SECTION 4 REASONABLE FURTHER PROGRESS DEMONSTRATION OCTOBER 2009 REVISION 4.1 Purpose of Section This section demonstrates that EMAand WMAwill meet the 8-hour ozone standard requirement related to Reasonable Further Progress (RFP) . EPA's Phase 2 Rule requires that, by the end of 2008, emissions of ozone precursors (VOCs and NOx) in each nonattainment area decrease by at least 15%of the MA 2002 Base Year Inventory.' MassDEP has projected 2008 emissions after taking into account anticipated growth in the economy and any additional control measures expected to be in effect by that date. Its projections demonstrate that emissions will decrease in both areas by a significantly greater percentage than the 15% reduction required to demonstrate RFP . 4.2 Reasonable Further Progress Requirements and Methodology Under the CAA, ozone nonattainment areas are required to demonstrate progress towards attaining the ozone standard prior to their attainment year . EPA's Phase 2 Rule RFP requirements for 8-hour ozone non-attainment areas vary according to: 1) whether an area's attainment year is more than 5 years after EPA's 2004 nonattainment designations ; and 2) whether an area was previously required to submit a 15%

VOC Rate of Progress2 plan under the 1-hour ozone standard. EMAand WMA have a 2010 attainment year and under the 1-hour ozone standard they were required to submit 15% Rate of Progress SIPs .3 The applicable RFP requirement, therefore, is to reduce emissions of VOCs and/or NOx by 15%

within the six years after the 2002 Base Year Inventory - that is, by the end of 2008. The procedures and methodology for demonstrating compliance with the 1-hour ozone standard Rate of Progress requirements were established in a 1992 EPAguidance document ; these are still applicable for purposes of the 8-hour ozone standard RFP .4 EPA's method for demonstrating that RFP requirements are met calls for : 1 . Developing a 2002 base year inventory for a nonattainment area that takes into account certain adjustments for RFP purposes ; 2 . Establishing a "target level" of emissions for the last year of the RFP period (the "milestone" year) that reflects the required 15%reduction fromthe base year;

1 As noted in Section 2, the MA 2002 Base Year Inventory is Appendix 2A. 2 Generally, the phrase "rate of progress" has been used in connection with 1-hour ozone standard requirements, while EPA has described 8-hour standard requirements as "reasonable further progress" . 3 The 15%Rate of Progress requirement was to demonstrate a 15%reduction in emissions ofVOCs fromthe 1990 baseline inventory by 1996. An additional 9%reduction in VOCs, NOx or a combination of both, was required by 1999. MassDEP submitted a number of SIP revisions between 1993 and 2002 demonstrating compliance with these 1-hour ozone standard ROP requirements. 4 Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the I S Percent Rate of Progress Plans, U.S . EPA, Office of Air Quality Planning and Standards, EPA-452/R-92-005, October 1992. Final Section 4 - Page 1 of 7 - Revised October 20093. Developing a projected inventory of VOC and NOx emissions for the nonattainment area in the milestone year ; and 4 . Demonstrating that the projected milestone year emissions of NOx and VOCwill be less than, or equal to, the target level for that year . Consistent with EPA's methodology, MassDEP demonstrates in the calculations below that the EMAand WMAnonattainment areas have met the RFP requirements . 4.3 2002 RFP Adjusted Base Year Inventory The MA 2002 Base Year Inventory estimates anthropogenic and biogenic emissions of VOCand NOx. Pursuant to EPA's RFP methodology, for RFP purposes, MassDEP has adjusted the inventory as follows: 1 . excluded biogenic VOC emissions; and 2. excluded non-creditable reductions fromthe Federal Motor Vehicle Control Program (FMVCP) .5 3. included unused point source banked emission reduction credits (ERCs) in 2002. Table RFP-1 reflects the emissions estimates of VOC and NOx fromthe MA 2002 Base Year Inventory for EMA and WMA by source categories, with these adjustments. The result is the 2002 RFPAdjusted Base Year Inventory.

