SIP) under the requirements of Texas Health and Safety Code, §382.017; Texas Government Code, Chapter 2001, Subchapter B; and 40 Code 

### of Federal Regulations §Sl.102, 

### and the United States Environmental Protection Agency (EPA) concerning SIPs. 

### Additionally, the commission will also receive testimony regarding the 

### proposed eight-hour ozone attainment demonstration and reasonable 

### further progress (RFP) demonstration for the Houston-Galveston-Brazoria (HGB) area.
The proposed amendment to Chapter 101, Subchapter 

### H, Division 3, Mass Emissions Cap and Trade (MEeT) Program, would revise the definition of "Uncon1rolled design capacity" to provide additional flexibility for certain stationary diesel engines and clarify both site and facility applicability. 

### In addition, the proposed amendment would 

### maintain the integrity of the 

### nitrogen oxides (NOx) cap in the HGB ozone nonattainment area and minimize increases 

### in the NOx cap by discontinuing the acceptance of late ECT-3 forms, Level of Activity Certification, from major sources of 

## NOx submitted 

### after March 30, 2010. (Rule Project No. 2009-019-101-EN)
The proposed amendment to Chapter 101, Subchapter 

### H, Division 6, Highly-Reactive Volatile Organic Compound Emissions Cap and Trade 

### Program, would reduce the total cap amount of allowances and revise the allocation methodology of allowances for participants in 

### the Highly-Reactive Volatile Organic .Compound (HRVOC) Emissions Cap and Trade Program. A 

### proposed amendment to §101.1 would also update the definition of volatile organic compound (VOC) to link the 30 TAC definition with the current definitiort in 40 Code of Federal Regulations and correct the reportable quantity for 1,1,1,2,3,3,3- heptafluoropropane. (Rule Project No. 2009-006-101-EN)
The proposed amendments to Chapter 115, Subchapter E, Division 4, Offset Lithographic Printing, would reduce the VOC content limits on fountain solutions used by sources that are subject to the existing Chapter 115 rules. The proposed rulemaking would also limit the VOC content of fountain and cleaning solutions used by certain sources that are exempt from the existing Chapter 115 rules. (Rule Project No.**2008-019-11S-E~** The proposed HGB Attainment Demonstration SIP revision contains Federal Clean Air Act-required SIP elements, including a photochemical modeling analysis, a weight of evidence analysis, a reasonable available control technology (RAeT) analysis, a reasonably available control measures (RACM) analysis, a motor vehicle emissions budget (MVEB) for 2018, and a contingency plan. 

### In addition, the HoustonGalveston Area Council has conmritted to emissions reductions through the Voluntary Mobile Emission Reduction Program and implementation of transportation control measures. The proposed revision also describes the concurrently proposed rule revisions 

### in Chapters 101 and 115. The conmrission is also

Dn**D~v** 1-:l0117soliciting comments on whether it is appropriate to perform a 1997 eight-hour ozone standard mid-course review analysis, and, if so, what elements should be contained in the analysis. The commission is also seeking input on the appropriate date to submit the mid-course review. 

### (Rule Project No. 2009-017-SIPNR)

. The proposed HGB Eight-Hour Ozone Nonattainment Area RFP SIP revision demonstrates that the 18 percent ozone precursor emissions reduction requirement will be met for the analysis 

### period of 2002 to 2008,9 percent between 2009 and 2011, 9 percent between 2012 and 2014,9 percent between 2015 and 2017, 3 percent in 2018, and 3 percent for contingency purposes. This revision also includes a revised MVEB for the milestone years 2008, 2011, 2014, 2017, and 2018. No new on-road mobile source controls have 

### been adopted as part of the plan. However, on-road mobile source emissions inventories have been updated using the latest available data and the EPA's MOBILE6 inventory development tool. As a result of the required mobile source emission inventory updates, the MVEBs are updated as part of 

### this SIP revision. 

### (Rule 

### Project No. 2009-018-SIP-NR)
Public hearings on these proposals will be held at the following times and locations: October 28, 2009, 2:00 p.m. and 6:00 p.m., 

### in Conference Room A at 

### the Houston-Galveston Area Council, 3555 Timmons Lane, Houston; and 

### in Austin on 

### October 29, 2009, 3:00 p.m., at the Texas Commission on Environmental Quality complex, Building E, Room 201S, 12100 Park 35 Circle. 

### The hearings will be structured for the receipt of oral or 

### written connnents by interested persons. Registration 

### will begin 30 minutes prior to 

### each hearing. Individuals may present 

### oral statements when called upon 

### in 

### order of registration. There will be no open discussion during 

### the hearing; however, commission staff members will be available to discuss the proposals 30 minutes before each hearing and will answer questions before and after the hearing.
Persons planning to attend 

### the hearing, who have special communication or other accommodation needs, should contact Charlotte Hom, Texas Register Team (512) 239-0779. Requests should be 

### made 

## as far in advance 

### as possible.
Comments may be submitted to Jessica Rawlings, Texas Register Team, Office of Legal Services, Texas Commission on 

### Environmental Quality, MC 205, P.O. Box 13087, Austin, Texas 78711-3087, or faxed to (512) 239-4808. Electronic comments may be submitted at www5.tceq.state.tx.us/ruIes/ecomments/. File 

### size restrictions may apply to comments being submitted via 

### the eComments system. All 

### comments should reference the rule or SIP project Dumber that the comment pertains to: Rule Project No. 2009-019-101-EN for the proposed MECT rule amendments, Rule Project No. 2009-006-101-EN for the proposed HRVOC rule amendments, Rule Project No. 2008-019-11S-EN for the 

### proposed VOC rule amendments, SIP Project No. 2009-017-SIP-NR for the proposed BGB Attainment Demonstration SIP revision and SIP Project No. 2009-018-SIP-NR for the proposed BGB RFP SIP revision. Comments must be received by 

### November 9, 2009. Copies of the proposed rules can be obtained from the commission's Web site at http://www.tceq.state.tx.us/nav/ndes/propose_adopt.html. Copies of the 

### proposed SIP revisions and all appendices can be obtained from the commission's Web site at http://www.tceq.state.tx.us/implementation/air/siplHottop.html.Forfi.n1:her information regarding the proposed rules and SIP revisions, please contact Ray Schubert, Air Quality Planning Section, at (512) 239-6615.
Issued in Austin, Texas, on September 

### 23, 2009.ES-1 REVISION TO THE STATE IMPLEMENTATION PLAN

FOR THE CONTROL OF OZONE AIR POLLUTION

HOUSTON-GALVESTON-BRAZORIA 1997 EI GHT-HOUR OZONE STANDARD NONATTAINMENT AREA

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

Houston-Galveston-Brazoria Reasonable Further Progress State Implementation Plan Revision fo r the1997 Eight-Hour Ozone Standard

PROJECT NO. 2009-018-SIP-NR

Proposed September 23, 2009HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

ES-1 EXECUTIVE SUMMARY The 1990 Federal Clean Air Act Amendments (F CAA), §182, require ozone nonattainment areas with air quality classified as moderate or higher to submit plans showing reasonable further progress (RFP) toward attainment of the ozone National Ambient Air Quality Standard (NAAQS). The Houston-Galveston-Brazoria (HGB ) area is classified as a severe nonattainment area for the 1997 eight-hour ozone standard, with an attainment date of June 15, 2019. This state implementation plan (SIP) revision is not required or intended to demonstrate attainment of the ozone NAAQS but rather to demonstrate that ozone precursor emissions will be reduced in accordance with the guidelines set forth in th e second phase of the United States Environmental Protection Agency’s (EPA) 1997 Eight-Hour Ozon e Implementation Rule (40 Code of Federal Regulations §51.910). This SIP revision demonstrates that the RFP emis sions reduction requirement will be met for the six-year period (2003-2008) beginning January 1 of the year following the year used for the baseline emissions inventory (2002) and all remain ing three-year periods after the first six-year period (2009-2011, 2012-2014, and 2015-2017) out to the area's attainment date (2019). Target year inventories include the latest information available to estimate emissions growth. Target levels for the attainment year (2018) also account for RFP corrections and non-creditable reductions. All of the RFP inventories ar e based upon an ozone season weekday analysis. The RFP methodology involves development of the base year and milestone year inventories, emissions reductions for each milestone year, and an estimate of the effects of non-creditable reductions and pre-1990 FCAA rules. Through this methodology, the reduction amount is determined. Once these values have been calculate d, the milestone targetlevels and emissions inventories can be compared to determine if the forecasted controlled emissions inventories are less than the target level. The results, whic h demonstrate that the HGB area meets the FCAA RFP requirements for each of the milestone years, are displayed in Table 3-3: Calculation of Required 3 Percent Per Year NO X

and VOC Reductions

. This SIP revision also sets the nitrogen oxides (NO X ) and volatile organic compounds (VOC) motor vehicle emissions budgets (MVEB) for transportation conformity purposes for the milestone years 2008, 2011, 2014, 2017, and 2018. An MVEB is the on-road mobile source allocation of the total allowable emissions for each applicable criteria pollutant or precursor, as defined in the SIP. Transportation conformity determinations must be performed using the budget test once the EPA determines the budget adequate for transportation conformity purposes. To pass the budget test, areas must demonstrate th at the estimated emissions from transportation plans, programs, and projects do not exceed the MVEB for the established year. Because the HGB area has been reclassified as a severe nonattainment area for the 1997 eighthour ozone NAAQS, the RFP milestone years adopted in the previous (May 23, 2007) HGB RFP SIP revision have been revised to reflect the area’s extended attainment date. Chapter 5: MOTOR VEHICLE EMISSIONS BUDGETS documents the development of the revised RFP MVEB for each of these milestone years for the eight-county HGB ozone nonattainment area.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

i SECTION V: LEGAL AUTHORITY A. General The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, maintain, and enforce the National Ambient Air Quality Standard s (NAAQS) and to control the quality of the state’s air, including maintaining adequate visibility. The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas Legislature in 1965. In 1967, the Clean Air Act of Te xas was superseded by a more comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon’s Texas Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, and 2009. In 1989, the TCAA was c odified as Chapter 382 of the Texas Health & Safety Code. Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution control agency and is principal authority in the state on matters relating to the quality of air resources. In 1991, the legislature abolished the TACB effective September 1, 1993, and its powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air quality is found in both the Te xas Water Code and the TCAA. Specifically, the authority of the TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the general provisions, organization, and general powers and duties of the TNRCC, and the responsibilities and authority of the executive director. This chapter also authorizes the TNRCC to implement action when emergency conditions arise, and to conduct hearings. Chapter 7 gives the TNRCC enforcement authority. In 2001, the 77 thTexas Legislature continued the existence of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the TCEQ. In 2009, the 81 stTexas Legislature, during a special session, amended § 5.014 of the Tex as Water Code, changing the expiration date of the TCEQ to September 1, 2011, unless continued in existence by the Texas Sunset Act. The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in the state’s air and to control the quality of the state’s air by preparing and developing a general, comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect information to enable the commission to develop an inventory of emissions; to conduct researc h and investigations; to enter property and examine records; to prescribe monitoring requirements; to institu te enforcement proceedings; to enter into contracts and execute instruments; to formulate rules; to issu e orders taking into consideration factors bearing upon health, welfare, social and economic factors, and practicability and reasonableness; to conduct hearings; to establish air quality control regions; to encourage cooperation with citizens’ groups and other agencies and political subdivisions of the state as well as with industries and the federal government; and to establish and operate a system of permits for construction or modification of facilities. Local government authority is found in Subchapter E of the TCAA. Local governments have the same power as the TCEQ to enter property and make inspec tions. They also may make recommendations to the commission concerning any action of the TCEQ that affects their territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements with the TCEQ or other local governments. In addition, a city or town may enact and enforce ordinances for the control and abatement of air pollution not inconsistent with the provisions of the TC AA and the rules or orders of the commission.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

ii Subchapters G and H of the TCAA authorize the TCEQto establish vehicle inspection and maintenance programs in certain areas of the state, consistent with the requirements of the Federal Clean Air Act; coordinate with federal, state, and local trans portation planning agencies to develop and implement transportation programs and measures necessary to attain and maintain the NAAQS; establish gasoline volatility and low emission diesel standards; and fund and authorize participating counties to implement vehicle repair assistance, retrofit, and accelerated vehicle retirement programs. B. Applicable Law The following statutes and rules provide necessary authority to adopt and implement the State Implementation Plan (SIP). The rules listed below have previously been submitted as part of the SIP.
Statutes TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2009 TEXAS WATER CODE September 1, 2009 All sections of each subchapter are included, unless otherwise noted. Chapter 5: Texas Natural Resource Conservation Commission Subchapter A: General Provisions Subchapter B: Organization of the Tex as Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties of the Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§ 5.225, 5.226, 5.227, 5.2275, 5.231, 5.232, and 5.236) Subchapter H: Delegation of Hearings Subchapter I: Judicial Review Subchapter J: Consolidated Permit Processing Subchapter L: Emergency and Temporary Orders (§§ 5.514, 5.5145 and 5.515 only) Subchapter M: Environmental Permitting Procedures (§ 5.558 only) Chapter 7: Enforcement Subchapter A: General Provisions (§§ 7.001, 7.002, 7.00251, 7.0025, 7.004, 7.005 only) Subchapter B: Corrective Action and Injunctive Relief (§ 7.032 only) Subchapter C: Administrative Penalties Subchapter D: Civil Penalties (except § 7.109) Subchapter E Criminal Offenses and Penalties: §§ 7.177, 7.179-7.183 Rules All of the following rules are found in Title 30 Texas Administrative Code, as of the following effective dates: Chapter 7, Memoranda of Understandi ng, §§ 7.110 and 7.119 May 2, 2002 Chapter 19, Electronic Reporting March 1, 2007 Chapter 35, Subchapters A-C, K: Emergency and Temporary July 20, 2006 Orders and Permits; Temporary Suspension or Amendment of Permit Conditions Chapter 39, Public Notice, §§ 39.201; 39.401; 39.403(a) and March 29, 2006HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

iii (b)(8)-(10); 39.405(f)(1) and (g);39.409; 39.411 (a), (b)(1)-(6) and (8)-(10) and (c)(1)-(6) and (d); 39.413(9), (11), (12) and (14); 39.418(a) and (b)(3) and (4); 39.419(a), (b),(d) and (e); 39.420(a), (b) and (c)(3) and (4); 39.423 (a) and (b); 39.601; 39.602; 39.603; 39.604; and 39.605

Chapter 55: Requests for Reconsideration and Contested Case Hearings; March 29, 2006 Public Comment, §§ 55.1; 55.21(a) - (d), (e)(2), (3), and (12), (f) and (g); 55.101(a), (b), and (c)(6) - (8); 55.103; 55.150; 55.152(a)(1), (2), and (6) and (b); 55.154; 55.156; 55.200; 55.201(a) - (h); 55.203; 55.205; 55.209, and 55.211 March 29, 2006 Chapter 101: General Air Quality Rules January 1, 2009 Chapter 106: Permits by Rule, Subchapter A June 30, 2004 Chapter 111: Control of Air Pollution from Visible Emissions July 19, 2006 and Particulate Matter Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 Chapter 113: Standards of Performance for Hazardous Air Po llutants May 14, 2009 and for Designated Facilities and Pollutants Chapter 114: Control of Air Pollution from Motor Vehicles June 26, 2008 Chapter 115: Control of Air Pollution from Volatile Organic Compounds July 19, 2007 Chapter 116: Permits for New Construction or Modification May 29, 2008 Chapter 117: Control of Air Pollution from Nitrogen Compounds March 4, 2009 Chapter 118: Control of Air Pollution Episodes March 5, 2000 Chapter 122, § 122.122: Potential to Emit December 11, 2002 Chapter 122, § 122.215: Minor Permit Revisions June 3, 2001 Chapter 122, § 122.216: Applications fo r Minor Permit Revisions June 3, 2001 Chapter 122, § 122.217: Procedures for Minor Permit Revisions December 11, 2002 Chapter 122, § 122.218: Minor Permit Revision Procedures for Permit Revisions Involving the Use of Economic Incentives, Marketable Permits, and Emissions Trading June 3, 2001HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

iv 

### SECTION VI. CONTROL STRATEGY

A. Introduction (No change) B. Ozone (Revised)
1. Dallas-Fort Worth(No change) 2. Houston-Galveston-Brazoria Reasonable Further Progress(Revised) Chapter 1: General Chapter 2: Emissions Inventories Chapter 3: Target Emissions Levels and RFP Demonstration Chapter 4: Control Measures to Achieve Target Emissions Levels Chapter 5: Motor Vehicle Emissions Budgets 3. Beaumont-Port Arthur (No change) 4. El Paso (No change) 5. Regional Strategies(No change) 6. Northeast Texas (No change) 7. Austin Area (No change) 8. San Antonio Area (No change) C. Particulate Matter (No change) D. Carbon Monoxide (No change) E. Lead (No change) F. Oxides of Nitrogen (No change) G. Sulfur Dioxide (No change) H. Conformity with the National Ambient Air Quality Standards (No change) I. Site Specific (No change) J. Mobile Sources Strategies (No change) K. Clean Air Interstate Rule (No change) L. Transport (No change) M. Regional Haze (No change)HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

v LIST OF ACRONYMS

ABY -- Adjusted Base Year APU -- Auxiliary Power Units ATP -- Anti-Tampering Programs DERC -- Discrete Emissions Reduction Credits DFW -- Dallas-Fort Worth DV -- Design Value EBT -- Emissions Banking and Trading EDMS -- Emissions and Dispersion Model System EDMS -- Environmental Data Management System EGAS -- Economic Growth Analysis System EGUs -- Electric Generating Units EI -- Emissions Inventory EIQ -- Emissions Inventory Questionnaires EPA -- United States Environmental Protection Agency ERC -- Emission Reduction Credits ERG -- Eastern Research Group, Inc. ESAD -- Emission Specifications for Attainment Demonstration FAA -- Federal Aviation Administration FCAA -- 1990 Federal Clean Air Act Amendments FMVCP -- Federal Motor Vehicle Control Program GSE -- Ground Support Equipment HAS -- Houston Airport System HDDV -- Heavy-Duty Diesel Vehicles HECT -- Highly Reactive Volatile Organic Compounds Emissions Cap and Trade Program HGB -- Houston-Galveston-Brazoria H-GAC -- Houston-Galveston Area Council HRVOC -- Highly Reactive Volatile Organic Compounds I/M -- Inspection and Maintenance MECT -- Mass Emissions Cap and Trade Program MSY -- Milestone Year MVEB -- Motor Vehicle Emissions Budgets NAAQS -- National Ambient Air Quality Standards NLEV -- National Low Emission Vehicle NO X-- Nitrogen Oxides PFC -- Portable Fuel Container PN -- Percent of NO X PV -- Percent of VOC REMI -- Regional Economic Modeling, Inc. RFG -- Reformulated GasolineHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

vi RFP -- Reasonable Further Progress ROP -- Rate of Progress RVP -- Reid Vapor Pressure SI -- Spark Ignition SIC -- Standard Industrial Classification SIP -- State Implementation Plan STARS -- State of Texas Air Reporting System TAC -- Texas Administrative Code TAF -- Terminal Area Forecast TCAA -- Texas Clean Air Act TCEQ -- Texas Commission on Environmental Quality TDM -- Travel Demand Models TexAER -- Texas Air Emissions Repository TexAQS 2000 -- Texas Air Quality Study 2000 TexN -- Texas NONROAD Model TIPI -- Texas Industrial Production Index TNRCC -- Texas Natural Resource Conservation Commission tpd -- Tons Per Day TxLED -- Texas Low Emission Diesel USC -- United States Code VMT -- Vehicle Miles Traveled VOC -- Volatile Organic CompoundsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

vii TABLE OF CONTENTS Executive Summary Legal Authority List of Acronyms Table of Contents List of Appendices List of Tables Chapter 1 General 1.1. Houston-Galveston-Brazoria Area Reasonable Further Progress Background 1.2. Reasonable Further Progress Requirements 1.3. Public Hearing and Comment Information 1.4. Social and Economic Considerations 1.5. Fiscal and Manpower Resources Chapter 2 Emissions Inventories 2.1 Introduction 2.1.1 Updated Uncontrolled Milestone Year Inventories 2.1.2 Updated Controlled Milestone Year Inventories 2.2 Point Sources 2.2.1 Emissions Inventories Development 2.2.2 Updated 2002 Base Year Inventories 2.2.3 Updated Uncontrolled Milestone Year Inventories 2.2.4 Updated Controlled Milestone Year Inventories 2.3 Area Sources 2.3.1 Emissions Inventories Development 2.3.2 Updated 2002 Base Year Inventories 2.3.3 Updated Uncontrolled Milestone Year Inventories 2.3.4 Updated Controlled Milestone Year Inventories 2.4 Non-Road Mobile Sources 2.4.1 Emissions Inventories Development 2.4.1.1 NONROAD Model Source Categories Emissions Estimation Methodology 2.4.1.2 Airport Emissions Estimation Methodology 2.4.1.3 Locomotive Emissions Estimation Methodology 2.4.1.4 Commercial Marine Emissions Estimation Methodology 2.4.1.5 Drilling Rig Diesel Engines Emissions Estimation Methodology 2.4.2 Updated 2002 Base Year Inventories 2.4.3 Updated Uncontrolled Milestone Year Inventories 2.4.4 Updated Controlled Milestone Year Inventories 2.5 On-Road Mobile Sources 2.5.1 Emissions Inventories Development 2.5.2 Updated 2002 Base Year Inventories 2.5.3 Updated 2002 Adjusted Base Year Inventories for the Base and Milestone Years 2.5.4 Updated Uncontrolled Milest one Year Emissions Inventories 2.5.5 Updated Controlled Milestone Year Emissions InventoriesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

viii 2.6 Biogenic Sources 2.7 Emissions Summary Chapter 3 Target Emissions Levels and Reasonable Further Progress Demonstration 3.1 Introduction 3.2 Target Level Methodology 3.3 Calculation of Target Emissions Levels 3.4 Growth 3.5 RFP Demonstration Chapter 4 Control Measures to Achieve Target Emissions Levels 4.1 Overview of Control Measures 4.2 Point Source Controls 4.3 Area-Source Controls 4.4 Non-Road Mobile Source Controls 4.4.1 NONROAD Model Categories 4.4.2 Non-Road Categories not in the NONROAD Model 4.5 On-Road Mobile Source Controls 4.6 Contingency Measures Chapter 5 Motor Vehicle Emissions Budgets 5.1 Introduction 5.2 Overview of Methodologies and Assumptions 5.2 Motor Vehicle Emissions Budgets for RFP Milestone Years AppendicesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

ix LIST OF APPENDICES AppendixAppendix Name Appendix 1 HGB Reasonable Further Progress Demonstration Calculations Spreadsheet Appendix 2 Development of Reasonable Further Progress Point Source Inventories Appendix 3 Development of Reasonable Further Progress Area Source Inventories Appendix 4 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Source Categories in the EPA’s NONROAD 2005 Model Appendix 5 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Airports Appendix 6 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Locomotives Appendix 7 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Commercial Marine Vessels Appendix 8 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Drilling Rigs Appendix 9 Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road M obile Source Emissions InventoriesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

x LIST OF TABLES NumberTable Name Table 2-1 HGB Eight-County RFP Point Source NO XEmissions Table 2-2 HGB Eight-County RFP Point Source VOC Emissions Table 2-3 HGB Eight-County RFP Area Source NO XEmissions Table 2-4 HGB Eight-County RFP Area Source VOC Emissions Table 2-5 HGB Eight-County RFP Non-Road Mobile Source NO XEmissions Table 2-6 HGB Eight-County RFP Non-Road Mobile Source VOC Emissions Table 2-7 HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VMT Table 2-8 HGB Eight-County RFP Ozone S eason Weekday On-Road Mobile Source NO XEmissions Table 2-9 HGB Eight-County RFP Ozone Season W eekday On-Road Mobile Source VOC Emissions Table 2-10 Summary of HGB Non-Creditable Reductions, Ozone Season Weekday On-Road Mobile Source VMT, and Adjusted Base Year Inventories Table 2-11 HGB RFP Ozone Season Weekday On-Road Mobile Source NO XEmissions and Control Strategy Reductions Table 2-12 HGB RFP Ozone Season Weekday On-R oad Mobile Source VOC Emissions and Control Strategy Reductions Table 2-13 HGB Eight-County RFP Uncontrolled Ozone Season Weekday NO XEmissions Table 2-14 HGB Eight-County RFP Uncontro lled Ozone Season Weekday VOC Emissions Table 2-15 HGB Eight-County RFP C ontrolled Ozone Season Weekday NO XEmissions Table 2-16 HGB Eight-County RFP Controlle d Ozone Season Weekday VOC Emissions Table 3-1 Step by Step Summary of Calc ulation of 2008 Target Levels for HGB Table 3-2 Summary of Non-Creditable Fleet Turnover Reduction Table 3-3 Calculation of Required 3 Percent Per Year NO Xand VOC Reductions Table 3-4 RFP Post-2002 Target Level of NO XEmissions Table 3-5 RFP Post 2002 Target Level of VOC Emissions Table 3-6 Summary of RFP Demonstration for Eight HGB Counties for 2008 Table 3-7 Summary of RFP Demonstration for Eight HGB Counties for 2011 Table 3-8 Summary of RFP Demonstration for Eight HGB Counties for 2014 Table 3-9 Summary of RFP Demonstration for Eight HGB Counties for 2017 Table 3-10 Summary of RFP Demonstration for Eight HGB Counties for 2018 Table 4-1 Summary of HGB RFP NO XEmission Reductions Table 4-2 Summary of HGB RFP VOC Emission Reductions Table 4-3 Control Programs Modeled in MOBILE6 Emissions Factors for the Base and Milestone Years Table 4-4 2009 RFP Contingency Demonstration for HGB Area Table 4-5 2019 RFP Contingency Demonstration for HGB Area Table 5-1 2008 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-2 2011 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-3 2014 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-4 2017 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-5 2018 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment AreaHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

1-1 CHAPTER 1: GENERAL
1.1 HOUSTON-GALVESTON-BRAZORIA AREA REASONABLE FURTHER PROGRESS BACKGROUND On April 30, 2004, nonattainmen t area designations were published as part of the first phase of the EPA’s implementation rule for the 1997 eigh t-hour ozone standard (69 FR 23936). This notice defined the Houston-Galveston-Brazori a (HGB) nonattainment area as Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties. Based on the area’s 1997 eight-hour ozone design value (DV), the area was classified as moderate nonattainment. As part of the first phase of the United States Environmental Protection Agency’s (EPA) implementation rule for the 1997 eight-hour ozone standard (69 FR 23951), the Texas Commission on Environmental Quality (TCEQ) was required to submit an attainment demonstration state implementation plan (SIP) revision for a moderate nonattainment area to the EPA by June 15, 2007. In addition to an attain ment demonstration, a reasonable further progress (RFP) SIP revision that demonstrated a 15 percent reduction in anthropogenic ozone precursors, nitrogen oxides (NO X ) and volatile organic compounds (VOC ), between 2002 and 2008 was also required to be submitted by the June 15, 2007, deadline. On May 23, 2007, the commission adopted the required RFP SIP revision, which was submitted to the EPA on June 13, 2007. On June 15, 2007, the TCEQ submitted a le tter from the Governor of Texas to the EPA requesting that the HGB area be reclassified fro m a moderate to a severe nonattainment area for the 1997 eight-hour ozone standard. The EPA gr anted the governor’s request on September 18, 2008. The effective date of this reclassificati on was October 31, 2008. As a result of the reclassification, the EPA set April 15, 2010, as th e deadline for the state to submit a SIP revision for the HGB area that addresses the severe oz one nonattainment area requirements, including RFP. The HGB area’s new attainment date fo r the 1997 ozone standard is as expeditiously as practicable, but no later than June 15, 2019. “The History of the Texas State Implementation Plan (SIP),” a comprehensive overview of the SIP revisions submitted to the EPA by the State of Texas is available at the following Web site: http://www.tceq.state.tx.us/implementation/air/sip/sipintro.html#History

. 1.2 REASONABLE FURTHER PROGRESS REQUIREMENTS The 1990 Federal Clean Air Act Amendments (FCAA), 42 United States Code (USC) §7410, require states to submit SIP revisions that cont ain enforceable measures to achieve the National Ambient Air Quality Standards (NAAQS). Th e FCAA also requires states with nonattainment areas classified as moderate or above to submit plans showing reasonable further progress toward attainment of the ozone standard . This RFP SIP revision is neith er required for, nor intended to, demonstrate attainment of the ozone NAAQS but rather to demonstrate that ozone precursor emissions will be reduced by 18 percent between 2002 and 2008, 9 percent between 2009 and 2011, 9 percent between 2012 and 2014, 9 percent between 2015 and 2017, 3 percent in 2018, and 3 percent in 2019 for contingency purposes. In addition to the RFP analyses, this SIP revi sion provides updated RFP on-road mobile vehicle emissions budgets (MVEB) and updated 2002 emissions inventories for point, area, on-road mobile, and non-road mobile sources. This SIP revision also includes existing contingency measure requirements to be implemented if the area fails to achieve the RFP milestones.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

1-2 A summary of how this plan meets RFP requirements can be found in Appendix 1: HGB Reasonable Further Progress Demonstration Calculations Spreadsheet

. 1.3 PUBLIC HEARING AND COMMENT INFORMATION The commission will hold public hearings at the times and locations listed below.

CITY DATE TIME LOCATION Houston October 28, 2009 2:00 P.M. Houston-Galveston Area Council 3555 Timmons Lane Houston, TX 77027 Conference Room A Houston October 28, 2009 6:00 P.M. Houston-Galveston Area Council 3555 Timmons Lane Houston, TX 77027 Conference Room A Austin October 29, 2009 3:00 P.M. TCEQ 12100 Park 35 Circle Austin, TX 78753 Building E, Room 201S

The public comment period will open on October 9, 2009, and close on November 9, 2009. Written comments will be accepted via mail, fax, or through the eComments system. All comments should reference the “Houston-Galveston-Brazoria Reasonable Further Progress State Implementation Plan Revision for the 1997 Eight -Hour Ozone Standard” and Project Number 2009-018-SIP-NR. Comments may be submittedto Walker Williamson, MC 206, State Implementation Plan Team, Chief Engineer’s Office, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-30 87 or faxed to (512) 239-5687. Electronic comments may be submitted at http://www5.tceq.state.tx.us/rules/ecomments . File size restrictions may apply to comments being submitted via the eComments system. Comments must be received by November 9, 2009.

1.4 SOCIAL AND ECONOMIC CONSIDERATIONS Because no new control strategies are associated w ith this SIP revision, there are no changes that would require an analysis of so cial and economic considerations.
1.5 FISCAL AND MANPOWER RESOURCES The state has determined that its fiscal and manpower resources are adequate and will not be adversely affected through the implementation of this plan.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-1 CHAPTER 2: EMISSIONS INVENTORIES 2.1 INTRODUCTION The 1990 Federal Clean Air Act Amendments (FC AA) require that reasonable further progress (RFP) emissions inventories (EI) be prepared for ozone nonattainment areas. Ozone is photochemically produced in the atmosphere wh en volatile organic compounds (VOC) are mixed with nitrogen oxides (NO X ) in the presence of sunlight. The Texas Commission on Environmental Quality (TCEQ) maintains an EI of up-to-date information on NO X and VOC sources. The EI identifies the types of emissions sources present in an area, the amount of each pollutant emitted, and the types of processes and control devices employed at each plant or source category. The inventory provides data for a vari ety of air quality planning tasks, including establishing baseline emission levels, calculating reduction targets, developing control strategies to achieve the emissions reductions, developing emission inputs for air quality models, and tracking actual emission reductions against establis hed emissions growth and control budgets. The total inventory of VOC and NO Xemissions for an area is summarized from the estimates developed for the five general categories of emission sources: point, area, non-road mobile, onroad mobile, and biogenic. Since the previous Houston-Galveston-Brazoria (HGB) RFP SIP revision was submitted to the United States Environmental Protection Agency(EPA) in 2007 for a moderate nonattainment area, the HGB area was reclassifi ed as a severe nonattainment area for the 1997 eight-hour ozone NAAQS on October 31, 2008. States are required by §172(e) of the FCAA to demonstrate an average of 3 percent annual reductions of VOC and/or NO Xemissions the first six years after the baseline year (2002) and every subsequent three year period, out to a severe area’s attainment date. In accordance with this requirement, this SIP revision includes anthropogenic EI from the 2002 base year as well as projected anthropogenic EI for the milestone years 2008, 2011, 2014, 2017, and 2018 to provide a basis for demonstrating how the required emissions reductions will be met. 2.1.1 Updated Uncontrolled Milestone Year Inventories The uncontrolled milestone year EIs represent the inventory for the milestone year if no further action to control emissions is taken beyond the controls already accounted for in the 2002 base year inventory. Inventories are first calcul ated for each source category using EPA-approved methodologies and then combined to obtain the total uncontrolled milestone year inventory for VOC and NO X . The uncontrolled milestone inventories include pre-2002 FCAA controls and growth in activity from 2002 to the milestone years, but do not include post-2002 FCAA controls. 2.1.2 Updated Controlled Milestone Year Inventories The controlled milestone year EIs represent the i nventory for the milestone year with growth from the 2002 base year and with all RFP controls taken into account. Inventories are first calculated for each major source category using EPA-approved methodologies and then combined to obtain the total controlled milestone year inventories for VOC and NO X . The controlled milestone year inventories include pre-2002 FCAA controls, growth in activity from 1990 to the milestone year, and post-2002 FCAA controls used to meet the RFP target emissions level, but it does not include post-2002 FCAA controls that are not used to meet the RFP target emissions level. 2.2 POINT SOURCES 2.2.1 Emissions Inventory Development Stationary point source emissions data are collected annually from sites that meet the reporting requirements of 30 Texas Administrative Code (T AC) §101.10. To collect the data, the TCEQHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-2 mails emissions inventory questionnaires (EIQ) to all sites identified as meeting the reporting requirements. Companies are required to report emissions data and to provide samples of calculations used to determine the emissions. Information characterizing the process equipment, the abatement units, and the emission points is alsorequired. All data submitted in the EIQ are reviewed for quality assurance purposes and then st ored in the State of Texas Air Reporting System (STARS) database. 2.2.2 Updated 2002 Base Year Inventory The 2002 base year inventory data were extrac ted from STARS on February 4, 2009. The extracted data contained ozone season daily emissions of NO Xand VOC from each site in the HGB area that submitted an EIQ for 2002 and reflec ted revisions made on or before the extract date. County-level reported VOC emissions were adjusted to account for unreported VOC emissions discovered in the Texas Air Quality Study 2000 (TexAQS 2000). 2.2.3 Updated Uncontrolled Milestone Year Inventories The uncontrolled milestone year inventories were developed from the 2002 inventory was projected using the following approaches: applying projection factors to 2002 emissions, refining the VOC emission estimates to reflect unreported emissions, and adding emissions credits. First, emissions were projected by applying growth factors to the 2002 actual emissions. The Economic Growth Analysis System (EGAS) 5.0 w as used to derive growth factors from the following data sets: the Regional Economic Modeli ng, Inc., (REMI) 5.5 factor set at the countywide level for Texas; the REMI 6.0 factor set at the state-wide level; and the Moody’s Economy, Inc., factor set at the county-wide level for Te xas. Growth factors were compared to actual growth in emissions from 2002 to 2005 for each contaminant and each industrial category at the county level, and the factors that most closely co rresponded to historical growth were selected. County-level reported VOC emis sions were then revised to account for unreported VOC emissions discovered in the TexAQS 2000. Based on TexAQS 2000 measurements ambient VOC concentrations in the Houston Ship Channel were determined to be several times greater than the estimates reported in the TCEQ’s emissions inventories. Finally, the inventories were adjusted to account for emissions credits. Emissions credits are emissions reductions that may to return to the ai r shed in the future. To account for the possible use of these banked NO Xand VOC emissions, unused emissi ons reduction credits (ERCs) and discrete emissions reduction credits (DERCs) as of October 2008, were applied to the inventory. 2.2.4 Updated Controlled Milestone Year Inventories The controlled milestone year inventories were developed from the 2005 inventory using the following approaches: applying projection factors to 2005 emissions, applying Emissions Banking and Trading program allocations, applying rules that limi t emissions from tank landings, refining VOC emission estimates to reflect unrepor ted emissions, and addingemissions credits. The 2005 inventory was designated as the baseline y ear for controlled projections because it was the most recent National Emissions Inventory year available. The 2005 inventory was extracted from STARS on February 4, 2009. The extr acted data were reported ozone season daily emissions of NO Xand VOC from each site in the HGB area that submitted a 2005 EIQ and reflected revisions made on or before the extract date. Industrial source NO Xcontrols are reflected in the Mass Emissions Cap and Trade program (MECT) 2008 NO Xcap. The MECT NO Xemissions allocations account for NO Xcontrols, including controls applied to electric generati ng units (EGUs) and large stationary engines asHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-3 defined by 30 TAC Chapter 117, Subchapters C: Combustion Control at Major Utility Electric Generation Sources in Ozone Nonattainment Areas and D: Combustion Control at Minor Sources in Ozone Nonattainment Areas . The controlled milestone year NO Xinventories were developed by applying projection factors to base line year emissions and then applying the unitspecific allocations from the MECT for regulated so urces. Emissions were then added to account for unused NO Xemissions credits. The VOC controls are reflected in the highly reactive volatile organic compounds emissions cap and trade program (HECT) and 30 TAC Chapter 115 changes that limit tank landings. The HECT cap is an annual cap on sitewide highly reactive volatile organic compounds (HRVOC) emissions from equipment that are subject to the HRVOC control requirements of 30 TAC Chapter 115, Subchapter H, Division 1: Vent Gas Controlor Division 2: Cooling Tower Heat Exchange Systemsfor applicable sites listed in the cap . Other 30 TAC Chapter 115 changes limit convenience landings unless an abatement device is used to control the VOC emissions or landing loss emissions are authorized under an emission limit or cap in a permit issued under 30 TAC Chapter 116. The controlled milestone year VOC inventories were developed by applying projection factors to baseline year emissions and then applying the HECT allocations to HRVOC emissions from applicable units at regulated s ites. Reductions were then applied for 30 TAC Chapter 115, Subchapter B, Division 1: Storage of Volatile Organic Compounds . County-level VOC emissions were then adjusted to account fo r unused credits and unreported VOC emissions determined from ambient monitoring data. A summary of the point source RFP inventories is presented in Table 2-1: HGB Eight-County RFP Point Source NOX Emissions and Table 2-2: HGB Eight-County RFP Point Source VOC Emissions. Table 2-1: HGB Eight-County RFP Point Source NO XEmissions NO X (tons per day) RFP Analysis Year Uncontrolled Controlled 2002 339.29 339.29 2008 375.56 155.73 2011 383.85 156.21 2014 401.05 157.17 2017 421.57 158.33 2018 428.69 158.75

Table 2-2: HGB Eight-County RFP Point Source VOC Emissions VOC (tons per day) RFP Analysis Year Uncontrolled Controlled 2002 316.62 316.62 2008 333.14 170.05 2011 338.75 164.33 2014 347.70 172.31 2017 358.79 181.86 2018 362.90 185.38

For more details on the point source projection method, please refer to Appendix 2: Development of Reasonable Further Progress Point Source Inventories.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-4 2.3 AREA SOURCES 2.3.1 Emissions Inventory Development Area sources are commercial, small-scale industrial, and residential sources that use materials or perform processes that generate emissions. Area sources are too small to meet the emissions reporting criteria for major point sources, so emissions are calculated as county-wide totals rather than as individual facilities. Area sources can be divided into two groups characterized by the emission mechanism: hydrocarbon evaporative emissions and fuel combustion emissions. Examples of evaporative sources include printi ng operations, industrial coatings, degreasing solvents, house paints, leaking underground stor age tanks, gasoline service station underground tank filling, and vehicle refue ling operations. Fuel combustion sources include oil and gas production sources, stationary source fossil fuel combustion at residences and businesses, outdoor refuse burning, structural fires, and wildfires. With some exceptions, these emissions may be calculated by multiplying an established emission factor (emissions per unit of activity) by the appropriate activity or activity surrogate responsib le for generating emissions. Population is the most commonly used activity surrogate for many area sources. Other activity data include the amount of gasoline sold in an area, employment by industry type, and acres of cropland. 2.3.2 Updated 2002 Base Year Inventory The 2002 base year EI was developed in 2003. Because the TCEQ was required to submit this inventory to the United States Environmental Protection Agency (EPA) as the Periodic Emissions Inventory, considerable effort went into its de velopment. Since that time, there have been additional updates to the 2002 area source EI. Improvements resulted from bottom-up surveys for some categories, such as gasoline stations. Su rveys produce data that more accurately depict facility activity levels than do top-down methodol ogies that usually rely on default surrogates such as county populations and numbers of empl oyees associated with appropriate EPA emission factors. Activity data for other categories were available from various sources. The Energy Information Administration maintains state level fueluse data for the residential, industrial, and commercial sectors for fuels ranging from coal to natu ral gas. This data is useful in calculating emissions from home cooking, water heating, and similar use at the i ndustrial and commercial levels. Actual oil and gas production data are available from the Railroad Commission of Texas, which were used in these updated 2002 inventories. State and local governments also provided data on asphalt usage in road paving projects. The EPA’s Emissions Inventory Improvement Program produced approved methodologies for several area source categories. The latest version of the EPA’s growth factor system, EGAS 5.0, was used to grow emissions from the 1999 area source emissions inventory for some sources. 2.3.3 Updated Uncontrolled Milestone Year Inventories For most area source categories, the 2002 base year EI was projected to 2008, 2011, 2014, 2017, and 2018 using improved growth factors. A contract or project developed a complete set of updated EGAS growth factors usi ng REMI and other economic data. 1 For a few categories, census populations were used to project the future emissions. 2.3.4 Updated Controlled Milestone Year Inventories The controlled 2008, 2011, 2014, 2017, and 2018 inve ntories were developed by first projecting the 2002 base year inventory to specific years and th en applying controls. The only rule affecting area sources in the HGB area that came into effect after 2002 is the federal portable fuel container

