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Table of Contents 

Letter: 9/16/2005, B. Keith Overcash, NCDAQ’s request for comments on geographic extent for 

motor vehicle emissions budgets for attainment demonstrations ........................................1 

Letter: 2/8/2006, Mike Nunn, Cabarrus-Rowan Urban Area Metropolitan Planning 

Organization’s response letter to NCDAQ’s 9/16/2005 letter .............................................4 

Letter: 1/31/2006, Dan Thomas, North Carolina Department of Transportation’s response letter 

to NCDAQ’s 9/16/2006 letter ..............................................................................................5 

Letter: 2/16/2006, James H. Graham, Gaston Urban Area Metropolitan Planning Organization, 

Robert W. Cook, Mecklenburg-Union Metropolitan Planning Organization, Rebecca 

Yarbrough, Lake Norman and Rocky River Rural Planning Organizations, response letter 

to NCDAQ’s 9/16/2006 letter ..............................................................................................7 

Email: 2/19/2006, Roland Tilley, Citizens for Smart Growth’s response to NCDAQ’s 9/16/2005 

letter ...................................................................................................................................24 

Letter: 6/21/2006, B. Keith Overcash, Response to Cabarrus-Rowan Urban Area Metropolitan 

Planning Organization’s 2/8/2006 letter ............................................................................25 

Letter: 6/21/2006, B. Keith Overcash, Response to North Carolina Department of 

Transportation’s 1/31/2006 letter .......................................................................................26 

Letter: 6/21/2006, B. Keith Overcash, Response to Gaston Urban Area Metropolitan Planning 

Organization, Mecklenburg-Union Metropolitan Planning Organization, Lake Norman 

Rural Planning Organization and Rocky River Rural Planning Organization 2/16/2006 

letter ...................................................................................................................................27 

Letter: 4/15/2004. Michael O. Leavitt, The USEPA’s 8-hour Ozone Nonattainment Boundary 

Designation ........................................................................................................................29 

Guidance Document: 8/15/2006, William T. Harnett, “8-Hour Ozone National Ambient Air 

Quality Standards (NAAQS) Implementation – Reasonable Further Progress 

(RFP)” ................................................................................................................................32 

Guidance Document: 11/29/2005, “Phase II 8-Hour Ozone Implementation Rule, Appendix A to 

Preamble” ...........................................................................................................................42 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

 April 15, 2004

THE ADMINISTRATOR

Honorable Michael Easley

Governor of North Carolina

20301 Mail Service Center

Raleigh, North Carolina 27699-0301

Dear Governor Easley:

Today, we enter a new chapter in our country’s clean air commitment. President Bush

outlined this chapter when he directed the Environmental Protection Agency (EPA) to implement a

national Clean Air strategy committing us to make the years ahead one of the most productive

periods of air quality improvement in our nation’s history. 

The last 35 years have seen a growing commitment to clean air and a progression of science

and technology that has informed our decision-making and guided our actions. I often think of our

clean air history as a relay where a baton is passed from generation to generation and from

Administration to Administration. It is a relay in which we must all be involved and a relay where

our participation is never done. This Administration has made a commitment to accelerate our clean

air progress so that all Americans live healthier, longer, more productive and prosperous lives. It is

a commitment to no turning around or backsliding in air quality improvement. 

Part of our nation’s commitment to clean, healthy air deals with reducing levels of ozone. 

That effort began in the1970s with a 1-hour standard for ozone — now, in 2004, the more protective,

health-based 8-hour ozone standard is ready for implementation.

Today, I fulfill my legal obligation under the Clean Air Act to issue final designations for all

areas of the country for the 8-hour ozone standard. The enclosed table identifies the areas in your

state that are designated as nonattainment, meaning that some areas of your state do not meet the

more protective, health-based 8-hour ozone standard. I am also today deferring the designation date

for the areas in your state participating in Early Action Compacts. I am confident that your

commitment and the actions you are taking in these areas will result in achieving clean air faster.

 Having been through this process as a governor myself, I recognize that having parts of your

state designated as being in nonattainment will require more actions on your part to achieve cleaner,

healthier air. This ozone standard is strong medicine, and we need to work together to

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2

make certain your state can, as others have in the past, clean the air while sustaining economic

growth. That is why the President has asked EPA to develop tools that reduce the transport of

pollution across state boundaries.

