## The North Carolina 8-Hour Ozone Reasonable Further Progress Demonstration
for the Charlotte-Gastonia-Rock Hill, NC-SC

8-Hour Ozone Nonattainment Area (Cabarrus, Gaston, Lincoln, Mecklenburg, Rowan, Union Counties and Coddle Creek and Davidson Townships in Iredell County)

Prepared by:
North Carolina Department of Environment and Natural Resources Division of Air Quality

November 30, 2009(This page intentionally left blank)The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone i North Carolina Reasonable Further Progress Demonstration November 30, 2009 

### TABLE OF CONTENTS

1 INTRODUCTION ................................................................................................................ ....... 1

2 CALCULATION METHOD FOR THE RFP TARGET............................................................. 1

3 EMISSIONS INVENTORY ........................................................................................................ 2 3.1 Stationary Point Sources ................................................................................................. ..... 3 3.2 Stationary Area Sources .................................................................................................. ..... 4 3.3 Off-Road Mobile Sources .................................................................................................. .. 4 3.4 Highway Mobile Sources ................................................................................................... .. 5 3.5 Emissions Inventory Summary ............................................................................................ 5

4 ESTIMATION OF NON-CREDI TABLE REDUCTIONS ......................................................... 6

5 REASONABLE FURTHER PROGRESS DEMONSTRATION ............................................. 10

6 MOTOR VEHICLE EMISSION BUDGETS ............................................................................ 11 6.1 Transportation Conformity ................................................................................................ 11 6.2 Motor Vehicle Emission Budgets ....................................................................................... 12

7 CONCLUSIONS.................................................................................................................. ...... 14



### LIST OF TABLES

Table 3-1 Metrolina Nonattainment Area 2002 Baseline VOC Emissions (tons/day) .................. 5 Table 3-2 Metrolina Nonattainment Area 2008 Baseline VOC Emissions (tons/day) .................. 6 Table 4-1 Cabarrus County Non-Creditable VOC Emission Estimates ........................................ 7 Table 4-2 Gaston County Non-Creditable VOC Emission Estimates ........................................... 7 Table 4-3 Nonattainment Portion of Iredell C ounty Non-Creditable VOC Emission Estimates .. 8 Table 4-4 Lincoln County Non-Cr editable VOC Emission Estimates .......................................... 8 Table 4-5 Mecklenburg County Non-Cr editable VOC Emission Estimates ................................. 9 Table 4-6 Rowan County Non-Creditable VOC Emission Estimates ........................................... 9 Table 4-7 Union County Non-Creditable VOC Emission Estimates ........................................... 10 Table 4-8 Total Metrolina Nonattainment Ar ea Non-Creditable VOC Emission Estimates ....... 10 Table 5-1 Metrolina Nonattainment Area 15 Percent RFP Analysis ........................................... 11 Table 6-1 Metrolina Nonattainment Area 2008 NOx Emissions (tons/day) ............................... 12 Table 6-2 On-Road Mobile Source 2008 Emi ssions Metrolina Nonattainment Area ................. 13 Table 6-3 County Level MVEB for 2008 .................................................................................... 14The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone ii North Carolina Reasonable Further Progress Demonstration November 30, 2009 

### APPENDICES

Appendix A – MOBILE Files for Non-Creditable Emissions

Appendix B – Point Source Emissi ons Inventory Documentation

Appendix C – Area Source Emissi ons Inventory Documentation

Appendix D – Nonroad Mobile Source Emissions Inventory Documentation

Appendix E – On-Road Mobile Source Emissions Inventory Documentation

Appendix F – Correspondence and Guidance

Appendix G – VISTAS S upporting Documentation

Appendix H – Public Hearing RecordThe Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 1 North Carolina Reasonable Further Progress Demonstration November 30, 2009 

### 1 INTRODUCTION

Section 182(b)(1) of the Clean Air Act Amen dments (CAAA) mandates a 15 percent volatile organic compounds (VOC) emission reduction, accounti ng for growth, in the first six years after the baseline year (2002) for Moderate and above ozone nonattainment areas. Thus, for the Charlotte-Gastonia-Rock Hill, NC-SC 8-hour oz one nonattainment area (referred to as the Metrolina area), a reasonable fu rther progress (RFP) analysis be tween 2002 and 2008 is required. Although the Charlotte-Gastonia 1-hour ozone nona ttainment area (comprised of Mecklenburg and Gaston Counties) was designated as Mode rate following the 1990 CAAA, the area had measured attainment of the 1-hour standard pr ior to the 15 percent Rate of Progress (ROP) requirement coming due on November 15, 1993. Ther efore, this area did not implement a 15 percent ROP plan under the 1-hour standard, and the RFP requi rement must be met through VOC reductions only, consistent with the CAAA.



