Appendix B

Georgia Marketing Rule Revocation

Technical Demonstration

In order to demonstrate that removal of Georgia Rule 39-3-1-.02(bbb),
Georgia Marketing Rule, will still result in a decrease in VOC and NOx
emissions over time and will not interfere with maintenance of the 1997
ozone NAAQS or attainment of the 2008 Ozone NAAQS, NOx and VOC emissions
inventories were calculated for two different scenarios over time and
compared with key emissions budgets/limits.  Emission inventory years
were 2008, 2010, 2013, 2016, 2024, 2030, and 2040.

One scenario quantifies emissions with the Georgia Marketing Rule in
place and the other with the Rule removed. This is accomplished by using
the two different Reid Vapor Pressure (RVP) limits of the two types of
gasoline, one labeled “Georgia Gas” representing the Georgia
Marketing Rule RVP requirements and the other, “conventional gas”,
which is the gasoline that would be used under Federal RVP requirements.
 The RVP for conventional gasoline is, on average, 0.8 psi higher than
for Georgia Gas in the 13-county Atlanta area and 2.0 psi higher for the
remaining seven counties in the Atlanta ozone NAA for the 1997 ozone
NAAQS (RVP for conventional gas requirements is referenced in 40 CFR
80.27(a)(2)(i-ii) and 40 CFR 80.27(d)(1-2)) as well as the additional 25
county “area of influence” that completes the 45 county area.   
Therefore, the “Georgia Gas” case is based on model defaults, while
the conventional gas case has the same inputs except the RVP is
increased by 2.0 psi or 0.8 psi in the relevant county.  In all
scenarios, it is assumed all gasoline contains 10% ethanol. For
instance, for the 13-county Atlanta region (13 county previous 1-hr
ozone NAAQS nonattainment area consisting of Cherokee, Clayton, Cobb,
Coweta, DeKalb, Douglass, Fayette, Forsyth, Fulton, Gwinnett, Henry,
Paulding, and Rockdale counties), the RVP for model years 2012 or later
is 7.8 psi in the MOVES 2010b fuel default database (7.0 psi + 0.8 psi
allocated from ethanol waiver).  This is what is used for the “Georgia
Gas” scenario. For the “Conventional Gas” scenario, RVP used would
be 8.6 psi (7.8 psi RVP rule + 0.8 ethanol waiver) which is 0.8 psi
higher than “Georgia Gas”.  For the remaining counties in the 45
county Georgia Gasoline Marketing Rule area, MOVES 2010b defaults and
“Georgia Gas” scenario apply 7.7 psi (7.0 psi +0.7 psi allotted to
ethanol waiver). In this case, 9.7 psi was used in the “Conventional
Gas” scenario (9.0 psi + 0.7 psi allotted to ethanol waiver) which is
2.0 psi higher than “Georgia Gas”. The sulfur content requirement is
the same for Georgia Gas and Conventional Gas and is illustrated by
MOVES 2010b defaults listing the same sulfur content for all gasoline in
Georgia. For ozone NAAQS, model runs were conducted using the scenario
of weekday traffic and typical summer conditions (July) to provide the
highest possible NOx and VOC emission levels and greatest sensitivities
to changes in RVP. 

Demonstrating non-interference using this conservative approach allows
for the assumption of non-interference in all other cases with regards
to the ozone NAAQS and removal of the Georgia Marketing Rule. There was
also an analysis comparing NOx emissions with and without the Georgia
Gasoline Rule for confirmation of non-interference with the PM2.5 NAAQS
and in this case July was used as a dummy month and annualized input
data into the emissions model were inputted. This data originated from
input used with the PM2.5 maintenance plan submittal.  See methodology
sections below for further details on MOVES 2010b inputs and fuels.

For clarification, the emissions were calculated in 25, 13, 7, and 2
county groupings for the analysis of impacts of GA Marketing rule
removal on Georgia attaining the 2008 ozone NAAQS and maintain
attainment of the 1997 ozone NAAQS. For PM2.5 NAAQS, 13, 7 and 2 county
groups were used as well as for Putnam county.  The reason for the
groupings is that the inputs used for modeling were aggregated in such a
matter to reflect the common regulatory requirements and that
transportation crosses county lines. There was no need to change these
groupings (except for adding 25 counties and disaggregating 2 counties
from the 7 county group) since it is data that has gone through QA/QC,
disaggregation had limited benefit except when absolutely necessary
(e.g. for 2 counties), and these inputs in these groupings were used in
SIP and transportation conformity work related to the ozone and PM2.5
NAAQS of concern.

The aggregated groupings are as follows:

13 counties: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette,
Forsyth, Fulton, Gwinnett, Henry, Paulding, Rockdale

7 counties: Barrow, Bartow, Carroll, Hall, Newton, Spalding, Walton

2 counties (disaggregated from 7 counties): Bartow, Newton

25 counties: Banks, Butts, Chattooga, Clarke, Dawson, Floyd, Gordon,
Haralson, Heard, Jackson, Jasper, Jones, Lamar, Lumpkin, Madison,
Meriwether, Monroe, Morgan, Oconee, Pickens, Pike, Polk, Putnam, Troup,
Upson

Portion of Putnam county in NAA (soon to be maintenance area) for 1997
PM2.5 NAAQS

For a proper, complete demonstration of non-interference with
maintenance of the 1997 ozone NAAQS, the key budgets/limits in which
emissions must not exceed in these scenarios are the 2008 15% Reasonable
Forward Progress Plan (RFP) SIP MVEB,  and 2024 Atlanta ozone
maintenance plan MVEB. 

