Revision to the 

New Hampshire 

State Implementation Plan 

Request for 

Redesignation of the Boston-Manchester-Portsmouth (SE), NH 

8-Hour Ozone (1997 Standard) Nonattainment Area 

Submitted 

March 2, 2012 

Amended 

September 21, 2012 

Air Resources Division 
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Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page i

TABLE OF CONTENTS 

1. INTRODUCTION

1.1 Original Designation of Ozone Nonattainment Areas....................................................1 

1.2 Description of the Southeast New Hampshire Nonattainment Area...................................4 

1.3 Status of Air Quality..........................................................................................4 

2. ATTAINMENT OF THE STANDARD........................................................................ 5 

2.1 Ozone Monitoring Network..................................................................................5 

2.2 Summary of Ozone Monitoring Data......................................................................6 

2.2.1 Annual Fourth-Highest Ozone Values..............................................................6 

2.2.2 Ozone Design Values..................................................................................6 

2.2.3 Threshold Analysis.....................................................................................8 

2.2.4 Ozone-Related Parameters............................................................................9 

2.2.4.1 Oxides of Nitrogen (NOx)......................................................................9 

2.2.4.2 Volatile Organic Compounds (VOC).......................................................10 

2.3 Summary of Meteorological Analyses....................................................................12 

2.3.1 Temperature vs. Ozone...............................................................................13 

2.3.2 Wind Direction Frequency...........................................................................13 

3. STATE IMPLEMENTATION PLAN FOR NONATTAINMENT AREA.................................15 

3.1 Recent SIP Revisions........................................................................................15 

3.2 Reasonably Available Control Technology Requirements.............................................16 

3.3 1-Hour Ozone Attainment Demonstration............................................................... 16 

3.4 Reasonable Further Progress Requirements...............................................................17 

3.5 Clean Data Rule for 8-Hour Ozone Attainment..........................................................17 

4. PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS......................................18 

4.1 Emission Control Programs.................................................................................18 

4.2 Upwind Emission Reductions..............................................................................23 

4.3 In-State Emission Reductions..............................................................................25 

5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT.....................27 

5.1 Requirements of Section 110(a)(2)........................................................................28 

5.1.1 Emission Reporting and Recordkeeping............................................................29 

 5.1.2 Periodic Testing and Inspection......................................................................29 

 5.1.3 Transportation-Related Control Measures..........................................................29 

 5.1.4 Continuous Monitoring and Recording of Emissions.............................................29 

 5.1.5 Legal Authority and Emergency Powers............................................................29 

5.2 Continuance of Existing Control Requirements after Redesignation.................................30 

5.3 Permitting of Stationary Sources...........................................................................32 

5.4 Monitoring of Stationary Sources..........................................................................32 

5.5 Transportation Conformity..................................................................................33 

5.6 Vapor Recovery: Stage II and Onboard Refueling........................................................34 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page ii

5.7 Resource Commitments.....................................................................................35 

5.8 Future Revisions to the Plan................................................................................35 

6. MAINTENANCE PLAN.........................................................................................36 

6.1 Attainment Inventory........................................................................................36 

6.2 Maintenance Demonstration................................................................................37 

6.2.1 Projected 2012 and 2022 Emissions Inventory...................................................38 

6.2.2 Air Quality Modeling.................................................................................39 

6.2.2.1 EPA Modeling Analysis for the Nonroad Land-Based Diesel Engines Standards.........39 

6.2.2.2 EPA Modeling Analysis for the CAIR Rulemaking.........................................40 

6.3 Air Quality Monitoring Network...........................................................................41 

6.4 Verification of Continued Attainment.....................................................................41 

6.5 Contingency Plan.............................................................................................41 

6.5.1 ICI Boilers (at Major Point Sources).................................................................43 

6.5.2 Emulsified Asphalt Paving............................................................................43 

6.5.3 Consumer Products....................................................................................43 

6.5.4 Additional Controls on Boilers.......................................................................43 

6.5.5 Other Contingency Measures.........................................................................44 

7. ADMINISTRATIVE DOCUMENTS...........................................................................45 

8. SUMMARY AND CONCLUSIONS...........................................................................46 

LIST OF FIGURES 

Figure 1-1 Map of New Hampshire’s Former 1-Hour Ozone Nonattainment Areas......................2 

Figure 1-2 Map of New Hampshire’s Attainment Status for 1997 8-Hour Ozone NAAQS..............3 

Figure 2-1 Ozone-Related Air Quality Monitors in New Hampshire........................................5 

Figure 2-2 8-Hour Ozone Trends in the Southeast New Hampshire Nonattainment Area, 

1990-2011..............................................................................................7 

Figure 2-3 8-Hour Ozone Trends in New Hampshire Attainment Areas, 1990-2011.....................7 

Figure 2-4 8-Hour Ozone Design Value Trends in the Southeast New Hampshire 

Nonattainment Area, 1990-2011.....................................................................8 

Figure 2-5 NOx Trends in New Hampshire, 1998-2010.......................................................9 

Figure 2-6 NOx Trends in Maine, 1998-2010.....................................................................9 

Figure 2-7 NOx Trends in Massachusetts, 1998-2010.........................................................10 

Figure 2-8 Ozone-Season Average NOx Concentrations in the Ozone Transport Region, 

1998-2010.............................................................................................10 

Figure 2-9 TNMOC and PAMHC Trends in New Hampshire, Maine, and Massachusetts, 

1998-2010..............................................................................................11 

Figure 2-10 Average TNMOC and PAMHC in Nashua, New Hampshire, 2006-2010.....................11 

Figure 2-11 Average TNMOC and PAMHC on Pack Monadnock in Peterborough, 

New Hampshire, 2006-2010.........................................................................11

Figure 2-12 Number of Days with Exceedances of the 1997 8-Hour Ozone Standard in 

New Hampshire, 1985-2011.........................................................................12 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page iii

Figure 2-13 Number of Days with Maximum Temperatures above 85 F and Number of Days 

with Ozone Exceedances in New Hampshire, 1985-2011......................................13 

Figure 2-14 New Hampshire Wind Direction Frequencies in the Months of April through 

September, 1995-2010...............................................................................14 

Figure 4-1 Ozone-Season NOX Emissions from All NOx Budget Trading Program Sources............24 

Figure 4-2 Ozone-Season NOx and VOC Emissions in the Eastern United States by 

Source Category: 1997, 2002 and 2004............................................................25 

Figure 4-3 Ozone-Season Daily NOx Emissions in New Hampshire by Source Category: 

2002, 2005, and 2008.................................................................................26

Figure 4-4 Ozone-Season Daily VOC Emissions in New Hampshire by Source Category: 

2002, 2005, and 2008.................................................................................26 

LIST OF TABLES 

Table 1-1 New Hampshire Designations/Classifications for 8-Hour Ozone Standard: 

Nonattainment Areas, Effective June 15, 2004.........................................................4 

Table 2-1 8-Hour Ozone Monitoring Data: 2012 Threshold Values and 2010-2011 Design Values 

Based on Fourth-Highest Annual Maxima (ppb)....................................................8 

Table 4-1 Federal Emission Control Programs for NOx and VOC in the Southeast New Hampshire 

Nonattainment Area.....................................................................................19 

Table 4-2 State Emission Control Regulations for NOx and VOC in the Southeast New Hampshire 

Nonattainment Area.....................................................................................20 

Table 4-3 NOx and VOC RACT Orders Issued in New Hampshire, 2001-Present........................23 

Table 4-4 NOx and VOC Emissions in New Hampshire, 2002, 2005, and 2008 (tons/year).............26 

Table 5-1 2008 and 2022 Motor Vehicle Emission Budgets for the Southeast New Hampshire 

Nonattainment Area (tons per summer day)...................................................................34 

Table 6-1 2008 vs. 2012 and 2022 NOx and VOC Emissions in the Southeast New Hampshire 

Nonattainment Area (pounds per day)..................................................................38 

Table 6-2 Summary of CAIR Modeling Results for Ozone Levels in New Hampshire (ppb)..............40 

Table 6-3 Estimated Emission Reductions from Three BOTW Control Measures........................43 

Table 6-4 Potential Contingency Measures for Reducing Ozone Levels.............................................45 

LIST OF ATTACHMENTS 

ATTACHMENT A Technical Support Document for Redesignation of the Boston-ManchesterPortsmouth (SE), NH 8-Hour Ozone (1997 Standard) Nonattainment Area 

ATTACHMENT B 8-Hour Ozone Data 

ATTACHMENT C Chemical Analyses 

ATTACHMENT D Meteorological Analyses 

ATTACHMENT E Administrative Documents 

ATTACHMENT F MOVES Input/Output Files for 2008 and 2022 Motor Vehicle Emissions Budgets 

ATTACHMENT G Documentation for 2008 Emissions Inventory 

ATTACHMENT H Projected 2012 and 2022 Emissions Inventories 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page iv

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Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 1

1. INTRODUCTION 

The New Hampshire Department of Environmental Services (NHDES) presents this report as 

documentation for its request to the Environmental Protection Agency (EPA) to redesignate the 

Boston-Manchester-Portsmouth (SE), NH ozone nonattainment area to attainment of the 8-hour 

ozone standard of 0.08 parts per million (ppm) promulgated in 1997. Ground-level ozone 

monitoring data from 2002-2011 show these New Hampshire counties are now in attainment for this 

standard. 

Section 107(d)(3)(E) of the Clean Air Act (CAA) establishes that, for an area to be redesignated, 

several determinations and approvals from the EPA Administrator are required. EPA provided 

guidance on redesignation in the General Preamble for the Implementation of Title I of the CAA 

Amendments of 1990, on April 16, 1992 (57 FR 13498), and supplemented this guidance on April 

28, 1992 (57 FR 18070). EPA has provided further guidance on processing redesignation requests 

in subsequent memoranda. The following lists the determinations and approvals required from the 

EPA Administrator:

• A determination that the area has attained the 8-hour ozone standard, 

• Approval of a State Implementation Plan (SIP) for the area under Section 110(k) of the 

Clean Air Act, 

• A determination that the improvement in air quality is due to permanent and enforceable 

reductions in emissions resulting from implementation of the SIP and other federal 

requirements, 

• Approval of a maintenance plan under Section 175A of the Clean Air Act, and 

• A determination that the state has met all Title I, Part A, Section 110, and Part D requirements 

for the area. 

Each of these requirements is addressed within the main body of this submittal. In addition, a 

technical support document is provided in Attachment A. The technical support document is 

presented in two sections. The first provides a conceptual description of the nature of ozone 

formation and transport in the Northeast. The second describes a photochemical air quality 

modeling assessment that was undertaken in 2007 by New Hampshire and other Ozone Transport 

Region states. The results of this modeling assessment were used by states for attainment 

demonstrations and other SIP planning purposes. They are offered for review in the technical 

support document because they support the conclusions of this redesignation request. 

NHDES is also submitting as part of this redesignation request a 2022 motor vehicle emissions 

budget (MVEB) for the area. The MVEB will be used to assure that emissions from on-road mobile 

sources do not exceed levels consistent with maintenance of the 1997 8-hour ozone standard. 

1.1 Original Designation of Ozone Nonattainment Areas 

Under the 1990 Clean Air Act Amendments, all or portions of five counties in New Hampshire were 

designated as nonattainment areas for the former 1-hour National Ambient Air Quality Standard 

(NAAQS) of 0.12 parts per million (ppm) for ground-level ozone (see Code of Federal Regulations

40 CFR 81.330): 

• All of Strafford County and large portions of Hillsborough and Rockingham Counties were 

designated as “serious” nonattainment areas; 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 2

• The remaining portions of Hillsborough and Rockingham counties plus all of Merrimack 

County were designated as “marginal” nonattainment areas; and 

• All of Cheshire County was designated as a nonattainment area with incomplete data. 

These former 1-hour ozone nonattainment areas are shown in Figure 1-1. 

Figure 1-1 . Map of New Hampshire’s Former 1-Hour Ozone Nonattainment Areas 

STATE OF

NEW HAMPSHIRE

1-Hour Ozone 

Nonattainment Areas

Seacoast Serious Area

Southern Serious Area

Marginal Area

Nonattainment/

Incomplete Data

Attainment or

Unclassifiable 

Areas

Pelham

Hudson

Nashua Hollis Brookline Mason

New 

Ipswich

Rindge

Windham

Salem

Atkinson

Newton

South

Hampton

Seabrook

Hampton

North

Hampton

Rye

Ports

mouth New Castle

Hampstead Derry

San

down Dan

Ville Kings

ton

East

Kings

ton

Kens

ington

Hamp

 ton

 Falls

Exeter

Strat

Brent ham

Fremont Wood

Epping

Newmarket

Newfields

Green

 land

Newing

ton

Durham

Madbury

Dover

Rollingsford

Sommersworth

Rochester

Barrington

Milton

Farmington

Strafford

Nottingham Lee

Northwood

Deerfield

Raymond

Candia

Auburn

Chester

London

Derry

Manchester

Hookset

Concord

Allens

Bow town

Pembroke

Hopkinton

Weare

Goffstown

Bedford

AmherstMerrimack

Litchfield

New

Boston

Lynde

borough

Mt.

Vernon

Milford

Wilton

Temple

Dunbarton

Richmound Fitzwilliam

Winchester

Hinsdale

Chesterfield

West

moreland Keene

Swanzey

Troy Jaffrey

Marl Dublin

borough

Roxbury

Harrisville

Peter

borough

Sharon

Greenland

Frances

town Hannock

Benning

ton

Deering

Antrim

Stoddard

Nelson

Sullivan

Gilsum

Surry

Walpole

Acworth Lempster

Langdon

Charles

town

Alstead

Marlow

Washington

Hillsborough

Henniker

Bradford

Warner

Newbury Goshen Unity

Claremont

Cornish

Plantfield

Lebanon

Hanover

Enfield

Enfield

Grantham

Croydon

Newport

Sunapee

Springfield

Grafton

Orange

Danbury

Alexandria

Wilmot

New

London

Sutton

Salibury

Andover

Hill

Bristol

Hebron

Bridge

water New

Hampton

Meredith

Sanbornton

Franklin

Northfield

Webster

Canterbury

Loudon

Epsom

Pittsfield

Gilmanton

Belmont Tilton

Laconia

Gilford

Alton

Barnstead

New

Durham

Brook

field

Middle

town

Wakefield

Wolfboro

Moulton

borough

Tuftonboro

Ossipee

Lyme

Orford

Piermont

Haverhill

Bath

Warren

Benton

Wentworth

Dorchester

Groton

Rumney

Ellsworth

Woodstock

Lincoln

Easton

Landaff

Monroe

Lyman

Lisbon

Sugar

Hill Franconia

Bethlehem

Littleton

Carroll

Livermore

Waterville

Valley

Thornton

Campton

Plymouth

Holderness

Ashland

Sandwich

Hebron

Albany

Tamworth

Freedom

Effingham

Conway

Madison Eaton

Hebron

Jackson

Chatham

Beans

Purchase

Sargents

Purchase Crawfords 

Purchase

Low&Burbanks

Grant

Beans

Grant

Martins Loc.

Greens Grant

Pinkhams 

Grant

Hales

Location

Dalton

Whitefield

Jefferson

Lancaster

North

Umberland

Kilkenny

Randolph

Berlin

Gorham Shelburne

Sucess

Milan

Stark

Stratford

Columbia

Colebrook

Stewartstown

Dixville

Millsfield

Odell

Dummer Cambridge

Errol

Wentworths

Location

Second

College 

Grant

Dixs

Grant

Atkinson & Gilmanton

Academy Grant

Clarksville

Pittburg

Ervings 

Location

On July 18, 1997, EPA promulgated a new 8-hour ozone standard to replace the 1-hour standard for 

ground-level ozone (62 FR 38855). The 8-hour ozone NAAQS, which was set at a level of 0.08 

parts per million (ppm) and is based on an 8-hour average of ambient ozone concentrations, more 

directly relates to ozone levels associated with adverse health effects. After the resolution of 

numerous legal challenges, on April 30, 2004, EPA published final attainment designations (69 FR 

23857) for the 1997 8-hour ozone NAAQS. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 3

The Boston-Manchester-Portsmouth (SE), NH nonattainment area (hereinafter referred to as the 

Southeast New Hampshire Nonattainment Area) was created covering the southeastern-most portion 

of the state (see Figure 1-2). This nonattainment area, which includes portions of four counties 

(Hillsborough, Merrimack, Rockingham, and Strafford), was classified as “Subpart 2/moderate” 

nonattainment for the 8-hour ozone standard.1 The area designations/classifications were based on 

2000-2002 data and the recommendations of NHDES in a letter submitted to EPA on July 15, 2003. 

The moderate nonattainment classification was selected to be consistent with contiguous 

nonattainment areas in Massachusetts and Maine.

Figure 1-2. Map of New Hampshire’s Attainment Status for 1997 8-Hour Ozone NAAQS 

STATE OF

NEW HAMPSHIRE

8-Hour Ozone 

Nonattainment Area

Southeast New Hampshire 

Moderate Area

Attainment Areas

Pe lham

Huds o n

N as hua Holli s Broo k line Ma son

N ew 

Ips wic h

R ind ge

W indha m

Sal em

Atk inson

Ne wt on

So uth

Ha mpton

Se abrook

Hampt on

North

Ha mpto n

Ry e

Ports

mo ut h Ne w C as tle

Ha mpstea d D erry

San

dow n Da n

Vill e Ki ngs

t on

East

Kings

ton

Ke ns

ing ton

H amp

 ton

 Fall s

Exe te r

St ra t

B re nt ha m

Fre mont W ood

Ep pin g

Ne wma rk et

Ne wfi elds G ree n

 la nd

N ew ing

to n

Du rha m

M adbury

Dov er

R ol lin gsford

Sommers worth

R oc hes te r

Ba rri ngt on

M ilton

F a rmi ng t on

Straf ford

No tt ingha m Le e

Nort hwo od

De erfi eld

Ra ymond

Ca ndia

A ub urn

Ches te r

Lon don

Derry

Manc h es te r

H ook se t

Co nc ord

Alle n s

Bow town

Pembrok e

H opk in ton

Wea re

Go ff st own

B ed ford

A mhe rstM e rrima ck

Li tc hf ie ld

N ew

B os ton

Ly nd e

bo roug h

M t.

Ve rnon

Milfo rd

Wil ton

Temple

Dunbarto n

R ic hmo und Fitzw ill iam

Winche st er

Hi ns dale

Che st erfi eld

We st

more la nd K ee ne

Swa nzey

Troy Ja ffrey

M arl D ub li n

borough

R ox bury Ha rris vi lle

Pe te r

borough

Sha ron

Gree n land

Fra nce s

tow n H an noc k

Be nning

ton

D ee ri ng

A nt rim

Stod dard

Ne ls on

Sulli va n

Gi lsu m

Surry

Wa lpo le

A cw ort h Lempst er

La ng don

Ch arle s

tow n

Als te ad

M arlow

Wa shin gton

Hi llsb orough

He nni ke r

Bra dfo rd

Wa rne r

New bury

G oshen Un it y

Cla re mont

Cornish

Plan tfie ld

Lebanon

Hanov er

Enfi eld

En fie ld

Gra nt ham

Croydon

N ew port

Suna pe e

Springfie ld

G raf to n

Ora nge

Da n bury

Ale xa ndria

Wi lmot

New

Londo n

Sutt on

Sal ibury

A ndove r

Hill

Bris tol

Hebron

Bridge

wa te r

Ne w

Ha mpton

M ere di th

Sanb orn ton

Fra nk lin

Northf iel d

W eb s te r

Cant erb ury

L ou don

E ps o m

P ittsf iel d

Gil man ton

Bel mont Ti lton

La co nia

G ilford

Alt on

Ba rns te ad

N ew

D urh am

Brook

fie ld

M id dl e

tow n

W ak efiel d

W ol fb oro

M oulton

borough

T uf tonboro

Oss ipe e

Lyme

Orford

Pie rmont

Hav erhill

Ba th

Wa rre n

Bent on

We nt worth

Dorche st er

Groto n

Ru mne y

Ells wo rth

Woods to ck

Li nc o ln

Eas ton

La nda ff

Monroe

Ly man

Lis bon

Su gar

Hi ll Fran c onia

Be thle he m

Lit tle to n

Ca rroll

Live rmore

Wa te rv ill e

Va lle y

T horn ton

Campt on

Pl ymo uth

H ol de rne ss

As hland

S andwic h

Hebron

Alb an y

Ta mwo rth

Fre edom

Ef fingham

Conwa y

Ma d ison Eat on

H ebron

Ja ck s on

C ha th a m

Be ans

Purc h as e

Sarg en ts

Purc has e Craw fords 

Pu rc h as e

Low&B urba nk s

G ra nt

Bea ns

Gran t

Ma rtins Loc .

Gre ens Gran t

Pi nk hams 

G ra nt

Ha les

Loc a tion

Da lto n Wh it efiel dJe ff ers on

La n ca st er

N ort h

U mbe rland

K ilk en ny

R an dolp h

B erlin

Gorham Shel burne

S uc es s

Mi lan Sta rk

Stra tf ord

C ol umb ia

C ol ebrook

St ew arts tow n

D ixv ille

Mill sf iel d

O de ll

Dummer Ca mbri dge

Errol

We nt wo rths

Loc at ion

Sec ond

Colle ge 

Grant

Dix s

Grant

Atk inson & Gil manton

Aca demy Gra nt

C lark sv ille

Pit tbu rg

Ervings 

L oc a tion

 

1 Subpart 2 refers to Subpart 2–Additional Provisions for Ozone Nonattainment Areas of Title I, Part D of the Clean Air 

Act, which supplements, and is more prescriptive than, the general requirements for nonattainment areas found in Subpart 1. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 4

1.2 Description of the Southeast New Hampshire Nonattainment Area 

The Southeast New Hampshire Nonattainment Area includes 52 cities and towns in Hillsborough, 

Merrimack, Rockingham, and Strafford Counties (Table 1-1). According to the 2010 census, these 

communities have a total population of 729,071. Manchester is the largest municipality in the area 

with a population of 109,565, followed in order by Nashua, 86,494; Derry, 33,109; Dover, 29,987; 

Rochester, 29,752; Salem, 28,776; and Merrimack, 25,494. 

Table 1-1. New Hampshire Designations/Classifications for 8-Hour Ozone Standard: 

Nonattainment Areas, Effective June 15, 2004 (FR 69 23857) 

Area County Cities and Towns Included Designation/ 

Classification 

Hillsborough (part) Amherst, Bedford, Brookline, Goffstown, Hollis, Hudson, 

Litchfield, Manchester, Merrimack, Milford, Nashua, Pelham 

Nonattainment 

Subpart 2/Moderate 

Merrimack (part) Hooksett Nonattainment 

Subpart 2/Moderate 

Rockingham (part) Atkinson, Auburn, Brentwood, Candia, Chester, Danville, 

Derry, E. Kingston, Epping, Exeter, Fremont, Greenland, 

Hampstead, Hampton, Hampton Falls, Kensington, 

Kingston, Londonderry, New Castle, Newfields, Newington, 

Newmarket, Newton, North Hampton, Plaistow, 

Portsmouth, Raymond, Rye, Salem, Sandown, Seabrook,

South Hampton, Stratham, Windham 

Nonattainment 

Subpart 2/Moderate 

Boston-ManchesterPortsmouth Area 

(Southeast New 

Hampshire Area) 

Strafford (part) Dover, Durham, Rochester, Rollinsford, and Somersworth Nonattainment 

Subpart 2/Moderate 

1.3 Status of Air Quality 

Ground-level ozone monitoring data for each three-consecutive-year monitoring period from 2002 

to 2011 show that air quality in the Southeast New Hampshire Nonattainment Area has met the 

1997 NAAQS for 8-hour ozone. (EPA reached the same conclusion after examining data for the 

2007-2009 monitoring period; see next section). This fact, accompanied by documented decreases 

in ozone-precursor pollutant emissions from in-state and upwind sources, is the basis for requesting 

redesignation of the nonattainment area to attainment for the 1997 8-hour ozone standard, in 

accordance with Section 107(d)(3)(E) of the Clean Air Act. 

Air quality data summaries describing improvements in local ambient ozone concentrations are 

included in the next section, 2. ATTAINMENT OF THE STANDARD. Emission reductions contributing 

to the improved ozone levels are described in 4. PERMANENT AND ENFORCEABLE EMISSION 

REDUCTIONS. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 5

2. ATTAINMENT OF THE STANDARD 

The determination of New Hampshire’s 1997 8-hour ozone attainment status is based on extensive 

analysis of real-time ozone and photochemical data collected from monitoring stations installed and 

maintained by NHDES at strategic locations across the state. Using quality-assured, certified data 

for the monitoring period 2007-2009, EPA determined that air quality in the Southeast New 

Hampshire Nonattainment Area (moderate) had attained the 1997 8-hour ozone NAAQS (76 FR 

14805, March 18, 2011). This determination is consistent with EPA’s Clean Data Rule (40 CFR 

51.918); see 3.5 Clean Data Rule for 8-Hour Ozone Attainment. [In a separate but related action, 

EPA issued a proposed rule determining that the Boston-Lawrence-Worcester MA-NH serious onehour ozone nonattainment area met the November 15, 2007, deadline for attaining the one-hour 

NAAQS for ozone, based on quality-assured, certified data for the 2005-2007 monitoring period (76 

FR 77739, December 14, 2011).] 

2.1 Ozone Monitoring Network 

New Hampshire’s current ozone monitoring network has a total of 14 sites, located as shown in 

Figure 2-1. Eleven of these ozone monitors are operated by NHDES and three are operated by partner 

agencies. Included in the ozone monitoring network are three ozone-related monitors that measure for 

oxides of nitrogen (NOx) and two sites that measure for Photochemical Assessment Monitoring 

Stations (PAMS) pollutants. 

Figure 2-1. Ozone-Related Air Quality Monitors in New Hampshire 

Keene

Nashua

Concord

Odiorne

State Park

Portsmouth

Laconia

Camp Dodge

Lebanon

Isles Of Shoals

Durham

Mt. Washington

(Summit)

Miller 

State Park

(NCore)

State of 

New Hampshire

Ozone Related Monitor Network

2011

Ozone

PAMs

NOx/NOy

Ozone Monitors Operated by the University of New Hampshire

DES Monitor Key

Ozone Monitors Operated by the Hubbard Brook Research Foundation

Hubbard Brook

Londonderry

(NCore)
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 6

All 11 NHDES stations operate throughout the ozone season from April 1 through September 30. 

Four of the ozone monitors – those at Londonderry, Nashua, Portsmouth, and Rye (Odiorne) – are 

located within the Southeast New Hampshire Nonattainment Area. Although the Portsmouth and 

Rye monitors are only a few miles apart, they represent different airsheds: continental population 

(Portsmouth), and coastal-oceanic (Rye). Also situated within the nonattainment area are two NOx

monitors (Nashua and Londonderry) and one PAMS installation (Nashua). 

2.2 Summary of Ozone Monitoring Data

Real-time ozone data collected from the monitoring network are used in a variety of analyses to 

determine whether monitored areas are meeting the 1997 NAAQS for 8-hour ozone. The following 

definitions are instrumental to assessing attainment status: 

• Annual fourth-highest value: the fourth-highest 8-hour ozone concentration for a given 

ozone season at a monitored location. 

• Design value: the 3-year average of the annual fourth-highest 8-hour ozone concentration at 

a monitored location. 

• Threshold value: the fourth-highest monitored 8-hour ozone concentration for a given ozone 

season that would cause that year’s design value at a monitored location to exceed the 8-hour 

ozone NAAQS. 

A description of 8-hour ozone data handling conventions is provided in Attachment B; also included 

is a table of the annual fourth-highest values, annual design values, and 2012 threshold values for 

each of the Manchester, Nashua, Portsmouth, and Rye monitor sites. Ozone concentrations at these 

locations represent ozone levels for the entire Southeast New Hampshire Nonattainment Area. 

2.2.1 Annual Fourth-Highest Ozone Values 

Figure 2-2 displays annual fourth-highest 8-hour ozone values in parts per billion (ppb) since 1990 

for monitoring locations in the nonattainment region. (In addition to ozone values for the four 

named locations, the chart includes values for monitor sites in Brentwood and Rochester that 

operated for shorter periods). Figure 2-3 shows corresponding values for ozone monitors in the 

remainder of the state. While meteorological conditions contribute to yearly variations, it is clear 

that ambient ozone concentrations in both attainment and nonattainment areas are trending 

downward. It is important to note that all ozone data through September 30, 2011, have passed all 

quality assurance requirements and have been entered into EPA’s Air Quality System (AQS) 

database.

2.2.2 Ozone Design Values 

Trends in the 8-hour ozone design values for monitoring locations in the Southeast New Hampshire 

Nonattainment Area are illustrated in Figure 2-4. As the graph shows, design values have been 

declining since 1990, and all stations have demonstrated attainment since 2003; i.e., design values 

for the four Southeast New Hampshire Nonattainment Area monitors have remained below the level 

of the 8-hour NAAQS during each of the periods 2002-2004, 2003-2005, 2004-2006, 2005-2007, 

2006-2008, 2007-2009, 2008-2010, and 2009-2011. (There are some gaps in the data plots due to 

relocation of monitor sites.) To be valid, design values require three years of quality-assured data 

collected at the same location. Based on quality-assured data through the 2011 ozone season, 8-hour 

ozone design values for the period 2009-2011 were no greater than 70 ppb at all locations, with most 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 7

sites in the southern part of the state displaying values in the low- to mid-60’s ppb range. See 

Attachment B for a technical discussion of data handling conventions and design value calculations. 

Figure 2-2. 8-Hour Ozone Trends in the Southeast New Hampshire Nonattainment Area, 

1990-2011 

Ozone Trends in New Hampshire's Nonattainment Area

(Annual 8-Hour Ozone 4th High Values)

40

50

60

70

80

90

100

110

120

1990199119921993199419951996199719981999200020012002200320042005200620072008200920102011

Year

Concentration (PPB)

Brentwood

Manchester

Nashua

Rochester

Rye

Portsmouth

1997 NAAQS

Figure 2-3. 8-Hour Ozone Trends in New Hampshire Attainment Areas, 1990-2011 

Ozone Trends in Attainment Areas of New Hampshire

(Annual 8-Hour Ozone 4th High Values)

40

50

60

70

80

90

100

110

120

1990199119921993199419951996199719981999200020012002200320042005200620072008200920102011

Year

Concentration (PPB)

Camp Dodge

Claremont

Concord

Conway

Haverhill

Keene

Laconia

Lebanon

Pittsburg

1997 NAAQS
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 8

Figure 2-4. 8-Hour Ozone Design Value Trends in the Southeast New Hampshire 

Nonattainment Area, 1990-2011 

Ozone Trends in New Hampshire's Nonattainment Area

(Annual 8-Hour Ozone Design Values)

40

50

60

70

80

90

100

110

120

1990199119921993199419951996199719981999200020012002200320042005200620072008200920102011

Year

Concentration (PPB)

Brentwood

Manchester

Nashua

Rochester

Rye

Portsmouth

1997 NAAQS

2.2.3 Threshold Analysis 

The threshold analysis presented in Table 2-1, based on supporting data in Table B-1 of Attachment 

B, further demonstrates that the Southeast New Hampshire Nonattainment Area is likely to remain 

in attainment once redesignated. While two of the four monitor sites represented in the table have 

had at least one value over the threshold, this value would not influence the design value unless it 

accounted for the season’s fourth-highest concentration. In fact, not one of these sites has had a 

fourth-highest value above its 2012 threshold at any time in its monitoring history. Therefore, it is

highly probable that the Southeast New Hampshire Nonattainment Area will continue to achieve 

attainment. This prospect is supported by the previous introduction of large-scale emission control 

measures that have reduced NOx emissions across the region – particularly the NOx SIP call and the 

phase-in of mobile source controls. 

Table 2-1. 8-Hour Ozone Monitoring Data: 2012 Threshold Values and 2010-2011 Design 

Values Based on Fourth-Highest Annual Maxima (ppb) 

4

th Highest Value Design Value* Most Recent Year at 

Monitor or above Threshold 

Location 

AQS 

Number 2008 2009 2010 2011 2010 2011 

2012 

Threshold 

Value** 1

st Highest 4th Highest 

Manchester 330110020 64 60 63 *** 62 *** *** None None 

Nashua 330111011 67 66 67 65 66 66 123 None None 

Portsmouth 330150014 69 70 66 64 68 66 125 1988 None 

Rye 330150016 75 68 66 66 69 66 123 1991 None 

* Example: The 2010 design value is the 3-year average of the annual fourth-highest 8-hour ozone concentration for the period 2008-2010. 

** The 2012 threshold value is the fourth-highest monitored daily maximum 8-hour ozone value during the 2012 ozone season that would 

cause the 2012 design value to exceed the 8-hour ozone NAAQS. 

*** No data; monitor was moved to Londonderry in 2011.
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 9

2.2.4 Ozone-Related Parameters 

The PAMS stations are set up to monitor ozone, NOx, speciated volatile organic compounds (VOC, 

mainly hydrocarbons and carbonyl compounds), and meteorological parameters. New Hampshire’s 

current PAMS monitors are located in Nashua (Gilson Road) and on the summit of Pack Monadnock 

Mountain (Miller State Park), in Peterborough. For its investigation of ozone trends in the Southeast

New Hampshire Nonattainment Area and surrounding region, NHDES analyzed data from the two 

PAMS sites in New Hampshire and nine PAMS sites in Maine and Massachusetts. The analyses 

confirm that the many efforts to control NOx and VOC emissions in recent years have resulted in 

lower ambient concentrations of NOx and TNMOC during the ozone season. Background 

information, descriptions of the analyses performed, and graphs of the chemical data are presented 

in Attachment C. The meteorological portion of the analyses is included in Attachment D. 

2.2.4.1 Oxides of Nitrogen (NOx) 

Figures 2.5 through 2.7 depict average NOx concentrations in New Hampshire, Maine, and 

Massachusetts during the PAMS reporting season of June 1 to September 30 for the period 1998-

2010. Because of monitor site changes in New Hampshire, there are only a few years of data for 

each PAMS location in the state. Nevertheless, average NOx concentrations at each of the New 

Hampshire sites either decreased or held nearly constant over the respective measurement period. 

The more complete data sets from PAMS sites in Maine and Massachusetts demonstrate a clear 

decline in NOx concentrations over the last decade, indicative of a regional downward trend in the 

Northeast. 

