Corrected
Version
as
of
February
18,
1994
Guidance
on
the
Post­
1996
Rate­
of­
Progress
Plan
and
the
Attainment
Demonstration
Ozone/
Carbon
Monoxide
Programs
Branch
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
NC
27711
ii
iii
CONTENTS
Page
LIST
OF
TABLES
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LIST
OF
FIGURES
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vi
ACRONYMS
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vii
EXECUTIVE
SUMMARY
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1
1.0
INTRODUCTION
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3
1.1
Purpose
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5
2.0
CALCULATION
OF
POST­
1996
TARGET
LEVELS
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7
2.1
Calculation
of
Post­
1996
Target
Level(
s)
of
Emissions
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7
2.2
Example
Calculation
of
Post­
1996
Target
Level(
s)
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13
Calculation
of
1999
Target
Level
of
Emissions
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13
2.3
Conditions
Permitting
Less
than
a
3
Percent
VOC
Emission
Reduction
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16
3.0
ATTAINMENT
DEMONSTRATION
REQUIREMENTS
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17
3.1
Modeling
Requirements
for
Attainment
Demonstrations
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17
3.2
Special
Air
Quality
Situations
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18
Areas
Requiring
Emission
Reductions
in
Addition
to
3
Percent
per
Year
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18
Multi­
State
Nonattainment
Areas
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18
States
Included
in
More
than
One
Modeling
Domain
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19
International
Border
Areas
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19
Areas
with
Differing
Required
Attainment
Dates
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19
Exceedances
Monitored
within
a
Modeling
Domain
Due
Primarily
to
Emissions
in
Another
Domain
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20
4.0
NOX
EMISSION
REDUCTIONS
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21
4.1
Substitution
of
NOx
Emission
Reductions
for
Post­
1996
VOC
Emission
Reductions
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21
4.2
Calculation
of
Post­
1996
NOx
and
VOC
Target
Levels
of
Emissions
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21
4.3
Creditability
of
Pre­
1996
VOC
and
NOx
Reductions
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29
4.4
Example
Calculation
of
Post­
1996
VOC
and
NOx
Target
Levels
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30
Calculation
of
1999
Target
Levels
of
Emissions
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30
5.0
CONTROL
STRATEGIES
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35
5.1
Mandatory
Requirements
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35
Serious
Nonattainment
Area
Requirements
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35
Severe
Nonattainment
Area
Requirements
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40
Extreme
Nonattainment
Area
Requirements
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40
5.2
Additional
Control
Measures
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41
5.3
Emission
Projections
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42
Growth
Factors
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43
5.4
Relationship
Between
the
Post­
1996
Rate­
of­
Progress
Plans
and
Other
Provisions
of
the
Act
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47
Multiple
Projection
System
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48
5.5
Economic
Incentive
Programs
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49
5.6
Contingency
Measures
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49
5.7
Long­
Term
Control
Measures
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51
5.8
New
Technologies
for
Extreme
Ozone
Nonattainment
Areas
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53
iv
6.0
POST­
1996
RATE­
OF­
PROGRESS
PLAN
AND
ATTAINMENT
DEMONSTRATION
SUBMITTALS
AND
DOCUMENTATION
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55
6.1
Post­
1996
Rate­
of­
Progress
and
Attainment
Demonstration
Requirements
.
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55
1990
Adjusted
Base
Year
Inventory
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56
Target
Level(
s)
of
Emissions
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56
Control
Measure
and
Growth
Factor
Information
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56
Milestone
Year
Projected
Inventories
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57
6.2
Multi­
State
Submittal
Information
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57
6.3
Mid­
Course
Corrections
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57
6.4
Suggested
Submittal
Tables
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58
REFERENCES
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63
APPENDIX
A:
DEFINITIONS
OF
TERMS
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A­
1
APPENDIX
B:
GENERAL
IMPLICATIONS
OF
MILESTONE
AND
ATTAINMENT
FAILURES
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B­
1
APPENDIX
C:
CHECKLISTS
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C­
1
APPENDIX
D:
COMPILATION
OF
GUIDANCE
MEMORANDA
ON
THE
15
PERCENT
RATE­
OF­
PROGRESS
REQUIREMENT
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D­
1
v
LIST
OF
TABLES
Number
Page
1.
SERIOUS
AND
ABOVE
OZONE
NONATTAINMENT
AREA
POST­
1996
MILESTONE
AND
ATTAINMENT
DATES
.
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.
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7
2.
SIP
SUBMITTAL
REQUIREMENTS
FOR
MODERATE
AND
ABOVE
OZONE
NONATTAINMENT
AREAS
.
.
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36
3.
BEA
PROJECTION
CATEGORIES
FOR
METROPOLITAN
STATISTICAL
AREAS
(
MSA'S)
AND
STATES
.
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.
45
5.
SUGGESTED
FORMAT
FOR
POST­
1996
RATE­
OF­
PROGRESS
CONTROL
STRATEGY
SUMMARY
SUBMITTAL
.
.
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59
6.
SUGGESTED
FORMAT
FOR
ATTAINMENT
CONTROL
STRATEGY
SUMMARY
SUBMITTAL
.
.
.
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60
7.
SUGGESTED
FORMAT
FOR
CONTINGENCY
MEASURE
SUBMITTAL
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
61
8.
SUGGESTED
FORMAT
FOR
SUBMITTAL
OF
RULE
EFFECTIVENESS
(
RE)
IMPROVEMENT
MEASURES
.
.
.
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.
62
9.
SUGGESTED
FORMAT
FOR
SUBMITTAL
OF
STATIONARY
SOURCE
CONTROL
MEASURES
FOR
THE
POST­
1996
RATE­
OF­
PROGRESS
PLAN
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
62
10.
SUGGESTED
FORMAT
FOR
SUBMITTAL
OF
STATIONARY
SOURCE
CONTROL
MEASURES
FOR
THE
ATTAINMENT
DEMONSTRATION
.
.
.
.
.
.
.
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.
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.
.
62
vi
LIST
OF
FIGURES
Number
Page
Figure
1.
Flowchart
for
generic
post­
1996
rate­
of­
progress
VOC
target
level
calculation
.
.
.
.
.
.
.
.
.
.
.
8
Figure
2.
Flowchart
of
hypothetical
example
1999
rate­
of­
progress
VOC
target
level
calculation
.
.
.
.
14
Figure
3.
Flowchart
for
generic
post­
1996
rate­
of­
progress
VOC
calculations
(
with
NOx
substitution)
.
.
.
.
.
.
.
.
.
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.
.
22
Figure
4.
Flowchart
for
rate­
of­
progress
NOx
calculation
for
1999
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
23
Figure
4a.
Flowchart
for
generic
post­
1999
rate­
of­
progress
NOx
calculations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
Figure
5.
Flowchart
for
hypothetical
example
1999
rate­
of­
progress
VOC
calculations
(
with
NOx
substitution)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
31
Figure
6.
Flowchart
for
hypothetical
example
1999
rate­
of­
progress
NOx
calculations
.
.
.
.
.
.
.
.
.
.
.
.
32
vii
ACRONYMS
Act
Clean
Air
Act
ACT
Alternative
Control
Technology
AEERL
Air
and
Energy
Engineering
Research
Laboratory
AFS
AIRS
Facility
Subsystem
AIRS
Aerometric
Information
Retrieval
System
AMS
AIRS
Area
and
Mobile
Source
Subsystem
ASC
Area
Source
Category
code
BEA
Bureau
of
Economic
Analysis
CFR
Code
of
Federal
Regulations
CO
carbon
monoxide
CTG
Control
Techniques
Guideline
E­
GAS
Economic
Growth
Analysis
System
EIP
Economic
Incentive
Program
EPA
U.
S.
Environmental
Protection
Agency
EPS
Emissions
Preprocessor
System
FIP
Federal
Implementation
Plan
FIPS
Federal
Information
Processing
Standards
FMVCP
Federal
Motor
Vehicle
Control
Program
FR
Federal
Register
I/
M
Inspection
and
Maintenance
lb
pound(
s)
LEV
Low­
Emitting
Vehicle
MPO
Metropolitan
Planning
Organization
MPS
Multiple
Projection
System
MSA
Metropolitan
Statistical
Area
NAAQS
National
Ambient
Air
Quality
Standard(
s)
NESHAP
National
Emission
Standard
for
Hazardous
Air
Pollutants
NO2
nitrogen
dioxide
NOx
nitrogen
oxides
NSPS
New
Source
Performance
Standards
NSR
New
Source
Review
OAQPS
Office
of
Air
Quality
Planning
and
Standards
ppb
parts
per
billion
ppm
parts
per
million
psi
pounds
per
square
inch
RACT
Reasonably
Available
Control
Technology
RE
rule
effectiveness
REMI
Regional
Economic
Models,
Inc.
ROM
regional
oxidant
modeling
RVP
Reid
vapor
pressure
SAS
Statistical
Analysis
System
SCC
Source
Classification
Code
SIC
Standard
Industrial
Classification
SIP
State
implementation
plan
STAPPA/
ALAPCO
State
and
Territorial
Air
Pollution
Program
Administrators
and
Association
of
Local
Air
Pollution
Control
Officials
TCM
transportation
control
measures
TIP
Transportation
Improvement
Program
tpy
tons
per
year
TSD
Technical
Support
Document(
ation)
UAM
Urban
Airshed
Model
VMT
vehicle
miles
traveled
VOC
volatile
organic
compound(
s)
ACRONYMS
(
continued)

1
EXECUTIVE
SUMMARY
Section
182(
c)(
2)
of
the
Clean
Air
Act
(
Act)
requires
each
serious
and
above
ozone
nonattainment
area
to
submit
a
State
implementation
plan
(
SIP)
revision
by
November
15,
1994,
which
describes,
in
part,
how
the
area
will
achieve
an
actual
volatile
organic
compound
(
VOC)
emission
reduction
of
at
least
3
percent
per
year
averaged
over
each
consecutive
3­
year
period
beginning
6
years
after
enactment
(
i.
e.,
November
15,
1996)
until
the
area's
attainment
date.
The
attainment
dates
prescribed
by
section
181(
a)
of
the
Act
are
as
follows:

!
November
15,
1999
for
serious
ozone
nonattainment
areas.

!
November
15,
2005
for
severe
ozone
nonattainment
areas.

!
November
15,
2007
for
severe
ozone
nonattainment
areas
with
a
1986­
1988
ozone
design
value
of
0.190
parts
per
million
(
ppm)
up
to,
but
not
including,
0.280
ppm.

!
November
15,
2010
for
extreme
ozone
nonattainment
areas.

This
SIP
revision
must
also
describe
how
any
growth
in
emissions
over
each
applicable
post­
1996
period
will
be
offset.
The
portion
of
the
SIP
revision
that
illustrates
the
plan
for
the
achievement
of
these
emission
reductions
is
subsequently
defined
in
this
document
as
the
"
post­
1996
rate­
of­
progress
plan."

The
Act
permits
less
than
a
3
percent
per
year
VOC
emission
reduction
averaged
over
each
consecutive
3­
year
period
for
serious
and
severe
ozone
nonattainment
areas
if
the
State
demonstrates
that
the
plan
includes
all
measures
that,
given
technological
achievability,
can
feasibly
be
implemented
in
the
given
area.
Additionally,
the
State
must
demonstrate
that
its
plan
includes
measures
that
are
achieved
in
practice
by
sources
in
the
same
source
category
in
nonattainment
areas
of
the
next
higher
classification
[
section
182(
c)(
2)(
B)(
ii)
of
the
Act].
The
3
percent
requirement
cannot
be
waived
in
areas
classified
as
extreme.
The
Act
also
provides
for
crediting
of
VOC
emission
reductions
achieved
in
the
1990­
1996
period
to
the
post­
1996
rate­
of­
progress
plan,
if
they
are
in
excess
of
the
15
percent
VOC
reductions
(
net
of
growth)
required
between
1990
and
1996
[
section
182(
c)(
2)(
B)(
ii)],
and
substitution
of
nitrogen
oxides
(
NOx)
emission
reductions
(
net
of
growth)
occurring
in
the
post­
1990
period
for
the
post­
1996
VOC
emission
reduction
requirements
[
section
182(
c)(
2)(
C)
of
the
Act].

In
addition
to
the
3
percent
VOC
emission
reduction
requirement,
section
182(
c)(
2)
also
requires
the
SIP
for
serious
and
above
ozone
nonattainment
areas
to
provide
"
a
demonstration
that
the
plan,
as
revised,
will
provide
for
attainment
of
the
ozone
national
ambient
air
quality
standard
(
NAAQS)
by
the
applicable
date."
Furthermore,
section
182(
c)(
2)
requires
that
the
demonstration
be
based
on
photochemical
grid
modeling
or
an
equivalent
analytical
method
as
determined
by
the
U.
S.
Environmental
Protection
Agency
(
EPA).
All
serious
and
above
ozone
nonattainment
areas
and
all
multi­
State
moderate
ozone
nonattainment
areas
are
required
to
submit
their
attainment
demonstrations,
based
on
the
use
of
a
photochemical
grid
model
such
as
the
Urban
Airshed
Model
(
UAM),
to
EPA
by
November
15,
1994.
It
is
important
to
note
that
the
underlying
requirement
of
the
SIP
is
that
nonattainment
areas
achieve
attainment
of
the
ozone
NAAQS
by
their
attainment
date.
That
is,
additional
reductions
beyond
the
required
3
percent
per
year
VOC
emission
reductions
may
be
needed
for
the
nonattainment
area
to
attain
the
NAAQS
by
its
applicable
date.

This
document
focuses
on
the
calculation
of
post­
1996
target
levels,
the
required
submittals
and
submittal
schedules
for
each
element
of
the
post­
1996
rate­
of­
progress
plan
and
attainment
demonstration,
and
the
development
of
control
strategies
to
achieve
the
required
emission
reductions.
This
document
also
provides
States
with
information
on
acceptable
data
sources
and
procedures
for
projecting
emissions.
ACRONYMS
(
continued)

2
Significant
overlap
occurs
between
concepts
relating
to
the
15
percent
rate­
of­
progress
plan
and
concepts
relating
to
the
post­
1996
plan.
Where
such
overlap
occurs,
the
applicable
guidance
documents
developed
for
the
15
percent
rate­
of­
progress
plan
are
referenced.
One
significant
difference
between
the
two
plans
is
that
unlike
the
15
percent
plan,
NOx
emission
reductions
can
be
substituted
for
the
required
VOC
emission
reductions
in
the
post­
1996
plan.
Guidance
is
provided
on
how
States
can
calculate
the
amount
of
NOx
emission
reductions
that
can
be
substituted
for
VOC
emission
reductions.

This
document
also
describes
the
EPA
requirements
for
an
attainment
demonstration
based
on
photochemical
grid
modeling
and
discusses
the
role
of
NOx
reductions
in
attainment
demonstrations.
Additionally,
this
document
discusses
the
general
implications
of
milestone
and
attainment
failures
for
serious
and
above
ozone
nonattainment
areas.
Specific
requirements
for
milestone
compliance
demonstrations
and
consequences
of
failure
to
meet
a
milestone
will
be
addressed
in
future
rulemaking.
This
document
also
provides
a
sample
checklist
to
aid
States
in
a
step­
by­
step
review
of
their
rate­
ofprogress
plans
to
ensure
that
they
contain
all
of
the
necessary
components
required
for
approval
by
EPA.
Finally,
this
document
provides
blank
forms
that
States
are
encouraged
to
use
to
document
and
submit
their
post­
1996
rate­
of­
progress
plans.
ACRONYMS
(
continued)

3
1.0
INTRODUCTION
Section
182(
c)(
2)
of
the
Act
requires
each
serious
and
above
ozone
nonattainment
area
to
submit
a
SIP
revision
by
November
15,
1994,
which
provides
for
an
actual
VOC
emission
reduction
of
at
least
3
percent
per
year
averaged
over
each
consecutive
3­
year
period
beginning
6
years
after
enactment
of
the
Act
(
i.
e.,
November
15,
1996)
until
the
area
attains
the
ozone
standard.
The
attainment
dates
prescribed
by
section
181(
a)
of
the
Act
are
as
follows:

!
November
15,
1999
for
serious
ozone
nonattainment
areas.

!
November
15,
2005
for
severe
ozone
nonattainment
areas.

!
November
15,
2007
for
severe
ozone
nonattainment
areas
with
a
1986­
1988
ozone
design
values
of
0.190
ppm
up
to,
but
not
including,
0.280
ppm.

!
November
15,
2010
for
extreme
ozone
nonattainment
areas.

If
an
area's
attainment
demonstration
shows
that
the
area
will
attain
before
the
statutory
attainment
date,
the
post­
1996
rate­
of­
progress
plan
is
only
required
to
extend
to
the
demonstrated
attainment
date.

The
portion
of
the
SIP
revision
that
illustrates
the
plan
for
the
achievement
of
the
post­
1996
emission
reductions
is
subsequently
defined
in
this
document
as
the
"
post­
1996
rate­
of­
progress
plan."
The
SIP
must
also
describe
how
any
growth
in
emissions
over
each
applicable
period
will
be
offset.

The
Act
also
mandates
a
15
percent
VOC
emission
reduction,
net
of
growth,
between
1990
and
1996.
The
SIP
revision
describing
how
this
requirement
will
be
met
was
due
by
November
15,
1993.
The
plan
for
these
1990­
1996
reductions
is
termed
the
"
15
percent
rate­
of­
progress
plan."
The
EPA
has
published
guidance
documents
describing
the
procedures
to
follow
in
developing
the
15
percent
rate­
ofprogress
plans.
Because
many
of
the
issues
discussed
in
these
documents
are
also
associated
with
concerns
relating
to
the
development
of
the
post­
1996
rate­
of­
progress
plan,
States
should
review
the
following
documents
pertaining
to
the
15
percent
rate­
of­
progress
plans:

!
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plans,
EPA­
452/
R­
92­
005,
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC.
October
1992.

!
Guidance
on
the
Relationship
Between
the
15
Percent
Rate­
of­
Progress
Plans
and
Other
Provisions
of
the
Clean
Air
Act,
EPA­
452/
R­
93­
007,
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC.
May
1993.

!
Guidance
for
Growth
Factors,
Projections,
and
Control
Strategies
for
the
15
Percent
Rateof
Progress
Plans,
EPA­
452/
R­
93­
002,
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC.
March
1993.

!
Guidance
on
Preparing
Enforceable
Regulations
and
Compliance
Programs
for
the
15
Percent
Rate­
of­
Progress
Plans,
EPA­
452/
R­
93­
005,
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC.
June
1993.

The
SIP
for
serious
and
above
ozone
nonattainment
areas
due
by
November
15,
1994
must
also
include
"
a
demonstration
that
the
plan,
as
revised,
will
provide
for
attainment
of
the
ozone
NAAQS
by
the
ACRONYMS
(
continued)

4
applicable
date"
[
section
182(
c)(
2)(
A)].
This
demonstration
must
be
based
on
photochemical
grid
modeling,
such
as
UAM,
or
an
equivalent
analytical
method
as
determined
by
EPA.
This
requirement
also
applies
to
all
multi­
State
moderate
ozone
nonattainment
areas.
Additionally,
those
intrastate
moderate
nonattainment
areas
that
opt
to
use
photochemical
grid
modeling
for
their
attainment
demonstrations
must
also
submit
their
demonstrations
by
November
15,
1994.
It
is
important
to
note
that
the
underlying
requirement
of
the
SIP
is
that
nonattainment
areas
attain
the
NAAQS
by
their
attainment
date.
That
is,
achievement
of
the
3
percent
per
year
VOC
emission
reduction
requirement
may
not
provide
all
of
an
area's
mandated
emission
reductions.

Section
182(
c)(
2)(
B)(
ii)
permits
less
than
a
3
percent
per
year
VOC
emission
reduction
averaged
over
each
consecutive
3­
year
period
for
serious
and
severe
ozone
nonattainment
areas
if
the
State
demonstrates
that
the
plan
includes
all
measures
that,
given
technological
achievability,
can
feasibly
be
implemented
in
the
given
area.
Additionally,
the
State
must
demonstrate
that
its
plan
includes
measures
that
are
achieved
in
practice
by
sources
in
the
same
source
category
in
nonattainment
areas
of
the
next
higher
classification.
The
3
percent
requirement
cannot
be
waived
in
areas
classified
as
extreme.
The
Act
also
provides
for
crediting
of
VOC
emission
reductions
achieved
in
the
1990­
1996
period
to
the
post­
1996
rate­
of­
progress
plan,
if
they
are
in
excess
of
the
15
percent
VOC
reductions
(
net
of
growth)
required
between
1990
and
1996
[
section
182(
c)(
2)(
B)(
ii)],
and
substitution
of
NOx
emission
reductions
(
net
of
growth)
occurring
in
the
post­
1990
period
for
the
post­
1996
VOC
emission
reduction
requirements
[
section
182(
c)(
2)(
C)].

Demonstrating
achievement
of
the
15
percent
VOC
emission
reductions
by
November
15,
1996,
and
then
subsequently
demonstrating
achievement
of
the
3
percent
per
year
VOC
emission
reductions
averaged
over
each
consecutive
3­
year
period
from
November
15,
1996
until
the
attainment
date,
are
termed
milestone
demonstrations.
Achievement
of
the
milestones
must
be
demonstrated
within
90
days
of
the
milestone
date
(
e.
g.,
the
9
percent
reduction
required
by
November
15,
1999
must
be
demonstrated
by
February
13,
2000).
Moderate
areas
are
not
required
to
submit
such
a
demonstration.
Serious
and
above
nonattainment
areas
will
not
be
required
to
demonstrate
achievement
of
the
milestone
if
the
milestone
date
and
attainment
date
are
the
same,
and
the
standard
has
been
attained.
The
EPA
will
instead
determine
whether
the
nonattainment
area
has
attained
the
ozone
NAAQS
based
on
the
nonattainment
area's
air
quality
data
for
the
previous
3
years.
However,
to
comply
with
the
rate­
of­
progress
requirements,
nonattainment
areas
are
required
to
develop
a
plan
for
milestone
emission
reductions
(
i.
e.,
a
post­
1996
rateof
progress
plan)
up
through
their
attainment
date.

The
EPA
expects
to
promulgate
in
late
1994
a
milestone
compliance
demonstration
rule
that
will
address
this
requirement.
The
rule
will
also
address
summary
data
needs,
detailed
reporting
requirements,
and
the
consequences
of
submitting
an
inadequate
demonstration
(
in
terms
of
documentation)
as
well
as
consequences
of
failure
to
demonstrate
the
15
percent
and
3
percent
per
year
emission
reduction
requirements.

1.1
Purpose
This
document
provides
guidance
on
the
procedures
that
States
should
follow
in
calculating
target
levels
of
emissions,
projecting
emission
inventories
and
creditable
emission
reductions,
and
developing
and
presenting
control
measures
which
serious
and
above
ozone
nonattainment
areas
must
include
in
their
post­
1996
rate­
of­
progress
plans.
Fully­
adopted
post­
1996
rate­
of­
progress
plans
are
due
to
EPA
by
November
15,
1994.

The
post­
1996
rate­
of­
progress
plan
must
account
for
the
effects
of
emissions
growth
projected
to
occur
in
a
nonattainment
area.
This
document
provides
information
and
references
on
acceptable
data
sources
and
procedures
for
projecting
emissions
using
growth
factors.
ACRONYMS
(
continued)

5
Attainment
demonstration
requirements
are
described
for
those
nonattainment
areas
that
are
required
or
choose
to
use
photochemical
grid
modeling.
This
section
also
discusses
special
air
quality
situations
involving
attainment
demonstrations.

Unlike
the
15
percent
rate­
of­
progress
plan,
NOx
reductions,
net
of
growth,
can
be
substituted
for
the
required
post­
1996
VOC
reductions.
This
document
explains
how
to
calculate
the
amount
of
NOx
reductions
available
to
an
ozone
nonattainment
area
to
meet
the
post­
1996
rate­
of­
progress
requirements
and
the
role
of
NOx
reductions
in
attainment
demonstrations
based
on
photochemical
grid
modeling
.

A
key
component
of
the
post­
1996
rate­
of­
progress
plan
is
the
control
measures
that
the
States
adopt
and
implement
to
reduce
VOC
and
or
NOx
emissions
to
meet
the
3
percent
per
year
reduction
requirements.
States
are
referenced
to
further
documentation
of
stationary
and
mobile
source
control
measures
and
economic
incentive
programs
(
EIP's)
if
they
wish
to
employ
a
particular
control
measure
toward
the
post­
1996
rate­
of­
progress
plan
and/
or
attainment
demonstration.
The
regulatory
concepts
of
long­
term
measures
(
for
serious
and
above
nonattainment
areas)
and
new
technologies
(
for
extreme
nonattainment
areas)
are
discussed
as
ways
for
States
to
obtain
additional
time
to
plan
for
and
adopt
certain
control
measures
that
require
complex
analyses
or
other
time
consuming
activities.
The
purpose
of
this
discussion
is
to
guide
States
as
to
how
EPA
intends
to
administer
these
two
concepts
in
the
context
of
the
rate­
of­
progress
plan
requirements.

The
Act
requires
that
States
with
ozone
nonattainment
areas
include
contingency
measures
in
their
SIP's
[
sections
172(
c)(
9)
and
182(
c)(
9)].
The
contingency
measures
are
the
additional
controls
to
be
implemented
in
the
event
of
a
milestone
or
attainment
failure.
This
document
discusses
contingency
measures
to
provide
States
with
guidance
on
how
to
comply
with
the
contingency
measure
requirements
for
serious
and
above
ozone
nonattainment
areas.

A
final
purpose
of
this
document
is
to
provide
the
States
with
a
suggested
format
for
their
post­
1996
rate­
of­
progress
control
strategy
submittals
and
describe
the
documentation
requirements
for
attainment
demonstrations
based
on
photochemical
grid
modeling.
ACRONYMS
(
continued)

6
ACRONYMS
(
continued)

7
2.0
CALCULATION
OF
POST­
1996
TARGET
LEVELS
To
determine
their
control
strategies
for
achieving
the
post­
1996
VOC
emission
reductions,
States
will
need
to
calculate
the
target
level
of
emissions
for
each
milestone
and
attainment
year.
This
section
explains
the
procedures
for
calculating
the
target
level
of
emissions
for
each
milestone
and
attainment
date
to
which
serious
and
above
ozone
nonattainment
areas
are
subject.

Emissions
and
emission
reductions
for
the
post­
1996
plan
are
calculated
on
a
typical
weekday
basis
for
the
"
peak"
3­
month
ozone
period
(
generally
June
through
August).
States
will
need
to
document
how
they
calculated
the
targets
for
each
of
their
applicable
milestone
and
attainment
dates.
The
documentation
will
need
to
show
the
3
percent
per
year
emission
reduction
levels
averaged
over
each
period
between
consecutive
milestone
dates
and
the
target
level
of
emissions
for
each
milestone.

Table
1
presents
the
post­
1996
milestone
and
attainment
dates
for
serious
and
above
ozone
nonattainment
areas.

TABLE
1.
SERIOUS
AND
ABOVE
OZONE
NONATTAINMENT
AREA
POST­
1996
MILESTONE
AND
ATTAINMENT
DATES
Nonattainment
Classification
Milestone
Date(
s)
Primary
NAAQS
Attainment
Date
Serious
Nov.
15,
1999
Nov.
15,
1999
Severe1
Nov.
15,
1999,
2002,
&
2005
Nov.
15,
2005
Severe2
Nov.
15,
1999,
2002,
2005,
&
2007
Nov.
15,
2007
Extreme
Nov.
15,
1999,
2002,
2005,
2008,
&
2010
Nov.
15,
2010
1
With
an
ozone
design
value
of
less
than
0.190
ppm.
2
With
a
1986­
1988
ozone
design
value
of
0.190
ppm
up
to,
but
not
including,
0.280
ppm.

