Appendix B

Georgia Marketing Rule Revocation

Technical Demonstration

In order to demonstrate that removal of Georgia Rule 39-3-1-.02(bbb), Georgia Marketing Rule, will still 

result in a decrease in VOC and NOx emissions over time and will not interfere with maintenance of the 

1997 ozone NAAQS or attainment of the 2008 Ozone NAAQS, NOx and VOC emissions inventories were 

calculated for two different scenarios over time and compared with key emissions budgets/limits. 

Emission inventory years were 2008, 2010, 2013, 2016, 2024, 2030, and 2040.

One scenario quantifies emissions with the Georgia Marketing Rule in place and the other with the Rule 

removed. This is accomplished by using the two different Reid Vapor Pressure (RVP) limits of the two 

types of gasoline, one labeled “Georgia Gas” representing the Georgia Marketing Rule RVP requirements 

and the other, “conventional gas”, which is the gasoline that would be used under Federal RVP 

requirements. The RVP for conventional gasoline is, on average, 0.8 psi higher than for Georgia Gas in 

the 13-county Atlanta area and 2.0 psi higher for the remaining seven counties in the Atlanta ozone NAA 

for the 1997 ozone NAAQS (RVP for conventional gas requirements is referenced in 40 CFR 80.27(a)(2)(iii) and 40 CFR 80.27(d)(1-2)) as well as the additional 25 county “area of influence” that completes the 

45 county area. Therefore, the “Georgia Gas” case is based on model defaults, while the conventional 

gas case has the same inputs except the RVP is increased by 2.0 psi or 0.8 psi in the relevant county. In 

all scenarios, it is assumed all gasoline contains 10% ethanol. For instance, for the 13-county Atlanta 

region (13 county previous 1-hr ozone NAAQS nonattainment area consisting of Cherokee, Clayton, 

Cobb, Coweta, DeKalb, Douglass, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale 

counties), the RVP for model years 2012 or later is 7.8 psi in the MOVES 2010b fuel default database (7.0 

psi + 0.8 psi allocated from ethanol waiver). This is what is used for the “Georgia Gas” scenario. For the 

“Conventional Gas” scenario, RVP used would be 8.6 psi (7.8 psi RVP rule + 0.8 ethanol waiver) which is 

0.8 psi higher than “Georgia Gas”. For the remaining counties in the 45 county Georgia Gasoline 

Marketing Rule area, MOVES 2010b defaults and “Georgia Gas” scenario apply 7.7 psi (7.0 psi +0.7 psi 

allotted to ethanol waiver). In this case, 9.7 psi was used in the “Conventional Gas” scenario (9.0 psi + 

0.7 psi allotted to ethanol waiver) which is 2.0 psi higher than “Georgia Gas”. The sulfur content 

requirement is the same for Georgia Gas and Conventional Gas and is illustrated by MOVES 2010b 

defaults listing the same sulfur content for all gasoline in Georgia. For ozone NAAQS, model runs were 

conducted using the scenario of weekday traffic and typical summer conditions (July) to provide the 

highest possible NOx and VOC emission levels and greatest sensitivities to changes in RVP. 

Demonstrating non-interference using this conservative approach allows for the assumption of noninterference in all other cases with regards to the ozone NAAQS and removal of the Georgia Marketing 
Rule. There was also an analysis comparing NOx emissions with and without the Georgia Gasoline Rule 

for confirmation of non-interference with the PM2.5 NAAQS and in this case July was used as a dummy 

month and annualized input data into the emissions model were inputted. This data originated from 

input used with the PM2.5 maintenance plan submittal. See methodology sections below for further 

details on MOVES 2010b inputs and fuels.

For clarification, the emissions were calculated in 25, 13, 7, and 2 county groupings for the analysis of 

impacts of GA Marketing rule removal on Georgia attaining the 2008 ozone NAAQS and maintain 

attainment of the 1997 ozone NAAQS. For PM2.5 NAAQS, 13, 7 and 2 county groups were used as well 

as for Putnam county. The reason for the groupings is that the inputs used for modeling were 

aggregated in such a matter to reflect the common regulatory requirements and that transportation 

crosses county lines. There was no need to change these groupings (except for adding 25 counties and 

disaggregating 2 counties from the 7 county group) since it is data that has gone through QA/QC, 

disaggregation had limited benefit except when absolutely necessary (e.g. for 2 counties), and these 

inputs in these groupings were used in SIP and transportation conformity work related to the ozone and 

PM2.5 NAAQS of concern.

The aggregated groupings are as follows:

a. 13 counties: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, 

Gwinnett, Henry, Paulding, Rockdale

b. 7 counties: Barrow, Bartow, Carroll, Hall, Newton, Spalding, Walton

c. 2 counties (disaggregated from 7 counties): Bartow, Newton

d. 25 counties: Banks, Butts, Chattooga, Clarke, Dawson, Floyd, Gordon, Haralson, Heard, 

Jackson, Jasper, Jones, Lamar, Lumpkin, Madison, Meriwether, Monroe, Morgan, Oconee, 

Pickens, Pike, Polk, Putnam, Troup, Upson

e. Portion of Putnam county in NAA (soon to be maintenance area) for 1997 PM2.5 NAAQS

For a proper, complete demonstration of non-interference with maintenance of the 1997 ozone NAAQS, 

the key budgets/limits in which emissions must not exceed in these scenarios are the 2008 15% 

Reasonable Forward Progress Plan (RFP) SIP MVEB, and 2024 Atlanta ozone maintenance plan MVEB. 

The 2008 MVEB is used because it represents the maximum level of mobile emissions where it can still 

be claimed that emissions levels will be not interfere with attainment (or maintenance of attainment) of 

the 1997 or 2008 ozone NAAQS. In this appendix, we further demonstrate that 2008 baseline levels

from the Atlanta ozone maintenance plan are used because it represents MOVES-based emissions levels 

for the year Atlanta attained the 1997 ozone NAAQS. This additional demonstration further proves that 

future emissions never return to the pre-2008 levels. The 2024 MVEB from the Atlanta ozone 

maintenance plan is used because it represents the maximum level of mobile emissions allowed after 

2024 to further assure continued attainment of the 1997 ozone NAAQS. 
In this demonstration, years 2024, 2030 and 2040 would be compared to the2024 motor vehicle 

emission budgets (MVEB) established by the Atlanta ozone maintenance SIP, with safety margin 

included, while all years will be compared to the 2008 MVEB. The same years and methodology applies 

to the PM2.5 NAAQS analyses as well. The exception is that 2013 is not used for the PM2.5 case due to 

lack of data. Also, PM2.5 is annualized where the RVP differences are only realized during ozone season 

whereas for the remainder of the year the Georgia gasoline and conventional gasoline are virtually 

identical. This incorporation of non-ozone season fuel blend is why PM2.5 annualized NOx differences 

are going to be smaller than NOx associated with ozone. The main narrative provides all the details 

regarding the results of the comparison between “Georgia Gas” and “Conventional Gas” scenarios for 

the PM2.5 NAAQS demonstration. Section 6 of the main narrative contains the demonstration of noninterference with Atlanta’s attainment of the 2008 NAAQS ozone standard through the use of offsets. 

