U NITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103 DATE: December 16, 2009 SUBJECT: Technical Support Document - Delaware ; R easonable Further Progress Plan ,

2002 Base Ye ar Emission s In ventory , Reasonably Available Control Measure s , Contingency

Measures, and Transportation Conformity Budgets for the Delaware Portion of the Philadelphia 1997 8 - Hour Ozone Moderate Nonattainment Area /s/ FROM: Rose Quinto, Environmental En gineer

Office of Air Program Planning TO: File /s/ THRU: Cristina Fernandez, Associate Director

Office of Air Program Planning This document provides a technical review of a revision to the Delaware State Implementation Plan (SI P) submitted by the Delaware Department of Natural R esources and Environmental Contr o l (DNREC) on June 13, 2007 . This SI P revision address es emissions inventory , reasonably

available control measures (RACM), contingency measures, and reasonable further progress (RFP) requ irements for the 1997 8 - hour ozone national ambient air qu ality standard (NAAQS) for the Delaware portion of the Philadelphia moderate nonattainment area . The SI P revision also establishes a motor vehicle emissions budget (MVEB) for 2008. A. BACKGROUND General Requirements Section 182 of the Clean Air Act (CAA) and the Environmental Protection Agency ’s ( EPA’s ) 1997 8 - hour ozone regulations (40 CFR 51.910) require each moderate and above 8 - hour ozone nonattainment area to submit an emissions inventory and RFP SI P revision that describes how the area will achieve actual emissions reductions of volatile organic compounds (VOC) and nitrogen oxides (NOx) from a baseline emissions inventory . An emissions inventory is an estimation of actual emissions of ai r pollutants in an area. The emissions inventory for an ozone nonattainment area contains VOC and NOx emissions, which are precursors to ozone formation. In this case, the baseline emissions inventory is 2002.2

Pursuant to section 172(c)(1) of the CAA, S tates are required to submit plans for nonattainment areas that provide for the implement of all r easonably available c ontrol m easures (RACM) as expeditiously as practicable. Specifically , section 172(c)(1) states the following: ‘‘Such plan provisions sh all provide for the implementation of all reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology ) and shall provide for attainment of the national primary ambient air quality standards.’’ Control measures that would advance the attainment date are considered RACM and must be included in the SI P. RACM are necessary to ensure that the attainment date is achieved ‘‘as expeditious as practicable.’’ Phase 1 of the 8 - hour ozone implementation rule, published on April 30, 2004 (69 FR 23951), set out criteria for classifying nonattainment areas under the 1997 8 - hour ozone standard. The Phase 1 rule also addressed revocation of the 1 - hour NAAQS; how anti - backsliding principles will ensure continued progress toward attainment of the 8 - hour ozone NAAQS; attainment dates; and the timing of emissions reductions needed for attainment . On November 29, 2005, EPA published the Phase 2 final rule for implementation of the 8 - hour standard. The Phase 2 rule addressed the RFP control and planning obligations as they apply to areas designated nonattainment for the 1997 8 - hour ozone NAAQS (70 FR 71612). The Phase 2 final rule was revised on June 8, 2007 (72 FR 31727). Among other things, the Phase 1 and 2 rules outline the SI P requirements and deadlines for various requirements in areas designated as moderate nonattainment. The rules set a d ue date of June 15, 2007 for the required base y ear emission inventory , RFP plan, modeling and attainment demonstration, RACM, MVEB, and contingency

measures (40 CFR 51.908(a), (c)). Section 182(b)(1) of the CAA and EPA’s 1997 8 - hour ozone implementation rule (40 CFR 51.910) require each 8 - hour ozone nonattainment area designated moderate and above to submit for r eview and approval into its SI P an emissions inventory and RFP p lan that describes how the area will achieve actual emissions reductions of VOC a nd NOx from a baseline emissions inventory . For a moderate 8 - hour ozone nonattainment area with an attainment date more than 5 y ears after designation, a 15 percent RFP reduction in ozone precursor emissions is required within 6 y ears (2002 - 2008). For a moderate area with an approved 15 percent rate - ofprogress (ROP) plan under the 1 - hour standard, States can use reductions from VOC or NOx or a combination of either. For a moderate area without an approved ROP plan, a 15% reduction in VOC is required. T hese VOC reductions can be obtained from the part of the area with an approved 1 - hour ROP. Table 1 outlines these requirements.3

