Page 1 of 23 Technical Support Document Pointe Coupee Parish Section 110(a)(1) Maintenance Plan

Ellen Belk and Sandra Rennie April 23, 2013

I. Background

Under section 107 of the 1977 Clean Air Act (CAA), Louisiana’s Pointe Coupee Parish was designated as a nonattainment area because it did not meet the National Ambient Air Quality Standards (NAAQS) for 1-hour ozone (40 CFR 81.319). Under the 1990 CAA Amendments, Pointe Coupee Parish was included as part of the Baton Rouge nonattainment area, and continued to be designated nonatta inment for the 1-hour ozone NAAQS by operation of law. Under these Amendments, the Baton Rouge area, which included Pointe Coupee, was classified as a serious 1-hour nonattainment area, pursuant to sections 107(d) and 181(a) of the CAA Amendments (56 FR 56694).

On December 20, 1995, Louisiana submitted a State Implementation Plan (SIP) requesting the removal of Pointe Coupee Parish from the Baton Rouge nonattainment area and redesignation of Pointe Coupee Parish to attainment for the 1-hour standard. As part of the submittal, the State provided the required ozone monitoring data and a maintenance plan for the Parish to ensure the area would remain in attainment for 1-hour ozone for a period of 10 years. EPA approved Louisiana’s requests to remove the Parish from the Baton Rouge nonattainment area and to redesignate Pointe Coupee Parish to attainment for the 1-hour ozone standard and approved the maintenance plan on January 6, 1997 (62 FR 648), with an effective date of December 20, 1996.

On April 30, 2004, EPA designated and classified areas for the 1997 8-hour ozone NAAQS (69 FR 23858), and published the final Phase 1 rule for implementation of the 1997 8- hour ozone NAAQS (69 FR 23951). Pointe Coupee Parish was designated as unclassifiable/attainment for the 1997 8-hour ozone standard, effective June 15, 2004. The area is consequently required to submit a 10-year maintenance plan under section 110(a)(1) of the CAA and the Phase 1 rule. On May 20, 2005, EPA issued guidance providing information regarding how a state might fulfill the maintenance plan obligation established by the Act and the Rule (Memorandum from Lydia N. Wegman to Air Division Directors, Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under Section 110(a)(1) of Clean Air Act

, May 20, 2005). This SIP revision satisfies the section 110(a)(1) CAA requirements for a plan that provides for implementation, maintenance, and enforcement of the 1997 8-hour ozone NAAQS in the Pointe Coupee Parish 1997 8-hour ozone unclassifiable/attainment area.

The above information is consistent with Designation Scenario C in the May 20, 2005, Guidance Document: “Areas that are designated unclassifiable / attainment for the 1997 8-hour ozone NAAQS and are designated attainment for the 1-hour ozone NAAQS with an approved maintenance plan (8UA/1M).”Page 2 of 23 On December 22, 2006, the United States Court of Appeals for the District of Columbia Circuit issued an opinion that vacated EPA's Phase 1 Implementation Rule for the 1997 8-hour

Ozone Standard. (South Coast Air Quality Management District

. v. EPA, 472 F.3d 882 (D.C.Cir. 2006). Petitions for rehearing were filed with the Court, and on June 8, 2007, the Court modified the scope of the vacatur of th e Phase I rule. See 489 F.3d 1245 (D.C. Cir. 2007),

cert. denied , 128 S.Ct. 1065 (2008). The Court vacated those portions of the Rule that provide for regulation of 1997 8-hour ozone nonattainment areas under Subpart 1 in lieu of Subpart 2 and that allow backsliding with respect to new source review, penalties, milestones, contingency plans, and motor vehicle emission budgets. Consequently, the Court’s modified ruling does not alter any requirements under the Phase 1 1997 8-hour ozone implementation rule for maintenance plans.

This SIP revision satisfies the CAA requirements for the Pointe Coupee Parish areas

under the 1997 8-hour ozone standard.

II. Analysis of the State’s Submittal

On February 28, 2007, the State of Louisiana submitted a maintenance plan for Pointe Coupee Parish. This February revision provides a maintenance plan for Point Coupee Parish, as required by section 110(a)(1) of the CAA and the provisions of EPA’s Phase 1 Implementation Rule (40 CFR 51.905(a)(4)) (see docket). The purpose of this plan is to ensure continued attainment and maintenance of the NAAQS for 1997 8-hour ozone in Pointe Coupee Parish.

The requirements for section 110(a)(1) plan components are discussed below.

A. General Requirements of 1997 8-hour O 3 Maintenance Plans

Section 110 of the Clean Air Act provides the general framework for Implementation

Plans. The EPA document entitled “Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under Section 110(a)(1) of Clean Air Act” dated May 20, 2005, provides more detailed information about maintenance plan components and their technical underpinnings.

The maintenance plan submitted by Louisiana for Pointe Coupee Parish meets CAA requirements, and follows EPA guidance.

B. Specific Requirements 1997 8-hour O 3 Maintenance Plans

A 1997 8-hour ozone 110(a)(1) maintenance plan constitutes a SIP revision and must provide for continued maintenance of the 1997 8-hour ozone NAAQS in the area for 10 years from the effective date of the area’s designation as unclassifiable/attainment for the 1997 8-hour ozone NAAQS. The Pointe Coupee Parish maintenance plan includes the following

components:
Section 1: IntroductionPage 3 of 23 Section 2: Emissions Inventory (including Reid Vapor Pressure) Section 3: Attainment Inventory

Section 4: Maintenance Demonstration Section 5: Ambient Air Quality Monitoring

Section 6: Verification of Continued Attainment Section 7: Contingency Plan

The information included in each of these sections will be discussed in detail below.

Section 1: Introduction . The information included in this section of the plans is included

above in section I. Background

.

Section 2: Emissions Inventory . An Emissions Inventory contains information about air emissions which has been compiled with input from numerous groups, including state and local air agencies, tribes, and industry. An emissions inventory database contains information on stationary and mobile sources that emit criteria air pollutants and their precursors, as well as hazardous air pollutants. Emissions Inventories are the basis for numerous air quality related efforts, including establishing baseline emission levels, developing emission reduction goals, developing control strategies for achieving emissions reductions, regional and local air quality modeling, regulatory impact assessments, and other applications such as the development of maintenance plans.

EPA interprets section 110 (a) (2) (F) of the Clean Air Act (codified in 40 CFR 51 Subparts A and Q) to require States to provide for the reporting of emissions of criteria air pollutants for all areas under the general SIP requirements on a regular basis. The Administrator also has the discretionary authority to require other emissions data as deemed necessary for SIP development. For the 1997 8-hour ozone NAAQS, the pollutants to be inventoried are volatile organic compounds (VOC), nitrogen oxides (NO

x ), and carbon monoxide (CO). More detailed information about emissions inventory requirement s can be found in the Consolidated Emissions Reporting Rule (CERR) (40 CFR Part 51, S ubpart A, 67 FR 39602, June 10, 2002). Guidance on how to develop emissions inventories can be found in a number of documents, including: “Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations,” August, 2005, as revised November 2005, and “2002 Base Year Emission Inventory SIP Pl anning: 8-hr Ozone, PM 2.5, and Regional Haze Programs” November 18, 2002 (see docket). For additional information, please see the websites www.epa.gov/ttn/chief/eiinformation.html, www.epa.gov/ttn/chief/eiip, and www.epa.gov/ttn/chief/efpac/index.html.