1 Eastern Research Group, Inc., “Development of County Level Growth Factors from 1990 through 2020,” TCEQ Contract No. 582-04-65564, Work Order No. 65564-05-18, August 2005.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-5 (PFC) rule (72 FR 8428, publis hed February 26, 2007). Controlled emissions based on the federal PFC rule do not take e ffect until 2010, so there were no emissions reductions from the federal rule in the 2008 inventories (i.e., no emis sions reductions credits were taken in 2008 for PFC). Many rules concerning industrial coati ngs and gasoline station underground tank filling (Stage I) and vehicle refueling (Stage II) were accounted for in the base year numbers. A summary of the area source RFP inventories is presented in Table 2-3: HGB Eight-County RFP Area Source NOX Emissions, and Table 2-4: HGB Eight-County RFP Area Source VOC Emissions . Please note that there is no difference between the uncontrolled and controlled NO X emissions for the base and all milestone years and the VOC emissions for the base year and 2008 because there were no controls applied to the projected area source inventories. Table 2-3: HGB Eight-County RFP Area Source NO XEmissions NO X (tons per day) RFP Analysis Year Uncontrolled Controlled 2002 89.11 89.11 2008 89.63 89.63 2011 93.90 93.90 2014 96.01 96.01 2017 98.23 98.23 2018 99.38 99.38

Table 2-4: HGB Eight-County RFP Area Source VOC Emissions VOC (tons per day) RFP Analysis Year Uncontrolled Controlled 2002 407.61 407.61 2008 371.82 371.82 2011 382.72 379.04 2014 393.07 383.42 2017 404.84 394.74 2018 408.82 398.57

For more details on the area source projection method, please refer to Appendix 3: Development of Reasonable Further Prog ress Area Source Inventories. 2.4 NON-ROAD MOBILE SOURCES 2.4.1 Emissions Inventory Development Non-road sources include vehicles, engines, and equipment used for construction, agriculture, transportation, recreation, and many other purposes. Non-road vehicles are also referred to as "off-road" or "off-highway" vehicles since they do not normally operate on roads or highways. This broad category is comprised of a diverse co llection of machines, many of which are powered by diesel engines. Non-road emissions sources include, but are not limited to: agricultural equipment; commercial and industrial equipment; construction and mining equipment; lawn and garden equipment; aircraft and airport equipment; locomotives; and commercial marine vessels and equipment.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-6 A Texas specific version of the EPA’s NONROAD 2005 model, called the Texas NONROAD (TexN) model, was used to calculate emissions from all non-road mobile equipment and recreational vehicles except aircraft, locomotives, commercial marine, and oilfield drilling rigs. The TexN model does not include commercial marine vessel, locomotive, or airport emissions. Emissions for these three source categories are estimated using other EPA methods and guidance documents. However, support equipment for ai rcraft, locomotive, and commercial marine operations and facilities are included in the NO NROAD model. Although oilfield drilling rigs are included in the NONROAD model, emissions fro m this category were developed separately to provide more accurate inventories. 2For this reason, equipment populations for oilfield drilling rigs were set to zero in the TexN model. 2.4.1.1 TexN Model Source Categories Emissions Estimation Methodology Emissions for all non-road mobile categories except aircraft, locomotives, and commercial marine vessels were calculated using the TexN model. Modeling emissions from the non-road sector is especially challenging because of difficu lties in determining in-use population, activity, load, and emission rates. Although, operating the EPA’s model with all of the default surrogates is acceptable, the EPA en courages states to update the model with local, county-level data based on surveys and other relevant information. In order to facilitate the development of non-road emissions inventories with locality specific input s, TexN was developed to estimate emissions from all sources included in the EPA’s NONROAD model for Texas. The TexN model is a software tool for developing emissions estimates for non-road mobile sources in Texas using county specific activity data. The model allows air quality planners to replace EPA’s default data with local bottom-up data. Local, county-level data is incorporated into the TexN model as it becomes available to the TCEQ. Several emis sion inventory studies have been conducted in Texas in recent years to improve upon the default data available in the EPA’s NONROAD 2005 model. These studies have focused on various equipment categories operating in different areas of the state, including diesel construction equipments, liquid propane gas powered forklifts, transportation refrigeration units, commercial lawn and garden, and recreational marine vessels. A detailed listing of the non-road equipment studies and surveys conducted in Texas and documentation of procedures used in developing the non-road RFP emissions inventories can be found in Appendix 4: Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Source Categories in the EPA’s NONROAD 2005 Model

. 2.4.1.2 Airport Emissions Estimation Methodology Emissions from airport activities in the HGB area were estimated for Ellington Field, George Bush Intercontinental Airport, and William P. H obby Airport. Emissions were calculated using the Federal Aviation Administration (FAA) Emissions and Dispersion Modeling System (EDMS), version 5.1. The airport emissions categ ories considered for this RFP analysis were aircraft (commercial air carriers, air taxis, general aviation, and military), auxiliary power units (APU), and ground support equipment (GSE) operati ons. The 2005 through 2018 aircraft, APU, and GSE (George Bush Intercontinental and Hobb y Airports) emissions were obtained from the Houston Airport System (HAS) emissions inventory, which was submitted to the TCEQ on January 9, 2009, by Jacobs Consultancy. GSE emissions from Continental Airlines was prepared by Landrum and Brown, Inc., and submitted to the TCEQ, January 21, 2009, and GSE emissions from Southwest Airlines were prepared using EDMS version 5.02. Since there were no emissions inventory data available for 2008, the 2008 emissi ons were estimated using an interpolation method between the years 2005 and 2011. The documentation of procedures used in developing

2Eastern Research Group, Inc., “Emissions from Oil and Gas Production Facilities,” TCEQ Contract No. 582-07-84003-01, August 31, 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-7 the airport emissions inventories can be found in Appendix 5: Development of RFP Non-Road Mobile Source Emissions Inventories for Airports

. 2.4.1.3 Locomotive Emissions Estimation Methodology Emissions for locomotive activities were obtained from the Texas Air Emissions Repository (TexAER) database. Controlled estimated emissions for calendar years 20 08, 2011, 20 14, 2017, and 2018 were determined from data extrapolated from the Tier-Specific Locomotive Engine Update , August 31, 2007, conduc ted for the TCEQ by Eastern Research Group, Inc., (ERG) and contained in TexAER. The study was developed toascertain emissions activity in the Dallas-Fort Worth area, the Houston-Galveston-Brazoria area, and Texas. The growth rate was developed using reports from railway companies and regulatory controls data. Uncontrolled estimated emissions for calendar years 2008, 2011, 2014, 2017, and 2018 were developed and extrapolated using emissions trends data from the 1997 EPA Technical Highlights document. 3 In this document, Tier I and II emission standards for manufactured and remanufactured diesel-powered locomotives and locomotive engines were established. The documentation of procedures used in developing the locomotive emissions inventories can be found in Appendix 6: Development of RFP Non-Road Mobile Source Emissions Inventories for Locomotives

. 2.4.1.4 Commercial Marine Emissions Estimation Methodology Commercial marine activities were obtained from the 2000 and 2007 emissions projections provided to TCEQ via contract with Starcrest and ERG. 4, 5 Emission growth factors provided by ERG were considered in obtaining 2008, 2011, 2014, 2017, and 2018 emission estimates. 6The documentation of procedures used in developing the commercial marine emissions inventories emissions inventories can be found in Appendix 7: Development of RFP Non-Road Mobile Source Emissions Inventories fo r Commercial Marine Vessels

. 2.4.1.5 Drilling Rigs Diesel Engines Emissions Estimation Methodology Oilfield drilling rig diesel engines are included in the NONROAD model category “Other Oilfield Equipment” which includes various types of equipment. Due to the significant growth in the oil and gas exploration and production industry, the emissions inventory for diesel drilling rigs was included in a contract with ERG. 7 Emission trends were developed using oil and gas production data trends for 2008, 2011, 2014, 2017, and 2018 emission estimates. The documentation of procedures used in developing the drilling rig emissions inventories can be found in Appendix 8: Development of RFP Non-Road Mobile Source Emissions Inventories for Drilling Rigs

.

3 United States Environmental Protection Ag ency, “Emission Factors for Locomotives,” Technical Highlights , EPA-420-F-97-051, December 1997. 4Starcrest Consulting Group, LLC, “2007 Goods Movement Air Emissions Inventory at the Port of Houston,” provided by the Port of Houston Authority, January 2009. 5 Eastern Research Group, Inc., “Development of Emission Estimates for Offshore Non-road Mobile Sources in Texas State Waters,” TCEQ Contract No. 582-04-65564, Work Order No. 65564-05-13, August 31, 2005. 6 ERG, “Commercial Marine Vessel, Locomotive, and Aircraft Growth Factors,” TCEQ Contract No. 582- 07-84003-02, August 31, 2007. 7 ERG, “Emissions from Oil and Gas Production Facilities,” TCEQ Contract No. 582-07-84003-01, August 31, 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-8 2.4.2 Updated 2002 Base Year Inventory Since the 2002 base year EI was originally de veloped in 2003, input data in the NONROAD model were updated using the results of several contracted projects. Since the TexN model incorporated all of the recently updated i nput data, revised 2002 non-road EI for the NONROAD model categories were developed using the TexN model. The 2002 aircraft and GSE as well as locomotive emissions were obtained from the Te xAER database. The 2002 base year EI for commercial marine vessels was obtained from th e 2000 and 2007 emissions projections provided to TCEQ via contract with Starcrest and ERG (see footnotes 4 and 5). The 2002 base year EI for drilling rigs was developed from data provided by ERG (see footnote 7). 2.4.3 Updated Uncontrolled Milestone Year Inventories The uncontrolled emissions per analysis year (2002, 2008, 2011, 2014, 2017, and 2018) were calculated by adding the controlled emissions for that year with the sum of all of the individual controls used to demonstrate RFP for thatyear. The locomotive uncontrolled emission inventories were obtained from the EPA’s D ecember 1997 Emission Factors for Locomotives document. Emissions for commercial marine vessels were developed from two surveys of vessel types and activities in the Port of Houston and surrounding ports. The Railroad Commission of Texas provided actual annual oil and gas produc tion data for each county, from which diesel drilling rig emissions trends were developed. 2.4.4 Updated Controlled Milestone Year Inventories The effects of federal and state control programs were evaluated. The TexN model was executed for ozone season daily emission for years 2002, 20 08, 2011, 2014, 2017, 2018, and 2019. To evaluate individual control measure emission redu ctions for the RFP requirements, a series of TexN model runs were executed for both contro lled and uncontrolled scenarios for each federal and state control program. Airport emissions were projected for future years 2008, 2011, 2014, 2017, and 2018 using the growth factors from the Terminal Area Forecast (TAF) summary for fiscal year 2008 – 2025. 8 Locomotive controlled emission estimates were developed from the TexAER data extrapolated from data obtained through a contract conducted for the TCEQ by ERG and contained in TexAER. 9 The growth rate was devel oped using reports from railway companies and regulatory controls data. The controlled emission inventories for commercial marine vessels were developed from two surveys of vessel types and activities in the Port of Houston and surrounding ports (see footnotes 4 and 5). Based on 2002 data from the Railroad Commission of Texas, diesel-drilling rig emissions trends were devel oped for 2008, 2011, 2014, 2017, and 2018. No controlled emissi ons reductions apply to drilling rigs. Summaries of all the non-road mobile source RFP inventories are presented in Table 2-5: HGB Eight-County RFP Non-Road Mobile Source NOX Emissions and Table 2-6: HGB Eight-County RFP Non-Road Mobile Source VOC Emissions . Because there are no controls applied to airport and drilling rigs, these columns display only uncontrolled emissions.

8 United States Department of Tran sportation, Federal Aviation Admini stration, “Terminal Area Forecast Summary, Fiscal Years 2008-2025,” FAA-APO-06-1, January 2009. 9Eastern Research Group, Inc., “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07- 84003-04, August 31, 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-9 Table 2-5: HGB Eight-County RFP Non-Road Mobile Source NO XEmissions (Tons/Day)
NONROAD Model Categories Locomotive Commercial Marine Airport Drilling Rig RFP Analysis

Year Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled 2002 88.63 79.01 34.58 34.58 28.01 27.63 6.35 9.41 2008 105.39 65.80 49.6 37.86 30.97 29.01 9.90 6.86 2011 111.18 54.97 49.17 36.42 32.45 29.22 10.43 6.79 2014 117.09 43.88 51.19 37.10 33.93 29.20 11.53 6.74 2017 124.33 35.94 52.42 37.18 35.41 29.20 12.12 6.71 2018 128.14 33.68 54.23 38.19 35.90 29.00 12.32 6.69

Table 2-6: HGB Eight-County RFP Non-Road Mobile Source VOC Emissions (Tons/Day)
NONROAD Model Categories Locomotive Commercial Marine Airport Drilling Rig RFP Analysis

Year Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled 2002 96.70 79.05 2.28 2.28 1.08 1.06 1.68 0.25 2008 109.00 63.01 2.56 2.29 1.20 1.12 2.62 0.18 2011 115.34 57.76 2.59 2.25 1.25 1.13 2.71 0.18 2014 121.33 55.02 2.71 2.28 1.31 1.13 2.81 0.18 2017 126.24 53.78 2.85 2.32 1.37 1.13 2.64 0.18 2018 129.34 53.58 2.94 2.35 1.39 1.13 2.60 0.18

2.5 ON-ROAD MOBILE SOURCES 2.5.1 Emissions Inventory Development On-road mobile emissions sources consist of automobiles, trucks, motorcycles, and other motor vehicles traveling on public roadways. On-road mobile source emissions are usually categorized as either combustion-related emissions or evaporative hydrocarbon emissions. Combustionrelated emissions are estimated for vehicle engi ne exhaust. Evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources on the vehicle. To calculate emissions, both the rate of emissions per unit of activity (emission factors) and the number of units of activity must be determined. Emission factors are developed using EPA's mob ile emission factor model MOBILE. The model may be run using national defau lt information or input may be provided to modify the model calculations to simulate the driving behavior, meteorological conditions, and vehicle characteristics specific to the HGB area. Because inputs influence the emission factors calculated by the MOBILE model, every effort is made to input parameters reflecting local conditions,HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-10 rather than national default values. The locali zed inputs used for the HGB RFP on-road mobile EI development include vehicle speeds for each ro adway link, temperature, humidity, vehicle age distributions for each vehicle type, percentage of miles traveled for each vehicle type, type of inspection-maintenance program, fuel control programs, and gasoline vapor pressure controls. To estimate on-road mobile emissions, emission factors calculated by the MOBILE model described above must be multiplied by the level of vehicle activity. On-road mobile source emission factors are expressed in units of grams per mile. Therefore, the activity information that is required to complete the inventory calculation is vehicle miles traveled (VMT) in units of miles per day. The level of vehicle travel activity is developed using travel demand models (TDM) run by the Texas Department of Transportation or the local metropolitan planning organizations. TDM are validated against a large number of ground counts, i.e., traffic passing over counters placed in various locations throughout a county or area. VMT estimates are often calibrated against outputs from the federal Highway Perform ance Monitoring System, a federal model built from a different set of traffic counters. In addition to the number of miles traveled on each roadway link, the speedon each roadway type or segment is also needed to complete an on-road emissions inventory. Roadway speeds, required inputs for the MOBILE model, are calcu lated by using the ac tivity volumes from the TDM and a post-processor speed model. In order to perform the RFP calculations, a state must determine the base inventory from which the calculations begin, the amount of reductions achieved from controls that were implemented prior to the FCAA and therefore not creditable toward FCAA RFP requirements, the uncontrolled milestone year inventory, and the emission reduction controls to demonstrate that RFP is met for each milestone year. To determine all of the in formation required for RFP calculations, a set of on-road mobile source inventories and control measure reduction estimates are required to complete the RFP calculations.

• The 2002 base year is the starting point for the 1997 eight-hour ozone RFP demonstration. This starting point establishes the inventory as it existed in 2002, the RFP base year established by the EPA for areas designated as nonattainment for the 1997 eight-hour ozone standard.

• The adjusted base year (ABY) inventories are the basis for calculating the percentreductions, as required in the RFP guidance, and as a basis for determining the noncreditable reductions due to control programs implemented prior to the FCAA. 10 Because the ABY inventory adjusts the 2002 base year inventory for the fleet turnover effects of the pre-1990 Federal Motor Vehicle Control Program (FMVCP) and the 1992 Reid Vapor Pressure (RVP) control, only th e emission rates are different than the 2002 base year. Speed and VMT activity leve ls for both the 2002 base year and ABY inventories are consistent with both the TDM output for the 2002 roadway network and demographic demands.

• An on-road mobile ABY inventory is required for each milestone year and for any year for which a percent reduction requirement cal culation must be completed. The ABY inventory is used to determine the level of non-creditable reductions for each RFP milestone year.

10United States Environmental Protection Agency, “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard; Final Rule,” Federal Register (70 FR 71631), November 29, 2005.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-11 • The RFP analysis also requires an uncontro lled inventory with growth between the base year and the milestone year. These uncontrolled inventories serve as the basis for determining how much emissions reduction is required to meet the RFP target.

• The RFP analysis requires the calculation of a controlled inventory to subtract from the uncontrolled inventory to determine the effectiveness of control strategies. RFP requires direct calculation of the emission reductions from control strategies that are then subtracted from the uncontrolled emissions to determine the controlled inventory value. Both the total from on-road mobile control strategies and the emission reductions from each individual control strategy are calculated. A summary of the on-road mobile source vehicle miles traveled used to develop the various NO X and VOC emissions levels in subsequent tables is presented in Table 2-7: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VMT , Table 2-8: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source NOX Emissions , and Table 2-9: HGB EightCounty RFP Ozone Season Weekday On -Road Mobile Source VOC Emissions . For complete documentation of the development of the on-roadmobile source inventories for the HGB RFP demonstration, refer to Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories . The complete set of input and output files are available upon request from the TCEQ’s Air Quality Division. Table 2-7: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VMT Inventory Scenario (vehicle miles traveled per day) RFP Analysis

Year Adjusted Base Year Uncontrolled Controlled 2002 135,716,461 135,716,461 135,716,461 2008 135,716,461 146,039,120 146,039,120 2011 135,716,461 154,332,688 154,332,688 2014 135,716,461 168,390,202 168,390,202 2017 135,716,461 180,067,224 180,067,224 2018 135,716,461 184,010,300 184,010,300HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-12 Table 2-8: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source NO X Emissions Inventory Scenario (tons per day) RFP Analysis

Year Adjusted Base Year Uncontrolled Controlled 2002 387.09 387.09 326.72 2008 346.01 363.05 175.80 2011 335.20 372.46 123.41 2014 334.08 407.05 86.61 2017 333.24 432.04 61.78 2018 333.17 443.70 55.39

Table 2-9: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VOC Emissions Inventory Scenario (tons per day) RFP Analysis

Year Adjusted Base Year Uncontrolled Controlled 2002 189.08 189.08 132.64 2008 185.46 194.89 86.15 2011 184.23 205.03 68.35 2014 183.60 222.41 56.21 2017 183.50 237.86 48.39 2018 183.46 242.84 46.68HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-13 2.5.2 Updated 2002 Base Year Inventory The 2002 base year EI for on-road mobile source s was updated using emission factors calculated using the latest version of the MOBILE model, MOBILE6.2.03. Additional updates were made to incorporate the latest activity estimates from the HGB travel demand model 2002 network. Only control strategies implemented prior to 20 02 were included in the input to the inventory development for the 2002 on-road mobile source baseyear inventory. These controls include: pre-1990 FMVCP, fleet turnover to Tier 1 FMVCP, reformulated gasoline, and the HGB vehicle inspection and maintenance (I/M) program. The acti vity levels used to calculate the inventory reflect the 2002 roadway network with 2002 VMT and speeds. A summary of the inventory is presented in Table 2-10: Summary of HGB Non-Creditable Reductions, Ozone Season Weekday On-Road Mobile Source VMT, and Emissions . For complete documentation of the development of the inventory and details on MOBILE model inputs, refer to Appendix 9: Houston-GalvestonBrazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories. 2.5.3 Updated 2002 Adjusted Base Year Inve ntories for the Base and Milestone Years The RFP planning process includes calculating the adjusted base year EI, from which required percent emission reductions are calculated. As specified by the FCAA, certain on-road mobile source emissions reductions are not creditable to ward these required percentage reductions. The non-creditable reductions include reductions from c ontrols that were promulgated prior to the 1990 FCAA. The two rules that are non-creditable for this HGB 1997 eight-hour ozone RFP SIP revision are pre-1990 FMVCP and pre-1990 promul gated federal fuel volatility regulations (summertime gasoline RVP limits beginning in 1992 ). Because the defeat device for heavy-duty diesel vehicles (HDDV) was affecting a FMVCP that was implemented prior to the 1990 FCAA, the HDDV NO Xoff-cycle emissions effects and associated mitigation program effects are also considered non-creditable. For this HGB RFP demonstration, pre-1990 non-creditable emission reductions include pre-1990 FCAA FMVCP, 1992 summertime RVP limits, and HDDV NO Xoffcycle emissions and mitigation programs. An adjusted base year EI for on-road mobile s ources is developed for each milestone year using emissions factors from the MOBILE model, whic h reflect only control strategies implemented prior to 1990. By projecting the pre-1990 FMVCP into future years, the effects of additional fleet turnover benefit due to the new standards is refl ected in the emission factors. The controls included in the ABY inventory development include pre-1990 FCAA FMVCP and the 1992 summertime RVP control. The activity levels usedto calculate the ABY inventories reflect the 2002 roadway network with 2002 VMT and speeds. The estimated non-creditable emissions reductions due to pre-1990 controls are calculated by subtracting the 2002 ABY inventory, relative to the target year, from the actual 2002 base year inventory. A summary of the inventories and associated non-creditable emissions reductions is presented in Table 2-10: Summary of HGB Non-Creditable Reductions, Ozone Season Weekday On-Road Mobile Source VMT, and Adjusted Base Year Inventories . Creditable controls are discussed are discussed in Section 2.5.5: Updated Controlled Milestone Year Emissions Inventories . For complete documentation of the development of the inventory and details on MOBILE model inputs, refer to Appendix 9: Houston-Galveston-Brazoria 1997 Eight -Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-14 Table 2-10: Summary of HGB Non-Creditable Reductions, Ozone Season Weekday On-Road Mobile Source VMT, and Adjusted Base Year Inventories Inventories Non-Creditable Emissions Reductions Calendar Year VMT NO X VOC NO X VOC 2002 Base Year 135,716, 461 326.72 132.64 N/A N/A 2002 Adjusted Base Year (ABY) 135,716,461 387.09 189.08 N/A N/A 2008 ABY 135,716,461 346.01 185.46 41.08 3.62 2011 ABY 135,716,461 335.20 184.23 10.81 1.23 2014 ABY 135,716,461 334.08 183.60 1.12 0.63 2017 ABY 135,716,461 333.24 183.50 0.84 0.10 2018 ABY 135,716,461 333.17 183.46 0.07 0.04 Note: VMT is presented in miles per day and NO Xand VOC emissions are presented in tons per day. 2.5.4 Updated Uncontrolled Milestone Year Emissions Inventories The uncontrolled on-road mobile emissions inventories for each RFP milestone year were developed using emission factors that reflect only control strategies implemented prior to 2002. The latest version of MOBILE, MOBILE6.2.03, was used to develop the inventories for this SIP revision. The activity levels were updated to include the latest output from the HGB transportation demand model. These controls include Pre-1990 FMVCP, the 1992 RVP control, fleet turnover to Tier 1 FMVCP, reformulated gasoline, and the HGB vehicle I/M program. The activity levels used to calculate the inventory reflect the milestone roadway network, with milestone year VMT and speeds. A summary of the inventories is presented in Tables 2-8: HGB Eight-County RFP Ozone Season We ekday On-Road Mobile Source NOX Emissionsand 2-9: HGB Eight-County RFP Ozone Season Week day On-Road Mobile Source VOC Emissions . For complete documentation of the development of the inventory and details on MOBILE model inputs, refer to Appendix 9: Houston-Galveston-Brazoria1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories. 2.5.5 Updated Controlled Milestone Year Emissions Inventories The controlled on-road mobile emissions i nventories for each RFP milestone year were developed using emission factors that reflect bot h control strategies implemented prior to 2002 and the control strategies used to demonstrate co mpliance with RFP requirements. These controls include pre-1990 FMVCP, fleet turnover to Tier 1 of the FMVCP, fleet turnover to Tier 2 of the FMVCP, the 2007 heavy-duty diesel FMVCP standards, summer reformulated gasoline, the HGB vehicle I/M program, the anti-tampering program , and Texas Low Emission Diesel (TxLED). control scenario inventory values include both the controlled inventory and the level of reductions for each control strategy. A summary of the uncontrolled on-road mobile inventory, the individual on-road mobile control reductions, and the resulting controlled on-road mobile inventory for each milestone year are summarized in Table 2-11 : HGB RFP Ozone Season Weekday On-Road Mobile Source NOX Emissions and Control Strategy Reductions and Table 2- 12: HGB RFP Ozone Season Weekday On-Road M obile Source VOC Emissions and Control Strategy Reductions

.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-15 Table 2-11: HGB RFP Ozone Season Weekday On-Road Mobile Source NO XEmissions and Control Strategy Reductions NO X( tons per day) Emissions Inventory and Control Strategy Description 2008 2011 2014 2017 2018 Uncontrolled (see Table 2- 8) 363.05 372.46 407.05 432.04 443.70 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 68.11 62.24 56.88 49.05 49.28 Federal Reformulated Gasoline (RFG) 46.75 72.94 104.41 128.94 135.65 I/M in Harris County 13.65 16.07 20.82 25.11 26.48 National Low Emission Vehicle Program (NLEV) 9.12 9.31 6.16 3.42 2.66 Expanded I/M 7.06 5.12 10.15 8.63 9.16 Tier 2 FMVCP 24.98 51.95 53.79 91.98 96.36 2007 Heavy-Duty Diesel FMVCP 8.70 28.22 66.13 61.69 67.54 On-road TxLED 8.87 3.21 2.11 1.45 1.19 Controlled 175.80 123.41 86.61 61.78 55.39

Table 2-12: HGB RFP Ozone Season Weekday On-Road Mobile Source VOC Emissions and Control Strategy Reductions VOC ( tons per day) Emissions Inventory and Control Strategy Description 2008 2011 2014 2017 2018 Uncontrolled (see Table 2- 9) 194.89 205.03 222.41 237.86 242.84 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 45.57 63.02 79.36 91.17 94.52 Federal Reformulated Gasoline (RFG) 34.24 34.51 37.17 39.99 40.97 I/M in Harris County 10.42 11.35 12.43 13.49 13.90 National Low Emission Vehicle Program (NLEV) 5.33 4.81 3.27 1.97 1.59 Expanded I/M 3.09 3.30 4.44 4.32 4.50 Tier 2 FMVCP 9.91 19.19 16.87 37.20 39.39 2007 Heavy-Duty Diesel FMVCP 0.15 0.45 12.53 1.00 1.08 On-road TxLED 0.04 0.06 0.12 0.33 0.21 Controlled 86.15 68.35 56.21 48.39 46.68

The MVEB calculations for each milestone year are documented in Chapter 5: MOTOR VEHICLE EMISSIONS BUDGETS

.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-16 The activity levels used to calculate the inventory reflect the milestone roadway network, with milestone year VMT and speeds. A summary of the inventories is presented in Table 2-8: HGB Eight-County RFP Ozone Season, W eekday On-Road Mobile Source NOX Emissionsand Table 2- 9 : HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VOC Emissions

. For complete documentation of the development of the inventory and de tails on MOBILE model inputs, refer to Appendix 9: Houston-Galveston-Brazoria1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories. 2.6 BIOGENIC SOURCES Biogenic sources include hydrocarbon emissions from crops, lawn grass, and trees as well as a small amount of NO Xemissions from soils. Plants are sources of VOC such as isoprene, monoterpene, and alpha-pinene. The tool for es timating biogenic emissions is the EPA Biogenic Emissions Inventory System. The biogenic emi ssions are important in determining the overall emissions profile of an area and therefore are required for regional air quality modeling and to meet periodic EPA reporting requirements. Si nce the 2002 base year EI is based upon the inventory developed to meet EPAperiodic reporting requirements, the 2002 base year EI includes biogenic emissions. The RFP methodology does not include biogenic emissions. Therefore, the first step in the RFP methodology subtracts the biogenic emissions from the 2002 base year EI. The resulting 2002 total anthropogenic EI is called the 2002 RFP base year EI. The calculation of the 2002 HGB RFP base year EI is documented in Sheet 16 of Appendix 1: HGB RFP Demonstration Calculations Spreadsheet

. Since the RFP methodology excludes biogenic emissions, biogenic RFP EI are not developed for RFP milestone years. 2.7 EMISSIONS SUMMARY Uncontrolled base and milestone year NO Xand VOC emissions in the HGB area for each RFP source category are summarized in Tables 2-13: HGB Eight-County RFP Uncontrolled Ozone Season Weekday NOX Emissionsand 2-15: HGB Eight-County RFP Uncontrolled Ozone Season Weekday VOC Emissions . Controlled base and milestone year NO Xand VOC emissions in the HGB area for each RFP source category are summarized in Tables 2-14: HGB Eight-County RFP Controlled Ozone Season Weekday NO X

Emissionsand 2-16: HGB Eight-County RFP Controlled Ozone Season Weekday VOC Emissions . Please note that there is no difference between the uncontrolled and controlled area source NO Xemissions for the base and all milestone years and the VOC emissions for the base year and 2008 because there were no controls applied to the projected area source inventories.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-17 Table 2-13: HGB Eight-County RFP Uncontrolled Ozone Season Weekday NO XEmissions

Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total

2002 339.29 89.11 166.98 387.09 982.47 2008 375.56 89.63 202.72 363.05 1030.96 2011 383.85 93.90 210.01 372.46 1060.22 2014 401.05 96.01 220.48 407.05 1124.59 2017 421.57 98.23 230.99 432.04 1182.82 2018 428.69 99.38 237.25 443.70 1209.02

Table 2-14: HGB Eight-County RFP Controlled Ozone Season Weekday NO XEmissions

Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total

2002 339.29 89.11 156.98 326.72 912.10 2008 155.73 89.63 149.44 175.80 570.60 2011 156.21 93.90 138.83 123.41 512.35 2014 157.17 96.01 128.45 86.61 468.25 2017 158.33 98.23 121.15 61.78 439.49 2018 158.75 99.38 119.88 55.39 433.40HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-18 Table 2-15: HGB Eight-County RFP Uncontrolled Ozone Season Weekday VOC Emissions

Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total

2002 316.62 407.61 100.15 189.08 1013.46 2008 333.14 371.82 113.68 194.89 1013.53 2011 338.75 382.72 120.10 205.03 1046.60 2014 347.70 393.07 126.28 222.41 1089.46 2017 358.79 404.84 132.38 237.86 1133.87 2018 362.90 408.82 134.29 242.84 1148.85

Table 2-16: HGB Eight-County RFP Contro lled Ozone Season Weekday VOC Emissions

Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total

2002 316.62 407.61 84.32 132.64 941.19 2008 170.05 371.82 69.23 86.15 697.24 2011 164.33 379.04 64.03 68.35 675.75 2014 172.31 383.42 61.42 56.21 673.35 2017 181.86 394.74 60.05 48.39 685.05 2018 185.38 398.57 59.84 46.68 690.47HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-1 CHAPTER 3: TARGET EMISSIONS LEVELS AND REASONABLE FURTHER PROGRESS DEMONSTRATION 3.1 INTRODUCTION This chapter describes how the elements of the Houston-Galveston-Brazoria (HGB) 2018 reasonable further progress (RFP) demonstration are calculated, documents the RFP calculations, and provides a summary of the HGB RFP demonstration for all RFP milestone years. The RFP guidance requires an average 3 percent reducti on between the RFP base year and an area’s attainment year. The United States Environmental Protection Agency (EPA) guidance requires demonstration of RFP six years from the base year and then every third year after that year until the attainment year. With an RFP base year of 2002 and an attainment date in 2019, the HGB RFP analysis has five RFP milestone years, 2008, 2011, 2014, 2017, and 2018. The RFP milestone year requirements for HGB are:

• an 18 percent emission reduction for the six year period between the 2002 base year and the first RFP milestone year 2008;

• a 9 percent emission reduction for each three year period ending in 2011, 2014, and 2017; and

• a 3 percent emission reduction for the one year period from 2017 to the attainment year, 2018. Compliance with the 2008, 2011, 2014, 2017, and 2018 milestone emission reduction requirements are demonstrated using EPA methodol ogies first to calculate the elements of the RFP demonstration and then to use these elements to complete the RFP analyses. First the inventories, control reductions, and non-creditable emission reductions are developed for each milestone year. Second, the target level of emissions for each milestone year is calculated. Third, the RFP control reductions for each mil estone year are subtracted from the uncontrolled milestone year emissions inventory (EI) that includes growth between 2002 and each milestone year. When the uncontrolled projected inventory for each milestone year, minus the RFP controls, is less than the target level of emis sions for volatile organic compounds (VOC) and/or nitrogen oxides (NO X ), the RFP requirement has been met. The required RFP elements are:

• 2002 base year emissions;

• non-creditable reductions for 2008, 2011, 2014, 2017, and 2018;

• 2008, 2011, 2014, 2017, and 2018 target levels of emissions;

• 2008, 2011, 2014, 2017, and 2018 projected emissions with growth; and

• individually quantified control strategy emissions reductions for 2008, 2011, 2014, 2017, and 2018.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-2 3.2 TARGET LEVEL METHODOLOGY EPA guidance specifies the method states should use to calculate the maximum amount of emissions a nonattainment area can emit for each RFP milestone year. These RFP target levels of emissions are calculated with a six-step process. The following six step process was used for the HGB RFP state implementation plan (SIP) revision for the 1997 eight-hour ozone standard.
1. Develop the 2002 base year inventory. 2. Develop the 2002 RFP base year inventory. 3. Develop the adjusted base year inventories for 2002, 2008, 2011, 2014, 2017, and 2018. 4. Calculate the non-creditable fleet turnover correction for each RFP milestone year. 5. Calculate the required 3 percent per year emission reduction amount. 6. Calculate the 2008, 2011, 2014, 2017, and 201 8 target levels of emissions for VOC and NO X . 3.3 CALCULATION OF TARGET EMISSIONS LEVELS A step by step summary of the six-step process described above for targetcalculations for 2008, which serves as an example of how all target levels for each milestone year is calculated, is presented in Tables 3-1: Step by Step Summary of Calculation of 2008 Target Levels for HGB. A summary of all target levels can be found in Tables 3-4: RFP Post-2002 Target Level of NOX Emissions and 3-5: RFP Post-2002 Target Level of VOC Emissions

. Table 3-1: Step by Step Summary of Calculation of 2008 Target Levels for HGB tons per day Description NO X VOC c Step 1: 2002 Base Year Inventory (see Tables 2-14 and 2-16) 912.10 941.19 d Step 2: Add or subtract emissions that are to be added from outside the nonattainment area 0.00 0.00 e 2002 RFP Base Year Inventory ( see Tables 2-14 and 2-16) 912.10 941.19 f Step 3: 2002 On-road Adjusted Base Year Inventory (see Table 2-10) 387.09 189.08 g 2008 On-road Adjusted Base Year Inventory (see Table 2-10) 346.01 185.46 h Step 4: Calculate Non-creditable reductions (see Table 2-10) 41.08 3.62 i Step 5: 2008 Adjusted Base Year Inventory 871.02 937.57 j Percent of NO x(PN) and VOC (PV) to meet 18% Reduction Requirement PN + PV = 18 17 1 k Calculate the 2002 to 2008 18% Reduction Requirement ( i x j ) 148.07 9.38 l Step 6: Calculate the Target Level of Emissions ( e minus h minus k ) 722.94 928.19

Step one of the RFP target calculation is devel opment of the 2002 base year EI. EPA guidance specifies the method states must use to develop the base year and all other SIP EI. Details of the development of the 2002 HGB base year i nventory are discussed in Chapter 2: EMISSIONS INVENTORIES . Summaries of the 2002 HGB base year NO Xand VOC emissions inventories are presented in; Table 2-14: HGB Eight-County RFP Controlled Ozone Season Weekday NOX Emission, and Table 2-16: HGB Eight-County RFP Controlled Ozone Season Weekday VOC Emission

.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-3 The second step of the RFP target calculation me thodology adds or subtracts any emissions from outside the nonattainment area that need to be included with or excluded from the nonattainment area inventory. The resulting inventory is called the 2002 RFP base year inventory, which represents the total anthropogenic emissions for the area and is the same as the 2002 base year inventory. Step three of the target calculation methodology is development of the adjusted base year (ABY) inventories for 2002, 2008, 2011, 2014, 2017, and 2018. These inventories are an algebraic representation of the effects of the pre-1990 Federal Clean Air Act Amendments (FCAA) controls projected to the RFP base and milestone y ears. As such, these inventories can be used to estimate the effects of the pre-1990 FCAA controls between milestone years. This estimation allows for the calculation of the non-creditable c ontrol reduction that is done as step four. The emission rates for an ABY inventory are develope d using the latest version of EPA’s emission factor model, MOBILE6.2.03. The model input file is set up to turnoff all 1990 FCAA effects and the model evaluation year is set to the RFP base or milestone year. The model is run to determine emission factors for each base or milestone year with only pre-1990 FCAA controls. The emission factors for all years are then multiplied by the 2002 base year VMT. Since all of the inventories use the base year VMT, these inventories are referred to as RFP ABY inventories. Details of the development of the HGB RFP AB Y inventories are documented in Chapter 2: EMISSIONS INVENTORIES and Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Furth er Progress On-road Mobile Source Emissions Inventories

. Step four, calculating the non-creditable fleet turnover correction, is accomplished by subtracting the ABY inventory for each RFP milestone year from the adjusted base inventory for the previousRFP milestone year. Since the ABY inventories estimate the effects of the non-creditable pre1990 FCAA controls, the difference between ABY inventories represent an estimate of the noncreditable RFP emission reductions, al so referred to as the fleet tu rnover correction. Table 3-2: Summary Non-creditable Fleet Turnover Reduction provides a summary of the fleet turnover corrections for all RFP milestone years. Th e equations for calculating the fleet turnover correction are shown below: Equation 3-1A: FTC MSY, VOC= ABY (MSY-1), VOC – ABY MSY, VOC and Equation 3-1B: FTC MSY, NOx= ABY (MSY-1), NOx – ABY MSY, NOx where: FTC MSY, VOC= VOC fleet turnover correction for year MSY FTC MSY, NOx= NO Xfleet turnover correction for year MSY ABY MSY, VOC = MSY adjusted base year inventory for VOC ABY MSY, NOx= MSY adjusted base year inventory for NO X ABY (MSY-1), VOC = previous MSY adjusted base year inventory for VOC ABY (MSY-1), NOx= previous MSY adjusted base year inventory for NO X MSY = RFP milestone year MSY - 1 = previous RFP milestone yearHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-4 Table 3-2: Summary Non-creditable Fleet Turnover Reduction On-road Mobile ABY EI Non-creditable Fleet Turnover Reductions RFP Analysis

Year NO X VOC NO X VOC Non-creditable Pre-1990 CAA Fleet Turnover

Reduction Years
2002 387.09 189.08 N/A N/A N/A 2008 346.01 185.46 41.08 3.62 2002-2008 2011 335.20 184.23 10.81 1.23 2008-2011 2014 334.08 183.60 1.12 0.63 2011-2014 2017 333.24 183.50 0.84 0.10 2014-2017 2018 333.17 183.46 0.07 0.04 2017-2018

Step five, calculating the required 3 percent per year emission reduction amount, is accomplished by multiplying the RFP milestone year ABY inventory values by the percent reduction needed to meet RFP requirements. For HGB, the requirement is to reduce emissions by 3 percent per year from the base year to the attainment year. The second phase of the EPA’s Eight-Hour Ozone Implementation Rule allows ozone nonattainment areas to substitute NO Xreductions for VOC reductions, but use of NO Xemissions reductions must meet the criteria in §182(c)(2)(C) in the FCAA. For the eight HGB counties, an equivalent percentage of NO Xreduction may be substituted for VOC reduction require ments for all RFP milestone years. The total of the percent NO Xand VOC reductions must equal the total emission reduction requirement for each milestone year. The RFP reduction requirement for this SIP is satisfied with a 1 percent reduction in VOC for each milestone year and the remaining percent reduction in NO Xemissions. Equation 3-2 describes the method to calculate the percentage of NO Xemissions substituted for VOC emissions: Equation 3-2: N MSY= [3 × (CY MSY – CY MSY-1 ) ] – V MSY where: V MSY= percentage VOC reductions for year MSY N MSY= percentage NO Xreductions for year MSY CY = calendar year MSY = RFP milestone year MSY - 1 = previous RFP milestone year The VOC and NO Xpercentages are multiplied by the mile stone year ABY inventories for VOC and NO X , respectively, to calculate the required VOC and NO Xemission reductions for each milestone year. Table 3-3: Calculation of Required 3 Percent Per Year NOX and VOC Reduction provides a summary of the NO Xand VOC reductions needed to satisfy the 3 percent per year requirement for all RFP milestone years. The equations for calculating the required percent reductions for VOC and NO Xare shown in Equations 3-3A and 3-3B.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-5 Equation 3-3A: RQvoc = [ BY 2002VOC – ( ABY 2002VOC – ABY MSY, VOC ) ] × PV MSY and Equation 3-3B: RQ NOx = [ BY 2002NOx – ( ABY 2002NOx – ABY MSY, NOx ) ] × PN MSY where: RQvoc = required percent VOC emission reductions by 2008 RQ NOx= required percent NO Xemission reductions by 2008 BY 2002VOC = 2002 base year inventory for VOC BY 2002NOx= 2002 base year inventory for NO X ABY 2002VOC = 2002 adjusted base year inventory for VOC ABY 2002NOx= 2002 adjusted base year inventory for NO X ABY MSY, VOC = MSY adjusted base year inventory for VOC ABY MSY, NOx= MSY adjusted base year inventory for NO X PV MSY= percentage VOC reductions for year MSY PN MSY= percentage NO Xreductions for year MSY MSY = RFP milestone year Table 3-3: Calculation of Required 3 Percent Per Year NO Xand VOC Reduction tons per day RFP Analysis

