Supplement to the Washington 

State Implementation Plan 

for the 

Vancouver Portion 

of the 

Portland-Vancouver AQMA 

Ozone Maintenance Plan 

Southwest Clean Air Agency 

11815 NE 99th Street, Suite 1294 

Vancouver, WA 98682-2454 

November 2, 2006

For more information

If you have questions or would like a copy of the Plan, please contact Robert Elliott, Executive 

Director at (360)574-3058 or Laurie Hulse-Moyer, Air Quality Scientist at (360)574-3058, ext. 

32. 

 
Washington State Implementation Plan 

Section 4.3.1.OZ.1 

Portland-Vancouver AQMA 

(Washington portion) 

Table of Contents 

Washington 

Section 

Washington 

Subsection 

Section Heading Page 

Acknowledgments 4

Executive Summary 5

1.0 Background 8

1.1 • Portland-Vancouver AQMA 8 

2.0 Ozone Trends and Compliance with Standards 11 

3.0 Attainment Inventory (2002) 14 

4.0 4.1 Portland-Vancouver AQMA Ozone Maintenance Plans 17 

4.2 • Vancouver Control Strategies 17 

4.2.1 o Current Strategies 17

4.2.1.1 • Motor Vehicle Inspection Program 18 

4.2.2 o Strategies with Proposed Rule Changes 19 

4.2.2.1 • Requirements for New Sources in 

a Maintenance Plan Area 

19 

4.2.3 o Additional Ozone Precursor Emissions 

Reduction Programs 

20 

4.2.3.1 • Changes to Commute Trip 

Reduction Program 

21 

5.0 Maintenance Demonstration 23

5.1 • Ozone Modeling Study 23 

5.2 • Growth Projections 23 

5.3 • Forecast and Maintenance Inventory (2015) 24 

5.4 • Maintenance Demonstration (2015) Ozone Level 

Projections 

30 

6.0 Air Quality Monitoring 32 

7.0 Contingency Plan 33

7.1 • Request to Remove 1-hour Contingency Plan 

Requirements 

33 

7.2 • Portland-Vancouver AQMA 33 

7.2.1 o Contingency Plan Based on Ambient 

Concentrations in Portland and 

Vancouver 

33 

8.0 8.0 Verification of Continued Attainment 35 

Appendices and References 36

These Washington Sections correspond with Sections in the Portland Portion of the Portland-Vancouver AQMA. For 

example, Washington Section 5.0 corresponds with Oregon Section 4.50.5 and includes the Maintenance 

Demonstration information 

Vancouver Ozone Plan November 2, 2006 2 of 56 
List of Tables 

Table No. Subject Page

1 8-hour Ozone, Maximum Values (1998, 2003-2005) 12 

2 8-hour Ozone, Fourth Highest Design Values (1998, 2003-2005) 13 

3 Portland and Vancouver 2002 Annual Emissions (tons/year) 14 

4 Portland Area 2002 Attainment Inventories (lb/day) 15 

5 Vancouver Area 2002 Attainment Inventories (lb/day) 16 

6 Portland-Vancouver Area Population Projections 24 

7 Portland-Area 2015 Maintenance Demonstration, Typical Summer Day,

(lb/day) 

28 

8 Vancouver-Area 2015 Maintenance Demonstration, Typical Summer Day, 

(lb/day), Clark County 

29 

9 2015 Maintenance Demonstration (ozone values) 30 

10 Portland Area VOC and NOx Emissions (tons/year) 42 

11 Vancouver Area VOC and NOx Emissions (tons/year) 42 

List of Figures 

Figure 

No. 

Subject 

1 Portland-Vancouver Interstate AQMA (map) 9 

2 Vancouver Maintenance Boundary (map) 10 

3 Portland-Vancouver 8-Hour Ozone Values 12 

4 Portland Area VOC and NOx Emissions (lb/day), 2002 and 2015 Growth 

Projection and Maintenance Demonstration 

26 

5 Vancouver Area VOC and NOx Emissions (lb/day), 2002 and 2015 Growth 

Projection and Maintenance Demonstration 

27 

6 Portland-Vancouver Ozone Maintenance Demonstration 31 

Appendices 

No. Subject 

1 AQMA Ozone Monitoring Network (Portland-Vancouver) 37 

2 1992 to 2005 Meteorological Factors Conducive to Ozone Formation in the 

Portland-Vancouver Area (April 2006) 

41 

3 Emission Inventory

• Annual Emissions Inventory 

• Typical Summer Day Emissions Inventory 

• Summary of Portland Area Emissions 

• Summary of Vancouver Area Emissions 

42 

4 Modeling and Maintenance Demonstration - (Historical and Future Ozone 

Simulations Using the MM5/SMOKE/CMAQ System in the Portland-Vancouver 

Area (WSU, December 31, 2005)) 

48 

5 Economic Report to the Metro Council, 2000-2030 Regional Forecast for the 

Portland-Vancouver Metropolitan Area (Metro’s Data Resource Center, 

December 2002 final draft) 

49 

6 Modeled Attainment Test 50 

7 Vancouver Area Control Strategies 

• SWCAA Regulations 

• Washington State Regulations 

51 

8 Other Emission Reduction Programs Information 52 

9 Vancouver Attainment Area Map and Description 53 

Vancouver Ozone Plan November 2, 2006 3 of 56 
Acknowledgement and Executive Summary

Acknowledgements 

Without the efforts of numerous individuals in state and local governments who are dedicated to 

healthy air, this maintenance plan would not have been possible. Special appreciation goes to: 

Principal Authors: Laurie Hulse-Moyer, SWCAA, Washington Sections, Marianne Fitzgerald 

and David Collier, DEQ Air Quality Planning, Oregon Section and Background, Ozone Modeling 

portions; 

Principal Contributors to the Portland-Vancouver AQMA plans: 

Southwest Clean Air Agency

Robert Elliott Executive Director 

Paul Mairose Chief Engineer 

Randy Peltier Operations Manager 

Wess Safford Air Quality Engineer 

Wade Strange Air Quality Engineer (former) 

Kathy Finkle Public Information Specialist 

Clint Lamoreaux Air Quality Engineer 

Jackie Brown Air Quality Scientist 

Washington State Department of Ecology

Doug Schneider Air Quality Program, SIP Coordination 

Clint Bowman Air Quality Program, Meteorology 

Sally Otterson Air Quality Program, Emission Inventories 

Cristiana Figueroa-Kaminsky Air Quality Program, Atmospheric Chemistry (former) 

Regional Transportation Council (Vancouver, Washington)

Robert Hart, Project Manager 

Mark Harrington, Transportation Analyst 

Oregon Department of Environmental Quality

Andy Ginsburg Division Administrator, Air Quality 

Dick Pedersen Division Administrator, Northwest Region 

David Collier Manager, Air Quality Planning 

Cory Ann Wind Acting Manager, Northwest Region Air Quality 

Cheryll Hutchens Manager, Western Region Air Quality 

Gerry Preston Manager, Air Quality Technical Services 

Jeffrey Stocum Acting Manager, Air Quality Technical Services 

Wes Risher Air Quality Technical Services 

Svetlana Lazarev Air Quality Technical Services 

Chris Swab Air Quality Technical Services 

Phil Allen Air Quality Technical Services 

Susan Drake Northwest Region Air Quality 

Karen White-Fallen Western Region Air Quality 

Metro (Portland, Oregon )

Mark Turpel 

Pam Peck 

Andy Cotugno 

Vancouver Ozone Plan November 2, 2006 4 of 56 
Executive Summary

The Portland-Vancouver Air Quality Maintenance Area (AQMA) currently meets the National 

Ambient Air Quality Standard (NAAQS) for ozone. This plan demonstrates the PortlandVancouver AQMA will maintain compliance with the 8-hour ozone standard through 2015 and 

meets other EPA requirements. 

The 8-hour standard for ozone is 0.08 parts per million (ppm). An ozone reading over this level 

is an exceedence. An exceedence is not a violation; Only a design value over the standard 

constitutes a violation. The design value for each monitor in the AQMA is calculated using the 

4th highest ozone value, averaged over three years. 

The Portland-Vancouver AQMA was designated nonattainment with the 1-hour ozone standard 

on March 3, 1978 under the Clean Air Act Amendments of 1977. The 1990 Amendments to the 

Clean Air Act continued the nonattainment designation and classified the AQMA as 

marginal. EPA determined that the AQMA attained the 1-hour standard as of November 15, 

1993. 

In 1996, the Southwest Clean Air Agency (SWCAA) and the Oregon Department of 

Environmental Quality (DEQ) developed ozone maintenance plans that included strategies to 

reduce ozone precursors and ensure compliance with the 1-hour standard for a ten year period. 

With EPA's approval of these plans, the AQMA was redesignated to attainment in 1997 and 

became a 1-hour ozone maintenance area. SWCAA requests that EPA remove the obligation to 

prepare a second 10-year one-hour ozone maintenance plan since the one-hour standard has 

been revoked and accept this 8-hour maintenance plan as replacement for the existing 

contingency plan addressing the 1-hour standard. 

In July 1997, the U. S. Environmental Protection Agency (EPA) revised the ozone standard from 

a one-hour average of 0.12 ppm to an 8-hour average of 0.08 ppm. In 2005, EPA revoked the 

one-hour ozone standard. The strategies identified in the 1996 plans have been successful in 

reducing smog forming emissions and no violations of the ozone standards have occurred in the 

Portland-Vancouver area since 1998. The last violation occurred in 1998 when the one-hour 

ozone standard was temporarily revoked so the one-hour ozone contingency plan was not 

triggered. DEQ and SWCAA determined that no further controls were necessary because all 

emission reduction measures had not been fully implemented. The last violations of the 1-hour 

standard were in the Portland area at the Carus site. No violations of the 8-hour standard have 

occurred. 

Therefore, the Portland-Vancouver AQMA was designated a maintenance area for the 1-hour 

ozone standard and currently is an attainment area for the 8-hour ozone standard. EPA's 

implementation requirements for the 8-hour ozone standard require areas so designated to 

develop a plan that demonstrates continued maintenance of the standard for a period of 10-

years after designation of attainment and contains contingency measures. EPA designated the 

Portland-Vancouver AQMA in attainment effective June 15, 2004. This plan demonstrates 

compliance with the 8-hour ozone standard through 2015 and fulfills requirements established in

Section 110(a)(1) of the Clean Air Act. Both the Vancouver and the Portland areas are included 

in the ozone modeling and maintenance demonstration. 

This is the ozone maintenance plan for the Vancouver portion of the Portland-Vancouver AQMA 

prepared by the Southwest Clean Air Agency in Vancouver, Washington for adoption into the 

Washington State Implementation Plan (SIP).This 2006 maintenance plan maintains the 

Vancouver Ozone Plan November 2, 2006 5 of 56 
existing strategies adopted for the Portland-Vancouver AQMA in the 1996 Ozone plan to reduce 

and manage volatile organic compounds (VOC) and nitrogen oxide (NOx) emissions. 

Transportation Conformity Rules, included as control strategies in the previous ozone plan, no 

longer to apply to the Portland-Vancouver AQMA since it is an attainment area for the 8-hour 

ozone standard. 

The following control strategies support the Portland-Vancouver Ozone Maintenance Plan and 

currently apply to sources in the Vancouver area. 

• Motor Vehicle Emission Inspection Program (WAC 173-422) 

• Control Strategies/Programs supported by SWCAA General Air Pollution Regulations 

(SWCAA 400) 

o Air Discharge Permit Applications (Notice of Construction) (400-109) 

o New Source Review (400-110) 

o Requirements for New Sources in Nonattainment Areas (400-112) 

o Requirements for Replacement of Substantial Alteration of Emission Control 

Technology at an Existing Stationary Source (400-114) 

o Maintenance of Equipment (400-116) 

o Requirements for New Sources in a Nonattainment area (400-190) 

o Emission Standards and Controls for Sources Emitting VOCs (SWCAA 490) 

o Emission Standards and Controls for Sources Emitting Gasoline Vapors 

(SWCAA 491) 

o VOC Area Source Rules (SWCAA 493) 

Some sections of the General Air Pollution Regulations will be updated in support of this plan. 

The following SWCAA 400 sections will be modified: 

• Definitions (400-030) - adds ‘emission unit’ to definition of source 

• Sources Exempt from Registration Requirements (400-101) - clarifies exemption 

threshold 

• Requirements for New Sources in a Maintenance Plan Area (400-111) - clarifies use 

of offsets and industrial growth allowance provisions 

• Requirement for New Sources in an Attainment or Nonclassifiable Areas (400-113) - 

describes impact level and offset requirements and use of growth allowance 

The following programs, regulations and other anticipated changes described below contribute

to emission reductions of ozone precursors but are not relied upon in this plan for the 

maintenance demonstration: 

• Commute Trip Reduction Program (replaced by the CTR Efficiency Act) and CTR 

performance grants 

• Commute Trip Reduction Efficiency Act passed by the Washington state legislature 

in 2006 to improve transportation system efficiency, conserve energy and improve air 

quality. It targets urban growth areas with local and regional goals and performance 

reviews to be every two years – (replaced the old CTR program) 

• Public education and outreach including Air Pollution Advisories (formerly Clean Air 

Action Days), Public Presentations, Public Interaction and Educational Materials. 

Other anticipated changes in the future include: 

• Implementation of California motor vehicle standards for low emission vehicles 

beginning with the 2009 model year.

• Vapor recovery systems rules will be modified once the Washington fleet contains 

sufficient on-board canister systems that capture refueling emissions 

Vancouver Ozone Plan November 2, 2006 6 of 56 
Modeled predicted values show that the area will continue to comply with the ozone NAAQS 

through 2015. The modeling values and actual air quality data show that ozone levels can 

occasionally approach or exceed the 8-hour ozone standard level in the Portland-Vancouver 

area. Exceedence of the standard does not constitute a violation of the standard. To be in 

violation, the design value must exceed 0.085 ppm. The suite of strategies described above will 

work together to protect air quality as growth and population pressures increase over the next 

ten years. Implementing this suite of strategies will also reduce emissions of air toxics and 

greenhouse gases that are important emerging issues of concern. 

Vancouver Ozone Plan November 2, 2006 7 of 56 
1.0 Background

Ground level ozone, also known as smog, is an air pollutant formed in the atmosphere by a 

chemical reaction of volatile organic compounds (VOC) and oxides of nitrogen (NOx). This 

reaction is most intense on hot summer days with poor ventilation. Ozone is a strong 

respiratory system irritant that aggravates respiratory illnesses, impairs athletic performance, 

and can cause permanent respiratory system damage. Ozone can be especially harmful to 

older people and children, and can damage crops and other materials. 

