# Clean Air Act Section 110(l) Non

Interference Demonstration to Support the Gasoline Reid Vapor Pressure (RVP) Standard Relaxation in Gaston and Mecklenburg Counties

for



# The Charlotte

- Gastonia

- Salisbury, NC 2008 8

- Hour Ozone Maintenance Area

Prepared by North Carolina Department of Environment and Natural Resources

Division of Air Quality

April 16 , 201 5(This page intentionally left blank)Non

- Interference Demonstration to Support i

Gaso line Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties 

## Table of Contents

1.0 OVERVIEW

................................ ................................ ................................ ............................ 1
2.0 REQUEST FOR A U NIFORM REID VAPOR PR ESSURE STANDARD IN T HE CHARLOTTE OZONE MAIN TENANCE/MARGINAL NON ATTAINMENT AREA

............. 2

2.1 CUR RENT EPA

- APPROVED MAINTENANCE PLAN

................................ ................... 3

3.0 NON

- INTERFERENCE DEMONST RATION

................................ ................................ ....... 4

3.1 EMISSIONS INVENTORIES

................................ ................................ .............................. 4
3.2 OZONE SENSITIVITY IN NORTH CAROLINA

................................ ............................ 16
3.3 NON

- INTERFERENCE WITH OZONE NAAQS

................................ ............................ 16
3. 4 NON

- INTERFERENCE WITH THE NAAQS FOR CARBON MONOXIDE,
PARTICULATE MATTER, SULFUR DIOXIDE, AND NITROGEN DIOXIDE

.................. 18

4.0 CONCLUSIONS

................................ ................................ ................................ .................... 20

5.0 REVISED SECTION S

................................ ................................ ................................ ........... 21



## List of Tables
Table 3.1 Point Source NOx Emissions (tons/day)

................................ ................................ ....... 6

Tab le 3.2 Point Source VOC Emissions (tons/day)

................................ ................................ ....... 7 Table 3.3 Area Source NOx Emissions (tons/day)

................................ ................................ ........ 8

Table 3.4 Area Source VOC Emi ssions (tons/day)

................................ ................................ ....... 9

Table 3.5 On

- road Mobile Source NOx Emissions (tons/day)

................................ .................... 10

Table 3.6 On

- road Mobile Source VOC Emissions (tons/day)

................................ ................... 11 Table 3.7 Nonroad Mobile Source NOx Emissions (tons/day)

................................ ................... 12
Table 3.8 Nonroad Mobile Source VOC Emissions (tons/ day)

................................ ................... 13 Table 3.9 Total Anthropogenic NOx Emissions (tons/day)

................................ ......................... 14 Table 3.10 Total Anthropogenic VOC Emissions (tons/day)

................................ ...................... 15

Table 3.11 Maintenance Demonstration for North Carolina Portion of the Charlotte Nonattainment Area

................................ ................................ ................................ ...... 17 Table 3.12 Safety Margin for North Carolina Portion of the Charlotte Nonattainment Area

..... 17Non

- Interference Demonstration to Support 1

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties 1.0 OVERVIEW

In addition to requesting the Charlotte marginal nonattainment area be redesignated as attaining
the 2008 8

- hour ozone National Ambient Ai r Quality Standard ( NAAQS ) , the North Carolina Division of Air Quality (DAQ) is requesting a relaxation of the federal summertime Reid vapor pressure (RVP) gasoline standard for Mecklenburg and Gaston Counties from 7.8 to 9.0 pounds per square inch (psi). The lower RVP requirement is effective in these two counties from June 1 through September 15 each year. This request is a stand

- alone analysis separate from the “Redesignation Demonstration and Maintenance Plan for the Charlotte

- Gastonia

- Salisbury,
Nort h Carolina 2008 8

- Hour Ozone Marginal Nonattainment Area” State Implementation Plan (SIP).

The DAQ has examined both the man

- made and natural sources of volatile organic compound (VOC) emissions and their contribution to ozone formation in North Carolina . B ecause of the generally warm and moist climate of North Carolina, vegetation abounds in many forms, and forested lands naturally cover much of the state. As a result, the biogenic sector is the most
abundant source of VOCs in North Carolina and accoun ts for approximately 90% of the total
VOC emissions statewide. The overwhelming abundance of biogenic VOCs makes the majority
of North Carolina a nitrogen oxide (NOx) limited environment for the formation of ozone. Since
reductions in man

- made VOC emissi ons do not reduce ozone levels, having a lower RVP
standard during the summer months is not an effective control measure for ozone. In addition, it results in higher fuel costs, which places additional cost s on businesses and consumers.

O ur analysis con ducted to support the non

- interference demonstration under Section 110(l) of the Clean Air Act (CAA) indicates that increasing the RVP from 7.8 to 9.0 psi in Gaston and Mecklenburg Counties would not negatively impact the redesignation demonstration and

ma intenance plan for the Charlotte area

. The emissions inventory comparison between the 7.8 and 9.0 psi RVP standards indicates that the estimated future year emissions are slightly higher
for NOx and VOC. By 2026, relaxing the RVP standard is estimated to increase emissions by only 0.01 ton/day of NOx and 0.32 ton/day of VOC from all man

- made emissions sources. This is equivalent to a 0.01% and 0.32 % increase in total man

- made emissions of NOx and VOC, respectively. When biogenic VOC emissions from natur al sources (average of 183.9 0 tons/day from April through October using the EPA’s 2011 National Emissions Inventory) are added to
the man

- made emissions ( 100.46 tons/day), the actual VOC emissions increase is only 0.11% (0.32/28 4. 36 tons/day x 100).Non

- Interference Demonstration to Support 2

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties De spite this small increase, the safety margin for the Charlotte maintenance area remains relatively unchanged. F rom 20 14 through 2026, under the current RVP standard of 7.8 psi, summer day NOx emissions decrease by 62.64 tons/day and VOC emissions decrease by 1 2

. 66

tons /da y which demonstrates that relaxing the RVP standard in Gaston and Mecklenburg
Counties will not interfere with maint ain in g the overall downward trend in the emissions for the
Charlotte area . The DAQ believes these small increases are with in the uncertainty of the emissions inventory modeling analyse s.

The DAQ concludes that relaxation of the federal RVP standard would not interfere with the attainment and maintenance of the NAAQS. The DAQ has developed a contingency plan based
on a numb er of triggers and tracking mechanisms that will ensure that the Charlotte
nonattainment area continues to maintain compliance with the 2008 8

- hour ozone NAAQS. In addition, based on the DAQ’ s re view of emissions and ambient monitoring data, it is very

un likely that relaxing the RVP standard in Gaston and Mecklenburg Counties will result in a
violation of the NAAQS for carbon monoxide ( CO )

, sulfur dioxide ( SO 2 )

, nitrogen dioxide (NO 2 ), and particulate matter with an aerodynamic diameter less than 2.5 micro meters (PM 2.5 )

. Therefore, with this submission, the DAQ believes the requirements of the C A A Section 110(1)
have been met.

2

. 0 REQUEST FOR A UNIFORM REID VAPOR PRESSURE STANDARD IN THE
CHARLOTTE OZONE MAINTENANCE/ MARGINAL NON ATTAINMENT AREA

The RVP is a federal control measure intended to lower air emissions of VOC s , a precursor to
ozone formation. In the mid

- to

- late 1 990s, the discovery that a significant amount of VOC emissions comes from natural sources began to change the understanding of the atmo spheric chemistry , particularly in the S outheastern United States. Statewide, natural sources account for
90 % of total VOC emissions. Today, we know that controlling ozone throughout North Carolina
and much of the S outheast is more effectively done throu gh emissions reductions of NOx. With this scientific understanding in mind, the DAQ is requesting the relaxation of the 7.8 psi RVP requirement in Gaston and Mecklenburg C ounties.

This analysis shows that North Carolina can implement the 9.0 psi gasolin e standard without interfering with the attainment of the NAAQS. The DAQ’s analysis indicates that i ncreasing the RVP from 7.8 to 9.0 psi would not negatively impact the redesignation request and maintenance plan . Therefore, the DAQ requests that the U.S . Environmental Protection Agency ( EPA ) relax the 7.8 psi RVP requirement and specify 9.0 psi as the applicable gasoline volatility standard for the entire maintenance area year round. This action would provide significant economic relief toNon

- Interference Demonstration to Support 3

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties North Carolin a consumers and businesses because it will (1) provide for a uniform gasoline

sta ndard throughout North Carolina, (2) lower summertime (June 1

– Sept. 15) gasoline prices at the pump for consumers and (3) simplify the gasoline distribution process for fuel distributors while not impacting the state’s ability to maintain the 2008 ozone standard or any of the other NAAQs

.

2

. 1 CURRENT EPA

- APPROVED MAINTENANCE PLAN

Section 110(a)(1) of the CAA requires that each state adopt and submit to the EPA a plan which provides for implementation, maintenance and enforcement of primary and secondary standards
for all areas within the state. The EPA stated that a 110(a)(1) maintenance plan is required for those areas that are designated as attainment/unclassifiable for the 2008 8

- hour ozone standard and are designated as attainment for the 1997 8

- hour and 1979 1

- hour ozone standard s with an approved maintenance plan. The three fundamental building blocks to this plan are:

 A foundatio n control program that contains all of the necessary federal and state control
measures to maintain the 2008 8

- hour ozone standard.

 A maintenance demonstration which shows the projected decreases in ozone

- precursor emissions from all sectors (e.g., point, area, on

- road and nonroad) from th e effective start through the last year of the plan (i.e., 2014 through 202 6 ) . The demonstration shows that NOx and VOC emissions are expected to decrease substantially during this time : NOx emissions are expected to decrease by 62.64 tons / day and VOC em issions are expected to decrease by 1 2.66 tons / day from 2014 through 2026

.

 A contingency plan which details actions that will be taken should the design value of any monitor within the maintenance area violate the 2008 8

- hour standard.

The EPA

- approved mai ntenance plan for the Charlotte marginal nonattainment area will be the document to which the proposed relaxation of the gasoline RV P standard will be made. Th e
propos ed and related revisions to the maintenance plan are described herein.Non

- Interference Demonstration to Support 4

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties 3 .0 NON

- INTER FERENCE DEMONSTRATION

3 .1 EMISSIONS INVENTORIES

The 110(a)(1) maintenance plan requires the development of an attainment inventory and a future year inventory for VOC and NOx emissions for those areas that must maintain the 2 008 8

- hour ozone NAAQS . The C harlotte 8

- hour ozone maintenance area ; consisting all of Mecklenburg County and a part of Gaston, Cabarrus, Lincoln, Rowan, Union and Iredell
Count ies ; meets the 110(a)(1) maintenance plan conditions as follows:

 The attainment inventory year must be one of the three years on which the 8

- hour ozone attainment designation was based. The base year of 201 4 was chosen since it is a year that falls within the attaining design value period of 20 12

- 201 4

.

 The future inventory year is at least 10 years after th e date that the EPA approves the redesignation request and maintenance plan. For this reason, 2026 was selected as the last year of the future inventory year is 202 6

.

 Finally, to be consistent with the EPA guidance , emissions inventories were prepared f or the interim years of 2015, 2018 and 2022 that demonstrate a consistent, downward trend
in emissions.

The emissions inventories are comprised of four major types of sources: point, area, on

- road and nonroad. The projected emissions inventories have b een estimated using projected rates of growth in population, traffic, economic activity, and other parameters. Naturally occurring, or biogenic, emissions are not included in the emissions inventory comparison, as these emi ssions
are outside the s tate’s s pan of control.

Relaxation of the RVP standard for Gaston and Mecklenburg Counties results in a slight increase
in NOx and VOC emissions for on

- road sources, and a slight increase in VOC emissions for
nonroad and area sources. The remainder of this sect ion provides a summary of the results. Appendix B to the redesignation request and maintenance plan SIP provides a detailed discussion on how the base and future year emission inventories were developed for each source
category . For the applicable source categories, Appendix B presents emissions for Gaston and Mecklenburg Counties for the current summertime RVP standard of 7.8 psi and emissions for a
9.0 psi standard

.Non

- Interference Demonstration to Support 5

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties For point sources, Table 3 .1 and Table 3 .2 provide a summary of NOx and VOC emissions with the current 7.8 psi and proposed 9.0 psi gasoline standard, respectively. The table also shows a comparison of emissions associated with the two standards in terms of net absolute di ff erence and percent change. No changes to point source emissions o ccur due to the relaxation of the RVP standard because the gasoline standard would not affect the air pollution sources reported in the point source inventory.

For area sources, relaxation of the RVP standard only affects VOC emissions associated with th e gasoline service station unloading

- stage I controls source category. A summary of the area source NOx and VOC emissions is presented in Table 3.3 and Table 3.4, respectively. Total area source VOC emissions are estimated to increase by 0.04 to 0.05 t on/day depending on the year.

A summary of the on

- road mobile source NOx and VOC emissions is presented in Table 3.5 and Table 3.6, respectively. The MOVES2014 model estimates a NOx increase of 0.11 ton/day and VOC increase of 0.18 ton/day in year 2015 due to RVP relaxation. For 2026, MOVES2014 model estimates a NOx increase of 0.01 ton/day and VOC increase of 0.04 ton/day due to RVP relaxation. The net change in emissions associated with the RVP relaxation decline from 2015 through 2026 because of the benefits of the RVP standard on cleaner vehicle fleets is less than those for older fleets. Note that the DAQ is uncertain of the technical reason behind the model

predicted NOx emissions increases associated with relaxing the RVP standard for a given ye ar. A discussion of the dependency between NOx emissions changes and gasoline RVP was not found in the model documentation, and a specific correlation equation could not be identified.
For detailed discussion on how the on

- road mobile emission inventory was developed, see Appendix B.3.

A summary of the nonroad mobile source NOx and VOC emissions is presented in Table 3.7 and Table 3.8, respectively. The relaxation of the RVP standard only affects VOC emissions from
nonroad mobile sources as shown in t he Table 3.8. The EPA ’s nonroad model estimates a VOC increase of 0.20 ton/day in 2015 and 0 .2 4 ton/day in 2026 due to RVP relaxation. The nonroad model estimates no increase in NOx emissions from 2015 through 2026.

The sum totals of the man

- made emiss ions for the North Carolina portion of the Charlotte
nonattainment area are tabulated in Table 3 .9 and Table 3 .10

. Overall, total NOx emissions are estimated to increase by 0.11 ton/day in 2015 and 0.01 ton/day in 2026. For VOC , total
emissions are esti mated to increase by 0. 42 ton/day in 2015 and 0.32 ton/day in 20 26 due to RVP
relaxation. As explained later in Sections 3.2 through 3.4 of this analysis , these increases are not expected to impact ozone levels in the Charlotte area.Non

- Interference Demonstration to Support 6

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 1 Point Source NOx Emissions (tons/day)

County Current 7.8 psi RVP

2014 2015 2018 2022 2026 Cabarrus 1 1.72 1.80 1.94 2.07 2.20
Gaston 1, 2 16.50 17.25 10.72 16.16 5.29
Iredell 1 2.02 2.03 2.04 2.04 2.05
Lincoln 1 0.18 0.84 0.95 1.20 0 .73 Mecklenburg 2 8.56 8.77 9.46 10.45 12.00
Rowan 1 2.80 3.16 3.51 3.71 3.76
Union 1 0.59 0.62 0.66 0.70 0.72
Total 32.38 34.47 29.28 36.33 26.7 5 Proposed 9.0 psi RVP 2015 201 8 20 22 202 6 Cabarrus 1 1.80 1.94 2.07 2.20
Gaston 1, 2 17.25 10.72 1 6.16 5.29
Iredell 1 2.03 2.04 2.04 2.05
Lincoln 1 0.84 0.95 1.20 0.73 Mecklenburg 2 8.77 9.46 10.45 12.00
Rowan 1 3.16 3.51 3.71 3.76
Union 1 0.62 0.66 0.70 0.72
Total 34.47 29.28 36.33 26.7 5

Net Change in ton/day emissions 0.00 0 .00 0.00 0.00 % Change in ton/day emissions 0.00% 0.00% 0.00% 0.00%

1 Emissions for portion of county included in nonattainment area.

2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these t wo counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 7

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 2 Point Source VOC Emissions (tons/day)

County Current 7.8 psi RVP

2014 2015 2018 2022 2026 Cabarrus 1 0.99 1.03 1.15 1.17 1.24
Gaston 1, 2 1.82 1.90 2.06 2.16 2.22
Iredell 1 0.68 0.68 0.69 0.69 0.69
Lincoln 1 1.50 1.54 1.72 1.83 1.94 Mecklenburg 2 3.36 3.45 3.73 4.02 4.36
Rowan 1 2.30 2.40 2.70 2.85 3.14
Union 1 1.38 1.42 1.57 1.64 1.74
Total 12.03 12.42 13.6 2 14.36 15.33 Proposed 9.0 ps i RVP 2015 201 8 20 22 202 6 Cabarrus 1 1.03 1.15 1.17 1.24
Gaston 1, 2 1.90 2.06 2.16 2.22
Iredell 1 0.68 0.69 0.69 0.69
Lincoln 1 1.54 1.72 1.83 1.94 Mecklenburg 2 3.45 3.73 4.02 4.36
Rowan 1 2.40 2.70 2.85 3.14
Union 1 1.42 1.57 1.64 1.74
Total 12.42 13.6 2 14.36 15.33

Net Change in ton/day emissions 0.00 0.00 0.00 0.00 % Change in ton/day emissions 0.00% 0.00% 0.00% 0.00%

1 Emissions for portion of county included in nonattainment area.

2 7.8 psi RVP requirement applies t o Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 8

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

T able 3

. 3 Area Source NOx Emissions (tons/day)

County Current 7.8 p si RVP

2014 2015 2018 2022 2026 Cabarrus 1 0.97 0.96 0.96 0.96 0.96
Gaston 1, 2 1.30 1.28 1.28 1.29 1.29
Iredell 1 0.54 0.53 0.54 0.56 0.55
Lincoln 1 0.40 0.40 0.40 0.40 0.40 Mecklenburg 2 6.07 6.01 6.01 6.01 6.00
Rowan 1 0.87 0.86 0.85 0.85 0.85
Union 1 1.25 1.24 1.24 1.24 1.23
Total 11.40 11.28 11.28 11.31 11.28 Proposed 9.0 psi RVP 2015 201 8 20 22 202 6 Cabarrus 1 0.96 0.96 0.96 0.96
Gaston 1, 2 1.28 1.28 1.29 1.29
Iredell 1 0.53 0.54 0.56 0.55
Lincoln 1 0.40 0.40 0.40 0.40 Mecklenburg 2 6.01 6.01 6.01 6.00
Rowan 1 0.86 0.85 0.85 0.85
Union 1 1.24 1.24 1.24 1.23
Total 11.28 11.28 11.31 11.28

Net Change in t on/ d ay emissions 0.00 0.00 0.00 0.00 % Change in ton/ d ay emissions 0.00% 0.00% 0.00% 0.00%

1 Emissions for port ion of county included in nonattainment area.

2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 9

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 4 Area Source VOC Emissions (tons/day)

County Current 7 .8 psi RVP

2014 2015 2018 2022 2026 Cabarrus 1 5.09 5.13 5.26 5.42 5.59
Gaston 1, 2 5.24 5.30 5.42 5.59 5.75
Iredell 1 3.08 3.13 3.26 3.43 3.58
Lincoln 1 2.56 2.57 2.64 2.74 2.82 Mecklenburg 2 20.59 20.73 21.15 21.70 22.22
Rowan 1 5.23 5.28 5.40 5.56 5.72
Union 1 6.09 6.12 6.26 6.43 6.60
Total 47.88 48.26 49.39 50.87 52.28 Proposed 9.0 psi RVP 2015 2018 2022 2026 Cabarrus 1 5.13 5.26 5.42 5.59
Gaston 1, 2 5.30 5.43 5.60 5.75
Iredell 1 3.13 3.26 3.43 3.58
Lincoln 1 2.57 2.64 2.74 2.82 Mecklenburg 2 20.77 21.19 21.73 22.26
Rowan 1 5.28 5.40 5.56 5.72
Union 1 6.12 6.26 6.43 6.60
Total 48.30 49.44 50.91 52.32

Net Change in t on/day emissio ns 0.04 0.05 0.04 0.04 % Change in t on/day emissions 0.08% 0.10% 0.08% 0.08%

1 Emissions for portion of county included in nonattainment area.

2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affect s these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 10

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 5 On

- road Mobile Source NOx Emissions (tons/day)

County Current 7.8 psi RVP

2014 2015 2018 2022 2026 Cabarrus 1 6.60 5.93 3.94 2.7 9 1.86
Gaston 1, 2 8.11 7.23 4.60 3.04 1.97
Iredell 1 3.36 3.05 2.05 1.41 0.93
Lincoln 1 3.00 2.75 1.84 1.23 0.76 Mecklenburg 2 26.99 24.12 14.35 9.63 6.85
Rowan 1 6.42 5.75 3.73 2.56 1.59
Union 1 5.67 5.14 3.41 2.28 1.51
Total 60.15 53.97 33.92 22.94 15. 47 Proposed 9.0 psi RVP 2015 2018 2022 2026 Cabarrus 1 5.93 3.94 2.79 1.86
Gaston 1, 2 7.26 4.62 3.04 1.98
Iredell 1 3.05 2.05 1.41 0.93
Lincoln 1 2.75 1.84 1.23 0.76 Mecklenburg 2 24.20 14.39 9.65 6.85
Rowan 1 5.75 3.73 2.56 1.59
Union 1 5.14 3.41 2.28 1.51
Total 54.08 33.98 22.96 15.48

Net Change in t on/day emissions 0.11 0.06 0.02 0.01 % Change in t on/day emissions 0.20% 0.18% 0.09% 0.06%

1 Emissions for portion of county included in nonattainment area.

2 7.8 psi RVP requir ement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 11

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 6 On

- road Mobile Source VOC Emission s (tons/day)

