
1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
REGION
I
MEMORANDUM
DATE:
December
15,
2005
SUBJ:
Technical
Support
Document
for
the
Maine
15%
VOC
Rate­
of­
Progress
Plan
and
5%
Increment
of
Progress
Plan
FROM:
Bob
McConnell,
Environmental
Engineer
Air
Quality
Planning
Unit
TO:
David
B.
Conroy,
Chief
Air
Quality
Branch
I.
BACKGROUND
Section
182(
b)(
1)
of
the
Clean
Air
Act
(
CAA)
as
amended
in
1990
requires
that
moderate
and
above
one
hour
ozone
nonattainment
areas
develop
plans
to
reduce
area
wide
Volatile
Organic
Compound
(
VOC)
emissions
from
a
1990
baseline
by
15%.
The
plans
were
required
to
be
submitted
by
November
15,
1993
and
the
reductions
were
required
to
be
achieved
within
6
years
after
enactment,
which
is
November
15,
1996.
The
Clean
Air
Act
also
set
certain
limitations
on
the
creditability
of
certain
types
of
reductions.
Specifically,
State's
cannot
take
credit
for
reductions
achieved
by
Federal
Motor
Vehicle
Control
Program
(
FMVCP)
measures
(
new
car
emissions
standards)
that
were
already
in
place
prior
to
the
1990
amendments,
or
for
reductions
due
to
controls
on
gasoline
Reid
Vapor
Pressure
(
RVP)
promulgated
prior
to
1990.
Furthermore,
the
CAA
does
not
allow
credit
for
corrections
for
vehicle
inspection
and
maintenance
(
I/
M)
programs
or
corrections
to
reasonably
available
control
technology
(
RACT)
rules
as
these
programs
were
required
prior
to
1990.

On
November
6,
1991,
a
listing
of
ozone
nonattainment
areas
was
published
in
the
Federal
Register.
The
Portland
area,
which
includes
all
of
Cumberland,
Sagadahoc
and
York
counties,
was
listed
as
a
moderate
nonattainment
area
for
the
one
hour
ozone
standard.
Maine
is,
therefore,
subject
to
the
15%
rate­
ofprogress
(
ROP)
requirement.

Maine
submitted
a
final
15%
ROP
plan
to
EPA
on
July
25,
1995.
However,
air
quality
in
the
Portland
area
fluctuated
above
and
below
the
one­
hour
ozone
NAAQS
since
1995.
Pursuant
to
EPA
1May
10,
1995,
guidance
memorandum
signed
by
John
S.
Seitz,
Director
of
the
Office
of
Air
Quality
Planning
and
Standards,
which
stated
in
part
that
ozone
nonattainment
areas
subject
to
15%
ROP
requirements
that
were
meeting
the
ozone
standard
did
not
need
to
submit
15%
ROP
plans
as
long
as
the
area
continued
to
meet
the
standard.

2
policy1,
the
15%
plan
was
not
a
requirement
during
times
that
the
Portland
area's
air
quality
was
better
than
EPA's
one
hour
ozone
NAAQS.
This
made
approval
of
the
15%
plan
a
low
priority
for
Region
1.
Table
1
below
shows
the
attainment
status
of
the
Portland
area
since
1995
with
the
one­
hour
ozone
standard.

Table
1:
Compliance
of
Portland
area
with
1­
hour
ozone
NAAQS
Year
One­
hour
Status
1995
Nonattainment
1996
Nonattainment
1997
Nonattainment
1998
Attainment
1999
Nonattainment
2000
Attainment
2001
Attainment
2002
Nonattainment
2003
Nonattainment
2004
Nonattainment
As
can
be
seen
in
Table
1,
the
Portland
area
has
been
violating
the
one
hour
ozone
standard
since
2002,
and
so
has
been
obligated
to
prepare
and
submit
to
EPA
a
15%
plan
since
that
time.
In
consultation
with
Maine
DEP,
it
was
determined
that
the
state
would
revise
the
15%
plan
submitted
in
1995
to
reflect
up
to
date
emission
estimation
methodologies
and
control
strategies.
On
June
9,
2005,
the
state
submitted
a
revised,
adopted
15%
rate­
ofprogress
plan
for
the
Portland
one­
hour
nonattainment
area.
In
partial
fulfillment
of
it's
obligations
under
the
8­
hour
ozone
standard,
Maine
DEP's
June
9,
2005
submittal
also
included
a
5%
increment
of
progress
plan.
A
description
and
evaluation
of
the
5%
increment
of
progress
plan
is
included
in
section
III.
of
this
document.
3
This
document
summarizes
the
EPA's
evaluation
of
the
Maine
15%
and
5%
emission
reduction
plans,
the
revised
emission
inventories
used
in
development
of
these
plans,
and
the
2007
motor
vehicle
emission
budgets
for
VOC
and
NOx
established
by
the
5%
increment
of
progress
plan,
to
determine
whether
these
items
can
be
approved
as
part
of
the
SIP.

To
perform
this
evaluation,
the
EPA
has
referred
to
the
requirements
of
Section
182
of
the
CAA
and
to
the
General
Preamble
to
Title
I
(
57
FR
13498),
and
to
the
Phase
1
rule
governing
implementation
of
the
8­
hour
ozone
standard
(
69
FR
23951).
Additionally,
Maine's
plan
was
reviewed
against
a
variety
of
guidance
documents
as
mentioned
herein.

II.
15%
Rate­
of
Progress
Emission
Reduction
Plan
As
chronicled
above,
the
Portland
one­
hour
ozone
area
was
designated
as
nonattainment
in
1991,
and
classified
as
a
moderate
area.
Pursuant
to
section
182(
b)(
1)(
a)
of
the
Clean
Air
Act
(
CAA),
moderate
nonattainment
areas
were
required
to
develop
plans
to
reduce
VOC
emission
by
15%
from
1990
to
1996,
net
of
growth.
The
calculation
of
the
required
emission
reductions
is
discussed
below.

II.
A.
CALCULATION
OF
REQUIRED
EMISSION
REDUCTIONS.

The
calculation
of
the
required
reductions
is
explained
in
the
guidance
document
entitled,
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
target
for
the
15%
Rate
of
Progress
plans.
An
explanation
and
evaluation
of
the
steps
involved
in
this
calculation
is
provided
below.

Step
1:
1990
Base
Year
Inventory:

The
first
step
in
calculating
the
emission
reductions
needed
to
comply
with
the
15%
VOC
emission
reduction
requirement
is
to
prepare
a
1990
base
year
emission
inventory
for
VOCs.
The
EPA
approved
the
Maine
1990
base
year
inventory
of
ozone
precursors
within
the
February
28,
1997
Federal
Register
(
62
FR
9081).
The
emission
estimates
contained
within
Maine's
revised
15%
plan
submitted
in
June
of
2005
were
updated
using
improved
methodologies
that
have
arisen
since
the
earlier
inventory
was
prepared.
Maine
DEP
checked
the
1990
emission
estimation
methodologies
against
the
methods
used
to
prepare
it's
projected
2005
inventory
to
ensure
that
the
same
methods
were
used
for
both
inventories.
This
ensures
that
emission
reduction
credit
is
not
taken
due
simply
to
changes
in
emission
estimation
technique.
Table
2
below
compares
the
previously
approved
emission
estimates
4
to
those
in
the
State's
revised
1990
inventory.

