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8.0 Reasonable Further Progress

Section 172(c)(2)of the Act requires the state to demonstrate reasonable further progress (RFP). If a State submits a SIP to EPA which demonstrates that it will attain the PM2.5 NAAQS within five years of the date of designation (April 5, 2010 based on the April 5, 2005 designation date), a separate RFP plan is not required. This is the case with the present submission since compliance is projected in 2009. Compliance with the emission reduction measures in the SIP will meet the requirements for achieving reasonable further progress.

States with areas for which an attainment date is projected of more than five years from the date of designation must submit an RFP plan with the SIP describing the control measures that provide for meeting the reasonable further progress milestones, the schedule for implementation of the measures, and the expected reductions in emissions of direct PM2.5 and PM2.5 precursors. If the attainment demonstration projects an attainment date of more than five and less than nine years from the date of designation, the RFP plan must include 2009 emissions milestones for direct PM2.5 and PM2.5 precursors. If the attainment date is nine or ten years from the date of designation, the RFP plan must include 2009 and 2012 emissions milestones for direct PM2.5 and PM2.5 precursors demonstrating that reasonable further progress will be achieved for the 2009 and 2012 emissions years. In each case, RFP plans must demonstrate that, in each milestone year, emissions will be at a level generally indicating linear progress reducing emissions between the base and attainment years.

For a multi-state nonattainment area, the RFP plans for each state must demonstrate RFP on the basis of common multi-state inventories. The states comprising the area must provide a coordinated RFP plan, ensuring that sources within its boundaries comply with enforceable emission levels and requirements that in combination with the reductions planned in other states, will provide for attainment as expeditiously as practicable and demonstrate reasonable further progress. For the present submission, each of the three states (CT, NJ and NY) are projected to reach attainment and, as discussed above, RFP plans, either state specific or combined, are not required.

In RFP's, states must identify direct PM2.5 precursor emissions regulated under the attainment plan and specify target emission reductions to be achieved during the milestone years. In developing the RFP plan, states must develop emission inventory information for the area included in the plan and conduct the following calculations:

  • For direct PM2.5 emissions and precursors, the full implementation reduction is calculated by subtracting the full implementation inventory from the baseline year inventory.
  • The ''milestone date fraction'' is the ratio of the number of years from the baseline year to the milestone inventory year divided by the number of years from the baseline year to the full implementation year.
  • For direct PM2.5 emissions and precursors, a benchmark emission reduction is calculated by multiplying the full implementation reduction by the milestone date fraction.
  • The benchmark emission level in the milestone year is calculated for direct PM2.5 emissions and precursors by subtracting the benchmark emission reduction from the baseline year emission level. The benchmark RFP plan is that which achieves benchmark emission levels for direct PM2.5 emissions and each precursor addressed in the attainment strategy for the area.
  • In comparing inventories between baseline and future years for direct PM2.5 emissions and each precursor, the inventories must be derived from the same geographic area. The plan must include emissions estimates for all types of emitting sources and activities in the geographic area from which the emission inventories for direct PM2.5 emissions and each precursor are derived.
  • To establish motor vehicle emissions budgets for transportation conformity purposes (as required in 40 CFR Part 93) for a PM2.5 nonattainment area, the state shall include in its RFP submittal an inventory of on-road mobile source emissions in the nonattainment area.

RFP plans due three years after designation must demonstrate that emissions for the milestone year are either:

  • At levels that are roughly equivalent to the benchmark emission levels for direct PM2.5 emissions and each precursor to be addressed in the plan; or
  • At levels included in an alternative scenario that is projected to result in a generally equivalent improvement in air quality by the milestone year as would be achieved under the benchmark RFP plan.

An equivalence of an alternative scenario to the corresponding benchmark plan must be determined by comparing the expected air quality changes of the two scenarios at the design value monitor location. This comparison must use the information developed for the attainment plan to assess the relationship between emissions reductions of the direct PM2.5 emissions and each precursor addressed in the attainment strategy and the ambient air quality improvement for the associated ambient species.


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  • NYSDEC
    Division of Air Resources
    PM2.5 SIP
    625 Broadway
    Albany, NY 12233-3251
    518-402-8396
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