                                       
                                       
                                       
                                       
                                       
                                   SECTION 1
                                       
                         2007 Base Year Inventory SIP 
                                   for the 
                       New York Metropolitan 10-County 
                           PM2.5 Nonattainment Area  
                                       
                        Technical Support Documentation
                                       
                                       
 PREFACE

This document is to support EPA's approval of a revision to the New York State Implementation Plan (SIP) which pertains to the following: 

Where applicable, 2007 base year inventory annual emissions for VOC, NH3, PM2.5, PM10, NOx and SO2 for the New York portion of the New York-N.New Jersey-Long Island, NY-NJ-CT nonattainment area, henceforth referred to as the New York Metropolitan area (NYCMA), which include the following counties: Bronx, Kings, Nassau, New York, Orange, Queens, Richmond, Rockland, Suffolk and Westchester.
 
This technical support document (TSD) contains a detailed review of New York's 2007 base year emission inventory submittal.  Among the topics discussed below are the recent history and criteria for approval and EPA's final recommendations.	


 BACKGROUND 

Section 182(a)(3) and 172(c)(3) of the Clean Air Act requires the periodic submission of base inventory for SIP planning process to address the pollutants for the eight hour-ozone, PM2.5 and CO national ambient air quality standard.  Identifying the base year gives certainty to states that requires submission of the ozone, PM2.5 and CO emission inventories periodically.  These requirements allow the EPA, based on the states' progress in reducing emissions, to periodically reassess its policies and air quality standards and revise them as necessary.  Most important, the ozone, PM2.5 and CO inventories will be used to develop and assess new control strategies that the states will need to submit in their attainment demonstration SIPs for the new national ambient air quality standards for ozone, PM2.5 and for CO.  The base year inventory may also serve as part of statewide inventories for purposes of regional modeling in transport areas.  The base year inventory plays an important role in modeling demonstrations for areas classified as nonattainment and outside transport regions.  For the reasons stated above, ideally EPA would therefore emphasize the importance and benefits of developing a comprehensive, current, and accurate ozone and PM2.5 emission inventory (similar to the 1990 base year inventory effort).  In this case, the 2007 base year has been selected as the inventory that will be used for planning purposes for the NYCMA PM2.5 nonattainment area



 CRITERIA FOR APPROVAL

There are general and specific components of an acceptable emission inventory.  In general, the State must submit a revision to its SIP and the emission inventory must meet the minimum requirements for reporting by source category.  Specifically, the source requirements are detailed below.

The Level I and II review process is used to determine that all components of the base year inventory are present.  The review also evaluates the level of supporting documentation provided by the State and assesses whether the emissions were developed according to current EPA or acceptable alternative guidance.  The data quality is also evaluated. 

The Level III review process is outlined here and consists of points that the inventory must adequately address.  For a base year emission inventory to be acceptable it must pass all of the following acceptance criteria: 

 Adequate documentation must be provided that enabled the reviewer to determine the emission estimation procedures and the data sources used to develop the inventory.

 Evidence that the inventory was quality assured by the state and its implementation documented.

 The point source inventory must be complete.

 Point source emissions must have been prepared or calculated according to the current EPA guidance.

 The area source inventory must be complete.

 The area source emissions must have been prepared or calculated according to the current EPA guidance.

 Non-road mobile emissions were prepared according to current EPA guidance for all of the source categories.

 The method (e.g., HPMS or a network transportation planning model) used to develop VMT estimates must follow EPA guidance.  The VMT development methods must be adequately described and documented in the inventory report.


 The MOBILE model must be correctly used to produce emission factors for each of the vehicle classes.


 DETAILED ACTION AND EVALUATION


This TSD contains a detail discussion and summary of the review conducted by EPA for, where applicable, the 2007 base year inventory annual emissions for VOC, NH3, PM2.5, PM10, NOx and SO2 for the NYCMA PM2.5 nonattainment area.

Table 1A below shows the 2007 base year VOC, NH3, PM2.5, PM10, NOx and SO2 emission inventories for the NYCMA nonattainment areas.