Figure 2-5. NOx Trends in New Hampshire, 1998-2010

Figure 2-6. NOx Trends in Maine, 1998-2010 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 10

Figure 2-7. NOx Trends in Massachusetts, 1998-2010

The observed decline in NOx concentrations in the three-state area is reflective of the general trend 

across the Ozone Transport Region (OTR)2. Since 1998, ozone-season average NOx levels in the 

OTR have fallen steadily by more than 40 percent (Figure 2-8). 

Figure 2-8. Ozone-Season Average NOx Concentrations 

in the Ozone Transport Region, 1998-2010 

0

5

10

15

20

25

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Year

Concentration (PPB)

2.2.4.2 Volatile Organic Compounds (VOC) 

Figure 2-9 exhibits seasonal averages of total nonmethane organic carbon (TNMOC) and total 

PAMS-measured hydrocarbons (PAMHC) for the combined data sets of New Hampshire, Maine, 

and Massachusetts. Both categories of VOCs have decreased in concentration significantly since 

1998. In particular, despite year-to-year variations, average concentrations since 2003 have been 

consistently lower than those in the five preceding years: the average PAMHC concentration was 18 

ppbC in 2003-2009 versus 28 ppbC in 1998-2002. 

 

2

 The OTR consists of eleven states in the northeastern U.S. plus the District of Columbia. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 11

Figure 2-9. TNMOC and PAMHC Trends in New Hampshire, 

Maine, and Massachusetts, 1998-2010

0

5

10

15

20

25

30

35

40

45

50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Concentration (PPBC)

TNMOC

PAMHC

The most recent VOC data from New Hampshire’s PAMS sites (Nashua and Pack Monadnock) are 

graphed in Figures 2-10 and 2-11. For the period from 2006 to 2010, TNMOC and PAMHC 

seasonal average concentrations at both sites were relatively stable. The seasonal averages at Pack 

Monadnock reached their lowest values in 2010. 

Figure 2-10. Average TNMOC and PAMHC in Nashua, New Hampshire, 2006-2010 

TNMOC and PAMHC Seasonal Averages

Gilson Road, Nashua

0

5

10

15

20

25

30

35

2006 2007 2008 2009 2010

Concentration (PPBC)

TNMOC

PAMHC

 

Figure 2-11. Average TNMOC and PAMHC on Pack Monadnock in 

Peterborough, New Hampshire, 2006-2010 

TNMOC and PAMHC Seasonal Averages

Pack Monadnock Summit, Peterborough

0

10

20

30

40

50

60

2006 2007 2008 2009 2010

Concentration (PPBC)

TNMOC

PAMHC

Note: 2010 data were not 

yet available for all states 

as of this publication. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 12

For Nashua, the 2009 seasonal averages were higher than in 2006-2008; but this phenomenon was 

due to contamination by local emissions. Extensive paving near the Nashua monitoring site began 

on July 16, 2009, and continued during the rest of the summer. This activity caused elevated values 

of certain unknown hydrocarbons as well as those on the target list, including 1,2,3-

Trimethlybenzene and 1,2,4-Trimethylbenzene, through the end of the PAMS season in September. 

This local influence resulted in higher averages of PAMHC and TNMOC for the entire 2009 season. 

PAMHC and TNMOC dropped to more historically consistent levels in 2010. In fact, the 2010 

seasonal averages are lower than those of any preceding year. 

Conclusion: Given the relatively stable or declining pattern in recorded ozone and ozone-precursor 

levels at New Hampshire monitors over the last 5 to 6 years, and observed longer-term regional 

decreases in both NOx and VOC emissions (see 4. PERMANENT AND ENFORCEABLE EMISSION 

REDUCTIONS), it is expected that ozone concentrations in New Hampshire will remain at 

attainment levels in the future. 

2.3 Summary of Meteorological Analyses

Meteorology is a major factor in the formation and transport of ozone and its precursors. High 

ozone concentrations in southern New Hampshire occur most often when low-pressure systems 

approach from the Great Lakes or southern Canada while high pressure is situated just off the 

eastern seaboard. When such a scenario is in place, it provides warm temperatures, clear skies, and 

southwesterly winds to allow the transport of ozone and its precursors into the Northeast. 

Upwind states have successfully begun to address the problem of regional transport and made it 

possible for New Hampshire to reach attainment of the 8-hour ozone standard. This fact is reflected 

by the recent decline in the number of days, year to year, in which New Hampshire’s ozone levels 

have exceeded the NAAQS (see Figure 2-12). 

Figure 2-12. Number of Days with Exceedances of the 1997 8-Hour Ozone Standard 

in New Hampshire, 1985-2011 

8

9

13

27

11

9

13

8 8 9 9

6

10

7

10

1

11

13

1

5

4

2

8

2

0 0 1

0

5

10

15

20

25

30

198519861987198819891990199119921993199419951996199719981999200020012002200320042005200620072008200920102011

Year

Number of Days

As required by EPA guidance for the redesignation process, New Hampshire must show evidence that 

unusual weather conditions would not have been the essential cause of the area’s newly acquired 

attainment status. NHDES has prepared two types of graphical analyses for this purpose – temperature 

vs. ozone and wind direction frequency – presented in detail as Attachment D and summarized below: 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 13

2.3.1 Temperature vs. Ozone 

Because warm weather is a principal condition for ozone formation, hotter summers tend to 

experience greater frequency of ozone exceedances. Figure 2-13 contains a bar graph depicting the 

number of days each year between 1985 and 2011 in which the National Weather Service recorded a 

maximum daily temperature above 85 F in Concord, New Hampshire. These data are sorted in 

ascending order by temperature (rather than by chronological order). Summers have varied from the 

relatively cool summer of 1996, with 20 days having maxima above 85 F, to the very hot summer of 

2010, with 63 days having maxima above 85 F. 

Also included in Figure 2-13 is a blue line graph showing the number of days with 8-hour ozone 

values exceeding 85 ppb. The upward-sloping trend line of exceedance days against the plotted 

temperature profile illustrates the expected correlation of ozone exceedances and higher temperatures. 

The light blue ovals on the line graph identify data points for 2003-2011, a period in which the 

frequency of exceedances was markedly below the expected frequency based on temperature 

patterns. Note that the number of exceedances was well below the linear trend line in each year 

since 2003, despite some very warm summers in 2005, 2007, and 2010. In fact, 2010 had the 

highest number of days with a maximum temperature over 85 F, but no ozone exceedances. These 

findings indicate that the decline in ozone levels since 2003 is not solely or primarily due to a 

decrease in summer temperatures. 

Figure 2-13. Number of Days with Maximum Temperatures above 85 F and Number of Days 

with Ozone Exceedances in New Hampshire, 1985-2011 

0

10

20

30

40

50

60

70

199619862009200819922000200419972006198919851987199820031999199419881993199020072011200120021991200519952010

Number of Days

Max Temperature >85 F 

Ozone Exceedances

Linear (Ozone

Exceedances)

2006

2003

2007

2005

2004

2009

Notes:

Temperatures are National 

Weather Service data from 

Concord Airport.

Data are sorted by number 

of days with maximum 

temperature >85 F 

(therefore, years are not in 

chronological order).

2008

2010

2011

2.3.2 Wind Direction Frequency 

Because transport of ozone and its precursors from outside state borders plays a critical role in 

elevated ozone levels in New Hampshire, another significant factor to consider is wind direction. 

Surface winds from the southwest are conducive to transport along the Northeast Corridor from 

metropolitan areas upwind. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 14

Figure 2-14 presents composite wind roses for the months of April-September for the period from 

1995 to 2010. To provide the most consistent basis for comparison, data were taken from the longterm databases of the National Weather Service for airport sites in Concord and Portsmouth, New 

Hampshire. The data were separated into two periods, 1995-2002 and 2003-2010, to distinguish 

between the wind direction patterns of the earlier period and those of the more recent period 

characterized by fewer exceedances. The wind roses are based on hourly wind observations for the 

entire summer season, without regard to ozone concentration. 

The Concord and Portsmouth wind roses display very different, site-specific wind patterns; but for 

each location, the wind direction frequencies were consistent over time. While the number of 

exceedances was declining, the wind direction patterns for 2003-2010 were remarkably similar to 

the wind direction patterns for 1995-2002. Therefore, the observed decline in the number of ozone 

exceedances since 2003 is not merely a consequence of shifts in wind direction. 

 Figure 2-14. New Hampshire Wind Direction Frequencies in the Months of 

April through September, 1995-2010 

Wind Direction Frequencies at Concord Airport

National Weather Service Data

1995-2010

1995-2002 

2003-2010

N

W E

S 

Wind Direction Frequencies at Pease Airport, Portsmouth

National Weather Service Data

1995-2010

1995-2002 

2003-2010

N

W E

S

Conclusion: As the graphical analyses show, the reduced number of ozone exceedances in recent 

years has occurred despite normal variations in temperature and consistent wind direction patterns. 

Thus, monitored attainment of the Southeast New Hampshire Nonattainment Area is not primarily 

due to unusual meteorological conditions. Should meteorological conditions during future summers 

favor transport of pollutants into New Hampshire, ozone levels in the Southeast New Hampshire 

Nonattainment Area are not expected to exceed the NAAQS because large-scale NOx emission 

reductions that began with the NOx SIP Call in 2003 will continue to mitigate upwind contributions. 

Furthermore, the upwind source regions impacting New Hampshire (i.e., southern New England and 

the New York metropolitan area) have higher and more frequent ozone exceedances than New 

Hampshire and are taking additional steps to control emissions contributing to this situation. These 

steps will further reduce the amounts of ozone and its precursors available for transport to New 

Hampshire. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 15

3. STATE IMPLEMENTATION PLAN FOR NONATTAINMENT AREA 

New Hampshire’s original state implementation plan (SIP) was submitted to EPA on January 27, 

1972, and approved on May 31, 1972 (37 FR 10842). It has undergone many revisions since then to 

meet new federal requirements as they occurred. New Hampshire’s approved SIP is published in 

the Code of Federal Regulations at 40 CFR 52 Subpart EE. 

3.1 Recent SIP Revisions 

 

Recent revisions to New Hampshire’s state implementation plan, all of which are effective for the 

Southeast New Hampshire Nonattainment Area, include the following: 

• RACT Certification. Pursuant to 40 CFR 51.912 and Clean Air Act Sections 172(c)(1), 

182(b)(2), and 184(b)(1), this plan revision was submitted to certify reasonably available 

control technology (RACT) requirements. The submission certified that New Hampshire’s 

RACT regulations for the former 1-hour ozone National Ambient Air Quality Standard 

(NAAQS), combined with all RACT orders issued by NHDES, satisfied RACT requirements 

under the 1997 revised 8-hour ozone NAAQS of 0.08 ppm. NHDES submitted the RACT SIP 

revision to EPA on January 28, 2008. 

• Interstate Transport Provisions. In 2005, EPA entered into a consent decree with Earth 

Justice that obligated EPA to determine whether states had made SIP submissions to meet the 

requirements of the Clean Air Act, Sections 110(a)(l) and (2). On April 25, 2005, EPA published 

a finding that all states had failed to submit SIP revisions addressing interstate transport for 

the 1997 8-hour ozone and PM2.5 NAAQS (70 FR 21147). Accordingly, on March 11, 2008, 

NHDES submitted a SIP revision to EPA to fulfill the requirements of the Finding of Failure 

and section 110(a)(2)(D)(i) relating to interstate transport of those pollutants.

• 8-Hour Ozone Certification. The consent decree with Earth Justice also obligated EPA to 

determine whether states had made submissions meeting the remaining “infrastructure” 

requirements of CAA Sections 110(a)(l) and (2) for 8-hour ozone and fine particulate matter. 

To the extent that existing SIPs already satisfied these requirements, states needed only to 

certify that fact to EPA. NHDES submitted New Hampshire’s certification of adequacy for 

8-hour ozone on December 14, 2007. EPA approved this SIP revision in a final rule 

published on July 8, 2011 (76 FR 40248).

• PM2.5 Certifications. In similar fashion, NHDES submitted New Hampshire’s certification of 

adequacy for the 1997 24-hour and average annual PM2.5 standards on April 3, 2008. EPA 

published a completeness finding for this submission on October 22, 2008 (73 FR 62902). 

NHDES followed this, on September 18, 2009, with submittal of a certification of adequacy 

for the 2006 revised 24-hour PM2.5 standard.

• Regional Haze Plan. In 1999, the Environmental Protection Agency (EPA) issued 

regulations to improve visibility in 156 national parks and wilderness areas (Federal Class I 

areas) across the United States. The Regional Haze Rule applies to any state having a federal 

Class I area as well as any state that contributes to visibility impairment at any (downwind) 

Class I area. Each state’s plan for regional haze takes the form of a SIP revision and must 

include reasonable progress goals for visibility improvement and a long-term strategy with 

enforceable emission reductions to meet those goals. On January 29, 2010, NHDES 

submitted New Hampshire’s regional haze plan to EPA and provided copies to the Federal 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 16

Land Managers. Following receipt of agency comments, NHDES made adjustments to the 

plan, adopted Env-A 2300 Mitigation of Regional Haze, and resubmitted the package as a 

final SIP revision on January 14, 2011. In response to additional EPA comments, NHDES 

submitted further amendments on August 26, 2011. On February 15, 2012, the Regional 

Administrator signed a proposed rule, approving the Regional Haze SIP revision. 

3.2 Reasonably Available Control Technology Requirements 

For areas of New Hampshire previously designated as 1-hour serious ozone nonattainment areas, 

Section 182(b) and (c) of the Clean Air Act required the state to adopt RACT rules for VOC sources 

covered by Control Technique Guidelines (CTGs) issued before and after enactment of the 1990 

Clean Air Act Amendments. These sections also required the state to implement RACT requirements 

for all other major sources of VOCs in the classified nonattainment areas. Note, however, that 

because New Hampshire is part of the Ozone Transport Region, Section 184(b) requires 

implementation of VOC RACT for all areas of the state regardless of attainment classification. New 

Hampshire met these requirements through the adoption of various VOC regulations and individual 

VOC RACT determinations for all major VOC sources not covered by the CTGs. New 

Hampshire’s VOC RACT rule, codified at Env-A 1204 Stationary Sources of Volatile Organic 

Compounds (VOCs), applies to facilities in designated source categories that have the potential to 

emit as little as 10 tons/year of VOCs, depending on the category. This rule expired in 2010 and 

was readopted with amendments, effective June 1, 2011. The rule, renumbered as Chapter Env-A 

1200, was amended to address the CTGs issued by EPA in 2006, 2007, and 2008 for Group II, III, and 

IV source categories, respectively; and the applicability threshold for sources in those categories was 

set at 3 tons/year of actual VOC emissions, prior to controls. The readopted rule was submitted to 

EPA as a SIP revision on July 26, 2011. 

Section 182(f) required states to make similar provisions for major stationary sources of NOx. 

Accordingly, New Hampshire established NOx RACT regulations covering major NOx sources in 

all areas of the state and issued NOx RACT determinations for several such sources. New 

Hampshire’s NOx RACT rule, codified at Env-A 1211 Nitrogen Oxides (NOx), applies to facilities 

that have the potential to emit 50 tons/year of nitrogen oxides or that meet specific size thresholds 

based on heat input capacity or other measure. This rule expired in 2010 and was amended, 

renamed, renumbered, and readopted as Env-A 1300 Nitrogen Oxides (NOx) Reasonably Available 

Control Technology (RACT), effective October 31, 2010. The readopted rule was submitted to EPA 

as a SIP revision on March 31, 2011. 

3.3 1-Hour Ozone Attainment Demonstration 

Section 182(c) of the Clean Air Act required any state with a serious nonattainment area for ozone 

to submit by November 15, 1994, a SIP revision demonstrating how the state would attain the 1-

hour ozone standard. Notwithstanding significant efforts by the states, in 1995 EPA recognized that 

many states in the eastern half of the United States could not meet this deadline because of ozone 

transport related to NOx and VOC emissions in upwind states. EPA subsequently allowed the states 

more time for study and planning. On June 30, 1998, NHDES submitted an attainment 

demonstration (SIP revision), for New Hampshire’s 1-hour ozone nonattainment area. In a final 

rule published on December 6, 2002 (67 FR 72574), EPA approved New Hampshire’s attainment 

demonstration and its attainment-level motor vehicle emissions budget for the New Hampshire 

portion of the Boston-Lawrence-Worcester, MA-NH serious ozone nonattainment area. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 17

3.4 Reasonable Further Progress Requirements 

Section 182(c) also required any state with a serious nonattainment area for ozone to prepare a plan 

for reasonable further progress (RFP) to reduce VOC emissions by at least 15 percent from 1990 

base year levels by November 15, 1996, and to achieve an additional 9 percent reduction in VOC 

emissions by November 15, 1999. NHDES submitted New Hampshire’s 15% RFP plan to EPA on 

February 2, 1994 (subsequently revised May 10, 1994; October 11, 1994; and August 29, 1996), 

followed by New Hampshire’s 9% RFP plan on September 27, 1996. These plans were specific to 

the Portsmouth-Dover-Rochester 1-hour ozone nonattainment area and the New Hampshire portion 

of the Boston-Lawrence-Worcester 1-hour ozone nonattainment area. EPA published final rules 

approving SIP revisions for the 15% RFP plan on December 7, 1998 (63 FR 67405), and April 16, 

2002 (67 FR 18493). 

With respect to the 8-hour ozone standard, EPA’s clean data determination (see next paragraph) 

suspended the requirements for a reasonable further progress plan and other SIP elements for the 

southern New Hampshire area. 

3.5 Clean Data Rule for 8-Hour Ozone Attainment 

From an analysis of monitoring data for the period 2007-2009, EPA determined that the Southeast 

New Hampshire Nonattainment Area (moderate) had reached attainment of the 8-hour ozone 

NAAQS. A final rule published on March 18, 2011 (76 FR 14805), effective on April 18, 2011, 

suspended the requirements for this area to submit an attainment demonstration, an RFP plan, 

contingency measures, and other State Implementation Plan elements related to attainment of the 8-

hour ozone NAAQS. This determination is consistent with EPA’s Clean Data Rule (40 CFR 

51.918), which exempts the state from certain SIP requirements if the area has three consecutive 

years of air quality data showing it meets the NAAQS, for as long as the area continues to attain the 

standard. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 18

4. PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS 

Recent air quality improvements in the Southeast New Hampshire Nonattainment Area, evidenced 

by the decline in 8-hour ozone design values, are the result of fewer emissions of NOx and VOC 

from a broad spectrum of sources: stationary point, area, and mobile. Most of the improvement 

over 2000-2002 baseline values is attributable to implementation of federally mandated emission 

control programs – in particular, the NOx SIP Call and the Federal Motor Vehicle Emission Control 

Program (FMVCP). Various New Hampshire programs have also reduced in-state emissions during 

the same period. 

More than 90 percent of all pollutants responsible for the formation and presence of high 

concentrations of ground-level ozone in New Hampshire’s nonattainment area originate from 

emission sources in upwind states.3 However, the transported pollutants from upwind states have 

shown steady declines since the early 1990s as a result of federal emission control programs and 

control measures adopted into the SIPs of upwind states. Air quality improvements associated with 

the remaining 10 percent of pollutants (i.e., in-state emissions) can be attributed to permanent and 

enforceable emission reduction measures adopted by New Hampshire. 

4.1 Emission Control Programs 

Regional and state strategies to control ozone have focused on reducing emissions of NOx and VOC 

as the major photochemical precursors of ground-level ozone formation. In urban areas, the 

relatively high density of local emission sources can lead to elevated concentrations of ozone. At 

the same time, ozone concentrations in both urban and rural areas are influenced by regional 

transport – the movement of ozone and its precursors by the wind. Controlling both NOx and VOC 

emissions can be effective for reducing local ozone levels in urban locations, while controlling NOx 

is typically more effective for reducing regional impacts, especially in New Hampshire, where 

biogenic sources dominate VOC emissions. As a consequence, ground-level ozone in New 

Hampshire may be addressed most successfully through a combination of regional programs 

focused on controlling NOx emissions and local programs controlling both ozone-precursor types. 

Some emission control programs for NOx and VOC were implemented and began to yield 

demonstrable emission reductions within the region prior to the 2000-2002 baseline period. That is, 

these programs were already reducing ozone-causing emissions before the official designation of 

New Hampshire’s 8-hour ozone nonattainment area, but continued thereafter to provide real and 

permanent decreases in emissions from the affected source categories, especially where source 

turnover/replacement is an important element of rule penetration (e.g., nonroad engines). On the 

other hand, some emission control measures implemented since 2000-2002 may not have had 

sufficient time yet to reach maximum rule penetration and full effectiveness. Thus, the downward 

trend in emissions attributable to control measures already in place is expected to continue. 

It should be emphasized that the decline in ozone concentrations from nonattainment to attainment 

levels in New Hampshire is due to implemented control measures rather than special circumstances 

such as the shutdown of a major emission source. In the future, New Hampshire intends to maintain 

existing emission control programs or replace them with equivalent or more stringent control 

measures as necessary to comply with all applicable laws and regulations. 

 

3

 New Hampshire Department of Environmental Services, “Air Pollution Transport and How It Affects New Hampshire,” 

May 2004. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 19

Tables 4-1 and 4-2 list federal and state enforceable emission control requirements that have 

contributed to the documented improvements in 8-hour ozone levels in the nonattainment area. 

Table 4-3 lists all NOx and VOC RACT orders for individual sources issued by NHDES since 2001. 

Table 4-1. Federal Emission Control Measures for NOx and VOC 

in the Southeast New Hampshire Nonattainment Area 

Federal Control Measure Citation NH SIP Revision

National VOC Emission Standards for Consumer and Commercial Products 40 CFR 59 -- 

Standards of Performance for New Stationary Sources 40 CFR 60 -- 

Acid Rain Nitrogen Oxides Emission Reduction Program 40 CFR 76 -- 

Control of Air Pollution from Mobile Sources 40 CFR 85 -- 

Control of Emissions from New and in-Use Highway Vehicles and Engines 40 CFR 86 -- 

Control of Air Pollution from Aircraft and Aircraft Engines 40 CFR 87 -- 

Control of Emissions from New and in-Use Nonroad Compression-Ignition Engines 40 CFR 89 -- 

Control of Emissions from Nonroad Spark-Ignition Engines 40 CFR 90 -- 

Control of Emissions from Marine Spark-Ignition Engines 40 CFR 91 -- 

Control of Air Pollution from Locomotives and Locomotive Engines 40 CFR 92 -- 

Control of Air Pollution from Marine Compression-Ignition Engines 40 CFR 94 -- 

NOx Budget Trading Program for State Implementation Plans 40 CFR 96 -- 

Reasonable Further Progress CAA Section 182(b)(1) and 

CAA Section 182(c)(2)(B) 

63 FR 67405 and 

67 FR 18493 

VOC Reasonably Available Control Technology (RACT) CAA Section 182(b)(2) and 

CAA Section 182(c) 

63 FR 11600 and 

67 FR 48036 

NOx Reasonably Available Control Technology (RACT) CAA Section 182(f) 62 FR 17092 

Gasoline Vapor Recovery: Stage II Vapor Recovery CAA Section 182(b)(3) and 

CAA Section 182(c) 63 FR 67405 

Motor Vehicle Inspection and Maintenance CAA Section 182(b)(4) and 

CAA Section 182(c) 67 FR 65710 

Enhanced Vehicle Inspection and Maintenance (Alternative Program) CAA Section 182(c)(3) 66 FR 1868 

Attainment Demonstration: 1-Hour Ozone CAA Section 182(c)(2)(A) 67 FR 72574 

Onboard Vapor Recovery (ORVR) CAA Section 202(a)(6) -- 

Emissions Control Diagnostics: Onboard Diagnostic (OBD) Systems CAA Section 202(m) -- 

Reid Vapor Pressure Requirements CAA Section 211(h) -- 

Reformulated Gasoline for Conventional Vehicles CAA Section 211(k) -- 

Conformity CAA Section 176(c) 64 FR 44417 

Motor Vehicle Emissions Budget (MVEB) CAA Section 182(c)(5) 74 FR 8863 

Note: The above list is not necessarily inclusive of all federal measures to control NOx and VOC that contributed to air quality 

improvements in the Southeast New Hampshire Nonattainment Area prior to the 2007-2009 attainment period. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 20

Table 4-2. State Emission Control Regulations for NOx and VOC 

in the Southeast New Hampshire Nonattainment Area 

(SIP-approved rules in black, other State rules in blue)

NH Administrative Rule Effective 

Date(s) 

Submitted for 

EPA Approval

EPA 

Approval Description 

Env-A 622 Additional Requirements in NonAttainment Areas and the New Hampshire Portion of 

the Northeast Ozone Transport Region 

01-30-1999 07-02-99 07-27-2001 

66 FR 39100 

Env-A 618 (formerly 622) Additional Requirements 

in Non-Attainment Areas and the New Hampshire 

Portion of the Northeast Ozone Transport Region

10-28-2002 Not Submitted 

Provisions applicable to 

new major stationary 

sources and major 

modifications to existing 

sources. 

 Env-A 623 Prevention of Significant Deterioration 

(PSD) of Air Quality Permit Requirements 

07-27-2001 08-06-2001 10-28-2002 

67 FR 65710 

Env-619 (formerly 623) Prevention of Significant 

Deterioration (PSD) of Air Quality Permit 

Requirements

04-26-2003 Not Submitted 

Preconstruction review 

procedures for new major 

stationary sources and 

major modifications to 

existing sources in areas 

where existing air quality 

meets the NAAQS. 

Env-A 1204 Stationary Sources of Volatile Organic 

Compounds (VOCs)

Env-A 1204.09 (Metal Cans) 

Env-A 1204.10 (Paper, Fabrics, Film and Foil 

Substrates) 

Env-A 1204.12 (Metal Furniture Coating) 

Env-A 1204.13 (Magnetic Wire Insulation Coating)

Env-A 1204.14 (Coating of Metal Coils) 

Env-A 1204.15 (Miscellaneous Metal Parts and 

Products) 

Env-A 1204.17 (Coating of Wood Furniture, Burial 

Caskets, and Gunstock) 

Env-A 1204.18 (Rotogravure and Flexographic 

Printing) 

Env-A 1204.19 (Offset Lithographic Printing) 

Env-A 1204.20 (Fixed Roof Tank VOL Storage) 

Env-A 1204.21 (External Floating Roof Tanks) 

Env-A 1204.22 (Bulk Gasoline Loading Terminals) 

Env-A 1204.23 (Bulk Gasoline Plant) 

Env-A 1204.25 (Cutback and Emulsified Asphalt) 

Env-A 1204.26 (Solvent Metal Cleaning) 

08-31-1995 06-28-96 

10-24-96 

03-10-98 

63 FR 11600 

Env-A 1204.27 (Misc. and Multicategory Station 

VOC Sources) 

08-31-1995 06-28-96 

10-24-96 

07-23-2002 

67 FR 48033 

Env-A 1204 Stationary Sources of Volatile Organic 

Compounds (VOCs)

Env-A 1204.09 (Metal Cans) 

Env-A 1204.10 (Paper, Fabrics, Film and Foil 

Substrates) 

Env-A 1204.12 (Metal Furniture Coating) 

Env-A 1204.13 (Magnetic Wire Insulation Coating)

Env-A 1204.14 (Coating of Metal Coils) 

12-31-2002 03-17-2003 Approval not yet 

acquired 

Provisions for 

implementation of 

reasonably available 

control technology 

(RACT) on certain 

VOC-emitting sources. 

(Note: Env-A 1204 was 

readopted as Env-A 1200, 

effective 06-01-2011, and 

submitted for SIP 

approval on 07-26-

2011.) 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 21

NH Administrative Rule Effective 

Date(s) 

Submitted for 

EPA Approval

EPA 

Approval Description 

Env-A 1204.15 (Miscellaneous Metal Parts and 

Products) 

Env-A 1204.17 (Coating Plastic Components of 

Automotive Interiors) 

Env-A 1204.18 (Coating Plastic Components of 

Automotive Exteriors 

Env-A 1204.19 (Specialty Coatings on Automotive 

Components) 

Env-A 1204.25 (Coating of Wood Furniture, Burial 

Caskets and Gunstock) 

Env-A 1204.36 (Rotogravure and Flexographic 

Printing) 

Env-A 1204.37 (Offset Lithographic Printing) 

Env-A 1204.38 (Fixed Roof Tank VOL Storage) 

Env-A 1204.39 (External Floating Roof Tanks) 

Env-A 1204.40 (Bulk Gasoline Loading Terminals 

Env-A 1204.41 (Bulk Gasoline Plants) 

Env-A 1204.42 (Cutback and Emulsified Asphalt 

Env-A 1204.43 – 1204.47 (Solvent Metal Cleaning)

Env-A 1204.48 (Misc. And Muilticategory 

Stationary VOC Sources) 

 

Env-A 1204 Stationary Sources of Volatile 

Organic Compounds (VOCs)

Env-A 1204.02 Scope

Env-A 1204.03 Definitions

Env-A 1204.43 (Solvent Metal Cleaning) 

Env-A 1204.44 (Cold Cleaning) 

02-26-2005 07-09-07 Approval not yet 

acquired 

Env-A 1205 VOC: Gasoline Dispensing Facilities 

and Gasoline Tank Trucks

08-17-1992 12-07-98 

63 FR 67405 

Env-Wm 1404 (formerly Env-A 1205) Gasoline 

Dispensing Facilities, Bulk Gasoline Plants, and 

Cargo Trucks

02-25-2004 

08-21-2004 

Not Submitted 

Requirements for 

underground storage tank 

facilites to prevent and 

minimize the 

contamination of the land 

and water of the state. 

Env-A 1211 Nitrogen Oxides (NOx)

Env-A 1211.03 (Utility Boilers) 

Env-A 1211.05 (Industrial Boilers) 

Env-A 1211.06 (Combustion Turbines) 

Env-A 1211.07 (Stationary Internal Combustion 

Engines) 

Env-A 1211.08 (Asphalt Plant Dryers) 

Env-A 1211.09 (Incinerators) 

Env-A 1211.10 (Wallboard Manufacturing) 

Env-A 1211.11 (Emergency Generators) 

Env-A 1211.12 (Auxilliary Boilers) 

Env-A 1211.13 (Load Shaving Units) 

Env-A 1211.14 (Miscellaneous Stationary Sources) 

08-31-1995 04-09-1997 

62 FR 17087 

Provisions for 

implementation of 

reasonably available 

control technology 

(RACT) on certain NOxemitting sources. 

(Note: Env-A 1211 was 

readopted as Env-A 1300, 

effective 10-31-2010, and 

submitted for SIP 

approval on 03-31-2011.)
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 22

NH Administrative Rule Effective 

Date(s) 

Submitted for 

EPA Approval

EPA 

Approval Description 

Env-A 1211 Nitrogen Oxides (NOx) 10-31-2002 

12-22-2004 

03-17-2003 

07-09-07 

Env-1211.03 (Utility Boilers) 

Env-A 1211.05 (Industrial Boilers) 

Env-A 1211.06 (Combustion Turbines) 

Env-A 1211.07 (Stationary Internal Combustion 

Engines) 

 

Env-A 1211.08 (Asphalt Plant Dryers) 

Env-A 1211.09 (Incinerators) 

Env-A 1211.10 (Wallboard Manufacturing) 

Env-A 1211.11 (Emergency Generators) 

Env-A 1211.12 (Auxilliary Boilers) 12-22-2004 07-09-07 

Env-A 1211.13 (Load Shaving Units) 

Env-A 1211.14 (Miscellaneous Stationary Sources) 

 

Approval not yet 

acquired 

Env-A 1500 Conformity 04-19-1996 08-16-1999 

 Env-A 1502 Conformity of General Federal Actions 04-25-1996 07-10-1996 08-16-1999 

64 FR 44417 

Env-A 1500 Conformity 

Env-A 1501 Transformation Conformity 10-27-1995 

8-27-1998 

10-14-2003 

06-22-2005 

12-1-1998 Approval not yet 

acquired 

Env-A 1502 Conformity of General Federal 

Actions 

10-14-2003 

06-22-2005 

 

Provisions related to the 

conformity of federal 

actions to New 

Hampshire’s SIP. 

Env-A 3200 NOx Budget Trading Program 07-27-1998 11-14-2000 

65 FR 68078 

Env-A 3200 NOx Budget Trading Program 08-25-1999 

02-01-2000 

05-24-2003 

02-28-2004 

08-25-2007 

11-02-2007 

02-21-2008 

Not Submitted 

Provisions to implement 

New Hampshire’s NOx 

Budget Program to help 

achieve attainment of the 

ozone NAAQS. 

Saf-C 3200 Official Motor Vehicle Inspection 

Requirements

Saf-C 3221A Emissions Requirements

11-17-1998 01-10-2001 

66 FR 1868

Saf-C 3200 Official Motor Vehicle Inspection 

Requirements

 

Saf-C 3220 Emissions Requirements 06-22-2007 

Saf-C 3222 On-board Diagnostic System 07-26-2002 

06-20-2008 

 

Provisions related to 

control of motor vehicles 

emissions. 

Saf-C 5800 Roadside Diesel Opacity Inspection 11-17-1998 01-10-2001 

66 FR 1868 

Saf-C 5800 Roadside Diesel Opacity Inspection 01-01-1999 

Provisions implementing 

a roadside heavy-duty 

diesel emissions testing 

program. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 23

Table 4-3. NOx and VOC RACT Orders Issued in New Hampshire, 2001-Present 

Order No. Company Name Pollutant Effective Date 

96-001 Textile Tapes Corp. VOC 04-19-02, rev. 08-10-07 

99-001 Kalwall Corp. - Manchester VOC 11-20-01 

00-001 Anheuser Busch, Inc. VOC 04-15-02 

01-001 Waste Management of NH, Inc. - Turnkey NOx 08-26-02, rev. 08-11-11 

01-002 Hutchinson Sealing Systems, Inc. VOC 08-08-02 

02-001 Hitchiner Manufacturing Co., Inc. - Milford VOC 06-20-02 

02-003 Newington Energy, LLC NOx 09-09-02 

03-001* Parker Hannifin Corporation, Chomerics VOC 07-17-02 

03-001* Sturm, Ruger & Company, Inc. VOC 10-13-03, rev. 12-01-03 & 03-02-10

03-002 Gates Mectrol Inc.** VOC 06-16-03 

04-001 Newington Energy, LLC NOx 06-20-07

05-001* Anheuser Busch, Inc. NOx 05-09-05 

05-001* Metal Works, Inc. VOC 12-22-04 

06-001 PSNH Schiller Station - Unit #5 NOx 08-04-06

07-001 Webster Valve, Inc. VOC 04-20-07, rev. 04-20-07 

07-002 TFX Medical, Inc. VOC 08-07-07 

07-003 Concord Litho Group, Inc. VOC 09-17-07 

07-004 Polyonics, Inc. VOC 12-28-07 

* duplicate numbers issued ** facility shut down; letter to cancel RACT order sent to EPA on 07-02-09

4.2 Upwind Emission Reductions 

As mentioned above, a broad array of NOx and VOC emission controls in upwind states has largely 

made possible the attainment of the 1997 8-hour ozone standard in the Southeast New Hampshire 

Nonattainment Area. The observed improvement in air quality would not have occurred without the 

concerted efforts of EPA and the Ozone Transport Commission (OTC) to reduce the emitted 

amounts of both pollutants across the region. 