If
an
area's
attainment
demonstration
shows
that
the
area
will
attain
before
the
statutory
attainment
date,
the
post­
1996
rate­
of­
progress
plan
is
only
required
to
extend
to
the
demonstrated
attainment
date.

2.1
Calculation
of
Post­
1996
Target
Level(
s)
of
Emissions
The
target
level(
s)
of
emissions
represents
the
maximum
amount
of
emissions
that
a
nonattainment
area
can
emit
for
a
given
target
year
while
complying
with
the
post­
1996
rate­
of­
progress
plan
requirements.
Figure
1
outlines
the
general
approach
to
calculating
the
target
level
of
ACRONYMS
(
continued)
8
a
=
1990y
FMVCP/
RVP
EMISSIONS
*
­
Does
not
include
preenactment
banked
emissions
reduction
credits
FINAL
BASE
YEAR
(
1990)
INVENTORY*
1990
RATE­
OF­
PROGRESS
BASE
YEAR
INVENTORY
1990
ADJUSTED
BASE
YEAR
INVENTORY
CALCULATED
RELATIVE
TO
YEAR
x
(
BEx)
EMISSIONS
REDUCTION
REQUIRED
BETWEEN
YEAR
y
AND
YEAR
x
(
BGr)

SUBTRACT
BIOGENICS,

EMISSIONS
OUTSIDE
NONATTAINMENT
AREA
SUBTRACT
FMVCP/
RVP
REDUCTIONS
BETWEEN
1990
AND
YEAR
x
multiply
by
r
FLEET
TURNOVER
CORRECTION
(
FTx)
=
a
­
b
x
=
current
target
year
y
=
previous
target
year
TARGET
LEVEL
FOR
YEAR
y
(
TLy)

TARGET
LEVEL
FOR
YEAR
x
(
TLx)
=

(
TLy
­
BGr
­
FTx)
b
=
1990x
FMVCP/
RVP
EMISSIONS
B
A
C
D
E
Figu
re
1.
Flowchart
for
generic
post­
1996
rate­
of­
progress
VOC
target
level
calculation
ACRONYMS
(
c
9
VOC
emissions.
Two
eq
post­
1996
target
levels.
Th
Target
level
=
(
previous
milestone's
progress
requirement)
­
(
fleet
turnove
or
TLx
=
TLy
­
BGr
­
FTx
where:

x
=
Current
milestone
or
attainment
year
y
Year
of
previous
milestone
TLx
=
Target
level
of
emissions
for
year
x
(
in
pounds
(
lb)/
day)

TLy
=
Target
level
of
emissions
for
year
y
(
in
lb/
day)

BGr
=
Emission
reduction
requirement
for
year
x
(
in
lb/
day)

FTx
=
Fleet
turnover
correction
term
x
day).

This
equation
can
be
used
to
calculate
the
target
level
of
emissions
for
each
target
level
for
each
milestone
year
(
TLx
)
is
calculated
by
subtracting
the
3
pe
progress
emission
reduction
(
BGr
)
and
the
fleet
turnover
correction
term
(
FTx
)
f
year
(
TLy
).
The
specific
steps
needed
to
calculate
target
are
discussed
below.

There
are
six
major
steps
in
calculating
a
post­
1996
target
level
of
emissions.
The
first
are
needed
to
calculate
the
3
percent
per
year
rate­
of­
progress
emission
reductions.
Steps
developing
the
1990
base
year
inventory
and
the
1990
rate­
of­
progress
inventory,
were
requ
been
submitted
by
States
in
15
percent
rate­
of­
progress
plan.
The
EPA
document
entitled
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Prog
Plans
(
see
reference
1),
describes
these
two
inventories
in
more
detail.

Step
1:
Develop
the
1990
base
year
inventory
The
total
1990
base
year
emissions
from
the
four
emission
source
types
(
point,
area,
mobile,
and
biogenic)
are
compiled.
It
should
be
noted
that
the
base
year
inventory
used
for
the
post­
1996
rate­
of­

progress
plan
must
be
consistent
with
the
base
year
inventory
used
for
attainment
demonstration
purposes.

Any
changes
that
were
made
to
the
inventory
between
submittal
of
the
15
percent
rate­
of­
progress
plan
and
the
post­
1996
rate­
of
progress
plan
should
be
reflected.

Step
2:
Develop
the
1990
rate­
of­
progress
base
year
inventory
Biogenic
source
emissions
and
other
emissions
from
sources
located
outside
the
nonattainment
area,
but
included
in
step
1,
are
removed
from
1990
base
year
inventory.

Step
3:
Calculate
the
1990
adjusted
base
year
inventory
The
Act
specifies
the
emissions
"
baseline"
from
which
each
emission
reduction
milestone
is
calculated.
Section
182(
c)(
2)(
B)
states
that
the
reductions
must
be
achieved
"
from
the
baseline
emissions
described
in
subsection
(
b)(
1)(
B)."
This
baseline
value
is
termed
the
1990
adjusted
base
year
inventory.

Section
182(
b)(
1)(
B)
defines
baseline
emissions
(
for
purposes
of
calculating
each
milestone
VOC/
NOx
emission
reduction)
as
"
the
total
amount
of
actual
VOC
or
NOx
emissions
from
all
anthropogenic
sources
in
the
area
during
the
calendar
year
of
enactment."
This
section
excludes
from
the
baseline
the
emissions
ACRONYMS
(
c
10
that
would
be
eliminated
January
1,
1990,
and
Reid
v
(
55
FR
23666,
June
11,
1990)

nonattainment
areas
during
the
p
The
1990
adjusted
base
year
inventor
attainment
date
because
the
emission
re
turnover.
Thus,
a
severe
ozone
nonattainm
would
need
to
calculate
the
1990
adjusted
ba
adjustment
that
must
be
made
to
the
inventory
including
emissions
from
vehicle
refueling,
using
separate
mobile
source
emission
factor
for
each
appl
multiplied
by
1990
vehicle
miles
traveled
(
VMT),
or
g
mobile
source
emissions
that
must
be
subtracted
from
the
calculate
the
1990
adjusted
base
year
inventory
for
each
mil
calculated
as
follows:

FMVCP/
RVP
Reductions
Between
1990
and
Current
Target
Year
(
x)
Subtract
Adjusted
1990
mobile
source
emissions
=
(
1990
VMT)(
MOBILE5a
emission
from
Actual
1990
mobile
source
emissions
=
(
1990
VMT)(
MOBILE5a
emission
factors
from
A)
MOBILE5a
run
from
the
1990
base
year
inventory.
Emission
factors
from
this
run
will
b
with
actual
1990
VMT
to
calculate
actual
1990
emissions.
If
the
refueling
emission
factor
is
calculated
in
MOBILE5a
as
a
grams
per
gallon
of
gasoline
factor,
that
factor
should
be
multiplied
by
actual
1990
gasoline
throughput
and
those
emissions
should
be
included
in
the
1990
actual
mobile
source
emissions.

B)
MOBILE5a
run
as
in
the
1990
base
year
inventory,
except
that
year
"
x"
will
be
used
as
the
evaluation
year
(
this
will
change
the
vehicle
mix
to
account
for
fleet
turnover).
Emission
factors
from
this
run
will
be
used
with
actual
1990
VMT
to
calculate
adjusted
1990
emissions
relative
to
year
"
x."
If
the
refueling
emission
factor
is
calculated
in
MOBILE5a
as
a
grams
per
gallon
of
gasoline
factor,
that
factor
should
be
multiplied
by
actual
1990
gasoline
throughput
and
those
emissions
should
be
included
in
the
adjusted
mobile
source
emissions.

A
detailed
description
of
the
procedure
for
calculating
the
1990
adjusted
base
year
inventory
is
provided
in
an
EPA
document
entitled
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plans.
(
See
reference
1.)
The
adjusted
base
year
inventory
can
be
calculated
the
same
way
for
each
post­
1996
milestone/
attainment
year.
After
this
inventory
has
been
calculated
for
each
applicable
milestone
and
attainment
year,
the
next
step
is
to
determine
the
required
creditable
emission
reductions.

Step
4:
Calculate
3
percent
per
year
reductions
In
general,
to
compute
the
required
emission
reductions,
the
number
of
years
between
successive
milestone
dates
(
or
in
some
cases
between
a
milestone
date
and
the
attainment
date)
should
be
0.03.
If
an
area
plans
to
substitute
NOx
for
VOC,
however,
the
percent
reduction
will
have
to
adjusted.

This
is
discussed
in
more
detail
in
section
4
of
this
document.
ACRONYMS
(
c
11
Percentage
reduction
=
r
where:

(
x­
y)
=
Number
of
years
between
c
For
example,
an
extreme
area
would
m
reduction
between
2008
and
2010.
Next,

inventory
calculated
relative
the
current
m
reduction.

BGr
=
BEx
*
r
where:

BGr
=
Emission
reduction
requirement
for
milestone
or
attain
BEx
=
1990
adjusted
base
year
inventory
calculated
relative
to
year
x
r
=
Percent
reduction
needed
to
meet
the
rate­
of­
progress
requiremen
The
fifth
step
is
to
calculate
the
fleet
turnover
correction
term.

Step
5:
Calculate
fleet
turnover
correction
term
In
the
absence
of
any
new
requirements
of
the
Act,
there
would
still
be
some
decrease
vehicle
emission
factors
for
many
years
as
a
result
of
fleet
turnover,
the
gradual
replacem
control
vehicles
with
newer
vehicles
with
controls.
The
Act
does
not
allow
States
to
take
reductions
for
rate­
of­
progress
purposes.
During
the
calculation
of
the
1996
milestone
target,
these
"
FMVCP
reductions"
(
along
non­
creditable
RVP
reductions)
that
would
occu
1990
and
1996
were
subtracted
from
the
1990
rate­
of­
progress
base
year
inventory
to
calculate
the
adjusted
base
year
inventory.
This
1990
adjusted
base
year
inventory
was
then
used
to
calculate
the
required
reductions
and
the
1996
target.

Because
nonattainment
areas
are
required
to
meet
their
1996
targets,
the
calculation
of
the
1999
target
must
be
based,
in
part,
on
the
1996
target.
Likewise,
the
calculation
of
each
subsequent
target
will
depend,
in
part,
on
the
level
of
the
previous
In
the
previous
step
(
step
4),
the
adjusted
base
year
inventory
was
multiplied
by
the
total
percent
required
reduction
in
order
to
determine
the
reductions
required
in
target
year.
This
emission
reduction
requirement
must
then
be
subtracted
from
the
emission
target
in
the
previous
milestone
year
to
calculate
the
new
milestone
target.
However,
one
additional
correction
term,
the
fleet
turnover
correction,
is
needed
properly
calculate
the
target.

The
fleet
turnover
correction
is
needed
to
account
for
the
mobile
source
emission
reductions
that
would
have
occurred
under
the
preenactment
FMVCP
and
RVP
requirements
(
under
55
FR
23666),

between
consecutive
milestone
years.
For
example,
assume
that
a
nonattainment
area
has
met
the
milestone
target
for
1996.
The
further
creditable
reduction
required
to
meet
the
post­
1996
rate­
of­
progress
requirements
was
calculated
step
4.
However,
between
1996
and
1999,
there
will
be
some
additional
reductions
in
emissions
due
to
fleet
turnover
of
older
vehicles
that
are
not
creditable.
These
reductions
must
also
be
subtracted
from
the
1996
target
to
determine
the
1999
target.
These
additional,
non­

creditable,
reductions
are
referred
to
here
as
the
fleet
turnover
correction
term.

The
calculation
of
the
fleet
turnover
correction
term
is
simple
and
does
not
require
any
additional
MOBILE
runs
beyond
what
has
been
required
in
previous
steps
of
this
calculation.
For
the
general
case,

the
fleet
turnover
correction
term
is
calculated
as
follows:
ACRONYMS
(
c
12
Fleet
Turnover
Correctio
where:

x
=
current
target
year
y
=
previous
target
year
1990y
FMVCP/
RVP
=
Adjusted
1990
mo
year
1990x
FMVCP/
RVP
=
Adjusted
1990
mobile
year.

The
adjusted
1990
mobile
source
emissions
for
the
c
step
3
as
1990
VMT
times
MOBILE5a
emission
factor
Act
measures
disabled
and
RVP
set
to
the
Phase
2
limit
r
mobile
source
emissions
for
the
previous
target
year
were
c
level
calculation
for
the
previous
year.
For
example,
the
fleet
equal
to
the
adjusted
mobile
source
emissions
calculated
for
the
the
adjusted
mobile
source
emissions
calculated
in
step
3
of
the
cur
Step
6:
Calculate
post­
1996
target
level
of
emissions
To
calculate
each
target
level
of
emissions,
the
required
emission
reductions
and
the
fleet
turnover
correction
term
from
step
5
are
subtracted
from
the
previo
For
the
purposes
of
calculating
the
1999
target,
it
may
be
necessary
to
recalculate
base
year
inventory
was
significantly
revised
after
submittal
of
the
15
percent
rate­
of
Target
level
=
(
previous
milestone's
target
level)
­
(
reductions
required
to
meet
the
rate­
of­

progress
requirement,
calculated
in
step
4)
­
(
fleet
turnover
correction
term,

calculated
in
step
5).

This
target
represents
the
level
of
emissions
that
must
be
achieved
in
order
for
a
nonattainment
area
to
demonstrate
that
the
rate­
of­
progress
requirement
will
be
met.

2.2
Example
Calculation
of
Post­
1996
Target
Level(
s)

This
section
presents
a
hypothetical
example
that
calculates
a
target
level
for
1999.
This
example
builds
on
the
example
contained
in
the
EPA
document
entitled
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plans
(
see
reference
1),
and
assumes
that
no
changes
have
been
made
to
base
year
emission
inventory.
Figure
2
outlines
the
procedure
to
follow
to
calculate
the
target.

Calculation
of
1999
Target
Level
of
Emissions
Step
1:
Develop
1990
base
year
VOC
emission
inventory
(
lb/
day)

Point
Sources
1,000
Area
Sources
2,500
Mobile
3,500
Biogenic
Sources
+
5,000
ACRONYMS
(
c
13
Total
12,000
Step
2:
Develop
1990
rate­
of­
prog
1990
base
year
inventory
=

12,000
Point
Sources
(
outside
nonattainment
area)

­
200
Area
Sources
(
outside
nonattainment
area)

­
500
Mobile
(
outside
nonattainment
area)

­
500
Biogenic
Sources
­
5,000
Total
5,800
ACRONYMS
(
continued)
14
a
=
1990y
FMVCP/
RVP
REDUCTIONS
(
600
lb/
day)

*
­
Does
not
include
preenactment
banked
emissions
reduction
credits
FINAL
BASE
YEAR
(
1990)
INVENTORY*

12,000
lb/
day
1990
RATE­
OF­
PROGRESS
BASE
YEAR
INVENTORY
5,800
lb/
day
1990
ADJUSTED
BASE
YEAR
INVENTORY
CALCULATED
RELATIVE
TO
YEAR
x
(
BEx)

5,200
lb/
day
EMISSIONS
REDUCTION
REQUIRED
BETWEEN
YEAR
y
AND
YEAR
x
(
BGr)

468
lb/
day
SUBTRACT
BIOGENICS
(
5,000
lb/
day),

EMISSIONS
OUTSIDE
NONATTAINMENT
AREA
(
1,200
lb/
day)
SUBTRACT
FMVCP/
RVP
REDUCTIONS
BETWEEN
1990
AND
YEAR
x
(
600
lb/
day)
multiply
by
r=
0.09
FLEET
TURNOVER
CORRECTION
(
FTx)
=
a
­
b
100
lb/
day
x
=
current
target
year
=
1999
y
=
previous
target
year
=
1996
TARGET
LEVEL
FOR
YEAR
y
(
TLy)

4,000
lb/
day
TARGET
LEVEL
FOR
YEAR
x
(
TLx)
=

(
TLy
­
BGr
­
FTx)

3,432
lb/
day
b
=
1990x
FMVCP/
RVP
REDUCTIONS
(
500
lb/
day)

B
A
C
D
E
Figu
re
2.
Flowchart
of
hypothetical
example
1999
rate­
of­
progress
VOC
target
level
calculation
ACRONYMS
(
c
15
Step
3:
Calculate
the
19
The
only
adjustment
that
mus
source
emission
reductions
using
emission
factor
for
1999,
multiplyi
1990
actual
mobile
source
emissions
For
this
example,
the
State
calculates
th
turnover
up
through
1999
and
the
RVP
lim
following
is
the
adjusted
base
year
inventory
1990
Adjusted
Base
Year
Inventory
(
lb/
day)

=
1990
rate­
of­
progress
inventory
­
(
FMVCP
and
RVP
1999)

=
5,800
lb/
day
­
600
lb/
day
=
5,200
lb/
day.

Step
4:
Calculate
3
percent
per
year
reductions
The
1990
adjusted
base
year
inventory
calculated
relative
to
the
1999
m
by
0.09
to
calculate
the
required
emission
reductions
from
1996
to
1999.

9
percent
reduction
=
5,200
x
0.09
=
468
lb/
day
Step
5:
Calculate
fleet
turnover
correction
term
The
fleet
turnover
correction
term
is
the
difference
between
the
FMVCP/
RVP
emission
re
calculated
in
step
3
and
the
previous
milestone
year's
FMVCP/
RVP
emission
reductions.
In
hypothetical
example,
the
FMVCP/
RVP
reductions
calculated
relative
to
1996
are
assumed
to
lb/
day.
Therefore,
the
fleet
turnover
correction
term
for
1999
is
100
lb/
day
(
i.
e.,
600
lb/
day
­
500
Step
6:
Calculate
target
level
of
emissions
for
1999
To
calculate
the
target
level
of
emissions
for
1999,
the
required
emission
reductions
calculated
in
step
4
and
the
fleet
turnover
correction
term
are
subtracted
from
the
1996
milestone
target
level.
The
1996
target
level
was
calculated
to
be
4,000
lb/
day
in
the
EPA
document
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plan
(
see
reference
1).

Target
level
=
(
1996
milestone
target
level)
­
(
reductions
calculated
in
step
4)
­
(
fleet
turnover
correction
term
calculated
in
step
5)

=
1996
target
level
­
(
5,200
lb/
day
*
0.09)
­
(
600
lb/
day
­
500
lb/
day)

=
4,000
lb/
day
­
468
lb/
day
­
100
lb/
day
=
3,432
lb/
day
This
area's
plan
must
therefore
demonstrate
that
the
projected
emissions
for
1999,
reflecting
the
adopted
control
strategy,
will
be
less
than
or
equal
to
3,432
lb/
day.
ACRONYMS
(
c
16
2.3
Conditions
Permittin
A
State
may
be
permitted
to
a
demonstrates
that
the
plan
includ
implemented
in
the
given
area.
In
are
achieved
in
practice
by
sources
in
classification.
The
measures
necessary
basis.
Any
determination
to
lessen
the
3
p
demonstration,
and
revised
to
include
any
ne
category
in
any
State,
allowing
a
reasonable
tim
It
is
important
to
note
that
the
waiver
provision
does
areas.
Furthermore,
States
must
understand
that
the
att
requirement
of
the
Act.
Although
less
than
a
3
percent
V
purposes
of
satisfying
the
rate­
of­
progress
requirements,
a
S
in
its
SIP
to
attain
the
ozone
NAAQS
by
its
applicable
attainm
demonstrate
attainment
to
obtain
a
waiver,
the
waiver
does
not
re
obligation
to
demonstrate
attainment.
ACRONYMS
(
c
17
3.0
ATTAINMENT
DE
This
section
of
the
document
nonattainment
areas
that
are
requ
air
quality
situations
involving
atta
3.1
Modeling
Requirements
for
Attain
The
UAM
is
described
in
the
EPA
document
(
see
reference
2).
In
addition,
the
General
Prea
attainment
demonstration
implications
of
using
U
Procedures
to
follow
in
applying
photochemical
grid
demonstration
are
described
in
Guideline
for
Regulatory
reference
3).
Chapters
1
and
2
of
the
Guideline
identify
est
protocol
identifies
Technical
Committees
whose
responsibiliti
and
specific
meteorological
episodes
to
be
modeled
(
note
that
the
than
the
nonattainment
area);
(
2)
develop
compatible
inputs
for
the
specific
quality,
wind
fields,
and
emissions;
(
3)
apply
the
model
an
performance
is
acceptable;
(
4)
develop
projected
emissions
for
the
requi
the
model
using
projected
emissions
see
whether
predicted
ozone
concen
(
ppb)
or
less
throughout
the
modeling
domain
(
i.
e.,
the
model
demonstrates
a
not
demonstrate
attainment,
additional
control
measures
must
be
developed
and
evaluated.
This
is
an
iterative
process
until
attainment
is
demonstrated.

It
should
be
noted
that
both
biogenic
and
anthropogenic
emissions
are
included
in
the
m
Also,
for
consistency
the
projected
emissions
should
reflect
the
control
measures
used
to
o
percent
VOC
emission
reduction
required
between
1990
and
1996,
additional
annual
3
perce
thereafter,
and
where
necessary,
additional
control
measures
to
achieve
attainment.

The
required
modeling
protocol
should
also
identify
a
Policy
Oversight
Committee.
This
group
provides
input
on
the
strategies
to
be
tested
and
is
responsible
for
reaching
consensus
on
the
strategy
t
implement
in
the
1994
SIP
revision.

The
modeling
demonstration
supporting
the
1994
SIP
revision
should
be
submitted
to
the
appropriate
U.
S.
EPA
Regional
Office(
s)
by
November
15,
1994.
The
Regional
Office
will
then
evaluate
the
plan
and
prepare
a
technical
support
document
(
TSD)
assessing
the
adequacy
of
the
documentation
of
the
analysis.
The
following
should
be
provided
by
States
to
support
preparation
of
this
document:
(
1)
the
modeling
protocol
with
episode
dates
and
the
modeling
domain
defined;
(
2)
the
emissions
input
preparation
for
the
base
case
inventory,
emission
projections
and
emission
estimates
derived
for
the
attainment
demonstration
to
be
implemented
in
the
1994
SIP
revision;
(
3)
air
quality
and
meteorological
input
preparations
for
the
selected
episodes;
(
4)
diagnostic
analyses
used
to
troubleshoot
model
performance,

including
the
rationale
for
revisions
to
inputs
which
resulted;
(
5)
results
of
the
model
performance
evaluation;
(
6)
air
quality
predictions
corresponding
with
the
attainment
demonstration
to
be
implemented
in
the
SIP;
and
(
7)
procedures
which
the
EPA
or
other
interested
parties
can
follow
to
gain
access
to
all
relevant
input
and
output
files
so
as
to
replicate
results,
if
desired.
Each
of
these
seven
required
components
is
described
in
greater
detail
in
Guidance
on
Urban
Airshed
Model
(
UAM)
Reporting
Requirements
for
Attainment
Demonstration
(
see
reference
4).
Regional
Offices
are
encouraging
States
to
submit
these
items
as
soon
as
possible
to
receive
early
feedback.

States
should
plan
to
achieve
emission
reductions
as
early
in
the
process
as
possible,
since
section
181(
b)(
2)
requires
EPA
to
make
a
determination
as
to
whether
an
area
has
attained
the
ozone
NAAQS
within
6
months
following
an
applicable
attainment
date.
This
requirement
dictates
the
use
of
the
most
ACRONYMS
(
c
18
recent
3
years
of
air
qual
NAAQS.
For
example,
for
quality
data
for
1997
­
1999
to
the
General
Preamble
(
57
FR
13
3.2
Special
Air
Quality
Situations
Areas
Requiring
Emission
Reductions
in
A
There
may
be
circumstances
under
which
a
non
of
the
NAAQS
will
require
additional
VOC
and/
o
reduction
mandated
in
section
182(
c)(
2)(
B)(
i).
The
areas
must
achieve
attainment
of
the
NAAQS
by
their
percent
per
year
reduction
requirement.

Multi­
State
Nonattainment
Areas
Section
182(
j)
defines
and
establishes
requirements
for
ozone
nona
in
more
than
one
State
called
multi­
State
nonattainment
areas.
Beyon
the
different
nonattainment
area
classifications,
section
182(
j)(
1)
require
coordinate
the
revisions
and
implementation
of
the
SIP's
applicable
to
the
n
photochemical
grid
modeling
(
or
another
method
determined
by
EPA)
as
par
process.

A
joint
modeling
demonstration
must
be
submitted
by
all
States
in
the
modeling
dom
will
not
to
approve
any
attainment
demonstration
unless
all
of
the
affected
States
have
This
demonstration
should
identify
the
strategy
be
used
for
attainment
and
should
iden
reduction
necessary
each
State.
The
demonstration
should
reference
the
applicable
model
and
include
a
schedule
for
developing
control
measures
and
the
attainment
demonstration
for
t
multi­
State
area.
Where
all
of
the
States
are
in
the
same
Region,
only
one
modeling
demonstratio
submitted.
If
the
States
are
in
different
Regions,
the
demonstration
should
be
sent
to
each
Region.

addition,
each
State
must
individually
submit
regulations
to
achieve
the
necessary
reductions
for
that
S
Section
182(
j)(
2)
recognizes
that
if
any
State
in
which
there
is
located
a
portion
of
a
multi­
State
nonattainment
area
fails
to
provide
a
demonstration
of
attainment
within
the
required
period,
the
State
may
petition
EPA
to
make
a
finding
that
the
State(
s)
would
have
been
able
to
make
such
a
demonstration
"
but
for
the
failure
of
one
or
more
other
States,
which
other
portions
of
the
area
are
located,
to
commit
to
the
implementation
of
all
measures
required
by
section
182...."
If
the
EPA
Administrator
makes
a
finding
that
this
situation
is
occurring,
the
sanctions
of
section
179
shall
not
apply
to
the
petitioning
State(
s).
Section
III.
A.
9
of
the
General
Preamble
provides
the
primary
guidance
for
these
nonattainment
area
SIP's
(
57
FR
13529).

States
Included
in
More
than
One
Modeling
Domain
There
are
a
number
of
cases
where
a
State
is
included
in
more
than
one
modeling
domain.
In
this
situation,
the
State
must
ensure
that
control
measures
are
applied
consistently
in
all
model
applications.

International
Border
Areas
Section
179B
applies
to
nonattainment
areas
that
are
affected
by
emissions
emanating
from
outside
the
United
States.
This
section
provides
relief
for
nonattainment
areas
along
international
borders
analogous
to
what
is
provided
to
States
within
multi­
State
nonattainment
areas
by
section
182(
j):
EPA
shall
approve
the
SIP
if
it
meets
all
the
requirements
in
the
Act
and
if
the
State
establishes
that
the
ACRONYMS
(
c
19
implementation
of
the
pl
emissions
emanating
from
the
Act)
section
V.
C
of
th
areas.

Areas
with
Differing
Required
Attain
There
are
several
situations
in
which
areas
with
earlier
attainment
dates.
In
some
cases,

nonattainment
areas
of
varying
severity.
A
com
nonattainment
area(
s)
(
required
attainment
date
of
nonattainment
area.
In
other
cases,
an
area
may
be
i
Each
ozone
nonattainment
area
is
still
subject
to
the
appl
attainment
under
section
182(
b)(
1)(
A)
and
(
c)(
2).
For
exam
transport
region
is
still
subject
to
the
6­
year
deadlin
However,
this
area
is
(
at
least,
presumptively)
being
affected
by
possibly
affecting
other
areas,
as
well.
If
the
areas
that
are
affecting
have
a
higher
classification,
that
moderate
area
may
be
receiving
trans
exceeding
the
NAAQS
well
after
its
own
mandatory
attainment
date.

