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Supplement III to the
Revised Maintenance Plan
for
The Charlotte-Gastonia-Salisbury, North
Carolina 2008 8-Hour Ozone Marginal
Nonattainment Area
Prepared by
North Carolina Department of Environmental Quality
Division of Air Quality
Revised, Supplement I: July 25, 2018
Revised, Supplement II: July 16, 2020
Revised, Supplement III: December 19, 2022
FINAL
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Final
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
Preface: In this supplement, North Carolina is proposing to revise the 2026 motor vehicle
emission budgets (MVEBs) for oxides of nitrogen (NOx) and volatile organic compound (VOC)
emissions in the Charlotte-Gastonia-Salisbury area by 1) revising the 2026 nonroad and onroad
emissions estimates, 2) recalculating the available safety margin emissions, and 3) increasing the
allocations of safety margin emissions to the MVEBs. The MVEB revisions are proposed to
accommodate a recent update to the MOtor Vehicle Emissions Simulation (MOVES) model used
to calculate onroad emissions of nitrogen oxides and volatile organic compounds in the affected
area. The previously approved MVEBs were based on emissions estimates from the
MOVES2014b version of the model. However, the new version of MOVES, MOVES3, estimates
much higher emissions of NOx from diesel vehicles operating at lower speeds than were estimated
with MOVES2014b. Therefore, North Carolina is proposing to revise the 2026 MVEBs to be
compatible with MOVES3 emissions estimates. The proposed revisions to the MVEBs do not
change the overall 2014 maintenance plan emissions estimates or the 2026 emissions estimates
except for the nonroad and onroad sectors. In addition, the revisions do not exceed the 50 percent
allocation of the total available NOx or VOC safety margin emissions.
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
EXECUTIVE SUMMARY
Introduction
Ozone is formed by a complex set of chemical reactions involving volatile organic compounds
(VOCs), nitrogen oxides (NOx) and to a lesser extent carbon monoxide (CO). These gases are
generated by utilities, combustion processes, certain industrial processes and even by natural
sources such as trees. Tailpipe emissions from mobile sources (vehicles) are also significant
sources of these pollutants. Emissions from smaller sources such as boat engines, lawn mowers
and construction equipment also contribute to the formation of ozone. Ozone formation is
promoted by strong sunlight, warm temperatures and light winds and is hence a problem
predominantly during the hot summer months.
The 2008 8-hour ozone National Ambient Air Quality Standard (NAAQS) is 0.075 parts per
million (ppm). An exceedance of the 2008 8-hour ozone NAAQS occurs when a monitor
measures ozone above 0.075 ppm on average for an 8-hour period. A violation of this NAAQS
occurs when the average of the annual fourth highest daily maximum 8-hour ozone values over
three consecutive years is greater than or equal to 0.076 ppm. This three-year average is termed
the “design value” for the monitor. The design value for a nonattainment area is the highest
monitor design value in the area.
On July 28, 2015, the U. S. Environmental Protection Agency (EPA) published its final rule (80
FR 44873) in which it (1) determined that the Charlotte-Gastonia-Salisbury, North Carolina 2008
8-Hour Ozone Marginal Nonattainment Area (hereinafter referred to as the “Charlotte area” or
“maintenance area”) was attaining the 2008 8-hour ozone NAAQS, (2) redesignated the North
Carolina portion of the Charlotte area to attainment for the 2008 8-hour ozone NAAQS, (3)
approved and incorporated North Carolina’s maintenance plan for maintaining attainment of the
2008 8-hour ozone standard for the North Carolina portion of the Charlotte area into the State
Implementation Plan (SIP), and (4) determined that the 2014 and 2026 sub-area NOx and VOC
motor vehicle emissions budgets (MVEBs) for 2026 for the North Carolina portion of the
Charlotte area were adequate for the purposes of transportation conformity. The final rule
became effective August 27, 2015.
On the same day, EPA also published its final rule (80 FR 44868) approving of North Carolina’s
Clean Air Act (CAA) Section 110(l) noninterference demonstration for relaxing the Federal Reid
vapor pressure (RVP) requirement from 7.8 pound per square inch (psi) to 9.0 psi applicable to
gasoline introduced into commerce from June 1 to September 15 of each year in Mecklenburg and
Gaston Counties. The EPA subsequently issued a direct final rule (80 FR 49164) on August 17,
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
2015, approving revisions to the rule (effective on October 16, 2015) to relax the summertime
RVP requirement in the two counties.
In 2017, the North Carolina General Assembly enacted Session Law 2017-10, Senate Bill 131
(An Act to Provide Further Regulatory Relief to the Citizens of North Carolina) which revised the
state’s emissions inspection and maintenance (I/M) program. Section 3.5.(b) of the Act amended
North Carolina General Statue (NCGS) §143-215.107A(c) §20-183.2(b) by changing the vehicle
model year coverage from 1996 and newer vehicles to the most recent 20 model years (excluding
the three most recent model year vehicles with less than 70,000 miles on the odometer).
On July 25, 2018, the DAQ submitted a revision to the maintenance plan for the Charlotte area to
update the emissions forecast and MVEBs for 2026 to account for the small increase in NOx and
VOC emissions associated with the change in vehicle model year coverage as proposed by
Section 3.5.(b) of the Act. The DAQ also submitted an accompanying I/M SIP revision, CAA
Section 110(l) noninterference demonstration, and revisions to North Carolina’s air quality rule
15A North Carolina Administrative Code (NCAC) 02D .1002 (Applicability). On September 11,
2019, EPA published a final rule (84 FR 47889) approving the revisions (effective on October 11,
2019).
In accordance with Section 3.5.(d) of the Act, on September 17, 2019, the Secretary of the
Department of Environmental Quality submitted official certification to North Carolina’s Revisor
of Statutes that EPA published its final approval of the SIP revisions. The Section also required
the changes to become effective on the first day of a month that is 60 days after the Secretary’s
official certification was submitted. As a result, the effective date for implementing the changes
to the vehicle model year coverage was on December 1, 2019.
On July 16, 2020, the DAQ submitted a supplement to revise the motor vehicle emission budgets
(MVEBs) for the Charlotte-Gastonia-Salisbury area by increasing the safety margin emissions
allocated to the MVEBs of each of the three budget regions in the area. Historically, the North
Carolina Division of Air Quality (DAQ) has limited the allocation of NOx and VOC safety
margin emissions to MVEBs so that less than 50% of the safety margin of each pollutant is
allocated. In this submittal, North Carolina proposed to increase the amount of the total safety
margin allocated to the 2026 MVEBs from 4.7% to 9.4% for NOx and from 18.7% to 37.4% for
VOC. The MVEB revisions were proposed to accommodate recent updates to the travel demand
model used to calculate vehicle miles traveled for the North Carolina portion of the Charlotte
Maintenance Area, and to account for the uncertainty associated with the mobile emissions model
and unanticipated growth in vehicle miles traveled in the area.
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
The proposed revisions to the MVEBs were agreed upon at the March 27, 2020, interagency
consultation meeting and did not change the overall maintenance plan emissions upon which the
safety margins are based. In addition, the Charlotte-Gastonia-Salisbury area was currently
attaining the 2008 and 2015 8-hour ozone NAAQS based on certified ambient monitoring data.
Therefore, the DAQ concluded that the proposed revisions to the 2026 MVEBs would not
interfere with any applicable requirement concerning the attainment and maintenance of the
NAAQS. On August 25, 2021, EPA published a final rule (86 FR 47387) approving the North
Carolina; Revision to Approved Motor Vehicle Emissions Budgets.
In response to the requirement to use the MOVES3 model, released January 7, 2021, in regional
emissions analyses for transportation conformity determinations after January 9, 2023, the DAQ
prepared this supplement to provide MOVES3-compatible MVEBs for the three budget areas in
the Charlotte-Gastonia-Salisbury, North Carolina 2008 8-Hour Marginal Nonattainment Area.
Transportation conformity in the area ensures that federal transportation actions do not interfere
with maintaining compliance with the 2008 8-hour ozone National Ambient Air Quality
Standards (NAAQS). As such, the level of emissions estimated for Transportation Improvement
Programs and Metropolitan Transportation Plans must not exceed the MVEBs as defined in the
area’s maintenance plan. The current MVEBs are based on emissions results from the previous
version of the MOVES model (MOVES2014b), therefore do not reflect the higher NOx emissions
from diesel vehicles operating at lower speeds that are estimated with MOVES3. It was,
therefore, necessary to develop revised MVEBs based on MOVES3 modeling results to ensure
accuracy in future transportation conformity analyses.
The MVEB revisions included were approved through interagency consultation on July 22, 2022.
The new MVEBs were developed by first calculating updated on-road and nonroad NOx and
VOC emissions for 2026 using the MOVES3 model, then recalculating the available safety
margin emissions for each pollutant. The revised MVEBs for each of the three budget areas were
obtained by allocating safety margin emissions to the MOVES3-based 2026 on-road emissions
according to the procedures agreed upon through interagency consultation. Revised safety margin
allocations totaled 21.4% for NOx and 49.7% for VOC, with a significant amount of safety
margin held in reserve, which indicates NOx and VOC emissions will continue to decline through
2026. The Charlotte-Gastonia-Salisbury area also continues to attain the 2008 and 2015 8-hour
ozone NAAQS based on certified ambient monitoring data. Therefore, the DAQ concludes that
the proposed revisions to the 2026 MVEBs will not interfere with any applicable requirement
concerning the attainment and maintenance of the 2008 8-hour Ozone NAAQS.
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
Charlotte-Gastonia-Salisbury Nonattainment Designation
The area surrounding Charlotte-Gastonia-Salisbury, North Carolina, called the Charlotte area, was
designated as marginal nonattainment for the 2008 8-hour ozone NAAQS on May 21, 2012 (77
Federal Register (FR) 30088). The nonattainment designation was an action taken by EPA under
Section 107(d) of the CAA. The CAA requires that some area be designated as nonattainment if a
monitor is found to be in violation of a NAAQS. For the 2008 8-hour ozone NAAQS, the EPA
took designation action in 2012 based on 2009-2011 design values. At that time, the design value
for the Charlotte area was 0.079 ppm.
The Charlotte area includes the entire county of Mecklenburg and parts of Cabarrus, Gaston,
Iredell, Lincoln, Rowan and Union Counties (see Figure 1). The partial counties include the
townships listed in Table 1. Note that the EPA also designated the portion of York County, South
Carolina that is adjacent to the Charlotte area nonattainment for the 2008 8-hour ozone NAAQS.
On April 17, 2015, the South Carolina Department of Health & Environmental Control
(SCDHEC) submitted to EPA a SIP package request to redesignate the York County portion of
the Charlotte nonattainment area to attainment. On December 11, 2015, EPA approved the
SCDHEC's request and the redesignation to attainment became effective on January 11, 2016 (80
FR 76865).
Charlotte Nonattainment Area Boundary
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
Table 1 Counties and Townships within the Charlotte Nonattainment Area
Cabarrus County Townships
Central Cabarrus Concord* Georgeville Harrisburg Kannapolis Midland
Mount Pleasant Odell Poplar Tent New Gilead Rimertown
Gaston County Townships
Dallas Crowders Mountain Gastonia Riverbend South Point
Iredell County Townships
Coddle Creek Davidson
Lincoln County Townships
Catawba Springs Lincolnton Ironton
Mecklenburg County – All Townships
Rowan County Townships
Atwell China Grove Franklin Gold Hill* Litaker Locke
Providence Salisbury Steele Unity
Union County Townships
Goose Creek Marshville Monroe Sandy Ridge Vance
*Note: Concord Township in Cabarrus County and Gold Hill Township in Rowan County were inadvertently left out
of North Carolina’s recommendation and EPA’s final designations. In a letter dated January 28, 2014, the DAQ
requested the EPA to add the missing townships in the state’s 2008 marginal ozone nonattainment area definition.
Current Air Quality
There are currently six ozone monitors located throughout the Charlotte area and one monitor
located in York County, South Carolina, just outside of the area. The design value for the
nonattainment area is 0.073 ppm based on the data from 2012-2014. The 2014 8-hour ozone
monitoring data for the Charlotte area was fully quality assured and officially submitted to the
EPA for certification approval on December 12, 2014. The EPA concurred with the North
Carolina Division of Air Quality (DAQ) and Mecklenburg County Air Quality (MCAQ)
certification on December 15, 2014. A detailed discussion of air quality levels in the region is
provided in Section 2.0.
Maintenance Plan Requirements
The state of North Carolina has implemented permanent and enforceable state and federal actions
to reduce ozone precursor emissions in the North Carolina portion of the Charlotte area. In
addition, MCAQ has implemented actions to reduce ozone precursor emissions. This
combination of state, federal, and local actions has resulted in cleaner air in the Charlotte area,
and the anticipated future benefits from these programs are expected to result in continued
maintenance of the 2008 8-hour ozone NAAQS in this region. State actions include the Clean
Smokestacks Act; the on-board diagnostic (OBDII) vehicle I/M program that began on July 1,
2002; and voluntary programs to reduce emissions from diesel engines. Local actions
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
implemented by MCAQ include a prohibition on open burning and a very effective voluntary
program called Grants to Replace Aging Diesel Engines (GRADE).1 The GRADE program is
designed to reduce NOx emissions by providing businesses and organizations funding incentives
to replace or repower heavy-duty non-road equipment with newer, cleaner, less polluting engines.
Several federal actions have resulted in lower emissions throughout the eastern portion of the
country. For on-road and nonroad vehicles, federal actions include the Tier 2 engine standards for
light- and medium-duty vehicles, heavy-duty engine standards, the low-sulfur gasoline and diesel
requirements, and off-road engine standards. For stationary sources, federal actions include the
Mercury and Air Toxics (MATS) rule for electricity generating units (EGUs) and the National
Emissions Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial and
institutional boilers and reciprocating internal combustion engines (RICE). In addition, there are
several federal actions that will be implemented starting in 2015. These actions will provide for
additional NOx emissions reductions in and near the Charlotte area. For EGUs, the future federal
actions include compliance with the Cross State Air Pollution Rule (CSAPR) and the Tennessee
Valley Authority (TVA) consent decree. For on-road vehicles, the future federal actions include
compliance with the Tier 3 vehicle emissions and fuel standards and corporate average fuel
economy standards for on-road vehicles.
Emissions
A base year inventory for NOx and VOC emissions was developed for 2014 since the design
value for the 2012-2014 period shows attainment of the 2008 8-hour ozone NAAQS. Future year
emissions inventories were also developed for the interim years 2015, 2018, 2022, and a final
year emission inventory was developed for 2026. For each future year, the total NOx and VOC
emissions is lower than the 2014 base year emissions. Furthermore, emissions modeling and air
quality modeling for 2018 and 2030 performed by the EPA for the new Tier 3 engine and fuel
standards and modeling performed by the Southeastern states for 2018 indicate that the area will
be in attainment of the 2008 ozone NAAQS.2, 3 The emission inventory comparison demonstrates
that the Charlotte area is expected to maintain the 2008 8-hour ozone NAAQS through 2026 since
in no future year are the emissions expected to be greater than they were in the base year. The
area is also in compliance with Section 110 and Part D requirements of the CAA.
1 http://charmeck.org/mecklenburg/county/LUESA/AirQuality/MobileSources/Pages/GRADE.aspx.
2 US EPA, http://www.epa.gov/otaq/documents/tier3/454r14002.pdf.
3 Southeastern States Air Resource Managers (SESARM); Southeastern Modeling, Analysis and Planning (SEMAP)
study, http://semap.ce.gatech.edu/sites/default/files/files/projections/base2018b-O3-DVFs-DDVFs-for-4configs.xls.
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Conclusion and Request for Approval of Revised Maintenance Plan
Based on the information provided in this supplement to the revised SIP and criteria established in
Section 107(d)(3)(E) of the CAA, North Carolina is requesting that EPA approve this supplement
to the revised maintenance plan for the Charlotte-Gastonia-Salisbury maintenance area. The
proposed revisions entail only revisions to the 2026 MVEBs to make them compatible with the
latest approved mobile source emissions model, MOVES3, and only affect the projected on-road
and nonroad emissions inventories for 2026. With the proposed revisions, the maintenance plan
continues to demonstrate that the projected emissions inventories for 2026, the final year of the
maintenance plan and 10 years beyond the redesignation year, as well as the interim years, are all
less than the base year emissions inventory. Therefore, continued maintenance of the 2008 8-
hour ozone NAAQS will not be affected by the proposed revisions.