Year Total Percent Reduction Requirement Percent NO X Percent VOC ABY EI NO X ABY EI VOC Required Reductions NO X Required Reductions VOC 2002 N/A N/A N/A 912.10 941.19 N/A N/A 2008 18.0 17.0 1.0 871.02 937.57 148.07 9.38 2011 9.0 8.0 1.0 860.21 936.34 68.82 9.36 2014 9.0 8.0 1.0 859.09 935.71 68.73 9.36 2017 9.0 8.5 0.5 858.25 935.61 72.95 4.68 2018 3.0 2.5 0.5 858.18 935.57 21.45 4.68 2019 3.0 2.5 0.5 858.18 935.57 21.45 4.68

Step six, calculating 2008 target levels of emi ssions, is accomplished by subtracting the required emission reductions calculated in step five and th e fleet turnover correction factor calculated in step four from the 2002 base year inventory. This target level represents the level of emissions for each RFP milestone year for the HGB area to meet its eight-hour ozone RFP requirements. Because the fleet turnover correction affects both NO Xand VOC emissions, target levels are calculated for both pollutants even when the entire reduction requirement is taken from one pollutant or the other. The method for calculati ng the target levels of emissions for the RFP milestone years is shown in Equation 3-4.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-6 Equation 3-4: TL MSY X= TL (MSY-1), X– RQ MSY ,x – FTC MSY, X where: TL MSY, X= target level of emissions for MSY TL (MSY-1), X= target level of emissions for the previous RFP milestone year (Note: For 2008 the target level of emissions for the previous RFP milestone year is equal to the 2002 base year inventory.) RQ MSY , X= emission reduction requirement for MSY for pollutant X FTC MSY, X= fleet turnover correction term for MSY for pollutant X X = either VOC or NO X MSY = RFP milestone year MSY - 1 = previous RFP milestone year Appendix 1: HGB RFP Demonstration Calculations Spreadsheet documents the calculation of the target values for all RFP milestone years. Table 3-1: Step by Step Summary of Calculation of 2008 Target Levels for HGB provides a step by step summary of the calculation of the target levels for 2008 for the HGB area. Tables 3-4: RFP Post-2002 Target Level of NO X

Emissionsand 3-5: RFP Post-2002 Target Level of VOC Emissionssummarize the calculation of the target levels of VOC and NO Xfor all RFP milestone years and provide the Federal Motor Vehicle Control Program (FMVCP) non-creditable emissions reductions. The following sections describe how the target levels are integrated into the RFP demonstration. Table 3-4: RFP Post-2002 Target Level of NO X Emissions tons per day RFP Milestone Year Previous Target FMVCP NonCreditable Reduction Post-2002 Percent Reduction Requirement NO X NO XTarget

2002 Base Year N/A N/A N/A 912.10 * 2008 912.10 41.08 148.07 722.94 2011 722.94 10.81 68.82 643.32 2014 643.32 1.12 68.73 573.47 2017 573.47 0.84 72.95 499.68 2018 499.68 0.07 21.45 478.15 * This is the base year inventory, which is the starting point for ca lculating target valuesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-7 Table 3-5: RFP Post-2002 Target Level of VOC Emissions tons per day RFP Milestone Year Previous Target FMVCP NonCreditable Reduction Post-2002 Percent Reduction Requirement VOC VOC Target

2002 Base Year N/A N/A N/A 941.19 * 2008 941.19 3.62 9.38 928.19 2011 928.19 1.23 9.36 917.60 2014 917.60 0.63 9.36 907.61 2017 907.61 0.10 4.68 902.84 2018 902.84 0.04 4.68 898.12 * This is the base year inventory, which is the starting point for ca lculating target values

3.4 GROWTH The HGB RFP SIP demonstration must also account for any growth in emissions between 2002 and each RFP milestone year; 2008, 2011, 2014, 2017, and 2018. The VOC and NO X uncontrolled projected year EI are derived by ap plying the appropriate projection methodologies to the 2002 base year EI, to emission factor develo pment, and/or to activity level estimates. The resulting inventories include any growth between2002 and each projection year. The projection methodology for the uncontrolled RFP EI excludes changes in the emission factors due to control strategies so that the projections represent the total growth in emissions. When the creditable RFP control reductions are subtracted from uncontrolled projected inventories that include growth, the result will be the forecast controlled RFP emissions. The controlled RFP emissions are compared to the target levels to determine if a nonattainment area meets the RFP requirements. This method for accounting fo r growth is based on the EPA guidance for performing RFP calculations. 11 The development of the uncontro lled projected EI is documented in Chapter 2: EMISSIONS INVENTORIES . The development of the projected control reductions are documented in Chapter 4: CONTROL MEASURES TO ACHIEVE TARGET LEVELS

. 3.5 RFP DEMONSTRATION The second phase of the EPA’s 1997 Eight-Hour Ozone Implementation Rule (40 Code of Federal Regulations §51.910) requires the RFP control strategy planto show emission reductions that will reduce the controlled RFP milestone year EI to a value less than the emissions target value. The creditable RFP control reductions are subtracted from the uncontrolled forecast inventory for each RFP milestone year. For mil estone years 2011 through 2018, the controls that are reserved to demonstrate 2009 to 2018 contingenc y are added to the controlled RFP inventory because the creditable reductions for those years in clude the reductions reserved for contingency. The RFP milestone requirement is met for 2008 if the controlled RFP emissions forecast is less than the target level of emissions. The RFP milestone requirement is met for all other years if the controlled RFP emissions forecast without reductio ns reserved for contingency is less than the target level of emissions. Tables 3-6: Summary of RFP Demonstration for Eight HGB Counties

11 United States Environmental Protection Agency, “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard; Final Rule,” Federal Register (70 FR 71631), November 29, 2005.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-8 for 2008 , 3-7: Summary of RFP Demonstration for Eight HGB Counties for 2011 , 3-8: Summary of RFP Demonstration for Eight HGB Counties for 2014 , 3-9: Summary of RFP Demonstration for Eight HGB Counties for 2017, and 3-10: Summary of RFP Demonstration for Eight HGB Counties for 2018summarize the demonstration of the RFP plan for HGB for the 2008, 2011, 2014, 2017, and 2018 milestone years. As concluded in the final row of each of these tables, the HGB area demonstrates the required RFP emission reductions for each milestone year. All RFP calculations, including the required reductions, the fleet turnover correction factor, and the target emission levels are calculated and shown in Appendix 1: HGB RFP Demonstration Calculations Spreadsheet . Details of the emission reductions used to satisfy the RFP requirements are documented in Chapter 4: CONTROL MEASURES TO ACHIEVE TARGET LEVELS and summarized in Tables 4-1: Summary of HGB RFP NOXEmission Reductions Represent Post2002 Cumulative Totals and 4-2: Summary of HGB RFP VOC Emission Reductions Represent Post-2002 Cumulative Totals. Table 3-6: Summary of RFP Demonstration for Eight HGB Counties for 2008 tons per day Line # Description NO X VOC Line 1 Uncontrolled Emissions Fo recast With Growth 1030.96 1013.53 Line 2 Creditable RFP Control Reductions for 2008 450.74 137.44 Line 3 Controlled RFP Emissions Forecast (Line 1 minus Line 2) 580.22 876.09 Line 4 RFP Target Level of Emissions 722.94 928.19 Line 5 Excess (+) / Shortfall (-) (Line 4 minus Line 3) +142.72 +52.10 Line 6 Is Controlled RFP EI Less Than Target Level of Emissions? Yes Yes

Table 3-7: Summary of RFP Demonstration for Eight HGB Counties for 2011 tons per day Line # Description NO X VOC Line 1 Uncontrolled Emissions Fo recast With Growth 1060.22 1046.60 Line 2 Creditable RFP Control Reductions for 2008 450.74 137.44 Line 3 Creditable RFP Control Reductions 2008 to 2011 88.54 54.82 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 520.94 854.34 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 542.71 859.03 Line 7 RFP Target Leve l of Emissions 643.32 917.60 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +100.60 +58.57 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes YesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-9 Table 3-8: Summary of RFP Demonstration for Eight HGB Counties for 2014 tons per day Line # Description NO X VOC Line 1 Uncontrolled Emissions Fo recast With Growth 1124.59 1089.46 Line 2 Creditable RFP Control Reductions for 2008, 2011 539.28 181.78 Line 3 Creditable RFP Control Reductions 2011 to 2014 107.44 44.35 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 477.86 863.33 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 499.64 868.02 Line 7 RFP Target Leve l of Emissions 573.47 907.61 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +73.83 +39.59 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes Yes

Table 3-9: Summary of RFP Demonstration for Eight HGB Counties for 2017 tons per day Line # Description NO X VOC Line 1 Uncontrolled Emissions Fo recast With Growth 1182.82 1133.87 Line 2 Creditable RFP Control Reductions for 2008, 2011, 2014 646.72 226.13 Line 3 Creditable RFP Control Reductions 2014 to 2017 88.72 31.28 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 447.38 876.46 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 469.15 881.15 Line 7 RFP Target Leve l of Emissions 499.68 902.84 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +30.53 +21.68 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes YesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-10 Table 3-10: Summary of RFP Demonstration for Eight HGB Counties for 2018 tons per day Line # Description NO X VOC Line 1 Uncontrolled Emissions Fo recast With Growth 1209.02 1148.85 Line 2 Creditable RFP Control Reductions for 2008, 2011, 2014, 2017 735.45 257.40 Line 3 Creditable RFP Control Reductions 2017 to 2018 30.60 8.99 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 442.98 882.45 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 464.76 887.14 Line 7 RFP Target Leve l of Emissions 478.15 898.12 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +13.40 +10.98 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes YesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-1 CHAPTER 4: CONTROL MEASURES TO ACHIEVE TARGET LEVELS 4.1 OVERVIEW OF CONTROL MEASURES This section briefly describes the control measu res used to achieve the necessary emission reductions to meet the reasonable further progress (RFP) requirements. The methodologies used to estimate reduced emission levels are described in Sections 4.2 through 4.5. The projected emission reductions reflect the identified federal and state emission controls. All state control measures are codified in Texas state regulations. The list of controls does not include all emission reduction programs for the Houston-Galveston-Brazoria (HGB) area. The summary of emission reductions from the control measures usedto meet the RFP targets is presented in Tables 4-1: Summary of HGB RFP NOX Emission Reductionsand 4-2: Summary of HGB RFP VOC Emission Reductions . Individual and total values shown in these summary tables have been extracted from the spreadsheet in Appendix 1: HGB Reasonable Further Progress Demonstration Calculations Spreadsheet . All values represent the numbers rounded to two significant figures. Since the totals in the tabl es are taken directly from the spreadsheet and rounded rather than summed from the rounded values in the table, there may be rounding discrepancies for the total values.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-2 Table 4-1: Summary of HGB RFP NO XEmission Reductions tons per day Control Strategy Description 2008 2011 2014 2017 2018 Mass Emissions Cap and Trade Progr am (MECT) 219.83 227.65 243.87 263.23 269.94 Tank Landing Loss Rule 0.00 0.00 0.00 0.00 0.00 Federal Portable Fuel Container (PFC) Rule 0.00 0.00 0.00 0.00 0.00 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 68.11 62.24 56.88 49.05 49.28 Federal Reformulated Gasoline (RFG) 46.75 72.94 104.41 128.94 135.65 Inspection and Maintenance (I/M) in Harris County 13.65 16.07 20.82 25.11 26.48 N ational Low Emission Vehicle program (NLEV) 9.12 9.31 6.16 3.42 2.66 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery Counties) 7.06 5.12 10.15 8.63 9.16
Tier 2 FMVCP 24.98 51.95 53.79 91.98 96.36 2007 Heavy-Duty FMVCP 8.70 28.22 66.13 61.69 67.54 On-road Texas Low Emission Diesel (TxLED) 8.87 3.21 2.11 1.45 1.19 Tier I and II Locomotive NO Xstandards 11.74 12.75 14.09 15.24 16.04 Small Non-Road Spark Ignition (SI) Phase I -0.30 -0.39 -0.47 -0.56 -0.58 Federal Standards for New Heavy-Duty Non-Road Engines 5.76 7.91 9.64 12.02 12.56
Tier 2 and 3 Federal Standards for New Non-Road Diesel Engines 8.13 14.01 18.76 23.25 24.29 Federal Standards for New Small Non-Road Spark Ignition (SI) Engines (Phase II) 1.25 1.65 1.85 1.99 2.04 Federal Standards for New Large Non-Road SI and Recreational Marine 12.27 20.30 27.01 31.10 32.13

N on-road TxLED 2.87 2.59 2.14 1.73 1.59 N on-road RFG 0.00 0.00 0.00 0.00 0.00 Tier 4 Federal Standards for Diesel Engines 0.00 0.52 4.67 10.96 12.82 Federal Marine Diesel Tier 2 1.96 3.23 4.72 6.20 6.90

Sum of Control Reductions 450.74 539.28 646.72 735.45 766.04 Note: The Small Non-road Spark Ignition Phase I rule is designed to reduce hydrocarbon emissions. The technology that is used achieve the reduction in hydrocarbon emissions also cau ses a slight increase in NO X emission rates. See Table 4-2 for information regarding VOC reductionsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-3 Table 4-2: Summary of HGB RFP VOC Emission Reductions tons per day Control Strategy Description 2008 2011 2014 2017 2018 Mass Emissions Cap and Trade Program (MECT) 0.00 0.00 0.00 0.00 0.00 Tank Landing Loss Rule 0.00 11.50 11.50 11.50 11.50 Federal Portable Fuel Container (PFC) Rule 0.00 3.68 9.65 10.10 10.25 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 45.57 63.02 79.36 91.17 94.52 Federal Reformulated Gasoline (RFG) 34.24 34.51 37.17 39.99 40.97 Inspection and Maintenance (I/M) in Harris County 10.42 11.35 12.43 13.49 13.90 N ational Low Emission Vehicle program (NLEV) 5.33 4.81 3.27 1.97 1.59 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery Counties) 3.09 3.30 4.44 4.32 4.50
Tier 2 FMVCP 9.91 19.19 16.87 37.20 39.39 2007 Heavy-Duty FMVCP 0.15 0.45 12.53 1.00 1.08 On-road Texas Low Emission Diesel (TxLED) 0.04 0.06 0.12 0.33 0.21 Tier I and II Locomotive NO Xstandards 0.27 0.34 0.43 0.53 0.59 Small Non-Road Spark Ignition (SI) Phase I 1.77 2.50 3.23 3.95 4.19 Federal Standards for New Heavy-Duty Non-Road Engines 4.73 6.82 8.54 10.17 10.58
Tier 2 and 3 Federal Standards for New Non-Road Diesel Engines 0.95 1.68 2.32 2.95 3.10 Federal Standards for New Small Non-Road Spark Ignition (SI) Engines (Phase II) 16.70 20.81 22.72 24.13 24.57 Federal Standards for New Large Non-Road SI and Recreational Marine 4.14 7.96 11.37 14.03 14.76

N on-road TxLED 0.00 0.00 0.00 0.00 0.00 N on-road RFG 0.04 0.13 0.22 0.30 0.33 Tier 4 Federal Standards for Diesel Engines 0.00 0.03 0.26 0.52 0.59 Federal Marine Diesel Tier 2 0.08 0.12 0.18 0.24 0.26

Sum of Control Reductions 137.44 192.26 236.61 267.88 276.87

4.2 POINT SOURCE CONTROLS The point source controls were calculated using sev eral sources of data, including but not limited to the point source emissions inventory and the Mass Emissions Cap and Trade Program (MECT). Emission reductions required by state rules were incorporated into the future projections for controlled inventories. Point source controls are detailed in Sheets 30-34 of Appendix 1: HGB RFP Demonstration Calculations Spreadsheet . The most significant NO X reduction strategies are the 30 Texas Administrative Code (TAC) Chapter 117 rules and the MECT Program. Some of the affected source categories are utility boilers, turbines and duct burners, heaters and furnaces, internal combustion engines, and industrial boilers. The reductions in point source VOC emissions were determined from the tank landing loss rules in 30 TAC Chapter 115, Subchapter B.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-4 4.3 AREA SOURCE CONTROLS The only area source control in the HGB area us ed in this RFP demonstration is the federal portable fuel container (PFC) rule. Controlled VOC emissions resulting from this rule will begin in 2010. Therefore, the first year of this HGB RFP State Implementation Plan (SIP) revision for PFC controls will be 2011. The EI forecast used EPA approved Economic Growth Analysis System (EGAS) growth factors to develop the corresponding controlled EI for milestone and attainment years. To develop the controlled emissions, rule effectiveness factors were applied for source categories with applicable rules. The summary of uncontrolled and controlled emissions for area sources in the HGB area may be found in Tables 2-3: HGB Eight-County Area Source NOX Emissions and 2-4: HGB Eight-County RFP Area Source VOC Emissions

.

. 4.4 NON-ROAD MOBILE SOURCE CONTROLS Most non-road mobile source emissions were calc ulated using a Texas specific version of the EPA’s NONROAD 2005 model, called the Texa s NONROAD (TexN) model. Although operating the EPA’s model with all of the defau lt surrogates is acceptable, the EPA encourages states to update the model with local, county-leve l data based on surveys and other relevant information. The TexN model is a software toolfor developing emissions estimates for non-road mobile sources in Texas using county specific activity data. The model allows air quality planning staff to replace EPA’s default data withlocal bottom-up data. Local, county-level data is incorporated into the TexN m odel as it becomes available. Emissions from the remaining non-road mobilesources not included in the NONROAD model, locomotives, aircraft and ground support equipment, commercial marine vessels, and oilfield drilling rigs, were calculated outside of the NONROAD 2005 model using EPA-approved methodologies. 4.4.1 NONROAD Model Categories For the RFP plan, the TexN model was executed using county specific population and activity files where available. In some cases, custom allocation and technology typedata files were also used. The technology type file identifies what percent of an equipment population is expected to use federal non-road equipment controls for the year of interest. The effects of federal and state control programs were evaluated. The TexNmodel was executed for ozone season daily emission for years 2002, 2008, 2011, 2014, 2017, 2018, and 2019. In order to evaluate RFP requirements, a series of TexN model runs we re executed for both controlled and uncontrolled scenario for each federal and state control progr am for each analysis year. The documentation and procedure of applicable federal and state rules modeled is in Appendix 4: Development of RFP Non-Road Mobile Source Emissions Inven tories for Source Categories in the EPA’s NONROAD2005 Model . The inventories developed incl ude county level ozone season day controlled and uncontrolled emissions estimates for years 2002, 2008, 2011, 2014, 2017, 2018, and 2019 for the eight counties in the HGB area. Once the individual uncontrolled and controlled emissions estimates were generated by the TexN model, the effectiveness of control strategies for eac h year of interest was evaluated. Emissions reductions from individual federal and state controls on non-road equipment was calculated by subtracting the controlled emissions estimates from the uncontrolled emissions estimates. 4.4.2 Non-Road Categories not in the NONROAD Model Locomotive controlled emissions were calculated us ing data extrapolated from a contractor report drafted by Eastern Research Group, Inc., (ERG ) and contained in the Texas Air EmissionsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-5 Repository (TexAER) database. 12The uncontrolled emissions were developed using the EPA Fleet Average Emission Factors for Locomotives document. 13 Commercial marine vessel emissions were developed based on emission i nventory completed in 2005 and 2007 by the contractor. 14,15 Emissions were developed from surveys to determine vessel types and shipping activities within the Houston Ship Channel. Oilfield drilling rig emissions were developed by contractor using drilling permit data from the Railroad Commission of Texas. 16 The reductions for each control strategy for each milestone year are summarized in Tables 4-1: Summary of HGB RFP NOX Emission Reductionsand 4-2: Summary of HGB RFP VOC Emission Reductions. Details of the non-road control strategy emission reductions are documented in Appendix 4: Development of RFP Non-Road Mobile Source Emissions Inventories for Source Categories in the EPA’s NONROAD2005 Model. 4.5 ON-ROAD MOBILE SOURCE CONTROLS The projected mobile source emissions inventories documented in Appendix 9: HoustonGalveston-Brazoria 1997 Eight-H our Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventoriesincludes quantification of emission reductions for all federal and state on-road mobile source control rules for each RFP milestone year for the eight-county HGB area. Not all available on-ro ad mobile source controls are needed to demonstrate RFP for the HGB area. A summary of the on-road mobile controls included in the 2002, 2008, 2011, 2014, 2017, and 2018 RFP inve ntories is presented in Table 4-3: Control Programs Modeled in MOBILE6 Emissions Fa ctors for the Base and Milestone Years RFP Controlled Emissions Inventories. The reductions for each control strategy for each milestone year are summarized Tables 4-1: Summary of HGB RFP NOX Emission Reductionsand 4-2: Summary of HGB RFP VOC Emission Reductions. Table 4-3: Control Programs Modeled in MOBILE6 Emissions Factors for the Base and Milestone Years RFP Controlled Emissions Inventories Control Program 2002 2008 2011 2014 2017 2018 Tier 1 Federal Motor Vehicle Control Program (FMVCP) X X X X X X I/M in Harris County X X X X X X Federal Reformulated Gasoline (RFG) X X X X X X National Low Emission Vehicle Program (NLEV) X X X X X X Tier 2 FMVCP X X X X X 2007 Heavy-Duty Diesel FMVCP X X X X X Expanded I/M X X X X X TxLED X X X X X

12ERG, “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07-84003-04, August 31, 2007. 13 EPA, “Emission Factors for Locomotives,” December 1997. 14ERG, “Development of Emission Estimates for Offshore Non-road Mobile Sources in Texas State Waters,” August 2005. 15 ERG, “Commercial Marine Vessel, Locomotive, and Aircraft Growth Factors,” August 2007. 16ERG, “Emissions from Oil and Gas Production Facilities,” August 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-6 4.6 CONTINGENCY MEASURES In case of a milestone failure, contingency contro l measures estimated to reduce emissions by an additional 3 percent between the milestone year and the next calendar year are required. As with the 3 percent per year reduction requirement, the 3 percent contingency requirement is based upon the adjusted base year and may be met using either VOC or NO Xreductions. As shown in Table 4-4: 2009 RFP Contingency Demonstration for the HGB Areathe 3 percent contingency analysis for 2009 and subsequent milestone years to 2018 is based upon a 2.5 percent reduction in NO Xand a 0.5 percent reduction in VOC to beachieved between 2008 and 2009. The excess emission reductions from the RFP milestone y ear 2008 were used to demonstrate the 2009 contingency. The 2009 contingency reductions are subtracted from creditable control reductions for milestone years 2011, 2014, 2017, and 2018 to account for the contingency requirements for each of those years. If the RFP milestone requirement is met for 2008, the contingency reductions designated for 2009 will be available to be used as contingency reductions for each following milestone where the RFP emissions requirement is met. Table 4-4: 2009 RFP Contingency Demonstration for HGB Area 2009 Description NO X VOC Adjusted 2008 Base Year EI 871.02 937.57 Percent for Contingency Calculation (total of 3 percent) 2.50 0.50 2008 to 2009 Required Contingency Reductions 21.78 4.69 Excess From 2008 RFP Demonstration (see Appendix 1 Sheet 2) 142.72 52.10 Subtract 2008 MVEB Safety Margin From Excess Reductions from 2008 RFP Demonstration -17.58 -8.61 Total Contingency Reductions 125.14 43.49 Contingency Excess (+) or Shortfall (-) +103.37 +38.80 Are contingency reductions greater than required contingency reduction? Yes Yes Note: Emissions are represented in tons per day. Since 2018 is the attainment year, there is no corresponding continuing 3 percent per year analysis for 2019. The 3 percent contingency analysis for 2019 was based upon a 2 percent reduction in NO Xand a 1 percent reduction in VOC to be achieved between 2018 and 2019. Inventory analyses were performed on the fleetturn over effects for the federal emission certification programs for on-road and non-road vehi cles. The emission reductions for the year from 2018 to 2019 were estimated for these programs. Controlled emission reductions not previously used in the 2018 milestone demonstration may also be used to satisfy contingency requirements, so the excess emission reductions from the 2018 RFP demonstration are included in the contingency analysis. Because this SIP re vision provided for a 10 percent MVEB safety margin using some of the excess emissions reductions from the 2018 RFP demonstration, those emissions are subtracted from the amount available to demonstrate 2019 contingency. A summary of the 2019 contingency analysis is provided in Table 4-4: 2019 RFP Contingency Demonstration for HGB Area . The analysis demonstrates that the 2019 contingency reductions exceed the 3 percent reduction requirement; therefore, the RFP contingency requirement is fulfilled for the HGB area.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-7 Table 4-5: 2019 RFP Contingency Demonstration for HGB Area 2019 Description NO X VOC Adjusted 2018 Base Year EI 858.18 935.57 Percent for Contingency Calculation (total of 3 percent) 2.50 0.50 2018 to 2019 Required Contingency Reductions 21.45 4.68 Excess From 2018 RFP Demonstration (see Appendix 1 Sheet 7) 13.40 10.98 Subtract 2018 MVEB Safety Margin From Excess Reductions from 2018 RFP Demonstration -5.54 -4.67 Tier 1 FMVCP -1.93 1.40 Federal RFG 5.09 0.70 I/M and ATP in Harris County 0.88 0.20 NLEV -0.60 -0.31 Expand I/M to Brazoria, Fort Bend, Galveston, and Montgomery Counties 0.35 0.11 Tier 2 FMVCP 2.92 1.60 2007 Heavy Duty Diesel FMVCP 3.58 0.04 On-road Texas Low Emission Diesel 0.00 0.00 TERP 0.00 0.00 VMEP 0.00 0.00 TCM 0.00 0.00 Tier I and II Locomotive NO XStandards 0.68 0.01 Small Non-Road Spark Ignition Phase I -0.03 0.24 Heavy Duty Non-road Engines 0.30 0.32 Tier 2, and 3 Non-road Diesel Engines 0.72 0.11 Small Non-road SI Engines (Phase II) 0.04 0.43 Large Non-road SI & Recreational Marine 0.95 0.62 Non-road Texas Low Emission Diesel 0.00 0.00 Non-road Reformulated Gasoline 0.00 0.03 Tier 4 Diesel Rule 1.58 0.06 Federal Marine Diesel Tier 2 0.55 0.02 Total Contingency Reductions 22.94 11.89 Contingency Excess (+) or Shortfall (-) +1.49 +7.21 Are contingency reductions greater than required contingency reduction? Yes Yes Note: Emissions are represented in tons per day.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-1 CHAPTER 5: MOTOR VEHICLE EMISSIONS BUDGETS 5.1 INTRODUCTION This Houston-Galveston-Brazoria (HGB) reasonable further progress (RFP) state implementation plan (SIP) revision establishes motor vehicle emissions budgets (MVEB), which set the allowable on-road mobile emissions the HGB area can produce and continue to demonstrate RFP. The HGB RFP SIP revision MVEB are calculated by subtracting the on-road mobile control strategyemission reductions that are necessary to demonstrate RFP from the uncontrolled, projected onroad mobile source emissions for each RFP milestone year. Local transportation planning organizations use the MVEB to demonstrate thatprojected emissions from transportation plans, programs, and projects are equal to, or less than the budget, as required by the federal transportation conformity rule. 5.2 OVERVIEW OF METHODOLOGIES AND ASSUMPTIONS The Texas Commission on Environmental Quality (TCEQ) developed updated on-road mobile source emissions inventories (EI) and control strategy reduction estimates that use the latest planning assumptions and the newest version of the United States Environmental Protection Agency’s (EPA) emission factor model. Updated inventory development included development of: a 2002 base year inventory; adjusted base y ear inventories for 2002, 2008, 2011, 2014, 2017, and 2018; 2008, 2011, 2014, 2017, and 2018 milestoneyear inventories; and control strategy reduction estimates for 2008, 2011, 2014, 2017, and 2018. The TCEQ worked with the HoustonGalveston Area Council (H-GAC) to devel op these inventories. Appendix 9: Houston-GalvestonBrazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventoriesis a copy of the H-GAC contractor (ENVIRON International Corporation) report, which provid es detailed documentation of the on-road mobile inventory development. 5.3 MOTOR VEHICLE EMISSIONS BUDGETS FOR RFP MILESTONE YEARS The RFP MVEB reflect the on-road mobile EI fo r each RFP milestone year, the on-road mobile reduction strategies used to demonstrate RFP, and a 10 percent transportation conformity safety margin. A transportation conformity safety margin is allowed when there is an excess in emission reductions required to demonstrate RFP for a milestone year. The amount of the safety margin is less than the total in excess emission reductions for nitrogen oxides (NO X ) and volatile organic compounds (VOC) and, therefore, even if the safety margin is used for a transportation conformity determination, the HGB area will s till meet the eight-hour ozone RFP requirements for all milestone years. Summaries of the calcu lation of the MVEB for each RFP milestone year are presented in Tables 5-1: 2008 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-2 : 2011 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-3 : 2014 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-4 : 2017 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-5 : 2018 RFP Motor Vehicle Emissions Budgets for the HGB Area . The details of the calculation of the MVEB is documented in Sheets 10 through 14 of Appendix 1: HGB RFP Demonstration Calculations Spreadsheet . The RFP control strategy produces more than the required emissions reductions for each milestone year. Some of the excess in emissions reductions for each milestone year is used to provi de a safety margin. This safety margin is less than the total emissions reductions needed for th e RFP demonstration; therefore, even if this safety margin is used, the HGB area willstill demonstrate RFP for each milestone.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-2 Table 5-1: 2008 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO X tons per day VOC tons per day 2008 On-Road Emissions Projection Without Post-1990 FCAA Controls 363.05 194.89 2008 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 68.11 45.57 Federal Reformulated Gasoline (All 8 Counties) 46.75 34.24 I/M in Harris County 13.65 10.42 National Low Emission Vehicle Program (NLEV) 9.12 5.33 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 7.06 3.09 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 24.98 9.91 2007 Heavy-Duty Diesel FMVCP 8.7 0.15 On-Road TxLED 8.87 0.04 2008 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory minus control reductions) 175.81 86.14
Add Transportation Conformity Safety Margin 1 17.58 8.61 2008 RFP Motor Vehicle Emissions Budgets 193.39 94.75
1 The 2008 RFP reductions exceed the required emi ssions reductions. Excess emissions equaling 10 percent of the 2008 on-road emissions projection with post-1990 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2008.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-3 Table 5-2: 2011 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO X tons per day VOC tons per day 2011 On-Road Emissions Projection Without Post-1990 FCAA Controls 372.46 205.03 2011 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 62.24 63.02 Federal Reformulated Gasoline (All 8 Counties) 72.94 34.51 I/M in Harris County 16.07 11.35 National Low Emission Vehicle Program (NLEV) 9.31 4.81 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 5.12 3.3 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 51.95 19.19 2007 Heavy-Duty Diesel FMVCP 28.22 0.45 On-Road TxLED 3.21 0.06 2011 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory minus control reductions) 123.40 68.34
Add Transportation Conformity Safety Margin 1 12.34 6.83 2011 RFP Motor Vehicle Emissions Budgets 135.74 75.17
1 The 2011 RFP reductions exceed the required emi ssions reductions. Excess emissions equaling 10 percent of the 2011 on-road emissions projection with post-1990 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2011.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-4 Table 5-3: 2014 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO X tons per day VOC tons per day 2014 On-Road Emissions Projection Without Post-1990 FCAA Controls 407.05 222.41 2014 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 56.88 79.36 Federal Reformulated Gasoline (All 8 Counties) 104.41 37.17 I/M in Harris County 20.82 12.43 National Low Emission Vehicle Program (NLEV) 6.16 3.27 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 10.15 4.44 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 53.79 16.87 2007 Heavy-Duty Diesel FMVCP 66.13 12.53 On-Road TxLED 2.11 0.12 2014 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory minus control reductions) 86.60 56.22
Add Transportation Conformity Safety Margin 1 8.66 5.62 2014 RFP Motor Vehicle Emissions Budgets 95.26 61.84
1 The 2014 RFP reductions exceed the required emissions reductions. Excess emissions equaling 10 percent of the 2014 on-road emissions projection with post-1990 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2014.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-5 Table 5-4: 2017 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO X tons per day VOC tons per day 2017 On-Road Emissions Projection Without Post-1990 FCAA Controls 432.04 237.86 2017 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 49.05 91.17 Federal Reformulated Gasoline (All 8 Counties) 128.94 39.99 I/M in Harris County 25.11 13.49 National Low Emission Vehicle Program (NLEV) 3.42 1.97 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 8.63 4.32 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 91.98 37.20 2007 Heavy-Duty Diesel FMVCP 61.69 1.00 On-Road TxLED 1.45 0.33 2017 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory minus control reductions) 61.77 48.39
Add Transportation Conformity Safety Margin 1 6.18 4.84 2017 RFP Motor Vehicle Emissions Budgets 67.95 53.23
1 The 2017 RFP reductions exceed the required emi ssions reductions. Excess emissions equaling 10 percent of the 2017 on-road emissions projection with post-1990 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2017.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-6 Table 5-5: 2018 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO X tons per day VOC tons per day 2018 On-Road Emissions Projection Without Post-1990 FCAA Controls 443.70 242.84 2018 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 49.28 94.52 Federal Reformulated Gasoline (All 8 Counties) 135.65 40.97 I/M in Harris County 26.48 13.90 National Low Emission Vehicle Program (NLEV) 2.66 1.59 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 9.16 4.50 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 96.36 39.39 2007 Heavy-Duty Diesel FMVCP 67.54 1.08 On-Road TxLED 1.19 0.21 2018 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory minus control reductions) 55.38 46.68
Add Transportation Conformity Safety Margin 1 5.54 4.67 2018 RFP Motor Vehicle Emissions Budgets 60.92 51.35
1 The 2018 RFP reductions exceed the required emi ssions reductions. Excess emissions equaling 10 percent of the 2018 on-road emissions projection with post-1990 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2018.

# WRITTEN AND ORAL TESTIMONYReference Number
W-1

W-2 INDEX OF WRITTEN TESTIMONY

Submitted 

### By Wendi Hammond, on behalf of KIDS for Clean Air, the Sustainable Energy and Economic Development (SEED) Coalition, the Clean Air Institute of Texas, and herself GUy R. Donaldson, United States Environmental Protection Agency

# i

. , . : PH:**(9~)** 

### 746-8540 LAW OFFICE OF 

### WENDl1lA:MMOND 7325

### Augus~ Circle Plano, 

## n 75025 

### Wendi@TexasEnvironmentalLaw.net i 11/139/2121139 

### I 

# i

I j I i i 

## T 17:133 46924112143121 HAMMOND

, I 

# W-1 PAGE D.Lt

.. ",- 

# RECEIVED

NOV 09 ZUUY AIR QUALITY**~'VtllON**



### FX: (469) 241..()430
'November 9, 2009

I. 

## i I ,

, I

. I

### ~IA 

### FAX: 

### (512)**239~5687** .'**~tln:** 

### Lola Brown, and**--~J;>:!>(Attn: Walk~r**  Williamson

, 

## . TviC 206.**S~** 

### Implementation 

### Team, phief**Engl~ers** 

### Office, TCEQ 

### r.O, Box 

### 13087 

# r

ustin, 

## TxtS711-3087

. . . '. REt: HG6 Attainment Demonstration 

### SIP Revision; Project No. 

## 2D09-017-SIP·NR



# ... - 1""-'"'' 

# VIr HGP

## Reaso~able Further progress SIP

## Revlslo~; Project No.

## 2009-o1~IP-NR 

# rar Lola 

# rrown and Walker Williamson: .'**l.D~n** 

### behalf 

# 9f the KIDS for Clean 

### AIr. the Sustainable 

### Energy and Economic qevelopment 

### (SEED) Coalition. 

### me Clean f'Jr Institute of Texas, and myself, 

### I am filing the following written comments on the above named and numb\r&d projects. In addijion 

### to 

## the comments provided below. any other comments submitted by 

## fnvlronT Defense 

## and/or SlllII1l Club 

## are hereby 

### adopted and incorporated by 

## reference. fCEQ's weight 

### of evidence 

### air quality 

### trends over-estimates 

### the air quality 

## trend forthe HGB 

### area ponsidering the past unusual weather fluctuations, the amount of oontlnued ozone reductions attributable to the existIng and proposed -new" oontrol strategies, and the proposed development 

### of significant point 

## rources**l~ted** outside and upwind of the 

### HGB area .: such, the proposals 

### fail 

### to adequately**C1emonstra~on** 

### the 

### area wnl 

### attain 

### by the deadline.· '.

. 

## I • ' . I 

### U usual Weather Fluctuations Created Unusual Low Desl n Values 0 • 

# I

. ifhe 

## 1997 /thour standard removed the 1·hour standard because In theory the 8-hour standard would 

### be as pr more 

### etrrctive at protecting the pUblic health. Unfortunately, air monitoring data has proven this 

# rumpti01 to be false" . , '. '.' For**examp~e,** 

### during 

### the three year period from 2009-2007, the Houston-Galveston-Brazoria area design 

# r

a1ue 

### did 

# npt violate the B-hour 

### standard. but several monItors 

### dId violate 

### the QId 

### 1·hour 

### standard for 

### the**~ame** 

### time period.'

. 

# !. 'j
/1be

## aiTm~ltors included reSQlatory 

### rnomtoring sites Northwest Harris 

### Co. C26IAllOIX1S4 andWallsvUle Road F617.**S~cnvirolllncntlli** data also iutiludcd nOD-rcgulatory monitoring sites Crosby Library C553 and Tom B888**~S8. No~:**  

### the Tom Bass monitor actually had 

### a design value exceedjng the 8-hour 

### stan4a:rd. but the site 

### isnot 

### an pA**regul~** approved site.



## 1\46924HI430

. PA6E E12/E12 

# I

An

# eXPlan~tion for this phenomenon 

### could be attributed 

## to the implication 

### of unusual and/or extreme weather f1u1ctuations. The current ozone NMQS form (forth-highest dally 

### maximum 8-hour concentration 

### averaged 

### qver 

### :3 years) 

## was developed 

## to supposedly account for such fluctuations. 

### Unfortunately, the 

### real world 

### Implication is that 

### it compensates for fluctuations that may provide an unusually high design value, but It

## do~e' ot compensate for fluctuations 

### that may provide an unusually low design

## valu~. . 

# For**exam~** :e 1 

### Texas experienced unusual/extreme weather fluctuations in 2007 and 

# 2009. In 2007 1 

### Texas experlen an unusuafly rainy and cool ozone season

.. As illustration, the Dallas-Fort Worth area-an area 

### that tYPiCally hIts triple digit temperatures throughout the**summer~1d** 

### not experience 1000 

### +**temperatu~** 

### until late August. Once normal czonaseason weather patterns occurred, air 

## monltoTS registered 

## Ixceedances. Ukewise 1 

### in 

### 2009, Texas**e~enced** 

### an unusually windy ozone seeson, but 

### again Whtthe**are~** 

### experienced 

### typical weather patterns for ozone fonnation, 

### the air monitors once again 

### reg red 

### ozone excaedances (spiking 

## to 157 ppm at one Houston monitor).

.

, 

## . The attainrpent demonstration must somehow account for ·normal a 

### weather patterns that are conducive for ozone fonnation 'in such 

### a 

### way 

## that unusuaVextreme weather fluctuations do not impact attainment

. dsmoJons in a favorable or non-favorable manner. Therefore, 

### little weight of evidence should be afforded 

### to the 

### "trend- of 2007·2009 skewed design values. Both D 

## nstratla 5 

### Ov I te 

## e Benefits of Exlstln and Pro ed 

### I



### r your attention to 

### this 

### matter. If·you 

### have any questions, feel free 

## to contact me

. 