5 The CAA (Section 182(b)(1)(D)) provides that reductions fromthe following measures are not creditable toward the required reductions : (1) Federal Motor Vehicle Control Program(FMVCP) tailpipe and evaporative standards issued in 1990 ; (2) Federal regulations limiting the Reid Vapor Pressure (RVP) of gasoline in ozone nonattainment areas issued by June 15, 1990 ; (3) State regulations correcting deficiencies in reasonably available control technology (RACT) rules; (4) Measures required to be enacted immediately after passage of the 1990 CAA Amendments concerning corrections to vehicle inspection and maintenance (I/M) programs. Only the FMVCP continues to generate emission reductions through 2008 in Massachusetts .

Final Section 4 - Page 2 of 7 - Revised October 2009Table RFP 1 2002 VOC and NOx Adjusted Base Year Inventory

MA 2002 Base Year Inventory - . : ` EMA N1MA TAT WMA STATE (FromAppendix 2A) VOC VOC VQC EMA NOx NOx NOx (tons per summer day) POINT 13 .6 2.4 16.0 , 116.6 13.0 129.6 AREA 282 .0 45 .5 327.5 ; 33.9 5 .2 39 .1 ON-ROAD 127.4 24.5 151 .9 381 .4 71 .7 453.1 OFF-ROAD 196.2 27.7 223 .9 122.1 22.4 144.5 BIOGENICS 535 .7 254.6 790.3 4.4 1 .1 5 .5

------------------------------------------ ----- ------ ------ ----- TOTAL ALL CATEGORIES 1154.9 354.7 1509.6 658.4 113.4 771 .8 Adjustments for RFP EMAIWMA : TOTAL ANTHROPOGENIC (after subtraction of biogenics) 619.2 100.1 719.3 654.0 112.3 766.3 FMVCP adjustment (Mobile On-Road) -15.3 -2 .9 -45.2 -8 .5 UNUSED BANKED POINT ERCs 2002 2.4 0.1 30.6 0.8 2002 RFP ADJUSTED BASE YEAR` 97.3`Y 639.4 104.6 INVENTORY EIIAA & WMA Note: Small discrepancies may be due to rounding ks/2.inventory-2002-SIP-RFP File: MA-RFP-base-targets-proj -revised- Oct-14-2009 4 .4 Target Level of Emissions MassDEP must demonstrate that the 2008 projected emissions for EMA and WMA will be at least 15%below

the 2002 RFPAdjusted Base Year Inventory shown in Table RFP-1 above. The reductions can be of VOCs, NOx or any combination thereof . MassDEP is establishing its target levels based on a combined reduction of 12% NOx emissions and 3%VOCemissions in both EMAand WMA

. The 2008 Target Levels are depicted in Table RFP 2 ; projected emissions in 2008 may not exceed these Target Levels . The amount of reductions of each pollutant needed to achieve the Target Levels based on the 12% NOx and 3%VOCbreakdown is also shown .

Final Section 4 - Page 3 of 7 - Revised October 2009Table RFP 2 - 2008 Target Levels and Reductions Needed (TPSD) EMA WMA EMA WMA 1 . 2002 RFP Adjusted Base VOc VOc NOx NOx Year Inventory (fromTable RFP 1) 606.3 97.3 639.4 104.6 2. Selected combination of reductions 3% 3% 12% 12% 3. Required Reductions (line 1 x line 2) 18.2 2 .9 76.7 12.6

588.1 94.4 562.7 92 .0 ks/2.inventory-2002-SIP-RFP File: MA-RFP-base-targets-proj -revised- Oct-14-2009 4.5 2008 Projected Emissions Inventory The projected emissions in 2008 are calculated by estimating anticipated growth in emissions between 2002 and 2008 and then adjusting for any controls that will reduce emissions during that time period. The basic methodology for growing point and area source emissions is the application of socio-economic growth factors to the base year data. For on-road and non-road sources, projected emissions are estimated using the current EPAemission models, which have built-in control factors. The NONROADmodel also has built-in growth factors. Appendix 4A, MA 2008 Projections by Categories, is based on the source category list used in the MA 2002 Base Year Inventory. It shows the growth factor that was applied to each source category to project 2008 emissions . It also indicates whether post-2002 controls have been taken into account . The projection methodology for the different source sectors listed in Appendix 4A is discussed below