In September 1994, the OTC member states4 adopted a memorandum of understanding to achieve 

regional NOx emission reductions. Phase I began with the installation of RACT, followed in Phases 

II and III by the development and implementation of regulations to achieve further reductions in 

ozone-season NOx emissions by 1999 and 2003, respectively. The second and third phases were 

modeled on the cap-and-trade principle and resulted in the creation of the OTC NOx Budget 

Program.5 This program established a de facto NOx emission rate of 0.15 lbs/MMBtu for 

 

4

 The OTC includes the states of Maine, New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island, New 

York, New Jersey, Pennsylvania, Maryland, Delaware, and the District of Columbia. 

5

 The NOx Budget Program involves an allowance trading system which harnesses free market forces to reduce 

pollution, similar to the U.S. EPA's Acid Rain Program. Under this program, budget sources were allocated allowances 

by their state governments. Each allowance permits a source to emit one ton of NOx during the control period (May 

through September) for which it is allocated or any later control period. Allowances may be bought, sold, or banked. 

Any person may acquire allowances and participate in the trading system. Each budget source must comply with the 

program by demonstrating at the end of each control period that actual emissions do not exceed the amount of 

allowances held for that period. However, regardless of the number of allowances a source holds, it cannot emit at 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 24

participating electric generating units and large industrial boilers. Rules for New Hampshire’s 

participation in the OTC NOx Budget Program are codified at Chapter Env-A 3200. 

In the midst of these efforts, in 1998, EPA issued a final rule aimed at reducing the regional 

transport of NOx and ozone. This rule, commonly known as the NOx SIP Call, required 22 eastern 

states and the District of Columbia (not including New Hampshire) to reduce ozone-season NOx 

emissions. Compliance with the NOx SIP call began on May 1, 2003, for the participating OTC 

states6 and on May 31, 2004, for states outside the Ozone Transport Region. Although the NOx SIP 

Call provided states with the flexibility to design their own programs to meet the NOx reduction 

requirements, all affected states chose to participate in a regional cap-and-trade program.7

The NOx SIP Call and the NOx Budget Trading Program (NBP) have had a major effect on 

reducing regional transport of this pollutant. EPA data presented in Figure 4-1 show that total 

ozone-season NOx emissions from all NBP sources fell from 1,256,000 tons in 2000 to 481,000 

tons in 2008.8

Figure 4-1. Ozone-Season NOx Emissions from All NOx Budget Trading Program Sources 

 

levels that would violate other federal or state limits (e.g., NSPS, Title IV, NOx RACT).

6

 The NOx SIP Call superseded Phase III of the OTC NOx Budget Program. Maine, New Hampshire, and Vermont 

were not participating states. 

7

 The NOx Budget Trading Program established under the NOx SIP Call is separate and distinct from the OTC NOx 

Budget Program. 

8

 USEPA, The NOx Budget Trading Program: 2008 Highlights, December 2008; available at 

http://www.epa.gov/airmarkt/progress/NBP_4.html. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 25

On March 10, 2005, EPA issued the Clean Air Interstate Rule (CAIR) to further reduce air pollution 

that moves across state boundaries. CAIR established permanent emission caps for nitrogen oxides 

(and sulfur dioxide) emanating from major sources in eastern states – representing a 60 percent cut 

in NOx emissions from 2003 levels. On July 6, 2011, following a round of legal challenges to the 

original rule, EPA replaced CAIR with the Cross-State Air Pollution Rule, which corrected certain 

deficiencies in the original. Although not fully implemented before its withdrawal, CAIR yielded 

significant reductions in NOx emissions and transport; these realized air quality benefits will 

continue largely in effect under the replacement rule. 

At the same time it was addressing NOx emissions, EPA was developing programs to reduce VOC 

emissions on a broad scale. Since the 1990’s, EPA has mandated numerous mobile and area source 

controls for VOC (see Table 4-1), all of which have contributed to improved air quality in New 

Hampshire and the other downwind states.

As a complement to these federal efforts, the OTC developed model rules to be implemented by the 

individual member states for a number of VOC and NOx source categories. The OTC model rules 

were developed in three series: 2001/2002, 2006, and 2009/2010. (Note: Some of the 2009/2010 

model rules exist in draft form.) Adoption of these rules (or their equivalent) in a number of upwind

states has helped to reduce the transport of ozone and its precursors into New Hampshire.9

 

As illustrated in Figure 4-2, both NOx and VOC emissions in the eastern United States declined 

steadily between 1997 and 2004 for all major source categories. 

Figure 4-2. Ozone-Season NOx and VOC Emissions in the Eastern United States 

by Source Category: 1997, 2002 and 2004 

 

4.3 In-State Emission Reductions 

Aggregated reductions in NOx and VOC emissions from all sources in New Hampshire are partly 

responsible for New Hampshire’s attainment of the 8-hour ozone standard. Table 4-4 summarizes 

statewide emissions by source category for the inventory years of 2002, 2005, and 2008. 

 

9

 Status reports on states’ adoption of the OTC model rules may be viewed by clicking on links to the model rule 

adoption matrices available at http://www.otcair.org/interest.asp?Fview=stationary. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 26

Table 4-4. NOx and VOC Emissions in New Hampshire, 2002, 2005, and 2008 (tons/year) 

2002 Emissions 2005 Emissions 2008 Emissions Source Category NOx VOC NOx VOC NOx VOC 

Point 9,938 2,010 12,583 1,404 6,734 962 

Area 10,681 56,054 11,482 59,263 4,678 19,510 

Non-Road Mobile 9,108 22,099 8,746 21,485 8,877 18,916 

On-Road Mobile 30,755 16,895 26,874 14,151 21,450 9,431 

Total 60,482 97,058 59,685 96,303 41,739 48,819 

Note: A revised methodology (EPA's residential wood combustion tool) was used in the 2008 inventory for 

residential wood combustion; this resulted in substantially lower estimates of NOx and VOC for area sources. 

Ozone-season daily NOx and VOC emissions in New Hampshire by source category are represented 

graphically in Figures 4-3 and 4-4. 

Figure 4-3. Ozone-Season Daily NOx Emissions in New Hampshire 

by Source Category: 2002, 2005, and 2008 

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

Point Area Non-Road

Mobile

On-Road

Mobile

Total

NOx Emissions (pounds per day)

2002 2005 2008

 

Figure 4-4. Ozone-Season Daily VOC Emissions in New Hampshire 

by Source Category: 2002, 2005, and 2008 

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

Point Area Non-Road

Mobile

On-Road

Mobile

Total

VOC Emissions (pounds per day)

2002 2005 2008

 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 27

5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT 

 

Pursuant to Section 107(d)(3) of the Clean Air Act, state implementation plan submittals requesting 

redesignation of any area or portion thereof must meet all requirements applicable to the area under 

Title 1, Part A, Section 110 – Implementation Plans, and Title 1, Part D – Plan Requirements for 

Nonattainment Areas. 

According to EPA's interpretation10, to qualify for redesignation, a state requesting redesignation to 

attainment must meet the relevant CAA requirements that come due prior to the submittal of a 

complete redesignation request. Applicable requirements of the CAA that come due subsequent to 

the area's submittal of a complete redesignation request remain applicable until a redesignation is 

approved, but are not required as a prerequisite to redesignation. The Section 110 and part D 

requirements which are linked with a particular area's designation and classification are the relevant

measures to evaluate in reviewing a redesignation request. 

Part D, Sections 172-176 of the CAA set forth the basic requirements for all nonattainment areas. 

General provisions for nonattainment plans appear in Section 172(c). Section 182 establishes 

additional specific requirements depending on the area's nonattainment classification. Section 

182(b) prescribes specific measures for a moderate nonattainment area such as the Southeast New 

Hampshire Nonattainment Area. Section 184 establishes additional requirements applicable to the 

area because of its location within the Ozone Transport Region. 

Previous EPA statements11 indicate that conformity, new source review requirements, and OTR 

requirements are not applicable to considerations of redesignation as they are not directly linked 

with an area's designation and classification. In particular, 

• It is reasonable to interpret the conformity SIP requirements as not applying for purposes of 

evaluating the redesignation request under Section 107(d) because state conformity rules are 

still required after redesignation and federal conformity rules apply where state rules have 

not been approved. 

• It is reasonable to interpret the Section 184 OTR requirements, including New Source 

Review (NSR), as not being applicable for purposes of redesignation based on two factors. 

First, the requirement to submit SIP revisions for the Section 184 requirements continues to 

apply to areas in the OTR after redesignation to attainment. Therefore, the state remains 

obligated to have New Source Review (as well as RACT and Vehicle Inspection and 

Maintenance (I/M) programs) even after redesignation. Second, the Section 184 control 

measures are region-wide requirements and do not apply to the area by virtue of its 

designation and classification. 

Once an area has been redesignated to attainment status, NSR requirements for nonattainment areas 

under Part D will be replaced by program requirements for Prevention of Significant Deterioration 

(PSD) under Part C of Title I. NHDES submitted a New Source Review equivalency demonstration 

to EPA on January 3, 2006, detailing how New Hampshire’s current and proposed programs are at 

least as stringent as the federal NSR and PSD programs. 

 

10 EPA memorandum from John Calcagni, Director, Air Quality Management Division, “Procedures for Processing 

Requests to Redesignate Areas to Attainment,” September 4, 1992. 

11 EPA, Approval and Promulgation of Implementation Plans and Designation of Areas for Air Quality Planning 

Purposes; Maine; Redesignation of the Portland, ME and the Hancock, Knox, Lincoln and Waldo Counties, Maine 

8-Hour Ozone Nonattainment Areas to Attainment for Ozone; Proposed Rule, October 17, 2006 (71FR 60937). 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 28

For redesignation, a major consideration is the adequacy of maintenance provisions to assure 

continued attainment of the standard. In the present redesignation request, the maintenance plan 

presented in 6. MAINTENANCE PLAN meets the requirements set forth in Section 175A of the 

CAA. The emissions inventory requirements of Section 172(c)(3) are satisfied by the inventory 

developed for the maintenance plan as described in 6.1 Attainment Inventory. The requirements of 

Section 172(c)(9) for contingency measures are fulfilled in 6.5 Contingency Plan. 

NHDES asserts that New Hampshire’s implementation plan meets the requirements of Section 110 

and Part D for the state, in general, and for the Southeast New Hampshire Nonattainment Area, in 

particular. The required rulemaking authority, powers of the Commissioner, provisions for permits 

and enforcement, and other provisions necessary to meet the state’s obligations under the Clean Air 

Act are established in New Hampshire’s Revised Statutes Annotated (RSA), Chapter 125-C Air 

Pollution Control. Regulations implementing New Hampshire’s air program are established in the 

Rules Governing the Control of Air Pollution, New Hampshire Code of Administrative Rules 

Env-A 100 through 4800. (Note: Many New Hampshire air rules have received SIP approval; see 

relevant titles listed in Table 4-2). Additional requirements for controlling mobile source emissions

are found in rules issued by the Department of Safety at Saf-C 3200 and Saf-C 5800. Provisions for 

compliance with the specific elements of Section 110 are described in more detail below. 

5.1 Requirements of Section 110(a)(2) 

Section 110(a)(2) of the Clean Air Act and EPA regulations at 40 CFR 51, Subparts K and L, 

require that New Hampshire’s state implementation plan: 

• Provide for legally enforceable emission reporting and recordkeeping; 

• Provide for periodic testing and inspection of emission sources and for enforcement and 

investigation of complaints; 

• Include procedures for implementing transportation-related emission control measures; 

• Contain legally enforceable procedures to require stationary sources to install, calibrate, 

maintain, and operate equipment for continuously monitoring and recording emissions; 

• Demonstrate that the state has legal authority to adopt emission standards and limitations 

and any other measures necessary for attainment and maintenance of national standards; 

• Demonstrate that the state has the legal authority to enforce applicable laws, regulations, and 

standards and to seek injunctive relief; 

• Provide the state with the legal authority to abate pollutant emissions on an emergency basis 

to prevent substantial endangerment to the health of persons; 

• Demonstrate that the state has the legal authority to prevent the construction, modification, 

or operation of a facility which directly or indirectly results or may result in emissions of any 

air pollutant at any location that will prevent the attainment or maintenance of a national 

standard; 

• Demonstrate that the state has the legal authority to obtain information necessary to 

determine whether air pollution sources are in compliance with applicable laws, regulations 

and standards and that the state has the legal authority to make inspections and conduct tests 

of air pollution sources. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 29

New Hampshire meets these requirements by having adopted and implemented the following state 

laws and regulations that are at least as stringent as the applicable federal requirements established

for the protection of air quality: 

5.1.1 Emission Reporting and Recordkeeping 

Env-A 900 Owner or Operator Recordkeeping and Reporting Obligations requires that records be 

kept at sources that discharge air pollutants so that the emissions of such pollutants can be readily 

calculated or estimated and reported to NHDES for the purposes of demonstrating compliance, 

compiling emission inventories, and developing air-related strategic plans. The statutory authority 

for this regulation is provided in RSA 125-C:4, I. 

5.1.2 Periodic Testing and Inspection 

Env-A 800 Testing and Monitoring Procedures establishes minimum testing and monitoring 

procedures, calculation procedures, and standards for any owner or operator of a stationary source, 

area source, or device, required to perform testing or monitoring to determine compliance with RSA 

125-C, any permit issued by the division, or the requirements of other provisions of Env-A 300 et 

seq. The statutory authority for this regulation is contained in RSA 125-C:6, XI, XII. Statutory 

provisions for investigations and enforcement are established in RSA 125-C:6 and RSA 125-C:15. 

5.1.3 Transportation-Related Control Measures 

Env-A 1501 Transportation Conformity implements Section 176 of the Clean Air Act and 40 CFR 

93, Subpart A, with respect to transportation plans, programs, and projects developed, funded, or 

approved by the federal government or that are deemed regionally significant. Conformity 

determinations made under this rule ensure that the metropolitan planning organization (MPO) and 

state transportation plans, programs, and projects in the non-attainment areas adhere to New 

Hampshire’s SIP. The statutory authority for these regulations is provided in RSA 125-C:4. (See 

expanded description under 5.4 Transportation Conformity.) Additional regulations for 

controlling mobile source emissions are presented at Saf-C 3200 Official Motor Vehicle Inspection 

Requirements and Saf-C 5800 Roadside Diesel Opacity Inspection. 

5.1.4 Continuous Monitoring and Recording of Emissions 

Env-A 808 Continuous Emission Monitoring requires the owner or operator of a stationary source 

meeting certain conditions to install, operate, and maintain a CEM system and to perform quality 

assurance testing on that system. The statutory authority for this regulation is provided in RSA 125-

C:6, XI, XII. 

5.1.5 Legal Authority and Emergency Powers 

Legal authority to carry out New Hampshire’s implementation plan is vested in the Commissioner 

of the New Hampshire Department of Environmental Services under New Hampshire statutes RSA 

125-C:4 Rulemaking Authority; Subpoena Power and RSA 125C:6 Powers and Duties of the 

Commissioner (see Attachment E). The Commissioner has delegated to the Director of the Air 

Resources Division major responsibilities for carrying out New Hampshire’s air programs. (Note: 
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Under RSA 125-C:8 Administration of Chapter; Delegation of Duties, the Commissioner cannot 

delegate rulemaking authority.) 

Permit conditions, orders, or directives issued by the Commissioner may be enforced by NHDES 

or by the New Hampshire Attorney General. NHDES may resolve a violation through an 

administrative consent agreement, schedule and hold an enforcement hearing, or refer the violation 

to the Attorney General to initiate a civil or criminal action. 

The Governor has appointed the Director of the Air Resources Division, acting under the authority 

of the Commissioner, as his designee for requesting EPA’s approval of revisions to New 

Hampshire’s State Implementation Plan (see Attachment E).

The authority of the Commissioner to undertake specific actions is established in the following 

sections of state law: 

• RSA 125-C:4 Rulemaking Authority; Subpoena Power provides the Commissioner with the 

legal authority to adopt emission standards and limitations and any other measures necessary 

for attainment and maintenance of national standards. 

• RSA 125-C:6 Powers and Duties of the Commissioner provides the Commissioner with the 

legal authority to prevent the construction, modification, or operation of a facility which 

directly or indirectly results or may result in emissions of any air pollutant at any location 

that will prevent the attainment or maintenance of a national standard; to obtain information 

necessary to determine whether air pollution sources are in compliance with applicable laws, 

regulations and standards; and to make inspections and conduct tests of air pollution sources. 

• RSA 125-C:9 Authority of the Commissioner in Cases of Emergency provides the 

Commissioner with the legal authority to abate pollutant emissions on an emergency basis to 

prevent substantial endangerment to the health of persons. 

• RSA 125-C:15 Enforcement provides the Commissioner with the legal authority to enforce 

applicable laws, regulations, and standards and to seek injunctive relief. 

5.2 Continuance of Existing Control Requirements after Redesignation 

New Hampshire’s implementation plan incorporates federal requirements for demonstrating that the 

ozone standard can be maintained in future years in the Southeast New Hampshire Nonattainment 

Area. Continued attainment of the standard is supported by adherence to anti-backsliding provisions 

established in Section 173(e) of the CAA and by maintenance provisions developed specifically for 

this area redesignation to meet the requirements of Section 175A (see 6. MAINTENANCE PLAN). 

Note that, in compliance with federal anti-backsliding requirements, existing NOx and VOC RACT 

control measures (as well as other control measures) implemented within the ozone nonattainment 

area will remain in effect after redesignation to attainment. 

Under EPA's anti-backsliding rules, areas designated nonattainment for the 1-hour ozone standard at 

the time of the 8-hour ozone designations remained subject to certain control measures that applied 

by virtue of the area's classification for the 1-hour NAAQS (40 CFR 51.900 et seq.). 40 CFR 

51.905(a)(1) prescribes the 1-hour NAAQS requirements that continue to apply to former 1-hour 

ozone nonattainment areas after revocation of the 1-hour NAAQS: “The area remains subject to the 

obligation to adopt and implement the applicable requirements as defined in section 51.900(f),...” 
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40 CFR 51.900(f) reads: “Applicable requirements means...the following requirements to the extent 

such requirements apply or applied to the area for the area's classification under section 181(a)(1) of 

the CAA for the 1-hour NAAQS at designation for the 8-hour NAAQS:...” 

For New Hampshire’s former 1-hour marginal nonattainment area, the applicable requirements are 

as follows: 

• RACT; 

• I/M programs; 

For New Hampshire’s former 1-hour serious nonattainment areas (Seacoast and Southern), the 

applicable requirements are as follows: 

• RACT; 

• I/M programs; 

• Major source applicability cut-offs for purposes of RACT; 

• ROP reductions; 

• Stage II vapor recovery; 

• Clean fuels fleet program under Section 182(c)(4) of the CAA; 

• Enhanced (ambient) monitoring under Section 182(c)(1) of the CAA; 

• Transportation controls under Section 182(c)(5) of the CAA; 

• NOx requirements under Section 182(f) of the CAA; and 

• Attainment demonstration or an alternative as provided under 40 CFR 51.905(a)(1)(ii). 

New Hampshire asserts that all required control provisions shall remain in place to prevent 

backsliding and assure maintenance of the 1997 8-hour ozone NAAQS after redesignation of the 

area to attainment. The 1-hour ozone attainment demonstration was submitted and approved, as 

previously described in 3.3 1-Hour Ozone Attainment Demonstration. Provisions for NOx and 

VOC RACT are as described in 3.2 Reasonably Available Control Technology Requirements. Rate 

of Progress (ROP) reductions are as described in 3.4 Rate-of-Progress Requirements. 

New Hampshire notes that it recently revoked the requirement that new gasoline dispensing 

facilities shall be equipped with Stage II vapor recovery control equipment and simultaneously 

adopted a requirement that owners of existing gasoline dispensing facilities equipped with Stage II 

controls shall decommission such equipment by December 22, 2015. This rulemaking was 

necessary to prevent a situation – forecast to occur in the next few years – whereby the Stage II 

equipment, because of incompatibility with ORVR equipment, would cause more VOC emissions 

than it would prevent. New Hampshire is preparing a separate SIP submittal demonstrating that 

these rule changes will not violate the anti-backsliding requirements of section 110(l) of the Clean 

Air Act. The demonstration would have been included with this SIP revision, but has been delayed 

as NHDES resolves discrepancies in motor vehicle emission estimates after conversion to the new 

MOVES model. 

New Hampshire has a motor vehicle I/M program requiring annual inspections of all motor vehicles. 

Pre-model year 1996 vehicles that are less than 20 years old undergo a visual anti-tampering 

inspection. Model year 1996 and newer gasoline and 1997 and newer diesel vehicles up to 8,500 

pounds Gross Vehicle Weight Rating (GVWR) are subject to an annual onboard diagnostics (OBD) 

inspection as specified in 40 CFR Parts 51 and 85. In addition, heavy duty diesel vehicles (GVWR 

>10,000 lbs) are also subject to random roadside opacity testing (see NH statute RSA 266:59-b and 

New Hampshire Department of Safety Administrative Rules Saf-C 3200 and Saf-C 5800). 
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NHDES operates two enhanced ambient air monitoring stations as required by Section 182(c)(1) of 

the CAA for serious nonattainment areas for the 1-hour ozone standard. These Photochemical 

Assessment Monitoring Stations (PAMS) were originally configured to track NOx and VOC 

emissions up- and downwind of the Portsmouth, New Hampshire, metropolitan area. With EPA 

approval, this network has since been modified to reflect updated science and to track high- and 

low-elevation ozone precursor emissions entering the state from the southwest. Because of the 

revocation of the 1-hour ozone standard, the PAMS monitors operate in an 8-hour ozone 

nonattainment area currently classified as moderate. 

New Hampshire meets Section 182(c)(5) requirements through compliance with the transportation 

conformity requirements found at 40 CFR Part 93. Using a consultative process set forth in Env-A 

1500, New Hampshire ensures that transportation-related emissions remain consistent with emission 

levels projected in the state’s attainment demonstration and established in the motor vehicle 

emissions budgets. 

5.3 Permitting of Stationary Sources 

Under Chapter Env-A 600 Statewide Permit System, all new, modified, and existing stationary 

emission sources of specified sizes and types are required to obtain permits; operate in compliance 

with applicable laws and regulations; maintain and test emission control equipment; and keep 

detailed records of emissions, fuel use, and related parameters. In addition, NHDES has the 

authority to conduct periodic inspections and surveillance of emission sources, to enter property at 

any reasonable time for such purposes, to require the submission of detailed plans and other data 

from permit applicants, and to require the submission of information regarding actual or suspected 

violations. 

New Hampshire’s process for permit application and review includes consideration of air quality 

impact analysis (modeling), emission control technology, operational limitations, public 

participation, and other procedural requirements for both existing sources seeking operating permits 

(renewals) and new or modified sources seeking temporary (initial construction) permits prior to 

operation. The permit process also includes consideration of federal New Source Review 

requirements applicable to all major sources of NOx, VOC, and other regulated pollutants. State 

rules designed to protect air quality in existing attainment areas are found at Part Env-A 619 

Prevention of Significant Deterioration (PSD) Air Quality Permit Requirements. These rules meet 

requirements of the Clean Air Act pertaining to PSD and visibility protection as established in 

Section 110(a)(2) of Title I, Part A and Sections 160-169 of Title I, Part C. These rules also are at

least as stringent as EPA requirements published at 40 CFR 51.166 and 40 CFR 52.21. 

All information submitted to NHDES in permit applications is available for public disclosure. Any 

exceptions to this general statement are determined by the provisions of RSA 125-C:6, VII, and 

Env-A 103 Claims of Confidentiality.

5.4 Monitoring of Stationary Sources 

NHDES requires qualifying facilities to install, maintain, and use emission monitoring devices and 

to make periodic submittals to NHDES on the nature and quantity of emissions. Air program rules 

at Chapter Env-A 800 Testing and Monitoring Procedures establish minimum testing and 

monitoring procedures, calculation methods, standards, and other requirements to determine 

compliance with applicable state/federal laws and rules. Part Env-A 808 Continuous Emission 
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Monitoring establishes the requirements for CEMs at major emission sources. Chapter Env-A 900 

Owner or Operator Recordkeeping and Reporting Obligations identifies requirements for keeping 

records of and reporting actual emissions to NHDES and EPA. All permitted emission sources are 

required to file annual emission statements by April 15 for the previous calendar year. NHDES is 

required to make all information on emissions available for public inspection, including any reports 

correlating source emission data with applicable emission standards and limitations. 

5.5 Transportation Conformity

In addition to requirements for the control of NOx and VOC emissions, the 1990 Clean Air Act 

Amendments established specific provisions regarding the conformity of transportation actions. 

Transportation conformity ("conformity"), as established in Section 176(c)(4) of the Act, is a way to 

ensure that Federal funding and approval goes to those transportation activities that are consistent 

with air quality goals as outlined in a SIP. Conformity applies to transportation plans, transportation 

improvement programs (TIPs), and projects funded or approved by the Federal Highway 

Administration (FHWA) or the Federal Transit Administration (FTA) in areas that do not meet or 

previously have not met air quality standards for ozone, carbon monoxide, particulate matter, or 

nitrogen dioxide. These areas are known as "nonattainment areas" or "maintenance areas," 

respectively. Regulations governing transportation conformity are found in 40 CFR Parts 51 and 93. 

EPA regulations for transportation conformity (40 CFR Parts 51 and 93) require MPOs and the U.S. 

Department of Transportation (US DOT) to make conformity determinations on metropolitan 

transportation plans and TIPs before they are adopted, approved or accepted. In addition, highway 

or transit projects which are funded or approved by the Federal Highway Administration or the 

Federal Transit Administration must also receive a conformity determination before they can be 

approved or funded by US DOT or an MPO. Regionally significant projects, regardless of their 

funding source, must also undergo a conformity finding. The federal rule applies in all 

nonattainment areas, or areas with maintenance plans for ozone, carbon monoxide, nitrogen oxides 

or particulate matter. 

EPA’s transportation conformity regulations, first promulgated November 24, 1993, have been 

amended several times, including on July 1, 2004, when EPA issued a final rule to implement 

conformity for the 8-hour ozone NAAQS, and on May 6, 2005, March 10, 2006 , and January 24, 

2008. 

Conformity determinations are made by demonstrating consistency with adequate or EPA-approved 

motor vehicle emissions budgets (MVEBs) established by rate-of-progress plans, attainment 

demonstrations, or other control strategy implementation plans. Section 176(c)(2)(A) specifically 

requires conformity demonstrations to show that emissions from transportation plans and TIPs are 

consistent with estimates of emissions from motor vehicles and necessary emission reductions as 

established by reasonable further progress, attainment demonstrations, and maintenance 

demonstrations contained in the SIP. MVEBs are the explicit or implicit identification of the motorvehicle-related portions of the projection inventory used to demonstrate reasonable further progress 

milestones, attainment, or maintenance for a particular year identified in the SIP. The MVEBs 

establish a cap on emissions which cannot be exceeded by predicted highway and transit vehicle 

emissions. 

On July 28, 2008, EPA deemed adequate for purposes of conformity New Hampshire's SIP revision 

establishing MVEBs for the Southeast New Hampshire Nonattainment Area. On February 27, 2009, 

EPA proposed final approval of the budgets, effective April 29, 2009. NHDES developed these 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 34

budgets using the MOBILE6.2 modeling platform. Subsequently, NHDES prepared new MVEBs 

using EPA’s MOVES2010a model (or, in the case of future-year VOC emissions, MOVES2010b) to be 

consistent with the agency’s latest policy on modeling emissions from mobile sources. As part of this

redesignation request, NHDES is requesting that EPA withdraw the approved MOBILE6.2 2009 

MVEBs and replace them with the new MOVES 2008 MVEBs (summarized in Table 5-1). 

Electronic input/output files for MOVES are provided as Attachment F.

Simultaneously, NHDES is submitting 2022 MVEBs for NOx and VOC for use in determining 

transportation conformity (see Table 5-1 and Attachment F). NHDES used MOVES to calculate onroad emissions of NOx and VOC for the 52 cities and towns in Hillsborough, Merrimack, 

Rockingham, and Strafford Counties comprising the Southeast New Hampshire Nonattainment 

Area. In this submittal, New Hampshire is proposing MVEBs for the last year of the 8-hour ozone 

maintenance planning period (2022) at 8.9 tons per summer day (tpsd) of VOC and 11.8 tpsd of 

NOx. These on-road mobile source emissions, when added to emissions from all other inventory 

sources – stationary, area, and other mobile sources (i.e., non-road, marine vessels, airplanes, and 

locomotives) – result in a year 2022 emissions inventory lower than the year 2008 attainment 

inventory (see NOx and VOC emissions summary in Table 6-1). These emissions budgets, once 

approved or deemed adequate by EPA, must be used for future transportation conformity 

determinations.

Table 5-1. 2008 and 2022 Motor Vehicle Emission Budgets for the Southeast New Hampshire 

Nonattainment Area (tons per summer day)

2008 2022 Category 

NOx VOC NOx VOC 

Onroad 37.2 17.8 11.8 9.2 

5.6 Vapor Recovery: Stage II and Onboard Refueling 

EPA established the federal Stage II vapor recovery program, a VOC emissions reduction control 

measure, in Section 182(b)(3) of the CAA. This section of the CAA directs state or local air pollution 

control agencies with moderate or worse ozone nonattainment areas to require Stage II vapor 

recovery systems (VRS) at gasoline dispensing facilities (GDF). However, Section 202(a)(6) of the 

CAA, states that the Section 182(b)(3) Stage II requirement shall not apply in moderate areas after 

new motor vehicle onboard refueling vapor recovery (ORVR) requirements are promulgated. 

For the Ozone Transport Region, there is an additional requirement, in Section 184(b)(2) of the CAA, 

for 1) EPA to “complete a study identifying control measures capable of achieving emission 

reductions comparable to those achievable through vehicle refueling controls contained in section 

7511a (b)(3) of this title, and such measures or such vehicle refueling controls shall be implemented 

in accordance with the provisions of this section” (referred to as comparable measures); and 2) OTR 

states to revise their state implementation plans to require Stage II controls or comparable measures 

in OTR areas (statewide in New Hampshire).12 This requirement is not affected by EPA’s 

promulgation of ORVR rules, or by any future widespread use determination under CAA Section 

202(a)(6). 

 

12 See U.S. EPA, Stage II Comparability Study for the Northeast Ozone Transport Region, EPA Publication No. EPA452/R-94-011, January 1995. 
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Portions of New Hampshire’s four-county nonattainment area (the Southern and Seacoast Serious 

areas) were assigned a higher than moderate classification for the 1997 ozone NAAQS, and the 

entire state is located in the OTR. Therefore, NHDES has required Stage II controls as an element 

of the state’s federally enforceable implementation plan in the four-county nonattainment area since 

1992. The Stage II requirements were codified in New Hampshire rule Env-A 1205 Volatile 

Organic Compounds (VOC): Gasoline Dispensing Facilities and Gasoline Tank Trucks and

subsequently approved into the SIP.13 (Note that New Hampshire identified comparable measures 

to avoid the OTR statewide Stage II requirement.) 

The CAA required EPA to develop standards for ORVR controls on new light-duty vehicles, which 

were phased in between 1998 and 2002. However, there is a technology mismatch: vacuum assist 

Stage II control systems are not fully compatible with ORVR-equipped vehicles. ORVR diminishes 

the effectiveness of the vacuum assist Stage II vapor recovery systems, resulting in an increase in 

emissions compared to the levels expected during refueling of non-ORVR-equipped vehicles. 

Consistent with these findings, NHDES has determined that Stage II vapor recovery controls are 

providing a diminished emissions reduction benefit due to the predominance of ORVR-equipped 

vehicles in the New Hampshire fleet. This benefit will disappear altogether over the next several 

years as more ORVR-equipped vehicles enter the fleet. 

Because of the conflicting technology and its potential to increase refueling emissions as ORVR 

achieves “widespread use,”14 NHDES, with guidance from EPA, is removing the Stage II 

requirement for existing and future gasoline dispensing facilities. Note, however, that NHDES is 

not submitting the phase-out of Stage II as a formal component of this SIP revision to redesignate 

the 1997 8-hour ozone nonattainment area, but will submit a separate request to remove Stage II 

requirements from the SIP in the near future. 

5.7 Resource Commitments 

Section 110(a)(2)(E) of the CAA requires assurances that the state will have adequate personnel, 

funding, and authority under state law to carry out the State Implementation Plan. Funding for New 

Hampshire’s air programs is appropriated by the New Hampshire General Court on a biannual 

budget cycle. EPA provides significant financial support for the administration of federal programs 

in New Hampshire. The majority of funding is derived through the Air Resource Division’s permit 

fee structure. NHDES is committed to providing continued funding and staffing levels adequate to 

maintain New Hampshire’s implementation plan.

5.8 Future Revisions to the Plan 

NHDES will revise the maintenance plan for the redesignated area, as necessary, to meet revisions 

to the NAAQS for ozone, to fulfill other requirements of the Clean Air Act, or take advantage of 

improved methods for maintaining the standard. More specifically, in compliance with Section 

175A of the Act, NHDES will revise the maintenance plan eight years after redesignation of the 

area, or at any such time that EPA deems the maintenance plan inadequate to meet the NAAQS. 