### 2 CALCULATION METHOD FOR THE RFP TARGET

The methodology the North Carolina Division of Air Quality (NCDAQ) us ed to calculate the RFP target levels of VOC emissions is base d on the method developed in the CAAA, while taking into account the restrict ions on creditable emissions and the need to use the 2002 inventory as a baseline. The CA AA specified four types of meas ures that were not creditable toward the 15 percent RFP requirement. These were:

(1) Any measure relating to motor vehicle exhaus t or evaporative emissions promulgated by the Administrator by January 1, 1990.

(2) Regulations concerning Reid Vapor Pressure (RVP) promulgated af ter 1990 or required under section 211(h).

(3) Measures required under sect ion 182(a)(2)(A) to correct deficiencies in State Implementation Plans (SIPs) regarding VOC Reasonably Availabl e Control Technology (RACT) regulations required prio r to enactment of the CAAA.

(4) State regulations submitted to correct defici encies in vehicle inspection and maintenance (I/M) existing or required programs.

These four types of measures were all expected to result in a d ecrease in emissions between 1990 and 1996. Of these four types of measures, RA CT and I/M program corrections and the 1992 RVP requirements were completely in place by 1996 and therefore are already accounted for in the 2002 baseline. As a result, these measures would produce no additional reductions between 2002 and 2008 or later milestone years.

However, the pre-1990 Federal Motor Vehicle Control Program (FMVCP) will continue to provide additional benefits during the first two decades of the 21st century until all remaining vehicles meeting pre-1990 standard s are removed from the vehicle fleet. Since these benefits are not creditable for RFP demonstrat ion purposes, the reductions that would occur over these futureThe Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 2 North Carolina Reasonable Further Progress Demonstration November 30, 2009 years as a result of the pre-1990 FM VCP must be calculated so that the target level of emissions for future RFP milestone year can be determine d. The United States Environmental Protection Agency (USEPA) provided guidance on calculating th e RFP targets for several kinds of areas in Appendix A (70 FR 71696) of the Phase 2 8-hour ozone implementation rule. Four methods were outlined in this guidance.

The NCDAQ used Method 1 to account for non- creditable reductions when calculating RFP targets for the 2008 milestone year. It is consis tent with requirements of Sections 182(b)(1)(C) and (D) and 182(c)(2)(B) of the CAAA. Only the on-road mob ile source sector required an estimation of non-creditable emissions since all ot her controls would have been in place by 2002 and no further reductions would have been expected between 2002 and 2008.

Method 1: For areas that must meet a 15 percent VOC reduction requirement by 2008:

(A) Estimate the actual anthropogenic base y ear VOC inventory in 2002 with all 2002 control programs in pl ace for all sources.

(B) Using the same highway vehicle activity inputs used to ca lculate the actual 2002 inventory, run the appropriate motor ve hicle emissions model for 2002 and for 2008 with all post-1990 Clean Air Act (CAA) measur es turned off. Any other local inputs for vehicle I/M programs should be set accord ing to the program that was required to be in place in 1990. Fuel RVP should be set at 9.0 or 7.8 pounds per square inch depending on the level required in the local area as a result of fuel RVP regulations promulgated in June 1990.

(C) Calculate the difference between the 2002 and 2008 VOC emission factors calculated in Step B and multiply by 2002 vehicle mile s traveled (VMT). The result is the VOC emissions reductions that will occur betw een 2002 and 2008 without the benefits of any post-1990 CAA measures. These are th e non-creditable reduc tions that occur over this period.

(D) Subtract the non-creditable reductions calculated in Step C from the actual anthropogenic 2002 inventory estimated in Step A. This adjusted VOC inventory is the basis for calculating the target level of emissions in 2008.

(E) Reduce the adjusted VOC inventory calculated in Step D by 15 percent. The result is the target level of VOC emissions in 2008 in order to meet the 2008 RFP requirement. The actual projected 2008 inve ntory for all sources with all control measures in place and including projected 2008 growth in activity must be at or lower than this target level of emissions.