County Current 7.8 psi RVP

2014 2015 2018 2022 2026 Cabarrus 1 4.15 3.89 3.01 2.53 2.04
Gaston 1, 2 4.61 4.24 3.05 2.31 1.72
Iredell 1 1.95 1.82 1.40 1.10 0.82
Lincoln 1 1.91 1.81 1.37 1.07 0.79 Mecklenburg 2 14.40 13.28 10.00 8.18 6.64
Row an 1 3.76 3.48 2.57 1.93 1.41
Union 1 3.54 3.30 2.54 2.04 1.56
Total 34.32 31.82 23.94 19.16 14.98 Proposed 9.0 psi RVP 2015 2018 2022 2026 Cabarrus 1 3.89 3.01 2.53 2.04
Gaston 1, 2 4.29 3.08 2.32 1.73
Iredell 1 1.82 1.40 1.10 0.82
Lincoln 1 1.8 1 1.37 1.07 0.79 Mecklenburg 2 13.41 10.09 8.22 6.67
Rowan 1 3.48 2.57 1.93 1.41
Union 1 3.30 2.54 2.04 1.56
Total 32.00 24.06 19.21 15.02

Net Change in t on/day e missions 0.18 0.12 0.05 0.04 % Change in t on/day emissions 0.57% 0.50% 0.2 6% 0.27%

1 Emissions for portion of county included in nonattainment area.

2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these two counties. The reaming counties already allow 9.0 psi gas oline.Non

- Interference Demonstration to Support 12

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 7 Nonroad Mobile Source NOx Emissions (tons/day)
Current 7.8 psi RVP 2014 2015 2018 2022 2026 Cabarrus 1 2.2 0 2.04 1.65 1.34 1.16
Gaston 1, 2 1.98 1.83 1.49 1.23 1.08
Iredell 1 0.94 0.88 0.72 0. 58 0.5 1
Lincoln 1 0.78 0.72 0.59 0.49 0.42 Mecklenburg 2 15.09 13.99 11.36 9.20 8.11
Rowan 1 1.65 1.53 1.26 1.04 0.89
Union 1 3.62 3.36 2.72 2.19 1.86
Total 26.26 24.35 19.79 16.07 14.03 Proposed 9.0 psi RVP 2015 2018 2022 2026 Cabarrus 1 2.04 1.65 1.34 1.16
Gaston 1, 2 1.83 1.49 1.23 1.08
Iredell 1 0.88 0.72 0.58 0.51
Lincoln 1 0.72 0.59 0.49 0.42 Mecklenburg 2 13.99 11.36 9.20 8.11
Rowan 1 1.53 1.26 1.04 0.89
Union 1 3.36 2.72 2.19 1.86
Total 24.35 19.79 16.07 14.03

Net Chang e in t on/ d ay emissions 0.00 0.00 0.00 0.00 % Change in t on/ d ay emissions 0.00% 0.00% 0.00% 0.00%

1 Emissions for portion of county included in nonattainment area.

2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP

re laxation only affects these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 13

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 8 Nonroad Mobile Source VOC Emissions (tons/day)
Current 7.8 psi RVP 2014 2015 2018 2022 2026 Cabarrus 1 1.27 1.22 1.17 1.19 1.24
Gaston 1, 2 1.29 1.23 1.12 1.10 1.12
Iredell 1 0.62 0.59 0.52 0.49 0.49
Lincoln 1 0.58 0.55 0.48 0.46 0.46 Mecklenburg 2 11.75 11.35 10.82 10.91 11.30
Rowan 1 1.30 1.22 1.05 0.96 0.94
Union 1 2.08 2.01 1.92 1.93 2 .0 0
Total 18.89 1 8.17 17.08 17.04 1 7.55 Proposed 9.0 psi RVP 2015 2018 2022 2026 Cabarrus 1 1.22 1.17 1.19 1.24
Gaston 1, 2 1.25 1.14 1.12 1.15
Iredell 1 0.59 0.52 0.49 0.49
Lincoln 1 0.55 0.48 0.46 0.46 Mecklenburg 2 11.53 11.01 11.11 11.51
Rowan 1 1.22 1.05 0 .96 0.94
Union 1 2.01 1.92 1.93 2 .0 0
Total 18.37 17.29 17.26 1 7.79

Net Change in t on/ d ay emissions 0.20 0.21 0.22 0 .2 4 % Change in t on/ d ay emissions 1.10% 1.2 3 % 1.29% 1

. 37 %

1 Emissions for portion of county included in nonattainment area

. 2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 14

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 9 Total Anthropo genic NOx Emissions (tons/day)

County Current 7.8 psi RVP

2014 2015 2018 2022 2026 Cabarrus 1 11.49 10.73 8.49 7.16 6.18
Gaston 1, 2 27.89 27.59 18.09 21.72 9.63
Iredell 1 6.86 6.49 5.35 4.59 4.04
Lincoln 1 4.37 4.71 3.78 3.32 2.32 Mecklenburg 2 56.71 52 .89 41.18 35.29 32.96
Rowan 1 11.74 11.30 9.35 8.16 7.09
Union 1 11.13 10.36 8.03 6.41 5.32
Total 130.19 124.07 94.27 86.65 67.54 Proposed 9.0 psi RVP 2015 2018 2022 2026 Cabarrus 1 10.73 8.49 7.16 6.18
Gaston 1, 2 27.62 18.11 21.72 9.64
Iredell 1 6.49 5.35 4.59 4.04
Lincoln 1 4.71 3.78 3.32 2.31 Mecklenburg 2 52.97 41.22 35.31 32.96
Rowan 1 11.30 9.35 8.16 7.09
Union 1 10.36 8.03 6.41 5.32
Total 124.18 94.33 86.67 67.5 4

Net Change in t on/day emissions 0.11 0.06 0.02 0.01
% C hange in t on/day emissions 0.09% 0.06% 0.02% 0.01%

1 Emissions for portion of county included in nonattainment area.

2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 15

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties

Table 3

. 10 Total Anthropogenic VOC Emissions (tons/day)

County Current 7.8 psi RVP

2014 2015 2018 2022 2026 Cabarrus 1 11.50 11.27 10.59 10.31 10.11
Gaston 1, 2 1 2.96 12.67 11.65 11.16 10.81
Iredell 1 6.33 6.22 5.87 5.71 5.58
Lincoln 1 6.55 6.47 6.21 6.10 6.01 Mecklenburg 2 50.10 48.81 45.70 44.81 44.52
Rowan 1 12.59 12.38 11.72 11.30 11.21
Union 1 13.09 12.85 12.29 12.04 11.9 0
Total 113.12 110.67 104.03 101.43 10 0.14 Proposed 9.0 psi RVP 2015 2018 2022 2026 Cabarrus 1 11.27 10.59 10.31 10.11
Gaston 1, 2 12.74 11.71 11.20 10.85
Iredell 1 6.22 5.87 5.71 5.58
Lincoln 1 6.47 6.21 6.10 6.01 Mecklenburg 2 49.16 46.02 45.08 44.80
Rowan 1 12.38 11.72 11.30 11 .21
Union 1 12.85 12.29 12.04 11. 9 0
Total 111.09 104.4 1 101.74 100.46

Net Change in t on/day emissions 0.42 0.3 8 0.31 0.32 % Change in t on/day emissions 0.38% 0.3 7 % 0.31% 0

. 32 %

1 Emissions for portion of county included in nonattainment a rea.
2 7.8 psi RVP requirement applies to Mecklenburg and Gaston Counties only. Proposed RVP relaxation only affects these two counties. The reaming counties already allow 9.0 psi gasoline.Non

- Interference Demonstration to Support 16

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties 3

. 2 OZONE SENSITIVITY IN NORTH CAROLINA

A study p ublished in the Journal of Environmental Management conclude d that the sensitivity of
ozone to anth ropogenic VOC emissions in the S outheastern United States is 2

- 3 orders of magnitude smaller than the sensitivity of ozone to NOx emissions, primarily due to the abundance of biogenic VOC emissions in this region. 1 As a result, controlling anthropogenic VOC emissions in the Southeast is far less effective than controlling NOx emissions for purposes of reducing ozone levels. In fact, the study evaluates the c hange in ozone concentrations resulting from decreases in anthropogenic VOC emissions and indicates that the change in ozone concentrations resulting from a 30% decrease in anthropogenic VOC emissions is virtually zero
in most cases. The virtual non

- impac t to ozone concentrations due to a change in anthropogenic VOC emissions in the Southeast supports the DAQ’s conclusion that VOC emissions changes occurring in Ga ston and Mecklenburg Counties due to RVP relaxation will not interfere with the
Charlotte main tenance area ’s ability to maintain compliance with the 2008 8

- hour ozone NAAQS.

The RVP relaxation results in the highest increase in VOC emissions in year 2026 ( 0.32 ton/day

or 0. 32 % of total man

- made emissions). When biogenic VOC emissions from natura l sources (average of 183.9 tons/day from April through October using the EPA’s 2011 National Emissions Inventory) are added to the man

- made emissions ( 100

. 4 6 tons/day ) , the actual VOC emissions increase is only 0. 11 % ( 0.32 / 28 4

. 3 6 tons/day x 100) . For the reasons cited above, the DAQ does not believe that the very small changes to VOC emissions will translate into measurable ground

- level ozone concentrations changes in the Charlotte area. Consequently,
maintenance of the 2008 8

- hour ozone NAAQS is expecte d to be preserved.

3 .3 N ON

- INTERFERENCE WITH OZONE NAAQS

There are currently six ozone monitors located throughout the Ch arlotte marginal nonattainment area and one monitor located in York County, South Carolina, just outside of the nonattainment

area. The latest design value for the nonattainment area is 0.073 parts per million (ppm) based
on the data from 2012

- 2014, and, therefore, is in attainment of the 2008 8

- hour ozone NAAQS
and the nonattainment area is eligible to be considered for redesignatio n to attainment.

1 Odman, M Talat et al., Quantifying the sources of ozone, fine particulate matter, and regional haze in the Southeastern United States, 90 Journal of Environmental Management 3155

- 3168 (2009).Non

- Interference Demonstration to Support 17

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties In addition, the emissions inventory comparison between the 7.8 and 9.0 psi RVP standards indicates that the estimated future year emissions are slightly higher for NOx and VOC
emissions. The highest NOx increase occurs in the first year the standard is relaxed at 0.11 ton/day which is equivalent to a 0.09% increase in total man

- made emissions. By 2026, relaxing the RVP results in an emissions increase of only 0.01 ton/day of NOx or 0.01% increase in total

man

- made NOx emissions. Despit e this small increase in NOx emissions, which is the primary ozone precursor, the Charlotte area continues to demonstrate a downward trend in NOx and VOC emissions through all future years. A large safety margin remains between 2014 and 2026
to ensure tha t the area continues to attain the 2008 8

- hour ozone NAAQS. Table 3.11 shows the difference between the base year emissions and the final year emissions with the proposed RVP relaxation request. Table 3

. 12 shows the corresponding safety margins with the proposed RVP
standard.

Table 3

. 11 Maintenance Demonstration for North Carolina Portion of the

Charlotte Nonattainment Area

Year NOx (tons/day) VOC (tons/day)

2014 130.18 113.12

2015 124.18 111.09

2018 94.33 104.41

2022 8 6.67 101.74

2026 67.54 100

. 4 6

Difference from 2014 to 2026 - 62 .64

- 1 2

. 6 6

Table 3

. 12 Safety Margin for North Carolina Portion of the Charlotte Nonattainment Area

Year NOx (tons/day) VOC (tons/day)

2014 N/A N/A

2015

- 6.00

- 2.03

2018

- 35.85

- 8

. 71

2022

- 43.51

- 11. 38

2026

- 62 .64

- 1 2

. 6 6Non

- Interference Demonstration to Support 18

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties The data show that future years ’ total man

- made emissions continue to follow a declining trend with the proposed RVP standard. The 2014 to 2015 safety margin for NOx contains the largest impact before and after the RFP relaxation:

- 6.1 1 tons/day of NO x with 7.8 psi compared to

- 6.0 0 tons/day of NOx with 9.0 psi. Based on emissions and air quality modeling studies conducted on previous RVP relaxation requests, the DAQ does not believe tha t the resulting difference of 0.11 tons/day of NOx (0.09% of total man

- made emissions) will have a measureable impact on ground

- level ozone formation. Subsequently, maintenance of the 2008 8

- hour ozone NAAQS is expected to continue with the proposed 9.0 p si RVP standard. The conclusion is further supported by reviewing the safety margin in the final maintenance year. By 2026, the safety mar gin with the 7.8 psi RVP is 62.65 to ns/day of NOx and 62.6 4 tons/day of NOx with 9.0 psi RVP. The 0.01 ton/day chan ge in the safety margin in year 2026 is expected to have no impact on ground

- level ozone concentrations. In summary, there is no expectation or concern that the small change in emissions due to the relaxation of the RVP standard will affect
the attainment and maintenance stats of the Charlotte area for the ozone NAAQS.

3

. 4 NON

- INTERFERENCE WITH THE NAAQS FOR CARBON MONOXIDE, PARTICULATE MATTER, SULFUR DIOXIDE, AND NITROGEN DIOXIDE

The current ambient air quality levels for CO are less than 20% of the CO standard s

. One of the two current NAAQS established by EPA for CO is an 8

- hour standard of 9 ppm, measured using
the annual second

- highest maximum 8

- hour concentration for two consecutive years as the design value. The other standard is a 1

- hour avera ge of 35 ppm, using the second

- highest 1

- hour average within a given year . Ambient monitoring data for the Charlotte area in the years 2012
and 2013 show an 8

- hour design value of 1.2 ppm, or about 13% of the CO NAAQS. Additionally, years 2012 and 2013 a mbient monitoring data show maximum 1

- hour values of 2.3 and 1.7 ppm, respectively, within the Charlotte region. Both of these values are well below the 35 ppm standard set forth in the CO NAAQS. On

- road mobile emissions are known to be a large
component of overall CO emissions. However, for the Charlotte maintenance area , relaxation of the RVP standard is estimated to increase CO emissions by approximately 2.78 tons/day or 0.71% of total on

- road mobile source CO emissions in 201 5 . For 2026, CO emission s are estimated to increase by approximately 1.44 tons/day or 0.60 % of total on

- road mobile source
CO emissions due to relaxation of the RVP standard. This projected increase in CO emi ssions is comparatively minimal and it is expected that the effect on a mbient concentrations of CO will be correspondingly minimal as well. Therefore, there is no expectation or concern that this change
in CO emissions due to the relaxation of the RVP standard will affect the attainment status of the
Charlotte area CO NAAQS. Nonroad and area sources are not large contributors to CO
emissions.Non

- Interference Demonstration to Support 19

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties T he EPA revised the NO 2 standard on February 9, 2010 to establish a new 1

- hour standard at a level of 100 parts per billion (ppb), based on the 3

- year average of the 98th percentile of the yearly distribution of 1

- hour daily maximum concentrations, to supplement the existing annual standard of 53 ppb based on the annual mean concentration. The annual mean NO 2 concentration in the Charlotte area was 8 ppb in 2013 or 15% of the annual NO 2 NAAQS. For
the 1

- hour standard, t he monitoring requirements are focused on near

- road monitoring; therefore,
one focus of this standard is on

- road mobile sources. To date, two near

- road NO 2 monitors have been established in North Carolina, one in the Tri angle area in January 2014 and the other in the
Charlotte area in June 2014. The maximum 1

- hour NO 2 concentration measured at the Triangle area near road site in 2014 was 41.2 ppb in March 2014 . The maximum 1

- hour NO 2 concentration measured in the Charlo tte area was 43.6 ppb recorded on November 12, 2014.
Since sufficient data has not yet been collected to determine if North Carolina is violating or close to exceeding this 1

- hour standard, it is difficult to unequivocally determine whether relaxing the R VP standard will result in a violation of the NO 2 standard. However, on

- road
mobile sources are a large contributor of NOx emissions and NO 2 is a component of NOx.
MOVES mobile emission s modeling results show that relaxing the RVP standard results in onl y slight increases in NOx emissions for the region (0.20% in 2015 and 0.05% in 2026). Based upon the se estimates, it can be assumed that the RVP relaxation would likewise only slightly
increase NO 2 emissions and therefore would not greatly affect attainmen t of the 1

- hour NO 2 standard.

On

- road, nonroad and area sources are not believed to be large contributors to directly emitted
PM 2.5 or indirectly formed PM 2.5 concentrations. In North Carolina, directly emitted PM 2.5 is a very small component of the o verall PM 2.5 ambient concentrations. The primary species impacting PM 2.5 concentrations are the secondarily formed sulfates and organic carbons. In 2013
the Charlotte area PM 2.5 design values were 9.8 micrograms per cubic meter for the annual
standard or 82% of the annual PM 2.5 NAAQS and 22 microgram per cubic meter for the 24

- hour standard or 63% of the daily PM 2.5 NAAQS. MOVES modeling results indicate that the RVP
relaxation would lead to slight reductions of direct PM 2.5 emissions (0.23% in 2015 and 0.61% in 2026) and would have no effect on SO 2 and ammonia emissions. Based on this, it is concluded
that the RVP relaxation will not affect the attainment of the PM 2.5 standard.

Sulfates are formed through the chemical reaction of SO 2 and ammonia and the majority of the organic carbons come from natural sources like trees. A 2009 analysis of SO 2 emissions, which is a primary contributor to the formation of PM 2.5 within North Carolina, found about 3.3% of
total SO 2 emissions came from on

- road, nonroad and area sources combined, while the remaining 96.7% came from point sources (see “Redesignation Demonstration and MaintenanceNon

- Interference Demonstration to Support 20

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties Plan for the Hickory (Catawba County) and Greensboro/Winston

- Salem/High Point (Davidson and Guilford Counties) Fine Particulate Matte r Nonattainment Areas”, submitted to the EPA on
December 18, 2009, Figure 4

- 2, p. 4

- 4). The SO 2 design value in 2013 for the Charlotte area was 10 ppb or 13% of the hourly SO 2 NAAQS.

For the reasons outlined above, it is un likely that relaxing the RVP s tandard in Gaston and Mecklenburg Counties will result in a violation of the CO, SO 2 , NO 2 , and PM 2.5 NAAQS.

4 .0 CONCLUSIONS

The most recent three years of ozone monitoring data for the Charlotte maintenance area demonstrate compliance with the 2008 8

- ho ur ozone NAAQS. None of the six ozone monitors in the area show any violations of the 2008 8

- hour ozone NAAQS. Since the 1990’s, there have been many major programs enacted in North Carolina that have led to significant actual,
enforceable emissions redu ctions which have led to air quality improvements in the Charlotte area. The closing ( Riverbend ) or conversion (Buck) of coal

- fired power plants in the Charlotte
nonattainment area from 2011 through 2013 has also helped to improve air quality in the
Charl otte maintenance area. In addition, the decline in utilization of the Allen power plant in Gaston County has also contributed to air quality improvements in the Charlotte maintenance

area. T he capacity factor for the Allen plant dropped from 30 % to 14 % f rom 2011 to 2013

, and is expected to continue to decline during the forecast period for the maintenance plan.

The maintenance plan demonstrates that the projected emissions inventory for 20 2 6 is less than the base year emissions inventory when the RVP re quirement of 7.8 psi is relaxed to 9.0 psi

. The lower RVP requirement was implemented as a control measure to reduce VOC emissions

. Since VOC emissions from biogenic sources dominate in the Southeast, controlling ozone in
North Carolina is mo st effective ly done through reduction in NOx emissions. The non

interference demonstrat ion shows that the slight increase in NOx emissions from 2014 through
2026 would not affect the declining trends in emissions, and is not expected to result in measurable ozone imp acts. The safety margin for NOx remains relatively unchanged with the 9.0 psi RVP standard, and, therefore, will not interfere with maintenance of the ozone NAAQS.
The relaxation of the RVP standard is also not expected to interfere with the maintenance o f the other NAAQS

.Non

- Interference Demonstration to Support 21

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties 5.0 REVISED SECTIONS OF REDESIGNATION REQUEST AND MAINTENANCE
PLAN

Following is the complete Pre

- hearing Draft of the Redesignation Request and Maintenance Plan
for the Charlotte

- Gastonia

- Salisbury , NC 8

- hour Ozone Maintenance Area that has been revised to reflect changes to NOx and VOC emissions should the EPA approve both the redesignation request and maintenance plan as well as the DAQ’s request to relax the RVP standard from 7.8 psi to 9.0 psi in Gaston and Mecklenburg Counties. The following identifies the sections of the redesignation request and maintenance plan that have been revised. For the area, onroad, and
nonroad source categories for which emissions change due to relaxation of the RVP standard from 7.8 to 9.0 psi, App endix B.2, Appendix B.3 and Appendix B.4 present emissions for both the current and proposed RVP standards , respectively

.

 Executive Summary

o Conclusion and Request for Redesignation, page v

 Section 3. 4 Emissions Inventories and Maintenance Demonstration

o Se ction 3.4.2 Emission Inventories

 Table 3.5 Area Source VOC Emissions (tons/day) , page 35

 Table 3.6 On

- road Mobile Source NOx Emissions (tons/day) , page 36

 Table 3.7 On

- road Mobile Source VOC Emissions (tons/day) , page 36

 Table 3.9 Nonroad Mobile Sourc e VOC Emissions (tons/day) , page 37

o Section 3.4.3 Summary of Emissions

 Table 3.10 Total Man

- Made NOx Emissions for the North Carolina Portion of the Charlotte Nonattainment Area (tons/day) , page 37

 Table 3.11 Total Man

- Made VOC Emissions for the North C arolina Portion of the Charlotte Nonattainment Area (tons/day) , page 3 7

o Section 3.4.4 Maintenance Demonstration

 Table 3.12 Maintenance Demonstration for North Carolina Portion of the Charlotte Nonattainment Area , page 38

 Table 3.13 Safety Margin for Nor th Carolina Portion of the Charlotte Nonattainment Area , page 3 8

 Section 4.3 MOTOR VEHICLE EMISSION BUDGETS

o Table 4.2 Highway Mobile Source NOx and VOC Emissions in 2014 and 2026 for North Carolina Portion of the Charlotte Nonattainment Area , page 44

o Tab le 4.4 Gaston

- Cleveland

- Lincoln Metropolitan Planning Organization (GCLMPO) MVEB in 2014 and 2026 (kg/day), page 47Non

- Interference Demonstration to Support 22

Gasoline Reid Vapor Pressure Standard April 16

, 201 5 Relaxation in Gaston and Mecklenburg Counties o Table 4.5 Charlotte Regional Transportation Planning Organization (CRTPO)

- Rocky River Rural Planning Organization (RRRPO) MVEB in 2014 an d 2026 (kg/day), page 47

o Table 4.6 New Safety Margins for the North Carolina Portion of the Charlotte Nonattainment Area (tons/day) , page 47

 Section 7.0 Conclusions

, page 52

# Redesignation Demonstration

And Maintenance Plan

and Clean Air Act Section 110(l) Non

- Interference Demonstration to Support the Gasoline Reid Vapor Pressure (RVP) Standard Relaxation in Gaston and Mecklenburg Counties

for

The Charlotte

- Gastonia

- Salisbur y, North Carolina 2008 8

- Hour Ozone Marginal Nonattainment Area

Prepared by North Carolina Department of Environment and Natural Resources

Division of Air Quality

April 16 , 201 5(This page intentionally left blank)Charlotte

- Gastoni a

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- hour Ozone Marginal i

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 

### Preface: This document contains the technical support for North Carolina’s Division of Air Quality to request the Charlotte

- Gastonia

- Salisbury 2008 8

- hour ozone nonattainment area be redesignated as attainment for the 2008 8

- hour ozone national ambient air quality standard pursuant to §§107(d)(3)(D) and (E) of the Clean Air Act, as amended.Charlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal ii

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015



## EXECUTIVE SUMMARY

Introduction
Ozone is formed by a complex set of chemical reactions involving volatile organic compounds (VOCs), nitrogen oxides (NOx) and to a lesser extent c arbon monoxide (CO) . These gases are generated by utilities, combustion processes, certain industrial processes and even by natural sources such as trees. Tailpipe emissions from mobile sources (vehicles) are also significant sources of these pollutants. Emissions from smaller sources such as boat engines, lawn mowers and construction equipment also contribute to the formation of ozone. Ozone formation is promoted by strong sunlight, warm temperatures and light winds and is hence a problem predominantly during the hot summer months.