Table 1. RFP Requirements for a Moderate 8 - Hour Ozone Nonattainment with an Attainment Date More than 5 Years after Des ignation Area Portion Requirement 40 CFR Reference Portion with approved 15% VOC ROP plan 15% VOC and/or NOx reductions (2002

– 2008) 51.910(a)(1)(iii)(B)(2) & 51.910(b)(2)(b)(ii) Portion without approved 15% VOC ROP plan 15% VOC reductions (2002 - 2008). The reductions may

come from any

where within the 8 - hour nonattainment area. 51.910(a)(1)(iii)(B)(1)

Inaddition, RFP plans must include contingency measure s , which are additional controls that would be implemented i f the area fails to make reasonable further progress. ( See CAA section 172(c)(9) ) . I mplementation of these measures would provide additional emissions reductions of up to 3 percent of the adjusted base y ear inventory (or lesser percentage that will make up the identified shortfall). RFP plans must also include a MVEB, which is the all owable on - road mobile emission an area can produce and continue to demonstrate RFP. ( See 40 CFR 93 ) . The State of Delaware In1997, EPA revised the health - based NAAQS f or ozone, setting it at 0.08 parts per million (ppm) averaged over an 8 - hour time frame. EPA set the 8 - hour ozone standard based on scientific evidence demonstrating that ozone causes adverse health effects at lower ozone concentrations and over longer pe riods of time, than was understood when the pre - existing 1 - hour ozone standard was set. EPA determined that the 8 - hour standard would be more protective of human health, especially children and adults who are active outdoors, and individuals with a pre - e xisting respiratory disease, such as asthma. On April 30, 2004 (69 FR 23951), EPA finalized its attainment/nonattainment designations for areas across the country with respect to the 8 - hour ozone standard. These actions became effective on June 15, 2004. Among those nonattainment areas is the Philadelphia - Wilmington - Atlantic City (PA - NJ - MD - DE) moderate nonattainment area (NAA). This NAA includes the three counties in Delaware, five counties in eastern Pennsylvania, one county in Maryland , and eight coun ties in southern New Jersey . Pursuant to Phase 1 of the 8 - hour ozone implementation rule, published on April 30, 2004 (69 FR 23951) , an area was classified under S ubpart 2 of the CAA based on its 8 - hour design value if that area had a 1 - hour design v alue at or above 0.121 ppm (the lowest 1 - h our design value in Table 1 of S ubpart 2). Based on this criterion, Delaware , as part of the Philadelphia area was classified under S ubpart 2 as a moderate nonattainment area. On November 29, 2005 (70 FR 71612), as revised on June 7, 2007 (72 FR 31727), EPA published the Phase 2 final rule for implementation of the 8 - hour standard that addressed the RFP control and planning obligations as they apply to areas designated nonattainment for the 19 97 8 - hour4

ozone NAAQ S. T he Phase 1 and 2 rules outline the SI P requirements and deadlines for various requirements in areas designated as moderate nonattainment. For such areas, reasonably available control technology (RACT) plans were due by Septemb er 2006 (40 CFR 51.912(a )(2)). The rules further require that modeling and attainment demonstrations, reasonable further progress plans, reasonably available control measures, projection y ear emission inventories, motor vehicle emissions budgets and contingency measures were all due by June 15, 2007 (40 CFR 51.908(a), (c)). Section 182(b)(1) of the CAA and EPA’s 1997 8 - hour ozone implementation rule (40 CFR 51.910) require each 8 - hour ozone nonattainment area designated moderate and above to submit an emissions inventory and R FP p lan, for review and approval into its SI P, that describes how the area will achieve actual emissions reductions of VOC and NOx from a baseline emissions inventory . B. STATE SUBMITTAL I. Base Year Emissions Inventory An emissions inventory

is a c omprehensive, accurate, current inventory of actual emissions from all sources and is required by section 172(c)(3) of the CAA. For ozone nonattainment areas, the emissions inventory needs to contain VOC and NOx emissions because these pollutants are prec ursors to ozone formation. EPA recommended 2002 as the base year emissions inventory , and is therefore the starting point for calculating RFP. Delaware submitted its 2002 base y ear emissions inventory on June 13, 2007. A summary of the 2002 base y ear VO C and NOx emissions in ventory are included in Tables 2 and 3 in this document . Table 2. Delaware 2 002 Base Year VOC Emissions in t ons per d ay (tpd) Source Sector Kent New Castle Sussex State Total Point 0.49 9.42 13.35 23.26 Stationary

