Bryan W. Shaw, Ph.D., P.E., Chairman
Toby Baker, Commissioner

Zak Coval', Commissioner

Richard A. Hyde, P .E., Executive Director



## TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Mr. Ron Curry Administrator PI'Otecting Texas by Reducing and P1-eventing Pollution



### July 22, 2014

Environmental Protection Agency, Region 6 Fountain Place 12 1 h 

### Floor, Suite 1200 1445 Ross Avenue Dallas, Texas 75202-2733

Subject: Redesignation Substitute Report for tbe Houston-Galveston-Brazoria (HGB) One-Hour Ozone Standard Nonattainment Area

Dear Mr. Curry:

The Texas Commission on Environmental Quality (TCEQ) submits the enclosed 

### Redesignation Substitute Report for the Houston-Galveston-Brazoria One-Hour Ozone Standard Nonattainment Area for your consideration and concurrence that the HGB area, which includes Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties, has met the requirements for the one- hour ozone N a tiona! Ambient Air Quality Standard (NAAQS). This redesignation substitute report includes: monitoring data showing attainment of the revoked one-hour ozone NAAQS; a showing that attainment was due to permanent and enforceable emissions reductions; and a demonstration that the area can maintain the standard through 2026 based on emission inventory trends and projections of future emissions.

The United States Environmental Protection Agency's (EPA) 

### Implementation of the 2008 

### National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements; Proposed Rule (zooS ozone standard SIP requirements rule) published in the June 6, 2013 

### Federal Register (78 FR 34178), includes a mechanism for lifting anti-backsliding obligations under a revoked ozone NAAQS. According to tbe proposal, a state can provide a showing, termed a "redesignation substitute," based on Federal Clean Air Act (FCAA), §107(d)(3)(E) redesignation criteria to demonstrate that an area qualifies for lifting anti-backsliding obligations under a revoked standard. The enclosed report fulfills the requirements for a redesignation substitute, as described in the proposed zooS ozone standard SIP requirements rule, for the HGB one-hour ozone nonattainment area.
The 2013 expected exceedances of the 0.12 parts per million one-hour ozone NAAQS for each monitor in tbe HGB area is less than 1.0 days per year and therefore the area is attaining the one-hour ozone standard. On March 7, 2014, the TCEQ submitted to the EPA a certification evaluation and concurrence report for early certification of 2013 ambient air monitoring data for

ozone along with a request for a finding of attainment for the HGB area for the revoked onehour ozone NAAQS.

While tbe proposed 2008 ozone standard SIP requirements rule is not expected to be finalized until this fall, the TCEQ submits this report to you now to facilitate your review of the elements described in FCAA, §107(d)(3)(E) as soon as possible.

P.O. Box13087 • Austin, Texas78711-3087 • 512-239-1000 • tceq.texas.gov

How is our customer service? tceq.texas.govjcustomersurvey

printecl on recyclecl paper using vcgctable"IJased mk

### Mr. Curry Page 2 

### July 22, 2014

If you have questions or need additional information please contact David Brymer, Director of the Air Quality Division, at (512) 239-1725.

Sincerely,

Richard A. 

### Hyde, P.E., Executive Director Texas Commission on Environmental Quality



### RH/DB/lb

Enclosure: 

### Redesignation Substitute Report for the Houston-Galveston-Brazoria One-Hour Ozone Standard Nonattainment AreaR E DESIGNATION SUBSTITU TE REPORT FOR THE HOUSTON

- GALVESTON

- BRAZORIA ONE

- HOUR OZONE STANDARD NONATTAINMENT AREA

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711

- 3087This page intentionally left blankPage 1 SECTION 1: G ENERAL

1.1 P urpose of this Redesignation Substitute Report This redesignation substitute (RS) report for the Houston

- Galveston

- Brazoria ( HGB ) one

- hour ozone nonattainment area fulfills the requirements for a n RS , as described in the United States Environmental Protection Agency’s ( EPA ) Implementation of the 2008 N ational Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements; Proposed Rule (proposed 2008 ozone standard SIP requirements rule) , published in the June 6, 2013 Federal Register (78 FR 34178)

. Data for 2011 through 2013 show that the HGB area is monitoring attainment of the one

- hour ozone National Ambient Air Quality Standard (NAAQS). The HGB area includes Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties. O n March 7, 2014 , the Texas Commiss ion on Environmental Quality (TCEQ) submitt ed to the EPA certified ambient air monitoring data along with a request for a finding of attainment for the HGB area for the revoked one

- hour ozone NAAQS

.

The EPA ’s proposed 2008 ozone standard SIP requirements r ule includes a mechanism for lifting anti

- backsliding obligations under a revoked ozone NAAQS. According to the EPA ’s
propos ed 2008 ozone standard SIP requirements rule , a state can provide a showing , termed a “redesignation substitute,” based on Federal Clean Air Act ( FCAA ) , §107(d)(3)(E) redesignation criteria to demonstrate that an area qualifie s for lifting anti

- backsliding obliga tions under a revoked standard.

This RS report satisfies the EPA’s proposed requirements to lift anti

- backsliding obligation s for the revoked one

- hour ozone NAAQS by ensur ing that specific redesignation requirements are met for the HGB area under the revoked standard

. Data for 2011 through 2013 demonstrate that the HGB area is monitoring attainment of the one

- hour ozone NAAQS, and attainment is due to permanent and enforceable emission reductions. This RS report provides verification of continued attainment of the one

- hour ozone NAAQS through 2026 via emission s inventory (EI) trends and future emission projections

. According to the EPA’s proposed 2008 ozone standard SIP requirements rule, th is RS report is based on FCAA redesignation criteria with the exception of certain elements. Th is report include s the following elements.

M onitoring d ata s howing a ttainment of the r evoked o ne

- h our o zone NAAQS Section 2 : Air Quality Data includes monitoring network and reporting requirements as well as ozone data and trend analyses. The 2013 expected number of exceedances of the 0.12 parts per million (ppm) one

- hour ozone NAAQS in the HGB area i s 0.7 days per year

. Ozone concentrations have decreased dramatically in the HGB area since the 1990s. Examination of the trends in one

- hour ozone design values and the number of expected exceedances reveals substantial downward trends.

S howing that a ttai nment was d ue to p ermanent and e nforceable e missions r eductions Section 3 : Permanent and Enforceable Emissions Reductions identifies permanent and enforceable control measures that have resulted in reductions in nitrogen oxides (NO X

) and volatile organic compounds (VOC) emissions, and air quality improvements in the HGB one

hour ozone nonattainment area. The 30 Texas Administrative Code (TAC) Chapter 115: Control of Air Pollution from Volatile Organic Compounds and 30 TAC Chapter 117: Control of Air Pollut ion from Nitrogen Compounds regulations along with implementation of the Mass Emissions Cap and Trade (MECT) program and the Highly

- Reactive Volatile Organic Compounds Emissions Cap and Trade (HECT) p rogram have significantly reduced overall ozone
precurso r emissions at both major and minor (point and area) stationary sources in the HGBPage 2 ozone nonattainment area. Innovative emissions reduction programs such as the Texas Emissions Reduction Plan (TERP) and the AirCheckTexas Drive a Clean Machine program have reduced mobile source emissions, the primary source of NO X emissions in the HGB area. The HGB area has attained the one

- hour ozone NAAQS as the result of implemented federal, state, and local controls. These enforceable measures will remain in place to ens ure continued maintenance of the one

- hour ozone NAAQS in the HGB area.

D emonstration that the a rea can m aintain the s tandard over the n ext 10 y ears Section 4 : Maintenance Demonstration provides EI trends, the 2011 attainment inventory, and future emissions and verification of continued attainment of the one

- hour ozone standard through 2026. Trend analysis using the 2026 future

- year emissions shows an overall decrease of 176.40 tons per day ( tpd ) in combined NO X and VOC emissions for the HGB area. T his net change includes a projected 18.49 tpd decrease in VOC and a 157.91 tpd decrease in NO X from 2011 to 2026. Based on emissions projections and previous photochemical analysis, continued attainment of the one

- hour ozone standard is shown for the HGB a rea through 2026

.

1.2 One

- Hour Ozone NAAQS History In 1971, t he EPA established the 0.08 ppm one

- hour ozone NAAQS (36 FR 8186). The EPA revised the one

- hour ozone standard to 0.12 ppm or 124 parts per billion ( ppb ) in 1979 (44 FR 4202). In 1990, the eight

- county HGB one

- hour ozone nonattainment area

, defined as Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties, was classified as severe 17 according to the FCAA. At that time, the FCAA also required submission of a SIP revision describing actions to be taken to reduce NO X and VOC by November 1996. Before that deadline, however, modeling showed uncertainties in the actual impact that NO X reductions would have on ground

- level ozone formation. The HGB area was theref ore granted a temporary exemption until December 1997 to fulfill its NO X control requirements after which the HGB area was given a new attainment deadline of November 15, 2007. In 1997, the EPA promulgated the more stringent eight

- hour ozone NAAQS.

T he HGB One

- Hour Ozone Attainment Demonstration and Post

- 1999 Rate

- of

- Progress (ROP) SIP R evision was adopted on December 6, 2000

. The attainment demonstration portion of the submittal contained numerous air pollution control measures resulting in an overall 90 % reduction in point source NO X emissions. Despite this reduction, a modeling analysis included in the SIP revision indicated a shortfall in NO X emissions reductions necessary for an approvable attainment demonstration . To address this shortfall, the SIP re vision also contained enforceable commitments to implement further measures in support of the attainmen t demonstration and to submit a mid

- course review (MCR) to the EPA. T he ROP plan portion of the December 2000 SIP revision submittal provided emissions i nventories, ROP analyses for milestone years 2002, 2005, and 2007, and motor vehicle emissions budget s (MVEB) for NO X and VOC.

On September 26, 2001, the Follow

- Up One

- Hour Ozone Attainment Demonstration and ROP S IP R evision was adopted

. This revision inco rporated changes to several control strategies and detailed the MCR process, which described how the state w ould fulfill the commitment to obtain the additional emission reductions necessary to address the remainder of the emission reductions shortfall and demonstrate attainment of the one

- hour ozone standard in the HGB

area. On November 14, 2001, the EPA published approval of both the December 2000 and September 2001 SIP revisions (66 FR 57159).

The Business Coalition for Clean Air Appeal Group and several regulated companies challenged the December 2000 HGB SIP revision and the 90% NO X reduction requirement from stationaryPage 3 sources. In 2001

, t he Texas Natural Resource Conservation Commission, now the TCEQ

, was required to perform an independent and thorough analysis of the causes of rapid ozone formation events and to identify potential mitigating measures not yet included in the HGB attainment demonstration.

O n December 13, 2002, t he commission a dopted the One

- Hour Ozone Attainment Demonstration Follow

- Up SIP R evision that addressed the agreements contained in the June 8, 2001 consent order . This SIP revision also incorporat ed energy efficiency measures and the T ERP protocol. The December 2002 SIP revision replaced 10% of industrial point source NO X emissions reductions with industrial source

, highly reactive volatile organic compounds ( HRVOC ) controls. The result was an industrial source ozone control strategy that relied on an 80% reduction in NO X emissions through 30 TAC Chapter 117 and the MECT p rogram
, and HRVOC rules in 30 TAC Chapter 115 that better quantified and reduced emissions of HRVOC from four key industrial sources: fugitives, flares, process vents, and cooling tower heat exchange sys tems.

On October 27, 2004, the commission adopted the HGB One

- Hour Ozone Post

- 1999 ROP SIP R evision

. This revision provided updated emissions inventories and ROP analyses for milestone years 2002, 2005, and 2007 and revised MVEB for the HGB area based on n ew models for estimating on

- road and non

- road mobile emissions sources. This SIP revision replaced the previous versions of the Post

- 1999 ROP that the EPA approved in November 2001

. On February 14, 2005, the EPA published approval of this SIP revision (70 FR 7407).

On December 1, 2004, the commission adopted the HGB One

- Hour Ozone Attainment Demonstration MCR SIP R evision reflecting a strategy based on reducing NO X and point source HRVOC rather than NO X alone. Th is SIP revision changed a number of NO X contr ol strategies and added the HRVOC emission reduction requirements. The results of photochemical modeling and technical documentation in cluded in this SIP revision demonstrated attainment of the one

- hour ozone standard by the November 15, 2007 deadline

. The one

- hour ozone SIP revision commitments addressed in this revision include d : completion of a one

- hour ozone MCR; adoption of measures sufficient to address the shortfall in NO X reductions; adoption of measures sufficient to demonstrate attainment; MVE B updates using EPA’s MOBILE6 model; and changes to voluntary mobile emissions reduction program measures.

On September 6, 2006, the EPA published approval of the HGB area’s one

- hour ozone attainment demonstration and associated rules (71 FR 52656). The ap proval was published in six parts covering the rules for the control of HRVOC, the one

- hour ozone attainment plan, the H ECT p rogram for HRVOC, the MECT p rogram for NO X , the Emissions Credit Banking and Trading P rogram, and the Discrete Emissions Credit Ban king and Trading P rogram.

The HGB area failed to attain the one

- hour ozone standard by the November 15, 2007 attainment deadline, and the EPA published a failure

- to

- attain determination o n June 19, 2012 based on air quality monitoring data for 2005 through 2007 (77 FR 36400 ). Although the EPA revoked the one

- hour ozone NAAQS in June 2005, former one

- hour ozone nonattainment areas remain subject to certain anti

- backsliding requirements . The three anti

- backsliding requirements that apply to the HGB severe one

- hour ozone nonattainment area are contingency

measures , new source review (NSR) permitting requirements for severe nonattainment areas,Page 4 and a penalty fee provision 1

. The anti

- backsliding requirement for contingency measures under FCAA, §172(c)(9) and § 182(c)(9) has already been achieved in the HGB area 2 , and a final determination of failure to attain does not trigger additional emission reductions. The NSR permitting requirements would apply for the one

- hour ozone NAAQS until the RS request is approved by the EPA, after which Prevention of Significant Deterioration permitting requirements would apply. However, because the HGB area is also classified as severe nonattainment for the 1997 eight

- hour ozone NAAQS, severe area NSR permitting requirements would still apply whether or not this RS is approved by the EPA. The anti

- backsliding requirement to implement a penalty fee program under FCAA, §182(d)(3) and §185 was triggered with the EPA’s failure

- to

- attain determination, and it continues to apply to the H GB

one

- hour ozone nonattainment area unless th e obligation is terminated. On May 22, 2013, the commission adopted rules under 30 TAC Chapter 101 : General Air Quality Rules , Subchapter B to implement these FCAA provisions.