. Table RFP 3 summarizes the total 2008 projected emissions for EMAand WMAfor all source sectors. 4.5.1 Stationary Point Sources The Stationary Point Source sector of the MA 2002 Base Year Inventory includes emissions fromElectric Generating Units (EGUs) and other industrial point sources. For EGUs and certain large boilers that have been subbject to the NOx Budget Program, instead of using 2002 base year data to project 2008 emissions, MassDEP is using 2006 actual emissions7 to which it applied growth factors based on the U .S . Department of Energy Forecast 8 for New England . 6 The NOx Budget Program is discussed in Section 3, Control Measures. Because the programbegan in 2003, 2002 base year data does not provide a good basis from which to project future year emissions from sources covered by the program . Final Section 4 - Page 4 of 7 - Revised October 2009For all other point sources (non-NOx Budget Program sources), MassDEP used MA 2002 Base Year emissions. To project 2008 emissions fromthis group of point sources, MassDEP interpolated from2009 projected emissions developed for MANE-VU9 for attainment demonstration modeling purposes . 10 MANE-VU used EPA's Economic Growth and Analysis System (EGAS, version 5.0) and the Annual Energy Outlook of the U.S. Department of Energy's Energy Information Administration (DOE/EIA) to project 2009 emissions for the non-EGU point source sector . MassDEP did not take any post-2002 control measures into account in projecting 2008 emissions fromthis group of point sources. Banked emission reduction credits (ERCs) unused as of 2008 are included in the 2008 projections. (See Table RFP 3 and Appendix 4c.) 4.5.2 Area Sources For most area sources, MassDEP projected 2008 emissions based on the MA 2002 Base Year inventory combined with growth factors based on employment data fromthe Massachusetts Department of Employment and Training (MA-DET) . For the consumer products and architectural coatings (paints) categories, projections were based on population growth factors fromthe U

.S. Census population projections. For residential, commercial and small industrial fuel use, MassDEP used the growth factors that MANE-VUdeveloped fromDOE-EIA data and EGAS. 4.5.3 On-Road and Non-Road Mobile Sources The Massachusetts Executive Office ofTransportation and Public Works, Office of Transportation and Planning (EOT) estimated on-road mobile source emissions in 2008 for purposes of establishing the Transportation Conformity budgets required for the 2008 RFP milestone year . (Transportation Conformity budget requirements are discussed in Section 9, Transportation Conformity.) These 2008 on-road mobile source projections are used in this section as part of the RFP calculations .

7 EPA Clean Air Markets Division 2006 NOx Budget Program Emissions Report for Massachusetts . Available at : http ://camddataandmaps epa .gov/g~dm/index .cfm . 8 U.S . Department of Energy, Energy Information Administration (DOE/EIA), Forecasts and Analysis, Table 1 - Energy Consumption by Sector and Source -New England -O1 http ://www

eia doe .gov/oiaf/forecasting.html 9 The Mid-Atlantic and Northeastern states, tribes, and federal agencies formed The MidAtlantic/Northeast Visibility Union (MANE-VU) to coordinate regional haze planning activities for the region. MANE-VU and the OTC coordinated the development of combined inventories for purposes of regional ozone and PM2.5 attainment planning and regional haze planning. 10 See Appendix 5K, "Development of Emission Projections for 2009, 2012 and 2018for NonEGUPoint, Area and Nonroad Sources in the MANE-VURegion, Prepared by MACTEC Federal Programs, Inc., Feb. 28, 2007. Final Section 4 - Page 5 of 7 - Revised October 2009EOT used the latest version of its Travel Demand Model to project 2008 vehicle miles traveled

