1. Reasonable Further Progress Policy and Mid-Course Reviews John Summerhays EPA Region 5 June 20, 2007

2. 2 RFP Policy Applicability of planning requirement “Generally linear emission reductions” Inventory area Pollutants included

3. 3 Who Must Do an RFP Plan? Area attaining by 2010: –Congratulations! No additional plan needed Area needing extension beyond 2010: –Must show “generally linear progress” from base year to attainment year –Purpose: Steady progress in implementing controls

4. 4 Dates RFP plan is due in April 2008 RFP plan must have controls early enough to project adequate interim progress by the “milestone dates” Milestone dates: –If attaining by 2010: None –If attainment date is 2011 - 2013: 2009 –If attainment date is 2014 or 2015: 2009, 2012

5. 5 Generally Linear Reductions Based on emissions Example 1: Base year: 2002, Clean air starts 2012: –About 7/10 of 2012 emission reductions must be achieved by 2009 Example 2: Base year: 2002, Clean air starts 2014: –About 7/12 of 2014 emission reductions by 2009 –About 10/12 of 2014 emission reductions by 2012

6. 6 Generally Linear Reductions (cont’d) Two options: –Option 1: all regulated pollutants reduced in generally linear faction –Option 2: Some reductions sooner, others later, to obtain same air quality improvement by milestone date Reflects all controls (federal and state) and all other influences on emissions No backloading of emission controls

7. 7 Example Calculation Suppose Kleenare City will have clean air in 2012 as a result of 20% reduction of SO2, 20% reduction of NOx, and 10% reduction of organic particles (direct PM) Reductions from 2002 to 2009 must be about 7/10 of reductions from 2012 Thus, “generally linear reductions” would be: SO2: 14%; NOx: 14%; organic particles: 7% Alternatively, other combinations with same air quality benefit (modeling not required)

8. 8 Area to be Included Nonattainment area, plus: –Optionally, for SO2 & NOx, sources to 200 km –Also, optionally, for VOC, ammonia, in special cases –For directly emitted PM, nonattainment area only State must provide justification for any area outside the nonattainment area

9. 9 Area to be Included (continued) Inventories must include all sources in applicable area –Unlike ozone policy Area cannot go outside state or states in nonattainment area For transportation conformity purposes, states must submit a budget that includes on-road emissions only from the nonattainment area

10. 10 Pollutants Include all regulated pollutants –Must include pollutants controlled in attainment plan –Therefore we expect RFP plans to include direct PM2.5, SO2, and NOx –EPA requires a proper fraction of the plan’s controls to be implemented by 2009 and in some cases 2012

11. 11 Multi-state Areas In multi-state areas, RFP must be achieved on a multi-state basis –Must include at least entire nonattainment area All states must demonstrate RFP on the basis of a common multi-state inventory

12. 12 Mid-course Review Applicability: –Areas needing attainment date extension to 2014 or 2015 Due Date: –April 2011 Purpose: –Assure progress toward attainment in problem areas using updated information –In lieu of formal milestone review

13. 13 Elements of Midcourse Review Review of emission reductions Review of air quality progress Updated attainment demonstration Any new or revised controls needed to attain by the planned attainment date