8/
126/
05
RFP/
CAIR
segment
The
requirements
for
RFP
under
subparts
1
and
2,
as
described
above,
are
the
minimum
required
for
an
area.
More
reductions
may
be
necessary
for
attainment
within
the
nonattainment
area.
Moreover,
an
upwind
area
that
contributes
to
nonattainment
in
a
downwind
area
in
the
same
State
may
need
more
reductions
in
a
shorter
time
in
order
for
the
downwind
area
to
reach
attainment
by
its
required
attainment
date.
Although
we
believe
most
8­
hour
nonattainment
areas
will
attain
the
standard
by
their
statutory
attainment
dateAs
we
noted
above
in
section
IV.
D.
8.,
we
recognize
that
some
areas
classified
under
subpart
2
may
need
additional
time
beyond
the
statutory
attainment
date
for
their
area
to
attain
as
expediously
as
practicable.
As
discussed
in
the
Phase
1
Rule
(
69
FR
at
23959,
col.
3),
iIn
the
event
an
area
cannot
practicably
attain
by
the
maximum
date
for
its
classification,
the
Clean
Air
Act
provides
the
opportunity
for
more
time.
An
area
regulated
under
subpart
2
can
receive
a
later
maximum
attainment
date
through
a
State
request
to
bump­
up
to
a
higher
classification
(
e.
g.
from
moderate
to
serious).
The
Act
requires
EPA
to
grant
a
State
request
to
reclassify
an
area
to
a
higher
classification;
the
State
plan
still
must
provide
for
attainment
as
expeditiously
as
practicable.
Although
bump­
up
means
that
certain
additional
specified
requirements
apply,
an
area
may
already
be
meeting
most
or
all
of
these
specified
requirements
due
to
controls
previously
adopted
to
implement
the
1­
hour
ozone
standard.
This
is
because
some
areas
had
1­
hour
classifications
that
were
higher
(
and
more
restrictive)
than
the
areas'
8­
hour
classification,
1
and
because
the
Phase
1
final
implementation
rule
for
the
8­
hour
O3
NAAQS
contains
antibacksliding
provisions
generally
requiring
areas
to
continue
implementating
measures
required
for
the
1­
hour
classification.
Although
thereThere
may
not
be
additional
mandatory
control
measures
required
because
the
areas
may
already
have
such
measures
in
place.
However,
an
area
that
needs
more
time
to
attain
may
also
need
additional
emission
reductions
to
reach
attainment.
These
reductions
may
be
achieved
through
implementation
of
measures
that
are
necessary
to
demonstrate
RFP
requirements
or
additional
reductions
beyond
RFP
may
be
needed.
Preliminary
analyses
indicate
that
already
required
control
measures
(
e.
g.,
motor
vehicle
and
nonroad­
engine
rules,
CAIR,
etc.)
may
largely
or
fully
fulfill
reasonable
further
progress
requirements
for
many
areas
and
that
they
will
provide
substantial
progress
toward
attainment
for
most
areas.
Many
areas
may
have
significant
creditable
reductions
as
a
result
of
federal
motor
vehicle
and
non­
road
rules,
the
NOx
SIP
Call,
and
the
Clean
Air
Interstate
Rule.
With
the
statutory
2
exceptions
enumerated
above,
assured
emissions
reductions
that
will
occur
in
an
area
after
the
base
year
can
be
credited
toward
meeting
an
RFP
emission
reduction
milestone.
To
reduce
interstate
ozone
transport,
the
CAIR
(
described
above
in
section
IV.
B.)
established
statewide
ozone­
season
NOx
budgets
for
25
States
and
the
District
of
Columbia
(
eastern
part
of
the
United
States
where
all
8­
hour
nonattainment
areas
are
classified
as
moderate
or
below).
As
noted
above,
the
first
phase
of
NOx
reductions
under
CAIR
starts
in
2009
(
covering
2009­
2014);
the
second
phase
of
NOx
reductions
begins
in
2015
(
covering
2015
and
thereafter).
With
respect
to
timing
of
reductions,
the
following
table
shows
how
summertime
NOx
reductions
from
local
CAIR
sources
that
will
be
achieved
by
May
1,
2009,
or
earlier
can
assist
in
demonstrating
RFP.

Type
of
8­
hour
nonattainment
area
RFP
Requirement*
Relationship
of
CAIR
and
RFP
Subpart
1
areas
with
attainment
dates
within
5
years
of
designation
Meet
RFP
through
showing
of
expeditious
attainment
No
separate
RFP
requirement,
so
creditability
of
CAIR
reductions
not
relevant
Subpart
1
areas
with
attainment
dates
6­
10
years
from
designation
Must
demonstrate
RFP
through
their
attainment
date
CAIR
reductions
in
2009
or
earlier
can
help
fulfill
RFP
requirement
Subpart
2
marginal
areas
No
subpart
2
RFP
requirement
for
marginal
areas
Not
relevant
Subpart
2
moderateand
above
areas
that
previously
achieved
15%
RFP
for
1­
hour
ozone
standard
Subject
to
subpart
1
RFP;
must
demonstrate
RFP
through
their
attainment
date
CAIR
NOx
reductions
in
2009
or
earlier
can
help
fulfill
RFP
requirement
Subpart
2
moderateand
above
areas
that
did
not
implement
15%
VOC
reductions
for
1­
hour
ozone
standard
15%
VOC
reduction
required
between
2002
and
2008;
continued
progress
required
through
attainment
date
CAIR
2009
NOx
reductions
can
help
demonstrate
continued
progress
after
2008
to
attainment
date.
*
RFP
requirement
descriptions
in
table
are
abbreviated;
RFP
requirements
are
more
precisely
described
elsewhere
in
preamble
and
rule
text.
CAIR
provisions
do
not
require
emission
reductions
prior
to
January
1,
2009.
However,
some
sources
may
elect
to
apply
CAIRlevel
NOx
controls
earlier
than
that
date.
If
such
controls
are
made
enforceable
in
the
SIP
(
e.
g.,
through
a
specific
rule),
the
State
may
take
RFP
credit
for
such
emission
reductions
for
the
period
ending
December
31,
2008.
The
RFP
provisions
in
the
Act
for
both
subpart
1
and
subpart
2
areas
require
that
actual
emissions
be
reduced
from
the
baseline
to
the
milestone
year.
Therefore,
only
projected
actual
emission
reductions
may
be
credited
toward
the
State's
RFP
obligation.
In
developing
their
RFP
plans,
States
will
have
to
provide
their
best
estimate
of
the
CAIR­
affected
sources
that
are
expected
to
actually
apply
controlsreduce
emissions
to
meet
the
CAIR
requirements
and
those
that
are
expected
to
meet
CAIR
through
holding
allowances
and
not
actually
reducing
emissions.
Local
CAIR
NOx
reductions
by
May
1,
2015,
could
assist
in
meeting
RFP
in
the
event
an
area
received
an
attainment
date
extension
to
2015
or
beyond.