The 2008 MVEB is used because it represents the maximum level of mobile
emissions where it can still be claimed that emissions levels will be
not interfere with attainment (or maintenance of attainment) of the 1997
or 2008 ozone NAAQS.  In this appendix, we further demonstrate that 2008
baseline levels from the Atlanta ozone maintenance plan are used because
it represents MOVES-based emissions levels for the year Atlanta attained
the 1997 ozone NAAQS.  This additional demonstration further proves that
future emissions never return to the pre-2008 levels. The 2024 MVEB from
the Atlanta ozone maintenance plan is used because it represents the
maximum level of mobile emissions allowed after 2024 to further assure
continued attainment of the 1997 ozone NAAQS. In this demonstration,
years 2024, 2030 and 2040 would be compared to the2024 motor vehicle
emission budgets (MVEB) established by the Atlanta ozone maintenance
SIP, with safety margin included, while all years will be compared to
the 2008 MVEB.  The same years and methodology applies to the PM2.5
NAAQS analyses as well. The exception is that 2013 is not used for the
PM2.5 case due to lack of data. Also, PM2.5 is annualized where the RVP
differences are only realized during ozone season whereas for the
remainder of the year the Georgia gasoline and conventional gasoline are
virtually identical. This incorporation of non-ozone season fuel blend
is why PM2.5 annualized NOx differences are going to be smaller than NOx
associated with ozone. The main narrative provides all the details
regarding the results of the comparison between “Georgia Gas” and
“Conventional Gas” scenarios for the PM2.5 NAAQS demonstration.
Section 6 of the main narrative contains the demonstration of
non-interference with Atlanta’s attainment of the 2008 NAAQS ozone
standard through the use of offsets. No further details were required
for this appendix regarding results.

Figures 1a-b display the results of running these two scenarios for both
the “Georgia Gas” and the conventional gas cases. The difference in
the two lines is nearly indistinguishable showing how Georgia Marketing
Rule removal will not significantly affect these trends or the magnitude
of emissions. In both the “Georgia Gas” and conventional gas cases
the NOx and VOC emissions after 2012 are well below the 2008 MVEB or
2008 ozone maintenance plan levels with emissions from 2024-2040 never
exceeding the 2024 ozone maintenance plan MVEB.  Tables 1a and 1b
quantify these results for the conventional gas case, further
illustrating how emissions with conventional gas after 2008 never exceed
these limits. The 2008 Ozone Maintenance Plan baseline year (or can be
called “attainment year”) is added for additional comparison.

Table 1a: Comparison of On-Road NOx Emissions With Conventional Gas 







	 	 	 	 

Year	2008	2024	Conventional Gas

 	RFP	Maintenance Plan SIP	Emissions

 	MVEB	MVEB  	 

 

 	 

 	tpd	 tpd	tpd

2013	272.67	N/A	226.39

2016	272.67	N/A	172.44

2024	272.67	126	99.27

2030	272.67	126	93.27

2040	272.67	126	99.49

Table 1b: Comparison of On-Road VOC Emissions With Conventional Gas



 	 	 	 

Year	2008	2024	Conventional Gas

 	RFP	Maintenance Plan SIP	Emissions

 	MVEB	MVEB  	 

 	 	 	 

 	tpd	 tpd	tpd

2013	171.83	N/A	113.74

2016	171.83	N/A	90.32

2024	171.83	92	62.82

2030	171.83	92	60.42

2040	171.83	92	66.56

 	 	 

 











Figure 1a

 

Figure 1b

 

Details concerning methodology used to obtain these emissions values
including the MOVES (Motor Vehicle Emission Simulator) model used are
provided below.

Methods Used to Determine VOC and NOx Emissions Inventory for the
20-county Atlanta maintenance area for ozone and nonattainment area for
PM2.5, as weall as the Georgia Marketing Rule 45-county Area of
Influence

The MOVES (Motor Vehicle Emission Simulator version 2010b) was employed
to calculate on-road mobile VOC and NOx emissions over the 20-county
Atlanta maintenance area for ozone, 20-county nonattainment area for
PM2.5 (plus portion of Putnam County) and the 45-county area of
influence.   In order to accomplish this task, a variety of inputs are
required. These inputs are described below including how the data was
collected for the years chosen in the technical demonstration.  Any
inputs not mentioned here used only the MOVES model defaults.

Age Distribution

The vehicle age distribution inputs for the former 1997 Atlanta ozone
nonattainment area and current 1997 PM2.5 nonattainment area are the
same as those used for our recently approved maintenance ozone SIP and
recently submitted PM2.5 maintenance SIP for the Atlanta metropolitan
area (ARC). Age distribution data has been developed from registration
data from R.L. Polk & Co.’s National Vehicle Population Profile
(current as of October 2002) and R.L Polk and Co.’s TIPNet (current as
of March 2003). The input data was aggregated into representative
13-county and 7-county age distributions (e.g., each county in the
13-county area and each county in the 7-county area has the same age
distribution).

These representative county regions are used since people travel within
each of these areas unrestricted by county boundaries so age
distributions should be very similar throughout each region. These same
two 13-county and 7-county age distributions were applied to all years
analyzed in this technical demonstration since it is assumed that the
age distribution does not change significantly from year to year. The
13-county and 7-county regions also represent the original 13 county
ozone non-attainment area and the additional 7-counties brought into the
non-attainment area (for a total of 20 counties, Putnam is included in
the case of PM2.5, run similarly as the 25 counties were for the ozone
case) with the 1997 8-hr based ozone NAAQS. For all the inputs, Fulton
county is the representative county for the 13-county area; Bartow
county for both the 7-county area, and the 45-county area of influence. 
For the 25 additional counties, a 139 county aggregated distribution was
employed based on the same developed registration data from R.L. Polk &
Co. (now I.H.S) as was used in the 1997 Atlanta 8-hour Ozone Attainment
Demonstration submitted to EPA on October 21, 2009. 