Area 5.75 20.02 7.31 33.08 Non - Road Mobile 5.17 12.24 9.36 26.77 On - Road Mobile 5.45 16.98 9.95 32.38 Total Emissions 16.86 58.66 39.97 115.49 Table 3. Delaware 2 002 Base Year NOx Emissions in tpd Source Sector Kent New Castle Sussex State Total Point 5.06 44.09 24.95 74.10 Stationary

Area 0.45 1.95 0.77 3.17 Non - Road Mobile 15.02 24.62 13.15 52.79 On - Road Mobile 13.97 36.56 18.50 69.03 Total Emissions 34.50 107.22 57.37 199.095

II. Adjusted Base Year Inventory and 2008 RFP Target Levels The process for determining the emissions baseline from which the RFP reductions are calculated , is described in section 182(b)(1) of the CAA and 40 CFR 51.910. This baseline value has been determined to be the 2002 adjusted base year inventory . Sections 182(b)(1)(B) and (D) require the exclusion from the base y ear inventory of emissions benefits resulting from the Federal Motor Vehicle Control Prog ram (FMVCP) regulations promulgated by January 1, 1990, and the Reid Vapor Pressure (RVP) regulations promulgated June 11, 1990 (55 FR 23666 ) . The FMVCP and RVP emissions reductions are determined by the State using EPA’s on - road mobile source emissions m odeling software, MOBI LE6. The FMVCP and RVP emission reductions are then removed from the base y ear inventory by the State, resulting in an adjusted base y ear inventory . The emission reductions needed to satisfy the RFP requirement are then calculated f rom the adjusted base y ear inventory . These reductions are then subtracted from the adjusted base y ear inventory

to establish the emissions target for the RFP milestone y ear (2008). For moderate areas like Delaware , the CAA specifies a 15 percent reducti on in ozone precursor emissions over an initial 6 - ye ar period . Inthe Phase 2 r ule, EPA interpreted this requirement for areas that were also designated nonattainment and classified as moderate or higher for the 1 - hour o zone standard. In the Phase 2 r ule , EPA provided that an area classified as moderate or higher that has the same boundaries as an area, or is entirely composed of several areas or portions of areas, for which EPA fully approved a 15 percent plan for the 1 - hour NAAQS, is considered to have met the requirements of section 182(b)(1) of the CAA for the 8 - hour NAAQS. In this situation, a moderate nonattainment area is subject to RFP under section 172(c)(2) of the CAA and shall submit, no later than 3 y ears after designation for the 8 - hour NAAQ S, a SI P revision that meets the requirements of 40 CFR 51.910(b)(2). The RFP SI P revision must provide for a 15 percent emission reduction (either NOx and/or VOC) accounting for any growth that occurs during th e 6 - ye ar period following the baseline emiss ions inventory ye ar , that is, 2002 - 2008. The section s 182 and 172 requirements differ in that section 182(b)(1) specifies that it must be a 15 percent VOC reduction , where section 172(c) (2) provides that the 15 percent reduction can be either a VOC and/or NOx reduction. According to EPA’ s Phase 2 I mplementation Rule ( 70 FR 71612), Delaware must achieve 15 percent VOC emission reduction in Sussex County from its 2002 baseline level, and 15 percent VOC and/or NOx emission reduction in Kent and New Castle C ounties from their combined 2002 baseline level before the end of 2008. According to section 182(b)(1)(D) of the CAA, emission reductions that resulted from th e FMVCP and RVP rules promulgated prior to 1990 are not creditable for achieving RFP emission r eductions. Therefore, the 2002 base y ear inventory is adjusted by

subtracting the VOC and NOX emission reductions that are expected to occur between 2002 and the future milestone years d ue to the FMVCP and RVP rules. The FMVCP/RVP VOC and NOx emission re ductions that are expected between 2002 and 2008 were determined using EPA’s MOBI LE6.2 model. The input and output files of the MOBI LE6.2 runs for the adjustments, the emission factors6

generated , and relev ant calculations for emission projections are foun d in Appendix 4 - 1 of the Delaware SI P submit t al. The adjustments are presented in Table 4 for Sussex County and Table 5 for Kent and New Castle Counties. Table 4. Mobile Source FMVCP/RVP Adjustments for Sussex County in tpd Adjusted On - Road Mobile Sour ce Emissions VOC NOx Note