The LDEQ developed comprehensive inventories of VOC and NO

x emissions from area, stationary, and mobile sources using 2002 as the base year to demonstrate maintenance of the 1997 8-hour ozone NAAQS for Pointe Coupee Parish. The year 2002 is an appropriate year for the LDEQ to base attainment level emissions because States may select any one of the three years on which the 8-hour attainment designation was based (2001, 2002, and 2003). The State’s submittal contains the detailed inventory data and summaries by source category. The 2002 base year inventory is a good choice. Using the 2002 inventory as a base year reflects onePage 4 of 23 of the years used for calculating the air quality design values on which the 8-hour ozone designation decision was based. It also is one of the years in the 2002-2004 period used to establish baseline visibility levels for the regional haze program.

A practical reason for selecting 2002 as the base year emission inventory is that Section 110(a)(2)(B) of the CAA and the Consolidated Emissions Reporting Rule (67 FR 39602, June 10, 2002) require States to submit emissions inventories for all criteria pollutants and their precursors every three years, on a schedule that includes the emissions year 2002. The due date for the 2002 emissions inventory is established in the rule as June 2004. In accordance with these requirements, the State of Louisiana compiles a statewide EI for point sources on an annual

basis.

In Section 2 of the maintenance plan, Louisiana provides Emissions Inventory information for the 2002 base year which identifies the types of emission sources in an area, the amount of each pollutant emitted, and the types of processes and control devices employed at each plant or source category. More specific info rmation about Louisiana’s Emissions Inventory is provided below for the each of the following i nventory categories: a) point sources, b) nonpoint sources, c) on-road mobile sources, and d) non-road mobile sources.

a) Point Sources. For purposes of the Emissions Inventory in Pointe Coupee Parish, point sources are defined as stationary commercial or industrial operations that emit 100 tons or more per year of VOC or 100 tons or more per year of NO

x . Louisiana compiles a statewide Emissions Inventory for point sources on an annua l basis. Emissions data provided by facilities are estimates of actual emissions for the facility during the previous year. In developing the emissions inventory for point sources, LDEQ us ed estimation methodologies based on state and federal guidelines. When available, actual testing or measurement data was used in the inventory. A list of point sources included in the 2002 base year emissions inventory for the parish is included in Appendix A of the maintenance plan.

b) Non-point Sources. Non-point sources include many small, individually unidentified points of air pollution emissions which are too numerous or small to be included in the inventory individually. These sources, sometimes referred to as area sources, may include activities such as dry cleaning, bakeries, graphic arts, auto refinishing, and consumer product usage. Louisiana calculated emissions in this category using data provided by E.H. Pechan & Associates, Inc. (Pechan) and the Carolina Environmental Program at the University of North Carolina, Chapel Hill, (UNC-CEP) through the Central Regional Air Planning Association (CENRAP) Regional Planning Organization (RPO), CENRAP 2004: Methods for Consolidation of Emission Inventories (see docket). The CENRAP region incl udes the states and tribal jurisdictions of Arkansas, Iowa, Kansas, Louisiana, Minnesota, Mi ssouri, Nebraska, Oklahoma, and Texas. In developing the 2002 inventory, Pechan and UNC-CEP worked with the CENRAP’s Emission Inventory Workgroup and State, Local, and Trib al (S/L/T) agencies to provide Quality Assurance (QA) and to augment the inventories to fill data gaps, CENRAP 2004B: Quality Assurance Project Plan for Consolidation of Emission Inventories.Page 5 of 23 Additional information about the development of the non-point source emissions inventory can be found in another submittal entitled, “2002 Base Year Emissions Inventory for the Baton Rouge Ozone Nonattainment Area”. The development of the emissions inventory for stationary non-point sources is discussed in Secti on 3 Stationary Non-point Sources, as well as in Appendix D: Consolidation of Emissions Inventories , Section C, Area Source Inventory Methods. This appendix includes detailed information regarding the development of the nonpoint source inventory, together with a detailed discussion of the associated quality assurance procedures which were followed. (Please see Attachments 4 and 5 below which are included in the docket for this rulemaking.)

c) On-road Mobile Sources. On-road mobile sources include light and heavy duty gasoline and diesel automobiles and trucks that travel primarily on public highways. Louisiana

estimated on-road mobile emissions of VOC and NO

x by using EPA’s MOBILE6.2 motor vehicle emissions factor model in accordance with established practice found in the User’s Guide to MOBILE6.1 and 6.2 (EPA420-R-03-010, August 2003, see http://www.epa.gov/otaq/models/mobile6/420r03010.pdf). Data and projections were based on Highway Performance Monitoring System (HPMS) data from the annual U.S. Highway Statistics Report Section V. EPA has endorsed the HPMS as the appropriate source for projections of vehicle miles traveled (Procedures for Emissions Inventory Preparation – Volume IV: Mobile Sources, EPA450/4-81-026d (revised), see http://ntl.bts.gov/DOCS/AQP.html). On-road mobile source data is included in Appendix B of the maintenance plan. Louisiana’s emission estimates for on-road mobile sources in Appendix B assume the summertime use, June 1 through September 15, of federally required low Reid Vapor Pressure gasoline in Pointe Coupee Parish.

d) Non-road Mobile Sources. Non-road mobile sources include railroad locomotives, aircraft, commercial marine vessels, farm equipment, recreational boating, and lawn equipment. Louisiana derived non-road mobile emissions data from the “Emission Inventory Development for Mobile Sources and Agricultural Dust Sources for the Central States " produced by Sonoma Technology, Inc. for CENRAP in October 2004. The inventory was developed using NONROAD 2004, which is an EPA-approved emissions factor model for most non-road mobile sources. For other source categories, NONROAD default activity data were used in conjunction with fuels information specific to the area to estimate emissions. For example, in Pointe Coupee Parish, the specific fuel is Federal 7.8 RVP gasoline which is required during the high ozone season (June 1- September 15). All diesel fuel in the area must meet federal sulfur requirements for on-road and nonroad use. Therefore, the LDEQ used this specific fuel in conjunction with NONROAD default activity data to estimate emissions. Estimation methods for locomotives

, aircraft, and marine vessels were based on EP A guidance documents, and LDEQ developed the activity data consistent with EPA guidance.

