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2010 ~.PR -7 PM 12: 46

TEXAS COMMISSION ON ENVIRONMENTAL QuAlflIn'filVISION

BryanW. Shaw, Ph.D.,Chairman

BuddyGarcia,Commissioner

Carlos Rubinstein, Commissioner

Mark R.Vickery, P.G., Executive Director

Protecting Texas by Reducing andPreuentinq Pollution

April 1,2010

Docket No. 2009-0801-SIP

Project No. 2009-018-SIP-NR

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Alfredo "AI" Armendariz, Ph.D., Regional Administrator

U.S. Environmental Protection Agency - Region6

1445 RossAvenue

Dallas,Texas 75202-2733

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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 ozonenonattainment area.

TheCommission adopted the HGBReasonable FurtherProgress (RFP) SIPrevision, demonstrating that the

RFP emissions reduction requirement will be met forthe six-year period (2003-2008) beginning January 1 of the

yearfollowing the yearusedfor the baselineemissions 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) andvolatile organic compounds (VOC) motorvehicle

emissions budgets (MVEB) fortransportation 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 lookforward to your expeditious approvalofthis SIPrevision.

Sincerely,

~~;dAtv- BryanW. Shaw, Ph.D.

Chairman

BWS/ts

Enclosures

cc: The Honorable RickPerry,Governor ofTexas

Mr. TobyBaker, Office of Budget, Planning andPolicy, Office of the Governor

.Mr, MarkR. Vickery, P.G.,Executive Director, TexasCommission 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

THESTATE OF TEXAS

COUNTY OF TRAVIS

Thisis to certify that the attached aretrue and correct copiesof documents for a revision to the Texas

StateImplementation Plan, adopted on March 10.2010. pursuant to 40 Code of FederalRegulations (C.F.R) §

51.104. I am the records administrator for theAir Quality Division oftheTexas Commission onEnvironmental

Quality (Commission).

<Dm~.~- '0" "Air Quality Division

TexasCommission onEnvironmental Quality
Texas Commission onEnvironmental Quality

Public Hearings

October 28 and29. 2009

Concerning Revisions to the

HGB Eight-Hour Ozone Reasonable Further Progress SIP

ProjectNo.2009-018-SIP-NR
INTRODUCTION

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 

PROPOSAL 
PUBLIC 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 Department
Galveston 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 proposedRegistratio 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 DaffanLane, 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

ofChiefClerk at the address incl d in the information section below.

Comments may also be received' a publicmeeting is held on the facility. A public meeting will be held y the executive director ifrequested

by a member ofthe legislature represents the general area where

the development is to be located, r ifthere is a substantial public interest in the proposed developmen Thepurpose ofthe public meeting

is for the public to provide input r consideration by the commission,

and for the applicant and the co . ion staffto 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 ifthe application will be approved or denied' whole or in part. Ifthe executive

director acts on an application, th chief clerk shallmail or otherwise

transmit notice ofthe action and explanation ofthe opportunity to

file a motion to reconsider the exe utive director's decision. The chief

clericshallmailthis 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

ofthe 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 ofPublic 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 TexasRegister

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 emakingand 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 Printingat 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 oforal orwritten comments interested persons. Registration

will begin 30 minutes prior to e hearing. Individuals may present

oral statements when called upon' order ofregistration. 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 afterthe 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 ofLegal 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 fromthe 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

TexasCommission on Environmen

Filed: September25.2009

• •

Notice ofPublic 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 ofAir Pollution from Volatile Organic
•

Compounds and corresponding revisions to the state implementation

plan (SIP) underthe requirements of TexasHealth and Safety Code,

§382.017;TexasGovernment Code,Chapter2001,SubchapterB; and

40 Code ofFederalRegulations §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, SubchapterH, Division3,

Mass Emissions Cap and Trade (MEeT) Program. would revise the

definitionof"Uncontrolled designcapacity" to provideadditionalflexibilityfor certainstationarydieselenginesand clarifyboth site and facility applicability. In addition, the proposedamendment wouldmaintain the integrityofthe nitrogenoxides(N0x) cap in the HOB ozone

nonattainment area andminimizeincreases in theNOx cap by discontinuing the acceptance of late ECT-3 forms, Level ofActivity Certification, from major sourcesof NOx 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

TradeProgram.wouldreducethe total capamountof allowances and

revisethe allocationmethodology ofallowances forparticipantsin the

Highly-Reactive Volatile Organic Compound (HRVOC) Emissions

Cap and TradeProgram.A proposedamendment 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 correctthe reportable quantityfor l,l,l,2,3,3,3-heptaftuoropropane. (Rule Project No. 2009-006-101-EN)

The proposedamendments to Chapter 115,Subchapter E, Division4,

OffsetLithographic Printing, wouldreducetheVOCcontentlimitson

fountainsolutionsusedby sourcesthat are subjecttothe existingChapter 115 rules. The proposed rulemaking would also limit the VOC

contentoffountain 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 AirAct-required SIP elements, includinga photochemical modeling analysis, a weight of evidence analysis, a reasonable

available controltechnology (RACT)analysis,a reasonablyavailable

control 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 oftransportation controlmeasures. The proposed revision also describesthe 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, ifso, 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 OzoneNonattainment Area RFP SIP

revisiondemonstratesthatthe 18percentozoneprecursoremissionsreductionrequirement will be metforthe analysisperiodof2002 to 2008,

9 percentbetween2009 and 2011,9 percentbetween2012 and 2014,

9 percent between 2015 and 2017,3 percent in 2018, and 3 percent

forcontingency purposes. Thisrevisionalsoincludesa revisedMVEB

for the milestoneyears 2008, 2011, 2014, 2017, and 2018. No new

on-roadmobile sourcecontrolshave been adoptedas part ofthe plan.

However,on-roadmobilesourceemissionsinventorieshave been updatedusingthelatestavailable data andtheEPA'sMOBILE6inventory

development tool. As a resultofthe requiredmobilesourceemission

inventory updates, theMVEBsare updatedas part of thisSIP revision.

(Rule Project No. 2009-018-SIP-NR)

Public hearingson these proposals will be held at the following times

and locations: October28,2009,2:00 p.m. and 6:00 p.m., in ConferenceRoomA at theHouston-Galveston AreaCouncil, 3555Tunmons

Lane, Houston; and in Austin on October 29, 2009, 3:00 p.m., at the

TexasCommission on Environmental Quality complex, Building E,

Room201S, 12100Pad 35 Circle. Thehearingswillbe structuredfor

the receipt of oral or written comments by interested persons. Registrationwill begin 30 minutesprior to each hearing. Individuals may

presentoralstatementswhencalleduponinorderofregistration. There

will be no open discussionduringthe hearing; however, commission

staffmemberswillbe availableto discussthe proposals30 minutesbefore each hearingand will answerquestionsbeforeand 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, OfficeofLegalServices, TexasCommission 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-NRfor 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 regardingthe

proposed rules and SIP revisions, please contact Ray Schubert, Air

QualityPlanningSection,at (512) 239-6615.

TRD-200904267

Robert Martinez

Director, Environmental Law DMsion

Texas Commission on Environmental Quality

Filed: september 25, 2009

•

Notice ofPublic Hearings on

Chapter 115 and to the State I plementation Plan

The TexasCommission 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 TACChapter 115,Controlof ir PollutionfromVolatile 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 7133
Bryan 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 ofTexas 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-:l0117
soliciting 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

thisSIP 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 ofLegal 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 oftheproposed 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 EIGHT-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 for the1997 Eight-Hour Ozone Standard 

PROJECT NO. 2009-018-SIP-NR 

Proposed 

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

ES-1

EXECUTIVE SUMMARY 

The 1990 Federal Clean Air Act Amendments (FCAA), §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 the second phase of the United States Environmental 

Protection Agency’s (EPA) 1997 Eight-Hour Ozone Implementation Rule (40 Code of Federal 

Regulations §51.910). 

This SIP revision demonstrates 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). 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 are 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 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 Table 3-3: Calculation of 

Required 3 Percent Per Year NOX and VOC Reductions. 

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. 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 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 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. 
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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 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 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 the 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 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 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 inconsistent with the provisions of the TCAA and the rules or orders of the commission. 
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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 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 Texas 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 Understanding, §§ 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 
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(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 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 for 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, 2001 
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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 Revision for the 1997 Eight-Hour Ozone Standard 

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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 

NOX -- Nitrogen Oxides 

PFC -- Portable Fuel Container 

PN -- Percent of NOX

PV -- Percent of VOC 

REMI -- Regional Economic Modeling, Inc. 

RFG -- Reformulated Gasoline 
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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 Compounds 
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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 Milestone Year Emissions Inventories 

 2.5.5 Updated Controlled Milestone Year Emissions Inventories 
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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 

Appendices 
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LIST OF APPENDICES 

Appendix Appendix 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 Mobile Source Emissions Inventories 
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LIST OF TABLES 

Number Table Name

Table 2-1 HGB Eight-County RFP Point Source NOX Emissions 

Table 2-2 HGB Eight-County RFP Point Source VOC Emissions 

Table 2-3 HGB Eight-County RFP Area Source NOX Emissions 

Table 2-4 HGB Eight-County RFP Area Source VOC Emissions 

Table 2-5 HGB Eight-County RFP Non-Road Mobile Source NOX Emissions 

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 Season Weekday On-Road Mobile Source NOX Emissions 

Table 2-9 HGB Eight-County RFP Ozone Season Weekday 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 NOX Emissions 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 NOX Emissions 

Table 2-14 HGB Eight-County RFP Uncontrolled Ozone Season Weekday VOC Emissions 

Table 2-15 HGB Eight-County RFP Controlled Ozone Season Weekday NOX Emissions 

Table 2-16 HGB Eight-County RFP Controlled Ozone Season Weekday VOC Emissions 

Table 3-1 Step by Step Summary of Calculation 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 NOX and VOC Reductions 

Table 3-4 RFP Post-2002 Target Level of NOX Emissions 

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 NOX Emission 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 Area 
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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 EPA’s 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 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 attainment demonstration, a reasonable further progress 

(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, 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 reclassified from a moderate to a severe nonattainment area for 

the 1997 eight-hour 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 a SIP revision 

for the HGB 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. 

“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 contain enforceable measures to achieve the National 

Ambient Air Quality Standards (NAAQS). The 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 neither 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 revision 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. 
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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 submitted to Walker Williamson, MC 206, State 

Implementation Plan Team, Chief Engineer’s Office, Texas Commission on Environmental 

Quality, P.O. Box 13087, Austin, Texas 78711-3087 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 with this SIP revision, there are no changes that 

would require an analysis of social 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. 
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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 ozone nonattainment areas. Ozone is 

photochemically produced in the atmosphere when volatile organic compounds (VOC) are mixed 

with nitrogen oxides (NOX) in the presence of sunlight. The Texas Commission on 

Environmental Quality (TCEQ) maintains an EI of up-to-date information on NOX 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 variety 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 established emissions growth and control budgets. 