No further details were required for this appendix regarding results.

Figures 1a-b display the results of running these two scenarios for both the “Georgia Gas” and the 

conventional gas cases. The difference in the two lines is nearly indistinguishable showing how Georgia 

Marketing Rule removal will not significantly affect these trends or the magnitude of emissions. In both 

the “Georgia Gas” and conventional gas cases the NOx and VOC emissions after 2012 are well below the 

2008 MVEB or 2008 ozone maintenance plan levels with emissions from 2024-2040 never exceeding the 

2024 ozone maintenance plan MVEB. Tables 1a and 1b quantify these results for the conventional gas

case, further illustrating how emissions with conventional gas after 2008 never exceed these limits. The 

2008 Ozone Maintenance Plan baseline year (or can be called “attainment year”) is added for additional 

comparison.

Table 1a: Comparison of On-Road NOx Emissions With Conventional Gas 

Year 2008 2024 Conventional Gas

RFP Maintenance Plan SIP Emissions

MVEB MVEB 

tpd tpd tpd

2013 272.67 N/A 226.39

2016 272.67 N/A 172.44

2024 272.67 126 99.27

2030 272.67 126 93.27

2040 272.67 126 99.49
Table 1b: Comparison of On-Road VOC Emissions With Conventional Gas

Year 2008 2024 Conventional Gas

RFP Maintenance Plan SIP Emissions

MVEB MVEB 

tpd tpd tpd

2013 171.83 N/A 113.74

2016 171.83 N/A 90.32

2024 171.83 92 62.82

2030 171.83 92 60.42

2040 171.83 92 66.56

Figure 1a

50

100

150

200

250

300

350

400

2010 2015 2020 2025 2030 2035 2040

N

O

x

E

missio

n

s (to

n

s/d

a

y)

Year

NOx Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Versus 2008 Maintenance

SIP Baseline and 2008 & 2024 MVEBs

NOx Inventory-Conventional Gas 20 cnty NAA

NOx Inventory-Georgia Gas 20 cnty NAA

2008 Atlanta RFP SIP NOx MVEB

2008 Maintenance Plan NOx Baseline

2024 Maintenance Plan NOx MVEB
Figure 1b

50

70

90

110

130

150

170

190

2010 2015 2020 2025 2030 2035

V

O

C

E

mis

sio

n

s (to

n

s/d

a

y)

Year

VOC Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Versus 2008 Maintenance SIP Baseline and 

2008 & 2024 MVEBs 

Details concerning methodology used to obtain these emissions values including the MOVES (Motor 

Vehicle Emission Simulator) model used are provided below.
Methods Used to Determine VOC and NOx Emissions Inventory for the 20-

county Atlanta maintenance area for ozone and nonattainment area for PM2.5,

as weall as the Georgia Marketing Rule 45-county Area of Influence

The MOVES (Motor Vehicle Emission Simulator version 2010b) was employed to calculate on-road 

mobile VOC and NOx emissions over the 20-county Atlanta maintenance area for ozone, 20-county 

nonattainment area for PM2.5 (plus portion of Putnam County) and the 45-county area of influence. In 

order to accomplish this task, a variety of inputs are required. These inputs are described below 

including how the data was collected for the years chosen in the technical demonstration. Any inputs 

not mentioned here used only the MOVES model defaults.

Age Distribution

The vehicle age distribution inputs for the former 1997 Atlanta ozone nonattainment area and current 

1997 PM2.5 nonattainment area are the same as those used for our recently approved maintenance 

ozone SIP and recently submitted PM2.5 maintenance SIP for the Atlanta metropolitan area (ARC). Age 

distribution data has been developed from registration data from R.L. Polk & Co.’s National Vehicle 

Population Profile (current as of October 2002) and R.L Polk and Co.’s TIPNet (current as of March 2003). 

The input data was aggregated into representative 13-county and 7-county age distributions (e.g., each 

county in the 13-county area and each county in the 7-county area has the same age distribution).

These representative county regions are used since people travel within each of these areas unrestricted 

by county boundaries so age distributions should be very similar throughout each region. These same 

two 13-county and 7-county age distributions were applied to all years analyzed in this technical 

demonstration since it is assumed that the age distribution does not change significantly from year to 

year. The 13-county and 7-county regions also represent the original 13 county ozone non-attainment 

area and the additional 7-counties brought into the non-attainment area (for a total of 20 counties, 

Putnam is included in the case of PM2.5, run similarly as the 25 counties were for the ozone case) with 

the 1997 8-hr based ozone NAAQS. For all the inputs, Fulton county is the representative county for the 

13-county area; Bartow county for both the 7-county area, and the 45-county area of influence. For the 

25 additional counties, a 139 county aggregated distribution was employed based on the same 

developed registration data from R.L. Polk & Co. (now I.H.S) as was used in the 1997 Atlanta 8-hour 

Ozone Attainment Demonstration submitted to EPA on October 21, 2009.

Annual Average VMT (hpmsvtypeyear), Road Type, Distribution, and Hour VMT Fractions

Atlanta Regional Council (ARC) Travel Demand Model (TDM) output provides road type distributions and

overall annual average daily vehicle miles traveled (AADVMT) by Highway Performance Monitoring 

System (HPMS) functional class (urban restricted (with ramps), urban unrestricted (no ramps), rural 
restricted, and rural unrestricted). The data needs to be split by vehicle class (motorcycles, passenger 

cars, light duty trucks etc.), which is done using data provided by the Georgia Department of 

Transportation (GDOT): Mileage By Route, Type, and Functional Classification Reports (445 Reports -

2008), through HPMS and defaults from the MOVES model database. This AADVMT (annual average 

daily vehicle miles traveled) data that is split by vehicle class is then used to calculate an annual average 

VMT (hpmsvtypeyear) by multiplying the AADVMT by 342 (instead of 365.25) to account for lower 

volume on weekends (same method used for SIPs and transportation conformity analyses based on an 

EPA converter). Vehicle miles traveled varies by hour of the day so hourly VMT fractions are needed and 

are provided by the ARC TDM. The TDM was calibrated using HPMS data from the Georgia Department 

of Transportation. The TDM networks available for Atlanta were 2008, 2010, 2016, 2024, 2030 and 2040 

from which input values for 2013 was interpolated for annual average VMT and hour VMT fractions. 