The 2008 8

- hour ozone N ational Ambient Air Q uality S tandard (NAAQS) is 0.0 75 parts per million (ppm). An exceedance of the 2008 8

- hour ozone NAAQS occurs when a mo nitor
measures ozone above 0.075 ppm on average for an 8

- hour period. A violation of this NAAQS occurs when the average of the annual fourth highest daily maximum 8

- hour ozone values over three consecutive years i s greater than or equal to 0.076 ppm. This three

- year average is termed the “design value” for the mon itor. The design value for a nonattainment area is the highest monitor design value in the area.

Charlotte

- Gastonia

- Salisbury Nonattainment Designation
The area surrounding Charlotte

- Gastonia

- Salisbury , North Carolina, called the Charlotte
nonattainment a rea, was designated as marginal nonattainment for the 2008 8

- hour ozone NAAQS on May 21 , 2012 ( 77 Federal Register (FR) 30088 ). The nonattainment designation was an action taken by the U. S. Environmental Protection Agency (EPA) under Section 107(d) of th e Clean Air Act (CAA). The CAA requires that some area be designated as nonattainment if a monitor is found to be in violation of a NAAQS. For the 2008 8

- hour ozone NAAQS, t he EPA
took des ignation action in 2012 bas ed on 2009

- 2011 design values . At that time, the design value
for the Charlotte area was 0. 079 ppm.

The Charlotte nonattainment area includes the entire county of Mecklenburg and parts of Cabarrus, Gaston, Iredell, Lincoln, Rowan and Union Counties (see Figure 1). The partial
counties include the townships listed in Table 1. Note that the EPA also designated the portion of York County, South Carolina that is adjacent to the Charlotte nonattainment area for the 2008 8

- hour ozone NAAQS. The South Carolina Department of Health & Environmental C ontrol ( SC DHEC) ha s develop ed a redesignation request and maintenance plan for the South Carolina portion of the Charlotte nonattainment area which is available upon request

.Charlotte

- Gastoni a

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- hour Ozone Marginal iii

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 Charlotte Nonattainment Area Boundary

Table 1 Counties and Townships within t he Charlotte Nonattainment Area

Cabarrus County Townships
Central Cabarrus Concord * Georgeville Harrisburg Kannapolis Midland
Mount Pleasant Odell Poplar Tent New Gilead Rimertown Gaston County Townships
Dallas Crowders Mountain Gastonia Riverbend Sou th Point Iredell County Townships
Coddle Creek Davidson Lincoln County Townships Catawba Springs Lincolnton Ironton Mecklenburg County

– All Townships Rowan County Townships
Atwell China Grove Franklin Gold Hill * Litaker Locke
Providence S alisbury Steel e Unity Union County Townships
Goose Creek Marshville Monroe Sandy Ridge Vance

* Note: Concord Township in Cabarrus County and Gold Hill Township in Rowan County were inadvertently left out of North Carolina’s recommendation and EPA’s f inal designations. In a letter dated January 28, 2014, the DAQ requested the EPA to add the missing townships in the state’s 2008 marginal ozone nonattainment area definition.Charlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal iv

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 Current Air Quality
There are currently six ozone monitors located throughout the Charlotte nonattainment area and one monitor located in York County, South Carolina, just outside of the nonattainment area . The latest design value for the nonattainment area is 0.0 73 ppm based on the data from 2012

- 20 1 4

. The 2014 8

- hour ozone monit oring data for the Charlotte nonattainment area was fully quality assured and officially submitted to the EPA for certification approval on December 12, 2014. The
EPA concurred with the North Carolina Division of Air Quality ( DAQ ) and Mecklenburg County
A ir Quality ( MCAQ ) certification on December 15, 2014. A detailed discussion of air quality levels in the region is provided in Section 2.0.

Maintenance Plan Requirements

The s tate of North Carolina has implemented permanent and enforceable state and fede ral actions
to reduce ozone precursor emissions in the North Carolina portion of the Charlotte nonattainment

area. In addition, MCAQ has implemented actions to reduce ozone precursor emissions. This
combination of s tate
, f

ederal , and local actions has re sulted in cleaner air in the Charlotte nonattainment area, and the anticipated future benefits from these programs are expected to result
in continued maintenance of the 2008 8

- hour ozone NAAQS in this region. State actions include
the Clean Smokestacks A ct ; the on

- board diagnostic (OBD II ) vehicle inspection and maintenance (I/M) pro gram that began on July 1, 2002; and voluntary programs to reduce emissions from diesel engines

. Local actions implemented by MCAQ include a prohibition on open burning and

a very effective voluntary program called Grants to Replace Aging Diesel Engines (GRADE)

. 1

The GRADE program is des igned to reduce NOx emissions by providing businesses and organizations funding incentives to replace or repower heavy

- duty non

- road equipment with newer, cleaner, less polluting engines.

S everal federal actions have resulted in lower emissions throughout the eastern portion of the
country. For on

- road and nonroad vehicles, f ederal actions include the Tier 2 engine standards for light

- and me dium

- duty vehicles, heavy

- duty engine standards, the low

- sulfur gasoline and diesel requirements, and off

- road engine standards. For stationary sources, federal actions include the Mercury and Air Toxic s (MATS) r ule for electricity generating units (EGUs) and the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial and
institutional boilers and reciprocating internal combustion engines (RICE )

. In addition, there are
several federal actions that will be implemented starting in 2015 . These actions will provide for
additional NOx emissions reductions in and near the Charlotte nonattainment area . For EGUs,
the future federal actions include compliance with the Cross State Air Pollution Rule (CSAPR)

1 http: //charmeck.org/mecklenburg/county/LUESA/AirQuality/MobileSources/Pages/GRADE.aspx

.Charlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal v

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 and the Tennessee V alley Authority (TVA) consent decree . For on

- road vehicles, the future
federal actions include compliance with the Tier 3 vehicle emissions and fuel standards and
corporate average fuel economy standards for on

- road vehicles.

Emissions
A base year invent ory for NOx and VOC emission s was developed for 20 1 4 since the design
value for the 20 12

- 20 1 4 period show s attainment of the 2008 8

- hour ozone NAAQS. Future year emissions inventories were also developed for the interim years 20 1 5 , 201 8 , 20 22 , and a final year emission inventory was developed for 20 2 6

. For each future year, t he total NOx and VOC
emissions i s lower than the 20 1 4 base year emissions. Furthermore, emissions modeling and air quality modeling for 2018 and 2030 performed by the EPA for the new Tier 3 engine and fuel standards and modeling performed by the Southeastern states for 2018 indicate that the area will be in attainment of the 2008 ozone NAAQS. 2

, 3 Th e emission inventory comparison demonstrates
that the Charlotte area is expected to ma intain the 2008 8

- hour ozone NAAQS through 20 2 6 since in no future year are the emissions expected to be greater than they were in the base year. The area is also in compliance with Section 110 and Part D requirements of the CAA.

Conclusion and Request for Redesignation

Based on the information provided in this State Implementation Plan ( SIP ) and criteria established in Section 107(d)(3)(E) of the CAA, North Carolina is requesting that the EPA redesignate the
Charlotte

- Gastonia

- Salisbury nonattainment a rea to attainment. North Carolina is also requesting that the EPA relax the 7.8 pounds per square inch (psi) Reid vapor pressure (RVP) requirement for Gaston and Mecklenburg Counties and specify 9.0 psi as the applicable gasoline volatility
standard for t he entire maintenance area year round. The monitoring data clearly show that the region has attained the 2008 8

- hour ozone standard, and the maintenance demonstration shows that the future emission inventories are expected to be lower than the attainment year inventory through the implementation of the various federal and state control measures. The CAA Section 110(l) non

- interfere nce demonstration analysis indicates that increasing the RVP from 7.8 to 9.0 psi in Gaston and Mecklenburg Counties would not negatively impact the redesignation demonstration and maintenance plan for the Charlotte area.

2 US EPA, http://www.epa.gov/otaq/documents/tier3/454r14002.pdf

. 3 Southeastern States Air Resource Managers (SESARM); Southeastern Modeling, Analysis and Planning (SEMAP) study, http://semap.ce.gatech.edu/sites/default/files/files/pro jections/base2018b

- O3

- DVFs

- DDVFs

- for

- 4configs.xls

.Charlotte

- Gastoni a

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- hour Ozone Marginal vi

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 TABLE OF CONTENTS

EXECUTIVE SUMMARY

................................ ................................ ................................ ............ ii

1.0 INTRODUCTION

................................ ................................ ................................ .................... 1

1.1 WHAT IS TROPOSPHERIC OZONE?

................................ ................................ .............. 1
1.2 CLEAN AIR ACT OF 1990

................................ ................................ ................................ 2 1.3 AIR QUALITY HISTORY

................................ ................................ ................................ . 2
1.4 CLEAN AIR ACT REDESIGNATION CRITERIA

................................ ........................... 4
2.0 AIR QUALITY

................................ ................................ ................................ ......................... 5 2.1 HISTORIC AIR QUALITY (2003

– 2011)

................................ ................................ ......... 5 2.2 RECENT AIR QUALITY VALUES (2012

– 2014)

................................ ............................ 7
2.3 PERMANENT AND ENFORCEABLE EMISSIONS REDUCTIONS

............................. 9
2.4 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE

................................ .... 13
2.5 EFFECT NOX CONTROL PROGRAMS ON OZONE LEVELS

................................ ... 14

3.0 MAINTENANCE PLAN

................................ ................................ ................................ ........ 18

3.1 CONCEPT OF NORTH CAROLINA'S MAINTENANCE PLAN

................................ .. 18
3.2 FOUNDATION CONTROL PROGRAM

................................ ................................ ......... 19
3.2.1 Federal Control Measures

................................ ................................ ........................... 19
3.2.2 State Control Measures

................................ ................................ ................................ 26
3.3 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE

................................ .... 28 3.3.1 State Programs Supporting Maintena nce

................................ ................................ .... 28 3.3.2 Local Programs Supporting Maintenance

................................ ................................ ... 29
3.4 EMISSIONS INVENTORIES AND MAINTENANCE DEMONSTRATION

............... 30 3.4.1 Theory of Approach

................................ ................................ ................................ .... 30
3.4.2 Emission Inventories

................................ ................................ ................................ ... 31 3.4.3 Summary of Emissions

................................ ................................ ............................... 37
3.4.4 Maintenance Demonstration

................................ ................................ ....................... 38 3.4.5 National and Regional Air Quality Assessments in Future Years

.............................. 39
3.5 CONTINGENCY PLAN

................................ ................................ ................................ ... 40
3.5.1 Overview

................................ ................................ ................................ ..................... 40 3.5.2 Contingency Plan Tr iggers

................................ ................................ ......................... 40 3.5.3 Action Resulting From Trigger Activation

................................ ................................ . 41 3.5.4 Tracking Program for Ongoing Maintenance

................................ ............................. 42

4.0 MOTOR VEHICLE EMISSIONS BUDGET FOR CONFORMITY

................................ .... 43

4.1 TRANSPORTATION CONFORMITY

................................ ................................ ............ 43
4.2 SAFETY MARGIN

................................ ................................ ................................ ........... 43
4.3 MOTOR VEHICLE EMISSION BUDGETS

................................ ................................ .... 44

5.0 STATE IMPLEMENTATION PLAN APPROVAL

................................ .............................. 48
5.1 INTRODUCTION

................................ ................................ ................................ ............. 48Charlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal vii

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 5.2 EVIDENCE OF COMPLIANCE

................................ ................................ ...................... 48

6.0 STATE COMPLIANCE WITH CLEA N AIR ACT REQUIREMENTS

............................... 51

7.0 CONCLUSION

................................ ................................ ................................ ....................... 52

LIST OF FIGURES Figure 1.1 Charlotte Nonattainment Area Boundary

................................ ................................ ....... 3 Figure 2.1 Ozone Monitor Locations in the Charlotte Nonattainment Area

................................ ... 5 Figure 2.2 Relationship between high tempe rature days and number of exceedance days in the Charlotte area

................................ ................................ ................................ ................................ .. 17 Figure 2.3 Relationship between high temperature days and maximum 4 th highest ozone value in the Charlotte Area

................................ ................................ ................................ ........................... 17

LIST OF TABLES Table 1.1 Counties and Townships within the Charlotte Nonattainment Area

............................... 3

Table 2.1 Charlotte Area’s Historic 4 th Highest 8

- hour Ozone Values (2003

- 2014)

...................... 6 Table 2.2 Charlotte Area’s Historic Design Values (2003

- 2014)

................................ .................. 7 Table 2.3 Charlotte Area’s Current Air Quality Data (2012

- 2014)

................................ ................ 8 Table 2.4 NOx Emissions from NC Sources in EPA’s Air Markets Program Database

............... 15 Table 2.5 April 1 through September 30 NOx Emissions for Electric Utilities Near Charlotte Area (tons/period)

................................ ................................ ................................ ........................... 16 Table 3.1 Population Percentages Used to Allocate Par tial County Emissions

............................ 31 Table 3.2 Point Source NOx Emissions (tons/day)

................................ ................................ ....... 34 Table 3.3 Point Source VOC Emissions (tons/day)

................................ ................................ ....... 34 Table 3.4 Area Source NOx Emissions (tons/day)

................................ ................................ ........ 35 Table 3.5 Area Source VOC Emissions (tons/day)

................................ ................................ ....... 35

Table 3.6 On

- road Mobile Source NOx Emissions (tons/day)

................................ ...................... 36

Table 3.7 On

- road Mobile Source VOC Emissions (tons/day)

................................ ..................... 36 Table 3.8 Nonroad Mobile Source NOx Emissions (tons/day)

................................ ..................... 36 Table 3.9 Nonroad Mobile Source VOC Emissions (tons/day)

................................ ..................... 37

Table 3.10 Total Man

- Made NOx Emissions for the North Carolina Portion of the Charlotte Nonattainment Area (tons/day)

................................ ................................ ................................ ....... 37

Table 3.11 Total Man

- Made VOC Emissions fo r the North Carolina Portion of the Charlotte Nonattainment Area (tons/day)

................................ ................................ ................................ ....... 37

Table 3.12 Maintenance Demonstration for North Carolina Portion of the Charlotte Nonattainment Area

................................ ................................ ................................ ........ 38Charlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal viii

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 Table 3.13 Safety Margin for North Carolina Portion of the Charlotte Nonattainment Area

....... 38 Table 3.14 Eight

- hour Design Values from SEM AP Photochemical Modeling

........................... 39 Table 3.15 Eight

- hour Design Values Scenarios from EPA Tier 3 Photochemical Modeling

...... 39

Table 4.1 Percent Increase to Mobile Vehicle Emissions Budget

................................ ................. 44 Table 4.2 Highway Mobile Source NOx and VOC Emissions in 2014 and 2026 for North Carolina Portion of the Charlotte Nonattainment Area

................................ ................................ .. 44 Table 4.3 Cabarrus Rowan Metropolitan Planning Organization (CRMPO) MVEB in 2014 and 2026 (kg/day)

................................ ................................ ................................ ................................ .. 46

Table 4.4 Gaston

- Cleve land

- Lincoln Metropolitan Planning Organization (GCLMPO) MVEB in 2014 and 2026 (kg/day)

................................ ................................ ................................ .................. 47 Table 4.5 Charlotte Regional Transportation Planning Organization (CRTPO)

- Rocky River Rural Plannin g Organization (RRRPO) MVEB in 2014 and 2026 (kg/day)

................................ .. 47 Table 4.6 New Safety Margins for the North Carolina Portion of the Charlotte Nonattainment Area (tons/day)

................................ ................................ ................................ ................................ 47

LIST OF APPENDICES

APPENDIX A: CORRESPONDENCE AND GUIDANCE DOCUMENTS

APPENDIX B .1: POINT SOURCE INVENTORY DOCUMENTATION

APPENDIX B .2: AREA SOURCE INVENTORY DOCUMENTATION

APPENDIX B .3: ON

- ROAD MOBILE SOURCE INVENTORY DOCUMENTATION

APPENDIX B .4: NONROAD MOBILE SOURCE INVENTORY DOCUMENTATIONCharlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal ix

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 LIST OF ACRONYMS
Acronym Definition
AADVMT Average annual daily vehicle miles traveled
AEO Annual Energy Outlook
AERR Air Emission Reporting Rule
AMPD Air Markets Program Data
APU Auxiliary Power Units
ARRA American Recovery and Reinvestment Act
AvGas Aviation gasoline
BTU British Thermal Unit
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CAMD Clean Air Markets Division
CDOT Charlotte Department of Transportation
CFR Code of Feder al Regulations CMAQ Congestion Mitigation and Air Quality Improvement
CNG Compressed Natural Gas
CO Carbon Monoxide
CO 2 Carbon Dioxide
CRMPO Cabarrus Rowan Metropolitan Planning Organization
CRTPO Charlotte Regional Transportation Planning Organizati on CSAPR Cross State Air Pollution Rule DAQ North Carolina Division of Air Quality
DERA Diesel Emissions Reduction Act
DOC Diesel Oxidation Catalyst
DPF Diesel Particulate Filter
EDMS Emissions and Dispersion Modeling System
EF Emission factor
EGU Electricity Generating Units
EIA Energy Information Administration
EIIP Emissions Inventory Improvement Program
EIS Emissions Information System
EMP Emissions Modeling Platform
EPA United States Environmental Protection Agency
ERTAC Eastern Regional Technical Advisory Committee
oF Degrees Fahrenheit
FAA Federal Aviation Administration
FHWA Federal Highway Administration
FIFRA Federal Insecticide, Fungicide and Rodenticide Act
FIP Federal Implementation Plan
FR Federal RegisterCharlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal x

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 Acronym Definition
FTR Federal Trans port Rule
GACT Generally Available Control Technology
GCLMPO Gaston

- Cleveland

- Lincoln Metropolitan Planning Organization
GHG Greenhouse Gas
GIS Geographic Information System
GRADE Grants to Replace Aging Diesel Engines
GSE Ground Support Equipment
H AP Hazardous Air Pollutant
HC Hydrocarbons
HDDV Heavy duty diesel vehicles
HDGV Heavy duty gas vehicles
HPMS High performance monitoring system
I/M Inspection and Maintenance
ICI Industrial and commercial/institutional
KCLT Charlotte Douglas Interna tional Airport kg/day Kilograms/Day
lbs Pounds
LDDT1 Light duty diesel trucks 1
LDDT1 Light duty diesel trucks 2
LDDV Light duty diesel vehicles
LDGT1 Light duty gas trucks 1
LDGT2 Light duty gas trucks 2
LDGV Light duty gas vehicles
LPG Liquid pe troleum gas
LTO Landing and takeoff
MACT Maximum Achievable Control Technology
MATS Mercury Air Toxics rule
MC Motorcycles MCAQ Mecklenburg County Air Quality
MOA Memorandum of Agreement
MOVES Motor Vehicle Emissions Simulator

mpg miles per gallon
MPO Metropolitan Planning Organization
MRM Metrolina Regional Model
MTP Metropolitan Transportation Plan
MVEB Motor Vehicle Emission Budget NAAQS National Ambient Air Quality Standard
NAICS North American Industrial Classification System
NCAA North Carolina Air Awareness
NCAC North Carolina Administrative CodeCharlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal xi

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 Acronym Definition NCDAQ North Carolina Division of Air Quality
NCDOT North Carolina Department of Transportation
NCFS North Carolina Forest Service
NCPCM North Carolina Petroleum and Convenience Marketers
NEI National Emissions Inventory
NESHAP National Emissions Standards for Hazardous Air Pollutants
NG Natural Gas
NHTSA National Highway Traffic Safety Administration
NMOG Non

- methane Organic Gases
NO 2 Nitrogen Dioxide
NOx Nitrogen Oxides
NSPS New So urce Performance Standard
OBD Onboard Diagnostic
PAD Petroleum Administration for Defense
PFC Portable fuel container
PM Particulate Matter
PM 10 Particulate matter with an aerodynamic diameter less than or equal to 10

micrometers
PM 2.5 Particulate ma tter with an aerodynamic diameter less than or equal to 2.5

micrometers ppb Parts per billion

ppm Parts per million psi pounds per square inch QA Quality Assurance QAPP Quality Assurance Project Plan
RICE Reciprocating Internal Combustion Engines
RP O Rural Planning Organization
RRRPO Rock River Rural Planning Organization
RT Road type
RVP Reid Vapor Pressure
SCDHEC South Carolina Department of Health and Environmental Control
SEMAP Southeastern Modeling, Analysis and Planning
SESARM Southeaster n States Air Resource Managers
SIP State Implementation Plan
SO 2 Sulfur Dioxide
SUV Sport Utility Vehicle
TAF Terminal Area Forecast
TDM Transportation Demand Model
TIP Transportation Improvement Program
TVA Tennessee Valley Authority
UI Urban inte rstateCharlotte

- Gastoni a

- Salisbury, NC 2008 8

- hour Ozone Marginal xii

Nonattainment Area Redesignation Demonstration and Maintenance Plan April 16 , 2015 Acronym Definition
UF Urban freeway
USCBP United Sates Census Bureau, County Business Patterns
USDA United States Department of Agriculture
UST Underground storage tank
VHT Vehicle Hours Traveled
VMT Vehicle Miles Traveled
VOC Volatile Organic CompoundsCharlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 1

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 

### 1.0 INTRODUCTION

1.1 WHAT IS TROPOSPHERIC OZONE?

Ozone, a strong chemical oxidant, adversely impacts human health through effects on respiratory function and can also damage forests and crops. Ozone is not emitted directly by the electric utilities, ind ustrial sources or motor vehicles but instead, is formed in the lower atmosphere, the troposphere, by a complex series of chemical reactions involving nitrogen oxides (NOx), resulting from the utilities, combustion processes and motor vehicles, and reactiv e volatile organic compounds (VOCs). VOCs include many industrial solvents, toluene, xylene and hexane as well as the various hydrocarbons (HC) that are evaporated from the gasoline used by motor vehicles or emitted through the tailpipe following combusti on.