Throughout the years of the maintenance plan, the Emissions Inventory information will be periodically updated and evaluated, as disc ussed below in Section 6: Verification of

Continued Attainment.Page 6 of 23 Section 3: Attainment Inventory . In this section of the maintenance plan, the State provides an attainment inventory for future years to project a level of emissions in the area which will be sufficient to attain the NAAQS. For Pointe Coupee Parish, the State uses emissions inventory data to develop its attainment invent ory (see Section 2: Emissions Inventory for more information). The attainment inventory is based on actual “typical summer day” emissions of volatile organic compounds (VOCs) and nitrogen oxides (NOx). The Phase 1 Implementation Rule provides that the 10-year maintenance period begins as of the effective date of designation for the 1997 8-hour NAAQS for the area, which was June 15, 2004, and indicates that the State may use one of any of the three years on which the 1997 8-hour attainment designation was based (i.e., 2001, 2002, and 2003) for an attainment inventory.

In projecting data for the future year 2014 inventory, LDEQ used several methods to project data from the base year 2002 to the years 2008, 2011, and 2014. These projected inventories were developed using EPA-approved technologies and methodologies. Point source and area source growth projections were derived from the Emissions Growth Analysis System version 4.0 (EGAS 4.0). Non-road mobile growth projections were derived from EGAS 4.0, as well as from the National Mobile Inventory Model ( http://www.epa.gov/otaq/nmim.htm ). On-road mobile source growth projections were derived from the HPMS data, traffic demand models, and the assumption of summertime use of the federally required low RVP gasoline in Pointe Coupee

Parish.

Table 1 provides VOC and NO

x emissions data for the 2002 base year attainment inventory, as well as projected VOC and NO

x emission inventory data for the major anthropogenic source categories for the years 2008, 2011, and 2014, for Pointe Coupee Parish.Page 7 of 23 Table 1 Pointe Coupee

VOC and NO

x Emissions Inventory Baseline (2002) and Projections (2008, 2011, and 2014) (in tons per day)

Emissions source 2002 2008 2011 2014

NOx VOC NOx VOC NOx VOC NOx VOC

Point Source 55.93 1.53 58.55 1.61 61.38 1.68 64.39 1.76 Non-point (Area) Source 1.04 2.91 1.14 3.18 1.21 3.34 1.27 3.48

Nonroad 6.81 2.83 6.84 2.36 6.87 1.99 6.87 1.81

Onroad 1.94 1.36 1.28 0.89 0.98 0.74 0.74 0.61

Total 65.72

8.63 67.81

8.04 70.44

7.75 73.27

7.66

As shown in Table 1, total VOC emissions are projected to decrease, and total NO

x emissions are projected to increase slightly, for the Pointe Coupee Parish area over the 10-year period of the maintenance plan. While emission projections for VOCs indicate a decrease of approximately 11% through 2014 (from 8.63 tpd to 7.66 tpd), NOx, emission projections through 2014 show an increase of approximately 11% (from 65.72 tpd to 73.27 tpd). The projected 11%

increase in NO

x emissions results primarily from projected increases in emissions for the point source category (55.93 tpd to 64.39 tpd, or 8.46 tpd). Th ere is also projected to be a very small increase from the nonpoint source category. Emi ssions of NOx from non-road mobile sources are projected to remain nearly the same, and on-road emissions decrease over the same time period.

This projected increase in non-mobile source NOx is relatively small considering that it occurs over a period of approximately twelve years (2002 to 2014), and, is overstated by the projection method used for point sources. As mentioned previously, growth projections for point and stationary area source projections were derived from th e Emissions Growth Analysis System version 4.0 (EGAS 4.0). The EGAS system for projecting emissions tends to overstate future emissions because the system relies principally on economic growth for the projections, and does not include reductions from regulatory or permit controls. In “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze” (EPA 454/B-07-002, April 2007), th e discussion on projecting emissions for future years begins on page 179, and includes the following: “Multiple sources of information can be used to better inform emissions modelers. . . . In addition, because of changes in technologies and fuel efficiency, economic growth is not necessarily a sufficient indicator of emissions growth. While this guidance does not provide a prescriptive approach for combining such information, the authors recognize that predicting the future of emissions is not an exactPage 8 of 23 science and therefore multiple sources of information should be used to develop an informed approach . . . ” (p. 185). In particular, the model that was used by Louisiana to develop its emissions projections for Pointe Coupee tends to overstate emissions. The reason for this is that “. . . EGAS relies primarily on three sources of data (1) state-specific economic data from the Regional Economic Model, Inc. (REMI) Policy Insight model (version 5.5) that includes population growth estimates, (2) Region-specific fuel-use projections from the U.S. Department of Energy (DOE) Annual Energy Outlook 2004, and (3) VMT projections included in the

MOBILE 6.0 model.

EGAS outputs growth factors that do not incl ude control information for a user defined base year and multiple future years through 2035. In the PM2.5 Regulatory Impact Assessment technical documentation “2006 National Ambient Air Quality Standards for Particle Pollution”, EPA determined a better approach was to not use EGAS or emissions growth at all until a better projection approach could be developed than the economic one in EGAS. See page 2-14 for the start of the emissions discussion, as well as Table 2-4 on page 2-17 for a list of relevant national controls some of which might impact Louisiana. (The control measures which definitely do impact Louisiana are discussed below in this TSD.) Note that none of these national controls is included in the projections by EGAS. Beginning on page 2-23, there is a discussion of the new projections approach which is referred to as an ‘interim’ emission projection approach, “. . . that assumes no growth to emissions for many stationary non-EGU sources in estimating future-year

emissions.”

Due to the significance of emissions inventory forecasting, EPA consulted with the Advisory Council on Clean Air Compliance Analysis and the Air Quality Modeling Subcommittee (Council) of the Science Advisory Board (SAB), and received a letter from the SAB’s Council, reporting the findings of the Council on September 15, 2006. “In this letter, the Council recommended an alternative forecasting methodology for the stationary non-EGU source categories as preferred to the method used in this RIA.” The Ozone Regulatory Impact Assessment technical document does not rely on EGAS, and in fact does not mention EGAS; rather the air quality model used to determine future emissions projections is the Community Multi-Scale Air Quality (CMAQ) model.

In summary, it is EPA’s technical position that the EGAS method which was previously recommended by EPA as an appropriate methodol ogy for developing emissions projections and which was used by Louisiana in developing its emissions projections for all point and area stationary non-EGUs sources, resulted in future estimates which are too high. In 2005-2006 Louisiana developed its emissions projections for its maintenance plan for Pointe Coupee according to EPA guidance using EGAS. In December 2006, Louisiana proposed its maintenance plan for Pointe Coupee, and prepared a final SIP revision in February 2007. EPA received the Pointe Coupee maintenance plan on March 6, 2007. Since Louisiana developed its point and area stationary sources projections for Point Coupee in accordance with EGAS, EPA, in consultation with the SAB, determined that emissions projections based on economic growth models such as EGAS tend to be overstated since they do not include reductions from regulatory or permit controls. Current acceptable methods for projecting emissions from point and areaPage 9 of 23 stationary sources for ozone do not rely on EGAS. As a result, although the Louisiana projections for NOx show an overall increase of 11% over the time of the maintenance period, EPA believes that the projections for the point and area stationary sources were overstated by EGAS, and that the overall projections for NOx will be much lower than predicted.