 

13 See 63 FR 67405, December 7, 1998, at http://www.epa.gov/region1/topics/air/sips/sips_nh.html. 

14 See U. S. EPA, Stage II Vapor Recovery Systems Issues Paper, Office of Air Quality Planning and Standards (D243-02), 

August 12, 2004, at http://www.epa.gov/ttn/naaqs/ozone/ozonetech/stage2/isspaper081204.pdf. 
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6. MAINTENANCE PLAN 

Section 175A of the Clean Air Act sets forth the elements of a maintenance plan for areas seeking 

redesignation from nonattainment to attainment. The plan must demonstrate continued attainment 

of the applicable NAAQS for 10 years after the area is redesignated. Section 175A(b) requires that, 

eight years after formal redesignation, the state submit a SIP revision for maintenance of the 

standard for an additional 10 years following the first 10-year period. To provide for appropriate 

response to the possibility of future NAAQS violations, the maintenance plan must contain 

contingency measures adequate to assure prompt correction of any air quality problems, including a 

schedule for implementation. 

EPA guidance15 recommends that states seeking redesignation of a nonattainment area consider the 

following provisions to ensure maintenance of the NAAQS: 

• An attainment emissions inventory to identify the level of emissions in the area that is 

sufficient to attain the NAAQS. 

• A maintenance demonstration showing that future emissions of a pollutant or its precursors 

will not exceed the level of the attainment inventory over the 10-year period following 

redesignation. 

• Continued operation of an appropriate air quality monitoring network to verify the area's 

attainment status. 

• Verification of continued attainment and evidence that the state has the legal authority to 

implement and enforce all measures necessary to attain and maintain the NAAQS. 

• Available contingency measures to promptly correct any NAAQS violation, including a 

schedule for implementation. 

6.1 Attainment Inventory 

The attainment emissions inventory should identify the level of emissions sufficient to achieve the 

NAAQS. This inventory should be consistent with EPA's most recent guidance on emission 

inventories for nonattainment areas available at the time and should include emissions during the 

time period associated with the monitoring data showing attainment of the ozone NAAQS. Where 

the state has made an adequate demonstration that air quality has improved as a result of the SIP, the

attainment inventory will generally be the actual inventory during the time period the area attained 

the standard. The inventory must be based on "typical summer day" emissions of VOCs and NOx 

during the attainment year. 

NHDES has developed an attainment inventory for 2008, representing the three-year period (2007-

2009) in which New Hampshire’s ozone monitoring data showed attainment of the 8-hour ozone 

standard. (Note that the monitoring data have met this standard since the 2002-2004 monitoring 

period). The 2008 attainment inventory and projected future inventories (see 6.2.1 Projected 2012 

and 2022 Emissions Inventories) are subdivided into the following general emissions categories: 

• Point Sources, which represent discrete facilities. These sources usually must meet certain 

emission criteria to be included as point sources and generally represent larger facilities. 

• Area Sources, which represent facilities and activities too numerous and widespread to be 

inventoried individually but which collectively may account for significant emissions. 

 

15 See footnote 10. 
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• Non-Road Mobile Sources, including aircraft, locomotives, commercial marine vessels, 

construction vehicles, lawn & garden equipment, and other mobile vehicles and equipment 

that are not meant to be operated on roadways. 

• On-Road Mobile Sources, including cars, trucks, buses, motorcycles, and other vehicles that 

operate on public roadways. 

The 2008 attainment inventory and the projected 2012 interim-year and 2022 maintenance 

inventories represent all NOx and VOC emissions originating within the specific cities and towns of 

the 8-hour ozone nonattainment area (see Table 1-1 for list). These inventories were developed in 

accordance with EPA guidance. Because the 2008 emissions inventory serves as the attainment 

inventory for this redesignation request, it is being formally adopted into the New Hampshire SIP. 

The 2008 emissions inventory is also being submitted to EPA for inclusion in the 2008 National 

Emissions Inventory. Detailed documentation for New Hampshire's 2008 emissions inventory is 

presented for SIP approval as Attachment G. The methodologies used in preparing the 2008 

emissions estimates are summarized in the following paragraphs. 

For point sources, affected facilities in New Hampshire are required to report their emissions on an 

annual basis. The reporting requirements for these facilities are provided under New Hampshire’s 

air regulations, its state air permitting program, and the CERR. Data submitted by these facilities are 

extensively cross-checked and quality assured by NHDES staff before eventual submittal to EPA. 

The point source data contained in New Hampshire’s 2008 attainment inventory originated from the 

quality-assured 2008 data from all reporting point sources in the 8-hour nonattainment area. 

The methodologies used to estimate emissions for area source categories come primarily from EPA’s 

Emissions Inventory Improvement Program (EIIP). Calculations for many area source categories are 

based on variables such as population, employment, and fuel consumption data. Descriptions of the 

methodologies for specific area source categories can be found in EIIP Volume 3, Area Sources, 

which is available at EPA’s Clearinghouse for Inventories and Emissions Factors website at 

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/index.html. 

For the non-road mobile category, NHDES used EPA’s NONROAD2008a model to estimate 2008 

emissions for those equipment types that are included in the model. For commercial aircraft and 

airport ground service equipment, NHDES used the Federal Aviation Agency’s (FAA’s) Emissions 

& Dispersion Modeling System (EDMS). Standardized methodologies and references were 

employed for equipment types not included in the EDMS or NONROAD models, e.g., locomotives 

and commercial marine vessels. 

For on-road mobile sources, NHDES used MOVES2010a with VMT and other road related data 

provided by the relevant MPOs within the state’s nonattainment area. Results represent emissions 

originating in cities and towns in the non-attainment area only, not whole counties as had been 

reported previously. 

Estimated emissions for the 2008 attainment inventory are shown in Table 6-1. 

6.2 Maintenance Demonstration 

EPA guidance on redesignation provides for demonstrating maintenance of the NAAQS through the 

use of either an emissions inventory approach (where a state demonstrates that future emissions of a 

pollutant or its precursors will not exceed the level of the attainment inventory), or by air quality 

modeling to show that future emission rates from all sources will not cause a violation of the NAAQS. 
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The maintenance demonstration should be for a period of 10 years following the redesignation and 

should consider future growth, including population and industry, be consistent with the attainment 

inventory, and provide documentation of data inputs and assumptions. All elements of the 

demonstration should be consistent with current EPA guidance. Enforceability through regulations 

must also be demonstrated. 

Any assumptions concerning emission rates must reflect permanent, enforceable measures. A state 

generally cannot take credit for reductions unless there are regulations in place requiring those 

reductions or the reductions are otherwise shown to be permanent. Therefore, the state is expected 

to maintain its implemented control strategy despite redesignation to attainment, unless such 

measures are shown to be unnecessary for maintenance or are replaced with measures that achieve 

equivalent reductions. Emission reductions from source shutdowns can be considered permanent 

and enforceable to the extent that those shutdowns have been reflected in the State Implementation 

Plan and all applicable permits have been modified accordingly. 

6.2.1 Projected 2012 and 2022 Emissions Inventories 

New Hampshire has chosen to utilize the emissions inventory approach to demonstrate that its 

future emissions of ozone precursors will not exceed the level of the 2008 attainment inventory, and 

has projected emissions for 2012 and 2022.16 Table 6-1 shows that future emissions of NOx and 

VOC will remain below the level of New Hampshire’s 2008 attainment inventory through the 10-

year planning period following redesignation – the result of a continuing decline in total emissions. 

The projected emissions reflect the expected summertime emissions based on enforceable emission 

limits and typical production rates. The methodologies used to estimate projected 2012 and 2022 

emissions are discussed in the following paragraphs. 

Table 6-1. 2008 vs. 2012 and 2022 NOx and VOC Emissions in the 

Southeast New Hampshire Nonattainment Area (pounds per summer day) 

NOx VOC Source Category 2008 2012 2022 2008 2012 2022 

Point 24,289 21,655 22,742 5,762 5,288 6,605 

Area 6,528 6,243 6,432 55,871 57,885 70,195 

Non-Road Mobile 31,364 26,121 17,670 33,512 26,863 19,152 

On-Road Mobile 74,352 51,204 23,558 35,666 28,470 18,410 

Total 136,533 105,223 70,402 130,811 118,506 114,362 

 

Except as noted below, New Hampshire used EPA's Economic Growth Analysis System (EGAS) 

Version 5.0 to develop the applicable growth factors for estimating projected 2012 and 2022 

emissions. Growth factors were matched to the appropriate point, area, and mobile source 

categories using Source Classification Codes (SCC). With respect to area sources, New Hampshire 

has adopted or is evaluating various control measures for a number of VOC source categories such as 

solvent cleaning, architectural surface coating, etc. For those measures that are not yet SIPapproved, the attendant emission reductions benefits are omitted from the 2012 and 2022 

inventories. As a consequence of this conservative approach, it is anticipated that actual future-year 

emissions will be lower than the projected emissions presented in Table 6-1.

 

16 The maintenance plan must show that emissions 10 years after the date on which EPA approves the redesignation 

request (expected to be in 2012) will be lower than they were in the base year (2008) of the maintenance plan. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 39

Because analysis year is an inherent input into the NONROAD model, projected 2012 and 2022 

non-road mobile emissions were estimated directly for those non-road equipment categories that are 

included in the model. For other non-road mobile categories such as aircraft, locomotives, and 

CMVs, the appropriate EGAS growth factors were used. For commercial aircraft and airport ground 

service equipment, the EGAS growth factors were applied to the specific activities (e.g., aircraft 

landing and takeoff operations); and the growth-adjusted values were then input into the EDMS 

model. (Note: The EDMS model uses the analysis year to select the appropriate emission factors.) 

For on-road mobile sources, VMT data were provided by the relevant Metropolitan Planning 

Organizations (MPOs) via their transportation demand models that use population, employment and 

other economic factors as inputs to growth-adjust to 2012 and 2022. These values were subsequently 

used as inputs to the MOVES model. Vehicle population data were adjusted for subsequent years 

using the growth factors from Table 3-14 of MOVES2010 Highway Vehicle Population and 

Activity Data, EPA-420-R-10-026, November 2010. For 2012 and 2022, the MOVES model was 

run with Stage II controls turned off to reflect the fact that New Hampshire’s Stage II vapor recovery

program is no longer providing emissions reductions as of January 1, 2012. The 2012 and 2022 onroad mobile VOC estimates were generated using the MOVES2010b model. All other on-road 

mobile emissions estimates shown in Table 6-1 were produced with MOVES2010a.

In addition to growth factors and future control measures, another consideration in making emission 

projections is that sources in New Hampshire hold a certain quantity of banked emissions under the 

state’s open market trading program. As of 2011, these sources held 68 tons of ozone-season 

Discrete Emissions Reductions (DERs) and 254 tons per season of ozone-season Emissions 

Reductions Credits (ERCs) for VOC. Similarly, New Hampshire sources held 1,882 tons of ozoneseason DERs and 198 tons of ozone-season ERCs for NOx. It is expected that these credits will 

remain banked and not be used. However, it was conservatively assumed that all available 

emissions credits would be used. Therefore, they have been included in the project point source 

emissions estimates shown in Table 6-1. 

All of the technical data files related to the projected 2012 and 2022 emissions inventories are 

enclosed on CD-ROM as Attachment H. 

6.2.2 Air Quality Modeling 

Although EPA’s redesignation guidance does not require air quality modeling for ozone 

nonattainment areas seeking redesignation, extensive modeling has been performed to determine the 

effect of national and regional emission control strategies on ozone air quality in New Hampshire 

and throughout the eastern United States. These modeling analyses have demonstrated that the 

Southeast New Hampshire Nonattainment Area is significantly impacted by transported ozone and 

ozone precursors and that regional NOx reductions will provide significant ozone air quality 

improvements in this area. 

6.2.2.1 EPA Modeling Analysis for the Nonroad Land-Based Diesel Engines Standards 

In 2003, EPA conducted modeling to support the rulemaking for the Nonroad Land-based Diesel 

Engines Standards.17 In its analysis, EPA used the Comprehensive Air Quality Model with 

Extensions (CAMx) to evaluate the impacts of the proposed emission reductions on future air 

quality levels. Three meteorological episodes (June 12-24, 1995; July 5-15, 1995; and August 7-21, 

 

17 “Technical Support Document for the Nonroad Land-based Diesel Engines Standards Air Quality Modeling 

Analyses”, U.S. EPA Office of Air Quality Planning and Standards, April 2003. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 40

 2001 Base Year  2010 Base Case 

 2010 CAIR Controls

 2015 Base Case 

 2015 CAIR Controls 

 2015 CAIR + BART 

 2015 BART Only

1995) were used for the modeling simulations. Ambient monitoring showed that ozone 

concentrations over the eastern United States were relatively elevated during these time periods. 

Using the relative reduction factor method, EPA applied CAMx to predict ozone values under 

several emissions scenarios: the 1996 base year, the 2021 baseline case, the 2021 control case, the 

2030 baseline case, and the 2030 control case. Results of this modeling show that under both the 

base case (without new rules on nonroad land-based diesel engines) and under the control scenario 

(with these new rules), there would be no counties in New Hampshire with predicted future design 

values that exceed (or come within 10 percent of) the 8-hour ozone standard. 

6.2.2.2 EPA Modeling Analysis for the CAIR Rulemaking

More recently, EPA conducted a similar modeling analysis as part of the Clean Air Interstate Rule 

(CAIR) rulemaking18. In this analysis, EPA used CAMx version 3.10 to model the 1995 ozone episode 

meteorology described above (i.e., June 12-24, July 5-15, and August 7-21, 1995). The analysis 

years and emissions scenarios that were assessed included: 

The 2010 and 2015 base cases reflect expected economic growth and the anticipated benefits 

associated with existing emissions control programs. 

As with the modeling done for the non-road diesel rulemaking, the CAMx model predictions for the 

CAIR analysis were used in a relative manner. Weighted-average 1999-2003 design values were 

used as the basis of the observed 8-hour ozone concentrations. EPA then estimated maximum 8-

hour ozone design values for each future-year scenario for each county in the modeling domain with 

an ozone monitor. Table 6-2 shows the maximum estimated future 8-hour design values for New 

Hampshire. These results show that, even without the emissions benefits associated with CAIR, all 

New Hampshire counties were predicted to be in attainment for 8-hour ozone for the 2010 and 2015 

analysis years. 

Table 6-2. Summary of CAIR Modeling Results for Ozone Levels in New Hampshire (ppb) 

Estimated Maximum 8-hour Future Design Values 

County 

1999-2003 

Average Design 

Value 2010 Base 2010 CAIR 2015 Base 2015 CAIR 

Belknap 78.0 68.5 68.2 65.8 65.0 

Carroll 66.5 60.3 60.0 58.6 58.0 

Cheshire 73.7 65.2 64.9 63.1 62.0 

Hillsborough 85.0 76.7 76.6 74.1 73.9 

Merrimack 73.0 64.8 64.6 62.3 61.8 

Rockingham 82.7 75.2 75.1 73.3 72.9 

Strafford 77.3 69.2 69.1 66.8 66.5 

Note: Data taken from Appendix E of EPA’s Technical Support Document for the Final Clean Air Interstate Rule, 

Air Quality Modeling, March 2005. 

 

18

 “Technical Support Document for the Final Clean Air Interstate Rule, Air Quality Modeling”, U.S. EPA Office of Air 

Quality Planning and Standards, March 2005. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 41

6.3 Air Quality Monitoring Network 

Once an area has been redesignated, the state must continue to operate an appropriate air quality 

monitoring network in accordance with 40 CFR Part 58, to verify the area's attainment status. In 

cases where measured mobile source parameters (for example, vehicle miles traveled) have changed 

over time, the state may also need to perform a saturation monitoring study to determine the need 

for and location of additional permanent monitors. NHDES is committed to the continued operation 

and maintenance of an appropriate air quality monitoring network for the Southeast New Hampshire 

Nonattainment Area, contingent on future EPA funding sufficient to sustain the network at the 

required operational levels.

6.4 Verification of Continued Attainment 

Verification of continued attainment can be accomplished through the acquisition of air quality data 

and source emission data. Air quality data will directly show whether the ozone NAAQS is being 

met in real time and over specified averaging periods. The gathering of source emission data 

enables the construction of periodic updates to emissions inventories for tracking progress in 

emission control measures or supplying inputs for revised air quality modeling projections. 

Emission inventory updates could be based, in part, on the annual update of EPA’s national 

emissions inventory (NEI) database and could indicate new source growth and other changes from 

the attainment inventory (such as changes in vehicle miles traveled or in traffic patterns). 

New Hampshire will track the progress of attainment maintenance by making periodic updates to 

the state emissions inventory. NHDES ordinarily revises the emissions inventory on a 3-year cycle; 

the latest one, the 2008 inventory, was completed in 2010. Subsequent updates will be prepared for 

2011 and 2014. NHDES will report the results of this tracking program to EPA on the same 3-year 

cycle, when the emissions inventory data become available. 

6.5 Contingency Plan 

Section 175A(d) of the Clean Air Act requires that a maintenance plan include contingency 

provisions to promptly correct any violation of the NAAQS that occurs after redesignation of a 

nonattainment area to attainment status. As an enforceable part of the SIP, the contingency plan 

should be implemented expediently if and when the need arises. According to EPA guidance19, the 

contingency plan should clearly identify the measures to be adopted, a schedule and procedure for 

adoption and implementation, and a specific time limit for action by the state. The plan should also 

identify specific indicators, or triggers, that the state will use to determine when the contingency 

measures are needed. Action-level indicators might be based on ambient ozone concentrations (e.g., 

monitored violations of the NAAQS) or on updated emission inventory values (e.g., tonnages of 

specific ozone-precursor pollutants). 

EPA points out that air quality levels above the NAAQS will not automatically necessitate a 

revision of the SIP where implementation of contingency measures is adequate to address the cause 

of the violation. The need for a SIP revision is subject to the EPA Administrator’s discretion. EPA 

states in its guidance that the agency will review what constitutes a contingency plan on a case-bycase basis. At a minimum, it is required that the state implement all measures contained in the SIP 

for the nonattainment area prior to its redesignation to attainment. 

 

19 See footnote 10. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 42

Despite New Hampshire’s best efforts to maintain compliance with air quality standards, the 

possibility exists that ambient ozone concentrations might at some future date exceed the NAAQS. 

Therefore, in accordance with the requirements of Section 175A(d), New Hampshire has identified 

various contingency measures that could be taken following an ozone “trigger” event and is 

committed to pursuing the following protocol: 

1. At the conclusion of each ozone season, NHDES will evaluate whether the 8-hour ozone 

design value for any ozone monitor in the redesignated planning area is above or below the 

1997 8-hour ozone standard (the “trigger”). The design value, in the case of this standard, is 

defined as the average of the annual 4th highest daily maximum 8-hour average concentration

for the preceding 3-year period. 

2. If the design value is above the standard for any ozone monitor, NHDES will investigate the 

cause and determine whether the exceedance is due to: 

• an increase in emissions from local, in-state sources; 

• an increase in emissions from upwind, out-of-state sources; or 

• exceptional event as defined in 40 CFR 50.1. 

3. If an increase in in-state emissions is determined to be a contributing factor to the 

exceedance, NHDES will evaluate the projected in-state emissions for the next ozone 

season. If the projected in-state emissions are not expected to decrease enough in the next 

ozone season to mitigate the violation, New Hampshire will implement one or more of the 

contingency measures listed below or will substitute other VOC or NOx control measures as 

necessary to achieve additional in-state emission reductions. 

4. The contingency measures(s) will be selected by the Governor or the Governor’s designee 

within six months of the end of the ozone season for which contingency measures have been 

determined to be needed. New Hampshire will then initiate a course of action to implement

enforceable control measure(s) to rectify the problem. New rulemaking can typically be 

adopted and implemented within a 12-month timeframe. NHDES will update the 

maintenance plan as necessary and develop and implement required regulations as soon as 

practicable within the guidelines established in the New Hampshire Administrative Procedures 

Act, but no later than 18 months after selection of the appropriate measure. 

New Hampshire is studying an array of possible contingency measures that would achieve further 

reductions in NOx and VOC emissions, including the following emission controls previously 

proposed by the Northeast states: 

• NOx controls for industrial, commercial, and institutional (ICI) boilers;

• VOC controls for emulsified and cutback asphalt paving; and 

• VOC controls for consumer products. 

These contingency measures are among several OTC control measures20 exceeding current on-thebooks/on-the-way (OTB/OTW) emission controls and serving as a subset of potential additional 

controls measures called beyond-on-the-way (BOTW). Details on BOTW control measures may be 

found in MACTEC’s report “Development of Emission Projections for 2009, 2012 and 2018 for 

NonEGU Point, Area and Nonroad Source in the MANE-VU Region,” Final Report, February 2007. 

 

20

 MACTEC Federal Programs, “Identification and Evaluation of Candidate Control Measures,” Final Technical Support 

Document, Ozone Transport Commission, February 28, 2007. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 43

Estimated emission reductions for New Hampshire from the three named control measures are given 

in Table 6-3. 

Table 6-3. Estimated Emission Reductions from Three BOTW Control Measures 

Control Measure Pollutant 2009 Estimated Emission 

Reductions (tons per day) 

ICI Boilers (OTC 2006 Model Rule) NOx 1.9 

Emulsified Asphalt Paving (OTC guidelines) VOC 4.4 

Consumer Products (OTC 2006 Model Rule) VOC 0.3 

Source: MACTEC, 2007 

These potential contingency measures are further described in subparts 6.5.1 through 6.5.3, below. 

6.5.1 ICI Boilers (at Major Point Sources) 

In 2006, the OTC commissioners recommended that the OTC member states pursue “as necessary 

and appropriate” state-specific rulemakings to establish required emission reduction percentages, 

emission rate performance standards, or control technologies to reduce emissions from industrial, 

commercial, and institutional boilers (OTC Resolution 06-02). The approximately 2-ton-per-day 

reduction in NOx emissions from ICI boilers reported in Table 6.3 was based on implementation of 

OTC’s recommended control levels on boilers of 25-250 MMBtu/hr heat input capacity at major 

point sources in New Hampshire. 

6.5.2 Emulsified Asphalt Paving 

NHDES is currently evaluating the proposed contingency measure for emulsified asphalt paving. 

OTC’s guideline would limit the VOC content of emulsified asphalt to 2 percent or less. The VOC 

content of emulsified asphalt in New Hampshire is assumed to be 2.5 percent at present. Thus, the 

estimated VOC emission reduction from this source category would be approximately 20 percent 

during the ozone season. 

6.5.3 Consumer Products 

The contingency measure for consumer products included in Table 6-3 would replace the OTC 2001 

VOC model rules with the OTC 2006 model rules, which provide amendments adopted by the 

California Air Resources Board (CARB) in July 2005. The amendments revise the existing VOC 

limit for contact adhesives and create VOC limits for nine new source categories (adhesive 

removers, electrical cleaner, electronic cleaner, fabric refresher, footwear or leather care, graffiti

remover, hairstyling products, toilet care, and wood cleaner). Based on estimates developed by 

CARB for 2009, these amendments would reduce VOC emissions by about 2 percent. 

6.5.4 Additional Controls on Boilers 

New Hampshire and the other OTC states have continued to investigate the possibility of additional 

controls on ICI boilers and utility boilers as stationary sources with the highest potential for NOx 

emission reductions. The additional controls would cover a wider range of boilers and would be 

more stringent than those described in the MACTEC report for non-EGU point sources and area 

sources in New Hampshire. More specifically, recent OTC proposals being considered by NHDES 

would provide additional NOx controls on the following boiler categories: 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 44

• Oil- and gas-fired boilers serving EGUs (OTC 2010 Model Rule): This proposed rule would 

impose the following NOx emission limitations on oil- and gas-fired utility boilers with a 

nameplate capacity of 25 MW or greater: for gas only, 0.08 lb/MMBtu; for oil or oil/gas, 

0.15 lb/MMBtu. 

• New small natural-gas-fired boilers and water heaters (OTC 2010 Model Rule): This proposed 

rule would establish NOx emission standards for various devices ranging in size from 75,000 

to 5,000,000 Btu/hr. 

• ICI boilers: Stricter NOx emission standards would be extended to any ICI boiler above a 

certain size threshold, e.g., 25 MMBtu/hr. 

Since 2006, OTC and the Lake Michigan Air Directors Consortium (LADCO) have worked 

collaboratively to assess the technical and economic feasibility of enhanced emission controls on ICI 

boilers of all sizes.21 A NESCAUM study22 from the same time period examined a variety of 

technologies available to reduce NOx emissions from ICI boilers with heat input ratings from as low 

as 10 MMBtu/hr to as high as 1,000 MMBtu/hr. It was determined that emission reductions of 5 to 

90 percent are achievable, depending on boiler size, fuel type, and chosen technology. Generally, 

the higher control efficiencies are applicable to larger ICI boilers, of which New Hampshire has 

relatively few. 

NHDES is gathering data on New Hampshire’s current stock of ICI boilers by size, fuel type, and 

existing control level. Preliminary data indicate that approximately 80 percent of ICI boilers in the

state have heat input ratings less than 25 MMBtu/hr and lack NOx controls. Another 13 percent 

have heat input ratings less than 50 MMBtu/hr and lack NOx controls. These units – most of them 

burning fuel oil – account for more than half of all NOx emissions from ICI boilers in the state. 

Boilers with heat input ratings above 100 MMBtu/hr, while far fewer in number, would generally 

have some existing level of NOx controls. Given all of these facts, NHDES anticipates that any 

reasonable control program for ICI boilers in New Hampshire would be capable of reducing overall 

NOx emissions from this sector by 25 percent or more.

Ongoing state and regional initiatives to control boiler emissions are overlain by EPA’s proposed or 

final rules pertaining to National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

industrial, commercial, and institutional (ICI) boilers at major sources and area sources; NESHAP 

for coal- and oil-fired electrical generating units; and New Source Performance Standards (NSPS) for 

fossil-fuel-fired electric utility and ICI boilers. Under these rules, affected sources would be subject 

to mandatory new emission limits and/or periodic boiler tune-ups that would yield direct emission 

reductions or indirect co-benefits with respect to NOx and VOC control. 

6.5.5 Other Contingency Measures 

NHDES is evaluating other potential NOx and VOC control measures that could be applied, if 

necessary, to further reduce ozone levels in the maintenance area. These control measures are listed 

in Table 6-4 along with the previously mentioned contingency measures for boilers, asphalt paving, 

and consumer products. 

 

21 OTC and LADCO, “Evaluation of Control Options for Industrial, Commercial and Institutional (ICI) Boilers,” 

Technical Support Document, Final, May 14, 2010. 

22 NESCAUM, Applicability and Feasibility of NOx, SO2, and PM Emission Control Technologies for Industrial, 

Commercial, and Institutional (ICI) Boilers, November 2008. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 45

Table 6-4. Potential Contingency Measures for Reducing Ozone Levels

Control Measure Source Category 

NOx Control Measures 

Oil and Gas Boilers Serving EGUs (OTC 2010 Model Rule) Major Point 

New Small Natural-Gas-Fired Boilers and Water Heaters (OTC 2010 Model Rule) Area* 

ICI Boilers Area or Major Point 

Stationary Generators (OTC 2010 Model Rule) Area 

Motor Vehicle Anti-Idling (mandatory, not voluntary) Onroad Mobile 

California Low-Emission Vehicles (CALEV) Standards Onroad Mobile 

Low-Carbon Fuel Standard (regional) Onroad Mobile / Nonroad 

VOC Control Measures 

Large above-Ground Storage Tanks (OTC 2010 Model Rule) Major Point 

Emulsified and Cutback Asphalt Paving (OTC guidelines) Area 

Adhesives and Sealants Application (OTC 2006 Model Rule) Area 

Architectural and Industrial Maintenance Coatings (OTC 2009 Model Rule) Area 

Solvent Cleaning (OTC 2009 Model Rule) Area 

Consumer Products (OTC 2006 Model Rule) Area 

Consumer Products (OTC 2010 Model Rule) Area 

Motor Vehicle and Mobile Equipment Non-Assembly Line Coatings Operations 

(OTC 2009 Model Rule) Area 

*Area sources include minor emission sources, typically large in number and widely distributed. 

7. ADMINISTRATIVE DOCUMENTS 

In accordance with the requirements for SIP submissions established in 40 CFR 51.103, the following 

documentation is herewith provided as integral to this redesignation request: 

• A formal letter of submittal from the Governor or his designee, requesting EPA approval of 

this SIP revision; 

• Evidence that NHDES has the necessary legal authority under state law to adopt and 

implement the plan. 

• Evidence that public notice was given of the proposed change consistent with procedures 

approved by EPA, including the date of publication of such notice. 

• Certification that public hearing(s) were held in accordance with the information provided in 

the public notice and the state's laws and constitution, if applicable and consistent with the 

public hearing requirements in 40 CFR 51.102. 

• Compilation of public comments and the state's response thereto. 

Documentation of legal authority, public notice, certification of the public process, and public 

comments and responses are provided in Attachment E. 
Request for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 46

8. SUMMARY AND CONCLUSIONS 

NHDES is requesting redesignation of the Southeast New Hampshire Nonattainment Area from 

moderate nonattainment to attainment for the 1997 National Ambient Air Quality Standard for 8-

hour ozone. Section 107(d)(3)(E) of the Clean Air Act establishes the requirements that an area 

must meet in order to be considered for redesignation. The following summarizes how the 

nonattainment area meets the essential criteria for redesignation: 

• The area has attained the 8-hour ozone standard. All four ozone monitoring sites within the 

nonattainment area have had ozone design values below the 1997 8-hour ozone standard for 

each year since 2006 (see Figure 2-4 and Attachment B). In addition, all other ozone 

monitoring sites throughout the state have shown levels below this standard.

• The state has an approved/approvable State Implementation Plan under CAA Section 110(k). 

New Hampshire’s approved SIP is published in the Code of Federal Regulations at 40 CFR 

52 Subpart EE. The implementation plan includes revisions to demonstrate attainment of 

the former 1-hour ozone NAAQS (67 FR 72574, December 6, 2002) and to meet reasonable 

further progress requirements for the former standard (3 FR 67405, December 7, 1998, and 

67 FR 18493, April 16, 2002). Consistent with EPA’s Clean Data Rule, certain SIP 

elements related to attainment of the 8-hour ozone NAAQS, including an attainment 

demonstration, a reasonable further progress plan, contingency measures, and other plan 

elements, have been suspended (73 FR 14387, March 18, 2008). The approved SIP 

incorporates rules implementing NOx and VOC RACT requirements (see Table 4-2).

• The improvement in air quality is due to permanent and enforceable emission reductions 

resulting from implementation of the SIP and other federal requirements. The vast majority 

of ozone-causing air pollutants in New Hampshire originate from sources in upwind states. 

Federally mandated programs such as the NOx SIP Call have made it possible for groundlevel ozone concentrations in the nonattainment area to reach attainment levels. Also 

contributing to local air quality improvements are New Hampshire regulations to control 

NOx and VOC emissions from diverse sources. Tables 4-1, 4-2, and 4-3 identify permanent 

and enforceable emission control measures that have resulted in statewide attainment for 

ozone. Table 4-4 shows the substantial decline in both NOx and VOC emissions from instate sources between 2002 and 2008.

• The state has prepared an approved/approvable maintenance plan under Section 175A. 

NHDES has prepared the requisite attainment inventory, maintenance demonstration, and 

contingency plan, and will continue to operate an appropriate air quality monitoring network 

to assure that the area stays in attainment of the 8-hour ozone standard after redesignation 

(see 6. MAINTENANCE PLAN). A comparison of NOx and VOC emission inventories for 

2008, 2012, and 2022 (Table 6-1) indicates continuing, substantial emission reductions for 

both types of ozone precursors in the next decade.

• The state has met all Title I, Part A, Section 110, and Part D requirements for the area. 

New Hampshire has satisfied the requirements of Section 110 related to emission reporting 

and recordkeeping, periodic testing and inspection of emission sources, transportationrelated emission control measures, continuous monitoring and recording, and legal authority 

and emergency powers. The state has also met Part D requirements for nonattainment areas, 

providing assurance of future attainment through continued implementation of appropriate 

emission control and monitoring measures and attention to anti-backsliding requirements. 

