MEMORANDUM
Date:
August
3,
2005
To:
Allen
Basala,
U.
S.
EPA,
OAQPS
From:
Frank
Divita,
E.
H.
Pechan
&
Associates
Subject:
Estimate
Reasonable
Further
Progress
(
RFP)
Requirements
for
Buffalo­
Niagara
Falls­
NY
8­
hour
ozone
nonattainment
area
EPA
Contract
No.
68­
D­
00­
283,
WA
No.
4­
66
A.
INTRODUCTION
The
purpose
of
this
memorandum
is
to
describe
the
methodology
used
by
Pechan
to
estimate
the
reasonable
further
progress
(
RFP)
requirements
for
Buffalo­
Niagara
Falls,
NY
8­
hour
ozone
nonattainment
area
under
one
of
two
legal
interpretations
proposed
for
the
Phase
2
Implementation
Rule
for
the
8­
hour
Ozone
National
Ambient
Air
Quality
Standard.
That
rule
is
not
yet
finalized.
This
analysis
was
performed
in
support
of
EPA's
technical
analysis
of
the
costs
of
the
final
rule.

The
designated
8­
hour
ozone
non­
attainment
area
included
in
this
assessment
is
subpart
1
area
and
is
estimated
to
exceed
the
8­
hr
standard
under
base
case
conditions
in
2010.
Under
the
alternative
assessed
here
­­
the
more
stringent
of
two
proposed
alternatives
­­
nonattainment
area
would
have
to
achieve
15%
reductions
in
volatile
organic
compound
(
VOC)
and
nitrogen
oxide
(
NOx)
emissions,
regardless
of
whether
the
area
had
already
fulfilled
a
15%
requirement
under
the
1­
hour
ozone
national
ambient
air
quality
standard.

Important
caveat:
These
estimates
were
conducted
solely
for
analytical
purposes
associated
with
national
EPA
rulemaking.
Actual
requirements
for
RFP
for
individual
nonattainment
areas
will
be
determined
through
analyses
by
states,
and
reviewed
by
EPA,
through
the
state
implementation
plan
process
under
the
Clean
Air
Act,
consistent
with
the
yet­
to­
be­
promulgated
phase
2
ozone
implementation
rule.
The
statutory
interpretation
of
RFP
requirements,
and
methodology
for
determining
RFP,
will
be
determined
by
that
rule.
The
methodology
and
data
used
in
this
analysis
may
differ
from
those
used
in
the
SIP
process.
Therefore,
the
RFP
estimates
below
may
vary
from
actual
future
RFP
reduction
requirements
to
be
determined
through
the
SIP
process.

The
estimation
methods
described
below
are
based
on
concepts
in
EPA's
early­
1990'
s
guidance
on
calculating
15%
VOC
rate­
of­
progress
targets
from
a
1990
base
year
for
purposes
of
implementing
the
1­
hour
ozone
standard.
For
purposes
of
this
analysis
of
potential
RFP
requirements
for
8­
hour
nonattainment
area,
2002
is
considered
as
the
base
year,
with
the
15%
reduction
to
be
achieved
by
2008.
Table
I
shows
the
NOx
and
VOC
progress
requirements
to
meet
a
15%
reduction
from
2002
emission
levels
by
2008.
The
15%
reduction
calculation
allows
100%
credits
for
NOx
and
VOC
reductions
obtained
from
2002
to
2008
through
implementation
of
other
emission
reduction
programs.
The
one
exception
is
that
mobile
source
reductions
are
discounted
by
13%
(
i.
e.,
only
87%
of
mobile
source
reductions
are
creditable
toward
the
RFP
progress
requirements).
The
reason
this
discount
is
applied
is
because
there
are
certain
reductions
in
motor
vehicle
emissions
that
will
occur
in
the
future
but
are
the
result
of
actions
taken
prior
to
the
enactment
of
the
1990
Clean
Air
Act
Amendments.

B
CALCULATION
METHODOLOGY
The
first
step
needed
to
determine
if
additional
RFP
emission
reductions
are
required
is
to
compare
emission
estimates
of
2002
with
2008.
Under
this
assessment
of
the
more
stringent
RFP
option,
the
emission
reductions
are
to
be
achieved
6
years
from
the
date
of
designations.
In
addition,
if
there
were
emission
reductions
during
these
periods
due
to
federal
emission
reduction
regulations
and
local
air
pollution
control
programs,
these
reductions
could
count
toward
the
15%
RFP
requirement.
For
this
analysis,
EPA
provided
2001,
2007
and
2010
emission
inventories
by
sector
(
stationary
non­
point,
non­
road,
mobile,
point
and
electricity
generating
units).
2002
emissions
were
estimated
by
the
linear
interpolation
of
the
2001
and
2007
inventories.
Similarly,
2008
emissions
were
interpolated
from
the
2007
and
2010
projected
inventories
The
RFP
requirement
for
the
non­
attainment
area
is
calculated
by
subtracting
85%
of
2002
emissions
(
i.
e.
reduction
by
15%)
from
the
2008
emissions,
assuming
that
mobile
source
emission
changes
are
discounted
by
13%.
If
this
value
is
greater
than
zero,
the
amount
represents
the
estimated
reductions
for
the
area
to
fulfill
the
requirements
of
the
more
stringent
RFP
option.
If
that
value
is
less
than
or
equal
to
zero,
no
further
reduction
in
NOx
and
VOC
emissions
are
needed
to
fulfill
the
RFP
requirements
of
the
more
stringent
RFP
option
as
interpreted
in
this
assessment.

C.
SAMPLE
CALCULATION
Below
is
a
sample
calculation
for
VOC
reductions
requirement:

2001
emissions
totals
=
64,327
tons
2007
emissions
totals
=
48,749
tons
2010
emissions
totals
=
54,173
tons
Interpolation
of
2001
&
2007
yields
2002
emissions=
61,731
tons
Interpolation
of
2007&
2010
yields
2008
emissions
=
50,557
tons
After
discounting
of
mobile
emissions
by
13%,
2002
emission
=
59,343
tons.

Additional
VOC
tons
required
to
reduce
=
(
2008
Emissions)
­
(
85%
of
2002
Emissions)
=
(
50,557)
­
(
0.85
x
59,343)
=
116
tons
Table
I.
Reasonable
Further
Progress
Requirements
for
NOx
and
VOC
in
Buffalo­
Niagara
Falls­
NY
8­
Hour
Non­
Attainment
Area
Designated
as
Subpart
1
and
Projected
to
Exceed
the
8­
hour
Ozone
Standard
in
2010
Buffalo­
Niagara
Falls,
NY
Nonattainment
Area
85%
of
the
2002
emissions
inventory*
2008
interpolated
emissions
inventory
2008
interpolated
inventory
minus
85%
of
the
appropriate
2002
inventory
Estimated
additional
emission
reductions
under
our
interpretation
of
the
less
flexible
RFP
option
VOC
50,442
50,557
116
116
NOx
51,193
48,835
­
2,358
0
*
Adjusted
2002
VOC
emissions
inventory
after
13%
mobile
emissions
discounting
