Final Section 7 - Page 1 of 8

SECTION 7 REASONABLY AVAILABLE CONTROL MEASURES (RACM)

7.1 Purpose of Section

This section addresses whether there are any reasonably available control measures (RACM) that 

could be adopted in Massachusetts that would result in EMA and/or WMA attaining the 8-hour 

ozone standard earlier than 2009. Consistent with EPA guidance on RACM, MassDEP has 

examined potential control measures for point and area sources and potential Transportation 

Control Measures (TCMs) for mobile sources based on whether such measures: 1) provide 

sufficient emissions reductions to accelerate attainment; and 2) are feasible both economically 

and technically. MassDEP concludes that there are no control measures that could be adopted in 

Massachusetts that satisfy these RACM criteria.

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 may be obtained from RACT (See Section 6). 

EPA’s Phase 2 Rule provides that states must include a RACM analysis with their attainment 

demonstration SIPs.

EPA guidance1interpreting 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 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 that have an attainment date of June 15, 2010 

(EMA and WMA) 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. 

 

1 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. 
Final Section 7 - Page 2 of 8

7.3 OTC Regional RACM Analysis 

As discussed in Section 5, Attainment Demonstration, 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 

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 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/regional 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 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 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 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. 

 

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 control measures is on the OTC web site at 

http://www.otcair.org/document.asp?fview=Report# 3under “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 - Page 3 of 8

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 

control measures for point and area 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 area source sectors. 

 

The OTC Workgroup made its recommendations 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.5These measures are listed 

in Table RACM 1. 

7.4 Point 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 analysis is summarized in Table RACM 1. The OTC regional review and analysis 

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 and 

area source RACM analysis 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 year 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 - Page 4 of 8

Table RACM 1 OTC Recommended Control Measures 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

No6 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 (Emulsified and 

Cutback)

Yes MassDEP is committing to 

adopt controls for this category

effective 5/1/2009. 

Asphalt Production Plants Yes MA facilities are already 

subject to fuel combustion 

requirements and case-by-case 

RACT determinations for major 

sources (310 CMR 7.19). 

MassDEP has concluded that 

additional controls (low NOx 

burners, flue gas recirculation) 

are not economically feasible 

for these facilities. 

Automotive Refinish Coatings No Already subject to 310 CMR 

7.18(28)

Cement Kilns Yes No sources 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 

additional controls 

recommended by 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 - Page 5 of 8

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 

reasonably available (Section 6, 

RACT). 

Industrial Surface Coatings: Fabric 

Printing, Coating, and Dyeing; Large 

Appliances; Metal Cans; Metal Coils; 

Metal Furniture; Miscellaneous Metal 

Parts;Paper and Web Coating; Plastics 

Parts; Wood Building Products; All 

Categories

No Already subject to VOC RACT, 

310 CMR 7.18. 

Lime Kilns No . 

Municipal Waste Combustors No

No regional 

measure 

recommended but 

individual states 

should evaluate. 

MassDEP has reviewed the 

potential for additional 

emissions reductions from this 

category as part of its RACT 

review. It concludes that no 

additional controls are 

reasonably available (Section 

6, RACT). 

Printing and Graphic Arts No Already subject to VOC RACT 

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 

effective date. 

7.5 Mobile Source RACM 

States are generally 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 - Page 6 of 8

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

 Programs for improved public transit

 High occupancy vehicle (HOV) lanes

 Employer-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 storage, travel lanes and related improvements and programs

 Control of idling vehicles

 Reduction of extreme cold start emissions

 Employer-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 already implemented and included in its 1-hour ozone standard SIPs for EMA and 

WMA many TCMs. (See Appendix 3A, Massachusetts 1-Hour Standard Control Measures). 

Massachusetts committed to expand existing public transit systems 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 - Page 7 of 8

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

Employer-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 

regulations 

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

Employer-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 Quality 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 traffic 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 Appendix 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 $16 
Final Section 7 - Page 8 of 8

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 early 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 RACM criteria. 

7.7 Mobile Source RACM Conclusions

Massachusetts is currently implementing all of the reasonably 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 

program. However, there are no RACM for mobile sources that would allow EMA to reach 

attainment any sooner than 2009.

7.8 Overall RACM Conclusions

There are no control measures that could be implemented in Massachusetts for any source 

sectors that meet the RACM feasibility criteria and that would advance the attainment year for 

EMA or WMA to 2008.