Bryan W. Shaw, Ph.D., Chainnan 

Carlos Rubinstein, Commissioner 

Toby Baker, Commissioner 

Zak Covar, Executive Director 

RECEIVED- 6POL 

AIR PLANNING SEC. 

12 JUL -5 PH 5: 23 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITI 

Protecting Texas by Reducing and Preventing Pollution 

June 28, 2012 

Mr. Samuel Coleman 

Acting Regional Administrator 

Environmental Protection Agency, Region 6 

Fountain Place 12th Floor, Suite 1200 

1445 Ross Avenue 

Dallas, Texas 75202-2733 

Subject: Request for Parallel Process Review of the Draft Beaumont-Port Arthur Attainment 

Area On-Road Mobile Source Emissions Invento:ry and Motor Vehicle Emissions Budget Update 

State Implementation Plan Revision 

Dear Mr. Coleman: 

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

Beaumont-Port Arthur (BPA) Attainment Area On-Road Mobile Source Emissions Invento:ry 

and Motor Vehicle Emissions Budget (MVEB) Update State Implementation Plan (SIP) 

Revision. MVEBs are being revised to comply with mandato:ry use of the United States 

Environmental Protection Agency's Motor Vehicle Emission Simulator (MOVES) model in 

future transportation conformity determinations. We are requesting parallel processing to assist 

BPA-area transportation partners in shortening an impending conformity lapse. 

The current BPA transportation plan does not conform to the MVEBs set by the most recently 

approved ozone SIP revision for the BPA area. Because the transportation plan cannot conform, 

it will "lapse" starting September 25, 2012, which means no new transportation projects or 

project phases may advance until the problem is fixed. This SIP revision provides MOVES-based 

MVEBs to which the BPA transportation plan may conform, ending the lapse. To allow EPAarea transportation partners to conduct a conformity determination as quickly as possible, the 

TCEQ requests that the EPA parallel process its review of this draft submission for approval into 

the Texas SIP. 

This SIP revision is an update to the 1997 Eight-Hour Ozone Redesignation Request and 

Maintenance Plan for the BPA Ozone Nonattainment Area (2008 BPA maintenance plan), 

which was approved by the EPA effective November 19, 2010. The BPA 1997 eight-hour ozone 

maintenance area includes Hardin, Jefferson, and Orange Counties. This SIP revision proposal 

was approved by the commission on June 27, 2012, for publication, solicitation of public 

comments, and a public hearing. The public comment period will begin on June 29, 2012, and 

end on August 3, 2012, and the public hearing is scheduled for August 1, 2012. The final 

submission of this SIP revision will document the public review process including a formal 

summa:ry of comments received and the TCEQ's responses to those comments. 

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.texas.gov 

How is our customer service? tceq.texas.govjcustomersurvey 
Mr. Coleman 

Page Two 

This SIP revision is expected to be noncontroversial as it will only update the approved 2008 

BPA maintenance plan to incorporate the EPA's MOVES model. This SIP revision replaces the 

existing 2008 BPA maintenance plan on-road mobile source emissions inventories for nitrogen 

oxides (NOx) and volatile organic compounds (VOC) based on the EPA's MOBILE model with 

those based on the EPA's MOVES model. On-road mobile source emissions inventory updates 

include those for 2005, 2011, 2014, 2017, and 2021. In addition, this SIP revision replaces the 

existing 2021 NOx and VOC MVEBs with those derived from the MOVES-based emissions 

inventories. 

Attached to this submission is one hardcopy of the required documentation. An electronic 

version of the submission in PDF format that is identical to the hardcopy has been sent to Guy 

Donaldson at EPA, Region VI. 

The TCEQ respectfully requests that the EPA proceed with final review of the enclosed draft BPA 

Attainment Area On-Road Mobile Source Emissions Inventory and MVEB Update SIP Revision. 

If you have any questions or need additional information, please contact David Brymer at 

(512)239-1725. 

Executive Director 

Texas Commission on Environmental Quality 

ZCjjz 

Enclosure: Draft Beaumont-Port Arthur Attainment Area On-Road Mobile Source Emissions 

Inventory and Motor Vehicle Emissions Budget Update State Implementation Plan Revision 
REVISIONS TO THE STATE OF TEXAS AIR QUALITY 

IMPLEMENTATION PLAN FOR THE CONTROL OF OZONE AIR 

POLLUTION

BEAUMONT-PORT ARTHUR ATTAINMENT AREA FOR THE 1997 

EIGHT-HOUR OZONE STANDARD

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

P.O. BOX 13087

AUSTIN, TEXAS 78711-3087

BEAUMONT-PORT ARTHUR ATTAINMENT AREA ONROAD MOBILE SOURCE EMISSIONS INVENTORY AND

MOTOR VEHICLE EMISSIONS BUDGET UPDATE STATE 

IMPLEMENTATION PLAN REVISION

Project Number 2012-005-SIP-NR 

Proposal

June 27, 2012
This page intentionally left blank
ES-1 

EXECUTIVE SUMMARY

In 2008, the commission adopted the Eight-Hour Ozone Redesignation Request and 

Maintenance Plan for the Beaumont-Port Arthur (BPA) Ozone Nonattainment Area (Project No. 

2008-006-SIP-NR), which fulfills all Federal Clean Air Act (FCAA) requirements to redesignate 

the BPA ozone nonattainment area (Hardin, Jefferson, and Orange Counties) to attainment of 

the 1997 eight-hour ozone standard and demonstrates continued attainment of that standard 

through 2021. The plan was approved by the United States Environmental Protection Agency 

(EPA) effective November 19, 2010, and the BPA area was redesignated to attainment for the 

1997 eight-hour ozone standard. The 2008 BPA maintenance plan contains on-road mobile 

emissions inventories, a nitrogen oxides (NOX) motor vehicle emissions budget (MVEB), and a 

volatile organic compounds (VOC) MVEB developed using the EPA’s MOBILE emissions 

estimation model. On March 2, 2010, the EPA officially released a new model, the Motor Vehicle 

Emission Simulator (MOVES) model, to replace the MOBILE model for SIP applications.

Beginning March 2, 2013, transportation conformity must be conducted using the MOVES 

model. To demonstrate transportation conformity, a nonattainment or maintenance area must 

show that its metropolitan transportation plans, transportation improvement programs, and 

projects funded by the Federal Highway Administration or the Federal Transit Administration 

conform to the MVEBs established in the state implementation plan (SIP). Conformity must be 

demonstrated before area transportation plans can be approved or funded by the United States

Department of Transportation or the Metropolitan Planning Organizations. Updating MVEBs 

using MOVES-based on-road mobile emissions inventories requires a SIP revision. This 

proposed SIP revision would facilitate future MOVES-based transportation conformity 

determinations by providing MVEBs based on the latest version of the MOVES model, 

MOVES2010a. 

This proposed SIP revision would replace the 2008 BPA maintenance plan on-road mobile 

source emissions inventories for NOX and VOC based on the EPA’s MOBILE model with those 

based on the EPA’s MOVES model. On-road mobile source emissions inventory updates include 

those for 2005, 2011, 2014, 2017, and 2021. In addition, 2021 NOX and VOC MVEBs would be

updated based on the MOVES-based emissions inventories.

This proposed SIP revision includes documentation to satisfy the EPA’s MOVES 

implementation policy guidance1 concerning updating maintenance plans with MOVES, which 

indicates that states must (1) demonstrate that the updated plan continues to meet all 

maintenance requirements and (2) document that growth and control strategy assumptions for 

all other source categories (area, non-road mobile, and stationary point) continue to be valid 

and any minor updates would not change the conclusions of the approved maintenance plan.

 

1 EPA, 2009. “Policy Guidance on the Use of MOVES2010 for State Implementation Plan Development,

Transportation Conformity, and Other Purposes.” Transportation and Regional Programs Division, Office 

of Transportation and Air Quality, U.S. Environmental Protection Agency, EPA-420-B-09-046, December 

2009.
i 

SECTION V-A: LEGAL AUTHORITY

General

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state’s air, including maintaining adequate visibility.