Data is aggregated into 13-county and 7-county representative area. Hour VMT fractions are assumed 

to be similar for the additional 25-county area as with the 7-county area which they border. For annual 

average, VMT calculations started with 2008 data from GDOT’s 445 Reports (the sum of VMT for 25 

counties) where these values were multiplied by vehicle splits in the 7-county area to get annual 

average VMT by vehicle type as required by MOVES. Indications are that vehicle splits between the 25-

county area and the 7-county area would be similar as well as growth (25-county grown at same rate as 

7-county). Putnam in the PM2.5 case is treated similarly to the 25 counties in the ozone case.

Source Type Population

Source type population data has been developed from registration data from R.L. Polk & Co.’s National 

Vehicle Population Profile (current as of October 2002) and R.L Polk and Co.’s TIPNet (current as of 

March 2003). This data through the help of EPA converters was modified from being sorted by MOBILE 6 

vehicle types into being based on MOVES based vehicle types. 

This data had already been “grown” from 2002-2003 values to 2007 values for use in Atlanta’s

transportation conformity analyses and application to SIP revisions. The data can be grown either based 

on human population growth trends over the time period or growth trends in vehicle population from 

the Georgia vehicle registration database (only trends can be used not exact numbers due to difficulty of 

matching vehicle types in the Georgia motor vehicle registration data to the vehicle types used in R.L 

Polk and Co’s data). Atlanta data is aggregated into 13 county and 7 county representative areas.

Table 1 below lists the vehicle type and preferred method. Using this table is consistent with what has 

been used in the previous national emissions inventory (NEI) compilation and with regards to any SIP 

motor vehicle budget determinations with MOVES. As indicated in Table 1, human population is 

adequate for all vehicle types except motorcycles, buses and combination long haul trucks. For 

motorcycles and buses, ratio of vehicle population is used instead. For example, if source type 

population is grown from 2007 to 2009 then the 2007 data is multiplied by 2009 human 

population/2007 human population unless a bus or motorcycle where it will be multiplied by 2011 

vehicle population/2009 vehicle population. For Atlanta, these human population ratios have already 
been developed in a “Source Type Population Growth Table”. For motorcycles and buses vehicle 

population ratios can be constructed from the “Georgia Statistics System – University of Georgia” 

website, www.georgiastats.uga.edu which organized by county all the Georgia vehicle registration data 

for public use. In this particular analysis source type population had already been developed using the 

above methodology for Atlanta for 2008, 2010, 2016, 2024, 2030 and 2040 through conformity 

determination reports and SIP development with 2013 data developed through linear interpolation 

between the 2010 and 2016 source type population. 2002 data was also available to provide a 

conformity baseline.

Table 1. List of different growth factors used by vehicle types

Vehicle types Growth factor

11 (Motorcycles) Georgia registration data, Motor cycles

21 (Passenger cars) Human Population 

31 (Passenger truck) Human Population

32 (Light commercial truck) Human Population 

41 (Intercity Bus) Georgia registration data, Buses 

42 (Transit Bus) Georgia registration data, Buses

43 (School Bus) Georgia registration data, Buses 

51 (Refuse Truck) Human Population

52 (Single Unit Short Haul Truck) Human Population

53 (Single Unit Long Haul Truck) Human Population

54 (Motor Home) Human Population

61 (Combination Short Haul Truck) Human Population

62 (Combination Long Haul Truck) Special methodology (see below)

For all cases with vehicle type 62-long haul combination trucks, a special determination is required 

because these vehicles do not reside in the areas investigated but usually just pass through the area 

along interstate routes. So, local population and vehicle registration data is not going to help since these 

vehicles are not part of the local population or registered in the state, but how far they all travel while 

they are in Georgia and how much far an average vehicle travels yearly in the U.S. are helpful. Local 

annual average total VMT for vehicle type 62 and national annual average VMT per vehicle 62 are 

required (this latter term is directly from MOVES). MOVES national default total population and

estimated local annual VMT of HPMS based vehicle type 60 are required as well for preliminary 

calculations. HPMS vehicle type 60 is the sum of MOVES vehicle type 61 and 62. The original data is in 

terms of HMPS vehicle type 60 as well and the goal here is to know what fraction of this VMT amount is 

from vehicle type 62 (filtering out vehicle type 61 in the process) on interstates with vehicles that could 

originate anywhere in the country. 
This preliminary calculation is:

local annual average total VMT by vehicle type 62=

HMPS vehicle type 60 local VMT x national default population vehicle type 62/(sum of national 

default population vehicle type 61+62))

The final calculation is:

vehicle type 62 population= 

local annual average total VMT by vehicle 62/national average VMT per vehicle 62.

HPMS vehicle type 60 local data used in this calculation is from TDM model-based annual VMT output 

data for the 20-county Atlanta region split by vehicle type based on MOVES defaults and HPMS counts. 

For the additional 25-county area, the same principle was applied as for the 20 counties in the Atlanta 

area with the population data grown from 2002 to 2007. However, 2011 National Emissions Inventory 

population data was available to use which was derived by growing the 2007 data further to 2011. The 

2007 and 2011 population data allowed for 2008 and 2010 values to be determined via linear 

interpolation. 2010 population was grown to 2013, 2016, 2024, 2030, and 2040 based on rate of growth 

of vehicle population observed for the 7 county Atlanta area (25 county ring is adjacent to the 7 county 

ring so growth should be equivalent) and used in this demonstration as well as other SIP and conformity 

work.

Ramp Fraction and Road Type Distribution

Atlanta Regional Commission (ARC)’s TDM model output provided road type distributions and ramp 

fractions based on travel networks developed by the ARC. Road fraction and road type distribution data 

were aggregated into 13-county and 7-county regions for the Atlanta data. 2013 data was linearly 

interpolated between 2010 and 2016 values for both ramp fraction and road type distribution. For the 

25 county area, ramp fractions for the 7 county area was employed as well as for road type distribution 

(this local data approach assuming similar road characteristics with neighboring ring of counties viewed 

as superior to use of just MOVES defaults or other alternatives).