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................................................................................................ ii
1.0 INTRODUCTION .................................................................................................................... 1
1.1 WHAT IS TROPOSPHERIC OZONE? .............................................................................. 1
1.2 CLEAN AIR ACT OF 1990 ................................................................................................ 2
1.3 AIR QUALITY HISTORY ................................................................................................. 2
1.4 CLEAN AIR ACT REDESIGNATION CRITERIA ........................................................... 4
2.0 AIR QUALITY ......................................................................................................................... 5
2.1 HISTORIC AIR QUALITY (2003 – 2011) ......................................................................... 5
2.2 RECENT AIR QUALITY VALUES (2012 –2014) ............................................................ 7
2.3 PERMANENT AND ENFORCEABLE EMISSIONS REDUCTIONS ............................. 9
2.4 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE.................................... 13
2.5 EFFECT OF NOX CONTROL PROGRAMS ON OZONE LEVELS ............................. 15
3.0 MAINTENANCE PLAN ........................................................................................................ 18
3.1 CONCEPT OF NORTH CAROLINA'S MAINTENANCE PLAN .................................. 18
3.2 FOUNDATION CONTROL PROGRAM......................................................................... 19
3.2.1 Federal Control Measures ........................................................................................... 19
3.2.2 State Control Measures ................................................................................................ 26
3.3 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE.................................... 29
3.3.1 State Programs Supporting Maintenance .................................................................... 29
3.3.2 Local Programs Supporting Maintenance ................................................................... 30
3.4 EMISSIONS INVENTORIES AND MAINTENANCE DEMONSTRATION ............... 31
3.4.1 Theory of Approach .................................................................................................... 31
3.4.2 Emission Inventories ................................................................................................... 32
3.4.3 Summary of Emissions ............................................................................................... 40
3.4.4 Maintenance Demonstration ....................................................................................... 41
3.4.5 National and Regional Air Quality Assessments in Future Years .............................. 42
3.5 CONTINGENCY PLAN ................................................................................................... 43
3.5.1 Overview ..................................................................................................................... 43
3.5.2 Contingency Plan Triggers ......................................................................................... 44
3.5.3 Action Resulting From Trigger Activation ................................................................. 44
3.5.4 Tracking Program for Ongoing Maintenance ............................................................. 45
4.0 MOTOR VEHICLE EMISSIONS BUDGET FOR CONFORMITY .................................... 46
4.1 TRANSPORTATION CONFORMITY ............................................................................ 46
4.2 SAFETY MARGIN ........................................................................................................... 46
4.3 MOTOR VEHICLE EMISSION BUDGETS .................................................................... 47
5.0 STATE IMPLEMENTATION PLAN APPROVAL .............................................................. 51
5.1 INTRODUCTION ............................................................................................................. 51
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2008 8-hour Ozone Marginal Nonattainment Area December 19, 2022
5.2 EVIDENCE OF COMPLIANCE ...................................................................................... 51
6.0 STATE COMPLIANCE WITH CLEAN AIR ACT REQUIREMENTS ............................... 54
7.0 SUMMARY AND CONCLUSION RELATED TO THIS REVISION TO THE
MAINTENANCE PLAN .............................................................................................................. 55
LIST OF FIGURES
Figure 1.1 Charlotte Nonattainment Area Boundary ....................................................................... 3
Figure 2.1 Ozone Monitor Locations in the Charlotte Nonattainment Area ................................... 5
Figure 2.2 Relationship between high temperature days and number of exceedance days in the
Charlotte area .................................................................................................................................. 17
Figure 2.3 Relationship between high temperature days and maximum 4th highest ozone value in
the Charlotte Area ........................................................................................................................... 17
LIST OF TABLES
Table 1.1 Counties and Townships within the Charlotte Nonattainment Area ............................... 3
Table 2.1 Charlotte Area’s Historic 4th Highest 8-hour Ozone Values (2003-2014) ...................... 6
Table 2.2 Charlotte Area’s Historic Design Values (2003 - 2014).................................................. 7
Table 2.3 Charlotte Area’s Current Air Quality Data (2012 -2014) ................................................ 8
Table 2.4 NOx Emissions from NC Sources in EPA’s Air Markets Program Database ............... 15
Table 2.5 April 1 through September 30 NOx Emissions for Electric Utilities Near Charlotte
Area (tons/period) ........................................................................................................................... 16
Table 3.1 Population Percentages Used to Allocate Partial County Emissions ............................ 32
Table 3.2 References/Data Sources for the Base Year Emissions Inventory and Revised
Emissions Forecast.......................................................................................................................... 33
Table 3.3 Point Source NOx Emissions (tons/summer day).......................................................... 36
Table 3.4 Point Source VOC Emissions (tons/summer day) ......................................................... 36
Table 3.5 Area Source NOx Emissions (tons/summer day) .......................................................... 37
Table 3.6 Area Source VOC Emissions (tons/summer day).......................................................... 37
Table 3.7 On-road Mobile Source NOx Emissions (tons/summer day) ........................................ 38
Table 3.8 On-road Mobile Source VOC Emissions (tons/summer day) ....................................... 38
Table 3.9 Nonroad Mobile Source NOx Emissions (tons/summer day) ....................................... 39
Table 3.10 Nonroad Mobile Source VOC Emissions (tons/summer day) ..................................... 40
Table 3.11 Total Man-Made NOx Emissions for the North Carolina Portion of the Charlotte
Maintenance Area (tons/summer day) ............................................................................................ 40
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Table 3.12 Total Man-Made VOC Emissions for the North Carolina Portion of the Charlotte
Maintenance Area (tons/summer day) ............................................................................................ 41
Table 3.13 Maintenance Demonstration for North Carolina Portion of the Charlotte Maintenance
Area ................................................................................................................................................. 41
Table 3.14 Safety Margins for North Carolina Portion of the Charlotte Maintenance Area ......... 42
Table 3.15 Eight-hour Design Values from SEMAP Photochemical Modeling ........................... 42
Table 3.16 Eight-hour Design Values Scenarios from EPA Tier 3 Photochemical Modeling ...... 43
Table 4.1 Percent Increase to Mobile Vehicle Emissions Budget ................................................. 47
Table 4.2 Highway Mobile Source NOx and VOC Summer Day Emissions in 2014 and 2026 for
North Carolina Portion of the Charlotte Maintenance Area ........................................................... 47
Table 4.3 Cabarrus Rowan Metropolitan Planning Organization (CRMPO) MVEB in 2014 and
2026 (kg/summer day)* .................................................................................................................. 49
Table 4.4 Gaston-Cleveland-Lincoln Metropolitan Planning Organization (GCLMPO) MVEB in
2014 and 2026 (kg/summer day)* .................................................................................................. 50
Table 4.5 Charlotte Regional Transportation Planning Organization (CRTPO) -Rocky River
Rural Planning Organization (RRRPO) MVEB in 2014 and 2026 (kg/summer day)* .................. 50
Table 4.6 New Safety Margins for the North Carolina Portion of the Charlotte Maintenance Area
(tons/summer day) .......................................................................................................................... 50
LIST OF APPENDICES
Appendix A: On-road Mobile Source Inventory Documentation
Appendix B: Nonroad Mobile Source Emissions Inventory Documentation - MOVES3.0 Run
Spec Files for 2026
Appendix C: Public Notice and U.S. EPA No Comment Documents
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LIST OF ACRONYMS
Acronym Definition
AADVMT Average annual daily vehicle miles traveled
AERR Air Emission Reporting Rule
ARRA American Recovery and Reinvestment Act
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CAMD Clean Air Markets Division
CDOT Charlotte Department of Transportation
CFR Code of Federal Regulations
CMAQ Congestion Mitigation and Air Quality Improvement
CNG Compressed Natural Gas
CO Carbon Monoxide
CRMPO Cabarrus Rowan Metropolitan Planning Organization
CRTPO Charlotte Regional Transportation Planning Organization
CSAPR Cross State Air Pollution Rule
DAQ North Carolina Division of Air Quality
DERA Diesel Emissions Reduction Act
DOC Diesel Oxidation Catalyst
DPF Diesel Particulate Filter
EF Emission factor
EGU Electricity Generating Units
EPA United States Environmental Protection Agency
ºF Degrees Fahrenheit
FHWA Federal Highway Administration
FIP Federal Implementation Plan
FR Federal Register
GCLMPO Gaston-Cleveland-Lincoln Metropolitan Planning Organization
GHG Greenhouse Gas
GIS Geographic Information System
GRADE Grants to Replace Aging Diesel Engines
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Acronym Definition
HAP Hazardous Air Pollutant
HC Hydrocarbons
HDDV Heavy duty diesel vehicles
HDGV Heavy duty gas vehicles
HPMS Highway performance monitoring system
I/M Inspection and Maintenance
ICI Industrial and commercial/institutional
KCLT Charlotte Douglas International Airport
kg/day Kilograms/Day
lbs Pounds
LDDT1 Light duty diesel trucks 1
LDDT2 Light duty diesel trucks 2
LDDV Light duty diesel vehicles
LDGT1 Light duty gas trucks 1
LDGT2 Light duty gas trucks 2
LDGV Light duty gas vehicles
MATS Mercury Air Toxics Standards
MC Motorcycles
MCAQ Mecklenburg County Air Quality
MOA Memorandum of Agreement
MOVES Motor Vehicle Emissions Simulator
mpg miles per gallon
MPO Metropolitan Planning Organization
MRM Metrolina Regional Model
MTP Metropolitan Transportation Plan
MVEB Motor Vehicle Emission Budget
NAAQS National Ambient Air Quality Standard
NCAA North Carolina Air Awareness
NCAC North Carolina Administrative Code
NCDOT North Carolina Department of Transportation
NEI National Emissions Inventory
NESHAP National Emissions Standards for Hazardous Air Pollutants
NHTSA National Highway Traffic Safety Administration
NMOG Non-methane Organic Gases
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OBD Onboard Diagnostic
PM Particulate Matter
PM10 Particulate matter with an aerodynamic diameter less than or equal to 10
micrometers
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Acronym Definition
PM2.5 Particulate matter with an aerodynamic diameter less than or equal to 2.5
micrometers
ppb Parts per billion
ppm Parts per million
psi pounds per square inch
QA Quality Assurance
QAPP Quality Assurance Project Plan
RICE Reciprocating Internal Combustion Engines
RPO Rural Planning Organization
RRRPO Rock River Rural Planning Organization
RT Road type
RVP Reid Vapor Pressure
SCDHEC South Carolina Department of Health and Environmental Control
SEMAP Southeastern Modeling, Analysis and Planning
SESARM Southeastern States Air Resource Managers
SIP State Implementation Plan
SO2 Sulfur Dioxide
SUV Sport Utility Vehicle
TDM Transportation Demand Model
TIP Transportation Improvement Program
TVA Tennessee Valley Authority
UI Urban interstate
UF Urban freeway
VHT Vehicle Hours Traveled
VMT Vehicle Miles Traveled
VOC Volatile Organic Compounds
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1.0 INTRODUCTION
1.1 WHAT IS TROPOSPHERIC OZONE?
Ozone, a strong chemical oxidant, adversely impacts human health through effects on respiratory
function and can also damage forests and crops. Ozone is not emitted directly by the electric
utilities, industrial sources or motor vehicles but instead, is formed in the lower atmosphere, the
troposphere, by a complex series of chemical reactions involving nitrogen oxides (NOx),
resulting from the utilities, combustion processes and motor vehicles, and reactive volatile
organic compounds (VOCs). VOCs include many industrial solvents, toluene, xylene and
hexane as well as the various hydrocarbons (HC) that are evaporated from the gasoline used by
motor vehicles or emitted through the tailpipe following combustion.
Ozone formation is promoted by strong sunlight, warm temperatures, and light winds. High
concentrations tend to be a problem in the eastern United States only during the hot summer
months when these conditions frequently occur. Therefore, the U. S. Environmental Protection
Agency (EPA) mandates seasonal monitoring of ambient ozone concentrations in North Carolina
from April 1 through October 31 (40 CFR 58 App. D, 2.5).4 The DAQ has examined both the
man-made and natural sources of VOC emissions and their contribution to ozone formation in
North Carolina. Because of the generally warm and moist climate of North Carolina, vegetation
abounds in many forms, and forested lands naturally cover much of the state. As a result, the
biogenic sector is the most abundant source of VOCs in North Carolina and accounts for
approximately 90% of the total VOC emissions statewide. The overwhelming abundance of
biogenic VOCs makes the majority of North Carolina a NOx limited environment for the
formation of ozone. This is supported by a study published in the Journal of Environmental
Management that concludes that the sensitivity of ozone to anthropogenic VOC emissions in the
Southeastern United States is 2-3 orders of magnitude smaller than the sensitivity of ozone to
NOx emissions, primarily due to the abundance of biogenic VOC emissions in this region.5 As a
result, controlling anthropogenic VOC emissions in the Southeast is far less effective than
controlling NOx emissions for purposes of reducing ozone levels.
On March 12, 2008, the EPA revised the primary (health) and secondary (welfare) National
Ambient Air Quality Standards (NAAQS) for ozone to a level of 0.075 parts per million (ppm).
An exceedance of the 2008 8-hour ozone NAAQS occurs when a monitor measures ozone above
0.075 ppm on average for an 8-hour period. A violation of this NAAQS occurs when the
average of the annual fourth highest daily maximum 8-hour ozone values over three consecutive
4 40 CFR 58 App. D, 2.5.
5 Odman, M Talat et al., Quantifying the sources of ozone, fine particulate matter, and regional haze in the
Southeastern United States, 90 Journal of Environmental Management 3155-3168 (2009).
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years is greater than or equal to 0.076 ppm. This three-year average is termed the “design value”
for the monitor. The design value for a nonattainment area is the highest monitor’s design value
in the area.
1.2 CLEAN AIR ACT OF 1990
Since the 1977 amendments to the Clean Air Act (CAA), areas of the country that had not
attained the ambient standard for a particular pollutant were formally designated as
nonattainment for that pollutant. This formal designation concept was retained in the 1990 CAA
Amendments.
1.3 AIR QUALITY HISTORY
The area surrounding Charlotte-Gastonia-Rock Hill, North Carolina-South Carolina, called the
Metrolina area (see Figure 1.1), was designated nonattainment for the 1997 8-hour ozone
NAAQS on April 30, 2004.6 The 1997 8-hour ozone NAAQS was set at 0.085 ppm. The
Metrolina nonattainment area includes the North Carolina counties of Cabarrus, Gaston, Lincoln,
Mecklenburg, Rowan and Union; Coddle Creek and Davidson Townships in Iredell County,
North Carolina; and the Rock Hill Metropolitan Planning Organization boundary in York County,
South Carolina. On December 2, 2013, the EPA approved North Carolina’s redesignation
demonstration and maintenance plan for the 1997 8-hour ozone NAAQS for the Charlotte-
Gastonia-Rock Hill, North Carolina area.7
On July 20, 2012, the EPA designated the Charlotte-Gastonia-Salisbury, North Carolina
nonattainment area (referred to as the Charlotte area) as “marginal” nonattainment for the 2008
8-hour ozone standard (Figure 1.1) based on the ambient data from 2009-2011. The
nonattainment area includes all of Mecklenburg County and portions of Cabarrus, Gaston,
Iredell, Lincoln, Rowan, and Union Counties. Table 1.1 identifies the townships in each county
that are included in the Charlotte nonattainment area. At that time, the design value for the
Charlotte area was 0.079 ppm. The official designation and classification was published in the
Federal Register (FR) on May 21, 2012.8 The designation became effective on July 20, 2012.
6 69 FR 23858.
7 78 FR 72036.
8 77 FR 30088.
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Figure 1.1 Charlotte Nonattainment Area Boundary
Table 1.1 Counties and Townships within the Charlotte Nonattainment Area
Cabarrus County Townships
Central Cabarrus Concord* Georgeville Harrisburg Kannapolis Midland
Mount Pleasant Odell Poplar Tent New Gilead Rimertown
Gaston County Townships
Dallas Crowders Mountain Gastonia Riverbend South Point
Iredell County Townships
Coddle Creek Davidson
Lincoln County Townships
Catawba Springs Lincolnton Ironton
Mecklenburg County – All Townships
Rowan County Townships
Atwell China Grove Franklin Gold Hill* Litaker Locke
Providence Salisbury Steele Unity
Union County Townships
Goose Creek Marshville Monroe Sandy Ridge Vance
*Note: Concord Township in Cabarrus County and Gold Hill Township in Rowan County were inadvertently left
out of North Carolina’s recommendation and EPA’s final designations. In a letter dated January 28, 2014, the North
Carolina Division of Air Quality (DAQ) requested EPA to add the missing townships in the state’s 2008 marginal
ozone nonattainment area definition.
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There are currently six ozone monitors located throughout the Charlotte area and one monitor
located in York County, South Carolina. The North Carolina Division of Air Quality (DAQ)
operates three of the monitors in the Charlotte area, the Mecklenburg County Air Quality
(MCAQ) operates three of the monitors in the Mecklenburg County, and South Carolina
Department of Health and Environmental Control (SCDHEC) operates the York County monitor.
In 2013, all but two monitors, Garinger and County Line located in Mecklenburg County, came
into attainment of the 2008 8-hour ozone NAAQS. With the completion of the 2014 ozone
season, the Garinger and County Line monitors attained the standard as well. The 2012-2014
design value for Charlotte area is 0.073 ppm.
1.4 CLEAN AIR ACT REDESIGNATION CRITERIA
Section 107(d)(3)(E) of the CAA, as amended, states an area can be redesignated to attainment if
the following conditions are met:
1. The EPA has determined that the NAAQS have been attained. For ozone, the areas must
show that the average of the fourth highest 8-hour ozone values from three (3) complete,
consecutive calendar years of quality-assured air quality monitoring data must be below
0.076 ppm.
2. The applicable implementation plan has been fully approved by the EPA under Section
110(k).
3. The EPA has determined that the improvement in air quality is due to permanent and
enforceable reductions in emissions. To demonstrate this, the state should estimate the
percent reduction (from the year used to determine the design value for designation and
classification) achieved from federal, state, and local measures.
4. The state has met all applicable requirements for the area under Section 110 and Part D.
5. The EPA has fully approved a maintenance plan, including a contingency plan, for the
areas under Section 175A.
In the following sections, the DAQ provides the technical data necessary to show that the
Charlotte-Gastonia-Salisbury nonattainment area has attained and is expected to maintain the
2008 8-hour ozone standard, and has met the requirements for redesignation set forth above.
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2.0 AIR QUALITY
2.1 HISTORIC AIR QUALITY (2003 – 2011)
The DAQ and MCAQ have collected ambient monitoring data for the Charlotte area since the
late seventies. Figure 2.1 shows the location of the six ozone monitors throughout the Charlotte
nonattainment area. In addition, one additional ozone monitor is located in York County, South
Carolina (not shown in Figure 2.1). These monitors were installed in accordance with the Code
of Federal Regulations (CFR) 40 CFR 58.
Figure 2.1 Ozone Monitor Locations in the Charlotte Nonattainment Area
Tables 2.1 and 2.2 show the air quality data and corresponding design values for the monitors in
the Charlotte region, respectively, from 2003 to 2014. As shown in Table 2.2, the design values
for most of the monitors near and downwind of Charlotte have been declining rapidly in the past
several years.