In
general,
two
situations
exist
in
which
an
area
might
be
subject
to
additiona
requirements
related
to
the
demonstration
of
attainment.
In
the
first,
an
area
mi
levels
of
transport
that
even
if
it
reduced
its
own
emissions
dramatically
(
e.
g.,
tota
emissions),
the
incoming
ozone
and
precursors
would
be
high
enough
to
continue
to
standard
beyond
the
applicable
attainment
date.
In
the
second
situation,
the
area
might
additional
reductions
(
beyond
those
required
under
section
182),
but
even
where
those
add
could
be
achieved
to
demonstrate
attainment,
the
question
arises
whether
it
is
equitable
to
re
reductions
or
to
allow
more
time
for
the
reductions
in
the
"
upwind"
area
to
take
place.
The
Ac
express
relief
for
these
situations.
Thus,
where
the
demonstration
of
attainment
is
complicated
by
between
two
areas
of
different
classifications,
the
State
is
still
responsible
for
developing
and
subm
demonstrations
which
show
that
the
standard
will
be
attained
by
the
applicable
date.
In
other
words,
t
State
must
provide
for
sufficient
emission
reductions
on
a
schedule
that
will
ensure
attainment
by
the
deadline
prescribed
in
the
Act
(
e.
g.,
by
1996
for
moderate
areas).
The
area
does
have
the
option
of
requesting
to
be
reclassified
the
next
higher
classification.

When
such
areas
develop
the
demonstration
of
attainment
due
in
November
1994,
they
should
provide
a
comprehensive
assessment
of
the
impacts
of
all
control
measures
being
implemented
in
both
the
local
and
upwind
areas.
States
should
clearly
show
the
extent
to
which
the
downwind
area
is
dependent
on
upwind
strategies
while
fully
meeting
its
own
requirements
associated
with
its
classification.
The
EPA
will
continue
working
with
States
facing
this
situation
to
resolve
these
issues.

Exceedances
Monitored
within
a
Modeling
Domain
Due
Primarily
to
Emissions
in
Another
Domain
Generally,
episodes
in
which
emissions
included
within
a
modeling
domain
do
not
play
a
significant
role
in
contributing
to
monitored
exceedances
within
that
domain
should
not
be
modeled
in
an
attainment
demonstration.
Guidance
on
"
overwhelming
transport"
contained
in
sections
3.1
and
3.2
of
Criteria
for
Assessing
the
Role
of
Transported
Ozone/
Precursors
in
Ozone
Nonattainment
Areas
(
see
reference
5)
may
be
used
to
identify
unsuitable
episodes.
Alternatively,
diagnostic
tests
described
in
section
4.3
of
Guideline
for
Regulatory
Application
of
the
Urban
Airshed
Model
(
see
reference
3)
may
be
used
to
identify
unsuitable
episodes.
Note
that
this
guidance
is
not
saying
that
episodes
in
which
transported
ozone/
precursors
play
an
important
role
are
unsuitable
for
modeling.
This
guidance
is
singling
out
cases
in
ACRONYMS
(
c
20
which
drastic
changes
in
in
predicted
daily
maximum
An
episode
which
is
otherwise
c
Regulatory
Application
of
the
Urb
this
case,
evidence
should
be
presente
the
upwind
domain(
s)
identified
as
likel
has
been
reached
that
the
upwind
area(
s)
w
pattern
to
ensure
that
predicted
concentration
downwind
grid
are
at
or
below
120
ppb.
Sectio
means
for
facilitating
such
interdomain
coordinati
evidence
of
a
good
faith
effort
to
implement
resultin
ACRONYMS
(
c
21
4.0
NO
X
EMISSION
RED
Section
182(
c)(
2)(
C)
of
the
A
occur
after
1990
to
meet
post­
19
describes
the
procedure
for
calcula
emission
reduction
requirements.

4.1
Substitution
of
NO
x
Emission
Reduct
Section
182(
c)(
2)(
C)
states
that
actual
NOx
emi
used
to
meet
post­
1996
emission
reduction
requir
outlined
in
EPA's
December
15,
1993
NOx
Substitut
progress
requirement
is
that
the
sum
of
all
creditable
V
percent
per
year
averaged
over
each
applicable
milestone
from
the
VOC
rate­
of­
progress
inventory
and
the
percent
N
of­
progress
inventory.
In
addition,
overall
VOC
and
NOx
modeled
attainment
demonstration.
In
other
words,
the
NOx
emi
of­
progress
plan
cannot
be
greater
than
the
cumulative
reductions
demonstration.
This
is
necessary
because
there
may
be
a
number
of
d
be
used
to
show
attainment,
the
rate­
of­
progress
plan
must
be
consis
the
State
as
its
attainment
strategy.
It
should
be
noted,
however,
that
if
a
S
corrections
to
demonstration,
it
can
also
make
corresponding
c
plan.

Although
the
NOx
supplement
to
the
General
Preamble
does
not
specify
that
photoch
modeling
must
used
for
this
demonstration,
this
modeling
is
generally
necessary
to
d
to
which
NOx
can
be
substituted
for
VOC.
In
addition,
use
of
photochemical
grid
modeli
substitution
demonstrations
would
be
consistent
with
requirements
that
photochemical
mode
justify
exempting
the
area
from
NOx
controls
or
lessening
the
amount
of
NOx
controls
required
If
a
State
plans
to
substitute
NOx
reductions
for
VOC
reductions,
separate
target
level(
s)
of
emissions
will
have
to
be
calculated
for
both
NOx
and
VOC.
Figure
3
provides
an
overview
of
the
procedure
for
calculating
the
VOC
target
level
and
Figures
4
and
4a
provides
an
overview
of
the
procedu
for
calculating
the
NOx
target
level.
The
target
levels
are
calculated
as
discussed
in
section
2
of
this
document
with
some
exceptions.

4.2
Calculation
of
Post­
1996
NO
x
and
VOC
Target
Levels
of
Emissions
The
target
levels
of
emissions
represent
the
maximum
amount
of
emissions
allowed
in
each
post­

1996
milestone
year
given
the
3
percent
per
year
rate­
of­
progress
requirement.
The
target
level(
s)
of
VOC
emissions
can
be
calculated
using
the
following
equation:
ACRONYMS
(
continued)
22
a
=
1990y
FMVCP/
RVP
EMISSIONS
*
­
Does
not
include
preenactment
banked
emissions
reduction
credits
FINAL
BASE
YEAR
(
1990)
INVENTORY*
1990
RATE­
OF­
PROGRESS
BASE
YEAR
INVENTORY
1990
ADJUSTED
BASE
YEAR
INVENTORY
CALCULATED
RELATIVE
TO
YEAR
x
(
BEx)
EMISSIONS
REDUCTION
REQUIRED
BETWEEN
YEAR
y
AND
YEAR
x
(
BGr)

SUBTRACT
BIOGENICS,

EMISSIONS
OUTSIDE
NONATTAINMENT
AREA
SUBTRACT
FMVCP/
RVP
REDUCTIONS
BETWEEN
1990
AND
YEAR
x
multiply
by
rVOC
FLEET
TURNOVER
CORRECTION
(
FTx)
=
a
­
b
x
=
current
target
year
y
=
previous
target
year
TARGET
LEVEL
FOR
YEAR
y
(
TLy)

TARGET
LEVEL
FOR
YEAR
x
(
TLx)
=

(
TLy
­
BGr
­
FTx)
b
=
1990x
FMVCP/
RVP
EMISSIONS
B
A
C
D
E
Figu
re
3.
Flow
char
t
for
generic
post­
1996
rate­
of­
progress
VOC
calculations
(
with
NOx
substitution)
ACRONYMS
(
continued)
23
*
­
Does
not
include
preenactment
banked
emissions
reduction
credits
FINAL
BASE
YEAR
(
1990)
INVENTORY*
1990
RATE­
OF­
PROGRESS
BASE
YEAR
INVENTORY
1990
ADJUSTED
BASE
YEAR
INVENTORY
CALCULATED
RELATIVE
TO
YEAR
x
(
BEx)
EMISSIONS
REDUCTION
REQUIRED
BETWEEN
1990
AND
YEAR
x
(
BGr)

SUBTRACT
EMISSIONS
OUTSIDE
NONATTAINMENT
AREA
SUBTRACT
FMVCP/
RVP
REDUCTIONS
BETWEEN
1990
AND
YEAR
x
multiply
by
n
TOTAL
EXPECTED
REDUCTIONS
BY
YEAR
x
x
=
current
target
year
TARGET
LEVEL
FOR
YEAR
x
(
A
­
C)
B
A
C
D
ADD
REDUCTIONS
FROM:

FMVCP/
RVP
Figu
re
4.
Flow
chart
for
rate­
of­
progress
NOx
calculation
for
1999
ACRONYMS
(
continued)
24
a
=
1990y
FMVCP/
RVP
EMISSIONS
*
­
Does
not
include
preenactment
banked
emissions
reduction
credits
FINAL
BASE
YEAR
(
1990)
INVENTORY*
1990
RATE­
OF­
PROGRESS
BASE
YEAR
INVENTORY
1990
ADJUSTED
BASE
YEAR
INVENTORY
CALCULATED
RELATIVE
TO
YEAR
x
(
BEx)
EMISSIONS
REDUCTION
REQUIRED
BETWEEN
YEAR
y
AND
YEAR
x
(
BGr)

SUBTRACT
BIOGENICS,

EMISSIONS
OUTSIDE
NONATTAINMENT
AREA
SUBTRACT
FMVCP/
RVP
REDUCTIONS
BETWEEN
1990
AND
YEAR
x
multiply
by
n
FLEET
TURNOVER
CORRECTION
(
FTx)
=
a
­
b
x
=
current
target
year
y
=
previous
target
year
TARGET
LEVEL
FOR
YEAR
y
(
TLy)

TARGET
LEVEL
FOR
YEAR
x
(
TLx)
=

(
TLy
­
BGr
­
FTx)
b
=
1990x
FMVCP/
RVP
EMISSIONS
B
A
C
D
E
Figu
re
4a.
Flow
char
t
for
generic
post­
1999
rate­
of­
progress
NOx
calculations
ACRONYMS
(
c
25
TLx,
VOC
=
TLy,
VOC
­
BGr,
VO
where:

x
=
Current
milestone
or
attainme
y
=
Year
of
previous
milestone
TLx,
VOC
=
Target
level
of
VOC
emissio
TLy,
VOC
=
Target
level
of
VOC
emissions
BGr,
VOC
=
Emission
reduction
requirement
f
FTx,
VOC
=
Fleet
turnover
correction
term
for
V
The
target
level
of
NOx
emissions
for
1999
can
be
TL1999
=
1990
ROP
­
BGr,
NOx
­
FMVCP/
RVP1999
where:

1990
ROP
=
1990
rate­
of­
progress
NOx
inventory
BGr,
NOx
=
NOx
emission
reduction
requirement
for
1999
(
in
lb/
day
FMVCP/
RVP1999
=
FMVCP/
RVP
NOx
reductions
calculated
relative
The
target
level
of
NOx
emissions
for
years
after
1999
can
be
calculated
TLx,
NOx
=
TLy,
NOx
­
BGr,
NOx
­
FTx,
NOx
where:

x
=
Current
milestone
or
attainment
y
=
Year
of
previous
milestone
TLx,
NOx
=
Target
level
of
NOx
emissions
for
year
x
(

TLy,
NOx
=
Target
level
of
NOx
emissions
for
year
y
(
in
lb/
day)

BGr,
NOx
=
Emission
reduction
requirement
for
NOx
for
year
x
(
in
lb/
day)

FTx,
NOx
=
Fleet
turnover
correction
term
for
NOx
for
year
x
(
in
lb/
day).

These
equations
can
be
used
to
calculate
the
target
level
of
emissions
for
each
post­
1996
milestone
ye
The
reason
that
the
1999
NOx
target
is
calculated
differently
is
that
there
is
not
a
1996
NOx
target
that
ca
be
used
to
calculate
the
1999
target.
Once
the
1999
NOx
target
is
established
it
can
be
used
to
calculate
the
next
target.
The
specific
steps
needed
to
calculate
each
target
are
discussed
below.

There
are
six
major
steps
in
calculating
a
post­
1996
target
level
of
emissions.
The
first
four
steps
are
needed
to
calculate
the
3
percent
per
year
rate­
of­
progress
emission
reduction.
The
first
three
of
these
steps,
developing
the
1990
base
year
inventory,
developing
the
1990
rate­
of­
progress
inventory,
and
developing
the
adjusted
base
year
inventory
were
discussed
in
detail
for
VOC
in
section
2
of
this
document.

The
following
describes
how
the
post­
1996
target
levels
should
be
calculated
when
NOx
substitution
for
VOC
will
occur.

Step
1:
Develop
the
1990
base
year
inventory
The
total
1990
base
year
VOC
and
NOx
emissions
from
the
five
major
emission
source
categories
(
point,
area,
on­
road
and
off­
road
mobile,
and
biogenic)
are
compiled.
It
should
be
noted
that
the
base
year
inventory
used
for
the
post­
1996
rate­
of­
progress
plan
must
be
consistent
with
the
base
year
inventory
used
for
attainment
demonstration
purposes.
Any
changes
that
were
made
to
the
inventory
between
submittal
of
the
15
percent
rate­
of­
progress
plan
and
the
post­
1996
rate­
of
progress
plan
should
be
reflected.
ACRONYMS
(
c
1
Most
emission
inventories
do
not
contain
biogenic
NOx
emissions.
If
these
emissions
are
included,

they
must
be
subtracted
in
developing
the
rate­
of­
progress
inventory.

26
Step
2:
Develop
the
1990
Biogenic
source
emissions
area,
but
included
in
step
1,
ar
Step
3:
Calculate
the
1990
adjust
The
Act
specifies
the
emissions
"
baselin
calculated.
Section
182(
c)(
2)(
B)
states
tha
described
in
subsection
(
b)(
1)(
B)."
This
bas
The
baseline
excludes
the
VOC
and
NOx
emiss
promulgated
by
January
1,
1990,
and
by
RVP
reg
(
55
FR
23666,
June
11,
1990),
which
require
maxim
nonattainment
areas
during
the
peak
ozone
season.

The
1990
adjusted
base
year
inventories
must
be
calculated
attainment
year
because
the
emission
reductions
associated
wi
turnover.
The
only
adjustment
that
must
be
made
to
the
inventor
source
emissions,
including
VOC
emissions
from
vehicle
refueling
made
by
calculating
a
separate
mobile
source
emission
factor
for
each
emission
factors
are
then
multiplied
by
1990
VMT,
or
gallons
of
gasolin
the
mobile
source
emissions
that
must
be
subtracted
from
the
1990
rate­
of­

calculate
the
1990
adjusted
base
year
inventories
for
each
milestone/
attainme
calculated
as
follows:

FMVCP/
RVP
Reductions
Between
1990
and
Current
Target
Year
(
x):
Subtract
Adjusted
1990
mobile
source
emissions
=
(
1990
VMT)(
MOBILE5a
emission
factors
from
B)

from
Actual
1990
mobile
source
emissions
=
(
1990
VMT)(
MOBILE5a
emission
factors
from
A)

A)
MOBILE5a
run
from
the
1990
base
year
inventory.
Emission
factors
from
this
run
will
be
used
with
actual
1990
VMT
to
calculate
actual
1990
emissions.
If
the
refueling
emission
factor
for
VOC
is
calculated
in
MOBILE5a
as
a
grams
per
gallon
of
gasoline
factor,
that
factor
should
be
multiplied
by
actual
1990
gasoline
throughput
and
those
emissions
should
be
included
in
the
1990
actual
mobile
source
emissions.

B)
MOBILE5a
run
as
in
the
base
year
inventory,
except
that
year
"
x"
will
be
used
as
the
evaluation
year
(
this
will
change
the
vehicle
mix
to
account
for
fleet
turnover).
Emission
factors
from
this
run
will
be
used
with
actual
1990
VMT
to
calculate
adjusted
1990
emissions
relative
to
year
"
x."
If
the
refueling
emission
factor
for
VOC
is
calculated
in
MOBILE5a
as
a
grams
per
gallon
of
gasoline
factor,
that
factor
should
be
multiplied
by
actual
1990
gasoline
throughput
and
those
emissions
should
be
included
in
the
1990
adjusted
mobile
source
emissions.

A
detailed
description
of
procedure
for
calculating
the
1990
adjusted
base
year
inventory
is
provided
in
an
EPA
document
entitled
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
ACRONYMS
(
c
27
for
the
15
Percent
Rate­
o
calculated
the
same
way
fo
Step
4:
Calculate
required
cred
The
percent
reduction
required
is
calc
VOC
reduction
and
the
percent
NOx
red
VOC
reduction
is
equal
to
the
number
of
y
minus
the
percent
(
n)
that
will
be
achieved
th
Percentage
VOC
reduction
=
rVOC
=
[
0.03
*
(
x­
y)]

where:

rVOC
=
percent
VOC
reduction
needed
to
meet
the
rate­
of­

Number
of
years
between
current
(
x)
and
previous
(
y)
targe
n
=
percent
of
reductions
that
will
be
achieved
through
NOx
re
Next,
these
percentage
figures
are
multiplied
by
the
adjusted
base
relative
to
the
current
milestone/
attainment
date
to
yield
the
required
BGr,
VOC
=
BEx,
VOC
*
rVOC
and
BGr,
NOx
=
BEx,
NOx
*
n
where:

BGr,
VOC
=
VOC
emission
reduction
requirement
for
milestone
date
(
in
lb/
day)

BGr,
NOx
=
NOx
emission
reduction
requirement
for
milestone
date
(
in
lb/
day)

BEx,
VOC
=
1990
adjusted
base
year
VOC
inventory
calculated
relative
to
year
x
BEx,
NOx
=
1990
adjusted
base
year
NOx
inventory
calculated
relative
to
year
x
rVOC
=
percent
VOC
reduction
needed
to
meet
the
rate­
of­
progress
requirement.

n
=
percent
NOx
reduction
needed
to
meet
the
rate­
of­
progress
requirement.

Step
5:
Calculate
fleet
turnover
correction
term
For
VOC
and
for
the
post­
1999
NOx
target,
the
fleet
turnover
correction
is
needed
to
account
for
the
mobile
source
emission
reductions
that
would
have
occurred
under
the
preenactment
FMVCP
and
RVP
requirements
(
under
55
FR
23666),
between
consecutive
milestone
years.
The
calculation
of
this
correction
for
VOC
is
described
in
detail
in
section
2
of
this
document.
This
term
is
calculated
the
same
way
for
NOx
.

For
the
1999
NOx
target,
different
adjustments
need
to
be
made
because
there
is
not
a
target
from
a
previous
year
that
accounts
for
reductions
between
1990
and
1996.
Adjustments
must
be
made
to
account
for
emission
reductions
associated
with
FMVCP
and
RVP
because
these
emission
reductions
are
not
creditable
for
substitution.
Unlike
the
adjustments
made
to
the
VOC
rate­
of­
progress
base
year
emission
inventory,
the
effects
of
reasonably
available
control
technology
(
RACT)
fix­
ups
do
not
need
to
be
included
in
the
adjustment
calculation
because
they
do
not
affect
NOx
emissions.
Due
to
the
lack
of
a
NOx
performance
standard
for
I/
M
programs
prior
to
enactment
of
the
1990
amendments
to
the
Act
and
the
negligible
impact
of
corrections
to
I/
M
programs
on
NOx
emissions,
the
NOx
target
does
not
need
to
be
adjusted
to
account
for
I/
M
program
corrections.

The
NOx
adjustment
for
FMVCP
for
the
1999
target
is
calculated
as
follows:
ACRONYMS
(
c
28
FMVCP/
RVP
NOx
Reductions
Between
1990
and
1999:
Subtract
Adjusted
1990
mobile
source
from
Actual
1990
mobile
source
emissions
=
(
199
A)
MOBILE5a
run
from
the
1990
base
year
inven
with
actual
1990
VMT
to
calculate
actual
1990
emis
B)
MOBILE5a
run
as
in
the
1990
base
year
inventory,
exc
year
(
this
will
change
the
vehicle
mix
to
account
for
fleet
tu
will
be
used
with
actual
VMT
to
calculate
adjusted
1990
Step
6:
Calculate
post­
1996
target
levels
of
emissions
To
calculate
the
target
level
VOC
emissions,
the
required
emission
redu
and
the
fleet
turnover
correction
term
from
step
5
are
subtracted
from
the
p
For
the
purposes
of
calculating
the
1999
VOC
target,
it
may
be
necessary
to
r
the
base
year
inventory
was
significantly
revised
after
submittal
of
the
15
percen
VOC
target
level
=
(
previous
milestone's
target
level)
­
(
reductions
required
to
meet
th
of­
progress
requirement,
calculated
in
step
4)
­
(
fleet
turnover
correction
term,
calculated
in
step
5).

The
1999
NOx
target
is
calculated
by
adding
the
required
emission
reductions
calculated
in
step
to
the
expected
reductions
from
the
FMVCP
and
RVP
and
subtracting
this
total
from
the
1990
N
of­
progress
inventory.

NOx
target
level
=
(
1990
NOx
rate­
of­
progress
inventory)
­
[(
reductions
required
to
meet
the
rate­
of­
progress
requirement,
calculated
in
step
4)
+
(
reductions
from
1990
to
target
year
from
FMVCP
and
RVP,
calculated
in
step
5)].

To
calculate
the
post­
1999
target
level
NOx
emissions,
required
emission
reductions
calculated
in
step
4
and
the
fleet
turnover
correction
term
from
step
5
are
subtracted
from
the
previous
milestone's
target
level.

Post­
1999
NOx
target
level
=
(
previous
milestone's
target
level)
­
(
reductions
required
to
meet
the
rate­
of­
progress
requirement,
calculated
in
step
4)
­
(
fleet
turnover
correction
term,
calculated
in
step
5).

These
targets
represent
the
level
of
VOC
and
NOx
emissions
that
must
be
achieved
in
order
for
a
nonattainment
area
to
demonstrate
that
the
rate­
of­
progress
requirement
will
be
met.
Once
these
targets
have
been
calculated,
the
overall
emission
levels
should
be
compared
to
the
area's
attainment
demonstration
to
ensure
that
the
rate­
of­
progress
plan
is
consistent
with
the
strategy
selected
for
the
area's
attainment
demonstration.
ACRONYMS
(
c
29
4.3
Creditability
of
Pre­
ACRONYMS
(
c
30
Under
section
182(
c)(
2)(

the
1990­
1996
period
to
the
reductions
(
net
of
growth)
req
provides
for
substitution
of
NOx
reductions.
As
discussed
in
the
"
G
Amendments
of
1990,"
(
57
FR
13517
such
as
NOx
reductions
achieved
as
a
re
NOx
RACT
provisions
may
allow
30­
day
subject
to
such
rules
to
a
typical
summer
day
4.4
Example
Calculation
of
Post­
1996
VOC
and
This
section
presents
a
hypothetical
example
that
descr
show
the
calculation
procedure
for
this
example
for
VOC
Calculation
of
1999
Target
Levels
of
Emissions
Developing
the
1990
base
year
inventory
and
the
1990
rate­
of­
prog
steps
in
calculating
the
post­
1996
target
levels.
These
inventories,
wh
to
have
been
submitted
by
the
States
in
their
15
percent
rate­
of­
progress
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Ta
Progress
Plans
(
see
reference
1)
describes
these
two
inventories
in
more
detai
Step
1:
Develop
the
1990
base
year
inventory
(
lb/
day)

VOC
NOx
Point
Sources
1,000
5,000
Area
Sources
2,500
2,000
Mobile
3,500
+
3,000
Biogenic
Sources
+
5,000
­­
Total
12,000
10,000
Step
2:
Develop
1990
rate­
of­
progress
base
year
inventory
(
lb/
day)

VOC
NOx
1990
base
year
inventory
12,000
10,000
Point
Sources
­
200
­
1,000
Area
Sources
­
500
­
500
Mobile
­
500
­
700
Biogenic
Sources
­
5,000
Total
5,800
7,800
ACRONYMS
(
continued)
31
a
=
1990y
FMVCP/
RVP
REDUCTIONS
(
600
lb/
day)

*
­
Does
not
include
preenactment
banked
emissions
reduction
credits
FINAL
BASE
YEAR
(
1990)
INVENTORY*

12,000
lb/
day
1990
RATE­
OF­
PROGRESS
BASE
YEAR
INVENTORY
5,800
lb/
day
1990
ADJUSTED
BASE
YEAR
INVENTORY
CALCULATED
RELATIVE
TO
1999
(
BEx)

5,200
lb/
day
EMISSIONS
REDUCTION
REQUIRED
BETWEEN
1996
AND
1999
(
BGr)

260
lb/
day
SUBTRACT
BIOGENICS
(
5,000
lb/
day),

EMISSIONS
OUTSIDE
NONATTAINMENT
AREA
(
1,200
lb/
day)
SUBTRACT
FMVCP/
RVP
REDUCTIONS
BETWEEN
1990
AND
1999
(
600
lb/
day)
multiply
by
rVOC=
0.05
FLEET
TURNOVER
CORRECTION
(
FTx)
=
a
­
b
100
lb/
day
x
=
1999
y
=
1996
TARGET
LEVEL
FOR
1996
(
TLy)

4,000
lb/
day
TARGET
LEVEL
FOR
1999
(
TLx)
=

(
TLy
­
BGr
­
FTx)

3,640
lb/
day
b
=
1990x
FMVCP/
RVP
REDUCTIONS
(
500
lb/
day)

B
A
C
D
E
Figu
re
5.
Flowchart
for
hypothetical
example
1999
rate­
of­
progress
VOC
calculations
(
with
NOx
substitution)
ACRONYMS
(
continued)
32
*
­
Does
not
include
preenactment
banked
emissions
reduction
credits
FINAL
BASE
YEAR
(
1990)
INVENTORY*

10,000
lb/
day
1990
RATE­
OF­
PROGRESS
BASE
YEAR
INVENTORY
7,800
lb/
day
1990
ADJUSTED
BASE
YEAR
INVENTORY
CALCULATED
RELATIVE
TO
1999
(
BEx)

7,600
lb/
day
EMISSIONS
REDUCTION
REQUIRED
BETWEEN
1990
AND
1999
(
BGr)

304
lb/
day
SUBTRACT
EMISSIONS
OUTSIDE
NONATTAINMENT
AREA
(
2,200
lb/
day)
SUBTRACT
FMVCP/
RVP
REDUCTIONS
BETWEEN
1990
AND
1999
(
200
lb/
day)
multiply
by
n=
0.04
TOTAL
EXPECTED
REDUCTIONS
BY
1999
504
lb/
day
TARGET
LEVEL
FOR
1999
(
A
­
C)

7,296
lb/
day
B
A
C
D
ADD
REDUCTIONS
FROM:

FMVCP/
RVP
(
200
lb/
day)

Figu
re
6.
Flow
chart
for
hypothetical
example
1999
rate­
of­
progress
NOx
calculations
ACRONYMS
(
c
33
Step
3:
Calculate
the
19
The
only
adjustment
that
mus
source
emission
reductions
using
emission
factor
for
1999,
and
mult
emissions
for
the
1990
adjusted
base
be
a
reduction
of
600
lb/
day
of
VOC
du
the
nonattainment
area
in
55
FR
23666,
an
following
is
the
adjusted
base
year
inventory
1990
adjusted
VOC
base
year
inventory
=
1990
VO
FMVCP/
RVP
reductions
=
5,800
­
600
lb/
day
=
5,200
lb/
day.