Average Speed Distribution

ARC TDM output provided average speed distribution by road type and source type aggregated into 13 

and 7 counties. 2013 average speed distribution data for the Atlanta region were developed through 

linear interpolation between 2010 and 2016 values For the 25 additional counties, the 7-county average 

speed distribution was employed with this distribution assumed to not vary between these neighboring 

ringed areas (this local data approach is superior to just national MOVES defaults). Also, this assumption 

is conservative because there is likely more congestion in the 7 county area than 25 county area.
I/M coverage

The original 13 county Atlanta non-attainment area for the 1-hour based ozone NAAQS has an ongoing 

I/M program. The MOVES default database pertaining to Georgia starting in year 2002 were removed 

because the regular MOVES default databases have I/M information for Atlanta that are faulty; however 

this data is replaced by the input I/M coverage file. This local I/M data is provided from the Georgia EPD 

Mobile & Area Sources program’s I/M unit. The 7-county area and the remaining 25 counties in the 45-

county area of influence have no I/M program. Putnam County in the PM2.5 case was treating the same 

as the remaining 25 counties in the ozone case. 

County Year- Stage II vapor recovery efficiency

For SIP work and transportation conformity assessments the state of Georgia has assumed, for the 13-

county area, a vapor recovery efficiency of 81% during refueling with regards to any vapors released into 

the air. A 0% reduction in fuel spillage benefit has been determined. The 7-county area and remaining 

25 counties in the 45-county area of influence (and Putnam in the PM2.5 case) have no program so the 

default value of 0 is used. Stage II vapor recovery is being phased out of the Atlanta area, however, this 

is because of redundancy with the On-Board Refueling Vapor Recovery (ORVR) systems in newer motor 

vehicles (EPA has declared ORVR in “widespread use” as of May 16, 2012 (77 FR 28772)), so no 

additional VOC emissions will be seen in future years (2016, 2024, 2030, 2040) from this action, so the 

efficiency was not changed in MOVES 2010b which does not take into account the replacement with 

ORVR (ORVR efficiency and widespread use in >81% of vehicles actually makes this efficiency 

assumption conservative).

Fuel Type-Formulation

For all years analyzed in this study, it was assumed that 100 percent of the gasoline supply contained 

10% ethanol (E-10) and that the month investigated was July (typical summer day) to provide for 

maximum possible emissions values when applying the ozone NAAQS standard case. For the PM2.5 

NAAQS analysis, the fuel was annualized where each fuel blend was divided into fractions of use 

throughout the year and then these fractions were applied to one fuel month (July was the dummy 

month to match the ozone runs). The default fuel supply files from MOVES were modified to reflect this 

ethanol assumption for 2008 and 2010 model years (the rest already assumed in MOVES to be all E-10). 

The default values for MOVES for fuel supply/formulation that are used here for this demonstration are 

the same values utilized in the approved ozone maintenance SIP and submitted PM2.5 maintenance SIP 

as well as all FHWA approved Atlanta area conformity determinations (CDRs) since MOVES has been 

employed. By making these choices, a demonstration of non-interference in this case would assure that 

removal of the Georgia Marketing Rule would not interfere with attainment and conformity in all other 

cases. For the Georgia Gas case, nothing else was modified in the fuel supply or fuel formulation MOVES 
default database. For the conventional gas case, the RVP in the fuel formulation table was modified to 

reflect the 0.8 (13 county 1-hr ozone NAAQS nonattainment area consisting of Cherokee, Clayton, Cobb, 

Coweta, DeKalb, Douglass, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale counties)

and 2.0 RVP increase (rest of the area analyzed) with Georgia Marketing Rule removal. The input data is 

usually grouped into 13, 7, and 25 counties which represent the ozone attainment status within the 45 

county Georgia Marketing Rule area (13 counties from old 1-hr ozone NAAQS NAA, 7 counties added to 

13 county area for 1997 8-hr ozone NAAQS NAA (now maintenance, rest attainment). In the case of 

PM2.5 there is just the 20 county NAA plus a portion of Putnam County that are of concern, although 

fuel property differences require groupings of 13 and 7 counties (plus Putnam) for PM2.5 as well. 

The fuel blends in detail are illustrated in the Tables 2a-2c for ozone NAAQS and 2d-2e for PM2.5 NAAQS 

below (yellow areas are where fuel blend was changed from GA gasoline to conventional gasoline):
Table 2a. Fuel for Years 2013, 2016, 2024, 2030, and 2040.

13 Counties 7 Counties Remaining 25 Counties**

GA Gas Conv. Gas Diesel** Nat. Gas** GA Gas Conv. Gas Diesel** Nat. Gas**

Fuel Formulation ID 3847 3847 20011 30 3838 3838 20011 30

FuelSub type ID* 12 12 20 30 12 12 20 30

RVP 7.8 8.6 0 0 7.7 9.7 0 0

Sulfur Level 22.5787 22.5787 11 0 22.5787 22.5787 11 0

ETOH Volume 10 10 0 0 10 10 0 0

MTBE Volume 0 0 0 0 0 0 0 0

ETBE Volume 0 0 0 0 0 0 0 0

TAME Volume 0 0 0 0 0 0 0 0

Aromatic Content 26.6551 26.6551 0 0 26.6551 26.6551 0 0

Olefin Content 6.47 6.47 0 0 6.47 6.47 0 0

Benzene Content 0.6325 0.6325 0 0 0.6325 0.6325 0 0

e200 50.7634 50.7634 0 0 50.7634 50.7634 0 0

e300 88.5038 88.5038 0 0 88.5038 88.5038 0 0

Vol To Wt Percent 

Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel Ester 

Volume

Cetane Index

PAH Content

T50 198.258 198.258 0 0 198.258 198.258 0 0

T90 304.392 304.392 0 0 304.392 304.392 0 0

* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20 means diesel, 30 means natural gas.

** Zeroes in this column indicate that these variables do not apply in emissions calculations for this non-gasoline fuel.
Table 2b. Fuel Year 2010 (Assuming all E-110) Used to Help Illustrate Trends.

* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20 means diesel, 30 means natural gas.

** Zeroes in this column indicate that these variables do not apply in emissions calculations for this non-gasoline fuel.

***Only difference between 7 and 25 county fuels is benzene content which has zero impact on VOC and Nox emissions future fuel.

and this benzene difference is not seen in any current or future fuel.

13 Counties 7 Counties Remaining 25 Counties***

GA Gas Conv. 

Gas

Diesel** Nat. 

Gas**

GA Gas Conv. 

Gas

Diesel** Nat. 

Gas**

GA Gas Conv. 

Gas

Diesel** Nat. 

