SECTION 2

2007 Attainment and 2017 and 2025 Projection Inventories 

for the 

New York Metropolitan 10-County

PM2.5 Nonattainment Areas  

PM2.5 Redesignation Full Maintenance Plan SIP 

Technical Support Document 



A.	Background

The maintenance demonstration must demonstrate effective safeguards of
the NAAQS for at least 10 years following the redesignation showing that
future year PM2.5 and associated precursors emissions will not exceed
the level of the attainment year.  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), PM2.5
nonattainment area, 2007 emissions were projected to 2017 and 2025.  New
York must demonstrate, with the control programs identified in this SIP,
that total 2017 or 2025 projected emissions do not exceed the 2007
emission levels.  Below are EPA’s review and evaluation of the
maintenance demonstration for the area.

Inventory Requirements for a Redesignation/Full Maintenance Plan

In order for states to satisfy redesignation/maintenance plan inventory
requirements under sections 110(a)(1), 172(c)(3), and 175A of the CAA,
the following inventory elements must be submitted: 

Maintenance Plan Attainment Inventory 

Maintenance plan provisions include a comprehensive, accurate, and
current emission inventory from all sources of relevant pollutants in
the nonattainment area.  States are required to develop an attainment
inventory to identify the level of emissions in the area which is
sufficient to attain the NAAQS.  This inventory should be consistent
with EPA’s most recent guidance and should include the emissions
during the time period associated with the monitoring data showing
attainment.

Maintenance Plan Interim Year Inventory 

At a minimum, emissions should be projected to a midpoint year between
the attainment year and the endpoint/10-year inventory.  This is the
interim inventory.  Provide summary of controlled emissions for point,
area, nonroad and onroad mobile sources for the PM2.5 nonattainment area
for the interim year inventory.

Maintenance Plan Projected Final Year Inventory 

Emissions should be projected from the attainment year to at least 10
years into the future.  Provide summary of controlled emissions for
point, area, nonroad and onroad mobile sources.  This is the
endpoint/10-year inventory.

B.	Selection of 2007 Base Year as the Maintenance Plan Attainment Year
Inventory

For the NYCMA PM2.5 nonattainment areas, air quality monitoring data
shows that for 2007-2009 was NOT in violation of the PM2.5 annual or
daily standards.  Historically, for the attainment inventory the state
would select an attainment year inventory based on the year in which an
area is not in violation of the standard.  This means that New York can
select 2007, 2008 or 2009 as the attainment year inventory for the PM2.5
annual and daily standard.  The State believes that the 2007 inventory
is an appropriate and representative inventory to use attainment
inventory NYCMA PM2.5 nonattainment area because 2007 inventory is the
most comprehensive inventory developed by states in the region for SIP
purposes.

EPA is approving the 2007 PM2.5 inventory for the NYCMA PM2.5
nonattainment areas.  Detailed evaluation of the 2007 inventory is
located in Section 1 of EPA’s TSD.   See Table 1A for 2007 base year
emissions inventory for the NYCMA PM2.5 nonattainment area.

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



2017 and 2025 Projection Inventories 

There are general and specific components for an acceptable 2017 and
2025 projection.  In general, the State must submit a revision to its
SIP and the aforementioned components must meet certain minimum
requirements for reporting by source category.  Specifically, the source
requirements are detailed below.

A review process is used to determine that all components of the
projection inventories 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.  For the projection inventories to be acceptable
they must pass the following acceptance criteria: 

Were the 2017 and 2025 projection inventories developed in accordance
with the procedures outlined EPA’s latest guidance 1,3,4,6,7? 

Were the Plans developed in accordance with EPA’s latest guidance for
Growth Factors, Projections, and Control Strategies for Reasonable
Progress Goal Plans 1,3,4,6,7? 

Calculation of 2017 and 2025 Projection Year Emission Inventories

A projection of 2007 anthropogenic emissions to 2017 and 2025 is
required to determine the emission reductions needed for inventory
maintenance plan.  The 2017 and 2025 projection year emission
inventories are calculated by multiplying the 2007 base year inventory
by factors which estimate growth from 2007 to 2017 and 2025.  A specific
growth factor for each source type in the inventory is required since
sources typically grow at different rates.  