# The existi control strategies 

### should have accomplished expected reductions prior 

## te, orshortly 

### thereafter, 

### these**~ons.** 

### The proposed new oonlrol slr.d&gi

.. have 

### very 

## lillie futtlre l8ducllons 

### assocIaIlKI 

## WIth them: 

### Thus, little weight should 

### be afforded to 

### a continuing. 

### "trend- of ozone reductions when the

. demon

.**·~ns** 

### themselves**~11s** 

### to adequately establish ongoing reductions attributable 

## to existing and/or

.**~roposed** 

# r w control strategl9s. , . 

### Both DemonstratJMUafl 

## to Adequately Account for Expected Known 

## Increases in 

# Ozon, PrecursoriJ;misStons Located OutsIde the HBS Area and within Texas. 

### Several

# J1~or emitting 

# point sources located outside the HG8 area ( but within Texas) 

### have been permitted and/or am', 

### rrently undergoing 

### the permItting**proc~s** 

### (e.g., new power plants in R!lberlson, Milam 1 

### Calhoun, oliad, and Matagorda counties). These point sources wiD emit vast amounts of ozone 

### precurso (e.g., NOx and VOe) 

### thatwlll 

### blow into the HGB nonattainment area and either cause or contribute 

### NMQS violations. Both demonstrations fall to adequately 

### account for these 

### Increases and !he 

## P"tentitl impacfs 

## on HGB's ability 

### In attain 

## the ozone NMOS s1enderd by 

## fhe dead6ne. Conclusion ' ,



## . ! i. 

### ,

, \·i 

### 2 d I: 

# 1

I 'I

i i

" 'i i 

# L

j

# ~, • I 

# !

### From: TRRules To: dryan; Hoekzema, Andrew; jrawling; lbrown; Meiller, Vincent; mparri... Date: 11/9/20095:07 PM Subject: Fwd: 2009-017-SIP-NR Attachments: EPA HGB SIP Comments 11 909.pdf

»> 

### < young.carl@epa.gov> 11/9/20095:00 PM »> 11109/200905:00 PM
This email is a confirmation of the comment that was submitted for the referenced rulemaking.
First Name: Carl Last Name: Young Company/Organization: EPA Region 6 E-mail Address: young.car1@epa.gov Street Address: 1445 Ross Ave City: Dallas State: TX Zip Code: 75202 Phone Number: 214-665-6645 Fax Number:
Rule: 2009-017-SIP-NR
Comments:
Comments on
• HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (Project No. 2009-017-SIP-NR) • HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard (Project No. 2009-0 18-SIP-NR) • Highly Reactive VOC Cap and Trade (HECT) Program Cap Reduction and Allowance Reallocation (Rule Project No. 2009-006-10 I-EN) • Mass Emissions Cap and Trade (MECT) Program Cap Integrity for the HGB Eight-Hour Ozone Nonattainment Area (Rule Project No. 2009-019-10 I-EN)

file:///qlDocuments%20ando/020Seltings/ahoekzernlDesktopIEPA%20HGB%20E-mail.txt [11110/20098:25:35 AM]

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 1445 ROSS AveNUE, surre 1200 DAU.AS, TX 75202-2733



## NOV 092009
Ms. Lola Brown, (MC 206) State Implementation Plan Team Chief Engineers Office Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087 Dear Ms. Brown: Thank you for the opportunity to comment on the proposed revisions to the State Implementation Plan (SIP)for the HoustonlOalveston/Brazoria (HOB) ozone nonattainment area. We have reviewed the revisions and our comments are 

### enclosed. With this 

### enclosure we are providing conunents on: • HOB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard**(Project~o. 2009-o17-SIP-~)**  

### • HOB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard (project**~o.** 

### 2009-0**18-SIP-~)** 

### • Highly ReactiveVOC Cap 

### and Trade (HECT) 

### Program Cap Reduction and Allowance Reallocation (Rule ProjectNo. 2009-006-101-EN) • Mass Emissions Cap and 

### Trade (MECT) Program Cap 

### Integrityforthe HOB Eight-Hour Ozone Nonattainment Area 

### (RuleProjectNo. 2009-o19-101-EN) We look forward to working 

### with your agency to continue to reduceozone levels. If you have any questions, pleasecontactme or Carl Young of my staffat 

### 214-665-6645. Sincerely yours,

# 4~ Chief Air 

### Planning Section Enclosure

cc: 

### Walker Williamson (TCEQ) Devon Ryan (TCEQ) Jessica Rawlings (TCEQ)

### Enclosure Detailed Comments on Proposed Revisions to 

### the HoustonlGaivestonIBrazoria (HGB) 

### SIP With this 

### enclosure we are providing detailed comments on: • HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (ProjectNo. 2009-017-SIP-NR) • HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard' (ProjectNo. 2009-Q18-SIP-NR) , • Highly Reactive VOC Cap and 

### Trade (HECT) Program Cap 

### Reduction and 

### Allowance Reallocation (Rule ProjectNo. 2009-oo6-101-EN)

• Mass Emissions Cap and 

### Trade (MECT) Program Cap Integrity for the HGB Eight-Hour Ozone NonattainmentArea (Rule Project 

### No. 2009-Q19-101-EN)

, 

### UGH Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (project No. 2909-017 -SIP-NR) EPA appreciates the levelof analysis that 

### TCEQ has 

### completed in 

### the HGB proposed 

### 1997 eight hour ozone attainment demonstration. 

### It is clear that 

### TCEQ and 

### researchers 

### have continued to 

### advance the science of modeling the 

### Houston area and 

### also the 

### understanding of the 

### ozone . conceptual model forhow ozone is 

### formed in 

### Houston. TCEQ's analysis and analysis 

### of other researchers (NOAA, DOE,UT, etc.) 

### that 

### the 

### highest ozone concentrations observed in the 

### HGB areacan invariably be 

### linked to 

### transport 

### of the 

### industrial plumes emitted in the 

### vicinity of the 

### Houston Ship Channel (HSC) whichis a 

### key findjng 

### in 

### developing plans to 

### lower ozone levels in 

### the HGB area.

. 

### The 

### current modeling indicates several monitors (Deer 

### Park,' Bayland Park, and**Wallisvill~)** 

### will not be 

### in 

### attainment in 

### 2018 usingthe 2006 baseline DV. The future 

### ozone levels are 

### higher usingthe 2005 baseline DV. Overall, 

### the 

### modeling doesnot indicate ,the 

### area will 

### reach attainment, but the modeling (using a 2006 baseline DV) is 

### in the rangeofEPA's modeling guidance of when 

### Weight of EVidence can be 

### usedto potentially support an conclusion 'that attainment will 

### still be 

### achieved,

. Recent Ozone monitoring trends andthe mostrecent data 

### (2007-2009) add 

### significant support to the Weight Of 

### Evidence in 

### the proposed 

### 1997 8 Hour Attainment Demonstration SIP that 

### the

. areamight attain 

### and maintain 

### attainment of the standard. Recent trends however to 

### area ozone formation can also be 

### a function ofthe meteorology not being particularly conducive the last 

### few years. The meteorology in 

### combination with decreased local, regional, and 

### national emissions due to the economic downturn must also be 

### considered when evaluating the weight of evidence. One qualitative indication that someof the ozone decreases are likely driven by 

### meteorology and 

### economic impacts is that 

### many areas within Region 6 saw their 

### 4 th 

### Highs 

### drop 5-10 ppb thelast 

### 2 years and 

### onlyDFWand Houston areas have had 

### any potentially large local reductions other than 

### annual fleet 

### turnover. 'With ozone levels decreasing in 

### much of Region 6 thelastfew years, .. ,

### it is 

### importantto try 

### and consider how muchof the Houston monitoring trendsare due to control measuresandhow muchis dueto favorable meteorology and emissions decreases due to 

### regional and temporary. economic downturns. Even 

## with the recenttrend and 

### 2007-2009 preliminary. data that 

### indicates a DV of 84 ppb, EPA remains 

### concerned 

### that the area will 

### continue to attainthe 1997eighthour ozone 

### standard.



## . . . 

### The modeling is 

### based 

### on moretypical ozone conducive meteorology (2005 and 2006)in the 

### HOB 

### area. It 

### shouldbe noted 

### that the 

### modeling attainment test allows the 

### usc of as-year weighted average 

### that is 

### easierto show attainment than usingthe worst 3-yearDVs that include the base modeled years. The 

### 5-year weighting was selected by EPAto givesome averaging of meteorology. TCEQ originally modeledusinga 2005Center Weighted DV (CWDV) 

### that resulted in 

### highervalues than 

### the 2006 CWDV included 

### in the 

### proposal. Modeling using 

### both the more favorable 2006 CWDV and the 2005 CWOV indicates several monitors with2018 FutureDVs (FDVs) severalppb abovethe 84 ppb standard. The modeling is 

### indicating 

### that even with additional federal measures that 

### the area will not 

### reach 

### attainment by 2018. Future reductions not included in this 

### proposedSIPmay be necessary to achieve attainment of 

### the 1997 eight hour ozone standard 

### EPA's guidance 

### is to use 

### the modeling in a relativesensefor the monitored attainment 

### test and 

### also for 

### the areasoutsideof the monitors usingEPA's MATS software. In 

### the draft 

### Houston package,TCEQ 

### has not includedthe MATS software analysis in the 

### attainment sectionof the 

### SIP. The MATSsoftware analysis shouldbe included as part of the attainment write-up of the SIP to indicate**~e** 

### model's predictions in areas outsidethe grid cell arrays used in the 

### monitor attainment 

### test

. TCEQ has 

### utilized 

### their Potential Source Contribution Function(pSCF)to adjust 

### reported emissions in the 2006 special inventory from 12.44 tpd 

### of HRVOCs in Harris 

### County (7.39 tpd 

### for HECT sources and 5.05 tpd 

### for non-HECT sources) to 22.44 tpd 

### ofHRVOCs in Harris County. Thusadding 10 tpd 

### to reported 

### inventory values. The 

### HECTsources(exceptfor some 

### small emission sources) have been subject to 

### monitoring requirements since 

### 200516, so 

### the extra 'emissions from HECTcan only be from unmonitored sources or incomplete combustion from flares. Because unmonitored sourcesare 

### small the most likelysourceof emissions is flares. The proposedSIP assumes HECTsourcesemitan additional 6 tpd 

### of unreported HRVOC emissions. TCEQ should justify this 

### assumption.

. Withthe additional 6 tpd 

### TCEQprojectsfor the future 

### 2018 inventory 13.39 tpd 

### for BECT sources. 

### In addition TCEQ added tpd 

### frombanked emissions, bringing the total 

### to 15.39 tpd 

### for HRVOC emission in the HECT. Then,TCEQ assumed 

### that the HECTemission will be 

### reducedto the current 

### cap level of 10 tpd. 

### This reduction is 

### not supported 

### by any regulation or controlmeasureor enforceable commitment, and 

### therefore shouldnot be 

### included in the modeled projections. In 

### additionto om overall concern that the area maynot continue to attain 

### the standard and may

. . still 

### be in nonattainment withthe 1997eighthourozone standard in 2018we have provided

comments. on specific sections of the proposal package.

### Ozone Model 

### Performance Ozone model performance 

### (with the PSCF .emissions added)does fairly well 

### at getting the spatial location of ozone,but continues to underestimate the peak 

### ozone levels. This creates some concern 

### that the median emission adjustment 

### approach may not be yieldingenough emissions in the modelingto generate the peak 

### ozone levels. Model performance indicates 

### that the model was 

### .underestimating the peak 

### valuesof some 

### VOC species and also ozone peaks. The modeled peak 

### should theoretically be higher 

### than the monitored peak, since the 

### odds 

### that the 

### modeling domain peak 

### are goingto happen at 

### a monitor 

### are not 

### a statisticiilly high probability. TCEQ discussed in chapter 5 the 

### Issue of incommensurability which may explainwhy the 

### modeled values 

### seemed to overpredict Ethylene and Olefinspecies at 

### the 

### Wallisville monitor 

### as ,modeled values 

### represented a value ofthe 

### grid cell versus the 

### monitored 

### data that 

### reflectsa point 

### ,This concept of comparingmodelvaluesto monitored values 

### is discussed by 

### TCEQand they point out someof the' limitations of drawing 

### conclusions from the technique. 

### Overall the ozone model performance is 

### some of the best 

### modeling conducted for the Houston 

## area; but concerns about under-prediction bias raises 

### concern that 

### more emissions should be 

### includedin the base and also be 

### left in the future 

### year inventory. Using a 

### multi-year annual 

### meanmay result in an underestimation of the 

### actual emissionsthat occurred. TCEQ's modeling of increased flare 

### emissions 

### as a replacement for the PSCF emission reconciliationyieldedbetter ozonemodel performance 

### than the base 

### special inventory. 

### In addition to the many other scientificstudiesthat indicatethat flare emissions 

### are underestimated in the modeledand 

### reported emission inventories this 

### modeling sensitivity also 

### supports the 

### conclusion that :flares 

### are a significantsource of the underestimation of VOC emissions from industrial 

### sourcesin Houston. We note that TCEQ is 

### in the process of studying flare 

### operations 

### and is consideringthe optionof requiring 

### more monitoringand oversightof 

### flare operation in the future 

### dependentupon findings , of studies. For this and'otherreasons we 

### supporta commitment by TCEQ to 

### conduct a Mid Course Reviewusing photochemical modeling. . Attainment Demonstration and WOE

On 

### Page 5-8 of the 

### TCEQ concludes that 

### the retrospective modelingbetween 2000 and 

### 2006 emission levels "appears to underestimate the response to emissioncontrols". The 

### retrospective modeling is not conclusivein showingthe models responsiveness to emission controls 

### as the 

### DVs from the two periods are made 

### up of multipleyears worth of ozone data 

### with meteorology .from two differentsets of multi-yearperiods. Considering 

### that 

### the 2006 reported 

### emission .inventory is 

### havingto be adjusted 

### based on monitoring data 

### and using gaussianbasedmodelsto estimate emissioncorrectionlevelsfor groups offacilities in the same back trajeCtory, 

### it is 

### clear that 

### TCEQ maypotentiallyhave an approximate estimate ofthe multi-year mean emissions that occurredin 2005/6. Data from field studiesindicates significant variability,but overall a large underestimation of emissions. But to base an emission change comparisonwhen no one has ali , 

### accurate assessment of 2000 and 

### 2006 actual emission inventories raises many incommensurability issues. These incommensurability issuesinclude: comparing two different

### multi-yearperiodsof meteorology, using a multi-year meanwhen the 

### emission inventory demonstrates a fluctuation of data, 

### the PSCF is likely underestimating the 

### amount of reported 

### emissionincreases that 

### shouldbe done since it doesnot take 

### into account chemistrythat decreases emission concentrations betweenthe facility and 

### the monitor, an 

### adjustment 

### based on a 

### multi-yearmean overlooks variables that 

### would theoretically leadto higher .ozone pre-cursors on summer days/meteorological conditions. The 2006 imputed emission estimates appear 

### to be getting decent 

### model**performan~,** 

### but there is an under-prediction biasin peak 

### values that is 

### not necessarily 

### a model formulation 

### issue as an issue that 

### without detailed facility monitoring we . will never knowwhat 

### are the correct emissions to model. When 

### even the 2006 reported inventories ofVOCslHR.VOCs have to be 

### adjusted by factors of2x to 

### lOx (on a multi-year mean)to reflect the 

### monitored values,it is clear that the 

### bigger variable to 

### how the 

### modelis reactingto emission changes is 

### whether we are startingwiththe correctemissions. The 

### PSCF technique 

### that TCEQ 

### is utilizing to 

### adjust emissions (2x to 

### lOx reported level from 

### a 

### special inventory') is 

### gettingthe model performance to withinEPA's performance metrics of 

### +/- 20%and +/- 

### 350/0, 

### but the 

### amountof potential changein DVs from2000 to 

### 2006 is 

### a function of many variables that we do 

### not have sufficient data to 

### concludethe modeling is not reacting sufficiently, it is 

### more likely the 

### issue of not havingthe 

### correct emissions, It 

### does not 

### appear that enough certainty 

### exists 

### in the data 

### andthere 

### are incommensurability issues that 

### seem to make 

### it inappropriate to 

### conclude that 

### comparing modeling of 2000 and2006 reported emissions 

### (evenwith imputed 

### estimates) while m9deling the 2006 meteorology with 2000 meteorology indicates the 

### model is 

### not reacting sufficiently to emission 

### changes. EPA appreciates the 

### level of analysis that 

### TCEQhas completed in the 

### HOB ozone conceptual model and in 

### the 

### Corroborative analysison the 

### highest Ozone 

### values that impact 

### the 

### Design Values at 

### the monitors in Houston. The conclusionfromTCEQ's analysis and 

### analysis of other researchers (NOAA, 

### DOE, 

### UT, etc.) 

### that the 

### highest ozone concentrations observed in the 

### HOB 

### area (including 

### areas in the 

### Southeast, Southern, and 

### Southwestern portions of Houston) can invariably be linkedto transport of the industrial plumes emitted in 

### the vicinity ofthe 

### Houston Ship Channel is 

### a key finding 

### in 

### developing plans to lower ozone levelsin the 

### HOB 

### area. Chapter5 of the 

### proposal includes many ozone monitoring trends that 

### are very 

### interesting but 

### the linkageto what 

### is 

### causing the 

### recent decreasesin 2007-2009 values (2009 

### values need to 

### be . QAlQC'd by TCEQIEPA) is 

### missing. EPA's analysis (including informationprovided at 

### the April 2009 SoutheastTexas Photochemical Technical Modeling Committee meeting) is that 

### valuesin 2007 and 2008 were 

### influencedby higher than 

### average frequency of high speed 

### winds, less ozone conducive daysthan normal, and 

### emissions lower than 

### normal due to the economic downturn. Industry 

### representatives have commented in pastpublicmeetings that 

### their emissions have been 

### lowerthe last few years (starting in 2007) due 

### to economic influences 

### and 

### whenthe demandimprovesit is likelytheir emissionswill increaseoverthe levels in 

### 2007-2009. TCEQ's . HECT cap requirements 

### and monitoring requirements wereput in placeprior to the recentlarge

changes in 

### 4 th 

### highozonelevelsthat make up 

### the DV calculations. As ofNovemb.er 1 It 

### 2009 four monitors had preliminary 

### 2007-2009DVs of 84 ppb, butall monitors appeared to 

### be in attainment. 

### After 

### the economy gains strength 

### and 

### emissions likely increase and 

### whenless favorable meteorology occurs in the future, it seems unlikely that the 

### area will continue to 

### monitor attainment, especially at the Deer Park monitor. As 

### discussed elsewherepeak ozone

### levelsare heavily influenced by industrial emissions. Without further 

### reductions over existing 

### emissionlevels from industrial sourcesit seemsunlikelythat the Deer Parkmonitorwill maintain 

### attainment and monitors downwiild of the 

### industrial emissions will continue to have some high 

### readings. WhileFourthHigh valuesare down, the area still 

### has a numberofbigh days. In 

### 2009, eighthour values of the 

### monitors(FRM and 

### other) in 

### the Houstonarea bad 

### 22 monitors with 1 st 

### High values 

## equal or greater 

### than 90 ppb (9 monitors with valuesfrom 100-110 ppb), 12 monitorswith2 Dd 

### Highvalues 

## equal or greater 

### than- 90 ppb, and 12 monitors with3 M 

### Highs greater than 

### 84ppb. With this 

### many exceedances of the 

### standard at many monitors it is easyto see how the combination ofbigher emissions and less favorable meteorology couldresult in 

### the area not monitoring attainment. chapter 

### 5 of the proposal did 

### not includeany discussion of emissions 

### trends and 

### how they 

### correlatewith the 

### recentozonemonitoringtrends analysis. EPA's modeling and 

### attainment guidanceindicates that 

### monitoring and 

### emission trends 

### should be 

### included as one ofthetbree areas that 

### should be 

### covered in WOE (including pages .99, 101-103 of 

## the 2007 modeling 

### and attainment guidance). In 

### addition to emission 

### trends analyses and 

### comparisons/correlations of emissionstrends and 

### ozone trends, 

### expected 

### future emission trends 

### (including the 

### major categoriessuch as 

### point area, 

### nonroad, onroad, etc.) 

### shouldbe included in 

### this analysis to help correlate that 

### future 

### emission reductions will 

### resultin lowerozonevaluesin the 

### future. Since TCEQand othershave concluded that the 

### valuessettingthe DV at monitors in the 

### southwest, southernand southeastern regions of Houstonare heavily impacted by emissions from 

### the HSC industrial emissions, a focus on future 

### changes 

### expected in HSC industrial emissions seems centralto the 

### argument thatthe HGB area will be 

### in 

### attainment in 

### the 

### future. This specific analysis of recent historical emissions and 

### monitoring 

### trends and future 

### emission 

### trends that impact the area's DV with expected impacts 

### on ozonelevels is a verykey WOE element that allowed us to-move forward with approval of the 

### DFW 19978-hour Ozone SIP. Including these analyses in 

### your WOEwouldhelp to make sure that youcoverthe three main 

### areas discussed in 

### the 

### WOE guidance. Summary 

### Fromthe information that TCEQincludedin the 

### SIP proposal, it 

### is obviousthat a lot ofhard work has 

### gone into 

### the modeling, WOE and 

### other analyses to better understand the 

### phenomena that 

### result in 

### ozone exceedances in 

### Houston. We appreciate the hardwork of the manyTCEQ people and researchers that 

### have contributed to the development of the draft 

### Houston SIP. Other than 

### the fleet 

### tumoverand other federal measures between2009and 2018,TCEQ has 

### not proposed in this SIP emission reduction requirements that will 

### lower emissions belowcurrent actuallevels. Without further reductions in the 

### HSCarea it is difficult to 

### see how the 

### Deer Park monitor and other monitors 

### will remain in 

### attainment when economic conditions improve and 

### less favorable meteorology occurs. EPA encourages TCEQ to 

### consider additional controls to 

### insure the 

### area 

### will continue to be in 

### attainment of the 

### 1997eighthour standard. 

# -l

# I

iI

## I

### RACM 

### TCEQ and othershave shown that 

### the 

### HOB Nonattainment areais heavily influenced by the emissionsfromindustryin the 

### Southeast quadrant of Houston (including industry around the' Houston Ship Channel). Therefore reductions 

### in industry emissions would 

### be most effective in 

### advancing attainment. Additional monitoring and requirements forflareswouldaid in improvingthe emission inventory and 

### alsocouldleadto real atmospheric reductions of ozone pre-cursors. We supportTCEQ'sFlareTaskForce initiative and 

### hope 

### it resultsin better flare 

### operations and 

### reduced emissions in 

### the future. The 

### proposed reduction and 

### reallocation of the 

### Banis county HRVOC cap does notrequire HRVOC levelsto be reduced below currently reported levels. The 

### current 25% reduction in 

### the HECT Capwould still be higherthan 

### reported emissions and would allow for growthand



### . allowances for upset conditions. 

### In essence, the 

### proposed25%HECT Cap 

### reductionwould

allow HRVOC emission increase at 

### HECT applicable facilities compared to the highest annual actual HECT emissions. 

### As part 

### of it's RACM analysis, TCEQ should consider whetherreductions in "actual" 

### HRVOC emissionscould accelerate attainment. Furthermore, TCEQ should explain why the 

### reductions can not be implemented sooner than 

### the proposed 2015-2017 timeframe. Mid-Co 

# mse Review We recommend that the attainment demonstration include a TCEQ commitment to a mid-course review of the 

### attainmelit demonstration. Because ofthe uncertainty in 

### long term 

### projections, we believea viable attainment demonstration that 

### relieson weightof evidence Should contain provisionsfor periodicreviewof monitoring, emissions, and modeling data. Clearly, current 

### monitoring trends 

### would mdicate significant progress is being made. Undoubtedly, control measures implemented bythe Texas andFederal government have contributed to this 

### progress; Other factors, however, haveplayeda role such as the economic downturn and 

### favorable meteorology. The current modeling show 

### several monitors exceeding the 

### 1997 standard. 

### The differences between the modeling and monitoring accentuate the overall uncertainty in long term 

### projections. The 

### mid-course review wouldshow whether the 

### adopted control measures are sufficient to reach attainment by 

### the 

### area's, attainment date 

### (basedon photochemical modeling), or that additional control measures are necessary, We recommend that 

### thereview be 

### completed by 

### December 2013. We also 

### anticipate that SIPsfor a revised ozone standard would be 

### due in 

### December 2013, so that 

### the review 

### couldbe done in conjunction witha SIP for the 

### revised ' standard. 

### NitrogenOxides (NOx) 

### Reasonable Available Control Technology (RACD Determination (Section 4.4.2. page 4-7 and Amxmdix 

### D) 

### Please confirm that 

### all 

### NOx point sources in the HOB area withthe potential to emit25 tons/year or more have been included in 

### the list 

### of sources that the State has included in its 

### evaluation for RACT purposes.

# As control technology is 

### dynamic and could change with time,pleaseconfirmthat the level of NOx controlfor affected NOx sources in 

### the 

### HGB area still represents RACT today. RACT should 

### be federally enforceable. Pleaseexplainwhy TCEQ believes it is appropriate to use a New Source Review permit condition for a glass manufacturing facility in 

### the affected area to implement RACT. Pleaseprovidea copyof the 

### final permit Volatile Organic COmPound <YOC) 

### RACT Determination (Section 4.4.3. pages 4-7 to 4-9 and**~~~** . 

### We have reviewed this actionwithrespect to 

### the 

### Clean Air Act (CAA) andthe Control Techniques Guidelines (CTGs) issued by 

### EPA 

### in 2006,2007, and 2008,and have the following comments. 

### WorkPractice Requirements: For a number ofCTG categories, TCEQhas chosennot to adopt the 

### recommended work practices. For all 

### applicable CI'Gs, EPA continues to 

### believework practice requirements 

### provide reasonable, cost effective ways 

### to reduceemissionsand that these control requirements should be 

### met In order to 

### meet RACT requirements, the 

### state should 

### either adopt rules implementing the 

### workpractice requirements, or provide analysis demonstrating that 

### the 

### requirements are satisfiedby existing 

### federally enforceable roles. 

## cm categories: Industrial Cleaning Solvents, Miscellaneous Industrial Adhesives. Large Appliance Coatings. Metal Furniture Coatings and 

### Miscellaneous Metal and 

### Plastic Parts Coatings (section4.4.3.3,and Appendix D). For these :five CTGs, Texas 

### has neitheradopted rules nor provideda negative declaration. 

### In 

### order for the HGB area to 

### meet the 

### requirements for RACT (40 CFR 51.912), the 

### state will 

### need to 

### complete RACT determinations and 

### take appropriate action for the CTG categories of Industrial Cleaning Solvents, Miscellaneous Industrial Adhesives, Large Appliance Coatings, Metal Furniture Coatings and 

### Miscellaneous . Metal and Plastic Parts Coatings. EPA will 

### be 

### ableto consider approval of the 

### VOC RACT

update onlyfor those CTGs that 

### have been 

### thoroughly addressed. Werecognize that 

### EPA has 

### not yet responded to 

### the TCEQletter of December 8,2008 concerning the 

### CTG documents for Large Appliance Coatings, Metal Furniture Coatings; and Miscellaneous Metaland PlasticParts Coatings (section 4.4.3.3, and 

### AppendixD). Whilethe new CTG documents for thesesource categories recommend morestringentlimits "for general use coatings, there are some specialty categories for: whichthe new CTGs recommend limits that 

### are less stringent than 

### the general use limits 

### established in 

### the guidance from the 1970s. For some of the subcategories withinthese CTGs, the limits in 

### the new CTGs 

### are less stringent than 

### the approved TexasSIP so it is possiblethe new 

### limitswillresult in 

### increased emissions. 

### In general, EPA expects the 

### limits in 

### the CTG to 

### result in 

### reductions in 

### VOCs but it is unclearfor specific states 

### or areaswhetheroverall reductions will 

### occur. We believe that 

### Texas has at 

### leasttwo options for moving forward withthe specialty coating typesdiscussed above. The state 

### couldleavethe limits in 

### placefor the specialty categories where 

### the existing limits 

### are more stringent than 

### the limits in 

### the CTGsor the 

### state couldrelax the 

### limits consistent with the 

### new CTG 

### in whichcase the statewouldhave to 

### provide additional : ! ,

; 

### .

', 

# I

### 'analysis to 

### show compliance with 110(1) 

### of the CAA. We notethat Texas is not required to 

### adoptthe less stringent limits in 

### the CTG. The 

### CTG provides recommendations, butdoesnot bind states to 

### adopt specific limitsor requirements to 

### meet RACT. If 

### the existing Texas roles as they apply to 

### specialty categories 

### are more 

### stringent than 

### the limits 

### recommended in the CTG, the state 

### could choose to 

### submitthem 

### as meeting the RACT requirement, 

### and, assuming all other requirements 

### are met, 

### we anticipate that 

### we would be 

### able to approve them 

### as meeting RACT for the source 

### categories addressed by the CTGs. The statewouldstillneed to 

### evaluate the more stringent recommendations for general 

### use categories and adopt 

### them 

### as appropriate. If 

### Texas chooses to relaxlimitsfor specialty coatings that are 

### in 

### the approved SIP consistent with the 

### recommended limits in 

### the CTGs, 

### the statewould need 

### to demonstrate under section 110(1) that the 

### SIP 

### as revisedwouldnot interfere with attainment of or reasonable further progress toward attainment of the National Ambient Air 

### Quality Standard 

### (NAAQS) or interfere withanyother applicable requirement of the CAA. 

### In general, if 

### a submitted revision achieves the 

### sameor greater 

### emission reductions as the approvedSll' 

### within the same 

### timeframe as provided under the existingplan,wehave beenable to 

### approve the revisionas meeting section 110(1). 

### Flat WoodPaneling Coatings (section 4.4.3.1 and Appendix D). Regarding workpractice requirements, please 

### see the comment above. Fiberglass Boat Manufacturing Materials (section 4.4.3.2 and 

### Appendix D). 

### Forthe Fiberglass Boat Manufacturing Materials 

### source category TCEQ has identified no facilities 

### in HOB subject 

### to this 

### CTG (pages 

### 4-8, D8 and 

### D-9). However TCEQ is 

### not making definitive negative 

### declaration for this 

### source category. Instead, 

### the TCEQ ''has 

### detemrlned that 

### implementing the recommended controls in the Fiberglass Boat Manufacturing Materials CTG document would neitherresult in 

### substantive VOC reductions nor be 

### economically feasible." The 

### proposal relies in part 

### on EPA's prior guidance, "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, Clarification to Appendix D of November 24, 1987 Federal Register", issued May 25, 

### 1988. 

### ID. particular, pleasesee Attachment 2 

### of the guidance, for an 

### Example 5% 

### Rule Calculation. This 

### calculation should be 

### based specifically on sources in 

### the 

### Houston area 

### Wedo not. believe the TCEQ's interpretation of this 1988 guidance 

### is 

### correct. EPA continues to believe that theseare costeffective controls. To meet VOC RACT requirements this 

### category needs to 

### be addressed. Flexible 

### Packaging Printing Materials (section 4.4.3.2and Appendix D). Regarding work practice requirements, pleaseseethe comment above. Paper, Film, and 

### Foil Coatings (section 4.4.3.2 and 

### Appendix D). 

### Regarding workpractice requirements, pleaseseethe comment above. Lithographic Printing Materials and 

### Letterpress Printing Materials (section 4.4.3.4 and 

### Appendix D). Detailed comments regarding this are included in 

### a separate letter addressing theserule revisions. (Rule Project 

### No. 2008-019-115-EN). Automobile and 

### Light-Duty TruckAssemblyCoatings (section 4.4.3.1, and 

### Appendix D). No comments.

### Transportation Control Measures (Section 4.6.2.1 and Amxmdix G) , Theplan specifies 

### that once Transportation Control Measures (TCMs) are included in the SIP, the 

### Houstonareais legallyboundto implement eachof these control measures in a timely manner. Please include estimated 

### time:fram.es for initiation and completion of the candidate TCMs listed 

### in Table1 of Appendix G.

HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard (project**N~.** 

### 2009-818-SIP-NR) 

### The discussion of the updatedpoint source 2002baseyear inventory 

### states that 

## voc emissions were adjusted 

### to account for unreported VOC emissions (page 2-2). Please further 

### describe how 

### the unreported emissions were' accounted for.

, One 

### severeozone nonattainment areaSIP requirement is to identify and 

### adopt transportation

. control measures (TCMs) that 

### would offset any growth in emissions from growth 

### in vehicle

.



# . mileS traveled 

### (VMT) or numbersof vehicle trips (CM section 182(d)(l)(A». The analysis providedin the Reasonable Further Progress SIP indicates that 

### the predictedgrowthin VMTin the 

### area is not 

### expected to result in a growth in motor vehicle emissions (tables2-14 and 

### 2-16). Pleaseconfirm that 

### the predietedgrowth 

### in VMTin the 

### area is 

### not expected to resultin a growth

, in motor vehicle emissions and 

### that 

### TCMsarenot neededto offset growth 

### in VMT..

BighIy-Reactive Volatile 

### Orgame CompouDd Emissions Cap and Trade Program (project 

### No. 2009-G06-101-EN) 

### Pleaseconfirm that 

### the 

### non-reportable emission events that 

### exceedthe emissionevent set-aside in section 101.396(c) will be 

### deducted 

### from the individual site's compliance account no later than 

### March31 ofthe year following the applicable calendar-year controlperiod. This approach

.is consistent with 

### the approach outlined at 

### section 1 O1.396( d) for reportable emission events that 

### exceedthe set-aside. The roles should be 

### revised to 

### clearlyreflectthis approach as well
Mass Emissions Cap 

### and Trade Program (project No.**2009~19-101-EN)** 

### Pleaseexplainwhythe revised roles at 

### section I01.353(b) do 

### not require 

### minor sources 

### that submit late ECT-3 forms to obtain allowances 

# from existing 

### sources. This exemption forminor sources could increase the overallcap and jeopardize the 

### attainment demonstration modeling for

, the 

### HGB area.'

. .Reference Number INDEX OF ORAL TESTIMONY

Submitted by

No oral testimony was received pertaining to this proposal.P.1


## TEXAS COMMISSION ON ENVIRONMENTAL QUALITY PUBUC HEARING REGISTRATION October28, 2009, 2:00 p.m, Houaton-Galveston Area Council, 355511mmons Lane, Hou8lDn Rule Project No.: 2009-017-8IP-NR (ADSIP Revisions), 2009-018-SIP-NR (RFPSIP Revisions), 2009-006-101--EN (HECT), 2009-Q19-101-EN (MECT), 2008-Q19-115-EN (Offset Utho) ,**~IIIJ** 

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5
6 TRANSCRIPT OF PROCEEDINGS BEFORE THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY HOUSTON, TEXAS 1

7 PUBLIC HEARINGS ON PROPOSED REVISIONS TO 30 TAC CHAPTERS 101 AND 115 8 9 10 PUBLIC HEARING 11 WEDNESDAY, OCTOBER 28, 2009 12 13
14 15 BE IT REMEMBERED THAT AT 2:00 p.m., on Monday, 16 the 28th of October 2009, the above-entitled matter 17 came on for public comment at 3555 Timmons Lane, 18 Houston, Texas; and the following proceedings were 19 reported by Karen L. Goh, a Certified Shorthand Reporter 20 of: 21 22 23 24 25

2

1
2 TABLE OF CONTENTS PAGE

### 3 PROCEEDINGS, WEDNESDAY, OCTOBER 28, 2009 3 4 OPENING REMARKS BY TEXAS COMMISSION ON ENVIRONMENTAL QUALITY (PATTERSON) ............•...... 3 5 

### PRESENTATION ON BEHALF OF PRINTERS' SERVICE 6 ( SADLER) . . . I • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 5 

### 7 PRESENTATION ON BEHALF OF PRINTING INDUSTRIES OF THE GULF COAST (ELDRIDGE) ..........•............. 8 8 

### PRESENTATION ON BEHALF OF a-HOUR OZONE SIP 9 COALITION (HENDLER) ..........................•..... 14 10 PRESENTATION ON BEHALF OF KANEKA TEXAS CORPORATION ( GARRI S I) ••.....•........•......................... 18 11 

### PRESENTATION ON BEHALF OF BIGLER, LP 12 (LIGHTFOOT) •.•.••••..••••.......•.................. 22 13 PRESENTATION ON BEHALF OF ENVIRONMENTAL DEFENSE FOND { CRA.FT} • • • • • . • • • .. . . . . . . . . . . • • • • • • • • • • • • • • • • • • • 25 

### 14 PRESENTATION ON BEHALF OF THE CITY OF HOUSTON 15 (PEPPLE) .......................................•... 26 

### 16 PRESENTATION ON BEHALF OF LEAGUE OF WOMEN VOTERS OF HOUSTON {BLACKBURN) .....•.........••....•.•..... 27 17 

### REPORTER'S CERTIFICATE ...........•................. 30 18 19 20 21 22 

### 23 24 25

3

1
2
3

4 5
14: 02: 05 6 

### PRO C E E DIN G S WEDNESDAY, OCTOBER 28, 2009 (2:00 p.m.) OPENING REMARKS ON BEHALF OF TEXAS COMMISSION ON ENVIRONMENTAL QUALITY MR. PATTERSON: Good afternoon. I'd like to

### 14:02:06 7 14:02:09 8
14: 

### 02: 12 9 14:02:16 10 14:02:18 11 

### 14:02:20 12 14:02:22 13 14:02:26 14 14:02:30 15 14:02:34 16 14:02:38 17 14:02:41 18 14:02:45 19 14:02:49 20 14:02:49 21 14 : 02 : 49 22 14:02:49 23 14:03:03 24 14:03:07 25

14:03;08 1 14:03:10 2 14:03:12 3 14:03:15 4 14:03:15 5 14:03:15 6 14:03:28 7 14:03:31 8
9 

### 10 welcome you to a public hearing being conducted by the Texas Commission on Environmental Quality or TCEQ. My

name is Brad Patterson. I work at the TCEQ's Office of Public Assistance. I'm going to introduce the folks that are here from the Agency but first, I have a couple of announcements. First of all, if you have a cell phone or a paging device, if you would please turn it off or put it on silent mode, we would appreciate that. Secondly, the facilities are right out this back door where you came in earlier. So with that, I'll
go ahead and start making introductions. From the Texas Commission on Environmental**Quali~y,** 

### we have David Brymer, who is the director of the Air Quality Division, Kim Herndon, who is the Assistant Air Quality Division director. We have Vincent Meilleri Jay Tonne, Dick Karp, Lola Brown, and Walker Williamson, who are all with the Air Quality Division as well. And at the registration table when you came in earlier, we have Emily Boyd and Faye Lu (phonetic), who are both with the

4



### Office of Public Assistance. We are here this afternoon to receive oral and/or written comments on the proposed Houston-Galveston-Brazoria or HGB Attainment Demonstration State Implementation Plan or SIP revision and the Reasonable Further Progress or RFP SIP revision for the 1997 eight-hour ozone standard and proposed revisions to 30 Texas Administrative Code or T-A-C or TAC Chapter 101, General Air Quality Rules, Subchapter A, Definitions, and Subchapter H, -Emissions Banking and11
12 13 14 15 16 17 18 19 20 21 22 14:04:19 23 14:04:22 24 14:04:23 25

14:04:26 1 14:04:29 2 14:04:31 3 14:04:34 4 14:04:37 5 14:04:40 6 14:04:44 7 14:04:48 8 14:04:50 9 14:04:53 10 14:04:56 11 14:04:58 12 14:05:00 13 14:05:04 14 

### Trading, Division 6, Highly Reactive Volatile Organic Compound Emissions Cap and Trade or HECT program, and Division 3, Mass Emissions Cap and Trade or MECT program, and to 30 

### TAC Chapter 115, 

### Subchapter E,
Division 

### 4, Offset Lithographic Printing and the corresponding revisions to the state implementation plan under the requirements of Texas Health and Safety Code, Section 382.017, 

### Texas Governmental Code, Chapter 2001, 

### Subchapter B, and finally, 40 

### Code of Federal Regulations, Section 51.102, 

### of the United States Environmental Protection Agency concerning state implementation plans. If you intend to present oral comments and have not already signed in at the registration table, please do so now. We also have copies of the hearing

5



### notice that was provided that you may take with you on the registration table. So if you're planning on sending in written comments, or submitting comments via the rules e-comments system, you can quickly find the information to submit those comments. We will 

### continue accepting comments on these rule packages until November 9th, 2009. 

### This hearing is 

### structured strictly for receipt of oral or written comments on these five proposals. There will be no open discussion during the hearing. However, if anyone still has additional questions regarding the proposals, there will be an opportunity to talk to staff after the hearing

-- after

we take the original oral comments. We will now be receiving comments in the

### 14:05:06 15 14:05:09 16 14:05:13 17 14 : 05: 15 18 14:05:27 19 14:05:29 20 14:05:34 21 14:05:37 22 14:05:41 23 14:05:42 24 14:05:47 25

14:05:50 1 14:05:53 2 14:05:57 3 14:06:00 4 14:06:04 5 14:06:06 6 14:06:09 7 14:06:11 8 14:06:14 9 

### 14:06:18 10 14:06:22 11 14:06:25 12 14:06:28 13 14:06:31 14 14: 06: 34 15 14:06:38 16 14:06:40 17 14:06:43 18 order in which you registered. When I call your name, please come up to the podium, speak directly into the microphone, state your name and who you represent when
you give your comments. I will begin with Jeff Sadler. MR. SADLER: Thank you. I'd like to comment

on the Chapter 115, proposed for Litho Offset. My name is Jeff Sadler, I'm a regional representative for Printers' Service. We're the largest provider of salt and base cleaning solutions to the printing companies in Texas and in the Gulf Coast region. I work hands-on myself

-- with the companies who will be affected by the

6



### changes that are outlined. We've taken it upon ourselves to evaluate several different products that represent the proposed 70 percent or lower VOC content. Our focus, initially, was to find out how effective they

were compared to the current products being used, and the overall cost rather than just price per unit of the products that were considered. These are five of the considerations that we found. 70 percent 

### voe products were considerably slower
to clean, and evaporate from the surface being cleaned

on the printing equipment. 