Gas**

Fuel 

Formulation ID

3135 3135 20011 30 3124 3124 20011 30 3130 3130 20011 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30 12 12 20 30

RVP 7.48571 8.28571 0 0 7.41429 9.41429 0 0 7.41429 9.414

29

0 0

Sulfur Level 30 30 11 0 30 30 11 0 30 30 11 0

ETOH Volume 10 10 0 0 10 10 0 0 10 10 0 0

MTBE Volume 0 0 0 0 0 0 0 0 0 0 0 0

ETBE Volume 0 0 0 0 0 0 0 0 0 0 0 0

TAME Volume 0 0 0 0 0 0 0 0 0 0 0 0

Aromatic 

Content

28.5165 28.5165 0 0 28.5165 28.5165 0 0 28.5165 28.51

65

0 0

Olefin Content 6.47 6.47 0 0 6.47 6.47 0 0 6.47 6.47 0 0

Benzene 

Content

0.64 0.64 0 0 0.64 0.64 0 0 0.8 0.8 0 0

e200 47.7167 47.7167 0 0 47.7167 47.7167 0 0 47.7167 47.71

67

0 0

e300 86.3913 86.3913 0 0 86.3913 86.3913 0 0 86.3913 86.39

13

0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0 0.3488 0.348

8

0 0

BioDiesel Ester 

Volume

Cetane Index

PAH Content

T50 204.476 204.476 0 0 204.476 204.476 0 0 204.476 204.4

76

0 0

T90 313.994 313.994 0 0 313.994 313.994 0 0 313.994 313.9

94

0 0
Table 2c. Fuel for Year 2008 (Assuming all E-10) Used to Help Illustrate Trends.

13 Counties 7 Counties Remaining 25 Counties***

GA Gas Conv. 

Gas

Diesel** Nat. 

Gas**

GA Gas Conv. 

Gas

Diesel** Nat. 

Gas**

GA Gas Conv. 

Gas

Diesel** Nat. 

Gas**

Fuel 

Formulation 

ID

2334 2334 20043 30 2323 2323 20043 30 2329 2329 20043 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30 12 12 20 30

RVP 7.17143 7.97143 0 0 7.12857 9.12857 0 0 7.12857 9.12857 0 0

Sulfur Level 28.1775 28.1775 43 0 28.1775 28.1775 43 0 28.1775 28.1775 43 0

ETOH 

Volume

10 10 0 0 10 10 0 0 10 10 0 0

MTBE 

Volume

0 0 0 0 0 0 0 0 0 0 0 0

ETBE Volume 0 0 0 0 0 0 0 0 0 0 0 0

TAME 

Volume

0 0 0 0 0 0 0 0 0 0 0 0

Aromatic 

Content

30.3779 30.3779 0 0 30.3779 30.3779 0 0 30.3779 30.3779 0 0

Olefin 

Content

6.47 6.47 0 0 6.47 6.47 0 0 6.47 6.47 0 0

Benzene 

Content

0.94 0.94 0 0 0.94 0.94 0 0 1.09 1.09 0 0

e200 44.67 44.67 0 0 44.67 44.67 0 0 44.67 44.67 0 0

e300 84.2788 84.2788 0 0 84.2788 84.2788 0 0 84.2788 84.2788 0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel 

Ester 

Volume

Cetane Index

PAH Content

T50 210.694 210.694 0 0 210.694 210.694 0 0 210.694 210.694 0 0

T90 323.596 323.596 0 0 323.596 323.596 0 0 323.596 323.596 0 0

* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20 means diesel, 30 means natural gas.

** Zeroes in this column indicate that these variables do not apply in emissions calculations for this non-gasoline fuel.

***Only difference between 7 and 25 county fuels is benzene content which has zero impact on VOC and Nox emissions future fuel

and this benzene difference is not seen in any current or future fuel.
Table 2d. Fuel for Years 2016, 2024, 2030, and 2040

Summer Months (33.3% of the year, months 6,7,8, and 9)

13 Counties 7 Counties

GA Gas Conv. Gas Diesel** Nat. Gas** GA Gas Conv. Gas Diesel** Nat. Gas**

Fuel 

Formulation 

ID

3847 3847 20011 30 3838 3838 20011 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30

RVP 7.8 8.6 0 0 7.7 9.7 0 0

Sulfur Level 22.5787 22.5787 11 0 22.5787 22.5787 11 0

ETOH 

Volume

10 10 0 0 10 10 0 0

MTBE 

Volume

0 0 0 0 0 0 0 0

ETBE 

Volume

0 0 0 0 0 0 0 0

TAME 

Volume

0 0 0 0 0 0 0 0

Aromatic 

Content

26.6551 26.6551 0 0 26.6551 26.6551 0 0

Olefin 

Content

6.47 6.47 0 0 6.47 6.47 0 0

Benzene 

Content

0.6325 0.6325 0 0 0.6325 0.6325 0 0

e200 50.7634 50.7634 0 0 50.7634 50.7634 0 0

e300 88.5038 88.5038 0 0 88.5038 88.5038 0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel 

Ester 

Volume

Cetane 

Index

PAH Content

T50 198.258 198.258 0 0 198.258 198.258 0 0

T90 304.392 304.392 0 0 304.392 304.392 0 0
Table 2d. (Continued) Fuel for Years 2016, 2024, 2030, and 2040

Fall/Spring Months (41.7% of the year, months 3,4,5,10, and 11) Where Georgia Gas and Conventional 

Gas are Identical

13 Counties 7 Counties

GA Gas Conv. Gas Diesel** Nat. Gas** GA Gas Conv. Gas Diesel** Nat. Gas**

Fuel 

Formulation 

ID

3846 3846 20011 30 3837 3837 20011 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30

RVP 10.1143 10.1143 0 0 10.0571 10.0571 0 0

Sulfur Level 23.9192 23.9192 11 0 23.9192 23.9192 11 0

ETOH 

Volume

10 10 0 0 10 10 0 0

MTBE 

Volume

0 0 0 0 0 0 0 0

ETBE 

Volume

0 0 0 0 0 0 0 0

TAME 

Volume

0 0 0 0 0 0 0 0

Aromatic 

Content

24.4686 24.4686 0 0 24.4686 24.4686 0 0

Olefin 

Content

7.09571 7.09571 0 0 7.09571 7.09571 0 0

Benzene 

Content

0.611071 0.611071 0 0 0.611071 0.611071 0 0

e200 52.8114 52.8114 0 0 52.8114 52.8114 0 0

e300 88.2882 88.2882 0 0 88.2882 88.2882 0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel 

