Rhode Island Attainment Plan 

for the 8-Hour Ozone National Ambient Air Quality Standard 

Rhode Island Department of Environmental Management 

Office of Air Resources 

Posted for Public Comment: February 12, 2008 

Submitted as SIP Revision: April 30, 2008 
TABLE OF CONTENTS

Tables and Figures.......................................................................................................................... 5 

1.0 INTRODUCTION AND BACKGROUND ....................................................................... 6 

1.1 Summary and Purpose of Document .............................................................................. 6 

1.2 Ozone Formation and Health Impacts ............................................................................ 7 

1.3 1-Hour Ozone NAAQS................................................................................................... 7 

1.4 8-Hour Ozone NAAQS................................................................................................... 8 

1.5 Rhode Island’s 8-Hour Ozone NAAQS Compliance ..................................................... 9 

2.0 EMISSIONS INVENTORIES.......................................................................................... 11 

2.1 2002 Emissions Inventory............................................................................................. 11 

2.2 2008 Projected Inventory.............................................................................................. 11 

2.3 2009 Projected Inventory.............................................................................................. 12 

3.0 CONTROL MEASURES ................................................................................................. 13 

3.1 Purpose of Section ........................................................................................................ 13 

3.2 Post -2002 Emissions Reductions................................................................................. 13 

3.2.1 Control Programs in the 1-Hour Ozone Standard SIP.......................................... 14 

3.2.2 Adopted New Control Measures........................................................................... 15 

3.3 Planned Emissions Controls ........................................................................................... 18 

4.0 REASONABLE FURTHER PROGRESS ANALYSIS................................................... 21 

4.1 Purpose of Section ........................................................................................................ 21 

4.3 2002 Adjusted Base Year Inventory............................................................................. 21 

4.4 Target Level of Emissions............................................................................................ 23 

4.5 2008 Projected Emissions Inventory ............................................................................ 23 

4.6 Results of RFP Analysis............................................................................................... 23 

5.0 ATTAINMENT DEMONSTRATION............................................................................ 25 

5.1 Purpose of Section .............................................................................................................. 25 

5.2 Ozone Conceptual Model ................................................................................................... 25 

5.2.1 Conceptual Description for Ozone Episodes in Rhode Island..................................... 25 

5.2.2 Geographical Considerations....................................................................................... 25 

5.2.3 Transport...................................................................................................................... 26 

5.2.4 Primary Meteorological Regimes for Rhode Island .................................................... 26 

5.3 OTC Modeling Protocol ..................................................................................................... 29 

5.3.1 Modeling Protocol (2002)................................................................................................ 29 

5.3.2 Modeling Protocol (2006)............................................................................................ 29 

5.4 Review of 2002 Ozone Episodes........................................................................................ 29 

5.4.1 Episode Selection Criteria............................................................................................ 29 

5.4.2 Episode Selection Procedure........................................................................................ 29 

5.5 Modeling Domain ............................................................................................................... 30 

5.5.1 Description................................................................................................................... 30 

5.5.2 Horizontal Grid Size .................................................................................................... 30 

5.5.3 Number of Vertical Layers.......................................................................................... 30 

5.6 Photochemical Grid Modeling System............................................................................... 31 

5.6.1 Photochemical Grid Modeling System........................................................................ 31 

5.6.2 CMAQ Modeling System Source Codes......................................................................... 32 

5.6.2 CMAQ Modeling System Source Codes..................................................................... 32 

2
5.6.3 CMAQ Model Setup for the OTR Domain.................................................................. 33 

5.7 Meteorological Modeling System................................................................................. 33 

5.7.1 MM5 Meteorological Model................................................................................. 33 

5.7.2 MM5 Meteorological Fields........................................................................................ 33 

5.7.3 MM5 Model Performance............................................................................................ 33 

5.8 Biogenic emissions ............................................................................................................. 34 

5.8.1 BEIS Modeling System................................................................................................ 34 

5.8.2 OTR Modeling Domain Biogenic Emissions.............................................................. 35 

5.9 Boundary and Initial Conditions......................................................................................... 35 

5.9.1 Generation of Boundary Conditions............................................................................ 35 

5.9.2 OTR Modeling Domain Boundary Conditions............................................................ 35 

5.10 CMAQ Emission Files for 2002 ....................................................................................... 35 

5.10.1 Regional Planning Organization Annual Emission Inventories for 2002.................. 35 

5.10.2 MANE-VU Annual Emission Inventory for 2002..................................................... 36 

5.10.3 Emission files for the OTR Domain .......................................................................... 38 

5.11 New OTR Control Measures for 2009.............................................................................. 39 

5.11.1 Potential Beyond On the Way (BOTW) Control Measures....................................... 39 

5.11.2 Final OTC Beyond On the Way (BOTW) Control Measures.................................... 39 

5.12 CMAQ Emission Files for 2009 with OTC BOTW Control Measures............................ 40 

5.12.1 Regional Planning Organization Annual Emission Inventories for 2009.................. 40 

5.12.2 MANEVU Annual Emission Inventory with BOTW Control Measures for 2009.... 41 

5.13 Quality Assurance of CMAQ Databases .......................................................................... 43 

5.14 CMAQ Model Simulation for 2002 Base Case ................................................................ 44 

5.14.1 CMAQ Model 2002 Application ............................................................................... 44 

5.14.2 CMAQ Input Files for 2002....................................................................................... 44 

5.14.3 CMAQ Output Files................................................................................................... 45 

5.15 Performance Evaluation of 2002 Simulation.................................................................... 45 

5.15.1 NY DEC Performance Evaluation for OTR Modeling Domain................................ 45 

5.15.2 CMAQ Spatial Performance in New England States ................................................ 45 

5.15.3 CMAQ Selected Model Metrics for New England States ......................................... 49 

5.16 CMAQ Model Simulation for 2009 Control Strategy ...................................................... 52 

5.16.1 CMAQ Model 2009 Application ............................................................................... 52 

5.16.2 CMAQ Input Files for 2009....................................................................................... 52 

5.16.3 CMAQ Output Files................................................................................................... 52 

5.17 Predicted Design Values for 2009 .................................................................................... 53 

5.17.1 Design Values for 2002 Base Case............................................................................ 53 

5.18 Estimating Design Values at Unmonitored Locations...................................................... 56 

5.18.1 Rhode Island Ozone Monitoring Network................................................................. 56 

5.18.2 Future Year Design Values at Unmonitored Locations............................................. 57 

5.19 Weight of Evidence................................................................................................... 57 

5.19.1 Air Quality Trends................................................................................................ 57 

5.19.3 Extra Ozone Reductions ............................................................................................ 59 

5.20 Conclusions....................................................................................................................... 59 

6.0 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ......................... 61 

6.1 Purpose of Section ........................................................................................................ 61 

6.2 1-Hour Ozone Standard RACT.................................................................................. 61 

3
6.2.1 Pre-1990 VOC RACT Requirements................................................................. 61 

6.2.2 1990 CAA Amendments (CAAA)........................................................................ 62 

6.2.3 Rhode Island 1-Hour RACT Compliance............................................................. 62 

6.3 8-Hour Ozone Standard RACT Requirements ............................................................. 63 

6.3.1 Required Analysis................................................................................................. 63 

6.4 VOC RACT Analysis ................................................................................................... 64 

6.4.1 CTGs..................................................................................................................... 64 

6.4.2 New CTGs ................................................................................................................ 65 

6.4.3 Non-CTG Major VOC Sources ............................................................................ 66 

6.5 NOx RACT Analysis.................................................................................................... 66 

6.6 RACT Revisions........................................................................................................... 67 

6.6.1 Solvent Degreasing ............................................................................................... 67 

6.6.2 Asphalt Paving...................................................................................................... 68 

6.6 Conclusions................................................................................................................... 69 

7.0 REASONABLY AVAILABLE CONTROL MEASURES (RACM).............................. 79 

7.1 Purpose of Section ........................................................................................................ 79 

7.4 Point and Nonpoint Source RACM Analysis for Rhode Island ...................................... 81 

7.5 Mobile Source RACM Analysis for Rhode Island .......................................................... 84 

7.6 Overall RACM Conclusions.............................................................................................. 85 

8.0 CONTINGENCY MEASURES .......................................................................................... 86 

8.1 Purpose of Section ............................................................................................................ 86 

8.3 RFP Contingency............................................................................................................... 86 

8.4 Attainment Contingency .................................................................................................. 87 

8.5 Conclusions................................................................................................................... 88 

9.0 TRANSPORTATION CONFORMITY .......................................................................... 89 

9.1 Purpose of Section ........................................................................................................ 89 

9.2 Background................................................................................................................... 89 

9.3 Methodology................................................................................................................. 90 

9.4 Mobile Source Budgets................................................................................................. 90 

4
Tables and Figures 

Table 2-1 Rhode Island Anthropogenic Ozone Precursor Emissions............................................. 12 

Table 3-1 Control Measures in the Rhode Island 1-Hour Ozone Standard Attainment 

Demonstration SIP........................................................................................................................ 14 

Table 3-2 RI DEM Control Technology Regulatory Action Commitments......................... 20 

Table 4-1 Rhode Island Base Year and Adjusted Base Year Emissions (tpsd) .............................. 22 

Table 4-2 RFP Calculations.................................................................................................... 24 

Figure 5-1: July 2, 2002 Ozone and Isobar Maps........................................................................... 27 

Figure 5-2: August 12, 2002 Ozone and Isobar Maps.................................................................. 28 

Table 5-1 Rhode Island Ozone Concentrations on 8-Hour Exceedance Days in 2002 (ppb).......... 28 

Figure 5-3: OTR Photochemical Grid Modeling Domain (Eastern Modeling Domain).............. 31 

Figure 5-4: Regional Haze Regional planning Organizations (RPOs)......................................... 32 

Figure 5-5: MM5 Modeling Domains (36 km and 12 km ............................................................ 34 

Table 5-2: MANE-VU 2002 Anthropogenic Emissions (Tons/Year ........................................... 36 

Table 5-3 Comparison of RIDEM and MARAMA 2002 Emissions Inventory for Rhode Island 

(tons per year)............................................................................................................................... 37 

Table 5-3A Status of Adoption of Rhode Island BOTW Control Measures.................................. 41 

Table 5-4: MANE-VU 2009 Anthropogenic Emissions with BOTW Controls (Tons/Yr).......... 42 

Figure 5-6: Maximum 8-Hour Values on August 8, 2002............................................................ 46 

Figure 5-7: Maximum 8-Hour Values on August 8, 2002............................................................ 47 

Figure 5-8: Maximum 8-Hour Values on June 21, 2002.............................................................. 47 

Figure 5-9: Maximum 8-Hour Values on July 18, 2002............................................................... 48 

Figure 5-10: Hourly Ozone Values for 2002 Ozone Season ........................................................ 48 

Table 5-5: Mean Normalized Gross Error and Mean Normalized Bias for RI Ozone Monitors...... 49 

Table 5-6: Mean Normalized Gross Error and Mean Normalized Bias for Other New England 

Ozone Monitors ............................................................................................................................ 50 

Table 5-7: 2009 Design Values (DVF) in Rhode Island for 2009 BOTW Emission Scenario .... 54 

Table 5-8: 2009 Design Values (DVF) in Massachusetts for 2009 BOTW Emission Scenario .. 54 

Table 5-9: 2009 Design Values (DVF) in New Hampshire for 2009 BOTW Emission Scenario 55 

Table 5-10: 2009 Design Values (DVF) in Connecticut for 2009 BOTW Emission Scenario .... 55 

Table 5-11: 2009 Design Values (DVF) in Maine for 2009 BOTW Emission Scenario ............. 56 

Table 5-12: 2009 Design Values (DVF) in Vermont for 2009 BOTW Emission Scenario ......... 56 

Figure 5-11: Design Value Trends for Rhode Island.................................................................... 58 

Table 5-13: MANE-VU Anthropogenic Emissions for 2002 and 2009 ....................................... 59 

Table 6-1 RI DEM 1-hour Ozone Standard RACT Regulations and 8-Hour Ozone Standard RACT 

Certification................................................................................................................................... 70 

Table 6-2 RI DEM Single Source 1-Hour Ozone Standard RACT Determinations and 8-Hour 

Ozone Standard RACT Certification............................................................................................ 77 

Table 7-1 OTC Recommended Control Measures and RI RACM Analysis ........................ 82 

Table 7-2 CMAQ Program Projects in 2006-2007 Transportation Implementation Plan.......... 85 

Table 9-1 2007 Emissions Budget, Projected 2008 and 2009 Inventory and Requested 2008 and 

2009 Emissions Budgets (tons per summer day)......................................................................... 90 

5
1.0 INTRODUCTION AND BACKGROUND 

1.1 Summary and Purpose of Document 

The Rhode Island Department of Environmental Management (RI DEM) is submitting this 

document, the “State Implementation Plan (SIP) to Demonstrate Attainment of the Eight-Hour 

National Ambient Air Quality Standard for Ozone in the Rhode Island Nonattainment Area” to 

the U.S. Environmental Protection Agency (EPA) to demonstrate that the Rhode Island 

nonattainment area, which is the entire State of Rhode Island, will be in attainment of the eighthour National Ambient Air Quality Standard (NAAQS) for ozone by the end of the 2009 ozone 

season. This document also demonstrates that, by 2008, Rhode Island will achieve the 

Reasonable Further Progress (RFP) goals that are prescribed by the Clean Air Act (CAA) and 

subsequent EPA guidance. 

. 

This submission includes the following: 

• Rhode Island 2002 Emissions Inventory, which quantifies emissions of ozone precursors and 

other air pollutants in Rhode Island in 2002, consistent with CAA requirements for the 

development of periodic emissions inventories. The 2002 inventory served as the base year 

for the attainment demonstration and RFP analysis and was used to develop projected 

emissions estimates for 2008 and 2009 for use in those analyses. 

• The RFP demonstration, which demonstrates that ozone precursor emissions in Rhode Island 

will be reduced by 15% in 2008 from 2002 baseline levels, as required by the CAA. 

• A demonstration that Rhode Island sources are subject to emissions limitations consistent 

with the Reasonably Available Control Technology (RACT) requirements in the CAA. 

• The attainment demonstration, which shows that Rhode Island will attain the 8-hour ozone 

NAAQS by the end of the 2009 ozone season 

• An analysis consistent with EPA’s Reasonable Available Control Measure (RACM) 

guidance that demonstrates that there are no additional reasonably available control 

requirements that could be adopted that would result in earlier attainment of the 8-hour 

NAAQS in Rhode Island. 

• A demonstration that Rhode Island has contingency measures in place that will result in 

additional reductions in ozone precursor emissions if Rhode Island fails to meet its RFP or 

attainment requirements. 

• On-road mobile source Transportation Conformity Budgets for Rhode Island for the 2008 

RFP year and for the 2009 attainment demonstration year. 

6
1.2 Ozone Formation and Health Impacts 

Ground level ozone is formed when oxides of nitrogen (NOx), volatile organic compounds 

(VOCs) and, to a lesser extent, carbon monoxide (CO) interact in the atmosphere in the presence 

of sunlight and elevated temperatures. NOx and VOCs, the primary ozone precursors, are 

emitted from many types of sources, including power plants, boilers, automobiles and the use of 

consumer and industrial products. VOCs are also emitted from vegetation. Because airborne 

VOCs and NOx, as well as ozone itself, are transported over long distances, sources emitting 

ozone precursors in states upwind of Rhode Island contribute to ground level ozone levels in the 

State. Ozone levels in Rhode Island generally are highest on hot sunny summer days when the 

winds are from the west or southwest. Variations in annual weather patterns contribute to yearto-year differences in ozone concentrations. 

Exposure to elevated ozone levels causes eye, nose and throat irritation; coughing; chest pain; 

shortness of breath; decreased lung function; headache; and fatigue. Repeated exposures can 

increase susceptibility to respiratory infection and lung inflammation and can aggravate 

preexisting respiratory diseases, such as asthma. Long-term exposures can cause irreversible 

changes in the lungs, leading to chronic respiratory illnesses such as emphysema and chronic 

bronchitis and to premature aging of the lungs. 

Children are at a particularly high risk for ozone-related health effects because they have 

developing lungs and are frequently active outside during the summertime when ozone levels are 

at their highest. Adults who work or exercise outside and people with respiratory and heart 

diseases are also at an increased risk. Elevated ozone levels also reduce agricultural and 

commercial forest yields; reduce the growth and survivability rates of tree seedlings; increase 

tree and plant susceptibility to disease, pests and other environmental stresses; and have longterm effects on forests and ecosystems. 

1.3 1-Hour Ozone NAAQS 

In 1979, EPA adopted a NAAQS for ozone of 0.12 parts per million (ppm) averaged over a 1-

hour period (the 1-hour ozone standard). Nonattainment areas were required to attain the 

standard by 1987. Rhode Island was in violation of that NAAQS and, as required by the CAA 

and EPA regulations, adopted regulations and programs to reduce emissions of ozone-precursors. 

Despite significant improvement in measured ozone levels, Rhode Island, along with many other 

areas in the northeast, continued to violate the 1-hour ozone standard throughout the 1980s. 

The 1990 CAA Amendments (CAAA) required EPA to classify the severity of ozone 

nonattainment areas and imposed additional control requirements on areas that had not attained 

the 1-hour ozone NAAQS. EPA classified the Rhode Island nonattainment area, which is the 

entire State of Rhode Island, as a serious nonattainment area for the 1-hour standard. In March 

2003, RI DEM submitted an attainment demonstration showing that Rhode Island had adopted 

all emissions reductions measures required by the CAAA and would attain the 1-hour ozone 

7
NAAQS by 2007. In December 2004, RI DEM submitted a Mid-Course Review analysis 

demonstrating that Rhode Island continued to be on track to attain the 1-hour standard by 2007. 

Rhode Island has been in monitored attainment of the 1-hour NAAQS since 20041

. However, on 

June 15, 2005, EPA revoked the 1-hour standard as part of its implementation of a new ozone 

NAAQS, the 8-hour ozone standard. Therefore, the 1-hour ozone NAAQS is no longer 

applicable. 

1.4 8-Hour Ozone NAAQS 

In 1997, based on evidence that exposures to ozone concentrations below the 1-hour NAAQS 

can cause adverse health effects, the EPA issued a new ozone standard of 0.08 ppm averaged 

over eight hours (the 8-hour ozone standard).2 Legal challenges ensued but, in 2001, the U.S. 

Supreme Court upheld the standard and implementation of the 8-hour ozone NAAQS began. In 

2004, EPA designated every county in the United States as attainment, non-attainment or 

unclassifiable and classified 8-hour ozone standard nonattainment areas according to the severity 

of their ozone violations. Rhode Island was classified as moderate non-attainment area under the 

8-hour standard, based on monitored ozone readings for the 2001 – 2003 period. (69 FR 23858, 

April 30, 2004) 

EPA promulgated implementation rules for the 8-hour ozone standard in two phases; Phase 1 

was promulgated on April 30, 20043

 and Phase 2 was promulgated on November 29, 2005.4 The 

Phase I Rule delineates procedures for classification of nonattainment areas and transitioning 

from the 1-hour to the 8-hour ozone standard. The Phase 2 Rule requires that moderate 

nonattainment areas, like Rhode Island, submit revisions to their State Implementation Plans 

(SIPs) to EPA by June 15, 2007 demonstrating that the area will attain the 8-hour standard by the 

end of the 2009 ozone season (the year prior to the June 15, 2010 attainment deadline) and will 

reduce ozone precursor emissions by at least 15% by 2008 in order to meet Reasonable Further 

Progress (RFP) requirements. The Phase 2 rule also requires that nonattainment areas submit a 

SIP addressing 8-hour ozone RACT requirements. 

The SIP for moderate nonattainment areas must include the elements listed below. This SIP 

submittal addresses all of the required elements in the Sections noted. 

 

1

 The 1-hour ozone NAAQS was violated when l-hour concentrations of 0.125 ppm were measured at a 

monitor in the area on 4 or more days in a three year period. The last year 3-year period in which more 

than 3 1-hour exceedances days occurred was 2001 – 2003. 

2

 The 8-hour ozone standard is met when the 3-year average of the 4th-highest daily maximum 8-hour 

average does not exceed 0.08 parts per million (ppm) at any one monitor (effectively, 0.084 ppm, given 

accepted rounding conventions). 

3

 “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard - Phase 1,” 69 FR 

23951 April 30, 2004. 

4

 “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard – Phase 2”, 70 FR 

71612, November 29, 2005. 

8
• Reasonable Further Progress demonstration of a 15% reduction in in-state VOC and/or 

NOx emissions within 6 years after the baseline year of 2002 (i.e., by 2008). (Section 4) 

• Attainment demonstration that uses modeling and other technical analyses to demonstrate 

that attainment of the 8-hour NAAQS is projected by the end of the 2009 ozone season. 

(Section 5) 

• Reasonably Available Control Technology (RACT) for RACT source sectors and for 

major sources of VOC and NOx . (Section 6) 

• Reasonably available control measures (RACM) for all sources. (Section 7) 

• Contingency measures to be implemented upon failure to meet RFP or attainment 

milestones. (Section 8) 

• Transportation conformity budgets for RFP milestone and attainment years. (Section 9) 

• Inspection and Maintenance (I/M) program for light-duty motor vehicles. (Adopted in 

Rhode Island under the 1-hour ozone standard; see Table 3-1) 

• Stage II vapor recovery for gas stations. (Adopted in Rhode Island under the 1-hour 

ozone standard; see Table 3-1) 

• New Source Review (NSR) program for major sources, including offsets for VOC and 

NOx at a 1.15 to 1 ratio and a permit program for new or modified sources. (Adopted in 

Rhode Island under the 1-hour ozone standard; see Table 3-1) 

In December 2006, the U.S. Court of Appeals for the D.C. Circuit issued a ruling vacating EPA’s 

Phase 1 rule, holding that parts of the rule violated provisions of the CAAA. On June 8, 2007, 

the Court clarified its decision stating that it was vacating only parts of the rule, while leaving 

other sections in effect. It urged EPA to promptly promulgate a revised rule. It is unclear how the 

future resolution of this litigation may impact 8-hour ozone SIP requirements. This SIP is based 

on the requirements of the published EPA rule that remain in effect and a memo from EPA 

concerning the implications of the June 15, 2007 opinion of the court.5

 Revisions to this SIP may 

be required upon resolution of the litigation and/or promulgation by EPA of a revised 

implementation rule. 

1.5 Rhode Island’s 8-Hour Ozone NAAQS Compliance 

In Section 5, Attainment Demonstration, RI DEM has demonstrated through modeling that 

Rhode Island will attain the 8-hour ozone standard in 2009. The modeling predicts that ozone 

concentrations will be below the attainment cutoff of 0.085 ppm at all Rhode Island monitors in 

2009 (see Section 5, Table 5-6). In fact, since the 2009 design values for all of the Rhode Island 

monitors are below 0.082 ppm, RI DEM is not required to submit a detailed weight of evidence 

demonstration, but is submitting a basic supplemental analysis to confirm the conclusion from 

the modeling that the State will be in attainment by 20096

. RI DEM has provided that support 

evidence in Section 5. 

 

5

 U.S. EPA, Memorandum from Robert J. Meyers, Acting Assistant Administrator, June 15, 2007, 

“Decision of the U.S. Court of Appeals for the District of Columbia Circuit on our Petition for Rehearing 

of the Phase 1 Rule to Implement the 8-Hour Ozone NAAQS”. 6

 U.S. EPA, “Guidance on the Use of Models and Other Analyses in Attainment Demonstrations for the 

8-hour Ozone NAAQS.” 

9
In addition to demonstrating attainment in the attainment year through modeling, the actual 

monitored design value for ozone must meet the standard in the attainment year. Rhode Island is 

on track to achieving monitored attainment by 2009; design values for the most recent 3-year 

period (2005-2007) were 0.084 ppm, slightly below the NAAQS, at the Narragansett and East 

Providence sites and 0.085 ppm, slightly above the standard, at the West Greenwich site. While 

year to year ozone concentrations are influenced by meteorological conditions, it is likely that 

concentrations will continue to drop and that attainment will be achieved by 2009, given the 

substantial emissions reductions that will take place in Rhode Island and upwind states during 

that period. 