During 2004, we are issuing a suite of national Clean Air Rules as part of the President’s

strategy that will specifically address the transport of pollution. These national rules and other clean

air actions will bring the vast majority of areas of the country into attainment with this standard over

the next 15 years. The Clean Air Rules, when fully implemented, will cut power plant emissions of

sulfur dioxides, nitrogen oxides and mercury by nearly 70 percent, and will also reduce emissions

from off-road diesel fuels, vehicles and engines by over 90 percent — those black puffs of smoke

are going to be a thing of the past. Together, these Clean Air Rules will build on the tremendous

progress made over the last 30 years, and do it in record time. 

We have a national strategy and tools to provide people with cleaner, healthier air now and in

the future. The result is more protection, faster and ensures that clean air and a prosperous economy

will be this generation’s contribution to our children and grandchildren.

Sincerely, 

/s/

Michael O. Leavitt 

Enclosure

cc (w/enclosure): 

 Ms. Robin Smith, Assistant Secretary for Environmental Protection

 North Carolina Environment and Natural Resources Department

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Enclosure

Boundary Designations for 8-hour Ozone Standards for North Carolina

(P) - Partial Counties

(EAC) - Early Action Compacts

Nonattainment Area

Name

Counties Classification Maximum

Attainment Date

(from June 15, 2004)

Charlotte-Gastonia-Rock

Hill, NC-SC

Gaston 

Mecklenburg 

Cabarrus 

Iredell (P)

Lincoln 

Rowan 

Union

Moderate June 2010

Greensboro-WinstonSalem-High Point, NC

(EAC)

Davidson 

Davie 

Forsyth 

Guilford

Alamance 

Caswell 

Randolph

Rockingham 

Moderate Dec 2007

Raleigh-Durham-Chapel

Hill, NC

Durham

Granville

Wake

Chatham (P)

Franklin 

Johnston 

Orange 

Person

Basic June 2009

Hickory-MorgantonLenoir, NC

(EAC)

Alexander

Burke (P)

Caldwell (P) 

Catawba

Basic Dec 2007

Haywood and Swain Cos

(Great Smoky Mountains

National Park), NC

Haywood (P)

Swain (P)

Basic June 2009

Fayetteville, NC

(EAC)

Cumberland Basic Dec 2007

Rocky Mount, NC Edgecomb 

Nash

Basic June 2009

Note: Remainder of state is attainment

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71696 Federal Register / Vol. 70, No. 228 / Tuesday, November 29, 2005 / Rules and Regulations 

119These methods assume the use of EPA’s onroad motor vehicle emissions model in all States 

other than California. All of the methods given here 

require the user to turn off all post-1990 CAA 

measures as part of the calculation. In EPA’s current 

motor vehicle emissions model, MOBILE6.2, this is 

accomplished using the NO CLEAN AIR ACT 

command as described in the MOBILE6.2 User’s 

Guide (found at http://www.epa.gov/otaq/m6.htm). 

Users of future versions of EPA’s motor vehicle 

emissions model should consult the appropriate 

User’s Guide for the version of the model they are 

using for instructions on what model command to 

use. For California nonattainment areas, the current 

motor vehicle emissions model is EMFAC2002. 

Users modeling California nonattainment areas 

should consult with the EPA Regional Office for 

information on doing equivalent calculations in that 

model and in future versions. 

Appendix A to Preamble—Methods to 

Account for Non-Creditable Reductions 

When Calculating ROP Targets for the 

2008 and Later ROP Milestone Years 

The following methods properly 

account for the non-creditable emissions 

reductions when calculating ROP targets 

for the 2008 and later ROP milestone 

years.119 They are consistent with 

requirements of sections 182(b)(1)(C) 

and (D) and 182(c)(2)(B) of the CAA. 

(1) Method 1: For areas that must 

meet a 15 percent VOC reduction 

requirement by 2008: 

(A) Estimate the actual anthropogenic 

base year VOC inventory in 2002 with 

all 2002 control programs in place for 

all sources. 

(B) Using the same highway vehicle 

activity inputs used to calculate the 

actual 2002 inventory, run the 

appropriate motor vehicle emissions 

model for 2002 and for 2008 with all 

post-1990 CAA measures turned off. 

Any other local inputs for vehicle 

inspection and maintenance (I/M) 

programs should be set according to the 

program that was required to be in place 

in 1990. Fuel Reid Vapor Pressure (RVP) 

should be set at 9.0 or 7.8 depending on 

the RVP required in the local area as a 

result of fuel RVP regulations 

promulgated in June, 1990. 