Projection Methodology

 ADVANCE \d14 Major Point Sources

 tc \l3 "Major Point Sources 

Electric Generating Units (EGU) and Non-Electric Generating Units
(Non-EGUs)

For the major point source category, the projected emissions inventories
were first calculated by estimating growth in each source category.  As
appropriate, the 2007 emissions inventory was used as the base for
applying factors to account for inventory growth.  The point source
inventory was grown from the 2007 inventory to 2017 and 2025 for each
facility using growth factors utilized in US Department of Energy’s
(USDOE) Annual Energy Outlook (AEO) projections for 2011-Electirc Region
and Fuel Source for EGUs and AEO 2010, state supplied employment data. 

The reader is referred to Technical Support Document for Development of
2025 Emissions Inventory for PM2.5 nonattainment areas in the MANE-VU
Region, Version 3.3, Revision 2.1, dated January 13, 2012. This document
provides further details and references on how projections were
performed. 

Since these methodologies and growth indicators are some of the
preferred growth indicators to use as outlined in EPA Guidance,
1,3,4,6,7 EPA finds New York’s methodology for projecting point
sources to be acceptable.

Area Sources

For the area source category, New York projected emissions from 2007 to
2017 and 2025 using growth factors generated from USDOE AEO 2010, state
supplied population, employment data and vehicle miles travelled (for
road dust categories)  where appropriate.  

The reader is referred to Appendix H and I Page 35, Section 3 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.

These documents provide further details and references on how
projections were performed. 

Since these methodologies and growth indicators are some of the
preferred growth indicators to use as outlined in EPA Guidance,
1,3,4,6,7 EPA finds New York’s methodology for projecting area sources
to be acceptable.

Non-Road Mobile Sources								

Nonroad Vehicle Equipment Emissions

Non-road vehicle equipment emissions were projected from 2007 to 2017
and 2025 using the EPA’s NONROAD Model2008a.  This model contains
growth factors, which are based on the historical trends in nonroad
equipment activity. This model was use to calculate past and future
emission inventories for all nonroad equipment categories except
commercial marine vessels, locomotives and aircrafts.  Revised inputs to
the model by the State included meteorological, fuel oil, housing unit
and population data where appropriate.  Emissions were determined on a
monthly basis and combined to provide annual emission estimates.

Aircrafts, Locomotives and Commercial Marine Vessels (CMV)

CMV emissions were projected from 2002 to 2017 and 2025 using Energy
Information Administration (EIA) Annual Energy Outlook (AEO) data and
EPA’s regulatory impact assessment RIA report, for category 1 and 2
vessels and EPA’s and RIA report for category 3 vessels based on
combined growth and control factors.  

Aircraft emissions were projected from 2007 to 2017 and 2025 based on
landing and takeoff growth factors from the Federal Aviation
Administration Terminal Area Forecast System for 2009-2030.  

Locomotives emissions were projected from 2007 to 2017 and 2025 based on
combined growth and control factors from EPA’s Regulatory Impact
Analysis for control of locomotive engines and USDOE’s 2006 Annual
Energy Outlook report.

For nonroad mobile inventory, the reader is referred to Page 34, Section
3 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.  These
documents provide further details and references on how projections were
performed. 

Since these methodologies and growth indicators are some of the
preferred growth indicators to use as outlined in EPA Guidance,
1,3,4,6,7 EPA finds New York’s methodology for projecting non-road
mobile sources to be acceptable.

Onroad Mobile Sources

New York State is modeled using county-specific inputs for meteorology,
vehicle activity and population, fuel formulation data, and I/M program
information. The on-road mobile source projection inventory was
developed by using MOVES with vehicle mile travelled (VMT) and vehicle
population projections for each future inventory year based on a linear
regression of Highway Performance Monitoring System (HPMS) historical
data for forecasting VMT prepared by the NYSDOT. These projections
employed HPMS data. 

All on-road mobile source emissions were estimated using EPA's Motor
Vehicle Emissions Simulator (MOVES) model using locally-developed inputs
for each of the New York counties. These inputs include varying
meteorological data, vehicle activity, fuel characteristics, and
emissions control programs.

MOVES is then run to produce emissions for each vehicle and road type
combination for all required counties.

For onroad mobile inventory, the reader is referred to Page 31, Section
3 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.  These
documents provide further details and references on how projections were
performed.