The total inventory of VOC and NOX emissions 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 reclassified 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 NOX emissions 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 calculated for each source category using EPA-approved 

methodologies and then combined to obtain the total uncontrolled milestone year inventory for 

VOC and NOX. 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 inventory 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 NOX. 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 (TAC) §101.10. To collect the data, the TCEQ 
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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 also required. All data submitted in the EIQ are 

reviewed for quality assurance purposes and then stored 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 extracted from STARS on February 4, 2009. The 

extracted data contained ozone season daily emissions of NOX and VOC from each site in the 

HGB area that submitted an EIQ for 2002 and reflected 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 was used to derive growth factors from the 

following data sets: the Regional Economic Modeling, 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 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 to return to the air shed in the future. To account for the possible 

use of these banked NOX and 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 factors 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 emissions, 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 available. The 2005 inventory was extracted 

from STARS on February 4, 2009. The extracted data were reported ozone season daily 

emissions of NOX and 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 NOX controls are reflected in the Mass Emissions Cap and Trade program 

(MECT) 2008 NOX cap. The MECT NOX emissions allocations account for NOX controls, 

including controls applied to electric generating units (EGUs) and large stationary engines as 
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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 NOX inventories were 

developed by applying projection factors to baseline year emissions and then applying the unitspecific allocations from the MECT for regulated sources. Emissions were then added to account 

for unused NOX emissions 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 Control or Division 2: Cooling Tower Heat 

Exchange Systems for 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 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 Table 2-2: HGB Eight-County RFP Point Source VOC 

Emissions.

Table 2-1: HGB Eight-County RFP Point Source NOX Emissions 

RFP Analysis NOX (tons per day) 

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 

RFP Analysis VOC (tons per day) 

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.
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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 printing operations, industrial coatings, degreasing 

solvents, house paints, leaking underground storage tanks, gasoline service station underground 

tank filling, and vehicle refueling 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 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 required to submit this 

inventory to the United States Environmental Protection Agency (EPA) as the Periodic Emissions 

Inventory, considerable effort went into its development. 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. 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 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 contractor 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 inventories 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 

 

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.
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(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 emissions 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 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 NOX

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 NOX Emissions 

RFP Analysis NOX (tons per day) 

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 

RFP Analysis VOC (tons per day) 

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 

"off-road" 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, 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. 
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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 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. 

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 with all of the default surrogates 

is acceptable, the EPA encourages 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 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 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 emission 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. Hobby Airport. Emissions were calculated using 

the Federal Aviation Administration (FAA) Emissions and Dispersion Modeling System 

(EDMS), version 5.1. The airport emissions categories 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) 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, 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 emissions were estimated using an interpolation 

method between the years 2005 and 2011. The documentation of procedures used in developing 

 

2

 Eastern Research Group, Inc., “Emissions from Oil and Gas Production Facilities,” TCEQ Contract No. 

582-07-84003-01, August 31, 2007. 
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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 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 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.6

 The 

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 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 Agency, “Emission Factors for Locomotives,” Technical 

Highlights, EPA-420-F-97-051, December 1997. 4

 Starcrest 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. 
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2.4.2 Updated 2002 Base Year Inventory

Since the 2002 base year EI was originally developed 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 aircraft and GSE as well as 

locomotive emissions were obtained from the TexAER database. The 2002 base 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 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 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 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, 2008, 2011, 2014, 2017, 2018, and 2019. To 

evaluate individual control measure emission reductions for the RFP requirements, a series of 

TexN model runs were executed for both controlled 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 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 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 Transportation, Federal Aviation Administration, “Terminal Area Forecast 

Summary, Fiscal Years 2008-2025,” FAA-APO-06-1, January 2009. 

9

 Eastern Research Group, Inc., “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07-

84003-04, August 31, 2007. 
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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

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 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 factors) and the number of 

units of activity must be determined. 

Emission factors are developed using EPA's mobile emission factor model MOBILE. The model 

may be run using national default 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, 
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rather than national default values. The localized inputs 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 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 Performance 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 speed on each roadway type 

or segment is also needed to complete an on-road emissions 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 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 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. 

• 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 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 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 requirement calculation must be completed. The ABY 

inventory is used to determine the level of non-creditable reductions for each RFP 

milestone year. 

 

10 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 Revision for the 1997 Eight-Hour Ozone Standard 

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• 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 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 NOX

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-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 

RFP Inventory Scenario (vehicle miles traveled per day) 

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
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Table 2-8: HGB Eight-County RFP Ozone Season Weekday On-Road Mobile Source NOX

Emissions 

RFP Inventory Scenario (tons per day) 

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 

RFP Inventory Scenario (tons per day) 

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
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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, 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 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, reformulated gasoline, 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 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 Inventories 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 toward these required percentage reductions. The 

non-creditable 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 the defeat device for heavy-duty 

diesel vehicles (HDDV) was affecting a FMVCP that was implemented prior to the 1990 FCAA, 

the HDDV NOX off-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 NOX offcycle 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 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 reflected 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 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 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 Revision 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 

Calendar Year VMT Emissions Reductions

NOX VOC NOX 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 NOX and 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 Weekday On-Road Mobile Source NOX Emissions and 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 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. 

2.5.5 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 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 Mobile Source VOC Emissions and Control 

Strategy Reductions. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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Table 2-11: HGB RFP Ozone Season Weekday On-Road Mobile Source NOX Emissions 

and Control Strategy Reductions 

Emissions Inventory and Control NOX (tons per day) 

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 

Emissions Inventory and Control VOC (tons per day) 

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 Revision for the 1997 Eight-Hour Ozone Standard 

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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, Weekday On-Road Mobile Source NOX Emissions 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 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 NOX emissions 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 determining the overall 

emissions 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 NOX and 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 Emissions and 2-15: HGB Eight-County RFP Uncontrolled Ozone Season 

Weekday VOC Emissions. Controlled base and milestone year NOX and 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 NOX Emissions and 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 NOX 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. 
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Table 2-13: HGB Eight-County RFP Uncontrolled Ozone Season Weekday NOX Emissions 

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 NOX Emissions 

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 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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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 46.68 690.47 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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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 reduction 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 methodologies 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 milestone 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 emissions for volatile organic compounds (VOC) and/or 

nitrogen oxides (NOX), 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 Revision 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 2018 target levels of emissions for VOC and 

NOX. 

3.3 CALCULATION OF TARGET EMISSIONS LEVELS 

A step by step summary of the six-step process described above for target calculations 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 NOX 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 NOx (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 development 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 NOX and 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 Revision for the 1997 Eight-Hour Ozone Standard 

3-3

The second step of the RFP target calculation methodology 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 years. 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 control reduction that is done as step four. The 

emission rates for an ABY inventory are developed using the latest version 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 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 ABY inventories are documented in Chapter 2: 

EMISSIONS INVENTORIES and 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 pre1990 FCAA controls, the difference between ABY inventories represent an estimate of the noncreditable RFP emission reductions, also referred to as the fleet turnover correction. Table 3-2: 

Summary Non-creditable 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: FTCMSY, VOC = ABY(MSY-1), VOC – ABYMSY, VOC 

 and 

Equation 3-1B: FTCMSY, NOx = ABY(MSY-1), NOx – ABYMSY, NOx 

 where: 

 FTCMSY, VOC = VOC fleet turnover correction for year MSY 

 FTCMSY, NOx = NOX fleet turnover correction for year MSY 

 ABYMSY, VOC = MSY adjusted base year inventory for VOC 

 ABYMSY, NOx = MSY adjusted base year inventory for NOX 

 ABY(MSY-1), VOC = previous MSY adjusted base year inventory for VOC 

 ABY(MSY-1), NOx = previous MSY adjusted base year inventory for NOX

 MSY = RFP milestone year 

 MSY - 1 = previous RFP milestone year 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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Table 3-2: Summary Non-creditable Fleet Turnover Reduction

On-road Mobile 

ABY EI 

Non-creditable Fleet 

Turnover 

Reductions 

RFP 

Analysis 

Year 

NOX VOC NOX 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 NOX reductions for VOC 

reductions, but use of NOX emissions reductions must meet the criteria in §182(c)(2)(C) in the 

FCAA. For the eight HGB counties, an equivalent percentage of NOX reduction may be 

substituted for VOC reduction requirements for all RFP milestone years. The total of the percent 

NOX and 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 NOX emissions. Equation 3-2 

describes the method to calculate the percentage of NOX emissions substituted for VOC 

emissions: 

 

Equation 3-2: NMSY = [3 × (CYMSY – CYMSY-1 ) ] – VMSY

 

 where: 

 VMSY = percentage VOC reductions for year MSY 

 NMSY = percentage NOX reductions for year MSY 

 CY = calendar year

 MSY = RFP milestone year 

 MSY - 1 = previous RFP milestone year 

The VOC and NOX percentages are multiplied by the milestone year ABY inventories for VOC 

and NOX, respectively, to calculate the required VOC and NOX emission reductions for each 

milestone year. Table 3-3: Calculation of Required 3 Percent Per Year NOX and VOC Reduction

provides a summary of the NOX and 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 NOX are shown in Equations 3-3A and 3-3B. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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Equation 3-3A: RQvoc = [ BY2002VOC – ( ABY2002VOC – ABYMSY, VOC ) ] × PVMSY

 and 

Equation 3-3B: RQNOx = [ BY2002NOx – ( ABY2002NOx – ABYMSY, NOx ) ] × PNMSY

 where: 

 RQvoc = required percent VOC emission reductions by 2008 

 RQ NOx = required percent NOX emission reductions by 2008 

 BY2002VOC = 2002 base year inventory for VOC 

 BY2002NOx = 2002 base year inventory for NOX 

 ABY2002VOC = 2002 adjusted base year inventory for VOC 

 ABY2002NOx = 2002 adjusted base year inventory for NOX 

 ABYMSY, VOC = MSY adjusted base year inventory for VOC 

 ABYMSY, NOx = MSY adjusted base year inventory for NOX 

 PVMSY = percentage VOC reductions for year MSY 

 PNMSY = percentage NOX reductions for year MSY 

 MSY = RFP milestone year 

Table 3-3: Calculation of Required 3 Percent Per Year NOX and VOC Reduction 

tons per day RFP 

Analysis 

Year 

Total Percent 

Reduction 

Requirement 

Percent 

NOX

Percent 

VOC ABY EI 

NOX

ABY EI 

VOC 

Required 

Reductions 

NOX

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 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 NOX and 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 calculating the target levels of emissions for the RFP 

milestone years is shown in Equation 3-4.