10
2.0 EMISSIONS INVENTORIES 

2.1 2002 Emissions Inventory 

EPA’s Consolidated Emissions Reporting Rule (CERR) requires states to inventory air pollution 

emissions within their borders every three years. The emissions inventory for 2002 is 

particularly important; because the EPA has designated 2002 as the base year for attainment 

demonstrations and RFP calculations for the 8-hour ozone NAAQS and the NAAQS for 

particulate matter smaller than 2.5 microns (PM2.5). The “Rhode Island 2002 Emissions 

Inventory”, which is attached as Appendix 2A of this document, satisfies this requirement for the 

Rhode Island nonattainment area. 

The inventory includes emissions from stationary point, stationary nonpoint, on-road mobile and 

non-road mobile sources and covers all areas of Rhode Island, since the entire State is a 

nonattainment area for ozone. Because high ozone concentrations are generally associated with 

warmer weather and emissions may vary seasonally, the inventory includes emissions estimates 

of VOCs, NOx, and CO for a typical summer day, as well as on an annual basis. The inventory 

document describes methods used for data collection, calculation of emissions and quality 

assurance/quality control in the preparation of the inventory. RI DEM submitted a draft of the 

2002 inventory to EPA Region I for comment in December 2006. The attached version of this 

document incorporates comments received from EPA on the draft in February 2007 

2.2 2008 Projected Inventory 

Nonattainment areas must also estimate emissions in future milestone years. Moderate 

nonattainment areas like Rhode Island must develop a projected emissions inventory for 2008 in 

order to show, in the RFP, that emissions in the area will decrease by 15% between the base 

year, 2002, and the RFP milestone year, 2008. 

Growth factors from the Emissions Growth Analysis System (EGAS) were used to calculate 

projected 2008 emissions for stationary point and nonpoint sources from the 2002 base year 

inventory. The EGAS configurations used were Default REMI 6.0 SCC for nonpoint sources 

and Default REMI 5.5 SIC for point sources. Emissions from point sources that permanently 

ceased operations between 2002 and 2008 were recorded as zero in the projected 2008 inventory, 

consistent with EPA guidance. Point and nonpoint growth factors and 2002 and 2008 emissions 

are attached as Appendix 2B. 

2008 emissions from non-road mobile sources were calculated using the same methodology as 

that used to derive the 2002 estimates. Nonpoint 2002 and 2008 emissions and growth factors 

used for commercial vessels and locomotive are shown in Appendix 2C. 

On-road mobile source emissions factors were generated from EPA’s MOBILE model, version 

6.2. Model inputs reflect air quality programs in effect in Rhode Island in 2008 and the latest 

registration distribution. Vehicle Miles Traveled (VMT) data were generated by the Travel 

Demand Model (TDM), which utilizes the most recent highway performance monitoring 

11
(HPMS) data, roadway network information, current planning assumptions, seasonal adjustment 

factors, peak/off-peak period speed characteristics and 2000 census land use data The VMT 

generated by the TDM were then multiplied by the Mobile 6.2 emission factors by speed and 

roadway type, adjusted for seasonality and aggregated by functional class to calculate typical 

summer day emission for each pollutant for 2008. MOBILE and TDM inputs and outputs and 

emissions calculations are included in Appendix 2D. 

2.3 2009 Projected Inventory 

Projected emissions for the year for which attainment must be demonstrated, which is 2009 for 

moderate areas like Rhode Island, are needed as inputs to the models used to demonstrate 

attainment. A discussion of how 2002 emissions were projected to 2009 for the modeling 

inventory is included in Section 5, “Attainment Demonstration” of this document. The 2009 

projections were calculated regionally and the methodology used was not the same for all source 

categories as that used for the 2008 inventory. 

A 2009 on-road mobile source inventory was developed using the same methodology as that used 

for the 2008 on-road inventory. The 2008 and 2009 on-road mobile source inventories will be used 

as budgets for transportation conformity analyses. 

2.4 Emissions Inventory Trends 

Table 2-1 shows 2002 and 2008 anthropogenic emissions inventories by source type for Rhode 

Island, in tons per summer day. 

Table 2-1 Rhode Island Anthropogenic Ozone Precursor Emissions 

in tons per summer day (tpsd) 

SOURCE TYPE 2002 VOC 2008 VOC 2002 NOx 2008 NOx 

Stationary Point 10.3 11.0 7.0 7.3 

Stationary Nonpoint 47.9 56.8 3.4 3.7 

Non-road Mobile 26.8 21.0 19.7 16.0 

On-road Mobile7 32.3 24.6 42.4 28.3 

Total 117.3 113.5 72.5 55.3 

Projected 2008 emissions are 3% lower than those in 2002 for VOC and 24% lower for NOx. 

Most of the projected emissions reductions are associated with the non-road and on-road mobile 

source sectors. Emissions reductions are discussed further in the RFP analysis in Section 4 of 

this document. 

 

7

 At the request of the Rhode Island Department of Administration, Statewide Planning Program, which is the 

Metropolitan Planning Organization for Rhode Island, the 2008 mobile source inventories for VOC and NOx listed 

above are actually 0.5 tpsd higher than those calculated. See Section 9, “Transportation Conformity.” 

12
3.0 CONTROL MEASURES 

3.1 Purpose of Section 

This section identifies and briefly describes the Rhode Island and federal control measures that 

will result in reductions of VOCs and/or NOx emissions from Rhode Island sources by 2008, for 

purposes of demonstrating Reasonable Further Progress (RFP) towards attainment (see Section 

4,”Reasonable Further Progress”), and by 2009, for purposes of demonstrating attainment of the 

ozone standard (see Section 5, “Attainment Demonstration”). Some of the measures delineated 

have already been promulgated. For other measures, RI DEM is committing to adopt regulations 

according to the schedule included in this section. This section also provides background for the 

discussions in Section 6, “RACT” and Section 7, “RACM.” 

3.2 Post -2002 Emissions Reductions 

For the RFP analysis, Rhode Island is allowed to take credit for reductions of VOC and NOx 

emissions that will take place in the State between the 2002 base year and the 2008 target year 

for the RFP. Reductions that occur by 2009 are relevant for the attainment demonstration, 

Reductions may be from state or federal control measures that are not yet in place, provided that 

the reductions from such measures will be take place after 2002, but before the years by which 

RFP and attainment must be demonstrated. 

Air quality in Rhode Island is significantly impacted by the transport of emissions from upwind 

states. Therefore, significant reductions the emissions of ozone precursors in upwind states are 

essential to Rhode Island’s ability to attain the ozone standard, as discussed in Section 5, 

“Attainment Demonstration.” For the RFP, however, Rhode Island can only take credit for 

emissions reductions that occur within the State 

In May 2005, the EPA promulgated the Clean Air Interstate Transport Rule (CAIR) (70 FR 

25162), which established a cap and trade program to reduce emissions of NOx and SO2, 

primarily from electric generating units. The rule applied to 28 states and the District of 

Columbia, which had been identified, through modeling, as contributing significantly to poor air 

quality in downwind areas that were in nonattainment of the 8-hour ozone or fine particulate 

(PM2.5) NAAQS. NOx budgets set by this rule will be effective beginning in 2009. Although 

Rhode Island is not a CAIR state, emissions reductions from upwind states associated with this 

program will benefit air quality in the State. 

In addition to CAIR, a number of other regulatory programs, discussed below, will result in 

emissions reductions between 2002 and 2009/2010. However, in 2004, the Ozone Transport 

Commission (OTC)8

 recognized that some states would not be able to attain the 8-hour ozone 

standard without more reductions than will be achieved under CAIR and other state and federal 

control measures expected to be in place by the 2009 attainment year. The OTC compiled a set 

 

8

 The Ozone Transport Commission comprises Connecticut, Delaware, the District of Columbia, Maine, Maryland, 

Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and northern 

Virginia. The OTC was created under the CAAA to address ozone transport issues within the Ozone Transport 

Region. 

13
of recommended additional control measures that could be adopted by states to yield additional 

emissions reductions.9

 A list of these measures is included in Section 7 as Table 7-1. The OTC 

went through a similar process under the 1-hour ozone standard and, in 2001, recommended new 

controls to help member states attain the 1-hour ozone standard. As part of its 8-hour ozone 

attainment strategy, RI DEM is adopting a number of OTC recommended control measures, as 

discussed below. 

3.2.1 Control Programs in the 1-Hour Ozone Standard SIP 

The control measures adopted in Rhode Island under the 1-hour ozone standard attainment 

demonstration SIP are listed in Table 3-1. A large part of the emissions reductions associated 

with those control measures occurred prior to 2002 and are therefore reflected in the Rhode 

Island 2002 Base Year Inventory. However, some of the mobile sources emissions control 

programs adopted for the 1-hour SIP, such as the federal emissions limits on certain types of 

non-road engines, continue to generate additional emissions reductions as older equipment and 

vehicles are replaced by lower-emitting, newer models and as phased-in emissions limits tighten. 

Those reductions are reflected in the RFP analysis. 

Table 3-1 Control Measures in the Rhode Island 1-Hour Ozone Standard Attainment 

Demonstration SIP 

Name of Control Measure Type of Measure Approval Status 

On-board Refueling Vapor 

Recovery Federal rule Promulgated at 40 CFR 86 

Federal Motor Vehicle 

Control program (Tier 0) 

Federal rule Promulgated at 40 CFR 86 

(pre-1990) 

National Low Emission 

Vehicle (NLEV) 

Federal voluntary rule, 

State opt-in 

Federal rule promulgated at 40 CFR 86 

State commitment to program SIP 

approved (65 FR 12480 ; 3/9/00) 

Heavy Duty Diesel Engines 

(On-road) 

Federal rule Promulgated at 40 CFR 86 

Federal Non-road Heavy 

Duty diesel engines 

Federal rule Promulgated at 40 CFR 89 

Federal Non-road Gasoline 

Engines 

Federal rule Promulgated at 40 CFR 90 

Federal Marine Engines Federal rule Promulgated at 40 CFR 91 

Rail Road Locomotive 

Controls 

Federal rule Promulgated at 40 CFR 92 

AIM Surface Coatings State Initiative 

Contingency Regulation 

SIP approved (61 FR 55903; 10/30/96) 

 

9

 The OTC regional 8-hour ozone planning process is discussed in greater detail in Section 5, “Attainment 

Demonstration” and Section 7, “Reasonably Available Control Measures”. 

14
Name of Control Measure Type of Measure Approval Status 

Consumer & commercial 

products 

State Initiative 

Contingency Regulation 

SIP approved (61 FR 55903; 10/30/96) 

Automotive Refinishing State InitiativeRegulation No. 30 SIP approved (61 FR 3827; 2/2/96) 

Enhanced Motor Vehicle 

Inspection 

CAA SIP requirementDMV Regulation No. 1 SIP approved (66 FR 9663; 2/9/01) 

NOx RACT CAA SIP requirementRegulation No. 27 SIP approved (62 FR 46202; 9/2/97) 

VOC RACT pursuant to 

sections 182(a)(2)(A) and 

182(b)(2)(B) of CAA 

CAA SIP requirement SIP approved (59 FR 52429;10/18/94)

VOC RACT pursuant to 

section 182(b)(2)(A) and 

(C) of CAA 

CAA SIP requirement Partially SIP Approved (64 FR 67500, 

12/2/99). EPA approval pending for 

certain non-CTG RACT determinations. 

Marine Vessel SIP Approved (61 FR 

14975, 4/4/96) 

Stage II Vapor Recovery CAA SIP requirement SIP Approved (58 FR 65933; 12/17/93) 

Reformulated Gasoline State opt-in SIP approved (65 FR 12476, 3/9/00) 

Clean Fuel Fleets CAA SIP requirement SIP approved (65 FR 12476, 3/9/00) 

Rhode Island used RFG reductions to 

meet the Clean Fuel Fleet requirement. 

OTC NOx MOU Phase II State initiative 

regulation 

SIP approved (64 FR 29567; 6/2/99) 

NOx SIP Call EPA requirement SIP approved (65 FR 81748, 12/27/00) 

New Source Review EPA requirement SIP approved (64 FR 67495, 12/2/99) 

3.2.2 Adopted New Control Measures 

As discussed above, EPA’s CAIR rule is expected to result in emissions reductions in states 

upwind of Rhode Island by 2009, but will not affect emissions from Rhode Island sources. A 

discussion of Federal and State emissions controls programs that have been promulgated since 

the 1-hour SIP was prepared and that will result in emissions reductions in Rhode Island between 

2002 and 2009/2010 follows. 

3.2.2.1 Federal On-Road Mobile Source Control Measures 

The EPA adopted Tier 2 Vehicle and Gasoline Sulfur Program in 2003 which set stricter tailpipe 

emission standards (Tier 2) for all new passenger vehicles, including cars, sport utility vehicles, 

minivans, vans, and pick-up trucks and which reduce the limits on sulfur content in gasoline over 

15
a 2004-2007 phase-in periods. The Tier 2 vehicle standards do not apply in Rhode Island, which 

has adopted the stricter California Low Emission Vehicle Program tailpipe standards discussed 

below. However, the low sulfur fuel requirements will reduce post-2002 motor vehicle emissions 

in the State. 

Federal Heavy-Duty Engine and Fuel Standards promulgated in 2000 set more stringent NOx 

and hydrocarbon (HC) emission standards for heavy-duty diesel engines and vehicles starting 

with the 2004 vehicle model year and for heavy-duty gasoline engines and vehicles starting with 

the 2005 vehicle model year. The rules also requires that certain heavy-duty vehicles (HDVs) be 

equipped with on-board gasoline vapor recovery systems phased-in over 2004 – 2006 model year 

vehicles. 

In 2001, EPA published a second phase of heavy-duty motor vehicle and fuel emission 

standards. The rule requires additional, significant reductions of NOx and HC (as well as 

particulate matter) emissions from heavy-duty engines and vehicles, beginning with vehicle 

model year 2007. It also requires lowering the sulfur content of diesel fuel to 15 parts per 

million (ppm) from previous levels of 500 ppm, beginning in 2006. 

3.2.2.2 Rhode Island On-Road Mobile Source Control Measures 

In June 1996, RI DEM Adopted APC Regulation No. 37, “Rhode Island’s Low Emissions 

Vehicle Program,” which requires adherence to EPA’s National Low Emissions Vehicles 

(NLEV) program in Rhode Island for passenger cars and light duty trucks beginning with model 

year 1999. In December 2005, RI DEM modified Regulation No. 37, to require the more 

stringent California Low Emission Vehicle (CAL-LEV) standards for passenger cars and light 

duty trucks beginning with model year 2008 and for medium duty trucks with model year 2009. 

The Rhode Island program includes 1) the California fleet-wide emission average for nonmethane organic gases (NMOG); 2) the second generation of California emission standards 

known as “LEV II”; 3) the LEV I & II emission standards for medium-duty vehicles (including 

diesel vehicles and engines); and 4) Zero Emissions Vehicles (ZEV) specifications. This 

program will provide control benefits in 2009 estimated at 0.2% additional reductions of NOx 

and VOC as compared to those that would be realized from the NLEV program. Reductions will 

be more substantial in later years (additional reductions of 0.6% NOx and 0.9% VOC in 2012 

and 5.2% NOx and 6.6% VOC in 2020, as compared to NLEV).10

3.2.2.3 Federal Non-Road Mobile Source Control Measures 

EPA has adopted national regulations that impose emission and fuel standards on new non-road 

engines. The regulations establish four tiers of emission standards for new non-road diesel 

engines. Tier 1 emission standards were issued in 1994 for most large (greater than 50 

horsepower (hp)), land-based non-road diesel engines used in agricultural and construction 

equipment. These were phased-in between 1996 and 2000. In 1998, EPA promulgated Tier 1 

standards for smaller (< 50 hp) diesel engines, which were phased-in between 1999 and 2000. At 

that time, EPA also issued more stringent Tier 2 emission standards for all non-road diesel 

 

10 Calculations by Cambridge Systematics, April 9, 2004. 

16
engine sizes, with a 2001- 2006 phase-in, and Tier 3 standards for new diesel engines between 50 

and 750 hp, with a 2006 - 2008 phase-in. 

In 2004, EPA promulgated regulations that integrate new non-road diesel engine emission 

standards (Tier 4 standards) with requirements to decrease the allowable levels of sulfur in nonroad diesel fuel. The regulations set emission standards for engines used in most construction, 

agricultural, industrial, and airport equipment beginning in 2008. Fuel requirements will decrease 

the sulfur levels in non-road diesel fuel to prevent damage to emission-control systems. Current 

sulfur levels of about 3,000 ppm will be reduced to a maximum of 500 ppm in 2007. The second 

phase will reduce sulfur levels in non-road diesel fuel to 15 ppm in 2010, except for locomotive 

and marine diesel fuel, which will be reduced to 15 ppm in 2012. 

In 1995, EPA issued Phase 1 standards for model year 1997 and newer small (< 25 hp) non-road 

spark-ignited engines, which are used primarily in lawn and garden equipment. In 1999, EPA 

issued more stringent Phase 2 emission standards for small non-handheld engines (e.g., lawn 

mowers, generator sets, air compressors) and, in 2000, for small handheld engines (e.g., leaf 

blowers, chain saws, augers). Phase 2 standards were phased-in from 2001 to 2007 for nonhandheld engines and from 2002 to 2007 for handheld engines. In 1996, EPA finalized emission 

standards for new gasoline spark-ignition marine engines to be phased-in between 1998 and 

2000. These engines are used for outboard engines, personal watercraft, and jet boats. 

In 2002, EPA promulgated new engine emission standards for large spark-ignition engines rated 

over 19 kilowatts (kW), or >25 hp. These are used in a variety of commercial and industrial 

settings, including forklifts, electric generators, airport baggage transport vehicles, farming and 

construction. The standards were implemented in two tiers - Tier 1 started in 2004 and Tier 2 in 

2007. EPA’s 2002 rulemaking also include exhaust emission standards for engines in 

recreational vehicles including snowmobiles, off-highway motorcycles, and all-terrain-vehicles 

(ATVs). These standards are phased-in in 2006 and 2007, except for snowmobiles, which have 

until 2009 to be fully phased-in. Plastic fuel tanks and rubber hoses available on recreational 

vehicles will also be subject to permeation standards effective in 2008. 

In 1999, EPA promulgated regulations setting emission standards for certain classes of new 

commercial marine diesel engines starting in 2004 and for other classes in 2007. In 2002, EPA 

promulgated new emission standards for recreational marine diesel engines, which are used in 

yachts, cruisers, and other types of pleasure craft. The standards are phased-in, beginning in 

2006, depending on the size of the engine. By 2009, emission standards will be in effect for all 

new recreational, marine diesel engines. 

3.2.2.4 New Federal Portable Fuel Containers Regulation 

In 2001, the OTC developed a model rule for reducing emissions for portable fuel containers 

(PFCs), gas cans, based on the California PFC regulation. In 2006, the OTC developed a revised 

model rule for this category, based on revisions to the California regulation. RI DEM did not 

adopt a PFC regulation for 1-hour ozone standard attainment, but intended to do so as part of its 

8-hour attainment strategy. However, in February 2007, EPA finalized a national regulation to 

reduce hazardous air pollutant emissions from mobile sources, which includes standards to 

17
reduce PFC emissions from evaporation, permeation, and spillage (72FR 8428, February 26, 

2007). The standards apply to containers manufactured on or after January 1, 2009. Emission 

reductions will be realized incrementally as consumers replace older PFCs with new ones. 

Because EPA’s rule has been finalized with a 2009 effective date and will achieve reductions 

equivalent to the OTC model rule, RI DEM no longer intends to adopt a state rule for this 

category. 

3.3 Planned Emissions Controls 

Among the control strategies developed by the OTC in 2001 were model rules for the 

Architectural and Industrial Maintenance (AIM) coatings and Consumer Products source 

categories. Those model rules were based on regulations in place for those source categories in 

California. In 2006, OTC produced an updated model rule for Consumer Products, which 

corresponds to newer California requirements. RI DEM planned to adopt rules for those 

categories as part of its 8-hour attainment strategy. However, on May 30, 2007 EPA issued a 

memo committing to adopt federal rules consistent with the OTC model rules for AIM and 

Consumer Products with emissions limits that would be effective by January 1, 2009.11. Based 

on that commitment, RI DEM decided not to promulgate state-specific regulations for those 

source categories. If, however, EPA does not propose those rules by July 1, 2008, RI DEM will 

adopt state rules consistent with the OTC models that will be effective by January 1, 2009. Those 

rules will be submitted to the EPA as a SIP revision by October 1, 2008. 

The 2001 OTC model rule for consumer products contains VOC limits for adhesives and 

sealants. However, with the exception of aerosol adhesives, the definitions of these products 

generally exempt products sold in larger containers. The OTC identified industrial and 

commercial use of adhesives as a category where additional reductions could be achieved and 

developed a 2006 OTC Adhesives model rule, based on a reasonably available control 

technology determination prepared by the California Air Resources Board in 1998. RI DEM 

commits to submit a new regulation for this category based on the OTC model rule by October 1, 

2008 with an effective date of January 1, 2009. 

The OTC 2001 model rules included a rule for limiting emissions from Solvent Cleaning 

operations. The 2006 OTC recommendations included a rule prohibiting the use of cutback 

asphalt and substantially restricting the use of emulsified asphalt. Rhode Island already has rules 

in place that are, for the most part, equivalent to the model rules. However, RI DEM had 

identified areas where the Rhode Island rules are not as stringent as the OTC recommendations 

and is committing to amend its existing rules for solvent cleaning and asphalt paving, APC 

Regulations No. 36 and 25, respectively, to address those discrepancies. The planned regulatory 

changes are discussed in more detail in Section 6.6, “RACT Changes.” These amendments will 

be submitted to the EPA as SIP revisions by January 1, 2009 and will be effective by April 1, 

2009. 

 

11 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to Regional 

Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer and 

Commercial Products,” May 30, 2007. 

18
In addition, as discussed in Section 6, “Reasonably Available Control Technology,” RI DEM 

plans to update APC Regulations No. 19, “Control of Volatile Organic Compounds from Surface 

Coating Operations,” and Regulation No. 35, “Control of Volatile Organic Compounds and 

Volatile Hazardous Air Pollutants from Wood Products Manufacturing Operations,” to be 

consistent with the provisions of a Control Technique Guideline for Flat Wood Paneling Coating 

which was finalized by the EPA in 2006. These amendments will be submitted to the EPA as a 

SIP revision by January 1, 2009 and will be effective by April 1, 2009. 

As discussed in Section 6, RI DEM is currently evaluating the applicability of CTGs released by 

the EPA in 2006 for Lithographic Printing Materials, Letterpress Printing Materials and Flexible 

Packaging Printing Materials to sources in Rhode Island. If it is determined that regulatory 

action is required for those sources, APC Regulation No. 21, “Control of Volatile Organic 

Compound Emissions from Printing Operations,” will be amended accordingly. Any such 

amendments will be submitted as a SIP revision by January 1, 2009 and will be effective by 

April 1, 2009. In addition, RI DEM plans to evaluate the applicability of new CTGs issued in 

October 2007 for paper, film and foil coating, metal furniture coating and large appliance coating 

to Rhode Island sources. If necessary, APC Regulation No. 19, “Control of Volatile Organic 

Compounds from Surface Coating Operations,” will be amended to reflect the new CTGs on the 

same schedule. 

Table 3-2 lists RI DEM’s commitments for regulatory amendments to reduce emissions in Rhode 

Island. 

19
Table 3-2 RI DEM Control Technology Regulatory Action Commitments 

Source Category Affected 

APC 

Regulation 

Comments SIP 

Submittal 

Date 

Effective 

Date 

AIM Coatings Reg. No. 33 State regulation will be 

amended to be consistent 

with 2001 OTC model rule 

only if EPA fails to propose 

a federal rule for this 

category by 7/1/08 

10/1/08 1/1/09 

Consumer Products Reg. No. 31 State regulation will be 

amended to be consistent 

with 2006 OTC model rule 

only if EPA fails to propose 

a federal rule for this 

category by 7/1/08 

10/1/08 1/1/09 

Adhesives and Sealants new 

regulation 

Consistent with 2006 OTC 

model rule 

10/1/08 1/1/09 

Industrial Solvents Reg. No. 36 Consistent with 2001 OTC 

model rule and 2006 CTG. 