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Table 2.1 Charlotte Area’s Historic 4th Highest 8-hour Ozone Values (2003-2014)
Monitor 4th Highest 8-hour Ozone Values (ppm)
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Crouse
AIRS ID #37-109-0004
Lincoln County
0.089 0.074 0.082 0.082 0.085 0.079 0.065 0.072 0.077 0.076 0.064 0.064
Garinger
AIRS ID #37-119-0041
Mecklenburg County
0.086 0.085 0.088 0.091 0.093 0.085 0.069 0.082 0.088 0.080 0.067 0.065
Arrowood
AIRS ID #37-119-1005
Mecklenburg County
0.073 0.077 0.085 0.078 0.087 0.073 0.068 0.078 0.082 0.073 0.062 0.063
County Line
AIRS ID #37-119-1009
Mecklenburg County
0.088 0.083 0.090 0.093 0.096 0.093 0.071 0.082 0.083 0.085 0.066 0.068
Rockwell
AIRS ID #37-159-0021
Rowan County
0.098 0.080 0.086 0.085 0.096 0.084 0.071 0.077 0.077 0.080 0.062 0.064
Enochville1
AIRS ID #37-159-0022
Rowan County
0.087 0.080 0.088 0.089 0.095 0.082 0.073 0.078 0.078 0.077 0.063 -----
Monroe
AIRS ID #37-179-0003
Union County
0.083 0.074 0.082 0.080 0.082 0.080 0.067 0.071 0.073 0.075 0.062 0.067
York
AIRS ID #45-091-0006
York County
0.076 0.071 0.079 0.078 0.080 0.075 0.062 0.065 0.065 0.065 0.061 0.056
1 Monitoring data for 2014 are not available for this monitor because it was shut down in 2014.
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Table 2.2 Charlotte Area’s Historic Design Values (2003 - 2014)
Monitor Design Value (ppm)
03-05 04-06 05-07 06-08 07-09 08-10 09-11 10-12 11-13 12-14
Crouse
AIRS ID #37-109-0004
Lincoln County
0.081 0.079 0.083 0.082 0.076 0.072 0.071 0.075 0.072 0.068
Garinger
AIRS ID #37-119-0041
Mecklenburg County
0.086 0.088 0.090 0.089 0.082 0.078 0.079 0.083 0.078 0.070
Arrowood
AIRS ID #37-119-1005
Mecklenburg County
0.078 0.080 0.083 0.079 0.076 0.073 0.076 0.077 0.072 0.066
County Line
AIRS ID #37-119-1009
Mecklenburg County
0.087 0.088 0.093 0.094 0.086 0.082 0.078 0.083 0.078 0.073
Rockwell
AIRS ID #37-159-0021
Rowan County
0.088 0.083 0.089 0.088 0.083 0.077 0.075 0.078 0.073 0.068
Enochville1
AIRS ID #37-159-0022
Rowan County
0.085 0.085 0.090 0.088 0.083 0.077 0.076 0.077 0.072 ----
Monroe
AIRS ID #37-179-0003
Union County
0.079 0.078 0.081 0.080 0.076 0.072 0.070 0.073 0.070 0.068
York
AIRS ID #45-091-0006
York County
0.075 0.076 0.079 0.077 0.072 0.067 0.064 0.065 0.063 0.060
Note: Bolded values represent violations of the 2008 8-hour ozone standard.
1 2012-2014 design value for this monitor is not available because it was shut down in 2014.
2.2 RECENT AIR QUALITY VALUES (2012 –2014)
Under the CAA, a marginal classification for the 2008 8-hour ozone NAAQS requires North
Carolina to attain the standard within three years of designation, or July 20, 2015. However, in
the 2008 Ozone Implementation Rule, the EPA extended the compliance date to December 31,
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2015.9 In a ruling by the U.S. Court of Appeals for the District of Columbia Circuit, the
extension deadline was vacated, among other decisions.10
The most recent three years of ozone monitoring data (2012-2014) for the Charlotte
nonattainment area demonstrate compliance with the 2008 8-hour ozone NAAQS. Table 2.3 is a
summary of the fourth highest 8-hour average ozone concentration and the design value at each
of the monitors in the Charlotte region for 2012-2014.
Table 2.3 Charlotte Area’s Current Air Quality Data (2012 -2014)
Monitor Year 4th Highest 8-hour
ozone values (ppm)
Design Value (ppm)
2012-2014
Crouse
AIRS ID #37-109-0004
Lincoln County
2012 0.076
0.068 2013 0.064
2014 0.064
Garinger
AIRS ID #37-119-0041
Mecklenburg County
2012 0.080
0.070 2013 0.067
2014 0.065
Arrowood
AIRS ID #37-119-1005
Mecklenburg County
2012 0.073
0.066 2013 0.062
2014 0.063
County Line
AIRS ID #37-119-1009
Mecklenburg County
2012 0.085
0.073 2013 0.066
2014 0.068
Rockwell
AIRS ID #37-159-0021
Rowan County
2012 0.080
0.068 2013 0.062
2014 0.064
Monroe
AIRS ID #37-179-0003
Union County
2012 0.075
0.068 2013 0.062
2014 0.067
York
AIRS ID #45-091-0006
York County
2012 0.065
0.060 2013 0.061
2014 0.055
9 78 FR 34178.
10 http://www.cadc.uscourts.gov/internet/opinions.nsf/E97A64FFBFE4DC1D85257DB70054D5EE/$file/12-1321-
1528834.pdf.
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The 2014 8-hour ozone monitoring data for the Charlotte nonattainment area was fully quality
assured and officially submitted to the EPA for certification approval on December 12, 2014.
The EPA concurred with the DAQ and MCAQ certification on December 15, 2014. The
Enochville site in Rowan County was shut down in 2014, but the most recent design value for
that site was 0.072 ppm in 2011-2013 and it was not the highest value in Rowan County or the
greater Charlotte area at the time of its shutdown.
The monitoring data shown above demonstrates that the Charlotte area is attaining the 2008 8-
hour ozone standard, and is on schedule with the compliance date mandated in the CAA and
upheld by the D.C. Circuit Court.
2.3 PERMANENT AND ENFORCEABLE EMISSIONS REDUCTIONS
There are several state and federal measures that have been enacted in recent years that have
ensured permanent and enforceable emissions reductions. A list of those measures that
contributed to the permanent and enforceable emission reductions are summarized here and are
more fully described in Section 3.2.
The federal measures that have been implemented include:
• Tier 2 vehicle and fuel standards: Implementation began in 2004 and requires all
passenger vehicles in each manufacture’s fleet to meet an average standard of 0.07
grams of NOx per mile. Additionally, in January 2006 the sulfur content of gasoline
was required to be on average 30 ppm which assists in lowering NOx emissions.
Most gasoline sold in North Carolina prior to January 2006 had a sulfur content of
about 300 ppm. These emission reductions are federally enforceable.
• Tier 3 vehicle and fuel standards: Implementation begins in 2017 with full
compliance required by 2025. Tier 3 requires all passenger vehicles to meet an
average standard of 0.03 gram/mile of NOx. Compared to Tier 2, the Tier 3 tailpipe
standards for light-duty vehicles are expected to reduce NOx and VOC emissions by
approximately 80%. Tier 3 vehicle standards also include evaporative standards
using onboard diagnostics (OBD) that will result in a 50% reduction in VOC
emissions over Tier 2. The rule reduces the sulfur content of gasoline to 10 ppm
starting in January 2017. These emission reductions will be federally enforceable.
• National program for greenhouse gas (GHG) emissions and fuel economy standards:
The federal GHG and fuel economy standards apply to light-duty cars and trucks in
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model years 2012-2016 (phase 1) and 2017-2025 (phase 2). The final standards are
projected to result in an average industry fleet-wide level of 163 grams/mile of carbon
dioxide (CO2) which is equivalent to 54.5 miles per gallon (mpg) if achieved
exclusively through fuel economy improvements. The fuel economy standards will
result in less fuel being consumed, and therefore less NOx emissions released. These
emission reductions will be federally enforceable.
• Heavy-duty gasoline and diesel highway vehicle standards: Implementation of the
program began in 2004 with full implementation in 2010. The program was
estimated to reduce NOx emissions by 95% and required that the sulfur content of
fuel be reduced to 15 ppm. These emission reductions are federally enforceable.
• Medium- and heavy-duty vehicle fuel consumption and GHG standards: Began
implementation in 2014 and requires on-road vehicles to achieve from a 7% to 20%
reduction in CO2 emissions and fuel consumption by 2018. The decrease in fuel
consumption will result in a 7% to 20% decrease in NOx emissions. These emission
reductions will be federally enforceable.
• Large nonroad diesel engine standards: Phased in between 2008 through 2014, the
combined engine and fuel requirements are expected to reduce NOx emissions by
90% and reduce the sulfur content in the nonroad diesel fuel to 15 ppm. These
emission reductions are federally enforceable.
• Nonroad spark-ignition engine and recreational engine standards: Tier 1 of these
standards was implemented in 2004 and Tier 2 started in 2007. These standards
reduce NOx emissions by 80%. These emission reductions are federally enforceable.
• Clean Air Interstate Rule (CAIR) and Cross State Air Pollution Rule (CSAPR): In
May 2005, the EPA promulgated CAIR to reduce NOx and sulfur dioxide (SO2)
emissions from electricity generating units (EGUs). After court challenges to CAIR,
the EPA issued CSAPR in July 2011. CSAPR will take effect starting January 1,
2015 for SO2 and annual NOx, and May 1, 2015 for ozone season NOx. Combined
with other final state and EPA actions, the CSAPR will reduce power plant SO2
emissions by 73% and NOx emissions by 54% from 2005 levels. The emission
reductions will be federally enforceable.
• Tennessee Valley Authority (TVA) Consent Decree: In January 2009, a federal court
required TVA coal-fired EGUs to install modern pollution controls for SO2 and NOx
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After an appeals court reversed the decision, North Carolina, TVA, and several other
parties agreed to a settlement. The settlement caps NOx and SO2 emissions at all of
TVA’s coal-fired facilities to permanent levels of 52,000 tons of NOx in 2018 and
110,000 tons of SO2 in 2019. These emission reductions are federally enforceable.
• Boiler and Reciprocating Internal Combustion Engine (RICE) National Emissions
Standards for Hazardous Air Pollutants (NESHAP): The NESHAPs for industrial,
commercial and institutional boilers and RICE are expected to result in a small
decrease in VOC emissions. Boilers must comply with the NESHAP by January 31,
2016 for all states except North Carolina which has a compliance date in May 2019
(see following discussion under state measures). RICE owners and operators had to
comply with the NESHAP by May 3, 2013. These emission reductions are federally
enforceable.
• Utility Mercury Air Toxics Standards (MATS) and New Source Performance
Standards (NSPS): On February 16, 2012, the EPA published final rules for both the
(1) MATS for new and existing coal- and oil-fired EGUs and (2) NSPS for fossil-fuel
fired electric utility, industrial-commercial-institutional and small industrial-
commercial-institutional steam generating units.11 The MATS reduce emissions of
toxic air pollutants from EGUs larger than 25 megawatts that burn coal or oil for the
purpose of generating electricity for sale and distribution through the national electric
grid to the public. For the NSPS, the EPA revised the standards that new coal- and
oil-fired power plants must meet for NOx, SO2, and particulate matter (PM). While
MATS is still under court review, and portions of it may be overturned, the rule can
be expected to result in the reduction of both NOx and SO2 emissions in addition to
the reduction in mercury and other air toxic emissions. The emission reductions
associated with the MATS and revised NSPS are federally enforceable.
The state measures that have been implemented include:
• Vehicle Emissions Inspection and Maintenance (I/M) Program: In 1999, the North
Carolina State Legislation passed the Clean Air Bill that expanded the on-road
vehicle I/M program from 9 to 48 counties. It was phased-in in the Charlotte area
from July 1, 2002 through January 1, 2004. This program reduces NOx, VOC and
CO emissions. The rule for the I/M program was submitted to the EPA for adoption
into the State Implementation Plan (SIP) in August 2002 and was federally approved
11 77 FR 9304.
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in October 2002. Therefore, these emission reductions are both state and federally
enforceable.
On February 5, 2015, the EPA approved a change to North Carolina’s I/M rules
triggered by a state law which exempted plug-in vehicles and the three newest model
year vehicles with less than 70,000 miles on their odometers from emission
inspection in all areas in North Carolina where I/M is required.12 In North Carolina’s
Section 110(l) demonstration, the state showed that the change in the compliance rate
from 95% to 96% more than compensates for the NOx and VOC emissions increase.
The EPA-approved change to the I/M rules was effective March 9, 2015, and are state
and federally enforceable. See Section 3.2.2 of this SIP for a more detailed
discussion of this change.
• Clean Smokestacks Act: This state law requires coal-fired power plants to reduce
annual NOx emissions by 77% by 2009, and to reduce annual SO2 emissions by 49%
by 2009 and 73% by 2013. This law set a NOx emissions cap of 56,000 tons/year for
2009 and SO2 emissions caps of 250,000 tons/year and 130,000 tons/year for 2009
and 2013, respectively. The public utilities cannot meet these emission caps by
purchasing emission credits. The EPA approved the statewide emissions caps as part
of the Charlotte SIP on September 26, 2011. In 2013, the power plants subject to this
law had combined NOx emissions of 38,857 tons/year, well below the 56,000
tons/year cap. The emissions cap has been met in all subsequent years as well. These
emissions limits are enforceable at both the federal and state level.
• Boiler NESHAP: Because of delays associated with the EPA’s promulgation of the
boiler NESHAP, North Carolina adopted and implemented equivalent emission
limitations by permit under Section 112(j) of the CAA.13 These limitations apply to
owners and operators of industrial, commercial and institutional boilers and process
heaters burning natural gas, coal, oil or biomass beginning in 2013. These emissions
limits are enforceable at both the federal and state level.
• Transportation Conformity Memorandum of Agreements (MOAs): The Conformity
MOAs are signed by federal and state transportation agencies and local air quality
organizations and the Metropolitan Planning Organization (MPOs) subject to
transportation conformity requirements for applicable transportation-related NAAQs
and satisfies the requirement in the CAA Section 176(c). The DAQ chose through
12 Approval and Promulgation of Implementation Plans; North Carolina; Inspection and Maintenance Program
Updates, 80 FR, 6455.
13 15A NCAC 02D .1109 - 112(j) Case-by-Case Maximum Achievable Control Technology.
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rulemaking to develop Conformity MOAs to ensure that interagency consultation
procedures for transportation conformity are followed in each of the nonattainment or
maintenance areas in the state.
2.4 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE
This section provides a brief summary of state and local programs that have been implemented in
the Charlotte area to maintain compliance with the NAAQS. Although these are important
programs that help to ensure compliance with the NAAQS, they have not been relied upon as
federally enforceable measures. These state and local programs are more fully described in
Section 3.3.
State programs that have been implemented include:
• Air awareness program: The North Carolina Air Awareness Program is a public
outreach and education program of the DAQ. The goal of the program is to reduce
air pollution though voluntary actions by individuals and organizations. The program
seeks to educate individuals about (1) the sources of air pollution; (2) the health
effects of air pollution and how these effects can be mitigated by modification of
outdoor activities on ozone action days; and (3) simple "action tips", such as
carpooling, vehicle maintenance and energy conservation that reduce individual
contributions to air pollution. One of the major program components is the daily air
quality forecast. The DAQ produces the 8-hour ozone forecasts and corresponding
air quality index for the Charlotte forecast area from April 1 through October 31 of
each year.14 Additionally, the DAQ produces daily PM forecasts for the Charlotte
area.
• Grant Program: The DAQ has offered multiple forms of grant funding from state
and federal funds to help cover the costs associated with emission reduction projects
across the state. These projects include diesel engine replacements, diesel oxidation
catalyst (DOC) retrofits, marine diesel repowers, replacing gasoline vehicles with
electric vehicles, vehicle replacement and many more. Grant projects that have been
awarded have helped to reduce PM, NOx, CO and VOC emissions from mobile
sources.
• Open burning rule: This rule prohibits open burning of man-made materials
throughout the state. Additionally, the rule prohibits open burning of yard waste in
areas that the DAQ forecasts air quality action days. The open burning regulation
14 See N.C. DAQ http://www.ncair.org/airaware/.
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reduces NOx, VOC, and CO emissions as well as PM with an aerodynamic diameter
less than or equal to 10 micrometers (PM10) and 2.5 micrometers (PM2.5).
• Idle Reduction Regulation: The North Carolina Environmental Management
Commission adopted the Heavy-Duty Vehicle Idling Restrictions rule to reduce
unnecessary idling of heavy-duty trucks on July 9, 2009 and the rule became
effective on July 10, 2010. This rule generally prevents any person who operates a
heavy-duty vehicle to cause, let, permit, suffer or allow idling for a period of time in
excess of 5 consecutive minutes in any 60 minute period. This rule is state
enforceable.
Local program that have been implemented include:
• Open Burning Prohibition: Mecklenburg County prohibits open burning of any kind
year round, except under extenuating circumstances with an approved burn permit.
This prohibition is more stringent than the state’s open burning rule and therefore
enhances this control measure’s overall benefit to the region. The open burning rule
reduces NOx, VOC, CO, PM10 and PM2.5. These emission reductions are enforceable
at the local level.
• Grants to Replace Aging Diesel Engines (GRADE) Program: In 2007, MCAQ
initiated an air pollution control program called GRADE designed to reduce NOx
emissions in the Charlotte area. Funded by federal, state and local county grant
money, GRADE provides businesses and organizations financial incentives to replace
or repower heavy-duty non-road equipment with newer, cleaner, less polluting
engines. GRADE has funded cost effective emission reduction projects operating in
multiple segments of the economy including construction, landfills, timber logging
operations, open pit mining, freight transportation, and commercial aviation. As of
July 31, 2014, GRADE projects have reduced over 350 tons of NOx region-wide.
• Mobile Source Emissions Reduction Grants: This program reduces NOx, PM, and
VOC emissions. MCAQ has also received Diesel Emissions Reduction Act (DERA)
funding as well as American Recovery and Reinvestment Act (ARRA) and
Congestion Mitigation and Air Quality Improvement (CMAQ) program funding.