                                   Table 1A
                                       
              2007 NYCMA PM2.5 Base Year Inventory (in Tons/Year)
                                       
                                 Source Sector
                                       
                                      VOC
                                      NOx
                                     PM10
                                     PM2.5
                                      SO2
                                      NH3
                                     Point
                                                                       3,707.01
                                                                      38,195.94
                                                                       3,206.28
                                                                     124,750.31
                                                                      43,886.32
                                                                         882.89
                                   Nonpoint
                                                                     101,481.89
                                                                      41,899.74
                                                                      48,054.84
                                                                      11,621.00
                                                                      29,513.22
                                                                       1,960.83
                                    Nonroad
                                                                      46,026.72
                                                                      59,512.46
                                                                       4,170.45
                                                                       3,899.30
                                                                       6,052.88
                                                                           1.96
                                   On‐road
                                                                      71,379.46
                                                                     149,501.91
                                                                       9,723.36
                                                                       6,835.30
                                                                         982.77
                                                                       3,484.40
                                   Road Dust
                                                                            N/A
                                                                            N/A
                                                                       3,483.59
                                                                       1,174.60
                                                                            N/A
                                                                            N/A
                                    Total 
                                                                     222,595.08
                                                                     289,110.05
                                                                      68,638.51
                                                                     148,280.52
                                                                      80,435.19
                                                                       6,610.08


Details on How New York Meets Criteria 1 for the Quality Assurance Plan

Quality Assurance Plan Implementation

The Quality Assurance (QA) plan was implemented for all portions of the inventory.  The QA plan included a QA/Quality control (QC) program for assessing data completeness and standard range checking.  Critical data elements relative to the inventory sources were assessed for completeness.  QA checks were performed relative to data collection and analysis, and double counting of emissions from point, area and mobile sources.  QA/QC checks were conducted to ensure accuracy of units, unit conversions, transposition of figures, and calculations. The QA plan for the inventory was performed in accordance with section 6.0 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005.

See Appendices F-H, and page 35 of New York's Redesignation Request and Maintenance Plan for the 1997 Annual and 24 Hour PM2.5 NAAQS: New York-Northern New Jersey-Long Island, NY-NNJ-LI, NY-NJ-CT Nonattainment Area, dated June 2013.

   B.  Details on How New York Meets Criteria 2 and 3 for the Point Source Inventory

Point Source Inventory
New York's inventory includes major point sources based on thresholds for each pollutant in tons per year (tpy).  The inventory report describes how point source activity levels and their associated parameters were developed, and how the data were used to calculate emission estimates.  The report provides referenced documents for activity level and emission factors used.  Information on how rule effectiveness and control efficiencies were derived (with the associated sample calculations) were also provided.  Plant summary information on detailed, plant, county and nonattainment area levels, are included in the inventory.  Where applicable, annual emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 for PM2.5 nonattainment area. The inventory was developed in accordance with section 5.3 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005. 

See Appendices F-H, and page 36 of New York's Redesignation Request and Maintenance Plan for the 1997 Annual and 24 Hour PM2.5 NAAQS: New York-Northern New Jersey-Long Island, NY-NNJ-LI, NY-NJ-CT Nonattainment Area, dated June 2013.


   C. Details on How New York Meets Criteria 4 and 5 for the Area Source Inventory

Area Source Inventory
The inventory lists the source categories that are included in (and excluded from) from the area source inventory.  The inventory documentation includes emissions factors, activity levels, seasonal adjustment factors, and sample calculations.  Referenced information for the input values to equations is included.  Point source contributions have been correctly factored out of the area source category totals where appropriate.  Rule effectiveness, control efficiency and rule penetration were correctly applied for several source categories and a discussion as to the basis for application is provided.  

The primary sources of anthropogenic ammonia emissions are two agricultural operations, livestock and fertilizer.  Ammonia emissions from livestock and fertilizer were prepared by the EPA using the Carnegie Mellon University (CMU) Ammonia Model, version.6.  The model runs are based on 2007 activity levels.  Ammonia emissions for industrial refrigeration, composting, and publicly owned treatment works were prepared by the EPA.

Area source emissions are presented on a source category, county basis.  Where applicable, annual emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 for PM2.5 nonattainment area.  The inventory was developed in accordance with section 5.4 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005.

See Appendices F-I, and page 35 of New York's Redesignation Request and Maintenance Plan for the 1997 Annual and 24 Hour PM2.5 NAAQS: New York-Northern New Jersey-Long Island, NY-NNJ-LI, NY-NJ-CT Nonattainment Area, dated June 2013.

                              
   D. Details on How New York Meets Criteria 7 for Non Road Mobile Source Inventory

Nonroad Mobile Source Inventory
For the New York, the predominant non-road mobile source categories (i.e., agricultural equipment, construction equipment, industrial equipment, airport service equipment, light commercial equipment, lawn and garden equipment...etc.) were developed by the Version 2008a of EPA's Nonroad Emissions Equipment Model released by EPA's Office of Transportation and Air Quality (OTAQ).  Nonroad mobile source emissions are presented on a source category, county basis. Where applicable, annual emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 for the NYCMA PM2.5 nonattainment area.  The inventory was developed in accordance with section 5.5.2 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005.