Since these methodologies and growth indicators are some of the
preferred growth indicators to use as outlined in EPA Guidance,
1,3,4,6,7 EPA finds New York’s methodology for projecting on-road
mobile sources to be acceptable.

Tables 2A-2B shows the 2017 and 2025 projection emission inventories
controlled after 2007 using the aforementioned growth
indicators/methodologies for the NYCMA PM2.5 nonattainment area.  Tables
3 and 4 shows the control strategies.

Table 2A

2017 NYCMA PM2.5 Nonattainment Area 

Projection Year Inventory (Controlled)

 (in Tons/Year)

On‐road 	33,083.83 	68,362.66	7,171.83	3,897.71 	939.20	2,340.95

Road Dust 	N/A 	N/A	2,959.46	954.01 	N/A

	Tappan Zee Project	N/A 	457.00	N/A	N/A 	N/A

	Total  	157,414.67 	187,724.00	50,672.82	141,355.28 	53,048.17 
5,124.68



Table 2B

2025 NYCMA PM2.5 Nonattainment Area 

Projection Year Inventory (Controlled)

 (in Tons/Year)

‐road 	26,911.17 	51,260.81	6,952.22	3,291.09 	935.40	2,443.53

Road Dust 	N/A 	N/A	3,184.31	960.05 	N/A

	Total  	150,500.68 	167,147.34	53,923.85	140,963.45 	53,520.61 
5,241.57



Table 3 List of Post-2002 New York Control Measures for PM2.5 and
Precursors 

Name of Control  Measure	Type of measure	Targeted Pollutants	Maintenance
Plan Measure	State Citation



NOx	PM2.5	SO2	VOC	NH3



Architectural and Industrial Maintenance Coatings	State



X

	6 NYCRR 205

Reasonably Available Control Technology for Major Facilities	State	X

	X

	6 NYCRR 212.10

Solvent Metal Cleaning Process	State



X

	6 NYCRR 226

Reasonably Available Control Technology for Major Facilities of Oxides
of Nitrogen	State	X



	X	6 NYCRR 227-2

Portland Cement Plants	State	X





6 NYCRR 220-1

Glass Plants	State	X





6 NYCRR 220-2

Surface Coating Processes, Commercial and Industrial Adhesives, Sealants
and Primers	State



X

X	6 NYCRR 228

Graphic Arts	State



X

	6 NYCRR 234

Portable Fuel Container Spillage Control	State



X

X	6 NYCRR 239

New York I/M Program	State	X

	X

X	6 NYCRR 217

Residential Woodstove NSPS	Federal rule	X	X

X

X

	CAIR	Federal rule	X

X





Federal Tier 2 Gasoline Sulfur Program	Federal rule

	X

	X

	Federal Clean Diesel Program	Federal rule	X	X	X	X

X

	Control of Emissions from Nonroad Large Sparking Engines, and
Recreational Engines (Marine and Land-based)	Federal rule	X	X

X

X

	Control of Emissions of Air Pollution from Nonroad Diesel Engines and
Fuel	Federal rule	X	X	X

	X

	

Table 4-List of 2007-2009 New York Maintenance Plan Control Measures for
PM2.5 and Precursors

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nd all-terrain vehicles)	Federal Rule	X

	X

X

	Gasoline Boats and personal watercraft, outboard engines	Federal Rule	X
X

X

X

	

Emission Inventory Guidance Documents

1Emission Inventory Improvement Program guidance document titled Volume
X, Emission Projections, dated December 1999 

2Draft Notice of Proposed Rulemaking for PM2.5 SIPs, dated August 2010

3Guidance for Growth Factors, Projections, and Control Strategies for
the 15 Percent Rate of Progress Plans, dated March 1993

4Guidance on the Post-1996 Rate of Progress Plan and Attainment
Demonstration, dated January 1994

5Emission Inventory Guidance for Implementation of ozone and Particulate
Matter NAAQS and Regional Haze Regulation, dated November 2005

6EPA’s follow-up memo “8-Hour Ozone National Ambient Air Quality
Standards Implementation-Reasonable Further Progress (RFP), dated August
2006

7Guidance on the Use of Models and Other Analyses for Demonstration
Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze,
dated April 2007 

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