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Section 10.0 Reasonable Further Progress (RFP)

10.1 Introduction

The CAA, in Section 182, requires ozone non-attainment areas with air quality classified as moderate or higher to submit plans showing RFP towards attainment of the NAAQS. RFP is defined, under Section 171(1) of the Act, to mean "such annual incremental reductions in emissions of the relevant air pollutant as are required by [part D of title I] or may reasonably be required by the Administrator for the purpose of ensuring attainment of the applicable [NAAQS] by the applicable date." The demonstration of RFP is based on guidelines contained in the Phase II Eight-Hour Ozone Implementation Rule (40 CFR 51.910) which specifies the base year emissions inventory upon which RFP is to be planned for and implemented, the increments of emissions reductions required over specified time periods, and the process for establishing whether RFP milestones were achieved. Emissions from stationary, area and mobile sources must all be included.

For the Poughkeepsie, NY ozone non-attainment area, the Department's RFP demonstration meets the requirements in the Phase II Eight-Hour Ozone Implementation Rule (40 CFR 51.910). This is more fully described below.

For clarification purposes, RFP means for the purposes of the 8-hour NAAQS, the progress reductions required under Section 172(c)(2) and Section 182(b)(1) and (c)(2)(B) and (c)(2)(C) of the CAA. Rate of Progress (ROP) means for the purposes of the 1-hour NAAQS, the progress reductions required under Section 172(c)(2) and Section 182(b)(1) and (c)(2)(B) and (c)(2)(C) of the CAA.

10.2 2008 15% RFP Plan

The 2008 RFP demonstration must provide at least a 15 percent reduction in the Poughkeepsie, NY non-attainment area 2002 base year anthropogenic VOC emissions by 2008. This percentage reduction is calculated from the adjusted baseline inventory that excludes: the emissions reduction benefits of the January 1, 1990 Federal Motor Vehicle Control Program (FMVCP), the June 11, 1990 federal RVP requirements of 9.0 psi, and the post-1990 "fix-up" of pre-1990 RACT rules and/or motor vehicle inspection programs. Further additional reductions must also be identified to compensate for any growth in emissions after 2002. EPA's document entitled "Guidance on the Adjusted Base Year Emissions Inventory and the Target for the 15 Percent Rate-of-Progress Plans," dated October 1992, provided the guidance for calculating the adjusted base year inventory and the 2008 target level of emissions. The target level of emissions for 2008 is the maximum amount of anthropogenic VOC emissions within the non-attainment area permitted to occur.

10.2.1 2008 Target Level VOC Emissions

The calculation of the 15 percent VOC reductions and the 2008 target level of emissions are summarized in the following steps:

Step 1: The compilation of the base year inventory for VOC emissions in the Poughkeepsie, NY non-attainment area, including biogenic emissions. See Chapter 4 for the 2002 base year inventory.

Step 2: The biogenic emissions were removed to develop the 2002 ROP base year anthropogenic emission inventory.

Step 3: The adjusted base year inventory was developed by removing the non-creditable FMVCP. Following EPA supplemental guidance, the Department also assumed the gasoline to have an RVP of 9.0 psi. Details of the mobile model inputs and procedures for estimating the benefits of the FMVCP are in the Appendix. The post-1990 RACT "fix-up" requirements were met previously and surpassed with the implementation of RACT statewide as required by CAA Section 184(b)(1)(B); therefore, the adjustment for this in 2002 is zero.

Step 4: The adjusted baseline inventory (Step 3) was multiplied by 0.85 to identify the required 2008 VOC emissions to demonstrate RFP.

Step 5: The 2008 VOC projection inventory, which includes emission growth and controls, was compared to the required 2008 VOC emissions target level to demonstrate RFP (Step 4).

The total VOC reduction needed to demonstrate the 15% RFP requirement is the difference between the 2008 projected base case emission (without controls) and the 2008 target emission level. If the 2008 VOC projection inventory is less than the 2008 VOC RFP target level, then RFP is met. For the Poughkeepsie, NY non-attainment area, the calculations are as follows:

Step 1: 2002 Base Year VOC Inventory (tpd)
Point (Non-EGU) 3.5
EGU 0.2
Area 40.2
Non-Road 26.5
On-Road 32.5
Biogenic 205.7
Total 308.6

Step 2: 2002 Base Year Anthropogenic VOC Inventory (tpd)
Point (Non-EGU) 3.5
EGU 0.2
Area 40.2
Non-Road 26.5
On-Road 32.5
Total 102.9

Step 3: Remove 2008 VOC Federal Motor Vehicle Control Program (FMVCP)

Dutchess County 1.7 tpd

Orange County 2.5 tpd

Putnam County 1.1 tpd

Total 5.3 tpd

2002 Adjusted Base Year Anthropogenic VOC Inventory

102.9 - 5.3 = 97.6 tpd

Step 4: Calculate 2008 Projected VOC Emissions to Demonstrate RFP

97.6 × 0.85 = 83.0 tpd

Step 5: Compare 2008 Projected VOC Anthropogenic Emissions Inventory to 2008 Projected VOC Emissions to Demonstrate RFP

2008 Projected VOC Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 4.5
EGU 0.4
Area 34.9
Non-Road 21.7
On-Road 19.2
Total 80.7

The comparison of the 2008 Projected VOC Anthropogenic Emissions Inventory to 2008 Projected VOC Emissions to Demonstrate RFP shows that reasonable further progress is met with VOC emission reductions alone. The Department has exceeded the 2008 RFP requirement by 2.3 tpd (2.8%).