These funds have been used to repower or replace existing diesel engines from on-
road vehicles and nonroad equipment. Even though these emission reductions are
voluntary and not enforceable, they are still considered permanent reductions.
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2.5 EFFECT OF NOX CONTROL PROGRAMS ON OZONE LEVELS
The foundation control program for stationary and mobile sources for the Charlotte area has
significantly reduced NOx emissions enabling the area to demonstrate attainment with the 2008
ozone NAAQS. As an example, historically EGUs have been a significant source of NOx
emissions contributing to ozone formation during the summer months in the Charlotte area as
well as statewide. A recent review of the NOx emissions in the EPA’s Air Markets Program
Data database shows a reduction in over 96,641 tons of NOx from the reporting sources in North
Carolina between 2002 and 2013. The trend in decreasing NOx emissions from these facilities
are attributable to a combination of state (Clean Smokestacks Act) and federal (CAIR / CSAPR)
measures and market forces (switching from coal to natural gas due to favorable natural gas
prices). Table 2.4 presents the annual emissions for the North Carolina sources obtained from
the EPA’s Air Markets Program Data database.
Table 2.5 shows trends in NOx emissions from 2002 through 2013 from North Carolina power
plants in the Charlotte area, as well as the power plants located directly north and west of the
Charlotte region that may impact the area. There are four facilities located within Gaston,
Lincoln and Rowan Counties. The facility west of the Charlotte area is Cliffside, located in
Cleveland County and the facility north of the
Table 2.4 NOx Emissions from NC Sources in EPA’s Air Markets Program Database
Year Annual NOx Emissions from NC
Sources (tons)
2002 145,706
2003 135,879
2004 124,079
2005 114,300
2006 108,584
2007 64,770
2008 61,669
2009 44,506
2010 57,305
2011 48,889
2012 51,057
2013 49,065
Charlotte area is Marshall located in Catawba County. These data are taken from the EPA Clean
Air Markets Division’s (CAMD) Air Markets Program Data and represent the second and third
quarters of the year (April through September), the period during which ozone levels are the
highest. The emissions from these facilities have significantly decreased during the ozone
season since 2002, with over 12,000 tons of NOx reduction in the 2013 ozone season compared
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to 2002. In addition, two coal-fired power plants (Buck and Riverbend) were retired in April
2013, which resulted in additional emissions reductions.
Table 2.5 April 1 through September 30 NOx Emissions for Electric Utilities Near
Charlotte Area (tons/period)
Facility County 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Allen* Gaston 5,011 3,643 4,002 3,589 3,001 3,053 3,082 2,188 2,925 2,738 1,676 1,906
Riverbend* Gaston 2,556 2,703 1,844 1,379 1,417 1,296 1,256 304 1,063 884 109 0
Lincoln* Lincoln 44 20 50 20 52 81 33 6 40 46 10 22
Buck* Rowan 1,084 1,468 1,089 1,286 1,262 870 832 197 783 477 196 61
Marshall Catawba 9,283 9,101 8,243 7,558 6,370 7,253 7,151 4,481 4,861 5,443 5,128 4,777
Cliffside Cleveland 1,944 2,149 1,738 1,782 1,540 1,311 1,173 561 357 469 267 673
Total ----- 19,922 19,084 16,966 15,614 13,642 13,864 13,527 7,737 10,029 10,057 7,386 7,439
*Facility is located within the Charlotte nonattainment area boundary.
Temperature is a key meteorological factor that determines the ozone production potential of a
given day. In North Carolina, many exceedances occur when the maximum daily temperature is
90 degrees Fahrenheit (ºF) or greater. In recent years, however, foundation control program
measures have reduced NOx emissions in the Charlotte area to the extent that recent trends are
showing that ozone levels are lower than the NAAQS even when the daily temperature is 90 ºF
or greater. Figure 2.2 shows the relationship of exceedance days to high temperature days from
2000 through 2014 for the Charlotte region monitors. The relationship between the maximum 4th
highest ozone value to high temperature days from 2000 through 2014 is displayed in Figure 2.3.
It is important to see how the ozone levels have changed over the last decade in response to
lower NOx emissions in the state. The worst summer in terms of the number of exceedance days
and observed 4th highest ozone concentrations was 2002, with 61 exceedance days in the
Charlotte region and a maximum 4th highest daily average 8-hour concentration of 0.108 ppm.
That summer there were 49 days when the temperature was 90 ºF or greater in the Charlotte
region. The next highest number of exceedance days occurred in 2007 with 56 days and 74 days
with temperatures at or above 90 °F, yet the maximum 4th highest daily average 8-hour
concentration was significantly lower than 2002 at 0.096 ppm. More recently, in the year 2010,
the Charlotte area experienced the hottest summer of the 21st century with 86 days at or above 90
°F. However, the Charlotte area only observed 17 exceedance days and the maximum 4th highest
daily average concentration was only 0.082 ppm. In subsequent years, the 4th-highest values
have generally decreased as the number of very hot days over 90 degrees has moderated. In
2014, there were a total of 37 days with a high temperature over 90 degrees, but no exceedances
of the 2008 8-hour ozone standard and a peak 4th highest daily average value of 0.068 ppm. The
steady decrease of ozone values over the last 15 years regardless of summertime temperature
regime illustrates the progress that North Carolina has made and the positive effects of the
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control strategies put in place by North Carolina, Mecklenburg County and the EPA to regulate
NOx emissions.
Figure 2.2 Relationship between high temperature days and number of exceedance days in
the Charlotte area
Figure 2.3 Relationship between high temperature days and maximum 4th highest ozone
value in the Charlotte Area
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3.0 MAINTENANCE PLAN
3.1 CONCEPT OF NORTH CAROLINA'S MAINTENANCE PLAN
The state's plan for maintaining compliance with the ambient air quality standard for the 2008
8-hour ozone in the Charlotte-Gastonia-Salisbury nonattainment area consists of three major
parts: a foundation control program, a maintenance demonstration, and a contingency plan. The
foundation control program consists of the current federal and state control measures already in
effect, as well as the future benefits of the federal actions. For EGUs, the future federal actions
include implementation of the MATS, CSAPR, and carbon rules and the TVA consent decree.
Additionally, North Carolina will continue to implement and enforce the Clean Smokestacks
Act. For on-road vehicles, the future federal actions include compliance with the Tier 3 vehicle
emissions and fuel standards and corporate average fuel economy standards for on-road vehicles.
Although North Carolina did not rely on the emission reductions from CSAPR or the TVA
consent decree for maintenance of the 2008 8-hour ozone standard, these actions will result in
additional reductions in NOx emissions regionally.
The foundation control program includes federally and state enforceable control programs that
have been adopted and implemented by the DAQ. These programs will remain enforceable and
ensure that maintenance of the 2008 8-hour ozone standard will continue. Sources are prohibited
from reducing or removing emission controls (anti-backsliding) following the redesignation of
the area unless such a change is first approved by the EPA as a revision to the North Carolina
SIP that is consistent with Section 110(l) of the CAA.
For the maintenance demonstration, the base year of 2014 was chosen since it is a year that falls
within the attaining design value period of 2012-2014. The interim years 2015, 2018 and 2022
were chosen based on consultation with the EPA. The final year of the maintenance
demonstration is 2026, since the CAA requires maintenance for at least 10 years after the EPA
approves the redesignation demonstration and maintenance plan. The maintenance
demonstration consists of a comparison between the 2014 baseline emissions inventory and the
projected emissions inventories (for 2015, 2018, 2022, and 2026), which consider economic and
population growth. The comparison shows that the total emissions in each of the interim years
and the final year is estimated to be lower than in the base year, which demonstrates maintenance
of the 2008 8-hour ozone standard. The reductions in emissions are due to the foundation
control programs outlined below.
The North Carolina contingency plan involves tracking and triggering mechanisms to determine
when contingency measures are needed and a process of implementing appropriate control
measures. The primary trigger of the contingency plan will be a violation of the ambient air
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quality standard for 2008 8-hour ozone standard. The secondary trigger will be a monitored air
quality pattern that suggests an actual 2008 8-hour ozone NAAQS violation may be imminent.
On April 17, 2015, the SCDHEC submitted to EPA a SIP package request to redesignate the
York County portion of the Charlotte nonattainment area to attainment. On December 11, 2015,
EPA approved the SCDHEC's request and the redesignation to attainment became effective on
January 11, 2016 (80 FR 76865).
3.2 FOUNDATION CONTROL PROGRAM
The main element of the maintenance plan is the foundation control program. The foundation
control program consists of a combination of federal and state control measures necessary to
maintain the ambient air quality standards. The purpose of the foundation control program is to
prevent the ambient air quality standards from being violated and thereby eliminate the need for
more costly controls being imposed on industry and the general public. Each component of the
foundation control program is essential in demonstrating maintenance of the air quality
standards. The following provides a summary of each federal and state control measure included
in the foundation control program for the Charlotte nonattainment area. All of these programs
have already been implemented or are in the process of being implemented.
3.2.1 Federal Control Measures
Tier 2 Vehicle and Fuel Standards
Federal Tier 2 vehicle standards require all passenger vehicles in a manufacturer’s fleet,
including light-duty trucks and sport utility vehicles (SUVs), to meet an average standard of 0.07
gram/per mile of NOx. Implementation began in 2004, with full compliance required by 2007.
The Tier 2 standards also cover passenger vehicles over 8,500 pounds gross vehicle weight
rating (the larger pickup trucks and SUVs), which are not covered by the Tier 1 regulations. For
these vehicles, the standards were phased in beginning in 2008, with full compliance required by
2009. The Tier 2 standards require vehicles to be 77% to 95% cleaner. The Tier 2 rule also
reduced the sulfur content of gasoline to 30 ppm starting in January of 2006. Most gasoline sold
in North Carolina prior to January 2006 had a sulfur content of about 300 ppm. Sulfur occurs
naturally in gasoline and interferes with the operation of catalytic converters on vehicles, which
results in higher NOx emissions. Lower-sulfur gasoline is necessary to achieve the Tier 2
vehicle emission standards.15 These emission reductions are federally enforceable.
15 Fact Sheet, Office of Mobile Sources, EPA-420-F-99-051, December 1999.
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Tier 3 Vehicle and Fuel Standards
Federal Tier 3 vehicle standards require all passenger vehicles in a manufacturer’s fleet,
including light-duty trucks and SUVs, to meet an average standard of 0.03 gram/per mile of
NOx. Heavy-duty passenger vehicles must meet average standards of 0.178 to 0.247 gram/per
mile of NOx depending on vehicle classification. Implementation begins in 2017, with full
compliance required by 2025. Compared to current standards in 2014, the Tier 3 tailpipe
standards for light-duty vehicles are expected to reduce non-methane organic gases (NMOG) and
NOx by approximately 80%. The Tier 3 program is expected to reduce per-vehicle PM
standards by approximately 70%. The heavy-duty tailpipe standards represent about a 60%
reduction in both fleet average NMOG+NOx and per vehicle PM standards. Tier 3 vehicle
standards also require evaporative standards including OBD that will result in a 50% reduction in
VOC emissions from Tier 2 for all 2017 and later light-duty and on-road gasoline-powered
heavy-duty vehicles. The Tier 3 rule also reduced the sulfur content of gasoline to 10 ppm
starting in January 2017. Tier 2 standards had limited the sulfur content to 30 ppm. Sulfur
occurs naturally in gasoline and interferes with the operation of catalytic converters on vehicles,
which results in higher NOx emissions.16 These emission reductions are federally enforceable.17
National Program for GHG Emissions and Fuel Economy Standards
The EPA and the National Highway Traffic Safety Administration (NHTSA) jointly developed
the federal GHG and fuel economy standards for light-duty cars and trucks in model years 2012-
2016 (phase 1) and 2017-2025 (phase 2). The EPA also aligned implementation of the Tier 3
program with the second phase of the EPA and NHTSA federal GHG and fuel economy
standards program. Together, phases 1 and 2 of the final standards are projected to result in an
average industry fleet-wide level of 163 grams/mile of CO2 in model year 2025, which is
equivalent to 54.5 mpg if achieved exclusively through fuel economy improvements.18 The fuel
economy standards will result in less fuel being consumed, and therefore less NOx emissions
released. These emission reductions will be federally enforceable.
Heavy-Duty Gasoline and Diesel Highway Vehicles Standards
The EPA standards designed to reduce NOx and VOC emissions from heavy-duty gasoline and
diesel highway vehicles began to take effect in 2004. A second phase of standards and testing
procedures that began in 2007 reduced PM from heavy-duty highway engines and also reduced
highway diesel fuel sulfur content to 15 ppm since the sulfur damages emission control devices.
The total program is expected to achieve a 90% reduction in PM emissions and a 95% reduction
16 Fact Sheets, Office of Transportation and Air Quality, EPA-420-F-14-008 and EPA-420-F-14-009, March 2014.
17 See U.S. EPA, http://www.epa.gov/otaq/tier3.htm.
18 See U.S. EPA, http://www.epa.gov/otaq/climate/regs-light-duty.htm.
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in NOx emissions for these new engines using low-sulfur diesel, compared to engines using
higher-content sulfur diesel. These emission reductions are federally enforceable.
Large Nonroad Diesel Engines Rule
In May 2004, the EPA promulgated new rules for large nonroad diesel engines, such as those
used in construction, agricultural and industrial equipment, to be phased in between 2008 and
2014. The nonroad diesel rules also reduced the allowable sulfur in nonroad diesel fuel to 15
ppm. Prior to the fuel standard change, nonroad diesel fuel averaged about 3,400 ppm sulfur.
The combined engine and fuel rules are expected to reduce NOx and PM emissions from large
nonroad diesel engines by over 90%.19 These emission reductions are federally enforceable.
Medium- and Heavy-Duty Vehicle Fuel Consumption and GHG Standards
In September 2011, the EPA and the NHTSA promulgated joint rules to reduce GHG emissions
and improve fuel efficiency of combination tractor trucks, heavy-duty pickups and vans, and
vocational trucks beginning with model year 2014 and applying to all model years by 2018.
Depending on truck type, the on-road vehicles must achieve from a 7% to 20% reduction in CO2
emissions and fuel consumption from the 2010 base year. The decrease in fuel consumption will
result in a 7% to 20% decrease in NOx emissions.20 These emission reductions are federally
enforceable.
Nonroad Spark-Ignition Engines and Recreational Engines Standard
The nonroad spark-ignition and recreational engine standards, effective in July 2003, regulates
NOx, hydrocarbons and CO for groups of previously unregulated nonroad engines. These
engine standards apply to all new engines sold in the United States and imported after these
standards began and applies to large spark-ignition engines (forklifts and airport ground service
equipment), recreational vehicles (off-highway motorcycles and all-terrain-vehicles), and
recreational marine diesel engines. The regulation varies based upon the type of engine or
vehicle.
The large spark-ignition engines contribute to ozone formation and ambient CO and PM levels in
urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like
the large spark-ignition, recreational vehicles contribute to ozone formation and ambient CO and
PM levels. For the off-highway motorcycles and all-terrain-vehicles, the exhaust emissions
standard was phased-in. Fifty percent of model year 2006 engines had to meet the standard and
for model years 2007 and later, all engines must meet the standard. Recreational marine diesel
19 See U.S. EPA http://transportpolicy.net/index.php?title=US:_Heavy-duty:_Fuel_Consumption_and_GHG
20 Fact Sheet, Office of Transport and Air Quality, EOA-420-F-11-031, August 2011.
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engines over 37 kilowatts are used in yachts, cruisers, and other types of pleasure craft.
Recreational marine engines contribute to ozone formation and PM levels, especially in marinas.
Depending on the size of the engine, the standard began phasing-in in 2006.
When the nonroad spark-ignition and recreational engine standards are fully implemented in
2020, an overall 72% reduction in hydrocarbons, 80% reduction in NOx, and 56% reduction in
CO emissions are expected. These controls will help reduce ambient concentrations of ozone,
CO, and fine PM.21 These emission reductions are federally enforceable.
CAIR and CSAPR
On May 12, 2005, the EPA promulgated the CAIR which required reductions in emissions of
NOx and SO2 from large fossil fuel fired EGUs. CAIR also allowed non-EGU industrial boilers
to participate in the program to meet their NOx SIP Call requirements.22 The U.S. Court of
Appeals for the D.C. Circuit ruled on petitions for review of CAIR and CAIR Federal
Implementation Plans (FIPs), including their provisions establishing the CAIR NOx annual and
ozone season and SO2 trading programs. On July 11, 2008, the Court issued an opinion vacating
and remanding these rules. However, parties to the litigation requested rehearing of aspects of
the Court's decision, including the vacatur of the rules. On December 23, 2008, the Court
remanded the rules to the EPA without vacating them. The December 23, 2008 ruling left CAIR
in place until the EPA issued a new rule to replace CAIR in accordance with the July 11, 2008
decision.
The EPA issued CSAPR in July 2011 to address CAA requirements concerning interstate
transport of air pollution and to replace the previous CAIR which the D.C. Circuit remanded to
the EPA for replacement. Following the original rulemaking, CSAPR was amended by three
further rules known as the Supplemental Rule, the First Revisions Rule, and the Second
Revisions Rule. As amended, CSAPR requires 28 states to limit their state-wide emissions of
SO2 and/or NOx in order to reduce or eliminate the states’ contributions to fine PM and/or
ground-level ozone pollution in other states. The emissions limitations are defined in terms of
maximum state-wide “budgets” for emissions of annual SO2, annual NOx, and/or ozone-season
NOx by each state’s large EGUs.
As the mechanism for achieving compliance with the emissions limitations, CSAPR establishes
FIPs that require large EGUs in each affected state to participate in one or more new emissions
trading programs that supersede the existing CAIR emissions trading programs. Non-EGU
21 Final Rule: Control of Emissions from Nonroad Large Spark-Ignition Engines, and Recreational Engines (Marine
and Land-Based), 67 FR 68242.
