Final Section 7

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**SECTION 7 REASONABLY AVAILABLE CONTROL MEASURES (RACM)** 
**7.1 Purpose of Section**  This section addresses whether there are an y reasonably available control measures (RACM) that could be adopted in Massachusetts that would result in EMA and/or WMA attaini ng the 8

- hour ozone standard earlier than 2009. Consistent with EPA guidance on RACM, Mass DEP has examined potential control measures for point and area sources and potential Transportation Control Measures (TCMs) for mobile sources based on whether such m easures: 1) provide sufficient emissions reductions to accelerate attainment; and 2) are feasible both economicall y and technically . MassDEP concludes that there are no control measures that could be adopted in Massachusetts that satisfy these RACM criter ia.
**7.2 RACM Analysis Criteria**  Section 172(c)(1) of the CAA requires that SIPs contain 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 m ay be obtained from RACT (See Section 6). EPA’s Phase 2 Rule provides that states must include a RACM anal ys is with their attainment demonstration SIPs. EPA guidance 1 interpreting the RACM requirements of section 172(c)(1) provides that for purposes of attainment demonstration SIPs, potentially available control measures can be justified as not meeting RACM if a measure (a) is not technically or economically

feasible, or (b) does not advance the attainment date for the area. EPA’s guidance further provid es 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 EP

A modeling guidance, areas that have an attainment date of June 15, 2010 (EMA and WMA) must implement the emission reductions needed for attainment no later th an 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.

1 EP A Memorandum, “Guidance on the RACM Requir ement and Attainment Demonstration Submissions for Ozone Nonattainment Ar eas”, from John S. Seitz, EP A Director, Off

ice of Air Quality Planning and St andards to the Regional Air Division Directors, November 1999. EP A Memorandum, “Additional Submission on RACM Fr

om S tates Wi th Sever

e 1

- hour Ozone Nonattainment Ar ea SIPs”, from John S. Seitz, EP A, Director Office of Air Quality Planning and Standards and Marge Oge, EP A Director, Office of Tr ansportation and Air Quality , to Regional Air Division Directors, December 14, 2000. 66 Federal Register No. 2, January 3, 2001, Final Rule for Appr oval and Pr

omulgation of Air quali ty Implementation Plans: Connecticut, 1

-Hour Ozone Attainment Demonstration for the Gr eater Connecticut Ozone Nonattainment Ar ea.Final Section 7

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**7.3 OTC Regional RACM Analysis**  As discussed in Section 5, Attainment D emonstration , the OTC conducted an extensive regional 8

- hour ozone standard attainment planning process. That planning effort included an assessment of the nature and magnitude of the ozone problem in the region, a comprehensive review and anal ys is of pote ntial additional controls within the OTC region, regional modeling under various control scenarios, and formal recommendations b y 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 and area sources. At the same meeting, it directed the Mobile Source Committee to identify mobile source control measures for evaluation. 2 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/re gional consultations, and stakeholder input. 3 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 narr owed 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 analy sis of the potential for reductions of VOCs or NOx, cost eff

ectiveness, 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 mea sures and developed separate Control Measures Summary Sheets for these measures. The Control Measure Summary

Sheets are in Appendix 5K4 . 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 cou ld 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 b y the OTC as a recommendation to the states.

2 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 3 The initial list of contro l measures is on the OTC web site at http://www.otcair.org/document.asp?fview=Report# 3 under “Documents/OTC Reports/Control Measures 2007. 4 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.Final Section 7

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These Control Measures Summary Sheets are a product of the comprehensive review and anal ys is of OTC member states’ staff with a wide range of expertise concerning the potential for control measures for point and area sources. Iterations of the p roposed 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. Frequentl y, the summary sheets were modified to refle ct stakeholder comments. Thus, the Control Measures Summary Sheets are the outcome of a thorough analy sis of the availability and feasibility of additional control measures for all point and area source sectors. The OTC Workgroup made its recommendati ons concerning the control measures to the OTC Commissioners. After further review, the OTC Commissioners recommended to OTC member states that they

individually

consider adoption of additional measures. 5 These measures are listed in Table RACM 1.

