# Appendix F Correspondence and Guidance

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### Correspondence and Guidance i The Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Appendix F North Carolina Reasonable Further Progress Demonstration November 30, 2009 

# Table of Contents Letter: 9/16/2005, B. Keith Overcash, NCDAQ’s re quest for comments on geographic extent for motor vehicle emissions budgets for attainment demonstrations ........................................1

Letter: 2/8/2006, Mike Nunn, Cabarrus-R owan Urban Area Metropolitan Planning Organization’s response lett er to NCDAQ’s 9/16/2005 letter .............................................4

Letter: 1/31/2006, Dan Thomas, North Carolina De partment of Transportation’s response letter to NCDAQ’s 9/16/2006 letter ..............................................................................................5

Letter: 2/16/2006, James H. Graham, Gaston Ur ban Area Metropolitan Planning Organization, Robert W. Cook, Mecklenburg-Union Metr opolitan Planning Organization, Rebecca Yarbrough, Lake Norman and Rocky River Ru ral Planning Organizations, response letter to NCDAQ’s 9/16/2006 letter ..............................................................................................7

Email: 2/19/2006, Roland Tilley, Citizens for Sm art 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, Res ponse to North Carolina Department of Transportation’s 1/31/2006 letter .......................................................................................26

Letter: 6/21/2006, B. Keith Overcash, Respons e to Gaston Urban Area Metropolitan Planning Organization, Mecklenburg-Un ion Metropolitan Planning Or ganization, Lake Norman Rural Planning Organization and Rocky Ri ver Rural Planning Organization 2/16/2006 letter ........................................................................................................................ ...........27

Letter: 4/15/2004. Michael O. Leavitt, The USEPA’s 8-hour Ozone N onattainment Boundary Designation ................................................................................................................... .....29

Guidance Document: 8/15/2006, William T. Harn ett, “8-Hour Ozone National Ambient Air Quality Standards (NAAQS) Implementation – R easonable Further Progress (RFP)” ........................................................................................................................ ........32

Guidance Document: 11/29/2005, “Phase II 8-Hour Ozone Implementation Rule, Appendix A to Preamble” ..................................................................................................................... ......42

### Correspondence and Guidance ii The Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Appendix F North Carolina Reasonable Further Progress Demonstration November 30, 2009 

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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-maki ng 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

## 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

## 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

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

119 These 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-1990CAA 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 NO X substitution allowed, following EPA ’ s NO X Substitution Guidance:

(A) Estimate the actual anthropogenic base year inventory for both VOC and NO X 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 NO X emissions factors calculated in Step B and multiply by 2002 VMT. This result is the NO X emissions reductions that will occur between 2002 and 2008 without the benefits of any post-1990 CAA measures. These are the non-creditable NO X 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 NO X reductions calculated in Step C from the actual anthropogenic 2002 NO X inventory estimated in Step A. These adjusted VOC and NO X inventories are the basis for calculating the target level of emissions in 2008.

(E) The target level of VOC and NO X emissions in 2008 needed to meet the 2008 ROP requirement is any combination of VOC and NO X 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 NO X inventory in Step D. The actual projected 2008 VOC and NO X 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 NO X emissions.

(3) Method 3: For all areas that have used Method 1 above (and therefore do not have a NO X target level of emissions for 2008) and must meet an additional reduction VOC requirement of 9 percent every 3 years after 2008 with NO X substitution allowed, following EPA ’ s NO X 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 NO X 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 NO X in 2002 and 2008 (previously done in Step B in Method 1 for VOC but not necessarily for NO X ) 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 NO X emission factors calculated in Step B and multiply by 2002 VMT. The result is the NO X emissions reductions that will occur between 2002 and 2011 without the benefits of any post-1990 CAA measures. These are the non-creditable NO X reductions that occur over this period.

(D) Subtract the non-creditable VOC reductions calculated in Step C from the 2008 VOC target level of emissionscalculated previously. Subtract the noncreditable NO X reductions calculated in Step C from the actual 2002 NO X inventory of emissions calculated in Step A. These adjusted VOC and NO X inventories are the basis for calculating the target level of emissions in 2011.


### 71697 Federal Register / Vol. 70, No. 228 / Tuesday, November 29, 2005 / Rules and Regulations

(E) The target level of VOC and NO X emissions in 2011 needed to meet the 2011 ROP requirement is any combination of VOC and NO X 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 NO X inventory in Step C. The actual projected 2011 VOC and NO X 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 NO X emissions.

(F) For subsequent 3-year periods until the attainment date, repeat the process for VOC. For subsequent 3-year periods, the adjusted NO X inventory should be based on the difference in NO X emissions during that 3-year period when all post-1990 CAA measures are turned off, subtracted from the previous NO X target level of emissions. For example, for 2014, take the difference in NO X 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 NO X emissions calculated in Step D to get the adjusted NO X inventory to be used as the basis for calculating the target level of NO X emissions in 2014.

(4) Method 4: For all areas that have used Method 2 above (and therefore do have a NO X target level of emissions for 2008) and must meet an additional reduction VOC requirement of 9 percent every 3 years after 2008 with NO X substitution allowed, following EPA ’ s NO X 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 NO X 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 NO X emission factors calculated in Step A and multiply by 2002 VMT. The result is the NO X emissions reductions that will occur between 2008 and 2011 without the benefits of any post-1990 CAA measures. These are the non-creditable NO X reductions that occur over this period.

(C) Subtract the non-creditable VOC reductions calculated in Step B from the 2008 VOC target level of emissionscalculated previously. Subtract the noncreditable NO X reductions calculated in Step B from the 2008 NO X target level of emissions calculated previously. These adjusted VOC and NO X inventories are the basis for calculating the target level of emissions in 2011.

(D) The target level of VOC and NO X emissions in 2011 needed to meet the 2011 ROP requirement is any combination of VOC and NO X 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 NO X inventory in Step C. The actual projected 2011 VOC and NO X 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 NO X 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 NO X — Nitrogen Oxides NO y — 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 PM 2.5 — Fine Particulate Matter PM 10 — 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 SO 2 — Sulfur Dioxide TAR

— Tribal Authority Rule TAS

— (Treatment in the Same Manner as a State ‘‘ Treatment as State ’’ ) TEA

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— 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