10.2.2 2008 NOx Reductions

The following calculations and charts demonstrate the NOx reductions that are projected though 2008.

2002 Base Year Anthropogenic NOx Inventory (tpd)
Point (Non-EGU) 2.0
EGU 17.6
Area 5.4
Non-Road 16.9
On-Road 50.3
Total 92.2

Remove 2008 NOx FMVCP

Dutchess County 1.1 tpd

Orange County 2.3 tpd

Putnam County 0.9 tpd

Total 4.3 tpd

2002 Adjusted Base Year Anthropogenic NOx Inventory (tpd)

92.2 - 4.3 = 87.9 tpd

2008 Projected NOx Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 2.5
EGU 22.4
Area 5.2
Non-Road 14.3
On-Road 32.3
Total 76.7

Therefore, in addition to meeting the 15 percent RFP requirement for total VOC reduction, the Poughkeepsie, NY non-attainment area is projected to realize an 12.7 percent (11.2 tpd) reduction in NOx emissions between 2002 and 2008.

10.2.3 Contingency Measures

CAA Section 172(c)(9) requires the state to adopt specific contingency measures that will take effect without further action by the state or EPA if the state fails to achieve its RFP requirements.

In order to demonstrate compliance with the contingency measures provision applicable to the attainment demonstration, the Department has opted to include measures that have been or will be adopted for its contingency measures for the New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area.

The EPA requires that the contingency measures identified by the State must be sufficient to secure an additional 3 percent reduction in ozone precursor emissions in the year following the year in which the failure has been identified.

For a non-attainment area that fails to meet RFP percent reduction requirements, and where it has been demonstrated that NOx controls are needed to attain the primary NAAQS for ozone, measures that produce a combination of NOx and VOC reductions may serve as contingency measures. EPA requires at least 0.3 percent out of every reduction of 3 percent be attributable to a reduction in VOC measures.

For the Poughkeepsie, NY non-attainment area, the Department needs to show that it has secured an additional 2.9 tpd (0.03 x 97.6) reduction of VOC, or an equivalent combination of VOC and NOx.

The 2008 RFP contingency requirement is met through the 2.3 tpd VOC and 11.2 tons NOx reduced beyond the 15 percent RFP requirement. This meets the EPA requirement that at least 0.3 percent out of every reduction of 3 percent be attributable to a reduction in VOC measures.

10.3 2009 RFP Plan

The 2009 RFP demonstration shows an additional 3 percent anthropogenic VOC and NOx emission reductions in the Poughkeepsie, NY non-attainment area between 2008 and 2009. This accounts for a total anthropogenic VOC and NOx emission reduction of 18 percent from 2002 base year anthropogenic emissions.

10.3.1 2009 Target Level VOC Emissions

The calculation of the VOC reductions and the 2009 level of emissions are summarized in the following steps below:

Step 1: The compilation of the base year inventory for VOC emissions in the Poughkeepsie, NY non-attainment area, including biogenic emissions. See Chapter 4 for the 2002 base year inventory.

Step 2: The biogenic emissions were removed to develop the 2002 ROP base year anthropogenic emission inventory.

Step 3: The adjusted base year inventory was developed by removing the non-creditable FMVCP. Following EPA supplemental guidance, the Department also assumed the gasoline to have an RVP of 9.0 psi. Details of the mobile model inputs and procedures for estimating the benefits of the FMVCP are in the Appendix. The post-1990 RACT "fix-up" requirements were met previously and surpassed with the implementation of RACT statewide as required by CAA Section 184(b)(1)(B), therefore, the adjustment for this in 2002 is zero.

Step 4: The adjusted baseline inventory (Step 3) was multiplied by 0.82 to identify the required 2009 VOC emissions to demonstrate RFP.

Step 5: The 2009 VOC projection inventory, which includes emission growth and controls, was compared to the required 2009 VOC emissions target level to demonstrate RFP (Step 4).