1.1 Portland-Vancouver AQMA 

The Portland-Vancouver AQMA was designated ‘nonattainment’ and was not in compliance with 

the one-hour ozone standard on March 3, 1978. Over several decades, efforts to reduce smog 

forming emissions in the Portland-Vancouver area have included a combination of federal, 

state, and local emission control strategies, including a vehicle inspection and maintenance 

program for Portland area motor vehicles (1975) and Vancouver area motor vehicles (1993), 

industrial VOC controls (1978), and area source controls on gasoline station vapors (1991). 

EPA determined that the AQMA attained the 1-hour standard as of November 15, 1993. The 

most recent ozone maintenance plans for Portland-Vancouver were adopted by the Oregon 

Environmental Quality Commission (EQC) on July 12, 1996 and by the Board of Directors of the 

SWCAA on March 19, 1996. The Portland and Vancouver Interstate AQMA ozone maintenance 

plans were approved by EPA on May 19, 1997 (62 FR 27204). At that time, the AQMA was 

redesignated to attainment and became a 1-hour ozone maintenance area. A violation of the 

one-hour ozone standard did occur in July 1998 at the Carus monitoring site in Oregon (see 

Appendix 1)1

 . However, the violation occurred during a time when the one-hour ozone standard 

was temporarily revoked so it did not trigger the one-hour ozone contingency plan. DEQ’s 

analysis that was supported by SWCAA demonstrated that this violation occurred before all 

emission reduction measures had been fully implemented so no additional measures were 

needed. Since 1998, there have been no further violations of the one-hour ozone standard. 

In 1997, the EPA revised the ozone standard from a one-hour average of 0.12 parts per million 

(ppm) to an 8-hour average of 0.08 ppm. After a lengthy court battle, the courts upheld the 8-

hour ozone standard in 2002. EPA adopted rules to implement the 8-hour ozone standard on 

April 30, 2004, and revoked the one-hour standard effective June 15, 2005. EPA designated 

the Portland-Vancouver AQMA as “Unclassifiable/Attainment” with the 8-hour ozone standard, 

effective June 15, 2004 (69FR 23858, April 30, 2004). Under this designation, DEQ and 

SWCAA are required to submit maintenance plans (110(a) plans) for the Portland-Vancouver 

AQMA per 40 CFR 51.905(a)(4)(iii). No violations of the 8-hour ozone standard adopted in 1997 

have occurred. 

EPA rules to implement the 8-hour ozone standard (69 FR 23951, April 30, 2004) require 

SWCAA to prepare this 2006 maintenance plan update for the Portland-Vancouver area to 

ensure continued compliance with the 8-hour ozone standard. In accordance with the same 

EPA rules, SWCAA joins with Oregon DEQ in its request that EPA remove the obligation to 

prepare a second one-hour ozone maintenance plan. SWCAA further requests that EPA accept 

the contingency plan in this Maintenance Plan for the 8-hour standard as a replacement for the 

contingency plan currently in place for the one-hour standard.

 1

 Ozone monitoring sites were established in Oregon beginning in the early 1970s. The current 

Washington monitoring site was established in 1988. 

Vancouver Ozone Plan November 2, 2006 8 of 56 
Figure 1: Portland-Vancouver Interstate Air Quality Maintenance Area (AQMA) 

An analysis of meteorological and growth factors indicates that the number of days with 

elevated ozone levels should have risen over the past several years, but in fact has remained 

relatively stable (see Appendix 2). This stable ozone trend indicates that the ozone strategies 

continue to work despite significant population growth in the metropolitan areas and the 

occurrence of high temperature/air stagnation events that drive ozone formation. Continuing the 

suite of emission reduction strategies in the Portland-Vancouver AQMA ozone maintenance 

plan will continue to contribute toward reducing smog forming emissions. Modeling submitted 

with this plan demonstrates compliance based on these strategies through 2015. Nonetheless, 

modeled predicted values and air quality data indicate that ozone levels can occasionally 

approach or even exceed the 8-hour ozone standard in the Portland-Vancouver area. But it is 

important to note an exceedence of the standard is not a violation of the standard, and that the 

existing control strategies and other programs will be protective of air quality. 

Vancouver Ozone Plan November 2, 2006 9 of 56 
Figure 2. Vancouver Maintenance Boundary 

A full page copy of Figure 2 showing the Vancouver Maintenance Area Boundary with a 

description of the boundary is provided in Appendix 9. 

Vancouver Ozone Plan November 2, 2006 10 of 56 
2.0 Ozone Trends and Compliance with Standards 

Figure 3 shows the ozone trends measured at monitoring sites for the Portland and Vancouver, 

areas for the period 1997 through 2005. Table 1 shows the highest maximum 8-hour average 

ozone concentrations measured for 19982

, 2003, 2004, and 2005. While these peak values are 

important in assessing public health risk, they are not used to determine compliance with the 

federal ozone standard. Compliance with the standard is based on a statistical method that 

looks at the three year average of the 4th highest (maximum 8-hr avg.) ozone value recorded 

each year. If the three-year average of the 4th highest value at any monitoring site exceeds the 

standard, the area is in violation. Table 2 shows the rolling three-year average of 4th high 

values for 1998, 2003, 2004, and 2005. It is these “design values” that are compared to the 

0.08 ppm ozone standard to determine compliance. Under EPA’s calculation convention, a 

value of 0.084 ppm would round down to 0.08 ppm (i.e., in compliance), while a value of 0.085 

ppm or higher would be a violation. 

Ozone monitoring sites are shown in Appendix 1. The “Mountain View” site is the only site 

located in the Washington portion of the AQMA. 

The values illustrated in Tables 1 and 2, together with the 2015 Maintenance Projection 

described in Section 5.4 show that ozone levels can still occasionally approach or exceed the 8-

hour ozone standard in the Portland-Vancouver area, but that with the existing strategies in 

place, the region will maintain compliance with the 8-hour ozone standard. SWCAA and DEQ’s 

analysis with Washington State University (WSU), described in Section 5.4, demonstrates 

compliance so there is not currently a need to add new ozone strategies for the PortlandVancouver area. Existing emission reduction strategies should be continued to be protective of 

air quality. 

 2

 1998 is included in the table because that year had the most recent violation of the 1-hour ozone 

standard and the July 1998 episode was used in the modeling analysis 

Vancouver Ozone Plan November 2, 2006 11 of 56 
Figure 3: Portland-Vancouver 8-Hour Ozone Values 

Portland-Vancouver 8-hour Ozone Trend 

(1997-2005)

3 year averages of the 4th highest daily ozone value

0.030

0.040

0.050

0.060

0.070

0.080

0.090

0.100

1997 1998 1999 2000 2001 2002 2003 2004 2005

Year

8 hr Ozone (ppm) 3 year rolling average of 4th highest

Portland/Carus

Portland/Milwaukie

Portland/Sauvie Island

Vancouver/Mtn.View

Ozone AQ Standard 0.085 ppm

Ozone Monitoring Sites

Table 1: 8-Hour Ozone Maximum Values 

8-hour ozone standard = 0.08 ppm 

Exceedance ≥ 0.085 ppm maximum daily 8-hour average 

Monitoring Site 1998 

8-hour 

Maximum 

2003 

8-hour 

Maximum 

2004 

8-hour 

Maximum 

2005 

8-hour 

Maximum 

Portland/Carus 0.116 0.084 0.084 0.079

Portland/Milwaukie 0.100 0.068 0.077 0.063

Portland/Sauvie 

Island 

0.077 0.073 0.061 0.064

Vancouver/Mountain 

View

0.078 0.077 0.066 0.076

Vancouver Ozone Plan November 2, 2006 12 of 56 
Table 2: 8-Hour Ozone 4th Highest, Design Values

Design Value = 4th highest 8-hour average, averaged over three years 

8-hour ozone standard = 0.08 ppm 

Violation ≥ 0.085 ppm design value 

Monitoring Site 1998 Design

Value 

2003 

Design 

Value3

2004 

Design 

Value 

2005 

Design 

Value 

Portland/Carus 0.080 0.069 0.068 0.069

Portland/Milwaukie 0.066 0.061 0.059 0.055

Portland/Sauvie Island 0.065 0.062 0.062 0.061 

Vancouver/Mountain 

View 0.065 0.063 0.060 0.061

 3

 2003 Design Value was used to determine the attainment designation for Portland-Vancouver AQMA 

(January 22, 2004 letter from DEQ to EPA). Design value is calculated using the 4th highest ozone value 

at each monitoring site, averaged over 3 years. 

Vancouver Ozone Plan November 2, 2006 13 of 56 
3.0 Attainment Inventory

SWCAA and DEQ developed an attainment emission inventory for the year 2002. The emission

inventory for SWCAA reflects detailed estimates of emissions from all sources, grouped in four 

major categories: 

• Industrial (Point) Sources (e.g., sources inside Clark County with a SWCAA air quality 

permit), 

• On-Road Mobile Sources (e.g., cars and trucks), 

• Non-Road Mobile Sources (e.g., lawnmowers, construction equipment and other small 

engines), and 

• Area Sources (e.g., household products, print shops, degreasing and surface coating

operations, pesticide application, open burning and wildfires). 

The 2002 Consolidated Emissions Reporting Rule (CERR) emissions data submitted by 

SWCAA and DEQ to EPA’s National Emission Inventory (NEI) was used as the basis for the 

2002 attainment year inventory. This 2002 county-by-county annual inventory was developed 

following the currently accepted methodologies for the National Emission Inventory. Appendix 3 

and Appendix 4 describe the emissions inventory calculations in more detail. 

Table 3 contains the annual countywide emission estimates for the Portland-Vancouver AQMA, 

Oregon portion (Clackamas, Multnomah and Washington Counties) and Vancouver portion 

(Clark County) in tons/year. Tables 4 and 5 contain the countywide estimates, seasonally 

adjusted for a typical summer day in lb/day. Tables 4 and 5 are considered the “attainment 

inventory” for the Portland-Vancouver AQMA Ozone Maintenance Plan. 

EPA guidance requires an emission inventory for three pollutants, VOC, NOx and carbon 

monoxide (CO). However, VOC and NOx are the most critical precursor emissions that

contribute to ozone formation, so these pollutants are emphasized in the emission inventory 

tables throughout this maintenance plan. CO is included in some tables for reference.

Table 3: Portland and Vancouver 2002 Annual Emissions (tons/year) 

 Portland Area 2002 Attainment Inventory

(Clackamas, Multnomah, 

 Washington Counties)

2002 2002

Source Type VOC NOx

AREA 92,946 5,808

NON-ROAD 13,247 17,344

ON-ROAD 23,683 36,786

POINT 3,056 2,522

Total 132,931 62,461 

Vancouver Area 2002 Emissions

(Clark County)

Source Type

2002

VOC

2002 

NOx

AREA 11,636 602

NONROAD 1,797 2,859

ON-ROAD 6,274 9,272

POINT 652 1,111

--- ---

Total 20,359 13,844

Area source emissions were calculated following EPA guidance for the 2002 NEI. Table 3 

shows that area sources were the largest category of VOC emission sources in 2002, but it is 

important to note that most of the VOC emissions were from woodstoves. The annual area 

source emissions inventory for 2002 in both Portland and Vancouver includes residential wood 

stoves, which are a significant emitter of VOCs. However, these stoves are not likely to be in 

use during ozone episode conditions with temperatures above 90 degrees. Therefore, the 

summer-seasonal emissions inventory and ozone maintenance modeling demonstration 

reflecting daily summertime conditions did not include fireplace or woodstove emissions. Other 

Vancouver Ozone Plan November 2, 2006 14 of 56 
VOC area sources include painting, surface coating and degreasing operations, print shops and 

household consumer products. 

Non-road mobile source emissions for Vancouver for 2002 were calculated using EPA’s draft 

NONROAD2004 model and other methods following EPA guidance for the NEI. Non-road 

engines are also significant contributors to both VOC and NOx during the summer ozone 

season, and sources include aircraft, locomotives and marine engines as well as lawn and 

garden equipment, construction equipment, boats and personal watercraft. 

On-road mobile source emissions for the attainment inventory were calculated using EPA’s 

MOBILE 6.2 model and traffic data from the Southwest Washington Regional Transportation 

Council (RTC). Gasoline vehicles are a significant source of VOC and NOx emissions, as are 

diesel powered vehicles. 

Point source emissions for the 2002 Attainment Inventory are based on data submitted by 

permitted facilities and reflect actual 2002 emissions reported in annual reports to SWCAA. 

Within the Portland-Vancouver AQMA, industrial point sources that emit more than 10 tons/year 

of VOC, 40 tons/year of NOx, or 100 tons/year of CO were inventoried. Outside of the PortlandVancouver AQMA but within 25 miles of the attainment boundary, point sources that emit more 

than 40 tons/year of NOx or 100 tons/year of VOC or CO were inventoried. 

Biogenic emissions are naturally produced by vegetation (e.g., terpenes from pine trees) and 

can be distinguished from anthropogenic emissions that are produced by human activities. 

Biogenic emissions data was provided by WSU for the modeling study (Appendix 4) and 

calculated by county for this emissions inventory. 