### An increased amount of 20 to 40 percent of the cleaning solution was used in order to effectively clean the printing blankets and the cylinders on the equipment. There was also a considerable amount of residual

-- residue left over in the roller train and on the cylinders of the presses. 

### An increased amount of solvent and water was needed to

remove this residue.

### 14:06:45 19 14:06:48 20 14:06:53 21 14:06:55 22 14:06:58 23 14:07:02 24 14:07:05 25

14:07:09 1 14:07:12 2 14:07:16 3 14:07:19 4 14:07:23 5 14:07:24 6 14:07:28 7 14:07:33 8 14:07:35 9 14:07:38 10 14:07:47 11 14:07:48 12 14:07:55 13 14:07:58 14 14:08:00 15 14:08:04 16 14:08:09 17 

### 14:08:11 18 14:08:14 19 14:08:15 20 14:08:19 21 14:08:21 22 This caused an increase of amount of solvent
usage by 20 to 30 percent. Some of the lower 

## vee solvents that we looked at made it necessary to use an additional rinsing agent to help dissolve and remove the residue left behind in the system, and this, of course, adds an additional step in the process, taking time and incurring an additional expense, and an additional

7



### product being purchased by the printing company. There

are several companies who will be affected by the new ruling that will have automatic wash systems in place already, and in working with those wash systems, they

run products that have been thoroughly tested and approved by the system manufacturers. These new proposed lower 

## vee products will need to be evaluated on the systems themselves from the manufacturers. There was an actual price increase of $325

to $400-increase of $325 to $400 per drum of solvent comparing the current level cost, typical product being used around the S500-per-drum level to comparing that with the new lower voe 

### solvents that are in the range of $825 to $900 per drum. That should be a consideration when asking these companies to change over to the 70 percent or lower 

## vee product. So in conclusion, I'll end with this. The lower vee 

### solvent products will cost printing companies affected by this ruling a considerable amount of money. The price per unit, as you've seen, is 20 to 40 percent higher. The less effective printing solvents will require a higher volume of chemistry to be used,

### 14: 08: 24 23 14:08:28 24 14:08:31 25

14:08:33 1 14:08:38 2 14:08:41 3 14:08:45 4 14:08:48 5 14:08:53 6 14:08:55 7 

### 14:08:58 8 14:09:03 9 14:09:04 10 14:09:05 11 

### 14:09:12 12 14:09:12 13 14:09:19 14 14:09:21 15 14:09:24 16 14:09:28 17 

### 14:09:32 18 14:09:34 19 14:09:38 20 14:09:38 21 14:09:40 22 14:09:43 23 14:09:45 24 14:09:47 25 somewhere in the neighborhood of 20 to 30 percent. Additional rinsing agents will need to be used in many instances. These will slow the process, increase the

overall cost. The several different types of automatic cleaning systems will have to be reevaluated, new testing will have to be done for compatibility, and the
necessary changes driven by this rule will cause a great deal of disruption, and cost an overall amount of high

revenue to the printing companies being affected for a very small amount of impact on the local environment. Thank you. MR. PATTERSON: Thank you, sir. Next up, I have Patty Eldridge. MS. ELDRIDGE: Good afternoon. My name is Patricia Eldridge. I'm a director of Printing Industries of the Gulf Coast. We're also' known as PIGC. PIGC is an affiliate of Printing Industries of America which is the largest trade association for the printing and graphics industries with over 11,000 member companies worldwide. PIGC's purpose is to service the official representative of the graphic communications industry in the Texas Gulf Coast region and further the

cause of the industry in the areas of business, government, and to the general public. I'd like to thank you, the TCEQ, for allowing me to speak with you today on our comments with our comments on this proposed rule. The association will be submitting formal written comments 8

### 14:09:50 1 14:09:54 2 

### 14:09:56 

### 3 14:09:59 4 14:10:02 5 14:10:06 6 

### 14:10:09 7 14:10:12 8 14:10:15 9 14:10:19 10 14:10:21 11 14:10:24 12 14:10:28 

### 13 14:10:30 

### 14 14:10:34 15 14:10:37 16 14:10:40 

### 17 14:10:43 18 14:10:47 19 14:10:50 20 14:10:53 21 14:10:56 22 14:11:02 23 14:11:06 24 14:11:08 25

14:11:12 1 14:11:15 2 as well. While our written comments will focus on several specific sections of the rule, today, I would like to focus my comments and concerns in two main

areas. The first is the economic impact on businesses by the adoption and implementation of the proposed rule, and second, the overall benefit to the public health, given the number of businesses affected by the rule. First, I'd like to provide a brief overview of the industry. The printing industry covers multiple
processes, of which lithographic is just one. Most print operations utilize more than one process in their business with lithography being the most common. In fact, 75 percent of all print businesses have lithographic operations. It is also an industry of small businesses. By the government definition of small business, Which is firoms with less than 100 employees, the general**camme~cial** 

### printing industry is 95 percent small businesses, of which approximately 65 percent of those have ten or fewer employees. There are less than 20 print facilities in the Texas Gulf Coast region that have more than 100 employees. These small businesses have limited financial and technical resources available to them. As

a result, more flexibility and options must be offered
to them. And then, there's the current economic

10

situation. Printing has traditionally been one of the first industries impacted by economic downturns, and one 914:11:18 3
14:11:21 4 14:11:24 5 14:11:28 6 14: 11: 32 7 14:11:35 B
14:11:38 9 14: 11: 42 10 14:11:46 11 14:11:50 12
14: 11: 52 13
14:il:57 14 14:12:01 15 14: 12: 02 16 14:12:05 17
14:12:08 18 14:12:10 19
14:12:14 20 14:12:18 21 14:12:21 22 14: 12: 25 23 14:12:28 24
14: 12: 32 25

14: 12: 34 1 14:12:38 2 14:12:42 3 14:12:45 4 14 : 12: 48 5 14:12:50 6 

### of the last to recover. As businesses scale back on their advertising/marketing promotions, the printing industry is hit hard by' greatly reduced print sales and volume. Profit margins in the graphic cormnunications industry are historically low compared to many other industries, but have really dropped since 2007. 

### From 2008 

### to 2009, 

### these margins have gone from 3.1 percent down to 1.6 

### percent, so almost cut by 50 percent. All of these factors are placing a tremendous burden on companies, making it difficult to absorb higher costs and cost-related activities: Specifically, the mandated low 

## vee requirements for fountain solutions and cleaning solvents from the proposed rule will add undue hardship on these firms. The rule summary published indicated a conservative six-percent price increase for these products. The actual price increase is more in the 40-percent range. That means if we use the 768-gallon-per-year threshold with the current average cost at 15 

### dollars per gallon of**solvent~** 

### a company would see an increase of $4,600 

### a year for the same amount of the low 

## vee product. Another aspect is 

### the overall effectiveness of low 

## voe solvents and cleaning

11



### agents. In general, low 

## vee cleaners have not had the

same cleaning ability as a traditional higher 

## vee product. This 

### means in order to achieve the same result, which is 

### a clean roller or blanket, a larger volume of the cleaner will be needed as well as an increase in the amount of time needed to adequately

### their labor cost $60 

### to $80 per day, $300 to $400 

### a week, $1,200 to $1,600 a month, or $14,400 to $19,200 

### annually. clean the rollers and blankets. So, now, a wash-up that would take 10 to 15 minutes, would now take, easily, 20

to 30 minutes. At the current average press operator rate of $21.64 an hour, it could add $45 per wash-up to labor

cost. Given the number of jobs that are run every day

on an average and the number of presses companies

The 4,600-dollar-a-year cost increase in products is for the equivalent amount for high 

## voe cleaner. That number does not take into account the increased amount of low 

## voe solvent needed to clean the

same amount of presses. In just adding the 4,600-dollar product cost increase to the $14,400 

### to $19,200 

### labor
cost increase, this adds $19,000 to $23,800 to a company's expenses. In discussing the use of low 

## voe 14: 12: 53 7 

### 14:12:57 8 

### 14:13:00 9 

### 14:13:01 10 14:13:05 11 

### 14:13:11 12 14:13:15 13 14:13:15 14 14:13:19 15 14:13:24 16 14: 13: 30 17. 14:13:31 18 14:13:31 19 14:13:36 20 14:13:38 21 14:13:42 22 14:13:46 23 14:13:52 24 14:13:57 25 have

-- again, on an average they will be increasing

14:14:04 1 14:14:05 2 14:14:08 

### 3 14:14:11 4 14:14:14 5 14:14:16 6 14:14:21 7 

### 14:14:21 8 14:14:25 9 

### 14:14:28 10 12

solvents and cleaning products with printers, the feedback has been, by and large, negative. Those who have tried them have mentioned that they do not work as well as the higher 

## voe material. To quote one printer, "Our guys that have said they"

-- meaning the more expensive washes

-- "don't do as good a job." Low vapor pressure solvents, although higher in cost than traditional cleaning solvents, is a more effective alternative. The product cost increase is not as high

as low 

## voe products, and most press operators do not see14:14:33 11 14:14:33 12 14:14:36 13 14:14:39 14 14:14:43 15 14:14:46 16 14:14:48 17 14:14:51 18 14:14:55 19 14:14:58 20 14:15:03 21 14:15:05 22 14:15:08 23 14:15:11 24 14:15:13 25

14:15:17 1 14:15:20 2 14:15:24 3. 14:15:27 4 14:15:31 5 14:15:33 6 14:15:35 7 14:15:38 8 14:15:41 9 14:15:44 10 14:15:45 11 14:15:48 12 14:15:51 13 14:15:51 14 

### the greatly increased wash-up time that they experience with the low VOC solvents. Reducing the amount of alcohol substitute to three percent by weight with no alcohol in the fountain solution will be a tremendous change of production for
most operations. It's not simply a matter of changing

one product out for another. You're changing a process. Printing is not just a mechanical process. It's a chemical process as well. Equipment must be modified in order to accommodate the chemistry change, and press operators must be trained in new procedures. In any case, all of these increased expenses will need to be passed on to the consumer. In addition, given the economic climate and the projection of its duration, these requirements could drive more printers

13



### out of business. No business, no jobs, no sales tax
revenue, no property tax revenue. Incorporating best management practices such as towel-handling procedures will be a viable low-cost alternative while reducing emissions. The 1990 

### Federal Clean Air Act states that air quality standards must be established. These standards must be obtained and maintained to protect health. When looking at the impact of the printing industry on the overall air emission from the Dallas/Fort Worth and especially the Houston/Galveston

area, it's not a significant contributor. The Houston/Galveston area has perhaps five
to seven lithographic facilities that are permitted and already using (inaudible). We estimate that 80

### 14:15:59 15 14:16:01 16 14:16:04 17 18 19 20 21 22 14:16:22 23 14:16:25 24 14:16:29 25

14:16:32 1 14:16:35 2 14:16:37 3 14:16:40 

### 4 14:16:43 5 14:16:46 6 14:15:49 7 14:16:50 

### 8 14:16:53 9 14:16:56 10 14:16:59 11 

### 14:17:00 12 14:17:03 13 14:17:05 14 14:17:10 

### 15 14:17:11 16 14:17:11 17 14:17:29 18 companies from the Houston/Galveston region have greater than three tons per year emissions. Approximately 70 percent of these firms or 56 of them will be below the 10 tons of emissions. Given the attempts of the industrial (inaudible) of the Houston/Galveston area in the petrochemical/energy industries, the printing industry is a minor source of emissions. Although there are several portions of the rule we can support since they follow the EPA's 2006 Offset Lithographic and Letter Press Printing CTG, there

are a few noted exceptions TCEQ would like to adapt that

14

are of concern to the printing industry. The items such

as the lower VOC cleaning solvents due to their higher
cost and reduced effectiveness will significantly increase production cost. Given the relatively low numbers of firms that will be affected in the Houston/Galveston area, the overall health benefit to the general public is negligible. The minor environmental benefit does not outweigh the high cost of small businesses. Printing Industries of the Gulf Coast is ready to continue to work with the TCEQ in finding solutions that "are responsible, fair, and equitable for all parties concerned, and we thank you for the opportunity to review and comment on this vital piece of proposed legislation. Thank you. MR. PATTERSON: Thank you. Next up, I have Liz Hendler. MS. HENDLER: Good afternoon. My name is

### 14:17:29 19 Elizabeth Hendler. I'm the project manager for the 14:17:30 

### 20 8-Hour Ozone SIP Coalition. The 8-Hour SIP Coalition is 14:17:36 21 comprised of seven large member companies with more than 14:17:39 22 15 facilities from the energy industry with a common 14:17:42 23 interest in achieving the goals of cleaner air and a 14:17:45 24 strong economy for Texas. The Coalition's refining, 14:17:45 25 petrochemical, and electric utility members have been

15

14:17:52 1 14:17:53 2 14:17:55 3 14:18:00 4 14:18:02 5 14:18:05 6 

### 14:18:09 7 14:18:12 8 14:18:15 9 14:18:17 10 14:18:17 11 

### 14:18:24 12 14:18:27 13 14:18:31 14 14:18:33 15 14: 18 : 37 16 14:18:41 17 

### 14:18:45 18 14:18:47 19 14: 18: 47 20 14:18:51 21 14:18:56 22 strong supporters of clean air improvements. The companies that comprise the Coalition have, by themselves,invested over $2,000,000 in state-of-the-art emissions controls since 2001. The Coalition supports the proposed demonstration that the HGB will attain the 1997 eight-hour ozone standard by the 2019 deadline. Our written comments will provide details and additional corroborative analysis of the following points. EPA has developed rigorous guidance that
states must follow when using photochemical modeling to demonstrate how a proposed suite of control strategies will lead to attainment of the standard by the deadline. TCEQ has strictly adhered to this guidance. Indeed, in important instances, the Agency has gone well beyond standard EPA methodology in diagnostic**test~ng,** 

### sensitivity analysis, and vetting of the HGB modeling results. In addition, our area has been a beneficiary of two major monitoring campaigns performed within a six-year period, and several associated measurement and analytical programs. Collectively, the measurements database available to the TCEQ constitutes the most extensive and

### 14:18:5723 14: 19: 01 24 14:19:06 25

14 : 19: DB 

### 1 14:19:12 2 14:19:13 3 14:19:13 4 14:19:13 5 14:19:23 6 14:19:25 7 14:19:31 8 14:19:34 9 14:19:35 10 14:19:35 11 

### 14:19:35 12 14:19:47 13 14 15 16 17 18 14:20:04 19 14:20:04 20 14:20:04 21 14:20:11 22 14:20:12 23 14:20:17 24 14:20:19 25 intense database ever developed for regulatory modeling in the United States. TCEQ has provided a robust weight of evidence determination that corroborates its

16

attainment modeling results. This weight of evidence determination assesses many of the uncertainties inherent in modeling, the complex airshed, and discusses the approach taken by TCEQ to better understand and minimize these uncertainties. The weight of evidence determination also provides an analysis of ambient ozone and precursor levels and trends, all of which support the conclusion that the region will attain the 1997 standard by the deadline. Eight-hour ozone data demonstrate that the number of exceedances, spatial distribution of ozone, seasonal distribution of ozone, and the strength of

ozone gradients have all decreased in the region. While the current ozone season is not yet complete, the 2009 design value is closely approaching the 1997 ozone standard level, which suggests that the ambient air is

more responsive to precursor controls than the model predicts

.. TCEQ has examined the year-to-year meteorological variation in the region and has determined that the ozone trends are the result of ongoing and sustained ozone precursor reductions. The region has made significant investments in precursor reductions. While emission reductions have occurred in all sectors, the large majority of the precursor

1714:20:22 1 14:20:24 2 14:20:27 3 14:20:30 4 14:20:34 5 14:20:38 6 7
8 9 10 11
12 14:20:58 13 14:21:03 14 14:21:06 15 14:21:08 16
14:21:08 17
14:21:15 18
14:21:20 19 14:21:21 20 14:21:24 21 14:21:27 22 14:21:29 23 14:21:30 24 14:21:34 25

14:21:36 1 14:21:39 2 14:21:42 3 

### reductions to date have been made by the industrial

source sector by means of the installation of new control technologies, manufacture of clean fuels, and the use of innovative technologies. In an associated rulemaking, TCEQ proposes a 25-percent reduction in the cap of Highly Reactive Volatile Organic Compound Emissions Cap and Trade program, or the HECT program emission allowances to ensure that progress continues, and we support the 25-percent reduction**i~** 

### the HECT program.. However, the Coalition does not support the reallocation portion of the proposed HRVOC rulernaking
at this time because it does not allocate allowances

. equitably, and penalizes facilities that have made early

and substantial HRVOC emission reductions. The reallocation included in this proposal is 

### not required for purposes of providing precursor reductions to the SIP. Because the reallocation portion is 

### not required

as part of this SIP proposal, we support an appropriate timeline for the development of additional data and analysis to develop more equitable reallocation methodology. Our written comments will provide more information on elements that we believe would be an equitable methodology. TCEQ has provided a list 

### of

18



### ongoing and planned future activities in the SIP proposal that will both improve modeling performance and provide additional precursor reductions. The Coalition

### 14:21:45 4 14:21:48 5 14:21:50 6 

### 14:21:52 7 14:21:57 B 

### 14:21:57 9 14:22:01 

### 10 14:22:03 11 

### 14:22:07 

### 12 14:22:11 13 14:22:12 14 14:22:15 15 14:22:18 16 14:22:18 17 14:22:18 18 14:22:18 19 14:22:42 20 14:22:44 21 14:22:44 22 14:22:44 23 14:22:56 24 14:22:58 25

14:23:02 1 14:23:07 2 14:23:10 3 14:23:13 4 14:23:18 5 14:23:19 6 

### 14:23:23 7 supports the initiatives described 

### in this section of the SIP, and in our written comments, we'll recommend additional analyses for investigation. We also support further development of quantification methods for emission reduction programs that have traditionally not been able to be quantified. The mission of the a-Hour Ozone SIP Coalition is to

assure that air quality decisions are made on the best scientific data, and result 

### in rules that are effective in addressing air quality issues while achieving the goals of clean air and a strong economy. We look forward to continuing to work with the TCEQ and other stakeholders in our region to achieve these goals. Thank you. MR. PATTERSON: Thank you. Next up, I have Tom Garrisi. MR. GARRISI: Good afternoon. My name 

### is Tom Garrisi. I'm the Director of Engineering for Kaneka Texas Corporation. Kaneka's facility 

### is located in Bayport, Pasadena, and we produce materials primarily used in the plastics industry. Kaneka employs about 450 people at our Pasadena site. My comments today are

19

focused on TCEQ proposed nullification of past HRVOC
stream trades. The proposed rule provides that all past trades will be invalidated. The trades will be voided. It will be as if these trades never occurred. Companies purchased hundreds of thousands of dollars in credits to plan for future growth in Houston. Now, these credits will be worth nothing.14:23:24 8 14:23:26 9 14:23:30 10 14:23:34 11 14:23:37 12 14:23:40 13 14:23:44 14 14:23:48 15 14:23:49 16 14: 23:53 17 14:23:53 18 14:23:56 19 14:24:01 20 14:24:03 21 14:24:03 22 14:24:03 23 14:24:03 24 14:24:16 25

14:24:19 1 14:24:23 2 14:24:27 3 14:24:28 4 14:24:30 5 14:24:34 6 14:24:34 7 14:24:37 8 14:24:39 9 14:24:43 10 14:24:46 11 While there were only three HRVOC trades, this proposed action impacts everyone in this room. It 

### is nothing less than the integrity of the emissions trading program in Texas which I believe 

### is at stake. Based on this precedent, what company would purchase
stream credits to plan for their future growth under the HECT or MECT programs? I certainly won't recommend Kaneka purchase any future credits. I can't. I spent

over $500,000 of my company's money, and now it will be
gone. If I'm a company that uses HRVOC as raw materials, what corporate executives would give me approval, or what financial institution would lend me money for a new plant if I can't secure the emissions credits to operate the new unit? In short, TCEQ's proposed precedent means that if you buy hundreds of thousands of dollars of credits in HECT or MECT stream credits, these credits might be completely nullified in

20

the next two years when TCEQ does another SIP. While these credits are expensive, the greater risk is to your

new project

-- the one you spent mUlti-millions of dollars to build might be impossible to operate because
you no longer have adequate allowances to continue to operate. Industry must be able to operate with the knowledge that the trades will be honored. Throughout the history of the cap and trade program, there has

never been a program that has made trades meaningless. Congress, EPA, and numerous other authorities have

### 14:24:49 12 14:24:52 13 14:24:56 14 14:24:59 15 14:25:02 16 17 18 19 20 21 22 23 24 25

14:25:33 1 14:25:35 2 14:25:40 

### 3 14:25:43 4 14:25:45 5 14:25:45 6 14:25:45 7 14:25:46 8 14:25:46 9 14:26:02 

### 10 14:26:06 11 14:26:06 12 14:26:14 13 14:26:15 14 14:26:19 

### 15 emphasized the importance of not taking actions such as nullifying stream trading that could jeopardize the integrity of the market. Under the Acid Rain Program, Congress issued allocations for 30 years. Congress was careful to recognize the importance of long-range planning to protect the integrity of the system. I want to share with you one excerpt from the legislative history of the Acid Rain Program that I think sums up the feelings
-- my feelings on TCEQ's proposed nullification of stream credits. "You know, all businesses and business executives fear uncertainty. And all of us are more or less subject to some form of government regulation, and we can live with that, provided we have some degree of certainty that we know

21

what we're dealing with. When we know that, we collectively unleash the ingenuity, the creativity, and the challenge among the engineers, and the scientists, and the business community to work to accomplish the objective in the most efficient manner, and beat our competition in doing it. When you have no certainty that the rules will stay intact for even a short period, it is very disheartening and it drains the enthusiasm for coming up with creative solutions." If TCEQ reallocates without validating past trades, TCEQ is severely impairing stream trading in Texas. If stream trades are meant to be perpetual, perpetuity must mean more than a couple years. Industry will not make investments in the stream trades or new plans that need them with the precedent that two years14:26:21 16
14:26:25 17
14:26:25 18
14:26:29 19
14:26:32 20 14:26:34 21
14:26:38 22
14:26:42 23
14:26:44 24
14:26:47 25

14:26:51 1
14:26:57 2
14:26:59 3
14:27:00 4
14:27:02 5
14:27:05 6
14:27:08 7
14:27:11 8
14:27:14 9 14:27:24 10 14:27:24 11 14:27:24 12
14:27:24 13
14:27:40 14 14:27:40 15 14:27:43 16 14:27:46 17 14:27:50 18 14:27:53 19 

### later, the credits would be worth nothing. Stream trading is a fundamental concept of both the HECT and MECT programs, and we must protect it. One closing note. One of the reasons cap and trade programs work is that the market for credits
encourages companies to invest in additional emissions controls to produce emission credits to trade, or to shut down less efficient operations, again, to produce emission credits. Nullifying the credits will not only stop this positive effect, but it will have the worse

22



### effect of encouraging emissions of HRVOCs since a year

or two from now, TCEQ might, yet again, reallocate emissions with the next SIP, and the more you emit now, the more you'll have then. Please, honor these past trades. Protect the integrity of the emissions trading program. Encourage companies to reduce emissions, and foster growth and jobs by recognizing the need for businesses
to be able to plan for their future in Texas with a certainty of hope. Thank you. MR. 

### PATTERSON: Thank you. Next up, I have Tom Lightfoot.

MR. 

### LIGHTFOOT: Hi. I'm Tom Lightfoot and I'm with Bigler, LP in Pasadena, Texas. Bigler supports the efforts of the TCEQ in listening to the concerns of the regulating community in regards to the inequalities in the original HRVOC allocations. It appears that the proposed reallocation addresses many of these concerns. However, Bigler feels that there has been one area in14:27:57 20 14:28:00 21 14:28:01 22 14:28:04 23 14:28:08 24 14:28:12 25

14:28:15 1 14:28:18 2 14:28:21 3 14:28:25 4 14:28:29 5 14:28:33 6 14:28:36 7 14:28:40 8 14:28:45 9 14:28:47 10 14:28:49 11 14:28:53 12 14:28:56 13 14:29:00 14 14:29:02 15 14:29:05 16 14 :29: 07 17 14:29:11 18 14:29:14 19 14:29:18 20 14:29:23 21 14:29:25 22 14:29:30 23 

### which the proposed reallocation actually increases the inequali ties. This is in regards to previously purchased
stream allowances. By completely nullifying all previous stream trades, this proposed reallocation sets

a precedent that threatens the integrity of all cap and

23



### trade programs. The preamble to the proposed rulemaking clearly states

-- and I quote, "Cap and trade programs aim to provide economic incentives for reducing emissions through controls by allowing excess allowances
to be sold to other program participants." For allowances to be sold, there needs to be both willing buyers and willing sellers. A potential buyer needs some assurance that their investment will have an opportunity for a reasonable return. Nullifying all trades under the current HRVOC emissions cap and trade program, less than three years after that program went into effect, does not provide buyers with adequate time to see a return on their investment. If buyers
cannot be assured of the opportunity for a return on their investment, they will not buy. If there are no buyers, there can be no sellers. If there is no market for sellers, the economic incentives to reduce emissions do not exist. If the economic incentives do not exist, cap and trade does not work. Therefore, Bigler believes 

### that it's in the best interest of all concerned to accommodate past
stream trades into the proposed reallocation. Bigler acquired the former SP Amoco Pasadena site in January of14: 29: 35 24 14:29:38 25

14:29:42 1 14:29:46 2 14:29:49 3 14:29:53 4 14:29:55 5 14:29:58 6 14:30:02 7 14:30:07 8 14:30:09 9 14:30:12 10 14:30:15 11 14:30:19 12 14:30:21 13 14:30:24 14 14:30:27 15 14: 30: 33 16 14:30:35 17 14:30:39 18 14:30:41 19 14:30:45 20 14:30:46 21 14:30:49 22 14:30:53 23 14:30:57 24 14:30:59 25 2007. Along with the land and the assets, Bigler acquired 20 tons of HEVOC stream allowances. Bigler had

24

no HRVOC allowances under the initial allocation, as we

were not engaged in activities associated with HRVOC at the time of the initial allocation. The HRVOC stream allowances were purchased for future business activities. These activities included the construction and operation of a high-purity isobutylene unit. After
proper permits were obtained, construction began with a start-up in March of this year. Without HRVOC allowances, this greater than

a hundred-million-dollar expenditure would not have been made. Onder the proposed reallocations, Bigler will receive 10 tons of allowance. This is half of the

amount that we previously obtained via cap and trade, and it is insufficient to operate our newly constructed unit at**desi~ned** rates. Nullifying the previous trades jeopardizes our ability to be commercially viable. Bigler made a good-faith effort to have all necessary operational requirements in place, including HRVOC allowances prior to constructing and starting up a new facility. It seems inconceivable that the TCEQ would
want to punish a company that tried to make cap and trade work. Bigler is a small company, and one of only

a few that are immediately affected by the nullification of previous HRVOC stream trades. That's a major

25

### 14:31:04 1 14:31:06 2 14:31:11 3 14:31:15 4 14:31:16 5 14:31:20 6 14:31:23 7 

### 14:31:26 8 

### 14:31:30 9 14:31:30 10 14:31:30 11 

### 14:31:48 12 14:31:48 13 14:31:53 14 14:31:57 15 14:32:03 16 14:32:06 17 14:32:11 18 14:32:16 19 14:32:17 20 14: 32: 22 21 14:32:23 22 14:32:27 23 14:32:28 24 14:32:31 25

14:32:34 1 14:32:39 2 14: 32: 41 3 challenge to get our voice heard, as it is not perceived that are problem is a global one. Bigler feels that is incorrect. We feel that the complete nullification of previous stream trades will permanently damage the integrity of all cap and trade programs. Cap and trade will lose credibility for all members of the regulation community, and thereby not meet the needs of the citizens of Texas. Bigler would like to work with the TCEQ to find an equitable solution for all parties. MR. PATTERSON: Thank you. Next up, I have Elena Craft. MS. CRAFT: Hi. I'm Elena Craft with Environmental Defense Fund. Houston has never met the health based eight-hour standard for ozone. We still do
not meet the revoked one-hour standard for ozone. TCEQ has projected that VOC emissions will increase by about 200 tons per day by the year 2018. The panel of experts who developed recommendations for the health based ozone standard have stated the health protective ozone standard lies somewhere within the range of 60 to 70 parts per billion. EPA is in the process of reconsidering the eight-hour ozone standard and it is likely that the standard will be lowered. The SIP proposal that TCEQ has prepared is a disappointment and a wasted

26

opportunity to implement real control measures to reduce

ozone concentrations to a level that is within the goal for which the ozone standard was developed, which is for14:32:44 4 14:32:52 5 14:32:54 6 14:32:54 7 14:32:54 8 14:32:54 9 14:33:06 10 14:33:07 11 14:33:09 12 1"4: 33: 14 13 14:33:15 14 14:33:20 15 14:33:22 16 14:33:25 17 14:33:28 18 14:33:31 19 14:33:32 20 14:33:35 21' 14:33:37 22 14:33:40 23 14:33:43 24 14:33:46 25

14:33:51 1 14:33:51 2 14:33:54 3 14:33:56 4 14:34:01 5 14:34:01 6 14:34:05 7 

### the protection of human health. Thank you. MR. PATTERSON: Thank you. Next up, I have Karl Pepple. And as Mr. Pepple approaches, I'll ask Emily or Faye if we have any others that have signed up
to speak, if they could please bring those pages forward. Thank you. MR. PEPPLE: Good afternoon. 

### My name 

### is Karl Pepple. I'm with the City of Houston. Thank you for the opportunity to make comments on the proposed HGB Attainment Demonstration SIP. The City of Houston submitted comments to.the TCEQ on September 22nd, 2009. Our executive director, Mark Vickery, responded on October 20th, we greatly appreciate the detailed
response that he provided. I would like to provide some additional comments based upon the response that we received from Mr. Vickery. The TCEQ is correct when it claims we are making progress in reducing emissions. Significant reductions have been made, and we need to recognize these reductions as successes. The fact that the 2009 eight-hour design value is as low as it is this year is promising. However, we must maintain forward progress

27



### in reducing emissions for the protection of public health. Work remains to be done in reducing ozone levels. This year, the region experienced exceedances in both the old one-hour and the current eight-hour

ozone standards. Additionally, the TCEQ needs to continue reducing air toxics in the ambient atmosphere. Several of these toxics affect ozone14:34:07 8 14:34:09 

### 9 14:34:12 10 14:34:14 11 

### 14:34:16 12 14:34:19 13 14:34:19 14 14:34:19 15 14:34:26 16 14:34:29 17 14:34:34 18 14:34:35 19 14:34:35 20 14:34:43 21 14:34:44 22 14:34:49 23 14:34:49 24 14:34:52 25

14:34:53 1 14:34:57 2 14: 35: 00 3 14:35:06 4 14:35:09 

### 5 14:35:11 6 

### 14 : 35: 16 7 14:35:19 8 14:35:21 9 14:35:24 10 14:35:26 11 

### production. The TCEQ also needs to keep in mind that the ozone standard, which 

### is a health-based standard based on the latest science will be tightening. Addressing air toxics will help move us toward meeting the forthcoming ozone standard, maintain the momentum that has been developed, and continue reducing regional emissions. Mr. Vickery's response was optimistic that the Houston-Ga1veston-Brazoria region would attain the NAAQS nine years early. We are hopeful that the TCEQ 

### is
correct and can maintain lower ozone levels for the
necessary length of time to have the non-attainment, designation removed from this region. Thank you. MR. PATTERSON: Thank you. Next up, I have Laura -- and I'm sorry, I can't
-- MS. BLACKBURN: Blackburn. MR. PATTERSON: Blackburn. MS. BLACKBURN: I just want to add a few

28

comments. I'm representing the League of Women Voters of Houston. I will be sUbmitting written comments as well. When I was thinking yesterday about what to say, and then at 4:00 

### o'clock this morning when I was further thinking about what to say, two major things occurred to me. One, which is 

### obvious, is 

### that the proposals do not
meet the health standard of ozone on its face in at least three areas in Houston. Now, I understand under the weight of the evidence, that that's okay with EPA. I happen to disagree with that, but I understand that that's there.

### 14:35:30 12 14:35:35 13 14:35:38 14 14:35:42 15 14:35:45 16 14:35:51 17 14:35:51 18 14:35:53 19 14:35:56 20 14:36:0121 14:36:07 22 14:36:14 23 24 25

1 2 3 14:36:28 4 14:36:29 5 14:36:31 6 14:36:33 7 14:36:33 8 14:36:39 9 14:36:39 10 14:36:43 11 

### 14:36:45 12 14:36:48 13 14:36:51 14 14:36:52 15 We, however, would prefer to see TCEQ err on the side of safety rather than breaking the standard. So we would wish that you would tighten those proposals so that indeed, even on its face, we would meet the standard. The next thing is, that suggestions have been made into (inaudible) course review. We would certainly support those. In fact, we think it's essential. The last thing is

-- 

### my question, which has to do with credibility. We didn't meet the 1997 standards with the plan of TCEQ. How does that make us have credible faith in meeting it for 2009

-- 2019? And I'd love an answer to that question. Thank you. MR. PATTERSON: Okay; And if you don't

29

mind, would you please speak your name into the microphone so we just have it on the record. MS. BLACKBURN: Laura Blackburn. MR. PATTERSON: Okay. Thank you. At this time, I have no one else who has indicated a desire to provide comments at this hearing. Is there anyone else who would like to do so at this point? (Brief pause) MR. PATTERSON: Okay. Once again, all
comments must be received by November 9th of 2009. All
comments should reference the rule or SIP project number that the comments pertain to. Copies of the proposed rule, SIP revisions and appendicis can be obtained from the Commission's Web site. Please Feel free to pick up

a handout of the list of these Web addresses from the

### 14:36:52 16 14:36:56 17 14:36:59 18 14:37:00 19 14:37:02 20 14:37:05 21 14:37:05 22 14:37:10 23 24 25 registration table. If you would like to sign up to receive e-mail updates whenever we have new information to the SIP hot topics Web page, the instructions on how to sign
up are also on that handout. We appreciate your comments and we thank you for coming. If there are no further comments, this hearing is now closed, and it's approximately 2:37 in the afternoon. (Proceedings concluded at 2:37 p.m.)

30

1 C E R T I F I CAT E 2 STATE OF TEXAS 3 COUNTY OF TRAVIS 4 I, Karen L. Goh, a Certified Shorthand 5 

### Reporter in and for the State of Texas, do hereby 6 certify that the above-mentioned matter occurred as 7 hereinbefore set out. 8 I FURTHER CERTIFY THAT the proceedings of 9 such were reporter by me or under my supervision, later 10 reduced to typewritten form under my supervision and 11 control and that the foregoing pages are a full, true 12 and correct transcription of the original notes. 13 IN WITNESS WHEREOF, I have hereunto set my 14 hand and seal this 2nd day of November 2009. 15 16 17 18 19 Karen L. 

### Goh Certified Shorthand Reporter CSR No. 8776

- Expires 12/31/0920 

### 21
22 

### 23 24 25 Firm Certification No. 276 Kennedy Reporting Service, Inc. Cambridge Tower 

### 1801 Lavaca Street, Suite 115 Austin, Texas 78701 512.474.2233

### INDEX OF ORAL TESTIMONY

october 28, 2009, 6:00 p.m. - Houston-Galveston Area Council, Houston, Texas

No oral testimony was received pertaining 

### to this proposal.Pap 1 

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### I am the hearing officer assigned to conduct the public hearing regarding the proposed revisions to the Houston-Galveston-Brazoria (HGB) Attainment Demonstration State Implementation Plan (SIP) for the 1997 Eight-Hour Ozone Standard (Project No. 2009- 017-SIP-NR); HGB Reasonable Further Progress SIP for the 1997 Eight-Hour Ozone Standard (Project No. 2009-018-SIP-NR); Highly Reactive Volatile Organic Compound Emissions Cap and Trade (HECT) Program Cap Reduction and Allowance Reallocation (Rule Project No. 2009-006-101-EN); Mass Emissions Cap and Trade (MECT) Program Cap Integrity for the HGB 1997 Eight-Hour Ozone Nonattainment Area (Rule Project No. 2009-019-101-EN); and Volatile Organic Compound (VOC) Control Technique Guidelines (CTG) Update - Offset Lithographic Printing (Rule Project No. 2008-019-115-EN). A public hearing was scheduled for October 28, 2009, at 6:00 p.m., in Conference Room A at the Houston-Galveston Area Council, 3555 Timmons Lane, Houston, Texas. At 5:30 p.m., the room was open. TCEQ staff and a court reporter were present and ready to open the hearing for public comment. After waiting until 6:15 p.m., no one had arrived to make comments on the record. Therefore, the public hearing was not formally opened for comment and no transcript was prepared.

Hearing Officer

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### INDEX OF ORAL TESTIMONY

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## TEXAS COMMISSION ON ENVIRON1v1ENTAL QUALITY

HEARING OFFICER REPORT



### I am the hearing officer assigned to conduct the public hearing regarding the proposed revisions to the Houston-Galveston-Brazoria (HGB) Attainment Demonstration State Implementation Plan (SIP) for the 1997 Eight-Hour Ozone Standard (Project No. 2009- 017-SIP-NR); HGB Reasonable Further Progress SIP for the 1997 Eight-Hour Ozone Standard (Project No. 2009-018-SIP-NR); Highly Reactive Volatile Organic Compound Emissions Cap and Trade (HECT) Program Cap Reduction and Allowance Reallocation (Rule Project No. 2009-006-101-EN); Mass Emissions Cap and Trade (MECT) Program Cap Integrity for the HGB 1997 Eight-Hour Ozone Nonattainment Area (Rule Project No. 2009-019-101-EN); and Volatile Organic Compound (VOC) Control Technique Guidelines (CTG) Update - Offset Lithographic Printing (Rule Project No. 2008-019-115-EN). A public hearing was scheduled for October 29, 2009, at 3:00 p.m., at the Texas Commission on Environmental Quality complex, Building E, Room 201S, 12100 Park 35 Circle, Austin, Texas. At 2:30 p.m., the room was open. TCEQ staff and a court reporter were present and ready to open the hearing for public comment. After waiting until 3:15 p.m., no one had arrived to make comments on the record. Therefore, the public hearing was not formally opened for comment and no transcript was prepared.