22 In 2009, the NOx SIP Call program was replaced by CAIR.
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boilers are not able to participate in CSAPR, resulting in a group of “orphaned” industrial units
that are still subject to the NOx SIP Call. Interstate trading of CSAPR’s emission allowances is
permitted, but the rule includes “assurance provisions” designed to ensure that individual states’
emissions do not exceed the states’ respective emissions budgets. CSAPR allows states to elect
to revise their SIPs to modify or replace the FIPs while continuing to rely on the rule’s trading
programs for compliance with the emissions limitations, and establishes certain requirements and
deadlines related to those optional SIP revisions. The rule also contains provisions that sunset
CAIR compliance requirements on a schedule coordinated with the implementation of CSAPR
compliance requirements.
Certain industry and state and local government petitioners challenged CSAPR in the D.C.
Circuit and filed motions seeking a stay of the rule pending judicial review. On December 30,
2011, the Court granted a stay of the rule, ordering the EPA to continue administering CAIR on
an interim basis. In a subsequent decision on the merits, the Court vacated CSAPR based on a
subset of petitioners’ claims, but on April 29, 2014, the U.S. Supreme Court reversed that
decision and remanded the case to the D.C. Circuit for further proceedings. Throughout the
initial round of D.C. Circuit proceedings and the ensuing Supreme Court proceedings, the stay
remained in place and the EPA has continued to implement CAIR. Following the Supreme
Court decision, in order to allow CSAPR to replace CAIR in an equitable and orderly manner
while further D.C. Circuit proceedings are held to resolve petitioners’ remaining claims, the EPA
filed a motion asking the D.C. Circuit to lift the stay and to toll by three years all CSAPR
compliance deadlines that had not passed as of the date of the stay order. On October 23, 2014,
the Court granted the EPA’s motion.
CSAPR will take effect starting January 1, 2015 for SO2 and annual NOx, and May 1, 2015 for
ozone season NOx. Combined with other final state and EPA actions, the CSAPR will reduce
power plant SO2 emissions by 73% and NOx emissions by 54% from 2005 levels in the CSAPR
region.23 The emission reductions will be federally enforceable.
TVA Consent Decree
In January 2009 a federal court found that four TVA coal-fired generating stations were creating
a public nuisance in North Carolina. The judge ordered that each unit of each facility install
modern pollution controls for SO2 and NOx and meet emission limits that are consistent with the
continuous operation of such controls. The court ordered that TVA meet these limits on a
staggered schedule ending in 2013. In July 2010 an appeals court reversed the decision.
23 Interim Final Rule: Rulemaking to Amend Dates in Federal Implementation Plans Addressing Interstate Transport
of Ozone and Fine Particulate Matter, 79 FR 71663.
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In April 2011 North Carolina, TVA, and several other parties agreed to a comprehensive
settlement of a variety of air pollution allegations. The detailed settlement would (1) subject SO2
and NOx emissions at all of TVA’s coal-fired facilities to system-wide caps that decline on an
annual basis to permanent levels of 110,000 tons of SO2 in 2019 and 52,000 tons of NOx in
2018; (2) require TVA to install modern pollution controls on or shutdown the majority of its
coal-fired units; and (3) require TVA to pay North Carolina $11.2 million to fund mitigation
projects in North Carolina. The settlement is being successfully implemented, including the
provision of funds directly to North Carolina for approved projects.24 These emission reductions
are federally enforceable.
Boiler NESHAP
The NESHAP for the industrial, commercial and institutional boiler source category is applicable
to boilers and process heaters burning natural gas, coal, oil or biomass. Boilers must comply
with the NESHAP by January 31, 2016 for all states except North Carolina (see state control
measure Section 3.2.2 below for further discussion) and by May 2019 for boilers in North
Carolina. The NESHAP contains work practice standards such as annual boiler tune ups for
most boilers. There are also emissions standards for the largest emitting boilers (<1% of all
boilers) including a CO standard that is a surrogate for gas-phase hazardous air pollutants
(HAPs) and VOC. There is estimated to be a small reduction in VOC emissions due to the
NESHAP.25 These new emission reductions are federally enforceable.
RICE NESHAP
The RICE NESHAP applies to stationary engines burning natural gas and diesel fuels that
generate electricity and power equipment at industrial, agricultural, oil and gas production,
power generation and other facilities. RICE owners and operators had to comply with the
NESHAP by May 3, 2013. The NESHAP contains work practice standards such as engine
maintenance, requires ultralow-sulfur diesel fuel for some engines, and requires the use of
catalytic converters on larger engines. There is estimated to be a slight reduction in VOC
emissions due to the NESHAP.26 These emission reductions are federally enforceable.
Utility MATS and NSPS Rules
On February 16, 2012, the EPA published final rules for both the (1) MATS for new and existing
coal- and oil-fired EGUs and (2) NSPS for fossil-fuel fired electric utility, industrial-
24 http://www.ncdoj.gov/getdoc/bdf66401-8137-4be2-bd20-57e89b570c1a/TVA-signed-consent-decree.aspx.
25 See U.S. EPA http://www.epa.gov/ttn/atw/boiler/boilerpg.html.
26 See U.S. EPA http://www.epa.gov/ttn/atw/icengines/.
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commercial-institutional and small industrial-commercial-institutional steam generating units.27
The MATS reduce emissions of toxic air pollutants from EGUs larger than 25 megawatts that
burn coal or oil for the purpose of generating electricity for sale and distribution through the
national electric grid to the public. For the NSPS, the EPA revised the standards that new coal-
and oil-fired power plants must meet for NOx, SO2, and PM.
Following promulgation of the final rules, the EPA received petitions for reconsideration of
various provisions of both rules, including requests to reconsider the work practice standards
applicable during startup periods and shutdown periods that were included in the final rule. The
EPA granted reconsideration of the startup and shutdown provisions because the public was not
provided an opportunity to comment on the work practice requirements contained in the final
rule. On November 30, 2012, the EPA published a proposed rule reconsidering certain new
source standards issued in MATS and the startup and shutdown provisions in MATS and the
Utility NSPS.28 The EPA proposed certain minor changes to the startup and shutdown
provisions contained in the 2012 final rule based on information obtained in the petitions for
reconsideration. On April 24, 2013, the EPA took final action on the new source standards that
were reconsidered and also the technical corrections contained in the November 30, 2012,
proposed action. 29 The EPA did not take final action on the startup and shutdown provisions,
and, on June 25, 2013, the EPA added new information and analysis to the docket and reopened
the public comment period for the proposed revisions to the startup and shutdown provisions in
MATS and the startup and shutdown provisions related to the PM standard in the Utility NSPS.
30 The EPA took final action on the remaining topics of the reconsideration on November 19,
2014.31 The compliance date for existing sources is April 16, 2015, while the compliance date
for new sources is April 16, 2012.
On November 25, 2014, The U.S. Supreme Court accepted several challenges to the rules
brought by the utility industry and a coalition of nearly two dozen states. The court will hear
arguments in the case in the spring and is likely to rule in June 2015.32 While MATS is still
under court review, and portions of it may be overturned, the rule can be expected to result in the
reduction of both NOx and SO2 emissions in addition to the reduction in mercury and other air
toxic emissions. The emission reductions are federally enforceable.
27 77 FR 9304.
28 77 FR 71323.
29 78 FR 24073.
30 78 FR 38001.
31 79 FR 68777.
32 Wall Street Journal, Nov. 25, 2014, Supreme Court to Review EPA Rule on Power Plant Emissions,
http://www.wsj.com/articles/supreme-court-to-review-epa-rule-on-power-plant-emissions-
1416942022?mod=WSJ_newsreel_6.
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3.2.2 State Control Measures
North Carolina has adopted a number of regulations, legislation and voluntary programs to
address pollution issues across the state. These are summarized below.
Vehicle Emissions Inspection and Maintenance (I/M) Program
The 1999 Clean Air Bill expanded the vehicle emissions I/M program in North Carolina from 9
counties to 48 counties from July 1, 2002 through January 1, 2006. Vehicles are tested using the
OBDII, an improved method of testing, which ensures proper emission system operation for
vehicles and light trucks during their lifetime by monitoring emission-related components and
systems for malfunction and/or deterioration. An important aspect of OBDII is its ability to
notify the driver of malfunction and/or deterioration by illuminating the "check engine light". If
the vehicle is taken to a repair shop in a timely fashion, it can be properly repaired before any
significant and prolonged emission increase occurs. The previously used tailpipe test (i.e., idle
test) did not measure NOx emissions; it only tested for VOC and CO emissions. By utilizing the
OBDII test method, the NOx emissions as well as other pollutants from motor vehicles are
reduced. The effective dates for the counties in the North Carolina portion of the Charlotte
nonattainment area are July 1, 2002 for Cabarrus, Gaston, Mecklenburg and Union Counties;
July 1, 2003 for Iredell and Rowan Counties; and January 1, 2004 for Lincoln County.
The I/M program rule was submitted to the EPA for adoption into the SIP in August 2002 and
was federally approved in October 2002. Therefore, these emission reductions are both state and
federally enforceable.
On February 5, 2015, the EPA approved a change to North Carolina’s I/M rules triggered by a
state law which exempted plug-in vehicles and the three newest model year vehicles with less
than 70,000 miles on their odometers from emission inspection in all areas in North Carolina
where I/M is required. 33 In North Carolina’s Section 110(l) demonstration, the state showed that
the change in the compliance rate from 95% to 96% more than compensates for the NOx and
VOC emissions increase from exempting the newest model year vehicles with less than 70,000
miles. Based on recent modeling the DAQ completed using the EPA’s Motor Vehicle Emission
Simulator (MOVES2014) model, North Carolina’s current I/M program with the three newest
model year vehicle exemption is expected to yield annual I/M emission reduction benefits
ranging from 5% to 8% for NOx and 6% to 8.5% for VOC. The EPA-approved change to the
33 Approval and Promulgation of Implementation Plans; North Carolina; Inspection and Maintenance Program
Updates, 80 FR, 6455.
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I/M rules was effective March 9, 2015. The emissions reductions are state and federally
enforceable.
The 2017 session of the North Carolina General Assembly enacted Session Law 2017-10, Senate
Bill 131 (An Act to Provide Further Regulatory Relief to the Citizens of North Carolina).
Section 3.5.(a) of the Act amended North Carolina General Statue (NCGS) §143-215.107A(c) to
remove 26 of 48 counties from North Carolina’s emissions inspection and maintenance (I/M)
program. For the 22 counties remaining in the I/M program, Section 3.5.(b) of the Act also
amended NCGS §20-183.2(b) by changing the vehicle model year coverage. Specifically, the
Act requires the following changes to North Carolina’s I/M program:
• Eliminate the following 26 counties from vehicle I/M requirements: Brunswick, Burke,
Caldwell, Carteret, Catawba, Chatham, Cleveland, Craven, Edgecombe, Granville, Harnett,
Haywood, Henderson, Lenoir, Moore, Nash, Orange, Pitt, Robeson, Rutherford, Stanly,
Stokes, Surry, Wayne, Wilkes, and Wilson.
Retain the vehicle I/M program in the following 22 counties: Alamance, Buncombe,
Cabarrus, Cumberland, Davidson, Durham, Forsyth, Franklin, Gaston, Guilford, Iredell,
Johnston, Lee, Lincoln, Mecklenburg, New Hanover, Onslow, Randolph, Rockingham,
Rowan, Union, and Wake. All seven counties in the Charlotte maintenance area will
continue to operate the I/M program.
• For the 22 counties remaining in the program, change the model year vehicle coverage to: (i)
a vehicle with a model year within 20 years of the current year and older than the three most
recent model years, or (ii) a vehicle with a model year within 20 years of the current year and
has 70,000 miles or more on its odometer. Previously, the program applied to (i) a 1996 or
later model year vehicle and older than the three most recent model years, or (ii) a 1996 or
later model year vehicle and has 70,000 miles or more on its odometer.
Implementation of these changes to North Carolina’s I/M program are contingent upon EPA’s
approval of the changes. In addition, for the counties covered by this maintenance plan for the
Charlotte area, EPA must also approve the revisions to the emissions inventory forecast, safety
margins, and motor vehicle emissions budgets (MVEBs) for the three local planning
organizations before implementing the changes to the vehicle model year coverage of the I/M
program for the area.
Clean Smokestacks Act
In June 2002, the North Carolina General Assembly enacted the North Carolina Clean
Smokestacks Act, which required coal-fired power plants in North Carolina to reduce annual
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NOx emissions by 77% by 2009.34 These power plants were also required to reduce annual SO2
emissions by 49% by 2009 and 74% by 2013. The utilities have reduced NOx emissions by 83%
and SO2 emissions by 89% relative to 1998 emissions levels.
With the requirement to meet annual emissions caps and disallowing the purchase of NOx credits
to meet the caps, the Clean Smokestacks Act reduces NOx emissions beyond the requirements of
the NOx SIP Call Rule. The CSA emissions caps were submitted to the EPA for adoption into
the SIP in August 2009 and were approved in September 2011. These regulations are both state
and federally enforceable.
Boiler NESHAP
Because of delays associated with the EPA’s promulgation of the boiler NESHAP, North
Carolina adopted and implemented equivalent emission limitations by permit under Section
112(j) of the CAA.35 These limitations apply to owners and operators of industrial, commercial
and institutional boiler boilers and process heaters burning natural gas, coal, oil or biomass
beginning in 2013. This rule reduced uncertainty for owners and operators of affected emission
units while the EPA resolved legal challenges to the federal rule, reduced emissions from
affected units three years earlier than the federal rule, and provided the time needed for owners
and operators to transition to the federal rule requirements beginning in May 2019.36 Although
the rule establishes limits for reducing HAPs form boilers and process heaters, VOC emissions
will also be controlled. In the Charlotte area, natural gas fired boilers are the only types of
emission units affected by this rule. For natural gas fired boilers, VOC emissions are estimated
to be reduced by 4%. The emission limits associated with this rule are state and federally
enforceable.
Transportation Conformity MOAs
Transportation conformity MOAs establish criteria and procedures related to interagency
consultation, conflict resolution, public participation and enforceability of certain transportation
related control measures and mitigation measures in the State of North Carolina and its SIP.
Transportation conformity is required under section 176(c) of the CAA for nonattainment and
maintenance areas to ensure that federally supported highway projects, transit projects, and other
activities are consistent with (conform to) the purpose of the SIP, which is to eliminate or reduce
the severity and number of violations of the NAAQS and to achieve expeditiously the attainment
34 Air Quality/Electric Utilities Bill (SB 1078), http://daq.state.nc.us/news/leg/.
35 15A NCAC 02D .1109 - 112(j) Case-by-Case Maximum Achievable Control Technology.
36 See U.S. EPA http://www.epa.gov/ttn/atw/boiler/boilerpg.html.
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of such standards. In compliance with Section 176(c) of the CAA, the DAQ chose, through
rulemaking as referenced in 15A North Carolina Administrative Code (NCAC) 02D.2005, to
develop Conformity MOAs to ensure that interagency consultation procedures for transportation
conformity are followed.37 The Conformity MOAs were submitted to the EPA on July 12, 2013.
The USEPA, through direct final rule action, approved a revision to the North Carolina SIP with
the effective date of February 24, 2014.38
3.3 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE
This section provides a summary of state and local programs that have been implemented in the
Charlotte area to maintain compliance with the NAAQS. Although these are important programs
that help to ensure compliance with the NAAQS, they have not been relied upon as federally
enforceable measures.
3.3.1 State Programs Supporting Maintenance
Air Awareness Program
The DAQ has found that the most effective outreach programs are performed by locally-based
personnel who can work closely with members of the local community. The DAQ has
contracted with MCAQ to manage the Charlotte area North Carolina Air Awareness (NCAA)
program since its inception in 1997. Charlotte area NCAA has conducted educational outreach
with the general public, built strong working relationships with regional interest groups, and
developed communication resources for business coalition members. Coalition activities are
designed to communicate air quality information, including the forecast, and promote voluntary
emissions reduction programs. The business coalition includes partnerships with private
businesses and civic organizations. These efforts are important for maintaining compliance with
the NAAQS. Under MCAQ’s management, Charlotte area NCAA has established itself as a
leader in advocating for voluntary pollution reduction efforts throughout the state’s only ozone
nonattainment region.
Grant Program
Since 1995, the DAQ has offered multiple forms of grant funding to help cover the costs
associated with emission reduction projects. These projects include diesel engine replacements,
DOC retrofits, marine diesel repowers, replacing gasoline vehicles with electric vehicles and
many more. One source of funding is the North Carolina Mobile Source Emissions Reduction
Grants funded by gasoline tax receipts. The Mobile Source Emissions Reduction Grant program
37 http://www.ncair.org/rules/rules/D2005.pdf.
38 78 FR 73266-78272.
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has awarded grants to a number of businesses, cities, counties and school districts that have
ranged from the installation of DOCs or Diesel Particulate Filters (DPFs) on their diesel
equipment to non-diesel emission reduction projects like purchase of electric vehicles. The DAQ
has also received federal funds from the DERA and the American Recovery and Reinvestment
Act (ARRA) to fund diesel emission reducing projects. The DERA and ARRA funds that the
DAQ has received have been used to retrofit, repower or replace existing diesel engines from on-
road and nonroad mobile source vehicles/equipment. Even though these emission reductions are
voluntary and not enforceable, they are still considered permanent reductions.
Open Burning Rule
The North Carolina open burning rule prohibits the burning of man-made materials statewide.
The rule also prohibits open burning of yard waste and land clearing debris on forecasted code
orange or higher "air quality action days" for those counties for which the DAQ or local air
programs forecast ozone or fine PM.39 The open burning rule reduces PM, SO2, CO, NOx, and
VOC emissions. This rule is state enforceable.