In addition to the concerns discussed above with the use of EGAS for projecting point and area stationary sources emissions, EGAS also does not take into account) the state’s control measures contained in rules for point and non-point stationary sources, and b) the state’s controls provided by permits limits on new and modified sources. These controls, together with the discussion above about EGAS, are expected to fu lly offset the NOx emissions increase projected in Pointe Coupee Parish, since the projections were developed without taking into account any of the state and federal controls, changes in technol ogy and fuel efficiency, the lack of correlation between economic growth and emissions, etc.

National rules which contain controls which will reduce actual VOC and NOx emissions from point and stationary non-point (area) sources, as well as non-road mobile which are not included in the growth estimates include: EPA’s national rules for VOC emission standards for Consumer and Commercial Products, and EPA’s Locomotive and Marine Compression-Ignition Engines rule. The purpose of these control measures is to reduce levels of 8-hour ozone, including the area of Pointe Coupee Parish, as well as to reduce transport to the Pointe Coupee

Parish area from other areas.

Louisiana adopted certain more stringent NOx control measures for point sources in June 2004, with compliance required by May 1, 2005, in the Baton Rouge area’s parishes (LR 30: 1170, June 2004). These measures resulted in reductions of NOx emissions from the Baton Rouge area, and therefore, result in less transport of ozone precursors into Pointe Coupee Parish. For example, starting May 2005 a >/= 1500 Horse power lean burn stationary internal combustion engines is required to emit no more than 4 g NOx/Hp-hour when operating in Pointe Coupee, St. Helena, and East and West Feliciana Parishes, parishes in the Baton Rouge “region of influence”. An engine 1500 Hp x 4 g NOx/Hp-hour x 1 lb/454 g x 8760 hour/year x 1 ton/2000 lb = 57.9 ton NOx/year = 57.9 TPY, while a 1499 Hp engine would have no emission limits. For the Baton Rouge 5-parish nonattainment area, the controlled engine size for the lean burn stationary internal combustion engines is significantly reduced from >/=1500 Hp to >/=320 Hp. As a result, a 1499 Hp or larger lean burn stationary internal combustion engines down to and including 320 Hp engines are allowed to emit no more than the same 4 g NOx/Hp-hour when operating in the Baton Rouge nonattainment area. 320 Hp x 4 g NOx/Hp-hour x 1 lb/454 g x 8760 hour/year x 1 ton/2000 lb = 12.3 ton NOx/year = 12.3 TPY.

The reductions in NOx emissions from the above Baton Rouge area control measures have not been taken into account on their impact on the future air quality for Pointe Coupee Parish. The following rules and other measures, some of which were mentioned above, are expected to have a positive impact on air quality in Pointe Coupee Parish: (1) On-Road Standards, (2) Non-road Engine Standards, (3) Control Technique Guidelines (CTGs), (4) Locomotives, and (5) Marine Emissions. Each of these is discussed below.Page 10 of 23 (1) On-Road Standards: Enacting of specifi c requirements from a) EPA’s Tier 2 Motor Vehicle Emission Standards (65 FR 6697), b) EPA’ s Heavy-Duty Engine and Vehicle Standards (66 FR 5002), as well as c) EPA’s gasoline and hi ghway diesel fuel sulfur control requirements (66 FR 5002).

Regarding the second of these, the heavy-duty highway engine standards, EPA believes that NOx control from Heavy-Duty Engines is a cost-effective strategy to control ozone levels. (The information that follows can be found on pages 5030 and 5033 of 66 FR 5002).

Heavy-duty vehicles (HDVs) make up about 15% of the national NOx inventory from all sources. Similarly, HDVs accounted for about 3% of national VOC and 8% from mobile sourcesin 2007. By implementation of the Heavy-Duty highway engine standards for NOx and nonmethane hydrocarbons (NMHC), which are required beginning in 2007 and must be fully phased in by model year 2010, the Baton Rouge / Pointe Coupee area can expect to see influential

reductions as both the area and national fleets turn over.

NOx is expected to drop by 25% between 2007 and 2010, and then continue to drop by an additional 22% by 2014 for a total reduction of NOx of 47% from new heavy-duty highway vehicles and engines.

NMHC, which includes both exhaust and evaporative emissions, is expected to drop by 8% between 2007 and 2010, and then continue to drop by approximately an additional 10% by 2014 for a total NMHC reduction of 18% from new heavy-duty highway vehicles and engines.

The influence of the national fleet emission reductions from heavy-duty highway vehicle turnover is enhanced by the geographic location of the Baton Rouge area. Baton Rouge is located on Interstate-10 which runs east and west between Los Angeles, CA and Jacksonville, FL. This is a recognized main east-west corridor for goods transportation. Baton Rouge is also the location where Interstate-12, which comes from the Port of New Orleans to go west, links with I-10. So in addition to the expected E-W truc k traffic, considerable truck traffic also flows through Baton Rouge from the Port of New Orlean s to the west. (Traffic from the Port going east will most likely go the other direction on I-12 and link up with I-10 in Slidell, thereby avoiding the Baton Rouge 5-parish area.)

(2) Non-Road Engine Standards: EPA’s required control of emissions from non-road diesel engines and fuels (69 FR 38958).

Nonroad diesel equipment, as described in this rule, currently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of nitrogen oxides (NOx) from mobile sources nationwide. These proportions are even higher in some urban areas. (This information is based on material found on page 38970 of 69 FR 38958).Page 11 of 23 The new emission standards apply to diesel engines used in most construction, agricultural, industrial, and airport equipment. The standard s will take effect for new engines beginning in 2008 and be fully phased in for most engines by 2014. The result of implementing this rule will be an approximately 23% reduction in NOx from new non-road equipment between 2007 and

2014.

This rule sets emission standards for different sizes of nonroad engines. These standards are similar in stringency to the standards adopted for 2007 and later diesel-powered trucks and buses. The standards are phased-in over several years to provide adequate lead time to engine and equipment manufacturers. Table 2 shows the new emissions standards.

Table 2
Final Emission Standards in grams per horsepower-hour (g/hphr)
Rated Power First Year that Standards Apply PM NOx
hp < 25 2008 0.30 -

25 ≤ hp < 75 2013 0.02 3.5*

75 ≤ hp < 175 2012-2013 0.01 0.30

175 ≤ hp < 750 2011-2013 0.01 0.30

hp ≥ 750 2011-2014

2015 0.075

0.02/0.03** 2.6/0.50† 0.50††

* The 3.5 g/hp-hr standard includes both NOx and nonmethane hydrocarbons. † The 0.50 g/hp-hr standard applies to gensets over 1200 hp. ** The 0.02 g/hp-hr standard applies to gensets; the 0.03 g/hp-hr standard applies to other engines. †† Applies to all gensets only.

This rule will reduce nonroad diesel fuel sulfur levels in two steps. First, starting in 2007, fuel sulfur levels in nonroad diesel fuel will be limited to a maximum of 500 ppm, the same as for current highway diesel fuel. This limit also covers fuels used in locomotive and marine applications (though not to the marine residual fuel used by very large engines on ocean-going vessels).