Annual Average VMT (hpmsvtypeyear), Road Type, Distribution, and Hour
VMT Fractions	

Atlanta Regional Council (ARC) Travel Demand Model (TDM) output provides
road type distributions and overall annual average daily vehicle miles
traveled (AADVMT) by Highway Performance Monitoring System (HPMS)
functional class (urban restricted (with ramps), urban unrestricted (no
ramps), rural restricted, and rural unrestricted). The data needs to be
split by vehicle class (motorcycles, passenger cars, light duty trucks
etc.), which is done using data provided by the Georgia Department of
Transportation (GDOT): Mileage By Route, Type, and Functional
Classification Reports (445 Reports - 2008), through HPMS and defaults
from the MOVES model database. This AADVMT (annual average daily vehicle
miles traveled) data that is split by vehicle class is then used to
calculate an annual average VMT (hpmsvtypeyear) by multiplying the
AADVMT by 342 (instead of 365.25) to account for lower volume on
weekends (same method used for SIPs and transportation conformity
analyses based on an EPA converter). Vehicle miles traveled varies by
hour of the day so hourly VMT fractions are needed and are provided by
the ARC TDM. The TDM was calibrated using HPMS data from the Georgia
Department of Transportation. The TDM networks available for Atlanta
were 2008, 2010, 2016, 2024, 2030 and 2040 from which input values for
2013 was interpolated for annual average VMT and hour VMT fractions.  

Data is aggregated into 13-county and 7-county representative area. 
Hour VMT fractions are assumed to be similar for the additional
25-county area as with the 7-county area which they border.  For annual
average, VMT calculations started with 2008 data from GDOT’s 445
Reports (the sum of VMT for 25 counties) where these values were
multiplied by vehicle splits in the 7-county area to get annual average
VMT by vehicle type as required by MOVES.  Indications are that vehicle
splits between the 25-county area and the 7-county area would be similar
as well as growth (25-county grown at same rate as 7-county). Putnam in
the PM2.5 case is treated similarly to the 25 counties in the ozone
case.

Source Type Population

Source type population data has been developed from registration data
from R.L. Polk & Co.’s National Vehicle Population Profile (current as
of October 2002) and R.L Polk and Co.’s TIPNet (current as of March
2003). This data through the help of EPA converters was modified from
being sorted by MOBILE 6 vehicle types into being based on MOVES based
vehicle types. 

This data had already been “grown” from 2002-2003 values to 2007
values for use in Atlanta’s transportation conformity analyses and
application to SIP revisions. The data can be grown either based on
human population growth trends over the time period or growth trends in
vehicle population from the Georgia vehicle registration database (only
trends can be used not exact numbers due to difficulty of matching
vehicle types in the Georgia motor vehicle registration data to the
vehicle types used in R.L Polk and Co’s data). Atlanta data is
aggregated into 13 county and 7 county representative areas.

Table 1 below lists the vehicle type and preferred method.  Using this
table is consistent with what has been used in the previous national
emissions inventory (NEI) compilation and with regards to any SIP motor
vehicle budget determinations with MOVES.  As indicated in Table 1,
human population is adequate for all vehicle types except motorcycles,
buses and combination long haul trucks. For motorcycles and buses, ratio
of vehicle population is used instead. For example, if source type
population is grown from 2007 to 2009 then the 2007 data is multiplied
by 2009 human population/2007 human population unless a bus or
motorcycle where it will be multiplied by 2011 vehicle population/2009
vehicle population. For Atlanta, these human population ratios have
already been developed in a “Source Type Population Growth Table”.
For motorcycles and buses vehicle population ratios can be constructed
from the “Georgia Statistics System – University of Georgia”
website,   HYPERLINK "http://www.georgiastats.uga.edu" 
www.georgiastats.uga.edu  which organized by county all the Georgia
vehicle registration data for public use.  In this particular analysis
source type population had already been developed using the above
methodology for Atlanta for 2008, 2010, 2016, 2024, 2030 and 2040
through conformity determination reports and SIP development with 2013
data developed through linear interpolation between the 2010 and 2016
source type population.  2002 data was also available to provide a
conformity baseline.

 Table   SEQ Table \* ARABIC  1 . List of different growth factors used
by vehicle types

Vehicle types	Growth factor

11 (Motorcycles)	Georgia registration data, Motor cycles

21 (Passenger cars)	Human Population 

31 (Passenger truck)	Human Population

32 (Light commercial truck)	Human Population 

41 (Intercity Bus)	Georgia registration data, Buses  

42 (Transit Bus)	Georgia registration data, Buses

43 (School Bus)	Georgia registration data, Buses  

51 (Refuse Truck)	Human Population

52 (Single Unit Short Haul Truck)	Human Population

53 (Single Unit Long Haul Truck)	Human Population

54 (Motor Home)	Human Population

61 (Combination Short Haul Truck)	Human Population

62 (Combination Long Haul Truck)	Special methodology (see below)



For all cases with vehicle type 62-long haul combination trucks, a
special determination is required because these vehicles do not reside
in the areas investigated but usually just pass through the area along
interstate routes. So, local population and vehicle registration data is
not going to help since these vehicles are not part of the local
population or registered in the state, but how far they all travel while
they are in Georgia and how much far an average vehicle travels yearly
in the U.S. are helpful. Local annual average total VMT for vehicle type
62 and national annual average VMT per vehicle 62 are required (this
latter term is directly from MOVES). MOVES national default total
population and estimated local annual VMT of HPMS based vehicle type 60
are required as well for preliminary calculations. HPMS vehicle type 60
is the sum of MOVES vehicle type 61 and 62. The original data is in
terms of HMPS vehicle type 60 as well and the goal here is to know what
fraction of this VMT amount is from vehicle type 62 (filtering out
vehicle type 61 in the process) on interstates with vehicles that could
originate anywhere in the country. 

This preliminary calculation is:

local annual average total VMT by vehicle type 62=

HMPS vehicle type 60 local VMT x national default population vehicle
type 62/(sum of national default population vehicle type 61+62))

The final calculation is:

vehicle type 62 population= 

local annual average total VMT by vehicle 62/national average VMT per
vehicle 62.

HPMS vehicle type 60 local data used in this calculation is from TDM
model-based annual VMT output data for the 20-county Atlanta region
split by vehicle type based on MOVES defaults and HPMS counts. 

For the additional 25-county area, the same principle was applied as for
the 20 counties in the Atlanta area with the population data grown from
2002 to 2007. However, 2011 National Emissions Inventory population data
was available to use which was derived by growing the 2007 data further
to 2011. The 2007 and 2011 population data allowed for 2008 and 2010
values to be determined via linear interpolation. 2010 population was
grown to 2013, 2016, 2024, 2030, and 2040 based on rate of growth of
vehicle population observed for the 7 county Atlanta area (25 county
ring is adjacent to the 7 county ring so growth should be equivalent)
and used in this demonstration as well as other SIP and conformity work.