1/1/09 4/1/09 

Asphalt Paving Reg. No.25 Consistent with 2006 OTC 

recommendations as 

feasible in Rhode Island 

1/1/09 4/1/09 

Flat Wood Paneling Reg. Nos. 19 

and 35 

Consistent with 2006 CTG 1/1/09 4/1/09 

Lithographic Printing 

Materials, Letterpress 

Printing Materials, 

Flexible Packaging 

Printing Materials 

Reg. No. 21 State regulation will be 

amended to be consistent 

with 2006 CTG if 

determined to be applicable 

and feasible in Rhode 

Island 

1/1/09 4/1/09 

Paper, Film and Foil 

coating; Metal 

Furniture coating; 

Large Appliance 

Coating 

Reg. No. 19 State regulation will be 

amended to be consistent 

with 2007 CTG if 

determined to be applicable 

and feasible in Rhode 

Island 

1/1/09 4/1/09 

RI Low Emission 

Vehicle Program 

Reg. No. 37 Submit updated regulation 

as SIP revision 

6/1/08 

RI Motor Vehicle 

Inspection/Maintenance 

Program 

Reg. No. 34 Finalize updated regulation 

and submit as SIP revision 

6/1/08 

20
4.0 REASONABLE FURTHER PROGRESS ANALYSIS 

4.1 Purpose of Section 

This section demonstrates that Rhode Island will meet the Reasonable Further Progress (RFP) 

requirement in EPA’s Phase 2 Rule. That rule requires that, by the end of 2008, emissions of 

VOC, NOx, or a combination of VOC and NOx must be at least 15% lower than the 2002 

baseline. As discussed in Section 2.2, RI DEM developed a 2008 projected emissions inventory 

for VOC and NOx that took into account anticipated growth in the economy and control 

measures expected to be in effect by that date. The projections demonstrate that emissions will 

decrease in the State by an amount greater than the required 15% reduction by 2008. 

4.2 Reasonable Further Progress Requirements and Methodology 

Since Rhode Island is a moderate nonattainment area, the Phase 2 Rule requires the State to 

demonstrate that emissions of VOC, NOx or a combination of VOC and NOx will be reduced by 

at least 15% by 2008 from the 2002 baseline. The procedures and methodology for 

demonstrating compliance with the 1-hour ozone standard Rate of Progress requirements were 

established in a 1992 EPA guidance document; these procedures are still applicable for purposes 

of the 8-hour ozone standard RFP.12 EPA’s method for demonstrating that RFP requirements are 

met calls for: 

1. Developing a 2002 base year inventory for a nonattainment area; 

2. Adjusting that inventory to subtract emissions reductions determined to be noncreditable; 

3. Establishing a target level of emissions for 2008 that reflects the required 15% 

reduction from the adjusted base year inventory; 

4. Developing a projected inventory of VOC and NOx emissions for 2008; and 

5. Demonstrating that the projected 2008 emissions of NOx, VOC or a combination of 

NOx and VOC will be less than or equal to the target level for that year. 

Using this methodology, RI DEM will demonstrate in the calculations below that the Rhode 

Island nonattainment area has met the RFP requirements. 

4.3 2002 Adjusted Base Year Inventory 

Estimates of typical summer day Rhode Island anthropogenic emissions of VOC and NOx for 

the 2002 base year were obtained from the 2002 Emissions Inventory discussed in Section 2 and 

attached as Appendix 2A. That inventory does not include organic compounds that are excluded 

from the EPA definition of “VOC.” Pursuant to EPA’s RFP methodology, for the purpose of the 

RFP, RI DEM adjusted this inventory by subtracting from the VOC and NOx base year 

 

12 Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15 Percent Rate 

of Progress Plans, U.S. EPA, Office of Air Quality Planning and Standards, EPA-452/R-92-005, October 

1992. 

21
emissions non-creditable emissions reductions, which are those realized from the pre-1990 

federal limits on the Reid Vapor Pressure (RVP) of gasoline (RVP of 9.0) and the Federal Motor 

Vehicle Control Program (FMVCP).13 Consistent with EPA guidance, non-creditable emissions 

reductions of VOC and NOx were calculated using the following methodology: 

1. EPA’s MOBILE model, version 6.2, was run for 2002 using the same highway 

vehicle activity inputs used to calculate the actual 2002 emissions but with FMVCP 

and RVP = 9.0 as the only control measures (all other control measures turned off). 

2. Similarly, MOBILE 6.2 was run for 2008 using the same highway vehicle activity 

inputs used to project 2008 emissions for the 2008 projected inventory but with 

FMVCP and RVP = 9.0 as the only control measures (all other control measures 

turned off). 

3. Non-creditable emissions reductions were calculated by subtracting the 2008 

emissions factors calculated in Step 2 from the 2002 factors calculated in Step 1 

and multiplying the difference by 2002 VMT. 

Non-creditable emissions calculated by this method are 5.51 tpsd VOC and 3.19 tpsd NOx. 

Non-creditable emissions calculations are shown in Appendix 4A. Table 4-1 shows the 2002 

Base Year and Adjusted Base Year Inventories of NOx and VOC, in tons per summer day 

Table 4-1 Rhode Island Base Year and Adjusted Base Year Emissions (tpsd) 

SOURCE TYPE 2002 Base Year 

VOC 

2002 Adjusted 

VOC 

2002 Base Year 

NOx 

2002 Adjusted 

NOx 

Stationary Point 10.3 10.3 7.0 7.0 

Stationary Nonpoint 47.9 47.9 3.4 3.4 

Non-road Mobile 26.8 26.8 19.7 19.7 

On-road Mobile 32.3 26.8 42.4 39.2 

Total 117.3 111.8 72.5 69.3 

 

13 The CAA (Section 182(b)(1)(D)) provides that reductions from the following measures are not 

creditable toward the required reductions: (1) Federal Motor Vehicle Control Program (FMVCP) tailpipe 

and evaporative standards issued in 1990; (2) Federal regulations limiting the Reid Vapor Pressure 

(RVP) of gasoline in ozone nonattainment areas issued by June 15, 1990; (3) State regulations correcting 

deficiencies in reasonably available control technology (RACT) rules; (4) Measures required to be 

enacted immediately after passage of the 1990 CAA Amendments concerning corrections to vehicle 

inspection and maintenance (I/M) programs. Only the FMVCP continues to generate emission reductions 

through 2008 in Rhode Island. 

22
4.4 Target Level of Emissions 

To fulfill RFP requirements, projected emissions for 2008 must be at least 15% lower than the 

2002 Adjusted Base Year Inventory shown in Table 4-2. The reductions can be VOCs, NOx or 

any combination of both. RI DEM is establishing its target levels based on a 15% reduction in 

NOx emissions. The 2008 Target Levels and resultant required emissions reductions were 

calculated as follows: 

NOx: 

Required Emissions Reductions = 2002 Adjusted Emissions (69.3 tpsd) X 0.15 = 10.4 tpsd 

2008 Target = 2002 Adjusted Emissions (69.3 tpsd) – Required Reductions (10.4 tpsd) = 58.9 

tpsd 

VOC 

Required Emissions Reductions = 2002 Adjusted Emissions (111.8 tpsd) X 0.00 = 0.0 tpsd 

2008 Target = 2002 Adjusted Emissions (111.8 tpsd) – Required Reductions (0.0 tpsd) = 111.8 

tpsd 

4.5 2008 Projected Emissions Inventory 

Projected emissions in 2008 were calculated by estimating anticipated growth in emissions 

between 2002 and 2008 and then adjusting for any controls that will reduce emissions during that 

time period. Calculations of the projected 2008 inventory are discussed in Section 2.2 of this 

document. 

4.6 Results of RFP Analysis 

The 2008 projections are shown in Table 4-2 below. Reductions anticipated by 2008 are 

compared to the reductions required to meet RFP. As shown, projected 2008 VOC emissions in 

Rhode Island are 1.5% (1.7 tons per day) higher than the target level. To compensate for the 

higher VOC levels, an additional 1.5% reduction in NOx emissions, for a total 16.5%, is needed 

to meet the RFP requirements. As shown in Table 4-2, projected 2008 NOx emissions are 

20.1% lower than the 2002 adjusted baseline; therefore RFP requirements will be met and NOx 

emissions will be reduced an additional 3.6% beyond the required reductions.. These emissions 

reductions occur primarily in the non-road and on-road mobile sectors. Note that the 2008 onroad mobile emissions of VOC and NOx used in these calculations are 0.5 tons per day higher 

than the 2008 modeled on-road mobile source emissions to allow for a buffer in the 

transportation conformity budget for 2008. This issue is discussed further in section 9.4, 

“Mobile Source Budgets.” 

23
Table 4-2 RFP Calculations 

VOC (tpsd) NOx (tpsd) 

Emissions 

2002 RFP 

Inventory 

2008 

Inventory 

2002 RFP 

Inventory 

2008 

Inventory 

 Stationary Point 10.3 11.0 7.0 7.3 

 Stationary Nonpoint 47.9 56.8 3.4 3.7 

 Non-road Mobile 26.8 21.0 19.7 16.0 

 On-road Mobile (adjusted) 26.8 24.6 39.2 28.3 

 Total 111.8 113.5 69.3 55.3 

2008 RFP Target Emissions 111.8 58.9 

Predicted 2002-2008 

Emissions Reductions 

(Increases)

(1.6) tpsd 

(1.4%) of 2002 RFP 

inventory) 

13.9 tpsd 

(20.1% of 2002 RFP inventory) 

Required 2002-2008 

Emissions Reductions 

0.0 tpsd 

(0.0% of 2002 RFP inventory) 

10.4 tpsd 

(15.0% of 2002 RFP inventory) 

Excess Emissions 

Reductions 

(1.7) tpsd 

(1.5%) of 2002 RFP 

inventory) 

3.5 tpsd 

(5.1% of 2002 RFP inventory) 

2008 RFP Target NOx 

Emissions Adjusted to 

Account for Increase in 

VOC Emissions 

57.8 tpsd 

(16.5% reduction from 2002 

RFP inventory) 

Required Emissions 

Reductions Adjusted to 

Account for Increase in 

VOC Emissions 

11.4 tpsd 

(16.5% of 2002 RFP inventory) 

Excess Emissions 

Reductions Adjusted to 

Account for Increase in 

VOC Emissions 

2.5 tpsd 

(3.6% of 2002 RFP inventory) 

24
5.0 ATTAINMENT DEMONSTRATION 

5.1 Purpose of Section 

EPA requires states with moderate ozone nonattainment areas to prepare and adopt SIP revisions 

demonstrating attainment of the 8-hour ozone standard using photochemical grid modeling and 

weight-of-evidence (WOE) analyses. States with moderate nonattainment areas are required to 

attain the 8-hour ozone NAAQS by June 15, 2010. However, because the June 15, 2010 

deadline occurs in the middle of the ozone season, according to EPA modeling guidance, 

modeled attainment must be based on the ozone season preceding 2010. Therefore, the target 

year for attainment monitoring is calendar year 2009. 

The following attainment demonstration demonstrates that, as a result of reductions in ozone 

precursor emissions in Rhode Island and upwind of Rhode Island, Rhode Island will attain the 8-

hour ozone NAAQS by 2009. The attainment demonstration is based upon the regional ozone 

attainment planning process undertaken by the OTC and OTC states to develop a SIP-quality 

ozone modeling platform and to prepare candidate control strategies for ozone attainment 

demonstrations. 

5.2 Ozone Conceptual Model 

5.2.1 Conceptual Description for Ozone Episodes in Rhode Island 

The Northeast States for Coordinated Air Use Management (NESCAUM), on behalf of the OTC, 

produced a comprehensive conceptual description of the meteorological processes underlying the 

formation of ozone episodes. The NESCAUM report (NESCAUM, 2006) was intended as a 

reference for SIP attainment demonstrations and is contained in Appendix 5A. State-specific 

information for Rhode Island is presented below. 

5.2.2 Geographical Considerations 

Rhode Island, at about 41 degrees north latitude, lies closer to the mean position of the polar 

front than more southern states in the Ozone Transport Region are. For that reason, Rhode Island 

experiences cooling and cleansing cold frontal passages more frequently than in areas to its 

south, resulting in fewer and shorter, although not necessarily weaker, ozone episodes. 

Although Rhode Island contributes to pollutant levels in Massachusetts, it is primarily 

considered to be a downwind state, being a recipient of ozone and precursors from much of the 

northeast corridor including Baltimore, Washington D.C., Philadelphia, New Jersey, and New 

York City. Stagnation, which occasionally results in elevated ozone in southern states, is not a 

major factor in Rhode Island episodes. Exceedances in Rhode Island are almost always due to 

elevated ozone and precursors transported from upwind areas; this is particularly true for the 

State’s Narragansett and W. Greenwich monitoring locations, which are upwind of the highly 

populated Providence metropolitan area. 

25
5.2.3 Transport 

Global scale circulations, while not a direct cause of Rhode Island ozone episodes, govern the 

location and strength of synoptic scale features such as high and low pressure systems and fronts, 

which are normally associated with ozone episodes. Global systems ultimately control the 

duration of weather patterns and how often they recur, thus determining the severity of an ozone 

season. When a summertime air mass resides for a long period over the eastern United States 

and this pattern becomes recurrent, Rhode Island is likely to experience an above average ozone 

season. 

Mesoscale features also influence the spatial pattern of ozone development in Rhode Island. Sea 

breezes often draw cleaner air onshore, thus lowering ozone concentrations, but they sometimes 

have the opposite effect. If a plume of ozone lies offshore, such circulations can bring polluted 

air onto the land, causing a rapid rise in ozone readings. This is a particular issue for the coastal 

Narragansett monitoring site. Lee troughs, induced by mountain ranges like the Appalachians, 

align the southwesterly airflow with the mountains, resulting in more highly concentrated 

streams of pollution entering Rhode Island’s airways. Low-level nocturnal jets are relative 

newcomers in our understanding of ozone transport. This rapid transit mechanism can move 

pollution long distances from southwest to northeast to spread ozone episodes hundreds of miles 

overnight. 

Smaller microscale circulations include the whorls and eddies that transfer heat and energy 

vertically. This transfer mechanism often shuts down in the evening when the earth cools and 

temperature inversions form. Ozone trapped near the ground is destroyed via chemical 

transformation and deposition. But ozone aloft remains relatively undepleted and mixes back to 

the surface the following morning when heating-induced eddies grow and erode the inversion. 

This mechanism is basic to the diurnal rise and fall of surface ozone values. 

 

5.2.4 Primary Meteorological Regimes for Rhode Island 

Two primary synoptic meteorological patterns typically trigger severe ozone episodes in Rhode 

Island and result in episodes having markedly different ozone signatures. The first synoptic type 

affects the immediate south coast and is controlled by the Atlantic oceanic anticyclone (high 

pressure area), which extends westward well into interior of the eastern United States. This 

results in westerly to sometimes a west-northwesterly surface winds over Rhode Island, with 

pollution transport from the New York and New Jersey area eastward across Long Island Sound, 

bringing ozone and precursors to coastal Connecticut, Rhode Island and Massachusetts. The 

westerly flow also blocks the plume’s northward penetration, keeping the rest of the state’s air 

relatively clean. A good example of this episode type is shown in 5-1 with (on the left) a distinct 

ribbon of high ozone along the New England south coast with (on the right) the westerly surface 

winds that forced the plume seaward. 

26
Figure 5-1: July 2, 2002 Ozone and Isobar Maps 

LEFT: EPA ozone mapping showing peak 8-hr values on July 2, 2002. Levels above the 8-hour 

NAAQS (orange and red) occurred along the south coast, while concentrations were lower 

inland. RIGHT: Surface isobars (sea-level pressure) and wind vectors at 2PM EST, July 2, 2002. 

(NOAA Air Resources Lab) 

The second synoptic type occurs when the Atlantic anticyclone has a more northeast-southwest 

orientation (as opposed to the west – east orientation in the previous example) with less 

extension into the interior of the eastern United States. This pattern generates a more southsouthwesterly wind across southern New England, which carries pollutants from the New York 

City area northeastward into Western and Central New England. This flow keeps the main 

pollutant plume in the interior of or to the west of Rhode Island, since southerly coastal breezes 

draw in cleaner marine air. In this case, the ozone gradient is reversed from the first episode type 

discussed above; ozone levels tend to be lowest along the south coast, while levels are elevated 

to the north and west. An example of this second flow pattern is shown in Figure 5-2 showing 

clean air along the south coast with higher ozone over more northern interior sections of southern 

New England. The surface flow with marine air drawn inland along south coastal locales can be 

seen on the right side of Figure 5-2. 

These two meteorological regimes occurred many times during 2002, resulting in exceedances of 

the 8-hour ozone NAAQS at one or more of the Rhode Island monitors on seventeen days. (See 

Table 5-1) Similarly, a significant number of elevated ozone days occurred in many other 

portions of the eastern Unite States that year. Therefore, 2002 is an appropriate ozone season for 

use in modeling to demonstrate ozone attainment in Rhode Island and other parts of the OTR. 

27
Figure 5-2: August 12, 2002 Ozone and Isobar Maps 

 

LEFT: EPA ozone mapping showing peak 8-hr values on August 12, 2002. Colors range from 

green (good air quality) along the south coast to red (unhealthy) inland. RIGHT: Surface isobars 

(sea-level pressure) and wind vectors at 2PM EST, August 12, 2002 (NOAA Air Resources Lab) 

Table 5-1 Rhode Island Ozone Concentrations on 8-Hour Exceedance Days in 2002 (ppb) 

 W. Greenwich E Providence Narragansett 

17-Apr NA 69 86 

24-May 69 73 86 

11-Jun 89 81 73 

23-Jun 92 87 76 

26-Jun 86 88 79 

27-Jun 92 91 84 

1-Jul 101 97 98 

2-Jul 76 79 112 

8-Jul 66 NA 86 

9-Jul 111 103 79 

18-Jul 91 86 101 

19-Jul 91 76 79 

4-Aug 79 77 94 

11-Aug 95 84 70 

12-Aug 100 87 56 

13-Aug 120 120 92 

14-Aug 92 92 70 

28
5.3 OTC Modeling Protocol 

5.3.1 Modeling Protocol (2002) 

In 2002 the Ozone Transport Commission began developing a SIP modeling system for using 

photochemical grid models to assess the impact of candidate ozone control strategies in the OTR. 

EPA’s Community Multi-scale Air Quality Modeling System (CMAQ) was selected for 

attainment demonstrations in the OTC states. Air quality staff from the OTC states subsequently 

prepared a modeling protocol for attainment demonstrations in the OTR. The modeling protocol, 

entitled “Modeling Protocol for the OTC SIP Quality Modeling System For Assessment of the 

Ozone National Ambient Air Quality Standard in the Ozone Transport Region”, was endorsed by 

OTC at the November 12-13, 2003 Fall meeting. 

5.3.2 Modeling Protocol (2006) 

The modeling protocol, now dated December 31, 2006, has been modified several times since 

then to incorporate CMAQ model modifications, boundary condition estimates and emission 

inventory improvements. The New York Department of Environmental Conservation (NY 

DEC), under the direction of the OTC Modeling Committee, agreed to be the lead agency for 

developing and using the SIP quality ozone modeling system as specified in the modeling 

protocol. The subject protocol, which describes the modeling procedures and databases to be 

used for SIP attainment demonstrations in the OTR, is contained in Appendix 5B. 

5.4 Review of 2002 Ozone Episodes 

5.4.1 Episode Selection Criteria 

Ozone-based research has shown that model performance evaluations and the model response to 

emissions reductions need to consider relatively long time periods. In order to examine the 

response to ozone control strategies, EPA recommends that episode days should be 

meteorologically representative of typical high ozone exceedance days and so severe that any 

control strategies predicted to attain the ozone NAAQS for that episode day would also result in 

attainment for all other exceedance days (EPA, 2007). Time periods to be modeled should 

display increasing ozone concentrations over time, followed by a ramp-down period to cleaner 

conditions to allow for a more complete evaluation of model performance under a variety of 

meteorological conditions.

5.4.2 Episode Selection Procedure 

Because of the large areal extent of the OTR modeling domain, the OTC Modeling Committee 

decided to model the entire 5-month ozone season in order to investigate numerous ozone 

episodes and to provide for better assessment of simulated pollutant fields. The 2002 ozone 

season was selected since a significant number of exceedance days were recorded across the 

eastern United States that year. A multi-year review (1997-2003) of elevated ozone days in the 

OTR indicted that associated meteorological regimes during high ozone days in 2002 were for 

29
the most part very similar to those found to occur in other years. The multi-year review, 

prepared by Environ (Environ, 2005) is contained in Appendix 5C. Based on this work, the OTC 

Modeling Committee is confident that the 2002 season is representative for purposes of 

photochemical modeling for ozone SIP attainment demonstrations. 

5.5 Modeling Domain 

5.5.1 Description 

The OTR modeling domain is displayed in Figure 5-3. The OTR modeling domain is embedded 

in the national grid that was adopted by the five U.S. Regional Haze Regional Planning 

Organizations (RPOs) for photochemical grid modeling. Individual RPOs are shown in Figure 5-

4. 

 

The OTR modeling domain was designed to both capture the effects of emissions transported 

into the OTR and to test the effectiveness of 2009 control strategies in the OTR states. OTR 

states consist of Connecticut, Delaware, Washington D.C., Maryland, Maine, Massachusetts, 

New Jersey, New York, New Hampshire, Pennsylvania, Rhode Island, Vermont and Virginia. 

Non-OTR states in the OTR modeling domain consist of Alabama, Arkansas, Georgia, Iowa, 

Louisiana, Illinois, Indiana, Kentucky, Michigan, Minnesota, Missouri, North Carolina, Ohio, 

South Caroline, Tennessee, Virginia and Wisconsin. The horizontal grid resolution is 12 km and 

there are 172 grids in the east-west and 172 grids in north-south direction. Details of the 

modeling system grid setup are contained in Appendix 5D. 

5.5.2 Horizontal Grid Size 

Following EPA guidance and as noted above, a 12 km grid resolution was used for the domain. 

Details of the horizontal grid layers are contained in Appendix 5D. 

5.5.3 Number of Vertical Layers 

Although the definition of the vertical structure can be adopted on a one-to-one basis with the 

meteorological model (which is 29 layers), it was decided not to do so. Given the available 

computational resources and runtime needs, it was decided to limit the number of vertical layers 

in the photochemical model to 22, with the lowest 16 layers (where most of the ozone chemistry 

takes place) set one-to-one with those of the meteorological model. Details of vertical grid 

layers are contained in Appendix 5D. 

30
Figure 5-3: OTR Photochemical Grid Modeling Domain (Eastern Modeling Domain) 

5.6 Photochemical Grid Modeling System 

5.6.1 Photochemical Grid Modeling System 

EPA’s Community Multi-scale Air Quality Modeling System (CMAQ) was selected for ozone 

attainment demonstrations in the OTR because it addresses multiple pollutants and different 

spatial scales (http://www.epa.gov/asmdnerl/CMAQ/index.html). The CMAQ platform is also 

being used for regional haze applications in the OTR and for PM2.5 attainment demonstrations 

for those jurisdictions within the OTR designated as non-attainment for the PM2.5. The CMAQ 

framework is an advanced computational platform that provides a sophisticated and powerful 

modeling environment for science and regulatory communities. CMAQ has a "one atmosphere" 

perspective; it was specifically designed to approach air quality as a whole by including state-ofthe-science capabilities to address multiple air quality issues, including tropospheric ozone, fine 

particles, toxics, acid deposition, and visibility degradation. The target grid resolutions and 

domain sizes for CMAQ can range spatially and temporally over several orders of magnitude. In 

addition, CMAQ also has temporal flexibility; simulations can be performed for long-term 

(annual to multi-year) pollutant climatologies as well as short term (weeks to months) to simulate 

transport of precursor emissions from localized sources. 

31
Figure 5-4: Regional Haze Regional planning Organizations (RPOs) 

5.6.2 CMAQ Modeling System Source Codes 

The CMAQ modeling system contains three types of modeling components: a meteorological 

modeling system (MM5) for the description of atmospheric states and motions; an emission 

model (SMOKE) for man-made and natural emissions that are injected into the atmosphere; and 

a chemistry-transport modeling system (CMAQ) for simulation of the chemical transformation 

and fate. Because CMAQ is designed to handle scale-dependent meteorological formulations and 

5.6.2 CMAQ Modeling System Source Codes 

The CMAQ modeling system contains three types of modeling components: a meteorological 

modeling system (MM5) for the description of atmospheric states and motions; an emission 

model (SMOKE) for man-made and natural emissions that are injected into the atmosphere; and 

a chemistry-transport modeling system (CMAQ) for simulation of the chemical transformation 

and fate. Because CMAQ is designed to handle scale-dependent meteorological formulations and 

a large amount of system flexibility, CMAQ's governing equations are expressed in a generalized 

coordinate system. The generalized coordinate system determines the necessary grid and 

coordinate transformations and can accommodate various vertical coordinates and map 

projections. The SMOKE and CMAQ codes are available at http://www.cmascenter.org/ and 

MM5 codes can be obtained at http://www.mmm.ucar.edu/mm5/

32
5.6.3 CMAQ Model Setup for the OTR Domain 

The CMAQ Model (Version 4.5.1) was used to predict ozone concentrations in the OTR 

modeling domain. The CMAQ model configuration and the MM5/SMOKE/CMAQ modeling 

system grid specifications employed by the NY DEC are presented in Appendix 5D. 