SECTION 2: AIR QUALITY DATA
2.1 Monitoring Network and Reporting Requirements The method chosen to verify continued attainment of the one

- hour ozone National Ambient Air Quality Standard (NAAQS) is the ambient air quality monitoring network , which will be used to track changes in the ambient air quality.

The Houston

- Galveston

- Brazoria (HGB) area monitoring network in 2014 consists of 21 regulatory ambient air ozone monitors located in Brazoria, Galveston, Harris, and Montgomery Counties, Texas. The City of Houston oper ates eight of the monitors: Clinton ( C403/C113/C304 ) ; Houston North Wayside ( C405 ) ; Houston Monroe ( C406 ) ; Lang ( C408 ) ; Houston Croquet ( C409 ) ; Houston Westhollow ( C410 ) ; Houston Texas Avenue ( C411 ) ; and Park Place ( C416 ). The Texas Commission on Environme ntal Quality (TCEQ) operates the remaining 13 ozone monitors : Houston East ( C1 ) ; Houston Aldine ( C8/C108/C150 ) ; Channelview ( C15/C115 ) ; Northwest Harris County ( C26 ), Houston Deer Park #2 ( C35/C139 ), Seabrook Friendship Park ( C45 ) ; Houston Bayland Park ( C53 ) ; Conroe Relocated ( C78 ) ; Manvel Croix Park ( C84 ) ; Lynchburg Ferry ( C1015 ) ; Lake Jackson ( C1016 ) ; Baytown Garth ( C1017 ) ; and Galveston 99th Street ( C1034 ).

The monitors are managed in accordance with 40 Code of Federal Regulations ( CFR ) Part 58 to veri fy the attainment status of the area. The TCEQ commits to keep in operation an appropriate air monitoring network in the HGB area and wil l continue to work with the EPA through the air monitoring network review process, as required by 40 CFR Part 58, to de termine: 1) the adequacy of the ozone monitoring network; 2) if additional monitoring is needed; and 3) when monitoring can be discontinued. Air monitoring data from these monitors will continue to be quality assured according to the requirements in EPA ’s regulations until the end of the maintenance period (2026 ) and report ed to the EPA on the schedule required by 40 CFR Part 58.

1 South Coast v. EPA, 472 F.3d 882 (D.C. Cir. 2006), directed the EPA to provide one

- hour ozone NAAQS
anti

- backsliding requirements for nonattainment new source review , §185 fees

, and §172(c)(9) and §182(c)(9) contingency measures for failure to attain the one

- hour ozone NAAQS by the applicable attainment date or to make reasonable further progress toward attainment of that standard.

2 The EPA

- approved one

- hour ozone attainment demonstration and ROP SIP revisions included contingency measures (71 FR 52670, 70 FR 7407, 66 FR 57195, and 66 FR 20750).Page 5 2.2 Ozone Data
The rest of this section provides an analysis of air quality observational data in the HGB area. While the ozone NAAQS is expressed in units of parts per million (ppm), the familiar convention of expressing concentrations in parts per billion (ppb) is also used in this section. Data for ozone and nitrogen oxides ( NO X

) were retrieved from United States Environmental Protection Agency’s ( EPA ) Air Quality System database, and VOC data were retrieved from TCEQ’s automated gas chromatograph ( auto

- GC ) database. Analyses of ozone data from federal reference method monitors and federal equivalent method monitors, those used by the EPA to compare to the NAAQS, are included in this section.

2.3 Ozone Trend Analysis
Trends in ozone are used to demonstrate the substantial progress the HGB area has made in improving air quality

. The downward trend in design values for the one

- hour ozo ne NAAQS in the HGB area is seen clearly in Figure 2

- 1: One

- Hour Ozone Design Values for the HGB Area

. In both 2011 and 2012, the one

- hour design value for t he HGB area was 0.13 ppm (or 125 ppb), which is just above the 0.12 ppm one

- hour ozone NAAQS

. I n 20 13 , however, the HGB area monitored attainment with a design value of 0.12 ppm (or 121 ppb). The design value for each monitor is the fourth

- highest concentration over a three

- year period, and the design value for the area is the highest of the design valu es from the individual monitors within the area. The

one

- hour ozone design value in the HGB area has shown large decreases over the past 24 years; the design value of 121 ppb achieved in 2013 represents a 45% decrease from the 1990 design value of 220 ppb.

Figure 2

- 1 : One

- Hour Ozone Design Values for the HGB AreaPage 6 F or the one

- hour ozone NAAQS, the design value was used to determine the classification of a nonattainment area but was not used for designating an area as attainment or otherwise. Designation is based on the maximum number of expected exceedances over all the monitors in

an area 3

. To show that the HGB area no longer violates the one

- hour ozone NAAQS, the remainder of this section will be based on expected exceedances , calculated as per 40 CFR Part 50

, Appendix H.

The expected number of exceedances of record in a metropolitan area is the maximum expected number of exceedances of all the area’s regulatory monitors’ individual expect ed number of exceedances . Because ozone concentrations var y spatially, it is also prudent to investigate trends at all regulatory monitors in an area. Table 2

- 1: One

- Hour Ozone Expected Exceedances by Monitor contain s one

- hour ozone expected number of exceedances at all regulatory monitors in the HGB area from 2000 t hrough 20 13 . More monitors than those listed in Table 2

- 1 operate in the HGB area, but expected number of exceedances at those additional monitors are not appropriate for compliance determin ations because the monitors’ data do not meet EPA’s quality assurance criteria and cannot be used for regulatory purposes

. In 2013, all monitors in the HGB area had expected exceedance s less than the threshold of 1.0 per year and o nly one monitor in the HG B area, the Houston East monitor (C1), had more than 1 .0 expected exceedance in 2011 and 2012

.

3 The expected exceedances for a monitor is defined as the number of exceedances that occ urred in the calendar year plus an increment that accounts for missing data , averaged across three consecutive years (for example, expected exceedances for 2013 is averaged across 2011, 2012, and 2013). The increment is calculated by finding the number of days without an associated ozone measurement that may not be assumed to be less than the standard

, multiplied by the number of observed exceedances

, then divided by the number of observations. This is done for each year and then averaged across three years to get the expected exceedances for that individual monitor. Note that unlike the calculation for expected exceedances, design values are not adjusted for data completeness.Page 7 Table 2

- 1 : One

- Hour Ozone Expected Exceedances by Monitor

Site Name20002001200220032004200520062007200820092010201120122013

Manvel Croix
Park C84 1.7 2.0 2.7 2.7 3.4 2.1 1.4 0.7 0.3 0.7 0.7 0.7

Houston East
C1 10.0 9.5 7.4 6.0 4.7 3.4 1.7 0.7 0.7 0.0 0.7 1.3 1.3 0.7

Northwest Harris County
C26 7.1 6.8 5.2 4.1 2.4 1.7 1.7 2.0 1.3 1.4 0.7 0.7 0.7 0.7

Houston Bayland Park
C53 14.4 12.2 7.1 6.4 4.4 5.4 5.1 3.7 1.7 0.3 0.3 0.7 0.7 0.7

Houston
Monroe C406 8.2 7.2 5.4 4.4 3.4 3.4 3.4 2.7 1.0 0.3 0.3 0.3 0.7 0.7

Seabrook Friendship
Park C45 3.7 5.4 4.0 3.7 2.7 2.0 1.0 0.3 0.0 0.0 0.3 0.7

Galveston 99th
St C1034 0.0 0.0 0.0 0.0 0.4 0.4 0.4

Park Place
C416 2.7 3.4 1.0 1.3 0.7 0.7 0.3

Houston Aldine C8/C108/C150 11.6 10.9 8.4 5.0 3.0 3.4 1.4 0.7 0.0 0.0 0.3 0.7 0.7 0.3

Houston Croquet C409 10.9 8.3 5.2 4.4 4.3 4.0 3.0 1.7 0.3 0.3 0.3 0.3 0.3 0.3

Houston Texas
Avenue C411 2.2 4.9 3.7 3.7 1.4 0.7 0.7 0.7 0.3 0.3 0.3 0.3

Clinton C403/C113/C3
04 10.2 9.9 6.2 5.5 3.7 3.1 1.0 0.3 0.0 0.3 0.3 0.3 0.3 0.3

Houston North Wayside C405 9.3 6.9 4.8 2.4 2.7 2.4 0.7 0.0 0.0 0.0 0.0 0.3 0.3 0.3

Houston Regional Office
C81 5.4 6.5 5.1 3.1 3.0 2.0 1.7 0.7 0.0 0.0 0.3 0.3 0.3

Channelview C15/C115 2.5 4.5 4.3 3.3 2.0 1.7 1.0 0.7 0.7 0.7 0.4 0.0

Lynchburg Ferry C1015 6.8 8.8 4.7 2.4 0.3 0.0 0.4 0.4 0.4 0.0

Houston Deer Park 2 C35/C139 11.6 11.2 8.2 6.2 5.8 5.2 4.1 2.4 1.7 1.1 1.1 0.7 0.0 0.0

Lang C408 6.2 4.5 3.9 2.4 2.7 2.0 1.3 0.0 0.0 0.3 0.3 0.3 0.0 0.0Page 8 Site Name20002001200220032004200520062007200820092010201120122013

Lake Jackson
C1016 0.6 0.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Houston Westhollow
C410 7.7 7.9 4.5 3.4 2.1 1.7 2.4 2.0 1.7 0.3 0.0 0.0 0.0 0.0

Conroe Relocated C78 0.3 1.0 1.3 1.3 1.3 1.0 0.7 0.0 0.0 0.0 0.0 0.0

Galveston Airport C34/C109 5.7 3.7 1.4 1.1 1.4 1.4 0.3 0.0

Texas City C10 4.4 3.4 1.0 0.3 0.3
Clute C11 2.4 2.0 1.4 1.5
Conroe C65 3.1 4.0 2.6
Houston Crawford C407 8.4 4.4

Number of
monitors 16 17 20 20 21 20 20 22 21 21 21 21 21 21

Figure 2

- 2: One

- Hour Ozone Expected Exceedance Statistics for All Monitors in the HGB Area displays the statistically summarized maximum, median, and minimum one

- hour ozone expected number of exceedances averaged across three years computed across all monitors in the HGB area. This figure shows the range of expected number of exceedances average d across three consecutive years observed at all regulatory monitors as well as how these distributions change d over time. The one

- hour ozone expected number of exceedances exhibit ed a noticeable downward trend from 1990 until about 199 4

, and again after 1 999 . Before 2002, no monitors in the HGB area met the one

- hour ozone NAAQS; since then, the area has seen a steady increase in the number of monitors attaining the standard. By 2013, all monitors in the HGB area were below or equal to the one

- hour ozone NA AQS expected number of exceedances of 1.0 days per
year

.Page 9 Figure 2

- 2 : One

- Hour Ozone Expected Exceedance Statistics for All Monitors in the HGB Area

2.4 Trend Analysis for Ozone Precursors
Decreases in NO X and volatile organic compounds ( VOC ), precursors to ozone formation, demonstrate the effectiveness of control measures in reducing emissions; however, due to its dependence on meteorological variables, ozone concentrations may not always exhibit trends identical to the concentrations of its precursors. This section evaluates trends in concentrations of NO X and VOC. Only data that met data completeness checks are used in this section. To meet the completeness check, each day must contain at least 18 valid hours of data

, each month must contain at least 75% of days with data, each quarter must have at least two months of data, and each year must contain at least three quarters of data

.

NO X are a variable mixture of nitric oxid e and nitrogen dioxide and are critical precursors to ozone formation. As NO X emissions decrease, ambient concentrations of these compounds should also decrease. NO X are primarily created by fossil fuel combustion, lightning, biomass burning, and microbial action in soil.

Annual maxima, annual 90 th percentile

, and annual average daily peak one

- hour NO X values observed in the HGB area are plotted in Figure 2

- 3 : Annual Maxima, 90th Percentile and Average of Daily Peak NOx V alues (ppb) in the HGB Area

, 2000 through 2013 . The figure uses a logarithmic scale so that all three statistics are visible, and a linear regression line was added to each statistic. The linear regression line of the yearly maximum shows a negative slope of 19.9Page 10 parts per billion ( p pb ) per year with a correlation coefficient (r 2 ) of 0.59, and the regression line of the yearly 90th percentile shows a negative slope of 3.6 ppb per year with an r 2 of 0.76. The linear regression line of the yearly average shows a negative slope of 1.8 pp b per year with an r 2 of 0.83. All three measures decreased markedly over the period from 2000 t hrough 201 3 , falling 25% (maximum), 24% (90 th percentile), and 28% (mean). Strong downward trends in ambient NO X concentrations are evidence of the effectivenes s of the emission controls depict ed in the emission

- trend data.

Figure 2

- 3 : Annual Maxima, 90th Percentile and Average of Daily Peak NO X Values (ppb) in the HGB Area, 2000 through 2013

The other major class of ozone precursors is VOC. Since the mid

- 1990s, the TCEQ has collected 40

- minute measurements, on an hourly basis, of over 4 0 species of VOC using auto

- GC instruments. This section focuses on two prevalent compounds , ethylene and pro pylene, that are associated with rapid and efficient ozone formation

. Since the majority of VOC production occurs along the Houston Ship Channel, the eight auto

- GC instruments near the area were examined. Yearly geometric means were computed from valid amb ient hourly measurements

. A geometric mean was calculated by taking the natural logarithm of each measurement, averaging these logs, and then calculating the antilog of this mean log value. The geometric mean is a preferable statistic to median or arithmet ic (ordinary) mean for evaluating the central tendency of data when the data are skewed, i.e. , when the data are not symmetrically, or normally, distributed, but instead clustered around extreme high or low values. A geometric mean is more robust than an o rdinary average, in that its value is not greatly influenced by one or a few veryPage 11 high or very low values. Many distributions of pollutant measurements , especially VOC, in the HGB area are skewed.

The annual geometric mean of ethylene concentrations in par ts per billion carbon (ppbC) is shown in Figure 2

- 4 : Yearly Geometric Mean Ethylene Concentrations (ppbC) at the Eight Houston Ship Channel Monitors, 2000 through 2013 . Prior to 2004, only three of the eight monitors had enough valid data to calculate annu al geometric mean ethylene. Generally, the geometric mean ethylene concentrations at all of the auto

- GC monitors ha ve decreased

. Ethylene at the Channelview monitor (C15) steadily decreas ed until 2013 when the geometric mean ethylene increased. Ethylene at the H ouston R egional M onitoring Corporation (HRM) 3 Haden Road non

- regulatory, industry

- sponsored monitor (C603) began increasing in 2011 and 2012 but resumed its decreasing trend in 2013.