Ramp Fraction and Road Type Distribution

Atlanta Regional Commission (ARC)’s TDM model output provided road
type distributions and ramp fractions based on travel networks developed
by the ARC. Road fraction and road type distribution data were
aggregated into 13-county and 7-county regions for the Atlanta data.
2013 data was linearly interpolated between 2010 and 2016 values for
both ramp fraction and road type distribution. For the 25 county area,
ramp fractions for the 7 county area was employed as well as for road
type distribution (this local data approach assuming similar road
characteristics with neighboring ring of counties viewed as superior to
use of just MOVES defaults or other alternatives).

Average Speed Distribution

ARC TDM output provided average speed distribution by road type and
source type aggregated into 13 and 7 counties.  2013 average speed
distribution data for the Atlanta region were developed through linear
interpolation between 2010 and 2016 values For the 25 additional
counties, the 7-county average speed distribution was employed with this
distribution assumed to not vary between these neighboring ringed areas
(this local data approach is superior to just national MOVES defaults).
Also, this assumption is conservative because there is likely more
congestion in the 7 county area than 25 county area.

I/M coverage

The original 13 county Atlanta non-attainment area for the 1-hour based
ozone NAAQS has an ongoing I/M program.  The MOVES default database
pertaining to Georgia starting in year 2002 were removed because the
regular MOVES default databases have I/M information for Atlanta that
are faulty; however this data is replaced by the input I/M coverage
file.  This local I/M data is provided from the Georgia EPD Mobile &
Area Sources program’s I/M unit.  The 7-county area and the remaining
25 counties in the 45-county area of influence have no I/M program.
Putnam County in the PM2.5 case was treating the same as the remaining
25 counties in the ozone case. 

County Year- Stage II vapor recovery efficiency

For SIP work and transportation conformity assessments the state of
Georgia has assumed, for the 13-county area, a vapor recovery efficiency
of 81% during refueling with regards to any vapors released into the
air. A 0% reduction in fuel spillage benefit has been determined.  The
7-county area and remaining 25 counties in the 45-county area of
influence (and Putnam in the PM2.5 case) have no program so the default
value of 0 is used. Stage II vapor recovery is being phased out of the
Atlanta area, however, this is because of redundancy with the On-Board
Refueling Vapor Recovery (ORVR) systems in newer motor vehicles (EPA has
declared ORVR in “widespread use” as of May 16, 2012 (77 FR 28772)),
so no additional VOC emissions will be seen in future years (2016, 2024,
2030, 2040) from this action, so the efficiency was not changed in MOVES
2010b which does not take into account the replacement with ORVR (ORVR
efficiency and widespread use in >81% of vehicles actually makes this
efficiency assumption conservative).

Fuel Type-Formulation

For all years analyzed in this study, it was assumed that 100 percent of
the gasoline supply contained 10% ethanol (E-10) and that the month
investigated was July (typical summer day) to provide for maximum
possible emissions values when applying the ozone NAAQS standard case.
For the PM2.5 NAAQS analysis, the fuel was annualized where each fuel
blend was divided into fractions of use throughout the year and then
these fractions were applied to one fuel month (July was the dummy month
to match the ozone runs). The default fuel supply files from MOVES were
modified to reflect this ethanol assumption for 2008 and 2010 model
years (the rest already assumed in MOVES to be all E-10). 

The default values for MOVES for fuel supply/formulation that are used
here for this demonstration are the same values utilized in the approved
ozone maintenance SIP and submitted PM2.5 maintenance SIP as well as all
FHWA approved Atlanta area conformity determinations (CDRs) since MOVES
has been employed. By making these choices, a demonstration of
non-interference in this case would assure that removal of the Georgia
Marketing Rule would not interfere with attainment and conformity in all
other cases.  For the Georgia Gas case, nothing else was modified in the
fuel supply or fuel formulation MOVES default database. For the
conventional gas case, the RVP in the fuel formulation table was
modified to reflect the 0.8 (13 county 1-hr ozone NAAQS nonattainment
area consisting of Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglass,
Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale
counties) and 2.0 RVP increase (rest of the area analyzed) with Georgia
Marketing Rule removal. The input data is usually grouped into 13, 7,
and 25 counties which represent the ozone attainment status within the
45 county Georgia Marketing Rule area (13 counties from old 1-hr ozone
NAAQS NAA, 7 counties added to 13 county area for 1997 8-hr ozone NAAQS
NAA (now maintenance, rest attainment). In the case of PM2.5 there is
just the 20 county NAA plus a portion of Putnam County that are of
concern, although fuel property differences require groupings of 13 and
7 counties (plus Putnam) for PM2.5 as well.  

The fuel blends in detail are illustrated in the Tables 2a-2c for ozone
NAAQS and 2d-2e for PM2.5 NAAQS below (yellow areas are where fuel blend
was changed from GA gasoline to conventional gasoline):

Table 2a.  Fuel for Years 2013, 2016, 2024, 2030, and 2040.





	13 Counties	7 Counties	Remaining 25 Counties**

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**

Fuel Formulation ID	3847	3847	20011	30	3838	3838	20011	30

FuelSub type ID*	12	12	20	30	12	12	20	30

RVP	7.8	8.6	0	0	7.7	9.7	0	0

Sulfur Level	22.5787	22.5787	11	0	22.5787	22.5787	11	0

ETOH Volume	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0

Aromatic Content	26.6551	26.6551	0	0	26.6551	26.6551	0	0

Olefin Content	6.47	6.47	0	0	6.47	6.47	0	0

Benzene Content	0.6325	0.6325	0	0	0.6325	0.6325	0	0

e200	50.7634	50.7634	0	0	50.7634	50.7634	0	0

e300	88.5038	88.5038	0	0	88.5038	88.5038	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0

BioDiesel Ester Volume









Cetane Index









PAH Content









T50	198.258	198.258	0	0	198.258	198.258	0	0

T90	304.392	304.392	0	0	304.392	304.392	0	0



* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20
means diesel, 30 means natural gas.			