 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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Equation 3-4: TLMSY X = TL(MSY-1), X – RQMSY,x – FTCMSY, X 

 

 where: 

 TLMSY, 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.) 

 RQMSY, X = emission reduction requirement for MSY for pollutant X 

 FTCMSY, X = fleet turnover correction term for MSY for pollutant X 

 X = either VOC or NOX 

 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 NOX Emissions and 

3-5: RFP Post-2002 Target Level of VOC Emissions summarize the calculation of the target 

levels of VOC and NOX for 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 NOX Emissions 

tons per day 

RFP Milestone 

Year Previous 

Target 

FMVCP NonCreditable 

Reduction 

Post-2002 

Percent 

Reduction 

Requirement 

NOX

NOX Target 

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
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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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 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 NOX

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 between 2002 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 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 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 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 added 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 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 reductions 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 Revision 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 2018 summarize 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 NOX Emission 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 NOX 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 Yes 

Table 3-7: Summary of RFP Demonstration for Eight HGB Counties for 2011 

tons per day Line # Description NOX 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 
HGB Reasonable Further Progress SIP Revision 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 NOX 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 NOX 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 Yes 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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Table 3-10: Summary of RFP Demonstration for Eight HGB Counties for 2018 

tons per day Line # Description NOX 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 Yes 
HGB Reasonable Further Progress SIP Revision 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) 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 used to meet the RFP targets is presented in 

Tables 4-1: Summary of HGB RFP NOX Emission Reductions and 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 tables 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 Revision for the 1997 Eight-Hour Ozone Standard 

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Table 4-1: Summary of HGB RFP NOX Emission 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 NOX standards 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

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 NOX 

emission rates. See Table 4-2 for information regarding VOC reductions
HGB Reasonable Further Progress SIP Revision 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 NOX standards 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

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 several 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 NOX

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 Revision for the 1997 Eight-Hour Ozone Standard 

4-4

4.3 AREA SOURCE CONTROLS 

The only area source control in the HGB area used 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 calculated 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 encourages 

states to update the model with local, county-level data based on surveys 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 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 type data 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 TexN model 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 were executed for both controlled and 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 

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 each 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 using data extrapolated from a contractor report 

drafted by Eastern Research Group, Inc., (ERG) and contained in the Texas Air Emissions 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

4-5

Repository (TexAER) database.12 The uncontrolled emissions were developed 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 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 Reductions and 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-Hour Ozone Nonattainment Area Reasonable Further Progress 

On-Road Mobile Source Emissions Inventories includes 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-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 NOX Emission Reductions and 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 

 

12 ERG, “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07-84003-04, August 31, 

2007. 

13 EPA, “Emission Factors for Locomotives,” December 1997. 14 ERG, “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. 16 ERG, “Emissions from Oil and Gas Production Facilities,” August 2007. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

4-6

4.6 CONTINGENCY MEASURES 

In case of a milestone failure, contingency control 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 NOX reductions. As shown in 

Table 4-4: 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 

NOX and a 0.5 percent reduction in VOC to be achieved between 2008 and 2009. The excess 

emission reductions from the RFP milestone year 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 

NOX 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 NOX and 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 contingency 

requirements, so the excess emission reductions from the 2018 RFP demonstration are included 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, 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 Revision for the 1997 Eight-Hour Ozone Standard 

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Table 4-5: 2019 RFP Contingency Demonstration for HGB Area 

2019 Description 

NOX 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 NOX Standards 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 Revision 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 strategy 

emission 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 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 (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 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 HoustonGalveston Area Council (H-GAC) to develop these inventories. Appendix 9: Houston-GalvestonBrazoria 1997 Eight-Hour Ozone Nonattainment Area Reasonable Further Progress On-Road 

Mobile Source Emissions Inventories is a copy of the H-GAC contractor (ENVIRON 

International Corporation) report, which provides 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 for 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 (NOX) and volatile 

organic compounds (VOC) and, therefore, even if the safety margin is used for a transportation 

conformity determination, the HGB area will still meet the eight-hour ozone 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, even if this 

safety margin is used, the HGB area will still demonstrate RFP for each milestone.
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-2

Table 5-1: 2008 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description 

NOX

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 Margin1 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 emissions equaling 10 

percent of the 2008 on-road emissions projection with post-1990 FCAA controls for each NOX and VOC is 

used to provide a safety margin for 2008.
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-3

Table 5-2: 2011 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description 

NOX

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 Margin1 12.34 6.83

2011 RFP Motor Vehicle Emissions Budgets 135.74 75.17

1 The 2011 RFP reductions exceed the required emissions reductions. Excess emissions equaling 10 

percent of the 2011 on-road emissions projection with post-1990 FCAA controls for each NOX and VOC is 

used to provide a safety margin for 2011.
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-4

Table 5-3: 2014 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description 

NOX

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 Margin1 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 NOX and VOC is 

used to provide a safety margin for 2014.
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-5

Table 5-4: 2017 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description 

NOX

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 Margin1 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 emissions equaling 10 

percent of the 2017 on-road emissions projection with post-1990 FCAA controls for each NOX and VOC is 

used to provide a safety margin for 2017.
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-6

Table 5-5: 2018 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description 

NOX

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 Margin1 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 emissions equaling 10 

percent of the 2018 on-road emissions projection with post-1990 FCAA controls for each NOX and VOC is 

used to provide a safety margin for 2018.
WRITTEN AND 

ORAL TESTIMONY 
Reference 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 OFWENDl1lA:MMOND

7325 Augus~ Circle

Plano,n 75025

Wendi@TexasEnvironmentalLaw.net

i

11/139/2121139

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17:133 46924112143121 HAMMOND

, I

W-1

PAGE D.Lt ..",-

RECEIVED

NOV 09 ZUUY

AIRQUALITY

~'VtllON

FX: (469) 241..()430

'November 9, 2009

I.

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, 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 behalf9f the KIDS for Clean AIr. the Sustainable Energy and Economic qevelopment (SEED) Coalition.

me Clean f'Jr Institute ofTexas, 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 byreference.

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 ofoontlnued ozone reductions attributable to

the existIng and proposed -new" oontrol strategies, and the proposed development of significant point

rources l~ted outside and upwind ofthe 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 nValues 0 •

I . ifhe 1997 /thour standard removed the 1·hour standard because In theory the 8-hour standard would beas

prmore etrrctive atprotecting 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

ra1ue did npt violate the B-hour standard. but several monItors dId violate the QId 1·hourstandard forthe

~ame time period.' .

!. 'j

/1be aiTm~ltors included reSQlatory rnomtoring sites Northwest Harris Co. C26IAllOIX1S4 andWallsvUle Road

F617. S~cnvirolllncntlli dataalso iutiludcdnOD-rcgulatory monitoringsitesCrosbyLibrary C553 and TomB888

~S8. No~: theTom Bassmonitor actually had a design value exceedjng the8-hourstan4a:rd. butthesite isnotan

pA regul~approved site.

1\
46924HI430 . PA6E E12/E12

I

An eXPlan~tion for this phenomenon could be attributed to the implication ofunusual 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 isthat itcompensates forfluctuations that may provide an unusually high design value,

but Itdo~e'otcompensate for fluctuations that may provide an unusually low design valu~. .

For exam~ :e1 Texas experienced unusual/extreme weather fluctuations in 2007 and 2009. In 20071 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. Ukewise1 in 2009, Texas e~enced an unusually windy ozone seeson, but

again Whtthe are~ experienced typical weather patterns for ozone fonnation, theair monitors once

again reg red ozone excaedances (spiking to 157 ppm atone Houston monitor). . , .

The attainrpent demonstration must somehow account for ·normalaweather patterns that are conducive for

ozone fonnation 'in such away that unusuaVextreme weather fluctuations do not impact attainment .

dsmoJons in afavorable ornon-favorable manner. Therefore, little weight ofevidence should be

afforded to the "trend- of2007·2009 skewed design values.

Both D nstratla 5 Ov I te e Benefits of Exlstln and Pro ed I

r your attention tothis 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 beafforded toacontinuing. "trend- ofozone reductions when the

. demon . ·~ns themselves ~11s toadequately establish ongoing reductions attributable to existing and/or .

~roposed rwcontrol strategl9s. , .

Both DemonstratJMUafl to Adequately Account forExpected Known Increases inOzon,

PrecursoriJ;misStons Located OutsIde theHBS 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 inR!lberlson, Milam1

Calhoun, oliad, and Matagorda counties). These point sources wiD emit vast amounts ofozone

precurso (e.g., NOx and VOe) thatwlll blow into the HGB nonattainment area and either cause or

contribute NMQS violations. Both demonstrations fall toadequately account for these Increases and

!he P"tentitl impacfs onHGB's ability Inattain the ozone NMOS s1enderd by fhe dead6ne.

Conclusion ' ,

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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 ofthe 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. 2009-006-10I-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

ChiefEngineers Office

TexasCommission on Environmental Quality,

P.O. Box 13087, Austin, Texas 78711-3087

Dear Ms. Brown:

Thank you for the opportunity to comment on the proposedrevisions 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 AttainmentDemonstration SIPRevision for the 1997Eight-Hour Ozone Standard

(Project~o. 2009-o17-SIP-~)

• HOBReasonable Further Progress SIPRevision for the 1997Eight-Hour OzoneStandard

(project ~o. 2009-018-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

OzoneNonattainment Area(RuleProjectNo. 2009-o19-101-EN)

We look forward to working with your agency to continue to reduceozonelevels. If you

have any questions, pleasecontactme or CarlYoung ofmy staffat 214-665-6645.