Figure 2

- 4 : Yearly Geometric Mean Ethylene Concentrations (ppbC) at the Eight Houston Ship Channel Monitors, 2000 through 2013

Figure 2

- 5: Yearly Geometric Mean Propylene Concentrations (ppbC) at the Eight Houston Ship Channel Monitors, 2000 through 2013 shows the an nual geometric mean for propylene. Like ethylene, only three of the eight monitors had enough data to calculate annual geometric mean propylene prior to 2004. Note that the y

- axis in this figure is the same as in Figure 2

- 5

. The geometric means for propyle ne are lower than the geometric means for ethylene for all the years. All monitors showed a steady decrease in geometric mean propylene from 2000 through 2013. Though decreasing at different rates , these long

- term decreases in ambient concentrationsPage 12 of eth ylene and propylene suggest overall industrial emissions of these compounds have decreased considerably since 2000.

Figure 2

- 5 : Yearly Geometric Mean Propylene Concentrations (ppbC) at the Eight Houston Sh ip Channel Monitors, 2000 through 2013

2.5 Ozone Data and Trend Analysis Summary Ozone concentrations decreased dramatically in the HGB area since the 1990s. In 2013, the three

- year average expected number of exceedances met the one

- hour ozone standard of 1.0 days per year . Examination of the trends in one

- hour ozone three

- year average expected number of days where the one

- hour ozone exceeded 0.12 ppm reveals substantial downward trends. Evaluation of local changes of ozone precursors showed similar significan t downward trends. These results suggest that the significant ozone reductions achieved in the HGB area are primarily due to local emission reductions

.

SECTION 3: PERMANENT AND ENFORC EABLE EMISSIONS REDU CTIONS
3.1 Control Measures
The Houston

- Galveston

- Brazoria (HGB) nonattainment area for the one

- hour ozone National Ambient Air Quality Standard (NAAQS), which consists of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties, includes one of the most comprehensively controlled industrial complexes in the world. The Texas Commission onPage 13 Environmental Quality (TCEQ) has developed stringent and innovative regulations that address nitrogen oxides (NO X

), volatile organic compounds (VOC), and highly reac tive volatile organic compounds (HRVOC).

3.2 List of Existing Control Measures
Over decades of air quality planning to improve ozone levels in the HGB area, a broad range of control measures have been implemented for each emission source category

. Table 3

- 1: E xisting Ozone Control Measures Applicable to the HGB Eight

- County Nonattainment Area lists the existing ozone control strategies that have been implemented for the one

- hour and 1997 eight

hour ozone standards in the HGB area. The measures listed in Table 3

- 1 are permanent and enforceable and are included in the applicable implementation plan in accordance with Federal Clean Air Act (FCAA), §107(d)(3)(E)(iii)

.

Table 3

- 1 : Existing Ozone Control Measures Applicable to the HGB Eight

- County Nonattainment Area

Measure Description Start Date(s)

NO X Mass Emissions Cap and Trade (MECT) Program

30 Texas Administrative Code (TAC) Chapter 101, Subchapter H, Division 3 Overall 80% NO X reduction from existing industrial sources and utility power plants, implemented through a cap and trade program

Affects utility boilers, gas turbines, heaters and furnaces, stationary internal combustion engines, industrial boilers, and many other indus trial sources April 1, 2003 and phased in through April 1, 2007

HRVOC Rules and Highly Reactive Volatile Organic Compounds Emissions Cap and Trade (HECT) Program

30 TAC Chapter 101, Subchapter H, Division 6 Affects cooling towers, process vents, and flar es, and establishes an annual emissions limit with a cap and
trade for each applicable site in Harris County

Seven perimeter counties subject to permit allowable limits and monitoring requirements Monitoring requirements began January 31, 2006

Cap and t rade program implemented January 1,
2007

HECT cap incrementally stepped

- down from 2014 through 2017 for a total 25% cap reduction HRVOC Fugitive Rules

30 TAC Chapter 115, Subchapter D, Division 3 More stringent leak detection and repair (LDAR) requirements for components in HRVOC service

Additional components included in LDAR program: more stringent repair times, lower leak detection, and
third

- party audit requirements March 31, 2004

VOC Control Measures

– Storage Tanks

30 TAC Chapter 115,
Su bchapter B, Division 1 Requires controls for slotted guide poles and more stringent controls for other fittings on floating roof tanks, and control requirements or operational limitations on landing floating roof tanks

Eliminates exemption for storage tan ks for crude oil or natural gas condensate, and regulates flash emissions
from these tanks January 1, 2009

Compliance with revised monitoring and testing requirements required by March 1, 2013Page 14 Measure Description Start Date(s)
VOC Control Measures

– Degassing Operations

30 TAC Chapter 115, Subchapter F, Division 3 Requires vapors from degassing to be vented to a control device for a longer time period, and removes exemption from degassing to control for tanks with capacity of 75,000 to 1,000,000 gallons

Clarification of rule and monito ring and testing requirements, additional control options, and notification requirements January 1, 2009

February 17, 2011

NO X Emission Standards for Nitric Acid and Adipic Acid Manufacturing

30 TAC Chapter 117, Subchapter F NO X emission standards for nitric acid and adipic acid manufacturing facilities in the HGB area November 15, 1999

Utility Electric Generation in
East and Central Texas

30 TAC Chapter 117, Subchapter E, Division 1 NO X control requirements (approximately 55 % ) on utility boilers and stationary gas turbines at utility electric generation sites in East and Central Texas May 1, 2003 through May 1, 2005

VOC Control Measures

30 TAC Chapter 115 Additional control technology requirements for batch processes and bak eries by December 31, 2002

Additional VOC measures adopted earlier for reasonably available control technology (RACT) purposes: general vent gas control, industrial wastewater, loading and unloading operations, general VOC LDAR, solvent using process, etc . (see Appendix D: Reasonably Available Control Technology Analysis of
the Houston

- Galveston

- Brazoria Attainment Demonstration State Implementation Plan Revision for the 1997 Eight

- Hour Ozone Standard adopted March 10, 2010 (2010 HGB AD SIP Revision) for m ore details) December 31, 2002 and
earlier

VOC Control Measures

– Offset Lithographic Printers

30 TAC Chapter 115, Subchapter E, Division 4 Additional control technology requirements for offset lithographic printers

Revised in 2010 to limit VOC content of solvents used by offset lithographic printing facilities and to include smaller sources in rule applicability (see Appendix D of the 2010 HGB AD SIP Revision for more details) December 31, 2002

March 1, 2011 for major

sources

March 1, 2012 for minor

sourcesPage 15 Measure Description Start Date(s)
VOC Control Measures

– Solvent

- Using Processes

30 TAC Chapter 115, Subchapter E Revised in 2011 to implement RACT requirements per control technique guidelines published by the United States Environmental Protection Agency (EPA)

Seven emission s ource categories in the HGB area: industrial cleaning solvents; flexible package printing; paper, film, and foil coatings; large appliance coatings; metal furniture coatings; miscellaneous metal and plastic parts coatings; and miscellaneous industrial
adhe sives (see Houston

- Galveston

- Brazoria Reasonably Available Control Technology Analysis Update State Implementation Plan Revision for the 1997 Eight

- Hour Ozone Standard adopted December 7, 2011 for more details) March 1, 2013

Refueling

– Stage I

30 TAC Chapter 115, Subchapter C, Division 2 Captures gasoline vapors that are released when gasoline is delivered to a storage tank

Vapors returned to the tank truck as the storage tank is being filled with fuel, rather than released into the
ambient air 1990

Refueling

– Stage II

30 TAC Chapter 115, Subchapter C, Division 4 Captures gasoline vapors when a vehicle is being fueled at the pump

Vapors returned through the pump hose to the petroleum storage tank, rather than released into the
air 1992

A SIP revision authorizing the decommissioning of Stage II vapor control equipment was submitted to the EPA on October 31, 2013

. Facilities may continue operating Stage II until August 31, 2018. Federal Area/Non

- Road
Measures Series of emissions limits, i mplemented by the EPA, for
area and non

- road sources Examples: diesel and gasoline engine standards for
locomotives and leaf

- blowers Through 2018

Texas Emissions Reduction
Plan (TERP)

30 TAC Chapter 114, Subchapter K Provides grant funds for on

- road and non

- road heavy

duty diesel engine replacement/retrofit January 2002

California Standards for Certain Gasoline Engines California standards for non

- road gasoline engines 25 horsepower and larger May 1, 2004

Stationary Diesel Engines

30 TAC Chapter 117, Subchapter B, Division 3 Prohibition on operating stationary diesel and dual

fuel engines for testing and maintenance purposes
between 6:00 a.m. and noon April 1, 2002Page 16 Measure Description Start Date(s)
Natural Gas

- Fired Small Boilers, Process Heaters,
and Water Heaters

30 TAC Chapter 117, Subchapter E, Division 3 NO X emission limits on small

- scale residential and industrial boilers, process heaters, and water heaters equal to or less than 2.0 million British thermal units per hour 2002

Minor Source NO X Controls
for Non

- MECT Sites

30 TAC Chapter 117, Subchapter D, Division 1 NO X emission limits on boilers, process heaters, stationary engines, and turbines at minor sites not included in the MECT program (uncontrolled design capacity to emit less than 10 tons per year) March 31, 2005

Te xas Low Emission Diesel (TxLED)

30 TAC Chapter 114, Subchapter H, Division 2 Requires all diesels for both on

- road and non

- road use to have a lower aromatic content and a higher cetane
number Phase in began October 31, 2005

TxLED for Marine Fuels

30 TAC Chapter 114, Subchapter H, Division 2 Adds marine distillate fuels X and A, commonly known as DMX and DMA, or Marine Gas Oil, into the definition of diesel fuels, requiring them to be TxLED compliant June 24, 2007

Texas Low Reid Vapor Pressure (RVP) Gaso line

30 TAC Chapter 114, Subchapter H, Division 1 Requires all gasoline for both on

- road and non

- road use to have a RVP of 7.8 pounds per square inch or less from May 1 through October 1 each year April 2000

Voluntary Mobile Emission Reduction Program Vo luntary measures administered by the Houston

Galveston Area Council (H

- GAC) (see Appendix F: Evaluation of Mobile Source Control Strategies for the
Houston

- Galveston

- Brazoria State Implementation Plan (With Detailed Strategies) , prepared for H

- GAC by ENVIRON International Corporation, of the 2010 HGB AD SIP Revision) Through 2018

Federal On

- Road Measures Series of emissions limits, implemented by the EPA, for

on

- road vehicles

Examples: Tier 1 and Tier 2 vehicle standards, low sulfur diesel standards, National Low Emission Vehicle standards, and reformulated gasoline Phase in through 2013

Vehicle Inspection/
Maintenance

30 TAC Chapter 114, Subchapter C Yearly treadmill

- type testing for pre

- 1996 vehicles and computer checks for 1996 and newer vehicles May 1, 2002 in Harris County

May 1, 2003 in Brazoria, Fort Bend, Galveston, and Montgomery
Counties Speed Limit Reduction

43 TAC Chapter 25, Subchapter B Five miles per hour (mph) below what was posted before May 1, 2002, on roadways where speeds were 65 mph or higher September 2003Page 17 Measure Description Start Date(s) Transportation Control
Measures Various measures in H

- GAC’s long

- range transportation plans (see Appendix F of the 2010 HGB AD SIP Revision for more details) Phase in through 2018

Voluntary Energy Efficiency/Renewable Energy Energy efficiency and renewable energy projects encouraged by Senate Bill (SB) 7, 76th Texas Legislature, 1999 and SB 5, 77th Texas Legislature,
2001 September 1, 1999 and September 1, 2001

Automotive Windshield
Washer Fluid

30 TAC Chapter 115, Subchapter G, Division 1 VOC content limitation on automotive windshield washer fluid sold, supplied, distributed, or
manufactured for use in Texas January 1, 1995

The following control measures being implemented in the HGB area are permanent and enforce able, but t he emissions reductions from these control measures were not included in previous HGB attainment demonstration SIP revisions.

3.2.1 Control of Volatile Organic Compounds Emissions from Storage Tanks In May 2007, the commission adopted revisions to the rules in 30 TAC Chapter 115, Subchapter B, Division 1 for VOC storage tanks located in th e HGB ozone nonattainment area. The revised requirements reduce uncontrolled VOC flash emissions at oil and gas exploration and production sites and other VOC emissio ns from storage tanks. These amendments to Chapter 115 are described in more detail in the preamble of the adopted rule ( 32 TexReg 3178 ) (http://www.tceq.texas.gov/assets/public/implementation/air/rules/texas

- register/32

- texreg

3178.pdf).

Although these rules result ed in actual reductions in flash emissions, no credit was claimed in the 2010 HGB AD SIP Revision. At the time the rules were a dopted, it was unknown how many affected sites would be required to install controls. In 2010, ENVIRON International Corporation (ENVIRON) Project 06

- 17477T quantified the VOC emission reductions resulting from the implementation of these Chapter 115 requi rements to control VOC flash emissions from crude oil and condensate storage tanks in the HGB ozone nonattainment area. Based upon area source emissions inventory development methods at the time of publication, ENVIRON Project 06

- 17477T estimated th at the Chapter 115 rules would result in 10,683 tons of VOC reductions per year (29.3 tons of VOC reductions per day) in the HGB area. More information

on ENVIRON Project 06

- 17477T can be found on the TCEQ website (http://www.tceq.texas.gov/assets/public/implementation/air/am/contracts/reports/ei/58207 84005FY1022

- 20100831

- environ

- flash_emission.pdf).

3.2.2 Mass Emissions Cap and Trade Program
The MECT p rogram uses an annual cap to limit the amount of NO X emissions from all applicable sources in the HGB area. The MECT program allocated NO X allowances to applicable facilities in the HGB area based on actual levels of activi ty from the years 1997 through 1999. These allowances are referred to as actual allowances. The program also allocated allowances to certain applicable facilities based on their permit limit. These allowances are referred to as allowable allowances and wer e allocated to facilities that had not yet been built or had not been operational long enough to establish baseline data. Applicable facilities that do not meet the criteria for receiving an allocation of actual or allowable allowances must acquire allowan ces from facilities in the program that receive an allocation of actual allowances. Additionally,Page 18 facilities that were allocated allowable allowances are required to revise their allocation to be based on actual operating data after an operational baseline period has been established. Participation in the MECT p rogram is mandatory for all applicable sources.