** Zeroes in this column indicate that these variables do not apply in
emissions calculations for this non-gasoline fuel.									

Table 2b.  Fuel Year 2010 (Assuming all E-110) Used to Help Illustrate
Trends.

	13 Counties	7 Counties	Remaining 25 Counties***

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**	GA Gas	Conv. Gas	Diesel**	Nat. Gas**

Fuel Formulation ID	3135	3135	20011	30	3124	3124	20011	30	3130	3130
20011	30

FuelSub type ID*	12	12	20	30	12	12	20	30	12	12	20	30

RVP	7.48571	8.28571	0	0	7.41429	9.41429	0	0	7.41429	9.41429	0	0

Sulfur Level	30	30	11	0	30	30	11	0	30	30	11	0

ETOH Volume	10	10	0	0	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0	0	0	0	0

Aromatic Content	28.5165	28.5165	0	0	28.5165	28.5165	0	0	28.5165	28.5165
0	0

Olefin Content	6.47	6.47	0	0	6.47	6.47	0	0	6.47	6.47	0	0

Benzene Content	0.64	0.64	0	0	0.64	0.64	0	0	0.8	0.8	0	0

e200	47.7167	47.7167	0	0	47.7167	47.7167	0	0	47.7167	47.7167	0	0

e300	86.3913	86.3913	0	0	86.3913	86.3913	0	0	86.3913	86.3913	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0	0.3488	0.3488
0	0

BioDiesel Ester Volume













Cetane Index













PAH Content













T50	204.476	204.476	0	0	204.476	204.476	0	0	204.476	204.476	0	0

T90	313.994	313.994	0	0	313.994	313.994	0	0	313.994	313.994	0	0



* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20
means diesel, 30 means natural gas.	

** Zeroes in this column indicate that these variables do not apply in
emissions calculations for this non-gasoline fuel.	

***Only difference between 7 and 25 county fuels is benzene content
which has zero impact on VOC and Nox emissions future fuel.

and this benzene difference is not seen in any current or future fuel.	

Table 2c.  Fuel for Year 2008 (Assuming all E-10) Used to Help
Illustrate Trends.

	13 Counties	7 Counties	Remaining 25 Counties***

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**	GA Gas	Conv. Gas	Diesel**	Nat. Gas**

Fuel Formulation ID	2334	2334	20043	30	2323	2323	20043	30	2329	2329
20043	30

FuelSub type ID*	12	12	20	30	12	12	20	30	12	12	20	30

RVP	7.17143	7.97143	0	0	7.12857	9.12857	0	0	7.12857	9.12857	0	0

Sulfur Level	28.1775	28.1775	43	0	28.1775	28.1775	43	0	28.1775	28.1775
43	0

ETOH Volume	10	10	0	0	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0	0	0	0	0

Aromatic Content	30.3779	30.3779	0	0	30.3779	30.3779	0	0	30.3779	30.3779
0	0

Olefin Content	6.47	6.47	0	0	6.47	6.47	0	0	6.47	6.47	0	0

Benzene Content	0.94	0.94	0	0	0.94	0.94	0	0	1.09	1.09	0	0

e200	44.67	44.67	0	0	44.67	44.67	0	0	44.67	44.67	0	0

e300	84.2788	84.2788	0	0	84.2788	84.2788	0	0	84.2788	84.2788	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0	0.3488	0.3488
0	0

BioDiesel Ester Volume













Cetane Index













PAH Content













T50	210.694	210.694	0	0	210.694	210.694	0	0	210.694	210.694	0	0

T90	323.596	323.596	0	0	323.596	323.596	0	0	323.596	323.596	0	0



* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20
means diesel, 30 means natural gas.			

** Zeroes in this column indicate that these variables do not apply in
emissions calculations for this non-gasoline fuel.			

***Only difference between 7 and 25 county fuels is benzene content
which has zero impact on VOC and Nox emissions future fuel		

and this benzene difference is not seen in any current or future fuel.

Table 2d.  Fuel for Years 2016, 2024, 2030, and 2040

	Summer Months (33.3% of the year, months 6,7,8, and 9)	

	13 Counties	7 Counties

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**

Fuel Formulation ID	3847	3847	20011	30	3838	3838	20011	30

FuelSub type ID*	12	12	20	30	12	12	20	30

RVP	7.8	8.6	0	0	7.7	9.7	0	0

Sulfur Level	22.5787	22.5787	11	0	22.5787	22.5787	11	0

ETOH Volume	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0

Aromatic Content	26.6551	26.6551	0	0	26.6551	26.6551	0	0

Olefin Content	6.47	6.47	0	0	6.47	6.47	0	0

Benzene Content	0.6325	0.6325	0	0	0.6325	0.6325	0	0

e200	50.7634	50.7634	0	0	50.7634	50.7634	0	0

e300	88.5038	88.5038	0	0	88.5038	88.5038	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0

BioDiesel Ester Volume









Cetane Index









PAH Content









T50	198.258	198.258	0	0	198.258	198.258	0	0

T90	304.392	304.392	0	0	304.392	304.392	0	0



Table 2d. (Continued)  Fuel for Years 2016, 2024, 2030, and 2040

Fall/Spring Months (41.7% of the year, months 3,4,5,10, and 11) Where
Georgia Gas and Conventional Gas are Identical	

	13 Counties	7 Counties

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**

Fuel Formulation ID	3846	3846	20011	30	3837	3837	20011	30

FuelSub type ID*	12	12	20	30	12	12	20	30

RVP	10.1143	10.1143	0	0	10.0571	10.0571	0	0

Sulfur Level	23.9192	23.9192	11	0	23.9192	23.9192	11	0

ETOH Volume	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0

Aromatic Content	24.4686	24.4686	0	0	24.4686	24.4686	0	0

Olefin Content	7.09571	7.09571	0	0	7.09571	7.09571	0	0

Benzene Content	0.611071	0.611071	0	0	0.611071	0.611071	0	0

e200	52.8114	52.8114	0	0	52.8114	52.8114	0	0

e300	88.2882	88.2882	0	0	88.2882	88.2882	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0