Sincerely yours,

4~Chief

Air Planning Section

Enclosure

cc: WalkerWilliamson (TCEQ)

Devon Ryan (TCEQ)

JessicaRawlings (TCEQ)
Enclosure

Detailed Comments on Proposed Revisionsto the

HoustonlGaivestonIBrazoria (HGB) SIP

Withthisenclosure we are providing detailed comments on:

• HGBAttainment Demonstration SIPRevision for the 1997 Eight-Hour Ozone Standard

(ProjectNo. 2009-017-SIP-NR)

• HGBReasonable FurtherProgress SIPRevision for the 1997 Eight-Hour Ozone Standard'

(ProjectNo. 2009-Q18-SIP-NR) ,

• HighlyReactive VOC Capand Trade (HECT) Program CapReduction and Allowance

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

• MassEmissions Capand Trade(MECT) Program CapIntegrity for the HGB Eight-Hour

Ozone NonattainmentArea (RuleProject No. 2009-Q19-101-EN)

,

UGHAttainment Demonstration SIP Revision for the 1997Eight-Hour OzoneStandard

(project No. 2909-017-SIP-NR)

EPAappreciates the levelof analysis that TCEQ has completed in the HGBproposed 1997 eight

hour ozoneattainment demonstration. Itis clearthatTCEQ and researchers havecontinued to

advance the science of modeling the Houston areaand alsotheunderstanding ofthe ozone .

conceptual model forhow ozone is formed in Houston. TCEQ's analysis andanalysis of other

researchers (NOAA, DOE,UT, etc.) thatthe highest ozone concentrations observed inthe HGB

areacan invariably be linkedto transport ofthe industrial plumes emittedin the vicinity ofthe

Houston ShipChannel (HSC) whichis a key findjng in developing plansto lower ozone levelsin

the HGBarea. .

The currentmodeling indicates several monitors (Deer Park,'Bayland Park, and Wallisvill~) will

not be in attainment in 2018 usingthe 2006 baseline DV. The future ozone levels arehigher

usingthe 2005baseline DV. Overall, the modeling doesnotindicate,the area willreach

attainment, but themodeling (using a 2006baseline DV)isin the rangeofEPA's modeling

guidance of when Weight of EVidence canbe usedto potentially support an conclusion'that

attainment will stillbeachieved, .

RecentOzone monitoring trends andthe mostrecentdata (2007-2009) add significant support to

the Weight OfEvidence in the proposed 1997 8 HourAttainment Demonstration SIPthatthe .

areamightattain andmaintain attainment of the standard. Recenttrendshoweverto area ozone

formation can also be a function ofthemeteorology not beingparticularly conducive the lastfew

years. Themeteorology in combination withdecreased local, regional, and national emissions

due to the economic downturn mustalsobe considered whenevaluating theweight of evidence.

One qualitative indication that someof the ozone decreases are likelydriven by meteorology and

economic impacts is that many areaswithin Region 6 sawtheir 4th Highs drop 5-10 ppbthelast2

years and onlyDFWand Houston areas havehad anypotentially largelocalreductions other

thanannual fleetturnover. 'With ozone levels decreasing in much ofRegion 6 thelastfewyears,

..,
it is importantto try andconsider how muchof the Houston monitoring trendsare dueto control

measuresandhow muchis dueto favorable meteorology and emissions decreases dueto

regional and temporary.economic downturns.

Evenwith the recenttrendand 2007-2009 preliminary. data thatindicates a DVof84 ppb, EPA

remains concerned that the areawill continue to attainthe 1997eighthour ozonestandard. . . .

The modelingis basedon moretypicalozone conducive meteorology (2005 and 2006)in the

HOBarea. It shouldbe notedthatthe modeling attainment test allows the usc of as-year

weightedaverage thatis easierto showattainment than usingthe worst 3-yearDVsthat include

the base modeled years. The 5-yearweighting wasselected by EPAto givesome averaging of

meteorology. TCEQ originally modeledusinga 2005CenterWeighted DV (CWDV) that

resultedin highervaluesthan the2006CWDV included in the proposal. Modeling usingboth

the more favorable 2006CWDV and the 2005CWOV indicates several monitors with2018

FutureDVs (FDVs) severalppb abovethe 84 ppb standard. Themodeling is indicatingthat even

with additional federal measures that the areawill not reach attainment by 2018. Future

reductions not included in this proposedSIPmay be necessary to achieveattainment ofthe 1997

eighthour ozonestandard

EPA's guidance isto use the modeling in a relativesenseforthe monitored attainment test and

also for the areasoutsideof the monitors usingEPA's MATS software. In the draft Houston

package,TCEQhasnot includedtheMATS software analysis in the attainment sectionofthe

SIP. The MATSsoftwareanalysis shouldbe included as part of the attainment write-up of the

SIP to indicate ~e model's predictions in areasoutsidethe grid cell arraysused in the monitor

attainmenttest .

TCEQhas utilizedtheirPotentialSource ContributionFunction(pSCF)to adjustreported

emissions in the 2006 special inventory from 12.44 tpd of HRVOCs in HarrisCounty (7.39tpd

for HECT sources and 5.05tpd for non-HECT sources) to 22.44tpd ofHRVOCs in Harris

County. Thusadding 10tpd to reported inventory values. The HECTsources(exceptfor some

small emissionsources) have beensubjectto monitoring requirements since200516, so the extra

'emissions from HECTcan only be fromunmonitored sources or incomplete combustion from

flares. Becauseunmonitored sourcesare small the most likelysourceof emissions is flares. The

proposedSIPassumes HECTsourcesemitan additional 6 tpd of unreported HRVOC emissions.

TCEQ shouldjustify this assumption. .

Withthe additional 6 tpd TCEQprojectsfor the future 2018inventory 13.39tpd for BECT

sources. In addition TCEQadded tpd frombankedemissions, bringing the total to 15.39tpd

for HRVOCemission in the HECT. Then,TCEQassumed that the HECTemissionwill be

reducedto the currentcap levelof 10tpd. This reduction is notsupportedby anyregulation or

controlmeasureor enforceable commitment, and therefore shouldnotbe included in the

modeledprojections.

In additionto om overallconcern that the area maynot continue to attain the standard and may

. .still be in nonattainment withthe 1997eighthourozonestandard in 2018we haveprovided

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 locationofozone,but continues to underestimate the peak ozone levels. This creates

some concernthat the median emissionadjustment approach may not be yieldingenough

emissions in the modelingto generate the peak ozone levels. Model performanceindicates that

the model was .underestimating the peak valuesof some VOC species and also ozonepeaks. The

modeled peak shouldtheoretically be higherthan the monitored peak, since the oddsthat the

modeling domainpeak aregoingto happen at a monitorarenot a statisticiillyhigh probability.

TCEQ discussed in chapter 5 the Issue of incommensurability which may explainwhythe

modeled valuesseemed to overpredict Ethylene and Olefinspeciesat the Wallisville monitor as

,modeled valuesrepresented a valueofthegrid cell versusthe monitoreddata thatreflectsa

point ,This conceptofcomparingmodelvaluesto monitored valuesis discussedby 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 aboutunder-prediction biasraises concernthat more emissions should be includedin

the base and also be left in the future yearinventory. Usingamulti-year annual meanmay result

in an underestimation ofthe actual emissionsthat occurred.

TCEQ's modelingofincreasedflare emissions as a replacement for the PSCF emission

reconciliationyieldedbetter ozonemodel performance thanthe base special inventory. In

addition to the many other scientificstudiesthat indicatethatflare emissions areunderestimated

in themodeledand reported emissioninventories this modeling sensitivityalso supports the

conclusion that:flares are a significantsourceofthe underestimation ofVOC emissions from

industrial sourcesin Houston.

We note that TCEQis in the processofstudyingflare operations and is consideringthe optionof

requiring more monitoringand oversightof flare operation in the future dependentuponfindings ,

ofstudies. For this and'otherreasonswe supporta commitment by TCEQto conduct a Mid

Course Reviewusingphotochemical modeling.

. AttainmentDemonstration and WOE

On Page 5-8 ofthe TCEQ concludesthatthe retrospective modelingbetween 2000 and 2006

emission levels "appears to underestimate the response to emissioncontrols". The retrospective

modeling is not conclusivein showingthe modelsresponsiveness to emissioncontrols asthe

DVs from the two periods are made up of multipleyears worthofozone datawithmeteorology

.from two differentsets ofmulti-yearperiods. Considering thatthe 2006 reported emission

.inventoryis havingto be adjusted based on monitoring data and using gaussianbasedmodelsto

estimate emissioncorrectionlevelsfor groupsoffacilities in the same back trajeCtory, it is clear

thatTCEQ maypotentiallyhave an approximate estimate ofthe multi-year meanemissions that

occurredin 2005/6. Data from field studiesindicatessignificant variability,but overall a large

underestimation ofemissions. But to base an emissionchange comparisonwhenno onehas ali ,

accurateassessment of2000 and 2006 actual emissioninventories raises many

incommensurability issues. These incommensurability issuesinclude: comparing two different
multi-yearperiodsof meteorology, using a multi-year meanwhenthe emission inventory

demonstrates a fluctuation of data, the PSCF is likelyunderestimating the amount ofreported

emissionincreasesthatshouldbe done since it doesnot take into account chemistrythat

decreases emissionconcentrations betweenthe facilityandthemonitor, an adjustmentbased on a

multi-yearmean overlooks variables thatwouldtheoretically leadto higher.ozone pre-cursors on

summerdays/meteorological conditions. The 2006 imputed emission estimatesappear to be

gettingdecent modelperforman~, but there is an under-prediction biasinpeak values thatis not

necessarily a modelformulation issue as an issuethatwithout detailed facility monitoring we .

will never knowwhat arethe correctemissionsto model. When eventhe 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 clearthatthe biggervariable to how the modelis

reactingto emissionchanges is whetherwe are startingwiththe correctemissions. The PSCF

techniquethat TCEQis utilizing to adjust emissions (2x to lOx reported level from a special

inventory') is gettingthe modelperformance to withinEPA'sperformance metrics of+/-20%and

+/- 350/0, but the amountofpotential changein DVs from2000to 2006is a function of many

variables that we do not have sufficient data to concludethemodeling is not reactingsufficiently,

it is more likely the issue ofnot havingthe correct emissions,

It doesnot appearthat enough certainty exists in the data andthere areincommensurability

issuesthatseemto make it inappropriate to concludethatcomparing modeling of 2000 and2006

reportedemissions (evenwithimputed estimates) whilem9deling the 2006 meteorology with

2000meteorology indicates the modelis not reactingsufficiently to emission changes.

EPAappreciatesthe level ofanalysis thatTCEQhas completed in the HOBozone conceptual

model and in theCorroborative analysison thehighestOzone values that impact the Design

Valuesat the monitors in Houston. The conclusionfromTCEQ's analysis and analysis of other

researchers(NOAA, DOE,UT, etc.)that the highest ozoneconcentrations observed in the HOB

area (includingareas in the Southeast, Southern, and Southwestern portions ofHouston) can

invariably be linkedto transport ofthe industrial plumes emittedin the vicinity ofthe Houston

Ship Channelis a key finding in developing plans to lowerozone levelsin the HOBarea.

Chapter5 ofthe proposal includes many ozonemonitoring trends thatarevery interesting but the

linkageto what is causingthe recent decreasesin 2007-2009 values(2009 valuesneedto be .