Second, starting in 2010, fuel sulfur levels in most nonroad diesel fuel will be reduced to 15 ppm. This ultra-low sulfur fuel will create immediate public health benefits and will make it possible for engine manufacturers to use advanced emission-control systems that will dramatically reduce both PM and NOx emissions. In the case of locomotive and marine diesel fuel, this second step will occur in 2012.

(3) Control Technique Guidelines (CTGs). EPA’s CTGs established reasonably available control technology (RACT) to apply to new and existing sources. (RACT is defined as “the lowest possible emission limitation that a particular source is capable of meeting by thePage 12 of 23 application of control technology that is reas onably available, considering technological and economic feasibility”.) Requirements in section 182(b)(2) of the Clean Air Act including RACT apply to moderate or worse ozone nonattainment areas which includes Baton Rouge.

Since 1975, EPA has issued over 30 CTGs covering a variety of surface coating, chemical manufacturing, and material handling operations. These CTGs provide federally recommended measures to be incorporated as part of approved SIPs. The available CTGs

include:

Group I: Consumer Products (rule) Autobody refinishing coatings (rule) Architectural coatings (rule) Shipbuilding and repair coatings (CTG) Aerospace coatings (CTG) Wood furniture coatings (CTG)

Group II: Flexible Packaging Printing Materials (CTG) (71 FR 58745); Lithographic Printing Materials (CTG) (71 FR 58745); Letterpress Printing Materials (CTG) (71 FR 58745); Industrial Cleaning Solvents (CTG) (71 FR 58745); Flat Wood Paneling Coatings (CTG) (71 FR 58745);

Group III Portable fuel containers (part of Mobile Source Air Toxics rule) Aerosol Coatings (rule) Paper, Film and Coatings (CTG) (72 FR 57215); Metal Furniture Coatings (CTG) (72 FR 57215); Large Appliance Coatings (CTG) (72 FR 57215);

Group IV Miscellaneous Metal Products Coatings (CTG) (73 FR 58481). Plastic Parts Coatings (CTG) (73 FR 58481). Auto and Light-Duty Truck Assembly Coatings (CTG) (73 FR 58481). Fiberglass Boat and Manufacturing Materials (CTG) (73 FR 58481). Miscellaneous Industrial Adhesives (CTG) (73 FR 58481).

At the time of writing this TSD (December, 2012), Louisiana had revised its rules to meet current RACT requirements. Some of the above-mentioned CTGs were addressed earlier as part of the 1-hour requirements in Baton Rouge, and others were approved on December 2, 2011 (76 FR 467). RACT-related rules reduce VOC emissions in the Baton Rouge / Pointe Coupee area.

(4) Locomotives: The Railroad Research Foundation received a DERA grant to replace 4 switcher locomotives in the Baton Rouge area that will yield a reduction of 1170 Tons

of NOx between 2010 to 2015.Page 13 of 23 (5) Marine Emissions: Hawk camera studies may result in some reductions in VOC from marine activity in the Baton Rouge nonattainment area.

The above discussion of rules and measures adds additional credence to the previous assessment that the 11% increase in NOx projected by Louisiana using EGAS is overstated. Also, this discussion addresses additional rules and measures which will help the Pointe Coupee area continue to maintain the standard through the remainder of the maintenance period.

As additional evidence that the EI projections for point source NOx emissions are overstated, the ambient PAMS monitoring data in the Baton Rouge area from the Capitol site demonstrate that actual NOx emissions from point sources in the nonattainment area, just southeast of Pointe Coupee, for the most part decreased since 2001. There is a single spike that occurs in 2006, but this is considered an anomaly resulting from the inflated population in the Baton Rouge area following Hurricane Katrina in August 2005. See the graph in Attachment 10 to this TSD, and a more detailed discussion in Section 5, Ambient Air Quality Monitoring.

In summary, as shown in the tables and discussion above, the State has demonstrated that the future year emissions of VOCs through 2014 will be less than the 2002 base attainment year’s emissions. For NOx, although the State’s projections show an 11% increase over the period of the maintenance plan, this increase has been shown to be overstated; based on EPA’s analysis considering the shortcomings of the EGAS projection method as well as the controls which were not taken into account in the projections, NOx emissions are expected to remain similar to 2002 levels. The attainment inventories submitted by the LDEQ for these areas are

consistent with the criteria as discussed in the EPA Maintenance Plan Guidance memo dated May 20, 2005 and in other guidance documents (please see the docket for additional information). Considering emissions projections together with actual monitoring data plus reductions from measures not accounted for in the state’s projections, EPA finds that the future emissions levels in 2008, 2011 and 2014 are expected to be less than or similar to emissions

levels in 2002.

Due to the delay in acting on this SIP revision for Pointe Coupee, we have taken the opportunity to compare the emissions inventory projections from Table 1 with actual emissions reported by the state to the NEI database. Tables 3 and 4 compare actual emissions in Pointe Coupee during the base year and 2005 and 2008 with the inventory projections through 2014. The 2011 EI data were not yet available at the time of this writing.Page 14 of 23 Table 3 Pointe Coupee

NO

x Emissions Inventory Baseline (2002) with Projections to 2014 and Actual Emissions (2002, 2005, and 2008) (tons per day)

Emissions source 2002

Baseline 2008 2011 2014 2002

NEI 2005

NEI 2008

NEI

Point Source NO

x 55.93 58.55 61.38 64.39 57.2 38.3 36.7 Non-point (Area)

Source NO

x 1.04 1.14 1.21 1.27 12.0 12.2 4.4

Nonroad NO

x 6.81 6.84 6.87 6.87 0.9 0 0.8

Onroad NO

x 1.94 1.28 0.98 0.74 1.6 1.1 1.3

Total NO

x 65.72 67.81 70.44 73.27 71.6 51.7 43.2

NOx Trends and differences

–

● Point source NOx was slightly higher in the 2002 NEI, but decreased steadily in 2005-2008 to well below the projection for 2008. Projections showed there would be a slight increase in NOx,

which did not materialize.

● Non-point source NOx in the 2002 NEI was considerably higher than the baseline number but dropped by 1/3 in 2008 from 2005. The projections showed these emissions as remaining fairly steady with only a slight increase through 2014.

● Nonroad NOx was considerably lower in 2002 NEI than the 2002 baseline but fluctuated some in 2005 -2008. In the projections, these emissions remained steady.

● Onroad NOx was slightly lower in the 2002 NEI than the baseline but remained fairly steady in 2005-2008. The projections showed a steady decrease in on-road NOx.

● Overall NOx emissions declined in the NEI, while the projected NOx emissions increased for 2008 in the attainment inventory.Page 15 of 23 Table 4 Pointe Coupee VOC Emissions Inventory Baseline (2002) with Projections to 2014 and Actual Emissions (2002, 2005, and 2008) (tons per day)

Emissions source 2002

Baselin

e 2008 2011 2014 2002

NEI 2005

NEI 2008

NEI

Point Source VOC 1.53 1.61 1.68 1.76 2.0 1.4 1.7 Non-Point (Area)

Source VOC 2.91 3.18 3.34 3.48 3.0 7.0 3.5

Nonroad VOC 2.83 2.36 1.99 1.81 1.0 0 0.8

Onroad VOC 1.36 0.89 0.74 0.61 1.1 0.8 1.1

Total VOC 8.63 8.04 7.75 7.66 7.1 9.2 7.2

VOC Trends and Differences

–

● Point source VOC was slightly higher in the 2002 NEI and fluctuated slightly through 2005 to 2008. The projected VOC emissions increased slightly through 2014.