Ester 

Volume

Cetane 

Index

PAH Content

T50 194.079 194.079 0 0 194.079 194.079 0 0

T90 305.372 305.372 0 0 305.372 305.372 0 0
Table 2d. (Continued). Fuel for Years 2016, 2024, 2030, and 2040

Winter Months (25% of the year, months 1,2, and 12) Where Georgia Gas and Conventional Gas are 

Identical

13 Counties 7 Counties

GA Gas Conv. Gas Diesel** Nat. Gas** GA Gas Conv. Gas Diesel** Nat. Gas**

Fuel 

Formulation 

ID

3836 3836 20011 30 3836 3836 20011 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30

RVP 13.2 13.2 0 0 13.2 13.2 0 0

Sulfur Level 25.7066 25.7066 11 0 25.7066 25.7066 11 0

ETOH 

Volume

10 10 0 0 10 10 0 0

MTBE 

Volume

0 0 0 0 0 0 0 0

ETBE 

Volume

0 0 0 0 0 0 0 0

TAME 

Volume

0 0 0 0 0 0 0 0

Aromatic 

Content

21.5534 21.5534 0 0 21.5534 21.5534 0 0

Olefin 

Content

7.93 7.93 0 0 7.93 7.93 0 0

Benzene 

Content

0.5825 0.5825 0 0 0.5825 0.5825 0 0

e200 55.5422 55.5422 0 0 55.5422 55.5422 0 0

e300 88.0009 88.0009 0 0 88.0009 88.0009 0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel 

Ester 

Volume

Cetane 

Index

PAH Content

T50 188.506 188.506 0 0 188.506 188.506 0 0

T90 306.678 306.678 0 0 306.678 306.678 0 0

* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20 means diesel, 30 means natural gas.

** Zeroes in this column indicate that these variables do not apply in emissions calculations for this non-gasoline fuel.
Table 2e. Fuel for Year 2008 (Assuming All E-10) Used to Illustrate Trends.

Summer Months (33.3% of the year, months 6,7,8, and 9)

13 Counties 7 Counties

GA Gas Conv. Gas Diesel** Nat. Gas** GA Gas Conv. Gas Diesel** Nat. Gas**

Fuel 

Formulation 

ID

2334 2334 20043 30 2323 2323 20043 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30

RVP 7.17143 7.97143 0 0 7.12857 9.12857 0 0

Sulfur Level 28.1775 28.1775 43 0 28.1775 28.1775 43 0

ETOH 

Volume

10 10 0 0 10 10 0 0

MTBE 

Volume

0 0 0 0 0 0 0 0

ETBE 

Volume

0 0 0 0 0 0 0 0

TAME 

Volume

0 0 0 0 0 0 0 0

Aromatic 

Content

30.3779 30.3779 0 0 30.3779 30.3779 0 0

Olefin 

Content

6.47 6.47 0 0 6.47 6.47 0 0

Benzene 

Content

0.94 0.94 0 0 0.94 0.94 0 0

e200 44.67 44.67 0 0 44.67 44.67 0 0

e300 84.2788 84.2788 0 0 84.2788 84.2788 0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel 

Ester 

Volume

Cetane 

Index

PAH Content

T50 210.694 210.694 0 0 210.694 210.694 0 0

T90 323.596 323.596 0 0 323.596 323.596 0 0
Table 2e. (Continued) Fuel for Year 2008

Fall/Spring Months (41.7% of the year, months 3,4,5,10, and 11) Where Georgia Gas and Conventional 

Gas are Identical

13 Counties 7 Counties

GA Gas Conv. Gas Diesel** Nat. Gas** GA Gas Conv. Gas Diesel** Nat. Gas**

Fuel 

Formulation 

ID

2333 2333 20043 30 2322 2322 20043 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30

RVP 9.62531 9.62531 0 0 9.6008 9.6008 0 0

Sulfur Level 29.13 29.13 43 0 29.13 29.13 43 0

ETOH 

Volume

10 10 0 0 10 10 0 0

MTBE 

Volume

0 0 0 0 0 0 0 0

ETBE 

Volume

0 0 0 0 0 0 0 0

TAME 

Volume

0 0 0 0 0 0 0 0

Aromatic 

Content

28.1796 28.1796 0 0 28.1796 28.1796 0 0

Olefin 

Content

7.09571 7.09571 0 0 7.09571 7.09571 0 0

Benzene 

Content

0.871429 0.871429 0 0 0.871429 0.871429 0 0

e200 47.4849 47.4849 0 0 47.4849 47.4849 0 0

e300 84.13 84.13 0 0 84.13 84.13 0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel 

Ester 

Volume

Cetane 

Index

PAH Content

T50 204.949 204.949 0 0 204.949 204.949 0 0

T90 324.273 324.273 0 0 324.273 324.273 0 0
Table 2e. (Continued) Fuel for Year 2008

Winter Months (25% of the year, months 1,2, and 12) Where Georgia Gas and Conventional Gas are 

Identical

13 Counties 7 Counties

GA Gas Conv. Gas Diesel** Nat. Gas** GA Gas Conv. Gas Diesel** Nat. Gas**

Fuel 

Formulation 

ID

2321 2321 20043 30 2321 2321 20043 30

FuelSub type 

ID*

12 12 20 30 12 12 20 30

RVP 12.8971 12.8971 0 0 12.8971 12.8971 0 0

Sulfur Level 30.4 30.4 43 0 30.4 30.4 43 0

ETOH 

Volume

10 10 0 0 10 10 0 0

MTBE 

Volume

0 0 0 0 0 0 0 0

ETBE 

Volume

0 0 0 0 0 0 0 0

TAME 

Volume

0 0 0 0 0 0 0 0

Aromatic 

Content

25.2486 25.2486 0 0 25.2486 25.2486 0 0

Olefin 

Content

7.93 7.93 0 0 7.93 7.93 0 0

Benzene 

Content

0.78 0.78 0 0 0.78 0.78 0 0

e200 51.2381 51.2381 0 0 51.2381 51.2381 0 0

e300 83.9318 83.9318 0 0 83.9318 83.9318 0 0

Vol To Wt 

Percent Oxy

0.3488 0.3488 0 0 0.3488 0.3488 0 0

BioDiesel 

Ester 

Volume

Cetane 

Index

PAH Content

T50 197.29 197.29 0 0 197.29 197.29 0 0

T90 325.174 325.174 0 0 325.174 325.174 0 0

* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20 means diesel, 30 means natural gas.