Idle Reduction Regulation
The North Carolina Environmental Management Commission adopted the Heavy-Duty Vehicle
Idling Restrictions rule to reduce unnecessary idling of heavy-duty trucks on July 9, 2009 and the
rule became effective on July 10, 2010. This rule generally prevents any person who operates a
heavy-duty vehicle to cause, let, permit, suffer or allow idling for a period of time in excess of 5
consecutive minutes in any 60 minute period. This rule is state enforceable.
3.3.2 Local Programs Supporting Maintenance
Mobile Source Emissions Reduction Grants
In the Charlotte area, between 2011 and 2013, with funding from a settlement, a nonroad
equipment repower was funded. This project resulted in significant fuel savings and reductions
in NOx and PM2.5 emissions.
GRADE Program
In 2007, MCAQ initiated an air pollution control program called GRADE designed to reduce
NOx emissions in the Charlotte nonattainment area. Funded by federal, state and local county
grant money, GRADE provides businesses and organizations financial incentives to replace or
repower heavy-duty non-road equipment with newer, cleaner, less polluting engines.
GRADE has funded cost effective emission reduction projects operating in multiple segments of
39 15A NCAC 02Q.1900 – Open Burning.
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the economy including construction, landfills, timber logging operations, open pit mining, freight
transportation, and commercial aviation. As of July 31, 2014, GRADE projects have reduced
over 350 tons of NOx region-wide.
Open Burning Prohibitions
Mecklenburg County prohibits open burning of any kind year round except under extenuating
circumstances with an approved burn permit. This prohibition is more stringent than the state’s
open burning rule and therefore enhances this control measure’s overall benefit to the region.
The open burning rule reduces emissions of NOx, VOC, CO, PM10 and PM2.5. These emission
reductions are enforced at the local level.
3.4 EMISSIONS INVENTORIES AND MAINTENANCE DEMONSTRATION
3.4.1 Theory of Approach
There are two basic approaches used to demonstrate continued maintenance. The first is the
comparison of a projected emissions inventory with a baseline emissions inventory. The second
approach involves complex analysis using gridded photochemical modeling. The approach used
by the DAQ is the comparison of emissions inventories for the years 2014 and 2026.
For the maintenance demonstration, the base year of 2014 was chosen since it is a year that falls
within the attaining design value period of 2012-2014. The maintenance demonstration is made
by comparing the 2014 baseline summer day emissions inventory to the 2026 projected summer
day emissions inventory. The baseline summer day emissions inventory represents an emission
level for a period when the ambient air quality standard was not violated, 2012-2014. If the
projected emissions remain at or below the baseline emissions, continued maintenance is
demonstrated and it then follows, if the projected emissions remain at or below the baseline
emissions, then the ambient air quality standard should not be violated in the future. In addition
to comparing the final year of the plan, all of the interim years are compared to the 2014 baseline
to demonstrate that these years are also expected to show continued maintenance of the 2008
8-hour ozone standard.
The emissions inventories are comprised of four major types of sources: point, area, on-road
mobile and nonroad mobile. The projected summer day emission inventories have been
estimated using projected rates of growth in population, traffic, economic activity and other
parameters. Naturally occurring, or biogenic, emissions are not included in the emissions
inventory comparison, as these emissions are outside the state’s span of control.
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On April 17, 2015, the SCDHEC submitted to EPA a SIP package request to redesignate the
York County portion of the Charlotte nonattainment area to attainment. On December 11, 2015,
EPA approved the SCDHEC's request and the redesignation to attainment became effective on
January 11, 2016 (80 FR 76865).
3.4.2 Emission Inventories
The base year and future year emissions include the emissions associated with all emission
sources in Mecklenburg County and the portion of the other six counties that is included in the
maintenance area. For point sources, the location coordinates for each facility were mapped
using Geographic Information System (GIS) software to identify the facilities located within the
maintenance area of each county. For the on-road mobile sector, emissions were modeled based
on vehicle activity within the maintenance area of each county. For the nonroad mobile and area
source sectors, total county emissions were multiplied by the population percentages for the
townships within the maintenance area to calculate the emissions for the maintenance area for
each county. Table 3.1 shows the population percentages that were used to determine emissions
contributions for the maintenance area of each partial county (except for Mecklenburg County).
The population percentages were obtained from transportation demand modeling (TDM) that the
Charlotte Department of Transportation completed to develop vehicle miles traveled (VMT) and
vehicle speed data used as inputs to the on-road model for the base year and each of the future
year inventories.
Table 3.1 Population Percentages Used to Allocate Partial County Emissions
County
Population Percentage
2014 2015 2018 2022 2026
Cabarrus 99.4 99.4 99.5 99.5 99.5
Gaston 92.2 92.4 92.5 92.7 92.7
Iredell 44.2 44.5 45.3 46.1 47.7
Lincoln 83.3 83.3 83.6 83.8 85.5
Rowan 93.9 93.9 93.9 94.0 93.9
Union 87.6 87.5 87.5 87.6 90.6
In this SIP revision, the 2014 base year and 2015 emissions presented in the original April 16,
2015, maintenance plan for the Charlotte area were not changed.40 However, the 2018, 2022,
and 2026 emissions forecast for all sectors was revised to (1) account for anticipated future
increases in on-road mobile source NOx and VOC emissions associated with changing the
40 Redesignation Demonstration And Maintenance Plan and Clean Air Act Section 110(l) Non-Interference
Demonstration to Support the Gasoline Reid Vapor Pressure (RVP) Standard Relaxation in Gaston and
Mecklenburg Counties for The Charlotte-Gastonia-Salisbury, North Carolina 2008 8-Hour Ozone Marginal
Nonattainment Area, Appendix B Emission Inventory Documentation, Prepared by North Carolina DEQ/DAQ,
April 16, 2015.
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vehicle model year coverage of North Carolina’s I/M program in accordance with Section 3.5.(b)
of Session Law 2017-10; and (2) incorporate the most recent emissions forecast data available
for the nonroad, point, and area source sectors.
The DAQ prepared a 2018-year inventory for all sectors for the CAA Section 110(l)
noninterference demonstration based on more recent data than were available when the original
maintenance SIP was prepared for the Charlotte area.41 Therefore, the DAQ revised 2018-year
emissions in this revised maintenance SIP to be consistent with the emissions presented in the
CAA Section 110(l) noninterference demonstration. The DAQ also revised the emissions for
2022 and 2026 in this maintenance SIP. Table 3.2 identifies the references/data sources for the
2014 base year emissions inventory and revised 2015, 2018, 2022, and 2026 emissions forecast
prepared for each sector.
Table 3.2 References/Data Sources for the Base Year Emissions Inventory and Revised
Emissions Forecast
Sector
Inventory
Year References / Data Sources
All Sectors 2014, 2015 Original Maintenance Plan.40
On-road,
nonroad (2026 only)
2018, 2022,
2026
MOVES modeling – See Appendix A and Appendix B of this
Revised Maintenance Plan.
Point EGU 2018, 2022,
2026
Emissions forecast provided by Duke Energy dated April 2017
Point non-EGU
(including aircraft and
rail yards), EGU NOx,
nonroad, and area
2018 CAA Section 110(l) Noninterference Demonstration for
Changing Vehicle Model Year Coverage of I/M program.41
Point non-EGU
(including aircraft and
rail yards), EGU
VOC, area, and
nonroad (2022 only)
2022, 2026 Applied 2022/2018 and 2026/2018 county-level ratio of
emissions in the Original Maintenance Plan to the revised
2018 emissions in the CAA Section 110(l) Noninterference
Demonstration to update the 2022 and 2026 emissions in this
Revised Maintenance Plan.
2022 𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟=2018 𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 𝑥𝑥2022 𝑜𝑜𝑟𝑟𝑟𝑟𝑜𝑜𝑟𝑟𝑜𝑜𝑜𝑜𝑜𝑜2018 𝑜𝑜𝑟𝑟𝑟𝑟𝑜𝑜𝑟𝑟𝑜𝑜𝑜𝑜𝑜𝑜
2026 𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟=2018 𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 𝑥𝑥2026 𝑜𝑜𝑟𝑟𝑟𝑟𝑜𝑜𝑟𝑟𝑜𝑜𝑜𝑜𝑜𝑜2018 𝑜𝑜𝑟𝑟𝑟𝑟𝑜𝑜𝑟𝑟𝑜𝑜𝑜𝑜𝑜𝑜
41 CAA Section 110(l) Noninterference Demonstration for Changing the Vehicle Model Year Coverage for 22
Counties Subject to North Carolina’s Motor Vehicle Emissions Inspection and Maintenance (I&M) Program, prepared
by North Carolina DEQ/DAQ, Appendix B (Nonroad Sources), Appendix C (Point Sources), and Appendix D (Area
Sources), Fall 2017.
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The following provides a brief discussion on the four different man-made emission inventory
source classifications: (1) stationary point, (2) stationary area, (3) on-road mobile and (4)
nonroad mobile.
Point Sources
Point sources are those stationary sources that require an air permit to operate. In general, these
sources have a potential-to-emit more than five tons per year of a criteria air pollutant or its
precursors from a single facility. The source emissions are tabulated from data collected by
direct on-site measurements of emissions or mass balance calculations utilizing emission factors
from the EPA’s AP-42 or stack test results. There are usually several emission sources for each
facility. Emission data are collected for each point source at a facility and reported to the DAQ
through its on-line system.
Airports and rail yards are not required to have air quality permits for construction and operation
(although they could have equipment such as a boiler or generator that requires a permit). They
do have fixed and known locations and their emissions quantities can be comparable to industrial
sources so, for purposes of the EPA’s National Emissions Inventory (NEI), they are included in
the point source inventory even though they are traditionally considered nonroad sources.
Point EGU Sources
For EGUs, 2014 base year NOx emissions for July were obtained from the EPA’s CAMD
database for the G.G. Allen Steam Station in Gaston County, Lincoln County Combustion
Turbine Station in Lincoln County, and Buck Steam Station in Rowan County. Total emissions
for the month of July for each unit were divided by the number of days the unit operated in July
to calculate average July day emissions. Base year 2014 July day VOC emissions were
calculated for each unit using emissions for the month of July that Duke Energy Carolinas
reported to the DAQ. A forecast that Duke Energy Carolinas provided to the DAQ was used to
estimate NOx emissions for 2015.42 For each unit, the 2014 to 2015 projection factor for NOx
emissions was applied to VOC emissions for 2014 to estimate VOC emissions for 2015.
In April 2017, Duke Energy Carolinas provided the DAQ with a revised unit-level NOx
emissions forecast for the month of July for 2018, 2022, and 2026.43 The forecast did not
include an estimate of the number of days each unit would operate in July; therefore, for each
emission unit, July emissions for each year were divided by the number of days the unit operated
42 Duke Energy Carolinas, NOx emissions forecast provided to NC DAQ, December 2, 2014.
43 Duke Energy Carolinas, NOx emissions forecast provided to NC DAQ, April 17, 2017.
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in July 2014 to estimate the average summer July day emissions for each year. The forecast
reflects compliance with the North Carolina Clean Smokestacks Act, the MATS rule, and Phase I
of CSAPR. Energy companies are not required to report VOC emissions to CAMD; therefore,
the DAQ used 2018 emissions from the noninterference demonstration and then applied the
growth rate for NOx emissions to estimate VOC emissions for 2022 and 2026.44
Point Non-EGU Sources
For non-EGU point sources, the latest data available were the 2013 emissions data that permitted
sources submitted to the DAQ, and, for these sources, 2013 emissions were used to represent
2014 base year emission. The Charlotte maintenance area includes some small sources that
report emissions to the DAQ once every five years and, for these sources, the most recently
reported data were used and assumed to be equivalent to 2014 since the emissions from these
small sources do not vary much from year to year.45 The DAQ reviewed recent historical
emissions data (i.e., 2010 - 2013) for non-EGU Title V sources and emissions sources subject to
the emissions statements requirements. Based on this review, the DAQ decided that 2013
emissions should be used to represent 2014 emissions due to the uncertainty associated with
applying regional growth factors to forecast emissions for one year.
For non-EGU point sources, aircraft, and rail yards, the 2018 inventory is based on the Mid-
Atlantic Regional Air Management Association (MARAMA) Beta 2 air quality modeling
platform for the year 2017.46 The 2017 MARAMA Beta 2 air quality modeling platform was
projected from EPA’s 2011 base year air quality modeling platform (referred to as version 6.2eh,
or 2011v6.2eh).47 The EPA’s 2011v6.2eh modeling platform was developed from the 2011 NEI
v2.48 The two modeling platforms and the 2011 NEI v2 all have undergone extensive
stakeholder reviews and, for this reason, are considered to be the most comprehensive and
accurate inventories available at the time that the 2018 inventory was prepared.
44 At the time the EGU inventory was prepared for the noninterference demonstration, the DAQ used 2015 actual NOx
and VOC emissions data to represent 2018 emissions. Note that although NOx emissions for 2016 were available
from EPA at the time, 2016 VOC emissions that Duke Energy reported to the DAQ would not available until
November 2017. Therefore, 2015 was selected to be representative of 2018 emissions because this is the most recent
year for which both actual NOx and VOC emissions were available.
45 North Carolina permit renewal intervals for small sources changed from every five years to every eight years,
effective 2014.
46 The previous version of the 2017 modeling platform was actually prepared for the year 2018. For most sources,
2018 emissions were assumed to represent 2017 emissions in the 2017 modeling platform.
47 Technical Support Document (TSD), Preparation of Emissions Inventories for the Version 6.2, 2011 Emissions
Modeling Platform, August, 2015, https://www.epa.gov/air-emissions-modeling/2011-version-62-technical-support-
document.
48 2011 National Emissions Inventory, version 2, Technical Support Document which can be downloaded from
https://www.epa.gov/air-emissions-inventories/2011-national-emissions-inventory-nei-documentation.
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The inventory includes 20 natural gas fired boilers that, beginning in 2014, are subject to
equivalent emission limitations by permit that North Carolina established per Section 112(j) of
the CAA. Although the Section 112(j) standards only apply to hazardous air pollutants,
compliance with the standards also reduces VOC and NOx emissions. Therefore, VOC and NOx
control factors were applied to the natural gas boilers to estimate emissions for 2018.
Non-EGU point, aircraft, and rail yard emissions for 2022 and 2026 were estimated by applying
the 2022/2018 and 2026/2018 county-level ratio of emissions in the original maintenance plan to
the revised 2018-year emissions. This approach provides consistency with the projection
methods previously applied to estimate emissions for 2022 and 2026. Table 3.3 and Table 3.4
present a summary of the point source NOx and VOC emissions, respectively, on a ton per
summer day basis.
Table 3.3 Point Source NOx Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 1.72 1.80 0.85 0.91 0.96
Gaston*¥ 16.50 17.25 5.27 1.44 4.09
Iredell* 2.02 2.03 2.46 2.46 2.46
Lincoln* 0.18 0.84 3.85 2.41 0.98
Mecklenburg 8.56 8.77 9.25 10.18 11.75
Rowan* 2.80 3.16 2.86 2.95 3.11
Union* 0.59 0.62 0.30 0.32 0.33
Total 32.37 34.47 24.83 20.67 23.67
* Emissions for portion of county included in maintenance area. Totals include emissions associated with
stationary point sources, aircraft, and rail yards.
¥ For Gaston County, the fluctuation in NOx emissions from 2014 through 2026 are primarily associated
with the emissions forecast that Duke Energy Carolinas provided for the G.G. Allen power plant.
Table 3.4 Point Source VOC Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 0.99 1.03 0.74 0.75 0.80
Gaston* 1.82 1.90 1.35 1.33 1.49
Iredell* 0.68 0.68 0.80 0.80 0.80
Lincoln* 1.50 1.54 1.02 1.08 1.15
Mecklenburg 3.36 3.45 1.83 1.98 2.14
Rowan* 2.30 2.40 5.15 5.45 5.97
Union* 1.38 1.42 0.90 0.94 1.00
Total 12.03 12.42 11.78 12.33 13.34
* Emissions for portion of county included in maintenance area. Totals include emissions associated with
stationary point sources, aircraft, and rail yards.
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Area Sources
Area sources are those stationary sources whose emissions are relatively small but due to the
large number of these sources, the collective emissions could be significant (i.e., dry cleaners,
service stations, etc.). In general, area source emissions are estimated by multiplying an
emission factor by some known indicator of collective activity such as production, number of
employees, or population. These types of emissions are estimated on the county level. For 2014
and 2015, the emissions estimation methodology varied depending on the latest available data for
each source category. The reader is referred to the area source documentation for the original
maintenance plan for details.
For 2018, the area source emissions inventory is based on the MARAMA Beta 2 air quality
modeling platform for the year 2017 as previously described for non-EGU point sources.
Emissions for 2022 and 2026 were estimated by applying the 2022/2018 and 2026/2018 county-
level ratio of emissions in the original maintenance plan to the revised 2018-year emissions.
Table 3.5 and Table 3.6 present a summary of the area source NOx and VOC emissions,
respectively, on a ton per summer day basis.
Table 3.5 Area Source NOx Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 0.97 0.96 0.45 0.45 0.45
Gaston* 1.30 1.28 0.58 0.59 0.59
Iredell* 0.54 0.53 0.26 0.27 0.27
Lincoln* 0.40 0.40 0.15 0.15 0.15
Mecklenburg 6.07 6.01 5.37 5.37 5.37
Rowan* 0.87 0.86 0.40 0.40 0.40
Union* 1.25 1.24 0.50 0.50 0.50
Total 11.40 11.28 7.71 7.73 7.73
* Emissions for portion of county included in maintenance area.
Table 3.6 Area Source VOC Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 5.09 5.13 4.56 4.70 4.83
Gaston* 5.24 5.30 5.86 6.04 6.21
Iredell* 3.08 3.13 2.56 2.69 2.82
Lincoln* 2.56 2.57 1.91 1.99 2.04
Mecklenburg 20.59 20.77 22.69 23.37 23.82
Rowan* 5.23 5.28 3.67 3.78 3.89
Union* 6.09 6.12 5.56 5.73 5.84
Total 47.88 48.30 46.81 48.30 49.45
* Emissions for portion of county included in maintenance area.
