Request for Redesignation of the Portland, Maine 8-Hour Ozone
Nonattainment Area

Table of Contents

1.0		Introduction

1.1		Initial Designation of the Portland Nonattainment Area

1.2		Description of the Portland Nonattainment Area

1.3		Status of Air Quality

2.0		Attainment of the Standard

2.1		Ozone Monitoring Network (sites) and Data

2.2 	Design Value

2.3 	Summary of Chemical Analysis

2.4		Summary of Meteorological Analysis

3.0	State Implementation Plan for the Portland, Maine 8-Hour Ozone
Nonattainment Area

3.1		Reasonably Available Control Technology Requirements

3.2		15 Percent Rate of Progress Requirements

3.3		Attainment Demonstration

Permanent and Enforceable Air Quality Improvements

Emissions Inventory- General

Emission Control Programs

Emission Control Programs Implemented Prior to 2002

Emission Control Programs Implemented After 2002

4.3		Regional Emission Reductions

5.0		Compliance With Part D and Section 110 of the CAAA

5.1		Enforcement of Existing Ozone State Implementation Plan

5.2		Permitting of Existing New or Modified Use Sources

5.3		Monitoring of Stationary Sources

5.4		Legal Authority and Resource Commitments

5.5		Legal Authority to Enforce Applicable Laws, Regulations and
Standards

5.6		Conflict of Interest

5.7		Provisions for Revising the Plan

5.8		Conformity

6.0		Maintenance Plan

6.1		Attainment Inventory

6.2		Maintenance Demonstration

6.3		Air Quality Monitoring Network

6.4		Verified Continued Attainment

6.5		Contingency Plan

7.0		Conclusion

Figures:

Map of the Nonattainment Areas in Maine

Map of Ozone Monitors in the Portland Nonattainment Area

One-Hour Ozone Level Trends

One-Hour Design Value Trends

Ozone Season NOx and VOC Emissions in the Eastern United States by
Category

1997-2005 OTC Average Monthly NOx Concentrations

7.  	1997-2005 Cape Elizabeth Average Monthly TNMOC Concentrations

8.  Attainment and Future Year Emissions

9.  Average Ambient and Projected 2010 and 2015 Base and CAIR Control
8-hour Ozone

     Concentrations

Appendix A.

8-Hour Ozone Data for Monitoring Sites in the Portland Nonattainment
Area

Appendix B.

Chemical Analysis From Photochemical Assessment Monitoring Stations

Appendix C.

Meteorological Analysis From Photochemical Assessment Monitoring
Stations

Appendix D.

2006 Ozone Redesignation Inventories

Appendix E.

Department Rules Incorporated in the State Implementation Plan

Appendix F

Establishment of a mobile source emissions budget

Request for Redesignation of the Portland, Maine 8-Hour Ozone
Nonattainment Area

1.0	  INTRODUCTION

This submittal supports a request from the Maine Department of
Environmental Protection (MEDEP) to the Environmental Protection Agency
(EPA) for the redesignation of the Portland, Maine 8-Hour Ozone
Nonattainment Area (Portland Nonattainment Area) to attainment of the
8-hour ozone standard.  Ozone monitoring data from 2003-2005 show these
counties are now in attainment for the 8-hour ozone standard.

Section 107 of the 1990 Clean Air Act Amendments (CAAA) establishes
specific requirements to be met in order for an area to be considered
for redesignation, including:

A determination that the area has attained the 8-hour ozone standard;

An approved State Implementation Plan (SIP) under Section 110(k) of the
CAAA;

A determination that the improvement in air quality is due to permanent
and enforceable reductions in emissions resulting from implementation of
the SIP and other federal requirements;

A fully approved maintenance plan under Section 175(A); and

A determination that all Section 110 and Part D requirements have been
met.

This document addresses each of these requirements and provides
additional information to support continued compliance with the 8-hour
ozone standard.

1.1	Initial Designation of the Portland Nonattainment Area

Under the 1990 Clean Air Act Amendments (CAAA) nine Maine counties were
designated as nonattainment of the old 1-hour National Ambient Air
Quality Standard (NAAQS) for ozone: York, Cumberland and Sagadahoc
counties (Planning Area 1); Androscoggin and Kennebec counties (Planning
Area 2); and Knox and Lincoln counties (Planning Area 3) were designated
as "moderate" nonattainment, while Waldo and Hancock counties (Planning
Area 4) were designated as "marginal" nonattainment for ozone.

On July 16, 1997, EPA issued updated final air quality standards for
ozone.  After an extensive scientific review, EPA concluded that the
1-hour ozone standard did not provide sufficient health protection
against extended periods of moderately elevated ozone.  The new 8-hour
ozone NAAQS (set at a level of 0.08 parts per million (ppm)) is based on
an 8-hour average of ozone concentrations and more directly relates to
ozone concentrations associated with health effects.

The 8-hour ozone NAAQS  was the subject of numerous legal challenges,
which delayed its implementation for several years, with EPA ultimately
issuing 8-hour ozone NAAQS designations on April 15, 2004.  Maine has
two 8-hour nonattainment areas.  The Portland Nonattainment area
consists of the 57 cities and towns comprising York, Cumberland and
Sagadahoc Counties along with Durham, Maine in Androscoggin County, and
has been designated as “marginal” nonattainment for the 8-hour ozone
standard.

The previous 1-hour ozone maintenance and nonattainment areas and the
current 8- hour ozone nonattainment areas are illustrated in Figure 1.

Figure 1

1.2	Description of the Portland Nonattainment Area

The Portland Nonattainment Area consists of 57 coastal towns and cities
in Sagadahoc County and portions of York, Cumberland, and Androscoggin
Counties, and has been designated as “marginal” nonattainment for
the 8-hour ozone standard (Figure 1).  According to the 2000 census,
these communities have a total population of 490,949.  Portland is the
largest municipality in the area, with a population of 64,249, followed
by South Portland and Brunswick at 23,324 and 21,172, respectively.