Ozone formation is promoted by strong sunlight, warm temperatures, and light winds. High concentrations tend to be a problem in the eastern United States only during the hot summer months when these conditions frequently occur. Therefore, the U. S. Environmental Protection Agency (EPA) mandates seasonal monitoring of ambient ozone concentrations in North Carolina from April 1 through October 31 (40 CFR 58 App. D, 2.5). 4 The DAQ has examined both the

man

- made and natural sources of VOC emissions and their contribution to ozone formation in
North Carolina. B ecause of the generally warm and moist climate of North Carolina, vegetation abounds in many forms, and forested lands naturally cover much of the state. As a result, the biogenic sector is the mo st abundant source of VOCs in North Carolina and accounts for approximately 90% of the total VOC emissions statewide. The overwhelming abundance of biogenic VOCs makes the majority of North Carolina a NOx limited environment for the
formation of ozone. T his is supported by a study published in the Journal of Environmental Management that concludes that the sensitivity of ozone to anthropogenic VOC emissions in the
Southeastern United States is 2

- 3 orders of magnitude smaller than the sensitivity of ozone to NOx emissions, primarily due to the abundance of biogenic VOC emissions in this region. 5 As a result, controlling anthropogenic VOC emissions in the Southeast is far less effective than controlling NOx emissions for purposes of reducing ozone levels.

O n March 12, 2008, t he EPA revised the primary (h ealth) and secondary (welfare) N ational
A mbient A ir Q uality S tandards (NAAQS) for ozone to a level of 0.075 parts per million ( ppm )

. An exceedance of the 2008 8

- hour ozone NAAQS occurs when a mo nitor measure s ozone above
0.075 ppm on average for an 8

- hour period. A violation of this NAAQS occurs when the average of the annual fourth highest daily maximum 8

- hour ozone values over three consecutive

4 40 CFR 58 App. D, 2.5.

5 Odman, M Talat et al., Quantifying the sources of ozone, fine particulate matter, and regional haze in the Southeastern United States, 90 Journal of Environmental Management 31 55

- 3168 (2009).Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 2

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 years i s greater than or equal to 0.076 ppm. This three

- year average is termed the “design value” for the monitor. The design value for a nonattainment area is the highest monitor’s design value
in the area.

1.2 CLEAN AIR ACT OF 1990

Since the 1977 amendments to the Clean Air Act (CAA), areas of the country that had not attained the ambient standard for a particular pollutant were formally designated as nonattainment for that pollutant. This formal designation concept was retained in the 1990 CAA
Amendments.

1.3 AIR QUALITY HISTORY

The area surrounding Charlot te

- Gastonia

- Rock Hill, North Carolina

- South Carolina, called the Metrolina area (see Figure 1.1), was designated nonattainment for the 1997 8

- hour ozone NAAQS on April 30, 2004. 6 The 1997 8

- hour ozone NAAQS was set at 0.085 ppm. The
Metrolina nonattainme nt area includes the North Carolina counties of Cabarrus, Gaston, Lincoln, Mecklenburg, Rowan and Union; Coddle Creek and Davidson Townships in Iredell County, North Carolina; and the Rock Hill Metropolitan Planning Organization boundary in York County,
So uth Carolina. On December 2, 2013, the EPA approved North Carolina’s redesignation demonstration and maintenance plan for the 1997 8

- hour ozone NAAQS for the Charlotte

Gastonia

- Rock Hill, North Carolina area. 7

On July 20, 2012, the EPA designated the Ch arlotte

- Gastonia

- Salisbury, North Carolina nonattainment area (referred to as the Charlotte nonattainment area) as “marginal” nonattainment
for the 2008 8

- hour ozone standard (Figure 1.1) based on the ambient data from 2009

- 2011. The
nonattainment area in cludes all of Mecklenburg County and portions of Cabarrus, Gaston, Iredell, Lincoln, Rowan, and Union Counties. Table 1.1 identifies the townships in each county that are included in the Charlotte nonattainment area. At that time, the design value for th e Charlotte area was 0.079 ppm. The official designation and classification was published in the Federal Register (FR) on May 21, 2012. 8 The designation became effective on July 20, 2012.

6 69 FR 23858

. 7 78 FR 72036.

8 77 FR 30088.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 3

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

Figure 1

. 1 Char lotte Nonattainment Area Boundary

Table 1

. 1 Counties and Townships within the Charlotte Nonattainment Area

Cabarrus County Townships
Central Cabarrus Concord * Georgeville Harrisburg Kannapolis Midland
Mou nt Pleasant Odell Poplar Tent New Gilead Rimertown Gaston County Townships
Dallas Crowders Mountain Gastonia Riverbend South Point Iredell County Townships
Coddle Creek Davidson Lincoln County Townships Catawba Springs Lincolnton Ironton
M ecklenburg County

– All Townships Rowan County Townships
Atwell China Grove Franklin Gold Hill * Litaker Locke
Providence Salisbury Steel e Unity Union County Townships
Goose Creek Marshville Monroe Sandy Ridge Vance

* Note: Concord Township in Caba rrus County and Gold Hill Township in Rowan County were inadvertently left out of North Carolina’s recommendation and EPA’s final designations. In a letter dated January 28, 2014, the North Carolina Division of Air Quality (DAQ) requested EPA to add the m issing townships in the state’s 2008 marginal ozone nonattainment area definition.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 4

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 There are currently six ozone monitors located throughout the Charlotte nonattainment area and one monitor located in York County, South Carolina. The North Carolina Divi sion of Air Quality (DAQ) operates three of the monitors in the Charlotte area, the Mecklenburg County Air Quality (MCAQ) operates three of the monitors in the Mecklenburg County, and South Carolina Department of Health and Environmental Control (SCDHEC) o perates the York County monitor.

In 2013 , all but two monitor s , Garinger and County Line located in Mecklenburg County, came
into attainment of the 2008 8

- hour ozone NAAQS. With the completion of the 20 14 ozone season, the Garinger and County Line monitor s attaine d the standard as well. The 2012

- 20 14 design value for Charlotte nonattainment area is 0. 073 ppm.

1.4 CLEAN AIR ACT REDESIGNATION CRITERIA

Section 107(d)(3)(E) of the CAA, as amended, states an area can be redesignated to attainment if
the fol lowing conditions are met:

1. The EPA has determined that the NAAQS have been attained. For ozone, the areas must show that the average of the fourth highest 8

- hour ozone values from three (3) complete, consecutive calendar years of quality

- assured air quali ty mon itoring data must be below
0.076 ppm.

2. The applicable implementation plan has been f ully approved by the EPA under S ection 110(k).

3. The EPA has determined that the improvement in air quality is due to permanent and
enforceable reductions in emissi ons. To demonstrate this, the s tate should estimate the percent reduction (from the year used to determine the design value for designation and classification) achieved from federal, state , and local measures.

4. The s tate has met all applicable r equirements for the area under S ection 110 and Part D.

5. The EPA has fully approved a maintenance plan, including a conting ency plan, for the
areas under S ection 175A.

In the following sections , the DAQ provide s the technical data necessary to show that the
Charlotte

- Gaston ia

- Salisbury nonattainment area has attained and is expected to maintain the
2008 8

- hour ozone standard, and has met the requirements for redesignation set forth above.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 5

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 

### 2.0 AIR QUALITY

2.1 HISTORIC AIR QUALITY (200 3

– 2011 )

The DAQ and MCAQ ha ve collec ted ambient monitoring data for the Charlotte area since the
late seventies. Figure 2. 1 shows the location of the six ozone monitors throughout the Charlotte
nonattainment area . In addition, one additional ozone monitor is located in York County, South
C arolina (not shown in Figure 2. 1)

. These monitors were installed in accordance with the Code of Federal Regulations (CFR) 40 CFR 58.

Figure 2

. 1 Ozone Monitor Locations in the Charlotte Nonattainment Area

Tables 2 .1 and 2

. 2 show the air quality data and corresponding design values for the monitors in
the Charlotte region , respectively, from 2003 to 201 4 . As shown in Table 2. 2, the design values
for most of the monitors near and downwind of Charlotte hav e been declining rapidly in the past several years

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 6

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Table 2

. 1 Charlotte Area’s Historic 4 th Highest 8

- hour Ozone Values (2003

- 201 4 )

Monitor 4 th Highest 8

- hour Ozone Values (ppm) 2003 2004 2005 2006 2007 2 008 2009 2010 2011 2012 2013 2014

Crouse AIRS ID #37

- 109

- 0004 Lincoln County 0.089 0.074 0.082 0.082 0.085 0.079 0.065 0.072 0.077 0.076 0.064 0.064

Garinger AIRS ID #37

- 119

- 0041 Mecklenburg County 0.086 0.085 0.088 0.091 0.093 0.085 0.069 0.082 0.088 0. 080 0.067 0.065

Arrowood AIRS ID #37

- 119

- 1005 Mecklenburg County 0.073 0.077 0.085 0.078 0.087 0.073 0.068 0.078 0.082 0.073 0.062 0.063

County Line AIRS ID #37

- 119

- 1009 Mecklenburg County 0.088 0.083 0.090 0.093 0.096 0.093 0.071 0.082 0.083 0.085 0.066 0.068

Rockwell AIRS ID #37

- 159

- 0021 Rowan County 0.098 0.080 0.086 0.085 0.096 0.084 0.071 0.077 0.077 0.080 0.062 0.064

Enochville 1 AIRS ID #37

- 159

- 0022 Rowan County 0.087 0.080 0.088 0.089 0.095 0.082 0.073 0.078 0.078 0.077 0.063 -----

Monroe AIRS ID #37

- 179

- 0003 Union County 0.083 0.074 0.082 0.080 0.082 0.080 0.067 0.071 0.073 0.075 0.062 0.067

York AIRS ID #45

- 091

- 0006 York County 0.076 0.071 0.079 0.078 0.080 0.075 0.062 0.065 0.065 0.065 0.061 0.056

1 Monitoring data for 2014 are not availabl e for this monitor because it was shut down in 2014.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 7

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

Table 2

. 2 Charlotte Ar e a’s Historic Design Values (2003

- 201 4 )

Monitor Design Value (ppm) 03

- 05 04

- 06 05

- 07 06

- 08 07

- 09 08

- 10 09

- 11 10

- 12 11

- 13 12

- 1 4

Crouse AIRS ID #37

- 109

- 0004 Lincoln County 0.081 0.079 0.083 0.082 0.076 0.072 0.071 0.075 0.072 0.068

Garinger AIRS ID #37

- 119

- 0041 Mecklenburg County 0.086 0.088 0.090 0.089 0.082 0.078 0.079 0.083 0.078 0.070

Arrowood AIRS ID #37

- 119

- 1005 Mecklenbu rg County 0.078 0.080 0.083 0.079 0.076 0.073 0.076 0.077 0.072 0.066

County Line AIRS ID #37

- 119

- 1009 Mecklenburg County 0.087 0.088 0.093 0.094 0.086 0.082 0.078 0.083 0.078 0.073

Rockwell AIRS ID #37

- 159

- 0021 Rowan County 0.088 0.083 0.089 0.088 0.083 0.077 0.075 0.078 0.073 0.068

Enochville 1 AIRS ID #37

- 159

- 0022 Rowan County 0.085 0.085 0.090 0.088 0.083 0.077 0.076 0.077 0.072

----

Monroe AIRS ID #37

- 179

- 0003 Union County 0.079 0.078 0.081 0.080 0.076 0.072 0.070 0.073 0.070 0.068

York AIRS ID #45

- 091

- 0006 York County 0.075 0.076 0.079 0.077 0.072 0.067 0.064 0.065 0.063 0.060

Note: Bolded values represent violations of the 2008 8

- hour ozone standard.

1 2012

- 2014 design value for this monitor is not available because it was shut down in 2014.

2.2 RECEN T AIR QUALITY VALUES (2012

– 2014 )

Under the CAA, a marginal classification for the 2008 8

- hour ozone NAAQS requires North Carolina to attain the standard within three years of designation, or July 20, 2015. However, in the 2008 Ozone Implementa tion Rule, the EPA extended the compliance date to December 31,Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 8

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 2015. 9 In a recent ruling by the U.S. Court of Appeals for the District of Columbia Circuit, the
extension deadline was vacated

, among other decisions. 10

The most recent three yea rs of ozone monitoring data (2012

- 2014 ) for the Charlotte nonattainment area demonstrate compliance with t he 2008 8

- hour ozone NAAQS. Table 2. 3 is a summary of the fourth highest 8

- hour average ozone concentration and the design value at each
of the monitors in the Charlotte region for 2012

- 2014

.

Table 2

. 3 Charlotte Area’s Cu rr ent Air Quality Data (2012

- 2014 )

Monitor Year 4 th Highest 8

- hour ozone values (ppm) Design Value (ppm) 20 12

- 201 4

Crouse AIRS ID #37

- 109

- 000 4 Lincoln County 2012 0.076
0.068 2013 0.064
2014 0.064
Garinger AIRS ID #37

- 119

- 0041 Mecklenburg County 2012 0.080
0.070 2013 0.067
2014 0.065

Arrowood AIRS ID #37

- 119

- 1005 Mecklenburg County 2012 0.073
0.066 2013 0.062
2014 0.063

Cou nty Line AIRS ID #37

- 119

- 1009 Mecklenburg County 2012 0.085
0.073 2013 0.066
2014 0.068

Rockwell AIRS ID #37

- 159

- 0021 Rowan County 2012 0.080
0.068 2013 0.062
2014 0.064
Monroe AIRS ID #37

- 179

- 0003 Union County 2012 0.075
0.068 2013 0.06 2
2014 0.067

York AIRS ID #45

- 091

- 0006 York County 2012 0.06 5
0.060 2013 0.061
2014 0.055

The 20 14 8

- hour ozone monitoring data for the Charlotte nonattainment area was fully quality assured and officially submitted to the EPA for certification a pproval on December 12, 2014

.

9 78 FR 34178.

10 http://www.cadc.uscourts.gov/internet/opinions.nsf/E 97A64FFBFE4DC1D85257DB70054D5EE/$file/12

- 1321

- 1528834.pdf

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 9

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 The EPA concurred with the DAQ and MCAQ certification on December 15, 201 4

. The Enochville site in Rowan County was shut down in 2014, but the most recent design value for
that site was 0.07 2 ppm in 2011

- 2013 and it was not the highest value in Rowan County or the
greater Charlotte area at the time of it s shutdown

.

The monitoring data shown above demonstrates that the Charlotte area is attaining the 2008 8

- hour ozone standard, and is on schedule with the compliance date manda ted in the CAA and upheld by the D.C. Circuit Court.

2.3 PERMANENT AND ENFORCEABLE EMISSIONS REDUCTIONS

There are several state and federal measures that have been enacted in recent years that have
ensured permanent and enforceable emissions reductions. A list of those measures that contributed to the permanent and enforceable emission reductions are summarized here and are more fully described in Section 3.2.

The federal measures that have been implemented include:

 T ier 2 vehicle and fuel standards: I mplementation began in 2004 and requires all passenger vehicles in each manufacture’s fleet to meet an average standard of 0.07 grams of NOx per mile. Additionally, in January 2006 the sulfur content of gasoline was required to be on average 30 ppm whic h assists in lowering NOx emissions. Most gasoline sold in North Carolina prior to January 2006 had a sulfur content of about 300 ppm. These emission reductions are federally enforceable.

 Tier 3 v ehicle and fuel s tandards : Implementation begins in 2017 with full compliance required by 2025. Tier 3 requires all passenger vehicles to meet an average standard of 0.03 gram /mile of NOx. Compared to Tier 2, the Tier 3 tailpipe standards for light

- duty vehicles are expected to reduce NOx and VOC emissions by approximately 80%. Tier 3 vehicle standards also include evaporative standards using onboard diagnostics (OBD) that will result in a 50% reduction in VOC emissions over Tier 2. The rule reduces the sulfur content of gasoline to 10 ppm starting in January 2017. These emission reductions will be federally enforceable.

 National program for greenhouse gas (GHG) emissions and fuel economy standards: The federal GHG and fuel economy standards apply to light

- duty cars and trucks in model years 2012

- 2016 (phase 1) and 2017

- 2025 (phase 2). The final standards are projected to result in an average industry fleet

- wide level of 163 grams/mile of carbonCharlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

dioxide ( CO 2 ) which is equivalent to 54.5 miles per gallon ( mpg ) if achieved exclusively through fuel economy impr ovements. The fuel economy standards will result in less fuel being consumed, and therefore less NOx emissions re leased. These emission reductions will be federally enforceable.

 Heavy

- duty gasoline and diesel highway vehicle standards: Implementation of the program b egan in 2004 with full implementation in 2010. The program was estimated to reduce NOx emissions by 95% and require d that the sulfur content of fuel be reduced to 15 ppm. These emission reductions are federally enforceable.

 Medium

- and h eavy

- duty vehicle fuel consumption and GHG standards: Began implementation in 2014 and requires on

- road vehicles to achieve from a 7% to 20%
reduction in CO 2 emissions and fuel consumption by 2018. The decrease in fuel consumption will result in a 7% to 20% decrease in NOx emissions. These emission reductions will be federally enforceable.

 Large nonroad diesel engine standards: Phased in between 2008 through 2014, the combined engine and fuel requirements are expected to reduce NOx emissions by
90% and reduc e the sulfur content in the nonroad diesel fuel to 15 ppm. These emission reductions are federally enforceable.

 Nonroad spark

- ignition engine and recreational engine standards: Tier 1 of these standards was implemented in 2004 and Tier 2 started in 2007. These standards reduce NOx emissions by 80%. These emission reductions are federally enforceable.

 Clean A ir I nterstate R ule (CAIR) and C ross S tate A ir P ollution R ule (CSAPR) : In May 2005, the EPA promulgated CAIR to reduce NOx and SO 2 emissions from
el ectricity generating units ( EGU s) . After court challenges to CAIR, the EPA issued CSAPR in July 2011. CSAPR will take effect starting January 1, 2015 for SO 2 and annual NOx, and May 1, 2015 for ozone season NOx. Combined with other final
state and EPA a ctions, the CSAPR will reduce power plant SO 2 emissions by 73 % and NOx emissions by 54 % from 2005 levels. The emission reductions will be federally enforceable.

 Tennessee Valley Authority ( TVA ) C onsent D ecree: I n Jan uary 2009

, a federal court required T VA coal

- fired EGU s to install modern pollution controls for SO 2 and NOx. After an appeals court reversed the decision, North Carolina, TVA, and several other parties agreed to a s ettlement

. The settlement caps NOx and SO 2 emissions at all ofCharlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

TVA’s coal

- f

ired facilities to permanent levels of 52,000 tons of NOx in 2018 and 110,000 tons of SO 2 in 2019 . These emission reductions are federally enforceable.

 Boiler and Reciprocating Internal Combustion Engine ( RICE ) National Emissions Standards for Hazardous Air Pollutants ( NESHAP ) : The NESHAP s for industrial,
commercial and institutional boilers and RICE are expected to result in a small decrease in VOC emissions. Boilers must comply with the NESHAP by January 31, 2016 for all states except North Carolina w hich has a compliance date in May 2019 (see following discussion under state measures)

. RICE owners and operators had to comply with the NESHAP by May 3, 2013. These emission reductions are federally
enforceable.

 Utility Mercury Air Toxics Standards (MA TS) and New Source Performance
Standards (NSPS): On February 16, 2012, the EPA published final rules for both the (1) MATS for new and existing coal

- and oil

- fired EGUs and (2) NSPS for fossil

- fuel fired electric utility, industrial

- commercial

- institution al and small industrial

commercial

- institutional steam generating units. 11 The MATS reduce emissions of toxic air pollutants from EGUs larger than 25 megawatts that burn coal or oil for the purpose of generating electricity for sale and distribution throug h the national electric grid to the public. For the NSPS, the EPA revised the standards that new coal

- and
oil

- fired power plants must meet for NOx, SO 2 , and particulate matter (PM). While MATS is still under court review, and portions of it may be overt urned, the rule can be expected to result in the reduction of both NOx and SO 2 emissions in addition to the reduction in mercury and other air toxic emissions. The emission reductions associated with the MATS and revised NSPS are federally enforceable.

T he state measures that have been implemented include:

 Vehicle Emissions Inspection and Maintenance (I/M) Program : In 1999

, the North
Carolina State L egislation passed the Clean Air Bill that e xpanded the on

- road
vehicle I/M program from 9 to 48 counties

. It was phased

- in in the Charlotte nonattainment area from July 1, 2002 through January 1, 2004. This program reduces NOx, VOC and CO emissions. The rule for the I/M program was submitted to the
EPA for adoption into the State Implementation Plan ( SIP ) i n August 2002 and was federally approved in October 2002. Therefore, t hese emission reductions are both

s tate and federally enforceable.