Table 4: Portland Area 2002 Attainment Inventories (lb/day)

 Portland Area 2002 Attainment Inventory

 Typical Summer Day, lb/day

Clackamas, Multnomah, Washington Counties

 

2002 2002 2002

Source Type VOC NOx CO

AREA 253,871 5,529 26,644

BIOGENIC 437,910 3,890

NON-ROAD 110,188 136,713 1,202,805

ON-ROAD 139,542 216,750 1,699,493

POINT 17,020 14,913 12,202

Total 958,531 377,794 2,941,144

Portland Area

2002 NOx Attainment Inventory

ON-ROAD

58%

NON-ROAD

36%

AREA

1%

BIOGENIC

1%

POINT

4%

AREA BIOGENIC NON-ROAD ON-ROAD POINT

Portland Area

2002 CO Attainment Inventory

ON-ROAD

58%

NON-ROAD

41%

POINT

0%

AREA

1% BIOGENIC

0%

AREA BIOGENIC NON-ROAD ON-ROAD POINT

Portland Area 

2002 VOC Attainment Inventory

AREA

26%

BIOGENIC

46%

NON-ROAD

11%

ON-ROAD

15% POINT

2%

AREA BIOGENIC NON-ROAD ON-ROAD POINT

Vancouver Ozone Plan November 2, 2006 15 of 56 
Table 5: Vancouver Area 2002 Attainment Inventories (lb/day)

 Vancouver-Area 2002 Attainment Inventory

 Typical Summer Day, lb/day

 (Clark County)

2002 2002 2002

 Source Type VOC NOx CO

AREA 18,014 665 3,912

BIOGENIC 79,417 965

NONROAD 15,374 23,222 228,078

ON-ROAD 38,315 50,495 397,983

POINT 3,572 6,089 3,803

Total 154,692 81,436 633,776

Vancouver Area

2002 VOC Attainment Inventory

AREA

12%

BIOGENIC

51%

ON-ROAD

25%

POINT

2%

NONROAD

10%

AREA BIOGENIC NONROAD ON-ROAD POINT

Vancouver Area

2002 NOx Attainment Inventory

ON-ROAD

62%

BIOGENIC

1%

NONROAD

29%

AREA

POINT 1%

7%

AREA BIOGENIC NONROAD ON-ROAD POINT

Vancouver Area

2002 CO Attainment Inventory

ON-ROAD

62%

BIOGENIC

0% POINT

1%

AREA

1%

NONROAD

36%

AREA BIOGENIC NONROAD ON-ROAD POINT

Vancouver Ozone Plan November 2, 2006 16 of 56 
4.0 Portland-Vancouver Control Strategies

4.1 Portland-Vancouver AQMA Ozone Maintenance Plan

Both Portland-Vancouver AQMA Ozone Maintenance Plan inventories are impacted by federal, 

state and local emission control programs. All four major source categories of ozone precursor 

emissions (VOC and NOx) are affected by control strategies that reduce emissions from these 

sources. Several of the strategies provide benefits beyond VOC and NOx emission reductions, 

such as air toxics and greenhouse gas emission reductions, traffic congestion reduction, energy 

savings, and overall cost-savings for the transportation systems. 

The existing Portland-Vancouver AQMA Ozone Maintenance Plan strategies in both plans will 

remain in place and work together to protect air quality as the population increases over the 

next ten years. These strategies have successfully reduced VOC and NOx emissions in the 

past and also should reduce emissions of air toxics and greenhouse gases that are emerging 

issues of concern. The “maintenance demonstration”, Section 5.0 below, includes very 

conservative point source estimates reflecting maximum predicted emissions. Keep mind that 

the maintenance demonstration is based on keeping the control strategies described below in 

place. The modeling demonstrates continued compliance with the standard through 2015. 

While the modeling shows continued compliance with the standard, it also shows peak ozone 

concentrations could exceed the standard threshold of 0.08 ppm in Oregon. Although an 

exceedence is not a violation, this illustrates the need to continue the suite of emission

reduction strategies that limit ozone formation in the Portland-Vancouver area, and for 

appropriately managing emissions growth from new industry. 

Transportation conformity rules, included as control strategies in the previous ozone plan, no 

longer apply to the Portland-Vancouver AQMA. Under EPA’s 2004 ozone implementation rules 

(40 CFR 51.900), neither general conformity nor transportation conformity applies to the AQMA 

since attaining the 8-hour ozone standard. This means that new transportation plans or 

programs no longer need to demonstrate that they conform to the ozone maintenance plans. 

4.2 Vancouver Control Strategies

The control strategies in the Portland-Vancouver Ozone maintenance plans are supported by 

current rules that are described in Section 4.2.1 below. Some of these rules will be updated for 

specific programs, such as the reestablishment of the industrial sources growth allowance and 

are mentioned in Section 4.2.2 below. Both the strategies in the current rules and the proposed 

revised rules were relied upon in the maintenance demonstration. There are also other 

programs, such as the Commute Trip Reduction and the Public Education program that 

contribute to ozone precursor emission reductions, but which were not quantified nor relied 

upon for the maintenance demonstration. More detail on the Commute Trip Reduction program 

can be found in section 4.2.3.1. 

4.2.1 Control Strategies Supported by Current Rules

The following strategies are fully supported by current versions of the rules and will remain in 

the Vancouver Ozone Maintenance Plan as they currently apply to sources in the Clark County, 

Washington area. SWCAA rules and their effective dates are in Appendix 7 as well as the 

Washington State Regulation for the Motor Vehicle Inspection program that supports the plan. 

• Motor Vehicle Inspection Program (WAC 173-422, see Section 4.2.1.1 below) 

• General Regulations for Air Pollution Sources (SWCAA 400) 

Vancouver Ozone Plan November 2, 2006 17 of 56 
o Air Discharge Permit Applications (Notice of Construction) (400-109) – submittal 

and processing of Air Discharge Permit (ADP) applications. 

o New Source Review (400-110) – General requirements for ADP issuance, Best 

Available Control Technology (BACT) is required of all sources 

o Requirements for New Sources in Nonattainment Areas (400-112) New source 

review for nonattainment areas 

o Requirements for Replacement of Substantial Alteration of Emission Control 

Technology at an Existing Stationary Source (400-114) Reasonably Available 

Control Technology (RACT) for control equipment required 

o Maintenance of Equipment (400-116) – minimum maintenance requirements 

o Requirements for Nonattainment Areas (400-190) - procedural requirements for 

developing nonattainment provisions

• Emission Standards and Controls for Sources Emitting VOCs (SWCAA 490) – category 

specific requirements for gasoline loading and dispensing facilities, drycleaners, surface 

coater, graphic arts systems, flatwood panel manufacturers and surface finishing 

facilities 

• Emission Standards and Controls for Sources Emitting Gasoline Vapors (SWCAA 491) – 

requirements for gasoline stations (includes Stage I and Stage II gasoline vapor 

recovery) and specific requirements for fixed roof gasoline storage tanks, gasoline 

loading terminals, bulk gasoline tanks and gasoline transport tanks. 

• VOC Area Source Rules for reducing emissions from Consumer Products, Spray Paints, 

Motor Vehicle Refinishing and Area Source Common Provisions (SWCAA 493-100 

through 500) 

4.2.1.1 Motor Vehicle Inspection Program - Vancouver 

The 1990 Amendments to the Clean Air Act continued the nonattainment status of the PortlandVancouver Interstate Area for the 1-hour National Ambient Air Quality Standard for ozone and 

classified the area as marginal. The 1990 Amendments required pre-existing marginal 

nonattainment areas that had not yet implemented a motor vehicle inspection and maintenance 

(I/M) program do so. An I/M Program measures emissions from motor vehicles. If excessive 

levels of emissions are found, the vehicle must be repaired. While Oregon had an ongoing I/M 

Program in Portland, no I/M Program had been implemented in southern Clark County area until 

1993. 

The Washington State Plan to attain the ozone standard in southern Clark County submitted to 

EPA in 1992 extended the State’s existing I/M Program to the Vancouver area.4

 The I/M 

Program became operational in southern Clark County on June 1, 1993.

The 1996 maintenance plan for southern Clark County brought changes to the boundaries for 

the I/M Program. The vehicle emission boundary was expanded to Brush Prairie, Battle 

Ground, Ridgefield and La Center Postal Zip Codes as of January 1, 1997; the testing 

methodology was changed to the Acceleration Simulation (ASM) mode; test standards were 

strengthened; testing was expanded to NOX emissions, and a gas cap leak detection check was 

instituted. EPA approval of the Clark County and Portland maintenance plans allowed EPA to 

redesignate the Portland-Vancouver AQMA to attainment for 1-hour ozone NAAQS. 

Since January 1, 2000, the I/M Program has exempted vehicles that are less than five or more 

than 25 years old from emissions testing. 

 4

 previously the program only applied to Puget Sound and Spokane.

Vancouver Ozone Plan November 2, 2006 18 of 56 
Vehicle emission test procedures have been modified over the years to better address real 

driving conditions. Since 1996, vehicles have been equipped with On Board Diagnostic 

Systems (OBD) that provide a comprehensive overview of the emissions control system. The 

I/M Program transitioned to OBD testing for newer vehicles on July 1, 2002. Even though 

emissions tests for NOX had to be discontinued in 2002 to keep costs down, OBD is a more 

effective check for NOX. Since 2006, gas cap checks have no longer been performed on 2000 

and newer model year vehicles. OBD checks are relied on to detect evaporative emission 

control system leaks including gas cap leaks. 

 

The 2015 projected inventory and the maintenance demonstration assume the current I/M 

program is maintained. A contract is in place for conducting I/M testing until 2012. The current 

I/M regulations are in Appendix 7. Ecology is submitting WAC 173-422 to EPA for approval. 

4.2.2 Control Strategies with Proposed Rule Revisions

Some sections of the General Air Pollution Regulations will be updated in support of this plan. 

The following SWCAA 400 sections will be modified: 

• Definitions (400-030) “New Source” definition amended, adds ‘emission unit’ to definition 

• Sources Exempt from Registration Requirements (400-101), clarifies exemption 

threshold 

• Requirements for New Sources in a Maintenance Plan Area (400-111) clarifies use of

offsets and industrial growth allowance provisions, (see section 4.2.2.1 below) 

• Requirement for New Sources in an Attainment or Nonclassifiable Areas (400-113) , 

clarifies allowable ambient impact level and use of growth allowance for offsets. 

4.2.2.1 Requirements for New Sources in a Maintenance Plan Area 

Under the existing SWCAA Rules adopted in 2005 (SWCAA 400-111), new or expanding major 

industrial sources located within the Vancouver portion of the AQMA must “offset” emission 

increases of more than 40 tons/year of VOC and NOx by obtaining an offset from another 

facility. Or, the owner or operator of a proposed major source or major modification may apply to 

SWCAA for an allocation of the growth allowance in lieu of providing an emission offset. 

The 1996 Ozone Maintenance Plans for the Portland-Vancouver areas both included an 

industrial emissions growth allowance for the Washington and Oregon sources that could be 

used by new and expanding major industry in lieu of obtaining emission offsets. Both 2006 

Plans continue to use this approach to manage industrial emissions growth. The growth 

allowances were included in the modeled 2015 ozone maintenance demonstration. 

This 2006 maintenance plan update re-establishes the growth allowance for new and expanding 

major VOC and NOx industrial sources, and retains the emission offset requirement as a 

safeguard. SWCAA 400-111 provides both flexibility for future economic opportunity and 

protection of the ozone NAAQS. 

Proposed sources applying for an increase in emissions of more than 40 tpy located inside the 

AQMA must either obtain an offset or use the available growth allowance at a rate of 1.1 to 1, 

for a net air quality benefit. If the new or modified source within Clark, Cowlitz or Skamania 

counties located outside the AQMA has caused or will cause a significant projected impact 

inside the AQMA as specified in SWCAA 400-113, the source must provide offsetting emission 

reductions to reduce the impact below the allowable ambient impact level. The source may fulfill 

Vancouver Ozone Plan November 2, 2006 19 of 56 
this offsetting requirement by either obtaining an offset from another facility or by requesting an 

allocation of the growth allowance. 

The Portland plan reestablishes the industrial growth allowance in Oregon at 5,000 tons for 

VOC and 5,000 tons for NOx. SWCAA adopted a growth allowance for the Vancouver AQMA 

(Clark Co., Washington) sources proportional to Oregon’s growth allowance to ensure a level 

playing field on both sides of the Columbia River when promoting economic development of the 

region. The current growth allowance for the Vancouver AQMA as directed by the 1996 ozone 

plan for the years 2004-2006 is 84 tons VOC and 151 tons of NOx. The growth allowance 

balance for the Vancouver portion of the AQMA will be reset to 411 tons of VOC and 1,313 tons 

of NOx. Consumption of the growth allowance will continue to be monitored and tracked by 

SWCAA as described in SWCAA 400-111. As required in the existing rules, the growth 

allowance will be allocated on a first come first served basis. To make the growth allowance 

‘pool’ last as long as possible, sources may provide offsets, if possible, for all or part of the 

proposed increase. If Oregon’s growth allowance decreases to 1,000 tons or less, DEQ may 

increase the growth allowance by utilizing new federally enforceable emission reductions and 

shutdown credits that were not relied on in the maintenance demonstration. Likewise, if the 

SWCAA growth allowance falls below 20% of the newly reset levels, i.e., the growth allowance 

balance falls to or below 82 tons VOC and 263 tons NOx , SWCAA will consider increasing the 

growth allowance also by utilizing new federally enforceable emission reductions and shutdown 

credits that were not relied on in the maintenance demonstration. Any such increase to the 

growth allowance will be subject to public comment and EPA approval. Federally enforceable 

emission reductions include requirements adopted by EPA, requirements adopted by the 

SWCAA Board of Directors and approved by EPA as a revision to the Washington SIP and 

requirements established by a federally enforceable permit condition. In the event all of the 

growth allowance is consumed, and cannot be re-established, emission offsets for VOC and 

NOx will be required for new and expanding major industries. SWCAA may consider temporarily 

reducing the amount of growth allowance that may be allocated to new or modified major 

industrial sources if monitored ozone concentrations exceed the “risk of violation” or “actual 

violation” thresholds described in the contingency plan (Section 7.2.1). SWCAA must provide 

reasonable advance notice to affected industries if there is a possibility that the growth 

allowance could be reduced. 

4.2.3 Additional Programs that Contribute to Emission Reductions

The following additional programs contribute to ozone precursor reductions, but were not relied 

upon in the maintenance demonstration; 

• Commute Trip Reduction (CTR) program originally passed in 1991(RCW 70.94.521-

551), - replaced by The CTR Efficiency Act (ESSB 6556 ) works with major employers in 

the state’s most populous counties to encourage employees to commute without driving 

alone.

• Commute Trip Reduction Efficiency Act passed on March 29, 2006, effective July, 2007 

(see Section 4.2.3.1 below). 

• CTR Performance Grants - the Washington Department of Transportation oversees the 

Trip Reduction Performance Program that was passed by the Washington State

legislature in 2003 to reduce the number of vehicle trips, 

• Public education and outreach 

o Air Pollution Advisories (formerly called Clean Air Action Days) are called when 

weather forecasts indicate a high probability for air pollution to approach levels 

that are unhealthy for sensitive groups. On such days SWCAA and DEQ work 

with local media and industry to encourage residents to carpool or take the bus to 

Vancouver Ozone Plan November 2, 2006 20 of 56 
work and avoid burning, lawn mowing and painting to reduce their personal 

impact on air pollution. 

o Public presentations – SWCAA offers presentations as requested to various 

school and community groups, addressing local concerns about air pollution and 

pollution prevention. These presentations address personal impacts on air 

pollution, related health issues and local measures to address ozone pollution. 

o Public interaction – SWCAA frequently distributes information and brochures at 

community events including fire district open houses, festivals and county fairs. 

o Educational materials – SWCAA routinely distributes informational brochures to 

residents concerned about ozone pollution. 