Status of Air Quality

Ozone monitoring data for the most recent three (3) years, 2003 through
2005, demonstrates that air quality in the Portland Nontattainment Area
has met the NAAQS for ozone.  This fact, accompanied by the decreases in
emission levels discussed in Section 4, justifies a redesignation to
attainment for the nonattainment area based on Section 107(d)(3)(E) of
the CAAA.

2.0  ATTAINMENT OF THE STANDARD

2.1	Ozone Monitoring Network (sites) and Data

Maine’s ozone monitoring network currently consists of 15 monitors
statewide, which operate during the ozone season (April 1 through
September 30).  Five of these monitors are located within York,
Cumberland, and Sagadahoc counties (Figure 2) in the Portland
Nonattainment Area.  The Kittery, Kennebunkport, Cape Elizabeth, and
Reid State Park monitors are located along the coast while the West
Buxton monitor is located approximately 20 miles inland.

Ozone data is used in a variety of analyses including a determination of
whether or not areas are meeting the 8-hr Ozone NAAQS.  Appendix A
includes 8-hour ozone data handling conventions and a table of the 4th
high values, design values and 2006 threshold values at Kittery,
Kennebunkport, West Buxton/Hollis, Cape Elizabeth and Reid State
Park/Phippsburg sites.  Ozone concentrations at these sites represent
ozone levels for the entire Portland 8-hour ozone nonattainment area.

Figure 3 displays the region’s 4th high values since 1981. While
yearly variations occur due to meteorological conditions, it is clear
that ozone values in this area are trending downward.   It is important
to note that all data has met all quality assurance requirements and has
been entered into the AQS database.

The threshold analysis, included in Table A-1 of Appendix A, further
demonstrates that the Portland Nonattainment Area is likely to remain
attainment once redesignated.  It has been more than 10 years since any
site in this area has exceeded the current threshold for 2006.

Figure 2

Furthermore, the NOx SIP call has reduced emissions of NOx in the region
thus enhancing the likelihood that the area would maintain attainment.

Design Value

The 8-hour ozone design value is the average of the 4th highest 8-hour
concentration in a 3 year period at a monitored location (see Appendix A
for a more technical discussion of data handling conventions and design
value calculations).   Figure 4 shows the trend of the yearly maximum
design value from the monitors in the Portland Nonattainment Area.
Eight-hour ozone design values have been declining since 1989.  Both the
2002-2004 and the 2003-2005 design values at all 5 monitors are below
the 8-hour ozone standard.

Figure 3

Summary of Chemical Analyses

Photochemical assessment monitoring stations (PAMS) monitor chemicals
associated with ozone formation, ozone and meteorological data.  The
data from sites in Maine and Massachusetts has been analyzed by MEDEP
staff meteorologists.   Background information, a description of the
analysis and graphs of the chemical data is included in Appendix B.  The
meteorological portion of the analysis is included in Appendix C.  As
part of the analysis many graphs and charts were created to visually
depict trends in these parameters.  Only the most pertinent are included
in the appendices.

The PAMS average concentrations are all trending downward for the
Portland Nonattainment Area and upwind sites.  Therefore, this data
demonstrates that the Portland Nonattainment Area is not likely to
exceed the ozone NAAQS in future years.

2.4	Summary of Meteorological Analysis

As required by EPA guidance for the redesignation process, MEDEP must
show evidence for each area that unusual weather conditions would not
have accounted for the newly acquired attainment status.

Figure 4

Meteorology is a major factor in the formation and transport of ozone
and its precursors.  High ozone concentrations in southern Maine occur
most often when low pressure systems approach from the Great Lakes or
southern Canada while high pressure is situated just off the eastern
seaboard.  When such a scenario is in place, it provides warm
temperatures, clear skies, and southwesterly winds to allow the
transport of ozone and its precursors into the Northeast.

Therefore, it is not surprising that the meteorological parameters most
closely associated with high ozone levels in the Portland Nonattainment
Area are: daily temperatures in the upper 80’s or higher, little cloud
cover, lack of precipitation and southwesterly surface winds of
approximately 10 knots.  These conditions bring ozone and its precursors
from large urban areas in the northeast to Maine.  A westerly wind at
the 850 mb level can occur simultaneously bringing additional ozone and
its precursors from the midwest.

Appendix C includes the descriptions and the visual results of the
following meteorological analyses:

Temperature versus ozone plots for several New England states.

Trajectory analyses of ozone events.

Streamline analysis of non ozone events.

Graphs of meteorological data collected from PAMS sites:

wind frequency during ozone events.

wind speed in general and during events.

Annual anomaly plots for various parameters both at the surface and
aloft.

These meteorological data analyses illustrate that exceedance days in
Maine occur when the surface wind has a southwesterly component along
with a westerly wind component at the 850 mb level.  These directions
indicate that ozone and its precursors are transported from larger
metropolitan areas into York, Cumberland, and Sagadahoc counties on
exceedance days.

While the summer of 2005 was marked by many hot sunny days in Maine, the
surface wind direction and wind speeds aloft were not as conducive to
transport ozone and its precursors to Maine.   Historically, ozone
levels have exceeded the standard even during marginally favorable
transport conditions.  This is no longer the case.  As ozone and its
precursors are reduced upwind, conditions that result in exceedances in
Maine are becoming more restrictive.

Even though temperatures during the peak of the 2005 Ozone season were
above normal, ozone levels in Maine were similar to the cooler summers
of 1996, 2000, 2003 and 2004.  This was a result of reduced ozone and
precursors available to be transported to Maine along with less
favorable transport conditions.  There has been a clear decline in the
number of ozone exceedances in Maine over the last 17 years.  Thus,
monitored attainment of the Portland Nonattainment Area is not primarily
due to unusual meteorological conditions.

In the event that meteorological conditions during future summers again
favor transport to Maine, ozone levels in the Portland Nonattainment
Area are less likely to exceed the NAAQS due to the fact that the NOx
SIP Call went into effect in 2003.  Furthermore, the upwind source
regions impacting Maine (i.e. southern New England and the New York
metropolis) have higher and more frequent ozone exceedances and are
taking additional steps to reduce contribution to their own ozone
problems.  These steps will further reduce the amount of ozone and its
precursors available for transport to Maine.