The photochemical modeling for the 2010 HGB AD SIP Revision included 120.0 tons per day ( tpd ) of NO X emissions in 2018 based on the October 2009 MECT cap. The modeled MECT cap is a function of the actual allowance allocations, allowable allowance allocations, and the conversion of emission reduction credits to allowance allocations. The projected 2018 MECT cap, as of March 2014 is 109.9 tpd of NO X emiss ions, which is a reduction of 10.1 tpd of NO X emissions from the modeled MECT cap. This reduction can be attributed to facilities revising allowance allocations based on permit limits to allocations based on actual operating data since typically most facil ities operate below their permit limits. Further MECT cap reductions are expected in the future due to sources that have yet to convert their allowable allowances into actual allowances and companies that choose to permanently retire allowances to comply w ith the requirements of other air quality programs.

3.2.3 Tier 3 Motor Vehicle Emission and Fuel Standards
On April 28 , 2014, the EPA published the final rule for the new Tier 3 Motor Vehicle Emission and Fuel Standards (79 FR 23414)

. Tier 3 emission standards will apply to new, light

- duty motor vehicles, light

- duty trucks, and medium

- duty passenger vehicles beginning model year 2017 and will be fully phased in by model year 2025. Tier 3 emission standards will also apply to chassis

ce rtified Class 2b and Class 3 heavy

- duty vehicles beginning model year 2018 and will be fully phased in by model year 2022. The Tier 3 emission standards also extend the regulatory useful life period during which the standards apply from 120,000 miles to 15 0,000 miles.

When fully implemented, the Tier 3 exhaust emission standards for light

- duty vehicles will provide approximately an 80% reduction in non

- methane organic gases (NMOG) and NO X (NMOG+NO X

) standards and a 70% reduction in per

- vehicle particulate m atter ( PM ) standards when compared to the current fleet average. The Tier 3 exhaust standards for heavy

- duty vehicles provide about a 60% reduction in both fleet average NMOG+NO X standards and per

vehicle PM standards when com pared to the current standards

. Tier 3 fuel standards will limit gasoline sulfur to no more than 10 parts per million ( ppm ) of sulfur on an annual average basis beginning January 1, 2017, a reduction of approximately 66% when compared to the current standard. The current gasoline sulfu r standards specifying an 80 ppm refinery gate cap and 95 ppm downstream cap are maintained under the new Tier 3 fuel standards. Removing sulfur from gasoline allows a vehicle’s catalyst to work more efficiently. The Tier 3 gasoline sulfur standard will ma ke emission control systems more effective for both existing and new vehicles, and will enable automobile manufacturers to meet the more stringent Tier 3 vehicle emissions standards.

3.2.4 New International Marine Diesel Engine and Marine Fuel Standards for Ocea ngoing Vessels and Emissions Control Areas In March 2009, the United States (U.S.) government submitted a request to the International Maritime Organization (IMO) for the creation of an emissions control area (ECA) around the nation's coastlines. The reque st was granted and the North American ECA was officially designated by the IMO on March 26, 2010 and became enforceable in August 2012. All marine diesel fuels used by oceangoing vessels (OGV) in the North American ECA will be limited to a maximum sulfur c ontent of 1,000 ppm beginning January 1, 2015, and all new engines on OGV operating in these areas must use emission controls that achieve an 80% reduction in NO X emissions beginning January 1, 2016.Page 19 The EPA regulations for marine diesel fuel and new marin e engines less than 30 liters per cylinder displacement and the new International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI standards for marine residual fuels and new marine diesel engines above 30 liters per cylinder displac ement will apply to all OGV flagged and registered in the U.S. The EPA's regulations for new Category 3 marine engines and new sulfur limits for marine diesel fuel will also apply to all OGV flagged and registered in the U.S. In addition, the new MARPOL An nex VI standards will apply to all new marine diesel engines and fuels on foreign marine vessels that operate near U.S. coasts and ports.

The new marine diesel engine and fuel standards will provide a 96% reduction in sulfur in marine diesel fuels, as well as an 85% reduction in PM emissions and an 80% reduction in NO X emissions, when compared to current stan da rds 4

. Cumulatively, these new marine diesel engine and fuel standards are estimated by the EPA to result in a 0.5 to 1.0 parts per billion ( ppb ) redu ction of ozone in the ambient air of the HGB ozone nonattainment area by 2020 5

.

3.3 Additional Measures
Additional air quality improvement measures being implemented in the HGB area are described in t his section . T hese additional measures are beneficial toward reducing ozone and assure that the HGB area will continue to maintain the one

- hour ozone standard.

3.3.1 SmartWay Transport Partnership and the Blue Skyways Collaborative Among its various efforts to improve air quality in Texas, the TCEQ continues to promote two voluntary programs in cooperation with the EPA: SmartWay Transport Partnership and Blue Skyways Collaborative.

The SmartWay Transport Partnership is a market

- drive n partnership aimed at helping businesses move goods in the cleanest most efficient way possible. This program is a voluntary EPA program primarily for the freight transport industry that promotes strategies and technologies to help improve fleet efficienc y while also reducing air emissions.

There are over 3,000 SmartWay partners in the U.S., including most of the nation’s largest truck carriers, all the Class 1 rail companies, and many of the top Fortune 500 companies. Since its founding, SmartWay has redu ced oil consumption by 120.7 million barrels and prevented the release of 738,000 tons of NO X and 37,000 tons of PM into the atmosphere 6 . Ports in the U.S. rely on SmartWay’s Port Drayage Truck program to help reduce pollution in and around major national ports. The Port of Houston Authority’s (PHA) partnership with the Environmental Defense Fund and H

- GAC in the Port Drayage Truck Bridge Loan Program received $9 million from the EPA’s Diesel Emission Reduction Act SmartWay Program in 2009. On average, four trucks a month, or about 50 trucks a year, were approved for replacement funding. Several workshops have been sponsored by the PHA for trucking companies and independent owner/operators to learn about funding opportunities.

4 EPA, 2009. Oceangoing Vessels, Emission Control Area Designation, http://www.ep a.gov/otaq/oceanvessels.htm#emissioncontrol, Office of Transportation and Air Quality.

5 EPA, 2009. Regulatory Announcement: Proposal of Emission Control Area Designation for Geographic Control of Emissions from Ships, EPA

- 420

- F

- 09

- 015, Figure 4: Potential Benefits of U.S. ECA Ozone Reductions in 2020, March 2009.

6 EPA, 2014. SmartWay Program Highlights 201 4 , EPA

- 420

- F

- 14

- 003, February 2014.Page 20 Approximately 160 Texas compani es are SmartWay partners. The SmartWay Transport Partnership will continue to benefit the HGB area by reducing emissions as more companies and affiliates join, and additional idle reduction, trailer aerodynamic kits, low rolling resistance tire, and retrof it technologies are incorporated into SmartWay

- verified technologies.

The Blue Skyways Collaborative was created to encourage voluntary air emission reductions by planning or implementing projects that use innovations in diesel engines, alternative fuels, and renewable energy technologies applicable to on

- road and non

- road sources. The Blue Skyways Collaborative partnerships include international, federal, state, and local governments, non

profit organizations, environmental groups, and private industries.

3.3.2 American Waterways Operators Tank Barge Emissions Best Management Practices Using infrared gas imaging technology in field studies conducted in the summer of 2005, the TCEQ detected inadvertent VOC emissions from tank barges operating in the HGB area. The Louisiana Department of Environmental Quality (LDEQ) also detected inadvertent emissions from tank barges in similar field studies conducted in the same time period. In response to these field studies, the American Waterways Operators (AWO) voluntarily dev eloped industry Best Management Practices (BMP) to reduce VOC emissions from tank barges. The BMP includes procedures to reduce VOC emissions from equipment and operations on tank barges. The recommendations are a combination of inspection, corrective acti on, preventative maintenance, and operational, procedural, and training practices.

The BMP was reviewed by the Chemical Transportation Advisory Committee (CTAC), United States Coast Guard (USCG), LDEQ, and TCEQ. The BMP was distributed to AWO members in 20 06 for implementation on a voluntary basis. While the BMP is a voluntary measure and does not impose an enforceable commitment on AWO members, the implementation of the BMP, where applicable, may contribute to reducing inadvertent VOC emissions from barges during dock operations and during transit, which will help improve the air quality in the HGB area. A copy of the 2006 BMP document is provided in Appendix J: Recommendations for Best Management Practices to Control and Reduce Inadvertent Cargo Vapor Emis sions in the Tank Barge Community of the 2010 HGB AD SIP Revision

.

3.3.3 Consent Decrees with Refineries
The EPA's National Petroleum Refinery Initiative 7 has resulted in multi

- issue settlement agreements with the nation's major petroleum refineries. As of March 2014, 109 refineries representing more than 90% of total domestic refining capacity are under settlement, and negotiations are underway with other refiners not currently under settlement. The EPA consent decrees limit emissions from fluidized catalytic cr acking units, sulfur recovery units, heaters and boilers, and flares. The EPA estimates that full implementation of the current settlements will result in more than 93,000 tons per year of NO X emission reductions. The EPA also anticipates VOC emission redu ctions will result from consent decree requirements that reduce hydrocarbon flaring including:

• installing continuous emissions monitoring system s (CEMS) or predictive emissions monitoring systems;

• operating a flare gas recovery system to control continuous or routine flaring;

• limiting flaring to only process upset gases, fuel gas released as a result of relief valve leakage, or gas released due to a malfunction; and

7 http://www2.epa.gov/enforcement/petroleum

- refinery

- national

- case

- resultsPage 21 • eliminating the routes of generated fuel gases and monitoring the flare with CEMS or a flow
meter.

Although some of the estimated NO X and VOC emission reductions may have occurred prior to 2006, full implementation of the settlements is not expected until the end of 2015. Since approximately 14% of the nation’s petrochemical refining capacity is located in the HGB area 8

, the commission expects the HGB area will benefit from the NO X and VOC emission reductions required by these settlements.

3.3.4 Standards of Performance for Stationary Compression Ignition Internal Combustion Engines The TCEQ previously adopted NO X emission standards for stationary diesel reciprocating internal combustion engines in 30 TAC Chapter 117 for the HGB area. The NO X emission standards for stationary diesel engines in §117.310 and §117.2010 are used in conjunction with the MECT program for sources subject to MECT. For sources subject to §117.2010 that are not in MECT, the NO X emission standards apply on a unit

- by

- unit basis. Additionally, the TCEQ adopted requirements in the exemption criteria for stationary diesel reciprocating internal combustion engines in §117.303 and §117.2003 that require engines installed, modified, reconstructed, or relocated on or after October 1, 2001 to meet the corresponding emission standards for non

- road engines in 40 Code of Federal Regulations (CFR ) Part 89, §89.112(a), Table 1 to be in effect at the time of the installation, modification, reconstruction, or relocation of the engine. The combination of the emission standards, the MECT program, and the provisions to meet EPA’s Tier standards (Tiers 1 , 2, and 3) in 40 CFR Part 89 to qualify for exemption makes the Chapter 117 requirements for stationary diesel reciprocating internal combustion engines equivalent to , or more stringent than , most of the requirements in EPA’s New Source Performance Standa rds in 40 CFR Part 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. However, the NO X emission standards in 40 CFR §60.4204(c)(3) for large

- cylinder non

- emergency stationary compression ignition int ernal combustion engines (i.e., diesel

- fired engines) installed on or after January 1, 2016 are more stringent than the lowest NO X emission standards for stationary diesel reciprocating internal combustion engines in §117.310 and §117.2010 and 40 CFR Part §89.112(a), Table 1. The exact amount of NO X reductions resulting from 40 CFR §60.4204(c)(3) will be dependent on the turnover of existing engines and new installations after 2015 and cannot be estimated at this time. However, the requirements for new non

- emergency stationary diesel

- fired engines in the large

- cylinder category starting in 2016 should ultimately result in additional NO X reductions beyond that already relied upon in the 2010 HGB AD SIP Revision.

3.3.5 Energy Efficiency and Renewable En ergy Measures Energy efficiency (EE) measures are typically programs that reduce the amount of electricity and natural gas consumed by residential, commercial, industrial, and municipal energy consumers. Examples of energy efficiency measures include increasing insulat ion in homes, installing compact fluorescent light bulbs, and replacing motors and pumps with high efficiency units. Renewable energy (RE) measures include programs that generate energy from resources that are replenished or are otherwise not consumed as w ith traditional fuel

- based energy production. Examples of renewable energy include wind energy and solar energy projects.

8 U.S. Energy Information Administration. Refinery Capacity Report . June 21, 2013. http://www.eia.gov/petroleum/refinerycapacity/Page 22 Emission reductions resulting from these programs were not explicitly included in the photochemical modeling for the 2010 HGB AD SIP R evision because local efficiency efforts may not result in local emissions reductions or may be offset by increased demand in electricity. The complex nature of the electrical grid makes accurately quantifying emission reductions from EE/RE measures diffic ult. At any given time, it is impossible to determine exactly where a specific user’s electricity was produced. The electricity for a user in the HGB area could be generated by a power plant in W est Texas, in a nearby attainment county, or within the
nonat tainment area. If electrical demand is reduced in the HGB area due to these local efficiency measures, then emission reductions from power generation facilities may occur in any number of locations around the state.

The Texas Legislature has enacted a numb er of EE/RE measures and programs. The following is a summary of Texas EE/RE legislation since 1999.

• 76th Texas Legislature, 1999

• SB 7

• House Bill (HB) 2492

• HB 2960

• 77th Texas Legislature, 2001

• SB 5

• HB 2277

• HB 2278

• HB 2845

• 78th Texas Legislature, 200 3

• HB1365 (Regular Session)

• 79th Texas Legislature, 2005

• SB 20 (First Called Session)

• HB 2129 (Regular Session)

• HB 2481 (Regular Session)

• 80th Texas Legislature, 2007

• HB 66

• HB 3070

• HB 3693

• SB 12

• 82nd Texas Legislature, 2011

• SB 898 (Regular Session)

• SB 924 (Regular Session)

• SB 981 ( Regular Session )

• SB 1125 (Regular Session)

• SB 1150 (Regular Session)

• HB 51 ( Regular Session )

3.3.5.1 Renewable Energy SB 5, 77th Texas Legislature, 2001, set goals for political subdivisions in affected counties to implement measures to reduce energy consumption from existing facilities by 5 % each year for five years from January 1, 2002 through January 1, 2006. In 2007, the 80th Texas Legislature passed SB 12, which extended the timeline set in SB 5 through 2007 and made the annual 5 % reduction a goal instead of a requirement. The State Energy Conservation Office (SECO) is charged with tracking the implementation of SB 5 and SB 12. Also during the 77th TexasPage 23 Legislature, the Energy Systems Laboratory (ESL), part of the Texas Engineerin g Experiment Station, Texas A&M University System, was mandated to provide an annual report on EE/RE efforts in the state as part of TERP under Texas Health and Safety Code ( THSC ), §388.003(e).