Aircraft Emissions
Where applicable, Aircraft emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 PM2.5, NOx and SO2 were calculated based on the number of landing and takeoffs (LTO) cycles generated at each airport.  These values were used as inputs to the Emissions and Dispersion Modeling System, the Federal Aviation Agency modeling tool.  Aircraft source emissions are presented on a source category, county basis. Where applicable, annual emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 for the NYCMA PM2.5 nonattainment area.


Locomotive Emissions
Locomotive emissions were based on version 2 of the 2008 NEI.  Where applicable, locomotives emissions for VOC, NH3, PM2.5, PM10, NOx and SO2 are calculated based on a report developed by the New York State Energy Research and Development Authority (NYSERDA).  The locomotive inventory is based upon a survey conducted of the national, regional, and local freight railroads, as well as passenger and commuter rail lines operation in New York State.  Information collected in the survey was used in development of the emissions inventory.  Where applicable, annual emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 for total combined nonroad emissions only by county for the all areas.  


Commercial Marine Vessel Emissions
Commercial Marine Vessel (CMV) emissions for 2007 are based on version 2 of the 2008 National Emission Inventory (NEI). The NEI emissions from Bronx, Kings, Nassau, New York, Queens, Richmond, Rockland, Suffolk and Westchester Counties are built off of the CMV emissions report prepared by the Starcrest Consulting Group in conjunction with their work on the New York Harbor Deepening Project. This emissions report was undertaken as part of the Harbor Deepening Project to update the baseline inventory and to optimize the offsets that would be utilized by the Army Corps of Engineers. These data are based on actual operational data from an intensive survey of all CMV types, activity, and fuel consumption.  Other areas of the state used other methodologies in version 2 of 2008 NEI.  The detailed CMV emissions inventory methodology can be found in the EPA document entitled "Documentation for Aircraft, Commercial Marine Vessel, Locomotive, and Other Components of the National Emissions Inventory  -  Volume I  -  Methodology".

CMV source emissions are presented on a source category, county basis. Where applicable, annual emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 for the NYCMA PM2.5 nonattainment area. The inventory was developed in accordance with section 5.5.2 of  Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005.

For Aircrafts, Locomotive and CMV, see Appendices F-I, and Section B2 of New York's Redesignation Request and Maintenance Plan for the 1997 Annual and 24 Hour PM2.5 NAAQS: New York-Northern New Jersey-Long Island, NY-NNJ-LI, NY-NJ-CT Nonattainment Area, dated June 2013.

The inventory was developed in accordance with section 5.5.2 of  Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005.


   E. Details on How New York Meets Criteria 8 and 9 for the Onroad Source Inventory

Onroad Mobile Source Inventory
For the onroad mobile source category, the primary indicator and tool for developing on-road mobile growth and expected emissions are vehicle miles traveled (VMT) and EPA's Motor Vehicle Emissions Simulator (MOVES) model.  The 2007 pollutant emission factors were generated by MOVES (with the associated controlled measures applied, where appropriate) and applied to the monthly VMT projections provided by the State.  Monthly emissions were then combined to develop annual emission estimates.

MOVES model was used to generate emission factors for VOC, NH3, PM2.5, PM10, NOx and SO2 on-road vehicle emission estimates.  The report also explains how MOVES emission factors are used, in conjunction with VMT data, to estimate mobile source emissions for the inventoried areas.  It provides the sources for the key inputs into the MOVES model.  Key assumptions are also included.  The methods used to determine on-road emission estimates are explained in the report.  VOC, NH3, PM2.5, PM10, NOx and SO2 annual combined on-road mobile emissions by county are provided.  Where applicable, annual emissions are provided for VOC, NH3, PM2.5, PM10, NOx and SO2 for all areas.  The breakdown of annual emissions by highway vehicle classifications is included in the inventory. 

The reader is referred to Appendix D, and Section B1 of New York's Redesignation Request and Maintenance Plan for the 1997 Annual and 24 Hour PM2.5 NAAQS: New York-Northern New Jersey-Long Island, NY-NNJ-LI, NY-NJ-CT Nonattainment Area, dated June 2013.


Conclusion
New York has a SIP that will ensure that the requirements for emission inventory measures and reporting are adequately met.  To comply with the emission inventory requirements, the State submitted a complete inventory containing point, area, on-road, and non-road mobile source data, and accompanying documentation.

The SIP submittal does not present any particular inconvenient issues associated with enforceability.

Recommendation
EPA is approving this SIP submittal as meeting the essential reporting requirements for an Emission Inventory.  EPA will also make a finding that the SIP revision meets the requirements for emission inventories. 