### 3 EMISSIONS INVENTORY

There are four different anthr opogenic emission inventory source cl assifications: stationary point and area sources, and off-road and on-road mobile sources. Stationary point sources are thoseThe Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 3 North Carolina Reasonable Further Progress Demonstration November 30, 2009 sources that emit greater than a sp ecified tonnage per year and the da ta is provided at the facility level. Stationary area sources are those sources whose emissions are relatively small but due to the large number of these sources, the collect ive emissions could be significant (i.e., dry cleaners, service stations, etc.). These types of emissions are estimated at the county level. Offroad mobile sources include equipment that can move but do not use th e roadways, i.e., lawn mowers, construction equipment, railroad locomotiv es, aircraft, etc. The emissions from these sources, like stationary area sources, are estimated at the county level. On-road mobile sources are automobiles, trucks, and motorcycles that us e the roadway system. The emissions from these sources are estimated by vehicle type and road type and are summed to the county level.

For these sources of emissions, the 2002 base year and the 2008 milestone year emission inventories were developed. The 2002 base year emissions were from the 2002 modeling attainment demonstration. The 2008 milestone year emissions were either developed by applying growth and control fact ors to the 2002 base year emissi ons or using 2008 specific data. The 2008 inventory was processed through the Sp arse Matrix Operator Kernel Emissions (SMOKE) pre-processing model so that the emissions would be comparable to the 2002 attainment demonstration emissions inventory.

In the sections that follow, a synopsis of the i nventories used for each source classification is discussed. The detailed discus sions of the emissions inventory development can be found in Appendices B through E.

3.1 Stationary Point Sources

Point source emissions are emissions from indivi dual sources having a fixe d location. Generally, these sources must have permits to operate a nd their emissions are inventoried on a regular schedule. Large sources having emissions of 100 tons per year (tpy) of a criteria pollutant, 10 tpy of a single hazardous air pollutant (HAP), or 25 tpy tota l HAP are inventoried annually. Smaller sources have been inventoried less freque ntly. The point source emissions data can be grouped into the electri c generating unit (EGU) sources and the other point sources, i.e., non-EGUs. Appendix B documents the point source inventory development in more detail.

The 2002 base year inventory for the EGU sour ces used 2002 continuous emissions monitoring (CEM) data reported to the USEPA’s Acid Rain program. This data provides hourly emissions profiles that can be used in the modeling of these large sources of nitrogen oxides (NOx) emissions and helps to provide more accurate modeling of these sources. The 2008 milestone year EGU emissions inventory was provided by Duke Power. This inventory provided the company’s estimated emissions taking into cons ideration their compliance plan for the North Carolina Clean Smokestacks Act.

For the non-EGU sources, the annual emissions as reported for the Consolidated Emissions Reporting Rule (CERR) for the year 2002 were used. These emissions were temporally allocated to month, day, and hour using source category code (SCC) ba sed allocation factors using the SMOKE emissions pre-processing m odel. For the 2008 inventory, the general approach was to use recently updated growth a nd control data consiste nt with the USEPA’s Clean Air Interstate Rule (CAIR) analyses. The growth and control factors were appliedThe Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 4 North Carolina Reasonable Further Progress Demonstration November 30, 2009 utilizing the SMOKE emissions pre-processing model, which also temporally allocated the emissions similar to the base year emissions inventory.

3.2 Stationary Area Sources

Stationary area sources include sources whose emi ssions are relatively small but due to the large number of these sources, the collective emissi ons could be significant (i.e., combustion of fuels for heating, structure fires, service stations, et c.). Emissions are estimated by multiplying an emission factor by some known indicator of collec tive activity, such as fuel usage, number of households, number of employees, or population. Stationary area source emissions are estimated on the county level.

The NCDAQ developed the 2002 base year emissi ons inventory by collecting 2002 activity data for the various source subcategories and applyi ng the USEPA developed emission factors. Growth factors supplied from the USEPA’s CAIR emission projections were applied to project the controlled emissions to the 2008 milestone year. In some cases, the USEPA’s Economic Growth and Analysis System Version 5 growth factors were used if no growth factor was available from the CAIR growth factor files. The growth and control factors were applied utilizing the SMOKE emissions pre-processing model, which also temporally allocated the emissions similar to the base year emissions inventory.

Appendix C provides a detailed discu ssion of the area source inventory.

3.3 Off-Road Mobile Sources

Off-road mobile sources, also referred to as non-ro ad mobile sources, include equipment that can move but does not use the roadways, such as construction equipment, aircraft, railroad locomotives, lawn and garden equipment, etc. Fo r the majority of the non-road mobile sources, the emissions were estimated using the USEPA’ s NONROAD2005c model. For two of the three source categories not included in the NONROAD model, i.e., ai rcraft engines and railroad locomotives, more traditional methods of estim ating the emissions were used. There are no emissions in the Metrolina area for commercial marine emissions, the th ird category not included in the NONROAD model.