BioDiesel Ester Volume









Cetane Index









PAH Content









T50	194.079	194.079	0	0	194.079	194.079	0	0

T90	305.372	305.372	0	0	305.372	305.372	0	0



Table 2d. (Continued).  Fuel for Years 2016, 2024, 2030, and 2040

Winter Months (25% of the year, months 1,2, and 12) Where Georgia Gas
and Conventional Gas are Identical	

	13 Counties	7 Counties

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**

Fuel Formulation ID	3836	3836	20011	30	3836	3836	20011	30

FuelSub type ID*	12	12	20	30	12	12	20	30

RVP	13.2	13.2	0	0	13.2	13.2	0	0

Sulfur Level	25.7066	25.7066	11	0	25.7066	25.7066	11	0

ETOH Volume	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0

Aromatic Content	21.5534	21.5534	0	0	21.5534	21.5534	0	0

Olefin Content	7.93	7.93	0	0	7.93	7.93	0	0

Benzene Content	0.5825	0.5825	0	0	0.5825	0.5825	0	0

e200	55.5422	55.5422	0	0	55.5422	55.5422	0	0

e300	88.0009	88.0009	0	0	88.0009	88.0009	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0

BioDiesel Ester Volume









Cetane Index









PAH Content









T50	188.506	188.506	0	0	188.506	188.506	0	0

T90	306.678	306.678	0	0	306.678	306.678	0	0



* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20
means diesel, 30 means natural gas.

** Zeroes in this column indicate that these variables do not apply in
emissions calculations for this non-gasoline fuel.		

Table 2e.  Fuel for Year 2008 (Assuming All E-10) Used to Illustrate
Trends.

Summer Months (33.3% of the year, months 6,7,8, and 9)	

	13 Counties	7 Counties

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**

Fuel Formulation ID	2334	2334	20043	30	2323	2323	20043	30

FuelSub type ID*	12	12	20	30	12	12	20	30

RVP	7.17143	7.97143	0	0	7.12857	9.12857	0	0

Sulfur Level	28.1775	28.1775	43	0	28.1775	28.1775	43	0

ETOH Volume	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0

Aromatic Content	30.3779	30.3779	0	0	30.3779	30.3779	0	0

Olefin Content	6.47	6.47	0	0	6.47	6.47	0	0

Benzene Content	0.94	0.94	0	0	0.94	0.94	0	0

e200	44.67	44.67	0	0	44.67	44.67	0	0

e300	84.2788	84.2788	0	0	84.2788	84.2788	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0

BioDiesel Ester Volume









Cetane Index









PAH Content









T50	210.694	210.694	0	0	210.694	210.694	0	0

T90	323.596	323.596	0	0	323.596	323.596	0	0





Table 2e. (Continued)  Fuel for Year 2008

Fall/Spring Months (41.7% of the year, months 3,4,5,10, and 11) Where
Georgia Gas and Conventional Gas are Identical	

	13 Counties	7 Counties

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**

Fuel Formulation ID	2333	2333	20043	30	2322	2322	20043	30

FuelSub type ID*	12	12	20	30	12	12	20	30

RVP	9.62531	9.62531	0	0	9.6008	9.6008	0	0

Sulfur Level	29.13	29.13	43	0	29.13	29.13	43	0

ETOH Volume	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0

Aromatic Content	28.1796	28.1796	0	0	28.1796	28.1796	0	0

Olefin Content	7.09571	7.09571	0	0	7.09571	7.09571	0	0

Benzene Content	0.871429	0.871429	0	0	0.871429	0.871429	0	0

e200	47.4849	47.4849	0	0	47.4849	47.4849	0	0

e300	84.13	84.13	0	0	84.13	84.13	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0

BioDiesel Ester Volume









Cetane Index









PAH Content









T50	204.949	204.949	0	0	204.949	204.949	0	0

T90	324.273	324.273	0	0	324.273	324.273	0	0



Table 2e. (Continued)  Fuel for Year 2008

Winter Months (25% of the year, months 1,2, and 12) Where Georgia Gas
and Conventional Gas are Identical	

	13 Counties	7 Counties

	GA Gas	Conv. Gas	Diesel**	Nat. Gas**	GA Gas	Conv. Gas	Diesel**	Nat.
Gas**

Fuel Formulation ID	2321	2321	20043	30	2321	2321	20043	30

FuelSub type ID*	12	12	20	30	12	12	20	30

RVP	12.8971	12.8971	0	0	12.8971	12.8971	0	0

Sulfur Level	30.4	30.4	43	0	30.4	30.4	43	0

ETOH Volume	10	10	0	0	10	10	0	0

MTBE Volume	0	0	0	0	0	0	0	0

ETBE Volume	0	0	0	0	0	0	0	0

TAME Volume	0	0	0	0	0	0	0	0

Aromatic Content	25.2486	25.2486	0	0	25.2486	25.2486	0	0

Olefin Content	7.93	7.93	0	0	7.93	7.93	0	0

Benzene Content	0.78	0.78	0	0	0.78	0.78	0	0

e200	51.2381	51.2381	0	0	51.2381	51.2381	0	0

e300	83.9318	83.9318	0	0	83.9318	83.9318	0	0

Vol To Wt Percent Oxy	0.3488	0.3488	0	0	0.3488	0.3488	0	0

BioDiesel Ester Volume









Cetane Index









PAH Content









T50	197.29	197.29	0	0	197.29	197.29	0	0

T90	325.174	325.174	0	0	325.174	325.174	0	0



* 12 means "E-10 gasoline: Gasoline with 9-10% ethanol content", 20
means diesel, 30 means natural gas.

** Zeroes in this column indicate that these variables do not apply in
emissions calculations for this non-gasoline fuel.		