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more 

comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon’s Texas 

Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 

1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, 2009, and 2011. In 1989, the TCAA was 

codified as Chapter 382 of the Texas Health and Safety Code.

Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution 

control agency and is the principal authority in the state on matters relating to the quality of air 

resources. In 1991, the legislature abolished the TACB effective September 1, 1993, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the 

general provisions, organization, and general powers and duties of the TNRCC, and the 

responsibilities and authority of the executive director. Chapter 5 also authorizes the TNRCC to 

implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives the 

TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence of 

the TNRCC until September 1, 2013, and changed the name of the TNRCC to the TCEQ. In 

2009, the 81st Texas Legislature, during a special session, amended section 5.014 of the Texas 

Water Code, changing the expiration date of the TCEQ to September 1, 2011, unless continued in 

existence by the Texas Sunset Act. In 2011, the 82nd Texas Legislature continued the existence 

of the TCEQ until 2023.

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state’s air and to control the quality of the state’s air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; to conduct research 

and investigations; to enter property and examine records; to prescribe monitoring 

requirements; to institute enforcement proceedings; to enter into contracts and execute 

instruments; to formulate rules; to issue orders taking into consideration factors bearing upon 

health, welfare, social and economic factors, and practicability and reasonableness; to conduct 

hearings; to establish air quality control regions; to encourage cooperation with citizens’ groups 

and other agencies and political subdivisions of the state as well as with industries and the 

federal government; and to establish and operate a system of permits for construction or 

modification of facilities.

Local government authority is found in Subchapter E of the TCAA. Local governments have the 

same power as the TCEQ to enter property and make inspections. They also may make 

recommendations to the commission concerning any action of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town may enact and enforce 

ordinances for the control and abatement of air pollution not inconsistent with the provisions of 

the TCAA and the rules or orders of the commission.
ii

Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies 

to develop and implement transportation programs and measures necessary to attain and 

maintain the NAAQS; establish gasoline volatility and low emission diesel standards; and fund 

and authorize participating counties to implement vehicle repair assistance, retrofit, and 

accelerated vehicle retirement programs.

Applicable Law

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP.

Statutes

All sections of each subchapter are included, unless otherwise noted.

TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2011

TEXAS WATER CODE September 1, 2011

Chapter 5: Texas Natural Resource Conservation Commission

Subchapter A: General Provisions

Subchapter B: Organization of the Texas Natural Resource Conservation Commission

Subchapter C: Texas Natural Resource Conservation Commission

Subchapter D: General Powers and Duties of the Commission

Subchapter E: Administrative Provisions for Commission

Subchapter F: Executive Director (except §§5.225, 5.226, 5.227, 5.2275,5.231, 5.232, and 

5.236)

Subchapter H: Delegation of Hearings

Subchapter I: Judicial Review

Subchapter J: Consolidated Permit Processing

Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145, and 5.515 only)

Subchapter M: Environmental Permitting Procedures (§5.558 only)

Chapter 7: Enforcement

Subchapter A: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 only) 

Subchapter B: Corrective Action and Injunctive Relief (§7.032 only)

Subchapter C: Administrative Penalties

Subchapter D: Civil Penalties (except §7.109)

Subchapter E: Criminal Offenses and Penalties: §§7.177, 7.179-7.183

Rules

All of the following rules are found in 30 Texas Administrative Code, as of the following latest 

effective dates:

Chapter 7: Memoranda of Understanding, §§7.110 and 7.119

December 13, 1996 and May 2, 2002

Chapter 19: Electronic Reporting March 15, 2007

Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

Permits; Temporary Suspension or Amendment of Permit Conditions July 20, 2006
iii

Chapter 39: Public Notice, §§39.402(a)(1) - (6), (8), and (10) - (12), 

39.405(f)(3) and (g), (h)(1)(A) - (4), (6), (8) - (11), (i) and (j), 39.407, 39.409, 

39.411(a), (e)(1) - (4)(A)(i) and (iii), (4)(B), (5)(A) and (B), and (6) - (10), 

(11)(A)(i) and (iii) and (iv), (11)(B ) - (F), (13) and (15), and (f)(1) - (8), (g) and 

(h), 39.418(a), (b)(2)(A), (b)(3), and (c), 39.419(e), 39.420 (c)(1)(A) - (D)(i)(I) 

and (II), (D)(ii), (c)(2), (d) - (e), and (h), and 39.601 - 39.605 June 24, 2010

Chapter 55: Requests for Reconsideration and Contested Case Hearings; 

Public Comment, §§55.150, 55.152(a)(1), (2), (5), and (6) and (b), 55.154(a), 

(b), (c)(1) - (3), and (5), and (d) - (g), and 55.156(a), (b), (c)(1), (e), and (g) June 24, 2010

Chapter 101: General Air Quality Rules October 27, 2011

Chapter 106: Permits by Rule, Subchapter A May 15, 2011

Chapter 111: Control of Air Pollution from Visible Emissions and Particulate 

Matter February 16, 2012

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for 

Designated Facilities and Pollutants May 14, 2009

Chapter 114: Control of Air Pollution from Motor Vehicles August 11, 2011 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds December 29, 2011

Chapter 116: Permits for New Construction or Modification March 1, 2012

Chapter 117: Control of Air Pollution from Nitrogen Compounds April 19, 2012

Chapter 118: Control of Air Pollution Episodes March 5, 2000

Chapter 122: §122.122: Potential to Emit December 11, 2002

Chapter 122: §122.215: Minor Permit Revisions June 3, 2001

Chapter 122: §122.216: Applications for Minor Permit Revisions June 3, 2001

Chapter 122: §122.217: Procedures for Minor Permit Revisions December 11, 2002

Chapter 122: §122.218: Minor Permit Revision Procedures for Permit 

Revisions Involving the Use of Economic Incentives, Marketable Permits, and 

Emissions Trading June 3, 2001
iv

SECTION VI: CONTROL STRATEGY

A. Introduction (No change)

B. Ozone (Revised)

1. Dallas-Fort Worth (No change)

2. Houston-Galveston-Brazoria (No change)

3. Beaumont-Port Arthur (Revised) 

Chapter 1: General (Revised)

Chapter 2: Redesignation Requirements (Revised) 

Chapter 3: Attainment Emissions Inventory (No change)

Chapter 4: Maintenance Demonstration (Revised)

Chapter 5: Monitoring Network (No change)

Chapter 6: Contingency Plan (No change)

4. El Paso (No change)

5. Regional Strategies (No change)

6. Northeast Texas (No change)

7. Austin Area (No change)

8. San Antonio Area (No change)

9. Victoria Area (No change) 

C. Particulate Matter (No change)

D. Carbon Monoxide (No change)

E. Lead (No change)

F. Oxides of Nitrogen (No change)

G. Sulfur Dioxide (No change)

H. Conformity with the National Ambient Air Quality Standards (No change)

I. Site Specific (No change)

J. Mobile Sources Strategies (No change)

K. Clean Air Interstate Rule (No change)

L. Transport (No change)

M. Regional Haze (No change)
v 

TABLE OF CONTENTS

Executive Summary

Section V-A: Legal Authority

Section VI: Control Strategy

Table of Contents

List of Acronyms

List of Tables

List of Figures

List of Appendices

Chapter 1: General (Updated)

1.1 Background and Introduction (Updated)

1.1.1 Purpose of Plan (Updated)

1.1.2 One-Hour Ozone History in the BPA Area (No Change)

1.1.3 Eight-Hour Ozone History in the BPA Area (Updated)

1.1.3.1 2008 and 2010 Eight-Hour Ozone Standards (Added)

1.2 Public Hearing Information (Updated)

1.3 Social and Economic Consideration (No Change)

1.4 Fiscal and Manpower Resources (No Change)

Chapter 2: Redesignation Requirements (Updated)