4.2.3.1 Changes to Commute Trip Reduction Program

The Washington Commute Trip Reduction (CTR) law passed in 1991 and covered ten counties 

including Clark County. The law applies to major employers (companies with over 100 

employees), requires annual performance reviews, and the goals were the same for all 

employers. This law expired and was replaced by the CTR Efficiency Act. This new legislation 

passed in the 2006 legislature modifies the CTR program and will become effective on July 1, 

2007. This legislation changed the program so that it will only apply to major employers in urban 

growth areas, changed the performance review to once every two years and provided for goals 

that can vary based on local and regional goals and allow companies to set goals beyond the 

state minimum target. Other programs that support the success of the CTR Program are Trip 

Reduction Performance Program, Rideshare Tax Credits, Vanpool Grant Program, Regional 

Mobility Grant Program and Park and Ride lots. 

In 2005, the Clark County CTR program has 52 affected worksites and 12 voluntary 

worksites. In this same year, 18% of employees at these worksites utilized alternative 

transportation to work. The CTR program also offers a Guaranteed Ride Home to participating

employers. The Guaranteed Ride Home program offers a free taxi ride home (up to 50 miles 

one way), including an intermediate stop, to employees who took an alternative ride to work and 

must leave work due to an unforeseen emergency (such as a sick child at school, employee 

illness, or unexpected mandatory overtime). Additional information about the CTR law and 

program can be found in Appendix 8. 

Note that there is Washington participation in a number of bistate area committees whose 

responsibilities include establishing policies and programs to reduce regional travel demand and 

manage traffic operations. For example, the Regional Travel Options Subcommittee, a 

subcommittee of Metro’s Transportation Policy Alternatives Committee (TPAC), has Washington 

members from inside the AQMA. The RTOS's specific purpose is to promote alternatives to 

driving alone in the region. 

Should elevated ozone levels or a violation occur, the impact of transportation sources as well 

as all other sources will be evaluated. Also, SWCAA will review emission levels from mobile 

sources when routinely evaluating all emission categories as required every three years by the 

Consolidated Emission Reporting Rule (CERR) to evaluate emission trends. 

Other anticipated changes over the next ten years include: 

• Low Emission Vehicles legislation will require cars sold in Washington to meet California 

motor vehicle emission standards beginning with the 2009 model year (WAC 173-423 

ESSB 5766, adopted November 30, 2005, effective January 1, 2006) . 

• Emission Standards and Controls for Sources Emitting Gasoline Vapors (WAC 173-491, 

SWCAA 491) Stage II vapor recovery system rules for gas stations will be modified 

Vancouver Ozone Plan November 2, 2006 21 of 56 
when the motor vehicle fleet reflects widespread use of on-board canister systems -

expected to be revised prior to 2015. 

The various control strategies described above work together with other elements in the 

maintenance plan, including the tracking of emission growth, ambient ozone monitoring and the 

early warning and action elements in the contingency plan, to meet air quality management 

goals and protect compliance with standards. 

Vancouver Ozone Plan November 2, 2006 22 of 56 
5.0 Maintenance Demonstration (Portland-Vancouver)

5.1 Ozone Modeling Study

SWCAA and DEQ teamed with WSU, the Washington Department of Ecology and EPA to study 

ozone formation using a computer dispersion model (see Appendix 4, “Historical and Future 

Ozone Simulations using the MM5/SMOKE/CMAQ System in the Portland/Vancouver Area”, 

WSU, December 31, 2005 final report). The purpose of the study was to develop a predictive 

tool to forecast future ozone concentrations based on emission projections and summer 

meteorology in which ozone formation occurs. 

The modeling study simulated two historical high ozone episodes that occurred during the 

summers of 1997 and 1998. The study compared actual ozone levels measured (monitored) 

during the 1997 and 1998 events to model predicted ozone levels for the same period in order 

to test and validate model performance. The model performed within EPA guidelines for both 

episodes. The model performance testing verifies that the CMAQ model can predict future 

ozone concentrations for the region (see Appendix 4 for more information on model 

performance testing). 

The modeling team selected the July 26-28, 1998 episode as the basis for future year 

projections because ozone levels were much higher in 1998 than in 1997, and meteorology 

reflected worst case conditions that contribute to ozone formation in the Portland-Vancouver 

area (high temperatures and low wind speeds, with predominant winds from the north). 

Methodology for developing the modeling emissions data is detailed in the WSU modeling 

report (Appendix 4). 

5.2 Growth Projections

The 2015 emissions forecast used in the modeling study reflects 2002 emissions, increased by 

expected growth in various sectors. The 2002 emission inventory reflects the 2002 

Consolidated Emissions Reporting Rule (CERR) emissions data submitted by DEQ and 

SWCAA to the National Emission Inventory (NEI) and documented in Appendix 3 and 4. 

Growth factors for various source sectors were derived from the 2002 “Economic Report to the 

Metro Council, 2000-2030 Regional Forecast for the Portland-Vancouver, Metropolitan Area” 

(Metro Report) (see Appendix 5). 

For the 2015 Maintenance Projection, the following growth assumptions were included in the 

forecast: 

Area sources: Area source emissions were calculated following EPA guidance for the 2002 

NEI. Table 6 describes population trends in the Portland and Vancouver areas. The 2015 

emissions inventory assumes a linear, non-compounding population growth rate of 1.8% per 

year, and household growth rate of 2.0% per year from the Metro Report. The area source 

emission inventory was adjusted to reflect summertime conditions when used in the modeling 

analysis and maintenance demonstration. 

Vancouver Ozone Plan November 2, 2006 23 of 56 
Table 6: Portland Vancouver Area Population Projections 

2000 

Estimate 

2005 

Forecast 

2010 

Forecast 

2015 

Forecast 

PortlandVancouver Area* 

(Clackamas, Multnomah, 

Washington and Clark 

Counties) 

1,789,460 1,956,300 2,134,300 2,287,000

Vancouver Area 

(Clark County)** 345,238 391,264 432,479 473,674

*”Economic Report to the Metro Council, 2002-2030 Regional Forecast,” page 4 

** Projections of the Total Resident Population for the Growth Management Act, Intermediate: Year After 

 2010 Clark 2000 TO 2025 by Single County, Office of Financial Management, released January 2002 

Non-road mobile sources: EPA’s draft NONROAD2004 model was used to estimate nonroad 

source emissions for 2015. This model incorporates the latest assumptions and rules, including 

EPA’s Tier 4 non-road diesel engine standards and non-road diesel fuel sulfur standards 

associated with the Tier 4 rule. Railroads, marine vessels and airports were estimated 

independently of the NONROAD model (see Appendix 4). Aircraft emissions for the four 

airports with the Portland AQMA were calculated using Port of Portland data (Aviation Demand 

Forecast Update for Portland International Airport, Port of Portland, November 4, 1999, and 

associated spreadsheets), which was also used in the 2002 NEI submittal. 

On-road mobile sources: 2015 on road vehicle miles traveled estimates used in the modeling 

analysis are based on travel demand forecast models run by Metro and the Southwest Regional 

Transportation Council (RTC) for the Portland-Vancouver AQMA, and Department of 

Transportation data and projections for the modeling domain. RTC’s last regional analysis 

completed in December 2004, predicted that even with high population, employment and VMT 

growth, hydrocarbon levels are expected to drop significantly between 2004 and 2025. Also, the 

projected emissions values for on road sources in the maintenance demonstration are 

consistent with RTC’s analysis. EPA’s MOBILE6.2 model was used to estimate emission rates 

per vehicle mile traveled for 2015. MOBILE6.2 incorporates federal motor vehicle and fuel 

standards expected in 2015, and allows incorporation of local data for many of the necessary 

parameters such as fleet and fuel characteristics, and I/M programs. The 2015 maintenance 

demonstration also shows reductions in emissions from these sources with the existing 

Inspection and Maintenance program control strategies in place. Expected changes in federal 

regulations include two classes of Heavy Duty gas vehicles that will be OBD tested starting in 

2008. In Oregon, the modeling projections included the change in their Vehicle Inspection 

Program rules to replace the “enhanced” vehicle inspection test with the “basic” vehicle 

inspection test for vehicle model years 1981-1995. This change is reflected in the modeling 

projections and maintenance demonstration of this plan. Although there are some changes to 

Washington’s I/M program, i.e., starting with model year 2009, cars will be required to meet 

California emission standards, the modeling projections did not include any changes for the 

Washington I/M program. 

Point sources: SWCAA and DEQ developed two different growth scenarios for major industrial 

(point) sources, and their purpose is discussed in more detail below. The two scenarios include: 

3⁄4 2015 Projection: reflecting actual 2002 emissions from existing industry, increased 

by expected employment projections in the Metro report.

Vancouver Ozone Plan November 2, 2006 24 of 56 
3⁄4 2015 Maintenance Demonstration: reflecting a conservative approach using 

estimates of maximum permitted levels for existing industry and new industry growth 

allowance. 

5.3 Forecast and Maintenance Inventory

As noted above, DEQ and SWCAA developed two different growth scenarios for major industrial 

(point) sources, and they are used for different purposes. The first growth scenario (called 

“2015 Projection” as seen in Figures 4 and 5) reflects the 2002 estimate of actual industrial 

emissions, increased by expected regional employment projections for that sector. This 

projection represents a baseline estimate of actual future year emissions, given expected 

growth, and is included in the WSU modeling report as the managed growth simulation 

projection (Appendix 4). 

The second growth scenario (called “2015 Maintenance Demonstration” also seen in Figures 4 

and 5) represents a very conservative approach using maximum estimates of possible future 

year emissions. The 2015 Maintenance Demonstration reflects maximum “legally allowable” 

emission levels currently permitted for existing industry, plus the emissions growth allowance reestablished for new industry growth. Because Oregon’s permitting program differs from 

SWCAA’s, there is a substantial difference between Oregon Plant Site Emission Limits (PSEL) 

and Washington sources’ Potential to Emit (PTE). Since PSELs and PTEs are not similar, 

Washington point source emissions were adjusted for the purposes of this maintenance 

demonstration to provide a more equal comparison. Using the ratio of Oregon ‘allowable‘ 

emissions to Oregon’s 2002 actual emissions for each pollutant, Washington point sources were 

increased by this same ratio. Then, a proportional growth allowance was added to this value. 

This 2015 Maintenance Demonstration represents the most conservative estimate of possible 

future industrial emissions for purposes of the maintenance plan. 

Tables 7 and 8 and Figures 4 and 5 below show the 2002 estimate of actual emissions and the 

conservative growth scenario “2015 Maintenance Demonstration” described above. Figures 4 

and 5 also show the intermediate 2015 Projection described in the WSU modeling report. 

Both VOC and NOx emissions are involved in the formation of ozone and the relative amounts 

of each (VOC/NOx ratio) can influence the level of ozone formation. The WSU modeling 

analysis shows that of the two pollutants, VOC is the primary driver of ozone formation in the 

urban Portland area. However, both VOC and NOx emission reduction strategies continue to be 

important to reducing ozone formation. 

Vancouver Ozone Plan November 2, 2006 25 of 56 
Figure 4 below shows graphically the 2002 estimate of actual VOC and NOx emissions, the 

intermediate 2015 Growth Projection, and the 2015 Maintenance Demonstration for the Portland 

area. In 2002, major industry accounted for about 2% of total VOC emissions in the Portland 

area. Under the 2015 Maintenance Demonstration, major industry would account for about 12% 

of total VOC in the Portland area, and the majority of VOC emissions (approximately 30% 

annually) would come from the area source sector. 

Figure 4: Portland-Area VOC and NOx Emissions (lb/day) and 2015 Growth Projection 

and Maintenance Demonstration 

Portland Area VOC Emissions

0

300,000

600,000

900,000

1,200,000

Lbs per day

POINT 17,020 18,304 119,943

ON-ROAD 139,542 54,521 54,521

NONROAD 110,188 101,699 101,699

BIOGENIC 437,910 437,910 437,910

AREA 253,871 291,098 291,098

2002 Actual 2015 Growth 

Projection

2015 

Maintenance 

Demonstration

Portland Area NOX Emissions

0

100,000

200,000

300,000

400,000

Lbs per day

POINT 14,913 16,783 86,780

ON-ROAD 216,750 68,910 68,910

NONROAD 136,713 95,638 95,638

BIOGENIC 3,890 3,890 3,890

AREA 5,529 6,157 6,157

2002 Actual 2015 Growth 

Projection

2015 

Maintenance

Demonstration

Vancouver Ozone Plan November 2, 2006 26 of 56 
Figure 5 shows expected growth in VOC and NOx emissions for the Vancouver area, including 

allowable emissions for existing industry. The industrial growth allowance has been established

for the Vancouver area in proportion to Oregon industrial sources. Future growth in that area is 

expected to be accommodated through the New Source Review process. Including maximum 

allowable emissions in these projections for existing industry, the major industry sector would 

account for approximately 7% of the total Vancouver area VOC emissions and 39% of the NOx 

emissions in the maintenance demonstration. On road vehicle emissions represented 25% of 

VOC emissions in 2002 and are expected to be 12% of the total VOC emissions in 2015. While

on-road sources were a larger percentage of ozone precursors in 2002, growth projections 

show area sources will contribute significantly to VOC emissions in 2015. Nonroad sources are 

projected to be the largest emission category for NOx in 2015 growth projections. 