The 79th Texas Legislature, 2005, Regular and First Called Ses sions, amended SB 5 through SB 20, HB 2129, and HB 2481 to add, among other initiatives, renewable energy initiatives that require: 5,880 megawatts of generating capacity from renewable energy by 2015; the TCEQ to develop a methodology for calculating emis sion reductions from renewable energy initiatives and associated credits; the ESL to assist the TCEQ in quantifying emissions reductions from EE/RE programs; and the Public Utility Commission of Texas (PUCT) to establish a target of 10,000 megawatts of installed renewable technologies by 2025.

HB 2129, 79th Texas Legislature, 2005, Regular Session, directed the ESL to collaborate with the TCEQ to develop a methodology for computing emission reductions attributable to use of renewable energy and for the ESL to annually quantify such emission reductions. HB 2129 directed the Texas Environmental Research Consortium to use the Texas Engineering Experiment Station to develop this methodology. With the TCEQ’s guidance, the ESL produces an annual report, Statewide Air Emissions Calculations from Energy Efficiency, Wind and Renewables

, detailing these efforts.

In addition to the programs discussed and analyzed in the ESL report, local governments may have enacte d measures beyond what has been reported to SECO and the PUCT. The TCEQ encourages local political subdivisions to promote EE/RE measures in their respective communities and to ensure these measures are fully reported to SECO and the PUCT.

SB 981, 82nd Tex as Legislature, 2011, Regular Session, allows a retail electric customer to contract with a third party to finance, install, or maintain a distributed renewable generation system on the customer's side of the electric meter, regardless of whether the custo mer owns the installed system . SB 981 also prohibits the PUCT from requiring registration of the system as an electric utility if the system is not projected to send power to the grid.

3.3.5.2 Residential and Commercial Building Codes and Programs THSC, Chapter 38 8, Texas Building Energy Performance Standards, as adopted in SB 5 of the 77th Texas Legislature, 2001, states in §388.003(a) that single

- family residential construction must meet the energy efficiency performance standards established in the energy effici ency chapter of the International Residential Code. The Furnace Pilot Light Program includes energy savings accomplished by retrofitting existing furnaces. Also included is a January 2006 federal mandate raising the minimum Seasonal Energy Efficiency Ratio (SEER) for air conditioners in single

- family and multi

- family buildings from 10 to 13.

THSC, Chapter 388, as adopted in SB 5 of the 77th Texas Legislature, 2001, states in §388.003(b) that non

- single

- family residential, commercial, and industrial construc tion must meet the energy efficiency performance standards established in the energy efficiency chapter of the International Energy Conservation Code.

3.3.5.3 Federal Facilit y Energy Efficiency and Renewable Energy Projects Federal facilities are required to reduc e energy use by Presidential Executive Order 13123 and the Energy Policy Act of 2005 (Public Law 109

- 58 EPACT 20065). The ESL compiled energy reductions data for the federal EE/RE projects in Texas.Page 24 3.3.5.4 Political Subdivisions Projects SECO funds loans for energ y efficiency projects for state agencies, institutions of higher education, school districts, county hospitals, and local governments. Political subdivisions in nonattainment and affected counties are required by SB 5, 77th Texas Legislature, 2001, to
repo rt EE/RE projects to SECO. These projects are typically building systems retrofits, non

building lighting projects, and other mechanical and electrical systems retrofits such as municipal water and waste water treatment systems.

3.3.5.5 Electric Utility Sponsored Programs Utilities are required by SB 7, 76th Texas Legislature, 1999, and SB 5, 77th Texas Legislature, 2001, to report demand

- reducing energy efficiency projects to the PUCT (see THSC, §386.205 and Texas Utilities Code (TUC), §39.905). These projects are typically air conditioner replacements, ventilation duct tightening, and commercial and industrial equipment replacement.

SB 1125, 82nd Texas Legislature, 2011, Regular Session, amended the TUC, §39.905 to require energy efficiency goals to be at least 30 % of annual growth beginning in 2013. The metric for the energy efficiency goal remains at 0.4% of peak summer demand when a utility program accrues that amount of energy efficiency. SB 1150, 82nd Texas Legislature, 2011, Regular Session, extended the ener gy efficiency goal requirements to utilities outside the Electric Reliability Council of Texas area.

3.3.5.6 Energy Efficiency Programs HB 3693, 80th Texas Legislature, 2007, amended the Texas Education Code, Texas Government Code, THSC, and TUC. The bill:

• requires state agencies, universities

, and local governments to adopt energy efficiency programs;

• provides additional incentives for electric utilities to expand energy conservation and efficiency programs;

• includes municipal

- owned utilities and cooperativ es in efficiency programs;

• increases incentives and provides consumer education to improve efficiency programs; and

• supports other programs such as revision of building codes and research into alternative technology and renewable energy.

HB 51, 82nd Texas Legislature, 2011, Regular Session, require s new state buildings and major renovations to be constructed to achieve certification under an approved high

- performance design evaluation system.

HB 51 also requires, if practical, that certain new and renovate d state

- funded university buildings comply with approved high

- performance building standards.

SB 898, 82nd Texas Legislature, 2011, Regular Session, extended the existing requirement for state agencies, state

- funded universities, local governments, and sch ool districts to adopt energy efficiency programs with a goal of reducing energy consumption by at least 5% per state fiscal year (FY) for 10 state FYs from September 1, 2011 through August 31, 2021.

SB 924, 82nd Texas Legislature, 2011, Regular Session, r equires all municipally

- owned utilities and electric cooperative s that had retail sales of more than 500,000 megawatt hours in 2005 to report each year to SECO information regarding the combined effects of the energy efficiencyPage 25 activities of the utility fr om the previous calendar year, including the utility's annual goals, programs enacted to achieve those goals, and any achieved energy demand or savings goals.

3.3.6 Clean Air Interstate Rule and Cross

- State Air Pollution Rule In March 2005, the EPA issued the Cl ean Air Interstate Rule (CAIR) to address electric generating utility ( EGU ) emissions that transport from one state to another. The rule incorporates the use of three cap and trade programs to reduce sulfur dioxide (SO 2 ) and NO X : the ozone

- season NO X tradi ng program, the annual NO X trading program, and the annual SO 2 trading program.

Texas was not included in the ozone season NO X program but was included for the annual NO X and SO 2 programs. As such, Texas must make necessary reductions in annual SO 2 and NO X emissions from new and existing EGUs to demonstrate that emissions from Texas do not contribute to nonattainment or interfere with maintenance of the 1997 particulate matter with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM 2 .5

) NAAQS in another state. CAIR consists of two phases for implementing necessary NO X and SO 2 reductions. Phase I addresses required reductions from 2009 through 2014. Phase II addresses reductions in 2015 and thereafter.

In July 2006, the commission adop ted a SIP revision to address how the state would meet emissions allowance allocation budgets for NO X and SO 2 established by the EPA to meet the federal obligations under CAIR. The commission adopted a second CAIR

- related SIP revision in February 2010. This revision incorporated various federal rule revisions that the EPA had promulgated since the TCEQ’s initial submittal. It also incorporated revisions to 30 TAC Chapter 101 resulting from legislation during the 80th Texas Legislature, 2007.

A December 2008 court decision found flaws in CAIR but kept CAIR requirements in place temporarily while directing the EPA t o issue a replacement rule. In July 2011, the EPA finalized the Cross

- State Air Pollution Rule (CSAPR) to meet FCAA requirements and respond to the court’s order to issue a replacement program. Texas was included in CSAPR for ozone season NO X , annual NO X , and annual SO 2 due to the EPA’s determination that Texas significantly contributes to nonattainment or interferes with maintenance of the 1997 eight

- hour ozone NAAQS and the 1997 and 2006 PM 2.5 NAAQS in other states. As a result of numerous EGU emission re duction strategies already in place in Texas, the annual and ozone season NO X reduction requirements from CSAPR were relatively small but still significant. The CSAPR required an approximate 7% reduction in annual NO X emissions and less than 5% reduction i n ozone season NO X emissions.

On August 21, 2012, the U.S. Court of Appeals for the District of Columbia (D.C.) Circuit vacated the CSAPR. Under the D.C. Circuit Court’s ruling, CAIR will remain in place until the EPA develops a valid replacement. On Octob er 5, 2012, the EPA filed a petition seeking an en banc rehearing of the U.S. Court of Appeals’ decision regarding CSAPR, but the appeal was denied.

The EPA and various environmental groups petitioned the Supreme Court of the United States to review the D .C. Circuit Court's decision on CSAPR. On June 24, 2013, the Supreme Court granted the petitions and heard oral arguments in the case on December 10, 2013. On April 29, 2014, a decision by t he Supreme Court reversed the D.C. Circuit and remanded the case. The case is currently back before the D.C. Circuit, which has not yet issued instructions for actions. At this time , CAIR remains in place. In the meantime, the EPA is seeking input from states on the next steps to address interstate transport for current and future NAAQS.Page 26 3.3.7 Clean School Bus Program HB 3469, 79th Texas Legislature, 2005, established the Clean School Bus Program , which provide s monetary incentives for school districts in the state for reducing emissions of di esel exhaust from school buses

. As of July 2014, the TCEQ Clean School Bus Program has reimbursed approximately $25

. 9 million in grants for over 7

, 1 00 school buses across the state, with $ 5

. 2 million being used for 2,4 68 school buses in the HGB area

.

3.3.8 Texas Emission Reduction Plan The TERP was created in 2001 by the 77th Texas Legislature to provide grants to offset the incremental costs associated with reducing NO X emissions from high

- emitting heavy

- duty internal combustion engines on heavy

- duty vehicles, non

- road equipment, marine vessels, locomotives, and some stationary equipment.

The majority of emissions reduction incentives have been awarded under the Diesel Emissions Reduction Incentive Program (DERI). The DERI incentives are awarded to projects to replace, repower, or retrof it eligible vehicles and equipment to achieve NO X emission reductions in Texas ozone nonattainment areas and other counties identified as affected counties under the TERP where ground

- level ozone is a concern. The last DERI grants were awarded through Augu st 31, 2013, with the next grant rounds anticipated after September 1, 2014. From 2001 through August 2013, $943 million in DERI grants were awarded for projects estimated to help reduce 176,364 tons of NO X . Over $405 million in DERI grants were awarded to projects in the HGB area, with a projected 80,765 tons of NO X reduced. These projects are estimated to reduce up to 27.7 tpd of NO X in the HGB areas during 2014. Of the $405 million, $11 million were awarded to H

- GAC through third

- party grants to administ er subgrants in the HGB area. H

- GAC has used this funding to target the replacement of drayage trucks operating in and from the Port of Houston with newer models with lower emission ratings

. Three other incentive programs under the TERP will result in the reduction in NO X emissions in the HGB area. The Texas Clean Fleet Program (TCFP) was established in 2009 to provide grants for the replacement of light

- duty and heavy

- duty diesel vehicles with vehicles powered by alternative fuels, including: natural gas, liquefied petroleum gas, hydrogen, methanol (85% or

more by volume), or electricity. This program is for larger fleets, with a requirement that an applicant apply for replacement of at least 20 vehicles at a time. The last TCFP grants were awarded by Augus t 31, 2013, with the next grant round anticipated in May 2014. From 2009 through August 2013, over $23.6 million in TCFP grants were awarded for projects to reduce an estimated 314.5 tons of NO X . Almost $6.8 million in TCFP grants were awarded to projects in the HGB area, with a projected 61.9 tons of NO X reduced. These projects are estimated to reduce up to 0.05 tpd of NO X in the HGB area during 2014

. The Texas Natural Gas Vehicle Grant Program (TNGVGP) was established in 2011 to provide grants for the rep lacement of medium

- duty and heavy

- duty diesel vehicles with vehicles powered by natural gas. This program may include grants for individual vehicles or multiple vehicles. The majority of the vehicle operation must occur in the Texas nonattainment areas,
ot

her counties designated as affected counties under the TERP, and the counties in and between the triangular area between Houston, San Antonio, Dallas, and Fort Worth. The last TNGVGP grants were awarded by August 31, 2013, with a new grant round currently open and contracts pending. From 2011 through August 2013, almost $26 million in TNGVGP grants were awarded for projects to help reduce a projected 816 tons of NO X . Over $9.5 million in TNGVGP grants were awarded to projects where the applicant indicated t he primary operation of the vehicle would occur in and around the HGB area, with a projected 266 tons of NO X reduced. These projects are expected to begin reducing 0.29 tpd of NO X in the HGB area starting in 2015.Page 27 A new Drayage Truck Incentive Program (DTI P) was established in 2013 to provide grants for the replacement of drayage trucks operating in and from seaports and rail yards located in nonattainment areas. The first grant application period for this program is anticipated to open after September 1, 2 014.

The TERP is currently authorized through 2019

, which will result in continued reductions in the significant emissions source categories of heavy

- duty on

- road and non

- road engines. TERP projects require reporting and documentation of emissions reductions over a five

- to seven

- year activity life or, in some cases, an even longer period. Projects funded in a particular year will continue to report emissions reductions achieved over th e activity

- life commitment period for each project.

3.3.9 83 rd Texas Legislature Summaries of the bills passed during the 83rd Texas Legislature, 2013, Regular Session, that have the potential to impact the HGB area are discussed in this section. For legislative updates regarding EE/RE measures and programs, see Sect ion 3.3. 9 : Energy Efficiency and Renewable Energy Measures

.

Senate Bill 1727 SB 1727 revised some of the criteria for the existing TERP incentive programs and established several new programs. The bill also revised the funding allocation formula for the various TERP programs.

The existing TERP programs that were revised include: the DERI, the TCFP, and the TNGVGP. A new program , the DTIP, was also established.

SB 1727 removed the maximum limits on t he cost

- effectiveness of a project funded under the DERI and authorized the TCEQ to fund projects to convert on

- road and non

- road diesel engines to a dual

- fuel configuration using diesel and natural gas. Changes were also made to the TCFP to simplify the r equirements on the percentage of costs that may be covered by a grant, and to authorize the TCEQ to allow trucks used to transport raw agricultural products that are replaced under this program to operate a lesser percentage of annual mileage in designated counties than is required for other TCFP projects.