2.1 Attainment of the 1997 Eight-Hour Ozone National Ambient Air Quality Standard 

(Updated)

2.1.1 Ozone Data (No Change)

2.1.2 Ozone Trend Analysis (Updated)

2.2 SIP Approvability Under Section 110(k) of the Federal Clean Air Act (No Change)

2.3 Permanent and Enforceable Emission Reductions (Updated)

2.3.1 Control Strategies (No Change)

2.3.2 2002 Periodic Emissions Inventory (No Change)

2.3.3 Trend Analysis (Updated)

2.3.3.1 Nitrogen Oxides Trends (Updated)

2.4 Section 175A Requirements for Maintenance Plans (No Change)

Chapter 3: Attainment Emissions Inventory (No Change)

Chapter 4: Maintenance Demonstration (Updated)

4.1 General (Updated)

4.2 Future Emissions and Verification of Continued Attainment (Updated)

4.2.1 Area Sources (Updated)

4.2.1.1 Flash Emissions from Upstream Oil and Gas Production (No Change)

4.2.1.2 Updated Verification of Continued Attainment for Area Sources (Added)
vi

4.2.2 On-Road Mobile Sources (Updated)

4.2.2.1 Motor Vehicle Emissions Budgets (Updated)

4.2.2.2 Safety Margin (Updated)

4.2.3 Non-Road Mobile Sources (Updated)

4.2.3.1 Airports (No Change)

4.2.3.2 Locomotives and Marine Vessels (No Change)

4.2.3.3 Updated Verification of Continued Attainment for Non-Road Mobile Sources 

(Added)

4.2.4 Stationary Point Sources (Updated)

4.2.4.1 Emissions Inventory Compilation (No Change)

4.2.4.2 Updated 2005 Base Year Inventory (No Change)

4.2.4.3 Updated Uncontrolled Milestone Year Inventories (No Change)

4.2.4.4 Updated Verification of Continued Attainment for Stationary Point Sources 

(Added)

4.3 Control Strategies (No Change)

4.3.1 Point Source NOX Control Strategy (No Change)

4.3.2 National Volatile Organic Compound Emission Standards for Consumer Products 

(No Change)

4.3.3 National Volatile Organic Compound Emission Standards for Architectural 

Coatings (No Change)

4.3.4 National Low Emission Vehicle Program / Tier 2 Engine and Fuel Standards (No 

Change)

4.3.5 Stage I Vapor Recovery (No Change)

4.3.6 Stage II Vapor Recovery (No Change)

4.3.7 Texas Low Emission Diesel (No Change)

4.3.8 Texas Emission Reduction Plan (No Change)

4.3.9 Locomotives and Marine Compression-Ignition Engines (No Change)

4.4 Emissions Summary (Updated)

4.5 Continued Maintenance with MOVES-Based On-Road Mobile Emissions Inventories 

(Added)

Chapter 5: Monitoring Network (No Change)

Chapter 6: Contingency Plan (No Change)
vii

LIST OF ACRONYMS

AutoGC automated gas chromatograph

BPA Beaumont-Port Arthur

EDMS Emissions and Dispersion Modeling System

EPA United States Environmental Protection Agency

FCAA Federal Clean Air Act

MOVES Motor Vehicle Emission Simulator model

MVEB motor vehicle emissions budget

NAAQS National Ambient Air Quality Standard

NOX nitrogen oxides 

ppb parts per billion

ppm parts per million

SIP state implementation plan

TACB Texas Air Control Board

TCAA Texas Clean Air Act

TCEQ Texas Commission on Environmental Quality (commission)

TDM Travel Demand Model

TexAER Texas Air Emissions Repository

TexN Texas-Specific NONROAD model

TNRCC Texas Natural Resource Conservation Commission

tpd tons per day

TTI Texas Transportation Institute

TxDOT Texas Department of Transportation

VOC volatile organic compounds
viii

LIST OF TABLES

Table 4-1: MOBILE-Based On-Road Mobile Source NOX and VOC Emissions in the BPA 

Area (2005, 2011, 2014, 2017, and 2021)

Table 4-2: Updated Summary of NOX Emissions in the BPA Area by Source Type (2005, 

2011, 2014, 2017, and 2021)

Table 4-3: Updated Summary of VOC Emissions in the BPA Area by Source Type (2005, 

2011, 2014, 2017, and 2021)

Table 4-4: Original Summary of Total NOX and VOC Emissions in the BPA Area

Table 4-5: Updated Summary of Total NOX and VOC Emissions in the BPA Area (2005, 

2011, 2014, 2017, and 2021)

Table 4-6: BPA Area Ozone Season Weekday On-Road Mobile Emissions Inventories

Table 4-7: 2021 Horizon Year MVEBs for the BPA area using MOVES2010a

Table 4-8: Updated Percentages of NOX Emissions in BPA by Source Category

Table 4-9: Updated Percentages of VOC Emissions in BPA by Source Category
ix

LIST OF FIGURES

Figure 2-1: Ozone Design Value Trends in the BPA Area

Figure 2-2: Ozone Design Values and Population Trends in the BPA Area

Figure 2-3: Ozone Exceedance Days and Number of Monitors in the BPA Area

Figure 2-4: Eight-Hour Ozone Exceedance Days by Monitor in the BPA Area

Figure 2-5: Average NOX Trends in the BPA Area

Figure 2-6: Median Ethylene at AutoGCs in the BPA Area

Figure 2-7: Median Propylene at AutoGCs in the BPA Area

Figure 2-8: Median Ethylene Trends from Canister Data in the BPA Area

Figure 2-9: Median Propylene Trends from Canister Data in the BPA Area
x 

LIST OF APPENDICES

Appendix Appendix Name

Appendix D BPA Area On-Road Emissions Inventories for SIP Submission - 2005, 

2011, 2014, 2017, and 2021, TTI Report, February 2012
1-1 

CHAPTER 1: GENERAL (UPDATED)

1.1 BACKGROUND AND INTRODUCTION (UPDATED)

1.1.1 Purpose of Plan (Updated)

In 2008, the commission adopted the Eight-Hour Ozone Redesignation Request and 

Maintenance Plan for the Beaumont-Port Arthur (BPA) Ozone Nonattainment Area (Project No. 

2008-006-SIP-NR), which fulfills all Federal Clean Air Act (FCAA) requirements to redesignate 

the BPA ozone nonattainment area (Hardin, Jefferson, and Orange Counties) to attainment of 

the 1997 eight-hour ozone standard and demonstrates continued attainment of that standard 

through 2021. The plan was approved by the United States Environmental Protection Agency 

(EPA), effective November 19, 2010, and the BPA area was redesignated to attainment for the 

1997 eight-hour ozone standard. The maintenance plan contains on-road mobile emissions 

inventories, a nitrogen oxides (NOX) motor vehicle emissions budget (MVEB), and a volatile 

organic compounds (VOC) MVEB developed using the EPA’s MOBILE emissions estimation 

model. On March 2, 2010, the EPA officially released a new model, the Motor Vehicle Emission 

Simulator (MOVES) model, to replace the MOBILE model for SIP applications.

Beginning March 2, 2013, transportation conformity must be conducted using the MOVES 

model. To demonstrate transportation conformity, a nonattainment or maintenance area must 

show that its metropolitan transportation plans, transportation improvement programs, and 

projects funded by the Federal Highway Administration or the Federal Transit Administration 

conform to the MVEBs established in the state implementation plan (SIP). Conformity must be 

demonstrated before area transportation plans can be approved or funded by the United States

Department of Transportation or the Metropolitan Planning Organizations. Updating MVEBs 

using MOVES-based on-road mobile emissions inventories requires a SIP revision. This 

proposed SIP revision would facilitate future MOVES-based transportation conformity 

determinations by providing MVEBs based on the latest version of the MOVES model, 

MOVES2010a. 