11 77 FR 9304.Charlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

On February 5, 2015, the EPA approved a change to North Carolina’s I/M rules triggered by a state law which exempted plug

- in vehicles and the three newest model year vehicles with less than 70,000 miles on their odometers from emission inspection in all areas in North Carolina where I/M is required. 12 In North Carolina’s Section 110(l) demonstration, the state showed th at the change in the compliance rate from 95% to 96% more than compensate s for the NOx and VOC emissions increase.
The EPA

- approved change to the I/M rules wa s effective March 9, 2015, and are state and federally enforceable. See Section 3.2.2 of this SI P for a more detailed discussion of this change.

 Clean Smokestacks Act: This s tate law requires coal

- fired power plants to reduce annual NOx emissions by 77 % by 2009

, and to reduce annual SO 2 emissions by 49 % by 2009 and 73 % by 2013. This law set a NOx e missions cap of 56,000 tons/year for
2009 and SO 2 emissions caps of 250,000 tons/year and 130,000 tons/year for 2009 and 2013, respectively. The public utilities cannot meet these emission caps by purchasing emission credits. The EPA approved th e statewi de emissions caps a s part
of the Charlotte SIP on September 26, 2011

. In 20 1 3 , the power plants subject to this
law had combined NOx emissions of 3 8

, 857 tons/year, well below the 56,000 tons/year cap. The emissions cap has been met in all subsequent year s as well. These
emission s limits are enforceable at both the federal and state level.

 Boiler NESHAP: Because of delays associated with the EPA’s promulgation of the boiler NESHAP, North Carolina adopted and implemented equivalent emission
limitations b y permit under Section 112(j) of the CAA. 13 These limitations apply to owners and oper ators of industrial, commercial and institutional boilers and process heaters burning natural gas, coal, oil or biomass beginning in 2013. These emission s limits are enf

orceable at both the federal and state level.

 Transportation Conformity Memorandum of Agreements (MOAs): The Conformity MOAs are signed by federal and state transportation agencies and local air quality organizations and the MPOs subject to transportati on conformity requirements for applicable transportation

- related NAAQs and satisf ies the requirement in the CAA
S ection 176(c). The DAQ chose through rulemaking to develop Conformity MOAs to ensure that interagency consultation procedures for transportati on conformity are followed in each of the nonattainment or maintenance areas in the state.

12 Approval and Promulgation of Implementation Plans; North Carolina; Inspection and Maintenance Program Updates, 80 FR, 6455.

13 15A NCAC 02D .1109

- 112(j) Case

- by

- Case Maximum Achie vable Control Technology.Charlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 2.4 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE

This section provides a brief summary of state and local programs that have been impl emented in
the Charlotte area to maintain compliance with the NAAQS. Although these are important

programs that help to ensure compliance with the NAAQS, they have not been relied upon as federally enforceable measures . These state and local program s are more fully described in
Section 3. 3

.

S tate programs that have been implemented include:

 Air awareness program: The North Carolina Air Awareness Program is a public outreach and education program of the DAQ. The goal of the program is to reduce air pollution though voluntary actions by individuals and organizations. The program seeks to educate individuals about (1) the sources of air pollution; (2) the health effects of air pollution and how these effects can be mitigated by modification of outdoor activities on ozone action days; and (3) simple "action tips", such as carpooling, vehicle maintenance and energy conservation that reduce individual contributions to air pollution. One of the major program components is the daily air quality forecast. The DAQ produces the 8

- hour ozone forecasts and corresponding air quality index for the Charlotte forecast area from April 1 through October 31 of each year. 14 Additionally, the DAQ produces daily PM forecasts for the Charlotte

area.

 Grant Program: The DAQ has offered multiple forms of g rant funding from state
and federal funds to help cover the costs associated with emission reduction projects
across the state

. These projects include diesel engine replacements, diesel oxidation catalyst retrofits, marine diesel repowers , replacing gasol ine vehicles with electric vehicles, vehicle replacement and many more. Grant projects that have been awarded have helped to reduce PM, NO x , CO and VOC emissions from mobile

sources.

 Open burning rule: This rule prohibits open burning of man

- made materia ls throughout the state. Additionally, the rule prohibits open burning of yard waste in areas that the DAQ forecasts air quality action days. The open burning regulation reduces NOx, VOC, and CO emissions as well as PM with an aerodynamic diameter
less t han or equal to 10 micrometers (PM 10 ) and 2.5 micrometers (PM 2.5 ).

14 See N.C. DAQ http://www.ncair.org/airaware/

.Charlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015  Idle Reduction Regulation: The North Carolina Environmental Management Commission adopted the Heavy

- Duty Vehicle Idling Restrictions rule to reduce unnecessary idling of heavy

- duty truck s on July 9, 2009 and the rule became effective on July 10, 2010. This rule generally prevents any person who operates a heavy

- duty vehicle to cause, let, permit, suffer or allow idling for a period of time in excess of 5 consecutive minutes in any 60 min ute period. This rule is state
enforceable

.

L ocal p rogram that have been implemented include:

 Open Burning Prohibition: M ecklenburg County prohibits open burning of any kind year round , except under extenuating circumstances with an approved burn permit

. This prohibit ion is more stringent than the s tate’s open burning r ule and therefore
enhances this control measure ’s overall benefit to the region. The open burning rule
reduces NOx, VOC, CO, PM 10 and PM 2.5

. These emission reductions are enforceable

at the local level.

 GRADE Program: In 2007, MCAQ initiated an air pollution control program called GRADE designed to reduce NOx emissions in the Charlotte nonattainment

area. Funded by federal, state and local county grant money, GRADE provides
businesses and organizations financial incentives to replace or repower heavy

- duty

non

- road equipment with newer, cleaner, less polluting engines. GRADE has funded cost effective emission reduction projects operating in multiple segments of the economy including co nstruction, landfills, timber logging operations, open pit mining, freight transportation, and commercial aviation. As of July 31, 2014, GRADE projects have reduced over 350 tons of NOx region

- wide.

 Mobile S ource E mission s R eduction G rants: This progra m reduce s NOx

, PM, and VOC emissions. MCAQ has also received DERA funding as well as American Recovery and Reinvestment Act (ARRA) and Congestion Mitigation and Air Quality Improvement (CMAQ) program funding. These funds have been used to repower or repl ace existing diesel engines from on

- road vehicles and nonroad equipment. Even though these emission reductions are voluntary and not enforceable, they are still considered permanent reductions.

2.5 EFFECT NOX CONTROL PROGRAM S ON OZONE LEVELS

The founda tion control program for stationary and mobile sources for the Charlotte area has significantly reduced NOx emissions enabling the area to demonstrate attainment with the 2008Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 15

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 ozone NAAQS. As an example, h istorically EGUs have been a significant source of NOx emissions contributing to ozone formation during the summer months in the Charlotte area as
well as statewide. A recent review of the NOx emissions in the EPA’s Air Markets Program
Data databas e shows a reduction in over 96,641 tons of NOx from the r eporting sources in North
Carolina between 2002 and 2013. The trend in decreasing NOx emissions from these facilities are attributable to a combination of state (Clean Smoke Stacks Act) and federal (CAIR / CSAPR) measures and market forces (switching from coal to natural gas due to favorable natural gas prices)

. Table 2. 4 presents the annual emissions for the North Carolina sources obtained from
the EPA ’s Air Markets Program Data database.

Table 2.5 shows trends in NOx emissions from 2002 through 2013 f rom North Carolina power plants in the Charlotte nonattainment area, as well as the power plants located directly north and west of the Charlotte region that may impact the nonattainment area. There are four facilities located within Gaston, Lincoln and R owan Counties. The facility west of the Charlotte nonattainment area is Cliffside, located in Cleveland County and the facility north of the

Table 2

. 4 NOx Emissions from NC Sources in EPA ’s Air Markets Progr am Data base

Year Annual NOx Emissions from NC Sources ( t ons) 2002 14 5

, 706 2003 135

, 879 2004 124

, 079 2005 114,300 2006 108,584 2007 64,770 2008 61,669 2009 44,506 2010 57,305 2011 48,889 2012 51,057 2013 49,065

Charlotte nonattainment area is M arshall located in Catawba County

. Th ese data are taken from
the EPA Clean Air Markets Division’s (CAMD) Air Markets Program Data and represent the second and third quarters of the year (April through September), the period during which ozone
levels are t he highest. T he emissions from these facilities have significantly decreased during the ozone season since 2002, with over 12,000 tons of NOx reduction in the 201 3 ozone season compared to 2002. In addition, t wo coal

- fired power plants (Buck and Riverben d) were retired
in April 2013

, which result ed in additional emissions reductions.Charlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Table 2

. 5 April 1 through September 30 NOx Emissions for Electric Utilities Near
Charlotte Area (tons/period)

Facility Coun ty 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Allen * Gaston 5,011 3,643 4,002 3,589 3,001 3,053 3,082 2,188 2,925 2,738 1,676 1,906 Riverbend * Gaston 2,556 2,703 1,844 1,379 1,417 1,296 1,256 304 1,063 884 109 0 Lincoln * Lincoln 44 20 5 0 20 52 81 33 6 40 46 10 22 Buck * Rowan 1,084 1,468 1,089 1,286 1,262 870 832 197 783 477 196 61 Marshall Catawba 9,283 9,101 8,243 7,558 6,370 7,253 7,151 4,481 4,861 5,443 5,128 4,777 Cliffside Cleveland 1,944 2,149 1,738 1,782 1,540 1,311 1,173 561 3 57 469 267 673 Total

----- 19,922 19,084 16,966 15,614 13,642 13,864 13,527 7,737 10,029 10,057 7,386 7,439

* Facility is l ocated within the Charlotte nonattainment area boundary.

Temperature is a key meteorological factor that determine s the ozone produc tion potential of a given day. In North Carolina, many exceedances occur when the maximum daily temperature is 90 degrees Fahrenheit (oF) or greater. In recent years, however, foundation control program
measures have reduced NOx emissions in the Charlott e area to the ext ent that recent trends are showing that ozone levels are lower than the NAAQS even when the daily temperature is 90 oF
or greater. Figure 2. 2 shows the relationship of exceedance days to high tempera ture days from 2000 through 2014 for th e Charlotte region monitors. The relationship between the maximum 4 th highest ozone value to high tempera ture days from 2000 through 2014 is displayed in Figure 2. 3

.

It is important to see how the ozone levels have changed over the last decade in respon se to lower NOx emissions in the state. The worst summer in terms of the number of exceedance days
and observed 4 th highest ozone concentrations was 2002, with 61 exceedance days in the Charlotte region and a maximum 4 th highest daily average 8

- hour conce ntration of 0.108 ppm. That summer there were 49 days when the temperature was 90 oF or greater in the Charlotte region. The next highest number of exceedance days occurred in 2007 with 56 days and 74 days with temperatures at or above 90 °F, yet the max imum 4 th highest daily average 8

- hour concentration was significantly lower than 2002 at 0.096 ppm. More recently, in the year 2010, the Charlotte area experienced the hottest summer of the 21 st century with 86 days at or above 90 °F. However, the Charlo tte area only observed 17 exceedance days and the maximum 4 th highest daily average concentration was only 0.082 ppm. In subsequent years, the 4 th

- highest values have generally decreased as the number of very hot days over 90 degrees has moderated. In
20 14, there were a total of 37 days with a high temperature over 90 degrees, but no exceedances
of the 2008 8

- hour ozone standard and a peak 4 th highest daily average value of 0.068 ppm. The steady decrease of ozone values over the last 15 years regardless of summertime temperature regime illustrates the progress that North Carolina has made and the positive effects of the control strategies put in place by North Carolina, Mecklenburg County and the EPA to regulate
NOx emissions.Charlotte

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- hour Ozone Marginal 17

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Figure 2

. 2 Relationship between high temperature days and number of exceedance days in
the Charlotte area

Figure 2

. 3 Relationship between high temperature days and maximum 4 th highest ozone value in the Charlotte Area 0 10 20 30 40 50 60 70

0 10 20 30 40 50 60 70 80 90 100

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 # Exceedance Days # Days High Temp at least 90F

May - Sept.

#Days T >= 90F #Days O3 >=76PPB

0.06 0.065 0.07 0.075 0.08 0.085 0.09 0.095 0.1 0.105 0.11

0 10 20 30 40 50 60 70 80 90 100

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Max 4th - highest value # Days High Temp at least 90F

May - Sept.

#Days T >= 90F Max. 4th HighestCharlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 

### 3.0 MAINTENANCE PLAN

3.1 CONCEPT OF NORTH CAROLINA'S MAINTENANCE PLAN

The s tate's plan for maintaining compliance with the ambient air quality standard for the 2008
8

- hour ozone in the Charlotte

- Gastonia

- Salisbury nonatt ainment area consists of three major
parts: a foundation control program, a maintenance demonstration, and a contingency plan. The foundation control program consists of the current federal and state control measures already in effect, as well as the fut ure benefits of the federal actions. For EGUs, the future federal actions
include implementation of the MATS

, CSAPR , and carbon rules and the TVA consent decree

. Additionally, North Carolina will continue to implement and enforce the Clean Smokestacks
Ac t. For on

- road vehicles, the future federal actions include compliance with the Tier 3 vehicle
emissions and fuel standards and corporate average fuel economy standards for on

- road vehicles. Although North Carolina did not rely on the emission reductions from CSAPR or the TVA
consent decree for maintenance of the 2008 8

- hour ozone standard, these actions will result in additional reductions in NOx emissions regionally.

The foundation control program includes federally and state enforceable control program s that
have been ado pted and implemented by the DAQ. T hese programs will remain enforceable and

e nsure that maintenance of the 2008 8

- hour ozone standard will continue. Sources are prohibited from reducing or removing emission controls (anti

- backsliding) following the redesignation of the area unless such a change is first approved by the EPA as a revision to the North Carolina SIP that is consistent with Section 110(l) of the CAA

.

For the maintenance demonstration, the base year of 20 1 4 was chosen since it is a year that falls within the attaining design value period of 20 12

- 20 1 4

. The interim years 2015, 20 1 8 and 20 2 2
were chosen based on consultation with the EPA . The final year of the maintenance
demonstration is 20 2 6 , since the CAA requires maintenan ce for at least 10 years after the EPA approves the redesignation demonstration and maintenance plan . The maintenance demonstration consists of a comparison between the 20 1 4 baseline emissions inventory and the projected emissions inventories (for 2015, 2 0 1 8 , 20 22 , and 20 2 6 ), which consider economic and population growth. The comparison shows that the total emissions in each of the interim years and the final year is estimated to be lower than in the base year, which demonstrates maintenance
of the 2008 8

- hour ozone standard. The reductions in emissions are due to the foundation control programs outlined below.

The North Carolina contingency plan involves tracking and triggering mechanisms to determine when contingency measures are needed and a process of implementing appropriate control measures. The primary trigger of the contingency plan will be a violation of the ambient airCharlotte

- Gastonia

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 quality standard for 2008 8

- hour ozone standard . The secondary trigger will be a monitored air quality pattern that suggests an actual 2008 8

- hour ozone NAAQS violation may be imminent.

The SCDHEC ha s develop ed a redesignation demonstration and maintenance plan for the South Carolina portion of the nonattainment area. Contact the SCDHEC for a copy of the South
Carolina redesi gnation demonstration and maintenance plan

.

3.2 FOUNDATION CONTROL PROGRAM

The main element of the maintenance plan is the foundation control program. The foundation control program consists of a combination of federal and state control measures necessar y to maintain the ambient air quality standards. The purpose of the foundation control program is to prevent the ambient air quality standards from being violated and thereby eliminate the need for more costly controls being imposed on industry and the ge neral public. Each component of the foundation control program is essential in demonstrating maintenance of the air quality
standards. The following provides a summary of each federal and state control measure included in the foundation control program f or the Charlotte nonattainment area. All of these programs have already been implemented or are in the process of being implemented.

3.2.1 Federal Control Measures

Tier 2 Vehicle and Fuel Standards
Federal Tier 2 vehicle standards require all passenger v ehicles in a manufacturer’s fleet, including light

- duty trucks and sport utility vehicles (SUVs), to meet an average standard of 0.07

gram / per mile of NOx . Implementation began in 2004, with full compliance required by 2007.
The Tier 2 standards also cov er passenger vehicles over 8,500 pounds gross vehicle weight rating (the larger pickup trucks and SUVs), which are not covered by the Tier 1 regulations. For these vehicles, the standards were phased in beginning in 2008, with full compliance required by
2009. The Tier 2 standards require vehicles to be 77% to 95% cleaner. The Tier 2 rule also reduced the sulfur content of gasoline to 30 ppm starting in January of 2006. Most gasoline sold in North Carolina prior to January 2006 had a sulfur content of a bout 300 ppm. Sulfur occurs naturally in gasoline and interferes with the operation of catalytic converters on vehicles, which results in higher NOx emissions. Lower

- sulfur gasoline is necessary to achieve the Tier 2
vehicle emission standards

. 15 These e mission reductions are federally enforceable.

15 Fact Sheet, Office of Mobile Sources, EPA

- 420

- F

- 99

- 051, December 1999.Charlotte

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- Salisbury , NC 2008 8

- hour Ozone Marginal 20

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Tier 3 Vehicle and Fuel Standards

Federal Tier 3 vehicle standards require all passenger vehicles in a manufacturer’s fleet, including light

- duty tru cks and SUVs, to meet an average standard of 0.0 3 gram / per m ile of
NOx

. Heavy

- duty passenger vehicles must meet average standard s of 0.178 to 0. 247 gram / per mile of NOx depending on vehicle classification. Implementation beg i n s in 20 17 , with full compliance required by 20 25

. Compared to current standards in 2014 , the Tier 3 tailpipe standards for light

- duty vehicles are expected to reduce non

- methane organic gases (NMOG) and NOx by approximately 80%. The Tier 3 program is expected to reduce per

- vehicle PM standards by approximately 70%. The heavy

- duty tailpipe standards represent about a 60% reduction in both fleet average NMOG+NOx and per vehicle PM standards. Tier 3 vehicle
standards also require evaporative standards including OBD that will result in a 50% reduction in
VOC emissions from Tier 2 for all 2017 and later light

- duty and on

- road gasoline

- powered heavy

- duty vehicles. The Tier 3 rule also reduced the sulfur co ntent of gasoline to 1 0 ppm starting in January 2017. Tier 2 standards had limited the sulfur content to 30 ppm. Sulfur occurs naturally in gasoline and interferes with the operation of catalytic converters on vehicles, which results in higher NOx emissions

. 16 These emission reductions are federally enforceable. 17

National Program for G HG Emissions and Fuel Economy Standards

T he EPA and the Nat ional Highway Traffic Safety Administration (NHTSA) jointly developed
the federal GHG and fuel economy stan dards for light

- duty cars and trucks in model years 2012

- 2016 (phase 1 ) and 2017

- 2025 (phase 2 ). The EPA also aligned implementation of the Tier 3

p rogram with the second phase of the EPA and NHTSA federal GHG and fuel economy

stan dards program. Together, phases 1 and 2 of the final standards are projected to result in an average industry fleet

- wide level of 163 grams/mile of CO 2 in model year 2025, which is equivalent to 54.5 mpg if achieved exclusively through fuel economy improv ements. 18 The fuel economy standards will result in less fuel being consumed, and therefore less NOx emissions
released

. These emission reduc tions will be federally enforcea ble.

Heavy

- Duty Gasoline and Diesel Highway Vehicles Standards
The EPA standards designed to reduce NOx and VOC emissions from heavy

- duty gasoline and diesel highway vehicles began to take effect in 2004. A second phase of standards and testing procedures that began in 2007 reduced PM from heavy

- duty highway engines and also reduced highway diesel fuel sulfur content to 15 ppm since the sulfur damages emission control devices. The total program is expected to achieve a 90% reduction in PM emissions and a 95% reduction

16 Fact Sheets, Office of Transportation and Air Quality, EPA

- 42 0

- F

- 14

- 008 and EPA

- 420

- F

- 14

- 009, March 2014.

17 See U.S. EPA, http://www.epa.gov/otaq/tier3.htm

. 18 See U.S. EPA, http://www.epa.gov/otaq/cli mate/regs

- light

- duty.htm

.Charlotte

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- hour Ozone Marginal 21

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 in NOx emissions for these new engines using low

- sulfur diesel, compared to engines using higher

- content sulfur diesel. These emission reductions are federally enforceable.

Large Nonroad Diesel Engines Rule
In May 2004, the EPA promulgated n ew rules for large nonroad diesel engines, such as those used in construction, agricultural and industrial equipment, to be phased in between 2008 and
2014. The nonroad diesel rules also reduced the allowable sulfur in nonroad diesel fuel to 15 ppm. Prio r to the fuel standard change, nonroad diesel fuel averaged about 3,400 ppm sulfur. The combined engine and fuel rules are expected to reduce NO x and PM emissions from large nonroad diesel engines by over 90 %

. 19 These emission reductions are federally enf orceable.

Medium

- and Heavy

- Duty Vehicle Fuel Consumption and GHG Standards
In September 2011, the EPA and the NHTSA promulgated joint rules to reduce GHG emissions and improve fuel efficiency of combination tractor trucks, heavy

- duty pickups and vans, and vocational trucks beginning with model year 2014 and applying to all model years by 2018. Depending on truck type, the on

- road vehicles must achieve from a 7% to 20% reduction in CO 2 emissions and fuel consumption from the 2010 base year. The decrease i n fuel consumption will
result in a 7% to 20% decrease in NOx emissions. 20 These emission reductions are federally
enforceable.

Nonroad Spark

- Ignition Engines and Recreational Engines Standard
The nonroad spark

- ignition and recreational engine standards, e ffective in July 2003, regulates
NOx , hydrocarbons and CO for groups of previously unregulated nonroad engines. These engine standards apply to all new engines sold in the United States and imported after these standards began and applies to large spark

- i gnition engines (forklifts and airport ground service equipment), recreational vehicles (off

- highway motorcycles and all

- terrain

- vehicles), and recreational marine diesel engines. The regulation varies based upon the type of engine or
vehicle.

The large s park

- ignition engines contribute to ozone formation and ambient CO and PM levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like the large spark

- ignition, recreational vehicles contribute to ozone formatio n and ambient CO and
PM levels. For the off

- highway motorcycles and all

- terrain

- vehicles, the exhaust emissions standard was phased

- in. Fifty percent of model year 2006 engines had to meet the standard and for model years 2007 and later, all engines must meet the standard. Recreational marine diesel

19 See U.S. EPA http://transportpolicy.net/index.php?title=US:_Heavy

- duty:_Fuel_Consumption_and_GHG

20 Fact Sheet, Office of Trans port and Air Quality, EOA

- 420

- F

- 11

- 031, August 2011.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 22

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 engines over 37 kilowatts are used in yachts, cruisers, and other types of pleasure craft. Recreational marine engines contribute to ozone formation and PM levels, especially in marinas. Depending on the si ze of the engine, the standard began phasing

- in in 2006.