(C) Calculate the difference between 

the 2002 and 2008 VOC emission factors 

calculated in Step B and multiply by 

2002 vehicle miles traveled (VMT). The 

result is the VOC emissions reductions 

that will occur between 2002 and 2008 

without the benefits of any post-1990 

CAA measures. These are the noncreditable reductions that occur over 

this period. 

(D) Subtract the non-creditable 

reductions calculated in Step C from the 

actual anthropogenic 2002 inventory 

estimated in Step A. This adjusted VOC 

inventory is the basis for calculating the 

target level of emissions in 2008. 

(E) Reduce the adjusted VOC 

inventory calculated in Step D by 15 

percent. The result is the target level of 

VOC emissions in 2008 in order to meet 

the 2008 ROP requirement. The actual 

projected 2008 inventory for all sources 

with all control measures in place and 

including projected 2008 growth in 

activity must be at or lower than this 

target level of emissions. 

(2) Method 2: For areas covered under 

40 CFR 51.910(a)(1)(ii)(C) and that meet 

an 18 percent VOC emission reduction 

requirement by 2008 with NOX

substitution allowed, following EPA’s 

NOX Substitution Guidance: 

(A) Estimate the actual anthropogenic 

base year inventory for both VOC and 

NOX in 2002 with all 2002 control 

programs in place. 

(B) Using the same highway vehicle 

activity inputs used to calculate the 

actual 2002 inventory, run the 

appropriate motor vehicle emissions 

model for 2002 and for 2008 with all 

post-1990 CAA measures turned off. 

Any other local inputs for I/M programs 

should be set according to the program 

that was required to be in place in 1990. 

Fuel RVP should be set at 9.0 or 7.8 

depending on the RVP required in the 

local area as a result of fuel RVP 

regulations promulgated in June, 1990. 

(C) Calculate the difference between 

2002 and 2008 VOC emissions factors 

calculated in Step B and multiply by 

2002 VMT. The result is the VOC 

emissions reductions that will occur 

between 2002 and 2008 without the 

benefits of any post-1990 CAA 

measures. These are the non-creditable 

VOC reductions that occur over this 

period. Calculate the difference between 

2002 and 2008 NOX emissions factors 

calculated in Step B and multiply by 

2002 VMT. This result is the NOX

emissions reductions that will occur 

between 2002 and 2008 without the 

benefits of any post-1990 CAA 

measures. These are the non-creditable 

NOX reductions that occur over this 

period. 

(D) Subtract the non-creditable VOC 

reductions calculated in Step C from the 

actual anthropogenic 2002 VOC 

inventory estimated in Step A. Subtract 

the non-creditable NOX reductions 

calculated in Step C from the actual 

anthropogenic 2002 NOX inventory 

estimated in Step A. These adjusted 

VOC and NOX inventories are the basis 

for calculating the target level of 

emissions in 2008. 

(E) The target level of VOC and NOX

emissions in 2008 needed to meet the 

2008 ROP requirement is any 

combination of VOC and NOX

reductions from the adjusted inventories 

calculated in Step D that total 18 

percent. For example, the target level of 

VOC emissions in 2008 could be a 10 

percent reduction from the adjusted 

VOC inventory in Step D and an 8 

percent reduction from the adjusted 

NOX inventory in Step D. The actual 

projected 2008 VOC and NOX

inventories for all sources with all 

control measures in place and including 

projected 2008 growth in activity must 

be at or lower than the target levels of 

VOC and NOX emissions. 

(3) Method 3: For all areas that have 

used Method 1 above (and therefore do 

not have a NOX target level of emissions 

for 2008) and must meet an additional 

reduction VOC requirement of 9 percent 

every 3 years after 2008 with NOX

substitution allowed, following EPA’s 

NOX Substitution Guidance. Each 

subsequent target level of emissions 

should be calculated as an emission 

reduction from the previous target. 

(A) Estimate the actual anthropogenic 

base year NOX inventory in 2002 with 

all 2002 control programs in place for 

all sources. 

(B) Using the same highway vehicle 

activity inputs used to calculate the 

actual 2002 inventory, run the 

appropriate emissions model for VOC 

and NOX in 2002 and 2008 (previously 

done in Step B in Method 1 for VOC but 

not necessarily for NOX) and 2011 with 

all post-1990 CAA measures turned off. 

Any other local inputs for I/M programs 

should be set according to the program 

that was required to be in place in 1990. 

Fuel RVP should be set at 9.0 or 7.8 

depending on the RVP required in the 

local area as a result of fuel RVP 

regulations promulgated in June, 1990. 

