Subpart
2
Nonattainment
Areas
with
additional
needed
controls
from
ROP
Base
Case
2010
VOC
Emissions
(
tons)
Estimated
Additional
VOC
Reductions
to
Meet
a
Stringent
15%
RFP
Requirement
(
tons)
Estimated
Additional
VOC
Reductions
Observed
in
2010
as
a
%
of
2010
Base
Case
Emissions
Chicago
124683
1731
1.4%
Cleveland
143384
3049
2.1%
Milwaukee
78997
803
1.0%
Providence
57929
8209
14.0%
Sheboygan
7576
402
5.3%
Attachment:
Analysis
of
Potential
Impacts
of
ROP
on
Ozone
in
Five
Cities
to
Support
Response
to
Comments
Background:

In
the
Response
to
Comments
(
RTC)
document
for
the
CAIR
final
rule,
EPA
addresses
the
comment
that
locally
mandated
Part
D
emission
controls
must
be
included
in
the
base
case
analysis
for
nonattainment
areas
that
EPA
plans
to
designate
for
PM2.5
and
ozone.
The
comment
concludes
that
it
is
not
reasonable
for
EPA
to
assume
that
these
local
control
programs
will
not
significantly
impact
the
attainment
status
of
many
of
the
areas
that
the
EPA
analysis
predicts
future
nonattainment.
Within
the
RTC
document,
EPA
concluded
that
five
nonattainment
areas
with
significance
linkages
to
upwind
States
may
be
required
to
achieve
additional
rate
of
progress
(
ROP)
reductions
in
VOC
by
2008
that
are
not
accounted
for
in
the
CAIR
2010
base
case
modeling
scenarios.
However,
EPA
does
not
believe
that
VOC
reductions
of
this
magnitude
would
be
enough
to
bring
these
areas
into
attainment
in
2010.
This
document
presents
the
analysis
that
supports
the
above
assertion.

Table
1.1
shows
the
initial
ROP
analysis
for
the
five
areas
determined
to
potentially
need
additional
reductions
in
VOC
emissions
to
achieve
a
15
percent
reduction.
(
Dallas
may
also
need
additional
VOC
controls,
but
since
no
States
are
covered
in
CAIR
due
to
a
linkage
with
Denton
or
Tarrant
counties,
this
area
was
not
considered
in
this
analysis.)

Table
1.1.
Emissions
information
for
the
subpart
2
nonattainment
areas
that
are
expected
to
need
additional
controls
from
rate
of
progress
requirements.

EPA
has
not
done
any
2010
CAMx
modeling
that
includes
the
additional
VOC
reductions
shown
in
the
far
right
column
of
Table
1.1.
However,
we
have
completed
a
series
of
sensitivity
analyses
using
the
same
ozone
modeling
platform
used
in
modeling
ozone
for
CAIR
(
i.
e.,
the
2010
base
case)
looking
at
the
impacts
of
NOx
and
VOC
controls
in
residual
nonattainment
areas.
This
modeling
platform
is
described
in
the
CAIR
Notice
of
Final
Rulemaking
Air
Quality
Modeling
Technical
Support
Document.
A
number
of
sensitivity
runs
were
completed
considering
NOx­
only
reductions
and
combined
NOx/
VOC
reductions
at
10
and
25
percent.
Only
manmade
emissions
within
the
2010
projected
nonattainment
areas
were
reduced.
A
plot
of
these
areas
is
shown
in
Figure
1.1.
No
modeling
runs
were
completed
for
VOC
only
runs,
but
as
a
first
Grids
Affected
by
2004
Analysis
Areas
1,280
Grids
in
146
Counties,
17
Analysis
Areas
approximation
it
is
possible
to
compare
the
model
response
from
the
NOx
only
runs
against
the
NOx/
VOC
runs
to
get
an
estimate
of
the
signal
from
VOC
only
controls.
Figure
1.1.
Map
of
areas
in
which
anthropogenic
emissions
were
reduced
in
the
10%
and
25%
sensitivity
modeling.

