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Section 10.0 Reasonable Further Progress (RFP)

10.1

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 New York-N. New Jersey-Long Island, NY-NJ-CT ozone non-attainment area, the Department's RFP demonstration exceeds 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 New York-N. New Jersey-Long Island, NY-NJ-CT 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 New York-N. New Jersey-Long Island, NY-NJ-CT 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 New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area, the calculations are as follows:

Step 1: 2002 Base Year VOC Inventory (tpd)
Point (Non-EGU) 11.2
EGU 2.7
Area 461.3
Non-Road 283.5
On-Road 236.8
Biogenic 204.4
Total 1199.9
Step 2: 2002 Base Year Anthropogenic VOC Inventory (tpd)
Point (Non-EGU) 11.2
EGU 2.7
Area 461.3
Non-Road 283.5
On-Road 236.8
Total 995.5

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

Suffolk County 7.3 tpd

Nassau County 5.2 tpd

Queens County 4.1 tpd

Kings County 2.6 tpd

Richmond County 0.9 tpd

New York County 4.7 tpd

Bronx County 2.0 tpd

Westchester County 4.4 tpd

Rockland County 1.3 tpd

Total 32.5 tpd

2002 Adjusted Base Year Anthropogenic VOC Inventory

995.5 - 32.5 = 963.0 tpd

Step 4: Calculate 2008 Projected VOC Emissions to Demonstrate RFP

963.0 × 0.85 = 818.6 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) 13.2
EGU 2.5
Area 406.3
Non-Road 214.9
On-Road 148.9
Total 785.8

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 32.8 tpd (4.6%).

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) 50.9
EGU 117.6
Area 78.3
Non-Road 178.5
On-Road 327.3
Total 752.6

Remove 2008 NOx FMVCP

Suffolk County 7.5 tpd

Nassau County 4.9 tpd

Queens County 4.0 tpd

Kings County 2.5 tpd

Richmond County 1.1 tpd

New York County 2.6 tpd

Bronx County 2.0 tpd

Westchester County 4.7 tpd

Rockland County 1.4 tpd

Total 30.7 tpd

2002 Adjusted Base Year Anthropogenic NOx Inventory (tpd)

752.6 - 30.7 = 721.9 tpd

2008 Projected NOx Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 65.0
EGU 108.9
Area 76.7
Non-Road 161.5
On-Road 211.8
Total 623.9

Therefore, in addition to meeting the 15 percent RFP requirement for total VOC reduction, the New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area is projected to realize a 13.6 percent 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 New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area, the Department needs to show that it has secured an additional 24.6 tpd (0.03 x 818.6) reduction of VOC, or an equivalent combination of VOC and NOx.

The 2008 RFP contingency requirement is met through the 32.8 tpd VOC reduced beyond the 15 percent RFP requirement.

10.3 2011 RFP Plan

The 2011 RFP demonstration shows an additional 9 percent anthropogenic VOC emission reduction in the New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area between 2008 and 2011. This accounts for a total anthropogenic VOC emission reduction of 24 percent from 2002 base year anthropogenic VOC emissions.

10.3.1 2011 Target Level VOC Emissions

The calculation of the 24 percent VOC reductions and the 2011 level of emissions are summarized in the following steps below:

Step 1: The compilation of the base year inventory for VOC emissions in the New York-N. New Jersey-Long Island, NY-NJ-CT 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 0.76 to identify the required 2011 VOC emissions to demonstrate RFP.

Step 5: The 2011 VOC projection inventory, which includes emission growth and controls, was compared to the required 2011 VOC emissions target level to demonstrate RFP (Step 4).

The total VOC reduction needed to demonstrate the 24 percent RFP requirement is the difference between the 2011 projected base case emission (without controls) and the 2011 target emission level. If the 2011 VOC projection inventory is less than the 2011 VOC RFP target level, then RFP is met. For New York-N. New Jersey-Long Island, NY-NJ-CT, the calculations are as follows:

Step 1: 2002 Base Year VOC Inventory (tpd)
Point (Non-EGU) 11.2
EGU 2.7
Area 461.3
Non-Road 283.5
On-Road 236.8
Biogenic 204.4
Total 1199.9
Step 2: 2002 Base Year Anthropogenic VOC Inventory (tpd)
Point (Non-EGU) 11.2
EGU 2.7
Area 461.3
Non-Road 283.5
On-Road 236.8
Total 995.5