Figure 5: Vancouver VOC and NOx Emissions (lb/day) and 2015 Growth Projection and 

Maintenance Demonstration 

Vancouver Area VOC Emissions

0

100,000

200,000

L b s per d ay

POINT 3,572 3,780 9,682

ON-ROAD 38,315 16,026 16,026

NONROAD 15,374 9,339 9,339

BIOGENIC 79,417 79,417 79,417

AREA 18,014 21,860 21,860

2002 Actual 2015 Growth Projection 2015 Maintenance

Demonstration

Vancouver Area NOx Emissions

0

40,000

80,000

120,000

L b s p er da y

POINT 6,089 6,197 22,965

ON-ROAD 50,495 19,482 19,482

NONROAD 23,222 15,183 15,183

BIOGENIC 965 965 965

AREA 665 786 786

2002 Actual 2015 Growth Projection 2015 Maintenance 

Demonstration

Vancouver Ozone Plan November 2, 2006 27 of 56 
Table 7 

Portland Area 2015 Maintenance Demonstration

 Typical Summer Day, lb/day

Clackamas, Multnomah, Washington Counties

 

2015 2015 2015

Source Type VOC NOx CO

AREA 291,098 6,157 29,373

BIOGENIC 437,910 3,890 --

NON-ROAD 101,699 95,638 2,260,810

ON-ROAD 54,521 68,910 560,955

POINT 119,943 86,780 108,526

Total 1,005,171 261,375 2,959,664

--- VOC, lbs per day --- --- NOX, lbs per day ---

2015 2015

Source 2002 Maintenance % Source 2002 Maintenance %

Type Actual Demonstration Change Type Actual Demonstration Change

AREA 253,871 291,098 14.7% AREA 5,529 6,157 11.4%

BIOGENIC 437,910 437,910 BIOGENIC 3,890 3,890

NONROAD 110,188 101,699 -7.7% NONROAD 136,713 95,638 -30.0%

ON-ROAD 139,542 54,521 -60.9% ON-ROAD 216,750 68,910 -68.2%

POINT 17,020 119,943 604.7% POINT 14,913 86,780 481.9%

---------- ---------- ---------- ----------

Totals 958,531 1,005,171 Totals 377,794 261,375

Portland Area VOC and NOx Emissions, (lb/day), % Change 2002-2015

(Clackamas, Multnomah, Washington Counties)

Portland Area

2015 VOC Maintenance Demonstration

BIOGENIC

44%

ON-ROAD

5%

NON-ROAD

10%

AREA

29%

POINT

12%

AREA BIOGENIC NON-ROAD ON-ROAD POINT

Portland Area

2015 NOx Maintenance Demonstration

NON-ROAD

38%

POINT

33%

ON-ROAD

26%

BIOGENIC

1%

AREA

2%

AREA BIOGENIC NON-ROAD ON-ROAD POINT

Portland Area

2015 CO Maintenance Demonstration

ON-ROAD

19%

BIOGENIC

0%

POINT

4%

NON-ROAD

76%

AREA

1%

AREA BIOGENIC NON-ROAD ON-ROAD POINT

The Portland area on-road emissions are expected to decrease significantly: 61% less VOC 

emissions and 68% less NOx emissions. This is primarily due to implementation of federal 

motor vehicle emission and fuel standards and continuing implementation of the vehicle 

inspection program. Non-road emissions also show a 30% decrease in NOx emissions due to 

the phase-in of federal emission and fuel standards. Point source “actual” emissions are not 

expected to change significantly, although Figure 4 shows the difference between “actual” 

emissions in the 2002 attainment inventory and the “allowable” emissions and growth allowance 

in the 2015 Maintenance Demonstration. 

Vancouver Ozone Plan November 2, 2006 28 of 56 
Table 8: Vancouver Area 2015 Maintenance Demonstration, Typical Summer Day, lb/day

Clark County

Vancouver Area 2015 Maintenance Demonstration

 Typical Summer Day, lb/day

 Clark County

2015 2015 2015

 Source Type VOC NOx CO

AREA 21,860 786 5,337

BIOGENIC 79,417 965 0

NONROAD 9,339 15,183 271,651

ON-ROAD 16,026 19,482 159,167

POINT 9,682 22,965 3,780

Total 136,323 59,381 439,935

Vancouver Area 

2015 VOC Maintenance Demonstration

BIOGENIC

58%

ON-ROAD

12%

POINT

7% AREA

16%

NONROAD

7%

AREA BIOGENIC NONROAD ON-ROAD POINT

Vancouver Area 

2015 NOx Maintenance Demonstration

NONROAD

26%

ON-ROAD

33%

AREA

1% BIOGENIC

2% POINT

38%

AREA BIOGENIC NONROAD ON-ROAD POINT

Vancouver Area 

2015 CO Maintenance Demonstration

NONROAD

62%

BIOGENIC

0%

AREA

1% POINT

1%

ON-ROAD

36%

AREA BIOGENIC NONROAD ON-ROAD POINT

Vancouver Area VOC and NOx Emissions (lb/day), % Change 2002-2015

(Clark County)

--- VOC, lbs per day --- --- NOX, lbs per day ---

2015 2015

Source 2002 Maintenance % Source 2002 Maintenance %

Type Actual Demonstration Change Type Actual Demonstration Change

AREA 18,014 21,860 21.3% AREA 665 786 18.2%

BIOGENIC 79,417 79,417 BIOGENIC 965 965

NONROAD 15,374 9,339 -39.3% NONROAD 23,222 15,183 -34.6%

ON-ROAD 38,315 16,026 -58.2% ON-ROAD 50,495 19,482 -61.4%

POINT 3,572 9,682 171.0% POINT 6,089 22,965 277.2%

---------- ---------- ---------- ----------

154,692 136,323 81,436 59,381

The Vancouver area on-road emissions are also expected to decrease significantly: 58% less 

VOC emissions and 61% less NOx emissions. This is primarily due to implementation of federal 

motor vehicle emission and fuel standards and continuing implementation of the vehicle 

inspection program. Non-road emissions also show an approximate 35% decrease in NOx and 

39% reduction in VOC emissions due to the phase-in of federal emission and fuel standards. 

The eventual shift from Stage II vapor recovery at gas stations to on-board canisters in cars is 

reflected in the 2015 modeling projections and maintenance demonstration of this plan. Point 

source “actual” emissions are not expected to change significantly. Figure 5 shows the “actual” 

emissions in the 2002 attainment inventory, the 2015 growth projection and the “allowable” 

emissions with the growth allowance used in the 2015 Maintenance Demonstration. 

Vancouver Ozone Plan November 2, 2006 29 of 56 
5.4 Maintenance Demonstration – Ozone Level Projections

The WSU Ozone Modeling study (December 2005 report, Appendix 4) used the 2015 

maintenance demonstration values and worst-case meteorology from the 1998 high ozone 

event in the CMAQ model to estimate future ozone concentrations for the Portland and 

Vancouver areas in 2015. Compliance with the 8-hour ozone NAAQS is demonstrated when 

the fourth highest daily maximum 8-hour average ozone concentration, averaged over three 

consecutive years (i.e., Design Value), is equal to or less than 0.08 ppm5

. 

Table 9 shows the 2015 predicted Design Value, which is used to compare to the ozone 

standard for purposes of determining compliance. The WSU modeling analysis also confirms 

that the existing monitoring network is capturing the areas of highest ozone concentrations. This 

modeling analysis also estimates that potential projected maximums could exceed the ozone 

standard. The largest predicted maximum potentially could be at the Milwaukie site in Portland; 

the estimated result is 0.096 ppm, an exceedance of the standard of 0.08 ppm. 

Table 9: 2015 Maintenance Demonstration (ozone values) 

8-hour ozone standard = 0.08 ppm 

Exceedance ≥ 0.085 ppm maximum 

Violation >0.085 ppm Predicted Design Value 

Monitoring Site 1998 Current 

Design 

Value, ppm 

Relative 

Reduction 

Factor 

2015 

Predicted 

Design 

Value*, ppm 

Portland/Carus 0.075 0.955 0.072

Portland/Milwaukie 0.059 1.046 0.062

Portland/Sauvie 

Island 

0.059 0.923 0.054

Vancouver/Mountain 

View

0.063 0.975 0.061

*Predicted Design Value is calculated using the EPA statistical procedure called the Relative 

Reduction Factor described in Appendix 6 and EPA 8-hour ozone modeling guidance. Predicted 

design value is compared to the 8-hour ozone standard to determine compliance. 

Figure 6 shows the ozone compliance trend for the Portland-Vancouver area, including the 2015 

maintenance projection. The values shown in Figure 6 and Table 9 demonstrate that the 

Portland-Vancouver area will remain in compliance with the 8-hour ozone standard, that is, 

there will be no design value over 0.08 ppm. However, the modeling results show that the 

standard may be exceeded, i.e., peak ozone concentrations may exceed 0.085 ppm, illustrating 

the need to continue the suite of emission reduction strategies that limit ozone formation in the 

Portland-Vancouver area, and for appropriately managing emissions growth from new industry. 

 5 Under EPA’s calculation convention, a value of 0.084 ppm would round down to 0.08 ppm (i.e. in compliance), 

while a value of 0.085 ppm or higher would be a violation. 

Vancouver Ozone Plan November 2, 2006 30 of 56 
Figure 6: Portland-Vancouver Ozone Maintenance Demonstration 

Portland-Vancouver 8-hour Ozone Trend 

(1997-2005) and 2015 projection

3 year averages of the 4th highest daily ozone value

0.030

0.040

0.050

0.060

0.070

0.080

0.090

0.100

1997 1998 1999 2000 2001 2002 2003 2004 2005 2015

Year

8 hr Ozone (ppm) 3 year rolling average of 4th highest

Portland/Carus

Portland/Milwaukie

Portland/Sauvie Island

Vancouver/Mtn.View

Ozone AQ Standard 0.085 ppm

Ozone Monitoring Sites

Again, Figure 6 and Table 9 illustrate that the Portland-Vancouver AQMA will maintain

compliance with the 8-hour ozone standard through 2015. The Carus monitoring site, 

downwind of Portland, has historically been the site with the highest ozone readings in the 

region. The model predicted that the Milwaukie site would produce a slightly higher maximum 

value under meteorological conditions similar to the 1998 episode, and the maximum values at 

both Milwaukie and Carus would exceed but not violate the standard. However, the Carus site 

is expected to remain the highest and most important site for determining compliance with the 

ozone standard. The 4th high design values at Carus and all other sites demonstrate continued 

compliance with the ozone NAAQS. 

Vancouver Ozone Plan November 2, 2006 31 of 56 
6.0 Air Quality Monitoring (Portland-Vancouver)

SWCAA and DEQ will continue to operate an ozone air quality monitoring network in

accordance with 40 CFR 58 to verify maintenance of the 8-hour ozone standard in Portland and 

Vancouver (see Appendix 1). Any modification to the ambient air monitoring network, such as 

removal of duplicative or unnecessary monitors, will be accomplished through close consultation

with EPA Region 10. Proposed network modifications would be accompanied by technical and 

statistical analysis sufficient to document a given monitor may be removed because it is 

unnecessary or duplicative in the case of network reductions, or to justify the value of investing 

in monitoring network enhancements. In accordance with 40CFR 58, the final network design 

will be subject to the approval of the EPA Regional Administrator. 

Vancouver Ozone Plan November 2, 2006 32 of 56 
7.0 Contingency Plan

The maintenance plan must include a process to quickly prevent or correct any measured 

violation of the 8-hour ozone standard. This process of investigation and (if needed) corrective 

action is called the “contingency plan”. Contingency plans typically have several stages of 

action depending on the severity of monitored ozone levels. Ambient ozone thresholds are 

established in the contingency plan as early-warning action levels. If monitored ozone levels 

exceed these action levels, the contingency provisions are triggered. Portland has contingency

plan measures based on VMT/capita whereas Vancouver’s contingency measures focus on 

performing evaluations to determine the root cause of the air pollution levels which triggered the 

contingency plan. 

7.1 Request to Replace the Portland-Vancouver AQMA 1-Hour Contingency Plan with an 8-

Hour Contingency Plan

EPA revoked the one-hour ozone standard, effective June 15, 2005 (69 FR 23951, April 30, 

2004). In accordance with EPA rules implementing the 8-hour ozone standard (40 CFR 

51.900), SWCAA requests that the one-hour ozone contingency plan be removed from the 

Portland-Vancouver AQMA Ozone Maintenance Plan, and replaced with a contingency plan that 

addresses the 8-hour ozone standard as described below. 

7.2 Portland-Vancouver AQMA 8-hour Ozone Contingency Plan 

The Portland contingency plan includes two sets of contingency measures. The provisions 

specified under Part A of the Contingency Plan for the Portland-Vancouver AQMA are linked to 

ambient concentrations of ozone and would be triggered if measured ozone levels at any of the 

ozone monitoring sites (Mountain View, Sauvie Island, Milwaukie, or Carus) exceed the earlywarning thresholds below, or if a violation of the 8-hour ozone standard occurs. The provisions 

specified under Part B of the Portland Contingency Plan are linked to increases in the average 

amount of vehicle use per person (VMT/capita) in the Portland metropolitan area, and would 

only affect the Oregon portion of the Portland-Vancouver AQMA. EPA’s 8-hour ozone 

implementation rule (69FR pages 23987-88, April 30, 2004) notes that although states cannot 

implement conformity for attainment areas as a matter of federal law, they could still work with 

their metropolitan planning organizations to develop a voluntary program to address motor 

vehicle emissions growth. The Portland plan Contingency Plan Part B includes actions that 

trigger based on increases in %VMT increases in two phases. Oregon’s Transportation 

Planning rule requires DEQ to track VMT/Capita growth. Washington does not have this 

legislation. Because of this difference, the Vancouver contingency plan measures will not be the

same as Portland’s Plan B contingency measures. SWCAA and DEQ will both focus on the 

evaluations for establishing the root cause of the contingency plan triggering emission levels. 

7.2.1 Part A, Contingency Plan Based On Ambient Concentrations in Portland or Vancouver

PHASE 1: ELEVATED OZONE LEVELS 

If the air quality index (AQI) is forecast to be within the “orange” range for ozone air quality 

(unhealthy for sensitive populations), or 8-hour daily maximum ozone values approach 0.100 

ppm or greater, and meteorological conditions conducive to ozone formation are expected to 

persist, SWCAA and DEQ will coordinate to issue an advisory to inform the public of air quality 

levels and voluntary actions they can take to limit exposure to unhealthy air pollution levels and 

reduce emissions. 

Vancouver Ozone Plan November 2, 2006 33 of 56 
PHASE 2: RISK OF VIOLATION 

If monitored 8-hour ozone levels at any site within the Portland-Vancouver area registers an 

annual fourth highest monitored value of 0.085 ppm or greater within a single ozone season or 

0.080 ppm or greater averaged over two years, SWCAA and DEQ will assess the likely sources 

of emissions and meteorological events contributing to elevated ozone levels. DEQ and 

SWCAA may form an advisory group to assist in its review. 