(C) Calculate the difference between 

2008 and 2011 VOC emission factors 

calculated in Step B and multiply by 

2002 VMT. The result is the VOC 

emissions reductions that will occur 

between 2008 and 2011 without the 

benefits of any post-1990 CAA 

measures. These are the non-creditable 

VOC reductions that occur over this 

period. Calculate the difference between 

2002 and 2011 NOX emission factors 

calculated in Step B and multiply by 

2002 VMT. The result is the NOX

emissions reductions that will occur 

between 2002 and 2011 without the 

benefits of any post-1990 CAA 

measures. These are the non-creditable 

NOX reductions that occur over this 

period. 

(D) Subtract the non-creditable VOC 

reductions calculated in Step C from the 

2008 VOC target level of emissions 

calculated previously. Subtract the noncreditable NOX reductions calculated in 

Step C from the actual 2002 NOX

inventory of emissions calculated in 

Step A. These adjusted VOC and NOX

inventories are the basis for calculating 

the target level of emissions in 2011. 


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(E) The target level of VOC and NOX

emissions in 2011 needed to meet the 

2011 ROP requirement is any 

combination of VOC and NOX

reductions from the adjusted inventories 

calculated in Step E that total 9 percent. 

For example, the target level of VOC 

emissions in 2011 could be a 4 percent 

reduction from the adjusted VOC 

inventory in Step C and a 5 percent 

reduction from the adjusted NOX

inventory in Step C. The actual 

projected 2011 VOC and NOX

inventories for all sources with all 

control measures in place and including 

projected 2011 growth in activity must 

be at or lower than the target levels of 

VOC and NOX emissions. 

(F) For subsequent 3-year periods 

until the attainment date, repeat the 

process for VOC. For subsequent 3-year 

periods, the adjusted NOX inventory 

should be based on the difference in 

NOX emissions during that 3-year 

period when all post-1990 CAA 

measures are turned off, subtracted from 

the previous NOX target level of 

emissions. For example, for 2014, take 

the difference in NOX emissions 

reductions that will occur between 2011 

and 2014 without the benefits of any 

post-1990 CAA measures. This value is 

subtracted from the 2011 target level of 

NOX emissions calculated in Step D to 

get the adjusted NOX inventory to be 

used as the basis for calculating the 

target level of NOX emissions in 2014. 

(4) Method 4: For all areas that have 

used Method 2 above (and therefore do 

have a NOX target level of emissions for 

2008) and must meet an additional 

reduction VOC requirement of 9 percent 

every 3 years after 2008 with NOX

substitution allowed, following EPA’s 

NOX Substitution Guidance. Each 

subsequent target level of emissions 

should be calculated as an emissions 

reductions from the previous target. 

(A) Using the same highway vehicle 

activity inputs used to calculate the 

actual 2002 inventory, run the 

appropriate emissions model for VOC 

and NOX in 2008 (previously done in 

Step B in Method 2) and 2011 with all 

post-1990 CAA measures turned off. 

Any other local inputs for I/M programs 

should be set according to the program 

that was required to be in place in 1990. 

Fuel RVP should be set at 9.0 or 7.8 

depending on the RVP required in the 

local area as a result of fuel RVP 

regulations promulgated in June 1990. 

(B) Calculate the difference between 

2008 and 2011 VOC emission factors 

calculated in Step A and multiply by 

2002 VMT. The result is the VOC 

emissions reductions that will occur 

between 2008 and 2011 without the 

benefits of any post-1990 CAA 

measures. These are the non-creditable 

VOC reductions that occur over this 

period. Calculate the difference between 

2008 and 2011 NOX emission factors 

calculated in Step A and multiply by 

2002 VMT. The result is the NOX

emissions reductions that will occur 

between 2008 and 2011 without the 

benefits of any post-1990 CAA 

measures. These are the non-creditable 

NOX reductions that occur over this 

period. 

(C) Subtract the non-creditable VOC 

reductions calculated in Step B from the 

2008 VOC target level of emissions 

calculated previously. Subtract the noncreditable NOX reductions calculated in 

Step B from the 2008 NOX target level 

of emissions calculated previously. 

These adjusted VOC and NOX

inventories are the basis for calculating 

the target level of emissions in 2011. 

(D) The target level of VOC and NOX

emissions in 2011 needed to meet the 

2011 ROP requirement is any 

combination of VOC and NOX

reductions from the adjusted inventories 

calculated in Step E that total 9 percent. 