7.4 **Po int and Area Source RACM Analysis for Massachusetts**  MassDEP has reviewed its own sources within the sectors identified as candidates for additional control by

the OTC Workgroup and recommended by the OTC Commissioners. The result of the MassDEP anal ys is is summarized in Table RACM 1. The OTC regional review and anal ys is of potential control measures, in combination with MassDEP assessment of the applicability and potential for these measures to meet the RACM criteria, constitute a comprehensive point a nd area source RACM anal ysis for Massachusetts. MassDEP has determined that there are no RACM for point and area sources that could be adopted in EMA or WMA that would advance the attainment y ear to 2008.

5 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.Final Section 7

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**Table RACM 1 OTC Recommended Control M**  **easures and MA RACM Analysis Source Categories with OTC Control**  **Measure Worksheets OTC 2006**  **Recommendation for Additional**  **Controls MassDEP RACM Analysis** 

**Adhesives and Sealants Yes**  MassDEP is committing to adopt controls for this category consistent with the OTC Model Rule, with a 4/1/2009 effective date. **Architectural and Industrial Maintenance Coatings**  **No 6**  MassDEP has finalized amendments to 310 CMR 7.25, consistent with the 2001 OTC Model Rule, with a 1/1/2009 effective date. **Asphalt Paving (Em ulsified and**  **Cutback) Yes**  MassDEP is committing to adopt controls for this category effective 5/1/2009. **Asphalt Production Plants Yes**  MA facilities are alread y subject to fuel combustion requirements and case

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- case RACT determinations for major sour ces (310 CMR 7.19). MassDEP has concluded that additional controls (low NOx burners, flue gas recirculation) are not economicall y feasible for these facilities. **Automotive Refinish Coatings No**  Alread y subject to 310 CMR 7.18(28) **Cement Kilns Yes**  No so urces in MA **Chip Reflash (Heavy Duty Diesel Engines)**  **Yes** See discussion under Mobile Sources. **Consumer Products Yes**  MassDEP has finalized amendments to 310 CMR 7.25, effective 1/1/2009, consistent with the 2001 OTC Model Rule, and including the additi onal controls recommended b y the OTC in 2006.

6 In 2001, the OTC recommended additional VOC controls for this category. It decided against recommending additional controls from this category during the 2006 review.Final Section 7

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**Glass and Fiberglass Furnaces Yes**  Only 1 facility in MA **Industrial, Commercial, Institutional Boilers**  **Yes** MassDEP has reviewed the potential for additional emissions reductions from this category as part of its RACT review and concludes that no additional controls are reasonabl y available (Section 6, RACT). **Industrial Surface Coatings: Fabric Printing, Coating, and Dyeing; Large**  **Appliances; Metal Cans; Metal Coils; Metal Furniture; Miscellaneous Metal**  **Par ts;Paper and Web Coating; Plastics**  **Parts; Wood Building Products; All Categories**  **No** Alread y subject to VOC RACT, 310 CMR 7.18.

**Lime Kilns No** 

. **Municipal Waste Combustors No**  No regional measure recommended but individual states should evaluate. MassD EP has reviewed the

potential for additional emissions reductions from this category as part of its RACT review. It concludes that no additional controls are reasonabl y available (Section 6, RACT). **Printing and Graphic Arts No**  Alread y subject to VOC RAC T requirements (310 CMR 7.18) and MassDEP Environmental Results Program 310 CMR

. **Portable Fuel Containers Yes**  EPA’s regulation of this category will take effect 1/1/2009. It would be impractical for MassDEP adopt a state regulation with an earlier effe ctive date.

**7.5 Mobile Source RACM** States are generall y precluded from regulating engines and fuels used in on

- road and non

- road vehicles and engines. 7 RACM analysis for mobile sources, therefore, focuses on the availability and feasibility

of transportation control measures (TCMs).