Adjusted for 2002 16.66 20.24 A Adjusted for 2008 15.51 18.81 B 2008 Mobile Source Adjustments for 2002 Baseline

2002 - 2008 1.15 1.42 C 2008 = A

– B 2008 Table 5. Mobile Source FMVCP/RVP Adjustments for Kent & New Castl e Counties in tpd Adjusted On - Road Mobile Source Emissions VOC NOx Note

Adjusted for 2002 42.16 56.02 a Adjusted for 2008 39.18 51.64 b 2008 Mobile Source Adjustments for 2002 Baseline

2002 - 2008 2.98 4.38 c 2008 = a – b 2008 The mobil e source ad

justments in Tables 4 and 5 are the non - creditable emission reductions due to the pre - 1990 FMVCP and RVP rules. Subtracting these adjustments from the 2002 base ye ar emissions inventory

(i.e., the S tate total emissions in Tables 2 and 3 ) will give the 200 2 adjusted base y ear emissions inventory relative to the subject milesto ne y ear, as presented in Table 6 for Sussex County and Table 7 for Kent and N ew Castle Counties. Table 6. The 2002 Adjusted Base Year Emissions Inventory for Sussex County in tpd VO C NOx Note 2002 Base Year Emissions Inventory 39.97 57.37 E Mobile Source Adjustments for 2002 - 2008 1.15 1.42 C 2008 2002 Adjusted Baseline Relative to 2008 38.82 55.95 F 2008 = E

– C 200 8 Table 7. The 2002 Adjust ed Base Year Emissions Inv entory for Kent & New Castle Counties in tpd VOC NOx Note 2002 Base Year Emissions Inventory 75.52 141.72 e Mobile Source Adjustments for 2002 - 2008 2.98 4.38 c 200 8 2002 Adjusted Baseline Relative to 2008 72.54 137.34 f 2008 = e – c 200 87

By the end of 2008, Delaware is required to reduce 15 percent in its 2002 adjusted base ye ar emissions invent ory . According to the Phase 2 r ule (70 FR 71612), Sussex County must achieve this 15 percent reduction in its VOC emission, si nce it did not h ave a 15 percent VOC ROP plan approved by

EPA under the 1 - hour ozone standard. For Kent and New Castle Counties , their 15 percent emissi on reductions can be achieved f r o m VOC emissions and/or from NOx emissions. The 15 percent VOC emission reduction and emission target in 2008 in Sussex County are calculated as follows:

Sussex 2002 adjusted VOC baseline relative to 2008 is 38.82 tpd. Required 15 percent emissio n reduction: 38.82 x 15% = 5.82 tpd. 2008 VOC emission target: 38.83
– 5.82 = 33.0 0 tpd. The 15 percent VOC emission reduction and emission target in 2008 in Kent and New Castle Counties are calculated as follows:

Kent/New Castle 2002 adjusted VOC baseline relative to 2008 is 72.54 tpd. Required 15 percent emissio n reduction: 7 2.54 x 15% = 10.88 tpd. 2008 VOC emission target: 72.54
– 10.88 = 61.66 tpd. III. Control Measures and Emission Reductions for RFP The only post - 2002 point source VOC control in Sussex County is Regulation No. 24, Section 46, Control of Crude Oil L i ghtering Operations. Since there were no new VOC controls for point sources, non - point source sector, and non - road mobile source sector for VOC emissions between 2008 and 2009, Delaware’s 2008 emission reductions and projections are estimated by interpolating the 2002 base y ear emissions and the 2009 projections. Kent and New Castle Counties applied for and obtained total VOC and NOx emission reductions from facility /unit shutdown or modification. The 2008 on - road mobile source VOC emissions were project ed using EPA’s MOBI LE6.2 for obtaining factors and the P eninsula Travel Demand Model (PTDM) for predicting future vehicle miles traveled (VMT). Tables 8 and 9 summarize the total 2008 VOC emission projection for the RFP requirements for Sussex County , and Kent and New Castle Counties, respectively .8