** Zeroes in this column indicate that these variables do not apply in emissions calculations for this non-gasoline fuel.
Meteorology:

The same meteorological assumptions regarding temperature and relative humidity were employed 

here as in the Atlanta maintenance plan for the 1997 8-hr ozone NAAQS which is “typical July” (based on 

July 2008) and the submitted Atlanta maintenance plan for the 1997 annual PM2.5 NAAQS (annualized 

meteorology based on 2008). For the 25 county area Floyd&Bartow county meteorology (2008, typical 

July and same year as the other groupings) was applied which is a good fit since the average maximum 

temperatures are a little higher (and relative humidity a little lower) than Atlanta. Although Atlanta is in 

the center of the 25 county ring and would make a good average, we chose this approach since it 

includes one of the 25 counties, is conservative (higher emissions), and makes sure we took into account 

the slightly higher influence of the southern warmer counties near Macon. 

Extra Notes:

For Putnam county, the whole county was run in MOVES with emissions calculated based on the above 

input methodologies and then a fraction (0.164) was applied to the nonattainment portion, the fraction 

identical to what was applied in the submitted PM2.5 maintenance plan (represents fraction of Putnam 

county’s population residing in NAA portion). Heard county is also in the NAA, but has no regular 

vehicular traffic so no emissions are assessed to it.

Other variables for MOVES inputs were taken directly from inputs used in the relevant maintenance plan 

for the relevant NAAQS.
Methodology for 15-county Non-Attainment Area Aggregated Input Data 

Collection for This Analysis

The Atlanta area was designated nonattainment in 1991 for 13-counties for the 1990 1-hour ozone 

standard: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, 

Paulding, and Rockdale. 

On April 30, 2004, EPA designated 20-counties as nonattainment area under the 1997 8-hour ozone 

standard. The eight-hour ozone nonattainment area encompasses the 13-counties of the former 1-hour 

ozone nonattainment area plus seven additional "ring" counties. These 7-counties included the counties 

of Barrow, Bartow, Carroll, Hall, Newton, Spalding, and Walton. 

On May 21, 2012, EPA published a final rule in the federal register designating a new 15-county Atlanta 

area marginal nonattainment for the 2008 8-hour Ozone National Ambient Air Quality Standard. The 15-

county area includes the counties of Bartow, Cherokee, Clayton, Cobb, Coweta, Dekalb, Douglas, Fayette, 

Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, and Rockdale.

This section of the document shows the methodology used to aggregate input data from 15 counties for 

the Georgia Marketing Analysis for the Rule Removal SIP. 

Data was aggregated into input files for the new 15-county NAA for the 2008 8-hr ozone NAAQS by the 

following steps:

Emissions information already compiled and interpolated for the 13-county area in the TDM network 

was kept as it was, since the 13-county area is a subset of the 15 counties. However, the data for two 

counties, Bartow and Newton, would need to be disaggregated from the 7-counties data.

For the 2 counties, it was assumed that the characteristics were similar to the 7 counties (hence why it 

was okay for them to be aggregated to the other 5 in the first place) so distributions for the 2 counties 

were identical as were used as inputs for the 7-county case. Inputs included average speed 

distributions, age distributions, road type distributions, vmt fractions (hour, day and month), ramp 

fractions, inspection and maintenance program (there was none), and meteorology (same geographic 

area). Two inputs that required a reanalysis were vehicle population and annual average daily vehicle 

miles traveled (AADVMT). National Emissions Inventory (NEI) data for 2011 for Bartow and Newton 

counties were combined and used as initial values. Initial 2011 values were “grown” to produce input 

values for 2013, 2016, 2024, 2030, 2040 (the same years as for the 1997 ozone NAAQS analysis except 

only focusing on the present and future year impacts) by multiplying the 2011 vehicle population and 

AADVMT by the percent increase in these variables between model network years for the 7-county area.

Fuel blend for the 2 counties had to take into account a 2.0 psi increase with Georgia Gasoline removal 

and not 0.8 because they were not in the former nonattainment area for the now revoked 1-hr ozone 

NAAQS so the RVP rule for general conventional gasoline (9.0 psi + 1.0 psi ethanol waiver) areas applies 

there. 
In order to grow the inputs from 2011 to 2013, an assumption had to be made to rely on a trend from 

2010 to 2013 since there was no 2011 network and that the trend would not vary significantly between 

these years. The MOVES model was run with the 2 county inputs for the Georgia Gas and conventional 

gasoline cases for each year and pollutant. 

By adding the 13-county and the 2-county emissions together for each pollutant (NOx and VOCs) for 

each year for the Georgia gasoline and conventional gasoline cases, Georgia EPD was able to illustrate 

impact of removal of Georgia Marketing Rule for the current non-attainment area in place for the 2008 

ozone NAAQS.
Total Inventory Analysis

In Georgia’s Redesignation Request and Maintenance Plan for the Atlanta 1997 8-hour Ozone 

Nonattainment Area and 1997 PM2.5 Nonattainment Area, it was demonstrated that future (through 

2024) total NOx and VOC emissions from all identified sources remained well below the emissions levels 

calculated in 2008, the year Atlanta attained the 1997 8-hour ozone and PM2.5 NAAQS (“Attainment 

Inventory”). A similar demonstration is made below to illustrate how removal of the Gasoline Marketing 

Rule will not impact Atlanta’s ability to maintain total emissions well below the Attainment Inventory. In 

fact, Figures 4a-b, 5 and Tables 4a-b, 5 not only confirm that conventional gas emissions remain below 

the Attainment Inventory, but also show how:

 The difference between the Attainment Inventory and future total emissions with both Georgia 

and conventional gasoline increase over time

 Emissions decrease over time for both the Georgia Gasoline and Conventional Gasoline case

(Gasoline Marketing rule removed along with more stringent conventional gasoline 

nonattainment area RVP requirements still in place for 13 counties)

 Total emissions as depicted by lines and points are nearly indistinguishable between the Georgia 

Gasoline and Conventional Gasoline case

Most of the emission years used for the demonstration in the Maintenance Plan for the Atlanta 1997 8-

hour Ozone and PM2.5 Nonattainment Areas (2008, 2014, 2017, 2020, and 2030) differed from the 

years applied in this Gasoline Marketing Rule analysis (2008, 2010, 2013, 2016, 2024, 2030, 2040) which 

is based on the network years available in the ARC TDM. To match the years and provide a good 

comparison, emissions for the Georgia Gasoline and conventional gasoline cases were interpolated 

between TDM years to match up with the Maintenance Plan inventory years. The total emissions for a 

given year in the Maintenance Plan demonstration (beyond the attainment year) are the same as the 

total emissions inventory in the Georgia Gasoline case since Georgia Gasoline was the fuel formulation 

used in the Maintenance Plan. The total emissions including Georgia Gasoline and the increase in 

emissions from switch over to conventional gas were added together to obtain a total inventory for 

conventional gasoline. 
Figure 4a: Comparison of Total NOx Emissions With Conventional Gas versus Emissions Limits