1990
adjusted
NOx
base
year
inventory
=
1990
NOx
rate­
of­
prog
FMVCP/
RVP
reductions
=
7,800
lb/
day
­
200
lb/
day
=
7,600
lb/
day.

Step
4:
Calculate
required
creditable
reductions
For
1999,
the
total
percentage
required
reduction
is
9
percent
(
3
percent
per
year
x
3
this
example,
VOC
emission
reductions
will
account
for
5
percent
of
the
reductions
nee
NOx
reductions
will
account
for
the
remaining
4
percent.
This
example
assumes
that
thes
reductions
are
consistent
with
the
area's
attainment
demonstration.
The
required
VOC
and
N
reductions
from
to
1999
are
calculated
as
follows:

Percent
NOx
reduction
=
n
=
4%.

Percent
VOC
reduction
=
rVOC
=
[
0.03
*
(
x­
y)]
­
n
=
[
0.03
*
(
1999­
1996)]
­
0.04
=
0.05
=
5%

Next,
these
percentage
figures
are
multiplied
by
the
adjusted
base
year
inventories
calculated
relative
to
the
current
milestone/
attainment
date
to
yield
the
required
VOC
and
NOx
emission
reductions.

BGr,
VOC
=
BEx,
VOC
*
rVOC
=
5,200
*
0.05
=
260
lb/
day
and
BGr,
NOx
=
BEx,
NOx
*
n
=
7,600
*
0.04
=
304
lb/
day.

Severe
and
extreme
nonattainment
areas
must
also
calculate
the
post­
1996
rate­
of­
progress
emission
reductions
for
each
of
their
milestone/
attainment
dates.

Step
5:
Calculate
fleet
turnover
correction
term
ACRONYMS
(
c
34
As
noted
previously,
this
For
VOC,
the
fleet
turnove
reductions
calculated
in
step
3
hypothetical
example,
the
FMVC
lb/
day
of
VOC.
Therefore,
the
flee
lb/
day
­
500
lb/
day).
The
NOx
correc
example,
the
FMVCP/
RVP
NOx
reducti
Step
6:
Calculate
target
level
of
emissions
To
calculate
the
target
level
of
emissions
for
VOC
calculated
in
step
4
and
the
fleet
turnover
correction
level.
The
1996
target
level
was
calculated
to
be
4,000
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
T
(
see
reference
1).

VOC
target
level
=
(
1996
milestone
target
level)
(
reductions
calc
turnover
correction
term)

=
1996
target
level
­
(
5,200
lb/
day
*
0.05)
­
(
600
lb/
day
­
500
lb/
day)

=
4,000
lb/
day
­
260
lb/
day
­
100
lb/
day
=
3,640
lb/
day.

The
target
for
NOx
is
calculated
by
subtracting
the
sum
of
the
NOx
reduction
required
a
FMVCP/
RVP
reductions
between
1990
and
1999
from
the
1990
rate­
of­
progress
inventor
NOx
target
level
=
(
1990
NOx
rate­
of­
progress
inventory)
­
[(
required
reductions
for
1999
calculated
in
step
4)
+
(
FMVCP/
RVP
reductions)]

=
7,800
lb/
day
­
(
7,600
lb/
day
*
0.04)
­
(
200
lb/
day)

=
7,296
lb/
day.

This
area's
plan
must
therefore
demonstrate
that
the
projected
1999
VOC
inventory
will
be
less
than
or
equal
to
3,640
lb/
day
and
the
projected
1999
NOx
inventory
will
be
less
than
or
equal
to
7,296
lb/
day.
ACRONYMS
(
c
35
5.0
CONTROL
STRAT
States
will
need
to
include
co
demonstrate
how
emissions
will
demonstrate
attainment
of
the
ozon
reductions
by
developing,
adopting,
a
stationary
and
mobile
sources
or
by
doc
future
Federal
regulatory
programs
for
VO
following
two
documents:

!
Guidance
for
Growth
Factors,
Projections,
and
C
of­
Progress
Plans
see
reference
6).

!
Guidance
on
the
Relationship
Between
the
15
Percent
R
Provisions
of
the
Clean
Air
Act
(
see
reference
7).

5.1
Mandatory
Requirements
This
section
identifies
the
specific
measures
required
by
the
Act
for
ea
nonattainment
area.
In
addition,
Table
2
lists
the
SIP
submittal
requirem
nonattainment
areas
in
chronological
order.

Serious
Nonattainment
Area
Requirements
Under
section
182(
c)
of
the
Act,
serious
nonattainment
areas
are
subject
to
the
contro
required
for
moderate
areas
(
i.
e.,
RACT
rule
fix­
ups,
RACT
catch­
ups,
I/
M
program
co
I/
M,
stage
II
vapor
recovery)
as
well
as
the
following
additional
control
measures:

!
Enhanced
I/
M
program.

!
A
major
stationary
source
cut­
off
for
RACT
of
50
tons
per
year
(
tpy)
VOC
or
NOx
.

!
Clean­
fuel
vehicle
program
in
areas
with
a
population
greater
than
or
equal
to
250,000.

!
Emission
offset
ratio
of
1.2:
1.

Emission
reductions
associated
with
stage
II
vapor
recovery,
RACT
catch­
ups,
basic
I/
M,
and
the
first
three
of
the
four
control
measures
listed
above
are
creditable
toward
the
post­
1996
VOC
emission
reduction
requirement
to
the
extent
that
they
occur
between
1990
and
1999;
represent
emission
reductions
that
are
real,
permanent,
and
enforceable;
and
are
not
needed
to
meet
the
15
percent
rate­
of­
progress
requirement.
Due
to
uncertainties
in
projecting
new
source
growth
and
determining
the
level
of
emission
reductions
needed
to
offset
minor
source
growth,
EPA
will
not
allow
States
to
take
credit
in
their
post­
1996
rate­
of­
progress
plan
for
projected
emission
reductions
resulting
emission
offsets.
However,
any
additional,
actual,
permanent,
and
enforceable
emission
reductions
from
an
offset
that
are
not
used
to
offset
minor
source
growth
will
be
creditable
in
the
milestone
compliance
demonstrations
required
for
serious
areas.
TABLE
2.
SIP
SUBMITTAL
REQUIREMENTS
FOR
MODERATE
AND
ABOVE
OZONE
NONATTAINMENT
AREAS
1992
ACRONYMS
(
c
36
Nov.
15
­­­­­­
Moderate
and
above
ozone
nonattainment
areas
must
submit
the
following
items
for
their
15
percent
rate­
ofprogress
plans:

!
Final
1990
base
year
inventory
for
VOC,
NO
x,
and
CO.

!
1990
rate­
of­
progress
base
year
inventory
for
VOC,
NO
x,
and
CO.

!
Initial
1990
adjusted
base
year
inventory
for
VOC.

!
Documentation
of
how
the
15
percent
VOC
reduction
and
1996
target
level
of
emissions
were
calculated.

!
Growth
factors
for
developing
projected
rate­
of­
progress
and
modeling
inventories.

!
Documentation
of
Act
mandated
control
measures
and
associated
control
efficiencies.

­­­­­­
Moderate
and
above
ozone
nonattainment
areas
must
submit:

!
New
source
review
(
NSR)
rules
for
VOC
and
NO
x.
!
VOC
and
NO
x
RACT
rules
(
committal
SIP
acceptable
for
NO
x
for
1993
under
certain
circumstances).

!
Stage
II
vapor
recovery
programs.

!
Requirements
for
emission
statement
program
(
major
sources
of
VOC
and
NO
x).

­­­­­­
Serious
and
above
ozone
nonattainment
areas
must
submit:

!
Enhanced
I/
M
programs
and
begin
implementation
(
committal
SIP
acceptable
for
1993
implementation).

!
Optional
clean
fuel
fleet
substitute
­­­­­­
Severe
and
extreme
ozone
nonattainment
areas
must
submit:

!
Employer
trip
reduction
programs.

!
Measures
for
reducing
VMT.

!
Transportation
control
measures
(
TCM's).

1993
37
Nov.
15
­­­­­­
Moderate
ozone
nonattainment
areas
not
using
the
UAM
must
submit
an
attainment
demonstration.

­­­­­­
Moderate
and
above
ozone
nonattainment
areas
must
submit
their
final
15
percent
rate­
of­
progress
plans
including:

!
Final
1996
projected
emission
inventory
for
VOC,
NO
x
and
CO.

!
Control
measures
that
will
achieve
emission
reductions
needed
to
meet
their
15
percent
VOC
emission
reduction
requirement.

!
Contingency
measures
for
failures
to
meet
their
1996
target
level
of
emissions
or
failure
to
attain
the
ozone
NAAQS.
TABLE
2.
SIP
SUBMITTAL
RE
ABOVE
OZONE
NONATTAINME
In
addition,
the
Federally
implemented
p
required
in
the
nine
nonattainment
areas
w
1987­
1989
period
and
populations
over
250,0
reformulated
gasoline
are
also
creditable
toward
Because
certain
measures
are
expected
to
require
sig
develop,
including
large
amounts
of
coordination
betw
may
have
difficulty
adopting
all
control
measures
in
their
rate­
of­
progress
plan
deadline.
The
EPA
will
allow
States
t
reductions
from
"
long­
term"
measures
in
their
post­
1996
rate­
o
backstop
measures
at
least
equivalent
reductions
have
been
ad
SIP,
and
such
backstop
measures
will
automatically
go
into
effect
i
measures
are
not
ready
in
time
for
their
projected
implementation
date
of
long­
term
control
measures
is
provided
in
section
5.7.

Severe
Nonattainment
Area
Requirements
Under
section
182(
d)
of
the
Act,
severe
nonattainment
areas
are
subject
to
the
control
measures
required
for
serious
areas
(
except
for
emission
offset
requirements)

well
as
the
following
additional
control
measures.

!
Measures
to
offset
VMT
growth.

!
Employer
trip
reduction
program.

!
A
major
stationary
source
cut­
off
for
RACT
of
25
tpy
VOC
or
NOx
.

!
Emission
offset
ratio
of
1.3
to
1
(
or
1.2
to
1
if
the
State's
plan
requires
all
existing
major
sources
in
the
nonattainment
area
to
use
the
best
available
control
technology
for
the
control
of
VOC
emissions).

As
with
serious
nonattainment
areas,
EPA
will
not
allow
States
with
severe
nonattainment
areas
to
take
credit
for
projected
emission
reductions
resulting
from
emission
offsets
in
their
post­
1996
rate­
of­
progress
plans.
However,
any
additional,
actual,
permanent,
and
enforceable
emission
reductions
from
an
offset
that
are
not
used
to
offset
minor
source
growth
will
be
creditable
in
the
milestone
compliance
demonstrations
required
for
severe
areas
(
i.
e.,
in
1999,
2002,
and
for
severe
areas
with
a
1986­
1988
ozone
design
value
of
0.190
ppm
up
to,
but
not
including,
0.280
ppm,
2005).
All
other
post­
1996
emission
reductions
that
are
real,
permanent,
and
enforceable
are
creditable
in
the
post­
1996
rate­
of­

progress
plan.

Extreme
Nonattainment
Area
Requirements
Under
section
182(
e)
of
the
Act,
extreme
ozone
nonattainment
areas
are
subject
to
the
control
measures
required
for
severe
areas
(
except
for
emission
offset
requirements)
as
well
as
the
following
additional
control
measures.
1
EPA
is
currently
considering
the
possibility
of
requiring
the
submittal
of
this
periodic
inventory
by
November
15,
1994.

2
EPA
is
currently
considering
the
possibility
of
requiring
the
submittal
of
this
periodic
inventory
by
November
15,
1997.

3
EPA
is
currently
considering
the
possibility
of
requiring
the
submittal
of
this
periodic
inventory
by
November
15,
2000.

4
EPA
is
currently
considering
the
possibility
of
requiring
the
submittal
of
this
periodic
inventory
by
November
15,
2003.

38
1994
May
15­­­­­­
Seriou
and
all
severe
and
ab
program.
Nov.
15­­­­­­
M
demonstration.

­­­­­­
Serious
and
above
ozone
1996
rate­
of­
progress
plans:

!
1990
adjusted
VOC
base
year
invento
year.

!
Projected
inventory
for
applicable
post­
19
inventory
for
serious
ozone
nonattainment
a
!
Documentation
of
how
the
3
percent
per
year
V
were
calculated
for
each
applicable
milestone
dat
!
Growth
factors
used
in
developing
projected
rate­
o
!
Final
Technical
Support
Documentation
(
TSD)
of
ma
control
efficiencies,
plus
discretionary
controls
needed
f
­­­­­­
Serious
and
above
ozone
nonattainment
areas
and
interst
submit
an
attainment
demonstration
based
on
UAM
modeling,
i
15­­­­­­
Moderate
and
above
ozone
nonattainment
areas
must
subm
NO
x
,
and
CO
emissions
in
1993.
1
1996Nov.
15­­­­­­
Attainment
date
for
m
areas
unless
the
area
has
requested
and
been
granted
an
extension.

­­­­­­
Milestone
date
for
moderate
and
above
ozone
nonattainment
areas
to
VOC
emission
reduction
requirement.
1997Feb.
15­­­­­­
Serious
and
above
ozon
must
submit
a
milestone
compliance
demonstration
showing
compliance
with
th
emission
reduction
requirement.
1998Nov.
15­­­­­­
Moderate
and
above
ozone
nona
must
submit
periodic
inventory
of
VOC,
NO
x
,
and
CO
emissions
in
1996.
2
1999Nov.
15
Attainment
date
for
serious
ozone
nonattainment
areas,
unless
the
area
has
requested
granted
an
extension.

­­­­­­
Milestone
date
for
serious,
severe,
and
extreme
ozone
nonattainment
areas
to
achieve
the
percent
per
year
VOC
emission
reduction
requirement.
2000Feb.
15­­­­­­
Severe
and
extreme
ozo
nonattainment
areas
must
submit
a
milestone
compliance
demonstration
showing
compliance
with
th
3
percent
per
year
VOC
emission
reduction
requirement.
2001Nov.
15­­­­­­
Serious
and
above
ozone
nonattainment
areas
must
submit
periodic
inventory
of
VOC,
NO
x
,
and
CO
emissions
in
1999.
3
2002Nov.
15­­­­­­
Milestone
date
for
severe
and
extreme
ozone
nonattainment
areas
to
achieve
the
3
percent
per
year
VOC
emission
reduction
requirement.
2003Feb.
15­­­­­­
Severe
and
extreme
ozone
nonattainment
areas
must
submit
a
milestone
compliance
demonstration
showing
compliance
with
the
3
percent
per
year
VOC
emission
reduction
requirement.
2004Nov.
15­­­­­­
Severe
and
extreme
ozone
nonattainment
areas
must
submit
periodic
inventory
of
VOC,
NO
x
,
and
CO
emissions
in
2002.
4
2005Nov.
15­­­­­­
Attainment
date
for
severe
ozone
nonattainment
areas
(
except
those
with
a
1986­
1988
design
value
between
0.190
and
0.280
ppm)
unless
the
area
has
requested
and
been
granted
an
extension.
5
EPA
is
currently
considering
the
possibility
of
requiring
the
submittal
of
this
periodic
inventory
by
November
15,
2006.

6
EPA
is
currently
considering
the
possibility
of
requiring
the
submittal
of
this
periodic
inventory
by
November
15,
2009.

39
­­­­­­
Milestone
d
year
VOC
emission
1986­
1988
design
val
submit
a
milestone
com
emission
reduction
requir
1988
design
value
between
0
!
Milestone
date.

!
Attainment
date
unless
the
area
­­­­­­
Severe
and
extreme
ozone
nonat
and
CO
emissions
in
2005.
5
2008Nov.
15­­

achieve
the
3
percent
per
year
VOC
emissi
nonattainment
areas
must
submit
a
milestone
3
percent
per
year
VOC
emission
reduction
re
nonattainment
areas:

!
Milestone
date.

!
Attainment
date
unless
the
area
has
requested
and
be
!
Submit
periodic
inventory
for
VOC,
NO
x
,
and
CO
emiss
40
MSA's
Farm
Agricultural
services,
fo
Mining
Construction
Manufacturing
Nondurable
goods
manufacturing
Durable
goods
manufacturing
Transportation
and
public
utilities
Wholesale
trade
Retail
trade
Finance,
insurance,
and
real
estate
Services
Government
and
government
enterprises
States
Farm
Agricultural
services,
forestry,
fisheries,
and
other
Agricultural
services,
forestry,
and
fisheries
Other
Mining
Coal
mining
Oil
and
gas
extraction
Metal
mining
Nonmetallic
minerals,
except
fuels
Construction
Manufacturing
Nondurable
goods
manufacturing
Food
and
kindred
products
Tobacco
manufacturers
Textile
mill
products
Apparel
and
other
finished
textile
products
Paper
allied
products
Printing
and
publishing
Chemical
and
allied
products
Petroleum
and
coal
products
Rubber
and
miscellaneous
plastic
products
Leather
and
leather
products
41
TABLE
3.
BEA
(
MSA's)
AND
STA
States
Manufacturing
Durable
goods
manufacturing
Lumber
and
wood
products
(
except
furniture
and
fixtures)
Furniture
and
fixtures
Stone,
clay,
and
glass
products
Primary
metal
industries
Fabricated
metal
products
Machinery,
except
electrical
Electric
and
electronic
equipment
Transportation
equipment,
except
motor
vehicles
Motor
vehicles
and
equipment
Instruments
and
related
products
Miscellaneous
manufacturing
Transportation
and
public
utilities
Railroad
transportation
Trucking
and
warehousing
Local,
suburban,
and
highway
passenger
transportation
Air
transportation
Pipeline
transportation
Transportation
services
Water
transportation
Communication
Electric,
gas,
and
sanitary
services
Wholesale
trade
Retail
trade
Finance,
insurance,
and
real
estate
Banking
Other
credit
and
securities
agencies
Insurance
Real
estate
and
combination
offices
Services
Hotels
and
other
lodging
places
Personal,
business,
and
miscellaneous
repair
services
Automotive
repair,
services,
and
garages
Amusement
and
recreation
services
Motion
pictures
Private
households
Health
services
Private
education
services
Nonprofit
organizations
Miscellaneous
professional
services
Government
and
government
enterprises
Federal,
civilian
Federal,
military
State
and
local
In
addition,
the
REMI
models
are
updated
yearly,
which
allows
the
forecasts
to
be
based
on
recent
information
on
the
economic
structure
and
activity
of
the
U.
S.
and
its
regional
economies.

The
EPA
is
not
preferring
or
requiring
the
use
of
E­
GAS.
States
are
encouraged
to
incorporate
the
most
accurate
growth
factors
available
into
their
projected
inventories.
E­
GAS
is
another
tool
that
can
be
used
in
this
process.
Documentation
of
the
system
was
released
in
April
1993.
(
See
references
8,
9.)
Copies
of
the
model
software
can
be
obtained
from
the
Global
Emissions
and
Control
Division
of
AEERL.

EPA's
Emissions
Preprocessor
System
(
EPS)
42
While
the
BE
EPS
is
a
tool
that
c
emissions.
If
a
State
These
projections
can
b
modeling
required
for
the
inventory
which
correspond
meteorological
conditions)
mu
temporally,
and
chemically
as
U
data,
by
chemical
species,
for
each
Act
include
typical
peak
ozone
day,
c
for
1990.
The
EPS
serves
to
develop
ho
by
grid
cell
from
county
emissions;
nitrog
NO
x
inventories
and
speciated
hydrocarbon
e
to
develop
these
inventories
for
1990
or,
using
population,
VMT,
and
industrial
sector
activity,

developed
in
a
similar
fashion
using
backcasts
of
th
Based
on
the
population,
VMT,
industrial
activi
speciated,
hourly
emission
inventory
for
a
future
episode
f
expected
growth
in
activity,
but
will
not
account
for
changes
changes,
or
other
factors
which
would
change
the
amount
em
These
changes
can
be
identified
by
the
user
and
input
to
EPS
to
r
scenarios
can
be
developed
to
examine
potential
or
expected
reducti
SCC's
or
more
general
source
categories
(
e.
g.,
fuel
combustion,
degrea
5.4
Relationship
Between
the
Post­
1996
Rate­
of­
Progress
Plans
and
Other
P
Reference
7
summarizes
the
regulatory
programs
required
by
the
Act
for
contr
and
NO
x
emissions.
This
guidance
document
also
provides
guidelines
on
the
types
reductions
that
can
be
credited
towards
meeting
the
emission
reduction
requiremen
progress
plans.
The
criteria
for
determining
creditable
emission
reductions
for
15
emission
reduction
requirement
are
also
applicable
for
determining
the
creditability
of
e
reductions
toward
the
post­
1996
rate­
of­
progress
plan
requirements
so
long
as
emission
red
were
not
credited
towards
meeting
the
15
percent
VOC
emission
reduction
requirement.
Stat
local
agencies
should
review
the
information
in
Reference
7
for
determining
the
creditability
of
emission
reductions
in
their
post­
1996
rate­
of­
progress
plans.

Multiple
Projection
System
(
MPS)

The
MPS
is
designed
to
facilitate
the
projection
of
future
emissions
of
ozone
precursors,

specifically
CO,
VOCs,
and
NO
x
,
in
any
given
geographic
area.
The
MPS
gives
state/
local
air
agencies
a
computer
system
capable
of
performing
"
what
if
scenario
analysis"
and
reporting
the
final
results
(
i.
e.,
their
rate­
of­
progress
inventory)
to
EPA.

The
system
is
capable
of
projecting
emissions
out
to
the
year
2008
at
intervals
of
3
years.
In
addition
to
projecting
emissions,
the
system
can
make
projections
in
the
form
of
percent
reduction
relative
to
base
year
emissions.
The
system
is
designed
to
accept
input
data
from
either
the
AIRS
Facility
Subsystem
(
AFS)
or
the
Area
and
Mobile
Source
Subsystem
(
AMS).
Output
from
system
is
in
the
form
of
tables
or
graphs,
which
can
be
directed
to
the
computer
screen
or
to
a
printer.

Tabular
results
can
also
be
output
to
an
ASCII
file,
allowing
user
to
subsequently
import
the
reported
information
into
other
software
for
further
analysis
(
either
numeric
or
graphic).
Data
contained
in
the
output
file
can
also
be
exported
to
Lotus
123,
dBaseIII,
Excel.
As
indicated
above,
the
principal
output
types
are
batch
transactions
in
AIRS
FS
and
AMS
format.
43
As
was
stated
ea
of
CO,
VOC,
and
basic
capabilities:

:
import
emission
data
for
data
for
1990
and
later
year
:
import
1990
activity
level
data,

for
on­
road
mobile
sources;

:
accept
user­
specified
criteria
for
selecti
:
allow
editing
of
imported
control
efficiency
prior
to
projection
of
future
emissions;

:
project
future
emissions
for
the
selected
records
ba
:
export
projected
emission
data
as
DBaseIII,
Lotus,
and
:
generate
tabular
reports
of
projected
emissions
out
to
the
ye
:
generate
graphs
depicting
projected
emissions
out
to
the
year
20
:
generate
batch
transaction
files
of
projected
emission
data
for
import
Necessary
input
from
the
user
to
the
MPS
may
be
apparent
from
this
list.

provide
files
containing
the
1990
emission
data
and
the
control
efficiency,
RE
growth
factor
data
for
future
years.
The
projected
growth
factor
file
is
generat
5.5
Economic
Incentive
Programs
(
EIP)

Section
182(
g)(
4)(
B)
of
the
Act
requires
EPA
to
promulgate
rules
for
EIP's.
A
State
with
extreme
ozone
nonattainment
area
must
submit
an
EIP
when
it
fails
to
submit
a
milestone
demonstration
or
to
meet
an
applicable
rate­
of­
progress
milestone.
Such
programs
are
also
id
as
an
explicit
option
upon
such
failures
in
serious
and
severe
ozone
nonattainment
areas.

Additionally,
the
Act
explicitly
allows
the
use
of
EIP's
in
the
general
SIP
requirements
[
section
110(
a)(
2)],
provisions
for
nonattainment
area
SIP's
[
section
172(
c)(
6)],
and
in
the
system
of
regulations
for
controlling
emissions
from
consumer
or
commercial
products
[
section
183(
e)(
4)].

On
February
23,
1993,
EPA
proposed
a
rule
for
implementing
EIP's
(
58
FR
11110).
The
proposed
EIP
rule
serves
as
interim
guidance
for
both
mandated
(
statutory)
and
discretionary
EIP's
and
addresses
some
of
the
general
issues
associated
with
the
design
and
implementation
of
EIP's.

Reference
7
presents
EPA's
interim
guidance
on
the
relationship
between
the
15
percent
rate­
of­

progress
plans
and
EIP's.
Because
the
discussion
provided
in
reference
7
is
also
relevant
to
the
post­

1996
plan,
States
should
review
the
guidance
provided
in
that
document.

5.6
Contingency
Measures
The
Act
requires
that
States
with
ozone
nonattainment
areas
classified
as
moderate
and
above
include
contingency
measures
in
their
SIP's
[
sections
172(
c)(
9)
and
182(
c)(
9)].
The
contingency
measures
are
the
additional
controls
to
be
implemented
in
the
event
of
a
milestone
or
attainment
failure.
Section
172(
c)(
9)
of
the
Act
specifies
the
general
requirements
for
nonattainment
area
SIP's
to
contain
contingency
measures
that
will
take
effect
without
further
action
by
the
State
or
EPA
if
an
area
either
fails
to
make
reasonable
further
progress
or
fails
to
attain
the
NAAQS
by
the
applicable
attainment
date.
Section
182(
c)(
9)
requires
SIP
contingency
measures
for
failure
of
serious
and
above
areas
to
meet
milestones.
Plans
to
meet
the
1996
milestone
date
are
required
as
part
of
the
15
44
percent
rate­
of­
p
information
on
the
which
is
also
applica
All
contingency
measures
implemented
unless
and
un
NAAQS.
EPA
recognizes
that
implemented
immediately
so
the
novel
concept.
The
SIP
should
clea
of
the
measures,
and
an
indication
th
State
or
EPA
(
e.
g.,
a
public
hearing
discusses
milestone
and
attainment
fai
development
or
implementation
of
contingen
below.

If
a
moderate
or
above
nonattainment
area
receives
attainment
date,
the
contingency
measures
will
not
be
attain
the
new
attainment
date.
If
a
milestone
complian
nonattainment
area
and
the
area
fails
to
meet
the
mileston
required
to
be
implemented
even
if
the
nonattainment
area
w
extension.

For
the
post­
1996
rate­
of­
progress
plan,
some
areas
will
be
able
to
m
measures
requirement
by
referencing
the
contingency
measures
identi
progress
plan.
The
policy
for
States
to
include
NO
x
contingency
measure
progress
plan
that
was
due
November
15,
1993
is
outlined
in
"
Guidance
on
15
Percent
Rate­
of­
Progress
Plans,"
Memorandum
from
Michael
H.
Shapiro
Administrator
for
Air
and
Radiation
to
the
Regional
Division
Directors,
Augus
Contingency
measures
for
the
post­
1996
rate­
of­
progress
plan
must
not
be
inconsi
area's
attainment
demonstration.
If
a
serious
or
above
area
fails
to
meet
the
15
perc
and
uses
their
contingency
measures
or
a
portion
thereof,
then
the
State
can
backfill
th
with
all
VOC,
NO
x
,
or
a
combination
of
VOC
and
NO
x
measures
based
upon
the
modeling
that
area.
EPA
finds
this
acceptable
due
to
the
fact
that
NO
x
substitution
for
the
3
percent
p
VOC
reduction
requirement
is
permitted
for
under
the
Act.