Step 3: Remove 2011 VOC FMVCP

Suffolk County 9.1 tpd

Nassau County 6.6 tpd

Queens County 5.1 tpd

Kings County 3.2 tpd

Richmond County 1.2 tpd

New York County 5.5 tpd

Bronx County 2.4 tpd

Westchester County 5.3 tpd

Rockland County 1.6 tpd

Total 40.0 tpd

2002 Adjusted Base Year Anthropogenic VOC Inventory (tpd)

995.5 - 40.0 = 955.5 tpd

Step 4 : Calculate 2011 Projected VOC Emissions to Demonstrate RFP

955.5 × 0.76 = 726.2 tpd

Step 5: Compare 2011 Projected VOC Anthropogenic Emissions Inventory to 2011

Projected VOC Emissions to Demonstrate RFP

2011 Projected VOC Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 13.7
EGU 2.5
Area 398.9
Non-Road 191.7
On-Road 120.9
Total 727.7

The comparison of the 2011 Projected VOC Anthropogenic Emissions Inventory to 2011 Projected VOC Emissions to demonstrate RFP shows that there is a 1.5 tpd shortfall to demonstrate RFP through 2011 and the Department must rely on substitution of NOx reductions to meet the requirement.

10.3.2 2011 NOx Reductions

The following calculations and charts demonstrate the NOx reductions that are projected though 2011.

2002 Base Year Anthropogenic NOx Inventory (tpd)
Point (Non-EGU) 50.9
EGU 117.6
Area 78.3
Non-Road 178.5
On-Road 327.3
Total 752.6

Remove 2011 NOx FMVCP

Suffolk County 8.2 tpd

Nassau County 5.5 tpd

Queens County 4.3 tpd

Kings County 2.6 tpd

Richmond County 1.1 tpd

New York County 2.7 tpd

Bronx County 2.1 tpd

Westchester County 5.3 tpd

Rockland County 1.5 tpd

Total 33.3 tpd

2002 Adjusted Base Year Anthropogenic NOx Inventory (tpd)

752.6 - 33.3 = 719.3 tpd

2011 Projected NOx Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 64.1
EGU 108.9
Area 77.1
Non-Road 149.9
On-Road 163.8
Total 563.8

The New York portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area is projected to realize a 21.6 percent reduction in NOx emissions between 2002 and 2011.

In order to make the 2011 RFP demonstration, 1.2 tpd NOx of the available 155.5 tpd total NOx reduction must be used, leaving a net reduction of 154.3 tpd NOx beyond the 24 percent RFP requirement. The 1.2 tpd NOx reduction was calculated using EPA's "NOx Substitution Guidance" dated December, 1993 on a percentage to percentage basis (563.8 × 1.5 / (727.7 +1.5)).

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 New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area, the Department needs to show that it has secured an additional 21.8 tpd (0.03 × 726.2) reduction of VOC, or an equivalent combination of VOC and NOx.

The 2011 RFP contingency requirement is met through the 154.3 tpd NOx reduced beyond the 24 percent RFP requirement.

10.4 2012 RFP Plan

The 2012 RFP demonstration requires an additional 3 percent anthropogenic VOC and NOx emission reductions in the New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area between 2011 and 2012. This accounts for a total anthropogenic VOC and NOx emission reduction of 27 percent from 2002 base year anthropogenic VOC and NOx emissions.

10.4.1 2012 Target Level VOC Emissions

The calculation of the VOC reductions and the 2012 level of emissions are summarized in the following steps below:

Step 1: The compilation of the base year inventory for VOC emissions in the New York-N. New Jersey-Long Island, NY-NJ-CT 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 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 0.73 to identify the required 2012 VOC emissions to demonstrate RFP.

Step 5: The 2012 VOC projection inventory, which includes emission growth and controls, was compared to the required 2012 VOC emissions target level to demonstrate RFP (Step 4).

The total VOC reduction needed to show the 27 percent RFP requirement is the difference between the 2012 projected base case emission (without controls) and the 2012 target emission level. If the 2012 VOC projection inventory is less than the 2012 VOC RFP target level, then RFP is met. For New York-N. New Jersey-Long Island, NY-NJ-CT, the calculations are as follows:

Step 1: 2002 Base Year VOC Inventory (tpd)
Point (Non-EGU) 11.2
EGU 2.7
Area 461.3
Non-Road 283.5
On-Road 236.8
Biogenic 204.4
Total 1199.9
Step 2: 2002 Base Year Anthropogenic VOC Inventory (tpd)
Point (Non-EGU) 11.2
EGU 2.7
Area 461.3
Non-Road 283.5
On-Road 236.8
Total 995.5

Step 3: Remove 2012 VOC FMVCP

Suffolk County 9.5 tpd

Nassau County 6.9 tpd

Queens County 5.3 tpd

Kings County 3.3 tpd

Richmond County 1.3 tpd

New York County 5.6 tpd

Bronx County 2.5 tpd

Westchester County 5.5 tpd

Rockland County 1.7 tpd

Total 41.6 tpd

2002 Adjusted Base Year Anthropogenic VOC Inventory (tpd)

995.5 - 41.6 = 950.9 tpd

Step 4 : Calculate 2012 Projected VOC Emissions to Demonstrate RFP

950.9 × 0.73 = 694.2 tpd

Step 5: Compare 2012 Projected VOC Anthropogenic Emissions Inventory to 2012 Projected VOC Emissions to Demonstrate RFP.