For the source categories estimated using the USEPA’s NONROAD model, the model was used to create the 2008 milestone y ear inventory. The NONROAD model takes into consideration rules that are in effect that c ould impact the emissions from th ese source categories. For the large airport in the Metrolina area, the Fede ral Aviation Administration’s (FAA’s) Terminal Area Forecast was used to project growth in airc raft emissions. For the railroad locomotives and the remaining airport emissions, the 2008 emissions were grown using detailed inventory data (both before and after contro ls) for 1996 and 2010 obtained from the USEPA’s CAIR Technical Support Document.

Appendix D provides a detailed discussion of the non-road mobile source inventory.The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 5 North Carolina Reasonable Further Progress Demonstration November 30, 2009 3.4 Highway Mobile Sources

In order to accurately model the mobile sour ce emissions in the Metrolina nonattainment area, the latest version of the MOBILE model, MO BILE6.2, was used. Key inputs for the MOBILE model include information on the age of vehicles on the roads, the average speed on the roads, the mix of vehicles on the roads, any control t echnologies in place in an area to reduce emissions for motor vehicles (e.g., emissions inspection pr ograms), and temperature. The MOBILE model inputs were developed through inte ragency consultation with the tr ansportation partners for this

area.
The MOBILE model takes into consideration rules in effect that impact the emissions from this source sector. The same model then is run fo r the milestone year em issions inventory using input data reflective of 2008. The 2002 and 2008 vehicle age and vehicle mix data were obtained from the North Carolina Department of Transportation (NCDOT). The vehicle miles traveled and speed data were provided by the Charlotte Department of Transportation (CDOT) and came from the Metrolina regi onal travel demand model.

For a detailed discussion about the on-road mobile source inventory development and the data used in the RFP demonstration, please refer to Appendix E.

3.5 Emissions Inventory Summary

The NCDAQ’s 2002 baseline VOC emissions for the Metrolina area are pres ented in Table 3-1. The 2008 VOC emission estimates are presented in Table 3-2. Since the only portion of Iredell County designated as nonattain ment are the townships of Coddle Creek and Davidson, the emissions for Iredell County have been adjusted to reflect this. Fo r point sources, only the facilities located within the nona ttainment area were used to estimate the emissions. For area sources and non-road mobile sources, these emis sions are estimated at the county level. To estimate the emissions for the nonattainment area, the fraction of the County’s population in the two nonattainment townships (32.6% based upon th e U.S. Census data) was used to apportion the emissions. For on-road mobile sources, th e VMT and speeds for the nonattainment portion of the County were used to estimate the emi ssions. This information was provided by CDOT.

Table 3-1 Metrolina Nonattainment Area 2002 Baseline VOC Emissions (tons/day)
County Point Area Non-Road Mobile On-Road Mobile Total
Cabarrus 2.2 6.0 2.7 20.5 31.4 Gaston 2.5 8.9 2.9 13.3 27.6 Iredell (partial) 0.9 1.9 0.9 6.6 10.3 Lincoln 2.1 3.1 1.3 6.7 13.2 Mecklenburg 5.7 29.4 24.1 66.1 125.3 Rowan 6.3 5.6 2.3 14.2 28.4 Union 1.0 6.4 4.7 12.3 24.4 Total 20.7 61.3 38.9 139.7 260.6The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 6 North Carolina Reasonable Further Progress Demonstration November 30, 2009 Table 3-2 Metrolina Nonattainment Area 2008 Baseline VOC Emissions (tons/day)
County Point Area Non-Road Mobile On-Road Mobile Total
Cabarrus 2.3 5.9 1.5 10.4 20.1 Gaston 2.7 9.4 2.0 7.5 21.6 Iredell (partial) 0.7 1.8 0.5 5.4 8.4 Lincoln 2.1 2.9 0.8 4.2 10.0 Mecklenburg 5.9 30.1 13.0 38.0 87.0 Rowan 6.0 5.6 1.5 9.2 22.3 Union 1.2 5.7 1.7 9.9 18.5 Total 20.9 61.4 21.0 84.6 187.9



### 4 ESTIMATION OF NON-CREDITABLE REDUCTIONS

As discussed in Section 2, the non-creditable emi ssions must be estimated and subtracted from the 2002 base year inventory. To calculate th ese emissions the USEPA’ s MOBILE6.2 model is run for both years with the “ NO CLEAN AIR ACT” flag set.