(See 5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT.)
ATTACHMENT A 

Technical Support Document 

for 

Redesignation of the Boston-Manchester-Portsmouth (SE), NH 

8-Hour Ozone (1997 Standard) Nonattainment Area 
This page intentionally left blank. 
Technical Support Document 

for 

Redesignation of the Boston-Manchester-Portsmouth (SE), NH 

8-Hour Ozone (1997 Standard) Nonattainment Area 

September 2010 

Air Resources Division 
TSD for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page i

Table of Contents 

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

2. NATURE OF OZONE AIR QUALITY PROBLEM IN THE NORTHEAST............................2 

2.1 OZONE PRODUCTION .....................................................................................................2 

2.2 AIR POLLUTION TRANSPORT MECHANISMS............................................................2 

2.2.1 High-Elevation Transport ...........................................................................................5 

2.2.1.1 Aircraft Measurements.......................................................................................5 

2.2.1.2 Mt. Washington, New Hampshire .....................................................................7 

2.2.1.3 Pack Monadnock Mountain – Miller State Park, New Hampshire....................9 

2.2.2 Mid-Elevation Transport.............................................................................................9 

2.2.3 Low-Elevation Transport .......................................................................................... 10 

2.2.3.1 Sea Breeze........................................................................................................ 10 

2.2.3.2 Offshore Transport........................................................................................... 11 

2.3 THE DEVELOPMENT OF AN OZONE EPISODE......................................................... 12 

2.4 NOx vs. VOC CONTROL STRATEGIES EFFECTIVENESS ........................................ 14 

3. ATTAINMENT MODELING ................................................................................................... 15 

3.1 MODELING METHODOLOGY ...................................................................................... 15 

3.1.1 Identification of Models and Domain Used.............................................................. 15 

3.1.2 Emissions Processing Methodology ......................................................................... 17 

3.1.3 Meteorology Processing Methodology ..................................................................... 21 

3.1.4 Model Testing ........................................................................................................... 23 

3.1.5 Establishing Estimates of Future Design Values ...................................................... 25 

3.2 CMAQ AND CALGRID MODELING RESULTS........................................................... 25 

3.3 EPA’s CAIR MODELING ................................................................................................ 28 
TSD for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page ii 

List of Figures 

Figure 2-1 Major Transport Regimes in the Northeast .................................................................3 

Figure 2-2 Typical Day/Night Ozone Cycle at Ground Level and Aloft ......................................4 

Figure 2-3 Number of 8-Hour Ozone Events Exceeding 85 ppb..................................................4 

Figure 2-4 How Upper-Level Transport Works............................................................................5 

Figure 2-5 Observed Vertical Ozone Profile Measured Above Poughkeepsie, NY .....................6 

Figure 2-6 Aircraft Ozone Observations in the Northeast ............................................................7 

Figure 2-7 Comparison of Average and Hourly Summer Ozone Concentrations.........................8 

Figure 2-8 Computer Model Illustration of the Low-Level Jet in the Northeast ..........................9 

Figure 2-9 How the Sea Breeze Works....................................................................................... 10 

Figure 2-10 Offshore Ozone Measurements from the Scotia Prince ............................................ 12 

Figure 2-11 Bermuda High Synoptic Scale Transport .................................................................. 13 

Figure 3-1 Map of the CMAQ/CALGRID Modeling Domain ................................................... 16 

Figure 3-2 Map of the RPO National Domain ............................................................................ 17 

Figure 3-3 QA/QC Plot of Surface Source CO Emissions ......................................................... 19 

Figure 3-4 QA/QC Plot of Surface Source VOC Emissions....................................................... 19 

Figure 3-5 QA/QC Plot of Point Source NOx Emissions........................................................... 20 

Figure 3-6 QA/QC Plot of Point Source SO2 Emissions............................................................ 20 

Figure 3-7 QA/QC Plot of Humidity Data.................................................................................. 21 

Figure 3-8 QA/QC Plot of Temperature Data............................................................................. 22 

Figure 3-9 QA/QC Plot of Rainfall Data .................................................................................... 22 

Figure 3-10 Relative Bias between Maximum 8-Hour Ozone Concentrations Predicted 

with CALGRID and Observed Values ...................................................................... 24 

Figure 3-11 Comparison of Modeled Maximum 8-Hour Ozone Concentrations ......................... 24 

Figure 3-12 CMAQ SIP-Quality Modeling Results for 2009 OTB/OTW vs. 2002 

Design Values............................................................................................................ 27 

Figure 3-13 Plot of 2009 Estimated Design Values for the OTC 2009 OTB/OTW Strategy....... 27 

Figure 3-14 Plot of Differences in Predicted Maximum 8-Hour Ozone Concentrations 

between 2002 Base Case and the OTC 2009 OTB/OTW Strategy ........................... 28 

List of Tables 

Table 2-1 Night and Daytime Patterns of Ozone at Mt. Washington..........................................8 

Table 3-1 Modeling Emissions Inventory: State-by-State Anthropogenic NOx ....................... 18 

Table 3-2 CMAQ Maximum Modeling Statistics for 2002 Base and 2009 OTB/OTW........... 25 

Table 3-3 CALGRID Maximum Modeling Statistics for 2002 Base, 2009 OTB/OTW, 

and 2009 Sensitivity Runs......................................................................................... 26 

Table 3-4 Modeling Summary for New Hampshire Monitors................................................... 26 

Table 3-5 CAIR Modeling Results for New Hampshire for 8-hour Ozone (ppb) ..................... 29 
TSD for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 1

1. INTRODUCTION 

This document is provided in support of New Hampshire’s request to EPA to redesignate the 

Boston-Manchester-Portsmouth (SE), NH nonattainment area (hereinafter referred to as the 

Southeast New Hampshire Nonattainment Area) to attainment status. On June 15, 2004, EPA 

officially classified this portion of New Hampshire as a moderate nonattainment area for the 1997 

8-hour ozone Ambient Air Quality Standard (NAAQS) of 0.08 parts per million (ppm) (Federal 

Register, 69 FR 223857). For several years since this classification was made, the Southeast New 

Hampshire Nonattainment Area has been monitoring attainment for the 8-hour ozone standard under 

EPA’s Clean Data Policy.∗ This nonattainment area is therefore eligible for redesignation to 

attainment in accordance with the provisions of the Clean Air Act (CAA). 

The information presented in this report is presented in two parts. The following section provides a 

conceptual description of the formation and transport of ozone in the Northeast. This information is 

useful in setting the context for New Hampshire's ozone redesignation request. Section 3 discusses 

a photochemical air quality modeling assessment that was undertaken in 2007 by New Hampshire 

and other Ozone Transport Region states. This modeling effort was performed in support of states' 

attainment demonstrations and for other SIP planning purposes, and is therefore not a specific 

component of this redesignation request. Nevertheless, it is presented here because it supports the 

conclusion that the improvement in New Hampshire's air quality is due to permanent, enforceable 

emissions control measures and is not simply an anomaly (due to cooler weather conditions, for 

example). 

 

∗ Using monitoring data for the period 2002-2007, EPA determined that the Southeast New Hampshire 8-hour Ozone 

Nonattainment Area (moderate) had reached attainment of the 8-hour ozone NAAQS. A final rule published on March 

18, 2008 (73 FR 14387), effective on that date, suspended the requirements for this area to submit an attainment 

demonstration, a reasonable further progress plan, contingency measures, and other State Implementation Plan elements 

related to attainment of the 8-hour ozone NAAQS. This determination is consistent with EPA’s Clean Data Policy, which 

exempts the state from certain SIP requirements if the area has three consecutive years of air quality data showing it 

meets the NAAQS, for as long as the area continues to attain the standard. 
TSD for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 2

2. NATURE OF OZONE AIR QUALITY PROBLEM IN THE NORTHEAST 

In order to form an effective ozone reduction plan for the State of New Hampshire, an 

understanding of ozone formation, source areas, wind patterns, and transport is necessary. The 

formation and transport of ground level ozone is a complex phenomenon affected by several 

variables. 

2.1 Ozone Production 

Ozone is formed in the atmosphere when NOx combines with VOCs in the presence of sunlight. 

Consequently, solar energy, mixing conditions, and relative NOx and VOC concentrations within an 

air mass are paramount to ozone formation. 

Typically, high pressure systems cause an air mass to flow downward, a phenomenon which 

increases ground level ozone concentrations in at least four ways: 1) the sinking motion of the air 

mass under high pressures stabilizes the air mass, reducing cloud formation and resulting in an 

increase in solar energy, thus increasing photochemical activity; 2) the sinking motion tends to keep

locally produced precursor emissions nearer to the surface, thus limiting upward movement and 

dilution of the air mass; 3) ozone and its precursors, present at higher elevations (500 to 1500 

meters) as a result of transport, are pushed down toward the ground; and 4) the sinking air raises the

ground level pressure, generating more heat at ground level. The result is a greater supply of ozone 

and precursors at or near ground level, more reaction energy in the form of heat and sunlight, and 

relatively limited dilution in the air mass. Additionally, the clockwise airflow pattern around a high 

pressure system transports pollutants northward and then eastward from the industrial Midwest or 

along the Northeast Urban Corridor to New England. These meteorological conditions are typical 

when New Hampshire monitors elevated levels of ground level ozone. 

2.2 Air Pollution Transport Mechanisms 

The predominant transport patterns in the Northeast were observed and documented in a study 

conducted by the North American Research Strategy for Tropospheric Ozone - Northeast 

(NARSTO/NE) entitled "Initial Results on Transport and Mixing Based on NARSTO-Northeast 

Data," and dated January 28, 1997. This study identified three basic flow regimes: synoptic, 

channeled, and near surface (Figure 2-1). 

• The Synoptic flow is the pattern of airflow at higher elevations (above 2600 feet). Synoptic 

flows are unaffected by large-scale frictional ground-level objects such as mountains, 

valleys, and lakes. 

• Channeled flows occur at lower elevations (650 to 2600 feet) where synoptic flow patterns 

are interrupted by large objects such as mountains, hills, and valleys but are not affected by 

lower, smaller objects such as trees and buildings.

• Low-level jets occur nocturnally along the eastern edge of the Appalachians. Although they 

somewhat resemble channeled flow, low-level jets are compact, relatively high-speed 

airflows that occur just above ground level. The speed of flow is made possible by the 

compression of converging airflows and the frictionless surface caused by the nocturnal 

thermal inversion, which the jet rides on. 

• Near-surface flows (below 650 feet) are affected by nearly all surface frictional objects, 

including trees and buildings. 
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Synoptic flows are generally from west to east, transporting pollution from the Midwest to the 

Northeast, while channeled flows generally follow the Appalachian Mountains from southwest to 

northeast, transporting pollution from the Northeast urban corridor toward northern New England. 

Figure 2-1 - Major Transport Regimes in the Northeast 

Absent transport, ground-level ozone concentrations increase during sunlight hours as a result of 

photochemical production and decrease substantially at night when ozone removal exceeds 

production (this is also known as diurnal variation or fluctuations within the daily cycle). However,

in areas such as New Hampshire, which are downwind of large urban regions, ozone concentrations 

often rise through the evening and/or early morning hours and peak between 6:00 p.m. and 6:00 

a.m. due to transport from upwind sources. At higher elevations, concentrations of ozone and ozone 

precursors may remain high at night, since there is minimal downward mixing of the atmospheric 

transport layers at night. During daylight hours when solar energy heats the ground, the resulting 

warm air near the ground begins to rise. Rising air creates an unstable atmospheric situation 

resulting in the upward and downward mixing of air masses (including ozone transport layers). 

Thus, ground level ozone concentrations typically rise for several hours immediately after sunrise 

(Figure 2-2). 

Long-range (synoptic scale) transport occurs from west to east across the Appalachian 

Mountains. Regional scale transport in channeled flows also occurs from west to east through 

gaps in the Appalachian Mountains and in nocturnal low level jets from southwest to northeast 

over the Northeast Corridor. Daytime sea breezes can affect local coastal areas by bringing in 

air pollution originally transported near the surface across water parallel to the coast (e.g., 

along the Maine coastline). Figure from NARSTO, 2000, citing Blumenthal et al., 1997. 
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-73.0 -72.0 -71.0

-73.0 -72.0 -71.0

42.0

43.0

44.0

45.0

42.0

43.0

44.0

45.0

Longitude

Latitude

for Each Ground-Level Wind Direction (1995 - 2002)

5

6

8

8

13

38

13

41

25

26

Claremont

Keene

Laconia

Concord

Manchester

Nashua

Rochester Kittery

Portsmouth

Rye

- Monitor Meets the 8-Hour 

 Ozone Standard for Health.

- Monitor Does NOT Meet the 8-Hour 

 Ozone Standard for Health.

Haverhill

0 Conway

1

Miller S.P.

7 Brentwood

13

Note: Brentwood starts 1999

 Rochester starts 1996

 Miller S.P. (elev = 2288') starts 8/2002

Wind directions at the time 

unhealthy ozone levels were 

measured in New Hampshire 

between 1995 and 2002: There is 

an overwhelming trend of winds 

coming into the state from the 

southwest, with the exception of 

the seacoast area which also 

suffers from a sea breeze that 

brings pollution from the Boston 

metro area to coastline 

communities. (Numbers indicate 

the number of unhealthy days.) 

Source: NHDES 

Figure 2-2 - Typical Day/Night Ozone Cycle at Ground Level and Aloft 

 

NHDES investigated weather conditions that lead to poor air days in the state. Generally, the 

majority of the ozone transported into the state comes from the Northeast corridor (Washington, 

DC, Baltimore, Philadelphia, New York, and Boston regions) (see Figure 2-3). On certain days, the 

Boston area provides the greatest amount of ozone along the immediate New Hampshire seacoast. 

The non-New England portion of the corridor provides the majority of the ozone for the remainder 

of New Hampshire. Air pollution contributions from the Midwest are significant and on some days 

provide the vast majority of pollution reaching New Hampshire. New Hampshire has its worst air 

pollution days when low-elevation winds come from the cities to our southwest (Northeast 

Corridor) and mid-elevation winds come from the Midwest. The smoggiest days occur when there 

is a slow airflow from the Midwest. 

Figure 2-3 - Number of 8-Hour Ozone Events Exceeding 85 ppb 

and Corresponding Wind Direction (1995-2002) 

Solar ultraviolet energy helps to create ozone 

which is present in high quantities late in the day. 

At night, there is no ultraviolet sunlight to create 

ozone and ground level objects and gases act to 

remove ozone, resulting in the curve in blue, 

which represents ozone at ground level. Ozone at 

higher elevations, conversely, is often not 

depleted at night and may remain at elevated 

concentrations throughout the day (red curve). 
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2.2.1 High-Elevation Transport 

Pollution transport should not be thought of only as a horizontal phenomenon. Pollutants can move 

upwards in the air and then travel downward in sinking air currents after being transported over 

great distances at elevations above 2,500 feet (Figure 2-4). 

Figure 2-4 - How Upper-Level Transport Works

2.2.1.1 Aircraft Measurements 

Measurements several thousand feet above the ground may record much higher ozone overnight than 

that measured at ground level. For example, ozone aloft concentrations above Poughkeepsie, NY and 

New Haven, CT approached levels of 120 ppb or greater on the night of July 14 (Zhang & Rao, 1999). 

Figure 2-5 displays the aircraft measurements above Poughkeepsie, NY around 4 a.m. EST. 

Aircraft measurements by the NARSTO-NE during the July 1995 ozone episode also demonstrate 

the existence of significant transport into and within the region, contributing to exceedances of the 

ozone standard in Maine (Blumenthal et al., 1997). Several "spiral" flights a few thousand feet 

above Poughkeepsie, NY, Gettysburg, PA, and Shenandoah, VA, recorded ozone levels of 100 ppb 

or greater in the early morning (4 AM) on two days. One aircraft actually recorded an ozone 

concentration well above 120 ppb at an elevation of approximately 2600 feet above Poughkeepsie 

on July 14, 1995, when ground level ozone measured about 30 ppb. Another flight during the early 

morning of July 14, 1995, from Virginia to Maine recorded ozone levels in the range of 70 to 100 

ppb at an elevation of 1600 feet throughout the Northeast corridor. 

These elevated ozone concentrations measured in the early morning at high elevations suggest that 

the ozone and its precursors originated during the active times of the previous day (or days) and 

traveled up and away from the source locations. Spiral flights in the afternoon over the same three 

New 

Hampshire

NOx

VOC

SO2

PM

Hg

Pollution 

Sources

During the 

heating of the 

day, pollutants 

mix upward.

Air pollutants get picked up and carried by the 

upper level winds

Pollutants can 

mix down the 

same way they 

came up OVER

UP

DOWN
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cities, measured uniform ozone levels from ground level to 2600 feet, showing that the air had 

become well mixed during the day and had thus brought transported ozone aloft down to the 

surface. A second flight along the length of the entire corridor showed that ozone levels at 1600 feet 

had risen well above 120 ppb in the Baltimore-Washington and New York metropolitan areas. 

Being well above the ground, this ozone was presumably destined to be transported further 

downwind overnight. 

Figure 2-5 - Observed Vertical Ozone Profile Measured Above Poughkeepsie, NY 

at about 4 AM EST on July 14, 1995 

On behalf of the Mid-Atlantic Northeast Visibility Union (MANE-VU), additional aircraft 

measurements were taken to track a regional haze event in the Northeast in August of 2002 (Figure 

2-6). The aircraft measured light scattering from particles as well as ozone. Like the earlier 

NARSTO-NE measurements, the MANE-VU study found high levels of ozone aloft which were 

blowing toward the northeastern states. In most cases, the ozone measured aloft exceeded 

measurements collected at ground level, indicating that the ground-level ozone was not all created 

locally. It is also noteworthy that the preliminary measurements collected above Baltimore, MD 

were already rich in ozone, suggesting that a large amount of the pollutant was blowing into the 

region from upwind areas. It should be noted that ozone aloft is depleted much more slowly than 

ozone at ground level, which comes into contact with various surfaces and obstructions. This means 

that, once ozone is present at high elevations, it becomes more likely to travel long distances 

downwind without breaking down. 
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Figure 2-6 - Aircraft Ozone Observations in the Northeast 

Other aircraft measurements reinforce these observations. Clarke and Ching (1983) during the 

summer of 1979 recorded aloft ozone concentrations of about 90 ppb transported overnight from 

eastern Ohio and entering into the Northeast Corridor over a region stretching from the lower 

Hudson River Valley north of New York City down across eastern Pennsylvania and into Maryland 

just west of Baltimore. The measurements also observed NOx aloft during the overnight hours that 

could contribute to additional ozone formation in the Ozone Transport Region as it mixed down to 

the surface in the morning. 

The presence of high levels of ozone and precursors aloft across a large spatial region gives rise to 

the concept of an “ozone reservoir” existing at night just above the nocturnal inversion boundary. 

The pollutants in this reservoir are not subject to destruction at the surface and can be transported 

long distances in the wind flows created by the synoptic scale weather patterns conducive to ozone 

formation and transport. 

2.2.1.2 Mt. Washington, New Hampshire 

Mt. Washington in Pinkham Notch, New Hampshire, is tall enough (elev. 6288 feet) to reach well 

up into the upper ozone transport layers with minimal obstruction by other terrain features. Ozone 

levels recorded at the summit mirror NARSTO-NE findings, showing consistently elevated levels of 

ozone with little diurnal variation during most episodes – clear evidence of long range transport. As

further evidence of long range transport, Camp Dodge (elev. 2400 feet), located at the base of Mt. 

Washington, usually records lower ozone concentrations than those seen contemporaneously at the 

summit. 
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Comparison of mountaintop 

(elev. 6288 ft) ozone with 

mountain base (elev. 2000± ft) 

hourly ozone: Often the ozone 

is higher in concentration at the 

summit due to pollution 

transport from distant sources. 

Many times the ozone at the 

base is driven by downward 

mixing from the upper transport 

layers during the day. 

Source: NHDES (Data: AMC) 

Both monitors have no major NOx sources within 75 miles and no major sources upwind in the 

direction of prevailing winds for approximately 150 miles. Transport from more distant upwind 

sources is the primary source of ozone monitored at these sites. Since the summit of Mt. 

Washington is high enough to be exposed to high elevation transport (synoptic flows), downward 

mixing is not a factor in creating the peak ozone values it experiences. In fact, transport time from

upwind source areas appears to be the single largest factor in determining the time at which the 

maximum ozone level occurs at the summit. Daily maximum ozone levels at Camp Dodge are 

dependent on inversion breakup caused by downward mixing from upper transport elevations, and 

thus are typically recorded during the afternoon hours. On the contrary, maximum ozone levels at 

the summit occur most often during the overnight hours, when no ozone is produced locally. The 

percent of daily one-hour ozone maxima which occur during the daylight heating hours and during 

the overnight hours on the summit of Mt. Washington and at Camp Dodge are listed in Table 2-1. 

Table 2-1 - Night and Daytime Patterns of Ozone at Mt. Washington 

Mt. Washington 

Monitor Location 

Percent of Hourly Maxima 

During Daylight Hours 

(9 a.m. to 5 p.m.) 

Percent of Hourly Maxima 

During Overnight Hours 

(6 p.m. to 8 a.m.) 

Summit 18% 82% 

Base (Camp Dodge) 80% 20% 

Note: Daylight heating hours are hours of the day when solar energy drives vertical mixing of 

transport layers 

The difference in ozone concentrations at the summit and base can also be seen when looking at 

plots of maximum ozone levels at each site. The graph in Figure 2-7 is typical of summertime 

ozone at Mount Washington. 

Figure 2-7 - Comparison of Average and Hourly Summer Ozone Concentrations 

at the Base and Summit of Mt. Washington 

 
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2.2.1.3 Pack Monadnock Mountain – Miller State Park, New Hampshire 

A similar mountaintop air pollution monitor was established in 2002 in Miller State Park at the 

summit of Pack Monadnock Mountain in Peterborough, NH (elevation 2288 feet). The mountain is 

located in the south-central portion of New Hampshire in an ideal location to track air pollution 

transport into the state. The monitor is only a short distance from the heavily visited and hiked Mt.

Monadnock. The early findings from this monitor are similar to those of Mt. Washington in that 

when an ozone or PM2.5 episode begins to build into the region, it is detected at higher elevations 

first where the stronger transport currents are located. The new Miller State Park monitor has been 

useful in tracking air pollution events entering the populated Merrimack Valley area (Nashua, 

Manchester, and Concord). 

2.2.2 Mid-Elevation Transport 

Mid-elevation transport is usually dominated by the effects of large topographical features, such as 

mountains, which redirect airflows and cause a channeling of the wind. In the Northeast, channeled 

airflows may occur on either side (east or west) of the Appalachian Mountain range and also 

between the subranges that comprise the Appalachian chain. Unhealthy air quality can be present 

on one side of a mountain while just a few miles away on the other side, the air quality is 

substantially cleaner. This mid-layer is generally heavily influenced by the airshed layers above and

below that mix polluted, or clean air into it. Pollutants can also be injected directly into this layer by 

some of the very tall smoke stacks (around 1000 feet tall) commonly found in the Midwest. 

Mid-level transport is often affected by a phenomenon known as the low-level jet (LLJ). It is called 

“low-level” because it is lower relative to the well known Jet Stream, a high elevation airflow that 

drives the movement of weather systems around the world. Recent advances in remote sensing 

instruments (i.e., radar profilers) have allowed the LLJ phenomena to be observed. During the 

overnight and early morning hours, a LLJ frequently forms just east of the Appalachian Mountains. 

Once formed, the LLJ is a strong west to southwest wind flow that develops at low altitudes just 

above the nocturnal boundary layer. These winds typically reach speeds of 40-50 mph and are 

located at approximately 1,000-2,000 feet above the ground. Figure 2-8 depicts the LLJ observed 

during an August 2002 ozone event. 

Figure 2-8 - Computer Model Illustration of the Low-Level Jet in the Northeast 

9:00 PM 11:00 PM 01:00 AM

03:00 AM 05:00 AM 07:00 AM

The low level jet 

(shown in red, orange, 

and yellow) normally 

sets up along the 

eastern side of the 

Appalachian Mountains 

and flows from 

southwest to northeast.

Source: 

University of Maryland 
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2.2.3 Low-Elevation Transport 

A number of one-day and multi-day transport mechanisms have been observed along the 

northeastern coastal plain. Blumenthal et al., (1997) described several transport mechanisms, 

including near-surface flows that act within a thousand feet of the ground and are capable of 

transporting ozone and its precursors along the urban corridor as far as 160 miles during the daylight

hours. Near surface flows are especially useful in explaining the transport and presence of the 

elevated ozone concentrations monitored aboard the MS Scotia Prince in the Gulf of Maine 

(Portland, Maine ferry to Yarmouth, Nova Scotia, Canada). 

Other transport mechanisms, including boundary layer synoptic (upper level) flows and channeled 

(mid-level) nighttime flows are capable of transporting ozone and precursors as far as 600 km in a 

24-hour period and are responsible for longer range transport from the south and west (Blumenthal 

et al., 1997). 

Residence time (or the time a pollutant stays in the air) analysis (Wishinski and Poirot, 1995) is a 

technique whereby the spatial characteristics of long-term trajectory climatology can be analyzed by 

keeping track of the residence time (in hours) for selected back trajectories. This was done for 

several New England sites during the summers from 1989 through 1995. Back trajectories from 

Port Clyde, Maine show that for days on which Maine exceeds the ozone national ambient air 

quality standard (NAAQS), the wind is invariably from the south and west. These trajectories also 

show that the Northeastern Corridor is principally responsible for nonattainment in New Hampshire 

and Maine, with areas to the south and west of the Corridor having lesser, but still significant impacts. 

2.2.3.1 Sea Breeze 

The Atlantic Ocean produces changes in wind directions and wind speeds along the shoreline, 

especially in New England. While most inland areas experience regional wind patterns with only 

small variations due to terrain features and other frictional effects, coastal locations are far more 

variable. Sea breezes develop during the heating of the day when the ground heats up, warming the 

onshore air mass. This air mass then rises, causing cooler air near the surface to flow in from over 

the ocean (Figure 2-9). Sea breezes are actually a subset of the NARSTO-NE near-surface flows 

that are driven by temperature differences between land and water, which also affects changes in 

mixing heights. Daytime sea breezes flow from the relatively cool waters of the ocean towards the 

coast, and diminish over a short distance due to mixing with regional wind patterns persisting 

further inland and with diurnal mixing. 

Figure 2-9 - How the Sea Breeze Works 

 

The sea breeze is developed 

through the temperature 

differences between the 

ground and the water. As the 

sun warms the ground, it 

begins a cycle by causing the 

air to rise. This air cools as it 

moves over the water, sinks 

and then blows back towards 

the shore. 
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Onshore breezes are the primary reason that high ozone concentrations occur along the New 

Hampshire coast, while substantially lower concentrations are recorded just a few miles farther 

inland. The afternoon sea breeze shifts the wind direction to the south and east, bringing ozone from

over the ocean onshore. As documented by the NHDES and the Maine Department of Environmental 

Protection, these sea breezes develop suddenly and can drive ozone concentrations sharply upward. 

The offshore ozone blown in by sea breezes appears to originate from precursors emitted in the 

metropolitan Boston area. 

2.2.3.2 Offshore Transport 

Offshore, just beyond the strongest coastal sea breezes, larger scale wind fields develop that may 

differ in direction from the inland regional wind pattern. Lower mixing heights, differing 

temperature gradients, and lower frictional effects cause this differential. Off the New Hampshire 

and Maine coasts (Figure 2-10), it is not uncommon for the over-water wind field to come from the 

south, while the inland regional wind field is more from the southwest. This pattern allows transport

of the ozone plume from the metropolitan Boston area to travel over the Gulf of Maine to the New 

Hampshire coast, even when inland wind observations suggest this should not be happening. 

The North Atlantic Regional Experiment (NARE) measured surface level ozone and precursor 

concentrations at both coastal and offshore locations in the Gulf of Maine during August and 

September of 1993 (Ray et al., 1996). The researchers observed ozone plumes in the Gulf of Maine 

ranging in width from 55 to 93 km and extending the entire length of the New Hampshire and 

Maine coastlines. The timing of the observed peak ozone concentrations, the presence of elevated 

ozone levels only along the coast, and low NOx concentrations all suggest that urban plumes 

transported over the Gulf of Maine are brought inland by sea breezes to the coastal regions, and that 

regional control strategies will be needed to reduce ozone concentrations along the coast. 

Recent photochemical modeling utilizing the California Photochemical Grid Model (CALGRID) 

model (Earth Tech, 2006) serves to confirm the presence of an urban plume moving northeastward 

over the Gulf of Maine, where it is then carried by afternoon sea breezes to the coast. 

Along the New Hampshire and Maine coastlines, ozone levels have not been observed to exceed the 

NAAQS unless there is at least a moderate westerly to southwesterly wind at the surface. Typical 

ozone episodes are characterized by the concentration of transported ozone and precursors in the 

Gulf of Maine during the morning and mid-day hours, with afternoon sea breezes bringing high 

concentrations of ozone ashore in the afternoon and evening. Monitored ozone concentration data 

and measured wind vectors show ozone exceedances in Maine and New Hampshire to be the direct 

result of a large mass of both ozone and unreacted precursors being transported into the Gulf of 

Maine from areas to the south and west. Here, precursors react and are then transported ashore, a 

conclusion supported by data collected by monitors on both the MS Scotia Prince (see Figure 2-10) 

in the Gulf of Maine and on land-based monitors that show significantly decreased levels of ozone 

at inland sites (AIRS). 

Ozone air quality monitors within Maine and New Hampshire also confirm the presence and 

significance of transported ozone and its precursors. The ozone monitoring network in Maine 

extends along the coast from the photochemical assessment monitoring station (PAMS) located in 

Kittery, Maine (operated by the State of New Hampshire Department of Environmental Services) to 

as far north as Bar Harbor. Maximum ozone concentrations along the Maine coast almost always 

follow a sequential pattern, with the most southerly sites monitoring daily ozone maximums in the 
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mid to late afternoon, and downwind sites experiencing maximum readings later in the day and into 

the evening hours. 

Figure 2-10 - Offshore Ozone Measurements from the Scotia Prince 

SCOTIA PRINCE FERRY (86ppb)

KENNEBUNKPORT (67 ppb)

KITTERY (72 ppb)

PORT CLYDE (78ppb)

CAPE ELIZABETH 

(57 ppb)

REID STATE PARK (78 ppb)

MCFARLAND HILL (47 ppb)

CADILLAC MTN (46 ppb)

GARDINER (39 ppb)

WEST BUXTON 

(37 ppb)

NORTH LOVELL 

35 ppb)

RCIP 

(MM)

HOLDEN 

(43 ppb)

49 70 98 102 87 90 87 82 75 73

JULY 9, 2002

CASTINE 

(42ppb)

BUOY 44013 

WD 220-250 WS 3-5m/s

BUOY IOSN3

WD 230-260 WS 3-11 m/s

BUOY 44005

Wind Direction 220-240

Wind Speed 3-7 m/s

850mb270 deg @ 35 kts

925mb 250 deg @ 25 kts

HOURLY OZONE CONCENTRATIONS ON THE 

SCOTIA PRINCE FERRY 

(Maximum 8-hr Ozone Level)

 

 

2.3 The Development of an Ozone Episode 

Since the late 1970s, a wealth of information has been collected concerning the regional nature of 

the Northeast’s ground-level ozone air quality problem. Scientific studies have uncovered a rich 

complexity in the interaction of meteorology and topography with ozone formation and transport. 

The evolution of severe ozone episodes in the eastern U.S. often begins with the passage of a large 

high pressure area from the Midwest to the middle or southern Atlantic states, where it assimilates 

into and becomes an extension of the Atlantic (Bermuda) high pressure system (see example in 

Figure 2-11). During its passage east, the air mass accumulates air pollutants emitted by large coalfired power plants and other sources located outside the region. These expansive weather systems 

favor the formation of ozone by creating a vast area of clear skies and high temperatures. These two 

prerequisites for abundant ozone formation are further compounded by a circulation pattern 

favorable for pollution transport over large distances. In the worst cases, the high pressure systems

stall over the eastern United States for days, creating ozone episodes of strong intensity and long 

duration. 

The Scotia Prince ferry is a scheduled passenger and vehicle ferry that runs between Portland, Maine, and 

Yarmouth, Nova Scotia, Canada. This ferry has an ozone monitor that tracks air pollution levels during its 

journey between ports. The ferry often identifies distinct air pollution areas or plumes offshore over the Gulf 

of Maine. Source: MEDEP
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Figure 2-11 - Bermuda High Synoptic Scale Transport

With the knowledge of the different transport scales into and within the region, a conceptual picture 

of bad ozone days emerges. After sunset, the ground cools faster than the air above it, creating a 

nocturnal temperature inversion. This stable boundary layer extends from the ground to only a few 

hundred meters in altitude. Above this layer, a nocturnal low level jet can form with higher velocity

winds relative to the surrounding air. It forms from the fairly abrupt removal of frictional forces 

induced by the ground that would otherwise slow the wind. Absent this friction, winds at this height 

are free to accelerate, forming the nocturnal low level jet. Ozone above the stable nocturnal 

inversion layer is likewise cut off from the ground, and thus it is not subject to removal on surfaces

or chemical destruction from low level emissions. Ozone in high concentrations can be entrained in 

the nocturnal low level jet and transported several hundred kilometers downwind overnight. The 

next morning as the sun heats the Earth’s surface, the nocturnal boundary layer begins to break up, 

and the ozone transported overnight mixes down to the surface where concentrations rise rapidly, 

partly from mixing and partly from ozone generated locally. By the afternoon, abundant sunshine 

combined with warm temperatures promotes additional photochemical production of ozone from 

local emissions. As a result, ozone concentrations reach their maximum levels through the 

combined effects of local and transported pollution. 

Ozone moving over water is, like ozone aloft, isolated from destructive forces. When ozone gets 

transported into coastal regions by bay, lake, and sea breezes arising from afternoon temperature 

contrasts between the land and water, it can arrive highly concentrated. 

H
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During severe ozone episodes associated with high pressure systems, these multiple transport 

features are embedded within a large ozone reservoir arriving from source regions to the south and 

west of the OTR. Thus a severe ozone episode can contain elements of long range air pollution 

transport from outside the Northeast, regional scale transport within the OTR from channeled flows 

in nocturnal low level jets, and local transport along coastal shores due to bay, lake, and sea breezes. 

The recognition that ground-level ozone in the eastern United States is a regional problem requiring 

a regional solution marks one of the greatest advances in air quality management in the United 

States. During the 1990s, air quality planners began developing and implementing coordinated 

regional and local control strategies for NOx and VOC emissions that went beyond the previous 

emphasis on urban-only measures. These measures have resulted in significant improvements in air 

quality across the OTR. Measured NOx emissions and ambient concentrations have dropped 

between 1997 and 2005, and the frequency and magnitude of ozone exceedances have declined 

within the OTR. 

2.4 NOx vs. VOC Control Strategies Effectiveness 

The effectiveness of a NOx-focused or VOC-focused control strategy to reduce ozone is not 

constant by location; rather, it is a changing chemical characteristic of an air parcel affecting a 

particular location. As a result, the effectiveness of a NOx or VOC-focused control strategy can 

vary within an air parcel as it dynamically evolves over time with transport, dispersion, and 

photochemical aging (NARSTO, 2000). 

On a regional basis, OTAG (Ozone Transport Assessment Group), Clean Air Interstate Rule 

(CAIR), and other modeling studies have consistently shown that NOx reductions have the greatest 

impact on regional ozone concentrations, while VOC reductions have more local impacts. This is 

largely a result of significant naturally occurring VOC emissions (especially isoprene) in large 

forested regions of the eastern U.S. Real-world results from regional NOx reductions at power 

plants (i.e., the NOx SIP Call) are now indicating that significant ozone reductions are occurring on 

a regional basis as a result of regional NOx strategies. 

As a general rule, VOC reductions may be effective at reducing urban-scale ozone pollution in lieu 

of or in combination with local NOx reductions, while regional NOx controls are most effective at 

reducing regional ozone. While a general approach can be outlined in evaluating the potential 

effectiveness of NOx and VOC-focused control strategies, the optimal strategy for a specific 

location will depend on the particular circumstances of that location. Exceptions to a VOC-only 

strategy for an urban area can occur when the urban area has large natural VOC emissions, ozone is 

transported from upwind, or there is recirculation of aged local pollution (e.g., sea breeze effect). 

Furthermore, because the conditions causing individual ozone episodes can vary, a given urban area 

may change in sensitivity between a NOx and VOC-focused strategy depending on a particular 

episode’s conditions (NARSTO, 2000). Therefore, the appropriate combination of NOx and VOC 

controls at the local level depends on local circumstances with the realization that a single approach

focusing on NOx- or VOC-only controls is not necessarily effective for all episode types. It is clear, 

however, that regional NOx reductions provide regional ozone reductions, and this will influence 

ozone levels being transported into local urban areas. Thus, the most effective controls for New 

Hampshire are NOx based regional controls with local NOx and VOC based controls. 
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3. ATTAINMENT MODELING 

Air quality modeling to demonstrate New Hampshire’s attainment of the 8-hour ozone standard uses 

a regional photochemical modeling platform capable of estimating the distribution and magnitude of 

air pollutant concentrations within a reasonable range of error. Base-year and projected future year 

emissions inventories are used as input into the air quality model. Emission reduction strategies are

applied as needed. The results of the air quality modeling are applied in a relative sense by 

calculating the percent ratio of the future year modeling results (which reflect the emissions 

reduction strategies) to the base-year modeling results. This ratio is then applied to the observed 

base year design value to obtain a corresponding estimated future year design value. Known as the 

relative reduction factor (RRF) technique, this method follows EPA guidance; for further 

description see Section 3.1.5. 