QAlQC'd by TCEQIEPA) is missing. EPA's analysis (including informationprovidedat the

April 2009 SoutheastTexasPhotochemical Technical Modeling Committeemeeting) is that

valuesin 2007 and 2008 were influencedby higherthan average frequency ofhigh speedwinds,

less ozone conducive daysthan normal, and emissions lowerthan normal due to the economic

downturn. Industry representatives have commented in pastpublicmeetingsthat their emissions

have been lowerthe last few years(startingin 2007) due to economic influences and whenthe

demandimprovesit is likelytheir emissionswill increaseoverthe levelsin 2007-2009. TCEQ's

. HECTcap requirements andmonitoring requirements wereput in placeprior to the recentlarge

changes in 4th highozonelevelsthat make up the DV calculations. As ofNovemb.er 1It2009

fourmonitorshad preliminary 2007-2009DVs of 84 ppb, butall monitors appearedto be in

attainment. After the economy gains strength and emissions likelyincreaseand whenless

favorable meteorology occurs in the future, it seems unlikely that the areawill continue to

monitorattainment, especially at the Deer Parkmonitor. As discussed elsewherepeak ozone
levelsare heavily influenced by industrialemissions. Without furtherreductions overexisting

emissionlevels fromindustrial sourcesit seemsunlikelythat the Deer Parkmonitorwill

maintain attainmentandmonitors downwiild ofthe industrial emissions will continue to have

somehigh readings. WhileFourthHigh valuesare down, the area stillhas a numberofbigh

days. In 2009, eighthour valuesofthe monitors(FRMand other)in the Houstonareabad 22

monitorswith 1stHigh valuesequal or greater than90 ppb (9 monitors with valuesfrom 100-110

ppb), 12 monitorswith2Dd Highvalues equal or greater than- 90 ppb, and 12 monitors with3M

Highsgreater than 84ppb. Withthis many exceedances ofthe standard at manymonitors it is

easyto see how the combination ofbigher emissions and lessfavorable meteorology couldresult

in the area not monitoring attainment.

chapter 5 of the proposaldid not includeany discussion of emissions trends and howthey

correlatewith the recentozonemonitoringtrendsanalysis. EPA'smodeling and attainment

guidanceindicatesthat monitoring and emissiontrends shouldbe included as one ofthetbree

areasthat shouldbe covered in WOE (including pages.99, 101-103 ofthe 2007 modeling and

attainmentguidance). In addition to emissiontrends analyses and comparisons/correlations of

emissionstrends and ozonetrends, expected future emission trends (including the major

categoriessuch as pointarea, nonroad, onroad,etc.) shouldbe includedin this analysisto help

correlatethat futureemission reductions will resultin lowerozonevaluesin the future. Since

TCEQand othershave concluded that the valuessettingthe DV at monitors in the southwest,

southernand southeastern regionsofHoustonare heavily impacted by emissions from the HSC

industrial emissions, a focus on future changesexpected in HSCindustrial emissions seems

centralto the argument thatthe HGB area will be in attainment in the future. Thisspecific

analysisofrecent historical emissionsand monitoring trends and future emissiontrends that

impactthe area's DV withexpected impacts on ozonelevels is a verykey WOE element that

allowed us to-move forward with approvalofthe DFW 19978-hourOzone SIP. Including these

analysesin your WOEwouldhelp to make sure that youcoverthe threemain areasdiscussed in

the WOE guidance.

Summary

Fromthe information that TCEQincludedin the SIPproposal, it is obviousthat a lot ofhard

workhas gone into the modeling, WOEand other analysesto betterunderstand the phenomena

that result in ozone exceedances in Houston. We appreciate the hardwork ofthe manyTCEQ

people and researchers that have contributed to the development of the draft HoustonSIP.

Otherthan the fleet tumoverand other federalmeasures between2009and 2018,TCEQhas not

proposed in this SIPemission reductionrequirements that will loweremissions belowcurrent

actuallevels. Withoutfurther reductions in the HSCarea it is difficult to see howtheDeer Park

monitor and othermonitors will remain in attainment wheneconomic conditions improveand

less favorablemeteorology occurs. EPA encourages TCEQto consider additional controlsto

insure the area will continue to bein attainment ofthe 1997eighthourstandard.

-l

I

iII
RACM

TCEQ and othershave shown thatthe HOB Nonattainment areais heavily influenced by the

emissionsfromindustryin the Southeast quadrant of Houston (including industry around the'

Houston ShipChannel). Therefore reductions in industry emissions would bemost effective in

advancingattainment. Additional monitoring andrequirements forflareswouldaid in

improvingthe emissioninventory and alsocouldleadto real atmospheric reductions of ozone

pre-cursors. We supportTCEQ'sFlareTaskForceinitiative and hope itresultsin better

flare operations and reduced emissions in the future.

The proposed reduction and reallocation of theBanis countyHRVOC cap does notrequire

HRVOC levelsto be reduced belowcurrently reportedlevels. The current 25% reduction in the

HECT Capwould still be higherthan reported emissions and wouldallow for growthand

. allowances for upset conditions. In essence, theproposed25%HECTCap reductionwould

allowHRVOC emissionincrease atHECT applicable facilities compared to the highestannual

actual HECTemissions.

As part of it's RACManalysis, TCEQ should consider whetherreductions in "actual" HRVOC

emissionscould accelerate attainment. Furthermore, TCEQ should explain whythe reductions

can not be implemented sooner than theproposed 2015-2017 timeframe.

Mid-Comse Review

We recommend that the attainment demonstration include a TCEQcommitment to a mid-course

review ofthe attainmelit demonstration. Because ofthe uncertainty in longterm projections, we

believea viable attainment demonstration thatrelieson weightof evidence Should contain

provisionsfor periodicreviewofmonitoring, emissions, and modeling data. Clearly, current

monitoring trends wouldmdicate significant progress is beingmade. Undoubtedly, control

measuresimplemented bythe Texas andFederalgovernment have contributed to this progress;

Otherfactors, however, haveplayeda role such as the economic downturn and favorable

meteorology. The currentmodeling showseveralmonitors exceeding the 1997standard. The

differences between the modeling andmonitoring accentuate the overall uncertainty in longterm

projections. The mid-course review wouldshowwhether the adopted control measures are

sufficient to reach attainment by the area's, attainment date (basedonphotochemical modeling),

or that additional controlmeasures are necessary, Werecommend thatthereviewbecompleted

by December 2013. We also anticipate that SIPsfor a revisedozonestandard wouldbe due in

December 2013, so that the reviewcouldbe done in conjunction witha SIPfortherevised '

standard.

NitrogenOxides(NOx) Reasonable Available Control Technology (RACD Determination

(Section 4.4.2. page 4-7 and Amxmdix D)

Please confirmthat all NOx pointsources in the HOB area withthe potential to emit25 tons/year

or more have been included in the list ofsources that the Statehas included in its evaluation for

RACTpurposes.
As controltechnology is dynamic and couldchange with time,pleaseconfirmthat the level of

NOx controlfor affected NOx sources in the HGB area stillrepresents RACTtoday.

RACT shouldbe federally enforceable. PleaseexplainwhyTCEQ believes it is appropriate to

use a New SourceReviewpermitcondition for a glassmanufacturing facility in the affected area