● Non-point source VOC was nearly identical in the 2002 Baseline and the 2002 NEI. While the NEI showed a doubling in 2005, it also showed a fall back to half again in 2008. The projections showed small steady increases through 2014 which were somewhat lower than what was reported in the NEI through 2008.

● Nonroad VOC in the NEI was 1/3 of that in the baseline. The NEI fluctuated slightly through 2008. The VOC projections in this category showed a steady decrease through 2014.

● Onroad VOC in the NEI mirrored the pattern of the nonroad VOC NEI, although the 2002 onroad NEI was nearer the value of the 2002 baseline. The projections showed a steady decrease through 2014 similar to the nonroad emissions.

● Overall, NEI VOC was the same in 2008 as it was in the 2002 NEI, while the projections showed a steady decrease through 2014.

Bottom line

–

● Emission values, both projected and actual, in this primarily rural parish are a fraction of emissions in the neighboring nonattainment parishes.

● Values in the NEI for Pointe Coupee were in the same order of magnitude as those projected by the attainment inventory. The 2002 NEI varied slightly from the baseline values but only by small amounts. There were no dramatic differences between trend lines for projections and actual emissions. Where there were slight differences in trends, they were not causes for concern. None of the data, projected or actual, points to a violation in 2007. (See a discussion of the 2007 violation as an anomaly in Section 5, Ambient Air Quality Monitoring.)

● Maintenance plans have backstops for failures in the form of contingency measures. Contingency measures in this maintenance plan are triggered upon monitoring a violation of the 1997 8-hour ozone standard. Emission inventory data is informative but should not be thePage 16 of 23 determining factor in predicting whether this particular maintenance plan will be adequate or not when actual monitoring data exists to support it. When clear monitoring data exists that has already shown the adequacy of the plan, emission inventory data, not available at the time the plan was developed, should not be the driving fact or in determining plan approval. By the time this action goes final, the maintenance plan will have about one more year left to run its course. Having EI data that does not exactly match actual inventory data is not a good reason to deny approvability of an otherwise successful plan. In many cases, the NEI inventory data supports what was projected in the attainment inventory. If this plan were to fail in the last few months of its 10 year span, approved contingency measures would be triggered to mitigate a violation.

Section 4. Maintenance Demonstration . The primary purpose of a maintenance plan is to demonstrate how an area will continue to remain in compliance with the 1997 8-hour ozone standard, including how an area return to compliance if necessary, for the 10 year period following the effective date of designation as unc lassifiable/attainment. The end projection year is 10 years from the effective date of the attainment designation, which for Pointe Coupee Parish was June 15, 2004. Therefore, this plan must demonstrate a plan to maintain or to return to maintenance of the 1997 8-hour ozone standard through June 15, 2014.

In this section, the State must demonstrate how the area will remain in compliance with the 1997 8-hour ozone standard for the applicable 10 year period, which for this parish begins with the effective date of designation of June 15, 2004, and extends to June 15, 2014. The typical method that areas used in the past to demonstrate that an area would maintain the 1-hour standard was to identify the level of ozone precursor emissions in the area which were sufficient to attain the NAAQS and to show that future emissions of ozone precursors would not exceed the levels previously associated with attainment of the standard. To perform this analysis for the 8-hour maintenance plan, the State needs to develop emission inventories for one of the three years used to establish the area’s attainment status and for the projection years. Maintenance may also be demonstrated using other methods, such as modeling.

Louisiana provided this demonstration for the parish using 2002 base year inventory data, and emission projections for 2008, 2011, and 2014. The State identified the level of precursor emissions in Pointe Coupee Parish that was sufficient to attain the NAAQS, i.e., the 2002 attainment inventory, and established interim emission projections of ozone precursors for the years 2008, 2011, and 2014.

As discussed in Section 2: Emissions Inventory above, Louisiana identified the level of ozone-forming emissions in Pointe Coupee Parish that is consistent with attainment of the NAAQS for ozone in 2002. As discussed in Secti on 3: Attainment Inventory above, Louisiana projected VOC and NO

x emissions for the years 2008, 2011, and 2014 in Pointe Coupee Parish,

and EPA finds that future emissions levels in thos e years are projected to be similar or below the

emissions levels in 2002. Please see Section 2: Emissions Inventory and Section 3: Attainment Inventory for more information on EPA’s review and evaluation of the State’s 2008, 2011, and 2014 projected emissions inventories.Page 17 of 23 As discussed in section 3 above, Louisiana relies on several air quality measures that will provide for additional 8-hour ozone emissions reductions in Pointe Coupee Parish. These measures include the following, among others: (1) On-Road Standards: Enacting of specific requirements from a) EPA’s Tier 2 Motor Vehi cle Emission Standards (65 FR 6697), b) EPA’s Heavy-Duty Engine and Vehicle Standards (66 FR 5002), as well as c) EPA’s gasoline and highway diesel fuel sulfur control requirement s (66 FR 5002); (2) Non-Road Engine Standards: EPA’s required control of emissions from non-road diesel engines and fuels (69 FR 38958); (3) implementation of additional Consumer and Commercial Products Control Technique Guidelines (CTGs) for various VOC sources, including Flexib le Packaging Printing Materials, Lithographic Printing Materials, Letterpress Printing Material s, Industrial Cleaning Solvents, and Flat Wood Paneling Coatings (71 FR 58745), for Paper, Film and Coatings; and Large Appliance Coatings (72 FR 57215), as well as for Miscellaneous Metal Products Coatings, Plastic Parts Coatings, Auto and Light-Duty Truck Assembly Coatings, Fiberglass Boat and Manufacturing Materials, and Miscellaneous Industrial Adhesives (73 FR 58481); (4) Locomotives: The Railroad Research Foundation received a DERA grant to replace 4 switcher locomotives in the Baton Rouge area that will yield a reduction of 1170 Tons of NOx between 2010 to 2015; and (5) Marine Emissions: Hawk camera studies may result in some reductions in VOC from marine activity in the Baton Rouge nonattainment area. The purpose of these control measures is to reduce levels of 8-hour ozone, including the area of Pointe Coupee Parish, as well as to reduce transport to the Pointe Coupee Parish area from other areas.

In its submittal for Pointe Coupee Parish, Louisiana demonstrated using several methods that the parish can continue to maintain the 1997 8-hour standard for ground-level ozone. LDEQ identified the level of ozone precursor emissions which were sufficient to attain the NAAQS and has shown that future emissions of ozone precursors are projected to be similar to levels previously associated with attainment of the standard. In addition, other control measures, such as VOC controls for Consumer Products, should help Pointe Coupee Parish continue to maintain the 1997 8-hour ozone air quality standard.