The average daily speeds for 2002 and 2008 were used for the purpose of estimating the non-creditable emissions. The year specific vehicl e age distribution and vehicle mix data were used as well. The fuel RVPs were set to th e appropriate June 1990 requirements. Since the Metrolina area did not have an ozone I/M program in place in 1990, no I/M program was modeled in accordance with the USEPA guidan ce for determining non-creditable emissions.

There were two instances in Ir edell County where road types we re reclassified between 2002 and 2008, resulting in a mismatch between 2002 and 2008 emission factors. The NCDAQ needed to make some adjustments so that the non-creditable emissions could be calculated correctly. First, the 2008 urban principal arterial em ission factor was used for the ru ral principal arterial emission factor since there were no longer any rural prin cipal arterial road classes in the 2008 data. Similarly, there were no longer a ny rural interstate road cla sses in the 2008 data for the nonattainment portion of Iredell County. In this case, the urban interstate emission factor was used in place of the rural interstate emission factor.

The difference between the 2002 and 2008 VOC emission factors was multiplied by the 2002 VMT. The result is the VOC emission reducti ons that occurred between 2002 and 2008 without the benefits of any post-1990 CAA measures. These are the non-creditable emission reductions that have occurred over this period.

The following table displays the results from the non-creditable emission estimates including the emission factors established thr ough the MOBILE6.2 runs. The input and output files from these runs can be found in Appendix A.The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 7 North Carolina Reasonable Further Progress Demonstration November 30, 2009 Table 4-1 Cabarrus County Non-Cred itable VOC Emission Estimates

Cabarrus County 2002 Average Daily VMT 2002 w/o CAA (gram/mile) 2008 w/o CAA (gram/mile) 2002w/o CAA EF2008w/o CAA EF (gram/mile) Non Creditable Emissions (tons/day) Rural Interstate 0.000 0.000 Rural principle arterial 324,349 2.093 1.734 0.359 0.128 Rural minor arterial 211,964 2.118 1.741 0.377 0.088 Rural major collector 385,957 2.184 1.889 0.295 0.126 Rural minor collector 299,131 2.235 1.901 0.334 0.110 Rural local 488,675 2.413 2.136 0.277 0.149

Urban interstate 1,246,972 2.049 1.719 0.33 0.454 Urban freeway - 0.000 0.000 Urban principle arterial 670,359 2.445 2.123 0.322 0.238 Urban minor arterial 583,244 2.416 2.148 0.268 0.172 Urban collector 298,966 2.367 2.151 0.216 0.071 Urban local 805,910 2.449 2.278 0.171 0.152 1.688

Table 4-2 Gaston County Non-Cred itable VOC Emission Estimates

Gaston County 2002 Average Daily VMT 2002 w/o CAA (gram/mile) 2008 w/o CAA (gram/mile) 2002w/o CAA EF2008w/o CAA EF (gram/mile) Non Creditable Emissions (tons/day) Rural Interstate 202,517 1.506 1.185 0.321 0.072 Rural principle arterial 227,278 1.364 1.292 0.072 0.018 Rural minor arterial 317,040 1.537 1.382 0.155 0.054 Rural major collector 460,235 1.523 1.423 0.100 0.051 Rural minor collector 219,603 1.517 1.447 0.070 0.017 Rural local 413,826 1.684 1.578 0.106 0.048

Urban interstate 2,020,626 1.404 1.29 0.114 0.254 Urban freeway 102,101 1.398 1.321 0.077 0.009 Urban principle arterial 1,091,841 1.749 1.543 0.206 0.248 Urban minor arterial 778,751 1.674 1.529 0.145 0.124 Urban collector 75,464 1.768 1.686 0.082 0.007 Urban local 801,096 1.713 1.702 0.011 0.010 0.912The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 8 North Carolina Reasonable Further Progress Demonstration November 30, 2009 Table 4-3 Nonattainment Portion of Ired ell County Non-Creditable VOC Emission Estimates

Iredell County (NA portion) 2002 Average Daily VMT 2002 w/o CAA (gram/mile) 2008 w/o CAA (gram/mile) 2002w/o CAA EF2008w/o CAA EF (gram/mile) Non Creditable Emissions (tons/day) Rural Interstate 968,000 1.8 1.541 0.259 0.276 Rural principle arterial 5,000 1.96 2.252 -0.292 -0.002 Rural minor arterial 176,000 2.978 2.348 0.63 0.122 Rural major collector 194,000 2.364 2.039 0.325 0.07 Rural minor collector 143,000 2.5 2.255 0.245 0.039 Rural local 354,000 2.5 2.193 0.307 0.12