Results:

Table
1.2
shows
the
sensitivity
modeling
results
over
the
five
nonattainment
areas
of
interest.
For
each
nonattainment
area,
there
is
a
single
county
that
has
the
controlling
site
(
i.
e.,
has
the
highest
ozone
projections
for
the
area).
The
Chicago
and
Milwaukee
nonattainment
areas
share
the
same
controlling
site,
Kenosha
Co.,
WI.
From
the
information
in
tables
1.1
and
1.2
it
is
possible
to
combine
the
percentage
level
of
needed
VOC
controls
with
the
estimated
effect
of
those
controls
to
develop
an
rough
estimate
of
the
2010
design
value
projections
for
these
five
areas
had
the
ROP
controls
been
included
in
the
base
case.

For
example,
Providence
RI
was
estimated
to
need
an
additional
14%
VOC
control
due
to
the
ROP
requirements.
The
projected
design
value
in
this
area
in
2010
without
these
controls
is
86.4
ppb.
Based
on
the
sensitivity
modeling,
we
see
that
10­
25%
additional
VOC
control
(
in
all
nonattainment
areas,
not
just
Providence)
will
lower
the
future
design
value
by
0.5
to
0.9
ppb.
Even
at
a
25%
level,
the
additional
VOC
reductions
then
would
not
be
enough
to
reach
attainment
(
86.4
­
0.9
=
85.5).
This
conclusion
also
holds
for
the
other
four
areas
where
the
unaccounted
ROP
VOC
reductions
are
even
smaller
and
the
excess
above
the
85
ppb
attainment
threshold
is
larger.

Nonattainment
area
County
Name
2010
Base
Case
projection
(
ppb)
type
of
emissions
control
10%
reduction
simulations
25%
reduction
simulations
Chicago
Kenosha
WI
91.3
NOx
only
91.3
90.5
NOx
+
VOC
90.7
89.3
VOC
only
90.7
90.1
Cleveland
Geauga
OH
87.1
NOx
only
86.0
84.0
NOx
+
VOC
85.8
83.4
VOC
only
86.9
86.5
Milwaukee
Kenosha
WI
91.3
NOx
only
91.3
90.5
NOx
+
VOC
90.7
89.3
VOC
only
90.7
90.1
Providence
Kent
RI
86.4
NOx
only
85.4
83.1
NOx
+
VOC
84.9
82.2
VOC
only
85.9
85.5
Sheboygan
Sheboygan
WI
88.3
NOx
only
87.2
85.3
NOx
+
VOC
87.1
85.0
VOC
only
88.2
88.0
Table
1.2.
Summary
of
2010
base
case
and
sensitivity
modeling
for
the
five
cities
of
interest.
All
units
are
ppb.
The
"
VOC
only"
runs
were
not
modeled
but
were
estimated
based
on
the
other
two
sets
of
runs.

Based
on
this
sensitivity
modeling
we
do
not
believe
VOC
reductions
of
the
magnitude
estimated
to
be
needed
for
ROP
purposes
would
alter
the
receptors
in
residual
nonattainment
in
2010.
As
noted
in
the
response
to
comments,
even
if
our
conclusion
was
incorrect,
and
all
five
cities
did
attain
as
a
result
of
8­
hour
ROP
reductions,
this
would
not
alter
our
conclusions
about
the
States
subject
to
CAIR.
All
upwind
States
are
linked
to
other
nonattainment
receptors
as
well
as
those
five
cities
shown
in
Table
1.1.
For
these
reasons,
we
believe
that
the
impact
of
subpart
2
requirements
for
8­
hour
ozone
areas
is
adequately
captured
in
our
CAIR
base
case
and
that
our
findings
are
valid
concerning
both:
a)
the
receptors
remaining
in
nonattainment
in
2010
and
b)
the
covered
States
that
result
from
those
receptors.