5.7 Meteorological Modeling System 

5.7.1 MM5 Meteorological Model 

The Fifth-Generation Pennsylvania State University/NCAR mesoscale model, referred to as 

MM5, was used by the University of Maryland (UMD) to generate meteorological fields for the 

OTR modeling domain. MM5 is a limited-area, non-hydrostatic, terrain-following sigmacoordinate model designed to simulate mesoscale atmospheric circulation. MM5 codes can be 

obtained at http://www.mmm.ucar.edu/mm5/. The set of options used by UMD for running 

MM5 (Version 3.6) in consultation with NY DEC are listed in Appendix 5E. 

5.7.2 MM5 Meteorological Fields 

The National Weather Service NCEP ETA 40 km resolution-forecasting model was employed to 

initialize the MM5 model and to provide outer edge boundary conditions for the MM5 model. 

To minimize model error, the model applied four-dimensional data assimilation nudging 

techniques employing National Weather Service surface wind and upper air data (Zheng and 

Zheng, 2004). The model was applied in a Lambert conformal map projection over two-way 

nested domains. The coarse grid (36 km) domain and the fine grid (12 km) domain are shown in 

Figure 5-5. MM5 was used to produce hourly meteorological fields for the calendar year 2002. 

Since there are a variety of options that can be exercised with MM5, initial testing was 

performed for a high ozone event of 2002 with commonly used default options as well as with 

modified boundary layer schemes (Zhang and Zheng 2004). Based on this work, a modified 

Blackadar scheme was employed in order to produce more accurate diurnal cycles of surface 

winds and temperatures. A description of the preparation of MM5 meteorological fields for the 

OTR modeling domain is contained in 5F. 

5.7.3 MM5 Model Performance 

NY DEC and UMD tested several MM5 configurations before settling on one that included a 

modification to the Blackadar planetary boundary scheme in order to obtain an accurate 

rendering of three-dimensional meteorological fields over the OTR modeling domain. This work 

was coordinated through the OTC Modeling Committee. 

33
Figure 5-5: MM5 Modeling Domains (36 km and 12 km) 

After MM5 hourly meteorological fields were prepared, the simulated meteorological fields for 

2002 ozone season (May 1 to September 30) were compared to National Weather Service (NWS) 

and CASTNet surface temperature, wind speed, and humidity observations. CASTNet is the 

nation’s primary source of rural ground-level ozone measurements and associated meteorological 

data. Comparisons with CASTNet data provide a more independent assessment of the MM5 

model since CASTNet data, unlike NWS data, is not used to in the MM5 application to improve 

model performance (model nudging). MM5 results were also compared with wind profiler data 

and cloud data derived from satellite images to diagnose if the MM5 simulation is yielding the 

right type of dynamics in the vertical. These analyses (Appendix 5F) indicate that the 

performance of MM5 is reasonable across the OTR both at the surface and in the vertical, 

thereby providing confidence in the use of MM5 results for the CMAQ simulations. 

5.8 Biogenic emissions 

5.8.1 BEIS Modeling System 

Biogenic emissions of VOCs, NOx and CO from natural sources for the time period from 

January 1, 2002 – December 31, 2002 were calculated by the NY DEC using the Biogenic 

34
Emissions Inventory System (BEIS version 3.12) integrated within SMOKE2.1. The procedures 

used to calculate biogenic emissions are contained in Appendix 5G. 

5.8.2 OTR Modeling Domain Biogenic Emissions 

NY DEC used gridded land use data and emissions factors to produce gridded normalized 

biogenic emissions for 34 species/compounds in the OTR modeling domain. The gridded land 

use file utilized by NY DEC included the fractional coverage of 230 different land use types for 

each of the 12-km grid cells in the OTR modeling domain. MM5/MCIP meteorological 

variables were then used to compute hour-specific, gridded biogenic emissions, which were then 

converted to CO, NO, and the Carbon Bond IV (CB-IV) VOC species utilized in CMAQ Model. 

5.9 Boundary and Initial Conditions 

5.9.1 Generation of Boundary Conditions 

NY DEC prepared boundary conditions for the OTR 12 km domain by performing a CMAQ 

simulation for a continental U.S. grid with a 36 km grid spacing. The simulation utilized the 

2002 emissions data provided from the five U.S. RPOs and the 2002 MM5 meteorological fields 

developed by the UMD (Section 7). Clean initial conditions were employed, and boundary 

conditions for the continental USA simulation were extracted from a simulation of the GEOSCHEM global chemical model. The interface program used to extract 36 km boundary conditions 

from the GEOS-CHEM global model was developed by University of Houston (Moon and Byun, 

2004). The CMAQ 36km simulation ran from December 15, 2001 to December 31, 2002 with 

the first 15 days in December 2001 as ramp up period. The boundary conditions simulation is 

described in more detail in Appendix 5H. 

5.9.2 OTR Modeling Domain Boundary Conditions 

The hourly boundary fields for the 12km CMAQ domain were obtained by using a boundary 

condition program (BCON) to extract the 3-D concentration fields from the NY DEC continental 

CMAQ run at the boundaries of the OTC 12 km modeling domain. Boundary conditions were 

obtained for the ozone season simulation period (May 1 through September 30) with the first 14 

days of May set as a ramp-up period to minimize the propagation of the boundary fields into the 

areas of concern. Clean initial conditions were employed at the start of the ramp-up period. 

5.10 CMAQ Emission Files for 2002 

 

5.10.1 Regional Planning Organization Annual Emission Inventories for 2002 

The OTR modeling domain (previously shown on Figure 5-3) contains states from 4 of the 5 

U.S. RPOs: Mid-Atlantic/Northeast Visibility Union (MANE-VU), Central Regional Air 

Planning Association (CENRAP), Midwest Regional Planning Organization (MRPO) and the 

Visibility Improvement State and Tribal Association of the Southwest (VISTAS). These RPOs 

35
were established by EPA to support regional haze planning activities, including the development 

of coordinated multi-purpose emission inventories. Each RPO has prepared detailed emission 

inventories for calendar year 2002 that are being used for ozone, PM2.5 and regional haze SIP 

attainment demonstrations. RPO boundaries were previously shown in Figure 5-4. 

5.10.2 MANE-VU Annual Emission Inventory for 2002 

The OTR states, except for Virginia, are members of the MANE-VU RPO (Virginia is in the 

VISTAS RPO). The Mid-Atlantic Regional Air Management Association (MARAMA) directed 

the preparation of the 2002 MANE-VU emission inventory. The MANE-VU states consist of 

Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New 

Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont. A detailed 

technical support document describing the development of 2002 MANE-VU emission inventory 

is contained in Appendix 5I. 

The 2002 MANE-VU emission inventory was based upon point, nonpoint, on-road, and nonroad emission inventory data submitted by MANE-VU states to EPA in 2004 as a requirement of 

the Consolidated Emissions Reporting Rule. Under contract to MARAMA, E.H. Pechan & 

Associates (Pechan) collected this information and ran EPA format and content quality assurance 

programs and other checks to identify format and data content issues. Data gaps were filled in 

accordance with a Quality Assurance Project Plan prepared for this project (MANE-VU, 2004a). 

After making corrections and filling data gaps, emission files for sulfur dioxide (SO2), oxides of 

nitrogen (NOx), volatile organic compounds (VOC), carbon monoxide (CO), ammonia (NH3) and 

particles with aerodynamic diameters less than or equal to a nominal 10 and 2.5 micrometers 

(primary PM10 and PM2.5) were prepared in National Emissions Inventory Input Format (NIF 

3.0) and placed on the MARAMA ftp site. 

Several versions of the emission inventory were prepared by Pechan to address corrections, 

improvements and ongoing state-of-the-art changes (for example, the non-road inventory was 

completely redone in Version 3 due to EPA modifications to the NONROAD2005 model). The 

most current version of the MANE-VU emission inventory (Version 3) was used for OTR state 

attainment demonstrations. MANE-VU state emission totals are shown in Table 5-2. 

Table 5-2: MANE-VU 2002 Anthropogenic Emissions (Tons/Year) 

2002 Version 3 

Base Case CO NOx VOC NH3 SO2 PM10 PM2.5 PMC 

 

Connecticut 992201 125208 162492 8598 32077 27061 15795 11266

Delaware 273433 58764 41120 14376 79868 15214 7931 7284

District of Columbia 101372 15389 14893 415 2939 2889 1276 1613

Maine 759882 94932 166501 11060 39362 64103 28458 35645

Maryland 1905406 283387 265220 31712 315251 72234 34805 37428

Massachusetts 1838763 276530 294703 25737 164112 89984 40667 49317

New Hampshire 594257 67326 111333 3678 55295 25796 19479 6316

36
New Jersey 2276006 303053 378877 24931 91273 47021 29350 17671

New York 5223096 655774 921593 83801 448322 229391 90977 138413

Pennsylvania 4448357 806061 594355 91842 1077658 228459 82467 145992

Rhode Island 312263 29418 57200 1789 8022 5058 2486 2571

Vermont 351716 28290 50461 10608 6022 21218 8330 12888

 

Total 19076752 2744133 3058749 308548 2320202 828427 362022 466405

Note that the Rhode Island emissions in the MANE-VU inventory are slightly different from 

those in Rhode Island’s 2002 Emissions Inventory, which is Appendix 2A of this document, due 

to the timing of the preparation of the inventories. However, as shown in Table 5-3, these 

differences are minor and would not affect the modeling results. 

Table 5-3 Comparison of RIDEM and MARAMA 2002 Emissions Inventory for Rhode 

Island (tons per year) 

VOC NOx 

RI DEM MARAMA RIDEM MARAMA 

Point 3,095 1,928 2,225 2,764

Nonpoint 16,809 31,402 3,045 3,886

On-Road 8,763 7,780 5,934 5,001

Non-Road 12,827 12,538 16,720 16,677

Biogenic 18,120 19,233 158 211

Total 59,614 72,881 28,082 28,539

The only substantial difference between the MARAMA and RI DEM emissions estimates is in 

emissions of VOC from nonpoint sources, specifically the nonpoint source surface coating and 

degreasing categories. MARAMA’s nonpoint source surface coating and degreasing emissions 

estimates came from 1999 EPA data based on outdated emissions factors, grown to 2002. RI 

DEM updated emissions estimates for both of these categories based on comments received on 

the draft inventory from EPA Region I The updated RI DEM emissions estimates for those 

categories are, as recommended, from an the EPA report “Solvent Mass Balance Approach for 

Estimating VOC Emissions from Eleven Point Source Categories.” Those emissions are much 

lower than the older EPA estimates for the nonpoint source surface coating and degreasing 

categories. 

RI DEM also modified its estimates of emissions from process solvents, graphic arts, gasoline 

distribution and asphalt paving after the MARAMA inventory was developed. Since, the RI 

DEM emissions estimates are, overall, lower than those in the MARAMA inventory, modeling 

done to show attainment, which used the MARAMA data, would actually slightly overestimate 

Rhode Island’s contribution to ozone levels in and downwind of the State. 

37
5.10.3 Emission files for the OTR Domain 

CMAQ-ready emission files for each RPO in the OTR domain (MANE-VU, CENRAP, MRPO, 

and VISTAS) were prepared by NY DEC. Emission files for portions of Canada in the OTR 

domain were also prepared by NY DEC. Emission processing procedures are summarized below 

and described in more detail in Appendix 5J. 

5.10.3.1 MANE-VU Emission Files for 2002 

Point, nonpoint, and non-road source emissions for MANE-VU states (MANE-VU Version 3 

emission inventory) were obtained from the MARAMA ftp site and mobile emissions were 

obtained from the NESCAUM ftp site. NY DEC processed these emission files with SMOKE2.2

to prepare CMAQ-ready hourly emission input files 

5.10.3.2 CENRAP Emission Files for 2002 

CENRAP states in the OTR modeling domain consist of Arkansas, Iowa, Louisiana, Minnesota, 

and Missouri. Point, nonpoint, mobile and non-road source emissions for CENRAP states 

(CENRAP Version BaseB emission inventory) were obtained from the CENRAP ftp site by NY 

DEC and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files. 

5.10.3.3 MRPO Emission Files for 2002 

MRPO states in the OTR modeling domain consist of Illinois, Indiana, Michigan Ohio, and 

Wisconsin. Point, nonpoint, mobile and non-road emissions for MRPO states were generated by 

Alpine Geophysics through a contract from MARAMA to convert the MRPO BaseK emission 

inventory to IDA format. The files were then obtained from the MARAMA ftp site by NY DEC 

and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files. 

5.10.3.4 VISTAS Emission Files for 2002 

VISTAS states in the OTR modeling domain consist of Alabama, Georgia, Kentucky, North 

Carolina, South Caroline, Tennessee and Virginia. Point, nonpoint, mobile and non-road 

emission files for VISTAS states (VISTAS BaseG emission inventory) were obtained from the 

Alpine Geophysics ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready 

hourly emission input files. 

5.10.3.5 Canadian Emissions Files for 2002 

Canadian non-road and mobile source emission files were obtained from EPA and processed 

with SMOKE2.1 by NY DEC. Non-EGU and EGU point source emissions were obtained from 

Canadian National Pollutant Release Inventory (NPRI) database. NY DEC inserted SCC code 

estimates (NPRI has no SCC codes) and then processed the emission files with SMOKE2.2 to 

prepare CMAQ-ready hourly emission input files. 

38
5.11 New OTR Control Measures for 2009 

5.11.1 Potential Beyond On the Way (BOTW) Control Measures 

Preliminary ozone modeling efforts (EPA, 2004) to support the proposed Clean Air Interstate Air 

Quality Rule (CAIR) indicated that additional controls beyond federal and state CAA control 

measures would be needed to attain the 8-hour ozone NAAQS in several portions of the OTR. 

Accordingly, OTC staff and member states formed several OTC workgroups to identify and 

evaluate potential control measures. Control measures were identified through published sources 

such as the U.S. Environmental Protection Agency’s Control Technique Guidelines, 

STAPPA/ALAPCO Menu of Options documents, the AirControlNET database, emission control 

initiatives in member states, state/regional consultations, and stakeholder input. OTC 

workgroups compiled and reviewed a list of approximately 1,000 candidate control measures 

from which 30 control measures were selected for detailed analyses. 

5.11.2 Final OTC Beyond On the Way (BOTW) Control Measures 

The OTC workgroups discussed the candidate control measures during a series of conference 

calls and workshops from the spring of 2004 through the autumn of 2006. OTC workgroups 

collected and evaluated information regarding emission benefits, cost-effectiveness, and 

implementation issues, and stakeholders were provided opportunity to review and provide input. 

The procedures used to develop and evaluate these control measures (MACTEC, 2007b) are 

contained in Appendix 5K. 

Based on this information, the OTC recommended that States consider emission reductions from 

the following source categories: Consumer Products, Portable Fuel Containers, Adhesives and 

Sealants Application, Diesel Engine Chip Reflash, Cutback and Emulsified Asphalt Paving, 

Asphalt Production Plants, Cement Kilns, Glass Furnaces, Industrial, Commercial, and 

Institutional (ICI) Boilers and Regional Fuels. These control measures are collectively referred to 

as beyond on the way (BOTW) control measures. 

As part of its 8-Hour Ozone Attainment Demonstration SIP, RI DEM plans to adopt a regulation 

to limit emissions from adhesives and sealants and to modify its regulations for Asphalt Paving 

(APC Regulation No. 25) and Solvent Metal Degreasing (APC Regulation No. 36) to be 

consistent with control measures recommended in the BOTW measures. 

The EPA’s Mobile Source Air Toxics rule, which was adopted in February 2007 (72 FR 8428, 

February 26, 2007), contains specifications for Portable Fuel Containers effective in 2009 similar 

to the OTC BOTW recommendations. Similarly, the EPA issued a memo on May 30, 2007 

committing to adopt federal rules consistent with the OTC BOTW limits for the Architectural 

and Industrial Maintenance(AIM) coatings category that would be effective by January 1, 

39
2009.14. Therefore, RI DEM plans to adopt state-specific regulations for those source categories 

only if EPA fails to fulfill its commitment in this area.. 

Rhode Island also does not plan to adopt rules for the source categories corresponding to the 

remaining BOTW categories. In January 2007, in response to a court ruling invalidating the 

California Chip Reflash regulation, which was the basis for the OTC recommendations for that 

source category, the California Air Resources Board announced that it would no longer enforce 

that regulation. Rhode Island has no major sources in the Asphalt Production Plant source 

category and has no Cement Kilns. The one Rhode Island Glass Furnace facility has permitted 

emissions limits lower than those in the OTC BOTW recommendations. Rhode Island already 

requires reformulated gasoline statewide, and thus would not benefit from the OTC Regional 

Fuels measure. The larger Industrial, Commercial, and Institutional (ICI) Boilers in Rhode 

Island are currently regulated under APC Regulation No. 27; RI DEM believes that further 

regulation of this source category at this time is unlikely to yield significant additional emissions 

reductions. 

In summary, Rhode Island will adopt all of the OTC BOTW measures that would feasibly yield 

additional emissions reductions in the State in 2009. BOTW measures included in the 2009 

modeling for Rhode Island are listed in Table 5-3A, along with the status of the adoption of those 

measures in Rhode Island. 

5.12 CMAQ Emission Files for 2009 with OTC BOTW Control Measures 

5.12.1 Regional Planning Organization Annual Emission Inventories for 2009 

The CENRAP, MRPO, VISTAS and MANE-VU RPOs prepared future year emission 

inventories for 2009 by applying growth and control measures to the 2002 base year emission 

inventories. The control measures reflected all control programs that are already on the way and 

in effect by 2009. These emission inventories, referred to as “on the way” emission inventories, 

reflect NOx SIP Call and CAIR requirements (http://www.epa.gov/interstateairquality/), federal 

on-road and off-road fuels, federal motor vehicle standards and state LEV (low emission vehicle) 

programs, federal MACT rules, 2001 OTC model rules for consumer products, architectural 

coatings, distributed generation and any other state-specific rules in effect by 2009. The interRPO work group utilized the Integrated Planning Model (IPM) to develop state and unit-level 

EGU emissions reflecting EPA’s Clean Air Interstate Rule (CAIR) in the CENRAP, MRPO, 

VISTAS and MANE-VU RPOs (ICF, 2005). 

 

14 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to Regional 

Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer and 

Commercial Products,” May 30, 2007. 

40
Table 5-3A Status of Adoption of Rhode Island BOTW Control Measures 

Control Measure Status 

Consumer Products Will submit by 10/1/08 if EPA has not proposed by 7/1/08 

AIM Coatings (OTB/OTW) Will submit by 10/1/08 if EPA has not proposed by 7/1/08 

Portable Fuel Containers Equivalent requirements adopted in EPA Mobile Source 

Air Toxics rule 

Mobile Equipment Repair & 

Refinishing (OTB/OTW) 

Equivalent rule (APC Regulation No. 30) adopted 1994 

Solvent Cleaning (OTB/OTW) Will submit update to APC Regulation No. 36 by 1/1/09 

Adhesives and Sealants Will submit new rule by 10/1/08 

Asphalt Paving Will submit update to APC Regulation No. 25 by 1/1/09 

5.12.2 MANEVU Annual Emission Inventory with BOTW Control Measures for 2009 

The Mid-Atlantic Regional Air Management Association (MARAMA) contracted MACTEC to 

prepare 2009 emissions for non-EGU point sources, nonpoint sources and non-road sources that 

reflected control measures that were already on the way and in effect by 2009. MACTEC in 

consultation with MANE-VU states developed the necessary growth and control factors and 

applied them to the 2002 MANE-VU emission inventory (Version 3) previously described in 

Section 10. Details of this work effort are contained in Appendix 5L (MACTEC, 2007a). 

Mobile source emissions were prepared by VA DEQ and NESCAUM, using MOBILE 6 input 

files and projected 2009 VMTs supplied by the MANE-VU states. 

MACTEC then calculated “beyond on the way” (BOTW) emission reductions reflecting the new 

OTC 2006 model rules for non-EGU point sources and several nonpoint source categories in the 

OTR states (previously described in Section 5.11). The BOTW control measures were 

developed because preliminary ozone modeling efforts indicated additional controls would be 

needed to attain the 8-hour ozone NAAQS in portions of the OTR. Emission reduction 

calculations are presented in Appendix 5K (MACTEC, 2007b). State totals for the MANE-VU 

2009 emission inventory reflecting BOTW control measures are shown in Table 5-4. BOTW 

emission reductions were incorporated into the 2009 MANE-VU 2009 emission inventory and 

all emission files were placed on the MARAMA ftp site 

5.12.3 Emission files for the OTR Domain 

CMAQ-ready emission files for 2009 for each RPO in the OTR modeling domain (MANE-VU, 

CENRAP, MRPO, and VISTAS) were prepared or obtained by NY DEC. Emission files for 

portions of Canada in the OTR domain were also prepared by NY DEC. Emission processing 

procedures are summarized below and described in more detail Appendix 5M. 

41
Table 5-4: MANE-VU 2009 Anthropogenic Emissions with BOTW Controls (Tons/Yr) 

2009 Version 3 

BOTW CO NOx VOC NH3 SO2 PM10 PM2.5 PMC 

 

Connecticut 751975 82139 122353 9255 22796 26481 15037 11443

Delaware 231392 49658 32109 14695 42569 15372 7694 7679

District of Columbia 67904 10433 10403 436 2297 2006 1124 882

Maine 579671 60201 141619 12974 38737 64881 27633 37247

Maryland 1373959 147710 205097 38971 114046 80496 39550 40946

Massachusetts 1290133 180391 229386 26513 64733 93839 42428 51411

New Hampshire 443286 44339 94330 4266 18597 26087 19511 6577

New Jersey 1778637 185314 285559 27935 49535 46183 28753 17430

New York 3730881 456457 710567 100682 325621 242237 98945 143293

Pennsylvania 3422688 518109 477042 113344 403150 259116 107315 151801

Rhode Island 240906 21900 44612 2144 8359 5410 2608 2802

Vermont 236142 17793 43063 13038 5966 22103 8099 14004

 

Total 14147574 1774443 2396138 364252 1096404 884212 398696 485516

5.12.3.1 MANE-VU Emission Files for 2009 

Non-EGU point source and nonpoint source emissions for MANE-VU states (2009 MANE-VU 

Version 3 emission inventory) reflecting BOTW control measures were obtained from the 

MARAMA ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready 

emission input files. Mobile source emissions for MANE-VU states were obtained from the 

MARAMA ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready 

emission input files. Non-road source emissions (2009 MANE-VU Version 3 emission 

inventory) were obtained from the MARAMA ftp site by VA DEQ and processed with 

SMOKE2.2 to prepare CMAQ-ready emission input files. EGU emissions (IPM2.1.9) were 

obtained from ICF (ICF, 2005) by VA DEQ and processed with SMOKE2.2 to prepare CMAQready hourly emission input files. 

5.12.3.2 CENRAP Emission files for 2009 

Non-EGU point, nonpoint, mobile and non-road emissions for CENRAP states in the OTR 

domain (2009 CENRAP BaseB emission inventory) were obtained from the CENRAP ftp site by 

VA DEQ and processed with SMOKE2.2 to prepare CMAQ-ready emission input files for the 

2009 simulation. EGU emissions (IPM2.1.9) were obtained from ICF (ICF, 2005) by VA DEQ 

and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files. 

5.12.3.3 MRPO Emission files for 2009 

Nonpoint and non-road emissions for MRPO states in the OTR domain (2009 MRPO BaseK 

emission inventory) were obtained from the MRPO by NY DEC and processed with SMOKE2.2

to prepare CMAQ-ready emission files for the 2009 simulation. Non-EGU and mobile emissions 

42
were obtained from the 2009 MRPO BaseK emission inventory by VA DEQ and processed with 

SMOKE2.2 to prepare CMAQ-ready emission input files. EGU emissions (IPM2.1.9) were 

obtained from ICF (ICF, 2005) by VA DEQ and processed with SMOKE2.2 to prepare CMAQready hourly emission input files. 