0

100

200

300

400

500

600

700

2010 2012 2014 2016 2018 2020 2022 2024 2026

N

O

x

E

mis

sio

n

s (to

n

s/d

a

y)

Year

NOx Total Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Total Inventory vs. 2008 Attainment Inventory

Table 4a: Comparison of Total NOx Emissions With Conventional Gas versus Emission Limits

Year Total 

Total 

Emissions 

Total 

Emissions The Margin:

Margin 

allotted

% of Margin 

allotted

Remaining 

Margin:

2008 Inventory Inventory

2008 

Attainment to switch to to switch to

2008 

Attainment 

Attainment

Georgia 

Gasoline

Conventional 

Gasoline

Inventory -

Total 

Emissions 

conventional 

gasoline

conventional 

gasoline

Inventory -

Total 

Emissions 

Inventory

using 

Georgia 

Gasoline

using 

Conventional 

Gasoline

tpd Tpd tpd tpd tpd % tpd

2010 606.78 564.39 566.20 42.39 1.81 4.27 40.58

2013 606.78 500.80 502.11 105.98 1.32 1.24 104.67

2014 606.78 479.60 480.77 127.18 1.17 0.92 126.01

2016 606.78 437.21 438.07 169.57 0.87 0.51 168.71

2017 606.78 416.01 416.84 190.77 0.83 0.43 189.94

2020 606.78 367.67 368.40 239.11 0.73 0.30 238.38

2024 606.78 303.19 303.35 303.59 0.16 0.05 303.43

2030 606.78 206.47 206.55 400.31 0.08 0.02 400.23
Difference between the Attainment Inventory and Total Emissions using Georgia Gasoline is referred to 

as “The Margin” since this is like a safety margin between actual emissions and the level at which an 

increase in emissions would lead to concerns over resulting nonattainment. This margin increases to 

over 400 tons/day of NOx by 2030 with the increase in emissions with Gasoline Marketing rule removal 

less than 0.1 tons/day or just 0.02% of the margin. By 2040 there is no difference in NOx emissions 

between Georgia Gas and conventional gas.

Figure 4b: Comparison of Total VOC Emissions with Conventional Gas versus Emissions Limits.

0

100

200

300

400

500

600

2010 2015 2020 2025 2030

V

O

C

E

mis

sio

n

s (to

n

s/d

a

y)

Year

VOC On-Road Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Total Inventory vs. 2008 

Attainment Inventory

Total Inventory Conventional Gas

Total Inventory Georgia Gasoline

Total 2008 Attainment Inventory
Table 4b: Comparison of Total VOC Emissions with Conventional Gas versus Emissions Limits

Year Total 

2008

Attainment

Inventory

Total 

Emissions 

Inventory

Georgia 

Gasoline

Total 

Emissions 

Inventory

Conventional 

Gasoline

The Margin:

2008 

Attainment 

Inventory -

Total

Emissions 

using 

Georgia 

Gasoline

Margin 

allotted

to switch to

Conventional 

Gasoline

% of Margin 

allotted

to switch to

Conventional 

Gasoline

Remaining 

Margin:

2008 

Attainment 

Inventory -

Total 

Emissions 

using 

Conventional 

Gasoline

tpd tpd tpd tpd tpd % tpd

2010 491.82 481.47 485.57 10.35 4.10 39.57 6.25

2013 491.82 465.94 469.29 25.88 3.35 12.93 22.53

2014 491.82 460.76 463.79 31.06 3.03 9.76 28.03

2016 491.82 450.41 452.80 41.41 2.39 5.77 39.02

2017 491.82 445.23 447.60 46.59 2.37 5.08 44.22

2020 491.82 440.23 442.57 51.59 2.34 4.54 49.25

2024 491.82 433.35 434.66 58.47 1.31 2.24 57.16

2030 491.82 423.03 424.10 68.79 1.07 1.56 67.72

Difference between the Attainment Inventory and Total Emissions using Georgia Gasoline is referred to 

as “The Margin” since this is like a safety margin between actual emissions and the level at which an 

increase in emissions would lead to concerns over resulting nonattainment. This margin increases to 

over 67.72 tons/day of VOC by 2030 with the increase in emissions with Gasoline Marketing rule 

removal near 1.1 tons/day or just 1.5% of the margin.
Figure 5: Comparison of Total PM2.5 Emissions with Conventional Gas versus Emissions Limits

50

150

250

350

450

550

650

750

850

2010 2015 2020 2025 2030 2035 2040

N

O

x

E

missio

n

s (to

n

s/d

a

y)

Year

PM2.5 NOx On-Road Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Total Inventory vs. 2008 

Attainment Inventory

Total Inventory Conventional Gas Total Inventory Georgia Gasoline

Total 2008 Attainment Inventory

Table 5: Comparison of Total PM2.5 Emissions with Conventional Gas versus Emissions Limits

Year Total

2008

Attainment

Inventory

Total 

Emissions

Inventory

Georgia 

Gasoline

Total 

Emissions

Inventory

Conventional 

Gasoline

The Margin:

2008 

Attainment

Inventory -

Total 

Emissions

using Georgia 

Gasoline

Margin 

allotted

to switch to

conventional 

gasoline

% of Margin 

allotted

to switch to

conventional 

gasoline

Remaining 

Margin:

2008 

Attainment

Inventory -

Total 

Emissions

using 

Conventional 

Gasoline

tpd tpd tpd tpd tpd % tpd

2014 743.92 539.48 539.80 204.44 0.32 0.15 204.12

2016 743.92 471.44 471.72 272.48 0.28 0.10 272.20

2017 743.92 437.42 437.68 306.50 0.26 0.08 306.24

2020 743.92 391.43 391.66 352.49 0.23 0.07 352.26

2024 743.92 330.22 330.27 413.70 0.05 0.01 413.65

2030 743.92 238.40 238.44 505.52 0.04 0.01 505.48
The margin in this PM2.5 case increases to over 500 tons/day of NOx by 2030 with the increase in 

emissions with Gasoline Marketing rule removal less than 0.04 tons/day or less than 0.01% of the 

margin. By 2040 there is no difference in PM2.5 NOx emissions between Georgia Gas and conventional 

gas.