Additionally,
areas
that
have
implemented
control
measures
from
their
overall
SIP
control
strategy
as
a
contingency
measure
or
that
have
implemented
any
of
their
contingency
measures
listed
in
their
15
percent
rate­
of­
progress
plan
must
develop
new
measures
to
backfill
the
contingency
plan
and/
or
the
control
strategy.
Within
1
year
of
the
triggering
a
contingency
requiring
the
early
implementation
of
control
measures,
the
State
must
submit
a
SIP
revision
containing
whatever
additional
provisions
are
needed
to
backfill
the
SIP
to
remedy
any
eventual
shortfall
that
may
occur
as
the
result
of
the
early
use
of
the
control
measures.
The
EPA
expects
any
control
measures
that
are
implemented
early
as
part
of
a
contingency
plan
will
remain
in
place
(
be
superseded
by
replacement
control
measures)
until
the
next
milestone.
At
the
next
milestone,
the
State
can
demonstrate
whether
or
not
these
control
measures
are
needed
to
stay
on
track.

The
EPA
encourages
the
early
implementation
of
required
control
measures
and
of
contingency
measures
as
a
means
of
guarding
against
failures
to
meet
a
milestone
or
to
attain.
Any
implemented
measures
(
that
are
not
needed
for
the
rate­
of­
progress
requirements
or
for
the
attainment
demonstration)
would
need
to
be
backfilled
only
to
the
extent
they
are
used
to
meet
a
milestone.
For
purposes
of
an
attainment
failure,
it
would
be
impractical
to
require
States
backfill
the
contingency
measures
when
they
have
already
fulfilled
the
contingency
measure
requirement
for
their
classification.
The
State
would
be
required
to
adopt
new
contingency
measures
as
part
of
the
process
of
developing
their
new
SIP
for
new
classification.
See
"
Early
Implementation
of
Contingency
Measures
for
Ozone
and
Carbon
Monoxide
(
CO)
Nonattainment
Areas,"
Memorandum
from
G.
T.
Helms,
Chief,
Ozone/
Carbon
Monoxide
Programs
Branch,
August
13,
1993.
45
For
milestone
fa
compensate
the
sufficient
measures
be
implemented.
Gene
B
of
this
document.
Add
and
implications
will
be
pro
For
an
attainment
failure,
EPA
States
could
adopt
measures
that
a
contingency
measure
requirement.
T
lowered
for
already­
adopted
measures
i
or
measure
that
meets
the
creditability
req
achieve
real,
permanent,
enforceable
reduct
contingency
measure.
In
addition,
please
refer
Measures
that
are
due
November
15,
1993
for
M
Memorandum
from
D.
Kent
Berry,
Acting
director
November
8,
1993,
for
more
information.

5.7
Long­
Term
Control
Measures
It
is
anticipated
that
some
serious
and
above
ozone
nonattainm
large
emission
reductions
to
achieve
attainment
by
their
attainme
may
be
an
unreasonable
burden
for
such
areas
to
identify,
develop,

control
measures
needed
to
demonstrate
attainment
in
their
post­
1996
must
be
submitted
to
EPA
by
November
15,
1994.
The
General
Preamb
Title
I
of
Clean
Air
Act
Amendments
of
1990
(
57
FR
13498)
sets
forth
t
areas
that
may
need
additional
time
to
fully
develop
and
adopt
certain
"
long
that
would
be
the
preferred
method
to
achieve
attainment.
The
long­
term
contr
include
those
that
require
complex
analyses,
decision
making,
and
coordination
a
governmental
agencies.
It
is
important
to
note
that
no
measure
that
is
specifically
re
Act
(
e.
g.,
NO
x
RACT
controls)
can
be
considered
a
"
long­
term"
control
measure.

The
EPA
intends
to
allow
such
areas
reasonable
time
to
complete
full
development
and
adoption
of
long­
term
control
measures
under
the
following
conditions:

!
The
portion
of
the
post­
1996
rate­
of­
progress
plan
that
contains
the
demonstration
of
attainment
must
identify
each
control
measure
for
which
additional
time
would
be
needed
for
full
development
and
adoption.

!
The
plan
must
show
that
the
long­
term
control
measures
cannot
be
fully
developed
and
adopted
by
the
submittal
date
the
attainment
demonstration.

!
The
plan
must
contain
an
enforceable
commitment
(
i.
e.,
a
commitment
that
has
been
subjected
to
hearing
as
part
of
the
SIP)
by
the
relevant
agency
that
development
and
adoption
will
occur
on
an
expeditious
schedule
to
achieve
specified
emission
reductions
from
each
long­
term
control
measure
for
each
year
through
the
attainment
year.

!
The
plan
must
contain
a
"
backstop"
control
measure
for
each
long­
term
control
measure
that
would
be
implemented
to
achieve
equivalent
emission
reductions
unless
the
long­
term
control
measure
is
adopted
and
implemented
on
schedule.

!
The
long­
term
control
measures
must
not
be
needed
to
meet
any
emission
reduction
requirements
during
the
first
6
years
after
enactment
(
i.
e.,
from
November
15,
1990
through
November
15,
1996).
46
47
!
States
must
hav
States
with
the
aut
1996
rate­
of­
progres
The
backstop
control
mea
progress
plan
submittal
and
milestone
and
attainment
failu
automatically
on
a
schedule
(
wh
emission
reductions
associated
attainment
year.
The
backstop
contr
reductions
rather
than
thoroughly
anal
declining
emission
cap
(
e.
g.,
lbs/
day,
tpy)

appropriate
backstop
control
measure.

Several
States
have
expressed
concern
about
the
EPA's
legal
counsel
has
advised
that
the
only
remed
in
their
post­
1996
rate­
of­
is
to
require
t
backstop
control
measures
is
set
forth
in
the
General
Pr
the
Clean
Air
Act
Amendments
of
1990
(
57
FR
13498).
Th
wording
in
the
Act
requires
that
States
submit
SIP
measures
attainment
within
a
certain
timeframe.
The
adoption
of
backst
that
these
will
be
achieved.

When
each
long­
term
control
measure
is
fully
developed
and
adopted,

EPA
as
a
SIP
revision.
The
revision
would
also
propose
deletion
of
the
c
control
measure.
The
EPA's
approval
of
each
long­
term
control
measure
w
corresponding
backstop
control
measure
from
the
SIP.
For
this
reason,
EPA
actual
implementation
of
backstop
control
measures
in
most
cases
because
Stat
opportunity
to
submit
SIP
revisions
to
incorporate
fully
developed
and
adopted
lo
measures
and
to
delete
the
backstop
control
measures
from
SIP.
In
addition,
if
a
control
measure
cannot
be
developed,
then
a
State
has
the
option
of
submitting
a
SIP
r
a
fully
developed
and
adopted
alternative
measure
to
replace
the
original
long­
te
measure
prior
to
any
necessary
implementation
of
a
backstop
control
measure.

Thus,
a
State
may
find
that
progress
can
be
achieved
with
control
measures
that
are
fully
developed,
adopted,
and
included
in
its
post­
1996
rate­
or­
progress
plan
by
November
15,
1994.

However,
the
State
may
determine
expeditious
attainment
of
the
NAAQS
is
impossible
unless
its
SIP
also
includes
control
measures
which
cannot
be
fully
developed
until
after
the
November
15,
1994
submittal
deadline.
In
its
post­
1996
rate­
of­
progress
plan
submittal,
the
State
must
clearly
describe
each
of
the
long­
term
control
measures
and
show
that
each
measure
cannot
be
fully
developed
and
adopted
until
a
specified
future
date,
despite
expeditious
implementation
efforts.
The
post­
1996
rate­

of­
progress
plan
must
include
with
each
long­
term
control
measure
an
enforceable
schedule
binding
responsible
agencies
to
achieve
the
identified
emission
reductions
associated
with
implementation
of
each
long­
term
control
measure.
Please
note
that
the
intention
of
long­
term
control
measures
are
for
aiding
in
attaining
NAAQS.
EPA
realizes,
however,
that
in
some
circumstances
long­
term
measures
may
be
needed
for
the
rate­
of­
progress
requirements
as
well.
Therefore,
these
(
if
all
above
requirements
are
followed)
are
creditable
to
the
post­
1996
rate­
of­
progress
plan
requirements
as
long
as
the
appropriate
amount
of
reductions
are
achieved
by
the
milestone
date.

5.8
New
Technologies
for
Extreme
Ozone
Nonattainment
Areas
In
addition
to
the
long­
term
measures
option
discussed
in
section
5.7
above,
section
182(
e)(
5)

of
the
Act
permits
the
EPA
to
approve
SIP's
and
attainment
demonstrations
for
extreme
ozone
nonattainment
areas
which
include
control
measures
that
anticipate
the
development
of
new
techniques
or
the
improvement
of
existing
technologies.
In
order
to
receive
EPA
approval,
the
State
cannot
use
such
measures
to
achieve
the
necessary
emission
reductions
required
during
the
1990­
2000
48
period
and
the
S
measures
in
case
t
reductions.
These
co
proposed
implementati
accordance
with
the
requ
addition
to
the
contingency
7
Both
the
1990
base
year
inventory
and
1990
rate­
of­
progress
base
year
inventories
were
calculated
for
the
15
percent
rate­
of­
progress
plan.
If
any
adjustments
are
made
to
these
inventories
since
they
were
submitted
for
the
15
percent
plan,
then
these
revised
inventories
will
need
to
be
submitted
as
part
of
the
post­
1996
rate­
of­
progress
plan,
with
a
full
explanation
of
the
changes
and
why
they
were
made.
If
no
changes
were
made,
then
the
State
should
reference
the
previous
inventories
in
the
post­
1996
rate­
of­

progress
plan.

8
See
CFR
Part
51.281
on
adopted
measures.
See
section
5.2
of
this
document
for
information
on
using
TCM's
that
are
not
adopted
measures
for
the
rate­
of­
progress
plan.

49
6.0
POST­
1996
R
SUBMITTALS
AN
6.1
Post­
1996
Rate­
of­
P
This
section
identifies
the
in
November
15,
1994
rate­
of­
pro
suggested
formats
for
these
subm
following
elements
and
documenta
!
1990
adjusted
base
year
inventory(
ies).

!
VOC
(
and
NO
x
,
where
applicable)
target
leve
supporting
calculations.

!
Growth
factors
for
developing
projected
rate­
of­
pro
inventories.

!
Control
measures
and
their
associated
control
efficiencies.

!
Projected
milestone
and
attainment
year
inventories
reflecting
strategy.

!
Fully
adopted
post­
1996
rate­
of­
progress
plan,
including
attainment
d
and
any
control
measures
needed
to
meet
rate­
of­
progress
or
attainment
demonstration
requirements.
8
!
Modeling
Documentation
(
see
reference
4).

1990
Adjusted
Base
Year
Inventory
Documentation
of
the
adjusted
base
year
inventory
for
each
milestone
year
will
take
two
distinct
forms.
The
written
documentation
must
include
the
expected
emission
reductions
f
FMVCP
and
RVP
program,
as
well
as
both
actual
1990
motor
vehicle
emissions
using
1990
V
and
MOBILE5a
emission
factors,
and
the
adjusted
emissions
using
1990
VMT
and
the
MOBIL
emission
factors
calculated
for
each
milestone/
attainment
year
with
the
appropriate
RVP
for
the
nonattainment
area
as
mandated
by
EPA.
States
must
provide
EPA
with
the
inputs
to
the
MOBILE5a
model
used
in
calculating
the
expected
emission
reductions
from
the
FMVCP
and
RVP
program.

For
purposes
of
the
AIRS
Area
and
Mobile
Source
Subsystem
(
AMS)
adjusted
base
year
submittal,
States
must
provide
the
RVP
inputs
as
required
under
the
Act
for
nonattainment
area,

and
run
the
MOBILE5a
model
for
1999
and
each
subsequent
milestone/
attainment
year
vehicle
mix
(
e.
g.,
extreme
areas
run
the
model
for
1999,
2002,
2005,
2008,
and
2010).
Because
the
calculation
of
50
the
FMVCP
and
States
will
not
sub
Other
requirements
for
AIRS
are
the
same
as
tho
documentation
of
the
base
y
Ozone
State
Implementation
P
Base
Year
Ozone
and
Carbon
M
reference
11.)
States
should
realize
inventory
for
the
AIRS
facility
subsy
calculation
of
the
adjusted
inventory
fro
for
both
the
rate­
of­
progress
an
retrieved
from
the
1990
base
year
inventory
All
adjustments
apply
to
mobile
source
emissio
emissions
are
different
because
the
base
year
inv
nonattainment
area
boundaries.
The
AIRS
has
a
fl
designated
nonattainment
area
boundaries
and,
there
develop
these
two
different
inventories.

Target
Level(
s)
of
Emissions
The
target
level(
s)
of
emissions
for
each
milestone
and
attainment
amount
of
anthropogenic
emissions
within
the
nonattainment
area
t
year
order
to
comply
with
the
rate­
of­
progress
requirements.
The
E
document
the
target
emission
level(
s)
as
well
as
calculations
made
in
level(
s).

Control
Measure
and
Growth
Factor
Information
Documentation
for
all
of
the
control
measures
and
their
associated
control
efficienci
factors
for
both
the
post­
1996
rate­
of­
progress
plan
and
the
attainment
demonstration
submitted.
See
Table
1
in
EPA
document
entitled
Guidance
on
the
Adjusted
Base
Ye
Emissions
Inventory
and
the
Target
for
the
15
Percent
Rate­
of­
Progress
Plans
(
see
ref
for
a
suggested
computerized
format.
Table
I
also
provides
an
example
of
growth
factor
documentation.

The
control
measure
information
consists
primarily
of
a
list
of
control
measures
and
associated
control
efficiencies
on
a
computer
diskette
file
formatted
as
discussed
above.
For
control
measures
that
will
be
applied
during
modeling
of
attainment,
control
information
must
be
reported
for
the
entire
modeling
domain
unless
measures
are
specifically
limited
to
the
nonattainment
area.

Supplied
control
information
for
attainment
year
strategies
will
be
used
as
input
to
the
upcoming
regional
oxidant
modeling
(
ROM)
exercises
to
improve
consistency
between
ROM
and
UAM
results.

Also
included
should
be
the
rule
penetration
(
percentage
of
rule
coverage)
associated
with
new
area­
source
control
measures
and
any
expected
changes
in
RE
for
point
or
area
sources.
In
addition
to
the
data
on
spreadsheet,
paper
documentation
should
be
provided
describing
the
control
measures,
their
implementation
dates,
assumptions
made,
and
any
further
explanation
needed
for
the
information
listed
on
the
spreadsheet.

Milestone
Year
Projected
Inventories
51
The
milestone
year
the
assumptions
used
documented.

6.2
Multi­
State
Submittal
In
The
officials
in
each
State
that
a
EPA
should
send,
as
part
of
their
p
Regional
Administrator(
s)
stating
tha
a
multi­
State
post­
1996
rate­
of­
progress
target
for
each
State,
percent
reduction
re
total
3
percent
per
year
VOC/
NO
x
emissi
original
targets
are
calculated
assuming
that
e
on
its
own.
The
sum
of
the
new
targets
must
equ
Each
State
will
be
responsible
for
adopting
and
imple
new
target.
No
State
will
be
responsible
for
the
failure
o
6.3
Mid­
Course
Corrections
The
EPA
recognizes
that
there
are
some
uncertainties
associated
generate
base
year
and
projected
emission
inventories
and
to
model
VOC
and
NO
x
emissions
and
ozone
air
quality.
It
is
expected
that,
ove
experience
in
running
the
current
version
of
UAM
and
improved
air
qua
be
available.
In
addition,
anticipated
improvements
in
emission
inventory
will
result
in
improved
input
to
UAM.

For
these
reasons,
States
are
encouraged
to
consider
making
mid­
course
correctio
attainment
demonstrations
and
rate­
of­
progress
plans
around
1997.
This
will
allow
advantage
of
improved
modeling
techniques,
air
quality
monitoring
systems
and
emiss
to
refine
their
attainment
strategies.

6.4
Suggested
Submittal
Tables
The
following
tables
are
the
suggested
submittal
forms
for
a
summary
of
the
post­
1996
rateof
progress
plan
and
the
attainment
demonstration.
Table
5
is
the
recommended
format
for
control
strategy
submittal.
Table
6
contains
information
for
all
of
the
controls
needed
for
the
attainment
demonstration.
Table
7
suggests
a
format
for
the
contingency
measure
submittal.
Table
8
provides
a
format
for
explaining
RE
improvement
measures.
Tables
9
and
10
recommend
a
format
for
giving
further
details
on
all
of
the
stationary
source
control
measures.
15
All
noncreditable
mobile
source
measures
should
be
listed
individually
but
may
be
calculated
in
a
single
MOBILE5a
run.

16
All
creditable
mobile
source
measures
that
are
calculated
through
MOBILE5a
should
listed
individually
but
may
be
calculated
in
a
single
run.

17
Emission
reductions
from
mobile
source
measures
that
are
not
calculated
in
MOBILE5a
should
be
calculated
and
listed
individually.

52
TABLE
5.
SUG
STRATEGY
SUM
Control
Measure
Creditable/
Noncreditable
Implementation
Date
Expected
VOC
Emissions
Reductions
(
lb/
day)
Expected
NO
x
Emissions
Reductions
(
lb/
day)

TOTAL
STATIONARY
MOBILE
SOURCE
CONTROLS:

Noncreditable15
Creditable16
Creditable17
TOTAL
MOBILE:

TOTAL
53
TABLE
6.
SUG
SUBMITTAL
Control
Measure
Implementation
Date
Expected
VOC
Emissions
Reductions
(
lb/
day)
Expected
NO
x
Emissions
Reductions
(
lb/
day)

TOTAL
STATIONARY
MOBILE
SOURCE
CONTROLS:

TOTAL
MOBILE:

TOTAL
TABLE
7.
SUGGESTED
FORMAT
FOR
CONTINGENCY
MEASURE
SUBMITTAL
1990
VOC
adjusted
base
year
inventory:
5,200
lb/
day
1990
NOx
adjusted
base
year
inventory:
7,600
lb/
day
IMPLEMENTATIO
NORDER
DESCRIPTION
OF
CONTROL
MEASURE
EXPECTED
VOC
EMISSION
REDUCTIO
N(
lb/
day)
EXPECTED
NOx
EMISSION
REDUCTION
(
lb/
day)
EMISSION
REDUCTION
AS
A
PERCENTAG
E
OF
1990
VOC
ADJUSTED
BASE
YEAR
INVENTORY
EMISSION
REDUCTION
AS
A
PERCENTAGE
OF
1990
NOx
ADJUSTED
BASE
YEAR
INVENTORY
1
Automobile
emission
tax
80
105
1.54
1.38
2
NO
x
RACT
w/
lower
major
stationary
source
cutoff
(
25
tpy
for
serious
area)
30
0.39
3
Stage
II
vapor
recovery
for
boats
25
0.48
TOTAL
105
135
2.02
1.77
TABLE
8.
SUG
IMPROVEMENT
RE
IMPROVEMENT
MEASURE
1990
RE
(
percent)
NEW
RE
(
percent)
IMPLEMENTATION
DATE
EXPECTED
EMISSIONS
REDUCTIONS
(
lb/
day)

TOTAL:

TABLE
9.
SUGGESTED
FORMAT
FOR
SUBM
CONTROL
MEASURES
FOR
THE
POST­
1996
R
CONTROL
MEASURE
IMPLEMENTATION
DATE
1990
CONTROL
EFFICIENCY
(
percent)
NEW
CONTROL
EFFICIENCY
(
percent)
EXPECTED
EMISSIONS
REDUCTIONS
(
lb/
day)

TOTAL:

TABLE
10.
SUGGESTED
FORMAT
FOR
SUBMITTAL
OF
STATIONARY
SOUR
CONTROL
MEASURES
FOR
THE
ATTAINMENT
DEMONSTRATION
CONTROL
MEASURE
IMPLEMENTATION
DATE
1990
CONTROL
EFFICIENCY
(
percent)
NEW
CONTROL
EFFICIENCY
(
percent)
EXPECTED
EMISSIONS
REDUCTIONS
(
lb/
day)

TOTAL:
1.
Guidance
on
the
Ad
Rate­
of­
Progress
Plans,

Research
Triangle
Park,
NC
2.
User's
Guide
for
t
A­
C,
D(
R),
E­
F,
U.
S.
E
Research
Triangle
Park,

3.
Guideline
for
Regulatory
A
Model,
450/
4­
91­
01,
U.
S.
E
Agency,
OAQPS,
Research
Triangle
4.
Guidance
on
Urban
Airshed
Model
(

for
Attainment
Demonstration,
EPA­
454
Environmental
Protection
Agency,
OAQPS
Park,
NC.
January
1994.

5.
Criteria
for
Assessing
the
Role
of
Transp
Ozone/
Precursors
in
Ozone
Nonattainment
Areas
015,
U.
S.
Environmental
Protection
Agency,
OAQP
Triangle
Park,
NC.
May
1991.

6.
Guidance
for
Growth
Factors,
Projections,
and
Cont
Strategies
for
the
15
Percent
Rate­
of­
Progress
Plans,

452/
R­
93­
007.
U.
S.
Environmental
Protection
Agency,
OAQ
Research
Triangle
Park,
NC.
March
1993.

7.
Guidance
on
the
Relationship
Between
the
15
Percent
Rate­
of­
Progress
Plans
and
Other
Provisi
of
the
Clean
Air
Act,
EPA­
452/
R­
93­
007,
U.
S.
Environmental
Protection
Agency,
OAQPS,

Research
Triangle
Park,
NC.
May
1993.

8.
Economic
Growth
Analysis
System:
Reference
Manual,
EPA­

600/
R­
93­
067a,
U.
S.
Environmental
Protection
Agency,
Office
of
Research
and
Development,
Washington,
DC.
April
1993.

9.
Economic
Growth
Analysis
System:
User's
Guide,
EPA­
600/
R­

93­
067b,
U.
S.
Environmental
Protection
Agency,
Office
of
Research
and
Development,
Washington,
DC.
April
1993.

10.
Emission
Inventory
Requirements
for
Ozone
State
Implementation
Plans,
EPA­
450/
4­
91­
010,
U.
S.
Environmental
Protection
Agency,
OAQPS,
Research
Triangle
Park,
NC.

March
1991.

11.
Example
Documentation
Report
for
1990
Base
Year
Ozone
and
Carbon
Monoxide
State
Implementation
Plan
Emission
Inventories,
EPA
450/
4­
92­
007,
U.
S.
Environmental
Protection
Agency,
OAQPS,
Research
Triangle
Park,
NC.
March
1992.
REFERENCES
A­
1
APPENDIX
A:

This
appendix
provide
document.
Different
EPA
source).
The
following
defin
reader
is
advised
to
refer
to
sp
definitions
for
the
program
or
ti
The
following
terms
are
defined
in
A
Growth
Factors,
Projections,
and
Contr
reference
6):

!
Area
Source.

!
Attainment
Demonstration.

!
Attainment
Determination.

!
Basic
Inspection
and
Maintenance.

!
Major
Stationary
Source.

!
Milestone
Compliance
Demonstration.

!
1990
Adjusted
Base
Year
Inventory.

!
1990
Base
Year
Inventory.

!
1990
Rate­
of­
Progress
Base
Year
Inventory.

!
1996
Target
Level
of
Emissions.

!
Peak
Ozone
Season.

!
Point
Source.

!
Post­
1996
Rate­
of­
Progress
Plan.

!
RACT
"
Catch­
ups."

!
RACT
"
Fix­
ups."

!
Rate­
of­
Progress
Plan.

!
Rule
Effectiveness.

!
Volatile
Organic
Compound.

The
following
terms
are
defined
in
Appendix
A
of
the
EPA
document
entitled
Guidance
on
the
Relationship
Between
the
15
Percent
Rate­
of­
Progress
Plans
and
Other
Provisions
of
the
C
Air
Act
(
see
reference
7):

!
Reclassification.

!
Reformulated
Gasoline.

!
Reid
Vapor
Pressure.

!
Stage
II.

!
Transportation
Control
Measures.

Backstop
Measure
Fully
adopted
control
measure
that
achieves
an
annual
emission
reduction
equivalent
to
those
that
would
be
achieved
by
the
implementation
of
long­
term
control
measures.

Economic
Growth
Analysis
System
(
E­
GAS)
An
EPA
model
for
projecting
emissions
growth
based
on
value­
added
and
physical
output
data.

Economic
Incentive
Program
A
program
which
may
include
State
established
emission
fees
or
a
system
of
marketable
permits,
or
a
system
of
State
fees
based
on
the
sale
or
manufacture
of
products
the
use
of
which
contributes
to
ozone
formation,
or
any
combination
of
the
foregoing
or
other
similar
measures,
as
well
as
incentives
and
requirements
to
reduce
vehicle
emissions
and
VMT
in
an
area.

Emissions
Preprocessor
System
(
EPS)
An
EPA
model
for
developing
hourly
emission
rates
from
annual
emissions,
emissions
by
grid
cell
from
county
emissions,
NO
and
NO
2
emissions
from
NO
x
inventories,
and
speciated
hydrocarbon
emissions
from
VOC
inventories.
A­
2
Fleet
Turnover
the
target
level
of
e
reflect
the
emission
r
55
FR
23666,
June
11,

Long­
Term
Control
Measur
more
time
to
develop
and
adop
progress
plans
(
i.
e.,
November
1
measure
that
will
achieve
equivalen
adopted
and
implemented
on
schedu
New
Technologies
Control
measures
for
development
of
new
control
techniques
or
th
VOC
and/
or
NO
x
emissions
that
require
more
t
submittal
of
the
post­
1996
rate­
of­
progress
plans
Projected
Milestone
Inventory
An
inventory
of
proje
control
measures.
A
nonattainment
area
computes
this
plan
for
each
target
year.

Target
Year
A
year
in
which
a
nonattainment
area
must
recalc
for
the
post­
1996
rate­
of­
progress
plan
(
e.
g.,
target
years
for
extre
2008,
and
2010).

Target
Level
of
Emissions
The
maximum
amount
of
emissions
that
a
no
a
given
target
year
while
complying
with
the
post­
1996
rate­
of­
progress
pla
Urban
Airshed
Model
(
UAM)
An
EPA­
approved
photochemical
grid
model
for
attainment
demonstrations
for
nonattainment
areas.
18
Appendix
H
of
the
document
entitled
Guidance
for
Growth
Factors,
Projections,
and
Control
Strategies
for
the
15
Percent
Rate­
of­
Progress
Plan,
EPA­
452/
R­
93­
002,
March
1993,
describes
the
attainment
failure
implications
for
marginal
and
moderate
areas.

B­
1
APPENDIX
B:

FAILURES
This
appendix
provides
a
failures
for
serious,
severe,
a
milestone
demonstrations
and
future
rulemaking.
Marginal
an
are
required
to
attain
by
1993
does
not
attain
by
1996,
it
may
be
rec
requirements
for
this
higher
classifi
to
achieve
the
1999
milestone
emission
red
nonattainment
areas.