(VMT) . EPA's MOBILE 6 .2 model generated emission factors based on MassDEP inputs to the model that reflect state and federal mobile source control programs that will be in place in 2008. EOT combined the emission factors generated from MOBILE 6 .2 with VMT to estimate on-road mobile emissions in 2008.11 The MassDEP on-road mobile control programs that were adopted under the 1-hour ozone standard and that are reflected in the 2002 and 2008 input files include: MA Enhanced Inspection and Maintenance (I/M) program, the California Low Emission Vehicle (LEV) program, Stage II vehicle refueling control and reformulated gasoline (RFG) . MassDEP does not anticipate changing the parameters of any state mobile source control programafter 2002 and prior to the end of 2008. Therefore, the inputs for the 2002 base year and the 2008 projection year are the same. 12 (MassDEP expects to implement program revisions for the I/M

programbeginning in late 2008.) For non-road mobile emissions, MassDEP used EPA's NONROAD Model (version 2005a, Feb.2006) to project 2008 emissions fromthis sector . The model has built-in state and county growth factors and factors for the federal control measures for non-road engines that will be in effect in 2008. (See Section 3, Control Measures) For the non-road category of airport emissions, MassDEP applied growth factors for Logan Airport to develop Suffolk County (EMA) projected emissions. The growth factors for other airports in each county in EMA and WMAwere derived fromMANE-VU projections. Growth factors for Commercial Marine Vessels and Locomotives were also derived from MANE-VU . 4 .6 Summary The 2008 projections are summarized in Table RFP 3 below . Reductions anticipated by 2008 are compared to the reductions required to meet RFP . As shown, both areas have demonstrated reductions significantly greater than the 15% reduction needed to meet RFP requirements .

i l Section 9, Transportation Conformity, includes additional discussion of the planning assumptions used to estimate mobile source emissions for the 2008 and 2009 Transportation Conformity Budgets . 12 Non-road input and output data and non-road emissions by county are contained in Appendix 4b, Tables 4B-7 and 4B-8.

Final Section 4 - Page 6 of 7 - Revised October 2009TABLE RFP 3

2002 RFP Adjusted Base Year, 2008 Projected Emissions & Target Level Comparison Tons per Summer Day 

### VoC NOX EMA EMA WMA WMA EMA EMA WMA WMA 2002 2008 2002 2008 2002 2008 2002 2008 BASE PROJECT BASE PROJECT BASE PROJECT BASE PROJECT YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR SOURCE SECTOR (Anthropogenic) VOC VOC VOC vOC NOx NOx NOx NOx POINT 13.6 13.9 2.4 2.4 116.6 77.2 13.0 8.6 AREA 282.0 286.0 45.5 46.3 - 33.9 38.1 5 .2 5.9 ON-ROAD 127.4 68.3 24.5 11 .8 ~ 381 .4 191 .3 71 .7 31 .3 OFF-ROAD 196.2 155.3 27.7 23.6 122.1 108.1 22 .4 20.3 TOTAL EMISSIONS unadjusted 619.2 523.5 100.1 84.1 654.0 414.7 112.3 66.1 UNUSED BANKED POINT ERCs 2 .4 2 .2 0.1 0.1 30.6 25.9 0.8 0.8 TOTAL EMISSIONS WITH ERCs 621 .6 525.7 100.2 84.2 - . 684.6 440 .6 113.1 66.9 FMVCP ADJUSTMENT (ON-ROAD) -15.3 -2.9 -45.2 -8 .5 - 1 . 2002 RFP Adjusted Base Year Emissions (Table RFP 1) 606.3 97.3 639.4 104.6 - 2 . 2008 Projected Emissions (with unused banked ERCs in 2008) 525 .7 84.2 440 .6 66.9 3 . Required VOC/NOx Reductions (must total 15%) 3% 3% 12% 12% 4 . 15%Reductions in tons (to calculate 2008 Target Levels = Line 1' line 3) 18.2 2.9 76.7 12.6 5 . 2008 RFP Target Levels (Table RFP 2) line 1- line 4 588.1 94.4 562.7 92 .0 6 . Projected 2002 to 2008 reductions Line 1- line 2 80.6 13.1 198.8 37 .7 7. Tons (and %) by which 2008 projected emissions are below RFP Target Levels Line 6 - line 4 62.4 10.2 - 122.1 25.1 Line 7 / line 5 10.6% 10 .8% 21 .7% 27 .3% °' Unused banked ERCs in 2002 and 2008 were added to 2002 base year and 2008 projection year, respectively . ksi2.lnventory-2002-51P-RFP File : MA-RFP-base-targets-proj -revised- ERCs-Oct--2009

Final Section 4 - Page 7 of 7 - Revised October 2009