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On-road Mobile Sources
For on-road mobile sources, EPA’s MOVES model was run to generate emissions for each year.
The MOVES model includes the road class VMT as an input file and can directly output the
estimated emissions. For the projected years’ inventories, the highway mobile source emissions
are calculated by running the MOVES model for the future year with the projected VMT to
generate emissions that take into consideration expected federal tailpipe standards, fleet turnover
and new fuels. In this revision, emissions for 2026 were updated to account for changes in NOx
and VOC emissions associated with a major revision to the MOVES model, MOVES3, which
was released on January 7, 2021. The 2026 emissions were modeled using MOVES3, based on
and the latest modeling assumptions and input data. On-road mobile source emissions for all
other years were unchanged from the previous approved version of the maintenance plan49. For
a detailed discussion on how the on-road mobile source emission inventory was developed, see
Appendix A. Table 3.7 and Table 3.8 present a summary of the on-road mobile source NOx and
VOC emissions, respectively, on a ton per summer day basis.
Table 3.7 On-road Mobile Source NOx Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 6.60 5.93 4.01 2.89 2.43
Gaston* 8.11 7.26 4.70 3.15 2.45
Iredell* 3.36 3.05 2.08 1.46 1.29
Lincoln* 3.00 2.75 1.87 1.28 1.06
Mecklenburg 26.99 24.20 14.62 9.93 12.08
Rowan* 6.42 5.76 3.81 2.66 1.94
Union* 5.67 5.14 3.47 2.36 2.29
Total 60.15 54.09 34.56 23.73 23.54
* Emissions for portion of county included in maintenance area.
Table 3.8 On-road Mobile Source VOC Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 4.15 3.89 3.08 2.63 1.76
Gaston* 4.61 4.29 3.15 2.42 1.68
Iredell* 1.95 1.82 1.43 1.15 0.86
Lincoln* 1.91 1.81 1.40 1.13 0.76
Mecklenburg 14.40 13.41 10.27 8.49 7.14
Rowan* 3.76 3.48 2.62 2.02 1.37
Union* 3.54 3.30 2.59 2.13 1.62
Total 34.32 32.00 24.54 19.97 15.19
49 86 FR 47387-47390
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* Emissions for portion of county included in maintenance area.
Nonroad Mobile Sources
Nonroad mobile sources, also referred to as off-road mobile sources, are equipment that can
move but do not use the roadways (i.e., lawn mowers, construction equipment, railroad
locomotives, etc.). The 2014 and 2015 emissions from this category were calculated using
EPA’s NONROAD2008a model, with the exception of the railroad locomotives. Emissions for
2018 were calculated using EPA’s MOVES2014a model.50 Railroad locomotive emissions for
2014 and 2015 were estimated by applying growth and control factors to the 2008 NEI.
Emissions for 2018 are based on the MARAMA Beta 2 air quality modeling platform for the
year 2017 as previously described for non-EGU point and area sources. Nonroad model and
railroad locomotive emissions for 2022 were estimated by applying the 2022/2018 county-level
ratio of emissions in the original maintenance plan to the revised 2018-year emissions.
For this revision, the 2026 emissions were calculated using EPA’s MOVES3 model and the
county-level MOVES3 Run Spec Files for 2026 that are provided in Appendix B. The MOVES3
model inputs that are in the Run Spec Files are for a typical 24-hour weekday in July. The fuels
used were compressed natural gas, gasoline, liquified petroleum gas, marine diesel fuel, and
nonroad diesel fuel. The sectors included were agriculture, airport support, commercial,
construction, industrial, lawn/garden, logging, oil field, pleasure craft, railroad, recreational, and
underground mining. Each sector can contain multiple SCC's. The emissions were calculated
and reported in U.S. tons per day for VOCs and NOx for each SCC in each sector and summed
for each county. The MOVES3 default database file used for calculations was
movesdb20220105.
Table 3.9 and Table 3.10 present a summary of the nonroad mobile source NOx and VOC
emissions, respectively, on a ton per summer day basis. The significant decrease in NOx (and to
a lesser extent VOC) emissions from 2015 to 2018 is most likely associated with differences
between the NONROAD2008a and MOVES2014a models.
Table 3.9 Nonroad Mobile Source NOx Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 2.20 2.04 1.47 1.19 0.77
Gaston* 1.98 1.83 1.48 1.23 0.75
Iredell* 0.94 0.88 0.61 0.49 0.40
50 After the on-road inventory was prepared and prior to preparing the nonroad inventory, EPA released MOVES2014a
which included revisions to the nonroad sector of the model. Therefore, MOVES2014a was used to prepare the
nonroad inventory rather than MOVES2014.
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County 2014 2015 2018 2022 2026
Lincoln* 0.78 0.72 0.54 0.45 0.29
Mecklenburg 15.09 13.99 9.92 8.04 5.75
Rowan* 1.65 1.53 1.21 1.00 0.57
Union* 3.62 3.36 2.36 1.91 1.28
Total 26.26 24.35 17.59 14.31 9.81
* Emissions for portion of county included in maintenance area.
Table 3.10 Nonroad Mobile Source VOC Emissions (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 1.27 1.22 1.13 1.15 1.18
Gaston* 1.29 1.25 1.17 1.15 1.05
Iredell* 0.62 0.59 0.50 0.47 0.40
Lincoln* 0.58 0.55 0.48 0.46 0.68
Mecklenburg 11.75 11.53 10.52 10.63 10.62
Rowan* 1.30 1.22 1.03 0.94 0.73
Union* 2.08 2.01 1.86 1.88 1.93
Total 18.89 18.37 16.69 16.68 16.59
* Emissions for portion of county included in maintenance area.
3.4.3 Summary of Emissions
The sum totals of the man-made emissions for the North Carolina portion of the Charlotte
maintenance area are tabulated in Table 3.11 and Table 3.12.
Table 3.11 Total Man-Made NOx Emissions for the North Carolina Portion of the
Charlotte Maintenance Area (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 11.49 10.73 6.78 5.44 4.61
Gaston* 27.89 27.62 12.03 6.41 7.87
Iredell* 6.86 6.49 5.41 4.68 4.42
Lincoln* 4.36 4.71 6.41 4.29 2.48
Mecklenburg 56.71 52.97 39.16 33.52 34.95
Rowan* 11.74 11.31 8.28 7.01 6.02
Union* 11.13 10.36 6.63 5.09 4.40
Total 130.18 124.19 84.69 66.44 64.75
* Emissions for portion of county included in maintenance area.
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Table 3.12 Total Man-Made VOC Emissions for the North Carolina Portion of the
Charlotte Maintenance Area (tons/summer day)
County 2014 2015 2018 2022 2026
Cabarrus* 11.50 11.27 9.51 9.23 8.57
Gaston* 12.96 12.74 11.53 10.94 10.42
Iredell* 6.33 6.22 5.29 5.11 4.88
Lincoln* 6.55 6.47 4.81 4.66 4.63
Mecklenburg 50.10 49.16 45.31 44.47 43.72
Rowan* 12.59 12.38 12.47 12.19 11.96
Union* 13.09 12.85 10.91 10.68 10.39
Total 113.12 111.09 99.82 97.28 94.57
* Emissions for portion of county included in maintenance area.
3.4.4 Maintenance Demonstration
As discussed above, maintenance is demonstrated when the future year’s total man-made
emissions are less than the 2014 baseline emissions. Table 3.13 summarizes the NOx and VOC
emissions for the North Carolina portion of the Charlotte maintenance area. The difference
between the base year and the final year illustrates that the continued maintenance of the 2008 8-
hour ozone NAAQS is expected. This is further supported by two modeling studies summarized
in the following section.
Table 3.13 Maintenance Demonstration for North Carolina Portion of the
Charlotte Maintenance Area
Year NOx (tons/summer day) VOC (tons/summer day)
2014 130.18 113.12
2015 124.19 111.09
2018 84.69 99.82
2022 66.44 97.28
2026 64.75 94.57
Difference from
2014 to 2026 65.43 18.55
The difference between the attainment level of emissions (2014) from all man-made sources and
the projected level of emissions (2015, 2018, 2022, and 2026) from all man-made sources in the
maintenance area is considered the “safety margin”. The safety margin for the North Carolina
portion of the maintenance area for each period is summarized in Table 3.14.
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Table 3.14 Safety Margins for North Carolina Portion of the Charlotte Maintenance Area
Year NOx (tons/summer day) VOC (tons/summer day)
2014 N/A N/A
2015 -5.99 -2.03
2018 -45.49 -13.30
2022 -63.74 -15.84
2026 -65.43 -18.55
3.4.5 National and Regional Air Quality Assessments in Future Years
The Southeastern States Air Resource Managers (SESARM) conducted a Southeastern
Modeling, Analysis and Planning (SEMAP) project to produce technical analyses to assist
member states in developing SIPs for ozone and PM2.5, and in the demonstration of reasonable
progress for the regional haze rule. Photochemical modeling predicts that ozone in the Charlotte
maintenance area will be well below 0.075 ppm in 2018. Base and future design values are
shown in Table 3.15. It should be noted that the benefits of Tier 3 engine and fuel standards
were not included in these results.
Table 3.15 Eight-hour Design Values from SEMAP Photochemical Modeling
Monitor County
2007 Base
Design Value,
ppm
2018 Future
Design Value,
ppm
Relative
Reduction
Factor1
371090004 Lincoln 0.080 0.064 0.7977
371190041 Mecklenburg 0.087 0.070 0.8149
371191005 Mecklenburg 0.079 0.065 0.8224
371191009 Mecklenburg 0.091 0.072 0.7927
371590021 Rowan 0.086 0.067 0.781
371590022 Rowan 0.087 0.068 0.7888
371790003 Union 0.079 0.062 0.7869
Source: Southeastern States Air Resource Managers (SESARM); Southeastern Modeling, Analysis and
Planning (SEMAP) study, http://semap.ce.gatech.edu/sites/default/files/files/projections/base2018b-O3-
DVFs-DDVFs-for-4configs.xls.
1 The Relative Reduction Factor is the ratio of the future modeled ozone concentration divided by the
base modeled ozone concentration. The future design value is computed by multiplying the Relative
Reduction Factor and the base design value.
The EPA used photochemical modeling to assess the impacts of the federal Tier 3 rule. Ozone
design values in 2018 within the Charlotte maintenance area are predicted to be below 0.075
ppm in the reference case, and even lower when Tier 3 controls are included. The downward
trend in ozone continues out to 2030. Table 3.16 shows EPA’s Tier 3 ozone modeling results.
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Table 3.16 Eight-hour Design Values Scenarios from EPA Tier 3 Photochemical Modeling
County
2007
Baseline
Design
Value, ppm
2018
Reference
Design
Value, ppm
2018 Tier 3
Control
Design
Value, ppm
2030
Reference
Design
Value, ppm
2030 Tier 3
Control
Design
Value, ppm
Lincoln 0.080 0.064 0.063 0.060 0.058
Mecklenburg 0.091 0.073 0.072 0.069 0.067
Rowan 0.087 0.069 0.068 0.065 0.063
Union 0.079 0.062 0.061 0.058 0.056
Source: US EPA http://www.epa.gov/otaq/documents/tier3/454r14002.pdf.
3.5 CONTINGENCY PLAN
3.5.1 Overview
The two main elements of the North Carolina contingency plan are tracking and triggering
mechanisms to determine when contingency control measures are needed and a process of
developing and adopting appropriate control measures. There will be three potential triggers for
the contingency plan. The primary trigger of the contingency plan will be a violation of the 2008
8-hour ozone NAAQS at any of the Charlotte area monitors. The secondary trigger will be a
monitored air quality pattern that suggests an actual 2008 8-hour ozone NAAQS violation may
be imminent. The tertiary trigger will be a monitored fourth highest exceedance of the NAAQS.
Upon either the primary or secondary triggers being activated, the DAQ, working in consultation
with the SCDHEC and the MCAQ local program, will commence analyses to determine what
additional measures, if any, will be necessary to attain or maintain the 2008 8-hour ozone
standard. If activation of either the primary or secondary triggers occurs, this plan provides a
regulatory adoption process for revising emission control strategies. Activation of the tertiary
trigger will result in an analysis to understand the cause of the exceedance and to identify
voluntary measures if needed.
In addition, there will be a tracking mechanism that requires a comparison of the actual
emissions inventory submitted under the Air Emission Reporting Rule (AERR) to the projected
inventory, and to the attainment year inventory contained in this maintenance plan. The AERR
reporting years coincide with the base year (2014) and final year (2026) for this maintenance
demonstration. In addition, the AERR reporting years will occur at 3-year intervals, thus
enabling the comparison of actual emissions developed for the AERR to the projected emissions
for the interim years presented in this maintenance demonstration.
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3.5.2 Contingency Plan Triggers
The primary trigger of the contingency plan will be a violation of the 2008 8-hour ozone
standard, or when the three-year average of the 4th highest values is equal to or greater than 0.076
ppm at a monitor in the Charlotte nonattainment area. The trigger date will be 60 days from the
date that the state observes a 4th highest value that, when averaged with the two previous ozone
seasons’ fourth highest values, would result in a three-year average equal to or greater than 0.076
ppm.
The secondary trigger will apply where no actual violation of the 2008 8-hour ozone standard
has occurred, but where the state finds monitored ozone levels indicating that an actual ozone
NAAQS violation may be imminent. A pattern will be deemed to exist when there are two
consecutive ozone seasons in which the 4th highest values are 0.076 ppm or greater at a single
monitor within the Charlotte nonattainment area. The trigger date will be 60 days from the date
that the state observes a 4th highest value of 0.076 ppm or greater at a monitor for which the
previous season had a 4th highest value of 0.076 ppm or greater.
Similarly, the tertiary trigger will not be an actual violation of the 2008 8-hour ozone standard.
This trigger will be a first alert as to a potential air quality problem on the horizon. The trigger
will be activated when a monitor in the Charlotte nonattainment area has a 4th highest value of
0.076 ppm or greater, starting the first year after the maintenance plan has been approved. The
trigger date will be 60 days from the date that the state observes a 4th highest value of 0.076 ppm
or greater at any monitor.
3.5.3 Action Resulting From Trigger Activation
Once the primary or secondary trigger is activated, the Planning Section of the DAQ, in
consultation with the SCDHEC and MCAQ, shall commence analyses including trajectory
analyses of high ozone days, and emissions inventory assessment to determine those emission
control measures that will be required for attaining or maintaining the 2008 8-hour ozone
standard. By May 1 of the year following the ozone season in which the primary or secondary
trigger has been activated, North Carolina will complete sufficient analyses to begin adoption of
necessary rules for ensuring attainment and maintenance of the 2008 8-hour ozone NAAQS.
The rules would become state effective by the following January 1, unless legislative review is
required.
The measures that will be considered for adoption upon a trigger of the contingency plan
include: NOx Reasonably Available Control Technology on stationary sources with a potential
to emit less than 100 tons per year in the North Carolina portion of the Charlotte nonattainment
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area, diesel I/M program, implementation of diesel retrofit programs, including incentives for
performing retrofits, and additional controls in upwind areas.
The DAQ commits to implement within 24 months of a primary or secondary trigger, or as
expeditiously as practicable, at least one of the control measures listed above or other
contingency measures that may be determined to be more appropriate based on the analyses
performed.
Once the tertiary trigger is activated, the Planning Section of the DAQ, in consultation with the
SCDHEC and MCAQ, shall commence analyses including meteorological evaluation, trajectory
analyses of high ozone days, and emissions inventory assessment to understand why a 4th highest
exceedance of the standard has occurred. Once the analyses are completed, the DAQ will work
with SCDHEC, MCAQ and the local air awareness program to develop an outreach plan
identifying any additional voluntary measures that can be implemented. If the 4th highest
exceedance occurs early in the season, the DAQ will work with entities identified in the outreach
plan to determine if the measures can be implemented during the current season, otherwise, DAQ
will work with SCDHEC, MCAQ and the local air awareness coordinator to implement the plan
for the following ozone season.
3.5.4 Tracking Program for Ongoing Maintenance
In addition to the measures listed above, emissions inventory comparisons will be carried out.
The large stationary sources are required to submit an emissions inventory annually to the DAQ
or MCAQ. The DAQ will commit to review these emissions inventories to determine if an
unexpected growth in NOx emissions in the Charlotte area may endanger the maintenance of the
2008 8-hour ozone standard. Additionally, as new VMT data are provided by the North Carolina
Department of Transportation (NCDOT), the DAQ commits to review these data and determine
if any unexpected growth in VMT may endanger the maintenance of the 2008 8-hour ozone
standard.
Additionally, under the AERR the DAQ is required to develop a comprehensive, annual,
statewide emissions inventory every three years and is due 12 to 18 months after the completion
of the inventory year. The AERR inventory years match the base year and final year of the
inventory for the maintenance plan, and are within one or two years of the interim inventory
years of the maintenance plan. Therefore, the DAQ commits to compare the AERR inventories
as they are developed with the maintenance plan to determine if additional steps are necessary
for continued maintenance of the 2008 8-hour ozone standard in this area.
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4.0 MOTOR VEHICLE EMISSIONS BUDGET FOR CONFORMITY
4.1 TRANSPORTATION CONFORMITY
For the Charlotte-Gastonia-Salisbury, North Carolina 2008 8-Hour Ozone Marginal
Nonattainment Area, the purpose of transportation conformity is to ensure that federal
transportation actions occurring in the area do not interfere with the area maintaining compliance
with the 2008 8-hour ozone standard. This means that the level of emissions estimated by the
NCDOT or the MPOs for the Transportation Improvement Program (TIP) and Metropolitan
Transportation Plan (MTP) must not exceed the MVEBs as defined in this maintenance plan.