Table
2:
Comparison
of
1990
Emission
Estimates
(
tpsd)

SOURCE
CATEGORY
Originally
approved
emissions
June,
2005
emissions
Point
Source
9.65
9.65
Area
Source
31.80
33.43
Non­
road
Mobile
7.40
18.08
On­
Road
Mobile
49.87
63.31
Biogenic
197.60
197.6
Total
296.32
322.07
1990
Inventory
Changes;
VOC
Area
Sources:

Maine
DEP
made
a
number
of
changes
to
it's
previously
approved
1990
area
source
VOC
emission
estimate
in
order
to
use
more
recent
emission
estimation
procedures.
The
largest
changes
were
to
the
cutback
asphalt
and
consumer
and
commercial
products
categories,
as
described
below.

Asphalt
paving;
cutback
asphalt:
The
original
1990
estimate
for
the
Portland
area
was
1.28
tpsd,
but
has
been
increased
significantly
to
7.71
tpsd.
This
increase
was
caused
by
a
change
in
the
source
of
activity
data
for
the
1990
base
year
estimate.
Maine's
original
activity
data
was
obtained
by
a
survey
conducted
in
the
early
1990s.
However,
the
state
no
longer
has
adequate
documentation
for
this
survey,
and
is
reluctant
to
use
it
within
the
revised
plans.
Therefore,
activity
data
from
the
U.
S.
Department
of
Energy
was
used
for
both
the
1990
base
year,
and
the
2005
projection
year
inventories.

Consumer
&
Commercial
Products:
The
original
1990
emission
estimate
of
3.81
tpsd
was
based
on
the
recommended
emission
factor
of
the
time,
which
was
6.3
lbs
VOC
per
capita.
The
recommended
emission
factor
was
subsequently
increased
by
EPA
to
7.84
lbs
VOC
per
capita,
and
Maine
DEP
has
used
that
factor
and
determined
that
it's
1990
emission
level
was
4.74
tpsd.
5
Additional,
smaller
changes
made
to
various
other
area
source
categories
account
for
the
overall
net
increase
of
1.63
tpsd
in
emissions
for
this
sector.

1990
Inventory
Changes;
Nonroad
Engines:

With
the
exception
of
the
commercial
marine,
locomotive,
and
aircraft
categories,
emissions
from
nonroad
engines
can
currently
be
estimated
using
EPA's
Nonroad
engine
model.
However,
at
the
time
Maine
DEP's
original
1990
inventory
was
prepared,
the
state
of
the
art
method
for
preparing
such
estimates
was
based
on
reports
produced
by
EPA's
then
Office
of
Mobile
Sources
entitled
the
"
Nonroad
Engine
and
Vehicle
Emission
Studies"
(
NEVES).
Maine's
original
estimate
for
this
sector
was
based
on
these
studies,
and
for
the
Portland
area
was
determined
to
be
7.06
tpsd
for
VOC.
To
update
this
emission
estimate,
Maine
DEP
ran
the
Nonroad
engine
model
for
calendar
year
1990
and
found
emissions
to
be
17.32
tpsd
VOC.
This
increase
of
10.26
tpsd,
coupled
with
minor
changes
made
to
the
aircraft,
rail,
and
commercial
marine
emission
estimates,
account
for
the
increased
1990
emission
estimate
for
this
sector.

1990
Inventory
Changes;
Onroad
Mobile
Sources:

Maine
DEP's
originally
approved
1990
emission
estimate
for
onroad
vehicles
was
based
on
EPA's
Mobile
5a
model.
Maine
DEP
has
re­
calculated
this
estimate
using
the
most
current
version
of
the
model,
which
is
the
Mobile
6.2
version,
and
found
emissions
to
be
63.31
tpsd
of
VOC.
EPA
Region
1
assisted
Maine
DEP
with
the
preparation
of
this
revised
1990
emission
estimate
and
believe
it
represents
a
more
accurate
estimate
of
emissions
from
the
on­
road
mobile
sector
than
the
previous
value.

Step
2:
Develop
1990
Rate­
of­
Progress
Base
Year
Inventory
The
second
step
involves
excluding
biogenic
emissions
and
emissions
included
within
the
base
year
inventory
which
do
not
emanate
from
within
the
boundaries
of
the
nonattainment
area.
Maine's
base
year
inventory
for
the
Portland
nonattainment
area
did
not
include
any
emissions
from
sources
outside
of
the
area.
Therefore,
step
2
consists
of
simply
subtracting
the
biogenic
VOC
component,
producing
a
"
rate­
of­
progress"
inventory
of
124.47
tpsd.

Step
3:
Develop
the
Adjusted
Base
Year
Inventory
The
third
step
in
calculating
the
required
emission
reductions
is
to
subtract
the
emission
reductions
that
are
not
creditable
toward
the
15%
VOC
emission
reduction
goal.
The
reductions
which
are
not
creditable
include
those
which
would
have
occurred
even
without
passage
of
the
1990
CAA
Amendments
due
to
control
programs
already
in
place.
The
FMVCP
and
gasoline
RVP
standards
6
are
examples
of
such
non­
creditable
programs.

The
magnitude
of
the
noncreditable,
pre­
Clean
Air
Act
Amendments
FMVCP
reductions
is
calculated
as
follows.
First,
an
emission
estimate
is
obtained
from
the
Mobile
6
model
using
2005
as
the
evaluation
year,
and
setting
the
model
to
not
activate
the
post­
1990
Clean
Air
Act
controls,
such
as
the
Tier
1
and
Tier
2
standards.
The
resulting
emission
factors
are
then
multiplied
by
by
the
1990
VMT
estimate.
2005
is
selected
as
the
evaluation
year
because
that
is
the
year
by
which
Maine
DEP's
revised
15%
plan
demonstrates
that
the
15%
VOC
reduction
occurred.
Creating
this
calculation
allows
one
to
determine
the
amount
that
emissions
will
be
reduced
between
1990
and
2005
from
the
noncreditable
FMVCP
by
subtracting
the
resulting
value
from
the
actual
1990
on­
road
emission
estimate.
The
difference
between
the
two
values
produces
the
emission
benefit
derived
from
implementation
of
the
"
noncreditable"
FMVCP.
Maine
included
within
the
15%
plan
submittal
the
input
and
output
MOBILE6.2
files
documenting
these
calculations.
The
noncreditable
FMVCP
reductions
have
been
determined
to
be
35.93
tpsd.

Maine
has
no
RVP
reductions
to
account
for
since
Maine
has
been
using
gasoline
with
a
RVP
of
9.0
psi
or
lower
since
1989.