This proposed SIP revision would replace the 2008 BPA maintenance plan on-road mobile 

source emissions inventories for NOX and VOC based on the EPA’s MOBILE model with those 

based on the EPA’s MOVES model. On-road mobile source emissions inventory updates include 

those for 2005, 2011, 2014, 2017, and 2021. In addition, 2021 NOX and VOC MVEBs would be

updated according to the MOVES-based emissions inventories.

This proposed SIP revision includes documentation to satisfy the EPA’s MOVES 

implementation policy guidance2 concerning updating maintenance plans with MOVES, which 

indicates that states must (1) demonstrate that the updated plan continues to meet all 

maintenance requirements and (2) document that growth and control strategy assumptions for 

all other source categories (area, non-road mobile, and stationary point) continue to be valid 

and any minor updates would not change the conclusions of the approved maintenance plan.

 

2 EPA, 2009. “Policy Guidance on the Use of MOVES2010 for State Implementation Plan Development, 

Transportation Conformity, and Other Purposes.” Transportation and Regional Programs Division, Office 

of Transportation and Air Quality, U.S. Environmental Protection Agency, EPA-420-B-09-046, December 

2009. 
1-2 

1.1.2 One-Hour Ozone History in the BPA Area (No Change)

1.1.3 Eight-Hour Ozone History in the BPA Area (Updated)

1.1.3.1 2008 and 2010 Eight-Hour Ozone Standards (Added)

On March 12, 2008, the EPA lowered the primary and secondary eight-hour ozone standards to 

0.075 parts per million (ppm). The governor recommended to the EPA in March 2009 that 

Hardin, Jefferson, and Orange Counties be designated as a nonattainment area for the 2008 

eight-hour ozone standard. In September 2009, the EPA announced that it intended to 

reconsider the 2008 ozone standard. On January 19, 2010, the EPA proposed revisions in the 

Federal Register (75 FR 2938) to strengthen the primary eight-hour ozone standard in the 

range of 0.060 to 0.070 ppm. On September 2, 2011, the President announced a request that the 

EPA withdraw the proposed, reconsidered ozone standard.

In a September 2011 memo, the EPA announced that it would proceed with initial area 

designations under the 2008 (0.075 ppm) eight-hour ozone standard, starting with the 

recommendations states made in 2009 and updating those recommendations with the most 

current, certified air quality data (2008 through 2010). The governor submitted a revised 

designation recommendation in October 2011 that excluded Hardin, Jefferson, and Orange 

Counties from being designated as nonattainment under the reinstated 2008 eight-hour ozone 

standard.

The EPA published final designations for the 2008 ozone standard along with a final rulemaking 

to revoke transportation conformity under the 1997 eight-hour ozone standard on May 21, 2012. 

Since the BPA area is designated attainment/unclassifiable for the 2008 eight-hour ozone 

standard and is a maintenance area for the 1997 eight-hour ozone standard, transportation 

conformity will no longer be required upon the effective date of revocation of transportation 

conformity for the 1997 eight-hour ozone standard, July 20, 2013. 

1.2 PUBLIC HEARING INFORMATION (UPDATED)

The commission will offer a public hearing in Beaumont on August 1, 2012, at six o’clock in the 

evening. The public hearing will be held in the Homer E. Nagel Conference Room of the South

East Texas Regional Planning Commission at 2210 Eastex Freeway, Beaumont, Texas 77703.

The public comment period will open on June 29, 2012, and will close on August 3, 2012. Notice 

of public hearing for this SIP revision will be published in the Texas Register and the 

“Beaumont Enterprise” newspaper. Written comments will be accepted via mail, fax, or through 

the eComments system. All comments should reference the “Beaumont-Port Arthur Attainment 

Area On-Road Mobile Source Emissions Inventory and Motor Vehicle Emissions Budget Update 

State Implementation Plan Revision” and Project Number 2012-005-SIP-NR. Comments may 

be submitted to Jamie Zech, MC 206, State Implementation Plan Team, Chief Engineer’s Office, 

Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087 or 

faxed to (512) 239-6188. If you choose to submit electronic comments, they must be submitted 

through the eComments (http://www5.tceq.state.tx.us/rules/ecomments) system. File size 

restrictions may apply to comments being submitted via the eComments system. Comments 

must be received by August 3, 2012. 

1.3 SOCIAL AND ECONOMIC CONSIDERATION (NO CHANGE)

1.4 FISCAL AND MANPOWER RESOURCES (NO CHANGE)
2-1 

CHAPTER 2: REDESIGNATION REQUIREMENTS (UPDATED)

2.1 ATTAINMENT OF THE 1997 EIGHT-HOUR OZONE NATIONAL AMBIENT AIR 

QUALITY STANDARD (UPDATED)

2.1.1 Ozone Data (No Change)

2.1.2 Ozone Trend Analysis (Updated)

Ozone trends in the Beaumont-Port Arthur (BPA) area have been decreasing over the past 20

years. Figure 2-1: Ozone Design Value Trends in the BPA Area shows decreases in both the 

eight-hour and one-hour ozone design values. Although both the eight-hour and the one-hour 

design values increased from 2010 to 2011, the overall design value trend has been decreasing. 

The eight-hour ozone design value has decreased by 22% over the past 20 years and the onehour ozone design value had decreased by 27% over the past 20 years. The 2011 eight-hour 

ozone design value for the BPA area was 79 parts per billion (ppb), which is below the 1997 

eight-hour ozone standard of 84 ppb (0.08 parts per million (ppm)). The BPA area has not 

exceeded the eight-hour ozone standard since 2006. The 2011 one-hour ozone design value for 

the BPA area was 110 ppb, which is also below the revoked one-hour ozone standard of 125 ppb 

(0.12 ppm). The decreases in ozone have occurred despite increases in population in the BPA 

area, as shown in Figure 2-2: Ozone Design Values and Population Trends in the BPA Area. 

Figure 2-3: Ozone Exceedance Days and Number of Monitors in the BPA Area shows that the 

number of eight-hour ozone exceedance days has decreased in the BPA area despite an increase 

in the number of monitors. Although there were more eight-hour ozone exceedance days in 2011 

compared to 2010, the overall trend in exceedance days is decreasing. There were only four

eight-hour ozone exceedance days in the BPA area in 2011, an unusual year with recordbreaking temperatures and an unusual number of days that favored the development of ozone.

Because the exceedance day count is dependent on the number of monitors in the area, the 

number of eight-hour ozone exceedance days by monitor is shown in Figure 2-4: Eight-Hour 

Ozone Exceedance Days by Monitor in the BPA Area. Exceedances by monitor tend to vary 

from year to year; however, the overall trend in the number of eight-hour ozone exceedance days 

has been decreasing over the past 20 years.
2-2 

101 100 97 93 94 91 93 91 88 87 85

90 91 92 88 85 83 81

77 74

79

150

140

130

124

139 139 139

133 133

152

127

144

129 130 128 127

107 107

101 102

110

0

20

40

60

80

100

120

140

160

180

199119921993199419951996199719981999200020012002200320042005200620072008200920102011

ppb Ozone Design Values in the BPA Area

1997 Eight-Hour Ozone NAAQS: 84 ppb

2008 Eight-Hour Ozone NAAQS: 75 ppb *Design Values are from EPA's AQS.

One-Hour Ozone Design Values

Eight-Hour Ozone Design Values

Figure 2-1: Ozone Design Value Trends in the BPA Area

0

75

150

225

300

375

450

0

30

60

90

120

150

180

199119921993199419951996199719981999200020012002200320042005200620072008200920102011

ppb Thousands Ozone Design Values and Population in the BPA Area

Population

Eight-Hour Ozone Design Values

One-Hour Ozone Design Values

1997 Eight-Hour Ozone NAAQS: 84 ppb

2008 Eight-Hour Ozone NAAQS: 75 ppb

*Design Values are from EPA's AQS. 