5.12.3.4 VISTAS Emission Files for 2009 

Non-EGU point, nonpoint, mobile and non-road emission files for VISTAS states in the OTR 

domain (2009 VISTAS BaseG emission inventory) were obtained from the Alpine Geophysics 

ftp site by VA DEQ and processed with SMOKE2.2 to prepare CMAQ-ready emission input 

files for the 2009 simulation. VISTAS EGU emissions were obtained from ICF (ICF, 2005) by 

VA DEQ and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files. 

5.12.3.5 Canadian Emission Files for 2009 

NY DEC obtained nonpoint, non-road and mobile source emission files for 2010 from EPA and 

obtained EGU point source emissions for 2010 from Environment Canada. These were 

considered to be a reasonable surrogate for 2009. Non-EGU point source emissions for 2002 

(Section 10.3) were used as a surrogate for 2009. NY DEC processed these Canadian emission 

files with SMOKE2.2 to prepare CMAQ-ready hourly emission input files. 

5.13 Quality Assurance of CMAQ Databases 

All air quality, emissions, and meteorological data were reviewed to ensure completeness, 

accuracy, and consistency before proceeding with modeling. Any errors, missing data or 

inconsistencies were addressed using standard practices. All modeling was benchmarked 

through the duplication of a set of standard modeling results including benchmark runs with five 

modeling centers in the OTR (New York Department of Environmental Conservation, University 

of Maryland, NESCAUM, Rutgers University, and Virginia Department of Environment 

Quality). 

Quality assurance activities were carried out for the various emissions, meteorological, and 

photochemical modeling components of the modeling study. Emissions inventories obtained 

from all RPOs (CENRAP, MANE-VU, MWRPO and VISTEAS) were examined to check for 

errors in the emissions estimates. When such errors were discovered, the problems in the input 

data files were corrected. 

The MM5 meteorological and CMAQ air quality model inputs and outputs were plotted and 

examined by NY DEC to ensure accurate representation of the observed data in the model-ready 

fields, and temporal and spatial consistency and reasonableness. Both MM5 and CMAQ 

underwent operational and scientific evaluations by NYDEC and the OTC Modeling Committee 

to facilitate the quality assurance review of meteorological and air quality modeling procedures. 

43
5.14 CMAQ Model Simulation for 2002 Base Case 

5.14.1 CMAQ Model 2002 Application 

The CMAQ 2002 base case simulation was performed by NY DEC using a one-way nesting 

approach for the 12 km OTR modeling domain. The OTR modeling domain was previously 

described in Section 4. CMAQ (version 4.5.1) was used with CB-IV chemistry, the aerosol 

module for PM2.5 and the Regional Air Deposition Model (RADM) cloud scheme. The 

simulation ran from May 1 to September 30, with the first 14 days of May used as a ramp-up 

period to minimize the propagation of boundary fields into areas of concern. The CMAQ results 

used for the performance evaluation were from May 15 through September 30. Details of the 

CMAQ setup and application are listed in Appendix 5N. 

5.14.2 CMAQ Input Files for 2002 

5.14.2.1 Emission Files for 2002 simulation 

The CMAQ-ready hourly emission files described in Sub-Section 10 for all RPO states and 

Canadian Provinces in the OTR modeling domain were used for the 2002 CMAQ base case 

simulation. As described in Section 8, NY DEC used the BEIS model to prepare gridded 

normalized biogenic emission files for CO, NO, and the CB-IV VOC species for the 2002 

simulation. 

5.14.2.2 Boundary and Initial Conditions for 2002 simulation 

As described in Sub-Section 9, hourly boundary fields for the 12km CMAQ domain were 

obtained by NY DEC using the BCON program to extract the 3-D concentration fields from the 

NY DEC continental USA CMAQ run at the four edges of the OTR modeling domain. Clean 

initial conditions were employed. 

5.14.2.3 Meteorological Files for 2002 simulation 

The meteorological data for the 2002 simulation were based on the MM5 modeling described in 

Sub-Section 7. The MM5 fields for the May 1 to September 30 MM5 simulation were processed 

with Meteorology Chemistry Interface Processor (MCIP Version 3.0) obtained from the CMAS 

Modeling Center (http://www.cmascenter.org) in order to provide CMAQ model-ready hourly 

meteorological input files. 

5.14.2.4 Photolysis Rates

Photolysis rate lookup tables were generated by NY DEC for each day using CMAQ’s 

Photolysis Rates Processor (JPROC) software (http://www.cmascenter.org). Daily ozone 

column measurements from NASA’s Earthprobe Total Ozone Mapping Spectrometer (TOMS) 

instrument (ftp://toms.gsfc.nasa.gov/pub/eptoms/data/ozone/Y2002/) were downloaded and used 

as input to the JPROC processing software. 

44
5.14.3 CMAQ Output Files 

Predicted hourly ozone concentrations for each ozone monitoring station location in all OTR 

states are listed in Appendix 5O. Daily ozone maps for the 2002 ozone season are contained in 

Appendix 5P. All input and output files for the 2002 Base Case CMAQ simulation for the OTR 

modeling domain are listed in Appendix 5U. Files are available in electronic format from NY 

DEC for use with the SMOKE/CMAQ system. Please contact Gopal Sistla at 518-402-8402 data 

file requests. 

5.15 Performance Evaluation of 2002 Simulation 

5.15.1 NY DEC Performance Evaluation for OTR Modeling Domain 

NY DEC conducted a detailed performance evaluation of the OTC CMAQ modeling platform 

simulation for the 2002 ozone season (Appendix 5Q). The CMAQ simulation ran from May 1 to 

September 30; May 1 through May 14 was the ramp up period to minimize effects of boundary 

conditions and the results for May 15 though September 30 were used for the performance 

evaluation. Air quality predictions for O3, CO, NO, NO2, SO2, C2H4, C5H8, HCHO, PM2.5 and 

several regional haze aerosol species were compared to measurements in every grid cell where 

air quality data were available. Hourly ozone measurements from 234 monitors were available 

to assess CMAQ model performance in the OTR. 

A variety of model performance metrics for each of these pollutants - observed average, 

predicted average, correlation coefficient (R2), normalized mean error, root mean square error 

(RMSE), mean absolute gross error (MAGE), mean normalized gross error (MNGE), mean bias 

(MB), mean normalized bias (MNB), mean fractionalized bias (MFB), normalized mean bias 

(NMB), along with temporal plots and daily ozone maps were prepared in order to help assess 

model performance. In general, the observed and predicted composite average ozone 

concentrations track well, although there was fairly substantial under-prediction during the midAugust period. Model performance was better in the vicinity of urban areas and along the 

northeastern corridor, compared to the performance in rural areas where the model tended to 

under-predict daily maximum concentrations. A complete set of model performance statistics 

for all OTR monitoring locations is contained in Appendix 5R. 

5.15.2 CMAQ Spatial Performance in New England States 

In assessing spatial performance of the CMAQ model, two elements are critical: (1) the model’s 

ability to replicate the general spatial pattern of ozone across most of the domain and, in 

particular, the New England region, and (2) whether the model can reproduce concentration 

gradients often observed along and within a few miles of the New England coast. A review of 

side-by-side maps of observed and predicted peak ozone values for the 2002 ozone season 

indicate the CMAQ model is doing a fairly good job of replicating spatial patterns and 

concentration gradients. A complete set of daily maps is contained in Appendix 5P. 

45
Figures 5-6 – 5-9 reveal good consistency between predicted and observed daily peak 8-hour 

ozone values. The simulations in Figure 5-6 and 5-7, for example, capture the narrow strip of 

elevated ozone from around Maryland northeastward to southern New England. The CMAQ 

model reproduced the splotchy areas of high ozone from the Midwest down across Tennessee 

(Figure5-7), as well as the clean areas near the Carolina coasts. In Figure 5-8, not only are the 

New England plume and broad Midwest region of high ozone captured, but the area of relative 

minimum ozone across Pennsylvania and New York is also replicated. 

In addition, and perhaps most importantly for New England, it appears that the model correctly 

handles the effect of slight wind trajectory differences on ozone patterns across the southern New 

England coast. Figure 5-8 shows that the CMAQ model correctly predicted high ozone values 

across southern New England, along with a clean area on the south coast caused by marine air 

blowing onshore. A reverse of that pattern is shown in Figure 5-9, in which south coastal New 

England has elevated ozone while values in interior southern New England are low. This typical 

westerly (as opposed to southwesterly) flow scenario draws polluted air from the New York 

City/New Jersey areas eastward along the New England south coast. Air reaching interior 

sections of New England had earlier crossed central New York and thus arrived fairly clean. That 

the model discerned these two episode types and reproduced the north-south gradient is 

encouraging, and gives confidence that the CMAQ model can replicate daily maximum 8-hour 

ozone concentrations in New England. 

Figure 5-6: Maximum 8-Hour Values on August 8, 2002 

46
Figure 5-7: Maximum 8-Hour Values on August 8, 2002 

Figure 5-8: Maximum 8-Hour Values on June 21, 2002 

 

47
Figure 5-9: Maximum 8-Hour Values on July 18, 2002 

Finally, the CMAQ model appears to do a reasonable job of simulating ground level ozone 

diurnal buildup and decay. Figure 5-10 is a time series of observed and modeled peak 8-hour 

ozone values averaged over the domain for the entire modeling period (NYDEC, 2006). 

Figure 5-10: Hourly Ozone Values for 2002 Ozone Season 

Observed and Predicted averages

208 SLAMS/NAMS sites; 40 ppb threshold

0

10

20

30

40

50

60

70

80

90

100

20020515

20020523

20020531

20020608

20020616

20020624

20020702

20020710

20020718

20020726

20020803

20020811

20020819

20020827

20020904

20020912

20020920

20020928

ppb

obs avg, ppb

CMAQ avg, ppb

48
Although an under prediction is evident, it is consistent, and the predictions do track the 

observations well. The model’s under prediction of ozone is not a big concern since CMAQ 

modeling results are to be used in a relative sense, and because the under-prediction is consistent 

over the modeling period and across the modeling domain. 

5.15.3 CMAQ Selected Model Metrics for New England States 

EPA recommends that several statistical metrics be developed for air quality modeling (EPA, 

2007). Two metrics that are most often used to assess performance are mean normalized gross 

error (MNGE) and the mean normalized bias (MNB). The mean normalized gross error provides 

an overall assessment of model performance and can be interpreted as precision, and the mean 

normalized bias parameter measures a model's ability to reproduce observed spatial and temporal 

patterns, and can be interpreted as accuracy. EPA suggests a MNGE of less than 35% above a 

threshold ozone level of 40-60 ppb and a MNB of less than ±15% as a reasonable test for 

acceptable model performance. The MNGE and the MNB for maximum daily 8-hour 

concentrations at or above 60 ppb at Rhode Island ozone monitors for the 2002 CMAQ 

simulation are shown in Table 5-5. 

Table 5-5: Mean Normalized Gross Error and Mean Normalized Bias for RI Ozone Monitors 

State AIRS-ID Location Observed ppb CMAQ ppb MNGE % MNB %

 

RI 440030002 W. Greenwich 77.9 75.7 10.5 -1.8 

RI 440071010 E. Providence 77.6 74.0 10.8 -4.3 

RI 440090007 Narragansett 76.9 83.3 14.9 9.4 

 AVERAGE 12.1 1.1 

Recommended <35% <+15% 

Both of the metrics, MNGE and MNB, are well within the acceptable range at all three of Rhode 

Island’s monitors. 

The MNGE and the MNB for maximum daily 8-hour concentrations at or above 60 ppb at all 

other New England state ozone monitors are listed in Table 5-6. The other New England state 

ozone monitors also meet the MNGE criteria of 35%. The MNB values are above the ±15% 

criteria at two sites in Massachusetts and at several ozone monitoring locations in Vermont and 

New Hampshire. This under-prediction at these monitors is not considered to be a significant 

concern since the 2002 design values at these monitors (Table 5-9 and Table 5-12) are already 

below or close to the ozone NAAQS. In addition, CMAQ modeling results are being used in a 

relative way which helps minimize the under-prediction of peak ozone concentrations. 

49
Table 5-6: Mean Normalized Gross Error and Mean Normalized Bias for Other New 

England Ozone Monitors 

State AIRS-ID Location Observed ppb CMAQ ppb MNGE % MNB %

 

MA 250010002 Truro 76.3 82.8 14.0 9.1 

MA 250034002 Adams 73.6 61.2 16.4 -16.0 

MA 250051002 Fairhaven 74.3 74.6 11.5 1.6 

MA 250090005 Lawrence 80.0 72.3 14.6 -8.0 

MA 250092006 Lynn 80.8 71.6 13.7 -10.7 

MA 250094004 Newbury 79.4 87.6 14.7 10.3 

MA 250130003 Agawam 76.6 67.1 15.1 -11.7 

MA 250130008 Chicopee 76.4 65.2 15.3 -14.0 

MA 250150103 Amherst 73.8 65.6 12.9 -10.9 

MA 250154002 Ware 76.0 66.7 14.9 -11.7 

MA 250171102 Stow 76.3 66.2 13.7 -12.8 

MA 250213003 Milton 79.6 68.3 15.4 -13.7 

MA 250250041 Boston (Long I) 76.7 76.1 17.1 0.2 

MA 250250042 Boston (Harris) 72.4 65.8 12.9 -8.4 

MA 250270015 Worcester 82.7 65.9 19.8 -19.8 

MA AVERAGE 14.8 -7.8 

CT 090010017 Greenwich 78.2 77.8 13.8 0.3 

CT 090011123 Danbury 80.9 73.4 13.4 -8.7 

CT 090013007 Stratford 80.8 80.0 17.1 -0.1 

CT 090019003 Westport 80.7 78.9 12.2 -1.8 

CT 090031003 E. Hartford 77.8 78.6 13.8 2.3 

CT 090050005 Cornwall 78.8 64.5 20.2 -17.8 

CT 090070007 Middletown 80.5 77.9 10.7 -3.7 

CT 090093002 Madison 83.1 83.8 14.5 1.7 

CT 090099005 Hamden 79.4 78.0 13.0 -1.0 

CT 090110008 Groton 75.5 94.4 30.3 28.1 

CT 090131001 Stafford 78.2 71.1 12.2 -8.7 

CT AVERAGE 15.6 -0.9 

NH 330012004 Laconia 70.1 52.7 24.6 -24.6 

NH 330031002 Conway 67.5 52.8 21.8 -21.3 

NH 330050007 Keene 75.9 64.5 15.9 -14.5 

NH 330074001 Mt Washington top 72.3 50.5 30.0 -30.0 

NH 330074002 Mt Washington base 66.7 57.0 17.4 -14.5 

50
State AIRS-ID Location Observed ppb CMAQ ppb MNGE % MNB %

NH 330074003 Pittsburg 68.7 54.7 20.5 -20.5 

NH 330090008 Haverhill 68.0 52.8 22.1 -22.1 

NH 330110020 Manchester 74.5 62.9 15.5 -15.0 

NH 330111010 Nashua 76.1 66.0 13.9 -12.3 

NH 330115001 Peterborough 80.9 60.3 24.7 -24.7 

NH 330130007 Concord 74.2 58.5 20.9 -20.7 

NH 330150012 Rye 78.2 69.6 13.4 -11.1 

NH 330150013 999 73.9 61.9 16.7 -15.3 

NH 330150015 Portsmouth 79.1 72.4 9.7 -8.5 

NH 330173002 Rochester 74.7 64.0 15.5 -14.0 

NH 330190003 Claremont 72.1 55.9 22.2 -22.2 

NH AVERAGE 19.0 -18.2 

VT 500030004 Bennington 70.9 59.2 16.5 -15.7 

VT 500070007 Underhill 74.8 56.1 24.2 -24.2 

VY AVERAGE 20.3 -19.9 

ME 230052003 Cape Elizabeth 76.0 72.4 13.6 -3.1 

ME 230090102 ANP Cadillac M 79.0 70.3 12.8 -10.7 

ME 230090103 ANP McFarland 76.4 69.4 11.6 -8.5 

ME 230090301 Castine 72.3 73.7 10.2 2.8 

ME 230112005 Gardiner Pray 77.3 65.4 17.2 -14.8 

ME 230130004 Port Clyde 73.1 77.1 15.6 5.6 

ME 230173001 North Lovell 67.6 51.8 24.0 -24.0 

ME 230194008 Holden Rider B 74.1 58.7 21.1 -20.3 

ME 230230004 Georgetown 75.6 83.4 12.5 11.0 

ME 230310038 West Buxton 76.8 62.1 19.0 -19.0 

ME 230313002 Kittery 82.3 71.6 15.9 -11.8 

ME 230312002 Kennebunkport 80.3 70.1 13.8 -12.3 

ME 239010001 Scotia Prince Ferry 73.0 64.7 17.8 -11.6 

ME AVERAGE 15.8 -9.0 

51
5.16 CMAQ Model Simulation for 2009 Control Strategy 

5.16.1 CMAQ Model 2009 Application 

The CMAQ 2009 base case simulation was performed by NY DEC in the same manner as the 

CMAQ 2002 base case simulation. The simulation period ran from May 1 to September 30, with 

the first 14 days of May as a ramp-up period to minimize the propagation of the boundary fields 

into areas of concern. The actual CMAQ results for the CMAQ control strategy evaluation were 

from May 15 through September 30. 

5.16.2 CMAQ Input Files for 2009. 

5.16.2.1 Emission Files for 2009 simulation 

The CMAQ 2009 control strategy simulation employed the 2009 CMAQ-ready hourly emission 

files described in Sub-Section 12 for RPO states and Canadian Provinces in the OTR modeling 

domain. These emission files reflect “beyond on the way” (BOTW) controls in all OTR states 

and “on the way controls” (OTW) controls in CENRAP, MRPO and VISTAS states in the OTR 

modeling domain. The 2002 hourly biogenic were also used for 2009 CMAQ simulations since 

significant change in land use would not be expected to occur between 2002 and 2009. 

5.16.2.2 Boundary and Initial Conditions for 2009 simulation 

The 2002 hourly boundary condition files (Section 14) were used for the 2009 future year 

CMAQ simulation. This was considered to be a reasonable and conservative approach since air 

pollution levels and emissions are expected to be lower in 2009. 

5.16.2.3 Meteorological Files for 2009 simulation 

The 2002 hourly meteorological files (Section 14) were used for the 2009 simulation. 

5.16.2.4 Photolysis Rates 

The photolysis rate tables generated for 2002 (Section 14) were used for 2009 simulation. 

5.16.3 CMAQ Output Files 

 

All input and output files for 2009 BOTW CMAQ simulation for the OTR modeling domain are 

listed in Appendix 5S. Files are available in electronic format for the 12km domain from 

NYSDEC for use with the SMOKE/CMAQ system. Please contact NY DEC Gopal Sistla at 518-

402-8402) for data file requests. 

52
5.17 Predicted Design Values for 2009 

5.17.1 Design Values for 2002 Base Case 

Design values at each monitoring site were calculated in accordance with 40 CFR Part 50.10, 

Appendix I. The design value for a three-year period of time is calculated as the 3-year average 

of the fourth highest monitored daily 8-hour maximum value. For example, the design value for 

the 2000-2002 periods is the average of the fourth highest monitored daily 8-hour maximum 

values in 2000, 2001 and 2002. 

For the modeled attainment test, EPA guidance (EPA, 2007) recommends averaging three design 

values that straddle the baseline inventory year (the baseline inventory year is 2002). Therefore, 

the 2002 design value for the attainment demonstration is the average of the “2002 design value” 

(determined from 2000-2002 observations), the “2003 design value” (determined from 2001-

2003 observations), and the “2004 design value” (determined from 2002-2004 observations). 

The 2002 design value (DVC) was calculated in ppb, and carried to 1 significant digit. The 2002 

design values for Rhode Island ozone monitors are listed in Table 5-7 and the 2002 design values 

for the other New England states are shown in Table 5-8 to 5-12. The design values for all other 

ozone monitors in the OTR are listed in Appendix 5T. 

5.17.2 Relative Response Factor for 2009 (RRF) 

In order to minimize the under-prediction or over-prediction of peak ozone concentrations, EPA 

recommends that photochemical grid models be used in a relative way for modeled attainment 

demonstrations (EPA, 2007). Instead of using the absolute modeled results for 2009, EPA 

recommends that the change in predicted ozone concentrations between 2002 and 2009 be used 

for the attainment demonstration. EPA recommends that the 2009 design value be determined 

by multiplying the 2002 design value by a quantity referred to as a relative response factor 

(RRF). The RRF is the ratio of the 2009 ozone prediction divided by the 2002 ozone prediction. 

The EPA guidance requires that an average daily RRF be determined for each monitor using the 

CMAQ model results from grid cells that are at and near a monitor with near being defined as a 3 

by 3 grid array centered on the monitoring station location. For each day, the maximum 

predicted 2002 base case concentration and the maximum predicted 2009 BOTW emission 

scenario concentration are selected from the 3 X 3 grid array surrounding for each monitor. 

Because photochemical models are less responsive to emission reductions on days of lower 

ozone concentrations, EPA guidance recommends applying screening criteria minimize using 

low ozone days when calculating RRFs (EPA, 2007). At least 10 days above 85 ppb are required 

to calculate the RRF at each monitoring location; if 10 days above 85 ppb are not available, EPA 

guidance allows for a smaller number of days at lower ozone concentrations. The minimum 

criterion is 5 days at or above 70 ppb for calculating a meaningful average daily RRF value. 

The detailed criteria for selecting high ozone days and calculating RRFs (to 3 significant digits) 

are described in Appendix 5T. 

53
The 2009 relative response factors (RRFs) calculated for each Rhode Island ozone monitor for 

the 2009 BOTW emission scenario are listed in Table 5-7, and the 2009 RRFs for all other New 

England states are shown in Table 5-8 – 5-12. The RRFs for each ozone monitor in the OTR are 

contained in Appendix 5U. 

5.17.3 Design Values for 2009 

The 2009 future case design value (DVF) for the BOTW emission scenario was determined by 

multiplying the 2002 DVC for each monitor by the 2009 relative response factor (RRF) 

determined for each monitor. After the DVF was calculated, the DVF was truncated at the 

decimal point and then compared to the ozone 8-hour NAAQS. A truncated value at or below 84 

ppb is considered to be a demonstration of modeled attainment (EPA, 2007). 

The 2009 DVFs for Rhode Island monitors are shown in Table 5-7. The highest predicted 2009 

DVF is 81 ppb at the Narragansett site, which is below the modeled attainment test of 84 ppb. 

The 2009 DVFs for other New England states are shown in Table 5-8 – 5-12. The highest 2009 

DVFs in Massachusetts, New Hampshire and Maine, areas that are downwind of Rhode Island, 

are 82 ppb, 74 ppb and 79 ppb, also below the modeled attainment test of 84 ppb. The 2009 

DVFs for all ozone monitors in the OTR for the 2009 BOTW emission scenario are contained in 

Appendix 5U. 