# ~fu~d**~l~~** /OJf---_

# EVALUATION OF TESTIMONYIN"TEROFFICE MEMORANDUM 

# Texas Commission on Environmental Quality

To: Thru:

From:

Docket No.: Commissioners LaDonna Castafiuela, Chief Clerk Mark R. Vickery, P.G., Executive Director 

### Susana M. Hildebrand, P.E.,

# CbiefEngin~ 2009-080 I-SIP Date: February 19,2010

Subject: Commission Approval for Adoption Houston-Galveston-Brazoria (HGB) Reasonable Further Progress (RFP) State Implementation Plan (SIP) Revision for the 1997 Eight-Hour Ozone Standard Project No. 2009-018-SIP-NR Background and reason(s) for the SIP revision: As part of the fIrst phase of the United States Environmental Protection Agency's (EPA) implementation rule for the 1997 eight-hour ozone standard, the Texas Commission on Environmental Quality was required to submit an attainment demonstration SIP revision for a moderate nonattainment area to the EPA by June 15, 2007. In addition to an attainment demonstration, an RFP SIP revision that demonstrated a 15 percent reduction in anthropogenic ozone precursors, nitrogen oxides (NOx) and volatile organic compounds (VOC), between 2002 and 2008 was also required to be submitted by the June 15,2007, deadline. On May 23,2007, the commission adopted the required RFP SIP revision. The EPA published notice of approval of the HGB RFP SIP revision for a moderate 1997 eight-hour ozone nonattainment area on April 22, 2009.
On June 15,2007, the TCEQ submitted a letter from the governor of Texas to the EPA requesting that the HGB area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties) be reclassified from a moderate to a severe nonattainment area for the 1997 eight-hour ozone standard. The EPA granted the governor's request effective October 31,2008. As a result of the reclassification, the EPA set April 15, 2010, as the deadline for the state to submit a SIP revision for the**~GB** area that addresses the severe ozone nonattainment area requirements, including RFP. The HGB area's new attainment date for the 1997 ozone standard is as expeditiously as practicable but no later than June 15, 2019. This SIP revision demonstrates reasonable further progress toward attainment of the 1997 eight-hour ozone National Ambient Air Quality Standard (NAAQS) for the HGB nonattainment area, which was reclassifIed as severe by the EPA based on the governor's request. Scope of the proposed SIP revision: A) Summary of what the SIP revision will do: This RFP SIP revision shows reasonable further progress toward attainment of the 1997 eight-hour ozone NAAQS for a severe nonattainment area. The EPA requires a demonstration of the initial 18 percent combined VOC and NO x reduction for 2002 through 2008. The EPA also requires demonstration of suffIcient ozone precursor reductions (an average of 3 percent per year between each of the milestone years 2008,2011,2014,2017, and 2018) and an additional 3 percent reduction for contingency. In addition to the RFP analyses, this SIP revision will provide updated 2002 emissions inventories for point, area, on-road mobile, and non-road mobile sources and updated RFP motor vehicle emissions budgets (MVEB) for each milestone year.Response to Comments Received Regarding the Houston-Galveston-Brazoria (HGB) Reasonable Further Progress (RFP) State Implementation Plan (SIP) Revision for the 1997 Eight-Hour Ozone Standard Proposed September 23, 2009 Adopted March 10, 2010 The commission conducted public hearings in Hous ton on October 28, 2009 at 2:00 p.m. and 6:00 p.m., and in Austin on October 29, 2009 at 2:00 p.m. During the comment period, which closed on November 9, 2009, the commission received comments from the Clean Air Institute of Texas (CAIT), KIDS for Clean Air (KIDS), the Sustainable En ergy and Economic Develo pment (SEED) Coalition, the United States Environmental Protection Agency ( EPA), and one individual. In addition, CAIT, KIDS, SEED, and one individual also incorpor ated by reference any comments submitted by Environmental Defense (ED) and/or the Sierra Club; however, no comments were received from either ED or the Sierra Club concerning the HGB RFP SIP revision. RESPONSE TO COMMENTS CONTROL STRATEGIES CAIT, KIDS, SEED, and one individual commented that control strategies in the RFP SIP revision failed to demonstrate ongoing emissions reductions from existing or proposed control strategies. The TCEQ disagrees with this comment. The HGB RFP SIP revision demonstrates more than the required reduction between 2002 and 2018,as demonstrated in Chapter 4: CONTROL MEASURES TO ACHIEVE TARGET EMISSIONS LEVELS of the RFP SIP. The reductions account for a 3 percent per year reduction, as we ll as off-setting any growth. In accordance with EPA requirements, the reductions are on-going and are demonstrated for every three-year interval. All reductions are quantified and attributable to specific control strategies. No revisions were made to the HGB RFP SI P revision based on this comment. EMISSIONS INVENTORY CAIT, KIDS, SEED, and one individual commented th at the RFP SIP revision failed to adequately account for potential increases in ozone precursor emissions from major point sources (such as power plants) outside the HGB area that have been permitted or are currently undergoing the permitting process. The baseline point source emissions inventory for the HGB RFP SIP revision includes only actual emissions from those sources within the designated nonattainment area, in accordance with the EPA’s guidance on inventories for Reas onable Further Progress plans. Please refer to Emissions Inventory Requiremen ts for Ozone State Implementation Plans (EPA 450/4-91-010) for further detail. The HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (Project No. 2009-017-SIP-NR) adequately accounted for the types of sources identified by the commenters. Please refer to Section 3.4.4.1: Point Sources of Chapter 3: PHOTOCHEMICAL MODELINGand Section 2.3.1.1.1: EGUs of Appendix B: EMISSIONS MODELING FOR THE HGB ATTAINMENT DEMONSTRATION SIP , where the TCEQ explains that newly permitted electric generating units (EGU) are in cluded in the 2018 modeling. Specifically, units for which a TCEQ air permit has been issued as of November 2009 are listed in Section 2.3: 2018 FUTURE YEAR POINT SOURCE MO DELING EMISSIONS DEVELOPMENT of Appendix B: EMISSIONS MODELING FOR THE HGB ATTAINMENT DEMONSTRATION SIP .EGUs that have not yet been granted a permit are not included in the modeling. Historically, many units that have not been issued a permit have withdrawn their permit applications due to market changes. The TCEQ does not speculate which of these applications may be withdrawn, so only permitted units are included. No re visions were made to the HGB RFP SIP revision based on this comment. The EPA requested further description concerning how unreported vol atile organic compounds (VOC) emissions were accounted for in the updated point source 2002 base year inventory. Unreported VOC emissions in the 2002 base year inventory were determined using the same adjustment as the previous HGB RFP SIP revi sion, which was adopted by the commission on May 23, 2007 ( http://www.tceq.state.tx.us/implem entation/air/sip/may2007hgb.html#rfp ). The difference in values between the 2002 uncontrolled adjustment and the future year controlled adjustment was not claimed as a reduction in thisRFP SIP revision. No revisions were made to the HGB RFP SIP revision based on this comment. FUTURE EMISSIONS AND VERIFICATION OF CONTINUED ATTAINMENT The EPA commented that the HGB RFP SIP revisi on should confirm that transportation control measures (TCMs) are not needed to offset vehicl e miles traveled (VMT) growth, because the growth in VMT is not expected to result in an increase in emissions. The growth in VMT in the HGB area will not resultin a growth in vehicle emissions. There is growth in VMT for the HGB area for the yea rs between the RFP base year of 2002 and the attainment year, 2018, as illustrated in Figure 4-1: RFP VMT Trends . However, the growth in VMT for the area is more than offset by control measures that reduce the per mile emission rates, resulting in a decrease in emissions of both VOC and NO Xfor the same time period as shown in Figure 4-2: RFP Controlled On-Road NOX and VOC Emissions Trends . The increase in VMT and decrease in vehicle emissions for th e RFP time period are summarized in Table 4-4: RFP Controlled NOX Emissions, VOC Emissions, and VMT. Chapter 4: CONTROL MEASURES TO ACHIEVE TARGET LEVELS was revised to include a new Section 4.6: VMT, On-Road Emissions, and Transportation Control Measures , Table 4-4: RFP Controlled NOX Emissions, VOC Emissions, and VMT, Figure 4-1: RFP VMT Trends , and Figure 4-2: RFP Controlled On-Road NOX and VOC Emissions Trends . This additional information was included to document the trend in VMT and vehicle emissions from 2002 to 2018, demonstrating compliance with the Federal Clean Air Act, §182(d )(1)(A). TCMs are in place in the HGB area and are documented in the Houston-Galveston-Brazoria Attainment Demonstration State Implementation Plan Revision for the 1997 Eight-Hour Ozone Standard.

# STAFF RECOMMENDATIONSREVISION TO THE STATE IMPLEMENTATION PLAN FOR THE CONTROL OF OZONE AIR POLLUTION

HOUSTON-GALVESTON-BRAZORIA 1997 EIGHT-HOUR OZONE STANDARD NONATTAINMENT AREA

TCEQ

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

Houston-Galveston-Brazoria Reasonable Further Progress State Implementation Plan Revision for th e1997 Eight-Hour Ozone Standard

PROJECT NO. 2009-018-SIP-NR

Adopted March 10, 2010HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard This page is intentionally left blank.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

ES-1 EXECUTIVE SUMMARY The 1990 Federal Clean Air Act Amendments (FCA A), §182, require ozone nonattainment areas with air quality classified as moderate or higher to submit plans showing reasonable further progress (RFP)toward attainment of the ozone National Ambient Air Quality Standard (NAAQS). The HoustonGalveston-Brazoria (HGB) area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty,Montgomery, and Waller Counties) is classified as a severe nonattainment area for the 1997 eighthour ozone standard, with an attain ment date of June 15, 2019. This state implementation plan (SIP) revision is not required or intended to demonstrate attainment of the ozone NAAQS but rather to demonstrate that ozone precursor emissions will be reduced in accordance with the guidelines setforth in the second phase of the United States Environmental Protection Agency’s (EPA) 1997 EightHour Ozone Implementation Rule (40 Code of Federal Regulations §51.910). This SIP revision demonstrates that the RFP emissi ons reduction requirement will be met for the sixyear period (2003 through 2008) beginning January 1 of the year following the year used for the baseline emissions inventory (2002) and all remaining three-year periods after the first six-year period (2009 through 2011, 2012 through 2014, and 2015 through 2017) out to the area's attainment date (2019). Target year inventories include the latest information available to estimate emissions growth. Target levels for the attainment year (2018) al so account for RFP corrections and non-creditable reductions. All of the RFP inventories ar e based upon an ozone season weekday analysis. The RFP methodology involves development of the base year and milestone year inventories, emissions reductions for nitrogen oxides (NO X ) and volatile organic compounds (VOC) in each milestone year, and an estimate of the effects of non-creditable reductions and pre-1990 FCAA rules. Through this methodology, the reduction amount is determined. Once these values have been calculated, the milestone target levels and emissions inventories can be compared to determine if the forecasted controlled emissions inventories are less than the target level. The results, which demonstrate that the HGB area meets the FCAA RFP requirements for each of the milestone years, are displayed in Chapter 3: TARGET EMISSIONS LEVELS AND REASONABLE FURTHER PROGRESS DEMONSTRATION , Table 3-3: Calculation of Required 3 Percent Per Year NO Xand VOC Reductions

. This SIP revision also sets the NO X and VOC motor vehicle emissions budgets (MVEB) for transportation conformity purposes for the milest one years 2008, 2011, 2014, 2017, and 2018. An MVEB is the on-road mobile source allocation of th e total allowable emissions for each applicable criteria pollutant or precursor, as defined in the SIP. Transportation conformi ty determinations must be performed using the budget test once the EPA determines the budget adequate for transportation conformity purposes. To pass the budget test, area s must demonstrate that the estimated emissions from transportation plans, programs, and projects do not exceed the MVEB for the established year. Because the HGB area has been reclassified as a severe nonattain ment area for the 1997 eight-hour ozone NAAQS, the RFP milestone years adopted in the previous (May 23, 2007) HGB RFP SIP revision have been revised to reflect the area’s extended attainment date. Chapter 5: MOTOR VEHICLE EMISSIONS BUDGETS documents the development of the revised RFP MVEB for each of these milestone years for the eight -county HGB ozone nonattainment area.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

i SECTION V: LEGAL AUTHORITY A. General The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the quality of the state’s air, including maintaining adequate visibility. The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon’s Texas Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, and 2009. In 1989, the TCAA was codified as Chapter 382 of the Texas Health & Safety Code. Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution control agency and is principal authority in the state on matters relating to the quality of air resources. In 1991, the legislature abolished the TACB effec tive September 1, 1993, and its powers, duties, responsibilities, and functions were transferre d to the Texas Natural Resource Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over ai r quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the general provisions, organization, and general powers and duties of the TNRCC, and the responsibilities and authority of the executive director. This chapter also authorizes the TNRCC to implement action when emergency conditions arise, and to conduct hearings. Chapter 7 gives the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence of the TNRCC until September 1, 2013, and changed the name of th e TNRCC to the TCEQ. In 2009, the 81st Texas Legislature, during a special session, amended §5.014 of the Texas Water Code, changing the expiration date of the TCEQ to September 1, 2011, unless continued in existe nce by the Texas Sunset Act. The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in the state’s air and to control the quality of the state’s air by preparing and developing a general, comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect information to enable the commission to develop an i nventory of emissions; to conduct research and investigations; to enter property and examine records; to prescribe monitoring requirements; to institute enforcement proceedings; to enter into contracts and execute instruments; to formulate rules; to issue orders taking into consideration factors bearing upon health, welfare, social and economic factors, and practicability and reasonableness; to conduct hearings; to establish air quality control regions; to encourage cooperation with citizens’ groups and other agencies and political subdivisions of the state as well as with industries and the federal government; and to establish and operate a system of permits for construction or modification of facilities. Local government authority is found in Subchapter E of the TCAA. Local governments have the same power as the TCEQ to enter property and make inspections. They also may make recommendations to the commission concerning any action of the TCEQ that affects their territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements with the TCEQ or other local governments. In addition, a city or town may enact and enforce ordinances for the control and abatement of air pollution not inconsiste nt with the provisions of the TCAA and the rules or orders of the commission. Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and maintenance programs in certain areas of the state, consistent with the requirements of the Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies to develop and implement transportation programs and measure s necessary to attain and maintain the NAAQS;HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

ii establish gasoline volatility and low emission diesel standards; and fund and authorize participating counties to implement vehicle repair assistance, retrofit, and accelerated vehicle retirement programs.
B. Applicable Law The following statutes and rules provide necessary authority to adopt and implement the State Implementation Plan (SIP). The rules listed below have previously been submitted as part of the SIP. Statutes TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2009 TEXAS WATER CODE September 1, 2009 All sections of each subchapter are included, unless otherwise noted. Chapter 5: Texas Natural Resource Conservation Commission Subchapter A: General Provisions Subchapter B: Organization of the Tex as Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties of the Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§5.225, 5.226, 5.227, 5.2275, 5.231, 5.232, and 5.236) Subchapter H: Delegation of Hearings Subchapter I: Judicial Review Subchapter J: Consolidated Permit Processing Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145 and 5.515 only) Subchapter M: Environmental Permitting Procedures (§5.558 only) Chapter 7: Enforcement Subchapter A: General Provisions (§§7.001, 7.002, 7.00251, 7.0025, 7.004, 7.005 only) Subchapter B: Corrective Action and Injunctive Relief (§7.032 only) Subchapter C: Administrative Penalties Subchapter D: Civil Penalties (except §7.109) Subchapter E Criminal Offenses and Penalties: §§ 7.177, 7.179-7.183 Rules All of the following rules are found in Title 30 Texas Administrative Code, as of the following effective dates: Chapter 7, Memoranda of Understandi ng, §§7.110 and 7.119 May 2, 2002 Chapter 19, Electronic Reporting March 1, 2007 Chapter 35, Subchapters A-C, K: Emergency and Temporary July 20, 2006 Orders and Permits; Temporary Suspension or Amendment of Permit Conditions Chapter 39, Public Notice, §§39.201; 39.401; 39.403(a) and March 29, 2006 (b)(8)-(10); 39.405(f)(1) and (g);39.409; 39.411 (a), (b)(1)-(6) and (8)-(10) and (c)(1)-(6) and (d); 39.413(9), (11), (12) and (14); 39.418(a) and (b)(3) and (4); 39.419(a), (b),(d) and (e); 39.420(a), (b) and (c)(3) and (4); 39.423 (a) and (b); 39.601; 39.602; 39.603; 39.604; and 39.605HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

iii Chapter 55: Requests for Reconsideration and Contested Case Hearings; March 29, 2006 Public Comment, §§55.1; 55.21(a) - (d), (e)( 2), (3), and (12), (f) and (g); 55.101(a), (b), and (c)(6) - (8); 55.103; 55.150; 55.152(a)(1), (2), and (6) and (b); 55.154; 55.156; 55.200; 55.201(a) - (h); 55.203; 55.205; 55.209, and 55.211 Chapter 101: General Air Quality Rules January 1, 2009 Chapter 106: Permits by Rule, Subchapter A June 30, 2004 Chapter 111: Control of Air Pollution from Visible Emissions July 19, 2006 and Particulate Matter Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 Chapter 113: Standards of Performance for Hazardous Air Pollutants May 14, 2009 and for Designated Facilities and Pollutants Chapter 114: Control of Air Pollution from Motor Vehicles June 26, 2008 Chapter 115: Control of Air Pollution from Volatile Organic Compounds July 19, 2007 Chapter 116: Permits for New Construction or Modification May 29, 2008 Chapter 117: Control of Air Pollution from Nitrogen Compounds March 4, 2009 Chapter 118: Control of Air Pollution Episodes March 5, 2000 Chapter 122, §122.122: Potential to Emit December 11, 2002 Chapter 122, §122.215: Minor Permit Revisions June 3, 2001 Chapter 122, §122.216: Applications fo r Minor Permit Revisions June 3, 2001 Chapter 122, §122.217: Procedures for Minor Permit Revisions December 11, 2002 Chapter 122, §122.218: Minor Permit Revi sion Procedures for Permit June 3, 2001 Revisions Involving the Use of Economic Incentives, Marketable Permits, and Emissions TradingHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

iv SECTION VI. CONTROL STRATEGY A. Introduction (No change)
B. Ozone (Revised) 1. Dallas-Fort Worth(No change) 2. Houston-Galveston-Brazoria Reasonable Further Progress(Revised) Chapter 1: General Chapter 2: Emissions Inventories Chapter 3: Target Emissions Levels and RFP Demonstration Chapter 4: Control Measures to Achieve Target Emissions Levels Chapter 5: Motor Vehicle Emissions Budgets 3. Beaumont-Port Arthur (No change) 4. El Paso (No change) 5. Regional Strategies(No change) 6. Northeast Texas(No change) 7. Austin Area(No change) 8. San Antonio Area(No change)
C. Particulate Matter (No change)
D. Carbon Monoxide (No change)
E. Lead (No change)
F. Oxides of Nitrogen (No change)
G. Sulfur Dioxide (No change)
H. Conformity with the National Ambient Air Quality Standards (No change)
I. Site Specific (No change)
J. Mobile Sources Strategies (No change)
K. Clean Air Interstate Rule (No change)
L. Transport (No change)
M. Regional Haze (No change)HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

v LIST OF ACRONYMS
ABY Adjusted Base Year APU Auxiliary Power Units ATP Anti-Tampering Programs DERC Discrete Emissions Reduction Credits DFW Dallas-Fort Worth DV Design Value EBT Emissions Banking and Trading EDMS Emissions and Dispersion Model System EDMS Environmental Data Management System EGAS Economic Growth Analysis System EGUs Electric Generating Units EI Emissions Inventory EIQ Emissions Inventory Questionnaires EPA United States Environmental Protection Agency ERC Emission Reduction Credits ERG Eastern Research Group, Inc. ESAD Emission Specifications for Attainment Demonstration FAA Federal Aviation Administration FCAA 1990 Federal Clean Air Act Amendments FMVCP Federal Motor Vehicle Control Program GSE Ground Support Equipment HAS Houston Airport System HDDV Heavy-Duty Diesel Vehicles HECT Highly Reactive Volatile Organic Co mpounds Emissions Cap and Trade Program HGB Houston-Galveston-Brazoria H-GAC Houston-Galveston Area Council HRVOC Highly Reactive Volatile Organic Compounds I/M Inspection and Maintenance MECT Mass Emissions Cap and Trade Program MSY Milestone Year MVEB Motor Vehicle Emissions Budgets NAAQS National Ambient Air Quality Standards NLEV National Low Emission Vehicle NO XNitrogen Oxides PFC Portable Fuel Container PN Percent of NO X PV Percent of VOC REMI Regional Economic Modeling, Inc. RFG Reformulated Gasoline RFP Reasonable Further Progress ROP Rate of Progress RVP Reid Vapor Pressure SI Spark Ignition SIC Standard Industrial Classification SIP State Implementation Plan STARS State of Texas Air Reporting System TAC Texas Administrative Code TAF Terminal Area Forecast TCAA Texas Clean Air Act TCEQ Texas Commission on Environmental Quality TCM Transportation Control Measures TDM Travel Demand ModelsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

vi TexAER Texas Air Emissions Repository TexAQS 2000 Texas Air Quality Study 2000 TexN Texas NONROAD Model TIPI Texas Industrial Production Index TNRCC Texas Natural Resource Conservation Commission tpd Tons Per Day TxLED Texas Low Emission Diesel USC United States Code VMT Vehicle Miles Traveled VOC Volatile Organic CompoundsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

vii TABLE OF CONTENTS Executive Summary Legal Authority List of Acronyms Table of Contents List of Appendices List of Tables Chapter 1 General 1.1 Houston-Galveston-Brazoria Area Reasonable Further Progress Background 1.2 Reasonable Further Progress Requirements 1.3 Public Hearing and Comment Information 1.4 Social and Economic Considerations 1.5 Fiscal and Manpower Resources Chapter 2 Emissions Inventories 2.1 Introduction 2.1.1 Updated Uncontrolled Milestone Year Inventories 2.1.2 Updated Controlled Milestone Year Inventories 2.2 Point Sources 2.2.1 Emissions Inventories Development 2.2.2 Updated 2002 Base Year Inventories 2.2.3 Updated Uncontrolled Milestone Year Inventories 2.2.4 Updated Controlled Milestone Year Inventories 2.3 Area Sources 2.3.1 Emissions Inventories Development 2.3.2 Updated 2002 Base Year Inventories 2.3.3 Updated Uncontrolled Milestone Year Inventories 2.3.4 Updated Controlled Milestone Year Inventories 2.4 Non-Road Mobile Sources 2.4.1 Emissions Inventories Development 2.4.1.1 NONROAD Model Source Categories Emissions Estimation Methodology 2.4.1.2 Airport Emissions Estimation Methodology 2.4.1.3 Locomotive Emissions Estimation Methodology 2.4.1.4 Commercial Marine Emissions Estimation Methodology 2.4.1.5 Drilling Rig Diesel Engines Emissions Estimation Methodology 2.4.2 Updated 2002 Base Year Inventories 2.4.3 Updated Uncontrolled Milestone Year Inventories 2.4.4 Updated Controlled Milestone Year Inventories 2.5 On-Road Mobile Sources 2.5.1 Emissions Inventories Development 2.5.2 Updated 2002 Base Year I nventories 2.5.3 Updated 2002 Adjusted Base Y ear Inventories for the Base and Milestone Years 2.5.4 Updated Uncontrolled Milestone Year Emissions Inventories 2.5.5 Updated Controlled Milestone Year Emissions Inventories 2.6 Biogenic Sources 2.7 Emissions SummaryHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

viii Chapter 3 Target Emissions Levels and Reasona ble Further Progress Demonstration 3.1 Introduction 3.2 Target Level Methodology 3.3 Calculation of Target Emissions Levels 3.4 Growth 3.5 RFP Demonstration Chapter 4 Control Measures to Achieve Target Emissions Levels 4.1 Overview of Control Measures 4.2 Point Source Controls 4.3 Area-Source Controls 4.4 Non-Road Mobile Source Controls 4.4.1 NONROAD Model Categories 4.4.2 Non-Road Categories not in the NONROAD Model 4.5 On-Road Mobile Source Controls 4.6 VMT, On-Road Emissions, and Tr ansportation Control Measures 4.7 Contingency Measures Chapter 5 Motor Vehicle Emissions Budgets 5.1 Introduction 5.2 Overview of Methodologies and Assumptions 5.3 Motor Vehicle Emissions Budgets for RFP Milestone Years AppendicesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

ix LIST OF APPENDICES AppendixAppendix Name Appendix 1 HGB Reasonable Further Progress Demonstration Calculations Spreadsheet Appendix 2 Development of Reasonable Further Progress Point Source Inventories Appendix 3 Development of Reasonable Further Progress Area Source Inventories Appendix 4 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Source Categories in the EPA’s NONROAD 2005 Model Appendix 5 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Airports Appendix 6 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Locomotives Appendix 7 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Commercial Marine Vessels Appendix 8 Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories for Drilling Rigs Appendix 9 Houston-Galveston-Brazoria 1997 Eight- Hour Ozone Nonattainment Area Reasonable Further Progress On-Road M obile Source Emissions InventoriesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

x LIST OF TABLES NumberTable Name Table 2-1 HGB Eight-County RFP Point Source NO XEmissions Table 2-2 HGB Eight-County RFP Point Source VOC Emissions Table 2-3 HGB Eight-County RFP Area Source NO XEmissions Table 2-4 HGB Eight-County RFP Area Source VOC Emissions Table 2-5 HGB Eight-County RFP Non-Road Mobile Source NO XEmissions (Tons/Day) Table 2-6 HGB Eight-County RFP Non-Road Mobile Source VOC Emissions (Tons/Day) Table 2-7 HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VMT Table 2-8 HGB Eight-County RFP Ozone S eason Weekday On-Road Mobile Source NO X Emissions Table 2-9 HGB Eight-County RFP Ozone Seas on Weekday On-Road Mobile Source VOC Emissions Table 2-10 Summary of HGB Non-Creditabl e Reductions, Ozone Season Weekday On-Road Mobile Source VMT, and Adjusted Base Year Inventories Table 2-11 HGB RFP Ozone Season Weekday On-Road Mobile Source NO XEmissions and Control Strategy Reductions Table 2-12 HGB RFP Ozone Season Weekday On-Road Mobile Source VOC Emissions and Control Strategy Reductions Table 2-13 HGB Eight-County RFP Uncontrolled Ozone Season Weekday NO XEmissions Table 2-14 HGB Eight-County RFP Uncontro lled Ozone Season Weekday VOC Emissions Table 2-15 HGB Eight-County RFP C ontrolled Ozone Season Weekday NO XEmissions Table 2-16 HGB Eight-County RFP Controlle d Ozone Season Weekday VOC Emissions Table 3-1 Step by Step Summary of Calc ulation of 2008 Target Levels for HGB Table 3-2 Summary of Non-Creditable Fleet Turnover Reduction Table 3-3 Calculation of Required 3 Percent Per Year NO Xand VOC Reductions Table 3-4 RFP Post-2002 Target Level of NO XEmissions Table 3-5 RFP Post 2002 Target Level of VOC Emissions Table 3-6 Summary of RFP Demonstration for Eight HGB Counties for 2008 Table 3-7 Summary of RFP Demonstration for Eight HGB Counties for 2011 Table 3-8 Summary of RFP Demonstration for Eight HGB Counties for 2014 Table 3-9 Summary of RFP Demonstration for Eight HGB Counties for 2017 Table 3-10 Summary of RFP Demonstration for Eight HGB Counties for 2018 Table 4-1 Summary of HGB RFP NO XEmission Reductions Table 4-2 Summary of HGB RFP VOC Emission Reductions Table 4-3 Control Programs Modeled in MO BILE6 Emissions Factors for the Base and Milestone Years Table 4-4 RFP Controlled NO XEmissions, VOC Emissions, and VMT Table 4-5 2009 RFP Contingency Demonstration for HGB Area Table 4-6 2019 RFP Contingency Demonstration for HGB Area Table 5-1 2008 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-2 2011 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-3 2014 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-4 2017 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment Area Table 5-5 2018 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone Nonattainment AreaHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

xi LIST OF FIGURES

NumberFigure Name Figure 4-1 RFP VMT Trends Figure 4-2 RFP Controlled On-Road NO Xand VOC Emissions TrendsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

1-1 CHAPTER 1: GENERAL 1.1 HOUSTON-GALVESTON-BRAZORIA AREA REASONABLE FURTHER PROGRESS BACKGROUND On April 30, 2004, nonattainment area designations were published as part of the first phase of the United States Environmental Protection Agency’s (EPA) implementation rule for the 1997 eight-hour ozone standard (69 FR 23936). This notice defined the Houston-Galveston-Brazoria (HGB) nonattainment area as Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties. Based on the area’s 1997 eight-hour ozone design value (DV), the area was classified as moderate nonattainment. As part of the first phase of the EPA’s implemen tation rule for the 1997 ei ght-hour ozone standard (69 FR 23951), the Texas Commission on Environmen tal Quality (TCEQ) was required to submit an attainment demonstration state im plementation plan (SIP) revision fo r a moderate nonattainment area to the EPA by June 15, 2007. In addition to anattainment demonstration, a reasonable further progress (RFP) SIP revision that demonstrated a 15 percent reduction inanthropogenic ozone precursors, nitrogen oxides (NO X ) and volatile organic compounds (VOC), between 2002 and 2008 was also required to be submitted by the June 15, 2007, deadline. On May 23, 2007, the commission adopted the required RFP SIP revision, which was submitted to the EPA on June 13, 2007. On June 15, 2007, the TCEQ submitted a letter from the Governor of Texas to the EPA requesting that the HGB area be recl assified from a moderate to a severe nonattainment area for the 1997 eighthour ozone standard. The EPA granted the governor’s request on September 18, 2008. The effective date of this reclassification was October 31, 2008. As a result of the reclassification, the EPA set April 15, 2010, as the deadline for the state to submit an attainment demonstration SIP revision for the HGB area that addresses the sev ere ozone nonattainment area requirements, including RFP. The HGB area’s new attainment date for the 1997 ozone standard is as expeditiously as practicable, but no later than June 15, 2019. “The History of the Texas State Implementation Pl an (SIP),” a comprehensive overview of the SIP revisions submitted to the EPA by the State of Te xas is available at the following Web site: http://www.tceq.state.tx.us/implementation/air/sip/sipintro.html#History

. 1.2 REASONABLE FURTHER PROGRESS REQUIREMENTS The 1990 Federal Clean Air Act Amendments (FC AA), 42 United States Code (USC) §7410, require states to submit SIP revisions that contain enforceable measures to achieve the National Ambient Air Quality Standards (NAAQS). The FCAA also requi res states with nonattainment areas classified as moderate or above to submit plans showing reasonable further progress toward attainment of the ozone standard. This RFP SIP revision is neith er required for, nor intended to, demonstrate attainment of the ozone NAAQS but rather to demo nstrate that ozone precursor emissions will be reduced by 18 percent between 2002 and 2008, 9 percent between 2009 and 2011, 9 percent between 2012 and 2014, 9 percent between 2015 and 2017, 3 percent in 2018, and 3 percent in 2019 for contingency purposes. In addition to the RFP analyses, this SIP revi sion provides updated RFP on-road mobile vehicle emissions budgets (MVEB) and updated 2002 emissi ons inventories for point, area, on-road mobile, and non-road mobile sources. This SIP revisi on also includes existing contingency measure requirements to be implemented if the area fails to achieve the RFP milestones. A summary of how this plan meets RFP requirements can be found in Appendix 1: HGB Reasonable Further Progress Demonstrati on Calculations Spreadsheet

.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

1-2 1.3 PUBLIC HEARING AND COMMENT INFORMATION The commission held public hearings at the times and locations listed below.
CITY DATE TIME LOCATION
Houston October 28, 2009 2:00 P.M. Houston-Galveston Area Council 3555 Timmons Lane Houston, TX 77027 Conference Room A
Houston October 28, 2009 6:00 P.M. Houston-Galveston Area Council 3555 Timmons Lane Houston, TX 77027 Conference Room A
Austin October 29, 2009 3:00 P.M. TCEQ 12100 Park 35 Circle Austin, TX 78753 Building E, Room 201S

Question and answer sessions were held 30 minutes prior to the hearings. Neither the October 28, 2009, hearing scheduled for 6:00 p.m. nor the October 29, 2009, hearing was officially opened because no party indicated a desire to provide comment. The public comment period opened on October 9, 2009, and closed on November 9, 2009. Written comments were accepted via mail, fax, and through the eComments system. There were five comments. Summaries of public comments and TCEQ responses are included as part of this SIP revision. 1.4 SOCIAL AND ECONOMIC CONSIDERATIONS Because no new control strategies are associated withthis SIP revision, there are no changes that would require an analysis of so cial and economic considerations. 1.5 FISCAL AND MANPOWER RESOURCES The state has determined that its fiscal and manpower resources are adequate and will not be adversely affected through the implementation of this plan.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-1 CHAPTER 2: EMISSIONS INVENTORIES 2.1 INTRODUCTION The 1990 Federal Clean Air Act Amendments (FCAA) require that reasonable further progress (RFP) emissions inventories (EI) be prepared for ozonenonattainment areas. Ozone is photochemically produced in the atmosphere when volatile organi c compounds (VOC) are mixed with nitrogen oxides (NO X ) in the presence of sunlight. The Texas Commission on Environmental Quality (TCEQ) maintains an EI of up-to-date information on NO Xand VOC sources. The EI identifies the types of emissions sources present in an area, the amount of each pollutant emitted, and the types of processes and control devices employed at each plant or source category. The inventory provides data for a variety of air quality planning tasks, including establishing baseline emission levels, calculating reduction targets, developing control strategies toachieve the emissions reductions, developing emission inputs for air quality models, and tracking actual emission reductions against established emissions growth and control budgets. The total inventory of VOC and NO Xemissions for an area is summarized from the estimates developed for the fi ve general categories of emission sources: point, area, non-road mobile, on-road mobile, and biogenic. The TCEQ submitted a Houston-Galveston-Brazoria (HGB) RFP SIP revision to the United States Environmental Protection Agency (EPA) in 2007 for a moderate nonattainment area. On October 31, 2008, the HGB area was reclassified as a severe nonattainment area for the 1997 eight-hour ozone NAAQS. States are required by §172(e) of the FCAA to demonstrate an average of 3 percent annual reductions of VOC and/or NO Xemissions the first six years after the baseline year (2002) and every subsequent three year period, out to a severe area’s attainment date. In accordance with this requirement, this SIP revision includes anthropogeni c EI from the 2002 base year as well as projected anthropogenic EI for the milestone years 2008, 20 11, 2014, 2017, and 2018 to provide a basis for demonstrating how the required emissions reductions will be met. 2.1.1 Updated Uncontrolled Milestone Year Inventories The uncontrolled milestone year EIs represent the inve ntory for the milestone year if no further action to control emissions is taken beyond the controls already accounted for in the 2002 base year inventory. Inventories are first calculated for each source category using EPA-approved methodologies and then combined to obtain the to tal uncontrolled milestone year inventory for VOC and NO X . The uncontrolled milestone inventories include pre-2002 FCAA controls and growth in activity from 2002 to the milestone years, but do not include post-2002 FCAA controls. 2.1.2 Updated Controlled Milestone Year Inventories The controlled milestone year EIs represent the inve ntory for the milestone year with growth from the 2002 base year and with all RFP controls taken into account. Inventories are first calculated for each major source category using EPA-approved methodol ogies and then combined to obtain the total controlled milestone year inventories for VOC and NO X . The controlled milestone year inventories include pre-2002 FCAA controls, growth in activity from 1990 to the milestone year, and post-2002 FCAA controls used to meet the RFP target emissi ons level, but it does not include post-2002 FCAA controls that are not used to meet the RFP target emissions level. 2.2 POINT SOURCES 2.2.1 Emissions Inventory Development Stationary point source emissions data are collected annually from sites that meet the reporting requirements of 30 Texas Administrative Code (TAC ) §101.10. To collect the data, the TCEQ mails emissions inventory questionnaires (EIQ) to all site s identified as meeting the reporting requirements. Companies are required to report emissions data and to provide samples of calculations used to determine the emissions. Information characterizing the process equipment, the abatement units, and the emission points is also required. All data su bmitted in the EIQ are reviewed for quality assurance purposes and then stored in the State of Te xas Air Reporting System (STARS) database.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-2 2.2.2 Updated 2002 Base Year Inventory The 2002 base year inventory data were extractedfrom STARS on February 4, 2009. The extracted data contained ozone seas on daily emissions of NO Xand VOC from each site in the HGB area that submitted an EIQ for 2002 and reflected revisions madeon or before the extract date. County-level reported VOC emissions were adjusted to account for unreported VOC emissions discovered in the Texas Air Quality Study 2000 (TexAQS 2000). 2.2.3 Updated Uncontrolled Milestone Year Inventories The uncontrolled milestone year inventories were developed from the 2002 inventory was projected using the following approaches: applying projection factors to 2002 emissions, refining the VOC emission estimates to reflect unreported emissions, and adding emissions credits. First, emissions were projected by applying growth factors to the 2002 actual emissions. The Economic Growth Analysis System (EGAS) 5.0 was u sed to derive growth factors from the following data sets: the Regional Economic Modeling, Inc., (REMI) 5.5 factor set at the county-wide level for Texas; the REMI 6.0 factor set at the state-wide level; and the Moody’s Economy, Inc., factor set at the county-wide level for Texas. Growth factors were compared to actual growth in emissions from 2002 to 2005 for each contaminant and each industrial category at the county level, and the factors that most closely corresponded to historical growth were selected. County-level reported VOC emissions were then revised to account for unreported VOC emissions discovered in the TexAQS 2000. Based on TexAQS 2000 measurements ambient VOC concentrations in the Houston Ship Channel were determined to be several times greater than the estimates reported in the TCEQ’s emissions inventories. Finally, the inventories were adjusted to account for emissions credits. Emissions credits are emissions reductions that may return to the air shedin the future. To accountfor the possible use of these banked NO Xand VOC emissions, unused emissions reduction credits (ERCs) and discrete emissions reduction credits (DERCs) as of October 2008, were applied to the inventory. 2.2.4 Updated Controlled Milestone Year Inventories The controlled milestone year inventories were developed from the 2005 inventory using the following approaches: applying projection factor s to 2005 emissions, applying Emissions Banking and Trading program allocations, applying rules that limit emissions from tank landings, refining VOC emission estimates to reflect unreported emi ssions, and adding emissions credits. The 2005 inventory was designated as the baseline year for controlled projections because it was the most recent National Emissions Inventory year availabl e. The 2005 inventory was extracted from STARS on February 4, 2009. The extracted data were reported ozone season daily emissions of NO Xand VOC from each site in the HGB area that submitte d a 2005 EIQ and reflected revisions made on or before the extract date. Industrial source NO Xcontrols are reflected in the Mass Emissions Cap and Trade program (MECT) 2008 NO Xcap. The MECT NO Xemissions allocations account for NO Xcontrols, including controls applied to electric generating units (EGU) and large stationary engines as defined by 30 TAC Chapter 117, Subchapters C: Combustion Control at Major Utility Electric Generation Sources in Ozone Nonattainment Areasand D: Combustion Control at Minor Sources in Ozone Nonattainment Areas

. The controlled milestone year NO Xinventories were developed by applying projection factors to baseline year emissions and then applying the unit- specific allocations from the MECT for regulated sources. Emissions were then added to account for unused NO Xemissions credits. The VOC controls are reflected in the highly reac tive volatile organic compounds emissions cap and trade program (HECT) and 30 TAC Chapter 115 chang es that limit tank landings. The HECT cap is an annual cap on sitewide highly reactive volatile organic compounds (HRVOC) emissions fromHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-3 equipment that are subject to the HRVOC contro l requirements of 30 TAC Chapter 115, Subchapter H, Division 1: Vent Gas Controlor Division 2: Cooling Tower Heat Exchange Systemsfor applicable sites listed in the cap. Other 30 TAC Chapter 115 changes limit convenience landings unless an abatement device is used to control the VOC emissions or landing loss emissions are authorized under an emission limit or cap in a permit issued under 30 TAC Chapter 116. The controlled milestone year VOC inventories were deve loped by applying projection factors to baseline year emissions and then applying the HECT allo cations to HRVOC emissions from applicable units at regulated sites. Reductions were then applied for 30 TAC Chapter 115, Subchapter B, Division 1: Storage of Volatile Organic Compounds . County-level VOC emissions were then adjusted to account for unused credits and unreported VOC emissions determined from ambient monitoring data. A summary of the point source RFP inventories is presented in Table 2-1: HGB Eight-County RFP Point Source NOX Emissions and Table2-2: HGB Eight-County RFP Point Source VOC Emissions

. Table 2-1: HGB Eight-County RFP Point Source NO XEmissions NO X(tons per day) RFP Analysis Year Uncontrolled Controlled 2002 339.29 339.29 2008 375.56 155.73 2011 383.85 156.21 2014 401.05 157.17 2017 421.57 158.33 2018 428.69 158.75

Table 2-2: HGB Eight-County RFP Point Source VOC Emissions VOC (tons per day) RFP Analysis Year Uncontrolled Controlled 2002 316.62 316.62 2008 333.14 170.05 2011 338.75 164.33 2014 347.70 172.31 2017 358.79 181.86 2018 362.90 185.38

For more details on the point source projection method, please refer to Appendix 2: Development of Reasonable Further Progress Point Source Inventories

. 2.3 AREA SOURCES 2.3.1 Emissions Inventory Development Area sources are commercial, small-scale industrial, and residential sources that use materials or perform processes that generate emissions. Area sources are too small to meet the emissions reporting criteria for major point sources, so emi ssions are calculated as county-wide totals rather than as individual facilities. Area sources can be divided into two groups characterized by the emission mechanism: hydrocarbon evaporative emissions and fuel combustion emissions. Examples of evaporative sources include printing operati ons, industrial coatings, degreasing solvents, house paints, leaking underground storage tanks, gasoline service station underground tank filling, and vehicle refueling operations. Fuel combusti on sources include oil and gas production sources, stationary source fossil fuel combustion at residences and businesses, outdoor refuse burning,HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-4 structural fires, and wildfires. With some exceptions, these emissions may be calculated by multiplying an established emission factor (emissions per unit of activity) by the appropriate activity or activity surrogate responsible for generating emissions. Population is the most commonly used activity surrogate for many area sources. Other activity data include the amount of gasoline sold in an area, employment by industry type, and acres of cropland. 2.3.2 Updated 2002 Base Year Inventory The 2002 base year EI was developed in 2003. Because the TCEQ was re quired to submit this inventory to the EPA as the Periodic Emissions I nventory, considerable effort went into its development. Since that time, there have b een additional updates to the 2002 area source EI. Improvements resulted from bottom-up surveys for some categories, such as gasoline stations. Surveys produce data that more accurately depict facility activity levels than do top-down methodologies that usually rely on default surrogates such as county populations and numbers of employees associated with appropriate EPA emission factors. Activity data for other categories were available from various sources. The Energy Information Administration maintains state level fuel use data for the residential, industrial, and commercial sectors for fuels ranging from coal to natural gas. This data is useful in calculating emissions from home cooking, water heating, and similar use at the industrial and commercial levels. Actual oil and gas production data are available from the Railroad Commission of Texas, which were used in th ese updated 2002 inventories. State and local governments also provided data on asphalt usage in road paving projects. The EPA’s Emissions Inventory Improvement Program produced ap proved methodologies for several area source categories. The latest version of the EPA’s growth factor system, EGAS 5.0, was used to grow emissions from the 1999 area source emissions inventory for some sources. 2.3.3 Updated Uncontrolled Milestone Year Inventories For most area source categories, the 2002 base year EI was projected to 2008 , 2011, 2014, 2017, and 2018 using improved growth factors. A contract or project developed a complete set of updated EGAS growth factors using REMI and other economic data. 1 For a few categories, census populations were used to project the future emissions. 2.3.4 Updated Controlled Milestone Year Inventories The controlled 2008, 2011, 2014, 2017, and 2018 in ventories were developed by first projecting the 2002 base year inventory to specific years and then applying controls. The only rule affecting area sources in the HGB area that came into effect after 2002 is the federal portable fuel container (PFC) rule (72 FR 8428, published February 26, 2007). Controlled emissions based on the federal PFC rule do not take effect until 2010, so there were no emi ssions reductions from the federal rule in the 2008 inventories (i.e., no emissions reductions credits were taken in 2008 for PFC). Many rules concerning industrial coatings and gasoline st ation underground tank filli ng (Stage I) and vehicle refueling (Stage II) were accounted for in the base year numbers. A summary of the area source RFP inventories is presented in Table 2-3: HGB Eight-County RFP Area Source NOx Emissions , and Table 2-4: HGB Eight-County RFP Area Source VOC Emissions

. Please note that there is no difference between the uncontrolled and controlled NO Xemissions for the base and all milestone years and the VOC emissions for the base year and 2008 because there were no controls applied to the projected area source inventories.