Serious
Areas
Milestone
Failures
Serious
areas
are
required
to
demonstrate
one
milestone,
t
emission
reduction
requirement
unless
they
apply
for
and
re
year
attainment
date
extensions
under
section
181(
a)(
5).
Plans
the
rate­
of­
progress
plan,
due
by
November
15,
1993.
Serious
are
compliance
demonstration
within
90
days
after
milestone
date
(
i
will
determine
within
90
days
whether
or
not
the
demonstration
was
a
182(
c)(
9)
requires
that
contingency
measures
go
into
effect
automatically
required
to
elect
one
of
three
additional
measures
to
implement
if
these
con
adequate
to
correct
the
failure.
The
elective
options
are:

!
Bumping
up
to
the
next
higher
classification.

!
Implementing
additional
contingency
measures.

!
Adopting
an
EIP
that
meets
the
requirements
of
section
182(
g)(
4).

This
election
must
occur
within
90
days
of
the
milestone
failure
determination
by
EPA.
If
the
State
fails
to
make
the
election
within
the
90
days
or
6
months
thereafter,
area
will
be
reclassif
to
the
next
higher
classification
by
operation
of
law.
Within
12
months
after
the
date
by
which
the
State
is
required
to
elect
an
option,
the
State
must
submit
a
SIP
revision
that
corrects
the
failure.

The
EPA
has
9
months
after
the
submittal
date
to
review
and
approve
or
disapprove
the
revised
SIP.

Because
the
timeframe
involved
in
making
a
State
election,
revising
the
SIP
to
reflect
the
election,
and
EPA
approval
of
the
SIP
revision
may
take
as
long
as
2.5
years,
States
with
serious
areas
are
strongly
encouraged
to
implement
control
measures
as
soon
as
a
milestone
failure
is
deemed
likely.

States
that
wait
until
the
milestone
failure
occurs
will
have
extremely
limited
time
available
to
develop,
implement,
and
evaluate
additional
control
measures
before
the
next
milestone
must
be
met.

Attainment
Failures
Serious
areas
are
required
to
attain
the
NAAQS
for
ozone
by
November
15,
1999,
unless
they
apply
for
and
receive
at
least
one
two
available
1­
year
attainment
date
extensions
under
section
181(
a)(
5).
EPA
shall
determine,
based
on
the
area's
design
value
(
as
of
the
attainment
date)
whether
B­
2
the
area
attained
November
15,
199
classification
[
section
attainment
date,
identi
implement
the
contingenc
expects
all
actions
implem
Severe
Areas
Severe
nonattainment
areas
with
a
1
demonstrate
post­
1996
emission
reducti
by
2005,
unless
they
apply
and
receive
extensions
under
section
181(
a)(
5).
Severe
a
up
to,
but
not
including,
0.280
ppm
must
demo
1999,
2002,
and
2005,
and
are
required
to
attain
receive
at
least
one
of
the
two
available
1­
year
attai
Milestone
Failures
As
with
serious
areas,
severe
areas
that
fail
to
meet
a
miles
measures
following
the
same
requirements
as
for
serious
are
options
specified
in
section
182(
g)(
3).

Attainment
Failures
Upon
an
attainment
failure,
severe
areas
must
implement
the
contingenc
in
the
SIP
[
section
172(
c)(
9)]
following
the
same
requirements
as
for
seriou
major
stationary
source
within
the
nonattainment
area
must
pay
the
fees
man
as
a
penalty
for
failure
to
attain.
These
emission
fees
apply
to
sources
of
NO
x
em
controls
are
used
in
the
attainment
demonstration.
Section
181(
b)(
4)(
B)
the
Ac
if
a
severe
area's
design
value
is
above
0.140
ppm
for
the
attainment
year
or
if
the
ar
its
most
recent
milestone,
NSR
requirements
pertaining
to
extreme
areas
become
appli
area,
and
the
major
stationary
source
threshold
for
extreme
areas
(
10
tpy
or
more)
also
g
effect.
A
severe
nonattainment
area
cannot
be
reclassified
as
an
extreme
area
upon
attainm
failure.

Extreme
Areas
Milestone
Failures
Extreme
areas
are
required
to
demonstrate
post­
1996
milestones
in
1999,
2002,
2005,
and
2008
[
182(
g)(
2)].
In
the
event
of
a
milestone
failure,
section
182(
g)(
5)
requires
that
extreme
areas
adopt
an
EIP,
as
described
in
section
182(
g)(
1),
and
implement
the
contingency
measures
described
in
the
SIP
[
section
172(
c)(
9)
and
182(
c)(
9)]
following
the
same
requirements
as
for
serious
areas.
Attainment
Failures
Extreme
areas
are
required
to
attain
the
NAAQS
for
ozone
by
November
15,
2010,
unless
they
apply
for
and
receive
at
least
one
of
the
two
available
1­
year
attainment
date
extensions
under
section
181(
a)(
5).
Extreme
areas
that
fail
to
attain
by
their
applicable
attainment
date,
must
implement
the
contingency
measures
contained
in
the
SIP
[
section
172(
c)(
9)]
following
the
same
requirements
as
for
serious
areas,
and
each
major
stationary
source
within
the
nonattainment
area
must
pay
the
fees
as
mandated
by
section
185.
These
emission
fees
apply
to
sources
of
NO
x
emissions
as
well
if
NO
x
controls
are
used
in
the
attainment
demonstration.

Bump­
up
Requirements
B­
3
The
EPA
classif
These
classificatio
Section
181(
a)
of
the
classification
must
atta
the
EPA
must
make
"

[
section
181(
b)(
2)
of
the
Act
to
quality
assurance
review,
co
of
ozone,
average
number
of
be
used
to
determine
whether
an
a
Under
section
181(
a)(
5)
of
the
Act,
a
Sta
nonattainment
area's
attainment
date;
up
be
granted
if
the
State
is
in
complete
compli
than
one
exceedance
of
the
ozone
NAAQS
has
According
to
section
181(
b)(
2)
of
the
Act,
failure
of
nonattainment
area
to
attain
the
ozone
NAAQS
by
th
will
result
in
their
reclassification
the
higher
of:

!
The
next
higher
classification
for
the
area.

!
The
classification
associated
with
the
area's
design
value
when
EP
determination
that
attainment
was
not
achieved.

This
reclassification
procedure
does
not
apply
to
severe
and
extreme
are
NAAQS
by
their
applicable
date.
If
a
severe
or
extreme
area
fails
to
attain
area
must
implement
contingency
measures
required
under
section
172(
c)(
9)

must
pay
the
fees
authorized
by
section
185.

"
Bump­
up"
refers
to
the
reclassification
process
that
a
marginal,
moderate,
or
serio
automatically
undergoes
if
it
fails
to
attain
the
NAAQS.
The
term
bump­
up
also
appli
reclassification
of
a
serious
or
severe
nonattainment
area
as
a
result
of
milestone
failure.

severe
nonattainment
areas
that
fail
to
meet
a
milestone
are
required
to
make
an
election,
u
section
182(
g)(
3)
of
the
Act,
from
three
given
measures
identified
on
page
B­
1.
One
explicit
op
reclassification
of
the
area
to
the
next
higher
classification.

Upon
bump­
up,
the
attainment
date
specified
for
the
higher
classification
applies
to
the
area
that
has
been
bumped­
up.
Section
182(
i)
of
the
Act
allows
EPA
to
establish
due
dates
for
required
submittals
associated
with
the
new
classification,
but
does
not
allow
EPA
to
adjust
the
attainment
date.
An
early
voluntary
bump­
up
will
allow
the
State
more
flexibility
and
time
in
planning
for
and
achieving
the
new
requirements
of
the
higher
classification.
Since
failure
to
submit
approvable
SIP
revisions
can
result
in
sanctions
or
Federal
implementation
plan
(
FIP)
measures,
it
will
be
in
the
best
interests
of
areas
to
attempt
to
assess
whether
attainment
is
improbable
as
soon
as
possible.

Attainment
Date
Extensions
If
a
moderate
or
above
nonattainment
area
receives
a
1­
year
extension
or
two
1­
year
extensions
of
their
attainment
date,
no
additional
rate­
of­
progress
requirements
are
required
during
the
time
of
the
extension(
s).
Contingency
measures
are
not
required
to
be
implemented
during
this
time
unless
the
nonattainment
area
failed
to
meet
a
required
milestone.
For
purposes
of
section
172(
c)(
9),
contingency
measures
would
be
required
to
be
implemented
when
the
area
failed
to
attain
the
new
attainment
date.
However,
if
a
nonattainment
area
receives
an
extension,
the
area
is
to
perform
a
milestone
compliance
demonstration
for
the
original
attainment
date
year.
Since
the
area
is
asking
for
an
extension,
the
nonattainment
area
has
not
attained
and
therefore
is
required
to
do
the
milestone
compliance
demonstration.
B­
4
Fee
Provisions
Section
185
of
the
Ac
in
their
SIP's
for
the
im
each
major
stationary
sou
failure
to
attain
during
the
year
until
the
area
attains.
Th
used
in
the
attainment
demonstr
The
Act
requires
that
these
fees
equa
stationary
source
during
the
calendar
y
will
also
be
adjusted
for
inflation
over
tim
baseline
level
of
emissions
for
a
source
is
det
!
The
actual
VOC
or
NO
x
emissions.

!
The
emissions
allowed
according
to
the
applicable
per
If
EPA
determines
that
the
fee
provisions
of
a
SIP
do
not
m
185,
or
the
State
is
not
administering
the
fee
program
as
requ
unpaid
fees,
including
any
interest
computed
in
accordance
wit
Revenue
Code
of
1986.

Additionally,
section
185
provides
a
fee
exemption
for
areas
with
a
po
that
can
demonstrate
that
their
failure
to
attain
is
due
to
ozone
or
precu
from
other
areas.
19
56
FR
42216,
"
State
Implementation
Plan
Completeness
Criteria;
Final
Rule."
August
26,
1991.

C­
1
APPENDIX
C:

The
following
checkl
plan.
Questions
in
the
question
requires
no
furth
not
necessarily
invalidate
th
occasionally,
will
require
a
SIP
These
checklists
are
designed
to
as
progress
plans,
and
also
to
assist
EPA
checklists
are
all­
inclusive,
however.

REVIEWING
PROCEDURES
This
section
outlines
the
required
steps
to
be
take
reviewing
post­
1996
rate­
of­
progress
plans.
The
co
timeframes
allotted
for
revisions
to
the
plans
are
discu
found
in
40
CFR
51
Requirements
for
Preparation,
Ado
Plans.
The
specific
requirements
for
post­
1996
rate­
of­
pro
document.

State
Agencies
State
agencies
have
the
responsibility
of
compiling
the
post­
1996
rateensure
that
the
plan
meets
the
minimum
completeness
criteria
(
40
CFR
P
a
plan
has
been
adopted
by
a
State,
five
copies
of
the
plan
are
be
submit
his/
her
designee)
to
the
Regional
Office
of
the
EPA
for
review.

A
State
may
want
to
submit
a
draft
copy
of
the
post­
1996
rate­
of­
progress
plan
to
comments
prior
to
November
15,
1994
deadline.
This
will
provide
an
early
oppo
feedback
on
the
plan.
The
EPA
will
not
consider
submission
of
requests
for
parallel
p
draft
plans
as
official
plans
in
order
to
meet
statutory
deadlines.
The
EPA
interprets
the
requiring
rules
that
are
acceptable
under
the
approval
options
section
110(
k).

The
EPA
is
presently
amending
the
completeness
criteria
to
remove
the
exception
for
parallel
processing
and
to
add
an
exception
for
the
submission
of
commitments
as
allowed
under
section
110(
k)(
4).

Regional
Offices
The
first
step
in
the
review
process
for
Regional
Offices
will
be
to
determine
if
the
post­
1996
rate­
of­
progress
plan
meets
the
completeness
criteria
outlined
in
40
CFR
Part
51,
Appendix
V.
The
completeness
criteria
require
that
within
60
days
of
EPA's
receipt
of
a
plan
or
plan
revision,
but
not
later
than
6
months
after
the
date
by
which
a
State
was
required
to
submit
the
plan
or
plan
revision,

the
EPA
shall
determine
whether
completeness
criteria
have
been
met.
If
EPA
has
not
made
a
completeness
determination
by
6
months
after
receipt
of
the
submission,
that
submission
shall
on
that
date
be
considered
to
meet
the
completeness
criteria.
The
completeness
criteria
require
that
EPA
inform
the
submitting
official
by
letter
if
the
plan
meets
the
requirements
of
Appendix
V.
If
a
submittal
is
deemed
incomplete,
EPA
shall
notify
the
State
by
letter
that
the
submittal
is
incomplete.

In
the
letter
EPA
will
request
corrective
action
and
identify
the
components
absent
or
insufficient
to
perform
a
review.
C­
2
When
it
has
bee
EPA
is
required
to
completeness
determ
C­
3
ADJUSTED
BA
1.
Was
the
MOBILE5
FMVCP
and
RVP?

__
Yes
__
No
Comments:

2.
Does
the
plan
include
informatio
noncreditable
emission
reductions
fro
__
Yes
__
No
Comments:

3.
Was
the
1990
adjusted
base
year
inventory
calc
attainment
year
to
reflect
the
effects
of
FMVCP
and
noncreditable
emission
reductions
from
FMVCP
and
applicable
adjusted
base
year
inventories)?

__
Yes
__
No
Comments:

4.
Does
the
adjusted
base
year
emission
inventory
include
only
anthr
emanating
from
within
the
designated
nonattainment
area
boundaries
__
Yes
__
No
Comments:

5.
Does
the
plan
document
the
target
level(
s)
as
well
as
calculations
made
in
det
target
level(
s)?

__
Yes
__
No
Comments:
20
The
3
percent
per
year
emissions
reduction
is
averaged
over
each
3
year
period
between
consecutive
milestone
dates
or
the
last
milestone
date
and
the
attainment
date.

21
Procedures
for
Preparing
Emissions
Projections,
EPA­
450/
4­
019,
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC.
July
1991.

C­
4
REQUIRED
TO
1.
Does
the
plan
demo
for
each
applicable
mil
__
Yes
__
No
Comments:

2.
Is
the
required
3
percent
per
year
adjusted
base
year
emission
inventor
__
Yes
__
No
Comments:

3.
If
NO
x
emission
reductions
are
used
in
place
of
V
per
year
requirement,
is
the
substitution
consistent
__
Yes
__
No
Comments:

4.
If
the
plan
outlined
a
less
than
3
percent
per
year
VOC
emiss
include
all
measures
that
can
feasibly
be
implemented
in
the
area
achievability
(
including
measures
that
are
achieved
in
practice
by
so
category
in
nonattainment
areas
of
the
next
higher
classification)?
__
Y
Comments:

5.
Does
the
plan
include
a
summary
of
projected
VOC
(
and
NO
x
where
appropria
levels
for
each
applicable
milestone
and
attainment
date?

__
Yes
__
No
Comments:

6.
Is
the
EPA
guidance
document
entitled
Procedures
for
Preparing
Emissions
Projections
followed
in
calculating
projected
emissions?
21
__
Yes
__
No
Comments:
C­
5
7.
Does
the
contr
emissions
for
each
strategy
provide
for
emission
reductions,
an
__
Yes
__
No
Comments:

8.
Were
emission
reductions
from
R
the
target
levels
(
this
is
not
necessary
percent
rate­
of­
progress
plan)?

__
Yes
__
No
Comments:

9.
If
a
State
plans
to
use
preenactment
banked
emiss
period,
are
the
use
of
such
banked
credits
considered
__
Yes
__
No
Comments:

10.
If
emission
reductions
achieved
in
the
1990­
1996
period
are
cre
are
they
documented
to
be
in
excess
of
the
emission
reductions
(
net
o
the
15
percent
rate­
of­
progress
plan?

__
Yes
__
No
Comments:
C­
6
STATE
IMPLE
AREAS
USING
U
1.
Was
an
approved
mo
model?

__
Yes
__
No
Comments:

2.
Are
attainment
year
emission
estim
inventory?

__
Yes
__
No
Comments:

3.
Were
allowable
emissions
used
as
the
basis
for
fut
__
Yes
__
No
Comments:

4.
Was
the
MOBILE5a
model
used
for
projecting
mobile
source
__
Yes
__
No
Comments:

5.
Have
all
MOBILE5a
model
inputs
for
the
projection
emission
inventory
b
__
Yes
__
No
Comments:

6.
Were
the
assumptions
used
to
simulate
the
effects
of
control
measures
(
e.
g.,
emission
reductions
and
implementation
dates)
in
the
modeling
analysis
consistent
with
the
assumptions
used
for
the
control
measures
specified
in
the
15
percent
and
post­
1996
rate­
of­

progress
plans
to
meet
the
target
level
of
emissions
for
each
applicable
milestone
date?

__
Yes
__
No
Comments:

7.
Was
EPS2.0
used
to
process
(
including
projection
and
control)
the
emission
estimates
for
the
attainment
year?

__
Yes
__
No
Comments:
22
Guideline
for
Regulatory
Application
of
the
Urban
Airshed
Model,
EPA­
450/
4­
91­
01,
U.
S.

Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triang
NC.
1991.

C­
7
8.
Were
mete
__
Yes
__
No
Comments:

9.
Are
emissions
for
the
entir
__
Yes
__
No
Comments:

10.
Are
EPA­
supplied
numbers
for
back
account
for
emissions
from
the
surroundin
__
Yes
__
No
Comments:

11.
Was
the
most
recent
regulatory
version
of
the
UAM
and
was
it
applied
in
accordance
with
EPA
guideline
pro
evaluation
specified
in
the
document
entitled
Guideline
for
Urban
Airshed
Model?
22
__
Yes
__
No
Comments:

12.
Was
a
modeling
demonstration
package
prepared
containing
requ
documented
in
EPA
guidance?

__
Yes
__
No
Comments:
C­
8
CONTROL
ME
1.
Does
the
plan
descr
__
Yes
__
No
Comments:

2.
Are
all
control
measures
requi
Stationary
Source
Controls:

Serious
and
above
ozone
nonattainment
a
a)
RACT
rule
fix­
ups
(
for
those
areas
with
RAC
b)
RACT
rule
catch­
ups:
__
Yes
__
No
Serious
ozone
nonattainment
areas:

a)
Major
stationary
source
threshold
of
50
tpy:

VOC
__
Yes
__
No
NO
x
__
Yes
__
No
b)
New
source
review
(
NSR)
offset
ratio
of
1.2
to
1:

VOC
__
Yes
__
No
NO
x
__
Yes
__
No
Severe
ozone
nonattainment
areas:

a)
Major
stationary
source
threshold
of
25
tpy:

VOC
__
Yes
__
No
NO
x
__
Yes
__
No
b)
NSR
offset
ratio
of
1.3
to
1:

VOC
__
Yes
__
No
NO
x
__
Yes
__
No
C­
9
Extreme
ozone
n
a)
Major
stationary
s
VOC
__
Yes
__
No
NO
x
__
Yes
__
No
b)
NSR
offset
ratio
of
1.5
to
1:

VOC
__
Yes
__
No
NO
x
__
Yes
__
No
c)
Clean
fuels
or
advanced
control
technology
for
Ozone
transport
region:

a)
Additional
requirements
deemed
by
the
transport
comm
__
Yes
__
No
Comments:

Mobile
Source
Controls
Serious
and
above
ozone
nonattainment
areas:

a)
FMVCP
and
RVP
program:
__
Yes
__
No
b)
Stage
II
vapor
recovery
program:
__
Yes
__
No
c)
Enhanced
I/
M
program:
__
Yes
__
No
d)
Clean
fuel
fleet
vehicle
program
(
in
areas
with
a
population
of
250,000
or
greater)
or:
__
Yes
__
No
Optional
clean
fuel
fleet
vehicle
program
substitute:
__
Yes
__
No
C­
10
Severe
and
abov
a)
TCM's
to
offset
VM
b)
Employer
trip
reductio
__
No
Ozone
transport
region:

a)
Enhanced
I/
M
program
for
any
m
100,000
or
more:

__
Yes
__
No
Comments:

3.
Did
the
State
identify
the
appropriate
MOBILE5a
__
Yes
__
No
Comments:

4.
Does
the
plan
present
a
control
strategy
implementation
sched
__
Yes
__
No
Comments:

5.
Will
all
control
measures
that
are
specified
in
the
post­
1996
rate­
of­
progr
implemented
by
the
appropriate
target
year?

__
Yes
__
No
Comments:

6.
Is
the
implementation
schedule
consistent
with
the
requirements
of
the
Act?

__
Yes
__
No
Comments:

7.
Is
the
agency
that
will
have
enforcement
authority
specified
for
each
control
measure?

__
Yes
__
No
Comments:

8.
Are
the
measures
adopted
and
copies
of
the
rules
submitted?

__
Yes
__
No
Comments:
C­
11
9.
Does
the
plan
each
control
measu
described
in
the
Gen
four
principles
are
as
f
measures
must
be
quantif
the
control
measures
must
b
the
General
Preamble
for
furt
__
Yes
__
No
Comments:

10.
Are
all
major
non­
CTG
stationary
sour
__
Yes
__
No
Comments:

11.
Does
the
plan
include
RACT
rules
for
major
non­
C
CTG
documents
are
not
available?

__
Yes
__
No
Comments:

12.
Is
RE
(
and
for
area
sources,
rule
penetration)
factored
into
the
ca
emission
reductions
associated
with
new
control
measures?

__
Yes
__
No
Comments:

13.
Is
the
80
percent
default
RE
used?

__
Yes
__
No
Comments:

14.
Is
the
EPA
guidance
followed
in
calculating
the
expected
emission
reductions
from
any
RE
improvements?

__
Yes
__
No
Comments:

15.
In
estimating
expected
emission
reductions
associated
with
new
control
measures,
is
the
compliance
period
(
e.
g.,
daily
compliance)
factored
into
the
calculation
consistent
with
EPA
guidance?

__
Yes
__
No
Comments:
C­
12
MILESTONE
A
1.
Does
the
post­
1996
automatically
impleme
__
Yes
__
No
Comments:

2.
Will
the
contingency
measures
ac
addition
to
the
emission
reductions
in
__
Yes
__
No
Comments:

3.
Are
the
contingency
measures
consistent
with
th
__
Yes
__
No
Comments:

4.
Do
the
contingency
measures
meet
the
minimum
requireme
in
the
General
Preamble
(
56
FR
13498)?

__
Yes
__
No
Comments:

5.
Does
the
post­
1996
rate­
of­
progress
plan
ensure
that
contingency
measure
implemented
with
no
additional
rulemaking
actions
such
as
public
hearings
o
review
by
the
State?

__
Yes
__
No
Comments:
D­
1
APPENDIX
D:

OF­
PROGRESS
R
This
appendix
contains
unsign
concerning
the
15
percent
rate­
o
1996
requirements.
D­
2
3/
2/
93
MEMORANDUM
SUBJECT:
Correction
to
"
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate
of
Progress
Plans"

FROM:
G.
T.
Helms,
Chief
Ozone
and
Carbon
Monoxide
Programs
Branch
(
MD­
15)

TO:
Air
Branch
Chief,
Regions
I­
X
This
memorandum
corrects
an
error
in
the
document
entitled,
"
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate
of
Progress
Plans"
(
EPA
452/
R­
92­
005),
which
was
released
in
October
1992.
Section
2.3
of
this
document,
Requirements
of
Section
182(
b)(
1)(
A)(
ii),
states
the
following
on
page
17:

Nonattainment
areas
can
achieve
less
than
the
15
percent
required
reductions
under
the
following
restrictive
circumstances.
The
State
must
demonstrate
that
the
area
has
a
new
source
review
program
equivalent
to
the
requirements
in
extreme
areas
[
section
182(
e)],
except
that
"
major
source"
must
include
any
source
that
emits,
or
has
the
potential
to
emit,
5
tons
per
year
(
tpy)
of
VOC
or
NOx.
Additionally,
all
major
sources
of
VOC
and
NOx
(
down
to
5
tpy)
in
the
area
must
be
required
to
have
RACT­
level
controls.

The
correction
removes
the
references
to
NOx
from
this
discussion
for
consistency
with
the
Clean
Air
Act.
Therefore,
the
corrected
portion
of
the
paragraph
now
reads
".
.
.
potential
to
emit,
5
tons
per
year
(
tpy)
of
VOC.
Additionally,
all
major
sources
of
VOC
(
down
to
5
tpy)
.
.
.
."

Please
share
this
information
with
your
State
and
appropriate
local
air
pollution
control
agencies.
Any
questions
about
this
correction
may
be
addressed
to
Kimber
Scavo
at
(
919)
541­
3354.
D­
3
3/
11/
93
MEMORANDUM
SUBJECT:
15
Percent
Rate­
of­
Progress
Plans
FROM:
G.
T.
Helms,
Chief
Ozone/
Carbon
Monoxide
Programs
Branch
(
MD­
15)

TO:
Air
Branch
Chief,
Regions
I­
X
The
purpose
of
this
memorandum
is
to
clarify
an
issue
related
to
the
15
percent
rate­
of­
progress
plans.
At
least
one
Region
has
interpreted
the
statement
that
moderate
areas
are
not
required
to
demonstrate
in
1997
that
the
15
percent
reduction
in
volatile
organic
compounds
(
VOC)
has
been
achieved
to
mean
that
these
areas
do
not
have
to
submit
a
rate­
of­
progress
plan
by
November
15,
1993.
This
interpretation
is
erroneous.

All
areas
classified
as
at
least
moderate
must
submit
a
plan
demonstrating
how
a
15
percent
reduction
in
VOC
emissions
(
net
of
growth)
will
be
achieved
by
1996
unless
the
waiver
provisions
of
section
182(
b)(
1)(
A)(
ii)
are
met.
Section
182(
g)(
1),
however,
requires
that
"
the
State
shall
determine
whether
each
nonattainment
area
(
other
than
an
area
classified
as
marginal
or
moderate)
has
achieved
a
reduction
in
emissions
during
the
preceding
intervals
equivalent
to
the
total
emission
reductions
required
to
be
achieved
by
the
end
of
such
interval
.
.
.
."
In
other
words,
moderate
areas
must
submit
a
plan
by
November
15,
1993
showing
how
the
15
percent
will
be
achieved,
but
will
not
be
required
to
demonstrate
in
1997
that
the
15
percent
was
actually
achieved.

The
test
for
moderate
areas
will
be
whether
they
attained
the
standard
because
the
attainment
date
for
moderate
areas
coincides
with
the
milestone
demonstration
date.
Failure
to
attain
will
cause
an
area
to
be
required
to
implement
its
contingency
measures,
and
may
cause
the
area
to
be
bumped
up
to
a
higher
classification.
Also,
failure
of
a
moderate
area
to
implement
its
15
percent
plan
may
result
in
a
finding
that
the
State
failed
to
implement
its
State
implementation
plan,
which
would
result
in
the
imposition
of
sanctions.