The DAQ held three conference calls with the Charlotte Regional Transportation Planning
Organization (CRTPO) - Rocky River Rural Planning Organization (RRRPO), Gaston-
Cleveland-Lincoln Metropolitan Planning Organization (GCLMPO), and Cabarrus-Rowan
Metropolitan Planning Organization (CRMPO) to determine what years to set MVEBs for the
Charlotte maintenance plan. According to Section 93.118 of the transportation conformity rule,
a maintenance plan must establish MVEBs for the last year of the maintenance plan (in this case,
2026). The consensus formed during the interagency consultation process was that another
MVEB should be set for the Charlotte maintenance plan base year of 2014.
4.2 SAFETY MARGIN
As stated in Section 3.3.4, a safety margin is the difference between the attainment level of
emissions from all source categories (i.e., point, area, on-road and nonroad) and the projected
level of emissions from all source categories. The safety margins for the North Carolina portion
of the Charlotte area are listed in Table 3.14. The state may choose to allocate some of the safety
margin to the MVEB, for transportation conformity purposes, so long as the total level of
emissions from all source categories remains below the attainment level of emissions.
The DAQ has decided to allocate a portion of the safety margin for 2026 to the MVEB to allow
for unanticipated growth in VMT, changes and uncertainty in vehicle mix assumptions, and
uncertainty associated with mobile modeling that will influence the future year emission
estimations. The DAQ has developed and implemented a five-step approach for determining a
factor to use to calculate the amount of safety margin to apply to the MVEB for 2026 (see the
following Section 4.3 and Appendix A). The resulting percent increase to the MVEBs for the
North Carolina counties in the Charlotte area are listed in the Table 4.1. Note that because the
initial MVEB year of 2014 is also the base year for the maintenance plan inventory, there is no
safety margin and, therefore, no adjustments were made to the MVEB for 2014.
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Table 4.1 Percent Increase to Mobile Vehicle Emissions Budget
County 2026
Cabarrus 65%
Gaston 60%
Iredell 62%
Lincoln 62%
Mecklenburg 57%
Rowan 65%
Union 60%
4.3 MOTOR VEHICLE EMISSION BUDGETS
Although the emissions up to this point have been expressed in terms of tons/summer day, for
conformity purposes the MVEBs are expressed in kilograms/day (kg/summer day). Note that,
for this reason, kg/summer day was selected as the specified unit for all MOVES model outputs.
MOVES output emissions values were rounded to the nearest kg/summer day, and were divided
by 907.1847 to convert them to units of tons/summer day. The resulting values in tons/summer
day were rounded to two decimal places.
Table 4.2 shows the counties with their highway mobile NOx and VOC emissions, respectively,
expressed in tons/summer day and the corresponding kg/summer day values for 2014 and 2026.
Table 4.2 Highway Mobile Source NOx and VOC Summer Day Emissions in 2014 and
2026 for North Carolina Portion of the Charlotte Maintenance Area
County 2014 NOx 2014 VOC 2026 NOx 2026 VOC
tons/day kg/day tons/day kg/day tons/day kg/day tons/day kg/day
Cabarrus* 6.60 5,989 4.15 3,765 2.43 2,208 1.76 1,600
Gaston*† 8.11 7,357 4.61 4,179 2.45 2,224 1.68 1,524
Iredell* 3.36 3,045 1.95 1,768 1.29 1,171 0.86 782
Lincoln* 3.00 2,723 1.91 1,737 1.06 963 0.76 688
Mecklenburg† 26.99 24,488 14.40 13,060 12.08 10,957 7.14 6,476
Rowan* 6.42 5,825 3.76 3,408 1.94 1,757 1.37 1,246
Union* 5.67 5,146 3.54 3,210 2.29 2,074 1.62 1,471
Total 60.15 54,572 34.32 31,127 23.54 21,354 15.19 13,787
* Emissions for portion of county included in maintenance area.
† The 2014 base year NOx and VOC emissions for Gaston and Mecklenburg counties have been revised
slightly to correct a transcription error in recording the values in this table in the original maintenance
plan.
As part of the consultation process on developing MVEBs, the DAQ coordinated three
interagency conference calls with local and state transportation partners and the EPA’s Region
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IV staff to establish the framework and process for developing MVEBs. Based on these
conference calls, the participants in the consultation process unanimously agreed to the
following:
Emissions Inventory and Forecast
• Use 2014 as the base year for the emissions inventory and include emissions estimates for
2018, 2022, and 2026 (4-year increments) from the base year.
• The Charlotte DOT runs the local transportation demand model based on inputs from the
local transportation planning organizations to generate inputs (VMT, and speeds for daily
travel periods, and human population to forecast VMT) needed to run MOVES2014 to
estimate emissions for each year.
Geographic Extent of MVEBs
• Prepare separate MVEBs based on the latest MPO jurisdictional boundaries such that
MVEBs are established for the CRMPO (Cabarrus and Rowan Counties), for the
CRTPO-RRRPO (Iredell, Mecklenburg and Union Counties), and for the GCLMPO
(Gaston and Lincoln Counties). Although Cleveland County is included in the
GCLMPO, it is not included in the Charlotte ozone maintenance area.
MVEB Years
• In addition to developing a MVEB for 2026 (required by EPA guidance), the group
agreed to develop a MVEB for the base year 2014.
Adjustment to MVEBs
• Allocate a portion of the safety margin to increase the MVEBs for each county grouping
following the process used to develop the MVEBs for the previous “Redesignation
Demonstration and Maintenance Plan for the Charlotte-Gastonia-Rock Hill, NC-SC 1997
8-Hour Ozone Nonattainment Area.” This process, which includes the following five
steps, was used to adjust the MVEBs for 2026. Because 2014 is the base year for the
emissions inventory there is no safety margin; consequently, the MVEB for 2014 was not
adjusted.
Step 1 - Percentage below the standard
• All counties get 2% of their emissions allocated to the NOx and VOC MVEBs in
2026
Step 2 - Account for unanticipated model input data changes
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• The amount of safety margin allocated to the MVEBs in 2026 was increased from
25% to 45% in 2026 for each county
Step 3 - Provide flexibility and account for rapid growth for counties that are determined
to be medium to small contributors to the on-road mobile NOx emissions inventory
Counties with <8% of total on-road mobile source NOx emissions received an
additional 5% of their emissions allocated to the MVEBs in 2026 (Iredell and
Lincoln)
Counties with 8% to 25% of total on-road mobile source NOx emissions received an
additional 3% of their emissions allocated to the MVEBs in 2026 (Cabarrus, Gaston,
Rowan and Union)
Step 4 - Account for input uncertainty in final year of the maintenance plan:
All counties get 10% additional of their emissions allocated to the MVEBs in 2026 to
account for potential changes in VMT, vehicle mix and vehicle age distribution
Cabarrus and Rowan Counties each get an additional safety margin allocation equal
to 5% of their emissions to account for projected high growth rates in the CRMPO
jurisdiction.
Step 5 - Ensure the sum of the safety margins applied to the MVEBs does not exceed
50% of the total safety margin available. For 2026, Steps 1-4 accounted for:
• 21.4% of the total NOx safety margin
• 49.7% of the total VOC safety margin
Tables 4.3 through 4.5 provide the NOx and VOC MVEBs in kg/summer day, for transportation
conformity purposes, for 2014 and 2026. Upon the EPA’s final approval for these sub-area
MVEBs, they will become the applicable MVEBs for transportation conformity.
Table 4.3 Cabarrus-Rowan Metropolitan Planning Organization (CRMPO)
MVEB in 2014 and 2026 (kg/summer day)*
2014 2026
NOx VOC NOx VOC
Base Emissions 11,814 7,173 3,965 2,846
Safety Margin Allocated to MVEB - - 2,578 1,907
Conformity MVEB 11,814 7,173 6,543 4,753
* Includes the portion of Cabarrus and Rowan Counties in the maintenance area.
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Table 4.4 Gaston-Cleveland-Lincoln Metropolitan Planning Organization (GCLMPO)
MVEB in 2014 and 2026 (kg/summer day)*
2014 2026
NOx VOC NOx VOC
Base Emissions 10,079 5,916 3,187 2,212
Safety Margin Allocated to MVEB - - 1,930 1,371
Conformity MVEB 10,079 5,916 5,117 3,583
* Includes the portion of Gaston and Lincoln Counties in the maintenance area. Although Cleveland
County is included in the MPO it is not included in the Charlotte ozone maintenance area.
Table 4.5 Charlotte Regional Transportation Planning Organization (CRTPO) -
Rocky River Rural Planning Organization (RRRPO) MVEB in 2014 and
2026 (kg/summer day)*
2014 2026
NOx VOC NOx VOC
Base Emissions 32,679 18,038 14,202 8,729
Safety Margin Allocated to MVEB - - 8,215 5,089
Conformity MVEB 32,679 18,038 22,417 13,818
* Includes all of Mecklenburg County and the portion of Iredell and Union Counties in the maintenance
area.
New Safety Margins
With this revision, an additional 6,743 kg/summer day (7.43 tons/summer day) of NOx
emissions and 2,558 kg/summer day (2.82 tons/summer day) of VOC emissions were allocated
from available safety margin emissions to the Charlotte area 2026 MVEBs. This results in total
safety margin emissions allocations to the 2026 MVEBs of 12,723 kg/summer day (14.02
tons/summer day) of NOx and 8,367 kg/summer day (9.22 tons/summer day) of VOC. The
updated safety margins for each projected year are listed in Table 4.6.
Table 4.6 New Safety Margins for the North Carolina Portion of the
Charlotte Maintenance Area (tons/summer day)
Year NOx VOC
2014 N/A* N/A
2015 -5.99 -2.03
2018 -45.49 -13.30
2022 -63.74 -15.84
2026 -51.41 -9.33
* N/A = not applicable.
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5.0 STATE IMPLEMENTATION PLAN APPROVAL
5.1 INTRODUCTION
For an area to be redesignated and have an approved maintenance plan, the SIP must include
evidence of compliance with the rules relied on to show maintenance of the standard. This
section provides the evidence of compliance with such rules for the Charlotte-Gastonia-Salisbury
2008 8-hour ozone nonattainment area.
5.2 EVIDENCE OF COMPLIANCE
Two counties in the Charlotte area (Gaston and Mecklenburg Counties) were designated as
moderate nonattainment for 1-hour ozone effective January 1992. Since a redesignation
demonstration and maintenance plan was submitted for this area prior to November 15, 1992, the
CAA requirements for moderate areas were not required with the exception of the I/M program.
An I/M program was established in the Charlotte area as prescribed by the 1990 CAA.
Therefore, North Carolina has a fully approved SIP for this area.
For the 1997 8-hour ozone standard, the DAQ submitted to the EPA for approval the Metrolina
Attainment Demonstration SIP on June 15, 2007, and a Supplement to the Attainment
Demonstration SIP on April 5, 2010. The North Carolina portion of the Metrolina nonattainment
area includes the counties of Cabarrus, Gaston, Lincoln, Mecklenburg, Rowan and Union and
Coddle Creek and Davidson Townships in Iredell County. The Reasonable Further Progress SIP
was submitted to the EPA for approval on June 15, 2007 and a Revised Reasonable Further
Progress SIP was submitted on November 30, 2009. The EPA approved the Revised Reasonable
Further Progress SIP on October 12, 2012.51 On November 2, 2011 the DAQ submitted to the
EPA a Redesignation Demonstration and Maintenance Plan for 1997 8-hour Ozone standard; and
submitted a supplement to this SIP on March 28, 2013. The EPA approved the redesignation
request and maintenance plan on December 2, 2013.52
For the 2008 8-hour ozone standard for the Charlotte nonattainment area, the DAQ submitted to
the EPA for approval the Base Year (2011) Emissions Inventory and Emissions Statements SIP
on July 7, 2014, to fulfill the requirements of Sections 182(a)(1) and 182(a)(3)(B) of the CAA.53
51 77 FR 62159-62166.
52 78 FR 72036-72040.
53 http://ncair.org/planning/metrolina/metrolina_area_sip_plans.shtml.
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Additionally, the following rules regulating emissions of VOCs and/or NOx in the Charlotte
nonattainment area counties have been approved, or have been submitted with a request to be
approved, as part of the SIP:
15A NCAC 2D .0958, Work Practices For Sources of Volatile Organic Compounds,
15A NCAC 2D .0530, Prevention of Significant Deterioration,
15A NCAC 2D .0925, Petroleum Liquid Storage in Fixed Roof Tanks,
15A NCAC 2D .0926, Bulk Gasoline Plants,
15A NCAC 2D .0927, Bulk Gasoline Terminals,
15A NCAC 2D .0928, Gasoline Service Stations Stage I,
15A NCAC 2D .0932, Gasoline Truck Tanks and Vapor Collection Systems,
15A NCAC 2D .0933 Petroleum Liquid Storage in External Floating Roof Tanks
15A NCAC 2D .1000, Motor Vehicle Emission Control Standards.
15A NCAC 2D .1200, Control and Emissions from Incinerators
15A NCAC 2D .1409(b), Stationary Internal Combustion Engines
15A NCAC 2D .1416 - .1423, NOx SIP rules
15A NCAC 2D .1600, General Conformity
15A NCAC 2D .1700, Municipal Solid Waste Landfills, and
15A NCAC 2D .1900, Open Burning
15A NCAC 2D .2000, Transportation Conformity
15A NCAC 2D .2400 Clean Air Interstate Rules
Rules 15A NCAC 2D .0925, .0926, .0927, .0928, .0932, .0933, .0948, .0949, and .0958 have
been approved as part of the SIP and are applicable across the state regardless of the size of the
source.
Section 15A NCAC 2D .1000 also regulates emissions from motor vehicles in the North
Carolina counties in and around the Charlotte nonattainment area and requires the use of the
OBDII system, which provides an indication of NOx emissions as well as other pollutants.
Section 15A NCAC 2D .1200 regulates the controls and emissions from incinerators. Part of this
rule has been submitted as part of the SIP, while .1205, .1206 and .1210 are part of the CAA
Section 111(d) plans.
Two rules are conformity related, 15A NCAC 2D .1600 and .2000. General conformity related
projects are covered under Section .1600, while transportation conformity related projects are
covered under Section .2000. Although neither of these rules requires reduction in emissions,
they do ensure that federal actions do not hinder attainment or maintenance of the NAAQS.
North Carolina has adopted an open burning rule, 15A NCAC 2D .1900 that prohibits open
burning of vegetative material during Air Quality Action Days of Code Orange or higher in
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forecasted areas of the state. Ozone forecasts are issued for the Charlotte area from May 1st
through September 30th, therefore this area is covered by this rule.
Section 15A NCAC 2D .2400 regulates nitrogen oxide emissions from electric generating units
with a nameplate capacity of 25 megawatts or more producing electricity for sale. Section 15A
NCAC 2D .2400 also covers industrial boilers that are covered under the NOx SIP rules. This
Section replaces the NOx SIP rules beginning January 1, 2009. Although North Carolina did not
rely on the emission reductions from CAIR for maintenance of the 2008 8-hour ozone standard,
these regulations will result in additional reductions in NOx emissions regionally.
Another important set of rules that control volatile organic compound emissions in these counties
is Section 15A NCAC 2D .1100, Control of Toxic Air Pollutants. These rules, however, have
not been submitted to the EPA to be approved as part of the SIP.
There are two other rules that control emissions of volatile organic compounds in these areas.
They are 15A NCAC 2D .0524, New Source Performance Standards, and 2D.1110, National
Emission Standards for Hazardous Air Pollutants. Also, rule 2D.1111, Maximum Achievable
Control Technology applies to control of emissions of volatile organic compounds. They are not
part of the SIP, but the EPA has delegated the state enforcement authority for standards that have
been adopted by the state. (The standards adopted by the state are state-enforceable regardless of
the EPA delegation.)
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6.0 STATE COMPLIANCE WITH CLEAN AIR ACT REQUIREMENTS
Section 107(d)(3)(E)(v) of the CAA requires that the provisions of Section 110 (State
Implementation Plans for the Primary and Secondary NAAQS) and Part D (Plan Requirements
for Nonattainment Areas) of the CAA be met within the area to be redesignated. This means that
North Carolina must meet all requirements, if any, that had come due as of the date of the
redesignation request.
The EPA, in its latest guidance on redesignation requirements (as contained in a memorandum
from John Calcagni, Director, Air Quality Management Division, Office of Air Quality Planning
and Standards to the EPA Regional Offices dated September 4, 1992), states that "For the
purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were
applicable prior to submittal of the complete redesignation request. When evaluating a
redesignation request, Regions should not consider whether the state has met requirements that
come due under the Act after submittal of a complete redesignation request."
Monitoring is one of the requirements of Section 110. The DAQ commits to continue operating
the current ozone monitors in the North Carolina portion of the Charlotte 2008 8-hour ozone
nonattainment area, providing sufficient funding is available for continued operation. Any
monitor shutdowns or relocations will only be made with the approval of EPA. No plans are
underway to discontinue operation, relocation or otherwise affect the integrity of the ambient
monitoring network in place. The current monitors are operated consistent with 40 CFR Part 58
and any changes will only be made if they are consistent with 40 CFR Part 58.
For the 2008 8-hour ozone standard for the Charlotte marginal nonattainment area, the DAQ
submitted to the EPA for approval the Base Year (2011) Emissions Inventory and Emissions
Statements SIP on July 7, 2014, to fulfill the requirements of Part D, Sections 182(a)(1) and
182(a)(3)(B) of the CAA.54 The DAQ believes that North Carolina has met all of the
requirements of Section 110 and Part D.
54 http://ncair.org/planning/metrolina/metrolina_area_sip_plans.shtml.
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7.0 SUMMARY AND CONCLUSION RELATED TO THIS REVISION TO
THE MAINTENANCE PLAN
This revised maintenance plan demonstrates that the projected emissions inventories for 2026,
the final year of the maintenance plan and 10 years beyond the redesignation year, as well as the
interim years, are all less than the base year emissions inventory. Therefore, maintenance of the
2008 8-hour ozone NAAQS has been demonstrated.
This maintenance plan has been prepared to meet the requirements of the 1990 CAA
Amendments.