The
net
affect
of
these
adjustments
is
shown
within
Table
3
below:

Table
3:
Subtraction
of
non­
creditable
emission
reductions
1990
Rate­
of
Progress
Inventory
124.47
(
tpsd)

Non­
creditable
FMVCP
­
35.93
Non­
creditable
RVP
0
1990
Adjusted
Base
Year
Inventory
88.54
(
tpsd)

Step
4:
Calculate
Required
15%
Reductions
In
this
step,
the
adjusted
base
year
inventory
is
multiplied
by
15%
to
calculate
the
amount
of
the
required
15%
emission
reduction:

88.54
*
0.15
=
13.28
7
Step
5:
Calculate
Total
Expected
Reductions
by
1996
The
total
expected
reductions
from
the
1990
rate­
of­
progress
inventory
(
calculated
in
step
2)
include
the
15%
emission
reduction
calculated
in
step
4,
and
the
emission
reductions
anticipated
from
the
noncreditable
programs
as
outlined
in
step
3.
Additionally,
emission
reductions
that
occur
between
1990
and
1996
due
to
corrections
to
pre­
existing
(
pre­
1990)
but
deficient
I&
M
programs
and/
or
deficient
RACT
rules,
though
not
eligible
to
count
towards
the
15%
emission
reduction
requirement,
still
represent
emission
reductions
that
are
expected
to
occur
between
1990
and
1996.
Maine
did
not
have
a
pre­
1990
I&
M
requirement,
nor
any
"
RACT
Fix­
up"
obligations.

The
total
expected
emission
reductions
for
the
Portland
nonattainment
area
are
as
shown
in
Table
4:

Table
4:
Total
Required
Reductions
for
the
Portland
Area
Creditable
Required
Reductions
13.28
Non­
creditable
Reductions
35.93
Total
Required
Reductions
(
before
growth)
49.21
Step
6:
Set
Target
Emission
Level
for
1996
The
target
level
of
emissions
for
1996
is
obtained
by
subtracting
the
total
required
reductions
(
step
5)
from
the
1990
rate­
ofprogress
inventory
(
step
2).
For
the
Portland
area
this
yields:

124.47
­
49.21
=
75.26
Step
7:
Project
emissions
to
evaluation
year
­
2005
The
original
15%
plans
required
by
the
CAA
were
required
to
be
submitted
to
EPA
in
1993.
These
plans
were
to
include
emission
projections
to
1996,
the
year
by
which
the
15%
emission
reductions
were
to
be
achieved.
Due
to
the
circumstances
described
above,
Maine
DEP's
revised
15%
plan
could
not
conceivably
demonstrate
that
a
15%
emission
reduction
occurred
from
1990
levels
by
1996,
as
that
year
has
passed.
Accordingly,
an
alternative
year
that
would
demonstrate
the
required
level
of
emission
reductions
were
achieved
expeditiously
was
needed.
In
accordance
with
past
case
law,
once
a
statutory
deadline
has
8
passed
and
has
not
been
replaced
by
a
later
one,
the
deadline
then
becomes
"
as
soon
as
possible."
(
Delaney
v.
EPA,
898
F.
2d
687,
691
(
9th
Circuit,
1990)).
EPA
has
interpreted
this
requirement
to
be
"
as
soon
as
practicable."
Upon
consultation
between
EPA
and
Maine
DEP,
2005
was
determined
to
be
the
most
suitable
year
for
Maine's
revised
15%
analysis
to
demonstrate
the
15%
reduction
by.
Accordingly,
an
estimate
of
emissions
in
2005
was
needed.

Although
an
estimate
of
2005
emission
was
needed,
the
most
current
inventory
available
to
Maine
DEP
was
it's
2002
inventory,
and
so
an
estimate
of
growth
in
emissions
from
2002
to
2005
was
used
to
complete
the
15%
VOC
emission
reduction
demonstration.
The
projection
was
made
by
taking
the
2002
inventory
and
multiplying
it
by
growth
factors
which
estimate
growth
from
2002
to
2005.
Growth
factors
specific
to
each
source
category
were
used
since
the
sources
typically
grow
at
different
rates.

Maine
used
growth
factors
obtained
from
the
Bureau
of
Economic
Analysis
(
BEA)
via
a
tool
they
developed
called
the
Economic
Growth
Analysis
System
(
EGAS)
to
project
most
of
the
point
and
area
source
emissions
from
2002
to
2005.
The
growth
factors
were
available
by
SIC
code,
and
are
shown
within
the
file
"
GF1999­
2007PA1Andro.
xls"
submitted
as
part
of
the
State's
15%
SIP.
The
Maine
Department
of
Transportation
(
DOT)
provided
an
estimate
of
2005
VMT
for
the
on­
road
mobile
source
projection,
and
the
EPA's
Nonroad
model
was
used
to
project
emissions
for
that
sector.

Once
emissions
were
projected
to
2005,
a
review
was
made
to
see
if
any
controls
not
in
existence
in
2002
became
effective
by
2005.
If
so,
the
state
reduced
emissions
to
account
for
the
controls
as
will
be
described
in
section
II.
B.
of
this
document.
Maine
DEP
did
not
use
the
emission
reductions
generated
pursuant
to
it's
adoption
of
area
source
VOC
rules
developed
by
the
Ozone
Transport
Commission
(
OTC)
in
it's
15%
plan,
i.
e.,
Maine's
projected
2005
emission
estimates
do
not
reflect
emission
reductions
from
these
measures.
Maine
DEP
did
use
reductions
from
these
measures
to
meet
it's
5%
plan
emission
reductions
requirements
as
is
explained
in
Section
III.
of
this
document.

Table
5
below
compares
Maine's
projected,
controlled
2005
emissions
for
the
Portland
nonattainment
area
with
it's
1990
emission
estimates:
9
Table
5:
Comparison
of
1990
and
2005
VOC
Emissions
Emission
Source
Category
1990
Base
Year
Emissions
2005
projected,
controlled
Emissions
Point
9.65
4.32
*

Area
33.43
24.70
Off­
road
Mobile
18.08
15.75
On­
road
Mobile
63.31
23.48
Total
124.47
68.25
*
includes
0.82
tpsd
in
VOC
offsets
awarded
to
Spinnaker
Coating
The
CAA
Section
182(
b)(
1)(
A)
language
regarding
the
15%
VOC
emission
reduction
requirement
states
that
this
reduction
must
occur,
"
accounting
for
any
growth
in
emissions
after
the
year
in
which
the
CAAA
of
1990
were
enacted".
This
has
been
interpreted
to
mean
any
growth
in
emission
levels
between
1990
and
1996
must
also
be
offset
so
that
by
1996,
emission
levels
will
be
truly
15%
lower
than
they
were
in
1990.
{
Note
­
in
actuality,
emission
levels
will
be
reduced
by
more
than
15%
in
the
evaluation
year
because
other
required
reductions,
such
as
those
from
preenactment
FMVCP,
will
also
be
occurring
as
described
above.}

Maine's
projected,
controlled
2005
inventory
for
the
Portland
area
totals
68.25
tpsd.
This
is
considerably
lower
than
the
target
level
of
emissions
of
75.26
calculated
in
step
6.
Maine
DEP
has
therefore
shown
that
emissions
have
been
reduced
by
15%
from
1990
levels,
after
accounting
for
growth,
and
not
counting
the
non­
creditable
reductions
from
the
FMVCP
program.