Urban interstate 8,000 1.914 1.541 0.373 0.003 Urban freeway - 0 0 Urban principle arterial 78,000 2.679 2.252 0.427 0.037 Urban minor arterial 130,000 2.53 2.224 0.306 0.044 Urban collector 43,000 2.567 2.361 0.206 0.01 Urban local 153,000 2.922 2.314 0.608 0.103 0.822

Table 4-4 Lincoln County Non-Cred itable VOC Emission Estimates

Lincoln County 2002 Average Daily VMT 2002 w/o CAA (gram/mile) 2008 w/o CAA (gram/mile) 2002w/o CAA EF2008w/o CAA EF (gram/mile) Non Creditable Emissions (tons/day) Rural Interstate - 0.000 0.000 Rural principle arterial 252,752 1.897 1.688 0.209 0.058 Rural minor arterial 556,376 2.242 1.94 0.302 0.185 Rural major collector 175,958 2.065 1.782 0.283 0.055 Rural minor collector 214,940 2.101 1.878 0.223 0.053 Rural local 487,396 2.413 2.111 0.302 0.162

Urban interstate - 0.000 0.000 Urban freeway - 0.000 0.000 Urban principle arterial 127,620 2.188 1.931 0.257 0.036 Urban minor arterial 50,780 2.726 2.32 0.406 0.023 Urban collector 24,699 2.641 2.151 0.490 0.013 Urban local 254,959 2.449 2.278 0.171 0.048 0.633The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 9 North Carolina Reasonable Further Progress Demonstration November 30, 2009 Table 4-5 Mecklenburg County Non-Cred itable VOC Emission Estimates

Mecklenburg County 2002 Average Daily VMT 2002 w/o CAA (gram/mile) 2008 w/o CAA (gram/mile) 2002w/o CAA EF2008w/o CAA EF (gram/mile) Non Creditable Emissions (tons/day) Rural Interstate 0.000 0.000 Rural principle arterial 862,659 1.583 1.379 0.204 0.194 Rural minor arterial 889,625 1.716 1.568 0.148 0.145 Rural major collector 102,926 1.473 1.576 -0.103 -0.012 Rural minor collector 676,325 1.579 1.447 0.132 0.098 Rural local 1,407,138 1.684 1.543 0.141 0.219

Urban interstate 6,526,862 1.449 1.302 0.147 1.058 Urban freeway 2,601,924 1.51 1.326 0.184 0.528 Urban principle arterial 4,120,914 1.79 1.643 0.147 0.668 Urban minor arterial 3,836,035 1.788 1.642 0.146 0.617 Urban collector 1,675,106 1.813 1.686 0.127 0.235 Urban local 2,961,152 1.713 1.825 -0.112 -0.366 3.384

Table 4-6 Rowan County Non-Cred itable VOC Emission Estimates

Rowan County 2002 Average Daily VMT 2002 w/o CAA (gram/mile) 2008 w/o CAA (gram/mile) 2002w/o CAA EF2008w/o CAA EF (gram/mile) Non Creditable Emissions (tons/day) Rural Interstate 0.000 0.000 Rural principle arterial 301,122 2.106 1.806 0.300 0.100 Rural minor arterial 138,870 2.04 1.741 0.299 0.046 Rural major collector 557,888 2.055 1.806 0.249 0.153 Rural minor collector 230,904 2.058 1.844 0.214 0.054 Rural local 647,760 2.413 2.136 0.277 0.198

Urban interstate 1,365,153 1.907 1.649 0.258 0.388 Urban freeway - 0.000 0.000 Urban principle arterial 290,314 2.242 2.009 0.233 0.075 Urban minor arterial 443,688 2.24 1.981 0.259 0.127 Urban collector 196,149 2.321 2.127 0.194 0.042 Urban local 698,343 2.449 2.278 0.171 0.132 1.315The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 10 North Carolina Reasonable Further Progress Demonstration November 30, 2009 Table 4-7 Union County Non-Cred itable VOC Emission Estimates

Union County 2002 Average Daily VMT 2002 w/o CAA (gram/mile) 2008 w/o CAA (gram/mile) 2002w/o CAA EF2008w/o CAA EF (gram/mile) Non Creditable Emissions (tons/day) Rural Interstate - 0.000 0.000 Rural principle arterial 879,771 2.068 1.794 0.274 0.266 Rural minor arterial 225,913 2.082 1.781 0.301 0.075 Rural major collector 723,540 2.133 1.877 0.256 0.204 Rural minor collector 247,019 2.125 1.878 0.247 0.067 Rural local 1,267,433 2.413 2.087 0.326 0.455

Urban interstate - 0.000 0.000 Urban freeway - 0.000 0.000 Urban principle arterial 85,523 2.341 2.009 0.332 0.031 Urban minor arterial 221,132 2.318 2.123 0.195 0.048 Urban collector 44,271 2.272 2.026 0.246 0.012 Urban local 279,986 2.449 2.217 0.232 0.072 1.230

The total non-creditable emissions for the Metr olina RFP demonstration are summarized in Table 4-8.