3.0  STATE IMPLEMENTATION PLAN FOR THE PORTLAND NONATTAINMENT AREA

3.1	Reasonably Available Control Technology Requirements

Under Section 182(b)(2) of the CAAA for each of Maine’s 1-hour
moderate ozone nonattainment areas, Maine was required to adopt
reasonably available control technology (RACT) rules for volatile
organic compound (VOC) sources covered by Control Technique Guidelines
(CTGs) issued before and after enactment of the 1990 CAAA  In addition,
Section 182(b)(2)(C) of the 1990 CAAA requires States to require
implementation of RACT with respect to all major sources of volatile
organic compounds (VOCs) in moderate ozone nonattainment areas or in
areas with higher than moderate nonattainment classifications.  Maine
met these requirements through the adoption of various VOC regulations
and VOC RACT determinations for each of the major VOC sources in the
moderate nonattainment areas that were not covered by a CTG.

Furthermore, section 182(f) states that, “the plan provisions required
under this subpart for major stationary sources of volatile organic
compounds shall also apply to major stationary sources of oxides of
nitrogen.”  This section of the CAAA, established the requirement for
Maine to submit a NOx RACT regulation for the Portland 1-hour ozone
nonattainment which covers major sources.

On August 5, 1994, the State of Maine formally submitted Chapter 138 as
a SIP revision.  On July 1, 1997, Maine submitted case-specific NOX RACT
determinations for Maine Energy Recovery Company in Biddeford (MERC).
On August 14, 1998, Maine submitted case-specific NOx RACT
determinations as single source SIP revisions for the following
facilities: FPL Energy’s (formerly Central Maine Power) W.F. Wyman
Station in Yarmouth; Portsmouth Naval Shipyard (PNSY) in Kittery; and
S.D. Warren Company’s (S.D. Warren) Westbrook Facility.  On October 9,
1997, Maine submitted an amendment to the case specific NOx RACT
determination for PNSY in Kittery.

15 percent Rate of Progress Requirements

Section 182(b)(1) of the 1990 CAAA requires that states identify and
adopt strategies which will reduce 1990 volatile organic compounds (VOC)
emissions by at least 15 percent and for moderate areas by enough so as
to attain NAAQS ozone standards by November 15, 1996.  The CAAA require
all moderate and more severe ozone nontattainment areas to reduce
volatile organic compound (VOC) emissions by at least 15 percent from a
1990 baseline net of growth, by November 15, 1996.   This requirement is
commonly known as the 15 Percent Rate of Progress Plan or 15% Plan.
Maine initially submitted its 15% Plan and 1990 Base Year Emissions
Inventory for Planning Area 1 (York, Cumberland and Sagadahoc Counties)
on July 19, 1995.  Maine’s 15% Plan was deemed “administratively and
technically complete” by EPA in 1995, but was never approved. On June
9, 2005, Maine submitted a revised 15% Plan illustrating that it has
satisfied its statutory obligation to reduce VOC emissions by 15 percent
net of growth, through a variety of state and federal control measures.
The Department’s 15% Plan was approved by EPA on March 24, 2006 (71 FR
14815).

 3.3  Attainment Demonstration

On April 30, 2004, the U.S. Environmental Protection Agency (EPA) issued
a final rule for implementing elements of the 8-hour National Ambient
Air Quality Standard for ozone.  This rule also provided options for
states with areas (such as the Portland 1-Hour Ozone Nonattainment Area)
having outstanding one-hour attainment demonstration requirements.  One
option, known as the 5 percent increment of progress, involves the
submission of a Reasonable Further Progress (RFP) plan that provides a
5% increment of emission reductions from the area’s 2002 emission
baseline, which must be in addition to measures already in the SIP as of
 June 15, 2004.  The Department submitted a 5 Percent Increment of
Progress Plan demonstrating that Maine has adopted control measures
providing a 5% reduction in VOC emissions from the Portland 1-Hour Ozone
Nonattainment Area by 2007 on June 9, 2005.  This plan was approved, by
EPA on March 24, 2006 (see 71 FR 14815).

4.0	  PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS

The air quality improvements in the Portland Nonattainment Area, as
verified by the lower design value, are due to the implementation of
permanent and enforceable emissions reductions of both volatile organic
compounds (VOCs) and nitrogen oxides (NOx) from a wide variety of
stationary, area and mobile sources.  Similar control programs in upwind
states have also decreased emissions during this time period.

4.1 Emissions Inventory - General

The 1990 Clean Air Act Amendments (CAAA) required a 1990 base year
inventory that includes both anthropogenic and biogenic sources of ozone
precursors; volatile organic compounds (VOC) and nitrogen oxides (NOx).
Periodic inventories are required every three years until the area is
redesignated to attainment.  The Department is using its final 2002
National Emissions Inventory as the basis for developing the 2006
redesignation inventory of point, area and mobile sources.  Emissions
were developed for future years by applying the appropriate growth
factors, as obtained from the Bureau of Labor Statistics (BLS) forecast
of economic activity (i.e. the EGAS model).

The inventory for the Portland Nonattainment Area is composed of point,
area, and mobile sources of NOx, VOC, and CO emissions, expressed as
tons per summer weekday. Emissions data are based on a number of factors
including 2005 levels of industrial activity, 2005 population (estimated
from census year 2000), and 2005 vehicle miles traveled for a typical
summer weekday, and have been prepared according to EPA guidance and
requirements. Mobile sources include both on-road vehicles, whose
emissions were estimated with EPA's model MOBILE 6.2.03 and off-road
vehicles, whose emissions were estimated with EPA's NONROAD2005.

Mobile sources continue to dominate as the major source of ozone
precursor emissions in the Portland Nonattainment Area.  On-road mobile
sources have been the greatest source of both VOC and NOx emissions for
several decades, and will continue to be the single greatest inventory
sector, despite an overall trend of decreasing emissions. Other
significant sources of VOC and NOx emissions include non-highway sources
and certain area sources (e.g. surface coating and consumer/commercial
solvent use), and this trend continues into the next 10 years. While
decreases in highway mobile source emissions are predicted, it will
clearly remain a dominant source of ozone precursors in the three
counties. Non-road emissions are also a significant source of ozone
precursors, whose importance will increase in outlying years, based upon
current growth factors.