SWCAA or DEQ could recommend that no action be taken if it is determined that: (a) elevated 

ozone levels were caused by an event that is unlikely to occur again, or (b) high ozone levels 

were caused by an uncontrollable event, such as a severe wildfire, or (c) federal regulations that 

will reduce ozone precursor emissions are scheduled to be implemented within two years. If it 

is determined that the event did not meet the criteria above, SWCAA and DEQ will evaluate 

options for appropriate action, including the option for additional emission reduction strategies to 

prevent future exceedances or a violation of the 8-hour ozone standard. An assessment by 

SWCAA at the “risk of violation” level would include a review of emissions to identify the source 

category that contributes the most emissions to the airshed. However, the emission source 

category with the largest contribution may not be the category that can provide the greatest 

emission reductions at the least cost. SWCAA would review each of the source categories to 

evaluate the best overall reduction potential. Based on this analysis, measures that would be 

considered for implementation of each emission source category include the following:

1. Mobile Sources 

o Evaluate options for maintaining the I/M program beyond the current I/M contract 

expiration in 2012. 

o Consult with RTC to review and evaluate possible transportation control 

measures. 

2. Point Sources 

o consider instituting LAER or eliminating the growth allowance for new or modified 

sources. 

3. Area Sources 

o Conduct a top-ten analysis to identify the activities associated with the largest 

contributors to area source emissions and consider alternatives to achieve 

reductions in emissions from these activities, (e.g., consider other surface 

coating regulations, curtailment of certain kinds of painting on hot summer days, 

etc.). 

4. Nonroad sources 

o Evaluate emission reduction opportunities for these categories (e.g., reducing 

idling from locomotives, rebates for old lawn mowers, etc.). 

PHASE 3: ACTUAL VIOLATION 

If a violation of the 8-hour ozone standard occurs, SWCAA and DEQ will determine the 

emissions and meteorological events contributing to the violation. If the violation is not due to 

an event unlikely to occur again, an uncontrollable event or other criteria in Phase 2, SWCAA 

and DEQ will identify new strategies necessary to ensure compliance with the 8-hour ozone 

standard within 18 months of the conclusion of the ozone season that prompted the contingency

plan, and revise the maintenance plan as needed to correct the violation. A revised 

maintenance plan would be submitted to EPA for approval. 

Should an actual violation occur, SWCAA would pursue the measures identified in Phase 2 and 

convene a community advisory group to choose control measures to achieve the necessary 

emission reductions. 

Vancouver Ozone Plan November 2, 2006 34 of 56 
8.0 Verification of Continued Attainment (Portland-Vancouver)

SWCAA and DEQ will continue to monitor ambient air quality ozone levels in the PortlandVancouver AQMA during the ozone season (May through September) using the ozone 

monitoring network as described in Appendix 1. DEQ and SWCAA will update countywide 

emission inventories every three years as required by the Consolidated Emission and Reporting 

Rule (CERR) to update the National Emissions Inventory. If ambient ozone levels increase, 

DEQ and SWCAA will compare CERR updates with the 2002 and 2015 emissions inventories 

and evaluate the assumptions used in the 2015 emissions projections to determine whether 

emissions are increasing at a rate not anticipated in the maintenance plan. 

Vancouver Ozone Plan November 2, 2006 35 of 56 
Appendices

1. AQMA Ozone Monitoring Network (Vancouver-Portland-Salem regional area map and site 

description)

2. 1992 to 2005 Meteorological Factors Conducive to Ozone Formation in the PortlandVancouver Area (ODEQ, April 2006) 

3. Emission Inventory 

a. Annual Emission Inventory 

b. Typical Summer Day Emissions Inventory 

c. Summary of Vancouver Area Emissions 

d. Summary of Portland Area Emissions 

4. Modeling and Maintenance Demonstration - Historical and Future Ozone Simulations Using 

the MM5/SMOKE/CMAQ System in the Portland-Vancouver Area (WSU, December 31, 

2005). 

5. Economic Report to the Metro Council, 2000-2030 Regional Forecast for the PortlandVancouver Metropolitan Area (Metro’s Data Resource Center, December 2002 final draft) 

6. Modeled Attainment Test (detailed spreadsheet).

7. Vancouver Area Control Strategies – SWCAA and Washington State Regulations 

8. Other Emission Reduction Programs Information 

9. Map and Description of Vancouver AQMA 

References 

• “Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under Section 

110(a)(1) of the Clean Air Act” (memo dated May 20, 2005 from Lydia Wegman, EPA). 

The May 20, 2005 guidance applies to areas designated in attainment with the 8-hour 

ozone standard and preparing maintenance plans under Section 110(a)(1) of the Clean 

Air Act and 40 CFR 51.905(c) and (d). 

• “Demonstrating Noninterference Under Section 110(l) of the Clean Air Act When 

Revising a State Implementation Plan” (draft EPA Guidance, 6/8/05) 

• “1-Hour Ozone Maintenance Plans Containing Basic I/M Programs (memo dated May 

12, 2004 from Tom Helms, EPA) 

• April 30, 2004 Federal Register (69FR 23951), Final Rule to Implement the 8-Hour 

Ozone NAAQS-Phase 1 

• July 8, 2005 Federal Register (70FR 39413), Notice of Final Rulemaking regarding 

Nonattainment Major New Source Review Implementation under 8-Hour Ozone NAAQS 

• “Guidance on the Use of Models and Other Analyses in Attainment Demonstrations for 

the 8-hour Ozone NAAQS” (EPA-450/R-05-002, October, 2005) 

• “Emission Inventory Guidance for Implementation of Ozone and Particulate Matter 

NAAQS and Regional Haze” (EPA-454/R-05-001, August 2005, updated November 

2005) 

• “2002 Base Year Emission Inventory SIP Planning: 8-hr Ozone, PM 2.5 and Regional 

Haze Programs” (memo dated November 18, 2002 from Lydia Wegman, EPA) 

• “Procedures for Processing Requests to Redesignate Areas to Attainment” (memo 

dated September 4, 1992 from John Calcagni, EPA) 

Vancouver Ozone Plan November 2, 2006 36 of 56 
Appendix 1 

Portland-Vancouver AQMA 

Ozone Monitoring Network 

Monitoring Sites (north to south): 

1. Sauvie Island (Portland, OR) (background site) 

2. Mountain View (Vancouver, WA) 

3. Milwaukie (Portland, OR) 

4. Carus (Portland, OR) (traditionally highest ozone values) 

5. Turner (Salem, OR) (not included in the Portland-Vancouver AQMA) 

The Portland-Vancouver AQMA Monitoring Network 

The Portland/Vancouver area has four ozone monitoring sites shown in the map above. (The map

also shows the Salem, Oregon site which is not a part of the Portland-Vancouver AQMA. One site is

located at Mountain View High School in Vancouver, Washington. The other three sites are located in 

the Portland area at the following locations: Sauvie Island, Milwaukie High School, and Carus 

(Spangler Road). 
The Portland area monitors have been in operation since the mid-1970's. The current Vancouver site 

has only been in operation since 1988. Prior to this date, there was an ozone monitor located at the 

Columbia River High School in Vancouver from 1979 to 1987.

The ozone monitoring season ran from April through October until 1999. In 1999, the ozone season

was changed to run from May through September instead. Since then, the monitors have run 

continuously May through September, with hourly averages derived electronically via data loggers

and integrators. After rigorous quality assurance, the data is input into the Air Quality System (AQS),

which supplies EPA with the air quality monitoring data. This data provides the basis for 

Portland/Vancouver's air quality status. 

SWCAA and DEQ Continuous Air Monitoring Method for Ozone 

The method used by the monitor to measure ozone is Ultraviolet Photometry. The air sample enters a 

chamber with an ultraviolet lamp at one end and detector at the other. The ozone in the sample 

stream absorbs the ultraviolet light at a specific wavelength. The amount absorbed is proportional to 

the amount of ozone in the air stream. The detector then sends an amplified signal to the recorder. 

This is an EPA Federal Reference Method. 

The Portland Area data is 8-hour Ozone Air Quality Data from DEQ Air Quality Annual Report, 

2004.The Vancouver data is from SWCAA Air Quality Annual Report, 2004. 

STATION LOCATION 

AND NUMBER Year 

SUMMER 

AVERAGE

1-HOUR

MAXIMUM 

(date)

# OF 

DAYS 

>0.125

ppm 

8-HOUR

AVERAGE

MAXIMUM

4TH

HIGHEST 

8-HOUR

AVERAGE 

# OF 

DAYS 

>0.085

ppm 

3 YEAR 

AVG 

OF 4TH

HIGH 

Portland Area 1994 0.029 0.117

(07/21) 

0 0.084

(07/21) 

0.078 

(07/27) 

2 0.079†

Carus (SPR) 1995 0.027 0.099

(06/30) 

0 0.084

(09/01) 

0.073 

(09/14) 

1 0.072†

13575 Spangler Road 1996 0.029 0.149 

(07/26) 

1 0.112

(07/26) 

0.099 

(07/27) 

7 0.083† 

Canby 1997 0.025 0.085

(07/04) 

0† 0.074

(07/04) 

0.062 

(05/13) 

0 0.078

DEQ# 10093 

EPA# 410050004 

1998 0.026 0.137

(07/28) 

3† 0.116

(07/26) 

0.081 

(09/01) 

3 0.080

1999 0.028 0.102

(07/10) 

0† 0.080

(07/09) 

0.072 

(07/28) 

0 0.071

2000 0.025 0.086

(06/28) 

0† 0.071

(06/03) 

0.065 

(07/30) 

0 0.072

2001 0.025 0.099

(08/09) 

0† 0.080

(08/09) 

0.069 

(06/20) 

0 0.068

2002 0.025 0.101

(07/22) 

0† 0.085

(07/10) 

0.063 

(07/21) 

1 0.065

2003 0.029 0.097

(07/29) 

0† 0.084

(09/03) 

0.075 

(07/28) 

0 0.069

2004 0.025 0.105

(07/24) 

0† 0.084

(07/24) 

0.067 

(08/11) 

0 0.068

2005 0.025 0.093

(08/04) 

0† 0.079 0.064

(07/27) 

0 0.069

Vancouver Ozone Plan November 2, 2006 38 of 56 
STATION LOCATION 

AND NUMBER Year 

SUMMER 

AVERAGE

1-HOUR

MAXIMUM 

(date)

# OF 

DAYS 

>0.125

ppm 

8-HOUR

AVERAGE

MAXIMUM

4TH

HIGHEST 

8-HOUR

AVERAGE 

# OF 

DAYS 

>0.085

ppm 

3 YEAR 

AVG 

OF 4TH

HIGH 

Milwaukie High Sch 

(MHS) 

1994 0.018 0.103

(07/20) 

0 0.087

(07/20) 

0.057 

(07/21) 

1 0.060†

11300 SE 23rd 1995 0.018 0.110

(07/18) 

0 0.092

(07/18) 

0.067 

(05/29) 

1 0.059†

DEQ# 10095 

EPA# 410052001 

1996 0.019 0.145

(07/14) 

2 0.120

(07/14) 

0.085 

(07/13) 

4 0.069†

1997 0.016 0.101

(07/20) 

0 0.082

(07/04) 

0.054 

(07/19) 

0 0.068†

1998 0.018 0.124

(07/26) 

0† 0.100

(07/26) 

0.061 

(08/31) 

1 0.066†

1999 0.015 0.080

(06/14) 

0† 0.054

(07/09) 

0.051 

(05/23) 

0 0.055†

Milwaukie (MSJ) 2000 0.018 0.085

(06/04) 

0† 0.068

(06/04) 

0.056 

(08/23) 

0 0.056

St. Johns Church 2001 0.018 0.082 

(08/10) 

0† 0.066

(08/10) 

0.059 

(08/12) 

0 0.055

DEQ# 23306 

EPA# 410052002 

2002 0.020 0.116

(07/22) 

0† 0.082

(07/22) 

0.063 

(08/13) 

0 0.059

2003 0.021 0.091

(06/07) 

0† 0.068

(06/06) 

0.061 

(07/28) 

0 0.061

2004 0.017 0.094

(07/24) 

0† 0.077

(07/24) 

0.054 

(08/15) 

0 0.059

2005 0.016 0.083

(05/27) 

0† 0.063

(05/27) 

0.05 

(8/14)

0 0.055

Sauvie Island (SIS) 1994 0.023 0.102

(07/20) 

0 0.086

(07/20) 

0.062 

(07/21) 

1 0.066†

Social Security Beach 1995 0.022 0.103 

(07/18) 

0 0.089

(07/18) 

0.061 

(07/17) 

1 0.063†

DEQ# 14152 

EPA# 410090004 

1996 0.026 0.096

(08/10) 

0 0.084

(07/13) 

0.076 

(07/26) 

0 0.066†

1997 0.022 0.081

(07/04) 

0† 0.064

(07/04) 

0.053 

(05/11) 

0 0.063

1998 0.023 0.093

(07/26) 

0† 0.077

(07/27) 

0.066 

(08/28) 

0 0.065

1999 0.021 0.070

(07/09) 

0† 0.056

(07/09) 

0.049 

(09/22) 

0 0.056

2000 0.022 0.080

(06/04) 

0† 0.066

(06/27) 

0.054 

(06/03) 

0 0.056

2001 0.025 0.089

(08/10) 

0† 0.068

(08/10) 

0.056 

(05/10) 

0 0.053

2002 0.025 0.084

(07/10) 

0† 0.067

(08/13) 

0.061 

(06/12) 

0 0.057

2003 0.025 0.088

(09/03) 

0† 0.073

(09/03) 

0.069 

(07/28) 

0 0.062

2004 0.023 0.074

(07/24) 

0† 0.061

(07/23) 

0.058 

(07/22) 

0 0.062

2005 0.023 0.08

(08/04) 

0† 0.064

(08/04) 

0.055 

(08/14) 

0 0.061

Vancouver Ozone Plan November 2, 2006 39 of 56 
STATION LOCATION 

AND NUMBER Year 

SUMMER 

AVERAGE

1-HOUR

MAXIMUM 

(date)

# OF 

DAYS 

>0.125

ppm 

8-HOUR

AVERAGE

MAXIMUM

4TH

HIGHEST 

8-HOUR

AVERAGE 

# OF 

DAYS 

>0.085

ppm 

3 YEAR 

AVG 

OF 4TH

HIGH 

Vancouver Area 1995 0.021 0.117

(7/19)

0 n/a n/a 0 n/a

Mountain View High

School 

1996 0.022 0.112

(07/19) 

0 n/a n/a 0 n/a

1500 SE Blairmont Dr. 1997 0.02 0.077 

(07/04) 

0 n/a n/a 0 n/a

Vancouver 1998 0.021 0.102

(07/28) 

0 0.078

(07/27) 

0.07 

(08/28) 

0 n/a

AIRS #530110011 1999 0.021 0.080 

(09/22) 

0 0.061

(07/09) 

0.057 

(08/23) 

0 n/a

 2000 0.021 0.104 

(06/04) 

0 0.073

06/04) 

0.059 

(06/27) 

0 0.062

 2001 0.022 0.089 

(05/22) 

0 0.071

(08/10) 

0.063 

(06/20) 

0 0.06

2002 0.023 0.086

(07/10) 

0 0.073

(7/22)

0.056 

(06/25) 

0 0.059

2003 0.026 0.098

(09/03) 

0 0.077

(09/03) 

0.069 

(06/07) 

0 0.063

2004 0.021 0.083

(08/09) 

0 0.066

(07/24) 

0.056 

(06/21) 

0 0.060

2005 0.023 0.090

(05/27) 

0 0.076

(05/27) 

0.057 

(08/19) 

0 0.061

*Parts per million 

† The 8hour ozone standard became effective in 1998; 

1-hour values are no longer evaluated for attainment purposes. 