II.
B.
EVALUATION
OF
CONTROL
MEASURES
A)
Point
Source
Controls
Maine
DEP's
revised
15%
plan
analysis
shows
that
VOC
emissions
from
point
sources
fell
5.33
tpsd
(
55%)
between
1990
and
2005.
Table
6
below
summarizes
the
control
programs
that
affected
this
decrease
in
emissions.
10
Table
6:
Point
Source
Controls
for
VOC
Sources
Point
Source
Category
Rule
Implementation
Date
Federal
Approval
Chapter
129
(
Surface
Coating)
May
31,
1995
June
17,
1994
(
59
FR
31154)

Chapter
130
(
Solvent
Degreasers)
May
31,
1995
June
17,
1994
(
59
FR
31154)

Chapter
134
(
Non­
CTG
Sources)
May
31,
1995
April
18,
2000
(
65
FR
20749)

Bulk
Terminal
Emission
Limit
May
31,
1996
October
15,
1996
(
61
FR
53636)

Additional
information
on
each
of
these
regulations
is
available
in
the
Federal
Register
notice
that
contains
EPA's
approval
of
them.

VOC
Offsets:
Maine
DEP's
revised
15%
plan
indicates
that
one
source
in
the
Portland
area,
Spinnaker
Coatings
in
Westbrook,
applied
for
and
obtained
VOC
offset
credits
in
the
amount
of
213
tons
which
could
be
used
(
emitted)
in
the
future.
To
account
for
this,
Maine
DEP
translated
these
emissions
into
what
could
be
emitted
during
a
typical
summer
day,
(
0.82
tons),
and
added
that
value
to
it's
projected
2005
(
and
2007
for
it's
5%
plan)
emission
estimate
from
point
sources.

B)
Area
Source
Controls
Maine
DEP's
revised
15%
plan
analysis
shows
that
VOC
emissions
from
area
sources
fell
8.73
tpsd
(
26%)
between
1990
and
2005,
despite
the
growth
that
occurred
in
population
and
other
activity
indicators.
The
discussion
below
summarizes
the
area
source
control
programs
that
caused
this
change
in
emissions.

Stage
I:
Maine
has
adopted
and
submitted
to
EPA
a
Stage
I
vapor
recovery
regulation
that
limits
VOC
emissions
from
the
filling
of
underground
storage
tanks
at
gasoline
stations.
The
rule
applies
to
facilities
with
throughputs
that
exceed
10,000
gallons
per
month.
Chapter
118
of
the
State's
VOC
control
regulations
entitled
"
Gasoline
Dispensing
Facilities
Vapor
Control"
was
11
submitted
to
EPA
on
July
11,
1994,
and
approved
as
a
revision
to
the
Maine
SIP
within
a
federal
register
notice
published
on
June
29,
1995
(
60
FR
33730).
The
State
projects
that
VOC
emissions
will
be
reduced
by
1.35
(
52%)
tpsd
by
this
program
between
1990
and
2005.

Stage
II:
Maine
has
adopted
and
submitted
to
EPA
a
Stage
II
vapor
recovery
regulation
that
limits
VOC
emissions
from
vehicle
refueling
activity
in
the
Portland
nonattainment
area.
Chapter
118
of
the
State's
VOC
control
regulations
entitled
"
Gasoline
Dispensing
Facilities
Vapor
Control"
was
submitted
to
EPA
on
July
26,
1995,
and
approved
as
a
revision
to
the
Maine
SIP
within
a
federal
register
notice
published
on
October
15,
1996
(
61
FR
53636).
The
rule
is
applicable
to
gasoline
stations
with
throughputs
greater
than
1,000,000
gallons
per
year.
The
state
included
the
Mobile6.2
runs
within
it's
revised
15%
plan
documenting
how
the
emission
reductions
from
the
stage
II
program
were
determined.
The
Mobile6.2
program
calculates
emission
reductions
from
a
State's
entire
set
of
on­
road
mobile
source
control
programs
simultaneously,
and
therefore
a
separate
amount
of
emission
reduction
credit
from
the
Stage
II
program
is
not
reported
in
the
State's
15%
SIP.

Cutback
Asphalt:
Maine
has
adopted
and
submitted
to
EPA
a
cutback
asphalt
regulation
(
Chapter
131)
that
prohibits
the
use
of
cutback
asphalt
for
most
applications
during
the
ozone
season.
Maine
adopted
this
rule
on
January
6,
1993,
and
submitted
it
to
EPA
as
a
revision
to
the
State's
SIP.
EPA
approved
the
rule
as
part
of
the
State's
SIP
within
a
federal
register
notice
dated
June
17,
1994
(
59
FR
31154).
The
State
determined
that
emissions
were
reduced
by
7.33
tpsd
(
95%)
between
1990
and
2005
due
to
this
control
program.

Architectural
and
Industrial
(
AIM)
Coatings:
Emission
reductions
were
taken
from
the
Architectural
and
Industrial
Maintenance
(
AIM)
surface
coating
emission
source
category
due
to
a
federal
rule
that
required
such
coatings
be
reformulated
to
emit
less
VOCs.
In
a
memo
dated
March
22,
1995,
EPA
provided
guidance
on
the
expected
reductions
from
the
national
rulemaking
on
AIM
coatings,
stating
that
emissions
would
be
reduced
by
20%.
Maine
correctly
calculated
the
emission
reductions
that
will
occur
due
to
the
federal
rule,
which
covered
the
architectural,
traffic
marking,
high
performance
maintenance,
and
other
specialty
purpose
coating
categories.
The
State
determined
that
despite
growth
in
this
sector
between
1990
and
2005,
emissions
were
reduced
by
0.46
tpsd
(
9%)
in
the
Portland
nonattainment
area
due
to
this
federal
rule.

Automobile
Refinishing:
A
November
29,
1994,
EPA
guidance
memorandum
specifies
that
States
can
assume
a
37%
control
level
for
this
source
category
due
to
a
National
rule.
The
State
projects
that
between
1990
and
2005,
the
net
effect
of
activity
12
growth
and
implementation
of
the
federal
rule
reduced
emissions
by
0.12
tpsd
(
20%)
in
the
Portland
nonattainment
area.

Consumer
Products:
On
June
22,
1995,
EPA
issued
a
guidance
memorandum
regarding
the
regulatory
schedule
for
consumer
and
commercial
products
which
indicated
that
States
that
have
not
adopted
their
own
consumer
and
commercial
products
rule
could
take
emission
reduction
credit
from
a
pending
national
consumer
and
commercial
products
rulemaking.
After
re­
calculating
it's
base
year
emission
estimate
to
account
for
updated
guidance
as
mentioned
earlier
in
this
document,
the
State
applied
the
recommended
control
level
of
12.5%
and
determined
that
between
1990
and
2005,
emissions
from
this
sector
actually
rose
by
0.19
tpsd
(
4%)
as
population
growth
overwhelmed
the
reductions
from
the
federal
rule.