Tabl e 8. Sussex County Total VOC Emission Projection in tpd Point Source Sector 10.71 Area Source Sector 6.32 Non - Road Mobile Sector 8.01 On - Road Mobile Sector 7.09 Total 2008 Emission Projection 3 2.13 The total VOC emission projection meets the 20 08 emission target under the 15 percent RFP requirements (33.00 tpd). Therefore, the 2008 RFP in Sussex County is demonstrated. Table 9. Kent & New Castle Counties Total VOC Emission Projection in tpd Point Source Sector 10.51 Area Source Sector 21.64 Non - Road Mobile Sector 13.81 On - Road Mobile Sector 14.75 Total 2008 Emission Projection 60.71 The total VOC emission projection meets the 20 08 emission target under the 15 percent RFP requireme nts (61.66 tpd). Therefore, the 2008 RFP in Kent and New Castle Counties is demonstrated. IV . Contingency

Measures The CAA requires States with nonattainment areas to implement specific control measures if the area fails to make RFP (CA A section 172( c)(9)) . This CAA provision is a requirement for States with moderate and above ozone nonattainment areas to include sufficient contingency

measures in their RFP so that, upon implementation of such measures, additional emission reductions of at least 3 pe rcent of the adjusted 2002 baseline emissions (or a lesser percentage that will make up the identified shortfall) would be achieved in the y ear after the failure has been identified . Under the same provision of the CAA, EPA also requires that the continge ncy

measures must be fully

adopted control measures or rules, so that upon failure to meet milestone requirements, the contingency measures can be implemented without any further rulemaking activities by

the States and/or EPA. For more information on cont ingency measures, see the April 16, 1992 General Preamble (57 FR 13512) and the November 29, 2005 Phase 2 8 - hour ozone implementation rule (70 FR 71612). To meet the requirements for contingency emission reductions, EPA allows States to use NOx emission reductions to substitute for VOC emission reductions in their contingency plans. The condition set forth by EPA for NOx substitution is that States must achieve a9

minimum of 0.3 V OC reductions of the total 3 percent contingency r eduction, and the remaini ng 2.7 percent reduction can be achieved through NOx emission controls. Delaware included both VOC and NOx emission controls as contingency measures in this 8 - hour ozone RFP. Based on the CAA and EPA requirements on contingency measures, the continge ncy VOC reduction for Delaware for the 2008 milestone year is as follows: The 2002 VOC baseline (statewide) adjusted to 2008 (see Tables 6 and 7 in this document) is 111.36 tpd, therefore, contingency VOC emission reduction in 2008 is 111.36 x 3 percent = 3.34 tpd. Analy sis in Chapter 5.5, page 29 of the Delaware SI P, indicates that the three counties in Delaware will have a VOC emission reduction surplus of 1.82 tpd in 2008 [i.e., (33.00 + 61.66)

– (32.13 + 60.71) = (94.66

– 92.84) = 1.82]. Therefore there is 3.34

– 1. 82 = 1.52 tpd contingency

VOC reduction shortfall in 2008. Delaware’s 2002 VOC - to - NOx baseline (with respect to 2008) ratio is (38.82 + 72.54): (55.95 + 137.34) = 111.36:193.29 = 1:1.74 (Section 4, Tables 4 - 3 and 4 - 4 in the Delaware S IP ) . Therefore, the contingency VOC reduction s hortfall is equivalent to 1.52 x 1.74 = 2.64 tpd NOx reduction shortfall. Del aware has implemented numerous controls leading to NOx reductions in 2008 that are greater than the identified 2.64 contingency shortfall ( see s ubsections 5.4 and 6.4 of the Delaware SI P) . Therefore, there is no need to specify additional contingency

meas ures for the 2008 milestone y ear. V. RACM Analy sis and Determination Section 172(c)(1) of the CAA and 40 CFR 51.912(d) impose a RACM requirement for areas designated nonattainment for the 8 - hour NAAQS. Delaware must demonstrate that it has adopted a ll RACM controls necessary to move toward attainment as expeditiously as practicable and to meet all RFP requirements.