to implementRACT. Pleaseprovidea copyof the final permit

Volatile Organic COmPound <YOC) RACTDetermination (Section 4.4.3.pages 4-7 to 4-9 and

~~~ .

We have reviewed this actionwithrespectto the CleanAir Act(CAA) andthe Control

Techniques Guidelines (CTGs) issuedby EPAin 2006,2007, and 2008,and have the following

comments.

WorkPractice Requirements: For a numberofCTG categories, TCEQhas chosennot to adopt

the recommended workpractices. For all applicable CI'Gs, EPAcontinues to believework

practice requirements providereasonable, cost effectiveways toreduceemissionsand that these

controlrequirements shouldbe met In orderto meet RACTrequirements, the stateshouldeither

adopt rulesimplementing the workpracticerequirements, or provide analysisdemonstrating that

the requirements are satisfiedby existing federally enforceable roles.

cm categories: Industrial Cleaning Solvents, Miscellaneous IndustrialAdhesives. Large

Appliance Coatings. Metal Furniture Coatings andMiscellaneous Metal andPlastic Parts

Coatings(section4.4.3.3,andAppendix D). For these :five CTGs, Texashas neitheradopted

rules nor provideda negativedeclaration. In order for the HGBarea to meet the requirements

for RACT (40 CFR51.912), the state will need to complete RACTdeterminations and take

appropriate actionfor the CTGcategories of Industrial Cleaning Solvents, Miscellaneous

Industrial Adhesives, LargeAppliance Coatings, MetalFurniture Coatings and Miscellaneous

. Metal and PlasticPartsCoatings. EPA will be ableto consider approval of theVOC RACT

update onlyfor those CTGsthathavebeen thoroughly addressed.

WerecognizethatEPAhas not yet responded to the TCEQletterofDecember 8,2008

concerning the CTGdocuments for LargeAppliance Coatings, MetalFurniture Coatings; and

Miscellaneous Metaland PlasticPartsCoatings (section4.4.3.3, and AppendixD). Whilethe

new CTG documents for thesesourcecategories recommend morestringentlimits"for general

use coatings, there are somespecialty categories for: whichthe new CTGsrecommend limitsthat

are less stringent than the general use limits established in the guidance from the 1970s. For

someofthe subcategories withintheseCTGs, the limitsin the new CTGsare lessstringent than

the approved TexasSIP so it is possiblethe new limitswillresultin increased emissions. In

general, EPA expectsthe limitsin the CTGto resultin reductions in VOCs but it is unclearfor

specific states or areaswhetheroverallreductions will occur.

We believethatTexashas at leasttwo options for movingforward withthe specialty coating

typesdiscussedabove. The state couldleavethe limitsin placefor the specialtycategories

where the existinglimits are more stringentthan the limitsin the CTGsorthestate couldrelax

the limits consistent with the new CTGin whichcase the statewouldhaveto provideadditional

:

! ,

; .

',

I
'analysisto showcompliance with 110(1) of the CAA. We notethatTexas is notrequired to

adoptthe lessstringent limits in the CTG. The CTGprovides recommendations, butdoesnot

bind statesto adopt specific limitsorrequirements to meetRACT. Ifthe existing Texas roles as

they applyto specialty categories aremore stringent than the limitsrecommended inthe CTG,

the state couldchoose to submitthemasmeeting the RACT requirement, and, assuming all other

requirements aremet, we anticipate that we wouldbe able to approve them asmeeting RACT for

the source categories addressed by the CTGs. The statewouldstillneedto evaluate the more

stringent recommendations for general use categories and adoptthemas appropriate. IfTexas

chooses to relaxlimitsforspecialty coatings thatare in the approved SIPconsistent with the

recommended limitsin the CTGs,the statewouldneed to demonstrate under section 110(1) that

the SIP asrevisedwouldnot interfere with attainment of orreasonable further progress toward

attainmentof theNational Ambient Air Quality Standard (NAAQS) orinterfere withanyother

applicable requirement of the CAA. In general, ifa submitted revision achieves the sameor

greater emission reductions as the approvedSll' within the same timeframe as provided under

the existingplan,wehave beenableto approve the revisionas meeting section110(1).

Flat WoodPanelingCoatings (section 4.4.3.1 and Appendix D). Regarding workpractice

requirements, pleaseseethe comment above.

Fiberglass BoatManufacturing Materials (section 4.4.3.2and Appendix D). Forthe Fiberglass

BoatManufacturing Materials source category TCEQhas identified no facilitiesin HOBsubject

to this CTG(pages 4-8, D8 and D-9). However TCEQis notmaking definitive negative

declaration forthis source category. Instead, the TCEQ''has detemrlned thatimplementing the

recommended controls in the Fiberglass BoatManufacturing Materials CTGdocument would

neitherresultin substantive VOC reductions nor be economically feasible."

The proposal reliesin part on EPA's priorguidance, "IssuesRelating to VOCRegulation

Cutpoints, Deficiencies, andDeviations, Clarification to Appendix D ofNovember 24, 1987

FederalRegister", issued May25, 1988. ID. particular, pleaseseeAttachment 2 of the guidance,

for an Example 5% RuleCalculation. Thiscalculation shouldbe basedspecifically on sourcesin

the Houstonarea Wedo not. believe the TCEQ'sinterpretation of this 1988 guidance is correct.

EPAcontinues to believe that theseare costeffectivecontrols. To meetVOC RACT

requirements this category needs to be addressed.

Flexible PackagingPrintingMaterials (section 4.4.3.2andAppendix D). Regarding work

practice requirements, pleaseseethe comment above.

Paper, Film, and FoilCoatings (section 4.4.3.2 and Appendix D). Regarding workpractice

requirements, pleaseseethe comment above.

Lithographic Printing Materials and Letterpress PrintingMaterials (section 4.4.3.4 and

Appendix D). Detailed comments regarding this are included in a separate letteraddressing

theserule revisions. (RuleProject No. 2008-019-115-EN).

Automobile andLight-Duty TruckAssemblyCoatings(section4.4.3.1, andAppendix D). No

comments.
Transportation Control Measures (Section 4.6.2.1 and Amxmdix G) ,

Theplan specifies that onceTransportation Control Measures (TCMs) areincludedin the SIP,

theHoustonareais legallyboundto implement eachof these controlmeasures in a timely

manner. Pleaseinclude estimatedtime:fram.es forinitiation andcompletion ofthe candidate

TCMslisted inTable1 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 updatedpointsource 2002baseyearinventory states that voc emissions

wereadjusted to account for unreported VOC emissions (page 2-2). Please further describe how

the unreported emissions were' accounted for.

, One severeozonenonattainment areaSIP requirement is to identifyand adopttransportation

.controlmeasures (TCMs) that wouldoffsetany growth in emissions from growth in vehicle.

.mileS traveled(VMT) or numbersof vehicle trips(CM section 182(d)(l)(A». The analysis

providedin theReasonable FurtherProgress SIPindicatesthat the predictedgrowthin VMTin

the area is not expected to result in a growth inmotorvehicle emissions(tables2-14and 2-16).

Pleaseconfirmthat the predietedgrowth in VMTin the areais not expected to resultin a growth

, in motor vehicle emissions and that TCMsarenot neededto offsetgrowth in VMT..

BighIy-Reactive Volatile Orgame CompouDd Emissions Cap and Trade Program (project

No. 2009-G06-101-EN)

Pleaseconfirmthat the non-reportable emission events that exceedthe emissioneventset-aside

in section 101.396(c) will bededucted from the individual site's compliance account no later

than March31 ofthe yearfollowing the applicable calendar-year controlperiod. This approach

.is consistent with the approach outlinedatsection1O1.396(d) forreportable emission eventsthat

exceedthe set-aside. Theroles shouldberevised to clearlyreflectthis approach as well

Mass Emissions Cap and Trade Program (project No. 2009~19-101-EN)

Pleaseexplainwhythe revisedroles at section I01.353(b) do not require minorsourcesthat

submit late ECT-3 forms to obtain allowances from existing sources. This exemption forminor

sources could increase the overallcap andjeopardize the attainment demonstration modeling for , the HGBarea.' . .
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) ,

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october 28,2009, 2:00p.m.

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Rule ProjectNo.: 2009-017-8IPooNR (ADSIPRevlalons), 2009-018-SIPooNR (RFP SIP Revisions), 2009-006-101-EN (HECT),

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Page3

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

PUBUC HEARING REGISTRAnON

october 28, 2009, 2:00 p.m.

Houston-Galveston Area Council, 355511mmons lane, Houston

RuleProject No.: 2009-017-8IP-NR (ADSIPRevisions), 2009-018-SIP-NR (RFP SIPRevisions), 2009-006-101-EN (HECl),

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Page4

TEXAS COMMISSION,ON ENVIRONMENTAL QUALITY

. PlJBUCHEARING REGISTRATION

October 28, 2009, 2:00 p.m.

Houston-Galveston AreaCouncil, 355511rnmoos Lane, Houston

- Rule Project No.: 2009-017-8IP-NR (AD SIP Revisions), 2~18-SIP-NR (RFP SIP RevIsions), 2009-006-101-EN (HECT),

2009-019-101-EN (MECl}, 2008-019-115-EN (Offset Litho)

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PageS

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

PUBUC HEARING REGISTRATION

October 28, 2009,2:00p.rn,

Houston-Galveston Area Council,355511mmons Lane, Houston

Rule Project No.: 2009-017-SIP-NR (ADSIP Revisions),2009-018-SIP-NR (RFPSIP Revisions), 2009-008-101-EN (HECT),

2009-019-101-EN (MECT), 2008-019-115-EN (OffsetLitho)

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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

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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:

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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

(GARRISI) ••.....•........•......................... 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

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REPORTER'S CERTIFICATE ...........•................. 30

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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
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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 and
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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
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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.
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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

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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,
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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

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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

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situation. Printing has traditionally been one of the

first industries impacted by economic downturns, and one

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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

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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

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have -- again, on an average they will be increasing

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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 see
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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

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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
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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

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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

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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
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intense database ever developed for regulatory modeling

in the United States. TCEQ has provided a robust weight

of evidence determination that corroborates its

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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

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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

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ongoing and planned future activities in the SIP

proposal that will both improve modeling performance and

provide additional precursor reductions. The Coalition
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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

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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.
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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

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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
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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

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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 years
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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

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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 in
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which the proposed reallocation actually increases the

inequalities.

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 of
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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
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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 for
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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 ozone
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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.
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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
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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 12/31/09
20

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 AreaCouncil, Houston, Texas

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

TEXA$ COMMISSION ON ENVIRONMENTAL QUALITY

PUBUC HEARING REGlsTRAnON

October 28, 2009, 8:00 p.m.

Houston-Galve8ton Anta Council, 35551inn101w Lane, HOlBlon . "

Rule Project No.: 2009-017-8IP-NR (AD SIP RevIsions), 2009-018-8IP-NR (RFP SIP RevIsIons). 2009-0D8-101-EN (H~Cl),

2009:019-101-EN (MECl)~ 2008-019-116-EN (orr.et LIho)

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TEXAS COMMISSION ON ENVIRONMENTAL 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 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

Date signed
INDEX OF ORAL TESTIMONY

October 29. 2009, 3:00 p.m. - TCEQ, Austin, Texas

No oraltestimony was received pertaining to this proposal. .. .
P.l

..

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 0' •

. -...... . "

PuBUC HEARING REGl8TRATION

o 0 October 29, 2008, 3:00 p.m.

Texa8 Commleelonon E~ronmental Quality, 12100 Park35 Circle, AuBtin

Rule ProJ~ No.: 2009-017-8IP-NR (AD SIP RevIsions), 2009-018-8IP-NR (RFP SIP RevIsions), 2009-008-101-EN(HECl),

200~19-101-EN(MECl), 2008-019-115-EN (ow-t Utho)

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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 

TESTIMONY 
IN"TEROFFICE MEMORANDUM

Texas Commission on Environmental Quality

To:

Thru:

From:

Docket No.:

Commissioners

LaDonna Castafiuela, ChiefClerk

Mark R. Vickery, P.G., Executive Director

Susana M. Hildebrand, P.E., CbiefEngin~

2009-080I-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 ofthe fIrst phase ofthe 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 ofthe 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 ofthe 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 ofthe 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 ofthe proposed SIP revision:

A) Summary ofwhat the SIP revision will do:

This RFP SIP revision shows reasonable further progresstoward 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 NOx reduction for 2002 through 2008. The EPA also requires demonstration of

suffIcient ozone precursor reductions (an average of 3 percent per year between each ofthe 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 Houston 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 Energy and Economic Development (SEED) Coalition, 

the United States Environmental Protection Agency (EPA), and one individual. In addition, CAIT, 

KIDS, SEED, and one individual also incorporated 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 well 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 SIP revision based on this comment. 

EMISSIONS INVENTORY 

CAIT, KIDS, SEED, and one individual commented that 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 Reasonable Further Progress plans. Please refer to 

Emissions Inventory Requirements 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 

MODELING and 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 included 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 MODELING 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 revisions were made to the HGB RFP SIP revision 

based on this comment. 

The EPA requested further description concerning how unreported volatile 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 revision, which was adopted by the commission on 

May 23, 2007 (http://www.tceq.state.tx.us/implementation/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 this RFP 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 revision should confirm that transportation control 