Section 5: Ambient Air Quality Monitoring . To verify the attainment status of the area over the ten-year maintenance period, the maintenance plan should contain provisions for continued operation of an appropriate, EPA-approved air quality monitoring network in accordance with 40 CFR Part 58. In the maintenance plan, the state agrees to continue with EPA through the air monitoring network review process as required by 40 CFR Part 58, and commits that air monitoring data will continue to be quality assured according to federal requirements.

The design value for the 2002 baseline attainment inventory for Pointe Coupee Parish is 0.071 ppm, which is equivalent to 71 parts per billion (ppb). The 1997 8-hour ozone NAAQS is 0.08 ppm based on the three-year average of the fourth-highest daily maximum 8-hour average

ozone concentration measured at each monitor within an area. The 1997 standard is considered to be attained at 84 parts per billion (ppb).

In the years 2002 through 2006, the 8-hour ozone design values, which are based on a three-year average of the fourth-highest daily maximum average ozone concentration, werePage 18 of 23 consistently below the NAAQS. However, data for the 2007 ozone season indicate that the area

had a 4 th high value of 81 ppb, and a corresponding design value of 86 ppb. Eight-hour ozone design values for Pointe Coupee Parish are provided in Table 2 in parts per billion (ppb).

From 2002 through 2005, the years included in the submittal, the 8-hour ozone design values, which are based on a three-year average of the fourth-highest daily maximum average ozone concentration, were consistently below the NAAQS. Eight-hour ozone design values for Pointe Coupee Parish are provided in Table 5 in parts per billion (ppb). As shown in the table, design values for 2003 through 2005 are such that the area was considered to be in attainment of the 8-hour ozone NAAQS.

Table 5 1997 8-Hour Ozone Design Values for Pointe Coupee Parish (in parts per billion)

Year Design Value

2000-2002 71

2001-2003 73

2002-2004 76

2003-2005 81

As shown in Table 5, the New Roads monitoring site in Pointe Coupee Parish monitored attainment with the 1997 8-hour ozone standard from 2002 through 2005. At the time the maintenance plan was submitted by LDEQ, the three most recent 8-hour design values for Pointe Coupee Parish were 73 ppb for 2003, 76 ppb for 2004, and 81 ppb for 2005. After the submittal was received by EPA, the design values for Pointe Coupee Parish site (New Roads, AQS #22- 077-0001) are as shown in Table 6. These are based on certified monitoring data submitted to EPA, except for prelminary 2012 data available at this time.

Table 6 1997 8-Hour Ozone Design Values for Pointe Coupee Parish (in parts per billion)

Year Design Value

2003-2005 81

2004-2006 84

2005-2007 86

2006-2008 83.3

2007-2009 77

2008-2010 75

2009-2011 75.3

2010-2012 77 (preliminary)

The 4 th highest values at the New Roads monitor are shown in Table 7. Even though the highest 4 th high occurred in 2006, the violation did not take place until 2007 due to the three yearPage 19 of 23 averaging that takes place in the design value calculation. The 4 th highs in 2005 and 2007 were not low enough to compensate for the spike in 2006.

Table 7

4 th High Value Monitored at the New Roads Site

Year 4 th High

2005 86

2006 92

2007 81

2008 77

2009 73

2010 75

2011 78

The greatest contributor to the 2007 ozone violation is the 4 th high in 2006. Speciated PAMS monitoring data from the Capitol site in Baton Rouge, about 30 miles to the southeast of New Roads, shows a spike in NOx from stationary sources in 2006. (See the graph in Attachment 10 to this TSD.) This is likely the result of the sudden increase in population in the Baton Rouge metropolitan area (that includes Pointe Coupee Parish) from Hurricane Katrina refugees that fled to the Baton Rouge area in August 2005. Upwards of 75,000 people moved to the area within a few days to escape the ravages of the storm. Of those, it is estimated that about 15,000 people ultimately stayed, and it is well documented by the Baton Rouge Area Chamber of Commerce and the local news media that the Baton Rouge area was used as a staging area for recovery and reconstruction activities in New Orleans during that time. Refining capacity south of Baton Rouge was impacted with several facilities being closed for repairs or running at reduced capacity for an extended period. This put more pressure on the facilities in the Baton Rouge area to step up fuel production to make up for the shortfall in the national and local fuel supply. Local power companies also needed to ramp up to provide more power for Baton Rouge’s inflated population energy needs.

To better understand the source of the 2007 ozone violation in Pointe Coupee Parish , EPA also reviewed and analyzed the conditions leading to the higher ozone concentrations and found that most data showed the higher ozone days in Pointe Coupee Parish were due to ozone concentrations or pre-cursors coming primarily from outside of the Parish. Of the twelve days in which there was an exceedance in 2005 - 2007, eleven show significant influence coming from outside the parish. For ten of the days, the trajectories show influence from the industrial area of Baton Rouge (southeast of Pointe Coupee), and for one of the days the trajectory goes through West and East Feliciana Parishes (northeast of Pointe Coupee) The twelfth exceedance was not high enough to be included in the design value calculation. A map entitled, “Analysis of High Ozone Concentrations in Pointe Coupee Parish, LA” is included in the docket. It provides information about conditions in the Parish during the 24 hours preceding high ozone concentrations for the year 2007. Please see the docket for this analysis. After we shared this information with the State, the State reviewed the status of the Baton Rouge area and evaluated potential control measures that could be available to lower the ozone concentration in both areas.Page 20 of 23 Before the State could finish its evaluation, however, Pointe Coupee came back into attainment for the year 2008. Pointe Coupee’s 2008 monitoring data had no exceedances, and the design value for 2008 is below the 1997 8-hour ozone standard. EPA certified the 2008 data in January

2009.

Because air quality in Pointe Coupee is influenced by air quality in the Baton Rouge 5- parish area, ozone monitoring information for that area is included here. The Baton Rouge 5- parish area continues to remain in attainment for the 1-hour ozone standard, with a current

uncertified 1 1-hour ozone design value of 100 ppb. Baton Rouge also continues to monitor

attainment for the 1997 8-hour ozone standard with an uncertified 1 8-hour ozone design value of 77 ppb. Baton Rouge was redesignated to attain ment for both the 1-hour and 1997 8-hour ozone standards on November 30, 2011. A map showing the air quality trends in Baton Rouge is

included in this docket.

Like the Baton Rouge 5-parish area, Pointe Coupee has been in attainment with the 1997

8-hour ozone standard since 2008. We believe the violation that occurred in 2007 was an anomaly caused by activity related to Hurricane Katrina in 2006.

A related, important factor for maintenance is that the Baton Rouge NOx Emissions Inventory shows a downward trend due to recent state and federal NOx regulatory controls. See Section 3: Attainment Inventory above for a deta iled discussion of regulatory controls and other measures which are helping to improve air quality in Baton Rouge, and therefore Pointe Coupee.