**Population from US Census Bureau. 

Figure 2-2: Ozone Design Values and Population Trends in the BPA Area
2-3 

22

12

18

6

31

7

14

11

2

17

7

11

9

13

7

8

3 2 2 2

4

0

3

6

9

12

0

10

20

30

40

199119921993199419951996199719981999200020012002200320042005200620072008200920102011

Days Monitors

Ozone Exceedance Days and the Number of Monitors 

in the BPA Area

*Data from EPA's AQS.

Eight-Hour Ozone Exceedance Days

(1997 NAAQS)

Number of Monitors

Figure 2-3: Ozone Exceedance Days and Number of Monitors in the BPA Area

0

4

8

12

16

20

199119921993199419951996199719981999200020012002200320042005200620072008200920102011

Days

Eight-Hour Ozone Exceedance Days by Monitor in 

the BPA Area 

Kountze C85

Beaumont C2/C112/C2002

Port Arthur West C28/C128/C228

Jefferson Co. Airport C1019/C2001

Jefferson Co. Airport C1019/C2001- POC 2

Hamshire C64/C654

SETRPC 40 Sabine Pass C640/C1654

SETRPC43 Jefferson Co. Airport C643

SETRPC Port Arthur C628

Nederland High School C1035

West Orange C9/C141

SETRPC 42 Mauriceville C311/C642/C665

*Data from EPA'sAQS.

Figure 2-4: Eight-Hour Ozone Exceedance Days by Monitor in the BPA Area
2-4 

2.2 SIP APPROVABILITY UNDER SECTION 110(k) OF THE FEDERAL CLEAN AIR 

ACT (NO CHANGE)

2.3 PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS (UPDATED)

2.3.1 Control Strategies (No Change)

2.3.2 2002 Periodic Emissions Inventory (No Change)

2.3.3 Trend Analysis (Updated)

2.3.3.1 Nitrogen Oxides Trends (Updated)

Overall, nitrogen oxides (NOX) trends in the BPA area are decreasing. Figure 2-5: Average NOX

Trends in the BPA Area shows the NOX trends at five monitors in the BPA area: Beaumont 

Downtown (CAMS 2/CAMS 112/ CAMS 2002), Jefferson County Airport (CAMS 

1019/CAMS2001), Hamshire (CAMS 64/CAMS 654), Nederland High School (CAMS 1035), and 

West Orange (CAMS 9/CAMS141). Data for 2011 cover only the first two quarters of the year, 

and NOX averages during 2011 are subject to change. The average NOX concentration has 

remained relatively flat at most monitors until sometime from 2003 to 2006. After 2006, the 

last year the BPA area had an ozone design value exceed 84 ppb, most monitors showed a large 

decrease in NOX concentrations. West Orange (CAMS 9/CAMS141) did show a slight increase in 

average NOX concentrations from 2010 to 2011, but the overall trend from 1991 to 2011 shows a 

decrease of 54%. NOX decreased 26% from 1991 to 2011 at the Beaumont Downtown (CAMS 

2/CAMS 112/ CAMS 2002) site, 40% from 2000 to 2011 at the Hamshire (CAMS 64/CAMS 654)

site, and 50% from 2006 to 2011 at the Nederland High School (CAMS 1035) site. 

0

2

4

6

8

10

12

14

16

18

199119921993199419951996199719981999200020012002200320042005200620072008200920102011

ppb

Average NOX in the BPA Area

Beaumont Downtown C2/C112/C2002

Jefferson County Airport C1019/C2001

Hamshire C64/C654

Nederland High School C1035

West Orange C9/C141

*Data fromEPA's AQS. Only the first 

two quarters of 2011 data are available. 

Data is subject to change.

Figure 2-5: Average NOX Trends in the BPA Area
2-5 

Volatile Organic Compounds Trends (Updated) 

Continuous volatile organic compounds (VOC) data are collected at two automated gas 

chromatograph (AutoGC) monitors in the BPA area. Those two monitors are Beaumont 

Downtown (CAMS 2/CAMS 112/ CAMS 2002) and Nederland High School (CAMS 1035), which 

have valid data beginning August 28, 2006, and August 29, 2006, respectively, and ending on 

December 1, 2011. Note that the last month of data from 2011 is not yet available. Figures 2-6: 

Median Ethylene at AutoGCs in the BPA Area and 2-7: Median Propylene at AutoGCs in the 

BPA Area show the median ethylene and propylene concentrations at the two AutoGC monitors 

in the BPA area, respectively. Both ethylene and propylene have decreased at all monitors over 

the last five years. Ethylene decreased 55% at Beaumont Downtown (CAMS 2/CAMS 112/ CAMS 

2002) and 41% at Nederland High School (CAMS 1035). Propylene decreased 54% at Beaumont 

Downtown (CAMS 2/CAMS 112/ CAMS 2002) and 35% at Nederland High School (CAMS 

1035). 

1.82

1.25

1.40

1.09

0.98

0.81

1.40

1.00

1.19

0.82

0.75

0.82

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

2006 2007 2008 2009 2010 2011

ppb

Median Ethylene at AutoGCs in the BPA Area

*2011 Data incomplete and subject to change.

Beaumont Downtown C2/C112/C2005

NederlandHigh School C1038

Figure 2-6: Median Ethylene at AutoGCs in the BPA Area
2-6 

1.31

1.08

0.95

0.80

0.74

0.60

0.78

0.60 0.63

0.58

0.64

0.51

0

0.2

0.4

0.6

0.8

1

1.2

1.4

2006 2007 2008 2009 2010 2011

ppb

Median Propylene at AutoGCs in the BPA Area

*2011 Data incomplete and subject to change.

Beaumont Downtown C2/C112/C2005

NederlandHigh School C1038

Figure 2-7: Median Propylene at AutoGCs in the BPA Area

VOC canister data have also been available in the BPA area since 1994. The VOC canisters 

samples are 24-hour averages and are sampled every 6 days. Figures 2-8: Median Ethylene 

Trends from Canister Data in the BPA Area and 2-9: Median Propylene Trends from Canister 

Data in the BPA Area both show that ethylene and propylene, two of the most reactive VOC, 

have been decreasing at nine canister sites in the BPA area over the past 14 and 17 years, 

respectively. Only one quarter of data are available for 2011, so concentrations are subject to 

change. While the ethylene concentrations are generally higher than the propylene 

concentrations, the median ethylene concentrations have decreased at the nine canister sites 

(one of the eight sites has three monitors), with an average decrease of 41%. West Orange

(CAMS 9/CAMS141) and Beaumont Mary (CAMS 1050) both showed increases in ethylene; 

however, the West Orange (CAMS 9/CAMS141) canister site stopped operation in 2006, and the 

Beaumont Mary (CAMS 1050) site has only been in operation for two years. Similarly, median 

propylene concentrations have decreased at the nine canister sites, with an average decrease of 

42%. Again, the Beaumont Mary (CAMS 1050) site showed a slight increase in propylene 

concentrations, but it has only been in operation for two years. For both propylene and ethylene, 

the increase at Beaumont Mary (CAMS 1050) was less than 0.5 ppb.
2-7 

0

1

2

3

4

5

6

7

8

9

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

ppb

Median Ethylene from Canister Data in the BPA Area

Beaumont Downtown

Port Arthur West

Port Arthur West POC 00

Port Arthur West POC 01

Groves

Port Neches

Jefferson County Airport

City Service Center / PA

CARROLL STREET PARK

Beaumont Mary

West Orange

*Only first quarter of 2011 data available. 2011 

concentrations subject to chage.

Figure 2-8: Median Ethylene Trends from Canister Data in the BPA Area

0

0.5

1

1.5

2

2.5

3

3.5

4

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

ppb

Median Propylene from Canister Data in the BPA Area

Beaumont Downtown Port Arthur West

Port Arthur West POC 00 Port Arthur West POC 01

Groves Port Neches

Jefferson County Airport City Service Center / PA

CARROLL STREET PARK Beaumont Mary

West Orange

*Only first quarter of 2011 data available. 2011 

concentrations subject to chage.