When the nonroad spark

- ignition and recreational engine standards are fully implemented in 2020, an overall 72% reduction in hydrocarbons, 80% reduction in NO x , and 56% reduction in
CO emissions ar e expected. These controls will help reduce ambient concentrations of ozone, CO, and fine PM. 21 These emission reductions are federally enforceable.

C AIR and C SAPR
On May 12, 2005, the EPA promulgated the CAIR which required reductions in emissions of
NOx and SO 2 from large fossil fuel fired EGUs. CAIR also allowed non

- EGU industrial boilers

to participate in the program to meet their NOx SIP Call requirements. 22 The U.S. Court of Appeals for the D.C. Circuit ruled on petitions for review of CAIR and CAIR Federal Implementation Plans (FIP s ), including their provisions establishing the CAIR NOx annual and
ozone season and SO 2 trading programs. On July 11, 2008, the Court issued an opinion vacating and remanding these rules. However, parties to the litigat ion requested rehearing of aspects of the Court's decision, including the vacatur of the rules. On December 23, 2008, the Court remanded the rules to the EPA without vacating them. The December 23, 2008 ruling left CAIR in place until the EPA issued a ne w rule to replace CAIR in accordance with the July 11, 2008
decision.

The EPA issued CSAPR in July 2011 to address CAA requirements concerning interstate transport of air pollution an d to replace the previous CAIR which the D.C. Circuit remanded to
the EPA for replacement. Following the original rulemaking, CSAPR was amended by three further rules known as the Supplemental Rule, the First Revisions Rule, and the Second Revisions Rule. As amended, CSAPR requires 28 states to limit their state

- wide emission s of
SO 2 and/or NOx in order to reduce or eliminate the states’ contributions to fine PM and/or ground

- level ozone pollution in other states. The emissions limitations are defined in terms of
maximum state

- wide “budgets” for emissions of annual SO 2 , annua l NOx, and/or ozone

- season NOx by each state’s large EGUs.

As the mechanism for achieving compliance with the emissions limitations, CSAPR establishes
FIP s that require large EGUs in each affected state to participate in one or more new emissions trading programs that supersede the existing CAIR emissions trading programs. Non

- EGU

21 Final Rule: Control of Emissions from Nonroad Large Spark

- Ignition Engines, and Recreational Engines (Marine and Land

- Based), 67 FR 68242.

22 In 2009, the NOx SIP Call program was replaced by CAIR.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 23

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 boilers are not able to participate in CSAPR, resulting in a group of “orphaned” industrial units that are still subject to the NOx SIP Call. Interstate trading of CSAPR’s emi ssion allowances is permitted, but the rule includes “assurance provisions” designed to ensure that individual states’ emissions do not exceed the states’ respective emissions budgets. CSAPR allows states to elect to revise their SIPs to modify or replace the FIP s while continuing to rely on the rule’s trading programs for compliance with the emissions limitations, and establishes certain requirements and deadlines related to those optional SIP revisions. The rule also contains provisions that sunset
CAIR compliance requirements on a schedule coordinated with the implementation of CSAPR compliance requirements.

Certain industry and state and local government petitioners challenged CSAPR in the D.C. Circuit and filed motions seeking a stay of the rule pen ding judicial review. On December 30, 2011, the Court granted a stay of the rule, ordering the EPA to continue administering CAIR on an interim basis. In a subsequent decision on the merits, the Court vacated CSAPR based on a subset of petitioners’ claim s, but on April 29, 2014, the U.S. Supreme Court reversed that decision and remanded the case to the D.C. Circuit for further proceedings. Throughout the initial round of D.C. Circuit proceedings and the ensuing Supreme Court proceedings, the stay
remaine d in place and the EPA h as continued to implement CAIR. Following the Supreme Court decision, in order to allow CSAPR to replace CAIR in an equitable and orderly manner while further D.C. Circuit proceedings are held to resolve petitioners’ remaining clai ms, the EPA filed a motion asking the D.C. Circuit to lift the stay and to toll by three years all CSAPR compliance deadlines that had not passed as of the date of the stay order. On October 23, 2014, the Court granted the EPA’s motion.

CSAPR will take effect starting January 1, 2015 for SO 2 and annual NO x , and May 1, 2015 for
ozone season NO x

. Combined with other final state and EPA actions, the CSAPR will reduce power plant SO 2 emissions by 73% and NOx emissions by 54 % from 2005 levels in the CSAPR

re gion

. 23 The emission reductions will be federally enforceable.

TVA Consent Decree

I n Jan uary 2009 a federal court found that four TVA coal

- fired generating stations we re creating a public nuisance in North Carolina. The judge ordered that each unit of each facility install modern pollution controls for SO 2 and NOx and meet emission limits that are consistent with the continuous operation of such controls. The court ordered that TVA meet these limits on a staggered schedule ending in 2013. I n July 2010 an appeals court reversed the decision.

23 I nterim Final Rule: Rulemaking To Amend Dates in Federal Implementation Plans Addressing Interstate Transport of Ozone and Fine Particulate Matter, 79 FR 71663.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 24

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 In April 2011 North Carolina, TVA, and several other parties agreed to a comprehensive settlement of a variety of air pollution allegations. The detailed settlement would (1) subject SO 2 and NOx emissions at all of TV A’s coal

- fired facilities to system

- wide caps that decline on an annual basis to permanent levels of 110,000 tons of SO 2 in 2019 and 52,000 tons of NOx in 2018; (2) require TVA to install modern pollution controls on or shutdown the majority of its
coal

- fi red units; and (3) require TVA to pay North Carolina $11.2 million to fund mitigation projects in North Carolina. The settlement is being successfully implemented, including the provision of funds directly to North Carolina for approved projects

. 24 These emission reductions are federally enforceable.

Boiler NESHAP

The NESHAP for the industrial, commercial and institutional boiler source category is applicable to boilers and process heaters burning natural gas, coal, oil or biomass. Boilers must comply
wit h the NESHAP by January 31, 2016 for all states except North Carolina (see state control

measur e S ection 3.2.2 below for further discussion) and by May 2019 for boilers in North Carolina. The NESHAP contains work practice standards such as annual boiler t une ups for most boilers. There are also emissions standards for the largest emitting boilers (<1% of all boilers) including a CO standard that is a surrogate for gas

- phase hazardous air pollutant s ( HAP s ) and VOC. There is estimated to be a small reducti on in VOC emissions due to the
NESHAP. 25 These new emission reductions are federally enforceable.

RICE NESHAP

The RICE NESHAP applies to stationary engines burning natural gas and diesel fuels that generate electricity and power equipment at industrial, ag ricultural, oil and gas production, power generation and other facilities. RICE owners and operators had to comply with the NESHAP by May 3, 2013. The NESHAP contains work practice standards such as eng ine maintenance, requires ultra low

- sulfur diesel fue l for some engines, and requires the use of catalytic converters on larger engines. There is estimated to be a slight reduction in VOC
emissions due to the NESHAP. 26 These emission reductions are federally enforceable.

Utility MATS and NSPS Rules

On Febru ary 16, 2012 , the EPA published final rules for both the (1) MATS for new and existing
coal

- and oil

- fired EGUs and (2) NSPS for fossil

- fuel fired electric utility, industrial

-

24 http://www.ncdoj.gov/getdoc/bdf66401

- 8137

- 4be2

- bd20

- 57e89b570c1a/TVA

- signed

- consent

- decree.aspx

. 25 See U.S. EPA http://www.epa.gov/ttn/atw/boiler/boilerpg.html

. 26 See U.S. EP A http://www.epa.gov/ttn/atw/icengines/

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 25

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 commercial

- institutional and small industrial

- commercial

- institutional steam gen erating units. 27 The MATS reduce emissions of toxic air pollutants from EGUs larger than 25 megawatts that burn coal or oil for the purpose of generating electricity for sale and distribution through the national electric grid to the public. For the NSPS, the EPA revised the standards that new coal

and oil

- fired power plants must meet for NOx, SO 2 , and PM.

Following promulgation of the final rules, the EPA received petitions for reconsideration of various provisions of both rules , including requests to reconsider the work practice standards applicable during startup periods and shutdown periods that were included in the final rule. The EPA granted reconsideration of the startup and shutdown provisions because the public was not provided an opportunity t o comment on the work practice requirements contained in the final
rule. On November 30, 2012, the EPA published a proposed rule reconsidering certain new source standards issued in MATS and the startup and shutdown provisions in MATS and the Utility NSPS

. 28 The EPA proposed certain minor changes to the startup and shutdown provisions contained in the 2012 final rule based on information obtained in the petitions for
reconsideration. On April 24, 2013

, the EPA took final action on the new source standards that were reconsidered and also the technical corrections contained in the November 30, 2012, proposed action. 29 The EPA did not take final action on the startup and shutdown provisions, and, on June 25, 2013

, the EPA added new information and analysis t o the docket and reopened the public comment period for the proposed revisions to the startup and shutdown provisions in MATS and the startup and shutdown provisions related to the PM standard in the Utility NSPS.

30 The EPA took final action on the remain ing topics of the reconsideration on November 19,
2014. 31 The compliance date for existing sources is April 16, 2015, while the compliance date for new sources is April 16, 2012.

On November 25, 2014, The U.S. Supreme Court accepted several challenges to the rules brought by the utility industry and a coalition of nearly two dozen states. The court will hear arguments in the case in the spring and is likely to rule in June 2015. 32 While MATS is still under court review, and portions of it may be overturne d, the rule can be expected to result in the
reduction of both NOx and SO 2 emissions in addition to the reduction in mercury and other air toxic emissions. The emission reductions are federally enforceable.

27 77 FR 9304.

28 77 FR 71323.

29 78 FR 24073.

30 78 FR 38001.

31 79 FR 68777.

32 Wall Street Journal, Nov. 25, 2014, Supreme Court to Review EPA Rule on Power Plant E missions, http://www.wsj.com/articles/supreme

- court

- to

- review

- epa

- rule

- on

- power

- plant

- emissions

1416942022?mod=WSJ_newsreel_6

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 26

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 3.2.2 State Control Measures

North Carolina has adopted a number o f regulations

, legislation and voluntary programs to
addre ss pollution issues across the s tate. These are summarized below.

Vehicle Emissions Inspection and Maintenance (I/M) Program
The 1999 Clean Air Bill expanded the vehicle emissio ns I/M program in North Carolina from 9 counties to 48 counties from July 1, 2002 through January 1, 2006. Vehicles are tested using the OBDII, an improved method of testing, which ensure s proper emission system operation for vehicles and light trucks dur ing their lifetime by monitoring emission

- related components and systems for malfunction and/or deterioration

. An important aspect of OBDII is its ability to notify the driver of malfunction and/or deterioration by illuminating the "check engine light"

. If the vehicle is taken to a repair shop in a timely fashion, it can be properly repaired before any significant and prolonged e mission increase occur s

. The previously used tailpipe test (i.e., idle test) did not measure NOx emissions; it only tested for VOC and CO emissions. By utilizing the OBDII test method, the NOx emissions as well as other pollutants from motor vehicles are reduced. The effective dates for the counties in the North Carolina portion of the Charlotte
nonattainment area are July 1, 20 02 for Cabarrus, Gaston, Mecklenburg and Union Counties; July 1, 2003 for Iredell and Rowan Counties; and January 1, 2004 for Lincoln County.

The I/M program rule was submitted to the EPA for adoption into the SIP in August 2002 and was federally approve d in October 2002. Therefore, these emission reductions are both state and federally enforceable.

On February 5, 2015, the EPA approved a change to North Carolina’s I/M rules triggered by a state law which exempted plug

- in vehicles and the three newest model year vehicles with less than 70,000 miles on their odometers from emission inspection in all areas in North Carolina where I/M is required. 33 In North Carolina’s Section 110(l) demonstration, the state showed that the change in the compliance rate from 95% to 96% more than compensate s for the NOx and
VOC emissions increase from exempting the newest model year vehicles with less than 70,000
miles . Based on recent modeling the DAQ completed using the EPA’s MOVES2014 model,
North Carolina’s current I/ M program with the the three newest model year vehicle exemption is expected to yield annual I/M emission reduction benefits ranging from 5% to 8% for NOx and
6% to 8.5% for VOC. The EPA

- ap proved change to the I/M rules wa s effective March 9, 2015.
The em issions reductions are state and federally enforceable.

33 Approval and Promulgation of Implementation Plans; North Carolina; Inspection and Maintenance Program Updates, 80 FR, 6455.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 27

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Clean Smokestacks Act
In June 2002, the North Carolina General Assembly enacted the North Carolina Clean Smokestacks Act, which required coal

- fired power plants in North Carolina to reduce annual
NOx emissions by 7 7 % by 2009. 34 These power plants were also required to reduce annual SO 2 emissions by 49% by 2009 and 74% by 2013. The utilities have reduced NOx emissions by 83%
and SO 2 emissions by 89% relative to 1998 emissions levels.

With the requir em ent to meet annual emissions caps and dis allowing the purchase of NOx credits to meet the caps, the Clean Smokestacks Act reduces NOx emissions beyond the requirements of
the NOx SIP Call Rule. Th e CSA emissions caps were submitted to the EPA for adoption into the SIP in August 2009 and were approved in September 2011. These regulations are both state and federally enforceable.

Boiler NESHAP
Because of delays associated with the EPA’s promulgation of the boiler NESHAP, North Carolina adopted and implement ed e quivalent emission limitation s by permit under Section 112(j) of the CAA. 35 These limitations apply to owners and operators of industrial, commercial and institutional boiler boilers and process heaters burning natural gas, coal, oil or biomass beginni ng in 2013. This rule reduced uncertainty for owners and operators of affected emission
units while the EPA resolv ed legal challenges to the federal rule, reduced emissions from affected units three years earlier than the federal rule, and provided the ti me needed for owners and operators to transition to the federal rule requirements beginning in May 2019. 36 Although the rule establishes limits for reducing HAP s form boilers and process heaters, VOC emissions
will also be controlled. In the Charlotte are a, natural gas fired boilers are the only types of emission units affected by this rule. For natural gas fired boilers, VOC emissions are estimated to be reduced by 4%. The emission limits associated with this rule are state and federally
enforceable.

T ransportation Conformity MOAs
Transportation conformity MOAs establish criteria and procedures related to interagency consultation, conflict resolution, public participation and enforceability of certain transportation related control measures and mitigati on measures in the State of North Carolina and its SIP.

34 Air Quality/Electric Utilities Bill (SB 1078), http://daq.state.nc.us/news/le g/

. 35 15A NCAC 02D .1109

- 112(j) Case

- by

- Case Maximum Achievable Control Technology.

36 See U.S. EPA http://www.epa.gov/ttn/atw/boiler/boilerpg.html

.Charlotte

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- Salisbury , NC 2008 8

- hour Ozone Marginal 28

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Transportation conformity is required under section 176(c) of the CAA for nonattainment and maintenance areas to ensure that federally supported highway projects, transit projects, and other
activiti es are consistent with (conform to) the purpose of the SIP, which is to eliminate or reduce the severity and number of violations of the NAAQS and to achieve expeditiously the attainment of such standards. In compliance with Section 176(c) of the CAA, Nort h Carolina Department of Environment and Natural Resources, Division of Air Quality chose, through rulemaking as
referenced in 15A North Carolina Administrative Code ( NCAC ) 02D.2005, to develop Conformity MOAs to ensure that interagency consultation proced ures for transportation conformity are followed. 37 The Conformity MOAs were submitted to the EPA on July 12, 2013.
The USEPA , through direct final rule action, approved a revision to the North Carolina SIP with the effective date of February 24, 2014. 38

3. 3 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE

This section provides a summary of state and local programs that have been implemented in the Charlotte area to maintain compliance with the NAAQS. Although these are important programs that help to ensure com pliance with the NAAQS, they have not been relied upon as federally
enforceable measures

.

3.3.1 State Programs Supporting Maintenance
Air Awareness Program
The DAQ has found that the most effective outreach programs are performed by locally

- based

person nel who can work closely with members of the local community. The DAQ has contracted with MCAQ to manage the Charlotte area North Carolina Air Awareness ( NCAA ) program since its inception in 1997. Charlotte area NCAA has conducted educational outreach
wi th the general public, built strong working relationships with regional interest groups, and developed communication resources for business coalition members. Coalition activities are designed to communicate air quality information, including the forecast , and promote voluntary emissions reduction programs. The business coalition includes partnerships with private businesses and civic organizations. These efforts are important for maintaining compliance with the NAAQS. Under MCAQ’s management, Charlotte area NCAA has established itself as a leader in advocating for voluntary pollution reduction efforts throughout the state’s only ozone nonattainment region.

37 http://www.ncair.org/rules/rules/D2005.pdf

. 38 78 FR 73266

- 78272.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 29

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Grant Program
Since 1995, the DAQ has offered multiple forms of grant funding to help cover the costs
associated with emission reduction projects. These projects include diesel engine replacements, diesel oxidation catalyst retrofits, marine diesel repowers , replacing gasoline vehicles with
electric vehicles and many more. One source of funding is t h e North Carolina Mobile Source Emissions Reduction Grants funded by gasoline tax receipts. The Mobile Source Emissions
Reduction Grant program has awarded grants to a number of businesses, cities, counties and
school districts that have ranged from the in stallation of Diesel Oxidation Catalysts (DOCs) or Diesel Particulate Filters (DPFs) on their diesel equipment to non

- diesel emission reduction projects like purchase of electric vehicles. The DAQ has also received federal funds from the
Diesel Emissions Reduction Act (DERA) and the American Recovery and Reinvestment Act (ARRA) to fund diesel emission reducing projects. The DERA and ARRA funds that the DAQ has received have been used to retrofit, repower or replace existing diesel engines from on

- road
and nonroad mob ile source vehicles/equipment. Even though these emission reductions are voluntary and not enforceable, they are still considered permanent reductions.

Open Burning Rule
The North Carolina open burning rule prohibits the burning of man

- made ma terials statewide.
The rule also prohibits open burning of yard waste and land clearing debris on forecasted code orange or higher "air quality action days" for those counties for which the DAQ or local air programs forecast ozone or fine PM. 39 The open b urning rule reduces PM, SO 2 , CO, NOx, and
VOC emissions. This rule is state enforceable.

Idle Reduction Regulation

The North Carolina Environmental Management Commission adopted the Heavy

- Duty Vehicle Idling Restrictions rule to reduce unnecessary idling of heavy

- duty trucks on July 9, 2009 and the rule became effective on July 10, 2010. This rule generally prevents any person who operates a heavy

- duty vehicle to cause, let, permit, suffer or allow idling for a period of time in excess of 5
consecutive mi nutes in any 60 minute period. This rule is state enforceable

.

3. 3

. 2 Local Programs Supporting Maintenance

Mobile Source Emission s Reduction Grants
In the Charlotte area, between 2011 and 2013, with funding from a settlement, a nonroad equipment repower was funded. This project resulted in significant fuel savings and reductions
in NOx and PM 2.5 emissions

.

39 15A NCAC 02Q.1900

– Open Burning.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 30

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 GRADE Program In 2007, MCAQ initiated an air pollution control program called GRADE designed to reduce
NOx emissions in the Charlotte nonattainment a rea. Funded by federal, state and local county grant money, GRADE provides businesses and organizations financial incentives to replace or repower heavy

- duty non

- road equipment with newer, cleaner, less polluting engines.
GRADE has funded cost effective emission reduction projects operating in multiple segments of the economy including construction, landfills, timber logging operations, open pit mining, freight transportation, and commercial aviation. As of July 31, 2014, GRADE projects have reduced

over 350 tons of NOx region

- wide.

O pen Burning Prohibitions Mecklenburg County prohibits open burning of any kind year round except under extenuating circumstances with an approved burn permit . This prohibition is more stringent than the state’s open burnin g rule and therefore enhances this control measure’s overall benefit to the region. The open burning rule reduces emissions of NOx, VOC, CO, PM 10 and PM 2.5

. These emission
reductions are enforce d at the local level.

3. 4 EMISSIONS INVENTORIES AND MAINTEN ANCE DEMONSTRATION

3. 4 .1 Theory of Approach
There are two basic approaches used to demonstrate continued maintenance. The first is the comparison of a projected emissions inventory with a baseline emissions inventory. The second approach involves comple x analysis using gridded photochemical modeling. The approach used by the DAQ is the comparison of emissions inventories for the years 20 1 4 and 20 2 6

.

For the maintenance demonstration, the base year of 20 1 4 was chosen since it is a year that falls
within the attaining design value period of 20 12

- 20 1 4

. The maintenance demonstration is made by comparing the 20 1 4 baseline summer day emissions inventory to the 20 2 6 projected summer day emissions inventory. The baseline summer day emissions inventory represen ts an emission level for a period when the ambient air quality standard was not violated, 20 12

- 20 1 4 . If the projected emissions remain at or below the baseline emissions, continued maintenance is demonstrated and it then follows, if the projected emission s remain at or below the baseline emissions, then the ambient air quality standard should not be violated in the future. In addition to comparing the final year of the plan, all of the interim years are compared to the 20 1 4 baseline
to demonstrate that th ese years are also expected to show continued maintenance of the 2008
8

- hour ozone standard.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 31

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 The emissions inventories are comprised of four major types of sources: point, area, on

- road
mobile and non road mobile. The projected summer day emission invento ries have been estimated using projected rates of growth in populat ion, traffic, economic activity and other parameters. Naturally occurring, or biogenic, emissions are not included in the emissions inventory comparison, as these emissions are outside the s tate’s span of control.

The SCDHEC ha s develop ed a redesignation demonstration and maintenance plan for the South Carolina portion of the nonattainment area. Contact the SCDHEC for a copy of the South
Carolina redesignation demonstration and maintenance plan

.