C)
On­
road
Mobile
Sources
Maine
DEP
identified
and
modeled
within
it's
Mobile
6.2
runs
a
number
of
state
and
federal
motor
vehicle
emission
and
fuel
control
programs
that
reduce
emissions
in
the
state.
These
control
programs
are
discussed
below.
Region
1
has
confirmed
that
Maine
correctly
modeled
these
programs
together
to
calculate
the
overall
emission
reduction
benefit
from
them.

1)
Low
RVP
Gasoline
program:
On
June
26,
1991
the
State
submitted
a
letter
from
the
Governor
requesting
that
Maine
participate
in
the
reformulated
fuels
program.
This
request
was
published
in
the
Federal
Register
on
September
10,
1991,
56
FR
46119.
However,
Maine
subsequently
rescinded
it's
participation
in
this
program
and
replaced
it
with
it's
Chapter
119
rule,
a
low
RVP
program
which
limits
the
RVP
of
gasoline
sold
in
the
7
southern
most
Maine
counties,
including
all
of
the
Portland
1­
hour
area,
to
a
level
no
greater
than
7.8
from
May
1
to
September
15
of
each
year.
This
regulation
was
submitted
to
EPA
and
approved
into
the
State's
SIP
on
March
6,
2002
(
67
FR
10099).

2)
Motor
Vehicle
Inspection
and
Maintenance
(
I&
M)
program:

Maine
state
regulations
require
an
I&
M
program
in
Cumberland
county.
The
program
has
minimal
requirements,
essentially
only
requiring
a
check
of
gas
cap
fitting
adequacy.
An
anti­
tampering
program
which
checks
for
any
modification
to
exhaust
catalysts
exists
in
Portland,
Sagadahoc,
and
York
counties.
Maine
adopted
it's
automobile
inspection
and
maintenance
program
on
July
9,
1998,
and
submitted
it
to
EPA
as
a
revision
to
the
State's
SIP.
EPA
approved
the
program
into
the
state's
SIP
in
a
federal
register
notice
published
on
January
10,
2001
(
66
FR
1875).

3)
Tier
I
Federal
Motor
Vehicle
Control
Program:
The
EPA
promulgated
standards
for
1994
and
later
model
year
light­
duty
vehicles
and
light­
duty
trucks
(
56
FR
25724,
June
5,
1991).
13
Since
the
standards
were
adopted
after
the
Clean
Air
Act
amendments
of
1990,
the
resulting
emission
reductions
are
creditable
toward
the
15
percent
reduction
goal.

4)
California
Low
Emission
Vehicle
Program:
Chapter
127
of
the
Maine
DEP
Air
rules
is
entitled
"
New
Motor
Vehicle
Emission
Standards",
began
phasing
in
during
2001,
and
requires
the
sale
of
motor
vehicles
meeting
California
certification
standards
contained
within
Title
13
of
the
California
Code
of
Regulations
pertaining
to
emission
standards
for
motor
vehicles.
Maine
submitted
this
rule
to
EPA
as
a
revision
to
the
State's
SIP
on
February
25,
2004.
EPA
approved
the
program
into
the
Maine
SIP
in
a
final
rule
published
in
the
Federal
Register
on
April
28,
2005
(
70
FR
21959).

5)
Onboard
Vapor
Recovery
Systems:
This
is
a
federal
program
required
by
section
202(
a)(
6)
of
the
1990
CAAA.
For
passenger
cars,
the
onboard
control
requirements
will
be
phased
in
over
three
model
years
with
40
percent,
80
percent,
and
100
percent
of
new
car
production
being
required
to
meet
the
standard
in
model
years
1998,
1999,
and
2000,
respectively.
The
phase­
in
of
onboard
controls
for
light
trucks
will
follow
the
phase­
in
period
for
cars.
Onboard
controls
for
the
lighter
class
of
light
trucks
(
those
under
6000
pounds
GVWR)
will
be
phased
in
during
models
years
2001
through
2003,
while
onboard
controls
for
the
heavier
light
trucks
(
those
from
6001
through
8500
pounds
GVWR)
will
be
phased
in
during
models
years
2004
through
2006.
When
fully
phased
in
the
new
controls
will
capture
95
percent
of
refueling
emissions.

D)
Non­
road
mobile
Federal
Non­
road
Control
Program
EPA
has
established
emission
standards
for
a
variety
of
non­
road
engine
categories
that
will
reduce
ozone
precursor
emissions
over
the
time
period
covered
by
the
Maine
15%
plan.
These
standards
affect
heavy
duty
compression
ignition
(
diesel)
engines,
small
non­
road
spark­
ignition
(
gasoline)
engines,
large
non­
road
gasoline
engines,
gasoline
powered
outboard
and
personal
watercraft
engines,
commercial
diesel
marine
engines,
recreational
stern­
drive
and
inboard
engines,
and
locomotives.
Detailed
information
regarding
each
of
these
emission
control
programs
is
available
on
EPA's
web­
site
at:
www.
epa.
gov/
otaq.

EPA
has
also
created
a
draft
Nonroad
air
emissions
estimation
model
that
can
be
used
to
calculate
emissions
from
all
nonroad
engines
except
those
used
to
power
aircraft,
locomotives,
and
large
commercial
marine
vessels,
for
the
present
year,
and
for
past
or
future
years.
Maine
DEP
used
the
Nonroad
model
to
calculate
air
emissions
from
this
sector
in
the
Portland
area.
14
Region
1
has
reviewed
and
confirmed
the
emission
estimates
for
Nonroad
engines
Maine
has
used
in
it's
revised
inventories
and
ROP
plans.

Table
7
illustrates
the
decline
in
non­
road
emissions
Maine
predicts
will
occur
due
to
implementation
of
the
various
federal
non­
road
engine
controls
in
the
Portland
area.
The
estimates
were
derived
from
the
Nonroad
model,
combined
with
individual
emission
estimates
calculated
for
aircraft,
commercial
marine
vessels
(
CMVs),
and
locomotives.

Table
7
­
Non­
road
Emissions
Trend
(
tpsd)

1990
2002
2005
2007
VOC
18.08
17.04
15.75
14.71
On
April
30th,
2004,
EPA
published
a
final
rule
(
the
"
Phase
1"
rule),
which
included
provisions
for
revoking
the
one­
hour
ozone
standard
one­
year
from
the
effective
date
of
the
designations
for
the
8­
hour
ozone
standard.
This
requirement
is
codified
in
the
Code
of
Federal
Regulations
at
40
CFR
Part
50.9(
b).
Prior
to
this
happening,
ozone
nonattainment
areas
classified
as
moderate
or
above
were
required
to
include
in
their
submittals
under
section
172(
b)
of
the
CAA,
contingency
measures
to
be
implemented
if
ROP
was
not
achieved
or
if
the
standard
is
not
attained
by
the
applicable
date.