1 Eastern Research Group, Inc., “Development of County Level Growth Factors from 1990 through 2020,” TCEQ Contract No. 582-04-65564, Work Order No. 65564-05-18, August 2005.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-5 Table 2-3: HGB Eight-County RFP Area Source NOx Emissions NO X(tons per day) RFP Analysis Year Uncontrolled Controlled 2002 89.11 89.11 2008 89.63 89.63 2011 93.90 93.90 2014 96.01 96.01 2017 98.23 98.23 2018 99.38 99.38 Table 2-4: HGB Eight-County RFP Area Source VOC Emissions VOC (tons per day) RFP Analysis Year Uncontrolled Controlled 2002 407.61 407.61 2008 371.82 371.82 2011 382.72 379.04 2014 393.07 383.42 2017 404.84 394.74 2018 408.82 398.57

For more details on the area source projection method, please refer to Appendix 3: Development of Reasonable Further Progress Area Source Inventories

. 2.4 NON-ROAD MOBILE SOURCES 2.4.1 Emissions Inventory Development Non-road sources include vehicles, engines, and equipment used for construction, agriculture, transportation, recreation, and many other purposes. Non-road vehicles are also referred to as "offroad" or "off-highway" vehicles since they do not normally operate on roads or highways. This broad category is comprised of a diverse collection of machines, many of which are powered by diesel engines. Non-road emissions sources include, bu t are not limited to: agricultural equipment; commercial and industrial equipment; construc tion and mining equipment; lawn and garden equipment; aircraft and airport equipment; lo comotives; and commercial marine vessels and equipment. A Texas specific version of the EPA’s NONROAD 2005 model, called the Texas NONROAD (TexN) model, was used to calculate emissions from all non-road mobile equipment and recreational vehicles except aircraft, locomotives, commercial mari ne, and oilfield drilling rigs. The TexN model does not include commercial marine vessel, locomoti ve, or airport emissions. Emissions for these three source categories are esti mated using other EPA methods and guidance documents. However, support equipment for aircraft, locomotive, and commercial marine operations and facilities are included in the NONROAD model. Although oilfield drilling rigs are included in the NONROAD model, emissions from this category were developed separately to provide more accurate inventories. 2 For this reason, equipment populations for oilfield drilling rigs were set to zero in the TexN model.

2Eastern Research Group, Inc., “Emissions from Oil and Gas Production Facilities,” TCEQ Contract No. 582- 07-84003-01, August 31, 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-6 2.4.1.1 TexN Model Source Categories Emissions Estimation Methodology Emissions for all non-road mobile categories except aircraft, locomotives, and commercial marine vessels were calculated using the TexN model. Modeling emissions from the non-road sector is especially challenging because of difficulties in determining in-use population, activity, load, and emission rates. Although operating the EPA’s model w ith all of the default surrogates is acceptable, the EPA encourages states to update the model wi th local, county-level data based on surveys and other relevant information. In order to facilitatethe development of non-road emissions inventories with locality specific inputs, TexN was developed to estimate emissions from all sources included in the EPA’s NONROAD model for Texas. The TexN model is a software tool for developing emissions estimates for non-road mobile sources inTexas using county specific activity data. The model allows air quality planners to replace EPA’s default data with local bottom-up data. Local, county-level data is incorporated into the TexN model as it becomes available to the TCEQ. Several emission inventory studies have been conducted in Texas in recent years to improve upon the default data available in the EPA’s NONROAD 2005 mode l. These studies have focused on various equipment categories operating in different areas of the state, including diesel construction equipments, liquid propane gas powered forklifts, transportation refrigeration units, commercial lawn and garden, and recreational marine vessels. A detailed listing of the non-road equipment studies and surveys conducted in Texas and documentation of procedures used in developing the non-road RFP emissions inventories can be found in Appendix 4: Development of Reasonable Further Progress Non-Road Mobile Source Emissions Inventories fo r Source Categories in the EPA’s NONROAD 2005 Model

. 2.4.1.2 Airport Emissions Estimation Methodology Emissions from airport activities in the HGB area were estimated for Ellington Field, George Bush Intercontinental Airport, and William P. Hobby Airport. Emissions were calculated using the Federal Aviation Administration (FAA) Emissions and Disp ersion Modeling System (EDMS), version 5.1. The airport emissions categories considered for th is RFP analysis were aircraft (commercial air carriers, air taxis, general aviation, and military), auxiliary power units (APU), and ground support equipment (GSE) operations. The 2005 through 2018 aircraft, APU, and GSE (George Bush Intercontinental and Hobby Airports) emissions were obtained from the Houston Airport System (HAS) emissions inventory, which was submitted to the TCEQ on January 9, 2009, by Jacobs Consultancy. GSE emissions from Continental Airlines was prepared by Landrum and Brown, Inc., and submitted to the TCEQ, January 21, 2009, an d GSE emissions from Southwest Airlines were prepared using EDMS version 5.02. Since there wereno emissions inventory data available for 2008, the 2008 emissions were estimated using an interpolation method between the years 2005 and 2011. The documentation of procedures used in developi ng the airport emissions inventories can be found in Appendix 5: Development of RFP Non-Road Mobile Source Emissions Inventories for Airports

. 2.4.1.3 Locomotive Emissions Estimation Methodology Emissions for locomotive activities were obtained from the Texas Air Emissions Repository (TexAER) database. Controlled estimated emissi ons for calendar years 2008 , 2011, 2014, 2017, and 2018 were determined from data extrapolated from the Tier-Specific Locomotive Engine Update , August 31, 2007, conducted for the TCEQ by Eastern Research Group, Inc., (ERG) and contained in TexAER. The study was developed to ascertain emis sions activity in the Dallas-Fort Worth area, the Houston-Galveston-Brazoria area, and Texas. The growth rate was developed using reports from railway companies and regulatory controls data. Uncontrolled estimated emissions for calendar years 2008, 2011, 2014, 2017, and 2018 were developed and extrapolated using emissions trends data from the 1997 EPA Technical Highlights document. 3 In this document, Tier I and II emissionstandards for manufactured and remanufactured

3 United States Environmental Protec tion Agency, “Emission Factors for Lo comotives,” Technical Highlights, EPA-420-F-97-051, December 1997.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-7 diesel-powered locomotives and locomotive engin es were established. The documentation of procedures used in developing the locomotive emis sions inventories can be found in Appendix 6: Development of RFP Non-Road Mobile Source Emissions Inventories for Locomotives

. 2.4.1.4 Commercial Marine Emissions Estimation Methodology Commercial marine activities were obtained from the 2000 and 2007 emissions projections provided to TCEQ via contract with Starcrest and ERG. 4,5 Emission growth factors provided by ERG were considered in obtaining 2008, 2011, 20 14, 2017, and 2018 emission estimates. 6The documentation of procedures used in developing the commercial marine emissions inventories emissions inventories can be found in Appendix 7: Development of RFP Non-Road Mobile Source Emissions Inventories for Commercial Marine Vessels

. 2.4.1.5 Drilling Rigs Diesel Engines Emissions Estimation Methodology Oilfield drilling rig diesel engines are included inthe NONROAD model category “Other Oilfield Equipment” which includes various types of equipment. Due to the significant growth in the oil and gas exploration and production industry, the emissi ons inventory for diesel drilling rigs was included in a contract with ERG. 7 Emission trends were developed using oil and gas production data trends for 2008, 2011, 2014, 2017, and 2018 emission estimates. The documentation of procedures used in developing the drilling rig emissions inve ntories can be found in Appendix 8: Development of RFP Non-Road Mobile Source Emissions Inventories for Drilling Rigs

. 2.4.2 Updated 2002 Base Year Inventory Since the 2002 base year EI was originally devel oped in 2003, input data in the NONROAD model were updated using the results of several contracted projects. Since the TexN model incorporated all of the recently updated input data, revised 2002 non-road EI for the NONROAD model categories were developed using the TexN model. The 2002 ai rcraft and GSE as well as locomotive emissions were obtained from the TexAER database. The 2002base year EI for commercial marine vessels was obtained from the 2000 and 2007 emissions projections provided to TCEQ via contract with Starcrest and ERG (see footnotes 4 and 5). The 2002 base yearEI for drilling rigs was developed from data provided by ERG (see footnote 7). 2.4.3 Updated Uncontrolled Milestone Year Inventories The uncontrolled emissions per analysis year ( 2002, 2008, 2011, 2014, 2017, and 2018) were calculated by adding the controlled emissions for th at year with the sum of all of the individual controls used to demonstrate RFP for that year . The locomotive uncontrolled emission inventories were obtained from the EPA’s December 1997 Emission Factors for Locomotives document. Emissions for commercial marine vessels were developed from two surveys of vessel types and activities in the Port of Houston and surrounding ports. The Railroad Commission of Texas provided actual annual oil and gas production data for eachcounty, from which diesel drilling rig emissions trends were developed. 2.4.4 Updated Controlled Milestone Year Inventories The effects of federal and state control programs were evaluated. The TexN model was executed for ozone season daily emission for y ears 2002, 2008, 2011, 2014, 2017, 2018, and 2019. To evaluate

4Starcrest Consulting Group, LLC, “2007 Goods Movement Air Emissions Inventory at the Port of Houston,” provided by the Port of Houston Authority, January 2009. 5 Eastern Research Group, Inc., “Development of Emissi on Estimates for Offshore Non-road Mobile Sources in Texas State Waters,” TCEQ Contract No. 582-04-65564, Work Order No. 65564-05-13, August 31, 2005. 6 ERG, “Commercial Marine Vessel, Locomotive, and Aircraft Growth Factors,” TCEQ Contract No. 582-07- 84003-02, August 31, 2007. 7 ERG, “Emissions from Oil and Gas Production Facilities,” TCEQ Contract No. 582-07-84003-01, August 31, 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-8 individual control measure emission reductions for the RFP requirements, a series of TexN model runs were executed for both controlled and uncontro lled scenarios for each federal and state control program. Airport emissions were projected for future years 2008, 2011, 2014, 2017, and 2018 using the growth factors from the Terminal Area Forecast (TAF) summary for fiscal year 2008 – 2025. 8 Locomotive controlled emission estimates were deve loped from the TexAER data extrapolated from data obtained through a contract conducted for the TCEQ by ERG and contained in TexAER. 9The growth rate was developed using reports from railway companies and regulatory controls data. The controlled emission inventories for commercial marine vessels were developed from two surveys of vessel types and activities in the Port of Houston and surrounding ports (see footnotes 4 and 5). Based on 2002 data from the Railroad Commission of Texas, diesel-drilling rig emissions trends were developed for 2008, 2011, 2014, 2017, and 2018. No controlled emissions reductions apply to drilling rigs. Summaries of all the non-road mobile source RFP inventories are presented in Table 2-5: HGB Eight-County RFP Non-Road Mobile Source NO XEmissions (Tons/Day) and Table 2-6: HGB EightCounty RFP Non-Road Mobile Sou rce VOC Emissions (Tons/Day) . Because there are no controls applied to airport and drilling rigs, these co lumns display only uncontrolled emissions. Table 2-5: HGB Eight-County RFP Non-Road Mobile Source NOx Emissions (Tons/Day) NONROAD Model Categories Locomotive Commercial Marine Airport Drilling Rig RFP Analysis

Year Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled 2002 88.63 79.01 34.58 34.58 28.01 27.63 6.35 9.41 2008 105.39 65.80 49.6 37.86 30.97 29.01 9.90 6.86 2011 111.18 54.97 49.17 36.42 32.45 29.22 10.43 6.79 2014 117.09 43.88 51.19 37.10 33.93 29.20 11.53 6.74 2017 124.33 35.94 52.42 37.18 35.41 29.20 12.12 6.71 2018 128.14 33.68 54.23 38.19 35.90 29.00 12.32 6.69 Table 2-6: HGB Eight-County RFP Non-Road Mobile Source VOC Emissions (Tons/Day) NONROAD Model Categories Locomotive Commercial Marine Airport Drilling Rig RFP Analysis

Year Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled 2002 96.70 79.05 2.28 2.28 1.08 1.06 1.68 0.25 2008 109.00 63.01 2.56 2.29 1.20 1.12 2.62 0.18 2011 115.34 57.76 2.59 2.25 1.25 1.13 2.71 0.18 2014 121.33 55.02 2.71 2.28 1.31 1.13 2.81 0.18 2017 126.24 53.78 2.85 2.32 1.37 1.13 2.64 0.18 2018 129.34 53.58 2.94 2.35 1.39 1.13 2.60 0.18

8 United States Department of Tran sportation, Federal Aviation Admini stration, “Terminal Area Forecast Summary, Fiscal Years 2008-2025,” FAA-APO-06-1, January 2009. 9Eastern Research Group, Inc., “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07- 84003-04, August 31, 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-9 2.5 ON-ROAD MOBILE SOURCES 2.5.1 Emissions Inventory Development On-road mobile emissions sources consist of automobiles, trucks, motorcycles, and other motor vehicles traveling on public roadways. On-road mob ile source emissions are usually categorized as either combustion-related emissions or evaporative hydrocarbon emissions. Combustion-related emissions are estimated for vehicl e engine exhaust. Evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources on the vehicle. To calculate emissions, both the rate of emissions per unit of activity (emission factor s) and the number of units of activity must be determined. Emission factors are developed us ing EPA's mobile emission fact or model MOBILE. The model may be run using national defau lt information or input may be provided to modify the model calculations to simulate the driving behavior, me teorological conditions, and vehicle characteristics specific to the HGB area. Because inputs influen ce the emission factors calculated by the MOBILE model, every effort is made to input parameters reflecting local conditions, rather than national default values. The localized i nputs used for the HGB RFP on-road mobile EI development include vehicle speeds for each roadway link, temperature, humidity, vehicle age distributions for each vehicle type, percentage of miles traveled for each vehicle type, type of inspection-maintenance program, fuel control programs, and gasoline vapor pressure controls. To estimate on-road mobile emissions, emission f actors calculated by the MOBILE model described above must be multiplied by the level of vehicle ac tivity. On-road mobile source emission factors are expressed in units of grams per mile. Therefore, th e activity information that is required to complete the inventory calculation is vehicle miles traveled (VMT) in units of miles per day. The level of vehicle travel activity is developed using travel demand models (TDM) run by the Texas Department of Transportation or the local metropolitan planning organizations. TDM are validated against a large number of ground counts, i.e., traffic passing over counters placed in various locations throughout a county or area. VMT estimates are often calib rated against outputs from the federal Highway Performance Monitoring System, a federal model built from a different set of traffic counters. In addition to the number of miles traveled on eachroadway link, the speed on each roadway type or segment is also needed to complete an on-roademissions inventory. Roadway speeds, required inputs for the MOBILE model, are calculated by using the activity volumes from the TDM and a post-processor speed model. In order to perform the RFP calculations, a state must determine the base inventory from which the calculations begin, the amount of reductions achieve d from controls that were implemented prior to the FCAA and therefore not creditable toward FCAA RFP requirements, the uncontrolled milestone year inventory, and the emission re duction controls to demonstrate that RFP is met for each milestone year. To determine all of the information required for RFP calculations, a set of on-road mobile source inventories and control measure reduction estimates are required to complete the RFP calculations.

 The 2002 base year is the starting point for the 1997 eight-hour ozone RFP demonstration. This starting point establishes the inventory as it existed in 2002, the RFP base year established by the EPA for areas designated as nonattainment for the 1997 eight-hour ozone standard.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-10  The adjusted base year (ABY) inventories are the basis for calculating the percent reductions, as required in the RFP guidance, and as a basis for determining the non-creditable reductions due to control programs implemented prior to the FCAA. 10Because the ABY inventory adjusts the 2002 base year inventory for the fleet turnover effects of the pre-1990 Federal Motor Vehicle Control Program (FMVCP) and the 1992 Reid Vapor Pressure (RVP) control, only the emission rates are different than the 2002 base year. Speed and VMT activity levels for both the 2002 base year and ABY inventories are consistent with both the TDM output for the 2002 roadway network and demographic demands.

 An on-road mobile ABY inventory is required for each milestone year and for any year for which a percent reduction requireme nt calculation must be completed. The ABY inventory is used to determine the level of non-creditable reductions for each RFP milestone year.

 The RFP analysis also requires an uncontrolled inventory with growth between the base year and the milestone year. These uncontrolled inventories serve as the basis for determining how much emissions reduction is required to meet the RFP target.

 The RFP analysis requires the calculation of a controlled inventory to subtract from the uncontrolled inventory to determine the effectiv eness of control strategies. RFP requires direct calculation of the emission reductions from control strategies that are then subtracted from the uncontrolled emissions to determine the controlled inventory value. Both the total from on-road mobile control strategies and the emission reductions from each individual control strategy are calculated. A summary of the on-road mobile source vehicle miles traveled used to develop the various NO Xand VOC emissions levels in subsequent tables is presented in Table 2-7: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VMT , Table 2-8: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source NO XEmissions , and Table 2-9: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VOC Emissions . For complete documentation of the development of the on-road mobile source inventories for the HGB RFP demonstration, refer to Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories . The complete set of input and output files are available upon request from the TCEQ’s Air Quality Division. Table 2-7: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VMT Inventory Scenario (vehicle miles traveled per day) RFP Analysis

Year Adjusted Base Year Uncontrolled Controlled 2002 135,716,461 135,716,461 135,716,461 2008 135,716,461 146,039,120 146,039,120 2011 135,716,461 154,332,688 154,332,688 2014 135,716,461 168,390,202 168,390,202 2017 135,716,461 180,067,224 180,067,224 2018 135,716,461 184,010,300 184,010,300

10United States Environmental Protection Agency, “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard; Final Rule,” Federal Register (70 FR 71631), November 29, 2005.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-11 Table 2-8: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source NOx Emissions Inventory Scenario (tons per day) RFP Analysis

Year Adjusted Base Year Uncontrolled Controlled 2002 387.09 387.09 326.72 2008 346.01 363.05 175.80 2011 335.20 372.46 123.41 2014 334.08 407.05 86.61 2017 333.24 432.04 61.78 2018 333.17 443.70 55.39 Table 2-9: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source VOC Emissions Inventory Scenario (tons per day) RFP Analysis

Year Adjusted Base Year Uncontrolled Controlled 2002 189.08 189.08 132.64 2008 185.46 194.89 86.15 2011 184.23 205.03 68.35 2014 183.60 222.41 56.21 2017 183.50 237.86 48.39 2018 183.46 242.84 46.68

2.5.2 Updated 2002 Base Year Inventory The 2002 base year EI for on-road mobile sources was updated using emission factors calculated using the latest version of the MOBILE model, MO BILE6.2.03. Additional updates were made to incorporate the latest activity estimates from th e HGB travel demand model 2002 network. Only control strategies implemented prior to 2002 were included in the input to the inventory development for the 2002 on-road mobile source base year inventory. These controls include: pre-1990 FMVCP, fleet turnover to Tier 1 FMVCP, reformulatedgasoline, and the HGB vehicle inspection and maintenance (I/M) program. The activity levels used to calculate the inventory reflect the 2002 roadway network with 2002 VMT and speeds. A su mmary of the inventory is presented in Table 2- 10: Summary of HGB Non-Creditable Reductions, Oz one Season Weekday On -Road Mobile Source VMT, and Emissions . For complete documentation of the de velopment of the inventory and details on MOBILE model inputs, refer to Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories

. 2.5.3 Updated 2002 Adjusted Base Year Inventories for the Base and Milestone Years The RFP planning process includes calculating th e adjusted base year EI, from which required percent emission reductions are calculated. As speci fied by the FCAA, certain on-road mobile source emissions reductions are not creditable towardthese required percentage reductions. The noncreditable reductions include reductions from controls that were promulgated prior to the 1990 FCAA. The two rules that are non-creditable for this HGB 1997 eight-hour ozone RFP SIP revision are pre-1990 FMVCP and pre-1990 promulgated federal fuel volatility regulations (summertime gasoline RVP limits beginning in 1992). Because th e defeat device for heavy-duty diesel vehicles (HDDV) was affecting a FMVCP that was im plemented prior to the 1990 FCAA, the HDDV NO X off-cycle emissions effects and associated mitigation program effects are also considered non-HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-12 creditable. For this HGB RFP demonstration, pre-1990 non-creditable emission reductions include pre-1990 FCAA FMVCP, 1992 summerti me RVP limits, and HDDV NO Xoff-cycle emissions and mitigation programs. An adjusted base year EI for on-road mobile sources is developed for each milestone year using emissions factors from the MOBILE model, which re flect only control strategies implemented prior to 1990. By projecting the pre-1990 FMVCP into future years, the effects of additional fleet turnover benefit due to the new standards is reflected in th e emission factors. The controls included in the ABY inventory development include pre- 1990 FCAA FMVCP and the 1992 summertime RVP control. The activity levels used to calculate the ABY inventories reflect the 2002 roadway network with 2002 VMT and speeds. The estimated non-creditable emissions reductions due to pre-1990 controls are calculated by subtracting the 2002 ABY inventory, relative to the target year, from the actual 2002 base year inventory. A summary of the inventories and associated non-creditable emissions reductions is presented in Table 2-10: Summary of HGB Non-Creditable Reductions, Ozone Season Weekday On-Road Mobile Source VMT, and Adjusted Base Year Inventories

. Creditable controls are discussed are discussed in Section 2.5.5: Updated Controlled Milestone Year Emissions Inventories . For complete documentation of the de velopment of the inventory and details on MOBILE model inputs, refer to Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories

. Table 2-10: Summary of HGB Non-Creditable Reductions, Ozone Season Weekday On-Road Mobile Source VMT, and Adjusted Base Year Inventories Inventories Non-Creditable Emissions Reductions Calendar Year VMT NO X VOC NO X VOC 2002 Base Year 135,716, 461 326.72 132.64 N/A N/A 2002 Adjusted Base Year (ABY) 135,716,461 387.09 189.08 N/A N/A 2008 ABY 135,716,461 346.01 185.46 41.08 3.62 2011 ABY 135,716,461 335.20 184.23 10.81 1.23 2014 ABY 135,716,461 334.08 183.60 1.12 0.63 2017 ABY 135,716,461 333.24 183.50 0.84 0.10 2018 ABY 135,716,461 333.17 183.46 0.07 0.04 Note: VMT is presented in miles per day and NO Xand VOC emissions are presented in tons per day. 2.5.4 Updated Uncontrolled Milestone Year Emissions Inventories The uncontrolled on-road mobile emissions inventories for each RFP milestone year were developed using emission factors that reflect only control strategies implemented prior to 2002. The latest version of MOBILE, MOBILE6.2.03, was used to deve lop the inventories for this SIP revision. The activity levels were updated to include the latest output from the HGB transportation demand model. These controls include Pre-1990 FMVCP, the 1992 RVP control, fleet turnover to Tier 1 FMVCP, reformulated gasoline, and the HGB vehicle I/M program. The activity levels used to calculate the inventory reflect the milestone roadway network, with milestone year VMT and speeds. A summary of the inventories is presented in Tables 2-8: HGB Eight-County RFP Ozone Season Weekday OnRoad Mobile Source NOx Emissionsand 2-9: HGB Eight-County RFP Ozone Season Weekday OnRoad Mobile Source VOC Emissions . For complete documentation of the development of the inventory and details on MOBILE model inputs, refer to Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Re asonable Further Progress On-Road Mobile Source Emissions Inventories

.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-13 2.5.5 Updated Controlled Milestone Year Emissions Inventories The controlled on-road mobile emissions inventories for each RFP milestone year were developed using emission factors that reflect both control strategies implemented prior to 2002 and the control strategies used to demonstrate compliance with RFP requirements. These controls include pre-1990 FMVCP, fleet turnover to Tier 1 of the FMVCP, fleet turnover to Tier 2 of the FMVCP, the 2007 heavy-duty diesel FMVCP standards, summer reformulated gasoline, the HGB vehicle I/M program, the anti-tampering program, and Texas Low Emissi on Diesel (TxLED). control scenario inventory values include both the controlled in ventory and the level of reductions for each control strategy. A summary of the uncontrolled on-road mobile inve ntory, the individual on-road mobile control reductions, and the resulting cont rolled on-road mobile inventory for each milestone year are summarized in Table 2-11: HGB RFP Ozone Season WeekdayOn-Road Mobile Source NO X Emissions and Control Strategy Reductionsand Table 2-12: HGB RFP Ozone Season Weekday OnRoad Mobile Source VOC Emissions and Control Strategy Reductions

. Table 2-11: HGB RFP Ozone Season Weekday On-Road Mobile Source NO XEmissions and Control Strategy Reductions NO X( tons per day )

Emissions Inventory and Control Strategy Description 2008 2011 2014 2017 2018 Uncontrolled (see Table 2- 8) 363.05 372.46 407.05 432.04 443.70 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 68.11 62.24 56.88 49.05 49.28 Federal Reformulated Gasoline (RFG) 46.75 72.94 104.41 128.94 135.65 I/M in Harris County 13.65 16.07 20.82 25.11 26.48 National Low Emission Vehicle Program (NLEV) 9.12 9.31 6.16 3.42 2.66 Expanded I/M 7.06 5.12 10.15 8.63 9.16 Tier 2 FMVCP 24.98 51.95 53.79 91.98 96.36 2007 Heavy-Duty Diesel FMVCP 8.70 28.22 66.13 61.69 67.54 On-road TxLED 8.87 3.21 2.11 1.45 1.19 Controlled 175.80 123.41 86.61 61.78 55.39

Table 2-12: HGB RFP Ozone Season Weekday On-Road Mobile Source VOC Emissions and Control Strategy Reductions VOC ( tons per day )

Emissions Inventory and Control Strategy Description 2008 2011 2014 2017 2018 Uncontrolled (see Table 2- 9) 194.89 205.03 222.41 237.86 242.84 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 45.57 63.02 79.36 91.17 94.52 Federal Reformulated Gasoline (RFG) 34.24 34.51 37.17 39.99 40.97 I/M in Harris County 10.42 11.35 12.43 13.49 13.90 National Low Emission Vehicle Program (NLEV) 5.33 4.81 3.27 1.97 1.59 Expanded I/M 3.09 3.30 4.44 4.32 4.50 Tier 2 FMVCP 9.91 19.19 16.87 37.20 39.39 2007 Heavy-Duty Diesel FMVCP 0.15 0.45 12.53 1.00 1.08 On-road TxLED 0.04 0.06 0.12 0.33 0.21 Controlled 86.15 68.35 56.21 48.39 46.68HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-14 The MVEB calculations for each milestone year are documented in Chapter 5: MOTOR VEHICLE EMISSIONS BUDGETS

. The activity levels used to calculate the inventory reflect the milestone roadway network, with milestone year VMT and speeds. A summary of the inventories is presented in Table 2-8: HGB Eight-County RFP Ozone Season, W eekday On-Road Mobile Source NO XEmissionsand Table 2-9: HGB Eight-County RFP Ozone Season WeekdayOn-Road Mobile Source VOC Emissions . For complete documentation of the development of th e inventory and details on MOBILE model inputs, refer to Appendix 9: Houston-Galveston-Brazoria 1997 Eight -Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventories

. 2.6 BIOGENIC SOURCES Biogenic sources include hydrocarbon emissions from crops, lawn grass, and trees as well as a small amount of NO Xemissions from soils. Plants are sources of VOC such as isoprene, monoterpene, and alpha-pinene. The tool for estimating biogenic emissions is the EPA Biogenic Emissions Inventory System. The biogenic emissions are important in de termining the overall emissi ons profile of an area and therefore are required for regional air quality modeling and to meet periodic EPA reporting requirements. Since the 2002 base year EI is based upon the inventory developed to meet EPA periodic reporting requirements, the 2002 base year EI includes biogenic emissions. The RFP methodology does not include biogenic emissions. Therefore, the first step in the RFP methodology subtracts the biogenic emissions from the 2002 base year EI. The resulting 2002 total anthropogenic EI is called the 2002 RFP base year EI. The calculation of the 2002 HGB RFP base year EI is documented in Sheet 16 of Appendix 1: HGB RFP Demonstration Calculations Spreadsheet

. Since the RFP methodology excludes biogenic emissions, biogenic RFP EI are not developed for RFP milestone years. 2.7 EMISSIONS SUMMARY Uncontrolled base and milestone year NO Xand VOC emissions in the HGB area for each RFP source category are summarized in Tables 2-13: HGB Eight-County RFP Uncontrolled Ozone Season Weekday NOX Emissionsand 2-15: HGB Eight-County RFP Uncontro lled Ozone Season Weekday VOC Emissions . Controlled base and milestone year NO Xand VOC emissions in the HGB area for each RFP source category are summarized in Tables 2-14: HGB Eight-County RFP Controlled Ozone Season Weekday NO XEmissionsand 2-16: HGB Eight-County RFP Controlled Ozone Season Weekday VOC Emissions . Please note that there is no di fference between the uncontrolled and controlled area source NO Xemissions for the base and all milestone years and the VOC emissions for the base year and 2008 because there were no c ontrols applied to the projected area source inventories. Table 2-13: HGB Eight-County RFP Uncontrolled Ozone Season Weekday NO XEmissions
Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total
2002 339.29 89.11 166.98 387.09 982.47 2008 375.56 89.63 202.72 363.05 1030.96 2011 383.85 93.90 210.01 372.46 1060.22 2014 401.05 96.01 220.48 407.05 1124.59 2017 421.57 98.23 230.99 432.04 1182.82 2018 428.69 99.38 237.25 443.70 1209.02HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

2-15 Table 2-14: HGB Eight-County RFP Controlled Ozone Season Weekday NO XEmissions
Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total
2002 339.29 89.11 156.98 326.72 912.10 2008 155.73 89.63 149.44 175.80 570.60 2011 156.21 93.90 138.83 123.41 512.35 2014 157.17 96.01 128.45 86.61 468.25 2017 158.33 98.23 121.15 61.78 439.49 2018 158.75 99.38 119.88 55.39 433.40 Table 2-15: HGB Eight-County RFP Uncontrolled Ozone Season Weekday VOC Emissions
Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total
2002 316.62 407.61 100.15 189.08 1013.46 2008 333.14 371.82 113.68 194.89 1013.53 2011 338.75 382.72 120.10 205.03 1046.60 2014 347.70 393.07 126.28 222.41 1089.46 2017 358.79 404.84 132.38 237.86 1133.87 2018 362.90 408.82 134.29 242.84 1148.85 Table 2-16: HGB Eight-County RFP Controlled Ozone Season Weekday VOC Emissions
Year Point Sources Area Sources Non-Road Mobile Sources On-Road Mobile Sources Total
2002 316.62 407.61 84.32 132.64 941.19 2008 170.05 371.82 69.23 86.15 697.24 2011 164.33 379.04 64.03 68.35 675.75 2014 172.31 383.42 61.42 56.21 673.35 2017 181.86 394.74 60.05 48.39 685.05 2018 185.38 398.57 59.84 46.68 690.47HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-1 CHAPTER 3: TARGET EMISSIONS LEVELS AND REASONABLE FURTHER PROGRESS DEMONSTRATION 3.1 INTRODUCTION This chapter describes how the elements of th e Houston-Galveston-Brazoria (HGB) 2018 reasonable further progress (RFP) demonstration are calculated, documents the RFP calculations, and provides a summary of the HGB RFP demonstration for all RFP milestone years. The RFP guidance requires an average 3 percent reduction between the RFP base y ear and an area’s attainment year. The United States Environmental Protection Agency (EPA) guidance requires demonstration of RFP six years from the base year and then every third year after th at year until the attainment year. With an RFP base year of 2002 and an attainment date in 2019, the HGB RFP analysis has five RFP milestone years, 2008, 2011, 2014, 2017, and 2018. The RFP milestone year requirements for HGB are:

 an 18 percent emission reduction for the six year period between the 2002 base year and the first RFP milestone year 2008;

 a 9 percent emission reduction for each three year period ending in 2011, 2014, and 2017; and

 a 3 percent emission reduction for the one year period from 2017 to the attainment year, 2018. Compliance with the 2008, 2011, 2014, 2017, and 2018 milestone emission reduction requirements are demonstrated using EPA methodologies first to cal culate the elements of the RFP demonstration and then to use these elements to complete th e RFP analyses. First the inventories, control reductions, and non-creditable emission reductions are developed fo r each milestone year. Second, the target level of emissions for each milestone year is calculated. Third, the RFP control reductions for each milestone year are subtracted from the unc ontrolled milestone year emissions inventory (EI) that includes growth between 2002 and each milestone year. When the uncontrolled projected inventory for each milestone year, minus the RFP contro ls, is less than or equal to the target level of emissions for volatile organic compounds (VOC) and/or nitrogen oxides (NO X ), the RFP requirement has been met. The required RFP elements are:

 2002 base year emissions;

 non-creditable reductions for 2008, 2011, 2014, 2017, and 2018;

 2008, 2011, 2014, 2017, and 2018 target levels of emissions;

 2008, 2011, 2014, 2017, and 2018 projected emissions with growth; and

 individually quantified control strategy emissi ons reductions for 2008, 2011, 2014, 2017, and 2018. 3.2 TARGET LEVEL METHODOLOGY EPA guidance specifies the method states should use to calculate the maximum amount of emissions a nonattainment area can emit for each RFP milestone y ear. These RFP target levels of emissions are calculated with a six-step process. The following six step process was used for the HGB RFP state implementation plan (SIP) revision for the 1997 eight-hour ozone standard. 1. Develop the 2002 base year inventory. 2. Develop the 2002 RFP base year inventory. 3. Develop the adjusted base year inventories for 2002, 2008, 2011, 2014, 2017, and 2018. 4. Calculate the non-creditable fleet turnover correction for each RFP milestone year. 5. Calculate the required 3 percent per year emission reduction amount.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-2 6. Calculate the 2008, 2011, 2014, 2017, and 2018 target levels of emissions for VOC and NO X . 3.3 CALCULATION OF TARGET EMISSIONS LEVELS A step by step summary of the six-step process described above for targetcalculations for 2008, which serves as an example of how all target levels for each milestone year is calculated, is presented in Tables 3-1: Step by Step Summary of Calculat ion of 2008 Target Levels for HGB . A summary of all target levels can be found in Tables 3-4: RFP Post-2002 Target Level of NO XEmissionsand 3-5: RFP Post-2002 Target Level of VOC Emissions

. Table 3-1: Step by Step Summary of Calculation of 2008 Target Levels for HGB Description NO X VOC  Step 1: 2002 Base Year Inventory (see Tables 2-14 and 2-16) 912.10 941.19  Step 2: Add or subtract emissions that are to be added from outside the nonattainment area 0.00 0.00  2002 RFP Base Year Inventory (see Tables 2-14 and 2-16) 912.10 941.19  Step 3: 2002 On-road Adjusted Base Y ear Inventory (see Table 2-10) 387.09 189.08  2008 On-road Adjusted Base Year Inventory (see Table 2-10) 346.01 185.46  Step 4: Calculate Non-creditable reductions (see Table 2-10) 41.08 3.62  2008 Adjusted Base Year Inventory 871.02 937.57  Percent of NO X(PN) and VOC (PV) to meet 18% Reduction Requirement PN + PV = 18 17% 1%  Step 5: Calculate the 2002 to 2008 18% Reduction Requirement (  x  ) 148.07 9.38  Step 6: Calculate the Target Level of Emissions (  minus  minus  ) 722.94 928.19 Note: Emissions are represented in tons per day. Step one of the RFP target calculation is deve lopment of the 2002 base year EI. EPA guidance specifies the method states must use to develop the base year and all other SIP EI. Details of the development of the 2002 HGB base year inventory are discussed in Chapter 2: EMISSIONS INVENTORIES . Summaries of the 2002 HGB base year NO Xand VOC emissions inventories are presented in; Table 2-14: HGB Eight-County RFP Controlled Ozone Season Weekday NOX Emission , and Table 2-16: HGB Eight-County RFP Controlled Oz one Season Weekday VOC Emission

. The second step of the RFP target calculation me thodology adds or subtracts any emissions from outside the nonattainment area that need to be in cluded with or excluded from the nonattainment area inventory. The resulting inventory is called the 2002 RFP base year inventory, which represents the total anthropogenic emissions for the area and is the same as the 2002 base year inventory. Step three of the target calculation methodology is development of the on-road adjusted base year (ABY) inventories for 2002, 2008, 2011, 2014, 2017, and 2018. These inventories are an algebraic representation of the effects of the pre-1990 Federal Clean Air Act Amendments (FCAA) controls projected to the RFP base and milestone years. As such, these inventories can be used to estimate the effects of the pre-1990 FCAA controls between mil estone years. This estimation allows for the calculation of the non-creditable control reduction that is done as step four. The emission rates for an ABY inventory are developed using the latestversion of EPA’s emission factor model, MOBILE6.2.03. The model input file is set up to turn off all 1990 FCAA effects and the model evaluation year is set to the RFP base or milest one year. The model is run to determine emission factors for each base or milestone year with only pre-1990 FCAA controls. The emission factors for all years are then multiplied by the 2002 base year VM T. Since all of the inventories use the base year VMT, these inventories are referred to as RFP ABY inventories. Details of the development of the HGB RFP ABY inventories are documented in Chapter 2: EMISSIONS INVENTORIES andHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-3 Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-road Mobile Source Emissions Inventories

. Step four, calculating the non-creditable fleet turnover correction, is accomplished by subtracting the ABY inventory for each RFP milestone year from the adjusted base inventory for the previous RFP milestone year. Since the ABY inventories estimate the effects of the non-creditable pre-1990 FCAA controls, the difference between ABY inventori es represent an estimate of the non-creditable RFP emission reductions, also referred to as the fleet turnover correction. Table 3-2: Summary Noncreditable Fleet Turnover Reduction provides a summary of the fleet turnover corrections for all RFP milestone years. The equations for calculating the fleet turnover correction are shown below: Equation 3-1A: FTC MSY, VOC = ABY (MSY-1), VOC– ABY MSY, VOC and Equation 3-1B: FTC MSY, NOx = ABY (MSY-1), NOx– ABY MSY, NOx where: FTC MSY, VOC = VOC fleet turnover correction for year MSY FTC MSY, NOx = NO Xfleet turnover correction for year MSY ABY MSY, VOC = MSY adjusted base year inventory for VOC ABY MSY, NOx= MSY adjusted base year inventory for NO X ABY (MSY-1), VOC= previous MSY adjusted base year inventory for VOC ABY (MSY-1), NOx= previous MSY adjusted base year inventory for NO X MSY = RFP milestone year MSY – 1 = previous RFP milestone year Table 3-2: Summary Non-creditable Fleet Turnover Reduction On-road Mobile ABY EI Non-creditable Fleet Turnover

Reductions RFP Analysis

Year NO X VOC NO X VOC Non-creditable Pre-1990 CAA Fleet Turnover

Reduction Years
2002 387.09 189.08 N/A N/A N/A 2008 346.01 185.46 41.08 3.62 2002-2008 2011 335.20 184.23 10.81 1.23 2008-2011 2014 334.08 183.60 1.12 0.63 2011-2014 2017 333.24 183.50 0.84 0.10 2014-2017 2018 333.17 183.46 0.07 0.04 2017-2018

Step five, calculating the required 3 percent per year emission reduction amount, is accomplished by multiplying the RFP milestone year ABY inventory values by the percent reduction needed to meet RFP requirements. For HGB, the requirement is to reduce emissions by 3 percent per year from the base year to the attainment year. The second phase of the EPA’s Eight-Hour Ozone Implementation Rule allows ozone nonattainment areas to substitute NO Xreductions for VOC reductions, but use of NO Xemissions reductions must meet the criteria in§182(c)(2)(C) in the FCAA. For the eight HGB counties, an equivalent percentage of NO Xreduction may be substituted for VOC reductionHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-4 requirements for all RFP milestone years. The total of the percent NO Xand VOC reductions must equal the total emission reduction requirement for each milestone year. The RFP reduction requirement for this SIP revision is satisfied with a 1 percent reduction in VOC for each milestone year and the remaining percent reduction in NO Xemissions. Equation 3-2 describes the method to calculate the percentage of NO Xemissions substituted for VOC emissions: Equation 3-2: N MSY= [3 × (CY MSY– CY MSY-1 ) ] – V MSY where: N MSY= percentage NO Xreductions for year MSY CY = calendar year MSY = RFP milestone year MSY - 1 = previous RFP milestone year V MSY= percentage VOC reductions for year MSY

The VOC and NO Xpercentages are multiplied by the milestone year ABY inventories for VOC and NO X , respectively, to calculate the required VOC and NO Xemission reductions for each milestone year. Table 3-3: Calculation of Required 3 Percent Per Year NOX and VOC Reductionprovides a summary of the NO Xand VOC reductions needed to satisfy the 3 percent per year requirement for all RFP milestone years. The equations for calculating the required percent reductions for VOC and NO Xare shown in Equations 3-3A and 3-3B. Equation 3-3A: RQ VOC= [ BY 2002VOC– ( ABY 2002VOC– ABY MSY, VOC ) ] × PV MSY and Equation 3-3B: RQ NOx= [ BY 2002NOx– ( ABY 2002NOx– ABY MSY, NOx ) ] × PN MSY where: RQ VOC= required percent VOC emission reductions by 2008 RQ NOx= required percent NO Xemission reductions by 2008 BY 2002VOC= 2002 base year inventory for VOC BY 2002NOx= 2002 base year inventory for NO X ABY 2002VOC= 2002 adjusted base year inventory for VOC ABY 2002NOx= 2002 adjusted base year inventory for NO X ABY MSY, VOC = MSY adjusted base year inventory for VOC ABY MSY, NOx= MSY adjusted base year inventory for NO X PV MSY= percentage VOC reductions for year MSY PN MSY= percentage NO Xreductions for year MSY MSY = RFP milestone yearHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-5 Table 3-3: Calculation of Required 3 Percent Per Year NO Xand VOC Reduction tons per day RFP Analysis Year Total Percent Reduction Requirement Percent NO X Percent VOC ABY EI NO X ABY EI VOC Required Reductions NO X Required Reductions VOC 2002 N/A N/A N/A 912.10 941.19 N/A N/A 2008 18.0 17.0 1.0 871.02 937.57 148.07 9.38 2011 9.0 8.0 1.0 860.21 936.34 68.82 9.36 2014 9.0 8.0 1.0 859.09 935.71 68.73 9.36 2017 9.0 8.5 0.5 858.25 935.61 72.95 4.68 2018 3.0 2.5 0.5 858.18 935.57 21.45 4.68 2019 3.0 2.5 0.5 858.18 935.57 21.45 4.68