The TNGVGP was affected by changes to the Clean Transportation Triangle (CTT) program, which provides grants for infrastructure to provide natural gas fueling in designated areas. SB 1727 expanded the eli gible areas under the CTT. The original areas included nonattainment areas and counties along the interstate highways connecting the cities of Houston, Dallas, Fort Worth, and San Antonio. The expanded areas include other counties designated as affected

co unties under the TERP and the counties located within the triangle formed by the previously designated interstate highways. The TNGVGP provides grants for replacement of heavy

- duty and medium

- duty vehicles that travel 75% of the annual mileage in the CTT d esignated areas. Thus, the expansion of the CTT areas also expands the eligible areas of travel under the TNGVGP. The bill also authorized the TCEQ to allow trucks used to transport raw agricultural products that are replaced under this program to operate a lesser percentage of annual mileage in designated counties than is required for other TNGVGP projects.

SB 1727 also established the new DTIP to provide grants for replacement of drayage trucks operating at seaports and rail yards located in a nonattainme nt area. The replacement trucks must continue to operate at designated seaports and rail yards and must also operate at leastPage 28 50% of annual mileage within a maximum distance from the seaports and rail yards as defined by the TCEQ.

Other TERP programs not s pecifically included as weight of evidence strategies, but which are expected to have beneficial impacts on reducing emissions in nonattainment areas and other areas, were also revised. The maximum grant amounts for the CTT program and the Alternative Fuel ing Facilities Program (AFFP), which provides grants for infrastructure to provide fueling for a range of alternative fuels, were increased to a maximum of $600,000. The TERP Light

Duty Purchase or Lease Incentive (LDPLI) program, which was established und er the original TERP legislation in 2001 but never implemented, was also revised and restarted. Under the new program criteria, the TCEQ will provide grants of up to $2,500 for the purchase or lease of vehicles under 10,000 pounds gross vehicle weight rati ng that are powered by natural gas, liquefied petroleum gas, or electricity (including plug

- in hybrid vehicles). The LDPLI program will be available statewide.

To implement SB 1727, the commission adopted revisions to 30 TAC §§114.622, 114.629, 114

. 650, 11 4.653, and 114.656 and new 30 TAC §§114.680

- 114.682 on April 9, 2014. T he commission adopted revisions to 30 TAC §§114.610

- 114.612 and 114.616 and the repeal of 30 TAC §114.619 on April 30, 2014

.

House Bill 2859 HB 2859 increased the funding allocated to the TCEQ’s Local Initiatives Projects ( LIP ) Program, which is available to counties that participate in the Low

- Income Vehicle Repair Assistance, Retrofit, and Accelerated Vehicle Retirement Program ( LIRAP ), from $5 million to $7 million per year. The f unding for LIRAP is from fees collected by the state’s I/M p rogram. In addition, the bill limits $2 million of the funding to projects for coordinating with local law enforcement officials to reduce the use of counterfeit state inspection stickers. This bi ll became effective September 1, 2013.

3.3.10 Local Initiative Projects Funds are provided to counties participating in LIRAP for implementation of air quality improvement strategies through local projects and initiatives. In the HGB area, LIP funding is availabl e to the five counties participating in LIRAP: Brazoria; Fort Bend; Galveston; Harris; and Montgomery.

Brazoria, Fort Bend, and Galveston Counties used LIP funds to purchase buses and initiate a new park

- and

- ride transit service in 2010. LIP continues to m aintain the park

- and

- ride funding as of 2013. The transit service links county residents with the Texas Medical Center area and creates immediate and long

- term benefits for reducing emissions and congestion by decreasing single occupancy vehicle trips from U.S. Route 59.

Harris County used LIP funds in 2010 to establish the Harris County Clean Air Emissions Task Force and initiate an emissions enforcement program. The enforcement program targets high

emitting vehicles, smoking vehicles, and suspicious vehic les to verify that the state safety and emissions inspection windshield certificates on these vehicles are legitimate and in compliance with air quality standards. The task force’s objective is to reduce the number of fraudulent, fictitious, or improperly issued safety and emissions inspection windshield certificates. The task force partners with local and state agencies to enforce state laws, codes, rules, and regulations regarding air quality and mobile emissions in Harris County. The citizens of Harris C ounty and the entire southeast Texas region stand to benefit from this program as a result of the reduction in NO X emissions from each vehicle brought into emissions compliance.Page 29 Montgomery County used LIP funds for signal light synchronization projects in FY 2010 and 2012. Synchronizing traffic signalization reduces idling by decreasing the number of times a vehicle must stop at a traffic light. The “Exhaust Phase” of an engine emits the most emissions during starting, idling, and breaking stationary inerti a. Synchronizing traffic signalization reduces both idling and the number of times a vehicle must resume travel

, i.e., break stationary inertia. The project increases the emissions reduction benefits by synchronizing the traffic signalization upon real

- time traffic flow instead of a stagnate model to better manage peak

- hour congestion, while minimizing cross

- traffic congestion, and reducing emissions.

3.3.11 Other Local Programs In the 2010 HGB AD SIP Revision, H

- GAC submitted the following programs that w ere not committed to as either transportation control measures or Voluntary Mobile Emission Reduction Program measures but may be implemented locally in the HGB area. Updates to these programs were included in the Houston

- Galveston

- Brazoria 1997 Eight

- Hour Ozone Standard Nonattainment Area Motor Vehicle Emissions Budgets Update State Implementation Plan Revision adopted in April 2013 (2013 MVEB SIP Revision). For a detailed analysis of these programs, see Appendix F of the 2010 HGB AD SIP Revision, and Sect ion 5.4.3.13: Other Local Programs and Section 5.4.3.14: Additional Strategies Not Included in the 2010 HGB AD SIP Revision of the 2013 MVEB SIP Revision.

• Scrappage and Buy

- Back Plan

• Limitations on Heavy

- Duty Vehicles Idling; Creation of Regional Governmen t Idling Restrictions

• Encourage/Mandate Livable Centers

• Enhanced Enforcement of Smoking Vehicles

• Limitation on Idling of Heavy

- Duty Construction Equipment

• Airport Emission Reduction Strategy

• Congestion Pricing/High Occupancy Vehicle (HOV) Lanes and High Oc cupancy Toll ( HOT) Lane Conversion

• Flextime

• Parking Pricing

• PHA Automated Gate Systems

• Third

- Party TERP Grants

3.4 Control Strategies Summary The permanent and enforceable VOC and NO X control measures contained in Section 3 .2: List of Existing Control Measur es of this report have resulted in air quality improvement in the HGB area. These enforceable measures will remain in place to ensure continued maintenance of the

one

- hour ozone NAAQS in t he HGB area. In addition, Section 3 .3

: Additional Measures lists control measures that may not meet all of the EPA’s standard tests of creditability (permanent, enforceable, surplus, and quantifiable) but are crucial to the success of the air quality plan in the HGB area. I mplementation of these control measures will contribute to the continued maintenance of the one

- hour ozone NAAQS and attainment of the 1997 and 2008 ozone N AAQS. The TCEQ continues to seek innovative air quality improvement measures and technologies to implement in the HGB area

.Page 30 SECTION 4: MAINTENANCE DEM ONSTRATION
4.1 General The redesignation substitute (RS) report is intended to demonstrate that the Houston

Galveston

- Brazoria (HGB) area will remain in attainment of the one

- hour ozone National Ambient Air Quality Standard (NAAQS) for the 10

- year period follo wing the date that anti

backsliding obligations under the revoked standard would be lifted. Since removing anti

backsliding obligations is contingent upon the United States Environmental Protection Agency’s (EPA) approval, the Texas Commission on Environme ntal Quality (TCEQ) has set a horizon year of 2026. Setting the horizon date at 12 years from the date this report was developed allows more than adequate time for review and approval before the 10

- year period begins . This ten

year period also aligns with the EPA’s requirement of maintenance plans to demonstrate attainment for a ten

- year period following the date of redesignation.

The most current emissions inventory (EI) data were analyzed as part of this maintenance demonstration. The 2011 periodic invent ory was chosen as the starting point for the analyses presented in this section since it was the most recent periodic inventory year. Specifically, the ten years prior to monitoring attainment of the one

- hour ozone NAAQS (2002 through 2011) were analyzed t o develop trend data. During this time, the HGB area EI showed a significant decrease in ozone precursor emissions from all source categories

, which contributed to the attainment of the one

- hour ozone NAAQS. These reductions were accomplished through a

var iety of federal, state, and local regulations and programs as detailed below.

4.2 Emissions Inventory Trends From 2002 to 2011, overall anthropogenic ozone precursor emissions in the HGB nonattainment area declined substantially as a result of regulations impl emented at the federal, state, and local levels and innovative programs implemented by the TCEQ. As demonstrated in Figure 4

- 1: HGB Eight

- County Nonattainment Area Historical NO X Emissions Trends and Figure 4

- 2: HGB Eight

- County Nonattainment Area Historical VOC Emissions Trends

, anthropogenic volatile organic compounds (VOC) emissions have decreased 30%, and anthropogenic nitrogen oxides (NO X

) emissions have decreased 46%. Both 30 Texas Administrative Code (TAC) Chapter 115: Control of Air Pollutio n from Volatile Organic Compounds and 30 TAC Chapter 117: Control of Air Pollution from Nitrogen Compounds regulations implemented from 1999 through 2006 along with implementation of the Mass Emissions Cap and Trade (MECT) program have significantly reduce d overall ozone precursor emissions at both major and minor (point and area) industrial, commercial, and institutional sources in the HGB ozone nonattainment area. Innovative emissions reduction programs such as the Texas Emissions Reduction Plan and the A irCheckTexas Drive a Clean Machine program in 30 TAC Chapter 114: Control of Air Pollution from Motor Vehicles have also reduced mobile source emissions, the primary source of NO X emissions in the HGB area.Page 31 Note: The 2002, 2005, and 2008 on

- road mobile values were generated using the MOBILE6 model while the 2011 value was generated using the MOVES2010b model. The upward trend from 2008 to 2011 for on

- road mobile is
due to the different NO X calculation methodologies between MOBILE6 and MOVES. If MOVES

- bas ed trends were available for 2002 through 2011, a downward trend would be seen throughout.

Figure 4

- 1 : HGB Eight

- County Nonattainment Area Historical NO X Emissions Trends 27.79 16.04 25.41

21.15 322.67

260.98

190.58 213.57

145.25 156.04 149.24
121.11 339.49

194.52

111.38 108.48

0.00 50.00 100.00 150.00 200.00 250.00 300.00 350.00 400.00

2002 2005 2008 2011Emissions in Tons Per Day

Area

On-Road

Non-Road

PointPage 32 Note: The 2002, 2005, and 2008 on

- road mobile values were generated using the MOBILE6 model while the 2011 value was generated using the MOVES2010b model.

Figure 4

- 2 : HGB Eight

- County Nonattainment Area Historical VOC Emissions Trends

4.3 201 1 Attainment Inventory The 1990 Federal Clean Air Act (FCAA) Amendments require that EIs be prepared for ozone nonattainment areas. Because ozone is photochemically produced in the atmosphere when VOC mixes with NO X in the presence of sunlight, the TCEQ must compile information on the sources of these precursor pollutants. The EI must identify the source types present in an area, the amount of each pollutant emitted, and the types of processes and control devices employed at stationary sources or other sour ce categories. The EI provide s data for a variety of air quality planning tasks, including establishing baseline emission levels, calculating reduction targets, control strategy development for achieving the required emission reductions, emission inputs in

to air quality simulation models, and tracking actual emission reductions against the established emissions growth and control budgets.

The attainment inventory for the HGB area is based on the VOC and NO X emissions that occur

on an actual typical summer w eek day. Consistent with a September 4, 1992 EPA memorandum entitled Procedures for Processing Requests to Redesignate Areas to Attainment

, the attainment EI base year may be any one of the three years used to determine the design value for the attainment y ear. For this RS report, t he attainment EI base year is 2011 because it is the year of the most recent periodic emissions inventory (PEI) and one of the three years used to determine the design value for the 2013 attainment year . The total VOC and NO X EI f or the area 115.34

106.58

96.37

85.05 82.79

72.28

62.65

49.92 149.37

140.08

108.10

96.11 422.14

425.83 446.60

308.74

0.00 50.00 100.00 150.00 200.00 250.00 300.00 350.00 400.00 450.00 500.00

0.00 20.00 40.00 60.00 80.00 100.00 120.00 140.00

2002 2005 2008 2011Emissions in Tons Per Day

On-Road

Non-Road

Point

AreaPage 33 is summarized from the estimates developed for four general categories of anthropogenic emissions sources, which are each explained in Section 4.3.1: Area Sources , Section 4.3.2: On

Road Mobile Sources , Section 4.3.3: Non

- Road Mobile Sources , a nd Section 3.4.4: Stationary Point Sources . Summaries of the 2011 VOC and NO X emissions by source type are provided in Section 4.4: Emissions Summary

.

4.4 Future Emissions and Verification of Continued Attainment To track progress of the HGB area toward continued attainment of the one

- hour ozone NAAQS, the TCEQ will develop and submit periodic EIs to the EPA every three years as required by the federal Air Emissions Reporting Requirements (AERR) rule. The 2011 inventory was the first PEI submitted under t he AERR. Per the AERR, the 2011 PEI was reported to the EPA’s National Emissions Inventory (NEI) as a comprehensive and detailed estimate of air emissions, including ozone precursors (NO X and VOC). As directed by the AERR, the 2011 Texas PEI includes annua l emissions for the entire state and summer week day emissions for the 2008 eight

- hour ozone nonattainment areas in Texas, including the HGB area. States can rely on periodic AERR EI submittals to satisfy ongoing state implementation plan ( SIP ) EI submission requirements every three years. The periodic EI SIP revision submission requirements would occur in the same years as the AERR submittals.

Because the EPA has not made guidance available for how to demonstrate verification of continued attai nment in a n RS , the TCEQ is using the method outlined in the EPA’s redesignation guidance 9

. Future emissions for the HGB area were projected from the base year inventory (2011) to a future year (horizon year) of 2026, 12 years from the time this RS will be submitted to the EPA. Projecting emissions to 2026 aligns with the EPA’s requirement of maintenance plans to demonstrate attainment for a 10

- year period following the date of redesignation. The requirement for verification of continued attainment is satis fied when the state demonstrates that future VOC and NO X emissions levels are not expected to result in exceedances of the one

- hour ozone NAAQS.

Future emissions were projected to the horizon year 2026 using three

- year intervals. A summary of the base year inventory and the future year inventories for ozone precursor emissions is presented in Section 4.4

.