However,
on
May
26,
2005,
EPA
published
a
final
rule
(
70
FR
30592)
that,
in
light
of
the
revocation
of
the
one­
hour
ozone
standard,
removed
the
requirement
that
contingency
plans
be
adopted
for
ROP
plans
submitted
to
make
progress
toward
achievement
of
the
one­
hour
ozone
standard.
Accordingly,
Maine­
DEP's
revised
15%
ROP
plan
does
not
contain
contingency
measures.

Maine's
revised
15%
plan
analysis
indicates
that
the
State
easily
meets
the
15%
VOC
emission
reduction
requirement
by
2005.

III.
5%
Increment
of
Progress
Plan
On
July
18,
1997,
EPA
promulgated
a
new
national
ambient
air
quality
standard
(
NAAQS)
for
ozone
based
on
an
8­
hour
averaging
period.
Court
challenges
to
the
8­
hour
ozone
standard
delayed
implementation
of
it,
but
eventually
these
issues
were
resolved
and
on
April
30,
2004,
EPA
promulgated
designations
for
the
8­
hour
ozone
standard
in
the
Federal
Register
(
69
FR
23858).
The
effective
date
for
the
designations
was
June
15,
2004.
Portions
of
Maine
were
designated
nonattainment
for
this
standard,
15
including
the
Portland
8­
hour
area
which
was
classified
as
a
marginal
nonattainment
area.
The
Portland
8­
hour
marginal
nonattainment
area
differs
geographically
from
the
Portland,
1­
hour
moderate
area.
The
8­
hour
area
consists
of
Sagadahoc
county,
most
portions
of
Cumberland
and
York
counties,
and
one
town
in
Androscoggin
county.

On
April
30,
2004,
EPA
also
published
the
first
part
of
it's
rule
governing
implementation
of
the
8­
hour
ozone
standard
(
69
FR
23951).
This
will
be
referred
to
as
the
"
Phase
1"
rule
in
the
remainder
of
this
document.
Although
the
Phase
1
rule
dealt
primarily
with
issues
pertaining
to
the
new
8­
hour
ozone
standard,
it
included
some
provisions
relevant
to
the
one­
hour
ozone
NAAQS.
Of
particular
interest
to
Maine
was
a
provision
allowing
one­
hour
areas
with
unmet
attainment
demonstration
obligations
to
submit,
in
lieu
of
a
full
one­
hour
ozone
attainment
demonstration,
an
early
5%
increment
of
progress
plan
toward
achievement
of
the
8­
hour
standard.
Such
plans
would
need
to
be
submitted
by
no
later
than
one
year
from
the
effective
date
of
the
8­
hour
ozone
standard,
meaning
no
later
than
June
15,
2005.
Maine's
Portland
one­
hour
nonattainment
area
has
an
unmet
attainment
demonstration
obligation,
and
so
Maine
DEP's
June
9,
2005
SIP
revision
request
included
a
5%
increment
of
progress
plan.

The
geographic
area
covered
by
the
Portland
8­
hour
area
is
smaller
than
the
area
covered
by
the
Portland
1­
hour
area
in
that
it
only
includes
portions
of
Cumberland
and
York
counties,
whereas
the
1­
hour
area
covers
these
two
counties
entirely
(
plus
all
of
Sagadahoc
county).
Given
the
difficulties
of
SIP
planning
activities
at
a
sub­
county
level,
such
as
preparation
of
emission
inventories
at
such
a
level
(
see
elaboration
on
this
below),
Maine
DEP
developed
it's
5%
increment
of
progress
plan
such
that
it
covers
all
of
the
old
one­
hour
nonattainment
area.
As
such
it
covers
a
considerably
larger
area
and
plans
for
more
emission
reductions
than
is
required,
even
though
one
town,
the
town
of
Durham
in
Androscoggin
county,
is
not
included
in
the
plan.
EPA
worked
closely
with
the
Maine
DEP
in
development
of
this
plan,
and
we
believe
that
the
geographic
area
Maine
DEP
chose
to
cover
in
it's
5%
increment
of
progress
plans
is
appropriate
and
reasonable.
This
is
so
primarily
because
the
mix
of
stationary
and
mobile
emission
sources
is
fairly
uniform
across
the
three
county
area,
and
so
the
net
result
of
expansion
of
the
geographic
area
is
simply
an
increase
in
the
amount
of
emission
reductions
that
must
be
planned
for.

As
mentioned
above,
Maine
chose
not
to
prepare
their
5%
SIP
at
the
exact
geographic
area
as
defined
by
the
8­
hour
Portland
area,
as
this
would
have
necessitated
preparation
of
inventories
at
the
sub­
county
level.
Doing
so
presents
numerous
challenges.
For
example,
many
of
the
largest
area
source
emission
categories,
such
as
those
for
industrial
surface
coatings,
degreasing,
and
2"
Guidance
on
5%
Increment
of
Progress
(
40
CFR
51.905(
a)(
1)(
ii));
dated
August
18,
2004;
from
Lydia
Wegman,
Director,
OAQPS,
to
EPA
Regional
Air
Directors
16
graphic
arts,
are
produced
by
multiplying
SIC
level
employment
data
available
from
the
U.
S.
Census
Bureau
by
SIC­
specific
emission
factors.
When
done
at
the
county
level
using
the
Census
Bureau's
County
level
employment
database,
this
is
a
relatively
straightforward
calculation.
However,
preparation
of
a
subcounty
inventory
would
necessitate
use
of
the
Census
Bureau's
Zip­
Code
level
employment
database,
and
would
greatly
expand
the
number
of
calculations
needed
to
develop
an
emission
estimate.

Additionally,
EPA's
Nonroad
model
is
designed
to
produce
emission
estimates
at
the
full
county
level.
Although
the
model
can
be
re­
configured
to
produce
sub­
county
emission
estimates,
this
is
not
easily
done.
More
importantly,
doing
so
is
pointless
unless
one
has
in
hand
accurate
sub­
county
level
data,
such
as
estimates
of
lawn
and
garden,
recreational
boat,
and
construction
equipment
populations
and
activity
levels
at
the
sub­
county
level.
It
is
unlikely
that
Maine
DEP
could
gather
the
necessary
data
to
make
running
the
EPA's
Nonroad
model
at
the
sub­
county
level
a
productive
exercise.

Given
the
difficulty
and
additional
uncertainty
introduced
by
developing
emission
inventories
at
the
sub­
county
level,
it
is
not
likely
that
doing
so
would
produce
data
that
would
improve
our
decision
making
ability.
Accordingly,
we
believe
that
Maine
DEP's
use
of
full
county
emission
inventories
is
appropriate,
with
one
exception.
Since
development
of
on­
road
mobile
source
emission
estimates
at
the
sub­
county
level
is
not
unduly
burdensome,
and
critical
for
transportation
conformity
purposes,
Maine
DEP
developed
on­
road
mobile
source
inventories
for
the
base
and
projected
years
that
exactly
match
the
geographic
area
of
the
8­
hour
nonattainment
area.
This
was
done
to
establish
transportation
conformity
budgets
for
the
Portland
8­
hour
ozone
nonattainment
area.