Step six, calculating 2008 target levels of emissions, is accomplished by subtracting the required emission reductions calculated in step five and the fleet turnover correction factor calculated in step four from the 2002 base year inventory. This targetlevel represents the level of emissions for each RFP milestone year for the HGB area to meet its eight-hour ozone RFP requirements. Because the fleet turnover correction affects both NO Xand VOC emissions, target le vels are calculated for both pollutants even when the entire reduction requirement is taken from one pollutant or the other. The method for calculating the target levels of emi ssions for the RFP milestone years is shown in Equation 3-4. Equation 3-4: TLMSY X = TL (MSY-1), X– RQ MSY,X – FTC MSY, X where: TL MSY, X= target level of emissions for MSY TL (MSY-1), X= target level of emissions for the previous RFP milestone year (Note: For 2008 the target level of emissions for the prev ious RFP milestone year is equal to the 2002 base year inventory.) RQ MSY, X= emission reduction requirement for MSY for pollutant X FTC MSY, X= fleet turnover correction term for MSY for pollutant X X = either VOC or NO X MSY = RFP milestone year MSY - 1 = previous RFP milestone year

Appendix 1: HGB RFP Demonstration Calculations Spreadsheet documents the calculation of the target values for all RFP milestone years. Table 3-1: Step by Step Summary of Calculation of 2008 Target Levels for HGB provides a step by step summary of th e calculation of the target levels for 2008 for the HGB area. Tables 3-4: RFP Post-2002 Target Level of NOX Emissionsand 3-5: RFP Post-2002 Target Level of VOC Emissionssummarize the calculation of the target levels of VOC and NO Xfor all RFP milestone years and provide the Federal Motor Vehicle Control Program (FMVCP) non-creditable emissions reductions. The following sections describe how the target levels are integrated into the RFP demonstration.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-6 Table 3-4: RFP Post-2002 Target Level of NO XEmissions tons per day RFP Milestone Year Previous Target FMVCP NonCreditable Reduction Post-2002 Percent Reduction Requirement NO X NO XTarget

2002 Base Year N/A N/A N/A 912.10* 2008 912.10 41.08 148.07 722.94 2011 722.94 10.81 68.82 643.32 2014 643.32 1.12 68.73 573.47 2017 573.47 0.84 72.95 499.68 2018 499.68 0.07 21.45 478.15 * This is the base year inventory, which is the starting point for calculating target values Table 3-5: RFP Post-2002 Target Level of VOC Emissions tons per day RFP Milestone Year Previous Target FMVCP NonCreditable Reduction Post-2002 Percent Reduction Requirement VOC VOC Target

2002 Base Year N/A N/A N/A 941.19* 2008 941.19 3.62 9.38 928.19 2011 928.19 1.23 9.36 917.60 2014 917.60 0.63 9.36 907.61 2017 907.61 0.10 4.68 902.84 2018 902.84 0.04 4.68 898.12 * This is the base year inventory, which is the starting point for calculating target values 3.4 GROWTH The HGB RFP SIP revision demonstration must also account for any growth in emissions between 2002 and each RFP milestone year; 2008, 2011, 2014, 2017, and 2018. The VOC and NO X uncontrolled projected year EI are derived by applying the appropriate projection methodologies to the 2002 base year EI, to emission factor development, and/or to activity level estimates. The resulting inventories include any growth between2002 and each projection year. The projection methodology for the uncontrolled RFP EI excludes ch anges in the emission factors due to control strategies so that the projections represent the total growth in emissions. When the creditable RFP control reductions are subtracted from uncontrolled projected inventories that include growth, the result will be the forecast controlled RFP emissions. The controlled RFP emissions are compared to the target levels to determine if a nonattainmen t area meets the RFP requirements. This method for accounting for growth is based on the EPA guidance for performing RFP calculations. 11 The development of the uncontrolled projected EI is documented in Chapter 2: EMISSIONS

11 United States Environmental Protection Agency, “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard; Final Rule,” Federal Register (70 FR 71631), November 29, 2005.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-7 INVENTORIES . The development of the projected contro l reductions are documented in Chapter 4: CONTROL MEASURES TO ACHIEVE TARGET LEVELS

. 3.5 RFP DEMONSTRATION The second phase of the EPA’s 1997 Eight-Hour Ozone Implementation Rule ( 40 Code of Federal Regulations §51.910) requires the RFP control strate gy plan to show emission reductions that will reduce the controlled RFP milestone year EI to a value less than the emissions target value. The creditable RFP control reductions are subtracted from the uncontrolled forecast inventory for each RFP milestone year. For milestone years 2011 through 2018, the controls that are reserved to demonstrate 2009 to 2018 contingency are adde d to the controlled RFP inventory because the creditable reductions for those years include the reductions reserved for contingency. The RFP milestone requirement is met for 2008 if the controll ed RFP emissions forecast is less than the target level of emissions. The RFP milestone requirement is met for all other years if the controlled RFP emissions forecast without reductions reserved for contingency is less than the target level of emissions. Tables 3-6: Summary of RFP Demonstration for Eight HGB Counties for 2008 , 3-7: Summary of RFP Demonstration for Eight HGB Counties for 2011 , 3-8: Summary of RFP Demonstration for Eight HGB Counties for 2014 , 3-9: Summary of RFP Demonstration for Eight HGB Counties for 2017, and 3-10: Summary of RFP Demonstration for Eight HGB Counties for 2018summarize the demonstration of the RFP plan for HGB for the 2008, 2011, 2014, 2017, and 2018 milestone years. As concluded in the fi nal row of each of these tables, the HGB area demonstrates the required RFP emission reductions for each milestone year. All RFP calculations, including the required reductions, the fleet turnover correction factor, and the target emission levels are calculated and shown in Appendix 1: HGB RFP Demonstration Calculations Spreadsheet

. Details of the emission reductions used to calcu late the creditable RFP control reduction for each milestone year are documented in Chapter 4: CONTROL MEASURES TO ACHIEVE TARGET LEVELS and summarized in Tables 4-1: Summary of HGB RFP NOX Emission Reductions Represent Post-2002 Cumulative Totalsand 4-2: Summary of HGB RFP VOC Emission Reductions Represent Post-2002 Cumulative Totals

. Table 3-6: Summary of RFP Demonstration for Eight HGB Counties for 2008 tons per day Line # Description NO X VOC Line 1 Uncontrolled Emissions Forecast With Growth 1030.96 1013.53 Line 2 Creditable RFP Control Reductions for 2008 450.74 137.44 Line 3 Controlled RFP Emissions Forecast (Line 1 minus Line 2) 580.22 876.09 Line 4 RFP Target Level of Emissions 722.94 928.19 Line 5 Excess (+) / Shortfall (-) (Line 4 minus Line 3) +142.72 +52.10 Line 6 Is Controlled RFP EI Less Than Target Level of Emissions? Yes YesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-8 Table 3-7: Summary of RFP Demonstration for Eight HGB Counties for 2011 tons per day

Line # Description NO X VOC Line 1 Uncontrolled Emissions Forecast With Growth 1060.22 1046.60 Line 2 Creditable RFP Control Reductions for 2008 450.74 137.44 Line 3 Creditable RFP Control Reductions 2008 to 2011 88.54 54.82 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 520.94 854.34 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 542.71 859.03 Line 7 RFP Target Level of Emissions 643.32 917.60 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +100.60 +58.57 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes Yes Table 3-8: Summary of RFP Demonstration for Eight HGB Counties for 2014 tons per day

Line # Description NO X VOC Line 1 Uncontrolled Emissions Forecast With Growth 1124.59 1089.46 Line 2 Creditable RFP Control Reductions for 2008, 2011 539.28 181.78 Line 3 Creditable RFP Control Reductions 2011 to 2014 107.44 44.35 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 477.86 863.33 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 499.64 868.02 Line 7 RFP Target Level of Emissions 573.47 907.61 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +73.83 +39.59 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes Yes Table 3-9: Summary of RFP Demonstration for Eight HGB Counties for 2017 tons per day

Line # Description NO X VOC Line 1 Uncontrolled Emissions Forecast With Growth 1182.82 1133.87 Line 2 Creditable RFP Control Reductions for 2008, 2011, 2014 646.72 226.13 Line 3 Creditable RFP Control Reductions 2014 to 2017 88.72 31.28 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 447.38 876.46 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 469.15 881.15 Line 7 RFP Target Level of Emissions 499.68 902.84 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +30.53 +21.68 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes YesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

3-9 Table 3-10: Summary of RFP Demonstration for Eight HGB Counties for 2018 tons per day Line # Description NO X VOC Line 1 Uncontrolled Emissions Forecast With Growth 1209.02 1148.85 Line 2 Creditable RFP Control Reductions for 2008, 2011, 2014, 2017 735.45 257.40 Line 3 Creditable RFP Control Reductions 2017 to 2018 30.60 8.99 Line 4 Controlled RFP Emissions Forecast (Line 1 minus Line 2 minus Line 3) 442.98 882.45 Line 5 Amount of Creditable Reductions Reserved for 2009 to 2018 Contingency 21.78 4.69 Line 6 Controlled RFP Forecast Without Reductions Reserved for Contingency (Line 4 plus Line 5) 464.76 887.14 Line 7 RFP Target Level of Emissions 478.15 898.12 Line 8 Excess (+) / Shortfall (-) (Line 7 minus Line 6) +13.40 +10.98 Line 9 Is Controlled RFP EI Less Than Target Level of Emissions? Yes YesHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-1 CHAPTER 4: CONTROL MEASURES TO ACHIEVE TARGET LEVELS 4.1 OVERVIEW OF CONTROL MEASURES This section briefly describes the control measures used to achieve the necessary emission reductions to meet the reasonable further progress (RFP) re quirements. The methodologies used to estimate reduced emission levels are described in Sections 4.2 through 4.5. The projected emission reductions reflect the identified federal and state emission cont rols. All state control measures are codified in Texas state regulations. The list of controls does not include all emission reduction programs for the Houston-Galveston-Brazoria (HGB) area. The su mmary of emission reductions from the control measures used to meet the RFP targets is presented in Tables 4-1: Summary of HGB RFP NOX Emission Reductionsand 4-2: Summary of HGB RFP VOC Emission Reductions . Individual and total values shown in these summary tables have beenextracted from the spreadsheet in Appendix 1: HGB Reasonable Further Progress Demonstration Calculations Spreadsheet . All values represent the numbers rounded to two significant figures. Since the totals in the tables are taken directly from the spreadsheet and rounded rather than summed fro m the rounded values in the table, there may be rounding discrepancies for the total values.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-2 Table 4-1: Summary of HGB RFP NO XEmission Reductions tons per day Control Strategy Description 2008 2011 2014 2017 2018 Mass Emissions Cap and Trade Program (MECT) 219.83 227.65 243.87 263.23 269.94 Tank Landing Loss Rule 0.00 0.00 0.00 0.00 0.00 Federal Portable Fuel Container (PFC) Rule 0.00 0.00 0.00 0.00 0.00 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 68.11 62.24 56.88 49.05 49.28 Federal Reformulated Gasoline (RFG) 46.75 72.94 104.41 128.94 135.65 Inspection and Maintenance (I/M) in Harris County 13.65 16.07 20.82 25.11 26.48 National Low Emission Vehicle program (NLEV) 9.12 9.31 6.16 3.42 2.66 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery Counties) 7.06 5.12 10.15 8.63 9.16 Tier 2 FMVCP 24.98 51.95 53.79 91.98 96.36 2007 Heavy-Duty FMVCP 8.70 28.22 66.13 61.69 67.54 On-road Texas Low Emission Diesel (TxLED) 8.87 3.21 2.11 1.45 1.19 Tier I and II Locomotive NO Xstandards 11.74 12.75 14.09 15.24 16.04 Small Non-Road Spark Ignition (SI) Phase I -0.30 -0.39 -0.47 -0.56 -0.58Federal Standards for New Heavy-Duty NonRoad Engines 5.76 7.91 9.64 12.02 12.56Tier 2 and 3 Federal Standards for New NonRoad Diesel Engines 8.13 14.01 18.76 23.25 24.29 Federal Standards for New Small Non-Road Spark Ignition (SI) Engines (Phase II) 1.25 1.65 1.85 1.99 2.04 Federal Standards for New Large Non-Road SI and Recreational Marine 12.27 20.30 27.01 31.10 32.13 Non-road TxLED 2.87 2.59 2.14 1.73 1.59 Non-road RFG 0.00 0.00 0.00 0.00 0.00 Tier 4 Federal Standards for Diesel Engines 0.00 0.52 4.67 10.96 12.82 Federal Marine Diesel Tier 2 1.96 3.23 4.72 6.20 6.90 Sum of Control Reductions 450.74 539.28 646.72 735.45 766.04 Note: The Small Non-road Spark Ignition Phase I rule is designed to reduce hydrocarbon emissions. The technology that is used achieve the reduction in hydrocarbon emissions also causes a slight increase in NO X emission rates. See Table 4-2 for information regarding VOC reductionsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-3 Table 4-2: Summary of HGB RFP VOC Emission Reductions tons per day Control Strategy Description 2008 2011 2014 2017 2018 Mass Emissions Cap and Trade Program (MECT) 0.00 0.00 0.00 0.00 0.00 Tank Landing Loss Rule 0.00 11.50 11.50 11.50 11.50 Federal Portable Fuel Container (PFC) Rule 0.00 3.68 9.65 10.10 10.25 Tier 1 Federal Motor Vehicle Control Program (FMVCP) 45.57 63.02 79.36 91.17 94.52 Federal Reformulated Gasoline (RFG) 34.24 34.51 37.17 39.99 40.97 Inspection and Maintenance (I/M) in Harris County 10.42 11.35 12.43 13.49 13.90 National Low Emission Vehicle program (NLEV) 5.33 4.81 3.27 1.97 1.59 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery Counties) 3.09 3.30 4.44 4.32 4.50 Tier 2 FMVCP 9.91 19.19 16.87 37.20 39.39 2007 Heavy-Duty FMVCP 0.15 0.45 12.53 1.00 1.08 On-road Texas Low Emission Diesel (TxLED) 0.04 0.06 0.12 0.33 0.21 Tier I and II Locomotive NO Xstandards 0.27 0.34 0.43 0.53 0.59 Small Non-Road Spark Ignition (SI) Phase I 1.77 2.50 3.23 3.95 4.19Federal Standards for New Heavy-Duty NonRoad Engines 4.73 6.82 8.54 10.17 10.58Tier 2 and 3 Federal Standards for New NonRoad Diesel Engines 0.95 1.68 2.32 2.95 3.10 Federal Standards for New Small Non-Road Spark Ignition (SI) Engines (Phase II) 16.70 20.81 22.72 24.13 24.57 Federal Standards for New Large Non-Road SI and Recreational Marine 4.14 7.96 11.37 14.03 14.76 Non-road TxLED 0.00 0.00 0.00 0.00 0.00 Non-road RFG 0.04 0.13 0.22 0.30 0.33 Tier 4 Federal Standards for Diesel Engines 0.00 0.03 0.26 0.52 0.59 Federal Marine Diesel Tier 2 0.08 0.12 0.18 0.24 0.26 Sum of Control Reductions 137.44 192.26 236.61 267.88 276.87

4.2 POINT SOURCE CONTROLS The point source controls were calculated using sever al sources of data, including but not limited to the point source emissions inventory and the M ass Emissions Cap and Trade Program (MECT). Emission reductions required by state rules were incorporated into the future projections for controlled inventories. Point source controls are detailed in Sheets 30-34 of Appendix 1: HGB RFP Demonstration Calculations Spreadsheet . The most significant NO Xreduction strategies are the 30 Texas Administrative Code (TAC) Chapter 117 rules and the MECT Program. Some of the affected source categories are utility boilers, turbines an d duct burners, heaters and furnaces, internal combustion engines, and industrial boilers. The reductions in point source VOC emissions were determined from the tank landing loss rules in 30 TAC Chapter 115, Subchapter B. 4.3 AREA SOURCE CONTROLS The only area source control in the HGB area used inthis RFP demonstration is the federal portable fuel container (PFC) rule. Controlled VOC emissions resulting from this rule will begin in 2010.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-4 Therefore, the first year of this HGB RFP State Implementation Plan (SIP) revision for PFC controls will be 2011. The EI forecast used EPA approved Economic Growth Analysis System (EGAS) growth factors to develop the corresponding controlledEI for milestone and attainment years. To develop the controlled emissions, ru le effectiveness factors were applied for source categories with applicable rules. The summary of uncontrolled and controlled emissions for area sources in the HGB area may be found in Tables 2-3: HGB Eight-County Area Source NOX Emissionsand 2-4: HGB Eight-County RFP Area Source VOC Emissions

. 4.4 NON-ROAD MOBILE SOURCE CONTROLS Most non-road mobile source emissions were calcul ated using a Texas specific version of the EPA’s NONROAD 2005 model, called the Texas NONROAD (TexN) model. Although operating the EPA’s model with all of the default surrogates is acceptable, the EPA encour ages states to update the model with local, county-level data based on survey s and other relevant information. The TexN model is a software tool for developing emissions estimates for non-road mobile sources in Texas using county specific activity data. The model allows air quality planning staff to replace EPA’s default data with local bottom-up data. Local, county- level data is incorporated into the TexN model as it becomes available. Emissions from the remaining non-road mobile sources not included in the NONROAD model, locomotives, aircraft and ground support equipment, commercial marine vessels, and oilfield drilling rigs, were calculated outside of the NONR OAD 2005 model using EPA-approved methodologies. 4.4.1 NONROAD Model Categories For the RFP plan, the TexN model was executed using county specific population and activity files where available. In some cases, custom allocation and technology type data files were also used. The technology type file identifies what percent of anequipment population is expected to use federal non-road equipment controls for the year of interest. The effects of federal and state control programs were evaluated. The TexN model was execute d for ozone season daily emission for years 2002, 2008, 2011, 2014, 2017, 2018, and 2019. In order to evaluate RFP requirements, a series of TexN model runs were executed for both controlled an d uncontrolled scenario for each federal and state control program for each analysis year. The documentation and procedure of applicable federal and state rules modeled is in Appendix 4: Development of RFP Non-Road Mobile Source Emissions Inventories for Source Categories in the EPA’s NONROAD2005 Model . The inventories developed include county level ozone season day controlle d and uncontrolled emissions estimates for years 2002, 2008, 2011, 2014, 2017, 2018, and 2019 for the eight counties in the HGB area. Once the individual uncontrolled and controlled emissions estimates were generated by the TexN model, the effectiveness of control strategies for e ach year of interest was evaluated. Emissions reductions from individual federal and state controls on non-road equipment was calculated by subtracting the controlled emissions estimates from the uncontrolled emissions estimates. 4.4.2 Non-Road Categories not in the NONROAD Model Locomotive controlled emissions were calculated usi ng data extrapolated from a contractor report drafted by Eastern Research Group, Inc., (ERG) and contained in the Texas Air Emissions Repository (TexAER) database. 12The uncontrolled emissions were de veloped using the EPA Fleet Average Emission Factors for Locomotives document. 13 Commercial marine vessel emissions were developed based on emission inventory completed in 2005 and 2007 by the contractor. 14,15 Emissions were

12ERG, “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07-84003-04, August 31, 2007. 13 EPA, “Emission Factors for Locomotives,” December 1997. 14ERG, “Development of Emission Estimates for Offshore Non-road Mobile Sources in Texas State Waters,” August 2005. 15 ERG, “Commercial Marine Vessel, Locomotive, and Aircraft Growth Factors,” August 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-5 developed from surveys to determine vessel types and shipping activities within the Houston Ship Channel. Oilfield drilling rig emis sions were developed by contract or using drilling permit data from the Railroad Commission of Texas. 16 The reductions for each control strategy for each milestone year are summarized in Tables 4-1: Summary of HGB RFP NOX Emission Reductionsand 4-2: Summary of HGB RFP VOC Emission Reductions . Details of the non-road control strategy emission reductions are documented in Appendix 4: Development of RFP Non-Road Mobile Source Emissions Inventories for Source Categories in the EPA’s NONROAD2005 Model

. 4.5 ON-ROAD MOBILE SOURCE CONTROLS The projected mobile source emissions inventories documented in Appendix 9: Houston-GalvestonBrazoria 1997 Eight-Hour Oz one Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventoriesincludes quantification of emis sion reductions for all federal and state on-road mobile source control rules for each RFP milestone year for the eight-county HGB area. Not all available on-road mobile source controls are needed to demonstrate RFP for the HGB area. A summary of the on-road mobile controls included in the 2002, 2008, 2011, 2014, 2017, and 2018 RFP inventories is presented in Table 4-3: Control Programs Modeled in MOBILE6 Emissions Factors for the Base and Milestone Years RFP Controlled Emissions Inventories . The reductions for each control strategy for each milestone year are summarized Tables 4-1: Summary of HGB RFP NO XEmission Reductionsand 4-2: Summary of HGB RFP VOC Emission Reductions

. Table 4-3: Control Programs Modeled in MOBILE6 Emissions Factors for the Base and Milestone Years RFP Controlled Emissions Inventories Control Program 2002 2008 2011 2014 2017 2018 Tier 1 Federal Motor Vehicle Control Program (FMVCP) X X X X X X I/M in Harris County X X X X X X Federal Reformulated Gasoline (RFG) X X X X X X National Low Emission Vehicle Program (NLEV) X X X X X X Tier 2 FMVCP X X X X X 2007 Heavy-Duty Diesel FMVCP X X X X X Expanded I/M X X X X X TxLED X X X X X

4.6 VMT, ON-ROAD EMISSIONS, AND TRANSPORTATION CONTROL MEASURES Transportation control measures (TCM) are required to offset growth in vehicle miles traveled (VMT) that results in an increase in vehicle emissions fo r nonattainment areas classified as serious under the National Ambient Air Quality Standards (NAAQS). TCMs are therefore part of the overall control strategy for the HGB area and are documented in the HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (Project No. 2009-017-SIP-NR). There is growth in VMT for the HGB area for the years between the RFP ba se year of 2002 and the attainment year, 2018, as illustrated in Figure 4-1: RFP VMT Trends . However, the growth in VMT for the area is more than offset by control measures that reduce the per mile emission rates, resulting in a decrease in emissions of both VOC and NO Xfor the same time period as shown in Figure 4-2: RFP Controlled On-Road NOX and VOC Emissions Trends . The increase in VMT and decrease in vehicle emissions for the RFP time period are summarized in Table 4-4: RFP Controlled NOX Emissions, VOC Emissions, and VMT and may also be found in Table 1: HGB RFP Ozone Season Week day On-Road Mobile Source

16ERG, “Emissions from Oil and Gas Production Facilities,” August 2007.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-6 VMT, Average Speed (mph), and Emissions (tpd) of Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reas onable Further Progress On-Road Mobile Source Emissions Inventories . The control measures used to achie ve the on-road mobile RFP emission reductions and to demonstrate RFP requirements do notinclude TCMs. TCMs are not needed to meet RFP requirements for the area and are therefore incl uded as part of the control strategy for the HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard only. Table 4-4: RFP Controlled NO XEmissions, VOC Emissions, and VMT NO X VOC VMT RFP Milestone Year tons per day miles per day 2002 Base Year 326.72 132.64 135,716,461 2008 175.80 86.15 146,039,120 2011 123.41 68.35 154,332,688 2014 86.61 56.21 168,390,202 2017 61.78 48.39 180,067,224 2018 55.39 46.68 184,010,300HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-7 

### 0 50,000,000 100,000,000 150,000,000 200,000,000

2002 2008 2011 2014 2017 2018 RFP YearVMT (miles per day)

Figure 4-1: RFP VMT Trends

0 50 100 150 200 250 300 350

2002 2008 2011 2014 2017 2018 RFP YearEmissions (tons per day)

NOx VOC Figure 4-2: RFP Controlled On-Road NO Xand VOC Emissions TrendsHGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-8 4.7 CONTINGENCY MEASURES In case of a milestone failure, contingency contro l measures estimated to reduce emissions by an additional 3 percent between each milestone year and the next calendar year are required. As with the 3 percent per year reduction requirement, the 3 percent contingency requirement is based upon the adjusted base year and may be met using either VOC or NO Xreductions. As shown in Table 4-5: 2009 RFP Contingency Demonstration for the HGB Area the 3 percent contingency analysis for 2009 and subsequent milestone years to 2018 is based upon a 2.5 percent reduction in NO Xand a 0.5 percent reduction in VOC to be achieved between2008 and 2009. The excess emission reductions from the RFP milestone year 2008 were used to demonstrate the 2009 contingency. The 2009 contingency reductions are subtr acted from creditable c ontrol reductions for milestone years 2011, 2014, 2017, and 2018 to account for the contingency requirements for each of those years. If the RFP milestone requirement is met for 2008, the contingency reductions desi gnated for 2009 will be available to be used as contingency reductions for each following milestone where the RFP emissions requirement is met. Table 4-5: 2009 RFP Contingency Demonstration for HGB Area 2009 Description NO X VOC Adjusted 2008 Base Year EI 871.02 937.57 Percent for Contingency Calculation (total of 3 percent) 2.50 0.50 2008 to 2009 Required Contingency Reductions 21.78 4.69 Excess From 2008 RFP Demonstration (see Appendix 1 Sheet 2) 142.72 52.10 Subtract 2008 MVEB Safety Margin From Excess Reductions from 2008 RFP Demonstration -17.58 -8.61 Total Contingency Reductions 125.14 43.49 Contingency Excess (+) or Shortfall (-) +103.37 +38.80 Are contingency reductions greater than required contingency reduction? Yes Yes Note: Emissions are represented in tons per day. Since 2018 is the attainment year, there is no corres ponding continuing 3 percent per year analysis for 2019. The 3 percent contingency analysis fo r 2019 was based upon a 2 percent reduction in NO Xand a 1 percent reduction in VOC to be achieved between 2018 and 2019. Inventory analyses were performed on the fleet turn over effects for the federal emission certification programs for on-road and non-road vehicles. The emission reductions for the year from 2018 to 2019 were estimated for these programs. Controlled emission reductions not previously used in the 2018 milestone demonstration may also be used to satisfy c ontingency requirements, so the excess emission reductions from the 2018 RFP demonstration are include d in the contingency analysis. Because this SIP revision provided for a 10 percent MVEB safety margin using some of the excess emissions reductions from the 2018 RFP demonstration, thos e emissions are subtracted from the amount available to demonstrate 2019 contingency. A summary of the 2019 contingency analysis is provided in Table 4-6 : 2019 RFP Contingency Demonstration for HGB Area . The analysis demonstrates that the 2019 contingency reductions exceed the 3 percent reduction requirement; therefore, the RFP contingency requirement is fulfilled for the HGB area.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

4-9 Table 4-6: 2019 RFP Contingency Demonstration for HGB Area 2019 Description NO X VOC Adjusted 2018 Base Year EI 858.18 935.57 Percent for Contingency Calculation (total of 3 percent) 2.50 0.50 2018 to 2019 Required Contingency Reductions 21.45 4.68 Excess From 2018 RFP Demonstration (see Appendix 1 Sheet 7) 13.40 10.98 Subtract 2018 MVEB Safety Margin From Excess Reductions from 2018 RFP Demonstration -5.54 -4.67 Tier 1 FMVCP -1.93 1.40 Federal RFG 5.09 0.70 I/M and ATP in Harris County 0.88 0.20 NLEV -0.60 -0.31 Expand I/M to Brazoria, Fort Bend, Galveston, and Montgomery Counties 0.35 0.11 Tier 2 FMVCP 2.92 1.60 2007 Heavy Duty Diesel FMVCP 3.58 0.04 On-road Texas Low Emission Diesel 0.00 0.00 TERP 0.00 0.00 VMEP 0.00 0.00 TCM 0.00 0.00 Tier I and II Locomotive NO XStandards 0.68 0.01 Small Non-Road Spark Ignition Phase I -0.03 0.24 Heavy Duty Non-road Engines 0.30 0.32 Tier 2, and 3 Non-road Diesel Engines 0.72 0.11 Small Non-road SI Engines (Phase II) 0.04 0.43 Large Non-road SI & Recreational Marine 0.95 0.62 Non-road Texas Low Emission Diesel 0.00 0.00 Non-road Reformulated Gasoline 0.00 0.03 Tier 4 Diesel Rule 1.58 0.06 Federal Marine Diesel Tier 2 0.55 0.02 Total Contingency Reductions 22.94 11.89 Contingency Excess (+) or Shortfall (-) +1.49 +7.21 Are contingency reductions greater than required contingency reduction? Yes Yes Note: Emissions are represented in tons per day.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-1 CHAPTER 5: MOTOR VEHICLE EMISSIONS BUDGETS 5.1 INTRODUCTION This Houston-Galveston-Brazoria (HGB) reasonable further progress (RFP) state implementation plan (SIP) revision establishes motor vehicle emissions budgets (MVEB), which set the allowable HGB area on-road mobile emissions. The HGB RFP SIP revision MVEB are calculated by subtracting the on-road mobile control strategy emission reductions that are necessary to demonstrate RFP from the uncontrolled, projected on-road mobile source emissions for each RFP milestone year. Local transportation planning organizations use the MVEB to demonstrate that projected emissions from transportation plans, programs, and projects are equal to, or less than the budget, as required by the federal transportation conformity rule. 5.2 OVERVIEW OF METHODOLOGIES AND ASSUMPTIONS The Texas Commission on Environmental Quality (TCE Q) developed updated on-road mobile source emissions inventories (EI) and control strategy reduction estimates that use the latest planning assumptions and the newest version of the United States Environmental Protection Agency’s (EPA) emission factor model. Updated inventory development included de velopment of: a 2002 base year inventory; adjusted base year inventories for 2002, 2008, 2011, 2014, 2017, and 2018; 2008, 2011, 2014, 2017, and 2018 milestone year inventories; and control strategy reduction estimates for 2008, 2011, 2014, 2017, and 2018. The TCEQ worked with the Houston-Galveston Area Council (H-GAC) to develop these inventories. Appendix 9: Houston-Galveston-Brazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road Mobile Source Emissions Inventoriesis a copy of the H-GAC contractor (ENVIRON International Corporation) report, which provides detailed documentation of the on-roadmobile inventory development. 5.3 MOTOR VEHICLE EMISSIONS BUDG ETS FOR RFP MILESTONE YEARS The RFP MVEB reflect the on-road mobile EI fo r each RFP milestone year, the on-road mobile reduction strategies used to demonstrate RFP, and a 10 percent transportation conformity safety margin. A transportation conformity safety margin is allowed when there is an excess in emission reductions required to demonstrate RFP for a milestoneyear. The amount of the safety margin is less than the total in excess emission reductions for nitrogen oxides (NO X ) and volatile organic compounds (VOC) and, therefore, even if the safetymargin is used for a transportation conformity determination, the HGB area will still meet the 199 7 eight-hour ozone standard RFP requirements for all milestone years. Summaries of the calculation of the MVEB for each RFP milestone year are presented in Tables 5-1: 2008 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-2: 2011 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-3: 2014 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-4: 2017 RFP Motor Vehicle Emissions Budgets for the HGB Area , 5-5: 2018 RFP Motor Vehicle Emissions Budgets for the HGB Area . The details of the calculation of the MVEB is documented in Sheets 10 through 14 of Appendix 1: HGB RFP Demonstration Calculations Spreadsheet . The RFP control strategy produces more than the required emissions reductions for each milestone year. Some of the excess in emissions reductions for each milestone year is used to provide a safety margin. This safety margin is less than the total emissions reductions needed for the RFP demonstration; therefore, evenif this safety margin is used, the HGB area will still demonstrate RFP for each milestone.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-2 Table 5-1: 2008 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO Xtons per day VOC tons per day 2008 On-Road Emissions Projection Without Post-1990 FCAA Controls 363.05 194.89 2008 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 68.11 45.57 Federal Reformulated Gasoline (All 8 Counties) 46.75 34.24 I/M in Harris County 13.65 10.42 National Low Emission Vehicle Program (NLEV) 9.12 5.33 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 7.06 3.09 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 24.98 9.91 2007 Heavy-Duty Diesel FMVCP 8.7 0.15 On-Road TxLED 8.87 0.04 2008 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory mi nus control reductions) 175.81 86.14 Add Transportation Conformity Safety Margin 1 17.58 8.61 2008 RFP Motor Vehicle Emissions Budgets 193.39 94.75 1 The 2008 RFP reductions exceed the required emissions reductions. Excess emissi ons equaling 10 percent of the 2008 on-road emissions projection with post-19 90 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2008.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-3 Table 5-2: 2011 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO Xtons per day VOC tons per day 2011 On-Road Emissions Projection Without Post-1990 FCAA Controls 372.46 205.03 2011 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 62.24 63.02 Federal Reformulated Gasoline (All 8 Counties) 72.94 34.51 I/M in Harris County 16.07 11.35 National Low Emission Vehicle Program (NLEV) 9.31 4.81 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 5.12 3.3 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 51.95 19.19 2007 Heavy-Duty Diesel FMVCP 28.22 0.45 On-Road TxLED 3.21 0.06 2011 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory mi nus control reductions) 123.40 68.34 Add Transportation Conformity Safety Margin 1 12.34 6.83 2011 RFP Motor Vehicle Emissions Budgets 135.74 75.17 1 The 2011 RFP reductions exceed the re quired emissions reductions. Excess emissions equaling 10 percent of the 2011 on-road emissions projection with post-19 90 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2011.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-4 Table 5-3: 2014 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO Xtons per day VOC tons per day 2014 On-Road Emissions Projection Without Post-1990 FCAA Controls 407.05 222.41 2014 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 56.88 79.36 Federal Reformulated Gasoline (All 8 Counties) 104.41 37.17 I/M in Harris County 20.82 12.43 National Low Emission Vehicle Program (NLEV) 6.16 3.27 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 10.15 4.44 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 53.79 16.87 2007 Heavy-Duty Diesel FMVCP 66.13 12.53 On-Road TxLED 2.11 0.12 2014 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory mi nus control reductions) 86.60 56.22 Add Transportation Conformity Safety Margin 1 8.66 5.62 2014 RFP Motor Vehicle Emissions Budgets 95.26 61.84 1 The 2014 RFP reductions exceed the required emissions reductions. Excess emissi ons equaling 10 percent of the 2014 on-road emissions projection with post-19 90 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2014.HGB Reasonable Further Progress SIP Revisi on for the 1997 Eight-Hour Ozone Standard

5-5 Table 5-4: 2017 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO Xtons per day VOC tons per day 2017 On-Road Emissions Projection Without Post-1990 FCAA Controls 432.04 237.86 2017 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 49.05 91.17 Federal Reformulated Gasoline (All 8 Counties) 128.94 39.99 I/M in Harris County 25.11 13.49 National Low Emission Vehicle Program (NLEV) 3.42 1.97 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 8.63 4.32 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 91.98 37.20 2007 Heavy-Duty Diesel FMVCP 61.69 1.00 On-Road TxLED 1.45 0.33 2017 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory mi nus control reductions) 61.77 48.39 Add Transportation Conformity Safety Margin 1 6.18 4.84 2017 RFP Motor Vehicle Emissions Budgets 67.95 53.23 1 The 2017 RFP reductions exceed the required emissions reductions. Excess emissi ons equaling 10 percent of the 2017 on-road emissions projection with post-19 90 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2017. Table 5-5: 2018 RFP Motor Vehicle Emissi ons Budgets for the HGB Eight-County Ozone Nonattainment Area Description NO Xtons per day VOC tons per day 2018 On-Road Emissions Projection Without Post-1990 FCAA Controls 443.70 242.84 2018 On-Road Mobile Reasonable Further Progress Controls Tier 1 Federal Motor Vehicle Control Program (Tier 1 FMVCP) 49.28 94.52 Federal Reformulated Gasoline (All 8 Counties) 135.65 40.97 I/M in Harris County 26.48 13.90 National Low Emission Vehicle Program (NLEV) 2.66 1.59 Expanded I/M (Brazoria, Fort Bend, Galveston, and Montgomery) 9.16 4.50 Tier 2 Federal Motor Vehicle Control Program (Tier 2 FMVCP) 96.36 39.39 2007 Heavy-Duty Diesel FMVCP 67.54 1.08 On-Road TxLED 1.19 0.21 2018 On-Road Emissions Projection With Post-1990 FCAA Controls (Uncontrolled inventory mi nus control reductions) 55.38 46.68 Add Transportation Conformity Safety Margin 1 5.54 4.67 2018 RFP Motor Vehicle Emissions Budgets 60.92 51.35 1 The 2018 RFP reductions exceed the required emissions reductions. Excess emissi ons equaling 10 percent of the 2018 on-road emissions projection with post-19 90 FCAA controls for each NO Xand VOC is used to provide a safety margin for 2018.

### Appendices for the Houston-Galveston-Brazoria (HGB) Eight-Hour **Ozone Reasonable Further Progress (RFP) SIP Revision, Texas Project No.2009-018-SIP-NR**  **The appendices were submitted to EPA on a compact disc (CD). The files on the CD are available by contacting the Texas**  **Commission on Environmental Quality or the EPA contact person listed in the “FOR FURTHER INFORMATION CONTACT” section of the**  **Federal Register(s) for this action.**

### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

ORDER ADOPTING REVISIONS TO THE STATE IMPLEMENTATION PLAN

Docket No. 2009-0801-SIP On March 10, 2010, the Texas Commission on Environmental Quality (Commission), during a public meeting, considered adoption of the Houston-Galveston-Brazoria Reasonable Further Progress

. State Implementation Plan Revision for the1997 Eight-Hour Ozone Standard. The Commission adopts this SIP revision demonstrating 

### that the RFP emissions reduction requirement 

### will 

### be met for the six-year period (2003- 2008) beginning 

### January 1 of the year following the year used for the baseline emissions inventory (2002) and all remaining three-year periods after the 

### first six-year 

### period (2009-2011, 2012-2014, and 2015-2017) out to the area's attainment date (2019). 

### This SIP revision 

### also sets the nitrogen oxides (NOx) and volatile organic compounds (VOC) motor vehicle emissions budgets (MVEB) for transportation conformity purposes for the milestone years 2008, 2011, 2014, 2017, and 2018. Under Tex. Health 

### & Safety 

### Code 

### Ann. §§ 382.011, 382.012, and 382.023 (Vernon 2008), the Commission has the authority to control the quality of the state's air and to issue orders consistent with the policies and purposes ofthe Texas Clean 

### Air Act, 

### Chapter 382 of the Tex. Health 

### & Safety Code. Notice of the proposed SIP revision was published for comment in the October 9,2009, issue of the 

### Texas Register (34 TexReg 7132).
Pursuant to 40 

### Code of Federal Regulations § 51.102 and 

### after proper notice, the Commission conducted public hearings to consider the revision to the SIP. 

### Proper notice included prominent advertisement in the areas 

### affected at least 30 days prior to the dates of the hearings. Public hearings were held in Houston, Texas on October 28,2009 and Austin, Texas on October 29,2009.

. The Commission circulated hearing notices of its 

### intended action to the public, including interested persons, the Regional Administrator of the EPA, 

### and all applicable local air pollution control agencies. The public 

### was invited to submit 

### data, views, and recommendations on the proposed SIP revision, either orally or in writing, at the hearings or during the comment period. Prior to the scheduled hearings, copies of the proposed SIP revision were available for public inspection at the Commission's central office and on the Commission's Web site. Data, views, and recommendations of interested persons regarding the proposed SIP revision 

### were submitted to the Commission during the comment period, and were considered by the Commission as reflected in the analysis of testimony incorporated by reference to this Order. The Commission finds 

### that the analysis of testimony includes the names of all interested groups or associations offering comment on the proposed SIP revision and their position concerning the same.
IT IS THEREFORE ORDERED BY THE COMMISSION that the Houston-Galveston-Brazoria Reasonable Further Progress State Implementation Plan Revision for the 1997 Eight-Hour Ozone Standard incorporated by reference to this Order is hereby adopted. The adopted revision to the SIP is incorporated by reference in this Order as if set forth at length verbatim 

### in 

### this Order.

### IT IS FURTHER ORDERED BY THE COMMISSION that on 

### behalfoftbe Commission, the Chairman should transmit a 

### copy of 

### this Order, together with the adopted revision to the SIP, to the Regional Administrator of EPA as a proposed revision to the Texas SIP pursuantto the Federal CleanAir Act, codifiedat 42 

### U.S. Code Ann. 

### §§ 7401- 7671q, 

### as amended. If 

### any portion of 

### this Orderis for any reasonheld to 

### be invalid 

### by a 

### court of competent jurisdiction, the invalidity of any portion shallnot affectthe validityof the remaining portions.

Date 

### issued: 

# MAR 15 Z 0

1

# 0 TEXAS COMMISSION ON ENVIRONMENTAL QUALITY