7 The only OTC recommendation concerning mobile source controls was that states that had not already adopted reformulated gas (RFG) statewide do so. Massachusetts already has RFG statewide.Final Section 7

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Section 108(f) of the CAA lists 16 ty pes of TCM’s:

 Programs for improved public transit
 High occupancy

vehicle (HOV) lanes
 Employ er - based transportation management plans
 Trip reduction ordinances
 Traffic flow improvement programs
 Fringe and transportation corridor parking for high occupancy vehicle programs
 Limits or restrictions on vehicle use in specified areas
 HOV and shared

- ride programs
 Bicycle and pedestrian facilities, lanes and restrictions
 Bicycle storag e, travel lanes and related improvements and programs
 Control of idling vehicles
 Reduction of extreme cold start emissions
 Employ er - sponsored flexible work schedules
 Facilitation of non

- automobile, HOV, and mass transit travel
 Pedestrian and non

- motorized vehicle facilities, paths and areas
 Voluntary

retirement of pre

- 1980 light duty vehicles MassDEP has alread y implemented and included in its 1

- hour ozone standard SIPs for EMA and WMA many

TCMs. (See Appendix 3A, Massachusetts 1

-Hour Standard Control Mea sures ). Massachusetts committed to expand existing public transit sy stems and to implement a significant number of other TCMs and Transportation Demand Management (TDM) measures over a decade ago in connection with its Central Artery /Third Harbor Tunnel (CA/T) project. The TCMs that have been implemented in EMA and WMA are noted below:Final Section 7

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**Table RACM 2 Transportation Control Measures Adopted in EMA and WMA CAA Section 108(f) TCMs**  **In EMA SIP**  **In WMA**

**SIP Comments**  Programs for improved public transit Yes Yes Numerous improvement and expansion projects: fixed rail, bus rapid transit, commuter trains, etc. High occupancy

vehicle (HOV) lanes Yes No Employ er - based transportation management plans Yes Yes Trip reduction ordinances Yes No Traffic flow improvement programs Yes Yes Fringe and transportation corridor parking for high occupancy

vehicle programs Yes Yes Park and ride available adjacent to HOV corridors Limits or restrictions on vehicle use in specified areas Yes No Parking Freeze regulati ons HOV and shared

- ride programs Yes No Bicycle and pedestrian facilities, lanes and restrictions Yes Yes Bicycle storage, travel lanes and related improvements and programs Yes Yes Control of idling vehicles Yes Yes Anti

- idling law 90 section 16a Employ er - sponsored flexible work schedules Yes Yes Facilitation of non

- automobile, HOV, and mass transit travel Yes No Pedestrian and non

- motorized vehicle facilities, paths and areas Yes No

**7.6 Massachusetts Congestion Mitigation and Air Quali ty Projects**  One of the funding sources for transportation projects is the Federal Highway Administration’s Congestion Mitigation and Air Quality (FHWA CMAQ) Program. FHW CMAQ funds are used for projects that reduce emissions from vehicles, improve traffi c congestion, and/or improve air quality . Through the FHWA CMAQ program, Massachusetts continues to fund transportation projects that reduce ozone precursor emissions. A list of FHWA CMAQ projects approved for funding in Federal Fiscal Year 2007 is Append ix 7A. An estimate of the reductions in VOC and NOx emission reductions that are realized from these projects is provided. One of the major programs listed for 2007 FHW CMAQ funding is the MassDEP Diesel School Bus Retrofit Program. The Executive Office of Transportation is providing approximately $16Final Section 7

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million in FHWA CMAQ and state matching funds to develop and implement the program, which will reduce air pollution from public school buses. MassDEP anticipates launching this program earl y in 2008, with the goal of retrofiting all eligible school buses by Fall 2010. While the Diesel School Bus Retrofit Program and other FHWA CMAQ programs are important efforts, they

result in relatively

small amounts of emissions reductions and, therefore, do not meet RA CM criteria.
**7.7 Mobile Source RACM Conclusions** Massachusetts is currently implementing all of the reasonabl y available TCMs listed in the Clean Air Act. Massachusetts has also included in its SIP a wide range of emissions

- reducing programs, including California LEV and Stage 2. The State is also implementing transit improvements and transportation

- related environmental actions as an integral part of the Central Artery /Third Harbor Tunnel project. It continues to fund new TCMs through the FHW CMAQ prog ram. However, there are no RACM for mobile sources that would allow EMA to reach attainment an y sooner than 2009.
**7.8 Overall RACM Conclusions**  There are no control measures that could be implemented in Massachusetts for an y source sectors that meet the RA CM feasibility criteria and that would advance the attainment y ear for EMA or WMA to 2008.