Population information for Pointe Coupee and the adjoining Baton Rouge area supports the air quality data reported. The population of Pointe Coupee increased by about 900 people since 2005 according to the U.S. Census data. The population density of Pointe Coupee for 2005 was 37.7 people per square mile. In 2010, the density had inched up to 39.7 people per square mile. This contrasts with a population density in East Baton Rouge Parish of 870 people per square mile in 2005 and 967 people per square mile in 2010, an 11% increase. Also, from 2000 – 2005, the population density for Pointe Coupee previously decreased by 2%. (Some of this data was provided by OAQPS as part of the 2008 ozone designation information for consideration; other data are from the 2005 and 2010 U.S. census).

Other considerations in support of maintaining attainment with the 1997 8-hour ozone standard include a) the 12 years Pointe Coupee Parish has been in attainment with the 1-hour NAAQS (EPA approved Louisiana’s request to redesignate Pointe Coupee Parish to attainment for the 1-hour ozone standard and the maintenance plan on January 6, 1997 (62 FR 648); b) the previously approved maintenance plan for the 1-hour standard (62 FR 648); and c) the designation of attainment of Pointe Coupee Parish for the 1997 8-hour ozone NAAQS (69 FR 23858).

1 2010-2012 monitoring data.Page 21 of 23 Further, in the event of a violation of the 1997 8-hour standard, the State of Louisiana commits in the Contingency Measures Plan included in the maintenance plan, to adopt and implement the chosen contingency measures no later than 24 months after the violation occurred. EPA defines the violation as the date that it certifies the monitoring data. In this case, EPA certified the 2007 data in July 2008. The State pursuant to its commitment was to adopt and implement appropriate control measures no later than July 2010 to ensure that the parish returns to maintenance of the 1997 8-hour ozone standard. Additional information regarding the contingency plan and contingency measures is included in Section 7. Contingency Plan, below.

If we were making a clean data determination for Pointe Coupee based on three years of clean data, we could easily make that finding with adequate supporting data. That is not the purpose of this action, however. We believe that with five years of clean data, and evidence to show that the 2007 violation was an anomaly, we can propose approval of the maintenance plan for Pointe Coupee.

Section 6: Verification of Continued Attainment

. Maintenance plans are required to indicate how the state will track the progress of the maintenance plan, since emissions projections made for the maintenance demonstration depend on assumptions of point, area and mobile source growth. The State should project maintenance during the 10-year period following the date of designation for the 8- hour NAAQS, including interim emission projection years to show a trend analysis for maintenance of the standard, as well as projection for the 10 th

year.

These requirements are addressed by LDEQ in Section 6 of this plan. In this section, Louisiana commits to verify the 8-hour ozone status in the maintenance plan through annual and periodic evaluations of the emissions inventories. In the annual evaluations, Louisiana will

review VOC and NOx emission data from sta tionary point sources. During the periodic evaluations (every three years), Louisiana will update the emissions inventory for all emissions source categories, and compare the updated emissions inventory data to the projected 2008, 2011

and 2014 attainment emissions inventories to ve rify continued attainment of the 1997 8-hour

ozone standard.

Section 7: Contingency Plan . The Phase 1 Rule requires that section 110(a)(1) maintenance plans include contingency provisions to promptly correct any violation of the NAAQS that occurs (51.905(a)(3)(iii) and (4)(ii)). The contingency plan should ensure that the contingency measures are adopted expeditiously once they are triggered. Consistent with the manner in which EPA has interpreted analogous requirements for contingency measures, EPA believes that the SIP should contain an enforceable commitment to adopt and implement the contingency measures in a timely fashion once they are triggered. The schedule for adoption and implementation should be as expeditious as practicable, but no longer than 24 months. The State should also identify specific indicators, or triggers, which will be used to determine when the contingency measures need to be adopted and implemented.Page 22 of 23 The section 110(a)(1) maintenance plan for Pointe Coupee Parish includes contingency provisions to promptly correct any violation of the NAAQS that occurs. The contingency indicator for the Pointe Coupee Parish maintenance plan is based on monitoring data. The contingency plan for the parish is triggere d upon monitoring a violation of the 8-hour ozone standard, and will be implemented as expeditiously as practicable, but no longer than 24 months following the trigger. As discussed in Section 5 above, the State pursuant to its commitment is to adopt and implement appropriate control measures no later than July 2010 to ensure that the parish returns to maintenance of the 1997 8-hour ozone standard.

Contingency measures to be considered for implementation include:

 Revision of VOC emission control regulations in LAC 33:III.Chpater 21, to increase stringency;

 Revision of NO

x emission control regulations on LAC 33:III Chapter 22 to increase stringency.

 Emission offsets for permits (1.10 to 1.0 ratio for VOC and NO

x ); and

 Other measures deemed appropriate at the time as a result of advances in control technologies.

The contingency measures and schedules for implementation included in the maintenance plan are consistent with EPA’s long-standing guidance on contingency measures, including the discussion of contingency measures in the General Preamble (57 FR 13498) (see docket). Continued attainment of the 8-hour ozone NAAQS in the Pointe Coupee Parish area will depend, in part, on the air quality measures discussed previously (see Section 4 above).

III. EPA Conclusion and Recommendation

Based on the above discussion, we recommend approval of the submitted SIP revisions incorporating the Pointe Coupee Parish Section 110(a)(1) 8-hr Ozone Maintenance Plan into the

Louisiana SIP.

The design value for 2007 of 86 ppb violated the 1997 8-hour ozone standard. EPA generally does not approve a redesignation request and corresponding maintenance plan whenever there has been a violation of the applicable standard in the area. However, for this specific scenario of Pointe Coupee with all of its facts, as described above and detailed below in the attachments, it is EPA’s technical and programmatic position that approval of the maintenance plan for this standard is warranted based upon the distinguishing facts.Page 23 of 23 Attachments:

1. Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard – Phase 1, 69 FR 23951, April 30, 2004.

2. EPA Guidance Memorandum: Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under Section 110(a) (1) of Clean Air Act (Lydia N. Wegman, Director, Air Quality Strategies and Standards Division, May 20, 2005).

3. Consolidated Emissions Reporting Rule (CERR), Final Rule, 67 FR 39602, June 10, 2002.

4. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations, August, 2005,

revised November 2005.

5. Central Regional Air Planning Associa tion (CENRAP): Consolidation of Emission Inventories. Prepared by E.H. Pechan & Associates Inc. and Carolina Environmental Program, University of North Carolina Chapel Hill for CENRAP, April 28, 2005.

6. State Implementation Plans; General Preamble for the Implementation of Title 1 of the Clean Air Act Amendments of 1990, 57 FR 13498, April 16, 1992.

7. EPA Guidance Memorandum: 2002 Base Year Emission Inventory SIP Planning: 8-hr Ozone, PM 2.5, and Regional Haze Programs” November 18, 2002.

8. EPA Map, “Analysis of High Ozone Concentrati ons in Pointe Coupee Parish, LA”, October, 10, 2007.

9. EPA Map of Baton Rouge Ozone Trends.

10. Kitchen sink. Graph: Baton Rouge Capitol Site, Mean Morning NOx Concentrations,

1996-2011.