III.
A.
5%
Increment
of
Progress
Plan
Requirements
EPA
issued
a
guidance
memorandum2
on
August
18,
2004
which
outlines
the
criteria
for
5%
increment
of
progress
plans.
In
essence,
the
guidance
requires
the
following:

1.
A
5%
emission
reduction
in
ozone
precursor
emissions
based
off
of
the
2002
inventory;
2.
Credit
is
not
allowed
from
emission
reduction
measures
already
in
the
SIP
as
of
2002;
3.
The
emission
reductions
must
occur
by
2007;
4.
Reductions
must
be
VOC,
NOx,
or
some
combination
of
these
17
that
equals
5%
in
total;
and,
5.
NOx
reductions
can
be
obtained
from
within
a
200
km
area
outside
the
nonattainment
area,
and
VOC
reductions
from
100
km
outside
the
area.

The
first
part
of
such
plans
is
a
demonstration
that
a
5%
reduction
will
occur
by
2007,
and
will
be
due
to
creditable
measures.

5%
Emission
Reduction
Calculation,
Step
1
The
first
step
in
this
calculation
is
the
establishment
of
a
2002
emissions
baseline.
Although
EPA's
August
18,
2004
guidance
allows
States
to
use
EPA's
draft
2002
National
Emissions
Inventory
(
NEI)
for
the
2002
baseline,
Maine
DEP
provided
a
better
2002
emissions
baseline
by
developing
their
own
2002
inventory.
This
inventory
includes
better
activity
data
in
many
instances
than
what
is
available
in
EPA's
NEI.
As
discussed
above,
Maine
DEP's
2002
emissions
inventory
was
prepared,
as
is
the
NEI,
at
the
full
county
level.
For
the
reasons
outlined
above,
EPA
believes
this
is
a
reasonable
and
appropriate
emissions
baseline.
Maine's
2002
inventory
of
ozone
precursors
for
the
full
3
county
area
is
shown
below
in
Table
8
by
major
source
category.

Table
8:
2002
Anthropogenic
Emissions
for
the
Portland
Area
Major
Source
Category
2002
VOC
Emissions
(
tpsd)
2002
NOx
Emissions
(
tpsd)

Point
3.29
13.08
Area
23.65
1.89
On­
road
30.94
61.20
Off­
road
16.59
13.23
Commercial
Marine,
Rail,
and
Aircraft
0.45
2.33
Total
74.90
91.70
5%
Emission
Reduction
Calculation,
Step
2
EPA's
August
18,
2004
5%
plan
guidance
allows
the
5%
reduction
to
be
made
from
only
VOC
emission
reductions,
only
NOx
reductions,
or
from
a
combination
of
VOC
and
NOx
reductions
which
in
total
equal
5%.
Maine
DEP
chose
to
demonstrate
it
could
meet
the
5%
emission
reduction
requirement
by
relying
exclusively
on
VOC
emission
reductions.
Therefore,
it's
emission
reduction
18
obligation
is
calculated
as
follows:
0.05
*
74.90
=
3.75
tpsd
of
VOC
emissions.

5%
Emission
Reduction
Calculation,
Step
3
The
third
step
in
the
5%
calculation
is
to
develop
a
2007
inventory
that
reflects
growth
and
controls
from
measures
already
in
the
SIP
or
expected
to
occur
due
to
federal
measures.
Maine
DEP
prepared
its
2007
inventory
for
the
three
county
Portland
area
by
using
several
different
resources.
For
the
point
and
area
source
categories,
Maine
DEP
used
EPA's
Economic
Growth
and
Analysis
System
(
EGAS)
to
obtain
growth
factors.
Based
upon
comments
from
EPA
Region
1,
Maine
DEP
revised
it's
2002
summer
day
estimate
for
the
largest
NOx
point
source
in
the
area,
Central
Maine
Power.
This
source
operates
as
a
peaking
unit,
and
so
it's
pattern
of
operation,
and
therefore
emissions,
are
erratic.
The
revised
2002
typical
summer
day
estimate
was
derived
by
determining
the
total
emissions
during
summer
weekdays
when
the
facility
was
producing
power,
then
dividing
that
value
by
the
number
of
weekday's
in
operation.
Maine
DEP
used
hourly
emissions
data
available
from
EPA's
acid
rain
program
to
make
this
calculation.
2002
summertime
emissions
were
determined
to
be
5.53
tpsd.
Maine
DEP
then
used
an
EGAS
growth
factor
to
project
this
revised
2002
emissions
estimate
to
2007
for
this
source.
During
development
of
draft
versions
of
the
5%
plan,
Maine
DEP
had
intended
to
use
NOx
emission
reductions
from
this
source
to
meet
part
of
it's
emission
reduction
obligation.
However,
as
the
final
plan
only
uses
VOC
emission
reductions.

Maine
DEP
used
EPA's
Nonroad
model
to
estimate
emissions
for
this
sector
for
2002
and
2007,
as
the
model
contains
both
growth
and
control
factors
which
reflect
the
phase
in
of
EPA's
various
emission
standards
for
nonroad
equipment.

For
on­
road
mobile
sources,
Maine
DEP
projected
emission
to
2007
using
a
forecast
of
vehicle
miles
traveled
provided
by
the
State's
Department
of
Transportation.

Table
9
below
shows
Maine's
projected
2007
emissions
inventory
for
VOCs;
NOx
is
not
shown
as
Maine's
final
plan
relies
exclusively
on
VOC
emission
reductions.

Table
9:
2002
and
2007
VOC
Emissions
by
Major
Source
Category
Major
Source
Category
2002
VOC
Emissions
(
tpsd)
2007
VOC
Emissions
(
tpsd)

Point
3.29
4.0
19
Area
23.65
25.52
On­
road
30.94
20.48
Off­
road
16.59
14.21
Commercial
Marine,
Rail,
and
Aircraft
0.45
0.5
Total
74.90
64.73
5%
Emission
Reduction
Calculation,
Step
4
In
Step
4,
the
required
5%
emission
reduction
of
3.75
tpsd
is
subtracted
from
the
projected
2007
emission
inventory
of
64.73
tpsd,
establishing
an
emissions
target
level
of
60.98
tpsd
for
2007.
Maine's
5%
plan
demonstrates
that
it
will
meet
this
target
by
reducing
the
area
source
inventory
by
4.47
tpsd,
taking
it
from
25.52
tpsd
down
to
21.05.
This
will
reduce
the
overall
inventory
similarly,
taking
it
from
64.73
tpsd
to
60.26
tpsd,
which
is
0.72
tpsd
below
the
target
level
of
emissions.

5%
Emission
Reduction
Calculation,
Step
5
The
final
step
in
the
5%
calculation
is
to
ensure
that
the
2007
projected,
controlled
inventory
is
5%
lower
than
the
2002
emissions
baseline.
This
step
is
required
because
in
a
rapidly
growing
area,
a
large
increment
of
growth
could
conceivably
overwhelm
the
5%
emission
reduction,
and
the
reductions
from
already
scheduled
SIP
and
Federal
control
programs.
This
is
not
the
case
in
Maine,
however,
as
the
projected,
controlled
emission
level
of
60.26
tpsd
is
almost
20%
lower
than
2002
emissions.