Table 5-7: 2009 Design Values (DVF) in Rhode Island for 2009 BOTW Emission Scenario 

State AIRS-ID Location DVC RRF 2009 DVF 2009 

 

RI 440030002 West Greenwich 93.3 0.862 80 

RI 440071010 East Providence 89.7 0.868 77 

RI 440090007 Narragansett 93.3 0.876 81 

Table 5-8: 2009 Design Values (DVF) in Massachusetts for 2009 BOTW Emission Scenario 

State AIRS-ID Location DVC RRF 2009 DVF 2009 

 

MA 250010002 Truro 92.0 0.877 80 

MA 250034002 Adams 83.3 0.877 73 

MA 250051002 Fairhaven 91.0 0.878 79 

MA 250090005 Lawrence 70.0 0.880 61 

MA 250092006 Lynn 90.0 0.916 82 

MA 250094004 Newbury 86.0 0.882 75 

MA 250130003 Agawam 83.0 0.873 72 

MA 250130008 Chicopee 92.0 0.872 80 

MA 250150103 Amherst 74.7 0.874 65 

MA 250154002 Ware 86.3 0.873 75 

54
MA 250171102 Stow 85.7 0.870 74 

MA 250213003 Milton 91.0 0.911 82 

MA 250250041 Boston (Long I) 88.7 0.909 80 

MA 250250042 Boston (Harris) 73.0 0.908 66 

MA 250270015 Worcester 84.0 0.863 72 

Table 5-9: 2009 Design Values (DVF) in New Hampshire for 2009 BOTW Emission 

Scenario 

State AIRS-ID Location DVC RRF 2009 DVF 2009 

 

NH 330012004 Laconia 76.5 below criteria below criteria 

NH 330031002 Conway 67.0 below criteria below criteria 

NH 330050007 Keene 74.3 0.865 64 

NH 330090008 Haverhill 70.3 below criteria below criteria 

NH 330111010 Nashua 86.0 0.867 74 

NH 330115001 Peterborough 84.0 0.873 73 

NH 330130007 Concord 74.7 below criteria below criteria 

NH 330150012 Rye 83.5 0.869 72 

NH 330150013 Rockingham 80.0 0.858 68 

NH 330150015 Portsmouth 68.0 0.869 59 

NH 330173002 Rochester 78.5 0.860 67 

NH 330190003 Claremont 74.3 below criteria below criteria 

Table 5-10: 2009 Design Values (DVF) in Connecticut for 2009 BOTW Emission Scenario 

State AIRS-ID Location DVC RRF 2009 DVF 2009 

6 7 

CT 090010017 Greenwich 95.7 0.913 87 

CT 090011123 Danbury 95.7 0.897 85 

CT 090013007 Stratford 98.3 0.919 90 

CT 090019003 Westport 94.0 0.909 85 

CT 090031003 E. Hartford 88.0 0.876 77 

CT 090050005 Cornwall 89.0 0.870 77 

CT 090070007 Middletown 95.7 0.888 84 

CT 090093002 Madison 98.3 0.905 88 

CT 090099005 Hamden 93.3 0.912 85 

CT 090110008 Groton 90.0 0.879 79 

CT 090131001 Stafford 92.3 0.867 80 

55
Table 5-11: 2009 Design Values (DVF) in Maine for 2009 BOTW Emission Scenario 

State AIRS-ID Location DVC RRF 2009 DVF 2009 

 

ME 230038001 Ashland135 64.0 below criteria below criteria 

ME 230052003 Cape Elizabeth 84.3 0.873 73 

ME 230090102 ANP Cadillac M 91.7 0.869 79 

ME 230090103 ANP McFarland 83.7 0.871 72 

ME 230090301 Castine 75.0 0.879 65 

ME 230112005 Gardiner Pray 78.0 0.869 67 

ME 230130004 Port Clyde 83.7 0.871 72 

ME 230173001 North Lovell 60.7 below criteria below criteria 

ME 230194007 Howland 66.7 below criteria below criteria 

ME 230194008 Holden Rider B 79.0 below criteria below criteria 

ME 230310038 West Buxton 75.0 0.860 64 

ME 230312002 Kennebunkport 88.3 0.875 77 

ME 230313002 Kittery 85.3 0.869 74 

Table 5-12: 2009 Design Values (DVF) in Vermont for 2009 BOTW Emission Scenario 

State AIRS-ID Location DVC RRF 2009 DVF 2009 

 

VT 500030004 Bennington 79.7 0.883 70 

VT 500070007 Underhill 77.0 below criteria below criteria 

5.18 Estimating Design Values at Unmonitored Locations 

5.18.1 Rhode Island Ozone Monitoring Network 

Based on our understanding of ozone formation, transport, and destruction and the size of the 

State, RI DEM considers Rhode Island’s network of ozone monitors to be adequate for 

measuring the highest ozone values occurring in the State. . 

Generally, ozone production via chemical transformation occurs some distance downwind of 

areas containing significant precursor emissions. What happens still farther downwind depends 

on the number and size of precursor emission sources in that area. If it lacks such sources, ozone 

will eventually be depleted because of its high reactivity (provided transport is over land). It 

would then follow that, in areas where ozone levels drop off, additional monitoring would be 

unnecessary. 

The primary source of ozone in Rhode Island is the stream of pollution from upwind states to the 

southwest. This is evidenced by the fact that ozone levels at the W. Greenwich monitor, which is 

in a rural area in the southwest portion of the State, upwind of the high population density, high 

56
emissions areas of Rhode Island, generally records higher ozone concentrations than those at the 

E. Providence site, which is downwind of the Providence metropolitan areas. Therefore, RI DEM 

believes that additional monitoring coverage in Rhode Island is unnecessary. 

5.18.2 Future Year Design Values at Unmonitored Locations 

Since VOC and NOx emissions are trending lower in Rhode Island and elsewhere in the region, 

RI DEM believes that using design values from the 2002 network to construct future year design 

values provides a reasonable estimate of maximum predicted design values in Rhode Island for 

2009 and beyond. 

5.19 Weight of Evidence 

EPA modeling guidance provides that a state include in its attainment demonstration additional 

evidence to support its modeling analysis and to better assess the likelihood of attainment. EPA 

will review all of the evidence and make its determination as to the likelihood that the area will 

attain the ozone standard in the attainment year based on the entire “weight of evidence”(WOE). 

A WOE analysis must be included in the attainment demonstration when the modeling is deemed 

“inconclusive”. EPA’s guidance establishes the “inconclusive” range for 8-hour ozone 

modeling results at 82 ppb through 87 ppb for the required attainment year. If all predicted future 

design values for a State are less than 82 ppb, only a basic supplemental analysis is required to 

confirm the outcome of the modeling. Since the highest modeled design value for 2009 in Rhode 

Island is 81 ppb, Rhode Island falls into the latter category, and only a basic supplemental 

analysis is required. 

5.19.1 Air Quality Trends 

Figure 5-11 displays Rhode Island ozone design values from 2002-2007. For comparison, the 

predicted design values for the 2009 BOTW emission scenario were inserted on the chart. The 

graphs suggest that Rhode Island is on track to meet the ozone NAAQS (85 ppb) by 2009. 

57
Figure 5-11: Design Value Trends for Rhode Island 

5.19.2 Emission Trends 

The principal precursors for ozone are NOx and VOCs. Substantial NOx and VOC emission 

reductions will take place between 2002 and 2009 in the OTR. Most of these reductions are 

associated with the NOx SIP Call, CAIR, federal on-road and non-road fuels, federal motor 

vehicle standards and state LEV (Low Emission Vehicle) programs, federal MACT rules, 2001 

OTC model rules for consumer products, architectural coatings, distributed generation and many 

state-specific rules in effect by 2009. In addition to these reductions, new 2006 OTC 

recommended control measures previously discussed in Section 11 (BOTW emission scenario) 

will provide for additional reductions by 2009. Finally, on-road and non-road federal motor 

vehicle control measures will provide substantial additional reductions between 2009 and 2012. 

MANE-VU state emission inventory totals for 2002 and 2009 are shown in Table 5-13. NOx 

and VOC emissions for MANE-VU states (which include all of OTR states except for Virginia) 

trend downward between 2002 and 2012. Rhode Island’s annual NOx and VOC emissions are 

estimated to go down by 26% and 22%, respectively, between 2002 and 2009. Similar emission 

reductions are taking place in states upwind of Rhode Island. NOx and VOC emissions in 

Connecticut, New York and New Jersey are estimated to go down by 33% and 24%, 

respectively, in that time period. . 

58
Table 5-13: MANE-VU Anthropogenic Emissions for 2002 and 2009 

NOx VOC 

2002 (tpy) 2009 (tpy) % decrease 2002 (tpy) 2009 (tpy) % decrease 

Connecticut 125,208 82,139 34 162,492 122,353 25 

Delaware 58,764 49,658 15 41,120 32,109 22 

District of Columbia 15,389 10,433 32 14,893 10,403 30 

Maine 94,932 60,201 37 166,501 141,619 15 

Maryland 283,387 147,710 48 265,220 205,097 23 

Massachusetts 276,530 180,391 35 294,703 229,386 22 

New Hampshire 67,326 44,339 34 111,333 94,330 15 

New Jersey 303,053 185,314 39 378,877 285,559 25 

New York 655,774 456,457 30 921,593 710,567 23 

Pennsylvania 806,061 518,109 36 594,355 477,042 20 

Rhode Island 29,418 21,900 26 57,200 44,612 22 

Vermont 28,290 17,793 37 50,461 43,063 15 

Total 2,744,133 1,774,443 35 3,058,749 2,396,138 22 

5.19.3 Extra Ozone Reductions 

Rhode Island will be in monitored attainment of the 8-hour ozone NAAQS if design values at all 

three of the State’s monitors are 84 ppb or less in 2009. The model predicts design values for 

that year that are significantly below that target (80 ppb for W. Greenwich, 77 ppb for E. 

Providence and 81 ppb for Narragansett). This provides a margin of safety for attaining the 

standard, even if monitored values are somewhat higher than those predicted by the model. 

5.20 Conclusions 

The above attainment demonstration demonstrates that reductions in ozone precursor emissions 

in Rhode Island and upwind of Rhode Island will result in statewide attainment of the 8-hour 

ozone NAAQS by 2009. The attainment demonstration was based on SIP-quality CMAQ ozone 

modeling results for 2002 and 2009. The attainment demonstration consisted of choosing a base 

year (2002) to test model performance and then rerunning the model using a future year emission 

scenario (2009) in order to determine the predicted reductions in ozone calculated levels in and 

downwind of Rhode Island. 

The 2002 ozone season was selected as the base year for OTR attainment demonstrations 

because a significant number of exceedance days were recorded that year over the eastern United 

States. A multi-year review of elevated ozone days in the OTR indicted that meteorological 

regimes associated with high ozone levels also occurred during 2002. In other words, 2002 

meteorology contained a good set of meteorological conditions for testing the effectiveness of 

ozone control strategies. The 2002 CMAQ model run results indicated that the CMAQ model 

was performing adequately and was acceptable for simulating future year emission scenarios in 

and downwind of Rhode Island. 

59
In 2006, all states in the OTR modeling domain prepared future year emission inventories for 

2009 by applying growth and control measures to 2002 base year emission inventories. The 

control measures reflected controls programs that were already on the way and in effect by 2009. 

These emission inventories, referred to as “on the way” emission inventories, reflect the NOx 

SIP Call and CAIR requirements, federal on-road and non-road fuels, federal motor vehicle 

standards and state LEV (Low Emission Vehicle) programs, 2001 OTC model rules for 

consumer products, architectural coatings, distributed generation and any other state-specific 

rules in effect by 2009. In addition, OTC states prepared a “beyond on the way” (BOTW) 

emission inventory for selected non-EGUs and nonpoint sources in the OTR. The BOTW 

emissions reflect new OTC 2006 model rules for several source categories in OTR states. The 

BOTW control measures were developed because preliminary ozone modeling efforts indicated 

additional controls would be needed to attain the 8-hour ozone NAAQS in portions of the OTR. 

The CMAQ model was run using emission input files prepared for the 2009 emission scenario 

(“on the way” emissions throughout the OTR modeling domain and “beyond on the way” control 

measures in OTC states). The 2009 and 2002 modeling results were then compared to determine 

the percent reduction in ozone levels between 2002 and 2009. The percent reduction was applied 

to the 2002 ozone design value at each ozone monitoring location in the OTR in order to 

calculate a design value for 2009. The maximum 2009 design value in Rhode Island was 81 ppb, 

indicating that Rhode Island will attain the ozone NAAQS (85 ppb) with “on the way” control 

measures throughout the OTR modeling domain and “beyond on the way” control measures in 

OTC states. 

Ozone air quality trends and ozone precursor trends also indicate that Rhode Island will be in 

attainment with the 8-hour ozone NAAQS. Based upon ozone modeling results, ozone air 

quality trends and ozone precursor trends, RI DEM expects that the State of Rhode Island will 

attain the 8-hour ozone NAAQS by 2009. 

60
6.0 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) 

6.1 Purpose of Section 

The CAA requires moderate and above ozone nonattainment areas to adopt rules that require 

Reasonably Available Control Technology (RACT) for applicable sources. To facilitate this 

process, EPA issued three sets of Control Techniques Guideline (CTG) and Alternate Control 

Techniques (ACT) documents, which delineate measures for controlling VOC and NOx 

emissions from stationary sources. Under the CAAA, RACT is required in moderate and above 

nonattainment areas for sources covered by a CTG and for non-CTG major sources. RI DEM 

demonstrated in its March 2003 attainment demonstration for the one-hour ozone NAAQS that 

Rhode Island had fulfilled that requirement. 

The Phase 2 8-Hour Ozone Implementation rule requires states to assure that RACT continues to 

be met in nonattainment areas, either through a certification that previously adopted one-hour 

ozone SIP approved RACT controls represent RACT for 8-hour implementation purposes or 

through adoption of more stringent regulations consistent with RACT. In this section RI DEM is 

certifying that all RACT measures adopted and in effect in Rhode Island pursuant to the 1-hour 

ozone standard continue to constitute RACT under the 8-hour ozone standard, except for the 

following categories: solvent metal degreasing and asphalt paving. For these categories, RI DEM 

has concluded that RACT measures previously adopted no longer constitute RACT and is 

committing to promulgate revised regulations that will further reduce emissions from applicable 

sources. Rhode Island RACT source categories and point sources for which source-specific 

RACT determinations have been made are listed in Tables 6-1 and 6-2. 

6.2 1-Hour Ozone Standard RACT 

6.2.1 Pre-1990 VOC RACT Requirements 

 

Prior to the 1990 CAAA, RACT requirements were governed by CAA Section 172(c), which 

provides that non-attainment areas must implement ... “all reasonably available control measures 

[RACM]...including such reductions in emissions from existing sources in the area as may be 

obtained through the adoption ... of reasonably available control technology [RACT].” EPA 

defined RACT as “the lowest emission limit that a polluting source is capable of meeting if it 

uses pollution control equipment and/or material or process changes that are reasonably available 

considering costs and current technology.” (44 FR 53762, September 17, 1979) 

To assist states with implementation of RACT, EPA issued Control Technique Guidelines 

(CTGs) for several categories of VOC sources.15 CTGs establish a ``presumptive norm'' for 

RACT for the VOC source category addressed. Some CTGs cover only major16 sources of VOC 

 

15. Prior to the 1990 CAA Amendments, EPA issued three sets of CTG documents: Group 1: 15 CTGs issued before 

January 1978; Group 2: 9 CTGs issued in 1978; and Group III: 5 CTGs issued in the early 1980s. (A list of all 

CTGs, as compiled by EPA, is in Table 6-1.) 

16. The emission threshold for a major source varies. Prior to the 1990 CAA Amendments, major VOC sources were 

those with a potential to emit >100 tons of VOCs per year. After the 1990 Clear Air Act amendments, major source 

thresholds for VOC and NOx were tied to a non-attainment areas classification and whether the state is located 

61
emissions. Other CTGs apply at thresholds below the major source level. In addition, states 

were required to adopt RACT controls for all major sources of VOCs, whether or not they were 

within a CTG source category. 

6.2.2 1990 CAA Amendments (CAAA) 

The 1990 CAAA made the general Section 172 RACT requirements more specific. Amendments 

to section 182(a)(2)(A) required that ozone non-attainment areas classified as marginal or above 

“fix” any deficient VOC RACT rules by May 1991. A new provision, Section 182(f), required 

states to adopt RACT for all major stationary NOx sources. Amendments to Section 184, which 

addresses control of ozone in an Ozone Transport Region, lowered the major source applicability 

threshold of RACT for states within the OTR from sources with a potential to emit 100 tons of 

VOC per year to sources with a potential to emit 50 tons per year. 

To assist states with NOx RACT implementation, EPA issued Alternative Control Technology 

Documents (ACTs), which provide analyses of the reductions that can be achieved with various 

controls at various levels of stringency, and the costs per ton to achieve those levels of control. 

Unlike CTGs, ACTs do not establish a presumptive RACT level of control. 

6.2.3 Rhode Island 1-Hour RACT Compliance 

During the late 1970s and the 1980s, RI DEM adopted and from time-to-time amended Air 

Pollution Control (APC) regulations which limited emissions from VOC sources consistent with 

EPA’s pre-1990 CTGs. Those regulations include: APC Regulation No. 11, “Petroleum Liquids 

Marketing and Storage,” No. 18 (later superseded by APC Regulation No. 36), “Control of 

Organic Solvent Cleaners,” No. 19, “Control of Volatile Organic Compounds from Surface 

Coating Operations,” and No. 21, “Control of Volatile Organic Compound Emissions from 

Printing Operations.” EPA approved these regulations as meeting RACT and incorporated them 

into the Rhode Island ozone SIP.17

 

The CTGs issued by EPA and the Rhode Island regulation that was adopted to meet the 

presumptive level of RACT established in the CTG for RACT is listed in Table 6-1. If there were 

no facilities within a CTG source category in the State, RI DEM submitted a “negative 

declaration” to EPA. The negative declaration categories are also listed in Table 6-1. 

For major sources not in a CTG category, RI DEM adopted APC Regulation No. 15, “Control of 

Organic Solvent Emissions,” which requires RACT controls for major non-CTG sources through 

single-source RACT SIPs. EPA approved RI DEM’s single-source RACT determinations 

pursuant to APC Regulation No. 15 as part of the Rhode Island SIP. The facilities subject to 

single-source RACT agreements are listed in Table 6-2. 

The 1990 CAAA required states to adopt “fix up” and “catch up” measures to ensure that all 

areas classified as moderate or above nonattainment areas are subject to requirements equivalent 

 within an ozone transport region. In Rhode Island, sources that have the potential to emit at least 50 tons per year of 

VOC or NOx are considered major sources.

17 See 40 CFR 52.2062 for a complete list of the EPA-approved Rhode Island SIP revisions, including those related 

to RACT regulations and determinations. 

62
to those specified in the CTGs and to reduce the non-CTG RACT major source applicability 

threshold form 100 tons to 50 tons of VOC emissions per year. To comply with these 

requirements, RI DEM adopted or amended the following regulations: APC Regulation No. 15, 

“Control of Organic Solvent Emissions,” No. 19, ``Control of Volatile Organic Compounds from 

Surface Coating Operations,'' No. 21, “Control of Volatile Organic Compound Emissions from 

Printing Operations,” No. 25, ``Control of Volatile Organic Compound Emissions from Cutback 

and Emulsified Asphalt,'' and No. 26, ``Control of Volatile Organic Compound Emissions from 

Manufacture of Synthetic Pharmaceutical Products,'' No. 30, “Control of VOCs from 

Automotive Refinishing Operations,” No. 35, “Control of VOC and Volatile Hazardous Air 

Pollutants from Wood Products Manufacturing Operations” and No. 36, “Control of Emissions 

from Organic Solvent Emissions.” These amended and new regulations were submitted to the 

EPA and approved as amendments to the SIP (see dates in Table 6-1). 

To address the 1990 CAAA NOx RACT requirement, RI DEM adopted APC Regulation No. 27, 

“Control of Nitrogen Oxide Emissions,” on February 1, 1994. That regulation, which required 

sources which have the potential to emit 50 tons or more per year of NOx to submit RACT plans, 

was approved by EPA as a SIP revision in 1997 (62 FR 42602). RACT plans prepared to 

comply with this requirement were submitted as single-source SIP revisions and are listed in 

Table 6-2. 

Rhode Island has adopted all RACT rules and submitted all RACT determinations necessary to 

comply with 1-hour ozone standard RACT requirements. 

6.3 8-Hour Ozone Standard RACT Requirements 

6.3.1 Required Analysis 

EPA’s Phase 2 Rule states that: 

Where a State has adopted, and EPA has approved, a control measure as RACT 

for a specific major stationary source or source category for the 1-hour ozone 

NAAQS and absent data indicating that the previous RACT determination is no 

longer appropriate, the State may submit a certification that the source is subject 

to a SIP-approved RACT requirement (70 FR 71652). 

Subsequent to the issuance of the Phase 2 Rule, EPA developed a set of questions and answers 

(Q&A) to further explain 8-hour ozone standard RACT SIP requirements. The Q&A document 

states that, in order for a state to certify that previously required RACT controls or newly applied 

controls represent RACT for 8-hour ozone standard purposes, a state should evaluate RACT for 

a source or source category by examining EPA guidance and other information. When a state 

concludes that the existing level of control is RACT and that no control is required beyond what 

was required for the 1-hour standard, it must submit its conclusions in its RACT SIP. 

The state may address RACT through adoption of rules, submission of permits or through 

negative declarations stating that there are no sources subject to RACT. If the state determines 

63
that additional controls are needed to meet 8-hour ozone standard RACT requirements, the 

controls must be made federally enforceable through a SIP revision. Any new RACT 

requirements must be implemented no later than May 1, 2009. 

 

As required by the Phase 2 Rule, RI DEM has reviewed its current RACT requirements. It has 

determined that VOC controls previously adopted as RACT for CTG source categories and nonCTG major sources still constitute RACT for 8-hour ozone standard purposes, except for two 

source categories - solvent metal degreasing and asphalt paving. It has also determined that 

RACT controls adopted for major sources of NOx continue to constitute RACT. RI DEM has, 

therefore, certified in Tables 6-1 and 6-2 that its current RACT requirements are consistent with 

8-hour RACT, except for the categories of solvent metal degreasing and asphalt paving. RI DEM 

is committing to submit revisions to the regulations for solvent metal degreasing and asphalt 

paving (APC Regulations No. 36 and 25, respectively) by January 1, 2009 and that the amended 

regulations will be effective by April 1, 2009.

6.4 VOC RACT Analysis 

6.4.1 CTGs 

As noted under the 1-hour RACT discussion, a state regulation imposing VOC controls that met 

EPA’s presumptive CTG control levels met 1-hour RACT requirements. Table 6-1 lists the 

VOC source categories for which EPA issued CTGs and the corresponding RI DEM APC 

regulation for each of these categories. For all CTG categories for which there are applicable 

sources in Rhode Island, RI APC regulations either incorporated the CTG recommended controls 

or achieved a level of control equivalent to those specified in the CTGs and were, as such, 

approved by EPA as meeting 1-hour RACT. Note that Regulations No. 11 and 25 were amended 

in 2001 to update control requirements. Those amendments were submitted to the EPA in 

January 2001 but have not as yet been approved as SIP revisions. Note also that virtually all of 

the APC regulations were modified in 2007; these modifications were primarily administrative in 

nature, e.g. the removal of the definitions of certain terms previously defined in more than one 

regulation to a separate definitions regulation. The updated versions of these regulations will be 

submitted as SIP revisions to the EPA in 2008. 

RI DEM has reviewed the APC regulations for all sources subject to CTGs and has determined 

that, with two exceptions, the levels of control required by these regulations continue to 

constitute VOC RACT under the 8-hour ozone standard. Pursuant to the requirement of the 

Phase 2 Rule, RI DEM certifies in Table 6-1 that the level of control in the current regulatory 

requirements for all CTG categories for which there are Rhode Island sources except solvent 

metal degreasing and asphalt paving are consistent with 8-hour RACT. 

Table 6-1 also lists the CTG categories for which there are no Rhode Island sources; RI DEM is 

making a negative declaration for those CTG categories. In making this determination, RI DEM 

reviewed its 2002 stationary point source inventory database for facilities with North American 

Industrial Classification System (NAICS) codes that correspond to the CTG categories and 

consulted relevant inspection and permitting records. 

64
6.4.2 New CTGs 

 

In October 2006, EPA adopted new CTGs for the following five source categories: Lithographic 

Printing Materials, Letterpress Printing Materials, Flexible Packaging Printing Materials, Flat 

Wood Paneling Coatings and Industrial Cleaning Solvents. (71 FR 58745, October 5, 2006) 

States are required to submit SIP revisions incorporating requirements of a new CTG for which 

there are sources in the state within one year of EPA’s promulgation of the final CTG. 

RI DEM has identified one source in Rhode Island that is subject to the Flat Wood Paneling 

CTG. The coating lines at that facility received preconstruction permits from RI DEM in 2000. 

Although the emissions limits established in that permit reflected Best Available Control 

Technology (BACT) at that time, they are not as stringent as those recommended in the CTG. 

Therefore, RI DEM is committing to revise APC Regulations No. 19, “Control of Volatile 

Organic Compounds from Surface Coating Operations,” and Regulation No. 35, “Control of 

Volatile Organic Compounds and Volatile Hazardous Air Pollutants from Wood Products 

Manufacturing Operations,” to make the requirements for flat wood paneling sources in Rhode 

Island consistent with the provisions of the 2006 Control Technique Guideline. These 

amendments will be submitted to the EPA as a SIP revision by January 1, 2009 and will be 

effective by April 1, 2009. 