Detailed emissions inventory information is contained in Appendix D.

4.2	Emission Control Programs

Tropospheric ozone is formed from the reaction of VOCs and NOx in the
presence of sunlight, and as a result, strategies to reduce ozone have
focused on reducing emissions of these ozone precursors.  Although ozone
concentrations in urban areas may be elevated due to concentrated local
sources of emissions, both urban and rural areas are affected by
regional transport, or the movement of ozone and its precursors by the
wind.

Controlling both VOC and NOx emissions has proven to be most effective
in reducing local ozone contributions, while NOx reductions are
typically more effective at reducing regional transport.  As a result,
ozone can be most successfully reduced through a combination of local
programs controlling both ozone precursors, and regional programs that
are focused on controlling NOx emissions.

4.2.1 Emission Control Programs Implemented Prior to 2002

The following emission control programs were implemented by the State of
Maine prior to 2002.  Citations to EPA approval of state rules are given
in Appendix E.  Unless noted otherwise, all rules are implemented
statewide. These programs represent emission reductions prior to the
federal 8-hour ozone nonattainment designation, but continue to provide
real and permanent decreases in emissions from the affected source
categories, especially for those source categories (e.g., nonroad
engines) where source turnover/replacement is an important element of
rule penetration:

Control Programs Implemented Prior to 2002

	State Control Program							Implementation Date

Fuel Volatility (RVP) Reductions to 9.0 psi				May 1, 1989

Stage I Vapor Recovery (>250,000 gal. annual			October 1, 1989

throughput)

Cutback and Emulsified Asphalt VOC Restrictions		January 1, 1994

NOx RACT												May 31, 1995

Non-CTG VOC RACT									May 31, 1995

Stage I Vapor Recovery (>10,000 gal monthly			May 31, 1995
throughput)

Solvent Degreaser Control								May 31, 1995

Surface Coating Control*									May 31, 1995

Rotogravure and Flexography Printing Control			May 31, 1995

Stage II Vapor Recovery (1,000,000 gal or 				Nov 15, 1996					greater
annual throughput)

Bulk Terminal VOC Reduction							May 31, 1996

Motor Vehicle Inspection and Maintenance in			January 1, 1999

Cumberland County

Low Volatility Fuel Program in southern Maine 			May 1, 1999

	(7.8 RVP)

High Pollution Vehicle Retirement Pilot Program		November 1, 2000

*As part of the surface coating rule, the Department has incorporated by
reference MACT standards for aerospace manufacturing and rework,
shipbuilding and repair, and wood furniture manufacturing.

	Federal Control Program							Implementation Date

Federal Motor Vehicle Control Program (FMVCP)		Prior to 1990

Federal Fuel Volatility (RVP) Reductions to 9.0 psi		1992

Tier I (Post 1990 Vehicle Standards)						February 19, 1993

Small Engine Standards									Phase I 1996

Treatment Storage and Disposal Facilities				Phased program starting
1996

Architectural and Industrial Maintenance Coatings		1999

Autobody Refinishing										1999

Onboard Vapor Recovery Systems						Phased program starting 1998

Consumer Products										1998

Diesel Truck and Bus Engines							Phase I 1990

															Phase II 1998

Non-Road Diesel Engines									Phase I 1996

															Phase II 1999-2007

Lawn and Garden equipment								Phase I 1997

Pleasure craft												1998

Aircraft													Phase I 1996

Marine vessel												1998

National Low Emission Vehicle Program				1999

4.2 Emission Control Programs Implemented After 2002

The following control programs represent real and permanent decreases in
emissions achieved after 2002.

4.2.1  Highway Mobile Source Emission Control Programs

Federal Motor Vehicle Emission Control Program (FMVCP)

	The Federal Motor Vehicle Program, enacted prior to 1990, created
significant reductions in vehicle emissions by establishing emission
standards for new motor vehicles.  These emission standards have become
increasingly stringent over the years, providing significant reductions
of both VOC and NOx.   As the vehicle fleet “turns over”, older
generation vehicles are replaced with new vehicles meeting the more
stringent emission standards.  Fleet turnover is the principal mechanism
by which more motor vehicle emission standards result in reduced
emissions.

The Tier 1 vehicle emission standards for automobiles and light-duty
trucks were phased in beginning in 1994, the national low emission
vehicle program (NLEV) began in 1999, and the Tier II vehicle emission
standards began in 2004.  These reductions are quantified in the highway
mobile model (Mobile 6.2.03) runs in Appendix D.

California Low Emission Vehicle Program

Beginning with the 2000 model year, Maine began implementing the
California Low Emission Vehicle Program (LEV), which provides
significant emission reductions above and beyond the federal Tier 1 and
NLEV programs for passenger cars and light duty trucks.  In 2004, Maine
began implementing the California Low Emission Vehicle II (LEV2)
program, which further reduces on-highway mobile source emissions from
new passenger cars, light duty trucks, medium duty vehicles, and
heavy-duty diesel vehicles.  EPA only allows the Maine DEP to take
credit for 90% of the total credit allowed for by the California Low
Emission Vehicle II (LEV2) program (see 70 FR 21959; April 28, 2005).

Quantification of these reductions is contained in the highway mobile
model (Mobile 6.2.03) runs in Appendix D.

Federal Heavy-Duty Engine and Vehicle Standards (2004/2007)

The federal heavy-duty engine and vehicle standards were phased-in
beginning in 2004 and will provide significant reductions in nitrogen
oxides (and particulates).  Beginning in 2007, more stringent standards
based on the use of high-efficiency catalytic exhaust emission control
devices (or comparable technologies) will reduce NOx emissions by 95
percent.  NOx and non-methane hydrocarbon standards will be phased in
between 2007 and 2010 for diesel engines, and gasoline engine
requirements will be phased-in between the 2008 and 2009 model years.
Quantification of these reductions is contained in the highway mobile
model (Mobile 6.2.03) runs and the non-road emission runs in Appendix D.