3.1 Modeling Methodology 

For the 8-hour ozone analyses, New Hampshire relied on the regional photochemical air quality 

modeling that was conducted by the New York State Department of Environmental Conservation 

(NYSDEC) and other modeling centers on the Community Multiscale Air Quality (CMAQ) 

modeling platform. In addition, New Hampshire and other states used the California Photochemical 

Grid Model (CALGRID) screening-level modeling platform to evaluate additional emissions control 

scenarios and perform sensitivity runs. The general methodologies that were used in running both 

of these modeling platforms for the evaluation of 8-hour ozone are described in the sections below. 

3.1.1 Identification of Models and Domain Used 

The SIP-quality modeling that was done for the 8-hour ozone analyses was performed on the 

CMAQ modeling platform. Additional modeling was done on the CALGRID screening-level 

platform. The CMAQ and CALGRID platforms were run on the same modeling domain using a 

common set of model inputs. Specifically, the OTC ozone modeling domain was set up on a 

Lambert Conic Conformal projection and covers the eastern United States and parts of Canada. The 

southwest corner of the domain was set at 264 km, -888 km and the northeast corner was set to 2328 

km, 1176 km. A 12-km grid cell resolution was used with 172 grid cells in the east-west direction 

and 172 grid cells in the north-south direction. For the vertical grid definition, 22 layers were used 

in the CMAQ simulations. For CALGRID, processing programs were used to reformat the 

boundary conditions, meteorology, and emissions; these mapped the 22 layers used for CMAQ to a 

total of nine vertical layers for the CALGRID modeling. The OTC CMAQ/CALGRID modeling 

domain is shown in Figure 3-1. The OTC 12-km ozone modeling domain is a subset of the 36-km 

national domain which was used by the Regional Planning Organizations (RPOs) for regional haze 

analysis. The 36-km national grid is shown in Figure 3-2. 

For the CMAQ modeling, boundary conditions were derived from GEOS-Chem (Goddard Earth 

Observing System) global atmospheric simulations by running CMAQ on the 36-km continental 

grid. For the CALGRID platform, initial conditions, side boundary conditions, and top layer 

concentrations were derived from the CMAQ boundary conditions files by means of a processing 

program. This program mapped the 22 vertical layers used in the CMAQ simulations to the nine 

layers used with CALGRID. It produced the necessary side boundary file and top layer 

concentration file for each modeled episode day. It also produced an initial conditions file for each

episode day processed; these files could be retained so that the CALGRID user could begin a 
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simulation on any desired episode day. It should be noted that the default option of using 2002 

boundary conditions was employed for all of the base case and future year CMAQ and CALGRID 

simulations. 

Further details regarding the technical options used in the CMAQ simulations are available in 

NYSDEC’s technical support document TSD-1d, 8hr Ozone Modeling using the SMOKE/CMAQ 

system, February 1, 2006. Additional information on the CALGRID modeling platform can be 

found in NHDES’ Modeling Protocol for the OTC CALGRID Screening-Level Modeling Platform 

for the Evaluation of Ozone, May 23, 2007. 

Figure 3-1 - Map of the CMAQ/CALGRID Modeling Domain 

0 20 40 60 80 100 120 140 160

0

20

40

60

80

100

120

140

160
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Figure 3-2 - Map of the RPO National Domain 

3.1.2 Emissions Processing Methodology 

The base year and future year emissions inventories that were used in the regional photochemical air 

quality modeling for the 8-hour ozone analyses were prepared by the RPOs and their contractors. 

These inventories were processed for input into the CMAQ air quality model using the Sparse 

Matrix Operator Kernel Emissions (SMOKE) model. The SMOKE modeling was performed by 

NYSDEC and other modeling centers, including NESCAUM and the Virginia Department of 

Environmental Quality (VADEQ). Emissions processing was done for the 2002 Base Year and 

2009 On The Books/On The Way (OTB/OTW) modeling scenario. The OTB/OTW scenario 

accounted for those emissions control measures that were either on the books or reasonably 

anticipated to occur. The 2002 Base Year and 2009 OTB/OTW emissions are summarized by state 

in Table 3-1. Further details on the SMOKE processing that was done in support of the 8-hour 

ozone analyses are provided in NYSDEC’s technical support document TSD-1c, Emission 

Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations, 

September 19, 2006. 
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Table 3-1 - Modeling Emissions Inventory: State-by-State Anthropogenic NOx 

State 

2002 

Baseline 

(tons/day) 

2009 

OTW/OTB 

(tons/day) 

Percent Reduction 

from 2002 Baseline 

Connecticut 232.16 149.41 35.64% 

Delaware 101.20 91.53 9.56% 

D.C. 29.13 18.30 37.18% 

Maine 170.64 109.75 35.68% 

Maryland 548.58 312.77 42.99% 

Massachusetts 483.18 312.68 35.29% 

New Hampshire 131.02 84.22 35.72% 

New Jersey 625.68 397.32 36.50% 

New York 1199.32 831.85 30.64% 

Pennsylvania 1614.24 1020.05 36.81% 

Rhode Island 89.78 57.60 35.84% 

Vermont 54.44 34.62 36.41% 

Virginia 975.74 673.39 30.99% 

Alabama 732.86 492.41 32.81% 

Arkansas 519.30 268.22 48.35% 

Georgia 1153.90 874.75 24.19% 

Kentucky 1043.23 641.29 38.53% 

Illinois 1797.25 1067.17 40.62% 

Indiana 1329.23 926.42 30.30% 

Michigan 902.07 812.06 9.98% 

Mississippi 356.48 271.04 23.97% 

Missouri 733.00 438.76 40.14% 

North Carolina 1141.21 744.30 34.78% 

Ohio 1379.28 848.93 38.45% 

South Carolina 660.35 481.35 27.11% 

Tennessee 1045.52 710.79 32.02% 

West Virginia 902.95 432.65 52.08% 

Wisconsin 667.49 447.50 32.96% 

For the CALGRID modeling effort, the pre-merged SMOKE emissions files were obtained from the 

modeling centers and re-formatted for input into EMSPROC, the emissions pre-processor for the 

CALGRID modeling system. EMSPROC allows the CALGRID user to adjust emissions 

temporally, geographically, and by emissions category for control strategy analysis. The pre-merged 

SMOKE files that were obtained from the modeling centers were broken down into the biogenic, 

point, area, non-road, and on-road emissions categories. These files by component were then 

converted for use with EMSPROC, thus giving CALGRID users the flexibility to analyze a wide 

variety of emissions control strategies. QA/QC plots were generated during the re-formatting of the 

emissions data to ensure that an accurate modeling inventory was generated for the CALGRID 

platform. Example emissions QA/QC plots are shown in Figures 3-3 through 3-6. 
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Figure 3-3 - QA/QC Plot of Surface Source CO Emissions 

Figure 3-4 - QA/QC Plot of Surface Source VOC Emissions 
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Figure 3-5 - QA/QC Plot of Point Source NOx Emissions 

Figure 3-6 - QA/QC Plot of Point Source SO2 Emissions 
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3.1.3 Meteorology Processing Methodology 

The meteorological modeling that was done for the CMAQ platform was performed by the 

University of Maryland (UMD) in conjunction with staff at NYSDEC. UMD used the Penn 

State/National Center for Atmospheric Research (NCAR) 5th Generation Mesoscale Model (MM5) 

Version 3.6 to generate year 2002 meteorological inputs. The MM5 modeling domain was set up on 

a two-way nested grid that followed the RPO national domain. The 36-km coarse mesh grid 

consisted of 149 grid cells in the east-west direction and 129 grid cells in the north-south direction. 

The 12-km fine mesh grid consisted of 175 grid cells in both the east-west and north-south 

directions. A total of 29 vertical layers were used in the MM5 simulations. An extensive analysis 

was undertaken to compare the MM5 predictions with observations for the period of May through 

September 2002. An assessment was made to compare MM5 outputs with surface observations 

from the National Weather Service and CASTNet, wind-profiler measurements from the 

Cooperative Agency Profilers (CAP) network, satellite cloud image data from the UMD Department 

of Atmospheric and Oceanic Science, and precipitation data from the Earth Observing Laboratory at 

NCAR. Technical details regarding the 2002 MM5 simulations and the assessment to compare 

them with observations are described in NYSDEC’s Technical Support Document TSD-1a, 

Meteorological Modeling Using Penn State/NCAR 5th Generation Mesoscale Model (MM5), 

February 1, 2006. 

For the CALGRID modeling platform, a processing program was used to interpolate the MM5 

outputs to the CALGRID modeling grid and map them to CALGRID’s vertical layer structure. 

QA/QC plots were generated during the processing to ensure the accuracy of the interpolated data. 

Figures 3-7 through 3-9 show example QA/QC plots from the re-formatting of the meteorological 

data for use with the CALGRID modeling platform. 

Figure 3-7 - QA/QC Plot of Humidity Data 

August 6, 2002 Hour 12

Humidity Layer 1

CALGRID 2.45 Modeling Domain

Humidity (ppm)

NHDES

7/18/06

400 600 800 1000 1200 1400 1600 1800 2000 2200

LCC Easting (km)

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-600

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Figure 3-8 - QA/QC Plot of Temperature Data 

August 6, 2002 Hour 18

Temperature Layer 1

CALGRID 2.45 Modeling Domain

Temp (K)

NHDES

7/23/06

400 600 800 1000 1200 1400 1600 1800 2000 2200

LCC Easting (km)

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-600

-400

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LCC Northing (km)

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Figure 3-9 - QA/QC Plot of Rainfall Data 

August 12, 2002 Hour 17

Rain

CALGRID 2.45 Modeling Domain

Rain (inches)

NHDES

7/17/06

400 600 800 1000 1200 1400 1600 1800 2000 2200

LCC Easting (km)

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3.1.4 Model Testing 

NYSDEC did an extensive quantitative analysis to evaluate predicted concentrations of ozone, as 

well as other gaseous and aerosol pollutants, against 2002 observations. This work is described in 

their technical support document TSD-1e, CMAQ Model Performance and Assessment, 8-Hr OTC 

Ozone Modeling, February 23, 2006. The authors used a wide variety of statistical metrics to assess 

the correlation of model predictions and observations, including: 

• Correlation coefficient 

• Normalized mean error 

• Root mean square error 

• Fractional error 

• Mean absolute gross error 

• Mean normalized gross error 

• Mean bias 

• Mean normalized bias 

• Mean fractionalized bias 

• Normalized mean bias 

NYSDEC also evaluated the diurnal patterns for those pollutant species that are reported hourly. 

With respect to 8-hour ozone, NYSDEC’s model performance evaluation showed that the CMAQ 

model performed reasonably and that it adequately reproduced the pattern of observations, 

especially in urban areas and along the northeast corridor. Their analysis showed some model 

under-prediction during the mid-August period. Their analysis also showed that the diurnal 

predictions for ozone tracked fairly well with observations. Detailed tables and figures illustrating

the CMAQ modeling platform’s performance evaluation are shown in NYSDEC’s technical support 

document TSD-1e. 

NHDES performed a qualitative and quantitative assessment of the CALGRID screening platform’s 

ability to reproduce observed ozone concentrations. To assess its performance, the CALGRID 

screening platform was run for the 2002 Base Case for the July 31 to August 16, 2002 modeling 

episode. Predicted maximum 8-hour ozone concentrations at monitor locations were compared 

against observations for 2002. Figure 3-10 shows the relative bias between maximum 8-hour ozone 

observations and predicted CALGRID 8-hour ozone concentrations for the 2002 Base Case for the 

episode from July 30 through August 12. Figure 3-11 shows a plot of predicted 2002 Base Case 

ozone concentrations against 2002 observations for an example episode day. Although the 

CALGRID model has a tendency to over-predict, especially in the urban core areas of northern 

Virginia, Maryland, southeastern Pennsylvania, New York City and Boston, it does a reasonable job 

of reproducing the pattern of the 2002 maximum ozone observations. 
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Figure 3-10 - Relative Bias between Maximum 8-Hour Ozone Concentrations Predicted with 

CALGRID and Observed Values 

Relative Bias (CALGRID minus Observed)

 -20 to -15

 -15 to -10

 -10 to -5

 -5 to -2

 -2 to 2

 2 to 5

 5 to 10

 10 to 15

 15 to 20

 20 to 50

Based on Model Data for 

July 30 - August 12, 2002

2002 Base Case Emissions

versus Observed Data

Green Circles are where

CALGRID Underpredicts

Red Triangles are where

CALGRID Overpredicts

NHDES 11/21/06

Figure 3-11 - Comparison of Modeled Maximum 8-Hour Ozone Concentrations 

for August 13, 2002 

Maximum 8-Hour Ozone Concentrations

CALGRID - 2002 Base Case

OTC Modeling Domain - August 13, 2002

Ozone

Concentrations

(PPB)

NHDES

11/27/06

 0 to 40

 40 to 50

 50 to 60

 60 to 70

 70 to 80

 80 to 90

 90 to 100

 100 to 150
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3.1.5 Establishing Estimates of Future Design Values 

In accordance with EPA guidance, future design values for regional modeling were estimated using 

the relative reduction factor (RRF) technique. This technique uses a statistically valid number of 

before-and-after modeling results for each monitoring location to calculate the RRF. Briefly, RRFs 

were calculated from the average strategy model predicted concentration divided by the average 

base model predicted concentration for the same grid cell location. This calculation was performed 

for the full ozone season (for CMAQ). A shorter, but representative period of time was used in 

some CALGRID modeling cases after proving to provide valid estimates based on comparisons to 

similar modeling for the full ozone period. In most cases, the RRF is less than 1.0, indicating that 

the emission control strategy lowers the future design value. In order to relate model predictions to

monitored values, the grid cells and actual monitor geographic locations must be paired. This was 

performed according to EPA guidance by using the maximum value of the block of the nearest 9 

grid cells to each monitor location as it is overlaid on the modeling grid. The resulting RRF is then

multiplied by the corresponding base 3-cycle (2000-2002, 2001-2003, 2002-2004) average design 

value for each monitor to calculate an estimated future year design value for comparison to the 

NAAQS. 

3.2 CMAQ and CALGRID Modeling Results 

Statistical summaries of peak 8-hour ozone concentration for each CMAQ and CALGRID model 

run are provided below in Tables 3-2 and 3-3. These results reflect the July 31 to August 16, 2002, 

modeling episode (the model was run for July 30 to August 16, but July 30 is considered to be a 

model warm-up day). Included in the summary tables are peak modeled ozone concentrations for 

five New Hampshire monitoring locations that routinely record elevated ozone levels (Keene, 

Manchester, Nashua, Portsmouth and Rye) and a more general statistic, “Grid Cell Hours” (Table 

3-3), providing a dynamic domain-wide response to emission reductions. Model predicted ozone 

concentrations at the five New Hampshire locations are averages of a 9-grid cell area surrounding 

each of the monitor locations (note that these are the absolute model-predicted concentrations and 

not the RRF-processed estimated future year design values used to determine future attainment – 

these values can be found in Table 3-4 below). 

In all, there are 29,584 grid cells in the modeling domain (172 x 172). “Grid Cell Hours” is a count 

of the number of grid cells exceeding the indicated thresholds (80 ppb, 100 ppb, and 120 ppb) in a 

given hour. This value is presented in order to show the depth of ozone exposure and how it 

improves under various emission reduction strategies. The maximum grid cell hour count possible 

is 710,016 for the full domain over a 24-hour day (172 x 172 x 24), although due to nighttime hours 

and geographically distinct areas within the domain, maximum expected Grid Cell Hour counts is 

about 400,000. 

Table 3-2 - CMAQ Maximum Modeling Statistics for 2002 Base and 2009 OTB/OTW

Peak 8-Hour Ozone Concentration (ppb) 

CMAQ Run 

Keene Manchester Nashua Portsmouth Rye 

2002 Base Case 85 79 87 133 133 

2009 OTW/OTB 73 68 74 114 114 
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Table 3-3 - CALGRID Maximum Modeling Statistics for 2002 Base, 2009 OTB/OTW, 

and 2009 Sensitivity Runs 

Peak 8-Hour Ozone Concentration (ppb) Grid Cell Hours CALGRID Run 

Keene Manchester Nashua Portsmouth Rye >70ppb >85ppb >100ppb 

2002 Base Case 89 100 102 130 130 86,751 30,576 8,266 

2009 OTW/OTB 79 92 93 124 124 56,234 15,444 3,447 

2009 NH Zero-Out 77 85 95 119 119 55,686 15,307 3,441 

2009 90% NOx 

Reduction 42 49 47 62 62 40 0 0 

2009 90% VOC 

Reduction 79 93 94 120 120 55,643 15,540 3,325 

Note: Grid cell hours are based on the full modeling domain. 

Table 3-4 summarizes the modeling results for New Hampshire by listing current design values and 

2009 modeled design values for all monitors in the state. 

Table 3-4 - Modeling Summary for New Hampshire Monitors 

8-hour Ozone Design Values (ppb) 

Predicted Design Value (DVF)

AIRS ID Name

Current 

Design Value 

(DVC)

2009 

OTB/OTW

(CMAQ)

2009 

OTB/OTW

(CALGRID)

330012004 Laconia 76.5 nc 66 

330031002 Conway 67 nc 61 

330050007 Keene 74.3 64 68 

330090008 Haverhill 70.3 nc 64 

 330110020 Manchester 75.5 na 70 

330111010 Nashua 86 74 80 

330115001 Peterborough 84 73 73 

330130007 Concord 74.7 nc 66 

330150012 Rye 83.5 72 78 

330150013 Brentwood 80 68 72 

330150015 Portsmouth 68 59 63 

330173002 Rochester 78.5 67 73 

330190003 Claremont 74.3 nc 67 

Notes: 

1. “nc” indicates that a future design value was not calculated because of the limitation of the 

relative reduction factor (RRF) methodology. 

2. The Manchester monitor was not included in the CMAQ results; this is indicated by “na” in 

the table. 
TSD for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 27 

The figures below show the geographical distribution of 8-hour ozone design values for the 2002 

Base Case and 2009 OTB/OTW scenario for ozone monitor locations in the Ozone Transport 

Region. Figure 3-12 displays the CMAQ-predicted 2009 design values versus the actual 2002 

design values. For comparison, Figure 3-13 shows CALGRID-predicted design values for the 2009 

OTB/OTW scenario. 

Figure 3-12 - CMAQ SIP-Quality Modeling Results for 2009 OTB/OTW vs. 2002 Design Values 

Figure 3-13 - Plot of 2009 Estimated Design Values for the OTC 2009 OTB/OTW Strategy 

EPISODES

July 7 - 23, 2002

July 31 - August 16, 2002

DESIGN VALUES

(Revised 2/23/07)

Average of 2000-2002,

2001-2003, 2002-2004

RRF THRESHOLDS

85 PPB, 70 PPB

EMISSIONS BASE

2002 Base

NHDES 2/23/07

OTR State Summary

Range # of Population

(ppb) Monitors Exposed

< 75

75 - 84.9

85 - 94.9

>= 95

31

64

73

19

6,035,113

19,106,873

28,772,373

7,668,413

CALGRID 172x172 

Modeling Domain

 OTR Domain 

 2002 Design Values 2009 Design Values
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Figure 3-14 shows the CALGRID-modeled differences (improvements) in the maximum 8-hour 

ozone concentration between the 2009 OTB/OTW scenario and the 2002 base case. 

Figure 3-14 - Plot of Differences in Predicted Maximum 8-Hour Ozone Concentrations 

between 2002 Base Case and the OTC 2009 OTB/OTW Strategy 

 

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Ozone

Concentrations

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NHDES 5/29/07

CALGRID 2.45 

Modeling Domain

After completion of the model runs, NHDES discovered that the 2009 on-road emission estimates 

for New Hampshire that were inputs to the modeling had been understated (by about 10% for VOC 

and 15% for NOx). To evaluate the uncertainty introduced by this situation, NHDES performed 

sensitivity modeling with CALGRID in which all New Hampshire on-road OTW/OTB NOx and 

VOC emission inputs were boosted by 25% for the July 31 to August 16, 2002, high ozone event. 

The results of this analysis showed that the adjusted inputs would have negligible effect on the 

modeled 8-hour design ozone values. 

3.3 EPA’s CAIR Modeling 

On May 12, 2005, EPA promulgated the Clean Air Interstate Rule (CAIR). Under CAIR, 28 states 

across the eastern United States and the District of Columbia are expected to make reductions in 

NOx and SO2 emissions. EPA performed technical analyses in support of CAIR, including air 

quality modeling to evaluate ambient levels of ozone and PM2.5. The CAIR modeling is described 

in EPA’s Technical Support Document for the Final Clean Air Interstate Rule, Air Quality 

Modeling, March 2005. The air quality modeling for ozone was performed with the Comprehensive 

Air Quality Model with Extensions (CAMx) version 3.10 on a modeling domain covering much of 

the eastern United States. Three summer 1995 meteorological episodes were used in the modeling. 

The analysis years and emissions scenarios that were assessed included: 

• 2001 Base Year 

• 2010 Base Case 

• 2015 Base Case 

• 2010 CAIR Controls 

• 2015 CAIR Controls 

• 2015 CAIR + BART 

• 2015 BART Only 

Note: 

A positive 

number 

denotes a 

decrease in 

ozone conc. 
TSD for Redesignation of the Boston-Manchester-Portsmouth (SE), NH Nonattainment Area Page 29 

The 2010 and 2015 Base Cases reflect expected economic growth and the anticipated benefits 

associated with existing emissions control programs. 

The CAMx model predictions were used in a relative manner. Weighted-average 1999-2003 design 

values were applied as the basis of the observed 8-hour ozone concentrations. Using this 

methodology, EPA estimated maximum 8-hour ozone design values for each future-year scenario 

for each county in the modeling domain with an ozone monitor. Table 3-5 lists the maximum 

estimated future 8-hour design values for New Hampshire. These results show that, even without 

the emissions benefits associated with CAIR, all New Hampshire counties were predicted to be in 

attainment for 8-hour ozone for the 2010 and 2015 analysis years. 

Table 3-5 - CAIR Modeling Results for New Hampshire for 8-hour Ozone (ppb) 

Estimated Maximum 8-hour Future Design Value 

County 1999-2003 Average 

Design Value 2010 Base 2010 CAIR 2015 Base 2015 CAIR 

Belknap 78.0 68.5 68.2 65.8 65.0 

Carroll 66.5 60.3 60.0 58.6 58.0 

Cheshire 73.7 65.2 64.9 63.1 62.0 

Hillsborough 85.0 76.7 76.6 74.1 73.9 

Merrimack 73.0 64.8 64.6 62.3 61.8 

Rockingham 82.7 75.2 75.1 73.3 72.9 

Strafford 77.3 69.2 69.1 66.8 66.5 

Note: Data taken from Appendix E of EPA’s Technical Support Document for the Final Clean Air Interstate Rule, 

Air Quality Modeling, March 2005.

References

1. Blumenthal, D.L., F. Lurmann, N. Kumar., T. Dye, S. Ray, M. Korc, R. Londergan, and G. 

Moore. Transport and mixing phenomena related to ozone exceedances in the northeast U.S. 

EPRI Report TR-109523, Electric Power Research Institute, Palo Alto, CA, 1997. 

2. Clarke, J.F., and J.K.S. Ching. “Aircraft observations of regional transport of ozone in the 

northeastern United States.” Atmos. Envt. 17, 1703-1712, 1983. 

3. Earth Tech, Inc. Calgrid User Instructions. November 2006. 

4. NARSTO. An Assessment of Tropospheric Ozone Pollution. NARSTO, July 2000. 

5. Ray, J., R. Heavner, M. Flores, and C. Michaelson. “Surface Level Measurements of Ozone and 

Precursors at Coastal and Offshore Locations in the Gulf of Maine.” J. Geophys. Res. 101 

(D22), 29005-29011, 1996. 

6. Wishinski, P. and R. Poirot. Air Trajectory Residence Time Analysis Investigation of Ozone 

Transport Pathways: 1989-95. 1995. 

7. Zhang J. and S.T. Rao. “The role of vertical mixing in the temporal evolution of groundlevel 

ozone concentrations.” J. Applied Meteor. 38, 1674-1691, 1999. 
ATTACHMENT B 

8-Hour Ozone Data 
This page intentionally left blank. 
8-Hour Ozone Data 

The following presents the 8-hour ozone 4th highest values from monitored ozone data as well as 

design value calculations for all sites in the Southeast New Hampshire Nonattainment Area. All data 

and calculations meet the criteria for data handling contained in EPA’s “Guideline on Data 

Handling Conventions for the 8-Hour Ozone NAAQS,” December 1998. For this analysis, the most 

significant of these data handling conventions are:

• A valid ozone monitoring day consists of “at least 18 out of 24 possible 8-hour averaging 

periods” unless “the daily maximum 8-hour average concentration for the day is greater than 

0.08 ppm.” 

• “A valid year must have valid 8-hour daily maximum ozone concentrations for at least 75% 

of the required monitoring days in the ozone season” unless the 4th high value is greater than 

0.08 ppm. 

• For purposes of determining attainment status, “all three years must average at least 90% 

data completeness.” In the event that the 3-year average of the 4th highest values exceeds 

0.08 ppm, then years with less than 75% data recovery are included in the calculations. 

Design values are calculated by taking the average of three consecutive years’ annual 4th highest 

values (which meet the data handling conventions listed above). The year cited for the design value 

is the final year of the 3-year average. Table B-1 contains data for the current Southeast New 

Hampshire Nonattainment Area since 1983. The data include the 4th highest value for each year, 

data capture rates for both individual years and each 3-year period, and the valid design values for 

each site. 

Table B-1 also includes the 2012 threshold value for each site that has monitored ozone from 2009-

2011. The threshold value is defined as the 4th highest value needed in a given year to cause the 

design value for that year to exceed the ozone NAAQS. To determine the threshold for exceeding, 

rather than just meeting, the 1997 8-hour ozone standard, the 2012 threshold value was calculated as 

the 4th highest value in 2012 that would make the mean of the 2010-2012 annual 4th highest values 

equal to 86 ppb. 

Threshold values help to determine the likelihood that a given site/area will exceed the ozone 

NAAQS in the following ozone season. The data in Table B-1 show that annual 4th highest values 

in the Southeast New Hampshire Nonattainment Area’s have not come close to the calculated 2012 

thresholds in recent history. (Note: Annual 4th highest values and design values that exceed the 

1997 8-hour ozone NAAQS are colored red in the table.)
Table B-1. Annual 4th Highest 8-Hour Values, Design Values, and Data Capture Rat

for Each Ozone Monitor Site in the Southeast New Hampshire Nonattainment Area 

 Brentwood Manchester Manchester Manchester  South Road Spring St. Hartnett Park N. Commercial St. 

Year 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 

1983 64 54% N/A N/A 1984 91 81% N/A N/A 1985 87 91% N/A N/A 1986 76 93% 88% N/A 1987 76 96% 93% 79 1988 98 98% 96% 83 1989 68 97% 97% 80 1990 75 97% 97% 80 1991 85 97% 97% 76 1992 78 97% 97% 79 1993 83 99% 98% 82 1994 78 98% 98% 79 1995 77 93% 97% 79 1996 84 94% 95% 79 1997 82 99% 95% 81 1998 67 96% N/A N/A 63 96% 96% 76 1999 79 97% N/A N/A 50 75% 90% 65 67 80% N/A N/A 2000 61 94% 96% 69 63 91% N/A N/A 2001 88 98% 96% 76 2002 91 93% 95% 80 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 

Threshold
Table B-1 (Continued)

 Nashua Nashua Nashua Roch Mulberry St. Spit Brook Rd. Gilson Rd. Rocheste

Year 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 

1983 86 99% N/A N/A 60 20% N/A N/A 1984 45 69% N/A N/A 89 97% N/A N/A 1985 88 88% 68% N/A 1986 90 94% 93% 89 1987 84 95% 92% 87 1988 107 96% 95% 93 1989 71 99% 97% 87 1990 85 99% 98% 87 1991 92 94% 97% 82 1992 90 99% 97% 89 1993 86 99% 97% 89 1994 83 94% 97% 86 1995 88 95% 96% 85 1996 81 100% 96% 84 76 92% 1997 94 98% 98% 87 80 99% 1998 84 98% 99% 86 79 93% 1999 89 92% 96% 89 84 98% 2000 70 89% 93% 81 65 98% 2001 91 94% 92% 83 78 99% 2002 94 99% 94% 85 90 100% 2003 78 99% 97% 87 58 49% N/A N/A 72 100% 2004 80 82% N/A N/A 2005 82 95% 75% N/A 2006 73 97% 91% 78 2007 81 96% 96% 78 2008 67 95% 96% 73 2009 66 97% 96% 71 2010 67 99% 97% 66 2011 65 96% 97% 66 2012 

Threshold 123 
Table B-1 (Continued) 

 Rye Rye Portsmouth Portsmouth  Rye Harbor State Park Seacoast Science Center Vaughan St. Port Authority 

Year 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 4th High 1-Yr% 3-Yr% Design Value 

1983 90 97% N/A N/A 1984 54 91% N/A N/A 1985 87 98% 95% 77 1986 95 99% 96% 78 1987 97 88% N/A N/A 79 100% 99% 87 1988 113 89% N/A N/A 110 96% 98% 94 1989 103 100% 92% 104 80 100% 99% 89 1990 84 97% 95% 100 78 97% 98% 89 1991 107 91% 96% 98 94 96% 98% 84 1992 87 75% 88% 92 86 98% 97% 86 1993 95 88% 85% 96 82 97% 97% 87 1994 97 93% 85% 93 86 97% 97% 84 1995 98 94% 92% 96 85 98% 97% 84 1996 87 97% 95% 94 79 98% 98% 83 1997 102 98% 96% 95 89 98% 98% 84 1998 85 98% 98% 91 84 97% 98% 84 1999 84 97% 98% 90 89 96% 97% 87 2000 68 97% 97% 79 67 98% 97% 80 2001 93 98% 97% 81 59 90% N/A N/A 2002 89 99% 98% 83 90 96% N/A N/A 2003 71 98% 98% 84 66 90% N/A N/A 55 95% 94% 68 2004 74 97% N/A N/A 2005 75 92% 93% 71 2006 76 95% 95% 75 2007 86 98% 95% 79 2008 75 98% 97% 79 2009 68 98% 98% 76 2010 66 99% 98% 69 2011 66 99% 98% 66 2012 

Threshold 123 
ATTACHMENT C 

Chemical Analyses 
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Chemical Analyses 

Photochemical assessment monitoring station (PAMS) sites monitor ozone, chemicals associated with 

ozone formation, and meteorological data. The data from sites in Maine and Massachusetts have been 

analyzed by NHDES staff. Sites in these states were included because they are downwind and upwind 

of New Hampshire, respectively. The meteorological portion of the analysis is presented in Attachment D. 

Background Information 

The Clean Air Act Amendments of 1990 required EPA to promulgate regulations for the “enhanced” 

monitoring of ozone and its precursors for ozone nonattainment areas classified as serious, severe or 

extreme. Both Congress and EPA recognized the need for an improved understanding of the ozone 

problem, and better feedback mechanisms for evaluating the effectiveness of ozone control strategies. 

In 1993, EPA published the final rule detailing the minimum requirements for PAMS, which includes 

measurements of nitrogen oxides (NOx), speciated volatile organic compounds (VOCs), and 

meteorological parameters. These monitoring regulations provide for the collection of an “enhanced” 

ambient air quality database which can be used to better characterize the nature and extent of the ozone 

problem, aid in tracking NOx and VOC emission inventory reductions, assess air quality trends, make 

attainment/nonattainment decisions, and evaluate photochemical grid-model performance. 

There are four different types of PAMS sites, each serving a specific monitoring purpose: a Type 1 is 

upwind of the urban area and represents background concentrations coming into the area; a Type 2 is on

the downwind fringe of the urban area and represents maximum precursor concentrations from the area; 

a Type 3 is located in an area with maximum ozone concentrations; and a Type 4 is at extreme 

downwind location to represent long-range transport from the area. Therefore, PAMS sites required for

an area will not necessarily all be located within the boundaries of the non-attainment area. 

New Hampshire currently operates two PAMS sites: Nashua (Type 1) and Peterborough (Type 3). The 

Nashua site is located in a populated area near the southern border of the state, and is part of the 

Boston--Worcester--Lawrence Consolidated Metropolitan Statistical Area (CMSA). The site in 

Peterborough is in Miller State Park on the summit of Pack Monadnock at an elevation of 2288 feet 

above sea level. Both sites are important for capturing the transport of ozone and its precursors into 

New Hampshire. 

The distinguishing features that make PAMS sites truly “enhanced” ozone monitoring stations is that 

they collect meteorological, ozone and its precursors (oxides of nitrogen and VOCs) data 

simultaneously. Gaining a better understanding of how these variables interact with each other in realworld instances is necessary in order to effectively address ozone levels in New Hampshire and the rest 

of the nation. 

Description of Analyses 

Analysis of PAMS data focused on nitrogen oxides, PAMS target compounds (PAMHC), and total nonmethane organic carbons (TNMOC) in New Hampshire and the surrounding states of Maine and 

Massachusetts. Data were acquired through AQS for 1998 to 2010. Only hourly data were considered. 

In addition, some data were removed if they did not meet the following criteria: 

• POC# was equal to 1. 

• Data capture of at least 60% (1757 hours) occurred during the period June-September. 
• To provide a consistent base of comparison in the charts of PAMHC and TNMOC, data for 

these parameters from a given year were available for both parameters. NOx data were treated 

separately. 