3. 4 .2 Emission Inventories
The base year and future year emissions inventory for this SIP includes the emissions associated with all emission sources in Mecklenburg County and the portion of the other six counties that is
included in the nonattai nment area. For point sources, the location coordinates for each facility were mapped using Geographic Information System ( GIS ) software to identify the facilities located within the nonattainment portion of each county. For the on

- road mobile, nonroad

m obile, and area source sectors, total county emissions were multiplied by the population percentages for the townships within the nonattainment area to calculate the emissions for the nonattainment portion for each county . Table 3

. 1 shows the population p ercentages that were used to determine emissions contributions for the nonattainment portion of each partial county (except for Mecklenburg County) . The population percentages were obtained from transportation demand model ing (TDM) that the Charlotte Depa rtment of Transportation completed to develop vehicle miles traveled (VMT) and vehicle speed data used as inputs to the

on

- road model for the base year a nd each of the future years.

The following provides a brief discussion on the four different man

- made emission inventory source classifications: (1) stationary point, (2) area, (3) on

- road mobile and (4) nonroad mobile.

Table 3

. 1 Population Percentages Used to Allocate Partial County Emissions

County Popula tion Percentage

2014 2015 2018 2022 2026 Cabarrus 99.4 99.4 99.5 99.5 99.5 Gaston 92.2 92.4 92.5 92.7 92.9 Iredell 44.2 44.5 45.3 46.1 46.6 Lincoln 83.3 83.3 83.6 83.8 84.1 Rowan 93.9 93.9 93.9 94.0 94.0 Union 87.6 87.5 87.5 87.6 87.6Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 32

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Point sourc es are those stationary sources that require an a ir p ermit to operate

. In general, these

sources have a potential

- to

- emit more than five tons per year of a criteria air pollutant or its

precursors from a single facility. The source emissions are tabulate d from data collected by
direct on

- site measurements of emissions or mass balance calculations utilizing emission factors
from the EPA’s AP

- 42 or stack test results. There are usually several emission sources for each facility. Emission data are collecte d for each point source at a facility and reported to the DAQ through its on

- line system.

Airports and rail yards are not required to have air quality permits for construction and operation (although they could have equipment such as a boiler or generato r that requires a permit). They do have fixed and known locations and their emissions quantities can be comparable to industrial sources so, for purposes of the EPA’s National Emission Inventory (NEI), they are included in the point source inventory even though they are traditionally considered nonroad sources.

For EGUs, base year 2014 average July day emissions were obtained from the EPA’s CAMD for the three Duke Energy Carolinas EGU facilities located in the Charlotte area (i.e., Allen in Gaston County , Lincoln in Lincoln County, and Buck in Rowan County). For the remaining Title V sources, the latest data available were the 2013 emissions data that the sources submitted to the DAQ , and, for these sources, 2013 emissions were used to represent 2014 bas e year emission

. For sources that emit less than 25 tons per year of NOx or VOC and are subject to
emission s statements requirements , the latest data available were the 2013 emissions data that the sources submitted to the DAQ, and, for these sources, 201 3 emissions were used to represent 2014 base year emission. The Charlotte nonattainment area includes some small sources that report emissions to the DAQ once every five years and, for these sources , the most recently

r eported data was used and assumed to be equivalent to 2014 since the emissions from these
small sources do not vary much from year to year

. 40 The DAQ reviewed recent historical
emissions data (i.e., 2010

- 2013) for non

- EGU Title V and emissions sources subject to the
emission s statements re quirements. Based on this review , the DAQ decided that 2013 emissions should be used to represent 2014 emissions due to the uncertainty associated with applying regional growth factors to for e cast emissions for one year.

For each of the three EGU facili ties located in the Charlotte area, Duke Energy Carolinas provided the DAQ with the projected emissions for July for each facility for each future year. Projected emissions for July were divided by the number of operating days during July to
estimate the average summer July day emissions. The forecast reflect s compliance with the
North Carolina Clean Smokestacks Act and the MATS rule ; however, it does not reflect any

40 North Carolina permit renewal intervals for small sources changed from every five years to every eight years, effective 2014.Charlotte

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- hour Ozone Marginal 33

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 additional controls to comply with CSAPR. Therefore, if additional controls are installe d to comply with CSAPR the emissions forecast may be lower than reflected in the forecast for the
three EGU facilities.

Non

- EGU p oint sources future year emission were adjusted by growth factors based on North American Industry Classification System (NAICS ) codes generated using growth patterns obtained from the Annual Energy Outlook 2014 reference case and state employment forecasts. 41
However, f

or EGU s , the estimated projected future year emissions were based on forecast data provided by the utility compa ny.

The inventory includes 20 natural gas fired boilers that , beginning in 2014, are subject to equivalent emission limitations by permit that North Carolina established per Section 112(j) of
the CAA. Because the base year inventory for these boilers di d not include the effects of
controls installed to comply with the NESHAP, a VOC control factor was applied to future year emissions to account for the effects of the controls. A NOx control factor was not applied to the future year emissions for the boil ers because the NESHAP is not expected to significantly affect NOx emissions. No other control factors were ap p lied to point source emissions for the future year inventories.

Aircraft future year emissions were generated by using growth factors produced by running the
Federal Aviation Administration’s ( FAA ) Terminal Area Forecast ( TAF ) model. For each aircraft category, the 2011 operations estimate was divided into the operations estimate of later years to calculate the growth factor.

Rail yard future year emissions were estimated by using growth factors calculated using national fuel use estimates for freight and for intercity passenger service found on Table 46 of the Energy
Information Administration ’s ( EIA ) Annual Energy Outlook,2014 . Rail yard fu ture year emission were also adjusted by control factors calculated using recommended emission factors for NOx and hydrocarbons (virtually the same as VOC) from Emission Factors for Locomotives,
EPA

- 420

- F

- 09

- 025.

For detailed discussion on how the point so urces emission inventory was developed, see Appendix B.1. A summary of the point source emissions is presented in Table 3. 2 a nd Table 3. 3

. The emissions are presented in a ton per summer day basis.

41 Ann ual Energy Outlook 2014, released May 7, 2014, http://www.eia.gov/forecasts/aeo/

.Charlotte

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Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

Table 3

. 2 Point Source NOx Emissions ( tons/day )

County 2014 2015 2018 2022 2026
Cabarrus* 1.72 1.80 1.94 2.07 2.20 Gaston* ¥ 16.50 17.2 5 10.72 16.16 5.2 9 Iredell* 2.02 2.03 2.0 4 2.04 2.0 5 Lincoln* 0.18 0.84 0.95 1.20 0.73 Mecklenburg 8.56 8.77 9.4 6 10.45 12.0 0 Rowan* 2. 80 3.1 6 3.5 1 3.71 3.76 Union* 0.59 0.6 2 0.66 0. 70 0.72 Total 32.38 34.47 29.28 36.33 26.75 * Emissions for portion of county included in nonattainment area

. Totals include emissions associated with stationary point sources, aircraft, and ra il yards.
¥ For Gaston County, the fluctuation in NOx emissions from 2014 through 2026 are primarily associated with the emissions forecast that Duke Energy Carolinas provided for the G.G. Allen power plant.

Table 3

. 3 Point Source VOC Emissions ( tons/day )

County 2014 2015 2018 2022 2026
Cabarrus* 0.9 9 1.0 3 1.15 1.17 1.24 Gaston* 1.82 1.90 2.0 6 2.16 2.22 Iredell* 0.68 0.68 0.6 9 0. 69 0.69 Lincoln* 1.50 1.54 1.72 1.83 1.94 Mecklenburg 3.36 3.4 5 3.7 3 4.0 2 4.36 Rowan* 2. 30 2.40 2.70 2.85 3.1 4 Union* 1.38 1.42 1.5 7 1.64 1.74 Total 12.03 12.42 13.6 2 14.36 15.33 * Emissions for portion of county included in nonattainment area

. Totals include emissions associated with stationary point sources, aircraft, and rail yards.

Area sources are those stationary sources whose emissions are relatively small but due to the large number of these sources, the collective emissions could be significant (i.e., dry cleaners, service stations, etc.). For area sources, emis sions are estimated by multiplying an emission factor by some known indicator of collective activity such as production, number of employees, or population. These types of emissions are estimated on the county level. For the future year inventory, base y ear area source emissions are changed by projected population or employment growth. For detailed discussion on how the area source emission inventory was developed, see Appendix B .2. A summary of the area source e missions is presented in Table 3

. 4 and Ta ble 3. 5

. The emissions are presented in a ton per summer day basis.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 35

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

Table 3

. 4 Area Source NOx Emissions ( tons/day )
County 2014 2015 2018 2022 2026
Cabarrus* 0.97 0.96 0.96 0.9 6 0.9 6 Gaston* 1. 30 1.28 1. 28 1.2 9 1.2 9 Iredell* 0.5 4 0.53 0.54 0.56 0.55 Lincoln* 0.40 0.40 0.40 0.40 0.40 Mecklenburg 6.0 7 6.01 6.01 6.01 6.00 Rowan* 0.8 7 0.8 6 0.85 0.85 0.8 5 Union* 1.25 1.2 4 1.2 4 1.2 4 1.23 Total 11. 40 11.2 8 11.2 8 11.3 1 11.2 8 * Emissions for portion of coun ty included in nonattainment area

.

Table 3

. 5 Area Source VOC Emissions ( tons/day )
County 2014 2015 2018 2022 2026
Cabarrus* 5.0 9 5.13 5.26 5.42 5.59 Gaston* 5.24 5.30 5.43 5.60 5.75 Iredell* 3.08 3.13 3.26 3.43 3.58 Lincoln* 2.5 6 2.57 2.64 2.74 2.82 Mecklenburg 20.59 20.77 21.19 21.73 22.26 Rowan* 5.23 5.28 5.40 5.56 5.72 Union* 6.09 6.12 6.26 6.43 6.60 Total 47.8 8 48.30 49.44 50.91 52.32 * Emissions for portion of county included in nonattainment are a

.

For highway mobile sources, the EPA ’s Motor Vehicle Emission Simulator (MOVES 2014 )
mobile model wa s run to generate emissions. The MOVES 2014 model includes the road class VMT as an input file and can directly output the estimated emissions. For the pr ojected years’ inventories, the highway mobile sources emissions are calculated by running the MO VES mobile model for the future year with the projected VMT to generate emissions that take into consideration expected f

ederal tailpipe standards, fleet turno ver and new fuels. For detailed
discussion on how the on

- road mobile emission inventory was developed, see Appendix B.3. A summary of the on

- road mobile source emi ssions is presented in Table 3. 6 and Table 3

. 7

. The emissions are presented in a ton per s ummer day basis.

Nonroad mobile sources, also referred to as off

- road mobile sources, are equipment that can move but do not use the roadways (i.e., lawn mowers, construction equipment, railroad locomotives, etc.). The emissions from this category are cal culated using the EPA ’s
NONROAD200 8a model, with the exception of the railroad locomotives. The railroad locomotive emissions are estimated by taking activity and multiply by an emission factor. These emissions are also estimated at the county level. Fo r the projected years’ inventories, theCharlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 36

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 emissions are estimated using the EPA ’s NONROAD200 8a model . For detailed discussion on how the nonroad mobile emission inventory was developed, see Appendix B.4. A summary of
the nonroad mobile source emissions is presented in Table 3.8 and Table 3.9. The emissions are presented in a ton per summer day basis.

Table 3

. 6 On

- road Mobile Source NOx Emissions ( tons/day )
County 20 14 2015 2018 2022 2026
Cabarrus* 6.60 5.9 3 3.94 2.79 1.86 Gaston* 8.11 7.26 4.62 3.04 1.98 Iredell* 3.36 3.05 2.05 1.41 0.93 Lincoln* 3.00 2.75 1.84 1.23 0.76 Mecklenburg 26.99 24.20 14.39 9.65 6.85 Rowan* 6.42 5.75 3.73 2.56 1.59 Union* 5.67 5.14 3.41 2.28 1.51 Total 60.15 54.08 33.98 22. 96 15.48 * Emissions for portion of county included in nonattainment area

.

Table 3

. 7 On

- road Mobile Source VOC Emissions ( tons/day )
County 20 14 2015 2018 2022 2026
Cabarrus* 4.15 3.89 3.01 2.53 2.04 Gaston * 4.61 4.29 3.08 2.32 1.73 Iredell* 1.95 1.82 1.40 1.10 0.82 Lincoln* 1.91 1.81 1.37 1.07 0.79 Mecklenburg 14.40 13.41 10.09 8.22 6.67 Rowan* 3.76 3.48 2.57 1.93 1.41 Union* 3.54 3.30 2.54 2.04 1.56 Total 34.32 32.00 24.06 19.21 15.02 * Emissions fo r portion of county included in nonattainment area

.

Table 3

. 8 Non road Mobile Source NOx Emissions ( tons/day )
County 2014 2015 2018 2022 2026
Cabarrus* 2.20 2.04 1.65 1.34 1.16 Gaston* 1.98 1.83 1.49 1.23 1. 08 Iredell* 0.94 0.88 0.72 0.58 0.51 Lincoln* 0.78 0.72 0.59 0.49 0.42 Mecklenburg 15.09 13.99 11.36 9.20 8.11 Rowan* 1.65 1.53 1.26 1.04 0.89 Union* 3.62 3.36 2.72 2.19 1.86 Total 26.26 24.35 19.79 16.07 14.03 * Emissions for portion of county incl uded in nonattainment area.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 37

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

Table 3

. 9 Non road Mobile Source VOC Emissions ( tons/day )

County 2014 2015 2018 2022 2026
Cabarrus* 1.27 1.22 1.17 1.19 1.24 Gaston* 1.29 1.25 1.14 1.12 1.15 Iredell* 0.6 2 0.59 0 .52 0.49 0.49 Lincoln* 0.5 8 0.55 0.48 0.46 0.46 Mecklenburg 11.75 11.53 11.01 11.11 11.51 Rowan* 1. 30 1.22 1.05 0.96 0.94 Union* 2.08 2.01 1.92 1.93 2.00 Total 18.89 18.37 17.29 17.26 17.79 * Emissions for portion of county included in nonattainment area

.

3. 4 .3 Summary of Emissions

The sum totals of the man

- made emissions for the North Carolina portion of the Charlotte
nonattainment area are tabulat ed in Table 3

. 10 and Table 3

. 1 1

.

Table 3

. 10 Total Man

- Made NOx Emissions for the North Carolina Portion of the

Charlotte Nonattainment Area (tons/day)
County 20 14 2015 2018 2022 2026
Cabarrus* 11.49 10.73 8.49 7.16 6.18
Gaston* 27.89 27.62 18.11 21.72 9.64 Iredell* 6.86 6.49 5.35 4.59 4.04 Lincoln* 4.36 4 .71 3.78 3.32 2.31 Mecklenburg 56.71 52.97 41.22 35.31 32.96 Rowan* 11.74 11.30 9.35 8.16 7.09 Union* 11.13 10.36 8.03 6.41 5.32 Total 130.18 124.18 94.33 86.67 67.54 * Emissions for portion of county included in nonattainment area

.

Table 3

. 11 Total Man

- Made VOC Emissions for the North Carolina Portion of the

Charlotte Nonattainment Area (tons/day)
County 20 14 2015 2018 2022 2026
Cabarrus* 11.50 11.27 10.59 10.31 10.11 Gaston* 12.96 12.74 11.71 11.20 10 .85 Iredell* 6.33 6.22 5.87 5.71 5.58 Lincoln* 6.55 6.47 6.21 6.10 6.01 Mecklenburg 50.10 49.16 46.02 45.08 44.80 Rowan* 12.59 12.38 11.72 11.30 11.21 Union* 13.09 12.85 12.29 12.04 11.90 Total 113.12 111.09 104.41 101.74 100.46 * Emissions for port ion of county included in nonattainment area

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 38

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 3. 4

. 4 Maintenance Demonstration
As discussed above, maintenance is demonstrated when the future year ’ s total man

- made
emissions are less than the 20 14 base line emissions. T able 3

. 1 2 summarize s the NOx and VOC
emissions for the North Carolina portion of the Charlotte nonattainment area

. The difference between the base year and the final year illustrates that the continued maintenance of the 2008 8

- hour ozone NAAQS is expected. This is further supported by two modeling studies summarized in the following section.

Table 3

. 12 Maintenance Demonstration for North Carolina Portion of the

Charlotte Nonattainment Area

Year NOx (tons/day) VOC (tons/day)

2014 130.18 113 .12

2015 124.18 111.09

2018 94.33 104.41

2022 86.67 101.74

2026 67.54 100.46

Difference from 2014 to 2026 - 62.64

- 12.66

The difference between the attainment level of emissions (20 1 4 ) from all man

- made sources and the projected level of emissions (2 026) from all man

- made sources in the nonattainment area is considered the “safety margin”. The safety margin for the North Carolina portion of the
nonattainment a rea is summarized in Table 3. 1 3

.

Table 3

. 13 Safety Margin for North Carolina Portion of the Charlotte Nonattainment Area

Year NOx (tons/day) VOC (tons/day)

2014 N/A N/A

2015

- 6.00

- 2.03

2018

- 35.85

- 8.71

2022

- 43.51

- 11.38

2026

- 62.64

- 12.66Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 39

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 3. 4

. 5 National and Regional Air Quality Assessmen ts in Future Years
The Southeastern States Air Resource Managers (SESARM) conducted a Southeastern Modeling, Analysis and Planning (SEMAP) project to produce technical analyses to assist member states in developing SIPs for ozone and PM 2.5 , and in the demo nstration of reasonable progress for the regional haze rule. Photochemical modeling predicts that ozone in the Charlotte nonattainment area will be well below 0.075 ppm in 2018. Base and future design values are
shown in Table 3.1 4

. It should be noted t hat the benefits of Tier 3 engine and fuel standards
were not included in these results.

Table 3

. 14 Eight

- hour Design Values from SEMAP Photochemical Modeling

Monitor County 2007 Base Design Value,
ppm 2018 Future

Design Value,
ppm Relative

Reduction Factor 1 371090004 Lincoln 0.080 0.064 0.7977 371190041 Mecklenburg 0.087 0.070 0.8149 371191005 Mecklenburg 0.079 0.065 0.8224 371191009 Mecklenburg 0.091 0.072 0.7927 371590021 Rowan 0.086 0.067 0.781 3715 90022 Rowan 0.087 0.068 0.7888 371790003 Union 0.079 0.062 0.7869 Source: Southeastern States Air Resource Managers (SESARM); Southeastern Modeling, Analysis and Planning (SEMAP) study, http://semap.ce.gatech.edu/sites/default/files/files/projections/base2018b

- O3

- DVFs

- DDVFs

- for

- 4configs.xls

. 1 The Relative Reduction Factor is the ratio of the future modeled ozone concentration divided by the base modeled ozone concentration. The future design value is computed by multiplying the Relative Reduction Factor and the base design value.

The EPA used photochemical modeling to assess the impacts of the federal Tier 3 rule. Ozone design valu es in 2018 within the Charlotte nonattainment area are predicted to be below 0.075 ppm in the reference case, and even lower when Tier 3 controls are included. The downward trend in ozone continues out to 2030. The EPA Tier 3 ozone modeling results are s hown in
Table 3.1 5

.
Table 3

. 15 Eight

- hour Design Values Scenarios from EPA Tier 3 Photochemical Modeling

County 2007

Baseline Design Value, ppm 2018

Reference Design Value, ppm 2018 Tier 3

Control Design Va lue, ppm 2030

Reference Design Value, ppm 2030 Tier 3

Control Design Value, ppm Lincoln 0.080 0.064 0.063 0.060 0.058 Mecklenburg 0.091 0.073 0.072 0.069 0.067 Rowan 0.087 0.069 0.068 0.065 0.063 Union 0.079 0.062 0.061 0.058 0.056

Source: US EPA http://www.epa.gov/otaq/documents/tier3/454r14002.pdf

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 40

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 3. 5 CONTINGENCY PLAN

3. 5 .1 Overview
The two main elements of the North Carolina contingency plan are tracking and triggering
mechani sms to determine when contingency control measures are needed and a process of developing and adopting appropriate control measures. There will be three potential triggers for the contingency plan. The primary trigger of the contingency plan will be a vi olation of the 2008
8

- hour ozone NAAQS at any of the Charlotte area monitors. The secondary trigger will be a monitored air quality pattern that suggests an actual 2008 8

- hour ozone NAAQS violation may be imminent. The tertiary trigger will be a monitore d fourth high est exceedance of the NAAQS. Upon either the primary or secondary triggers being activated, the DAQ , working in consultation with the SCDHEC and the MCAQ local program, will commence analyses to determine what additional measures, if any, wil l be necessary to attain or maintain the 2008 8

- hour ozone standard. If activation of either the primary or secondary triggers occurs, this plan provides a regulatory adoption process for revising emission control strategies. Activation of the tertiary

t rigger will result in an analysis to understand the cause of the exceedance and to identify voluntary measures if needed.

In addition, there will be a tracking mechanism that requires a comparison of the actual emissions inventory submitted under the Air Emission Reporting Rule (AERR) to the projected inventory, and to the attainment year inventory contained in this maintenance plan. The AERR reporting year s co incide with the base year (2014) and final year (2026) for this maintenance
demonstration

. In addition

, the AERR reporting years will occur at 3

- year int ervals

, thus enabling the comparison of actual emissions developed for the AERR to the projected emissions for the interim years presented in this maintenance demonstration.

3. 5 .2 Contingency Pl an Triggers
The primary trigger of the contingency plan will be a violation of the 2008 8

- hour ozone standard, or when the three

- year average of the 4 th highest values is equal to or greater than 0.0 76 ppm at a monitor in the Charlotte nonattainment area. The trigger date will be 60 days from the
date that the s tate observes a 4 th highest value that, when averaged with the two previous ozone seasons’ fourth highest values, would result in a three

- year averag e equal to or greater than 0.076

ppm.

The seconda ry trigger will apply where no actual violation of the 2008 8

- hour ozone standa rd has occurred, but where the s tate finds monitored ozone levels indicating that an actual ozone NAAQS violation may be imminent. A pattern will be deemed to exist when there are two
consecutive ozone seasons in which the 4 th highest values are 0.076 ppm or greater at a singleCharlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 41

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 monitor within the Charlotte nonattainment area. The trigger date will be 60 days from the date
that the s tate observes a 4 th highest value of 0.076 ppm or greater at a monitor for which the previous season had a 4 th highest value of 0.076 ppm or greater.