The total VOC reduction needed to demonstrate the 18 percent RFP requirement is the difference between the 2009 projected base case emission (without controls) and the 2009 target emission level. If the 2009 VOC projection inventory is less than the 2009 VOC RFP target level, then RFP is met. For Poughkeepsie, NY, the calculations are as follows:

Step 1: 2002 Base Year VOC Inventory (tpd)
Point (Non-EGU) 3.5
EGU 0.2
Area 40.2
Non-Road 26.5
On-Road 32.5
Biogenic 205.7
Total 308.6

Step 2: 2002 Base Year Anthropogenic VOC Inventory (tpd)
Point (Non-EGU) 3.5
EGU 0.2
Area 40.2
Non-Road 26.5
On-Road 32.5
Total 102.9

Step 3: Remove 2009 VOC FMVCP

Dutchess County 1.8 tpd

Orange County 2.7 tpd

Putnam County 1.2 tpd

Total 5.7 tpd

2002 Adjusted Base Year Anthropogenic VOC Inventory (tpd)

102.9 - 5.7 = 97.2 tpd

Step 4: Calculate 2009 Projected VOC Emissions to Demonstrate RFP

97.2 × 0.82 = 79.7 tpd

Step 5: Compare 2009 Projected VOC Anthropogenic Emissions Inventory to 2009 Projected VOC Emissions to Demonstrate RFP

2009 Projected VOC Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 4.6
EGU 0.4
Area 34.0
Non-Road 20.8
On-Road 17.6
Total 77.4

The comparison of the 2009 Projected VOC Anthropogenic Emissions Inventory to 2009 Projected VOC Emissions to Demonstrate RFP shows that reasonable further progress is met through 2009. The Department has exceeded the 2009 RFP requirement by 2.3 tpd (2.9%).

10.3.2 2009 NOx Reductions

The following calculations and charts demonstrate the NOx reductions that are projected though 2009.

2002 Base Year Anthropogenic NOx Inventory (tpd)
Point (Non-EGU) 2.0
EGU 17.6
Area 5.4
Non-Road 16.9
On-Road 50.3
Total 92.2

Remove 2009 NOx FMVCP

Dutchess County 1.2 tpd

Orange County 2.4 tpd

Putnam County 1.0 tpd

Total 4.6 tpd

2002 Adjusted Base Year Anthropogenic NOx Inventory (tpd)

92.2 - 4.6 = 87.6 tpd

2009 Projected NOx Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 2.6
EGU 22.4
Area 5.2
Non-Road 13.9
On-Road 29.8
Total 73.9

Therefore, in addition to meeting the 18 percent RFP requirement for total VOC reduction in 2009, the Poughkeepsie, NY non-attainment area is projected to realize a 15.6% (13.7 tpd) reduction in NOx emissions between 2002 and 2009.

10.3.3 Contingency Measures

CAA Section 172(c)(9) requires the state to adopt specific contingency measures that will take effect without further action by the state or EPA if the State fails to achieve its RFP requirements.

In order to demonstrate compliance with the contingency measures provision applicable to the attainment demonstration, the Department has opted to include measures that have been or will be adopted for its contingency measures for the New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area.

EPA requires that the contingency measures identified by the state must be sufficient to secure an additional 3 percent reduction in ozone precursor emissions in the year following the year in which the failure has been identified.

For the Poughkeepsie, NY non-attainment area, the Department needs to show that it has secured an additional 2.9 tpd (0.03 × 97.2) reduction of VOC, or an equivalent combination of VOC and NOx.

The 2009 RFP contingency requirement is met through the 2.8 tpd VOC reduced and 13.7 tpd NOx reduced beyond the 18 percent RFP requirement.

10.4 Motor Vehicle Emissions Budgets

Year VOC (tpd) NOx (tpd)
2008 19.22 32.32
2009 17.63 29.77

10.5 Emissions Reductions by Control Strategy

Proposed Revisions
6 NYCRR Part Rule Name Implementation Year Contaminant % Reduction (2009 CF) Reduction Ton/OSD NAA 2008 Reduction Ton/OSD NAA 2009
228, 235 Adhesives and Sealants 2009 VOC 64.4 0.41 0.47
235 Consumer Products (2) 2009 VOC 2.0 0.81 0.95
241 Asphalt Paving 2009 VOC 20 0.77 0.89
220-1 Portland Cement Plants 2009 NOx 70 0 0
220-2 Glass Manufacturing 2009 NOx 70 0 0
227-4 Asphalt Production 2009 NOx 35 0 0
239 Portable Fuel Containers (1) 2009 VOC 5.8 1.04 1.21

Adopted Rules

6 NYCRR Part Rule Name Implementation Year Contaminant % Reduction (2009 CF) Reduction Ton/OSD NAA 2008 Reduction Ton/OSD NAA 2009
205 AIM Coatings 2005 VOC 31 0.62 0.72
235 Consumer Products (1) 2005 VOC 14.2 0.81 0.95
228 Mobile Equipment Repair 2004 VOC 38 0.52 0.61
226 Solvent Metal Cleaning 2005 VOC 66 0.41 0.48
239 Portable Fuel Containers (1) 2003 VOC 48.8 1.04 1.21

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