Table 4-8 Total Metrolina Nonattainment Area Non-Creditable VOC Emission Estimates County Non-Creditable VOC Emissions (tons/day) Cabarrus 1.688 Gaston 0.912 Iredell 0.822 Lincoln 0.633 Mecklenburg 3.384 Rowan 1.315 Union 1.230 Total 9.984



### 5 REASONABLE FURTHER PROGRESS DEMONSTRATION

To determine if reasonable further progress is de monstrated, the steps as outlined in Method 1 of the USEPA’s guidance are followed.

• Step A is the actual anthropogenic base ye ar VOC emissions inve ntory in 2002. This value comes from Table 3-1.The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 11 North Carolina Reasonable Further Progress Demonstration November 30, 2009 • Step C are the non-creditable emissions which can be found in Table 4-8.

• Step D is the 2002 base year emissions (S tep A) minus the non-creditable emissions (Step C).

• Step E is the 2008 target level VOC emi ssions which is calculated by reducing the emissions from Step D by 15 percent.

• Finally, the estimated 2008 VOC emissions (Tab le 3-2) are compared to the 2008 target level VOC emissions (Step E).

Since the 2008 VOC emissions are well below the target level, RFP is demonstrated for the Metrolina nonattainment area. Table 5-1 belo w provides the summary 15 percent RFP analysis showing the projected 2008 VOC emissions for the area, 187.9 tons/da y, are well below the target level of emissions, 213.0 tons/d ay, as calculated using Method 1.

Table 5-1 Metrolina Nonattainment Area 15 Percent RFP Analysis
Metrolina 15% RFP Analysis VOC (tons/day) Step from Method 1
Total 2002 Base year anthropogenic VOC emissions 260.6 Step A Non-creditable VOC reductions 10.0 Step C 2002 base year minus the non-creditable emissions 250.6 Step D 2008 target level of VOC emissions 213.0 Step E 2008 projected VOC emissions 187.9 Projection < Target RFP goal met

The NCDAQ must show continued progress from 2008 through the attainment date. To do so, the NCDAQ calculated the expected benefits from the fleet turnover for the on-road and off-road mobile sectors. Based on modeling em issions for 2009 and 2011, the NCDAQ expects approximately 14 tons per day of nitrogen oxi des (NOx) emissions reductions from fleet turnover. Since the CAAA allows an area to focus on NOx emission reductions once the first RFP demonstration is approved, the NCDAQ did not calculate future expected VOC emissions reductions in these years due to the region being NOx limited. However, additional VOC reductions are expected from the fleet turnover of the on-road mobile sector. The NCDAQ believes these additional reducti ons demonstrate continued reas onable further progress toward attainment beyond 2008.



### 6 MOTOR VEHICLE EMISSION BUDGETS

6.1 Transportation Conformity

Another requirement of the RFP demonstrati on is that VOC motor vehicle emission budgets (MVEBs), for transportation conformity purposes, need to be set for the RFP milestone year 2008. The purpose of transportation conformity is to ensure that Federal transportation actionsThe Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 12 North Carolina Reasonable Further Progress Demonstration November 30, 2009 occurring in nonattainment and maintenance ar eas do not hinder the area from attaining and maintaining the 8-hour ozone standard. This mean s that the level of emissions estimated by the NCDOT or the metropolitan planning organi zations for the Transportation Improvement Program and Long Range Transportation Plan must not exceed the MVEBs as defined in this RFP demonstration.

Since the State is NOx limited with respect to ozone formation, as a SI P strengthening measure the NCDAQ has elected to also set NOx MVEBs. In order to establish NOx MVEBs, the USEPA requires the SIP to include the NOx em issions from all source sectors. Table 6-1 summarizes the 2008 NOx emissions from all so urce sectors. The de velopment of these emissions is discussed in Appendices B through E.