Meteorology:

The same meteorological assumptions regarding temperature and relative
humidity were employed here as in the Atlanta maintenance plan for the
1997 8-hr ozone NAAQS which is “typical July” (based on July 2008)
and the submitted Atlanta maintenance plan for the 1997 annual PM2.5
NAAQS (annualized meteorology based on 2008). For the 25 county area
Floyd&Bartow county meteorology (2008, typical July and same year as the
other groupings) was applied which is a good fit since the average
maximum temperatures are a little higher (and relative humidity a little
lower) than Atlanta. Although Atlanta is in the center of the 25 county
ring and would make a good average, we chose this approach since it
includes one of the 25 counties, is conservative (higher emissions), and
makes sure we took into account the slightly higher influence of the
southern warmer counties near Macon. 

Extra Notes:

For Putnam county, the whole county was run in MOVES with emissions
calculated based on the above input methodologies and then a fraction
(0.164) was applied to the nonattainment portion, the fraction identical
to what was applied in the submitted PM2.5 maintenance plan (represents
fraction of Putnam county’s population residing in NAA portion). Heard
county is also in the NAA, but has no regular vehicular traffic so no
emissions are assessed to it.

Other variables for MOVES inputs were taken directly from inputs used in
the relevant maintenance plan for the relevant NAAQS.



Methodology for 15-county Non-Attainment Area Aggregated Input Data
Collection for This Analysis

The Atlanta area was designated nonattainment in 1991 for 13-counties
for the 1990 1-hour ozone standard: Cherokee, Clayton, Cobb, Coweta,
DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding,
and Rockdale. 

On April 30, 2004, EPA designated 20-counties as nonattainment area
under the 1997 8-hour ozone standard. The eight-hour ozone nonattainment
area encompasses the 13-counties of the former 1-hour ozone
nonattainment area plus seven additional "ring" counties.  These
7-counties included the counties of Barrow, Bartow, Carroll, Hall,
Newton, Spalding, and Walton. 

On May 21, 2012, EPA published a final rule in the federal register
designating a new 15-county Atlanta area marginal nonattainment for the
2008 8-hour Ozone National Ambient Air Quality Standard.  The 15-county
area includes the counties of Bartow, Cherokee, Clayton, Cobb, Coweta,
Dekalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton,
Paulding, and Rockdale.

This section of the document shows the methodology used to aggregate
input data from 15 counties for the Georgia Marketing Analysis for the
Rule Removal SIP.  

Data was aggregated into input files for the new 15-county NAA for the
2008 8-hr ozone NAAQS by the following steps:

Emissions information already compiled and interpolated for the
13-county area in the TDM network was kept as it was, since the
13-county area is a subset of the 15 counties.  However, the data for
two counties, Bartow and Newton, would need to be disaggregated from the
7-counties data.

For the 2 counties, it was assumed that the characteristics were similar
to the 7 counties (hence why it was okay for them to be aggregated to
the other 5 in the first place) so distributions for the 2 counties were
identical as were used as inputs for the 7-county case.  Inputs included
average speed distributions, age distributions, road type distributions,
vmt fractions (hour, day and month), ramp fractions, inspection and
maintenance program (there was none), and meteorology (same geographic
area).  Two inputs that required a reanalysis were vehicle population
and annual average daily vehicle miles traveled (AADVMT).  National
Emissions Inventory (NEI) data for 2011 for Bartow and Newton counties
were combined and used as initial values.  Initial 2011 values were
“grown” to produce input values for 2013, 2016, 2024, 2030, 2040
(the same years as for the 1997 ozone NAAQS analysis except only
focusing on the present and future year impacts) by multiplying the 2011
vehicle population and AADVMT by the percent increase in these variables
between model network years for the 7-county area. Fuel blend for the 2
counties had to take into account a 2.0 psi increase with Georgia
Gasoline removal and not 0.8 because they were not in the former
nonattainment area for the now revoked 1-hr ozone NAAQS so the RVP rule
for general conventional gasoline (9.0 psi + 1.0 psi ethanol waiver)
areas applies there.  

In order to grow the inputs from 2011 to 2013, an assumption had to be
made to rely on a trend from 2010 to 2013 since there was no 2011
network and that the trend would not vary significantly between these
years.  The MOVES model was run with the 2 county inputs for the Georgia
Gas and conventional gasoline cases for each year and pollutant. 

By adding the 13-county and the 2-county emissions together for each
pollutant (NOx and VOCs) for each year for the Georgia gasoline and
conventional gasoline cases, Georgia EPD was able to illustrate impact
of removal of Georgia Marketing Rule for the current non-attainment area
in place for the 2008 ozone NAAQS.



Total Inventory Analysis

In Georgia’s Redesignation Request and Maintenance Plan for the
Atlanta 1997 8-hour Ozone Nonattainment Area and 1997 PM2.5
Nonattainment Area, it was demonstrated that future (through 2024) total
NOx and VOC emissions from all identified sources remained well below
the emissions levels calculated in 2008, the year Atlanta attained the
1997 8-hour ozone and PM2.5  NAAQS (“Attainment Inventory”).  A
similar demonstration is made below to illustrate how removal of the
Gasoline Marketing Rule will not impact Atlanta’s ability to maintain
total emissions well below the Attainment Inventory. In fact, Figures
4a-b, 5 and Tables 4a-b, 5 not only confirm that conventional gas
emissions remain below the Attainment Inventory, but also show how:

The difference between the Attainment Inventory and future total
emissions with both Georgia and  conventional gasoline increase over
time

Emissions decrease over time for both the Georgia Gasoline and
Conventional Gasoline case (Gasoline Marketing rule removed along with
more stringent conventional gasoline nonattainment area RVP requirements
still in place for 13 counties)

Total emissions as depicted by lines and points are nearly
indistinguishable between the Georgia Gasoline and Conventional Gasoline
case

Most of the emission years used for the demonstration in the Maintenance
Plan for the Atlanta 1997 8-hour Ozone  and PM2.5 Nonattainment Areas
(2008, 2014, 2017, 2020, and 2030) differed from the years applied in
this Gasoline Marketing Rule analysis (2008, 2010, 2013, 2016, 2024,
2030, 2040) which is based on the network years available in the ARC
TDM.  To match the years and provide a good comparison, emissions for
the Georgia Gasoline and conventional gasoline cases were interpolated
between TDM years to match up with the Maintenance Plan inventory years.
The total emissions for a given year in the Maintenance Plan
demonstration (beyond the attainment year) are the same as the total
emissions inventory in the Georgia Gasoline case since Georgia Gasoline
was the fuel formulation used in the Maintenance Plan. The total
emissions including Georgia Gasoline and the increase in emissions from
switch over to conventional gas were added together to obtain a total
inventory for conventional gasoline. 