III.
B.
Emission
Control
Measures
that
will
Achieve
the
5%
Reduction
Maine
DEP's
5%
plan
demonstrates
that
it
will
achieve
the
required
level
of
emission
reductions
due
to
adoption
of
four
VOC
emission
control
measures
that
are
based
on
model
rules
developed
by
the
OTC.
The
four
rules
apply
to
small
source
solvent
cleaners
(
degreasers),
architectural
and
industrial
maintenance
(
AIM)
coatings,
consumer
and
commercial
products,
and
mobile
equipment
repair
and
refinishing.
Each
of
these
rules,
and
the
emission
reductions
anticipated
from
them,
are
discussed
below.

Chapter
130
Solvent
Cleaning
rule
This
regulation
establishes
requirements
for
testing,
evaluating,
and
limiting
VOCs
from
solvent
cleaning
machines
and
sets
minimum
requirements
for
equipment
and
operation
standards
in
order
to
3E.
H.
Pechan
and
Associates,
"
Control
Measures
Development
Support
Analysis
of
Ozone
Transport
Commission
Model
Rules,"
March
31,
2001.

20
reduce
VOC
emissions.
Maine
used
a
control
factor
of
66%
as
recommended
in
a
report
by
E.
H.
Pechan
and
associates3
in
work
done
for
th
Ozone
Transport
Commission.
Facilities
were
required
to
comply
with
the
rule
by
January
1,
2005,
and
Maine
DEP
expects
it
to
produce
2.57
tpsd
in
emission
reductions.
EPA
approved
this
rule
into
the
state's
SIP
in
a
final
rule
published
in
the
Federal
Register
on
May
26,
2005
(
70
FR
30367).

Chapter
151;
AIM
Coatings
rule
Chapter
151
establishes
limits
for
emissions
of
VOCs
from
51
AIM
coating
categories.
Compliance
with
the
rule
will
be
required
as
of
January
1,
2006,
and
Maine
DEP
expects
it
to
produce
0.99
tpsd
in
emission
reductions.
However,
Maine
DEP
will
need
to
adjust
the
credit
claimed
for
AIM
reductions
downward
to
reflect
recent
revisions
to
it's
Chapter
151
rule.
Specifically,
the
proposal
contains
a
new,
less
stringent,
emission
limit
for
interior
wood
clear
and
semitransparent
stains.
The
proposal
also
includes
a
less
stringent
2006
emission
limit
for
varnishes
(
although
by
2011
varnishes
are
required
to
meet
the
same
limit
as
in
the
existing
rule).
These
revisions
will
impact
the
emission
reductions
Maine
achieves
from
the
implementation
of
Chapter
151
by
2007.
However,
given
that
Maine's
5%
Plan
currently
includes
0.72
tpsd
of
surplus
credits,
it
appears
that,
even
with
these
adjustments,
Maine
will
be
able
to
meet
its
5%
Plan
target.

Additionally,
in
the
August
31,
2005
Federal
Register
(
70
FR
51694)
EPA
published
a
notice
soliciting
comments,
data
and
information
with
regard
to
calculation
of
emission
reductions
from
AIM
coating
rules.
Therefore,
future
adjustments
may
also
need
to
be
made
to
Maine's
credit
claim
from
this
rule.
However,
as
mentioned
above
Maine's
four
VOC
limiting
rules
achieve
surplus
emission
reductions
beyond
what
is
required
to
meet
the
5%
emission
reduction
obligation,
and
so
it
is
unlikely
that
such
adjustment
would
inhibit
Maine's
ability
to
meet
it's
5%
emission
reduction
target.

Chapter
152;
Consumer
and
Commercial
Products
rule
This
regulation
limits
emissions
of
VOC
from
consumer
products
by
establishing
emission
limits
for
consumer
product
source
categories.
Compliance
with
the
rule
was
required
by
May
1,
2005,
and
Maine
DEP
expects
it
to
produce
0.72
tpsd
in
emission
reductions
in
the
three
county
area.
21
III.
D
Chapter
153;
Mobile
Equipment
Repair
and
Refinishing
rule
This
regulation
limits
emissions
of
VOCs
from
mobile
equipment
refinishing
and
repair
facilities
by
limiting
the
VOC
content
of
coatings,
requiring
the
use
of
high
efficiency
coating
application
systems,
and
through
work
practice
standards.
Maine
used
a
control
factor
of
38%
as
recommended
in
the
previously
mentioned
report
by
E.
H.
Pechan.
This
38%
emission
reduction
is
above
and
beyond
the
emission
reductions
achieved
by
an
earlier
federal
rule
from
this
sector.
Facilities
were
required
to
comply
with
the
rule
by
January
1,
2005,
and
Maine
DEP
expects
it
to
produce
0.19
tpsd
in
emission
reductions
in
the
three
county
area.
EPA
approved
this
rule
into
the
state's
SIP
in
a
final
rule
published
in
the
Federal
Register
on
May
26,
2005
(
70
FR
30367).

Transportation
Conformity
Budget
Maine's
5%
increment
of
progress
plan
contains
projected,
controlled
emission
levels
for
on­
road
mobile
sources
for
2007.
Although
the
15%
plan
also
contains
projected,
controlled
emission
levels,
they
are
for
2005,
and
are
geographically
matched
to
the
full
county
Portland
one­
hour
nonattainment
area.
EPA
revoked
the
one­
hour
ozone
standard
on
June
15,
2005.
Therefore,
the
on­
road
mobile
source
VOC
and
NOx
emissions
estimates
for
2007
contained
in
Maine's
5%
increment
of
progress
plan
will
establish
a
transportation
conformity
budget,
but
the
2005
on­
road
mobile
estimates
in
the
15%
plan
will
not.

Although
Maine
DEP
prepared
it's
base
year
and
future
year
inventories
at
the
full
county
level,
the
state
included
in
it's
5%
plan
a
2007
emission
estimate
for
on­
road
mobile
sources
for
the
exact
geographic
area
that
comprises
the
Portland
8­
hour
nonattainment
area.
These
2007
emission
estimates
establish
transportation
conformity
budgets,
and
they
are
as
follows:
for
VOCs,
20.115
tpsd,
and
for
NOx,
39.893
tpsd.

In
the
August
30,
2005
Federal
Register
(
70
FR
51353)
EPA
published
a
notice
of
adequacy
determination
for
the
above
transportation
conformity
budgets.
These
budgets
were
calculated
in
accordance
with
standard
EPA
methods,
and
should
be
approved
into
the
State's
SIP
along
with
the
5%
increment
of
progress
plan.

IV.
Recommended
Actions
The
Maine
DEP
has
submitted
15%
and
5%
rate
of
progress
plans,
2002,
2005,
and
2007
emission
inventories,
and
transportation
conformity
budgets
for
2007
for
VOC
and
NOx
for
the
Portland
8­
hour
ozone
nonattainment
area
that
were
prepared
in
accordance
with
EPA
methods
and
guidance.
I
recommend
that
they
be
approved
22
into
the
State's
SIP
via
traditional
notice
and
comment
rulemaking.