Similarly, the tertiary trigger will not be an actual violation of the 2008 8

- hour ozone standard. This trigger will be a first alert as to a potential air quality problem on the horizon. The trigger
will be activated when a monitor in the Charlotte nonattainment area has a 4 th highest value of
0.076 ppm or greater, starting the first year after the maintenance plan has been approved. The trigger date will be 60 days from the date that the s tate ob serves a 4 th highest value of 0.076 ppm or greater at any monitor.

3. 5 .3 Action Resulting From Trigger Activation
Once the primary or secondary trigger is activated, the Planning Section of the DAQ , in

cons ultation with the SCDHEC and MCAQ, shall commence analyses including trajectory analyses of high ozone days, and emissions inventory assessment to determine those emission control measures that will be required for attaining or maintaining the 2008 8

- hour ozone standard. By May 1 of the year following the ozone season in which the primary or secondary trigger has been activated, North Carolina will complete sufficient analyses to begin adoption of necessary rules for ensuring attainment and maintenance of the 2008 8

- hour ozone NAAQS.
The rules would become s tate effective by the following January 1, unless legislative review is required.

The measures that will be considered for adoption upon a trigger of the contingency plan
include : NOx Reasonably Availa ble Control Technology on stationary sources with a potential
to emit less than 100 tons per year in the North Carolina portion of the Charlotte nonattainment

area , diesel I/M program, implementation of diesel retrofit programs, including incentives for

pe rforming retrofits, and additional controls in upwind areas.

The DAQ commits to implement within 24 months of a primary or secondary trigger, or as expeditiously as practicable, at least one of the control measures listed above or other contingency measure s that may be determined to be more appropriate based on the analyses performed.

Once the tertiary trigger is activated, the Planning Section of the DAQ , in consultation with the SCDHEC and MCAQ, shall commence analyses including meteorological evaluation, trajectory analyses of high ozone days, and emissions inventory assessment to understand why a 4 th highest exceedance of the standard has occurred. Once the analyses are completed, the DAQ will work
with SCDHEC, MCAQ and the local air awareness program t o develop an outreach planCharlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 42

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 identify ing any additional voluntary measures that can be implemented. If the 4 th highest exceedance occurs early in the season, the DAQ will work with entities identified in the outreach plan to determine if the measures can be implemented during the current season, otherwise, DAQ
will work with SCDHEC, MCAQ and the local air awareness coordinator to implement the plan for the following ozone season.

3. 5 .4 Tracking Program for Ongoing Maintenance

In addition to the measures li sted above, emissions inventory comparisons will be carried out. The large stationary sources are required to submit an emissions inventory annually to the DAQ or MCAQ . The DAQ will commit to review these emissions inventories to determine if an
unexpect ed growth in NOx emissions in the Charlotte area may endanger the maintenance of the
2008 8

- hour ozone standard. Additionally, as new VMT data are provided by the NCDOT, the DAQ commits to review th ese data and determine if any unexpected growth in VMT ma y

en danger the maintenance of the 2008 8

- hour ozone standard.

Additionally, under the AERR the DAQ is required to develop a comprehensive, annual, statewide emissions inventory every three years and is due 12 to 18 months after the completion
of the invent ory year. The AERR inventory years match the base year and final year of the inventory for the maintenance plan, and are within one or two years of the interim inventory years of the maintenance plan. Therefore, the DAQ commits to compare the AERR invent ories as they are developed with the maintenance plan to determine if additional steps are necessary
for continued maintenance of the 2008 8

- hour ozone standard in this area.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 43

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 

### 4.0 MOTOR VEHICLE EMISSIONS BUDGET FOR CONFORMITY

4.1 TRANSPORTATION CONFORMITY

The purpose of transportatio n conformity is to ensure that f ederal transportation actions occurring in nonattainment and maintenance areas do not hinder the area from attaining and maintaining the 2008 8

- hour ozone standard. This means that the level of emissions estimated by the NCDOT or the metropolitan planning organizations for the TIP and Metropolitan Transportation Plan (MTP) must not exceed the motor vehicle emission s budgets (MVEBs) as defined in this maintenance plan.

The DAQ held three conferen ce calls with the Charlotte Regional Transportation Planning Organization (CRTPO)

- Rocky River R ural Planning Organization (RRRPO) , Gaston

Cleveland

- Lincoln Metropolitan Planning Organization (GCLMPO), and Cabarrus Rowan Metropolitan Planning Organization (CRMPO) to determine what years to set MVEBs for the Charlotte maintenance plan. According to Section 93.118 of the transportation conformity rule, a maintenance plan must establish MVEBs for the last year of the maintenance plan (in this case, 2026). T he consensus formed during the interagency consultation process was that another
MVEB should be set for the Charlotte maintenance plan base year of 2014.

4. 2 SAFETY MARGIN

As stated in Section 3.3.4, a safety margin is the difference between the attainm ent level of emissions from all source categories (i.e., point, area, on

- road and nonroad) and the projected level of emissions from all source categories. The safety margins for the North Carolina portion
of the Charlotte nonattain ment area are listed in Table 3. 12. The state may choose to allocate some of the safety margin to the MVEB, for transportation conformity purposes, so long as the total level of emissions from all source categories remains below the attainment level of
emissions.

The DAQ has decided to allocate a portion of the safety margin to the MVEB to allow for unanticipated growth in VMT, changes and uncertainty in vehicle mix assumptions, and uncertainty associated with mobile modeling that will influence the future year emission
estima tions. The DAQ has developed and implemented a five

- step approach for determining a factor to use to calculate the amount of safety margin to apply to the MVEB for 2026 (see the following Section 4.3 and Appendix B.3 ). The percent increase to the MVEBs f or the North
Carolina counties in the Charlotte nonattainment area are listed in the Table 4. 1. Note that because the initial MVEB year of 2014 is also the base year for the maintenance plan inventory, there is no safety margin and, therefore, no adjustme nts were made to the MVEB for 2014.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 44

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015

Table 4

. 1 Percent Increase t o Mobile Vehicle Emissions Budget

County 2026
Cabarrus 20% Gaston 20% Iredell 22% Lincoln 22% Mecklenburg 17% Rowan 20% Union 20%

4. 3 MOTOR VEHICLE EMISSION BUDGETS

Although the emissions up to this point have been expressed in terms of tons / day, for conformity purposes the MVEBs are expressed in kilograms / day (kg/day) . Note that, for this reason, kg/day

w as selected as the specified units for all MOVES2014 model outputs. Emissions values in kg/day were divided by 907.1847 to convert them to units of tons / day.

Table 4.2 show s the counties with their highway mobile NOx and VOC emissions, respectively, expressed in tons/day and the cor responding kg/day values for 2014 and 2026.

Table 4

. 2 Highway Mobile Source NOx and VOC Emissions in 2014 and 2026 for North

Carolina Portion of the Charlotte Nonattainment Area

County 2014 NOx 2014 VOC 2026 NOx 2026 VOC

tons/day kg/day tons/day kg/day tons/day kg/day tons/day kg/day

Cabarrus* 6.60 5,989 4.15 3,765 1.86 1,685 2.04 1,854

Gaston* 8.14 7,389 4.66 4,228 1.98 1,793 1.73 1,571
Iredell* 3.36 3,045 1.95 1,768 0.93 841 0.82 742
Lincoln* 3.00 2,72 3 1.91 1,737 0.76 692 0.79 713 Mecklenburg 27.09 24,574 14.55 13,201 6.85 6,219 6.67 6,052
Rowan* 6.42 5,825 3.76 3,408 1.59 1,439 1.41 1,281
Union* 5.67 5,146 3.54 3,210 1.51 1,370 1.56 1,420

Total 60.28 54,691 34.52 31,317 15.4 8 14,03 9 1 5.02 13,633
* Emissions for portion of county included in nonattainment area

.

As part of the consultation process on developing MVEBs, the DAQ coordinated three interagency conference calls with local and state transportation partners and the EPA’s Region
IV staff to establish the framework and process for developing MVEBs. Based on theseCharlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 45

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 conference calls, the participants in the consultation process unanimously agreed to the following:

Emissions Inventory and Forecast

 Use 2014 as the base year for the emissions inven tory and include emissions estimates for 2018, 2022, and 2026 (4

- year increments) from the base year.

 The Charlotte DOT runs the local transportation demand model based on inputs from the local transportation planning organizations to generate inputs (VMT

, and speeds for daily travel periods , and human population to forecast VMT) needed to run MOVES2014 to estimate emissions for each year

Geographic Extent of MVEBs

 Prepare separate MVEBs based on the latest MPO jurisdictional boundaries such that
MVEBs ar e established for the CRMPO (Cabarrus and Rowan Counties), for the
CRTPO

- RRRPO (Iredell, Mecklenburg and Union Counties), and for the G CLMPO (Gaston and Lincoln Counties). Although Cleveland County is included in the
G CLMPO

, it is not included in the Char lotte ozone nonattainment area.

MVEB Years

 In addition to developing a MVEB for 2026 (required by EPA guidance), the group agreed to develop a MVEB for the base year 2014.

Adjustment to MVEBs

 Allocate a portion of the safety margin to increase the MVEB for each county grouping following the process used to develop the MVEBs for the previous “ Redesignation
Demonstration and Maintenance Plan for the Charlotte

- Gastonia

- Rock Hill, NC

- SC 1997
8

- Hour Ozone Nonattainment Area .” This process , which includes th e following five
steps , was used to adjust the MVEB for 2026. Because 2014 is the base year for the emissions inventory there is no safety margin; consequently, the MVEB for 2014 was not adjusted.

Step 1

- Percentag e below the standard

 All counties get 2% of their emissions allocated to MVEB in 2026

Step 2

- Account for unanticipated model input data changes

 All counties get an additional 5% of their emissions allocated to MVEB in 2026Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 46

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Step 3

- Provide flexibility and account for rapid growth for countie s that are determined
to be medium to small contributors to the on

- road mobile NOx emissions inventory

 Counties with < 8% of total on

- r oad mobile source NOx emissions received an additional 5% of their emissions allocated to MVEB in 2026 ( Iredell and Lincol n )

 Counties with 8% to 25 % of total on

- road mobile source NOx emissions received an additional 3 % of their emissions allocated to MVEB in 2026 ( Cabarrus, Gaston,
Rowan and Union )

Step 4

- Account for input uncertainty in final year of the maintenance plan :

 All counties get 10% additional of their emis sions allocated to MVEB in 2026 to account for potential changes in VMT, vehicle mix and vehicle age distribution

 A dditional percentage is added to the current percentages outlined in the steps above

Step 5

- Ensure the sum of the safety margins applied to the MVEB does not exceed 50% of the total safety margin available. For 2026 , Steps 1

- 4 accounted for:

 5 % of the total NOx safety margin

 22 % of the total VOC safety margin

Tables 4

. 3 through 4

. 5 provide the NO x and VOC MVEBs in kg/day , for transportation conformity purposes, for 2014 and 2026. Upon the EPA’s affirmative adequacy finding for these
sub

- area MVEBs, they will become the applicable MVEBs for transportation conformity.

Table 4

. 3 Cabarrus Rowan Metropolitan Planning Organization (CRMPO)

MVEB in 2014 and 2026 (kg/day) *

2014 2026
NOx VOC NOx VOC
Base Emissions 11,814 7,173 3,124 3,135 Safety Margin Allocated to MVEB

- - 625 627 Conformity MVEB 11,81 4 7,173 3,749 3,762

* Includes the portion of Cabarrus and Rowan Counties in the nonattainment area

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 47

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Table 4

. 4 Gaston

- Cleveland

- Lincoln Metropolitan Planning Organization (GCLMPO) MVEB in 2014 and 2026 (kg/day) *

2014 2026
NOx VOC NOx VOC
Base Emissions 10,079 5,916 2,485 2,284 Safety Margin Allocated to MVEB

- - 511 471 Conformity MVEB 10,079 5,916 2,996 2,755

* Includes the portion of Gaston and Lincoln Counties in the nonattainment area. Altho ugh Cleveland County is included in the MPO it is not included in the Charlotte ozone nonattainment area.

Table 4

. 5 Charlotte Regional Transportation Planning Organization (CRTPO)

- Rocky River Rural Planning Organization (RRRPO) MVEB in 2014 and 2026 (kg/day) *

2014 2026
NOx VOC NOx VOC
Base Emissions 32,679 18,038 8,430 8,214 Safety Margin Allocated to MVEB

- - 1,516 1,476 Conformity MVEB 32,679 18,038 9,946 9,690

* Includes all of Mecklenburg County a nd the portion of Iredell and Union Counties in the nonattainment

area

.

New Safety Margins
A total of 2,650 kg/day (2.92 tons/day) of 2026 NOx safety margin were added to the MVEB for
the Charlotte area. A total of 2,569 kg/day (2.83 tons/day) of 2026 VOC safety margin were
added to the MVEB for the Charlotte area. The revised safety margins, which take into consideration the portion of the safety margin applied to the MVEB, for each projected year is
listed below in Table 4. 6

.

Table 4

. 6 New Safety Margins for the North Carolina Portion of the

Charlotte Nonattainment Area (tons/d ay )

Year NOx VOC

2014 N/A* N/A

2015

- 6.00

- 2.03

2018

- 35.85

- 8.71

2022

- 43.51

- 11.38

2026

- 59.72

- 9.82 * N/A = not applicable.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 48

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 

### 5.0 STATE IMPLEMENTATION PLAN APPROVAL

5.1 INTRODUCTION

For an area to be redesignated and have an approved maintenance plan, the SIP must include
evidence of compliance with the rules relied on to show maintenance of the standard. This section provides t he evidence of compliance with such rules for the Charlotte

- Gastonia

- Salisbury
2008 8

- hour ozone nonattainment area.

5.2 EVIDENCE OF COMPLIANCE

Two counties in the Charlotte area ( Gaston and Mecklenburg Counties) were designated as
moderate nonattainment for 1

- hour ozone effective January 1992. Since a redesignation demonstration and maintenance plan was submitted for this area prior to November 15, 1992, the CAA requirements for moderate areas were not required with the exception of the I/M program. An I/M program was established in the Charlotte area as prescribed by the 1990 CAA.

T herefore, North Carolina has a fully approved SIP for this area.

For the 1997 8

- hour ozone standard, the DAQ submitted to the EPA for approval the Metrolina
Attainment Dem onstration SIP on June 15, 2007

, and a Supplement to the Attainment Demonstration SIP on April 5, 2010. The North Carolina portion of the Metrolina nonattainment
area includes the counties of Cabarrus, Gaston, Lincoln, Mecklenburg, Rowan and Union and
Cod dle Creek and Davidson Townships in Iredell County. The Re asonable Further Progress SIP
was submitted to the EPA for approval on June 15, 2007 and a Revised Reasonable Further Progress SIP was submitted on November 30, 2009. The EPA approved the Revised Reasonable Further Progress SIP on October 12, 2012

. 42 On November 2, 2011 the DAQ submitted to the
EPA a Redesignation Demonstration and Maintenance Plan for 1997 8

- hour Ozone standard; and submitted a supplement to this SIP on March 28, 2013. The EPA ap proved the redesignation request and maintenance plan on December 2, 2013. 43

For the 2008 8

- hour ozone standard for the Charlotte nonattainment area , the DAQ submitted to the EPA for approval the Base Year (2011) Emissions In ventory and Emissions Statement s SIP on July 7, 2014, to fulfill the requirements of S ections 182(a)(1) and 182(a)(3)(B) of the CAA. 44

42 77 FR 62159

- 62166.

43 78 FR 72036

- 72040.

44 http://ncair.org/planning/metrolina/metrolina_area_sip_plans.shtml

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 49

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 Additionally, the following rules regulating emissions of VOCs and/or NOx in the Charlotte nonattainment area counties have been approved, or have been submitted with a request to be approved, as part of the SIP:

15A NCAC 2D .0958, Work Practices For Sources of Volatile Organic Compounds, 15A NCAC 2D .0530, Prevention of Significant Deterioration, 15A NCAC 2D .0925, Petroleum Liquid Storage in Fixed Roof Tanks, 15A NCAC 2D .0926, Bulk Gasoline Plants, 15A NCAC 2D .0927, Bulk Gasoline Terminals, 15A NCAC 2D .0928, Gasoline Service Stations Stage I, 15A NCAC 2D .0932, Gasoline Truck Tanks and Vapor Collection Systems, 15A NCAC 2D .0933 Petroleum Liquid Stora ge in External Floating Roof Tanks 15A NCAC 2D .1000, Motor Vehicle Emission Control Standards. 15A NCAC 2D .1200, Control and Emissions from Incinerators 15A NCAC 2D .1409(b), Stationary Internal Combustion Engines 15A NCAC 2D .1416

- .1423, NOx SIP rules 15A NCAC 2D .1600, General Conformity 15A NCAC 2D .1700, Municipal Solid Waste Landfills, and 15A NCAC 2D .1900, Open Burning 15A NCAC 2D .2000, Transportation Conformity 15A NCAC 2D .2400 Clean Air Interstate Rules

Rules 15A NCAC 2D .0925, .0926, .0927 , .0928, .0932,

. 0933, .0948, .0949, and .0958 have
b een approved as part of the SIP and are applicable across the state regardless of the size of the

source.

Section 15A NCAC 2D .1000 also regulates emissions from motor vehicles in the North
Carolina co unties in and around the Charlotte nonattainment area and requires the use of the
OBD II system , which provides an indication of NOx emissions as well as other pollutants.

Section 15A NCAC 2D .1200 regulates the controls and emissions from incinerators. Pa rt of this rule has been submitted as part of the SIP, while .1205, .1206 and .1210 are part of the CAA Section 111(d) plans.

Two rules are conformity related, 15A NCAC 2D .1600 and .2000. General conformity related projects are covered under Section .160 0, while transportation conformity related projects are covered under Section .2000. Although neither of these rules requires reduction in emissions, they do ensure that federal actions do not hinder attainment or maintenance of the NAAQS.

North Carolina h as adopted an open burning rule, 15A NCAC 2D .1900 that prohibits open burning of vegetative material during Air Quality Action Days of Code Orange or higher inCharlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 50

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 forecasted areas of the state. Ozone forecasts are issued for the Charlotte area from May 1 st through September 30 th , therefore this area is covered by this rule.

Section 15A NCAC 2D .2400 regulates nitrogen oxide emissions from electric generating units with a nameplate capacity of 25 megawatts or more producing electricity for sale. Section 15A
N CAC 2D .2400 also covers industrial boilers that are covered under the NOx SIP rules. This Section replaces the NOx SIP rules beginning January 1, 2009. Although North Carolina did not rely on the emission reductions from CAIR for maintenance of the 2008 8

- hour ozone standard, these regulations will result in additional reductions in NOx emissions regionally.

Another important set of rules that control volatile organic compound emissions in these counties is Section 15A NCAC 2D .1100, Control of Toxic Air Pollutants. These rules, however, have
not been submitted to the EPA to be approved as part of the SIP.

There are two other rules that control emissions of volatile organic compounds in these areas. They are 15A NCAC 2D .0524, New Source Performance Stan dards, and 2D.1110, National Emission Standards for Hazardous Air Pollutants. Also, rule 2D.1111, Maximum Achievable Control Technology applies to control of emissions of volatile organic compounds. They are not part of the SIP, but the EPA has delegated the state enforcement authority for standards that have been adopted by the state . (The standards adopted by the state are state

- enforceable regardless of
the EPA delegation.)Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 51

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 

### 6.0 STATE COMPLIANCE WITH CLEAN AIR ACT REQUIREMENTS

Section 107(d)(3)(E)(v) of the CAA requires that the provisions of Section 110 ( State
I mplementation P lans for the Primary and S econdary NAAQS) and P art D ( Plan Requirements
for Nonattainment Areas ) of the CAA be met within the area to be redesignated. This means that
North Caroli na must meet all requirements, if any, that had come due as of the date of the redesignation request.

The EPA

, in its latest guidance on redesignation requirements ( as contained in a memorandum from John Calcagni, Director, Air Quality Management Division, Office of Air Quality Planning
and Standards to the EPA Regional Offices dated September 4, 1992 , s ee Appendix A), states that "For the purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were applicable prior to s ubmittal of the complete redesignation request. When evaluating a redesignation request, Regions should not consider whether the state has met requirements that come due under the Act after submittal of a complete redesignation request."

Monitoring is one of the requirements of Section 110. The DAQ commits to continue operating
the current ozone monitors in the North Carolina portion of the Charlotte 2008 8

- hour ozone nonattainment area, providing sufficient funding is available for continued operation. Any monitor shutdowns or relocations will only be made with the approval of EPA . No plans are underway to discontinue operation, relocation or otherwise affect the integrity of the ambient monitoring network in place. The current monitors are operated co nsistent with 40 CFR Part 58 and any changes will only be made if they are consistent with 40 CFR Part 58.

For the 2008 8

- hour ozone standard for the Charlotte marginal nonattainment area , the DAQ submitted to the EPA for approval the Base Year (2011) Emis sions In ventory and Emissions Statements SIP on July 7, 2014, to fulfill the requirements of Part D, S ections 182(a)(1) and 182(a)(3)(B) of the CAA. 45 The DAQ believes that North Carolina has met all of the requirements of Section 110 and P art D.

45 http://ncair.org/planning/metrolina/metrolina_area_sip_plans.shtml

.Charlotte

- Gastonia

- Salisbury , NC 2008 8

- hour Ozone Marginal 52

Nonattainment Area Redesignation Demonst ration and Maintenance Plan April 16, 2015 

### 7.0 CONC LUSION

The most recent three years of ozone monitoring data (2012

- 2014) for the Charlotte

- Gastonia

Salisbury nonattainment area demonstrate compliance with the NAAQS for 2008 8

- hour ozone. Since the 1990’s, there have been many major programs enacted in N orth Carolina that have led to significant actual, enforceable emissions reductions, which have led to improvements in the air quality in the Charlotte area. Additionally, the maintenance plan demonstrates that the projected emissions inventories for 20 2 6 , the final year of the maintenance plan and 10 years beyond the expected redesignation year, as well as the interim years, are all less than the base year emissions inventory. In addition, the CAA Section 110(l) non

- interfere nce demonstration analysis in dicates that increasing the RVP from 7.8 to 9.0 psi in Gaston and Mecklenburg Counties would not negatively impact the redesignation demonstration and maintenance plan for
the Charlotte area. Therefore, maintenance of the 2008 8

- hour ozone NAAQS has also been
demonstrated.

This redesignation demonstration and maintenance plan has been prepared to meet the requirements of the 1990 CAA Amendments.