Low Sulfur Gasoline

Beginning in 2004, gasoline sulfur limits were phased down, with fuel
sulfur in 2006 limited to 30 parts per million (ppm).  These reduced
gasoline sulfur levels improve catalytic converter efficiency and
longevity, thereby providing greater emission reductions from on-road
gasoline powered vehicles.  These emission reductions are also contained
in the highway mobile runs in Appendix D.

On-Road (2006) and Non-Road Diesel Fuel (2010)

Federal rules require the use of ultra-low sulfur (15 parts per million)
diesel fuel beginning in 2006 for on-highway diesel fuel, and 2010 for
most non-road diesel fuel.  These fuels enable the use of aftertreatment
(post-combustion) technologies for new diesel engines, reducing both NOx
and particulate emissions.  These emission reductions are contained in
the highway mobile runs and non-road modeling runs in Appendix D.

Federal Nonroad Engine Standards

EPA has established emission standards for a number of nonroad engine
categories.  These engines operate in a wide variety of applications,
including construction equipment, marine vessels, lawn and garden
equipment, and locomotives.

Land-Based Diesel Engines

In 1994, EPA adopted the first set of emission standards (“Tier 1”)
for all new nonroad diesel engines greater than 37 kilowatts except
those used in locomotives and marine vessels.  The Tier 1 standards
reduced NOx emissions from these engines by 30 percent.  EPA has since
adopted more stringent standards for NOx, hydrocarbons (HC) and
particulate matter.  Tier 2 standards were phased in between 2001 and
2006, while Tier 3 standards will be phased in between 2006 and 2008.
The Tier 2 and Tier 3 standards will further reduce nonroad diesel
engine NOx emissions by 60 percent from Tier 1 levels.

Land-Based Spark Ignition Engines

EPA regulates three broad categories of nonroad spark-ignition engines:
small spark ignition engines, large spark-ignition engines and
recreational vehicles.  Small engines below 19 kW (25 horsepower) are
typically used in lawn and garden equipment such as lawnmowers, string
trimmers, and chainsaws.  These engines have been regulated for HC
(hydrocarbons), NOx and carbon monoxide since 1997 under a multiphase
approach.  The Phase 1 standards resulted in a 32 percent reduction in
hydrocarbon levels from these engines.  (Phase 2 standards for small
engines were phased-in between 2001 and 2007, and provide and additional
60 to 70 percent reduction in HC and NOx emissions (depending on the
application).

Large nonroad spark ignition engines (greater than 19kW) are typically
used in industrial equipment such as forklifts, airport service
equipment, generators, and welders.  The federal emission standards for
large spark-ignition engines are also phased-in, with the first
standards becoming effective in 2004, and more stringent standards
requiring a 90 percent reduction in NOx and HC emissions along with
reduced evaporative losses taking effect in 2007.

The recreational vehicle category includes off-highway motorcycles,
all-terrain vehicles, and snowmobiles that operate on gasoline.  In
2002, EPA adopted emission standards for new recreational vehicles that
will be phased-in beginning in 2006.  These standards will reduce HC
emissions from these vehicles by 67 percent.

Nonroad engine emissions were estimated through the use of EPA’s
Nonroad2005 model and are detailed in Appendix D.

The following five control programs adopted by Maine have been approved
by EPA.  Citations to EPA approval of these regulations are given in
Appendix E.

Portable Fuel Container Spillage Control

The Department adopted its Chapter 151 Portable Fuel Container Spillage
Control rule in 2003.  This rule requires all portable fuel containers
sold, or manufactured, in Maine to be equipped with an automatic
shut-off device that stops fuel flow before the fuel tank overflows and
an automatic device that closes and seals when it is removed from the
fuel tank.  In addition, portable fuel containers must be constructed of
low-permeability materials.   The emission reductions attributable to
this program are estimated in Appendix D.

Architectural and Industrial Maintenance Coatings

In 2004, the Department adopted its Chapter 151 Architectural and
Industrial Maintenance Coatings rule.  This rule regulates VOC emissions
from approximately 51 categories of architectural and industrial
maintenance coatings beginning January 1, 2006.  The VOC emission
reductions from this rule are detailed in Appendix D.

Mobile Equipment Refinishing and Repair

The Department’s Chapter 153 Mobile Equipment Refinishing and Repair
rule was adopted in 2003, and addresses VOC emissions from automobile
and mobile equipment refinishing activities.  This rule requires the use
of high-efficiency application technologies, and establishes work
practices and training requirements.  The emission reductions from this
rule are estimated in Appendix D.

Solvent Cleaning

In 2004, the Department amended its Chapter 130 Solvent Cleaners rule to
further reduce the emissions of VOCs from solvents used in solvent
cleaning operations.  The amended rule requires the use of very low
vapor pressure solvents (1 mm mercury or less) in cold cleaners.  These
emission reductions are estimated in Appendix D.

Distributed Generation

The Department’s Chapter 148 Emission From Smaller Scale Electric
Generating Resources applies to all non-mobile generators having a
capacity equal to or greater than 50 kilowatts installed on or after
January 1, 2005.  This regulation limits emissions of nitrogen oxides
(NOx), sulfur dioxide (SO2), particulate matter (PM), and carbon
monoxide (CO) from smaller-scale electric generating units, and is
expected to reduce emissions growth from these units.

Maximum Available Control Technology (MACT)

The CAAA require EPA to review and update its list of categories of
industries that emit one or more of 188 listed toxic air pollutants, or
Hazardous Air Pollutants (HAPS).  For listed categories of major
industrial sources, the law requires EPA to develop standards requiring
those industries to achieve emission reductions equivalent to putting
into place what is known as “maximum available control technology”
(MACT).  Many of the HAPS under these industrial categories of control
are also VOCs, and compliance with these new MACT standards as they are
promulgated will decrease VOC emissions from the affected industries.

4.3  Regional (Upwind) Emission Reductions

VOC Controls

As noted previously, upwind states that contribute ozone and ozone
precursors to Maine have also implemented a wide range of NOx and VOC
controls that contributed to attainment of the 8-hour ozone standard in
Maine.   In 2001, the membership of the Ozone Transport Commission (OTC)
committed to the development and implementation of model rules for a
number of VOC sources.  These rules (or the equivalent) have been
adopted in a number of states upwind of Maine, and have reduced upwind
transported emissions of both ozone and its precursors.