Please
make
this
information
available
to
the
appropriate
State
and
local
agencies
in
your
Region.
If
you
have
any
questions
concerning
this
issue,
please
contact
Laurel
Schultz
at
(
919)
541­
5511.
D­
4
5/
6/
93
MEMORANDUM
SUBJECT:
Credit
Toward
the
15
Percent
Rate­
of­
Progress
Reductions
from
Federal
Measures
FROM:
G.
T.
Helms,
Chief
Ozone/
Carbon
Monoxide
Programs
Branch
(
MD­
15)

Susan
Wyatt,
Chief
Chemicals
and
Petroleum
Branch
(
MD­
13)

TO:
Air
Branch
Chief,
Regions
I­
X
As
you
know,
many
States
have
been
asking
whether
they
will
be
able
to
take
credit
in
their
15
percent
rate­
of­
progress
plans
for
reductions
of
volatile
organic
compounds
(
VOC)
from
federal
measures
and
imminent
control
techniques
guidelines.
We
have
identified
several
categories
for
which
we
believe
reductions
will
be
achieved
by
1996.
The
attached
table
lists
these
categories
along
with
the
amount
of
reductions
for
which
States
can
take
credit
in
the
plans.
Please
share
this
information
with
the
appropriate
State
and
local
agencies
in
your
Region.
If
you
have
any
questions,
please
contact
Laurel
Schultz
at
(
919)
541­
5511.

Attachment
23
The
number
in
this
column
represents
the
percent
reduction
that
EP
for
the
purposes
of
the
15%
plans
only.

24
The
term
"
major
source"
is
defined
for
hazardous
air
pollutants
in
section
Air
Act.

D­
5
New
VOC
Related
Requirements
Category
Percent
Reduction23
CTG's
SOCMI
Distillation
98%
from
each
controlled
vent
SOCMI
Reactor
Vents
98%
from
each
controlled
vent
National
Rules
TSDF
Phase
II
93%
from
1990
baseline
NESHAP's
Hazardous
Organic
NESHAP
for
SOCMI
5%
from
1990
baseline
Ethylene
Oxide
Commercial
Sterilizers
97%
from
each
major
source24
D­
6
6/
14/
93
MEMORANDUM
SUBJECT:
Correction
to
"
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate
of
Progress
Plans"

FROM:
G.
T.
Helms,
Chief
Ozone
and
Carbon
Monoxide
Programs
Branch
(
MD­
15)

TO:
Air
Branch
Chief,
Regions
I­
X
This
memorandum
corrects
an
error
in
the
document
entitled
"
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate
of
Progress
Plans"
(
EPA
452/
R­
92­
005),
which
was
released
in
October
1992.
Appendix
B
of
this
document
explains
how
to
calculate
the
emissions
reductions
achieved
through
the
correction
of
existing
reasonably
available
control
technology
(
RACT)
rules.
Two
of
the
examples
in
this
appendix
incorrectly
use
growth
factors
in
determining
the
reductions
from
rule
corrections.
As
with
the
inspection
and
maintenance
corrections
and
reductions
from
the
Federal
motor
vehicle
control
plan
and
Reid
vapor
pressure,
the
RACT
corrections
should
not
include
growth.
A
corrected
version
of
Appendix
B
is
attached.
Because
the
adjustment
for
RACT
corrections
is
relatively
small,
this
correction
should
not
have
a
significant
impact
on
States'
calculations.

Please
share
this
information
with
your
State
and
appropriate
local
air
pollution
control
agencies.
Any
questions
about
this
correction
may
be
addressed
to
Laurel
Schultz
of
my
staff
at
(
919)
541­
5511.

Attachment
D­
7
APPENDIX
B:
CALCULATION
OF
EMISSIONS
REDUCTIONS
FROM
RACT
RULE
CORRECTIONS
Section
4.1
of
this
document
discusses
cases
where
RACT
rule
corrections
do
not
directly
result
in
quantifiable
emissions
reductions.
Any
incidental
reductions
that
occur
in
these
cases
may
be
handled
as
part
of
a
rule
effectiveness
improvement.
Corrections
to
RACT
rules
that
may
result
in
additional,
enforceable,
and
quantifiable
emissions
reductions
include
situations
where:

!
A
rule
was
missing
[
i.
e.,
a
State
committed
to
develop
a
rule
as
part
of
its
1977
State
implementation
plan
(
SIP),
or
post­
1982
SIP,
but
never
carried
through
on
the
commitment
prior
to
the
Clean
Air
Act
Amendments
of
1990.

!
The
limit
was
wrong.

!
A
capture
system
is
now
required
to
ensure
meeting
a
RACT
limit.

For
the
case
where
a
rule
was
missing,
the
State
should
first
calculate
the
uncontrolled
emissions
in
1990.
Next,
the
State
must
evaluate
the
expected
emissions
reduction
in
1996
by
calculating
1996
emissions
(
including
controls)
and
subtracting
this
number
from
1990
emissions.
This
total
expected
emissions
reduction
should
be
added
to
the
total
reductions
in
step
5
in
the
example
in
section
2.1
of
this
document.
These
reductions
are
not
creditable
toward
the
15
percent
volatile
organic
compounds
(
VOC)
emissions
reduction
requirement.

For
the
second
case,
the
State
should
first
evaluate
the
pound
(
lb)
VOC/
gallon
(
gal)
solids
for
each
limit.

1990
limit
=
3.5
lb
VOC/
gal
coating
1)
1990
lb
VOC/
gal
solids
=

3.5
lb
VOC
x
1
gal
coating
=
0.476
gal
VOC
gal
coating
7.36
lb
VOC
gal
coating
2)
Calculate
solids
in
1
gal
coating:
1
­
0.476
=
0.524
gal
solids
3)
Calculate
gallons
of
coating
needed
to
get
gallon
of
solids:
1
gal
coating
=
1.908
gal
coating
0.524
gal
solids
gal
solids
D­
8
4)
Convert
3.5
lb/
gal
coating
to
lb
VOC/
gal
solids:
3.5
lb
VOC
x
1.908
gal
coating
=
6.678
lb
VOC
gal
coating
gal
solids
gal
solids
The
1996
limit
will
be
2.9
lb/
gal.

Similarly,
convert
2.9
lb
VOC/
gal
coating
to
lb
VOC/
gal
solids.

5)
2.9
lb
VOC
x
1
gal
VOC
=
0.394
gal
VOC
gal
coating
7.36
lb
VOC
gal
coating
6)
Volume
of
solids
in
1
gal
coating:
1
­
0.394
=
0.606
gal
solids
7)
Calculate
gallons
of
coating
needed
to
get
1
gallon
of
solids:
1
gal
coating
=
1.650
gal
coating
0.606
gal
solids
gal
solids
8)
Convert
2.9
lb
VOC
gal
coating
to
lb
VOC/
gal
solids:
2.9
lb
VOC
x
1.650
gal
coating
=
4.785
lb
VOC
gal
coating
gal
solids
gal
solids
The
facility
uses
100
gal
solids
in
1990
day
9)
Compare
1990
and
1996
Emissions:

1990
=
6.678
lbs
VOC
x
100
gal
solids
=
667.8
lbs
VOC
gal
solids
day
day
1996
=
4.785
lb
VOC
x
100
gal
solids
=
478.5
lb
VOC
gal
solids
day
day
1990
Emissions
­
1996
Emissions
=
667.8
­
478.5
=
189.3
lb
VOC
day
Therefore,
189.3
lb
VOC/
day
are
noncreditable.

For
the
third
case
where
a
capture
system
is
required,
expected
emissions
reductions
should
be
calculated
in
the
following
way.
First,
uncontrolled
emissions
should
be
determined.

1990
Paper
Coaters:

!
Eighty
percent
of
emissions
coming
out
of
the
oven
and
vented
to
an
incinerator
of
98
percent
demonstrated
destruction
efficiency.

!
Twenty
percent
of
emissions
are
fugitive
from
uncontrolled
flash­
off
area.
D­
9
Total
uncontrolled
emissions
in
1990
=

1,000
lb/
day
if
total
is
uncontrolled,
however,
when
system
is
controlled,
80
percent
of
this
is
captured,
and
98
percent
of
captured
emissions
are
destroyed.

Therefore,
emissions
from
the
incinerator
after
control
are
1,000
lb/
day
x
(
1­(
0.80))
x
(
1­(
0.98))
=

(
1,000
lb/
day)
x
(
0.20)
x
(
0.02)
=
4
lb/
day
controlled.
Total
Emissions
from
incinerator
+
fugitives
=
4
lb/
day
+
(
1,000
lb/
day
x
(
0.20))
=
204
lb/
day
1996
Emissions:
New
State
rule
now
requires
permanent
total
enclosure,
so
the
controlled
emissions
are:

1,000
lb
day
(
1.0)
(
0.02)
=
20
lb/
day
Noncreditable
Emissions
Reductions
=
1990
Emissions
­
1996
Emissions
=
204
lb/
day
­
20
lb/
day
184
lb/
day
The
preceding
examples
are
not
intended
to
be
fully
inclusive.
States
should
evaluate
all
RACT
rule
corrections
to
determine
if
such
measures
result
in
real,
enforceable,
and
permanent
emissions
reductions.
If
so,
such
reductions
must
be
quantified
and
considered
in
the
SIP
development
process
when
preparing
the
1996
target
level
of
emissions.
If
a
State
is
unclear
on
how
to
calculate
such
reductions,
then
the
State
should
consult
with
the
Regional
Office
and
Headquarters
for
guidance.
D­
10
7/
28/
93
MEMORANDUM
SUBJECT:
Correction
Errata
to
the
15
Percent
Rate­
of­
Progress
Plan
Guidance
Series
FROM:
G.
T.
Helms,
Chief
Ozone
and
Carbon
Monoxide
Programs
Branch
(
MD­
15)

TO:
Air
Branch
Chief,
Regions
I­
X
This
memorandum
corrects
several
errors
in
the
15
percent
rate­
of­
progress
plan
guidance
series.

1.
There
is
an
error
in
the
Table
entitled,
"
Major
Source
Thresholds
and
Minimum
Emissions
Offset
Ratio
Requirements
for
Ozone
Nonattainment
Area
Classifications,"
in
the
following
15
percent
guidance
documents:

!
"
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate
of
Progress
Plans"
(
EPA­
452/
R­
92­
005),
p.
A­
3.

!
"
Guidance
for
Growth
Factors,
Projections,
and
Control
Strategies
for
the
15
Percent
Rate­
of­
Progress
Plans"
(
EPA­
452/
R­
93­
002),
p.
A­
3.

!
"
Guidance
on
the
Relationship
Between
the
15
Percent
Rate­
of­
Progress
Plans
and
Other
Provisions
of
the
Clean
Air
Act"
(
EPA­
452/
R­
93­
007),
p.
12.

!
"
Guidance
on
Preparing
Enforceable
Regulations
and
Compliance
Programs
for
the
15
Percent
Rate­
of­
Progress
Plans"
(
EPA­
452/
R­
93­
005),
p.
A­
4.

The
error
is
in
the
item,
"
All
Other
Nonattainment
Areas,
in
an
Ozone
Transport
Region."
The
volatile
organic
compounds
tons
per
year
(
tpy)
should
be
50
tpy
rather
than
100
tpy.

2.
The
document
entitled
"
Guidance
on
the
Relationship
Between
the
15
Percent
Rate­
of­
Progress
Plans
and
Other
Provisions
of
the
Clean
Air
Act"
(
EPA­
452/
R­
93­
007),
has
an
error
concerning
the
creditability
of
certain
transportation
control
D­
11
measures.
Section
5.8
of
this
document
states
the
following
on
page
39:

Emissions
reductions
resulting
from
TCM's
are
creditable
if
the
TCM
is
not
already
federally
mandated
(
e.
g.,
the
employee
trip
reduction
program
required
under
section
182(
d)(
1)(
B)
for
severe
and
extreme
ozone
nonattainment
areas),
or
is
not
part
of
an
already
existing
SIP.
As
with
all
other
emissions
reductions,
emissions
reductions
associated
with
TCM's
are
only
creditable
to
the
15
percent
rate­
of­
progress
plan
if
they
are
quantifiable,
real,
enforceable,
replicable,
accountable,
and
occur
by
November
15,
1996.

The
correction
revises
the
first
sentence
of
the
preceding
paragraph:

Emissions
reductions
resulting
from
TCM's
are
creditable
if
the
TCM
was
not
a
pre­
1990
control
measure
in
an
already
existing
SIP.
As
with
all
other
emissions
reductions,
emissions
reductions
associated
with
TCM's
are
only
creditable
to
the
15
percent
rateof
progress
plan
if
they
are
quantifiable,
real,
enforceable,
replicable,
accountable,
and
occur
by
November
15,
1996.

3.
In
the
document,
"
Guidance
for
Growth
Factors,
Projections,
and
Control
Strategies
for
the
15
Percent
Rate­
of­
Progress
Plans"
(
EPA­
452/
R­
93­
002,
March
1993),
there
are
several
errors
in
Chapter
6.

a.
On
page
55,
the
text
under
the
table,
last
sentence,
"
The
[(
200­
RE
PY)/
100]
factor
is
not
valid
for
low
RE
values"
is
incorrect
and
should
be
deleted.

b.
On
page
57,
the
sentence
before
the
heading,
"
Equation
5
­
Projection
calculated
from
permitted
emissions
rates,"
("
The
[(
200
­
RE)/
100]
factor
is
not
valid
for
low
RE
values")
is
incorrect
and
should
be
deleted.

c.
On
page
57,
the
second
and
third
paragraphs
under
the
heading,
"
Equation
5
­
Projection
calculated
from
permitted
emissions
rates,"
should
read
as
follows:
D­
12
EMIS
PY

ER
PY

(
200

RE
PY)

100
(
200

RE
BY)

100

EMIS
BY,
O
EMIS
BY,
Annual
(
5)
The
equation
for
projecting
emissions
in
this
case
is:

where:
EMIS
PY
=
Projection
year
emissions
ozone
season
typical
weekday
(
mass
of
pollutant/
day)
ER
PY
=
Projection
year
annual
emissions
cap
(
mass
of
pollutant/
year)
RE
BY
=
Base
year
RE
(
percent)
RE
PY
=
Projection
year
RE
(
percent)
EMIS
BY,
O
=
Base
year
ozone
season
typical
weekday
emissions
(
mass
of
pollutant/
day)
EMIS
BY,
Annual
=
Base
year
annual
emissions
(
mass
of
pollutant/
year)

The
factor
EMIS
BY,
O/
EMIS
BY,
Annual
converts
the
long­
term
annual
emissions
cap
to
an
ozone
season
typical
weekday
emissions
cap
using
the
ratio
of
base
year
ozone
season
typical
weekday
to
annual
emissions.
Note
that
the
mass
units
(
i.
e.,
tons,
pounds)
must
be
equivalent
in
both
terms.
These
projections
must
also
account
for
RE.
The
factor,
"[(
200
­
RE)/
100],"
adjusts
emissions
for
RE.
See
the
explanation
under
equation
(
2)
for
additional
information
about
this
factor.

d.
On
page
65
under:
"
6.
Mass
Emissions
Limit­
Based
Permits,"
the
second
and
third
paragraphs
should
be
replaced
with
the
following:

The
long­
term
annual
limits
will
be
used
for
emissions
projections
since
these
are
more
representative
of
expected
rather
than
maximum
activity.
These
limits
must
be
converted
to
reflect
ozone
season
typical
weekday
conditions.
Annual
limits
are
converted
using
the
ratio
of
base
year
ozone
season
emissions
to
base
year
annual
emissions.

Base
Year
Operating
Conditions
Ozone
season
emissions
=
150
lb/
day
=
0.075
tons/
day
Annual
emissions
=
23
tpy
RE
=
80%
Projection
Year
Conditions
Current
permit
=
30
tpy
RE
=
80%
D­
13
EMIS
PY

ER
PY

(
200

RE
PY)
100
(
200

RE
BY)
100

EMIS
BY,
O
EMIS
BY,
Annual
(
5)

EMIS
PY

30

(
200

80)

100
(
200

80)

100

0.075
23

0.098
tons/
day

196
lb/
day
Equation
(
5)
is
used
to
calculate
projection
year
emissions
as
follows:

Please
share
this
information
with
your
State
and
local
air
pollution
control
agencies.
Any
questions
about
these
corrections
may
be
addressed
to
Kimber
Scavo
at
(
919)
541­
3354
or
Laurel
Schultz
at
(
919)
541­
5511.
D­
14
8/
23/
93
MEMORANDUM
SUBJECT:
Guidance
on
Issues
Related
to
15
Percent
Rate­
of­
Progress
Plans
FROM:
Michael
H.
Shapiro
Acting
Assistant
Administrator
for
Air
and
Radiation
(
ANR­
443)

TO:
Director,
Air
Pesticides
and
Toxics
Management
Division,
Regions
I
and
IV
Director,
Air
and
Waste
Management
Division,
Region
II
Director,
Air,
Radiation
and
Toxics
Division,
Region
III
Director,
Air
and
Radiation
Division,
Region
V
Director,
Air,
Pesticides
and
Toxics
Division,
Region
VI
Director,
Air
and
Toxics
Division,
Regions
VII,
VIII,
IX,
and
X
As
you
know,
section
182(
b)(
1)
of
the
Clean
Air
Act
(
Act)
requires
States
to
submit,
by
November
15,
1993
for
all
ozone
nonattainment
areas
classified
as
moderate
and
above,
a
State
implementation
plan
(
SIP)
that
provides
for
a
15
percent
reduction
in
emissions
of
volatile
organic
compounds
(
VOC)
by
November
15,
1996.
The
purpose
of
this
memorandum
is
to
provide
guidance
related
to
these
SIP
submissions.

Committal
SIP's
for
15
Percent
Plan
Control
Measures
Several
States
asked
to
what
extent
will
the
Environmental
Protection
Agency
(
EPA)
accept
committal
SIP's
for
the
measures
necessary
to
achieve
the
15
percent
reduction.
Under
section
110(
k)(
4)
of
the
Act,
EPA
has
the
authority
to
conditionally
approve
a
SIP
submittal
based
on
a
commitment
by
the
State
to
adopt
specific
enforceable
measures
by
a
date
certain.
A
previous
memorandum
identified
specific
cases
in
which
EPA
would
accept
commitments
for
submittals
which
were
due
by
November
15,
1992.
For
the
15
percent
rate­
of­
progress
plans,
EPA
will
not
accept
commitments
to
adopt
the
measures
needed
to
meet
the
15
percent
reduction
requirement
and
any
such
plans
would
not
be
D­
15
considered
approvable.
In
fact,
EPA
may
determine
such
submittals
to
be
incomplete,
which
would
trigger
a
findings
letter
starting
the
clock
for
mandatory
sanctions.
The
only
exception
would
be
for
the
State
of
Texas
where
EPA
Headquarters,
based
on
initial
views
at
the
time,
indicated
a
commitment
would
be
acceptable.

NOx
Substitution
for
Contingency
Measures
Section
172(
c)(
9)
of
the
Act
requires
moderate
and
above
ozone
nonattainment
areas
to
adopt
contingency
measures
by
November
15,
1993.
These
measures
would
have
to
be
implemented
if
the
area
fails
to
make
reasonable
further
progress
(
RFP)
or
to
attain
the
national
ambient
air
quality
standards
(
NAAQS)
by
the
applicable
attainment
date.
In
addition,
section
182(
c)(
9)
of
the
Act
requires
serious
and
above
areas
to
adopt
contingency
measures
which
would
be
implemented
if
the
area
fails
to
meet
any
applicable
milestone.
When
triggered,
the
contingency
measures
must
be
implemented
without
further
action
by
the
State
or
the
EPA.

The
"
General
Preamble
for
the
Implementation
of
Title
I
of
the
Clean
Air
Act
Amendments
of
1990"
(
57
FR
13498,
April
16,
1992)
requires
that
the
contingency
measures
generally
must
provide
reductions
of
3
percent
of
the
emissions
from
the
adjusted
base
year
inventory.
The
reductions
must
be
achieved
in
the
year
following
that
in
which
the
failure
has
been
identified.
Three
percent
represents
1
year's
worth
of
reductions
under
the
post­
1996
rate­
of­
progress
requirement.

The
contingency
measures
that
are
required
to
be
adopted
by
November
15,
1993
are
for
both
failure
to
achieve
RFP
and
failure
to
attain.
While
the
contingency
measures
to
address
failure
to
achieve
RFP
must
be
for
VOC,
the
contingency
measures
for
failure
to
attain
may
be
for
VOC
and/
or
NOx.
Since
these
measures
will
be
implemented
after
1996,
and
because
these
measures
serve
two
purposes
(
i.
e.,
failure
to
achieve
RFP
and
failure
to
attain),
the
contingency
measures
could
provide
for
less
than
3
percent
in
VOC
reductions
as
long
as
some
of
the
measures
are
for
VOC
and
the
area
would
have
the
difference
(
up
to
3
percent)
in
NOx
reductions.
Based
on
discussions
with
EPA's
Office
of
General
Counsel,
we
have
determined
that
States
must
adopt
a
minimum
of
0.3
percent
in
VOC
measures
of
the
3
percent
contingency
measure
requirement
to
be
legally
defensible.
Therefore,
in
an
area
that
has
demonstrated
that
NOx
controls
are
needed
for
attainment,
2.7
percent
of
the
required
3
percent
could
be
NOx
contingency
measures;
at
least
0.3
percent
must
still
be
VOC
to
cover
the
contingency
requirement
for
meeting
RFP.
Note
that
this
applies
to
moderate
areas
as
well;
moderate
areas
must
submit
an
approvable
plan
that
shows
how
they
will
achieve
the
15
percent
requirement
but
are
not
required
to
submit
a
demonstration
that
the
milestone
was
achieved.
Moderate
areas,
of
course,
must
D­
16
demonstrate
that
they
have
attained
the
NAAQS
for
ozone
by
November
15,
1996.

In
order
for
NOx
contingency
measures
to
be
acceptable,
the
State
must
adhere
to
EPA's
forthcoming
guidance
on
NOx
substitution.
In
addition,
States
must
show
with
modeling
evidence
that
NOx
reductions
are
needed
in
a
particular
nonattainment
area.
Therefore,
in
order
to
give
States
enough
time
to
consult
EPA's
guidance
on
NOx
substitution
and
to
determine
if
NOx
reductions
are
needed,
EPA
will
accept
committals
for
contingency
measures
that
are
due
November
15,
1993.
If
the
contingency
measures
themselves
are
not
included
with
the
November
15,
1993
submittal,
that
submittal
must
include
a
commitment,
with
schedule,
for
contingency
measures
to
be
adopted
by
November
15,
1994.

We
believe
that
this
is
acceptable
due
to
the
fact
that
the
earliest
a
contingency
measure
would
be
implemented
would
be
in
1997.
The
first
attainment
date
and
milestone
date
for
areas
that
are
required
to
adopt
contingency
measures
is
November
15,
1996.
The
EPA
will
expect
all
actions
needed
to
make
the
measures
fully
effective
to
occur
within
60
days
after
EPA
notifies
the
State
of
its
milestone
failure
or
within
6
months
of
its
attainment
failure.
Therefore,
the
State
would
not
need
to
implement
the
contingency
measures
until
1997
and
EPA
could
accept
measures
that
could
not
be
implemented
until
1997.

Upon
activation
of
the
contingency
measures,
reductions
of
up
to
3
percent
(
or
such
lesser
percentage
that
will
cure
the
identified
failure)
must
be
achieved
1
year
following
the
date
on
which
the
failure
had
been
identified.
The
State
must
achieve
these
reductions
while
conducting
additional
control
measure
development
and
implementation
as
necessary
to
correct
the
shortfall
if
it
is
beyond
the
3
percent
the
State
would
have
already
adopted.
In
determining
what
measures
should
be
implemented
if
less
than
3
percent
reduction
is
needed
to
cure
the
failure,
all
VOC
contingency
measures
should
be
required
first
followed
by
the
appropriate
percentage
of
NOx
measures
that
will
correct
the
shortfall.

15
Percent
Waiver
Provision
Under
section
182(
b)(
1)(
A)(
ii),
areas
can
submit
plans
demonstrating
less
than
a
15
percent
emission
reduction
if
the
following
conditions
are
met.
First,
the
State
must
demonstrate
that
the
area
has
a
new
source
review
program
equivalent
to
the
requirement
in
extreme
areas
[
section
182(
e)],
except
that
a
"
major
source"
must
include
any
source
that
emits,
or
has
the
potential
to
emit,
5
tons
per
year
(
tpy)
of
VOC.
Second,
all
major
sources
(
down
to
those
with
emissions
of
5
tpy
of
VOC
or
greater)
in
the
area
must
be
required
to
have
RACT­
level
controls.
Third,
the
State
must
demonstrate
that
the
SIP
D­
17
includes
all
measures
(
both
stationary
and
mobile)
that
are
achieved
in
practice
by
sources
in
the
same
source
category
in
nonattainment
areas
of
the
next
higher
classification.
Fourth,
the
plan
must
include
all
measures
that
can
be
feasibly
implemented
in
the
area,
in
light
of
technological
achievability
and
cost.

If
an
area
chooses
to
meet
the
requirements
of
section
182(
b)(
1)(
A)(
ii)
to
get
a
waiver
of
the
15
percent
provision,
EPA
interprets
title
V
to
require
operating
permits
for
all
VOC
sources
in
that
area
that
emit
or
have
the
potential
to
emit
5
tpy
of
VOC.
This
is
because
the
definition
of
"
major
source"
in
title
V
expressly
refers
to
"
major
stationary
source"
as
defined
in
part
D
of
title
I.
Since,
under
the
waiver
provision,
"
major
stationary
source"
would
be
defined
as
having
the
potential
to
emit
5
tpy
for
the
purposes
of
title
I,
this
would
become
the
definition
of
major
source
for
the
purposes
of
title
V.

I
suggest
that
you
provide
a
copy
of
this
memo
to
your
affected
State
and
local
agencies.
Inquiries
may
be
directed
to
John
Silvasi
at
(
919)
541­
5666.
D­
18
9/
20/
93
MEMORANDUM
SUBJECT:
Reclassification
of
Areas
to
Nonattainment
and
15
Percent
Rate­
of­
Progress
Plans
FROM:
John
S.
Seitz,
Director
Office
of
Air
Quality
Planning
and
Standards
(
MD­
10)

TO:
Winston
A.
Smith,
Director
Air,
Pesticides
and
Toxics
Management
Division,
Region
IV
This
is
in
response
to
your
August
20,
1993
memorandum
requesting
guidance
on
the
reclassification
of
areas
to
nonattainment
and
the
15
percent
rate­
of­
progress
plans.
Your
specific
questions
are
addressed
as
follows:

1.
If
an
attainment
area
becomes
a
moderate
nonattainment
area,
what
is
the
year
of
the
baseline
inventory?
Will
it
be
1990
or
some
other
year?
If
it
is
a
year
other
than
1990,
how
will
it
be
determined?

Answer:
Section
181(
b)(
1)
of
the
Clean
Air
Act
(
Act)
covers
areas
that
were
attainment
after
enactment
and
that
are
redesignated
to
nonattainment.
These
areas
are
subject
to
the
requirements
under
section
110
upon
classification,
except
that
any
absolute,
fixed
date
applicable
in
connection
with
any
such
requirement
is
extended
by
operation
of
law
by
a
period
equal
to
the
length
of
time
between
the
date
of
the
enactment
of
the
Act
and
the
date
the
area
is
classified.
Therefore,
the
base­
year
inventory
year
would
be
the
year
in
which
the
area
was
redesignated
to
nonattainment.

2.
Are
there
any
regulatory
programs
that
if
adopted
for
nonattainment
areas
would
be
creditable
toward
the
15
percent
requirement
but
if
adopted
prior
to
the
nonattainment
designation
would
not
be
creditable?

Answer:
A
regulatory
program
adopted
for
a
nonattainment
area
that
would
be
creditable
toward
the
15
percent
requirement
could
be
considered
noncreditable
for
an
area
that
was
redesignated
to
nonattainment
if
the
regulatory
program
was
1
The
Federal
RVP
standards
were
promulgated
under
both
section
211(
c)
and
211(
h)
of
the
Act.
States
are
generally
preempted
under
section
211(
c)(
4)(
A)
from
establishing
State
fuel
standards
that
are
not
identical
to
those
established
under
section
211(
c).
California
is
not
subject
to
this
preemption
pursuant
to
section
211(
c)(
4)(
B).