The 8 hr standard is the 3-year average of the 4th highest value. 

Vancouver Ozone Plan November 2, 2006 40 of 56 
Appendix 2 

1992 to 2005 Meteorological Factors Conducive to Ozone Formation 

in the Portland-Vancouver Area 

(ODEQ, April 2006) 

Anthony Barnack 

Air Quality Division 

Oregon Department of Environmental Quality 

(503) 229-5713 

Vancouver Ozone Plan November 2, 2006 41 of 56 
Appendix 3 

Emission Inventory 

The Portland-Vancouver AQMA was designated “Unclassifiable/Attainment” with the 8-hour 

ozone National Ambient Air Quality Standard (NAAQS) on April 30, 2004 (69FR 23829-30), as 

demonstrated through air quality monitoring data. EPA requires this maintenance plan to 

demonstrate continued compliance for at least ten years following EPA designation. WSU 

performed a modeling analysis with SWCAA and DEQ that forecasted ozone levels to 2015 and 

determined that these areas will continue to meet the standard. 

Both Portland and Vancouver maintenance plans accommodate future growth and provides for 

the protection of public health by ensuring compliance with the 8-hour ozone standard. These 

maintenance plans continue emission reduction strategies needed to maintain compliance. To 

approve the maintenance plan, EPA requires permanent and enforceable reductions in 

emissions to remain in effect throughout the maintenance period. 

This emission inventory is provided in compliance with published EPA requirements to formulate 

a strategy to maintain the NAAQS as a part of each state’s revisions to its State Implementation 

Plan (SIP). The principal components for development and documentation for the maintenance 

plan inventories include stationary point sources, stationary area sources, non-road mobile 

sources, on-road mobile sources, biogenic emission sources, quality assurance implementation, 

and emissions summaries. Countywide estimates are used to facilitate comparison with future 

year National Emissions Inventory submittals. The emissions inventory for the PortlandVancouver AQMA (Oregon portion) includes Clackamas, Multnomah and Washington counties; 

The emissions inventory for the Washington portion includes Clark county. Complete copies of 

these emission inventories are on file at SWCAA or DEQ and are available upon request. 

The WSU modeling study (Appendix 4) details the emissions inventory that was used to validate 

the model and evaluate the 2015 simulation. The model meteorology was based on a July 1998 

episode in which the Portland area violated the one-hour ozone NAAQS at the Carus monitoring 

site. 

Point source emissions from sources that are not Title 5 point sources were inventoried by DEQ 

regional staff and SWCAA staff using the following parameters: 

Geographic Area VOC NOx CO 

AQMA >10 tons/year >40 tons/year >100 tons/year 

25-mile buffer >100 tons/year >40 tons/year >100 tons/year 

Modeling domain >100 tons/year >40 tons/year >100 tons/year 

For point sources, SWCAA used 2002 ‘actual’ data generated from point source annual reports 

for the attainment year inventory. For 2015, SWCAA and DEQ developed two different growth 

scenarios for major industrial (point) sources. The scenarios are described in detail in Section 

5.0 of this plan.

In this document, the terms “annual emissions” and “typical summer day” emissions are used to 

categorize the estimated emissions for a particular time period. The annual emissions, in tons 

per year, are a total amount of emissions for the source category that occurred throughout the 

year. Typical summer day emissions are those produced on a hot summer weekday. The 

typical summer day emissions, in pounds per day, are based on the ozone season period from 

May 1st through the end of September as one in which, historically, the 8-hour ozone standard 

would most likely be exceeded. 

Vancouver Ozone Plan November 2, 2006 42 of 56 
 Percentages reported below reflect anthropogenic (human-caused) emissions; biogenic 

emissions have been subtracted from the total when calculating percentages except when 

reporting on biogenic emissions themselves. 

Annual Emission Inventory

The attainment year emission inventory (2002) for area sources, non-road mobile and on-road 

mobile sources and Title 5 point sources was developed from the DEQ and SWCAA 2002 

Consolidated Emissions Reporting Rule (CERR) National Emission Inventory (NEI) submittal. 

For point sources, DEQ and SWCAA used 2002 data generated from point source annual 

reports for the attainment year inventory. 

Fireplace and woodstove emissions were included in the annual emission values, but not in the 

typical summer day values. Wildfires, prescribed fires and structural fires were not included in 

either the annual averages or the typical summer day values. These sources were not 

significant in 2002 and not expected to be significant in 2015. Because the maintenance area is 

predominantly urban/suburban, large wildfires and prescribed fires are not common; therefore, 

emissions from these sources are insignificant. Structural fires are also considered insignificant 

sources. 

The annual emission inventories are summarized in Tables 10 and 11 below. The annual 

emissions are included for ease of comparison with future year CERR National Emission 

Inventory submittals. 

Table 10: Portland Area VOC and NOx Emissions (tons/year) 

 Portland Area VOC Emissions Portland Area NOx Emissions 

Clackamas, Multnomah, Washington Counties) (Clackamas, Multnomah, Washington Counties)

 Source Type

2002 Actual

2015

Projection (no 

growth

allowance)

2015

Maintenance

Demonstration

 Source Type

2002 Actual

2015

Projection (no 

growth

allowance)

2015

Maintenance

Demonstration

AREA 92,946 108,109 108,109 AREA 5,808 5,822 5,822

NON-ROAD 13,260 13,308 13,308 NON-ROAD 17,347 17,223 17,223

ON-ROAD 23,683 8,538 8,538 ON-ROAD 36,786 10,339 10,339

POINT 3,056 3,292 21,721 POINT 2,522 2,862 15,191

Total 132,944 133,246 151,675 Total 62,464 36,245 48,574

Table 11 – Vancouver Area VOC and NOx Emissions (tons/year) 

Vancouver Area VOC Vancouver Area NOx Emissions

(Clark County) (Clark County)

AREA 11,636 14,891 14,891 AREA 602 764 764

NONROAD 1,797 1,123 1,123 NONROAD 2,859 1,991 1,991

ON-ROAD 6,274 2,616 2,616 ON-ROAD 9,272 3,540 3,540

POINT 652 690 1,767 POINT 1,111 1,131 4,191

Total 20,359 19,320 20,397 Total 13,844 7,426 10,486 2015 Growth Projection 2015 Maintenance

Demonstration2015 MaintenanceDemonstration

Source 

200

Type

2 Actual

2015 GrowthProjection

Source

Type

2002 Actual

Vancouver Ozone Plan November 2, 2006 43 of 56 
Typical Summer Day Emission Inventory

DOE generated the typical summer day emission inventory for Area, Nonroad and On-road 

Mobile sources for SWCAA. For area sources and three non-road source categories 

(commercial marine, locomotives, aircraft), DOE used month and day-of-week profiles 

appropriate for each individual source category. On-road and all other non-road sources were 

specifically estimated for summer day conditions. The point sources were not adjusted for a 

typical summer day as these sources operate at the same levels year round. 

DEQ generated the typical summer day emission inventory using the Sparse Matrix Operator 

Kernel Emissions Modeling System (SMOKE) model to make the seasonal adjustments to the 

annual emissions inventory. Complete descriptions of the seasonal adjustment factors used to 

develop typical summer day emissions can be found in the Inventory Preparation Plan, available 

from DEQ. The SMOKE model was used to seasonally adjust the emissions for the CMAQ 

model validation, 2002 attainment inventory and 2015 maintenance demonstration emissions 

inventories. 

In both Washington and Oregon, fireplace and woodstove emissions were not included in the 

seasonally-adjusted area source inventory because they would not likely be used during 

meteorological conditions conducive to ozone formation (hot, stagnant summer days). Wildfires, 

prescribed fires and structural fires were also not included in the 2002 Attainment Inventory and 

2015 maintenance demonstration inventory because the modeling team’s research on source 

activity during the July 1998 episode indicated that these emissions were not significant during 

the 1998 episode. These sources were not significant on an annual basis either. 

Summary of Portland AQMA Emissions (Clackamas, Multnomah, and Washington 

Counties)

A summary of the Portland-Vancouver AQMA Ozone Maintenance Plan Emission Inventory for 

Point, Area, Non-road Mobile and On-road Mobile sources of VOC and NOx emissions is 

presented in the following section. Percentages reflect anthropogenic (human-caused) 

emissions; biogenic emissions have been subtracted from this summary. A full copy of the 

emission inventory is available upon request from DEQ. 

Source

Source

Type

Typ

e

AREA 253,871 291,098 291,098 AREA 5,529 6,157 6,157

BIOGENIC 437,910 437,910 437,910 BIOGENIC 3,890 3,890 3,890

NONROAD 110,188 101,699 101,699 NONROAD 136,713 95,638 95,638

ON-ROAD 139,542 54,521 54,521 ON-ROAD 216,750 68,910 68,910

POINT 17,020 18,304 119,943 POINT 14,913 16,783 86,780

---------- ---------- ---------- ---------- ---------- ----------

Totals 958,531 903,531 1,005,171 Totals 377,794 191,378 261,375

Totals

Minus

Biogenic 520,621 465,621 567,260 373,904 187,487 257,485 2002 Actual 2015 Growth Projection

Portland Area VOC and NOx Emissions, (lb/day)

(Clackamas, Multnomah, Washington Counties)

--------- VOC, lbs per day --------- --------- NOx, lbs per day --------- 2015 Growth Projection 2015 Maintenance Demonstrati

o

2015 Maintenancn

e 

Demonstrati

o

n2002 Actual

Vancouver Ozone Plan November 2, 2006 44 of 56 
2002 Attainment Inventory (Clackamas, Multnomah, and Washington Counties)

During an ozone season day, on-road mobile sources contribute 25% of the total VOC and 58% 

of the total NOx air emissions in the Oregon portion of the Portland-Vancouver AQMA. On-road 

mobile source emissions are based on motor vehicle travel during a typical summer day. The 

seasonal adjustment factor reflects the fact that emissions would likely increase during the 

summer months when tourism traffic picks up. Gasoline vehicles contribute 24% of the VOC 

emissions and 34% of the NOx emissions within the on-road mobile category; diesel vehicles 

contribute 24% of the NOx emissions. 

Stationary area sources comprise 54% of the total VOC and 1% of the total NOx air emissions in 

the Portland area on a typical summer day. Within the area source category, surface coating 

contributes 32% of the total VOC emissions while consumer solvents contribute 6% and graphic 

arts contribute 10% of the VOC emissions. NOx emissions from area sources are insignificant. 

Non-road mobile sources contribute 19% of the total VOC and 37% of the total NOx emissions 

on a typical summer day. Off-highway diesel equipment comprises 21% of the daily NOx

emissions; 7% of the total VOC emissions originate from 2-cycle engines within the non-road 

mobile source category. 

Stationary point sources comprise 3% of the VOC and 4 % of the NOx air emission in the 

Portland area on a typical summer day. 

Biogenic emissions which are produced by vegetation (e.g. terpenes from pine trees) contribute 

43% of the total VOC during a typical summer day. Washington State University provided the 

biogenic emissions data and these emissions are assumed to remain unchanged in the future, 

although urban development does modify the amount, location and type of vegetation over time. 

2015 Maintenance Demonstration (Clackamas, Multnomah, and Washington Counties)

During an ozone season day, on-road mobile sources contribute 12% of the total VOC and 39% 

of the total NOx air emissions in the Oregon portion of the Portland-Vancouver AQMA. On-road 

mobile source emissions are based on motor vehicle travel during a typical summer day and the 

seasonal adjustment factor reflects the fact that emissions would likely increase during the 

summer months when tourism traffic picks up. Gasoline vehicles contribute 11% of the VOC 

emissions and 25% of the NOx emissions within the on-road mobile category; diesel vehicles 

contribute 13% of the NOx emissions. 

Stationary area sources comprise 63% of the total VOC and 3% of the total NOx air emissions in 

the Portland area on a typical summer day. Within the area source category, surface coating 

contributes 33% of the total VOC emissions while consumer solvents contributes 9% and 

graphic arts contribute 13% of the VOC emissions. 

Non-road mobile sources contribute 22% of the total VOC and 52% of the total NOx emissions 

on a typical summer day. Off-highway diesel equipment comprises 24% of the daily NOx

emissions. 

Stationary point sources comprise 4% of the VOC and 9 % of the NOx air emissions in the 

Portland area on a typical summer day. 

Biogenic emissions which are produced by vegetation (e.g. terpenes from pine trees) contribute 

44% of the total VOC during a typical summer day. Washington State University provided the 

Vancouver Ozone Plan November 2, 2006 45 of 56 
biogenic emissions data and these emissions are assumed to remain unchanged in the future, 

although urban development does modify the amount, location and type of vegetation over time. 

Summary of Vancouver Emissions (Clark County, Washington)

A summary of the Vancouver Area Ozone Maintenance Plan Emission Inventory for Point, Area, 

Biogenic, Non-road Mobile and On-road Mobile sources is presented in the following section. A 

full copy of the emission inventory is available upon request from SWCAA. 

Vancouver Area VOC and NOX Emissions, Pounds per Season Day

(Clark County)

--- VOC, lbs per day --- --- NOX, lbs per day ---

Source

Source

Type

Type

AREA 18,014 21,860 21,860 AREA 665 786 786

BIOGENIC 79,417 79,417 79,417 BIOGENIC 965 965 965

NONROAD 15,374 9,339 9,339 NONROAD 23,222 15,183 15,183

ON-ROAD 38,315 16,026 16,026 ON-ROAD 50,495 19,482 19,482

POINT 3,572 3,780 9,682 POINT 6,089 6,197 22,965

---------- ---------- ---------- ---------- ---------- ----------

Totals 154,692 130,421 136,323 Totals 81,436 42,613 59,381

Anthropogenic 

Totals 75,275 51,004 80,471 41,648

2015 Growth Projection2015Maintenance Demonstration2002 Actual2015 Growth Projection2015Maintenance Demonstration2002 Actual

2002 Attainment Inventory (Clark County)

Biogenic emissions contribute 51% of the total VOC during a typical ozone season day. 