At the federal level, EPA has adopted a number of mobile and area source
controls targeted toward reducing VOC emissions.

NOx Controls

In September of 1994, the OTC adopted a memorandum of understanding to
achieve regional reductions of NOx in three phases, beginning with the
installation of reasonably available control technology (RACT).  Phase I
and II of the program (the “NOx Budget Program”) was modeled on the
cap and trade principle, and established a de facto 0.15 lbs/mmBtu NOx
emission rate for participating electric generating units and large
industrial boilers.  By the beginning of 2003, the 10 participating
jurisdictions had reduced their emissions more than 50 percent from 1990
baseline levels.

Meanwhile, in 1998, EPA had issued a regulation to reduce the regional
transport of ground level ozone.  This rule, the NOx SIP Call, required
22-states and the District of Columbia to reduce ozone season emission
of NOx.  Compliance with the NOx SIP call began on May 1, 2003 for the
OTC states, and on May 31, 2004 for states outside the Ozone Transport
Region.  Although the NOx SIP Call provided states with the flexibility
of designing their own programs to meet their NOx reduction
requirements, all affected states have chosen to participate in a
regional cap and trade program.  While Maine was not included in the NOx
SIP call, this rule has had a significant effect on transported NOx and
ozone, reducing upwind NOx emissions from 819,000 tons in 2003 to
593,000 tons in 2004.

Ozone Season NOx and VOC Emissions in the Eastern United States by
Category: 1997, 2002 and 2004

Figure 5

The Maine Department of Environmental Protection analyzed average
monthly NOx and Total Non-Methane Organic Compound (TNMOC)
concentrations at Photochemical Analysis Monitoring System (PAMS) sites
throughout the Ozone Transport Region during the period from 1997
through 2005.  Our analysis confirmed that state, regional and federal
emission control initiatives have resulted in both decreased emissions
and decreased ambient concentrations of NOx and during the ozone season.

Figure 6

Figure 7

5.0	  COMPLIANCE WITH PART D AND SECTION 110 OF THE 1990 CAAA

Section 107 of the CAAA requires that nonattainment areas considering
redesignation comply with Part D and section 110 of the CAAA.

5.1	Enforcement of the Existing Ozone State Implementation Plan

This SIP revision incorporates federal requirements for demonstrating
that the ozone standard can be maintained in future years in the
Portland Nonattainment Area.  All existing RACT controls required in
these counties will remain in effect after redesignation to attainment.
The Department RACT rules affect both facilities that emit or have the
potential to emit 40 tons or more per year of volatile organic compounds
(e.g., the Chapter 134 Reasonably Available Control Technology For
Facilities that Emit Volatile Organic Compounds regulation) and
facilities with much lower applicability thresholds (e.g., the Chapter
129 Surface Coating Regulations).  Appendix E provides a listing of
current SIP-approved rules for the State of Maine.

5.2	Permitting of Existing, New, or Modified VOC Sources

Stationary sources are required to (1) obtain permits for all new,
modified, and existing sources, (2) operate in compliance with
applicable laws and regulations, (3) test equipment, and (4) keep
detailed records.  Chapter 137 of the Department's Regulations, Emission
Statements, establishes requirements for the annual reporting of
pollutant emissions from stationary sources of air pollution.  In
addition, the Department has the authority to conduct a program of
periodic inspections and surveillance, to enter property at any
reasonable time for the purpose of inspection for possible violations,
to require the submission of plans from any permit applicant, and to
require the submission of reports regarding actual or potential
violations.

The Department, in compliance with Title I, Part D of the 1990 CAAA, has
adopted rules for preconstruction review of new sources and
modifications to existing sources (NSR).  Chapter 115 requires any new
source or modification acceptable for processing after November 15, 1992
will be subject to new source requirements in Title I, Part D of the
1990 CAAA and Chapter 113 and Chapter 115 of the Department's
regulations.  Chapter 140 of the Department’s regulations establishes
an operating permit program for major stationary sources of air
pollution pursuant to Title V of the 1990 CAAA.  This regulation
addresses control technology requirements, air quality impact analysis
requirements, license conditions and public participation and other
procedural requirements for license renewals as well as new sources and
modifications of existing sources.  New source review permitting applies
to new and modified major sources of NOx as well as other regulated
pollutants.

All information and data submitted in a license application is available
for public disclosure.  Any exception to this general rule is determined
by the provisions of the Right to Know Law, Title 1 M.R.S.A. Section
401.

5.3	Monitoring of Stationary Sources

The Department has legal authority to require facilities to install,
maintain, and use emission monitoring devices.  Sources are required to
make periodic submittals to the Department on the nature and quantity of
emissions.  Chapter 117, Source Surveillance, specifies which air
emission sources are required to operate continuous emission monitoring
systems (CEMS), and details the performance specifications, quality
assurance requirements and procedures for such systems, and
recordkeeping and reporting requirements.  Chapter 137, Emission
Statements, requires sources to file annual emission statements
beginning July 1, 1994, and annually every year after that by July 1.

The Department is required to make this information available for public
inspection, including any reports correlating source emission data with
the applicable emission standards and limitations.

5.4	Legal Authority and Resource Commitments

The legal authority for the Department to carry out the implementation
plan is established in 38 Maine Revised Statutes Annotated, Chapter 2.
This legislation establishes the Department of Environmental Protection,
its purpose, and responsibilities.  The Board of Environmental
Protection fulfills its purpose through rulemaking, decisions on
selected permit applications, review of the Department's licensing and
enforcement actions and recommending changes in the law to the
Legislature.

The Department will continue providing adequate funding and personnel to
maintain the provisions of this plan necessary for meeting the air
quality standards.

5.5	Legal Authority to Enforce Applicable Laws, Regulations, and
Standards

The Board's orders may be enforced by the Department or by the State of
Maine's Attorney General.  The Department, among other actions, may
resolve the violation through an administrative consent agreement, refer
the violation to the Attorney General, schedule and hold an enforcement
hearing, or with prior approval of the Attorney General, initiate a
civil action.