measures (TCMs) are not needed to offset vehicle 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 result in a growth in vehicle emissions. There is 

growth in VMT for the HGB area for the years 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 NOX for 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. 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 

RECOMMENDATIONS
REVISION 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 the1997 Eight-Hour Ozone Standard 

PROJECT NO. 2009-018-SIP-NR 

Adopted 

March 10, 2010 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

This page is intentionally left blank.
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

ES-1

EXECUTIVE SUMMARY 

The 1990 Federal Clean Air Act Amendments (FCAA), §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 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 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 emissions 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) also account for RFP corrections and non-creditable 

reductions. All of the RFP inventories are 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 (NOX) 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 NOX and 

VOC Reductions. 

This SIP revision also sets the NOX and 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 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 nonattainment 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. 
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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 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 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 the 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 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 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 inconsistent 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 measures necessary to attain and maintain the NAAQS; 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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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 Texas 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 Understanding, §§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 39.605 
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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 for 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 June 3, 2001 

Revisions Involving the Use of Economic Incentives, Marketable 

Permits, and Emissions Trading 
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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) 
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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 

NOX Nitrogen Oxides 

PFC Portable Fuel Container 

PN Percent of NOX

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 Models 
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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 Compounds
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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 Milestone Year Emissions Inventories 

2.5.5 Updated Controlled Milestone Year Emissions Inventories 

2.6 Biogenic Sources 

2.7 Emissions Summary 
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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 VMT, On-Road Emissions, and Transportation 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 

Appendices
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LIST OF APPENDICES 

Appendix Appendix 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 Mobile Source Emissions Inventories 
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LIST OF TABLES 

Number Table Name

Table 2-1 HGB Eight-County RFP Point Source NOX Emissions 

Table 2-2 HGB Eight-County RFP Point Source VOC Emissions 

Table 2-3 HGB Eight-County RFP Area Source NOX Emissions 

Table 2-4 HGB Eight-County RFP Area Source VOC Emissions 

Table 2-5 HGB Eight-County RFP Non-Road Mobile Source NOX Emissions (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 Season Weekday On-Road Mobile Source NOX

Emissions 

Table 2-9 HGB Eight-County RFP Ozone Season Weekday 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 NOX Emissions 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 NOX Emissions 

Table 2-14 HGB Eight-County RFP Uncontrolled Ozone Season Weekday VOC Emissions 

Table 2-15 HGB Eight-County RFP Controlled Ozone Season Weekday NOX Emissions 

Table 2-16 HGB Eight-County RFP Controlled Ozone Season Weekday VOC Emissions 

Table 3-1 Step by Step Summary of Calculation 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 NOX and VOC Reductions 

Table 3-4 RFP Post-2002 Target Level of NOX Emissions 

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 NOX Emission 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 RFP Controlled NOX Emissions, 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 Area 
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LIST OF FIGURES 

Number Figure Name

Figure 4-1 RFP VMT Trends 

Figure 4-2 RFP Controlled On-Road NOX and VOC Emissions Trends 
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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 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 attainment demonstration, a reasonable further 

progress (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, 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 reclassified 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 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. 

“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 contain enforceable measures to achieve the National Ambient Air 

Quality Standards (NAAQS). The 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 neither 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 revision 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. 

A summary of how this plan meets RFP requirements can be found in Appendix 1: HGB Reasonable 

Further Progress Demonstration Calculations Spreadsheet. 
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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 with this SIP revision, there are no changes that 

would require an analysis of social 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. 
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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 ozone nonattainment areas. Ozone is photochemically 

produced in the atmosphere when volatile organic compounds (VOC) are mixed with nitrogen oxides 

(NOX) in the presence of sunlight. The Texas Commission on Environmental Quality (TCEQ) 

maintains an EI of up-to-date information on NOX 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 

variety 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 established 

emissions growth and control budgets. The total inventory of VOC and NOX emissions for an area is 

summarized from the estimates developed for the five 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 NOX emissions 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 calculated for each source category using EPA-approved 

methodologies and then combined to obtain the total uncontrolled milestone year inventory for VOC 

and NOX. 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 inventory 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 NOX. 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 (TAC) §101.10. To collect the data, the TCEQ 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 also required. All data submitted in the EIQ are reviewed for quality assurance 

purposes and then stored in the State of Texas Air Reporting System (STARS) database. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

2-2 

2.2.2 Updated 2002 Base Year Inventory 

The 2002 base year inventory data were extracted from STARS on February 4, 2009. The extracted 

data contained ozone season daily emissions of NOX and VOC from each site in the HGB area that 

submitted an EIQ for 2002 and reflected 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 was used 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 shed in the future. To account for the possible use of 

these banked NOX and 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 factors 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 emissions, 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 available. The 2005 inventory was extracted from STARS 

on February 4, 2009. The extracted data were reported ozone season daily emissions of NOX and 

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 NOX controls are reflected in the Mass Emissions Cap and Trade program (MECT) 

2008 NOX cap. The MECT NOX emissions allocations account for NOX controls, 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 Areas and D: Combustion Control at Minor Sources in Ozone Nonattainment Areas. 

The controlled milestone year NOX inventories 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 NOX emissions 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 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

2-3 

equipment that are subject to the HRVOC control requirements of 30 TAC Chapter 115, Subchapter 

H, Division 1: Vent Gas Control or Division 2: Cooling Tower Heat Exchange Systems for 

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 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 Table 2-2: HGB Eight-County RFP Point Source VOC Emissions. 

Table 2-1: HGB Eight-County RFP Point Source NOX Emissions 

RFP Analysis NOX (tons per day) 

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 

RFP Analysis VOC (tons per day) 

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 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 printing operations, industrial coatings, degreasing solvents, house 

paints, leaking underground storage tanks, gasoline service station underground tank filling, and 

vehicle refueling operations. Fuel combustion sources include oil and gas production sources, 

stationary source fossil fuel combustion at residences and businesses, outdoor refuse burning, 
HGB Reasonable Further Progress SIP Revision 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 required to submit this 

inventory to the EPA as the Periodic Emissions Inventory, considerable effort went into its 

development. 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. 

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 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 contractor 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 inventories 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 emissions 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 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 NOX 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. 

 

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 Revision for the 1997 Eight-Hour Ozone Standard 

2-5 

Table 2-3: HGB Eight-County RFP Area Source NOx Emissions 

RFP Analysis NOX (tons per day) 

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 

RFP Analysis VOC (tons per day) 

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, 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. 

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 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.

 

2

 Eastern 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 Revision for the 1997 Eight-Hour Ozone Standard 

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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 with all of the default surrogates is acceptable, 

the EPA encourages 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 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 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 

emission 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. Hobby Airport. Emissions were calculated using the Federal 

Aviation Administration (FAA) Emissions and Dispersion Modeling System (EDMS), version 5.1. 

The airport emissions categories 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) 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, 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 emissions were estimated using an interpolation method between the years 2005 and 2011. 

The documentation of procedures used in developing 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 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 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 

 

3 United States Environmental Protection Agency, “Emission Factors for Locomotives,” Technical Highlights, 

EPA-420-F-97-051, December 1997. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

2-7 

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.6

 The 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 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. 

2.4.2 Updated 2002 Base Year Inventory 

Since the 2002 base year EI was originally developed 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 aircraft and GSE as well as locomotive emissions 

were obtained from the TexAER database. The 2002 base 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 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 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 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, 2008, 2011, 2014, 2017, 2018, and 2019. To evaluate 

 

4

 Starcrest 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 Revision for the 1997 Eight-Hour Ozone Standard 

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individual control measure emission reductions for the RFP requirements, a series of TexN model 

runs were executed for both controlled 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 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 NOX Emissions (Tons/Day) and Table 2-6: HGB EightCounty RFP Non-Road Mobile Source VOC Emissions (Tons/Day). Because there are no controls 

applied to airport and drilling rigs, these columns 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 Transportation, Federal Aviation Administration, “Terminal Area Forecast 

Summary, Fiscal Years 2008-2025,” FAA-APO-06-1, January 2009. 

9

 Eastern Research Group, Inc., “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07-

84003-04, August 31, 2007. 
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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 mobile source emissions are usually categorized as 

either combustion-related emissions or evaporative hydrocarbon emissions. Combustion-related 

emissions are estimated for vehicle 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 factors) and the number of units of activity must be 

determined. 

Emission factors are developed using EPA's mobile emission factor model MOBILE. The model 

may be run using national default 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, rather than national 

default values. The localized inputs 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 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 

Performance 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 speed on each roadway type or 

segment is also needed to complete an on-road emissions 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 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 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 Revision 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.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 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 requirement 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 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 NOX 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 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 

RFP Inventory Scenario (vehicle miles traveled per day) 

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

 

10 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 Revision 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 

RFP Inventory Scenario (tons per day) 

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 

RFP Inventory Scenario (tons per day) 

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, 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 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, reformulated gasoline, 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 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-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 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 toward these 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 the defeat device for heavy-duty diesel vehicles 

(HDDV) was affecting a FMVCP that was implemented prior to the 1990 FCAA, the HDDV NOX 

off-cycle emissions effects and associated mitigation program effects are also considered non-
HGB Reasonable Further Progress SIP Revision 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 summertime RVP limits, and HDDV NOX off-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 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 reflected 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 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 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. 

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 

Calendar Year VMT Emissions Reductions

NOX VOC NOX 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 NOX and 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 Weekday OnRoad Mobile Source NOx Emissions and 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 Reasonable Further Progress On-Road Mobile Source 

Emissions Inventories. 
HGB Reasonable Further Progress SIP Revision 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 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 OnRoad Mobile Source VOC Emissions and Control Strategy Reductions. 