Figure 2-9: Median Propylene Trends from Canister Data in the BPA Area
2-8 

2.4 SECTION 175A REQUIREMENTS FOR MAINTENANCE PLANS (NO CHANGE)
3-1 

CHAPTER 3: ATTAINMENT EMISSIONS INVENTORY (NO CHANGE)
4-1 

CHAPTER 4: MAINTENANCE DEMONSTRATION (UPDATED)

4.1 GENERAL (UPDATED)

This proposed state implementation plan (SIP) revision is an update to the 2008 BeaumontPort Arthur (BPA) maintenance plan that revises the original on-road mobile source emissions 

inventories, nitrogen oxides (NOX) motor vehicle emissions budget (MVEB), and volatile organic 

compounds (VOC) MVEB to be based on the United States Environmental Protection Agency’s 

(EPA) Motor Vehicle Emission Simulator (MOVES) model. The on-road mobile source 

emissions inventories and MVEBs adopted with the 2008 BPA maintenance plan, which was 

approved by the EPA effective November 19, 2010, were developed using the MOBILE emissions 

estimation model. On March 2, 2010, the EPA officially released the MOVES model to replace 

the MOBILE model for SIP applications. Beginning March 2, 2013, transportation conformity 

must be conducted using the MOVES model. This proposed update to the 2008 BPA 

maintenance plan would facilitate future, required, MOVES-based transportation conformity 

determinations.

The EPA provided a guidance document3 to assist states in incorporating MOVES-based onroad mobile source emissions inventories and MVEBs into existing area maintenance plans. The 

guidance allows states, under stipulated conditions, to update only the on-road mobile source 

portions of their maintenance plans. States must (1) demonstrate that the updated plan 

continues to meet all maintenance requirements and (2) document that growth and control 

strategy assumptions for all other source categories (area, non-road mobile, and stationary 

point) continue to be valid and any minor updates would not change the conclusions of the 

approved maintenance plan.

This proposed SIP revision satisfies both conditions of the MOVES guidance document; 

therefore, only Section 4.4.2: On-Road Mobile Sources has been revised. For each of the other 

source categories (area, non-road mobile, and stationary point), sections have been added

describing that any minor updates have not changed the conclusions of the 2008 BPA 

maintenance plan: Section 4.2.1.2: Updated Verification of Continued Attainment for Area 

Sources; Section 4.2.3.3: Updated Verification of Continued Attainment for Non-Road Mobile 

Sources; and Section 4.2.4.4: Updated Verification of Continued Attainment for Stationary 

Point Sources. 

4.2 FUTURE EMISSIONS AND VERIFICATION OF CONTINUED ATTAINMENT

(UPDATED)

MOVES-based on-road mobile source NOX and VOC emissions estimates would change slightly 

from the MOBILE-based estimates adopted with the 2008 BPA maintenance plan. Table 4-1: 

MOBILE-Based On-Road Mobile Source NOX and VOC Emissions in the BPA Area (2005, 2011, 

2014, 2017, and 2021) summarizes, in tons per day (tpd), the on-road mobile source emissions 

estimates (MOBILE-based) that were included in the original maintenance plan. Emissions 

estimates for area, non-road mobile, and stationary point sources were not included in Table 4-1 

because they were not updated from the 2008 BPA maintenance plan. MOVES-based NOX and 

VOC on-road mobile source emission estimates are summarized in Tables 4-2: Updated 

Summary of NOX Emissions in BPA by Source Type (2005, 2011, 2014, 2017, and 2021) and 4-

 

3 EPA, 2009. “Policy Guidance on the Use of MOVES2010 for State Implementation Plan Development, 

Transportation Conformity, and Other Purposes.” Transportation and Regional Programs Division, Office 

of Transportation and Air Quality, U.S. Environmental Protection Agency, EPA-420-B-09-046, December 

2009.
4-2 

3: Updated Summary of VOC Emissions in BPA by Source Type (2005, 2011, 2014, 2017, and 

2021) along with the original estimates for the other source categories (area, non-road mobile, 

and stationary point). Tables 4-2 and 4-3 show how this proposed update to the MOVES model 

would affect the projected overall emissions trends included in the 2008 BPA maintenance plan.

Table 4-1: MOBILE-Based On-Road Mobile Source NOX and VOC Emissions in the 

BPA Area (2005, 2011, 2014, 2017, and 2021)

Source Category 2005 2011 2014 2017 2021 Net 

Change

NOX 45.60 tpd 17.91 tpd 12.38 tpd 8.66 tpd 6.24 tpd -39.36 tpd

VOC 11.63 tpd 7.92 tpd 6.51 tpd 5.58 tpd 4.77 tpd -6.86 tpd

Note: The estimated emissions included in this table were extracted from Tables 4-1: Summary of VOC Emissions in 

BPA by Source Type (2005, 2011, 2014, 2017, and 2021) and 4-2: Summary of NOX Emissions in BPA by Source Type 

(2005, 2011, 2014, 2017, and 2021) of the 2008 BPA maintenance plan.

Table 4-2: Updated Summary of NOX Emissions in the BPA Area by Source Type 

(2005, 2011, 2014, 2017, and 2021)

Source Category 2005 2011 2014 2017 2021 Net 

Change

Area Source 9.06 tpd 9.95 tpd 10.40 tpd 10.86 tpd 11.47 tpd 2.41 tpd

MOVES-Based OnRoad Mobile 

Source

44.50 tpd 26.60 tpd 18.60 tpd 13.50 tpd 9.70 tpd -34.80 tpd

Non-Road Mobile 

Source 25.99 tpd 27.08 tpd 27.88 tpd 28.87 tpd 30.63 tpd 4.64 tpd

Stationary Point 

Source 68.49 tpd 79.17 tpd 81.14 tpd 83.04 tpd 85.44 tpd 16.95 tpd

Total 148.04 tpd 142.80 tpd 138.02 tpd 136.27 tpd 137.24 tpd -10.80 tpd

Table 4-3: Updated Summary of VOC Emissions in the BPA Area by Source Type 

(2005, 2011, 2014, 2017, and 2021)

Source Category 2005 2011 2014 2017 2021 Net 

Change

Area Source 151.57 tpd 155.68 tpd 156.84 tpd 158.40 tpd 160.54 tpd 8.97 tpd

MOVES-Based OnRoad Mobile 

Source

11.30 tpd 8.30 tpd 6.30 tpd 5.00 tpd 3.90 tpd -7.40 tpd

Non-Road Mobile 

Source 4.96 tpd 4.36 tpd 4.23 tpd 4.20 tpd 4.30 tpd -0.66 tpd

Stationary Point 

Source 42.68 tpd 48.26 tpd 49.83 tpd 51.54 tpd 53.95 tpd 11.27 tpd

Total 210.51 tpd 216.60 tpd 217.20 tpd 219.14 tpd 222.69 tpd 12.18 tpd
4-3 

The MOBILE-based on-road mobile source emissions estimates adopted with the 2008 BPA 

maintenance plan trend downward for both NOX and VOC, with a net decrease from 2005 

through 2021 of 39.36 tpd and 6.86 tpd, respectively. The MOVES-based on-road estimates also 

trend downward for both NOX and VOC, with a net decrease of 34.80 tpd and 7.40 tpd, 

respectively.

Tables 4-4: Original Summary of Total NOX and VOC Emissions in the BPA Area and 4-5: 

Updated Summary of Total NOX and VOC Emissions in BPA (2005, 2011, 2014, 2017, and 

2021) depict combined total NOX and VOC base and projection values. Table 4-4 is from the 

2008 maintenance plan, containing MOBILE-based on-road mobile source emissions estimates. 

Table 4-5 shows how this proposed MOVES update would affect total NOX and VOC emissions 

projections in the BPA area.