Table 6-1 Metrolina Nonattainment Area 2008 NOx Emissions (tons/day)
County Point Area Non-Road Mobile On-Road Mobile Total
Cabarrus 2.6 1.5 4.1 9.6 17.8 Gaston 32.8 2.2 4.8 10.0 49.8 Iredell (partial) 0.5 0.4 0.9 6.9 8.7 Lincoln 9.3 0.7 1.4 3.7 15.1 Mecklenburg 2.0 11.3 20.9 45.6 79.8 Rowan 22.4 1.3 4.6 9.5 37.8 Union 0.2 1.5 3.3 7.4 12.4 Total 69.8 18.9 40.0 92.7 221.4

6.2 Motor Vehicle Emission Budgets

As part of the consultation process on se tting MVEBs, the NCDAQ sent out a request for comment on setting the geographic extent of the MV EBs to all of the tran sportation partners. A copy of the letter can be found in Appendix F. In the letter, the NCDAQ e xpressed its preference for setting county level budgets and the reasons why the NC DAQ believed county level budgets were appropriate.

The NCDAQ received comments from several of the transportation partners regarding the geographic extent of the MVEBs. Some of the partners wanted county-by-county budgets; others wanted regional budgets. Those transporta tion partners preferring a regional budget stated in their letter that they would agree to c ounty-by-county MVEBs for those areas wanting county level MVEBs and a single budget for the rema inder of the North Ca rolina portion of the Metrolina nonattainment area. C opies of the letters received can be found in Appendix F. Upon careful consideration of all arguments, the NC DAQ decided to move forward with setting county level MVEBs. The NCDAQ believes that since mobile source NOx emissions play a significant role in the ozone formation in the Metrolina area, it is important that th e large counties in the area meet the county level MVEBs that closely repr esent the emissions that were modeled for the attainment demonstration.The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 13 North Carolina Reasonable Further Progress Demonstration November 30, 2009 The MVEBs will be set for the RFP milestone year 2008. Although the emissions are usually expressed in terms of tons per day, the MVEBs w ill be set in terms of kilograms (kg) per day. The reason for the change is because the MOBI LE model generates the emissions factors in grams per mile. In past conform ity exercises, there have been some issues with conversion to tons per day, as well as concerns with how the MVEBs were rounded to the hundredth place. Setting MVEBs in kilograms per day will avoid these issues in future conformity determinations.

The mobile inputs used to develop the MVEBs were developed through in teragency consultation with the transportation partners for this area. These inputs were c onsistent with what was used in the RFP demonstration, and do not represent a significant change to the emissions.

The table below shows the North Carolina countie s with their on-road mobile source emissions expressed in kilograms per day and the corresponding tons per day values for 2008.

Table 6-2 On-Road Mobile Source 2008 Emissions Metrolina Nonattainment Area
County NOx VOC Kg/day Tons/day Kg/day Tons/day Cabarrus 7,324 8.07 6,941 7.65 Gaston 7,647 8.43 5,132 5.66 Iredell* 5,637 6.21 3,601 3.97 Lincoln 2,948 3.25 2,726 3.01 Mecklenburg 34,526 38.06 26,368 29.07 Rowan 7,193 7.93 6,149 6.78 Union 5,660 6.24 6,299 6.94 Total 70,935 78.19 57,216 63.08 * Iredell County emissions for nonattainment area only.

The NCDAQ is setting MVEB, for transportation conformity purposes, as county budgets within the Metrolina nonattainment area for 2008. Table 6-3 below lists out the MVEBs in kilograms per day, for transportation conformity purpos es, by county. Upon the USEPA’s affirmative adequacy finding for these county level sub- area MVEBs, these MVEBs will become the applicable MVEBs for each county.The Charlotte-Gastonia-Rock H ill, NC-SC 8-Hour Ozone 14 North Carolina Reasonable Further Progress Demonstration November 30, 2009 Table 6-3 County Level MVEB for 2008
County NOx MVEB (Kilograms/day) VOC MVEB (Kilograms/day) Cabarrus 7,324 6,941

Gaston 7,647 5,132

Iredell* 5,637 3,601

Lincoln 2,948 2,726

Mecklenburg 34,526 26,368

Rowan 7,193 6,149

Union 5,660 6,299 * Iredell County MVEB fo r nonattainment area only



### 7 CONCLUSIONS

The NCDAQ has demonstrated that reasonable fu rther progress has been made from the base year 2002 to the milestone year 2008. For pur poses of SIP strengthening, the NCDAQ has established NOx MVEBs in addition to the required VOC MVEBs for 2008.