Section I II of this document, demonstrates that the RFP requirements for Delaware have been met. Control measures under RACT, constitute a major group of RACM control measures for stationary

sources. To meet the CAA’s RACT requirements under the 8 - hour ozone standard, Delaware submitted a RACT SI P revision o n October 2, 2006, which certifies that all relevant RACT controls have been implemented in Delaware for attaining the 8 - hour ozone standard . EPA approved Delaware’s 8 - hour RACT SI P revision on July 23, 2008 (73 FR 42681). On May

2, 2007, Delaware submitted a new VOC control from crude oil lightering operations. EPA approved this rule on September 13, 2007 (72 FR 52285).10 Inaddition to those RACT control measures, Delaware adopted a number of other VOC and NOx RACM measures . A summary of the other control measures that Delaware adopted are listed in Table 10. Table 10. Summary of Other Control Measures

Control Measures Date submitted to EPA Approval Date Regulation 1113

– Tightening of Delaware’s Open Burning Regulation 05/02/07 09/20/07 (72 FR 53686) Regulation 1144

– Control of Stationary Generator Emissions 11/01/07 04/29/ 08 (73 FR 23101) Regulation 1148

– Control of Stationary Combustion Turbine Emissions 09/11/07 11/10/08 (73 FR 66554) Regulation 1145

– Restrictions on Excessive Id ling of Heavy

Duty Vehicles Brandy wine School Districts Clean School Bus USA grant V oluntary

and mandatory

Ozone Action Day initiatives T here are no additional RACM measures or group of RACM measures that Delaware could adopt to advance the attainment date from 2009 to 2008 , therefore Delaware has met the RACM requirements of the CA A. V I . Transportation Conformity Budgets Section 176 of the CAA requires that highway transportation activities in ozone nonattainment areas must: (1) establish in their SI P, mobile source VOC and NOx emission budgets for each of the milestone y ears up to the attainment y ear and submit the mobile budgets to EPA for approval; (2) upon adequacy determination or approval of EPA, States must conduct transportation conformity analy sis for their Transportation Improvement Programs (TI Ps) and long range transportation plans to ensure highway vehicle emissions will not exceed relevant mobile budgets; and (3) failure of demonstrating such transportation conformity lapses resulting in freezing of Federal highway funds and all Federal highway projects in the lap sed area. The mobile emission budgets for 2008 RFP milestone are based on the projected 2008 mobile source emissions, accounting for all relevant mobile source controls including all Federal controls and Delaware specific controls. The 2008 mobile emis sions are projected using EPA’s MOBI LE6.2 for obtaining emission factors and the “Peninsula Travel Demand Model” for11

predicting future vehicl e miles traveled (VMT). Table 11 is a summary of the 2008 VOC and NOx motor vehicle emissions budgets for the thre e counties in Delaware. Table 11 . Motor Vehicle Emission Budgets for 2008 County FIPS 2008 Emissions (tpd ) VOC NOx Kent 10001 4.14 9.68 New Castle 10003 10.61 21.35 Sussex 10005 7.09 12.86 State Total 21.84 43.89 On Marc h 21, 2008, EPA posted the availability of these budgets for Delaware on EPA’s conformity

website for the purpose of soliciting public comments. The public comment period closed on April 21, 2008 and no comments were received. On December 19, 2008 (73 FR 77682), EPA published a notice of adequacy for the Delaware 2008 RFP MVEBs. In this notice, EPA found that Delaware’s RFP MVEBs are adequate for transportation conformity purposes. As a result of EPA’s finding, Delaware shall use the MVEBs from the June 13, 2007 RFP plan for future conformity

determinations for the 8 - hour standard. D . SUMMARY AND RECOMMENDATIONS : D NREC has used acceptable techniques and methodologies to develop the base year and milestone y ear inventories, the emi ssion reductions for the milestone y ear, and the effects of non creditable reductions and pre - 1990 CAA rule corrections. VOC and NOx emissions for the period between 2002 and 2008 were well below the target level for 2008, and emissions in 2008 will be be low the rate - of

- progress target level. Therefore, we recommend approval of the Delaware RFP plan , contingency measures, RACM analy sis , and the 2002 base y ear inventory . Inaddition, we recommend the approval of the MVEBs which are based on the RFP plan.