Table 4-4: Original Summary of Total NOX and VOC Emissions in the BPA Area

Pollutant (tons per 

average ozone 

season day)

2005 2011 2014 2017 2021 Net 

Change

Total NOX 149.14 tpd 134.11 tpd 131.80 tpd 131.43 tpd 133.78 tpd -15.36 tpd

Total VOC 210.84 tpd 216.22 tpd 217.41 tpd 219.72 tpd 223.56 tpd 12.72 tpd

Total Combined 359.98 tpd 350.33 tpd 349.21 tpd 351.15 tpd 357.34 tpd -2.64 tpd

This table is a copy of Table 4-3: Summary of Total VOC and NOX Emissions in BPA (2005, 2011, 2014, 2017, and 

2021) of the 2008 BPA maintenance plan.

Table 4-5: Updated Summary of Total NOX and VOC Emissions in the BPA Area 

(2005, 2011, 2014, 2017, and 2021)

Pollutant (tons per 

average ozone 

season day)

2005 2011 2014 2017 2021 Net 

Change

Total NOX 148.04 tpd 142.80 tpd 138.02 tpd 136.27 tpd 137.24 tpd -10.80 tpd

Total VOC 210.51 tpd 216.60 tpd 217.20 tpd 219.14 tpd 222.69 tpd 12.18 tpd

Total Combined 358.55 tpd 359.40 tpd 355.22 tpd 355.41 tpd 359.93 tpd 1.38 tpd

The 2008 BPA maintenance plan demonstrates that overall NOX emissions are projected to 

decline by 15.36 tpd from 2005 through 2021 using MOBILE-based on-road emissions 

estimates. Updating the BPA maintenance plan to incorporate the MOVES model would still 

result in a decline in projected NOX emissions; however, the decline would be slightly smaller, 

10.80 tpd. The original maintenance plan (MOBILE-based) demonstrated an increase in overall 

VOC emissions projections from 2005 through 2021, 12.72 tpd. While MOVES-based 

projections also show an increase in overall VOC emissions, that increase is smaller, 12.18 tpd.

Although there is a slight estimated increase in VOC over the 16 years projected for the BPA 

maintenance plan, it has been established that NOX emissions reductions are more effective 

than VOC reductions at reducing ozone design values in the BPA area. In fact, photochemical 

modeling analysis adopted with the 2008 BPA maintenance plan showed that reductions in NOX

emissions are 3.76 times as effective as VOC reductions at reducing the BPA-area ozone design 

value. In its proposed approval of the 2008 plan in the Federal Register (75 FR 27514), the EPA 

supported the 2008 demonstration by stating that “based on photochemical modeling analyses 

showing that the formation of ozone in the BPA area is more sensitive to NOX than to VOC 

emissions, the increase in VOC emissions is expected to be fully offset by the decrease in NOX.” 
4-4 

Based on the photochemical modeling analysis included in the original 2008 BPA maintenance 

plan and supported by the EPA, emissions in the BPA area are expected to remain at levels 

consistent with attainment for the 1997 eight-hour ozone standard through 2021. Please see 

Section 4.2: Future Emissions and Verification of Continued Attainment of the original 2008 

BPA maintenance plan for further details on the photochemical modeling analysis 

demonstrating the effectiveness of NOX in reducing ozone design values in the BPA area.

4.2.1 Area Sources (Updated)

4.2.1.1 Flash Emissions from Upstream Oil and Gas Production (No Change)

4.2.1.2 Updated Verification of Continued Attainment for Area Sources (Added)

In reviewing the 2008 BPA maintenance plan and applying updates, staff determined that 

emissions would be further decreased for both NOX and VOC. There are two factors attributed to 

these reductions: updated growth factors provided by the Eastern Research Group through a 

contract in 2010;

4 and speciation updates performed on the oil and gas categories for 2005. 

Although minor updates have occurred in the area source category since the 2008 submission, 

those updates do not change the overall conclusions of the BPA maintenance plan SIP revision.

4.2.2 On-Road Mobile Sources (Updated)

The Texas Commission on Environmental Quality (TCEQ) updated the 2008 BPA maintenance 

plan’s on-road mobile source emissions inventory estimates for this proposed SIP revision by 

contracting with the Texas Transportation Institute (TTI). TTI developed detailed, hourly, linkbased ozone season weekday emissions estimates for the three BPA counties, Jefferson, Hardin, 

and Orange, using the newest version of the EPA’s MOVES model, MOVES2010a. The updated 

emissions inventory estimates include NOX and VOC emissions for the 2005 base year for the 

2011, 2014, and 2017 interim years and for the 2021 horizon year. TTI also used the latest 

planning assumptions to develop the maintenance inventories in an effort to ensure that the 

MVEBs would be consistent with transportation conformity analysis assumptions.

TTI produced emissions estimates using a link-based methodology that used a travel demand 

model (TDM) and MOVES “rates-per-activity.” Emissions were estimated by hourly and 24-

hour periods by MOVES source use type and fuel type, pollutant process, and TDM roadway 

class. The most recently available data were used, including Texas Department of 

Transportation (TxDOT) vehicle classification counts and TxDOT/Texas Department of Motor 

Vehicles registration data. MOVES default data were used as needed. Control programs that 

were modeled in the analysis include: 

• Federal Motor Vehicle Control Program Standards; 

• Federal Low Emissions Heavy-Duty Diesel Engines Rebuild Program; 

• Federal Heavy-Duty 2004 Pull-Ahead Program; 

• Conventional Gasoline with Federal Low Reid Vapor Pressure; and

• Diesel Fuel with Texas Low Emission Diesel as appropriate for applicable years. 

For the fuel programs, MOVES defaults, fuel survey data, and federally regulated values were 

used. Details of how these were modeled are found in Appendix D: BPA Area On-Road 

Emissions Inventories for SIP Submission - 2005, 2011, 2014, 2017, and 2021, TTI Report, 

 

4 Eastern Research Group, Inc., “Projection Factors for Point and Area Source,” TCEQ Contract No. 582-

07-84003, Work Order No. 582-07-84003-FY10-27, August 2010.
4-5 

February 2012. The emissions inventory development methodology is consistent with the 

MOVES guidance document provided by the EPA. Table 4-6: BPA Area Ozone Season Weekday 

On-Road Mobile Emissions Inventories summarizes the updated 2005, 2011, 2014, 2017, and 

2021 NOX and VOC emissions calculated using the latest planning assumptions for the threecounty BPA area. Detailed documentation is provided in Appendix D concerning MVEB 

calculations, modeling methods, and input parameter development and usage. 

Table 4-6: BPA Area Ozone Season Weekday On-Road Mobile Emissions 

Inventories

Year VMT Summer Weekday OnRoad VOC Emissions

Summer Weekday OnRoad NOX Emissions

2005 12,766,328 11.30 tpd 44.50 tpd

2011 13,221,528 8.30 tpd 26.60 tpd

2014 13,691,363 6.30 tpd 18.60 tpd

2017 14,178,111 5.00 tpd 13.50 tpd

2021 14,854,487 3.90 tpd 9.70 tpd

4.2.2.1 Motor Vehicle Emissions Budgets (Updated)

The 2008 BPA maintenance plan established MOBILE-based MVEBs, setting the allowable onroad mobile emissions that an area can produce while continuing to demonstrate maintenance. 

Local transportation planning organizations demonstrate that projected emissions from 

transportation plans, programs, and projects are equal to or less than the MVEBs as required by 

the federal transportation conformity rule. The NOX and VOC on-road mobile source emissions 

inventory totals for 2021, the final year of this maintenance plan, establish the MVEBs. The 

MOVES-based MVEBs for this proposed SIP revision are summarized in Table 4-7: 2021 

Horizon Year MVEBs for the BPA area using MOVES2010a. Detailed documentation of MVEB 

calculations, modeling methods, and input parameter development and usage is provided in 

Appendix D.

Table 4-7: 2021 Horizon Year MVEBs for the BPA area using MOVES2010a

Calendar Year VOC MVEB NOX MVEB

2021 3.9 tpd 9.7 tpd

4.2.2.2 Safety Margin (Updated)

No safety margin is included in the revised, MOVES-based MVEBs included in this proposed 

SIP revision. 