4.4.1 Area Sources Stationary source emissions data from sites and processes that do not meet the reporting requirements for point sources are classified as are a sources. Area sources are small

- scale industrial, commercial, and residential sources that generate emissions

. Emissions are calculated and recorded on the county level. Examples of area sources include: printing operations ; industrial coatings ; degreasi ng solvents ; house paints ; gasoline service station underground tank filling ; vehicle refueling operations ; stationary source fossil fuel combustion ; outdoor refuse burning ; and structural fires. With some exceptions, area source emissions are calculated b y multiplying an established emissions factor (emissions per unit of activity) by the appropriate activity or activity surrogate responsible for generating emissions. Population is one of the more commonly used activity surrogates for area sources. Other a ctivity data include the amount of gasoline sold in an area, employment by industry type, and crude oil and natural gas production.

9 Memorandum from John Calcagni, Director of Air Quality Management Division, September 4, 1992, Procedu res for Processing Requests to Redesignate Areas to Attainment

. EPA Office of Air Quality Planning and Standards

.Page 34 4.4.1.1 Updated 2011 Base Year Inventories
The 20 11 area source inventory was developed per the AERR reporting requirements. The 20 11 inventory was creat ed using a combination of methodologies and data: EPA

- generated EIs; TCEQ

- contract ed projects ; TCEQ staff projects ; and categories grown from the 200 8 EI using factors derived from study data compiled by Eastern Research Group (ERG), the Economic and Consumer Credit Analytics website ( http://www.economy.com/default.asp ), and the United States Energy Information Administration’s (EIA) a nnual e nergy o utlook publication. The documentation for the development of the ERG study factors can be found in Attachment A: Projection Factors for Point and Area Sources

. The EPA developed EIs for states to use for many source categories as part of the NEI. The states access these individual inventories through the EPA’s NEI website ( ftp://ftp.epa.gov/EmisInventory/2011nei/doc/ ). These source categories include but are not limited to: industrial coatings; degreasing; residential, commercial/institutional, and industrial fuel use; commercial cooking; aviation fuel use; and consumer products . For some source categories, the TCEQ developed state

- specific emissions estimates by acquiring current state

specific activity data and applyin g appropriate emissions factors. These source categories include but are not limited to : storage tanks ; structural fires ; dry cleaners ; and automobile fires

. In particular, significant resources were expended to improve the oil and gas area source inventor y production categories for the 2011 inventory. The improvements included the development and refinement of a state

- specific oil and gas area source emissions calculator. This oil and gas area source emissions calculator uses county

- level production and lo cal equipment activity data with local emissions requirements to estimate emissions from individual production categories including compressors engines, condensate and oil storage tanks, loading operations, heaters, and dehydrators. The documentation for t he development of the oil and gas emissions calculator can be found in Attachment B : Characterization of Oil and Gas Production Equipment and Develop a Methodology to Estimate Statewide Emissions . A significant improvement made to the oil and gas calculato r for the 2011 inventory was the development of refined emission factors for VOC emissions from condensate storage tanks. The documentation for the refined emission factors can be found in Attachment C : Condensate Tank Oil and Gas Activities

.

For those are a source categories affected by TCEQ rules, rule effectiveness factors are applied to the baseline or uncontrolled emissions to estimate controlled emissions . These factors address the efficiency of the controls and the percentage of the category’s populat ion affected by the rule. Quality assurance of area source emissions involves ensuring that the activity data used for each separate category is current and valid. Data such as current population figures, fuel usage, and material usage were updated and the EPA guidance on emission factors was used. Other routine efforts such as checking calculations for errors and conducting reasonableness and completeness checks were implemented.

4.4.1.2 Updated Milestone Years Inventories The updated milestone year inventories for the area source categories were developed using factors derived from Attachment A, the Economic and Consumer Credit Analytics website ( http://www.economy.com/default.asp ), and the EIA’s annual energy outlook publication . The ERG

- derived factors contain individual growth factors for each category and for each forecasting year. This projection method is the EPA standard

, accepted method for developing future year EIs.Page 35 4.4.1.3 Area Source Emissions Inventories
The 2011 area source NO X and VOC emissions totals for the eight

- county HGB 2008 eight

- hour ozone nonattainment area are presented in Table 4

- 1 : HGB 2011 Area Source NO X and VOC Emissions (tons per day)

.

Table 4

- 1 : HGB 2011 Area Source NO X and VOC Emissions (tons per day)

Pollutant 2011 2014 2017 2020 2023 2026

NO X 21.15 22.19 22.90 23.28 23.17 23.23

VOC 308.74 321.92 332.43 339.67 342.58 346.13

4.4.2 On

- Road Mobile Sources
On

- road mobile emission sources consist of automobiles, trucks, motorcycles, and other motor vehicles traveling on public roadways. On

- road mobile source emissions are usually categorized as either combustion

- related emissions or evaporative hydrocarbon emissions. Combustion

related emissions are e stimated for vehicle engine exhaust. Evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative

- leak sources on the vehicle. To calculate emissions, both the rate of emissions per unit of activity (emissions factors) and the nu mber of units of activity must be determined. The emissions factors for on

- road mobile sources are determined using models developed and approved by the EPA. The models allow for input of local conditions and vehicle characteristics. The activity informati on corresponding to the emissions factors is obtained using local travel demand models (TDMs) , the output from the highway performance monitoring system, and speed models.

In March 2010, the EPA released the Motor Vehicle Emissions Simulator (MOVES) as the official emissions factor model for developing on

- road mobile source category EIs . Although MOVES represented a new approach to assessing on

- road emissions, the sources are the same, and the opportunity to use local inputs for meteorological conditions, c ontrol programs, and fleet characteristics remains. When using MOVES in emission

- rates mode, emission rates are produced for subsets of the on

- road fleet, and the emission rates are multiplied by the activity level of each vehicle type or source

- use type t o calculate emissions. The EPA prefers that states use the latest version of MOVES that is available. The EPA released MOVES2010b in April 2012 and an updated MOVES2010b database in October 2012. MOVES2010b with the October 2012 database updates was used i n the inventory development for all on

- road HGB EIs.

In accordance with EPA guidance, if states have completed significant work on an inventory for periodic reporting or for a SIP revision when a new version of MOVES is released, such work can be completed and submitted to EPA using the previous version of the model. The EPA

announced release date for an updated version of MOVES, MOVES2014, is July 2014. T he schedule for the inventory development for this HGB RS report did not allow time to incorporate MOVE S2014.

To estimate on

- road mobile source emissions, emissions rates calculated by the MOVES model must be multiplied by the level of vehicle activity. On

- road mobile source emissions factors are expressed in units of grams per mile; therefore, the activity information that is required to complete the inventory calculation is vehicle miles traveled (VMT) in units of miles per day. The level of vehicle travel activity is developed using a TDM run by the Texas Department of Transportation or by the local metro politan planning organization. The TDMs are validated against a large number of ground counts, i.e., traffic passing over counters placed in variousPage 36 locations throughout a county or area. For SIP and reporting inventories, VMT estimates are calibrated agai nst outputs from the federal highway performance monitoring system, a model built from a different set of traffic counters.

In addition to the number of miles traveled on each roadway link, the speed on each roadway type or segment is also needed to comple te an on

- road EI. Roadway speeds, required inputs for the MOVES model, are calculated by using the activity volumes from the TDM and a post

processor speed model.

4.4.2.1 On

- R oad Mobile Source Emissions Inventories The 2011, 2014, 2017, 2020, 2023, and 2026 on

- road mobile source EI s for the HGB RS were developed using the latest available data, current emissions factors and models, and the most current planning assumptions. The inventories include the eight HGB

- area counties designated as nonattainment for the one

- h our o zone NAAQS. On

- road inventory estimates were developed under contract by the Texas Transportation Institute (TTI). Consistent with on

- road inventory development procedures for reporting requirements an d rate of further progress, the on

- road inventories for each of these calendar years are based on VMT estimates and emission rates for an average summer work weekday. MOVES2010b, which is the latest available version of the EPA’s MOVES model, was used to e stimate the summer weekday emission rates in units of grams per mile for NO X and VOC. The roadway link

- level VMT estimates were obtained from travel demand modeling for the eight

- county HGB area for each analysis year. A summary of the

on

- road mobile sourc e VMT used to develop the various NO X and VOC emission s levels is presented in Table 4

- 2 : HGB VMT (miles per average summer day)

. The HGB on

- road mobile source 2011, 2014, 2017, 2020, 2023, and 2026 EI s for NO X and VOC are summarized in Table 4

- 3 : HGB Aver age Summer Weekday NO X and VOC Emissions for On

- R oad Mobile Sources (tons per day)

. For complete documentation of the development of the on

- road mobile source EI s for this HGB RS including the inventory development methods, MOVES inputs, and the results

, r efer to Attachment D: MOVES2010b

- Based On

- Road Inventories in Support of the HGB Ozone Nonattainment Area Redesignation Substitute Analysis . The complete set of input and output files are available from the TCEQ Air Quality Division upon request.

Table 4

- 2 : HGB VMT (miles per average summer day)
Description 2011 2014 2017 2020 2023 2026
Vehicle Miles
Traveled 150,968,794 144,916,411 151,890,390 159,509,450 167,539,317 176,004,008

Table 4

- 3 : HGB Average Summer Weekday NO X and VOC Emissions for On

- R oad Mobile Sources (tons per day)

Pollutant 2011 2014 2017 2020 2023 2026

NO X 181.28 127.70 88.85 69.80 59.28 54.51

VOC 80.92 60.43 46.51 40.51 38.09 36.93

4.4.2.2 On

- R oad Mobile Source Control Strategies
The on

- road mobile EIs for each HGB RS analysis year were developed using emission factors that reflect all control strategies for each analysis year except for the Tier 3 Federal Motor Vehicle Control Program ( FMVCP ) that will begin implementation in 2017. The controls thatPage 37 were modeled include: pre

- 1990 FMVCP, fleet turnover to Tier 1 of the FMVCP, fleet turnover to Tier 2 of the FMVCP, the 2007 heavy duty diesel FMVCP, summer reformulated gasoline ( RFG )

, the HGB veh icle inspection and maintenance ( I/M ) program, the HGB anti

- tampering program, and Texas Low Emission Diesel (TxLED). The Tier 3 FMVCP was finalized in March 2014 and will begin implementation in 2017. Although the 2017, 2020, 2023

, and 2026 emissions in t h is HGB RS r eport will be reduced when the effects of Tier 3 are included, MOVES2010b was released before the final Tier 3 rule took effect and does not include Tier 3 benefits. A summary of the HGB on

- road mobile source control strategies used for the HGB RS are presen ted in Table 4

- 4 : HGB On

- Road Mobile Control Strategies Summary

.

Table 4

- 4 : HGB On

- Road Mobile Control Strategies Summary
Control Program Description Year Control Program Started Control Scenario Notes

Pre

- 1990 FMVCP Pre

- 1990 Included for 2011, 2014, 2017, 2020, 2023

, and 2026

Anti

- Tampering Program 1986 Included for 2011, 2014, 2017, 2020, 2023

, and 2026

1992 Federal Controls on Gasoline Volatility 1992 Maximum Reid Vapor Pressure of 7.8 pounds per square inch Included for 2011, 2014, 2017, 2020, 2023

, and 2026

Tier 1 FMVCP 1994 Included for 2011, 2014, 2017, 2020, 2023

, and 2026

RFG Phase 1 1995 for Phase
One Superseded by RF G Phase 2

I/M Program 1997 Included for 2011, 2014, 2017, 2020, 2023

, and 2026

RFG Phase 2 2000 for Phase
Two Included for 2011, 2014, 2017, 2020, 2023

, and 2026

National Low Emission Vehicle (NLEV) Program 2001 Included for 2011, 2014, 2017, 2020, 2023

, and 2026

Tier 2 FMVCP 2004 Phase in 2004 to 2009 Included for 2011, 2014, 2017, 2020, 2023

, and 2026

TxLED 2006 Low aromatic hydrocarbon and high cetane number
to control NO X Included for 2011, 2014, 2017, 2020, 2023

, and 2026
Federal Low

- Sulfur Highway Diesel 2006 15 parts per million maximum sulfur c ontent Included for 2011, 2014, 2017, 2020, 2023

, and 2026

2007 Heavy Duty FMVCP 2007 Phase in 2007 to 2010 Included for 2011, 2014, 2017, 2020, 2023

, and 2026

Tier 3 FMVCP 2017 Not final until March 2014, Effects are not included in MOVES2010b, effects not included for any HGB
RS Scenarios If included, 2017, 2020, 2023

, and 2026 emissions
would be lower

Due to the on

- road mobile source control programs in place for each analysis year, the on

- road NO X and VOC emiss ions are steadily decreasing fro m the b ase year of 2011 to each milestone year and the 2026 horizon year despite growth in VMT. A summary of the tons per day (tpd) change from the 2011 base year to each milestone year and the horizo n year are summarized inPage 38 Table 4

- 5: Estimated Reductions from 2 011 Basel ine Due to FMVCP, I/M, RFG, and TxLED (tons per day)

. A summary of the percent change in NO X and VOC from the 2011 base year to each milestone year and the horizo n year are summarized in Table 4

- 6: Estimated Percent Reductions from 2011 Baseline D ue to FMVC P, I/M, RFG, and TxLED

.

Table 4

- 5 : Estimated Reductions from 2011 Ba seline Due to FMVCP, I/M, RFG, and TxLED (tons per day)

Inventory Year NO X VOC

2011 0 0

2014

- 53.58

- 20. 49

2017

- 9 2 .4 3

- 34

. 4 1

2020

- 11 1

. 48

- 40

. 4 1

2023

- 12 2

. 00

- 42

. 83

2026

- 1 26

. 77

- 43

. 99

Table 4

- 6 : Estimated Percent Reductions from 2011 Ba seline Due to FMVCP, I/M, RFG, and TxLED
Inventory Year NO X VOC

2011 0.0 0.0

2014

- 29

. 6

- 2 5

. 3

2017

- 51

. 0

- 42

. 5

2020

- 61

. 5

- 4 9

. 9

2023

- 6 7

. 3

- 52 .9

2026

- 6 9

. 9

- 54 .4

4.4.3 Non

- Road Mobile Sources
Non

- road vehicles do not typically operate on roads or highways and are often referred to as off

road or off

- highway vehicles. The non

- road source category is composed of a diverse collection of equipment. Non

- road emissions sources include but are not limited to: agricultural equipment; construction and mining equipment; lawn and garden equipment; aircraft and airport equipment; locomotives; commercial mari ne vessels (CMV); and drilling rigs. EIs for

non

- road sources developed as subcategories include: NONROAD model categories; airports; CMVs; drilling rigs; and locomotives. The following sections describe the emissions calculation methods used for the non

- r oad mobile source subcategories.