2012 Projected VOC Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 13.8
EGU 2.5
Area 399.8
Non-Road 187.2
On-Road 120.9
Total 724.2

The comparison of the 2012 Projected VOC Anthropogenic Emissions Inventory to 2012 Projected VOC Emissions to demonstrate RFP shows that there is a 30.0 tpd shortfall to demonstrate RFP through 2012 and the Department must rely on substitution of NOx reductions to meet the requirement.

10.4.2 2012 NOx Reductions

The following calculations and charts demonstrate the NOx reductions that are projected though 2012.

2002 Base Year Anthropogenic NOx Inventory (tpd)
Point (Non-EGU) 50.9
EGU 117.6
Area 78.3
Non-Road 178.5
On-Road 327.3
Total 752.6

Remove 2012 NOx FMVCP

Suffolk County 8.5 tpd

Nassau County 5.7 tpd

Queens County 4.3 tpd

Kings County 2.6 tpd

Richmond County 1.1 tpd

New York County 2.8 tpd

Bronx County 2.1 tpd

Westchester County 5.5 tpd

Rockland County 1.6 tpd

Total 34.2 tpd

2002 Adjusted Base Year Anthropogenic NOx Inventory (tpd)

752.6 - 34.2 = 718.4 tpd

2012 Projected NOx Emissions Anthropogenic Inventory (tpd)
Point (Non-EGU) 62.8
EGU 108.9
Area 77.3
Non-Road 145.7
On-Road 163.8
Total 558.5

The New York portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area is projected to realize a 22.3 percent (159.9 tpd) reduction in NOx emissions between 2002 and 2012. In order to make the 2012 RFP demonstration, 22.2 tpd NOx of the available 159.9 tpd total NOx reduction must be used, leaving a net reduction of 137.7 tpd NOx beyond the 27 percent RFP requirement. The 22.2 tpd NOx reduction was calculated using EPA's "NOx Substitution Guidance" dated December, 1993 on a percentage to percentage basis.

10.4.3 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 New York State portion of the New York-N. New Jersey-Long Island, NY-NJ-CT non-attainment area, the Department needs to show that it has secured an additional 20.8 tpd (0.03 × 694.2) reduction of VOC, or an equivalent combination of VOC and NOx.

The 2012 RFP contingency requirement is met through the 137.7 tpd NOx reduced beyond the 27 percent RFP requirement.

10.5 Motor Vehicle Emissions Budgets

Year VOC (tpd) NOx (tpd)
2008 148.85 211.77
2011 120.93 163.84
2012 111.08 147.43

10.6 Emissions Reductions by Control Strategy

Proposed Revisions
6 NYCRR Part Rule Name Implementation Year Contaminant % Reduction (2012 CF) Reduction Ton/OSD NYMA 2008 Reduction Ton/OSD NYMA 2011 Reduction Ton/OSD NYMA 2012
228, 235 Adhesives and Sealants 2009 VOC 64.4 5.58 6.08 5.86
235 Consumer Products (2) 2009 VOC 2.0 15.041 16.73 16.31
241 Asphalt Paving 2009 VOC 20 2.31 2.45 2.32
220-1 Portland Cement Plants 2009 NOx 70 0 0 0
220-2 Glass Manufacturing 2009 NOx 70 0 0 0
227-4 Asphalt Production 2009 NOx 35 -0.01 -0.01 -0.03
239 Portable Fuel Containers (1) 2009 VOC 23.2 16.022 25.29 28.59
Adopted Rules
6 NYCRR Part Rule Name Implementation Year Contaminant % Reduction Reduction Ton/OSD NYMA 2008 Reduction Ton/OSD NYMA 2011 Reduction Ton/OSD NYMA 2012
205 AIM Coatings 2005 VOC 31 9.97 9.45 8.36
235 Consumer Products (1) 2005 VOC 14.2 15.041 16.73 16.31
228 Mobile Equipment Repair 2004 VOC 38 8.50 8.89 8.38
226 Solvent Metal Cleaning 2005 VOC 66 3.78 4.27 4.20
239 Portable Fuel Containers (1) 2003 VOC 71.3 16.022 25.29 28.59

1 For Consumer Products, tons/OSD reduction includes both rule revisions

2 For Portable Fuel Containers, tons/OSD reduction includes both rule revisions