4.2.3 Non-Road Mobile Sources (Updated)

4.2.3.1 Airports (No Change)

4.2.3.2 Locomotives and Marine Vessels (No Change)

4.2.3.3 Updated Verification of Continued Attainment for Non-Road Mobile Sources (Added)

NONROAD Model

For all Texas non-road mobile source categories except aircraft, airport equipment, locomotives, 

and commercial marine vessels, emissions are calculated using the Texas-Specific NONROAD 
4-6 

(TexN) model that utilizes the EPA’s latest NONROAD model. While the TexN model utilizes 

input files and post-processing routines to estimate Texas specific emissions estimates, it retains 

the EPA’s NONROAD model as the core model to conduct the basic emissions calculations.

The EPA’s NONROAD2005 model, which was used as the core model for the 2008 BPA 

maintenance plan, was updated to the NONROAD2008a version in April 2009. The 

NONROAD2008a model accounted for the addition of two new federal rules that affect the 

equipment categories in the non-road mobile source sector; therefore, the TexN model was 

updated accordingly. In addition, equipment survey studies have been conducted and emissions 

updated for the diesel construction equipment sector, the agricultural equipment sector, and 

drilling rig diesel engines since 2009. 

Using current methodology and the TexN/EPA NONROAD2008a model, emissions calculated 

for each county in the BPA area are, overall, lower and demonstrate a downward trend for both 

NOX and VOC compared to the emissions reported in the 2008 BPA maintenance plan. 

Although minor updates have occurred in the non-road mobile source category since the 2008 

submission, those updates do not change the overall conclusions of the BPA maintenance plan. 

Airports

The Federal Aviation Administration’s Emissions and Dispersion Modeling System (EDMS) 

version 5.1 was used to estimate NOX and VOC emissions for commercial aircraft, general 

aviation, and ground support equipment emissions in the 2008 BPA maintenance plan. The 

model has not changed since the 2008 submission, and the repopulated EDMS files, which 

reflect 2011 operations, indicate that both NOX and VOC emissions declined between 2005 and 

2011.

The 2011 emissions calculated for the airports source category in the BPA area demonstrate a 

downward trend for both NOX and VOC compared to the emissions reported in the 2008 BPA 

maintenance plan. Although minor updates have occurred in the airports source category since 

the 2008 submission, those updates do not change the overall conclusions of the BPA 

maintenance plan.

Locomotives and Commercial Marine Vessels

Texas Air Emissions Repository (TexAER) data from 2005, which was developed from the 2005 

Consolidated Emissions Reporting Rule data, were used to estimate NOX and VOC emissions 

from locomotive and commercial marine vessel activities in the 2008 BPA maintenance plan. 

The methodology has not changed since the 2008 submission.

Actual 2011 emissions calculated for locomotive and commercial marine vessel activities in the 

BPA area, when compared to the projected 2011 emissions reported in the 2008 BPA 

maintenance plan, are lower and demonstrate a downward trend for both NOX and VOC. Since 

the original inventories conservatively estimated future year locomotive and commercial marine 

vessel activities emissions, recalculation of the milestone year inventories would not change the 

overall conclusions of the 2008 BPA maintenance plan.
4-7 

4.2.4 Stationary Point Sources (Updated)

4.2.4.1 Emissions Inventory Compilation (No Change)

4.2.4.2 Updated 2005 Base Year Inventory (No Change)

4.2.4.3 Updated Uncontrolled Milestone Year Inventories (No Change)

4.2.4.4 Updated Verification of Continued Attainment for Stationary Point Sources (Added)

There have been no changes to the point source emissions inventories included in the 2008 BPA 

maintenance plan. Those inventories projected positive point source emissions growth for all 

future milestone years. Actual point source emissions for 2008 through 2010 are below the 

2005 base year emissions, below emissions trends projected in the maintenance plan, and are 

anticipated to remain below projected emissions. Since the original inventories conservatively 

estimated future year point source emissions, recalculation of the milestone year inventories 

would not change the overall conclusions of the 2008 BPA maintenance plan.

4.3 CONTROL STRATEGIES (NO CHANGE)

4.4 EMISSIONS SUMMARY (UPDATED)

Updated percentages of emissions by source category for 2005, 2011, 2014, 2017, and 2021 are 

reflected in Tables 4-8: Updated Percentages of NOX Emissions in BPA by Source Category and 

4-9: Updated Percentages of VOCEmissions in BPA by Source Category. The percentages of 

contribution from source categories have changed slightly with the MOVES-based on-road 

mobile source emissions inventory updates. Table 4-8 shows that on-road mobile source 

emissions determined using the MOVES model account for a slightly larger percentage of NOX

emissions, overall, than those determined using the MOBILE model. Table 4-9 shows that onroad mobile source emissions determined using the MOVES model account for a slightly smaller 

percentage of VOC emissions, overall, than those determined using the MOBILE model. As in 

the 2008 BPA maintenance plan, these tables show that the largest man-made contribution of 

NOX is from stationary point sources and the largest man-made contribution of VOC is from 

area sources. Contributions from biogenic emissions are not included in the summary, because 

the maintenance measures are limited to the reduction of man-made emissions.

Table 4-8: Updated Percentages of NOX Emissions in BPA by Source Category

Source Category 2005 2011 2014 2017 2021

Area Source 6.12% 6.97% 7.54% 7.97% 8.36%

MOVES-Based 

On-Road Mobile 

Source

30.06% 18.63% 13.48% 9.91% 7.07%

Non-Road Mobile 

Source 17.56% 18.96% 20.20% 21.19% 22.32%

Stationary Point 

Source 46.26% 55.44% 58.79% 60.94% 62.26%

Table 4-9: Updated Percentages of VOC Emissions in BPA by Source Category

Source Category 2005 2011 2014 2017 2021

Area Source 72.00% 71.87% 72.21% 72.28% 72.09%

MOVES-Based 

On-Road Mobile 

Source

5.37% 3.83% 2.90% 2.28% 1.75%
4-8 

Source Category 2005 2011 2014 2017 2021

Non-Road Mobile 

Source 2.36% 2.01% 1.95% 1.92% 1.93%

Stationary Point 

Source 20.27% 22.28% 22.94% 23.52% 24.23%

4.5 CONTINUED MAINTENANCE WITH MOVES-BASED ON-ROAD MOBILE 

EMISSIONS INVENTORIES (ADDED)

Revising the on-road mobile source emissions inventories and MVEBs for this proposed SIP 

revision would minimally affect projected NOX and VOC emissions trends from the 2005 base 

year across the 2011, 2014, and 2017 milestone years and the 2021 horizon year; however, NOX

emissions are still projected to decrease and VOC emissions are still projected to increase (see 

Tables 4-2 and 4-3). On-road mobile source emissions inventories were the only inventories 

updated; however, in determining whether to update inventories for the other source categories, 

TCEQ staff found that area, non-road mobile, and stationary point source emissions all trended

below the projections included in the 2008 BPA maintenance plan. In addition, photochemical 

modeling analyses adopted with the 2008 BPA maintenance plan and supported by the EPA 

demonstrate that the formation of ozone in the BPA area is more sensitive to NOX than to VOC 

emissions. The slight increase in VOC emissions, which was shown in the original BPA 

maintenance plan as well as this proposed update, would be offset by the decrease in NOX

emissions. Those factors, along with the overall downward trend in ozone design values for the 

BPA area, show that this proposed SIP revision would continue to meet all requirements for 

maintenance of the 1997 eight-hour ozone standard. 
5-1 

CHAPTER 5: MONITORING NETWORK (NO CHANGE)
6-1 

CHAPTER 6: CONTINGENCY PLAN (NO CHANGE)
Appendix Available Upon Request

Jamie Zech

jamie.zech@tceq.texas.gov

512.239.3935