For example, the target level of VOC 

emissions in 2011 could be a 4 percent 

reduction from the adjusted VOC 

inventory in Step C and a 5 percent 

reduction from the adjusted NOX

inventory in Step C. The actual 

projected 2011 VOC and NOX

inventories for all sources with all 

control measures in place and including 

projected 2011 growth in activity must 

be at or lower than the target levels of 

VOC and NOX emissions. 

(E) Repeat entire process for 

subsequent 3-year periods until the 

attainment date. 

Appendix B to Preamble—Glossary of Terms 

and Acronyms 

ACT—Alternative Control Techniques 

ARTBA—American Road and Transportation 

Builders Association 

BACT—Best Available Control Technology 

BART—Best Available Retrofit Technology 

CAA—Clean Air Act 

CAAAC—Clean Air Act Advisory Committee 

CADCs—Clean Air Development 

Communities 

CAIR—Clean Air Interstate Rule 

CERR—Consolidated Emissions Reporting 

Rule 

CFR—Code of Federal Regulations 

CMAQ—Congestion Mitigation and Air 

Quality 

CMSA—Consolidated Metropolitan 

Statistical Area 

CO—Carbon Monoxide 

CTG—Control Technique Guideline 

DOT—Department of Transportation 

EMFAC—EMissions FACtors (a mobile 

emissions model) 

ESRP—Emissions Statement Reporting 

Program 

CTG—Control Technique Guidelines 

EGUs—Electricity Generating Units 

EPA—Environmental Protection Agency 

FIP—Federal Implementation Plan 

FMVCP—Federal Motor Vehicle Control 

Program 

HON—Hazardous Organic NESHAP 

ICR—Information Collection Requirement 

I/M—Inspection and Maintenance Area 

km—Kilometers 

LADCO—Lake Michigan Air Directors 

Consortium 

LAER—Lowest Achievable Emission Rate 

MACT—Maximum Achievable Control 

Technology 

MCR—Mid-course Review 

MPO—Metropolitan Planning Organization 

MSA—Metropolitan Statistical Area 

NAA—Nonattainment Area 

NAAMS—National Ambient Air Modeling 

Strategy 

NAAQS—National Ambient Air Quality 

Standards 

NAMS/SLAMS—National Air Monitoring 

Stations/State and Local Air Monitoring 

Stations 

NAS—National Academy of Sciences 

NCore—National Core Monitoring Stations 

NESHAP—National Emission Standards for 

Hazardous Air Pollutants 

NOX—Nitrogen Oxides 

NOy—Reactive Oxides of Nitrogen 

NPRM—Notice of Proposed Rulemaking 

NSR—New Source Review 

NTAA—National Tribal Air Association 

NTTAA—National Technology Transfer 

Advancement Act of 1995 

OMB—Office of Management and Budget 

OTAG—Ozone Transport Assessment Group 

OTR—Ozone Transport Region 

PAMS—Photochemical Assessment 

Monitoring Stations 

PM—Particulate Matter 

PM2.5—Fine Particulate Matter 

PM10—Particulate Matter Having a Nominal 

Aerodynamic Diameter Less than or 

Equal to 10 Microns 

ppb—Parts per Billion 

ppm—Parts per Million 

PSD—Prevention of Significant Deterioration 

psi—Pounds Per Square Inch 

RACM—Reasonably Available Control 

Measures 

RACT—Reasonably Available Control 

Technology 

RFASA—Regulatory Flexibility Act 

Screening Analysis 

RFP—Reasonable Further Progress 

RIA—Regulatory Impact Analysis 

ROG—Reactive Organic Gases 

ROP—Rate of Progress 

RPOs—Regional Planning Organizations 

RVP—Reid Vapor Pressure 

SBA—Small Business Administration 

SCR—Selective Catalytic Reduction 

SIPs—State Implementation Plans 

SO2—Sulfur Dioxide 

TAR—Tribal Authority Rule 

TAS—(Treatment in the Same Manner as a 

State ‘‘Treatment as State’’) 

TEA–21—Transportation Equity Act for the 

Twenty-first Century 

TIPs—Tribal Implementation Plans 

tpy—Tons Per Year 

TSP—Total Suspended Particulates 

TTN/SCRAM—Technical Transfer Network/ 

Support Center for Regulatory Air 

Models 


Correspondence and Guidance 

The Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone 

North Carolina Reasonable Further Progress Demonstration 

 43 

 Appendix F 

November 30, 2009