Figure 4a:  Comparison of Total NOx Emissions With Conventional Gas
versus Emissions Limits

 

Table 4a: Comparison of Total NOx Emissions With Conventional Gas versus
Emission Limits









	 	 	 	 	 	 	 	 

Year	Total 	Total Emissions  	Total Emissions  	The Margin:	Margin
allotted	% of Margin allotted	Remaining Margin:

 	2008	Inventory	Inventory	2008 Attainment 	to switch to	to switch to
2008 Attainment 

 	Attainment	Georgia Gasoline	Conventional Gasoline	Inventory - Total
Emissions 	conventional gasoline	conventional gasoline	Inventory - Total
Emissions 

 	Inventory	 	 	using Georgia Gasoline	 	 	using Conventional
Gasoline

 	 	 	 	 	 	 	 

 	tpd	Tpd	tpd	tpd	tpd	%	tpd

2010	606.78	564.39	566.20	42.39	1.81	4.27	40.58

2013	606.78	500.80	502.11	105.98	1.32	1.24	104.67

2014	606.78	479.60	480.77	127.18	1.17	0.92	126.01

2016	606.78	437.21	438.07	169.57	0.87	0.51	168.71

2017	606.78	416.01	416.84	190.77	0.83	0.43	189.94

2020	606.78	367.67	368.40	239.11	0.73	0.30	238.38

2024	606.78	303.19	303.35	303.59	0.16	0.05	303.43

2030	606.78	206.47	206.55	400.31	0.08	0.02	400.23









	

Difference between the Attainment Inventory and Total Emissions using
Georgia Gasoline is referred to as “The Margin” since this is like a
safety margin between actual emissions and the level at which an
increase in emissions would lead to concerns over resulting
nonattainment. This margin increases to over 400 tons/day of NOx by 2030
with the increase in emissions with Gasoline Marketing rule removal less
than 0.1 tons/day or just 0.02% of the margin. By 2040 there is no
difference in NOx emissions between Georgia Gas and conventional gas.

Figure 4b:  Comparison of Total VOC Emissions with Conventional Gas
versus Emissions Limits.

 

Table 4b: Comparison of Total VOC Emissions with Conventional Gas versus
Emissions Limits









	 	 	 	 	 	 	 	 

Year	Total 

2008

Attainment

Inventory	Total Emissions  

Inventory

Georgia Gasoline	Total Emissions  

Inventory

Conventional Gasoline	The Margin:

2008 Attainment 

Inventory - Total Emissions 

using Georgia Gasoline	Margin allotted

to switch to

Conventional Gasoline	% of Margin allotted

to switch to

Conventional Gasoline	Remaining Margin:

2008 Attainment 

Inventory - Total Emissions 

using Conventional Gasoline

 







	 







	 

 	 

 	 

	 	 	 	 	 	 	 	 

 	tpd	tpd	tpd	tpd	tpd	%	tpd

2010	491.82	481.47	485.57	10.35	4.10	39.57	6.25

2013	491.82	465.94	469.29	25.88	3.35	12.93	22.53

2014	491.82	460.76	463.79	31.06	3.03	9.76	28.03

2016	491.82	450.41	452.80	41.41	2.39	5.77	39.02

2017	491.82	445.23	447.60	46.59	2.37	5.08	44.22

2020	491.82	440.23	442.57	51.59	2.34	4.54	49.25

2024	491.82	433.35	434.66	58.47	1.31	2.24	57.16

2030	491.82	423.03	424.10	68.79	1.07	1.56	67.72



Difference between the Attainment Inventory and Total Emissions using
Georgia Gasoline is referred to as “The Margin” since this is like a
safety margin between actual emissions and the level at which an
increase in emissions would lead to concerns over resulting
nonattainment. This margin increases to over 67.72 tons/day of VOC by
2030 with the increase in emissions with Gasoline Marketing rule removal
near 1.1 tons/day or just 1.5% of the margin.

Figure 5: Comparison of Total PM2.5 Emissions with Conventional Gas
versus Emissions Limits

 

Table 5: Comparison of Total PM2.5 Emissions with Conventional Gas
versus Emissions Limits

 	 	 	 	 	 	 	 

Year	Total

2008

Attainment

Inventory	Total Emissions

Inventory

Georgia Gasoline	Total Emissions

Inventory

Conventional Gasoline	The Margin:

2008 Attainment

Inventory - Total Emissions

using Georgia Gasoline	Margin allotted

to switch to

conventional gasoline	% of Margin allotted

to switch to

conventional gasoline	Remaining Margin:

2008 Attainment

Inventory - Total Emissions

using Conventional Gasoline









	 







	 

 	 

 	 

	 	 	 	 	 	 	 	 

 	tpd	tpd	tpd	tpd	tpd	%	tpd

2014	743.92	539.48	539.80	204.44	0.32	0.15	204.12

2016	743.92	471.44	471.72	272.48	0.28	0.10	272.20

2017	743.92	437.42	437.68	306.50	0.26	0.08	306.24

2020	743.92	391.43	391.66	352.49	0.23	0.07	352.26

2024	743.92	330.22	330.27	413.70	0.05	0.01	413.65

2030	743.92	238.40	238.44	505.52	0.04	0.01	505.48



The margin in this PM2.5 case increases to over 500 tons/day of NOx by
2030 with the increase in emissions with Gasoline Marketing rule removal
 less than 0.04 tons/day or less than 0.01% of the margin. By 2040 there
is no difference in PM2.5 NOx emissions between Georgia Gas and
conventional gas.