Due to a high number of monitoring sites in Massachusetts, a few with long-term datasets were selected

to illustrate NOx trends. After accounting for the above, data from the following sites were 

incorporated into the charts shown below: 

New Hampshire

• Nashua, Gilson Road (33-011-1011) 

• Peterborough, Pack Monadnock Summit in Miller State Park (33-011-5001) 

• Portsmouth, Pierce Island (33-015-0014) 

• Brentwood, South Road (33-015-0013) 

Maine

• Cape Elizabeth, Two Lights State Park (33-005-2003)

• Portland, Marginal Way (23-005-0027) and State Street (23-005-0029) 

• Kittery, Frisbee School (23-031-3002) – operated by NHDES 

• Bar Harbor, Cadillac Mountain Summit, Acadia National Park (23-009-0102) 

Massachusetts

• Boston, Kenmore Square (25-025-0002) 

• Springfield, Liberty P-Lot (25-013-0016) 

• Worcester, Central Street (25-027-0020) and Summer Street (25-027-0023) 

• Lynn, Parkland (25-009-2006) 

• Newbury, Sunset Blvd (25-009-4004) 

• Milton, Top of Blue Hill (25-021-3003) 

• Chicopee, Anderson Rd (25-013-0008) 

• Ware, Quabbin Summit (25-015-4002) 

Average TNMOC and PAMHC (June-September)

New Hampshire, Maine, Massachusetts

0

5

10

15

20

25

30

35

40

45

50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Concentration (PPBC)

TNMOC

PAMHC

TNMOC and PAMHC Seasonal Averages

Gilson Road, Nashua

0

5

10

15

20

25

30

35

2006 2007 2008 2009 2010

Concentration (PPBC)

TNMOC

PAMHC

TNMOC and PAMHC Seasonal Averages

Pack Monadnock Summit, Peterborough

0

10

20

30

40

50

60

2006 2007 2008 2009 2010

Concentration (PPBC)

TNMOC

PAMHC
ATTACHMENT D 

Meteorological Analyses 
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Meteorological Analyses 

Meteorology is a major factor in the formation and transport of ozone and its precursors. High ozone 

concentrations in southern New Hampshire occur most often when low pressure systems approach from 

the Great Lakes or southern Canada while high pressure is situated just off the eastern seaboard. When 

such a scenario is in place, it provides warm temperatures, clear skies, and southwesterly winds to allow 

the transport of precursors into the Northeast. 

Following the NOx SIP call, which went into effect in 2003, and other emission control programs, NOx 

and VOC emissions have been reduced throughout the region. Ozone exceedances in recent years have 

been fewer in large part because of these emissions reductions. To confirm that lower ozone levels in

New Hampshire are not simply a result of anomalous weather conditions, such as lower summer 

temperatures or changing wind patterns, the following analyses were performed: 

• Temperature versus ozone graphs 

• Graphs of wind frequency data 

Temperature vs. Ozone Graphs 

Since ozone exceedances are typically associated with hot sunny summer days, NHDES staff compared 

maximum daily temperatures to numbers of ozone exceedance days in New Hampshire. Concord 

Airport temperature data were downloaded from the National Weather Service’s website for the months 

of April through September and the years 1985 to 2011. Concord Airport was chosen as a 

representative site because it has historical data for the full period and is located in a central part of 

southern New Hampshire. 

Formulas were then written to count the number of days during each year’s ozone season that the 

maximum daily temperature rose above 85 F. These counts, as well as the number of days in which one 

or more New Hampshire sites exceeded the 1997 NAAQS, were tabulated for each year 1985-2011. 

Next, the data were sorted in ascending order by the number of days with a maximum temperature over 

85 F, and the sorted data were used to create the bar-line chart displayed in the figure below. This 

depiction creates an upward-sloping trend line for temperature and exceedance days. To emphasize the 

period 2003-2011, the data points for these years were circled and labeled. 

Number of Days with Maximum Temperatures above 85 F and Number of Days with 

Ozone Exceedances in New Hampshire, 1985-2011 

0

10

20

30

40

50

60

70

199619862009200819922000200419972006198919851987199820031999199419881993199020072011200120021991200519952010

Number of Days

Max Temperature >85 F 

Ozone Exceedances

Linear (Ozone

Exceedances)

2006

2003

2007

2005

2004

2009

Notes:

Temperatures are National 

Weather Service data from 

Concord Airport.

Data are sorted by number 

of days with maximum 

temperature >85 F 

(therefore, years are not in 

chronological order).

2008

2010

2011
Wind Direction Frequency Charts

NHDES staff explored historical wind direction frequencies in New Hampshire. Again, National 

Weather Service data were used to provide a consistent, long-term dataset. Wind directions and wind 

speeds were downloaded from the National Weather Service’s website for the months of April through 

September to provide ozone season wind data for the years 1995-2010. Data were gathered for two 

sites, centrally located Concord Airport and the coastal site at Pease International Airport in 

Portsmouth. 

The downloaded data were consolidated to produce once-hourly lists of wind direction and wind speed 

observations. Because the number of observations each hour varied in the raw dataset, extraneous 

observations outside the regular measurement interval were removed to provide greater consistency for 

the final calculations. Also, to avoid bias from the inclusion of wind directions during calm conditions, 

wind observations were excluded if the corresponding wind speed was less than 3 mph. 

All raw wind direction data were measured in intervals of 10 degrees. Formulas were written to 

calculate the percentage of total hours for which the wind direction was recorded at each 10-degree 

interval. This was done separately for two time periods, 1995-2002 and 2003-2010. The resulting 

percentages were then incorporated into wind roses to illustrate typical wind direction frequencies at

each site, as shown here. 

New Hampshire Wind Direction Frequencies in the Months of 

April through September, 1995-2010 

Wind Direction Frequencies at Concord Airport

National Weather Service Data

1995-2010

1995-2002 

2003-2010

N

W E

S 

Wind Direction Frequencies at Pease Airport, Portsmouth

National Weather Service Data

1995-2010

1995-2002 

2003-2010

N

W E

S
ATTACHMENT E 

Administrative Documents: 

 Evidence of Legal Authority 

 Certification of Public Process 

 Copy of Public Notice 

 Public Comments and State’s Response 
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STATE OF NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES AIR RESOURCES 

DIVISION CONCORD, NEW HAMPSHIRE NOTICE OF PUBLIC COMMENT PERIOD AND PUBLIC 

HEARINGS In accordance with New Hampshire Administrative Rule Env-A 204.01(b) and Title 

40 of the Code of Federal Regulations (CFR) Section 51.102, notice is hereby given that the 

New Hampshire Department of Environmental Services, Air Resources Division (the 

Department) has prepared, and intends to submit to the U.S. Environmental Protection Agency 

(EPA) for approval, a request for redesignation of the Boston-Manchester-Portsmouth (SE), 

New Hampshire 8-hour ozone (1997 standard) nonattainment area, including a maintenance 

plan for that area, hereinafter referred to as "Request for Redesignation (including MP I)," 

pursuant to section 110(a) of the federal Clean Air Act. This request, if approved by EPA, will 

revise New Hampshire's State Implementation Plan (SIP). In addition, the Department has 

prepared and intends to submit to EPA for approval as a SIP revision a maintenance plan, 

hereinafter referred to as "MP II," for the area of the state that was formerly designated 

nonattainment for the 1-hour ozone standard, but which was classified as 

unclassifiable/attainment for the 8-hour ozone standard. The Boston-Manchester-Portsmouth 

(SE), New Hampshire 8-hour ozone (1997 standard) nonattainment area consists of 52 cities 

and towns in the southern and/or eastern parts of Hillsborough, Merrimack, Rockingham, and 

Strafford Counties. Ground-level ozone monitoring data for the most recent 3-year monitoring 

period of 2008-2010 show that air quality in the nonattainment area has met the 1997 

National Ambient Air Quality Standard for 8-hour ozone. For EPA to approve the Request for 

Redesignation, the Department must submit maintenance plan MP I as part of this request, 

detailing how the state will insure that the area will not fall back into nonattainment once it is 

redesignated as attainment. MP I must demonstrate that the area will remain in compliance for 

a period of 10 years from the date of redesignation. The former nonattainment area for the 1-

hour ozone standard that was classified as unclassifiable/attainment for the 8-hour ozone 

standard on June 15, 2004, consists of 79 cities and towns in Cheshire County and the 

northern and/or western parts of Hillsborough, Merrimack, Rockingham, and Strafford 

Counties. The maintenance plan for this area, MP II, must demonstrate that the area will 

remain in compliance with the 8-hour ozone standard for the 10-year period from June 15, 

2004 to June 15, 2014. The Department hereby solicits comments and has scheduled public 

hearings on the Request for Redesignation (including MP I) and MP II. A public hearing on the 

Request for Redesignation (including MP I) has been scheduled for 10:30 a.m., Tuesday, 

January 24, 2012, at the Department offices in Rooms 110 and 111 at 29 Hazen Drive, 

Concord, NH 03301. A public hearing on MP II has been scheduled to start at the conclusion of 

the first hearing. Comments may be presented orally and/or in writing at the public hearings. 

Written comments may also be submitted by postal delivery, email, or fax to Charles Martone, 

Air Resources Division, NH Department of Environmental Services, P.O. Box 95, Concord, NH 

03302-0095; email Charles.Martone@des.nh.gov; fax (603)271-1381. Please specify which 

plan each comment addresses. All written comments on the Request for Redesignation 

(including MP I) and all written comments on MP II must be received by 4:00 p.m. on Tuesday, 

January 24, 2012, to be entered into the record. The Request for Redesignation (including MP 

I) and MP II are available for public inspection at the Department's offices at 29 Hazen Drive, 

Concord, NH, during regular working hours from 8:00 a.m. to 4:00 p.m., Monday through 

Friday. The main text of both documents may be downloaded from the Department's website at 

http://des.nh.gov/. Questions regarding the Request for Redesignation (including MP I) and MP 

II may be directed to Charles Martone at (603) 271- 1089. Robert R. Scott Director, Air 

Resources Division NH Department of Environmental Services Dated: December 23, 2011 

Appeared in: The Union Leader on Friday, 12/23/2011 
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Page 1 of 5 

Responses to Comments on 

New Hampshire's Proposed Redesignation Request 

On January 24, 2012, the New Hampshire Department of Environmental Services (NHDES) 

received comments from the U.S. Environmental Protection Agency (EPA) on New Hampshire’s 

proposed redesignation request for the Boston-Manchester-Portsmouth (SE), NH 8-hour ozone 

(1997 standard) Nonattainment Area. No other public comments were received. The following are 

NHDES’s responses to EPA’s comments. Comments are written in regular font and responses 

are written in italics.

Ozone Data

1. Table 2-1 on Page 8 should identify that the ozone concentrations are presented in units of parts 

per billion (ppb). 

Response: The requested clarification has been added. 

2. In Table 2-1 on Page 8, the 2012 threshold values should be 123, 125, and 123 ppb for Nashua, 

Portsmouth, and Rye, respectively. Therefore, NH DES should adjust the “most recent year at or 

above the threshold” column correspondingly. In addition, it should be noted that in the current 

version of the table, it appears that 1-hour values, rather than 8-hour values, were used when 

determining the most recent year at or above the threshold. 

Response: The 2012 threshold values and the most recent years at or above threshold have been 

corrected in the table.

Motor Vehicle Emission Budgets

3. In Section 5.5, including in Table 5-1, NH DES should express the year 2008 and year 2022 NOx 

and VOC motor vehicle emission budgets for the Boston-Manchester-Portsmouth (SE), NH area in 

units of tons per summer day for use as future transportation conformity budgets. 

Response: The requested edit has been made to Table 5-1.

2008 Inventory and Projections to 2012 and 2022

4. New Hampshire selected its 2008 emissions inventory to use as the base year inventory for the 

maintenance plan developed to support redesignation of former 8-hour nonattainment areas in the 

state. The 2008 inventory should be submitted to EPA in conjunction with submittal of the final 

redesignation request, as EPA will need to approve the 2008 inventory into the SIP. 

Response: The 2008 emissions inventory is being submitted to EPA as Attachment G to the 

redesignation request. Because of the volume of technical data associated with the emissions 

inventory, a data CD-ROM is being submitted which includes the inventory documentation, data 

tables (as Microsoft Excel spreadsheets), and other supporting technical data. 
Page 2 of 5 

5. The write-up for New Hampshire's 2008 emissions inventory should describe how the partial 

county emission estimates for the 8-hour ozone nonattainment area were derived. It appears that the 

town by town population data within the tabbed sheet labeled “3 - 17 Population,” within the 

spreadsheet with file name “NH 2008 PEI Section 3 Tables.xls” was used to apportion the county 

level area and nonroad emission estimates to the town level. This enabled New Hampshire to then 

sum up nonroad and area source emissions by town to match the sub-county geography of the 8-

hour nonattainment area. This methodology, along with an indication of how on-road mobile 

emission estimates at the sub county level were derived, should be included in the 8-hour ozone 

inventory documentation. 

Response: As EPA notes, population data was used to apportion many of the area and non-road 

emissions source categories to the sub-county geography of the 8-hour nonattainment area. Onroad mobile emissions estimates were derived using VMT data that was provided by the relevant 

metropolitan planning organizations (MPOs). Since the MPOs comprise the 8-hour nonattainment 

area, the VMT data and resulting emissions estimates were specific to that geography. Appropriate 

wording to describe these methodologies has been added to Sections 1.2 and Section 4 of the 2008 

emissions inventory documentation. 

6. New Hampshire should extract a table from the spreadsheet labeled, 

“ISTEPS_2008_POINT_EMISSIONS_SORT.xls” that identifies the NOx and VOC stationary 

sources whose emissions were summed to produce the 24,289 lbs/day NOx and 5,762 lbs/day VOC 

point source emission totals, and place this table within the write-up for the 2008 inventory. 

Response: The requested tables were added to Section 2 of the 2008 emissions inventory 

documentation. 

7. Section 6.2.1 of the proposed redesignation request for New Hampshire's 8-hour nonattainment 

area mentions that growth factors from the Economic Growth and Analysis System (EGAS) were 

used to project point and area source emissions to 2012 and 2014. The final submittal should 

include the specific point and area source growth factors that were used to make these projections. 

Additionally, a review should be made of the growth factors used to project NOx point sources from 

2008 to 2012, as the nearly 50% increase shown seems quite high. New Hampshire may want to 

consider to instead use 2011 actual emissions, grown (or diminished) a minor amount to reflect 

2012 conditions. 

Response: All of the supporting technical files for the projected 2012 and 2022 emissions 

inventories relevant to the redesignation request are being provided to EPA on CD-ROM as 

Attachment H. These files include the EGAS factors that were used to do the projections. 

Final quality-assured actual emissions data for calendar year 2011 is not yet available. However, 

in response to this comment, New Hampshire used 2010 actual emissions data and the applicable 

growth factors to develop revised point source emissions estimates for 2012 and 2022. Table 6-1 of 

the redesignation request has been revised accordingly. 

8. In several locations within the write-up of 2008 area source emission estimates, the phrase, 

“adjustments to account for New Hampshire's 15% ROP plan” is used. This is a somewhat vague 

reference, and should be replaced with something more descriptive such as “adjustments to account 

for the regulations New Hampshire adopted to meet its 15% ROP plan for the 1-hour ozone 
Page 3 of 5 

standard, as some of those rules contained lower applicability thresholds and thus required 

reductions at area sources.” 

Response: The requested edits were made to the 2008 emissions inventory documentation. 

9. The area source inventory documentation indicates that for some source categories, County 

Business Pattern data for 2008 was not available and so data for 2007 was used. 2008 data from 

this resource should now be available. 

Response: Per EPA's request, 2008 County Business Patterns data was obtained and incorporated 

into the relevant area source emissions calculations. Further, 2008 Energy Information 

Administration fuel consumption estimates were not available at the time when work on the 2008 

inventory commenced, so 2007 data was used. New Hampshire has now obtained the 2008 fuel 

consumption estimates and incorporated them into the calculations for the applicable area source 

categories. These changes have resulted in edits to the 2008 emissions inventory documentation 

and Table 6-1 of the redesignation request. 

10. For the redesignation request, it is important to note that the ten year maintenance plan is keyed

to when EPA takes final action. Therefore, in order for the 2022 emission inventory to remain 

relevant, it is critical for New Hampshire to submit the final redesignation request to EPA as soon as

possible (i.e., at a minimum, within the next couple of months). Otherwise, EPA may not have 

enough time to complete its action by December 31, 2012. 

Response: The time limitation is duly noted.

Contingency Measures

11. On page 42, in Section 6.5, NH DES cites one reason to investigate an ozone season exceedance 

as “an anomaly in the ozone-season meteorology.” Since weather anomalies alone do not exempt 

NH DES from contingency measures, EPA recommends replacing this bullet with reference to 

“exceptional events,” as shown below: 

“2. If the design value is above the standard for any ozone monitor, NHDES will investigate 

the cause and determine whether the exceedance is due to: 

• an increase in emissions from local, in-state sources; 

• an increase in emissions from upwind, out-of state sources; or 

• an anomaly in the ozone season meteorology an exceptional event as defined in

40 CFR 50.1.” 

Response: The requested rewording has been made.

12. On page 42, EPA recommends that NH DES delete the word “significant” from the third step 

for the protocol, as shown below, since all factors contributing to ozone exceedances should be 

evaluated: 

“3. If an increase in in-state emissions is determined to be a significant contributing factor to 

the exceedance, NHDES will evaluate the projected in-slate emissions for the next ozone 

season.” 
Page 4 of 5 

Response: The word “significant” has been removed.

13. On page 42, the 4th step of the protocol states: 

“The contingency measures(s) will be selected by the Governor or the Governor's designee 

within six months of/he end a/the ozone season/or which contingency measures have been 

determined to be needed. New Hampshire will then initiate a course of action to implement 

enforceable control measurers) to rectify the problem. New rulemaking, when required, can 

typically be adopted and implemented within a 12-month timeframe, assuming that no new 

legislation is required.” 

In the final submittal, NH DES should clarify the timeframe to implement contingency measures. 

Response: The end of the quoted paragraph has been revised to read as follows: “New rulemaking 

can typically be adopted and implemented within a 12-month timeframe. NHDES will update the 

maintenance plan as necessary and develop and implement required regulations as soon as 

practicable within the guidelines established in the New Hampshire Administrative Procedures Act, 

but no later than 18 months after selection of the appropriate measure.” 

Stage II Vapor Recovery

14. As stated on page 35, NH DES is not submitting the phase-out of Stage II as a formal 

component of this SIP revision to redesignate the 1997 8-hour ozone nonattainment area. 

However, we acknowledge that New Hampshire has recently adopted revisions to its Env-Wm 

1404.17 regulation, “Applicability of Stage II Requirements.” The adopted amendments to EnvWm 1404.17 eliminate the requirements, as of January I, 2012, for Stage II vapor recovery systems 

at gasoline dispensing facilities. We have reviewed the MOVES modeling inputs associated with 

the proposed redesignation request, and note that the emissions projections for 2012 and later years 

appropriately reflect that the NH Stage II vapor recovery program is no longer providing emission 

reductions after January 1, 2012. 

It is, therefore, acceptable that the Stage II phase-out be submitted to EPA as a SIP revision 

subsequent to the redesignation request. The Stage II phase-out supporting documentation and 

calculations, which should be based on MOVES, need to be proposed and adopted, and then 

submitted, along with the recently adopted amendments to New Hampshire's Env-Wm 1404.17 rule, 

to EPA as a SIP revision. Furthermore, EPA encourages NH DES to provide draft versions of this 

documentation and relevant MOVES modeling files to EPA for review prior to the formal proposal 

of this information. 

Response: NHDES acknowledges that Stage II vapor recovery may be addressed as a separate 

item. Accordingly, NHDES intends to submit a SIP revision for the phase-out of Stage II after 

submission of this redesignation request. Draft versions of supporting documentation and modeling 

files will be provided to EPA in advance of any formal submission of the Stage II proposal.

15. In Section 5.2, on page 31, a list of the applicable requirements of New Hampshire's former 1-

hour serious nonattainment areas is presented. One of the measures listed is Stage II vapor 

recovery. The first paragraph following this list states: 
Page 5 of 5 

“New Hampshire asserts that all required control provisions shall remain in place to prevent 

backsliding and assure maintenance of the 1997 8-hour ozone NAAQS after redesignation of 

the area to attainment.” 

This statement does not hold true for Stage II, since New Hampshire has adopted revisions to its 

Env-Wm 1404.17 rule to eliminate the Stage II requirements. New Hampshire should clarify this 

discussion in the final submittal of the ozone redesignation request. 

Response: The following paragraph has been added to Section 5.2 after the indicated passage: 

“New Hampshire notes that it recently revoked the requirement that new gasoline dispensing 

facilities shall be equipped with Stage II vapor recovery control equipment and simultaneously 

adopted a requirement that owners of existing gasoline dispensing facilities equipped with Stage II 

controls shall decommission such equipment by December 22, 2015. This rulemaking was 

necessary to prevent a situation – forecast to occur in the next few years – whereby the Stage II 

equipment, because of incompatability with ORVR equipment, would cause more VOC emissions in 

New Hampshire than it would prevent. New Hampshire is preparing a separate SIP submittal 

demonstrating that these rule changes will not violate the anti-backsliding requirements of section 

110(l) of the Clean Air Act . The demonstration would have been included with this SIP revision, 

but has been delayed as NHDES resolves discrepancies in motor vehicle emission estimates after 

conversion to the new MOVES model.” 

Attachment G – CD Files (Note: This attachment has been renamed as Attachment F)

16. The MOVES modeling inputs associated with the redesignation request should be consistent 

with previous SIP-approved inputs. Once a mobile source modeling input is approved into the SIP, 

all subsequent SIP submittals should reflect the same program characteristics as the SIP-approved 

version of the program inputs. For example, the Attachment G MOVES modeling inputs relating to 

New Hampshire's motor vehicle inspection and maintenance program utilize I/M compliance figures 

that were “modified to actual NH data.” The current New Hampshire I/M SIP, as well as a NH I/M 

SIP revision recently submitted to EPA on November 17, 2011, both utilize an I/M compliance rate 

of 96%. Therefore, all modeling of New Hampshire's I/M program should be conducted using this 

96% compliance rate. However, for other parameters that are not included in NH's SIP as part of a 

formal control measure, or air emissions reduction program, for example “fuel formulation,” EPA 

encourages the use of recent/accurate state-specific data as much as possible over the use of national

defaults in the MOVES model. 

Response: The MOVES runs were redone using a compliance rate of 96%. Tables 5-1 and 6-1 

were revised accordingly. 

17. The MOVES run spec file “rrpc_2008.mrs” appears to have left out the associated input 

database “rrpc_2008_in,” and thus generated emission figures strictly based on the MOVES default 

database for the 2008 analysis of the Rockingham and Strafford Regional Planning Commission 

non-attainment towns. Therefore, the 2008 onroad mobile source emission estimates are not 

accurate. Since NH DES has proposed replacing its 2009 MOBILE6 motor vehicle emission 

budgets with 2008 MOVES2010 budgets, this issue must be corrected in the final SIP submittal. 

EPA would be unable to make a positive adequacy determination on the proposed 2008 VOC and 

NOx onroad motor vehicle emission budgets if the MOVES2010 runs contain errors. 

Response: The identified error was corrected and Tables 5-1 and 6-1 were revised accordingly.
This page intentionally left blank.
ATTACHMENT F 

MOVES Input/Output Files for 

2008 and 2022 Motor Vehicle Emissions Budgets 

(Files available on accompanying CD.) 
This page intentionally left blank.
ATTACHMENT G 

Documentation for 2008 Emissions Inventory 

(Supporting data files available on accompanying CD.) 
This page intentionally left blank. 
New Hampshire 2008 Periodic Emissions Inventory for Ozone Precursors 

1. INTRODUCTION

This document and attached spreadsheet tables serve as New Hampshire's State Implementation Plan 

(SIP) submittal of its 2008 Periodic Emissions Inventory (PEI) for ozone precursors. Calendar year 

2008 emissions estimates for New Hampshire have also been submitted via EPA's new Emissions 

Inventory System (EIS) for inclusion in the 2008 National Emissions Inventory (NEI). Together, these 

submissions fulfill New Hampshire's emissions reporting obligations as required in its SIP and under 

the Consolidated Emissions Reporting Rule (CERR) at 40 CFR Part 51. The sections immediately 

following provide an overview and summary of New Hampshire's 2008 PEI, including pollutants of 

concern, general methodologies, and geographic coverage. Subsequent sections describe in more 

detail the methodologies and assumptions used in the estimates for the various emissions categories. 

The emissions categories included in this submittal are as follows: 

• Point Sources (Section 2) are discrete facilities which generally report their emissions directly 

via the Air Emissions Inventory and Reporting program at the New Hampshire Department of 

Environmental Services (NHDES). Point sources usually represent larger facilities. 

• Area Sources (Section 3) comprise a wide range of anthropogenic activities that generate 

emissions. These activities are generally too widespread and numerous to be inventoried 

individually; therefore, estimates for these categories are made using available state-wide data 

such as population, employment, and fuel consumption. Also included in Section 3 are NonRoad Mobile Sources. Non-road mobile sources include a variety of vehicles and equipment 

which do not operate on roadways, including construction vehicles, lawn and garden 

equipment, and recreational vehicles. For the purposes of New Hampshire's PEI, aircraft, 

locomotives, and commercial marine vessels are also included in the non-road mobile 

category. 

• On-Road Mobile Sources (Section 4) are vehicles that are principally intended to be operated 

on roadways. This category includes cars, trucks, buses, and motorcycles. 

• Biogenic Emissions are naturally-occurring emissions due to vegetation and other nonanthropogenic sources. EPA and other parties will be calculating biogenic emissions to support 

ozone SIP-related activities such as photochemical air quality modeling. NHDES will accept 

these estimates. In the Air Emissions Reporting Requirements (AERR) Final Rule, EPA is 

proposing to remove the requirement that state, local, and tribal agencies report biogenic 

emissions. Therefore, biogenic emissions are not addressed further in this submittal. 

1.1 Pollutants of Concern

The 2008 PEI was prepared in support of New Hampshire's SIP for attaining and maintaining the 1997 

national ambient air quality standard for ozone. Therefore, the focus of this documentation is the two 

principal precursors of ozone, volatile organic compounds (VOC) and oxides of nitrogen (NOx). 

However, because New Hampshire made a submittal to the NEI, emissions estimates were also made 

for the other criteria pollutants, including carbon monoxide (CO), sulfur dioxide (SO2), particulate 

matter with an equivalent diameter of 10 microns (PM10), and particulate matter with an equivalent 

diameter of 2.5 microns (PM2.5). For some source categories, estimates were also made for ammonia 

(NH3). 

1.2 Methodology

The methodologies used in the preparation of the 2008 PEI were based on standard guidance and 

procedures. The resources that New Hampshire used included EPA's Clearinghouse for Inventories & 

Emissions Factors (CHIEF) and Emission Inventory Improvement Program (EIIP). Stated briefly, 
emissions estimates are generally made by multiplying an emission factor times an activity or 

throughput factor. Many of the emission factors used in the calculations were based on AP-42, Fifth 

Edition, Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources. 

Activity and throughput data was obtained from a wide variety of sources, including the U.S. Census 

Bureau, the U.S. Department of Energy, and New Hampshire state agencies such as the NH 

Department of Transportation and the NH Office of Energy and Planning. The calculations that were 

used for each category are shown in the tables, which can be found in the Microsoft Excel 

spreadsheets that accompany this documentation. Each spreadsheet tab is designed to be selfdocumenting, listing the methodology, emission factors, activity, and other assumptions that were used

in the calculations. 

Emissions were calculated and apportioned to the county level using a variety of data elements 

including population, employment, product sales, housing units, and heating-degree days. The method 

that was used to apportion each emissions category is provided on each corresponding spreadsheet 

tab of the Excel workbook that accompanies this text. Many of the data elements used for 

apportionment are not available at a resolution lower than county level; however, New Hampshire's 8-

hour non-attainment area (discussed in greater detail below) does not follow county boundaries. Since

population data for New Hampshire was available at the town level, this data element was used to 

apportion the emissions estimates for many categories to the irregularly shaped 8-hour non-attainment 

area. Detailed population data for New Hampshire has been provided in the accompanying 

spreadsheet and is discussed further below. 

Quality assurance was employed during inventory preparation to ensure an accurate and high-quality 

inventory. Quality assurance measures included "reality checks" against previous inventories and 

hand-calculation checks of spreadsheet calculations. In addition, inventory staff from the point and 

area source sectors worked closely together to ensure that no emissions were double counted. 

1.3 Geographic Coverage

In 1997, EPA promulgated the 8-hour ozone standard and published its final 8-hour ozone attainment 

designations and classifications in 2004. The State of New Hampshire contains one classified 8-hour

non-attainment area, the New Hampshire portion of the Boston-Manchester-Portsmouth (SE) NH 

Ozone Non-Attainment Area. This area is classified as moderate, and contains parts of Hillsborough, 

Merrimack, Strafford, and Rockingham counties. So in total, New Hampshire has parts of four counties 

classified as moderate non-attainment. Cities and towns that are in the 8-hr non-attainment area are:

Amherst, Atkinson, Auburn, Bedford, Brentwood, Brookline, Candia, Chester, Danville, Derry, Dover, 

Durham, East Kingston, Epping, Exeter, Fremont, Goffstown, Greenland, Hampstead, Hampton, 

Hampton Falls, Hollis, Hooksett, Hudson, Kensington, Kingston, Litchfield, Londonderry, Manchester, 

Merrimack, Milford, Nashua, Newcastle, Newfields, Newington, Newmarket, Newton, North Hampton, 

Pelham, Plaistow, Portsmouth, Raymond, Rochester, Rollinsford, Rye, Salem, Sandown, Seabrook, 

Somersworth, South Hampton, Stratham, and Windham. As of this writing, New Hampshire is in the 

process of submitting a formal request to EPA to re-designate this area as being in attainment of the 

1997 8-hour ozone standard. Cheshire, Belknap, Coos, Carroll, Grafton, and Sullivan counties are 

classified as unclassifiable/attainment for the ozone standard. 

The tables in the attached spreadsheets show emissions estimates for each county and for the entire 

state. Estimates are also shown for the 8-hour non-attainment area. In addition, estimates are shown

for the former 1-hour ozone non-attainment areas (i.e. the former Seacoast, Southern, and Marginal 

non-attainment areas). Estimates for the former 1-hour areas are shown only for continuity with 

previous inventories. Figure 1, which is provided as an attachment to this document, contains maps 

showing the former 1-hour non-attainment areas as well as the current moderate 8-hour ozone nonattainment area. 
1.4 Inventory Summary

A summary of New Hampshire's 2008 PEI is presented in the following tables. Estimates in pounds 

per summer day for VOC and NOx are shown for the 8-hour non-attainment area in Table 1-1 and for 

the entire state in Table 1-2. Emissions are broken down into the point, area, non-road, and on-road 

sectors. Tables 1-3 and 1-4 compare the 2008 estimates with New Hampshire's two most recent PEIs 

from 2002 and 1999. Statewide 2008 emissions estimates decreased by approximately 28% and 10% 

respectively for VOC and NOx when compared with 2002. 

Table 1-1: Summary of NH 2008 PEI for the 8-Hour Non-Attainment Area

Emissions in Pounds Per Summer Day 

Category VOC NOx 

Point 5,762 24,289 

Area 55,871 6,528 

Non-Road Mobile 33,512 31,364 

On-Road Mobile 35,666 74,352 

Total 130,811 136,533 

Table 1-2: Summary of NH 2008 PEI, Statewide Total

Emissions in Pounds Per Summer Day 

Category VOC NOx 

Point 8,722 62,551 

Area 106,150 12,515 

Non-Road Mobile 98,345 61,863 

On-Road Mobile 62,652 188,699 

Total 275,869 325,628 

Table 1-3: Comparison of NH 2008 PEI with 2002 and 1999, Statewide VOC

VOC Emissions in Pounds Per Summer Day 

Category 1999 2002 2008 

Point 21,698 18,096 8,722 

Area 112,660 136,347 106,150 

Non-Road Mobile 89,248 124,582 98,345 

On-Road Mobile 142,440 105,775 62,652 

Total 366,046 384,800 275,869 

Table 1-4: Comparison of NH 2008 PEI with 2002 and 1999, Statewide NOx

NOx Emissions in Pounds Per Summer Day 

Category 1999 2002 2008 

Point 127,187 87,667 62,551 

Area 11,514 14,932 12,515 

Non-Road Mobile 93,209 65,881 61,863 

On-Road Mobile 248,920 195,136 188,699 

Total 480,830 363,616 325,628 

2. POINT SOURCES

Each year, NHDES collects emissions information from point source facilities within the state, tracks 

construction and modification actions by these facilities, and monitors compliance and enforcement 
activities. Data collection for the point source inventory encompasses several types of report collation 

and evaluation depending on the applicable air program. Generally, reporting is made via three routes: 

First, in accordance with CHAPTER Env-A 700 of New Hampshire’s air regulations, all permitted 

sources are required to submit annual emissions inventories for the purpose fee calculation. Fees are

assessed on a dollar per ton basis for each ton of pollutant emitted. 

Second, in accordance with CHAPTER Env-A 900, NOx and VOC emission statements are required for 

sources having 10 tons per year actual emissions of NOx annually and 10 tons per year actual 

emissions of VOC annually. 

Finally, most permitted sources are required to perform additional reporting to demonstrate compliance

with various standards (e.g., National Ambient Air Quality Standards, New Hampshire Ambient Air 

Limits). 

Reports for point sources subject to more than one of these programs were collected, collated, crossreferenced and if discrepancies existed, the point sources were contacted in order to determine correct 

usages or emissions. Also, many of these sources have Continuous Emissions Monitoring Systems 

(CEMS) or have been stack tested. Both of these types of data have been incorporated into the 

inventory. 

Data for the point source emissions was collected by the most complete means possible: from point 

source air program reporting, NOx and VOC emissions statements, reporting required by permits, field 

engineers, field trip reports, material purchase orders, material safety data sheets (MSDS) and process 

rate information. It is important to note that these reports required all of the information necessary to 

calculate the emissions, and to categorize them by Source Classification Code (SCC). Reported 

information includes the process rate, the speciation, the name of the solvent, the operating schedule, 

the permitted emission limitation, and any control equipment as applicable. They also include New 

Hampshire specific factors, if developed. 

A reasonableness check was performed on the information provided by the reports. An emissions 

number was never accepted by itself, rather the data used to calculate that number was reviewed and, 

if accepted, the emissions were then recalculated independent of the point source report. These 

emissions were cross-checked against the emissions reported in the 1990, 1996, 1999, 2002 and 2005 

inventories, and in some cases, against SARA Title III information. Also, when entered into ISteps, the 

in house emissions database, the calculations were redone and any math errors were detected since 

the computer itself does the emissions calculations. 