Table 2-11: HGB RFP Ozone Season Weekday On-Road Mobile Source NOX Emissions and 

Control Strategy Reductions 

Emissions Inventory and Control NOX (tons per day)

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 

Emissions Inventory and Control VOC (tons per day)

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
HGB Reasonable Further Progress SIP Revision 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, Weekday On-Road Mobile Source NOX Emissions 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 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 NOX emissions 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 determining the overall emissions 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 NOX and 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 Emissions and 2-15: HGB Eight-County RFP Uncontrolled Ozone Season Weekday 

VOC Emissions. Controlled base and milestone year NOX and 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 NOX Emissions and 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 NOX 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 2-13: HGB Eight-County RFP Uncontrolled Ozone Season Weekday NOX Emissions 

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 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

2-15 

Table 2-14: HGB Eight-County RFP Controlled Ozone Season Weekday NOX Emissions 

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 46.68 690.47 
HGB Reasonable Further Progress SIP Revision 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 reduction 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 methodologies 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 milestone 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 or equal to the target level of 

emissions for volatile organic compounds (VOC) and/or nitrogen oxides (NOX), 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. 

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. 
HGB Reasonable Further Progress SIP Revision 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 NOX. 

3.3 CALCULATION OF TARGET EMISSIONS LEVELS 

A step by step summary of the six-step process described above for target calculations 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 

Description NOX 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 Year 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 NOX (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 development 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 NOX and 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. 

The second step of the RFP target calculation methodology 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 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 milestone 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 latest version 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 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 ABY inventories are documented in Chapter 2: EMISSIONS INVENTORIES and 
HGB Reasonable Further Progress SIP Revision 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 inventories 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: FTCMSY, VOC = ABY(MSY-1), VOC – ABYMSY, VOC

and 

Equation 3-1B: FTCMSY, NOx = ABY(MSY-1), NOx – ABYMSY, NOx

where: 

FTCMSY, VOC = VOC fleet turnover correction for year MSY 

FTCMSY, NOx = NOX fleet turnover correction for year MSY 

ABYMSY, VOC = MSY adjusted base year inventory for VOC 

ABYMSY, NOx = MSY adjusted base year inventory for NOX

ABY(MSY-1), VOC = previous MSY adjusted base year inventory for VOC 

ABY(MSY-1), NOx = previous MSY adjusted base year inventory for NOX

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 

NOX VOC NOX 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 NOX reductions for VOC reductions, but use of 

NOX emissions reductions must meet the criteria in §182(c)(2)(C) in the FCAA. For the eight HGB 

counties, an equivalent percentage of NOX reduction may be substituted for VOC reduction 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

3-4 

requirements for all RFP milestone years. The total of the percent NOX and 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 NOX emissions. Equation 3-2 describes the method to 

calculate the percentage of NOX emissions substituted for VOC emissions: 

Equation 3-2: NMSY = [3 × (CYMSY – CYMSY-1 ) ] – VMSY

where: 

NMSY = percentage NOX reductions for year MSY 

CY = calendar year 

MSY = RFP milestone year 

MSY - 1 = previous RFP milestone year 

VMSY = percentage VOC reductions for year MSY 

The VOC and NOX percentages are multiplied by the milestone year ABY inventories for VOC and 

NOX, respectively, to calculate the required VOC and NOX emission reductions for each milestone 

year. Table 3-3: Calculation of Required 3 Percent Per Year NOX and VOC Reduction provides a 

summary of the NOX and 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 

NOX are shown in Equations 3-3A and 3-3B. 

Equation 3-3A: RQVOC = [ BY2002VOC – ( ABY2002VOC – ABYMSY, VOC ) ] × PVMSY

and 

Equation 3-3B: RQNOx = [ BY2002NOx – ( ABY2002NOx – ABYMSY, NOx ) ] × PNMSY

where: 

RQVOC = required percent VOC emission reductions by 2008 

RQNOx = required percent NOX emission reductions by 2008 

BY2002VOC = 2002 base year inventory for VOC 

BY2002NOx = 2002 base year inventory for NOX

ABY2002VOC = 2002 adjusted base year inventory for VOC 

ABY2002NOx = 2002 adjusted base year inventory for NOX

ABYMSY, VOC = MSY adjusted base year inventory for VOC 

ABYMSY, NOx = MSY adjusted base year inventory for NOX

PVMSY = percentage VOC reductions for year MSY 

PNMSY = percentage NOX reductions for year MSY 

MSY = RFP milestone year 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

3-5 

Table 3-3: Calculation of Required 3 Percent Per Year NOX and VOC Reduction 

tons per day RFP 

Analysis 

Year 

Total Percent 

Reduction 

Requirement 

Percent 

NOX

Percent 

VOC ABY EI 

NOX

ABY EI 

VOC 

Required 

Reductions 

NOX

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 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 NOX and 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 calculating the target levels of emissions for the RFP milestone years is shown in 

Equation 3-4. 

Equation 3-4: TLMSY X = TL(MSY-1), X – RQMSY,X – FTCMSY, X

where: 

TLMSY, 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.) 

RQMSY, X = emission reduction requirement for MSY for pollutant X 

FTCMSY, X = fleet turnover correction term for MSY for pollutant X 

X = either VOC or NOX

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 NOX Emissions and 3-5: RFP 

Post-2002 Target Level of VOC Emissions summarize the calculation of the target levels of VOC and 

NOX for 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 Revision for the 1997 Eight-Hour Ozone Standard 

3-6 

Table 3-4: RFP Post-2002 Target Level of NOX Emissions 

tons per day 

RFP Milestone 

Year Previous 

Target 

FMVCP NonCreditable 

Reduction 

Post-2002 

Percent 

Reduction 

Requirement 

NOX

NOX Target 

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 NOX

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 between 2002 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 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 Revision for the 1997 Eight-Hour Ozone Standard 

3-7 

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 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 added 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 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 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 

2018 summarize 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 calculate 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 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 NOX 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 Yes
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

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Table 3-7: Summary of RFP Demonstration for Eight HGB Counties for 2011 

tons per day Line # Description NOX 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 NOX 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 NOX 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 Yes
HGB Reasonable Further Progress SIP Revision 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 NOX 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 Yes
HGB Reasonable Further Progress SIP Revision 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) 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 used to meet the RFP targets is presented in Tables 4-1: Summary of HGB RFP NOX

Emission Reductions and 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 tables 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 Revision for the 1997 Eight-Hour Ozone Standard 

4-2 

Table 4-1: Summary of HGB RFP NOX Emission 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 NOX standards 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 NonRoad Engines 5.76 7.91 9.64 12.02 12.56

Tier 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 NOX

emission rates. See Table 4-2 for information regarding VOC reductions 
HGB Reasonable Further Progress SIP Revision 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 NOX standards 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 NonRoad Engines 4.73 6.82 8.54 10.17 10.58

Tier 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 several 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 NOX 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. 

4.3 AREA SOURCE CONTROLS 

The only area source control in the HGB area used in this 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 Revision 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 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 calculated 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 encourages states to update the 

model with local, county-level data based on surveys 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 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 type data 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 TexN model 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 were executed for both controlled and 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 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 each 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 using data extrapolated from a contractor report 

drafted by Eastern Research Group, Inc., (ERG) and contained in the Texas Air Emissions Repository 

(TexAER) database.12 The uncontrolled emissions were developed 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 

 

12 ERG, “Tier-Specific Locomotive Engine Updated,” TCEQ Contract No. 582-07-84003-04, August 31, 2007. 

13 EPA, “Emission Factors for Locomotives,” December 1997. 14 ERG, “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 Revision 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 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 Reductions and 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 Ozone Nonattainment Area Reasonable Further Progress On-Road 

Mobile Source Emissions Inventories includes 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-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 

NOX Emission Reductions and 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 for 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 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 NOX for 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 Weekday On-Road Mobile Source 

 

16 ERG, “Emissions from Oil and Gas Production Facilities,” August 2007. 
HGB Reasonable Further Progress SIP Revision 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 Reasonable Further Progress On-Road Mobile Source 

Emissions Inventories. The control measures used to achieve the on-road mobile RFP emission 

reductions and to demonstrate RFP requirements do not include TCMs. TCMs are not needed to meet 

RFP requirements for the area and are therefore included 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 NOX Emissions, VOC Emissions, and VMT 

RFP Milestone NOX VOC VMT 

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 46.68 184,010,300 
HGB Reasonable Further Progress SIP Revision 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 Year

VMT (miles per day)

Figure 4-1: RFP VMT Trends 

0

50

100

150

200

250

300

350

2002 2008 2011 2014 2017 2018

RFP Year

Emissions (tons per day)

NOx VOC

Figure 4-2: RFP Controlled On-Road NOX and VOC Emissions Trends 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

4-8 

4.7 CONTINGENCY MEASURES 

In case of a milestone failure, contingency control 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 NOX reductions. 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 NOX and a 0.5 

percent reduction in VOC to be achieved between 2008 and 2009. The excess emission reductions 

from the RFP milestone year 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 4-5: 2009 RFP Contingency Demonstration for HGB Area 

2009 Description NOX 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 NOX and 

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 contingency requirements, so the excess emission 

reductions from the 2018 RFP demonstration are included 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, those 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 Revision for the 1997 Eight-Hour Ozone Standard 

4-9 

Table 4-6: 2019 RFP Contingency Demonstration for HGB Area 

2019 Description NOX 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 NOX Standards 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 Revision 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 (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 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 Inventories is 

a copy of the H-GAC contractor (ENVIRON International Corporation) report, which provides 

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 for 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 (NOX) and volatile organic 

compounds (VOC) and, therefore, even if the safety margin is used for a transportation conformity 

determination, the HGB area will still meet the 1997 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, even if this safety margin is used, the HGB area will 

still demonstrate RFP for each milestone. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-2 

Table 5-1: 2008 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description NOX 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 Margin1 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 emissions equaling 10 percent of 

the 2008 on-road emissions projection with post-1990 FCAA controls for each NOX and VOC is used to 

provide a safety margin for 2008. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-3 

Table 5-2: 2011 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description NOX 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 Margin1 12.34 6.83

2011 RFP Motor Vehicle Emissions Budgets 135.74 75.17

1 The 2011 RFP reductions exceed the required emissions reductions. Excess emissions equaling 10 percent of 

the 2011 on-road emissions projection with post-1990 FCAA controls for each NOX and VOC is used to 

provide a safety margin for 2011. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-4 

Table 5-3: 2014 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description NOX 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 Margin1 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 NOX and VOC is used to 

provide a safety margin for 2014. 
HGB Reasonable Further Progress SIP Revision for the 1997 Eight-Hour Ozone Standard 

5-5 

Table 5-4: 2017 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description NOX 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 Margin1 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 emissions equaling 10 percent of 

the 2017 on-road emissions projection with post-1990 FCAA controls for each NOX and VOC is used to 

provide a safety margin for 2017. 

Table 5-5: 2018 RFP Motor Vehicle Emissions Budgets for the HGB Eight-County Ozone 

Nonattainment Area 

Description NOX 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 Margin1 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 emissions equaling 10 percent of 

the 2018 on-road emissions projection with post-1990 FCAA controls for each NOX and 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 thatthe RFP emissions reduction requirement will be met for the six-year period (2003-

2008) beginning January 1 ofthe year following the year used for the baseline emissions inventory (2002) and

all remaining three-year periods after the firstsix-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 ofthe state's air

and to issue orders consistent with the policies and purposes ofthe Texas Clean Air Act, Chapter 382 ofthe Tex.

Health & Safety Code. Notice ofthe proposed SIP revision was published for comment in the October 9,2009,

issue ofthe 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 ofthe 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 ofthe 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 ofthe 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 oftestimony 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 ifset forth at length verbatim in this Order.
IT IS FURTHERORDERED 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 ofEPA as a proposed revision to the Texas SIP pursuantto the Federal CleanAir Act, codifiedat

42 U.S. CodeAnn. §§ 7401- 7671q, as amended.

If any portion of this Orderis for any reasonheld to be invalidby a court of competentjurisdiction, the

invalidity of any portion shallnot affectthe validityof the remainingportions.

Date issued: MAR 15 Z010 TEXAS COMMISSION ON

ENVIRONMENTAL QUALITY