Biogenic emissions data was provided by Washington State University and are assumed to 

remain unchanged in the future, although urban development does modify the amount, location 

and type of vegetation over time. 

During an ozone season day, on-road mobile sources contributed 51% of the total humancaused volatile organic compound (VOC) and 63 % of the total nitrogen oxides (NOx) air 

emissions in the Vancouver area. On-road mobile source emissions are based on motor 

vehicle travel during a typical summer day. The seasonal adjustment factor reflects the fact that 

emissions would likely increase during the summer months when tourism traffic picks up. 

Stationary area sources in 2002 comprised 24% of the total anthropogenic VOC and 1% of the 

NOx air emissions in the Vancouver area on a typical summer day. The largest contributors of 

emissions from this category are architectural coatings and degreasing. 

Non-road mobile sources contribute 20% of the total anthropogenic VOC and 29% of the total 

NOx air emissions on a typical summer day. Emissions from lawn and garden equipment are 

the majority contributors of ozone precursors from this source category.

Stationary point sources comprised 5% of the anthropogenic VOC and 8 % of the NOx air 

emission in the Clark county area on a typical summer day in 2002 

2015 Maintenance Demonstration (Clark County)

Biogenic emissions which are produced by vegetation (e.g. terpenes from pine trees) contribute 

61% of the total VOC during a typical summer day. The estimated emission values used for 

Vancouver Ozone Plan November 2, 2006 46 of 56 
2015 biogenic emissions are the same values used for 2002 estimates. Washington State 

University provided the biogenic emissions data and these emissions are assumed to remain 

unchanged in the future, although urban development does modify the amount, location and 

type of vegetation over time. 

In the 2015 maintenance demonstration, during an ozone season day, on-road mobile sources 

would contribute 31% of the total VOC and 47% of the total NOx air emissions in the Vancouver 

portion of the Portland-Vancouver AQMA. On-road mobile source emissions are based on 

motor vehicle travel during weekdays as a typical summer day reflecting increased tourist traffic. 

Stationary area sources are predicted to be 43% of the total VOC and 2% of the total NOx air 

emissions in the Vancouver area on a typical summer day in 2015. 

Non-road mobile sources are projected to contribute 18% of the total VOC and 36% of the total 

NOx emissions on a typical summer day. 

Stationary point sources emissions in the Vancouver area using the growth projection numbers 

are projected to represent only 7% of the VOC and 15% of the NOx emissions on a typical 

summer day. 

Vancouver Ozone Plan November 2, 2006 47 of 56 
Appendix 4 

Modeling and Maintenance Demonstration 

WSU Modeling Study

The Oregon Dept. of Environmental Quality, Washington Dept. of Ecology (Ecology), Southwest 

Clean Air Agency (SWCAA), Washington State University (WSU) and EPA Region 10 teamed 

together to perform photochemical modeling for the Portland-Vancouver Air Quality 

Maintenance Area to improve our understanding of the potential for ozone exceedances in the 

future. The modeling work involved simulation of a July 1998 episode meteorology that had the

highest ozone levels observed in recent years. The model results were compared to available 

observed data, and the 1998 episode was used as a basis for evaluation of future year (2015) 

growth projections. 

The agencies contracted with WSU to use the CMAQ dispersion model to help assess the 

status of the Portland-Vancouver airshed with respect to the national ambient air quality 

standard for tropospheric ozone. The Turner monitoring site is included within the modeling 

domain and allowed DEQ to asses the status of the Salem-Keizer airshed at the same time. 

The modeling effort is documented in the report, “Historical and Future Ozone Simulations 

Using the MM5/SMOKE/CMAQ System in the Portland-Vancouver Area” (WSU, December 31, 

2005), in this Appendix. Although most of the modeling effort has been performed by WSU, 

DEQ recently developed the technical capability to run the SMOKE and CMAQ simulations inhouse. 

2015 Projection

The “managed growth projection simulation” in the WSU modeling report is the modeling results 

described as the “2015 Projection” in the Portland-Vancouver Ozone Maintenance Plan. The 

emission inventory that was used in that modeling simulation is detailed in an appendix to the 

WSU report. 

2015 Maintenance Demonstration

The “2015 Maintenance Demonstration” in the Portland-Vancouver uses the same emission 

inventory as the “2015 Projection,” except for point sources. Point sources within Oregon were 

based on the maximum allowable permitted emission limits (Plant Site Emission Limits), and 

within Washington were based on allowables proportional to Oregon counties for Washington 

sources. A point source growth allowance was added to both inventories: 5000 tons VOC and 

5000 tons NOx were added to areas zoned for industrial growth in the Oregon portion of the 

Portland-Vancouver AQMA, and a proportional amount of 411 tons of VOC and 1313 tons of 

NOx was added to areas zoned for industrial growth in the Washington portion of the PortlandVancouver AQMA. 

The results of the modeled attainment test are described in Appendix 6. 

Vancouver Ozone Plan November 2, 2006 48 of 56 
Appendix 5 

Economic Report to the Metro Council 

2000-2030 Regional Forecast 

for the Portland-Vancouver Metropolitan Area 

(Data Resource Center, Metro, December 2002 final draft) 

Vancouver Ozone Plan November 2, 2006 49 of 56 
Appendix 6 

Modeled Attainment Test 

Appendix 6 details how SWCAA, Ecology and DEQ applied the modeled attainment test to the 

2015 Maintenance Demonstration modeling results. 

The modeled attainment test is an exercise in which an air quality model is used to simulate 

current and future air quality. The 8-hour NAAQS for ozone requires the fourth highest 8-hour 

daily maximum ozone concentration, averaged over three consecutive years, to be less than 80 

ppb6

 . The recommended attainment test is one in which model estimates are used in a 

“relative” rather than “absolute“ sense. That is, take the ratio of the model’s future to current 

(baseline) predictions at ozone monitors. EPA calls these ratios “relative reduction factors”. 

Future ozone concentrations are estimated at existing monitoring sites by multiplying a modeled 

relative reduction factor at locations near each monitor by the observation-based, monitorspecific, “baseline” ozone design value. The resulting predicted future concentrations are 

compared to 84 ppb. 

For more information, see “Guidance on the Use of Models and Other Analyses in Attainment 

Demonstrations for the 8-hour Ozone NAAQS” (EPA-450/R-05-002, October, 2005). 

 6 Because of rounding conventions in which non-significant figures are truncated, a modeling 

estimate of <85 ppb is equivalent to <= 84 ppb. Attainment is demonstrated when a modeling 

target of future estimates of ozone concentrations are <=84 ppb. 

Vancouver Ozone Plan November 2, 2006 50 of 56 
Portland-Vancouver AQMA Analysis of 8-Hour Ozone Maintenance using the CMAQ dispersion model

Step 1. Current Design Value (1998 "observed" values)

Year

Carus Milwaukie Sauvie Island Mt View Turner Wishram 1996-1998 1997-1999 1998-2000

1996 99 85 76 81 92 70 Carus 81 72 73 75.0

1997 62 54 53 53 61 60 Milwaukie 67 55 56 59.3

1998 81 61 66 69 77 63 Sauvie Island 65 56 56 59.1

1999 72 51 49 57 65 63 Mt View 68 60 61 62.9

2000 65 56 54 58 59 66 Turner 77 68 67 70.4

Wishram 64 62 64 63.4

Step 2. Determination of Maintenance, 2015 projection including growth allowance

Carus

1 90 86

2 97 92

3 107 103

Mean 75.0 98 94 0.955 71.7

Milwaukie

1 86 93

2 91 92

3 98 102

Mean 59.3 92 96 1.046 62.1

Sauvie Island

1 70 69

2 90 79

3 87 80

Mean 59.1 82 76 0.923 54.5

Mtn View

1 76 81

2 86 77

3 88 87

Mean 62.9 83 81 0.975 61.3

Turner

1 74 64

2 101 88

3 89 73

Mean 70.4 88 75 0.852 60.0

Wishram

1 55 51

2 56 51

3 59 52

Mean 63.4 57 52 0.910 57.7

1998 Baseline

8-Hour Max

2015 

Predicted 8-

Hour Max

Relative

Reduction

Factor (RRF)

Future 

Design Value 

(DVF)

Day

Current Design

Value (DVC)

1998 Baseline

8-Hour Max

2015 

Predicted 8-

Hour Max

Relative

Reduction

Factor (RRF)

Future 

Design Value 

(DVF)

Day

Current Design

Value (DVC)

Day

Current Design

Value (DVC)

1998 Baseline

8-Hour Max

2015 

Predicted 8-

Hour Max

Day

Current Design

Value (DVC)

1998 Baseline

8-Hour Max

2015 

Predicted 8-

Hour Max

1998 Baseline

8-Hour Max

2015 

Predicted 8-

Hour Max

Relative

Reduction

Factor (RRF)

Future 

Design Value 

(DVF)

Relative

Reduction

Factor (RRF)

Future 

Design Value 

(DVF)

Relative

Reduction

Factor (RRF)

Future 

Design Value 

(DVF)

Day

Current Design

Value (DVC)

1998 Baseline

8-Hour Max

2015 

Predicted 8-

Hour Max

Relative

Reduction

Factor (RRF)

Future 

Design Value 

(DVF)

Day

Current Design

Value (DVC)

Current Design 

Value (DVC) 4th High (ppb) Monitoring 

Site

Design Values

*The Wishram monitoring site is not within the Portland-Vancouver AQMA or Salem Area Ozone Maintenance Plan areas. 

Wishram data is included here for informational purposes only. 

Vancouver Ozone Plan November 2, 2006 51 of 56 
Appendix 7 

Vancouver Control Strategies 

SWCAA Regulations 

SWCAA 400 - General Regulations for Air Pollution Sources, last updated 12/16/05 

400-030 – Definitions – strikeout proposed version, (last adopted 11/9/03)

400-101 – Sources Exempt from Registration Requirements – strikeout version (last

adopted 11/9/03) 

400-109 – Air Discharge Permit Applications (Notice of Construction), as adopted 

12/16/05 

400-110 – New Source Review, as adopted 11/9/03 

400-111 - Requirements for New Sources in a Maintenance Plan Area - strikeout 

proposed version, (last adopted 11/9/03) 

400-112 – Requirements for New Sources in Nonattainment Areas (as adopted 11/9/03) 

400-113 - Requirements for New Sources in an Attainment or Nonclassifiable Area – 

strikeout version with proposed changes (last adopted 11/9/03) 

400-114 - Requirements for Replacement of Substantial Alteration of Emission Control 

Technology at an Existing Stationary Source, (as adopted 11/9/03) 

400-116 – Maintenance of Equipment, (as adopted 11/9/03) 

400-190 – Requirements for New Sources in Nonattainment Areas, (as adopted 11/9/03) 

SWCAA 490- Emission Standards and Controls for Sources Emitting Volatile Organic 

Compounds, adopted March 18, 2001, no current rulemaking 

SWCAA 491- Emission Standards and Controls for Sources Emitting Gasoline Vapors, adopted 

March 18, 2001, no current rulemaking 

SWCAA 493- VOC Area Source Rules, adopted May 25, 1996, no current rulemaking 

Washington State Regulations 

Chapter 173 422 WAC Motor Vehicle Emission Inspection, effective date June 3, 2002 

(supporting sections 422-030, 422-050, 422-060, 422-070, 422-170, 422-190, entire 

173-422 included) 

Vancouver Ozone Plan November 2, 2006 52 of 56 
Appendix 8 

Other Emission Reduction Programs Information 

Commute Trip Reduction Program Information 

Commute Trip Reduction Efficiency Act Frequently Asked Questions and Presentation 

Washington State Department of Transportation CTR Performance Grants Information 

Vancouver Ozone Plan November 2, 2006 53 of 56 
Appendix 9 

Vancouver Attainment Area Map and Description 

Vancouver Ozone Plan November 2, 2006 54 of 56 
Southwest Clean Air Agency Maintenance Area Map 

Vancouver Ozone Plan November 2, 2006 55 of 56 
Description of the Vancouver Ozone and Carbon Monoxide Maintenance Area Boundary

The ozone and carbon monoxide maintenance area boundary description begins at the 

northwest corner at the intersection of the section line on the south side of Section 36 of 

T4N.R1W and the north side of Section 1 of T3N.R1W. The boundary turns southward following 

the east shores of Lake River, until it would intersect with the 14900 block NW, then easterly to 

join with NW 149th Street. This boundary runs until it meets the western edge of Interstate 5, 

then north to 159th Street and east on 159th Street to the east side of NE 50th Avenue. On 50th 

Avenue the boundary runs south until it joins the south bank of Salmon Creek, following the 

south branch of the creek until it reaches NE Caples Road, then southerly on the west side of 

Caples Road (currently SR-502) until it intersects with NE 144th Street. The boundary continues 

eastward along the south side of NE 144th Street following the 14400 block plane to where it 

would join with the west side of NE 212 Avenue, then southward to the south side of NE 109th 

Street. The boundary continues east on NE 109th Street, then southerly along the west side of 

NE 232 Avenue to where the 23200 block joins with the northern edge of NE 58th Street. The 

boundary continues east on NE 58th Street until the 5800 block intersects with the western 

edge of Livingston Road. The boundary follows Livingston Road South until it turns into NE 

292nd Avenue. Staying on the plane of the 29200 block, the boundary proceeds south until it 

joins SE Blair Road. The boundary follows along the south-west side of Blair Road southeastward to its intersection with Washougal River Road. The boundary proceeds eastward at 

the northern edge of the 2000 block to SE 20th Street. The boundary continues east on SE 20th 

Street until it intersects the western edge of SE Jennings Road (352nd Avenue), then south 

along the 4900 plane to SE 49th Avenue. The boundary follows the 4900 plane south until it 

intersects Evergreen Boulevard (the eastern edge of current Washougal City limits). The 

boundary continues south along the Washougal City limits to the State border along the section 

line on the west side of Section 21 of T1N.R4E. The boundary follows the Clark County line 

(State boundary) down the Columbia River until it connects at the northwest corner of the 

boundary at the section line of Section 36 of T4N.R1W and the north side of Section 1 of 

T3N.R1W. 

Note: The Columbia River is the common boundary shared by Washington and Oregon for the 

Portland-Vancouver carbon monoxide and ozone non-attainment area. 

Vancouver Ozone Plan November 2, 2006 56 of 56