4.4.3.1 Updated 2011 Base Year Inventories
A Texas

- specific version of the EPA’s latest NONROAD 2008a model, called the Texas NONROAD (TexN) model, was used to calculate emissions for all non

- road mobile source equipment and recrea tional vehicles, with the exception of airports, locomotives, CMVs, and drilling rigs. Several equipment survey studies have been conducted that focused on various equipment categories operating in different areas in Texas. The resulting survey data are us ed as inputs to the TexN model to more accurately estimate non

- road emissions for the State of Texas. The 2011 EI development used the meteorological data, and fuel data collec ted for the calendar year 2011.Page 39 The 2011 airport emission sources include aircra ft engines, auxiliary power units, and ground support equipment. The United States Federal Aviation Administration’s Emissions and Dispersion Modeling System , Version 5.1.3 (EDMS) was used to calculate airport source emissions. To estimate the 2011 emissio ns from the airport sources, a survey was conducted by ERG under contract with the TCEQ to collect updated information on aircraft activity, fleet mix, and EDMS model input parameters. Documentation of methods and procedures used in developing HGB area 201 1 airport EI can be found in Attachment E: Development of Statewide Annual Emissions Inventory and Activity Data for Airports

. The 2011 Texas locomotive EI includes Class I, II, and III locomotive activity and emissions by rail segment for all counties wit hin Texas. Locomotive line

- haul and yard activity data were compiled from companies operating in Texas to create a county

- level Class I line

- haul inventory. Data developed by Eastern Regional Technical Advisory Committee in collaboration with the Federal R ailroad Administration, the American Short Line and Regional Railroad Association (ASLRRA), and members of the Class II and III railroad communities used 2008 activity and emissions profiles for Class II and Class III railroads. To calculate annual gallons of fuel used by railroads, data compiled by ASLRRA from the Class II and III railroads, including total industry fuel use in 2008 for locomotives and total Class II/III route miles, were used. Based on the EIA ’s latest annual energy outlook publication , 2 008 fuel usage values were grown to estimate 2011 emissions. Documentation of methods and procedures used in developing the locomotive EIs can be found in Attachment F : 2011 Texas Railroad Emission Inventory Report

.

The 2011 CMV EI was based on 2011 activi ty data compiled using local port data and data from the United States Department of Transportation Maritime Administration. The EPA’s updated 2011 emissions factors were used to account for vessel turnover and compliance with marine vessel air quality reg ulations. The emissions factors were applied to the 2011 activity values to calculate 2011 emissions. The emissions were spatially allocated to geographic information system (GIS) shapefiles. Documentation of methodologies and procedures used in developing the CMV EIs can be found in Attachment G: Development of 2011 Statewide Toxics and Actual Annual and Ozone Season Weekday Emissions Inventories for Commercial Marine Vessels

. The 2011 inventory for the drilling rig diesel engines was developed based on a statewide EI improvement study and updated with 2011 activity data. A survey of oil and gas exploration and production companies was used to develop improved drilling rig emissions characterization profiles. Documentation of methods and procedures used in developing the drilling rig diesel engine EIs can be found in Attachment H : Development of Texas Statewide Drilling Rigs Emissions Inventories for the Years 1990, 1993, 1996, and 1999 through 2040 or online at http://www.tceq.texas.gov/assets/public/implem entation/air/am/contracts/reports/ei/582119 9776FY1105

- 20110815

- ergi

- drilling_rig_ei.pdf

. The drilling rig emissions characterization profiles from this study were combined with 2011 drilling activity data obtained from the Railroad Commission of Texas (RRC) to develop the 2011 inventory.

4.4.3.2 Updated Milestone Years Inventories The updated milestone year inventories for the NONROAD model categories were developed using the most recent TexN/NONROAD2008a model

. The TexN model runs were performed for the analyses years 2014, 2017, 2020, 2023, and 2026 to estimate the ozone season da ily emissions for the NONROAD model categories. Unlike the NONROAD 2008a model that uses one state

- level population file, the TexN model contains unique population files for all 254 Texas counties. Population files in TexN have been developed for every pos sible analysis year (1970 to 2050) within the TexN model, utilizing county and source category classification

- specific growth factors. Due to fluctuations in engine activity and their associated surrogates, the TexNPage 40 population files are periodically update d using the most recent growth factors such as those available via Economy.com to allow for more accurate forecasting and back

- casting of emissions

. The updated milestone year inventories for the airport sources were based on the study Projection Factors f or Point and Area Sources developed by ERG (see Attachment A), the 2011 airport EI data

, and projections using Federal Aviation A ssociation’s Ter minal Area Forecast data.

The updated milestone year inventories for locomotives were based on the data develop ed by ERG in the final version of the 2011 NEI. The emissions rate adjustment factors used for projections by source classification code can found in the EPA’s fact sheet, Emission Factors for Locomotives ( http://www.epa.gov/otaq/regs/nonroad/locomotv/420f09025.pdf )

. The updated milestone year inventories for CMV sources were based on the data developed by ERG in the final version of the 2011 NEI and projections using trend data developed by E.H. Pechan & Associates, Inc. found in Attachment I: Development of Locomotive and Commercial Marine Emissions Inventory

- 1990 to 2040

. The updated milestone year inventories for drilling rigs were based on the 2011 inventory developed using the drilling rig emissions characterization profiles from the ERG report in Attachment H combined with 2011 drilling rig activity data from the RRC. The 2011 inventory was then projected to future years using growth fact ors. Documentation on the development of growth factors can be found in Attachment A.

4.4.3.3 Non

- Road Mobile Source Emissions Inventories
The 2011 non

- road category source NO X and VOC emissions totals for the eight

- county HGB

area are presented in Table 4

- 7 : HGB 2011 NO X Emissions for Non

- R oad Categories (tons per day) and Table 4

- 8: HGB 2011 VOC Emissions for Non

- R oad Categories (tons per day )

.

Table 4

- 7 : HGB 2011 NO X Emissions for Non

- R oad EI Categories (tons per day)

C ategory 2011 2014 2017 2020 2023 2026
NONROAD Model 57.20 44.53 34.51 27.28 23.14 20.92
Airport 8.66 9.45 10.30 11.22 12.25 13.38

Locomotive 18.03 16.10 14.99 14.30 13.19 11.32

Commercial Marine Vessels 36.74 36.44 34.71 30.40 26.46 22.86 Drilling Rigs 0.48 0.47 0.48 0.50 0.50 0.50

Total 121.11 106.99 94.99 83.70 75.54 68.98Page 41 Table 4

- 8 : HGB 2011 VOC Emissions for Non

- R oad EI Categories (tons per day)

C ategory 2011 2014 2017 2020 2023 2026
NONROAD Model 45.63 34.24 29.17 26.58 25.66 25.43
Airport 1.88 1.80 1.95 2.10 2.30 2.49

Locomotive 1.04 0.85 0.75 0.67 0.61 0.52

Commercial Marine Vessels 1.33 1.40 1.43 1.46 1.49 1.53
Drilling Rigs 0.04 0.04 0.04 0.05 0.05 0.05

Total 49.92 38.33 33.34 30.86 30.11 30.02

4.4.4 Stationary Point Sources
4.4.4.1 Emissions Inventory Development Stationary point source emissions data are collected annually from sites that meet the reporting requirements of 30 TAC §101.10. To collect the data, the TCEQ sends notices to all sites identified as potentially meeting the reporting requirements. Companies are required to report emissions data and to provide sample calculations used to determine the emissions. Information characterizing the process equipment, the abatement u nits, and the emission points is also required.

All data submitted in the emissions inventory questionnaire ( EIQ ) are reviewed for quality

assurance purposes and then stored in the State of Texas Air Reporting System (STARS) database. EIQ guidance document s and historical point source emissions of major pollutants are available on the TCEQ’s Point Source Emissions Inventory Web page (https://www.tceq.texas.gov/airquality/point

- s ource

- ei/psei.html). Additional information is available upon request from the TCEQ’s Air Quality Division.

4.4.4.2 Updated 2011 Base Year Inventory The TCEQ extracted the 2011 point source inventory data from STARS on February 13, 2014. The extracted data include d reported annual and ozone season daily emissions of NO X and VOC for each site in the HGB area for which a 2011 E IQ was submitted and reflected revisions made on or before the extract date. The TCEQ designated the 2011 inventory as the base year because it was the most recent NEI year available.

4.4.4.3 Updated Milestone Year Inventories When developing the milestone year inventories, the T CEQ used the 2012 EI as a baseline for projections.

The TCEQ designated the 2012 inventory as the baseline year for projections because it was the
most recent finalized point source EI data available. The TCEQ extracted the 2012 point source inventory dat a from STARS on February 18, 2014. The extracted data included reported annual and ozone season daily emissions of NO X and VOC for each site in the HGB area that submitted a 2012 EIQ and reflected revisions made on or before the extract date.

NO X emissions from sites containing equipment applicable to the MECT p rogram were projected using MECT data. MECT data were reviewed to identify sites with applicable units. For each of these sites, it was assumed that the significant majority of NO X emissions are from MECT applicable units. Since the MECT cap is an annual value, it was prorated by the ratio of the aggregate of the 2012 ozone season daily emissions to the aggregate of the 2012 annualPage 42 emissions for applicable sites to project future daily emissions for t he HGB area. To maintain a conservative approach, the entire cap was applied to the aggregate of the site emissions in the first milestone year inventory.

VOC emissions from sites identified as major sources of VOC emissions were projected using the major modification threshold for severe ozone nonattainment areas. Title V operating permit data from 2012 were reviewed to identify major sources of VOC emissions. For each site, the annual 25

- ton major modification threshold was prorated by the site

- wide ratio of ozone season to annual emissions to provide a one

- time growth limit added to the site’s 2012 emissions. To maintain a conservative approach, all growth was taken into account for the first milestone year inventory.

NO X emissions from sites not listed i n the MECT and VOC emissions from sources not identified as major sources of VOC emissions were projected using emissions trend data and growth factors. Emission trends for each site were established using 2009 through 2012 annual emissions data. For sites with decreasing emission trends, milestone year inventories were set equal to the 2012 baseline inventory. For sites with increasing emission trends, milestone year inventories were determined by applying growth factors to the 2012 baseline inventory. The growth factor information can be found in Attachment A. To maintain a conservative approach, any growth factors that projected a decrease in future emissions were modified so that emissions for these source categories remained constant through future year s

. Finally, the milestone year inventories were adjusted to account for emissions credits. Emissions credits are banked emissions reductions that may return to the airshed in the future. To account for the possible use of the banked NO X and VOC emissions, available Emissions Reduction Credit (ERC) and Discrete Emissions Reduction Credit (DERC) data were applied to the inventories.

Banked ERC use was determined based on New Source Review permitting offsets with a severe nonattainment offset ratio of 1.3 to 1 applied to such credits. ERCs listed in the Emissions Banking and Trading database as of February 24, 2014 were used. All of the banked ERCs were assumed to be allocated by 2017. The ERC transactions from 2008 to 2014 were also applied.

Banked DERCs were projected based on historical data with a 10% environmental contribution deduction under the assumption that DERCs will be used to meet 30 TAC Chapter 115 and/or Chapter 117 emissions standards. Available credits were averaged over the projected timespan. This approach is conservative and simplified; historical use has been considerably less 10 . DERCs listed in the Emissions Banking and Trading database as of February 18, 2014 were used. Past DERC transactions were not considered because of the short

- term nat ure of DERCs.

A summary of the point source inventories is presented in Table 4

- 9 : HGB Point Source NO X and VOC Emissions (tons per day)

.

10 Texas Commission on Environmental Quality. “ Discrete Emission Credit Banking and Trading Program Audit

. ” Accessed March 6, 2014

. http://www. tceq.texas.gov/assets/public/implementation/air/banking /reports/2013decprogramaudit.pdf.Page 43 Table 4

- 9 : HGB Point Source NO X and VOC Emissions (tons per day )

Pollutant 2011 2014 2017 2020 2023 2026

NO X 108.48 126.31 126.82 127.01 127.20 127.39

VOC 96.11 100.81 102.86 103.29 103.71 104.12

4.5 E missions S ummary The 2011 base year and the 2014, 2017, 2020, 2023, and 2026 future year EI summaries by source categories for the HGB area are shown in Table 4

- 10: HGB NO X Emissions by Source Category (tons per day) and Table 4

- 11: HGB VOC Emissions by Source Category (to ns per day) . These tables illustrate that in the horizon year of 2026, mobile sources (on

- road and non

road) contribute the most NO X emissions and area sources contribute the most VOC emissions. Contributions from biogenic emissions are not included in the summary because this analysis is limited to anthropogenic sources.

Table 4

- 10 : HGB NO X Emissions by Source Category (tons per day)

C ategory 2011 2014 2017 2020 2023 2026

Point Sources 108.48 126.31 126.82 127.01 127.20 127.39

Area Sources 21.15 22.19 22.90 23.28 23.17 23.23

On

- Road Mobile Sources 181

. 28 127.70 88.85 69.80 59.28 54.51

Non

- Road Mobile Sources 121.11 106.99 94.99 83.70 75.54 68.98
Total 4 32

. 02 383

. 19 333.56 303.79 285.19 274.11

Table 4

- 11 : HGB VOC Emissions by Source Category (tons per day)

C ategory 2011 2014 2017 2020 2023 2026

Point Sources 96.11 100.81 102.86 103.29 103.71 104.12

Area Sources 308.74 321.92 332.43 339.67 342.58 346.13

On

- Road Mobile Sources 8 0

. 92 60.43 46.51 40.51 38.09 36.93

Non

- Road Mobile Sources 49.92 38.33 33.34 30.86 30.11 30.02
Total 535

. 69 521.49 515.14 514.33 514.49 517.20

4.6 M aintenance Demonstration Conclusion

T rend analysi s using the 2026 future year emissions shows an overall decrease of 17 6

. 40 tpd in combined NO X and VOC emissions for the HGB area. This net change includes a projected 18.49 tpd de crease in VOC and a 157.91 tpd decrease in NO X

.

Previous photochemical model ing analysis for the HGB area shows that reducing NO X emissions is expected to be more effective in reducing the ozone design value than VOC reductions. Therefore, the projected 157.91 tpd decrease of NO X will reduce ozone design values more effectively th an the smaller 18.49 tpd de crease in VOC emissions . Based on future trends and previous photochemical analysis, the HGB area is projected to show continued attainment of the

one

- hour ozone standard through 2026

.