D­
19
adopted
and
implemented
prior
to
the
base­
year
inventory
year
in
the
redesignated
area.
Thus,
the
base­
year
inventory
must
reflect
actual
emissions
including
the
effect
of
reductions
occurring
prior
to
that
year.
Only
reductions
that
occur
after
the
base
year
are
creditable
toward
the
15
percent
requirement
[
assuming
that
they
meet
the
other
creditability
requirements
of
section
182(
b)(
1)(
D)].
Also,
if
a
regulatory
program
that
met
the
creditability
provisions
was
adopted
and
implemented
prior
to
the
base
year
but
continued
to
result
in
emissions
reductions
after
the
base
year,
then
those
emissions
reductions
occurring
after
the
base
year
would
be
creditable
to
the
15
percent
requirement.

3.
If
a
State
implements
nonregulatory/
voluntary
programs
and
is
subsequently
designated
nonattainment
for
ozone,
can
the
State
use
these
programs
to
meet
the
15
percent
requirement
by
passing
legislation
and
submitting
a
State
implementation
plan
(
SIP)
revision?

Answer:
The
program
would
be
creditable
only
if
the
reductions
occur
after
the
base
year.

4.
Can
a
State
pass
legislation
lowering
the
Reid
vapor
pressure
(
RVP)
of
gasoline
below
the
9.0
allowed
in
attainment
areas
for
purposes
of
maintaining
the
standard?
If
they
can,
what
are
the
procedures
that
must
be
followed?

Answer:
States
are
generally
preempted
under
section
211(
c)(
4)(
A)
from
establishing
controls
on
the
RVP
of
gasoline
for
purposes
of
motor
vehicle
emissions
control
unless
the
State
RVP
control
is
identical
to
the
Federal
requirement.
1
A
State
may,
however,
adopt
and
enforce
a
nonidentical
RVP
control
if
an
applicable
SIP
so
provides.
The
EPA
may
approve
such
a
SIP
provision
only
if
the
State
RVP
control
is
"
necessary
to
achieve"
the
national
ambient
air
quality
standards
(
NAAQS)
that
the
SIP
implements.

The
EPA
has
previously
approved
several
State
RVP
controls
where
the
State
was
able
to
show
that
an
RVP
control
more
stringent
than
the
Federal
requirement
was
necessary
to
achieve
attainment
for
designated
ozone
nonattainment
areas
in
that
State
[
see,
e.
g.,
EPA's
approval
of
a
Maryland
State
RVP
control
published
at
56
FR
23804
(
May
24,
1991)].
That
decision
D­
20
describes
the
criteria
used
by
EPA
in
determining
whether
such
a
SIP
revision
is
necessary
to
achieve
the
NAAQS.

For
an
area
that
is
currently
designated
attainment,
a
State
would
generally
have
to
demonstrate
that
the
RVP
measure
is
needed
in
the
attainment
area
in
order
to
achieve
the
standard
in
another
area
that
is
not
in
attainment.
The
EPA
approved
a
SIP
revision
for
statewide
RVP
controls
in
the
State
of
New
York
based
on
such
a
showing.
However,
it
is
questionable
whether
EPA
would
have
authority
to
approve
a
State
RVP
control
adopted
solely
to
maintain
compliance
with
the
NAAQS
in
attainment
areas.
If
a
State
would
like
to
pursue
this
latter
issue,
then
we
would
work
with
the
Office
of
General
Counsel
to
determine
under
what
conditions
EPA
could
approve
such
a
SIP
submittal.

The
process
for
obtaining
a
waiver
of
Federal
preemption
for
State
RVP
controls
involves
submission
by
the
State
of
a
SIP
revision
in
section
110
of
the
Act.
The
Federal
Register
notice
referred
to
above
provides
detailed
information
on
the
criteria
used
by
EPA
in
acting
on
such
a
SIP
revision.

If
you
have
any
further
questions
or
concerns,
please
give
me
a
call.
D­
21
10/
6/
93
MEMORANDUM
SUBJECT:
Clarification
of
"
Guidance
for
Growth
Factors,
Projections
and
Control
Strategies
for
the
15
Percent
Rate
of
Progress
Plans"

FROM:
G.
T.
Helms,
Chief
Ozone/
Carbon
Monoxide
Programs
Branch
(
MD­
15)

TO:
Air
Branch
Chief,
Regions
I­
X
This
memorandum
clarifies
the
document
entitled,
"
Guidance
for
Growth
Factors,
Projections
and
Control
Strategies
for
the
15
Percent
Rate
of
Progress
Plans,"
(
EPA­
452/
R­
93­
002)
which
was
released
in
March
1993.
Section
6.5
of
this
document
discusses
the
effects
of
equipment
replacement
and
new
source
requirements
on
the
15
percent
plans.
However,
this
discussion,
as
it
relates
to
new
source
review,
is
inconsistent
with
the
document
entitled,
"
Guidance
on
the
Relationship
Between
the
15
Percent
Rate­
of­
Progress
Plans
and
Other
Provisions
of
the
Clean
Air
Act,"
(
EPA­
452/
R­
93­
007)
which
was
released
in
May
1993.
As
discussed
in
this
document,
emissions
reductions
projected
to
occur
from
the
part
D
new
source
review
offset
requirements
are
not
creditable
toward
the
15
percent
rate­
of­
progress
plan
requirements.
However,
at
the
time
of
reconciliation,
any
additional,
actual,
permanent,
and
enforceable
emissions
occurring
after
1990
resulting
from
offsets
that
are
not
used
to
offset
minor
source
growth
will
be
creditable
in
the
milestone
compliance
demonstration
due
in
February
1997
for
serious
and
above
areas.
The
EPA's
Office
of
General
Counsel
concurs
with
this
position.

A
corrected
version
of
section
6.5
of
the
growth
factors
document,
which
is
consistent
with
the
relationship
document,
is
attached.

Please
share
this
information
with
your
State
and
appropriate
local
air
pollution
control
agencies.
Any
questions
about
this
correction
may
be
addressed
to
Laurel
Schultz
of
my
staff
at
(
919)
541­
5511,
or
me
at
(
919)
541­
5527.

Attachment
D­
22
Ert

[
(
Eb

En)

(
1

r)
exp
t]
6.5
Effects
of
Equipment
Replacement
Failure
to
consider
the
effects
of
equipment
replacement
and
NSPS
requirements
for
an
affected
facility's
existing
capital
stock,
may
result
in
development
of
a
SIP
which
requires
more
emissions
reductions
than
necessary
to
meet
rate­
of­
progress
milestones
or
NAAQS
attainment
dates.

As
an
existing
facility
wears
out
and
is
replaced
with
newer
equipment,
it
may
become
subject
to
a
NSPS.
To
the
extent
NSPS
requirements
are
more
restrictive
than
present
requirements
on
the
existing
(
not
modified
or
reconstructed)
facility,
future
emissions
will
be
reduced.
The
implications
of
such
emissions
reductions
can
be
assessed
using
the
following
formula:

where:
Ert
=
Emissions
reductions
in
year
t
Eb
=
Emissions
in
the
base
year
En
=
NSPS
emissions
r
=
Annual
replacement
rate
for
worn
out
capital
stock
t
=
Years
from
the
base
year
Consequently,
zero
net
growth
emissions
need
not
be
the
same
as
baseline;
they
might
actually
be
less.
D­
23
10/
29/
93
MEMORANDUM
SUBJECT:
Rate­
of­
Progress
Plan
Guidance
on
the
15
Percent
Calculations
FROM:
D.
Kent
Berry,
Acting
Director
Air
Quality
Management
Division
(
MD­
15)

TO:
Director,
Air,
Pesticides
and
Toxics
Management
Division,
Regions
I
and
IV
Director,
Air
and
Waste
Management
Division,
Region
II
Director,
Air,
Radiation
and
Toxics
Division,
Region
III
Director,
Air
and
Radiation
Division,
Region
V
Director,
Air,
Pesticides
and
Toxics
Division,
Region
VI
Director,
Air
and
Toxics
Division,
Regions
VII,
VIII,
IX,
and
X
The
Clean
Air
Act
(
Act)
requires
a
specified
rate
of
emissions
reductions
for
all
ozone
areas
classified
as
moderate
and
above.
Moderate
and
above
areas
must
submit
a
State
implementation
plan
(
SIP)
revision
detailing
how
the
area
will
achieve
a
reduction
in
volatile
organic
compounds
emissions
of
at
least
15
percent
between
November
15,
1990
and
November
15,
1996
(
hereafter
called
the
rate­
of­
progress
plan).
The
rate­
ofprogress
requirement
is
based
on
the
1990
base­
year
emissions
inventory.
The
rate­
of­
progress
plan
revision
is
part
of
the
full
SIP
(
including
an
attainment
demonstration
based
on
modeling)
for
most
moderate
areas,
and
a
separate
submittal
for
serious
and
above
areas
(
due
November
15,
1993).

The
Ozone/
Carbon
Monoxide
Programs
Branch
coordinated
the
development
of
a
series
of
guidance
documents
to
guide
States
as
they
develop
their
SIP's
to
meet
the
new
rate­
of­
progress
requirements
of
section
182(
b)(
1).
These
documents
were
released
between
October
1992
and
June
1993.
In
addition,
Office
of
Air
Quality
Planning
and
Standards
staff
presented
a
satellite
training
workshop
on
the
15
percent
rate­
of­
progress
plans
and
the
attainment
demonstrations
in
the
spring
of
1993.
The
guidance
documents
and
the
workshop
explained
the
procedures
for
D­
24
calculating
the
15
percent
requirement
that
was
first
put
forth
in
the
"
General
Preamble
for
the
Implementation
of
Title
I
of
the
Clean
Air
Act
Amendments
of
1990,"
(
57
FR
13498,
April
16,
1992).

Several
variations
have
been
suggested
for
the
calculation
procedures
of
this
requirement.
One
suggestion
would
allow
States
to
offset
only
15
percent
of
the
growth
rather
than
all
of
the
growth.
Another
suggestion
would
take
credit
for
the
Federal
motor
vehicle
control
program
as
a
means
to
achieve
the
total
reductions
necessary
to
meet
the
15
percent
requirement
and
offset
growth.

Regarding
the
requirement
to
account
for
growth,
the
Environmental
Protection
Agency's
(
EPA's)
interpretation
of
the
Act
ensures
that
actual
reductions
will
occur
if
an
area
is
to
meet
the
15
percent
reduction
requirement.
Some
of
the
alternative
interpretation
suggested
could
lead
to
a
situation
where,
due
to
significant
growth,
an
area's
projected
emissions­­
even
after
applying
a
15
percent
reduction­­
could
be
higher
in
1996
than
in
1990,
but
the
area
would
still
be
considered
as
meeting
the
progress
requirement.
We
do
not
believe
this
reflects
the
intent
of
the
Act.
States
should,
therefore,
follow
the
guidance
documents
issued
by
EPA
when
developing
their
15
percent
rate­
of­
progress
plans
that
are
due
November
15,
1993.
Thus,
we
do
not
foresee
allowing
the
variations
such
as
those
discussed
above.

A
second
issue
arises
as
a
result
of
some
confusion
concerning
the
above­
cited
EPA
guidance
on
15
percent
plans.
The
EPA
intends
to
determine
the
approvability
of
the
15
percent
rate­
of­
progress
plans
using
four
basic
criteria:
(
1)
the
baseyear
inventory
and
associated
projections
must
be
appropriately
justified;
(
2)
the
target
level
of
emissions
is
properly
calculated;
(
3)
the
target
level
of
emissions
will
be
achieved
if
the
strategies
adopted
and
identified
in
the
plan
are
shown
to
successfully
achieve
the
necessary
level
of
reductions
by
the
end
of
1996;
and
(
4)
contingency
measures
of
3
percent
(
or
a
commitment
to
adopt
such
measures)
are
included.
Some
of
the
confusion
associated
with
the
guidance
may
come
from
the
discussion
of
total
required
reductions.
The
best
test
of
whether
a
15
percent
rate­
of­
progress
plan
will
be
acceptable
is
not
whether
a
certain
amount
of
reductions
is
achieved,
but
whether
the
projected
emissions
in
1996
will
be
at
or
below
the
target.
The
attachment
to
this
memorandum
explains
specifically
how
these
calculations
are
to
be
done.

Finally,
there
is
apparently
some
confusion
concerning
the
creditability
of
reductions
due
to
the
Federal
motor
vehicle
control
program
(
FMVCP).
The
Act
states
that
emission
reductions
from
"[
a]
ny
measures
relating
to
motor
vehicle
exhaust
or
evaporative
emissions
promulgated
by
the
Administrator
by
D­
25
January
1,
1990"
are
not
creditable
toward
the
15
percent
requirement.
This
means
that
reductions
due
to
the
pre­
1990
FMVCP
standards
are
not
creditable
but
that
reductions
due
to
any
new
standards
promulgated
after
January
1,1990
are
creditable.

We
suggest
that
you
forward
this
information
to
your
State
and
local
agencies.
If
you
have
questions
or
comments,
please
contact
Kimber
Scavo
at
(
919)
541­
3354
or
Laurel
Schultz
at
(
919)
541­
5511.

Attachment
D­
26
ATTACHMENT
A
specific
question
that
has
been
raised
is
whether
the
1996
projected
emissions
that
are
used
to
calculate
the
total
required
reductions
(
box
"
C"
in
the
attached
flowchart)
should
reflect
the
effects
of
the
noncreditable
Federal
motor
vehicle
control
program
(
FMVCP)
and
Reid
vapor
pressure
(
RVP)
requirements.
There
are
at
least
three
approaches
to
this.
All
three
approaches
will
result
in
the
same
answer
if
followed
carefully.
However,
some
may
be
easier
than
others
depending
on
what
work
has
already
been
done.
Method
3
may
be
the
simplest
of
the
three
because
it
does
not
require
individual
calculation
of
reductions
associated
with
each
mobile
source
measure.
In
all
cases
(
including
method
3),
full
documentation
must
be
provided,
including
information
on
MOBILE5a
input
and
vehicle
miles
travelled
(
VMT)
used
in
the
calculations.

States
should
also
note
that
the
test
of
the
plan
will
be
to
determine
whether
the
reductions
from
the
measures
listed
below
are
greater
than
or
equal
to
the
"
Reductions
Needs
by
1996
to
Achieve
15
Percent
Net
of
Growth"
(
box
C
­
box
D).
Because
of
the
possibility
for
errors
in
these
reduction
calculations,
States
should
double­
check
their
calculations
by
looking
at
whether
the
projected
emissions
for
1996,
including
growth
and
all
of
the
controls
expected
to
be
in
place,
will
be
at
or
below
the
calculated
1996
target.
If
there
is
a
discrepancy
between
the
results
calculated
by
comparing
the
projected
1996
inventory
to
the
target
and
the
results
calculated
above,
it
is
likely
that
some
of
the
reductions
have
been
double­
counted.
The
EPA
intends
to
compare
the
1996
projected
inventory
(
that
should
be
submitted
with
the
documentation
of
the
15
percent
rate­
of­
progress
plan)
to
the
target
as
the
primary
test
of
whether
a
State's
plan
demonstrates
the
required
reduction.

1.
Growth
Projections
without
Control
Projections
(
a)
The
State
can
project
the
1996
emissions
as
if
the
reductions
from
FMVCP
and
RVP
will
not
occur.
In
other
words,
the
"
1996
Estimated
Emissions
(
Anthropogenic)"
is
the
"
1990
Rateof
Progress
Base­
Year
Inventory"
(
box
A)
multiplied
by
the
appropriate
growth
factors.
The
on­
road
mobile
portion
of
this
1996
inventory
is
determined
by
multiplying
the
1990
emission
factors
by
the
1996
VMT.
The
"
Reductions
Needs
by
1996
to
Achieve
15
Percent
Net
of
Growth"
(
box
C
­
box
D)
will
represent
all
of
the
reductions
needed
by
1996,
including
pre­
enactment
FMVCP
and
RVP
that
will
occur
anyway.

(
b)
The
reductions
that
will
count
toward
this
total
are
as
follows:

Pre­
enactment
FMVCP
and
RVP
I/
M
corrections
D­
27
Tier
1
(
post­
1990
vehicle
emission
standards)
Enhanced
I/
M
Reformulated
gasoline
RACT
corrections
Reductions
from
any
other
stationary
or
mobile
source
measures
States
should
take
care
that
the
reductions
are
properly
calculated.
For
example,
the
reductions
associated
with
the
preenactment
FMVCP
and
RVP
in
this
case
are
calculated
as
the
difference
between
the
product
of
box
A
times
growth
factors
(
i.
e.,
1990
emission
factors
times
1996
VMT)
and
1996
projected
emissions
with
no
new
Clean
Air
Act
(
Act)
measures
(
1996
emission
factors
with
NEWFLG=
5
and
Phase
II
RVP
times
1996
VMT).
Note
that
this
is
different
than
the
calculation
used
to
adjust
the
1990
base­
year
inventory.

The
reductions
associated
with
Tier
1
standards
are
then
calculated
as
the
difference
between
1996
emissions
with
no
new
Act
measures
(
calculated
in
the
previous
step)
and
1996
projected
emissions
with
NEWFLG=
1
and
Phase
II
RVP.
Reductions
for
other
measures
can
then
be
calculated
sequentially
in
the
same
manner
(
i.
e.,
compare
1996
projected
emissions
with
the
new
control
measure
in
place
to
1996
emissions
without
the
new
control
measure
in
place
but
with
all
the
previously
calculated
control
measures
in
place).

2.
Growth
Projections
with
Federal
Mobile
Source
Control
Projections
(
a)
The
State
can
project
the
1996
emissions
as
if
the
reductions
from
FMVCP
and
RVP
will
occur,
but
no
additional
mobile
or
stationary
source
controls
will
be
in
effect.
In
this
case,
the
"
1996
Estimated
Emissions
(
Anthropogenic)"
is
essentially
the
"
1990
Adjusted
Base­
Year
Inventory"
multiplied
by
the
appropriate
growth
factors.
The
on­
road
mobile
portion
of
this
1996
inventory
is
determined
by
multiplying
the
1996
emission
factors
(
with
NEWFLG=
5,
Tier
1
turned
off,
Phase
II
RVP
on)
by
the
1996
VMT.

(
b)
The
"
Reductions
Needs
by
1996
to
Achieve
15
Percent
Net
of
Growth"
(
box
C
­
box
D)
will
represent
all
of
the
reductions
needed
by
1996,
in
addition
to
pre­
enactment
FMVCP
and
RVP
that
will
occur
anyway.
The
reductions
that
will
count
toward
this
total
are
as
follows:

Tier
1
(
post­
1990
vehicle
emission
standards)
Enhanced
I/
M
Reformulated
gasoline
I/
M
corrections
RACT
corrections
D­
28
Reductions
from
any
other
stationary
or
mobile
source
measures
3.
Growth
Projections
with
all
Current
Control
Projections
(
a)
The
State
can
project
the
1996
emissions
as
if
the
reductions
from
FMVCP
and
RVP
and
any
other
mobile
and
stationary
source
controls,
planned
or
in
effect,
will
occur.
In
this
case,
the
"
1996
Estimated
Emissions
(
Anthropogenic)"
is
essentially
the
"
1990
Rate­
of­
Progress
Base­
Year
Inventory"
with
the
appropriate
growth
factors
and
controls
applied.
The
on­
road
mobile
portion
of
this
1996
inventory
is
determined
by
multiplying
the
1996
emission
factors
(
with
NEWFLG=
1,
enhanced
I/
M,
reform,
and
any
other
controls
turned
on)
by
the
1996
VMT.

(
b)
The
"
Reductions
Needs
by
1996
to
Achieve
15
Percent
Net
of
Growth"
(
box
C
­
box
D)
will
represent
all
of
the
additional
reductions
needed
by
1996.
The
reductions
that
will
count
toward
this
total
are
as
follows:

Reductions
from
any
other
stationary
or
mobile
source
measures.
D­
29
11/
8/
93
MEMORANDUM
SUBJECT:
Clarification
of
Issues
Regarding
the
Contingency
Measures
that
are
due
November
15,
1993
for
Moderate
and
Above
Ozone
Nonattainment
Areas
FROM:
D.
Kent
Berry,
Acting
Director
Air
Quality
Management
Division
(
MD­
15)

TO:
Director,
Air
Pesticides
and
Toxics
Management
Division,
Regions
I
and
IV
Director,
Air
and
Waste
Management
Division,
Region
II
Director,
Air,
Radiation
and
Toxics
Division,
Region
III
Director,
Air
and
Radiation
Division,
Region
V
Director,
Air,
Pesticides
and
Toxics
Division,
Region
VI
Director,
Air
and
Toxics
Division,
Regions
VII,
VIII,
IX,
and
X
The
August
23,
1993
memorandum
"
Guidance
on
Issues
Related
to
15
Percent
Rate­
of­
Progress
Plans,"
from
Michael
H.
Shapiro,
Acting
Assistant
Administrator
for
Air
and
Radiation,
to
you,
set
forth
the
policy
on
accepting
nitrogen
oxide
(
NOx)
measures
for
a
portion
of
the
contingency
measures
that
are
due
November
15,
1993,
and
for
allowing
committal
State
implementation
plans
(
SIP's)
for
the
contingency
measure
submittal.
This
memorandum
provides
additional
clarification
on
a
number
of
related
issues
that
were
raised
after
issuance
of
the
August
23
memo.

NOx
Reasonably
Available
Control
Technology
(
RACT)

Section
172(
c)(
9)
of
the
Clean
Air
Act
(
Act)
states
that
moderate
and
above
ozone
nonattainment
areas
".
.
.
shall
provide
for
the
implementation
of
specific
measures
to
be
undertaken
if
the
area
fails
to
make
reasonable
further
progress,
or
to
attain
the
national
ambient
air
quality
standard."

In
addition,
section
182(
c)(
9)
of
the
Act
states
that
serious
and
above
areas
".
.
.
shall
provide
for
the
1Note
that
an
area
may
use
as
a
contingency
measure
a
rule
or
measure
that
is
required
for
another
pollutant
(
such
as
carbon
monoxide)
as
long
as
it
would
provide
reductions
in
volatile
organic
compounds
(
VOC)
or
NOx.

D­
30
implementation
of
specific
measures
to
be
undertaken
if
the
area
fails
to
meet
any
applicable
milestone."

Because
the
Act
says
that
specific
measures
must
be
undertaken
if
the
area
fails
to
meet
a
milestone,
any
measures
that
are
already
required
in
any
ozone
nonattainment
area
would
not
be
creditable
for
the
3
percent
contingency
measure
requirement.
1
Therefore,
since
NOx
RACT
is
already
a
requirement,
it
would
not
be
accepted
as
a
contingency
measure.
The
only
exception
would
be
the
early
implementation
of
required
measures
scheduled
for
implementation
at
a
later
date
in
the
SIP.
In
this
case,
if
an
area
then
failed
to
meet
a
milestone
which
triggered
the
implementation
of
the
contingency
measures,
the
State
would
have
1
year
to
backfill
the
shortfall.

Note
that
measures
that
provide
for
emissions
reductions
beyond
RACT
would
be
creditable
as
contingency
measures.

Control
Techniques
Guidelines
(
CTG's)

States
may
adopt,
as
a
contingency
measure,
rules
for
categories
where
the
Environmental
Protection
Agency
(
EPA)
plans
to
issue
a
CTG.
When
EPA
finally
issues
the
CTG,
however,
the
State
will
have
to
revise
its
SIP
to
ensure
implementation
of
the
RACT
rule
by
a
date
certain.
In
other
words,
the
rule
can
no
longer
be
a
"
contingency
measure"
that
is
triggered
by
failure
to
attain
or
failure
to
meet
reasonable
further
progress.
The
rule
would
thus
have
to
be
replaced
with
another
contingency
measure
after
EPA
issues
the
CTG
because
of
the
rationale
stated
above.
When
a
CTG
is
issued
by
EPA,
States
can
consider
moving
a
rule
or
measure
from
its
15
percent
plan
to
its
contingency
plan
and
replacing
the
15
percent
rule
or
measure
with
the
CTG
rule.
This
type
of
transaction
would
require
a
SIP
revision.

Maximum
Available
Control
Technology
(
MACT),
and
Other
Federal
Rules
Any
reductions
that
occur
because
of
implementing
MACT
or
any
Federal
rule
are
not
creditable
toward
the
contingency
measure
requirement
because
of
the
rationale
stated
above.
States
may,
however,
use
as
contingency
measures
rules
for
categories
for
which
EPA
plans
in
the
future
to
issue
Federal
rules.
Note
that
such
contingency
measures
must
be
replaced
when
EPA
finally
issues
the
rule.
As
stated
in
the
discussion
of
CTG's,
a
SIP
revision
would
be
required
when
a
State
replaces
rules
or
measures
in
their
15
percent
plan
with
the
new
MACT
2Two
of
which
are:
"
General
Preamble
for
the
Implementation
of
Title
I
of
the
Clean
Air
Act
Amendments
of
1990,"
57
FR
13498,
April
16,
1992,
and
"
Guidance
for
Growth
Factors,
Projections,
and
Control
Strategies
for
the
15
Percent
Rate­
of­
Progress
Plans,"
EPA­
452/
R­
93­
002,
March
1993.

D­
31
standard
or
Federal
rule
and
moves
the
replaced
rule
or
measure
to
its
contingency
plan.

Episodic
Strategies
Section
123
of
the
Act
states
that
an
emissions
limitation
may
not
be
affected
by
any
dispersion
technique,
which
includes
"
any
intermittent
or
supplemental
control
of
air
pollutants
varying
with
atmospheric
conditions."
According
to
EPA
guidance
documents,
2
by
November
15,
1993,
EPA
expects
the
regulations
or
measures
that
are
adopted
for
the
15
percent
rate­
of­
progress
plan
to
be
fully
adopted,
real,
permanent,
quantifiable,
and
enforceable.
Therefore,
since
episodic
strategies
do
not
result
in
real,
permanent,
quantifiable,
and
enforceable
emission
reductions,
they
will
not
be
approvable
for
the
contingency
measure
requirement,
as
well
as
the
15
percent
plan
requirement.
The
EPA's
policy
was
set
forth
in,
"
Stack
Height
Regulation;
Final
Rule,"
50
FR
27892,
July
8,
1985.

Committal
SIP's
If
a
State
elects
to
submit
in
its
SIP
a
commitment
for
the
contingency
measure
requirement,
it
must
include
a
commitment
to
adopt,
by
November
15,
1994,
the
measures
or
rules
for
the
entire
3
percent
required.
The
commitment
must
provide
as
much
information
as
possible,
but
we
recognize
that
in
some
cases
it
may
be
difficult
to
list
the
measures
that
an
area
is
considering
with
a
schedule
because
the
area's
modeling
may
not
yet
be
complete.
Completion
of
modeling
may
be
necessary
in
cases
where
a
State
is
considering
NOx
controls
as
part
of
the
contingency
measures.
Therefore,
EPA
will
accept
such
commitments
without
a
list
of
specific
measures,
but
the
commitment
should
at
least
note
the
possible
kinds
of
measures
under
consideration
for
NOx
and
VOC.

Please
forward
this
information
to
your
State
and
local
agencies.
Your
staff
may
contact
Kimber
Scavo
at
(
919)
541­
3354
with
questions.