5.6	Conflict of Interest

Section 128 of the 1990 CAAA requires that a majority of members of any
board that approves permits or enforcement orders to represent the
public interest, not derive a significant portion of their income from
persons subject to the permits or enforcement orders and disclose any
potential conflict of interest.  Both the Board and the Department have
the authority to issue permits and are involved in enforcement actions.

Board members are appointed by the Governor and subject to review by the
joint standing committee of the Legislature having jurisdiction over
energy and natural resource matters and to confirmation by the
Legislature.  Members of the Board are chosen to represent the broadest
possible interest and experience that can be brought to the Board.

5.7	Provision for Revising the Plan

The Department will revise this maintenance plan as necessary in
response to revisions of the ozone NAAQS or to take advantage of
improved or more expeditious methods of maintaining the standard.  The
Department will also revise the maintenance plan every eight (8) years
in compliance with Section 175(A) of the 1990 CAAA, or as necessary to
comply with the EPA's finding that the maintenance plan is inadequate to
attain or maintain the NAAQS.

5.8	Conformity

In addition to a wide range of requirements for the control of VOC and
NOx emissions, the 1990 Clean Air Act Amendments (CAAA) established
specific provisions regarding the conformity of transportation actions.
Section 176(c)(4) of the CAAA requires transportation plans, programs,
and projects which are funded or approved under Title 23 U.S.C. or the
Federal Transit Act to conform with State or Federal air quality
implementation  plans.  Conformity is defined in the CAAA as conformity
to a SIP's purpose of eliminating or reducing the severity and number of
violations of the national ambient air quality standards, and achieving
expeditious attainment of these standards.  In addition, activities may
not cause or contribute to new violations of air quality standards,
exacerbate existing violations, or interfere with timely attainment or
the emission reductions needed for attainment.

On November 24 1993, EPA promulgated regulations for transportation
conformity (40 CFR Parts 51 and 93), requiring metropolitan planning
organizations (MPOs) and the U. S. Department of Transportation (US DOT)
to make conformity determinations on metropolitan transportation plans
and transportation improvement programs (TIPs) before they are adopted,
approved or accepted.  In addition, highway or transit projects which
are funded or approved by the Federal Highway Administration or the
Federal Transit Administration must also receive a conformity
determination before they can be approved or funded by US DOT or an MPO.
 The federal rule applies in all nonattainment areas, or areas with
maintenance plans for ozone, carbon monoxide, nitrogen oxides or
particulate matter.

The transportation conformity rule has been amended several times,
including on July 1, 2004, when EPA issued a final rule to implement
conformity for the 8-hour ozone NAAQS. The transportation conformity
rule as also modified on both May 6, 2005, and March 10, 2006.

The criteria for meeting a conformity determination differ according to
the pollutant for which an area has been designated nonattainment or
maintenance, and according to the approved control strategy
implementation plan revision. In addition to transportation plans and
TIPs, all regionally significant highway and transit projects must come
from either a conforming transportation plan and TIP, been included in
the regional emissions analysis of the plan and TIP supporting the plan,
or be included in a newly performed regional analysis.

Conformity determinations are made by demonstrating consistency with
adequate or EPA-approved motor vehicle emissions budgets established by
rate of progress, attainment demonstration SIPs or other control
strategy implementation plans.  Section 176(c)(2)(A) of the CAAA
specifically requires conformity demonstrations to show that emissions
from transportation plans and programs are consistent with estimates of
emissions from motor vehicles and necessary emissions reductions as
established by reasonable further progress, attainment and maintenance
demonstrations contained in the SIP.  Motor vehicle emissions budgets
are the explicit or implicit identification of the motor vehicle related
portions of the projection inventory used to demonstrate reasonable
further progress milestones, attainment or maintenance for a particular
year identified in the SIP.  The motor vehicle emissions budget
establishes a cap on emissions which cannot be exceeded by predicted
highway and transit vehicle emissions.

On June 9, 2005, the Department submitted a 5 Percent Increment of
Progress Plan to EPA that established an explicit on-road motor vehicle
emission budget pursuant to 40 CFR Section 93.118.  The 2007 motor
vehicle emissions budget established for the Portland 8-hour ozone
nonattainment area by the 5 Percent Increment of Progress Plan was
20.115 tons per summer weekday (tpswd) of VOC and 39.893 tpswd NOx,
which is the level of on-road emissions as conservatively modeled under
the “no-build” scenario within the STIP using MDOT modeling
assumptions.  The Federal Register citation for the approved MVEBs is 71
FR 14815, (March 24, 2006), effective April 24, 2006, and incorporated
into the Federal Code of Federal Regulation at 40 CFR 52.1023(f).

40 CFR Section 93.118(b)(2) provides that when a maintenance plan has
been submitted (as in this redesignation request), motor vehicle
emissions must be less than or equal to the motor vehicle emissions
budgets established for any other years for which the maintenance plan
establishes motor vehicle emissions budgets.

The Department utilized the Mobile 6.2.03 model to calculate on-road
emissions of VOC and NOx for the 57 towns in York, Cumberland, Sagadahoc
and Androscoggin County comprising the 8-hour nonattainment area (See
Appendix F).  Maine is establishing motor vehicle emissions budgets for
the last year of the Portland 8-hour ozone maintenance plan (year 2016)
at 16.659 tpswd of VOC and 32.837 tpswd of NOx.  These on-road mobile
source emissions when added to emissions from all other inventory
sources [stationary, other mobile (i.e., non-road, marine vessels
airplanes, locomotives) and area sources] result in year 2016 emissions
inventories lower than the year 2005 attainment emissions inventory.

For the Portland Nonattainment Area, conformity will continue to be
demonstrated through the current 2007 VOC and NOx emissions budgets.
Once the motor vehicle emissions budgets contained in this redesignation
request are determined adequate or approved into the SIP the new motor
vehicle emissions budgets will also be used for analysis years 2016 and
later.