 

The CTG for Industrial Cleaning Solvents contains VOC content, operations and equipment 

requirements for all industrial cleaning categories and operations18 that have VOC emissions of 

at least 15 lb/day. The requirements in APC Regulation No. 36 are, for the most part, consistent 

with the requirements in the new CTG, with the exception of a solvent vapor pressure limit for 

cold cleaners, which is in the CTG but not in Regulation No. 36. RI DEM plans to amend APC 

Regulation No. 36 to include that requirement. With that amendment, the requirements in APC 

Regulation No. 36 will be consistent with the new CTG. That amendment will be submitted to 

the EPA as a SIP revision by January 1, 2009 and will be effective by April 1, 2009. This source 

category is discussed further in Section 6.6.1. 

RI DEM has not yet determined whether its existing regulations include controls that are 

equivalent to the new CTGs for the three printing categories. RI DEM plans to survey 

potentially applicable sources in these categories in the first quarter of calendar year 2008 to 

define the universe of sources applicable to these CTGs in the State and to determine, in 

consultation with the EPA, whether the existing Rhode Island regulations provide for controls 

equivalent to those specified in the new CTGs. If deficiencies are identified, RI DEM will amend 

its existing regulations to ensure that requirements for sources in those categories meet the 

presumptive RACT limits established in these new CTGs Amended regulations, if needed, will 

be submitted to the EPA as a SIP revision by January 1, 2009 to be effective by April 1, 2009. 

 

18 EPA states that all operations evaluated to date by EPA can be categorized under one of the nine “Unit 

Operations” (UO) identified in the CTG: Spray Gun Cleaning; Spray Booth Cleaning; Large Manufactured 

Components Cleaning; Parts Cleaning; Equipment Cleaning; Line Cleaning; Floor Cleaning; Tank Cleaning; and 

Small Manufactured Components Cleaning. 

65
On October 9, 2007, EPA issued new CTGs for the following source categories: paper, film, and 

foil coatings; metal furniture coatings, and large appliance coatings. RI DEM will analyze the 

CTGs to determine whether there are applicable sources in Rhode Island and will amend its 

regulations as necessary so that control requirements for applicable Rhode Island source 

categories are consistent with those in the CTG. All regulatory amendments will be submitted to 

the EPA as SIP revisions by January 1, 2009 to be effective by April 1, 2009. 

6.4.3 Non-CTG Major VOC Sources 

As previously discussed, States must require RACT controls for all non-CTG major VOC 

sources. APC Regulation No. 15, “Control of Organic Solvent Emissions,” established 

requirements for major facilities not covered by a CTG. RACT specifications for each such 

facility are delineated in an emission control plan specific to that facility. RI DEM issued a 

number of single-source RACT determinations pursuant to APC Regulation No. 15. The singlesource VOC RACT determinations, which were approved by EPA as part of the Rhode Island 

SIP, are listed in Table 6-2 along with the date of approval and the current status of the facility. 

For facilities that are still operating, RI DEM has concluded that the controls specified in the 

single-source agreements constitute RACT under the 8-hour standard. 

6.5 NOx RACT Analysis 

RI DEM’s APC Regulation No. 27, “Control of Nitrogen Oxide Emissions,” requires RACT for 

stationary sources emitting 50 or more tons per year of NOx. The regulation includes specific 

emissions limits for utility boilers, industrial-commercial-institutional boilers and internal 

combustion engines and requires all applicable sources to submit RACT plans to RI DEM which, 

after review, are incorporated into an enforceable agreement. The enforceable agreement is then 

submitted to the EPA as a single-source RACT determination. Single-source NOx RACT 

determinations issued by RI DEM pursuant to APC Regulation No. 27 and submitted to the EPA 

as source-specific SIP revisions are listed in Table 6-2. RI DEM certifies that APC Regulation 

No. 27 and the single-source NOx RACT SIP revisions listed in Table 6-2 are consistent with 

RACT requirements for the 8-hour ozone NAAQS. 

In addition to the requirements in APC Regulation No. 27, electric generation units (EGUs) and 

large industrial boilers in Rhode Island are also subject to APC Regulation No. 41, “NOx Budget 

Trading Program,” which caps emissions of NOx from covered sources for the 2003 through 

2008 ozone seasons. This regulation was adopted in 1999 to meet the requirements of EPA’s 

NOx SIP Call (63 CFR 61712). EPA’s Phase 2 Rule provides that compliance with the NOx SIP 

Call, regardless of the manner of compliance by individual sources (e.g. control equipment 

installation or purchase of allowances from other sources), constitutes RACT. States need not 

submit 8-hour RACT analyses for sources in compliance with a SIP meeting the NOx SIP Call. 

EPA determined that the Rhode Island NOx Budget Program met the NOx SIP Call and 

approved it as part of the Rhode Island 1-hour Ozone SIP. Therefore, RI DEM certifies that all 

NOx sources regulated by APC Regulation No. 41 meet 8-hour ozone RACT requirements for 

2003 - 2008. 

66
These sources and the NOx allowances allocated to each source in APC Regulation No. 41 for 

the control periods (May 1 – September 30) in 2003 through 2008 are as follows: 

Ocean State Power 275 tons 

Pawtucket Power 42 tons 

Manchester Street 262 tons 

Tiverton Power 46 tons 

Rhode Island State Energy Center 52 tons 

Total allocation: 677 tons 

The quantity of allowances allocated to each of the above sources is equal to the potential to emit 

for that source for the control period. Therefore for 2009 and beyond the nitrogen oxides 

emissions from the five existing power plants cannot exceed the 677 ton cap that had been in 

place from the NOx Budget Trading program. 

These five power plants are the only sources in Rhode Island that are subject to the NOx Budget 

Trading Program. No new EGUs have been permitted since the promulgation of APC 

Regulation No. 41. RI DEM has not yet determined how it will regulate new sources to ensure 

that NOx SIP call requirements continue after 2008. 

As discussed in Section 5.11.2, the OTC identified potential additional control measures for ICI 

boilers at major sources in its February 2007 document entitled “Identification and Evaluation of 

Candidate Control Measures, Final Technical Support Document,” which is attached as 

Appendix 5k. RI DEM examined the OTC recommendations and determined that adoption of 

additional controls for that source category would yield minimal emissions reductions in Rhode 

Island and are not cost effective. The OTC estimated in the above document that implementation 

of its recommended ICI boiler control measures would reduce summer day NOx emissions in 

Rhode Island by 0.5 tons. Almost all of the ICI boilers located at major sources in Rhode Island 

are currently equipped with low-NOx burners with flue gas recirculation. Replacing that 

equipment to meet the recommended OTC limits would require the facilities to incur substantial 

expenses while only marginally reduce emissions. Such a requirement would also create a 

substantial administrative burden for RI DEM with minimal effect. Therefore, it is not 

economically reasonable to require this measure in Rhode Island. 

 

6.6 RACT Revisions 

RI DEM has determined that its existing solvent metal degreasing and asphalt paving regulations 

do not constitute RACT under the 8-hour ozone standard and will revise its regulations for these 

categories to require additional VOC controls, as discussed below. 

6.6.1 Solvent Degreasing 

The CTG covering solvent metal degreasing applies to units that clean/degrease metal in three 

types of systems - cold cleaning, open top vapor degreasers and conveyorized degreasers. The 

control measures specified in the CTG for this sector are largely equipment and operating 

67
practice specifications rather than emission limits. APC Regulation No. 36 is consistent with, or 

more stringent than, those requirements. 

However, APC Regulation No. 36 does not include vapor pressure limits on solvents used in 

cold cleaning consistent with the CTG and with the model rule for this source category 

developed by OTC and adopted by several OTC states. Therefore, RI DEM has determined that 

APC Regulation No. 36 is not currently consistent with RACT and is committing to amend that 

regulation accordingly. The amendment will be submitted to the EPA as a SIP revision by 

January 1, 2009 and will be effective by April 1, 2009. With this revision, Rhode Island will 

meet 8-hour RACT control requirements for this source category. 

6.6.2 Asphalt Paving 

Asphalt paving is used to pave, seal and repair surfaces such as roads, parking lots, and 

walkways. Asphalt paving is grouped into three general categories: hotmix, cutback, and 

emulsified. Hot-mix asphalt, the most commonly used paving asphalt, produces minimal VOC 

emissions. Cutback asphalt is prepared by blending asphalt cement with a diluent, typically from 

25 to 45 percent by volume of petroleum distillates. Emulsified asphalt is a lower emitting 

alternative to cutback asphalt; emulsified asphalts use a blend of asphalt cement, water and an 

emulsifying agent, such as soap. Some emulsified asphalts may contain virtually no VOCs; 

others may contain up to 12% VOC by volume. 

The EPA published a CTG for the use of cutback asphalt in December 1977. The CTG 

recommended replacing cutback asphalt binders with emulsified asphalt during the ozone season. 

In 1979, EPA added a specification for emulsified asphalt to the CTG recommendations to limit 

the content of oil distillate in emulsified asphalt to no higher than 7 percent oil distillate. APC 

Regulation No. 25, “Control of Volatile Organic Compound Emissions from Cutback and 

Emulsified Asphalt,” which was adopted in November 1992, contains requirements that are at 

least as stringent as those in the CTG for this source category and which met 1-hour RACT. It 

bans the use of cutback asphalt during the ozone season, but with a number of exceptions, and 

limits the VOC content of emulsified asphalt to 3 – 12%, depending on the type of application. . 

During its review of additional control measures that states should consider adopting as part of 

the OTC regional 8-hour ozone attainment strategy, the OTC identified asphalt paving as a 

category where further VOC emission reductions could be achieved. It developed a model rule 

for this source category that prohibits the use of cutback asphalt during the ozone season and 

limits the use of emulsified asphalt to that which contains not more than 0.5 mL of oil distillate 

from a 200 mL sample (as determined using American Society for Testing and Materials 

Methods) regardless of application. This is equivalent to a VOC content of 0.25 percent. 

RI DEM will propose an amendment to APC Regulation No. 25 to eliminate all exceptions to the 

ozone season ban on use of cutback. It will also propose to limit the VOC content of emulsified 

asphalt to the level proposed in the OTC model rule, or to the most stringent level that is 

determined to be feasible in Rhode Island. Upon completion of this rule amendment process, 

Rhode Island will meet 8-hour RACT control requirements for this source category. RI DEM 

68
69

will submit the amended regulation to the EPA as a SIP revision by January 1, 2009. The 

revised requirements will be effective by April 1, 2009. 

6.6 Conclusions 

By complying with 1-hour ozone standard RACT requirements, emissions of VOCs and NOx 

from stationary point and nonpoint sources have decreased significantly over the past 30 years. 

In order to meet the 8-hour ozone standard RACT requirements, RI DEM is committing to 

further reduce VOC emissions for the source categories solvent metal degreasing and asphalt 

paving by adopting revised regulations that will be submitted as SIP revision to the EPA by 

January 1, 2009 with an effective date no later than April 1, 2009. 

RI DEM intends to review the three printing CTGs finalized by EPA in October 2006 and, if 

necessary, to propose new regulatory requirements for these source categories. Amendments 

would be submitted to the EPA as SIP revisions by January 1, 2009 and would be effective by 

April 1, 2009. RI DEM will also review the CTGs for paper, film and foil coating, metal 

furniture coating and large appliance coating issued in October 2007 and, if applicable, submit 

appropriate SIP revisions relative to these source categories by January 1, 2009 with any 

amended control requirements effective on April 1, 2009. For each CTG for which RI DEM 

determines that are not applicable in Rhode Island, RI DEM will submit a negative declaration. 

With respect to all other CTG RACT categories and major non-CTG sources of VOC and NOx 

emissions, RI DEM certifies that current RACT controls, as adopted and approved by EPA under 

the 1-hour ozone standard, constitute RACT under the 8-hour ozone standard. 
Table 6-1 RI DEM 1-hour Ozone Standard RACT Regulations and 8-Hour Ozone Standard RACT 

EPA Control Technology 

Guidelines (CTGs) 

Corresponding RI DEM 

APC Regulation

Most Recent SIP 

Approval of APC 

Regulation 

Date APC 

Regulation 

Last Amended 

Pre-1990 CTGs: Group 1 1. Stage I Vapor Control Systems (1975) 

Regulation No. 11, “Petroleum Liquids Marketing and Storage” 

2/17/93, 58 FR 65933 (1/31/93 version of regulation) 

7/18/07 

2. Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-duty trucks (1977) 

Regulation No. 19, “Control of Volatile Organic Compounds form Surface Coating Operations” 

12/2/99, 64 FR 67495 (3/7/96 version of regulation) 

.7/18/07 

3. Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds (1977) 

Negative Declaration 

4. Solvent Metal Cleaning (1977) 

Regulation No. 36, “Control of Emissions from Organic Solvent Cleaning” (superseded Regulation No. 18 in 1996) 

12/2/99, 64 FR 67495 (4/18/96 version of regulation) 

7/18/07 

5. Tank Truck Gasoline Loading Terminals (1977). 

Regulation No. 11, “Petroleum Liquids Marketing and Storage” 

2/17/93, 58 FR 65933 (1/31/93 version of regulation) 

7/18/07 

6. Surface Coating Metal Furniture (1977) 

Regulation No. 19, “Control of Volatile Organic Compounds form Surface Coating Operations” 

12/2/99, 64 FR 67495 (3/7/96 version of regulation) 

. 7/18/07 

70
EPA Control Technology 

Guidelines (CTGs) 

Corresponding RI DEM 

APC Regulation

Most Recent SIP 

Approval of APC 

Regulation 

Date APC 

Regulation 

Last Amended 

7. Surface Coating Magnet Wire (1977) 

Regulation No. 19, “Control of Volatile Organic Compounds form Surface Coating Operations” 

12/2/99, 64 FR 67495 (3/7/96 version of regulation) 

. 7/18/07 

8. Surface Coating Large Appliances (1977) 

Regulation No. 19, “Control of Volatile Organic Compounds form Surface Coating Operations” 

12/2/99, 64 FR 67495 (3/7/96 version of regulation) 

. 7/18/07 

9. Bulk Gasoline Plants (1977) 

Regulation No. 11, “Petroleum Liquids Marketing and Storage” 

2/17/93, 58 FR 65933 (1/31/93 version of regulation) 

7/18/07 

10. Fixed Roof Petroleum Tanks (1977) 

Regulation No. 11, “Petroleum Liquids Marketing and Storage” 

2/17/93, 58 FR 65933 (1/31/93 version of regulation) 

7/18/07 

11. Use of Cutback Asphalt (1977) 

Regulation No. 25, “Control of VOC Emissions from Cutback and Emulsified Asphalt 

12/2/99, 64 FR 67495 (4/8/96 version of regulation) 

7/18/07 

Pre-1990 CTGs: Group II 12. Surface Coating Misc. Metal Parts (1978) 

Regulation No. 19, “Control of Volatile Organic Compounds form Surface Coating Operations” 

12/2/99, 64 FR 67495 (3/7/96 version of regulation) 

. 7/18/07 

13. Surface Coating Flat Wood Paneling (1978) 

Regulation No. 19, “Control of Volatile Organic Compounds form Surface Coating Operations” 

12/2/99, 64 FR 67495 (3/7/96 version of regulation) 

. 7/18/07 

71
EPA Control Technology 

Guidelines (CTGs) 

Corresponding RI DEM 

APC Regulation

Most Recent SIP 

Approval of APC 

Regulation 

Date APC 

Regulation 

Last Amended 

14. Leaks from Petroleum Refinery Equipment (1978) 

Negative Declaration . 

15. Manufacture of Synthetic Pharmaceutical Product (1978) 

Regulation No. 26, “Control of Organic Solvent Emissions from Manufacture of Synthesized Pharmaceutical Products” 

12/2/99, 64 FR 67495 (4/8/96 version of regulation) 

7/18/07. 

16. Manufacture of Pneumatic Rubber Tires (1978) 

Negative Declaration 

17. Graphic Arts – Rotogravure & Flexography (1978) 

Regulation No. 21, “Control of Volatile Organic Compounds from Printing Operations: 

12/2/99, 64 FR 67495 (4/8/96 version of regulation) 

7/18/07. 

18. Petroleum Storage in External Floating Roof Tanks (1978) 

Regulation No. 11, “Petroleum Liquids Marketing and Storage” 

2/17/93, 58 FR 65933 (1/31/93 version of regulation) 

7/18/07 

19. Perchloroethylene Dry Cleaning Systems (1978) 

Regulation No. 23, “Control of Perchloroethylene Emissions from Dry Cleaning Operations” 

7/18/07. 

20. Leaks from Gasoline Tank Trucks and Vapor Collection System (1978) 

Regulation No. 11, “Petroleum Liquids Marketing and Storage” 

2/17/93, 58 FR 65933 (1/31/93 version of regulation) 

7/18/07 

Pre-1990 CTGs: Group III 21. Large Petroleum Dry Cleaners (1982) 

Negative Declaration . 

22. Manufacture of HighDensity Polyethylene, Polypropylene and Polystyrene Resins (1983) 

Negative Declaration 

72
EPA Control Technology 

Guidelines (CTGs) 

Corresponding RI DEM 

APC Regulation

Most Recent SIP 

Approval of APC 

Regulation 

Date APC 

Regulation 

Last Amended 

23. Natural Gas/Gasoline Process Leaks (1983) 

Negative Declaration 

24. Synthetic Organic Chemical Mfg Equipment Fugitive Emissions (1984) 

Negative Declaration 12/2/95, 64 FR 67495 

(submitted 4/5/95) 

25. Synthetic Organic Chemical Mfg Air Oxidation Processes (1984) 

Negative Declaration 12/2/95, 64 FR 67495 

(submitted 4/5/95) 

Post-1990 CTGs 1. Synthetic Organic Chemical Manufacturing Industry (SOCMI) Distillation Operations and Reactor Processes (1993) 

Negative Declaration 12/2/95, 64 FR 67495 

(submitted 4/5/95) 

2. Wood Furniture Manufacturing (1996) 

Regulation No. 35, “Control of VOCs and Volatile Hazardous Air Pollutants from Wood Products Manufacturing Operations” 

12/2/99, 64 FR 67495 (7/7/96 version of regulation) 

7/18/07 

3. Ship Building and Repair (1996) 4. Aerospace Coatings (1996 draft) 

Negative Declaration 7/10/00, 65 FR 42290 

(submitted 3/28/00) 

73
EPA Control Technology 

Guidelines (CTGs) 

Corresponding RI DEM 

APC Regulation

Most Recent SIP 

Approval of APC 

Regulation 

Date APC 

Regulation 

Last Amended 

5. Flat Wood Paneling (2006) 6. Industrial Cleaning Solvents (2006) 

RI DEM intends to propose amendments to Regulation No. 36, “Control of Emissions from Organic Solvent Cleaning.” The amended regulation will be consistent with the 2006 CTG. 

7. Lithographic print materials (2006) 

RI DEM will survey sources that may be applicable to this CTG and, if necessary, to amend APC Regulation No. 21 to be consistent with the CTG 

8. Letterpress printing materials (2006) 

See #7. 

9. Flexible packaging printing materials (2006) 

See #7. 

NOx RACT Categories EPA’s NOx Achievable Control Technology (ACT) documents are listed below only to illustrate NOx RACT source categories. ACTs do 

Regulation No. 27, “Control of Nitrogen Oxide Emissions,” applies to all sources with a potential to emit > 50 tons per year of 

9/20/97, 62 FR 46202 (1/16/96 version of regulation) 

.7/18/07 

74
EPA Control Technology 

Guidelines (CTGs) 

Corresponding RI DEM 

APC Regulation

Most Recent SIP 

Approval of APC 

Regulation 

Date APC 

Regulation 

Last Amended 

not establish presumptive levels of control; therefore RI DEM is not required to certify that RACT is consistent with the ACTs.

NOx, with certain exceptions. Applicability to an individual unit at a source is based on exceedance of a minimum capacity rating. 

1. Nitric and Adipic Acid Plants (1991) 

Negative Declaration . 

2. Combustion Turbines (1993) 

Regulation No. 27, “Control of Nitrogen Oxide Emissions” 

9/20/97, 62 FR 46202 (1/16/96 version of regulation) 

.7/18/07 

3. Process Heaters (1993) Regulation No. 27, “Control 

of Nitrogen Oxide Emissions” 

9/20/97, 62 FR 46202 (1/16/96 version of regulation) 

.7/18/07 

4. Internal Combustion Engines (1993) 

Regulation No. 27, “Control of Nitrogen Oxide Emissions” 

9/20/97, 62 FR 46202 (1/16/96 version of regulation) 

.7/18/07 

5. Utility Boilers (1994) Regulation No. 27, “Control 

of Nitrogen Oxide Emissions” Regulation No. 41, “NOx Budget Trading Program” 

9/20/97, 62 FR 46202 (1/16/96 version of regulation) 12/27/00, 65 FR 81743, (10/1/99 version of regulation 

7/18/07 7/18/07 

6. Cement Manufacturing (1994, updated 2000) 

. Negative Declaration . 

7. ICI Boilers (1994) Regulation No. 27, “Control 

of Nitrogen Oxide Emissions” 

9/20/97, 62 FR 46202 (1/16/96 version of regulation) 

.7/18/07 

75
EPA Control Technology 

Guidelines (CTGs) 

Corresponding RI DEM 

APC Regulation

Most Recent SIP 

Approval of APC 

Regulation 

Date APC 

Regulation 

Last Amended 

8. Glass Manufacturing (1994) 

Regulation No. 27, “Control of Nitrogen Oxide Emissions” 

9/20/97, 62 FR 46202 (1/16/96 version of regulation) 

.7/18/07 

9. Iron and Steel (1994) Negative Declaration . 10. Municipal Waste 

Combustors 

(no ACT) 

Negative Declaration . 

76
Table 6-2 RI DEM Single Source 1-Hour Ozone Standard RACT Determinations and 8-Hour Ozone 

Certification 

Single Source VOC RACT determinations were made for major VOC sources not covered by a CTG pursRegulation No. 15. Single Source NOx RACT determinations were made for major NOx sources pursuant to APC Regulation 

FACILITY EPA Approval of 

Single-Source SIP Revision 

Current Facility Status 

Major for VOC or NOx? 

Certification of 8-hour RACT 

Co

Keene Corp (Arlon) 8/31/87, 52 FR 

32793 

Closed VOC Not required 

Tech Industries 3/10/89, 54 FR 

10145 

Open VOC Current requirements 

meet 8-hour RACT. 

University of Rhode Island 

9/20/97, 62FR 46202 

Open NOx Current requirements 

meet 8-hour RACT. 

Providence Metalizing 

9/6/90, 55 FR 36635 Open VOC Current requirements 

meet 8-hour RACT. 

Tillotson-Pearson (now Pearson Composites) 

8/31/90, 55 FR 35623 

Open VOC Current requirements 

meet 8-hour RACT. 

UpApSIP 

Rhode Island Hospital 

9/20/97, 62 FR 46202 

Open NOx Current requirements 

meet 8-hour RACT 

Upin T

Osram Sylvania 9/20/97, 62 FR 

46202 

Open NOx Current requirements 

meet 8-hour RACT 

Algonquin Gas Transmission Co. 

9/20/97, 62 FR 46202 

Open NOx Current requirements 

meet 8-hour RACT 

Bradford Dyeing Assoc. 

9/20/97, 62 FR 46202 

Open NOx Current requirements 

meet 8-hour RACT. 

Hoechst Celanese Corp. (now Clariant) 

9/20/97, 62 FR 46202 

Open NOx Current requirements 

meet 8-hour RACT. 

Placlo

77
78

Naval Education and Training Center 

9/20/97, 62 FR 46202 

Open NOx Current requirements 

meet 8-hour RACT. 

Upin T

Rhode Island Economic Development 

6/02/99, 64 FR 29567 

Closed NOx Not required 

Cranston Print Works 

12/02/99, 64 FR 67495 

Closed VOC Not required 

CCL Custom Mfg. 12/02/99, 64 FR 

67495 

Open VOC Current requirements 

meet 8-hour RACT. 

Upsubrev

Victory Finishing Technologies 

12/02/99, 64 FR 67495 

Open VOC Current requirements 

meet 8-hour RACT. 

Quality Spray and Stenciling 

12/02/99, 64 FR 67495 

Open VOC Current requirements 

meet 8-hour RACT. 

Guild Music 12/02/99, 64 FR 

67495 

Closed VOC Not required 

. 
7.0 REASONABLY AVAILABLE CONTROL MEASURES (RACM) 

7.1 Purpose of Section 

This section consists of an analysis to determine whether any reasonably available control 

measures (RACM) could be adopted in Rhode Island that would result in the State attaining the 

8-hour ozone standard earlier than the required 2009 attainment date. Consistent with EPA 

guidance, RI DEM has examined potential control measures for point and nonpoint sources and 

potential Transportation Control Measures (TCMs) for mobile sources to determine whether 

such measures: 1) would provide emissions reductions sufficient to accelerate attainment; and 2) 

are feasible both economically and technically. RI DEM concludes that there are no control 

measures that could be adopted in Rhode Island that satisfy those RACM criteria. 