All of the sources have been extensively quality assured by NHDES personnel when entering them into 

the EIS for the EPA reporting requirement. Therefore, all of these sources have had the emissions 

calculated and verified at least twice and usually more. Most of the emissions entered into the EIS 

were done under method code 9, by which emissions are calculated by ISteps based on the throughput 

and emission factors entered. The ozone dailies were calculated by ISteps which takes the annual 

emissions and multiplies it by the seasonal throughput percentage then divides it by the number of 

days of operation during the ozone season. However, where CEM data was available, the ozone 

dailies were calculated both by the using the throughputs, emission factors and seasonal percentages 

as well as taking the ozone season CEM data and dividing it by the number of days of operation. In all 

cases the ozone daily emissions were similar enough so that they were entered with method code 9 as 

well. 

Point source emissions for the 8-hour non-attainment area and for the entire state are summarized in 

Section 1 in Tables 1-1 through 1-4. Point source emissions by facility for the 8-hour non-attainment

area are shown in Tables 2-1 and 2-2 below. A more detailed summary of emissions by individual 

facility is provided in Appendix A, which has been submitted electronically with this documentation. 
Table 2-1: Point Source VOC Emissions for the 8-Hour Non-Attainment Area

Facility Town VOC (pounds per summer day) 

FOSS MANUFACTURING COMPANY INC HAMPTON 48

GENERAL ELECTRIC - SOMERSWORTH SOMERSWORTH 26

GEORGIA-PACIFIC GYPSUM LLC NEWINGTON 130

GOSS INTERNATIONAL AMERICAS INC - DURHAM DURHAM 27

HUTCHINSON SEALING SYSTEMS NEWFIELDS 147

LONZA BIOLOGICS INC - INTERNATIONAL DR PORTSMOUTH 72

NATIONAL GYPSUM COMPANY PORTSMOUTH 12

NEWINGTON ENERGY LLC NEWINGTON 3

NOVEL IRON WORKS INC GREENLAND 177

PARK NAMEPLATE COMPANY DOVER 50

PHILLIPS EXETER ACADEMY EXETER 2

PSNH - NEWINGTON STATION NEWINGTON 314

PSNH - SCHILLER STATION PORTSMOUTH 145

SPRAGUE ENERGY CORPORATION/RIVER ROAD NEWINGTON 1

SPRAGUE ENERGY CORP-SHATTUCK WAY NEWINGTON 14

TAPE-O CORPORATION DOVER 476

TEXTILE TAPES CORPORATION GONIC 57

TRELLEBORG SEALING SOLUTIONS US INC SOMERSWORTH 12

TURNKEY RECYCLING & ENVIRONMENTAL ENT ROCHESTER 128

UNIVERSITY OF NEW HAMPSHIRE DURHAM 32

AVILITE CORPORATION MANCHESTER 157

CUMMINGS PRINTING COMPANY HOOKSETT 350

DUNBARTON ENERGY PARTNERS LP MANCHESTER 2

ELECTROPAC COMPANY INC MANCHESTER 46

FREUDENBERG NOK - MANCHESTER MANCHESTER 81

G&K SERVICES COMPANY MANCHESTER 184

HARVEY INDUSTRIES INC LONDONDERRY 108

KALWALL PANELS & ACCESSORIES MANCHESTER 402

MOORE WALLACE MANCHESTER 36

NEXTERA ENERGY SEABROOK LLC SEABROOK 22

NYLON CORPORATION OF AMERICA MANCHESTER 1

OAK DESIGNS INC MANCHESTER 108

VELCRO USA INC - MANCHESTER MANCHESTER 211

ANHEUSER-BUSCH INC MERRIMACK 358

CORIUM CORPORATION SEABROOK 38

FOUR HILLS LANDFILL NASHUA 232

GATES MECTROL INC SALEM 154

GRANITE RIDGE ENERGY LLC LONDONDERRY 77

HITCHINER MANUFACTURING - WILTON ROAD MILFORD 205

NASHUA CORPORATION - MERRIMACK MERRIMACK 382

NORCROSS SAFETY PRODUCTS LLC NASHUA 320

PARKER CHOMERICS - 16 FLAGSTONE HUDSON 57

PRIMERO INC NASHUA 15

SAINT GOBAIN CERAMICS - IGNITER PRODUCTS MILFORD 29

SAINT GOBAIN PERFORMANCE PLASTICS MERRIMACK 181

SPEAR - NEW HAMPSHIRE MILFORD 66

TECHNICAL GRAPHICS INC MILFORD 65

Total 5,762
Table 2-2: Point Source NOx Emissions for the 8-Hour Non-Attainment Area

Facility Town NOx (pounds per summer day) 

FOSS MANUFACTURING COMPANY INC HAMPTON 1,072

GENERAL ELECTRIC - SOMERSWORTH SOMERSWORTH 5

GEORGIA-PACIFIC GYPSUM LLC NEWINGTON 256

LONZA BIOLOGICS INC - INTERNATIONAL DR PORTSMOUTH 54

NATIONAL GYPSUM COMPANY PORTSMOUTH 186

NEWINGTON ENERGY LLC NEWINGTON 716

PHILLIPS EXETER ACADEMY EXETER 35

PSNH - NEWINGTON STATION NEWINGTON 9,516

PSNH - SCHILLER STATION PORTSMOUTH 7,917

SPRAGUE ENERGY CORPORATION/RIVER ROAD NEWINGTON 163

SPRAGUE ENERGY CORP-SHATTUCK WAY NEWINGTON 15

TAPE-O CORPORATION DOVER 1

TEXTILE TAPES CORPORATION GONIC 5

TRELLEBORG SEALING SOLUTIONS US INC SOMERSWORTH 3

TURNKEY RECYCLING & ENVIRONMENTAL ENT ROCHESTER 723

UNIVERSITY OF NEW HAMPSHIRE DURHAM 568

DUNBARTON ENERGY PARTNERS LP MANCHESTER 98

FREUDENBERG NOK - MANCHESTER MANCHESTER 93

G&K SERVICES COMPANY MANCHESTER 9

KALWALL PANELS & ACCESSORIES MANCHESTER 10

MOORE WALLACE MANCHESTER 5

NEXTERA ENERGY SEABROOK LLC SEABROOK 700

NYLON CORPORATION OF AMERICA MANCHESTER 19

VELCRO USA INC - MANCHESTER MANCHESTER 516

ANHEUSER-BUSCH INC MERRIMACK 342

FOUR HILLS LANDFILL NASHUA 110

GRANITE RIDGE ENERGY LLC LONDONDERRY 965

HITCHINER MANUFACTURING - WILTON ROAD MILFORD 53

NASHUA CORPORATION - MERRIMACK MERRIMACK 85

NORCROSS SAFETY PRODUCTS LLC NASHUA 2

SAINT GOBAIN PERFORMANCE PLASTICS MERRIMACK 47

Total 24,289

 

3. AREA AND NON-ROAD MOBILE SOURCES

As described in Section 1, area sources represent those emissions categories that are too widespread 

and/or numerous to be inventoried individually. In general, the calculations used to estimate area 

source emissions involve a descriptor of activity or throughput multiplied by an emission factor. 

Examples of activity and throughput include population, employment, and fuel consumption. The types 

of area sources for which NHDES has made emissions estimates can be grouped into the following 

broad categories: 

• Gasoline Marketing 

• Degreasing (Surface Cleaning) 

• Surface Coating 

• Graphic Arts 

• Asphalt Paving 
• Pesticide Use 

• Commercial and Consumer Solvent Use 

• Bakeries 

• Waste Management Practices 

• Underground Storage Tank Remediation 

• Residential, Commercial, and Industrial Fuel Combustion 

• Accidental and Intentional Fires 

Further, NHDES made emissions estimates for the following types of non-road mobile sources: 

• Non-road vehicles as contained in EPA's NONROAD emissions model 

• Aircraft, Airport Ground Service Equipment, and Auxiliary Power Units 

• Locomotives 

• Commercial Marine Vessels 

The emissions estimates that were made for these categories are described further in the sections that

follow. However, the reader is referred to the individual tabs in the attached spreadsheet tables for

detailed information on the activity, emission factors, and other assumptions that were used in the 

emissions calculations for each subcategory. Area and non-road emissions estimates for the 8-hour 

non-attainment area and for the entire state are shown in Section 1 in Tables 1-1 through 1-4. 

Additional emissions summaries can be found in the attached spreadsheet in Spreadsheet Tables 3-1 

through 3-16. These summaries include VOC and NOx as well as the other criteria pollutants. 

Detailed area and non-road mobile emissions summaries by source category are provided for the 

following geographic areas: 

• Statewide (Spreadsheet Table 3-1) 

• The former Seacoast 1-hour ozone non-attainment area (Spreadsheet Table 3-2) 

• The former Southern 1-hour ozone non-attainment area (Spreadsheet Table 3-3) 

• The former Marginal 1-hour ozone non-attainment area (Spreadsheet Table 3-4) 

• The 8-hour ozone non-attainment area (Spreadsheet Table 3-5) 

• The former total 4-county 1-hour ozone non-attainment area (Spreadsheet Table 3-6) 

• Belknap County (Spreadsheet Table 3-7) 

• Carroll County (Spreadsheet Table 3-8) 

• Cheshire County (Spreadsheet Table 3-9) 

• Coos County (Spreadsheet Table 3-10) 

• Grafton County (Spreadsheet Table 3-11) 

• Hillsborough County (Spreadsheet Table 3-12) 

• Merrimack County (Spreadsheet Table 3-13) 

• Rockingham County (Spreadsheet Table 3-14) 

• Strafford County (Spreadsheet Table 3-15) 

• Sullivan County (Spreadsheet Table 3-16) 

Note to Reader: 

Table numbers from this point forward refer to the 

individual tabs in the Microsoft Excel workbook entitled 

"NH 2008 PEI Section 3 Tables.xls," which has been 

submitted electronically along with this documentation. 
Population is an important variable that is used in the emissions calculations for many area source 

categories. In many cases, it is also used to apportion emissions to the appropriate geographic 

regions. 2008 population data for New Hampshire was obtained from the New Hampshire Office of 

State Planning. Populations by town were used to assign population to the non-attainment areas. The 

population data used in the New Hampshire 2008 PEI is shown in Spreadsheet Table 3-17. 

3.1 Gasoline Marketing

Gasoline marketing emissions estimates were made for the following subcategories and source 

classification codes (SCCs): 

2501060050: Gasoline Service Stations Stage I: Total 

2501060201: Gasoline Service Stations: Tank Breathing & Emptying 

2505030120: Petroleum Product Transport, Truck, Gasoline

The activity factor used in the emissions calculations for these SCCs was gasoline throughput. The 

number of gallons of gasoline sold by month for 2008 was obtained from the New Hampshire 

Department of Safety. These figures are shown in Spreadsheet Table 3-18. The emission factors 

used for these SCCs were based on EIIP Volume III, Chapter 11, Gasoline Marketing (Stage I and II). 

For Stage I (delivery from truck to service station), it was assumed that 99% of the gasoline in New 

Hampshire is dispensed with Stage I controls. Emissions estimates for Stage II (vehicle refueling at the 

pump) have historically been calculated as an area source category using gasoline throughput and 

MOBILE6.2 emission factors. However, these emissions are now calculated using EPA's Motor 

Vehicle Emissions Simulator (MOVES) and are included in the on-road mobile portion of the inventory. 

For the Stage I estimates, MOBILE6.2 refueling factors were developed and used to reflect the use of 

reformulated gasoline in New Hampshire's southern four counties. MOBILE6.2 input and output files 

can be found in Appendix B, which has been submitted electronically along with this documentation. 

Total emissions estimates for the gasoline marketing category were as follows: 

Gasoline Marketing (pounds per summer day) 

VOC 

8-hour NAA 618 

Statewide 1,299 

Detailed emissions and calculation summaries for the gasoline marketing subcategories can be found 

in the attached spreadsheet as Spreadsheet Tables 3-19 through 3-22. 

3.2 Degreasing

Degreasing (or surface cleaning) emissions estimates were made for the following SCC: 

2415000000: Degreasing, All Processes, All Solvent Types

Emissions from degreasing activities were estimated using methodologies found in EIIP Volume III, 

Chapter 6, Surface Cleaning. The activity factor used in the calculations was employment. Data on the 

number employees by county for the applicable North American Industry Classification System 

(NAICS) codes was obtained from the U.S. Census County Business Patterns data series. A 20% 

reduction was applied to the emission factor to account for VOC RACT per New Hampshire's 15% 

VOC Rate of Progress (ROP) plan for the 1-hour ozone standard. Total emissions estimates for the 

degreasing category were as follows: 

Degreasing (pounds per summer day) 

VOC 

8-hour NAA 11,279 

Statewide 19,336 
Detailed emissions and calculation summaries for degreasing can be found in the attached 

spreadsheet as Spreadsheet Table 3-23. 

3.3 Surface Coating

Surface coating activities involve applying paints, varnishes, lacquers, and other materials to a wide

variety of surfaces, including residential structures, roadways, vehicles, and manufactured products. 

Surface coating emissions estimates were made for the following subcategories and SCCs: 

2401003000: Architectural Surface Coating - Water Based 

2401002000: Architectural Surface Coating - Solvent Based 

2401008000: Traffic Markings 

2401005000: Auto Body Refinishing 

2401020000: Surface Coating, Wood Furniture 

2401025000: Surface Coating, Metal Furniture 

2401070000: Surface Coating, New Automobiles 

2401055000: Surface Coating, Machinery & Equipment 

2401075000: Surface Coating, Other Transportation Equipment 

2401050000: Surface Coating, Misc. Finished Metals 

2401015000: Surface Coating, Factory Finished Wood 

2401065000: Surface Coating, Electronic & Electrical Equipment 

2401080000: Marine Coatings

For architectural surface coating, the activity factor used in the emissions calculations was gallons of 

paint, which was obtained from "2008 Quantity of Paint & Allied Products", which can be found in Table

2 of the U.S. Census form MA325F. The nationwide estimates of the amount of paints used were 

proportioned to New Hampshire using the ratio of New Hampshire population to U.S. population. 

Similarly, for traffic markings, the quantity of paint was obtained from the same reference. The 

estimated amount of traffic markings used in New Hampshire were obtained by using the ratio of New 

Hampshire highway spending to total U.S. highway spending (highway spending for maintenance & 

services). These figures were obtained from the U.S. Department of Transportation. 

Employment data was used as the activity factor for the other surface coating categories. As described 

above for degreasing, this information was obtained from the County Business Patterns data series. 

Emission factors for all surface coating subcategories included adjustments to account for the 

regulations New Hampshire adopted to meet its 15% ROP plan for the 1-hour ozone standard, as some 

of those rules contained lower applicability thresholds and thus required reductions at area sources. 

Many of the subcategories involve a variety of industrial activities and facilities. Therefore, where

applicable, point source subtractions were made to ensure that emissions were not double counted. 

Emissions estimates for the surface coating category were as follows: 

Surface Coating (pounds per summer day) 

VOC 

8-hour NAA 18,784 

Statewide 35,486 

Detailed emissions and calculation summaries for the surface coating subcategories can be found in 

the attached spreadsheet in Spreadsheet Tables 3-24 through 3-36. 

3.4 Graphic Arts

Emissions estimates for the graphic arts category were made for the following SCC: 

2425000000: Graphic Arts, Total, All Solvent Types
The methodology used in the calculations was taken from EIIP, Chapter 7, Graphic Arts and used 

population as an activity factor. Since printing and other activities that fall under this category can 

occur at fairly large facilities, point source emissions associated with graphic arts were subtracted to 

eliminate double counting. 

Emissions estimates associated with the Graphic Arts category were as follows: 

Graphic Arts (pounds per summer day) 

VOC 

8-hour NAA 3,246 

Statewide 5,356 

Detailed emissions and calculation summaries for the graphic arts category can be found in the 

attached spreadsheets in Spreadsheet Table 3-37. 

3.5 Asphalt Paving

Emissions estimates for the asphalt paving category were made for the following SCC: 

2461022000: Emulsified Asphalt

The activity factor for the asphalt paving category is gallons of asphalt paved. During the 2002 PEI 

cycle, the number of gallons of asphalt paved was obtained from the NH Department of Transportation. 

Similar data for calendar year 2008 (or other recent year) were not readily available. Therefore, EPA's 

Economic Growth Analysis System (EGAS) Version 5.0 was used to grow the 2002 activity data to 

2008. The emission factor for this category was developed during the 1999 PEI cycle and assumed 

that 37% of the asphalt is emulsifier and that 9.5% of the emulsifier is VOC. The calculations also 

assumed 75% evaporation and a density of 8.34 lb/gallon. Emissions for this category were 

apportioned to the counties using the total number of lane miles. Emissions estimates for the asphalt

paving category were as follows: 

Asphalt Paving (pounds per summer day) 

VOC 

8-hour NAA 3,399 

Statewide 9,276 

Detailed emissions and calculation summaries for asphalt paving can be found in the attached 

spreadsheet in Spreadsheet Table 3-38. 

3.6 Pesticide Application

Emissions estimates for pesticide application were made for the following SCC: 

2461850000: Pesticide Application, Agricultural

Data on the amount of pesticide applied was obtained from the NH Department of agriculture. The 

most recent readily available data was for calendar year 2003. It was felt that this activity would not 

necessarily follow any particular economic trends, and therefore it was assumed that 2003 would be 

adequately representative of 2008 for this category. Emission factors and calculation methodologies 

came from EIIP Volume III, Chapter 9, Pesticides - Agricultural and Nonagricultural. Emissions were 

apportioned to the individual counties using agricultural acreage, which was obtained from the 2007 

Census of Agriculture. Emissions estimates for pesticide application were as follows: 
Pesticide Application (pounds per summer day) 

VOC 

8-hour NAA 570 

Statewide 2,210 

Detailed emissions and calculation summaries for this category can be found in the attached 

spreadsheet in Spreadsheet Table 3-39. 

3.7 Commercial and Consumer Solvent Use

Emissions estimates for solvent use were made for the following SCC: 

2460000000: Solvent Utilization, Miscellaneous Non-Industrial, Total

Calculations for this category were based on EIIP Volume III, Chapter 5, Solvent Use. The emission 

factor that was used incorporated an adjustment to account for the regulations New Hampshire 

adopted to meet its 15% ROP plan for the 1-hour ozone standard, and the activity factor was based on 

population. Emissions estimates for this category were as follows: 

Commercial and Consumer Solvent Use (pounds per summer day) 

VOC 

8-hour NAA 13,712 

Statewide 24,749 

Detailed emissions and calculation summaries for commercial and consumer solvent use can be found 

in the attached spreadsheet as Spreadsheet Table 3-40. 

3.8 Bakeries

Emissions estimates for this category were made for the following SCC: 

2302050000: Food & Kindred Products, Bakery Products

Calculations were based on EIIP Volume III, Area Source Method Abstracts - Bakeries and used 

population as the activity factor. The emission factor was based on the straight dough baking process, 

and a consumption factor of 70 lb/person was assumed. Emissions estimates for bakeries were as 

follows: 

Bakeries (pounds per summer day) 

VOC 

8-hour NAA 70 

Statewide 126 

Emissions and calculation summaries for bakeries can be found in the attached spreadsheet as 

Spreadsheet Table 3-41. 

3.9 Waste Management Practices

Emissions estimates for waste management were made for the following SCCs: 

2630020000: Waste Water Treatment, Publicly Owned 

2620000000: Landfills, All Categories 

2680001000: Bio-Solids Composting 

2680002000: Mixed Waste Composting
Emissions estimates for wastewater treatment have been carried forward from historical inventories 

starting in 1996. The original methodologies were taken from Section 3.5.1 of Procedures for the 

Preparation of Emissions Inventories for Carbon Monoxide and Precursors of Ozone, Volume I: 

General Guidance for Stationary Sources. The activity for this category, millions of gallons per day of 

wastewater treated, were grown from the historical data using EGAS to obtain estimates for more 

recent inventories, including the 2008 PEI. 

Emissions for landfills were estimated with EPA's Landfill Gas Emissions Model (LandGEM) Version 

3.02 using the latest available data on landfill capacity for landfills throughout the state. Two of the 

state's largest landfills, Four Hills Landfill in Nashua and Turkey Recycling & Environmental Enterprises 

in Rochester, are inventoried as point sources and are therefore not included in the area source 

estimates described here. 

Also included in the waste management category are bio-solids composting and mixed waste 

composting. These estimates were taken from an ammonia emissions inventory prepared for the MidAtlantic Regional Air Management Association (MARAMA) as documented in Technical Memorandum: 

MANE-VU 2002 Ammonia Emissions Inventory for Miscellaneous Sources, Final, dated March 31, 

2004. Emissions estimates for the waste management practices category were as follows: 

Waste Management Practices (pounds per summer day) 

VOC 

8-hour NAA 985 

Statewide 1,918 

Emissions and calculation summaries for waste management practices are presented in Spreadsheet 

Tables 3-42 through 3-45. 

3.10 Underground Storage Tank Remediation

Emissions estimates for underground storage tank remediation were made for the following SCC: 

2660000000: Leaking Underground Storage Tanks

The methodology for this category was carried forward from historical inventories that estimated 0.75 

tons of VOC per remediation. The number of remediation events for 2008 was obtained from the 

NHDES Waste Management Division, Oil Remediation & Compliance Bureau, resulting in the following 

emissions estimates for this category: 

Underground Storage Tank Remediation (pounds per summer day) 

VOC 

8-hour NAA 125 

Statewide 226 

Emissions and calculation summaries for this category are shown in the attached spreadsheet in 

Spreadsheet Table 3-46. 

3.11 Area Source Fuel Combustion

Area source fuel combustion emissions estimates were made for the following SCCs: 

2104006000: Residential Natural Gas Combustion 

2104004000: Residential Distillate Combustion 

2104007000: Residential LPG Combustion 

2104008000: Residential Wood Combustion 

2103001000: Commercial Coal Combustion 
2103006000: Commercial Natural Gas Combustion 

2103004000: Commercial Distillate Combustion 

2103007000: Commercial LPG Combustion 

2103008000: Commercial Wood Combustion 

2102006000: Industrial Natural Gas Combustion 

2102004000: Industrial Distillate Combustion 

2102007000: Industrial LPG Combustion 

2102005000: Industrial Residual Combustion

The methodologies for the area source fuel combustion category came primarily from EIIP Volume III 

and AP-42. The activity factor for the combustion source categories was the amount of each fuel type 

burned. This data was obtained from the U.S. Department of Energy, Energy Information 

Administration (EIA). Data was available for New Hampshire for each fuel type for the residential, 

commercial, and industrial sectors. Point source fuel use was obtained from the NHDES Air Emissions 

Inventory and Reporting program and subtracted from the EIA statewide fuel consumption figures. The 

remaining fuel consumption figures were assumed to apply to the area source category. In the case of 

industrial wood, the net remaining fuel use after subtraction was zero, implying that all industrial wood 

combustion occurs at permitted point sources. 

For the residential sector, the activity data was apportioned to the counties by the number of houses 

that use each fuel type and by heating degree days. For the commercial sector, the data was 

apportioned by heating degree days and employment, and for the industrial sector, the data was 

apportioned by employment. Housing data by fuel type was obtained from the U.S. Census, and 

heating degree day data was obtained from the National Climactic Data Center. Detailed information 

on the fuel consumption and apportionment data that was used in the area source fuel combustion 

estimates can be found in Appendix C, which is enclosed electronically with this submittal. 

Detailed emissions summaries and calculations for each area source fuel combustion category can be 

found in the attached spreadsheet in Spreadsheet Tables 3-47 through 3-59. As mentioned earlier, the 

activity data described above was multiplied by emission factors obtained primarily from EIIP and AP42. The exception was the residential wood combustion category - these estimates were derived using 

EPA's Residential Wood Combustion Tool, Version 3 MV. Emissions estimates for the area source 

fuel combustion category were as follows: 

Area Source Fuel Combustion (pounds per summer day)

VOC NOx 

8-hour NAA 3,001 6,512 

Statewide 5,992 12,480 

3.12 Accidental and Intentional Fires

Emissions estimates for accidental and intentional fires were made for the following SCCs: 

2810030000: Structure Fires 

2810050000: Vehicle Fires 

2610000100: Open Burning, Yard Waste, Leaves 

2610040400: Municipal Yard Waste Burning

The methodologies for structure fires and vehicle fires came from EIIP Volume III, Chapter 18, 

Structure Fires and Volume III Method Abstracts, Vehicle Fires. Data on the number of structure and 

vehicle fires in the U.S. came from a 2009 National Fire Protection Association Document entitled Fire 

Loss in the United States During 2008. The number of fires that occurred in New Hampshire was 

estimated using the proportion of New Hampshire population to U.S. population. Data were further 

apportioned to the New Hampshire counties using population. 
Estimates for open burning of yard waste and municipal yard waste burning were taken from a report 

prepared for the Mid-Atlantic/Northeast Visibility Union (MANE-VU) entitled Open Burning in 

Residential Areas, Emissions Inventory Development Report, January 31, 2004. Because the 

estimates in this report were for 2002, they were grown to 2008 using EGAS. Emissions estimates for 

accidental and intentional fires were as follows: 

Accidental and Intentional Fires (pounds per summer day) 

VOC NOx 

8-hour NAA 87 16 

Statewide 177 35 

Detailed emissions and calculation summaries for these categories can be found in the attached 

spreadsheet in Spreadsheet Tables 3-60 to 3-63. 

3.13 NONROAD Model Sources

Emissions estimates were made for the following SCCs and categories, which are included in EPA's 

NONROAD emissions model for non-road vehicles and equipment: 

2260000000: Off-Highway Vehicles, 2-Stroke Gasoline

2265000000: Off-Highway Vehicles, 4-Stroke Gasoline

2267000000: Off-Highway Vehicles, LPG 

2268000000: Off-Highway Vehicles: CNG 

2270000000: Off-Highway Vehicles: Diesel

As described in Section 1, the non-road emissions source category includes vehicles that generally do 

not travel on public roadways. This category includes a wide variety of vehicles and equipment 

including construction equipment; recreational vehicles such as snowmobiles and ATVs; and lawn and 

garden equipment such as lawnmowers, trimmers, and chain saws. For these types of equipment, 

emissions were estimated using the EPA's NONROAD2008a model for estimating emissions from nonroad vehicles. The NONROAD model does not include aircraft, locomotives, or commercial marine 

vessels; these categories are discussed in the sections that follow. NONROAD model input files 

(*.OPT files) have been provided electronically in Appendix D. Emissions estimates for the non-road 

vehicles contained in the NONROAD model are shown below. It is important to note that these 

estimates do not include airport ground service equipment (GSE). Estimates for airport GSE were 

made separately and are discussed further in Section 3.14. 

Non-Road Vehicles contained in NONROAD (pounds per summer day) 

VOC NOx 

8-hour NAA 32,891 26,710 

Statewide 97,351 53,115 

More detailed emissions estimates for NONROAD model sources are shown in the attached 

spreadsheet in Spreadsheet Tables 3-64 to 3-68. 

3.14 Aircraft, Ground Service Equipment, and Auxiliary Power Units

Aircraft emissions estimates were made for the following SCCs: 

2275020000: Commercial Aircraft 

2275060000: Air Taxis 

2275050000: General Aviation 

2275001000: Military Aircraft 

2270008000: Airport Ground Service Equipment and Auxiliary Power Units
Manchester-Boston Regional Airport is New Hampshire's largest airport. It serves northern New 

England and serves as an alternative airport for the greater Boston area. Emissions estimates for all

aircraft-related categories at Manchester Airport were estimated using the Federal Aviation 

Administration's (FAA) Emissions Dispersion Modeling System (EDMS) Version 5.1.2. These 

estimates were made on behalf of the airport by KM Chng Environmental Inc. and documented in their 

report, Manchester-Boston Regional Airport, 2008 Airport Emissions Inventory, dated September 2010. 

As mentioned above, these estimates addressed all aircraft-related activity at the airport, including 

commercial, commuter, general aviation, and military aircraft as well as ground support equipment 

(GSE) and auxiliary power units (APUs). 

Emissions estimates for other airports in New Hampshire were made by NHDES using aircraft activity 

data taken from the FAA Air Traffic Activity Data System (ATADS) and the GCR & Associates 

5010Web website. The unit of activity for aircraft emissions estimates is the landing-takeoff operation 

(LTO), which represents a complete takeoff and landing cycle. Specific phases of flight represented by 

the LTO include taxi out, takeoff, climb out, approach, landing, and taxi in. LTO activity data was 

multiplied by emission factors taken from references such as Procedures for Emission Inventory 

Preparation, Volume IV: Mobile Sources dated 1992 and Documentation for Aircraft Component of the 

National Emissions Inventory, Methodology dated December 15, 2009. 

Emissions estimates for aircraft, ground support equipment, and auxiliary power units were as follows:

Aircraft, GSE, and APUs (pounds per summer day) 

VOC NOx 

8-hour NAA 443 1,171 

Statewide 655 1,206 

Detailed emissions summaries for aircraft, GSE, and APUs can be found in the attached spreadsheet 

in Spreadsheet Tables 3-69 through 3-73. Further details, including activity and emission factor data, 

can be found in Appendix E, which is submitted electronically along with this documentation. Please 

note that all GSE and APUs have been lumped under a single SCC (2270008000) in this 

documentation (although estimates were made for GSE of all fuel types, a breakdown by fuel type was 

not available). 

3.15 Railroad Locomotives

Locomotive emissions estimates were made for the following SCC: 

2285002006: Railroad Locomotives

The activity factor for this category is the gallons of diesel fuel consumed by the railroads. This data 

was obtained by surveying the railroad companies that operate in New Hampshire. In many cases, the 

railroad companies were able to provide fuel use data for their locomotive operations in New 

Hampshire for 2008. For existing railroad companies that did not respond to the survey, the fuel use 

data that was used for previous inventory cycles was grown to 2008 using EGAS. Emission factors 

were drawn from Technical Highlights, Emission Factors for Locomotives, dated April 2009. 

Locomotive emissions were apportioned to the individual counties using track miles. 

Emissions estimates for locomotives were as follows: 

Locomotives (pounds per summer day) 

VOC NOx 

8-hour NAA 60 1,506 

Statewide 221 5,566 

A more detailed emissions summary for locomotives can be found in the attached spreadsheet in 
Spreadsheet Table 3-74. Further details, including activity data and emission factors, can be found in 

Appendix F, which is included electronically with this submittal. 

3.16 Commercial Marine Vessels

Commercial marine vessel (CMV) emissions estimates were made for the following SCCs: 

2280002200: Commercial Marine Vessels, Underway Emissions 

2280002100: Commercial Marine Vessels, Port Emissions

Emission factors used in the emissions estimates for CMVs were taken primarily from Chapter 7 of 

Final Regulatory Support Document: Control of Emissions from New Marine Compression-Ignition 

Engines at or Above 30 Liters per Cylinder, dated January 2003. Additional emission factor data was 

taken from the MANE-VU Marine Non-road Source Category Calculation Methodology Sheet. 

Additional information used in the calculations included assumptions about the amount of time that 

each vessel spends in the various phases of operation (i.e. cruise, reduced speed zone, maneuvering, 

and hotelling) and the engine load factor associated with each phase. The data used for these 

assumptions were based on Commercial Marine Activity for Deep Sea Ports in the United States, Final 

Report, dated September 1999. 

All major commercial marine vessel activity in New Hampshire occurs in the port of Portsmouth in 

Rockingham County. Monthly pilot reports for the port of Portsmouth were obtained from the Pease 

Development Authority for 2008. These reports provided the name of each vessel that made a call to 

port, the date of its arrival and departure, its dead weight tonnage, and the horsepower of its assist

tugs. These reports provided the activity data necessary to make the emissions estimates using the 

emission factors and operational assumptions described above. In some cases, it was clear from the 

pilot reports that the visiting vessel made a shift from one dock to another during its stay in port. In 

these particular instances, only the emissions associated with maneuvering and the assist tugs were 

accounted for. Emissions for the other phases of operation were accounted for on the days when the 

vessel arrived and departed. For most cases, however, the vessel remained at one dock or terminal 

during its stay, allowing emissions to be calculated for a single, complete cycle of operation. 

Emissions estimates for CMVs are shown below. The port of Portsmouth, where all major CMV activity 

in New Hampshire occurs, lies entirely within the 8-hour ozone non-attainment area. 

Commercial Marine Vessels (pounds per summer day) 

VOC NOx 

8-hour NAA 118 1,977 

Statewide 118 1,977 

CMV emissions estimates for underway and in-port are shown in the attached spreadsheet in 

Spreadsheet Tables 3-75 and 3-76, respectively. Detailed data and calculations for CMVs are provided 

in Appendix G, which is submitted electronically with this documentation. 

4. ON-ROAD MOBILE SOURCES

As described in Section 1, on-road mobile sources represent vehicles that operate principally on 

roadways; this includes cars, trucks, buses, and motorcycles. Historically, the method used to 

calculate emissions from on-road mobile sources was to multiply vehicle activity times an emission 

factor. On-road vehicle activity is commonly expressed in units of vehicle miles traveled (VMT). In the 

past, emission factors were derived from MOBILE6.2. For this 2008 inventory however, NHDES used 

the MOVES model (MOVES2010a). Further, using VMT, vehicle population, and other input data, 

NHDES ran MOVES in inventory mode to produce on-road mobile emissions estimates directly rather 

than use the historic activity times emission factor approach. 
NHDES obtained 2008 VMT from the New Hampshire Department of Transportation and from the 

Metropolitan Planning Organizations (MPOs) that comprise the 8-hour ozone non-attainment area. 

VMT were provided by town, allowing it to be distributed to the applicable geographic regions, including 

the counties and the non-attainment area. The MPOs derived VMT using the traffic demand models 

set up for their specific planning areas. Together, the MPOs' planning areas comprise New 

Hampshire's 8-hour non-attainment area. Therefore, the VMT that was obtained from the MPOs and 

that was used to derive the on-road mobile source emissions estimates was specific to the 8-hour nonattainment area. Vehicle population data were obtained from the New Hampshire Department of 

Safety and from the MPOs. 

On-road mobile source emissions estimates are summarized in Section 1 in Tables 1-1 through 1-4. 

As mentioned in Section 3.1, these estimates include emissions from Stage II vehicle refueling activity. 

Detailed MOVES input files have been submitted electronically as part of the overall submittal package

for the re-designation request for the 8-hour ozone non-attainment area. 
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ATTACHMENT H 

Projected 2012 and 2022 Emissions Inventories 

(Files available on accompanying CD.)