7.2 RACM Analysis Criteria 

Section 172(c)(1) of the CAAA requires that SIPs include RACM, as necessary, to provide for 

attainment as expeditiously as practicable, and that RACM include, at a minimum, reductions in 

emissions from existing sources as may be obtained from RACT. EPA’s Phase 2 Rule provides 

that states must include a RACM analysis in their attainment demonstration SIPs. 

EPA guidance19 interpreting the RACM requirements of section 172(c)(1) provides that, for 

purposes of attainment demonstration SIPs, a potentially available control measure can be 

justified as not meeting RACM if the measure (a) is not technically or economically feasible, or 

(b) does not advance the attainment date for the area. EPA’s guidance further provides that states 

may consider local conditions, including economic impacts and implementation issues, in 

rejecting potential control measures. EPA does not require that all sources apply RACM if less 

than all RACM will suffice for reasonable further progress and attainment and application of 

RACM will not advance the attainment date. 

According to EPA modeling guidance, areas such as Rhode Island that have an attainment date of 

June 15, 2010 must implement the emission reductions needed for attainment no later than June 

2009. Thus, to advance the attainment date, the potential RACM measures would have to 

achieve the emission reductions needed for attainment during the 2008 ozone season. 

 

19 EPA Memorandum, “Guidance on the RACM Requirement and Attainment Demonstration Submissions for 

Ozone Nonattainment Areas”, from John S. Seitz, EPA Director, Office of Air Quality Planning and Standards to the 

Regional Air Division Directors, November 1999. EPA Memorandum, “Additional Submission on RACM From 

States With Severe 1-hour Ozone Nonattainment Area SIPs”, from John S. Seitz, EPA, Director Office of Air 

Quality Planning and Standards and Marge Oge, EPA Director, Office of Transportation and Air Quality, to Regional 

Air Division Directors, December 14, 2000. 

66 Federal Register No. 2, January 3, 2001, Final Rule for Approval and Promulgation of Air quality 

Implementation Plans: Connecticut, 1-Hour Ozone Attainment Demonstration for the Greater Connecticut Ozone 

Nonattainment Area. 

79
7.3 OTC Regional RACM Analysis 

As discussed in Section 5, “Attainment Demonstration,” the OTC conducted an extensive 

regional attainment planning process for the 8-hour ozone standard. That planning effort 

included an assessment of the nature and magnitude of the ozone problem in the region, a 

comprehensive review and analysis of potential additional controls within the OTC region, 

regional modeling under various control scenarios, and formal recommendations by the OTC to 

its member states to adopt selected control measures. 

At the November 2004 OTC Meeting, the OTC directed its Stationary and Area Sources 

Committee to review programs to address emissions from all stationary point and nonpoint 

sources. At the same meeting, it directed the Mobile Source Committee to identify mobile source 

control measures for evaluation.20 OTC staff compiled an initial list of over 1,000 candidate 

control measures identified through published sources such as EPA’s Control Technique 

Guidelines, STAPPA/ALAPCO “Menu of Options” documents, emission control initiatives in 

other states including California, state/regional consultations, and stakeholder input.21 From that 

list, workgroups comprised of OTC staff and member states’ air quality staff eliminated 

measures that were not feasible because of technical, economic and/or implementation issues. 

The list was narrowed to approximately 50 candidate control measures that were considered to 

have the potential to advance ozone attainment in the OTC states. 

These measures were subjected to more detailed analysis of the potential for reductions of VOCs 

or NOx, cost effectiveness, likelihood of implementation, and effectiveness in reducing ozone 

levels in the OTC region. After consideration of these criteria, the OTC Control Measures 

Workgroup identified the most promising candidates from the list of approximately 50 measures 

and developed separate Control Measures Summary Sheets for these measures. The Control 

Measure Summary Sheets are in Appendix 5K22. They provide they the following information 

for each measure: 

1. A summary of potential additional controls for the sector. 

2. A review of existing controls in OTC states and in other states (most often California). 

3. A detailed description of the candidate control measures, including estimates of cost per ton of 

emissions reductions, estimate of reductions that could be achieved, time in which the measure 

could be implemented, and technical and implementation issues. 

4. A rationale for the proposed strategy and a policy recommendation with respect to whether it 

should be adopted by the OTC as a recommendation to the states. 

These Control Measures Summary Sheets are a product of the comprehensive review and 

analysis of OTC member states’ staff with a wide range of expertise concerning the potential for 

 

20 OTC Formal Actions related to the regional ozone planning process are available on the OTC website 

at http://www.otcair.org/document.asp?fview=Formal 21 The initial list of control measures is on the OTC web site at 

http://www.otcair.org/document.asp?fview=Report# 21 under “Documents/OTC Reports/Control 

Measures 2007. 

22 All of the Control Measure Summary Sheets relate to controls for point and area sources, with the exception of 

Reformulated Gasoline, a mobile source control measure. 

80
control measures for point and nonpoint sources. Iterations of the proposed control measures 

were made available to stakeholders who commented on the technical and economic feasibility 

of the various measures, the proposed timeframes for implementation and other issues. 

Frequently, the summary sheets were modified to reflect stakeholder comments. Thus, the 

Control Measures Summary Sheets are the outcome of a thorough analysis of the availability and 

feasibility of additional control measures for all point and nonpoint source sectors. 

 

The OTC Workgroup made its recommendations concerning the control measures to the Ozone 

Transport Commission. After further review, the Commission recommended to OTC member 

states that they individually consider adoption of additional measures.23 These measures are 

listed in Table 7-1. 

7.4 Point and Nonpoint Source RACM Analysis for Rhode Island 

RI DEM has reviewed the applicability of the OTC recommendations to Rhode Island sources; 

the result of that analysis is summarized in Table 7-1. The OTC regional review and analysis of 

potential control measures, in combination with the RI DEM assessment of the applicability and 

potential for these measures to meet the RACM criteria, constitute a comprehensive point and 

nonpoint source RACM analysis for Rhode Island. RI DEM has determined that there are no 

RACM for point and nonpoint sources that could be adopted in Rhode Island that would advance 

the attainment year to 2008. 

 

23 As noted in footnote 2, all OTC formal actions are available on the OTC website. The formal recommendations 

concerning control measures are at Documents/Formal Actions. 

81
Table 7-1 OTC Recommended Control Measures and RI RACM Analysis 

Source Categories for which OTC 

Recommended Controls 

OTC Action RI DEM RACM Analysis 

Adhesives and Sealants 2006 model rule RI DEM is committing to 

adopt controls for this 

category consistent with the 

OTC Model Rule. Rule will 

be submitted as a SIP revision 

by 10/1/08 with a 1/1/09 

effective date. 

Architectural and Industrial 

Maintenance Coatings 

2001 model rule If, by July 1, 2008, the EPA 

has not fulfilled its 

commitment24 to adopt a 

federal regulation for this 

category which is as stringent 

as the 2001 OTC Model Rule 

and which will be effective by 

2009, RI DEM commits to 

submit an equivalent State 

regulation as a SIP revision by 

10/1/08, effective on 1/1/09. 

Asphalt Paving (Emulsified and 

Cutback) 

2006 control 

recommendations 

RI DEM is committing to 

submit an amended rule for 

this category consistent with 

OTC recommendations as a 

SIP revision by 1/1/09, 

effective by 4/1/09. 

Asphalt Production Plants 2006 control 

recommendations 

for major sources 

Not applicable No major 

sources in Rhode Island 

Cement Kilns 2006 control 

recommendations 

Not applicable No sources in 

Rhode Island 

Chip Reflash (Heavy Duty Diesel 

Engines) 

2006 model 

mandatory rule, 

staff report 

See discussion in Section 7.5, 

“Mobile Sources” 

 

24 24 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to 

Regional Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer 

and Commercial Products,” May 30, 2007. 

82
Source Categories for which OTC 

Recommended Controls 

OTC Action RI DEM RACM Analysis 

Consumer Products 2001 model rule 

2006 updated model 

rule 

If, by July 1, 2008, the EPA 

has not fulfilled its 

commitment25 to adopt a 

federal regulation for this 

category which is as stringent 

as the 2006 OTC Model Rule 

and which will be effective by 

2009, RI DEM commits to 

submit an equivalent State 

regulation as a SIP revision by 

10/1/08, effective on 1/1/09. 

Distributive Generation Standards 2001 model rule APC Regulation No. 43, 

“General Permits for SmallerScale Electric Generating 

Facilities,” includes standards 

for this sector effective 

5/15/07. 

Glass and Fiberglass Furnaces 2006 control 

recommendations 

Only 1 facility in RI, federally 

enforceable permitted 

emissions limits are lower 

than those recommended by 

OTC (Approval 1350 and 

Title V Operating Permit RI07. 

Industrial, Commercial, Institutional 

Boilers 

2006 control 

recommendations 

RI DEM has determined that 

additional emissions 

reductions from this category 

are not feasible in the State. 

Mobile Equipment Repair and 

Refinishing 

2001 model rule Sources in this category are 

subject to APC Regulation 

No. 30, “Control of VOCs 

from Automobile Refinishing 

Operations,” which is 

essentially equivalent to the 

2001 OTC model rule. 

Municipal Waste Combustors No regional measure 

recommended but 

individual states 

should evaluate. 

Not applicable. No sources in 

RI. 

 

25 25 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to 

Regional Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer 

and Commercial Products,” May 30, 2007. 

83
Source Categories for which OTC 

Recommended Controls 

OTC Action RI DEM RACM Analysis 

Portable Fuel Containers 2001 model rule 

2006 updated model 

rule 

EPA’s requirements for this 

category in its Mobile Source 

Air Toxics rule will take 

effect 1/1/09. It would be 

impractical for RI DEM to 

adopt a State regulation with 

an earlier effective date. 

Solvents and Cleaners 2001 model rule RI DEM will submit 

amendments to APC 

Regulation No. 36, “Control 

of Emissions from Organic 

Solvent Cleaning,” by 1/1/09 

to incorporate recommended 

vapor pressure limits for cold 

cleaners effective by 4/1/09. 

7.5 Mobile Source RACM Analysis for Rhode Island 

Emissions from non-road and on-road mobile sources together constituted 51% of the daily VOC 

and 86% of the daily NOx anthropogenic emissions in Rhode Island in 2002. A number of 

programs are in place that will substantially reduce emissions from these sectors before the 2009 

attainment date. These programs are discussed in Section 3.2.2.1 and 3.2.2.2 (on-road mobile 

source control programs) and 3.2.2.3 (non-road mobile source control programs). 

Since states are generally precluded from regulating engines and fuels used in on-road and nonroad vehicles and engine,26 Rhode Island has a limited ability to further reduce emissions from 

mobile sources. However, RI DEM, in conjunction with the State Planning Council, the Office 

of Statewide Planning, the RI Department of Transportation (RI DOT) and others, is involved 

with the design of the State’s Congestion Mitigation and Air Quality program(CMAQ program), 

which aims to reduce ozone precursor emissions in the transportation sector. 

Table 7-2 lists the CMAQ program projects that are included in Rhode Island’s 2006-2007 

Transportation Implementation Plan (TIP), along with the expected emissions reductions 

associated with those programs. These programs include measures aimed at increasing 

pedestrian, bicycle, ferry and public transit travel, facilitating intermodal connections, 

eliminating traffic congestion through improving transportation management, signalization and 

roadways, and reducing emissions from the installation of emissions controls on public transit 

diesel busses. Together, these programs are expected to reduce VOC emissions in the State by 

138.5 kilograms (kg), or 0.15 tons, per summer day, and to reduce NOx emissions by 123.8 kg, 

or 0.14 tons, per summer day. 

 

26 The only OTC recommendation concerning mobile source controls was that states that had not already adopted 

reformulated gas (RFG) statewide do so. Rhode Island already has RFG statewide. 

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Implementation of these projects and other similar programs that will be funded with CMAQ 

program monies in the coming years will not result in an acceleration of the attainment date. 

However, it is important that such projects continue to be funded, because, at the current growth 

rate, the increase in vehicles mile traveled in the State will eventually outstrip efforts to reduce 

emissions from cars with stricter inspections, cleaner engines and cleaner fuels. 

Since a large number of mobile source emissions control programs are already being 

implemented and since additional measures funded by CMAQ program monies would not 

accelerate the attainment date, RI DEM did not identify any additional mobile source RACM 

measures. 

 Table 7-2 CMAQ Program Projects in 2006-2007 Transportation Implementation Plan 

Project Name 

VOC Reductions 

(kg/day) 

NOx Reductions 

(kg/day) 

 

Transportation Management Center 59.7 9.2 

South County Commuter Rail 46.3 60.9 

Bicycle / Pedestrian Program 5.0 5.2 

Arterial Program - Warwick Avenue 0.3 0.3 

Bus Service Initiatives 8.6 6.9 

Bus Operations Initiatives 0.2 0.1 

Express Travel 0.5 0.5 

Passenger Initiatives 0.4 0.4 

Comparison of Alternative Fuels for 

Providence-Newport Ferry: Ultra Low 

Sulfur Diesel 0.0 32.8 

Comparison of Alternative Fuels for 

Providence-Newport Ferry: Biodiesel 

Fuel 4.9 (3.6) 

Traffic Signal Control Center 6.9 5.3 

Islander Shuttle Train 3.5 3.4 

Ferry/Airport/Train Shuttle Service 0.6 0.6 

Ferry Facility Improvements 1.6 1.8 

Total 138.5 123.8 

7.6 Overall RACM Conclusions 

There are no control measures that could be implemented in Rhode Island for any source sectors 

that meet the RACM feasibility criteria and that would advance the date that the State attains the 

8-hour ozone NAAQS. 

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8.0 CONTINGENCY MEASURES 

8.1 Purpose of Section 

This section demonstrates that the Rhode Island nonattainment area meets the requirements for 

SIP contingency measures related to both Reasonable Further Progress (RFP) and to the 

attainment of the ozone standard. If implemented, the contingency measures discussed in this 

section would result in reductions in addition to those required to demonstrate RFP (discussed in 

Section 4) and in addition to those that have been taken into account in the attainment 

demonstration (discussed in Section 5). Contingency measures ensure that if Rhode Island fails 

to achieve the 15% required RFP reductions by the 2008 RFP milestone year, or fails to attain 

the ozone standard by 201027, additional reductions will occur without further state or federal 

action. 

8.2 Contingency Requirements 

Section 172(c)(9) of the CAA and EPA’s Phase 2 Rule require that nonattainment areas include 

contingency measures in their RFP and attainment SIPs. If a state receives a notification from 

EPA that a nonattainment area within its borders has failed to achieve the level of reductions 

demonstrated in the RFP SIP by the milestone year (2008 for moderate areas such as Rhode 

Island), or has failed to attain the standard by the attainment date (June 2010 for Rhode Island), 

the area must be able to implement contingency measures within one year after EPA’s notice. 

The RFP contingency and the attainment contingency must each provide for reductions 

equivalent to at least 3% of the 2002 RFP Adjusted Base Year VOC emissions inventory.28 The 

contingency reductions are in addition to the 15% reduction required to demonstrate RFP and in 

addition to the reductions taken into account in the attainment demonstration. 

8.3 RFP Contingency 

As discussed in Section 4, RI DEM is meeting the requirement to reduce emissions by 15% in 

the 2008 RFP milestone year through reductions in NOx emissions. Since VOC emissions are 

projected to be 1.7 tons (1.5%) higher in 2008 than those in the 2002 adjusted RFP inventory, 

NOx emissions reductions totaling 16.5% were needed to satisfy the RFP requirement. To 

satisfy the contingency requirement, RI DEM must be able to demonstrate that if Rhode Island 

fails to achieve the required RFP target by 2008, without further state or federal action, an 

additional 3% reduction could be achieved from control measures not already taken in account in 

the RFP calculations. 

 

27 The attainment date for moderate nonattainment areas is June 15, 2010. For attainment contingency purposes, this 

is the milestone year. This is in contrast to the milestone year for the attainment demonstration, which is the ozone 

season prior to the attainment year – 2009. 

28 The RFP Adjusted Base Year Inventory is based on the RI 2002 Base Year Inventory adjusted for RFP purposes, 

as discussed in detail in Section 4. 

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According to EPA’s interpretation of this requirement, the RFP contingency may be met by 

showing reductions in the 2008 RFP milestone year of at least 3% beyond those required to meet 

the RFP.29 As demonstrated in Section 4, NOx emissions in Rhode Island will be reduced an 

additional 3.6% between 2002 and 2008 beyond the reductions required to meet the RFP target 

(See Table 4-2). Therefore, Rhode Island has met the RFP contingency requirement. 

In addition, RI DEM is committing in this document to adopt a number of further control 

measures that will be effective before the 2009 ozone season, resulting in further emissions 

reductions that would qualify as contingency measures. For example, VOC limitations for 

consumer products and AIM coatings, which will be effective in January 2009, will reduce VOC 

emissions by 5.0 tons per day from the 2002 baseline (see calculations consistent with EPA 

guidance in Appendix 8A). 

8.4 Attainment Contingency 

EPA will assess whether Rhode Island has attained the 8-hour standard by June 2010, based on 

monitored ozone readings for 2007 – 2009. If the State is not meeting the standard based on 

readings for the 3-year period, EPA may issue a notification of failure to attain. The notification 

will trigger a requirement for RI DEM to implement contingency reductions within one year of 

the notification. For purposes of this contingency analysis, RI DEM is assuming that the 

contingency measures would need to be in place by June 2011. Therefore, to meet the attainment 

contingency requirement, RI DEM must identify control measures that will achieve reductions in 

emissions after 2009 and before June 2011 from control measures that will be effective without 

any further state or federal action. 

The amount of additional reductions that must be achieved in order to meet the attainment 

contingency requirement is 3% of the 2002 RFP Adjusted Base Year VOC emissions. While the 

required reductions are calculated as a percentage of the 2002 VOC emissions, NOx reductions 

can be used as a direct substitute for up to 90% of the required reductions of 3% of VOCs 

Therefore, only 0.3% of the reductions achieved by the contingency measures must be VOCs. 

 Calculations of the required emissions reductions for attainment contingency are as follows: 

2002 Adjusted Base Year Inventory: 

 VOC 111.80 tpsd 

 NOx 69.26 tpsd 

Required Attainment Contingency (tpsd) = VOC Adjusted Base Year Inventory * 0.03 

 = 111.80 tpsd * 0.03 

 = 3.4 tpsd 

This contingency reduction can be made up of a combination of NOx and VOC reductions, as 

long as at least 10% (0.3 tpsd) is VOC.. 

 

29 U.S. EPA Memorandum from Michael H. Shapiro to Region 1 through 10 Air Directors, “Guidance on Issues 

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

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RI DEM will meet this attainment contingency requirement by taking credit for emission 

reductions that will be achieved from the existing federal and state on-road and federal on-road 

and non-road mobile source control measures described in Section 7.5, “Mobile Source RACM 

Analysis for Rhode Island.,” including the Rhode Island Low-Emission Vehicle (LEV) Program. 

These measures will continue to provide substantial VOC and NOx emission reductions through 

2011 (and beyond) as newer, less-polluting vehicles and equipment replace the older fleet. As 

shown in Appendix 8B, emissions from the non-road mobile source categories calculated using 

the Non-Road model are projected to decrease by 2.0 tpsd of VOC and 1.8 tpsd of NOx between 

2008 and 2011 without the imposition of additional controls. Although quantitative estimates of 

2011 on-road mobile source emissions are not available, those emissions will also decrease 

during that period. As shown below in Section 9.0, on-road emissions of VOC are projected to 

decrease by 1.2 tons and NOx by 2.1 tons in the one year period between 2008 and 2009. That 

decline is projected to continue in subsequent years, as a result of fleet turnover. 

Therefore, without the need for imposition of additional controls, emissions in Rhode Island will 

continue to decline after the attainment year and Rhode Island will meet its attainment 

contingency obligations. 

 

8.5 Conclusions 

 

Rhode Island has met the RFP contingency by demonstrating that the reductions of VOC and 

NOx projected by 2008 are greater than the 18% reduction that is required (15% for RFP and 3% 

for RFP contingency). For the attainment contingency, the reductions of VOC and NOx that will 

be achieved during the 2009-2011 period from the on-road and non-road mobile source control 

measures already in effect are greater than reductions needed to meet the 3% attainment 

contingency requirement. Therefore, Rhode Island meets the attainment contingency 

requirement. 

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9.0 TRANSPORTATION CONFORMITY 

9.1 Purpose of Section 

This section establishes Transportation Conformity budgets for the on-road mobile source sector 

for Rhode Island in the 2008 RFP milestone year and in the 2009 attainment demonstration year. 

The Transportation Conformity budgets set the levels of mobile source emissions that may not be 

exceeded in the State in the budget years. The budget was developed using the Rhode Island 

Statewide Travel Demand Model using methods agreed upon by RIDEM, the Rhode Island 

Statewide Planning Program (RISPP) and the Rhode Island Department of Transportation, in 

consultation with EPA Region 1. 

 Technical data files related to the Mobile 6 model runs used to estimate mobile source emissions 

in the budget years and an explanation of the modeling methodology are attached in Appendix 

2D. 

9.2 Background 

Transportation conformity is required by section 176(c) of the CAA to ensure that transportation 

plans, programs and projects receiving federal funds are consistent with the SIP. Conformity to a 

SIP means that transportation activities will not produce new air quality violations, worsen 

existing violations, or delay timely attainment of a NAAQS. 

EPA’s Phase 2 Implementation Rule provides that nonattainment areas establish motor vehicle 

emissions budgets for the RFP milestone year (2008) and for the attainment demonstration year 

(2009). The budgets are set at the level of emissions from the on-road mobile sector projected for 

these years. Emissions of VOC and NOx from this sector may not exceed the budget levels. 

Emissions in years for which no budget is set may not exceed the budget established for the most 

recent prior year. 

RI DEM established a conformity budgets for Rhode Island under the 1-hour ozone standard. 

The budget was submitted to the EPA as part of the State’s 1-hour ozone standard attainment 

demonstration on March 24, 2003 and was approved by the EPA on April 7, 2003. (68 FR 

16724) The 2007 budget is shown in Table 9-1. 

The 2008 and 2009 transportation conformity budgets presented in the document, once approved 

by EPA, will replace the conformity budgets previously submitted and approved. 

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9.3 Methodology 

Conformity budgets are set through a conformity consultation process. The 2008 and 2009 

budgets were developed using the Rhode Island Statewide Travel Demand Model using methods 

agreed upon by RIDEM, the Rhode Island Statewide Planning Program (RISPP) and the Rhode 

Island Department of Transportation, in consultation with EPA Region 1. The methodology used 

to calculate the budget is described in a document entitled “Rhode Island 2008 and 2009 Mobile 

Source Emissions,” which was prepared for the Rhode Island Department of Administration, 

Statewide Planning Program, RISPP, by Vanasse, Hangen and Brustlin, Inc. and which is 

attached as Appendix 2D. 

9.4 Mobile Source Budgets 

Application of the methods described in the Vanasse et al document resulted in the projected 

emissions for the 2008 and 2009 years for Rhode Island shown in Table 9-1. However, the 

RISSP, which is the Metropolitan Planning Organization (MPO) for the State of Rhode Island, 

requested, in a letter attached in Appendix 9A, that the 2008 VOC and NOx budgets be set at a 

level 0.5 tons per day higher than those predicted by the model to allow a buffer for conformity 

analyses. 

2007 emissions budgets, projected 2008 and 2009 emissions, and the emissions budgets for 2008 

and 2009 requested by the RISPP are shown in Table 9-1. Since RI DEM used the requested 

2008 emissions budgets in its RFP calculations, allowing the requested 2008 budget will not 

interfere with the State’s ability to make RFP or contingency targets. Therefore, RIDEM plans 

to accept the requested budgets, pending approval by the EPA. 

Table 9-1 2007 Emissions Budget, Projected 2008 and 2009 Inventory and Requested 2008 

and 2009 Emissions Budgets (tons per summer day) 

2007 

Budget 

2008 Projected

Inventory 

2008 Mobile 

Source Budget 

2009 Projected 

Inventory 

2009 Mobile 

Source Budget

VOC 30.68 24.14 24.64 22.75 22.75 

NOx 33.97 27.76 28.26 25.29 25.29