6.0	  MAINTENANCE PLAN

Section 175A of the Act sets forth the elements of a maintenance plan
for areas seeking redesignation from nonattainment to attainment.  The
plan must demonstrate continued attainment of the applicable NAAQS for
ten years after the area is redesignated. Section 175A(b) of the Act
requires that eight years after formal redesignation, the state
continues to provide for maintenance of the standard for an additional
ten years. The ME DEP commits to submit to U.S. EPA a plan for future
maintenance of the standard in Portland area as required. To provide for
the possibility of future NAAQS violations, the maintenance plan must
contain contingency measures, with a schedule for implementation,
adequate to assure prompt correction of any air quality problems.  EPA
requires the following provisions to ensure maintenance of the NAAQS:

1.	An attainment emissions inventory to identify the level of emissions
in the area which is sufficient to attain the NAAQS.

2.	A state may generally demonstrate maintenance by showing that future
emissions of a pollutant or its precursors will not exceed the level of
the attainment inventory over the 10-year period following
redesignation.

3.	Once an area has been redesignated, the state must continue to
operate an appropriate air quality monitoring network in order to verify
the area's attainment status.

4.	The state must ensure that it has the legal authority to implement
and enforce all measures necessary to attain and maintain the NAAQS.
Continued attainment must be verified by the state through the tracking
of the maintenance plan.

5.	Contingency measures must be available to promptly correct any NAAQS
violation.

The Department has developed the following maintenance plan to ensure
that continued attainment will be achieved in the Portland Nonattainment
Area.

6.1	Attainment inventory

Pursuant to the CAAA, states must develop an attainment emissions
inventory to identify the level of emissions sufficient to achieve the
NAAQS.  This inventory should be consistent with EPA's most recent
guidance on emission inventories for nonattainment areas available at
the time, and should include emissions during the time period associated
with the monitoring data showing attainment of the ozone NAAQS.  Where
the state has made an adequate demonstration that air quality has
improved as a result of the SIP, the attainment inventory will generally
be the actual inventory during the time period the area attained the
standard.  The inventory must be based on "typical summer day" emissions
of volatile organic compounds (VOC) and oxides of nitrogen (NOx) during
the attainment year.

Maine has developed an emissions inventory on a whole county basis that
identifies the level of emissions sufficient to achieve the NAAQS.  The
attainment inventory consists of the actual emissions for a year during
the three-year period associated with the monitoring data showing
attainment of the ozone standard (2003-2005).  Maine has chosen to use
2005 emissions as its attainment inventory because it represents the
typical inventory for the three-year period demonstrating attainment.
The State of Maine 2005 emissions inventory is consistent with EPA
guidance, is based on "typical summer day" emissions of VOC and NOx
during 2005, and consists of a list of sources by tons of emissions
produced.  Appendix D provides a detailed accounting of the 2005
attainment inventory.

6.2	Maintenance demonstration

EPA Redesignation Guidance provides for demonstrating maintenance of the
NAAQS through the use of either an emissions inventory approach (where a
state demonstrates that future emissions of a pollutant or its
precursors will not exceed the level of the attainment inventory), or by
modeling to show that the future mix of sources and emission rates will
not cause a violation of the NAAQS.

The maintenance demonstration should be for a period of 10 years
following the redesignation, and should consider future growth,
including population and industry, be consistent with the attainment
inventory, and document data inputs and assumptions.  All elements of
the demonstration should be consistent with current EPA guidance.
Enforceability through regulations must also be demonstrated.

Any assumptions concerning emission rates must reflect permanent,
enforceable measures.  A state generally cannot take credit for
reductions unless there are regulations in place requiring those
reductions or the reductions are otherwise shown to be permanent.
Therefore, the state is expected to maintain its implemented control
strategy despite redesignation to attainment, unless such measures are
shown to be unnecessary for maintenance or are replaced with measures
that achieve equivalent reductions.  Emission reductions from source
shutdowns can be considered permanent and enforceable to the extent that
those shutdowns have been reflected in the SIP and all applicable
permits have been modified accordingly.

Maine has chosen to utilize the emissions inventory approach to
demonstrate that its future emissions of ozone precursors will not
exceed the level of the 2005 attainment inventory, and has projected
emissions to 2016, which is 11 years after attainment.  Figure 8
demonstrates that future emissions of VOC and NOx (on a whole county
basis) will not exceed the level of Maine's 2005 attainment inventory
(also on a whole county basis) for a 10-year period following
redesignation.  The projected emissions reflect the expected summertime
emissions based on enforceable emission rates and typical production
rates.

The Department's primary maintenance strategy is the California Low
Emission Vehicle Program.  In addition, point and area source emission
projections assume the use of reasonably available control technology on
all source types covered by current control technology guidelines as
well as other regulations adopt by Maine and approved by EPA into the
SIP.  Further discussion of the regulations in place to enforce emission
reductions may be found in Section 4 of this plan.

all emissions expressed in tons per summer week day

2005	2005	2009	2009	2016	2016

Category	Subcategory	VOC	NOx

	VOC	NOx	VOC	NOx

Point

4.220	10.480	4.540	11.140	5.350	12.990

Nonpoint

41.557	6.301	42.579	6.491	47.331	6.723

Mobile	Onroad	27.033	55.328	20.018	38.849	13.243	19.078

Mobile	Nonroad	20.592	12.020	17.917	10.170	15.560	6.801

Mobile	Locomotives	0.030	0.849	0.027	0.747	0.024	0.620

	Total	93.432	84.978	85.081	67.397	81.508	46.212

Attainment, Interim and Maintenance Inventories for

York, Cumberland and Sagadahoc Counties

Figure 8

Although EPA’s redesignation guidance does not require modeling for
ozone nonattainment areas seeking redesignation, extensive modeling has
been performed to determine the effect of national and regional emission
control strategies on ozone air quality in Maine and throughout the
eastern United States.  These modeling analysis have demonstrated that
the Portland Nonattainment Area is significantly impacted by transported
ozone and ozone precursors, and that regional NOx reductions will be
provide significant ozone air quality improvements in this area.

EPA Modeling Analysis for the Nonroad Land-based Diesel Engines
Standards

In 2003, EPA conducted modeling to support the rulemaking for the
Nonroad Land-based Diesel Engines Standards.  In its analysis, EPA used
the Comprehensive Air Quality Model with Extensions (CAMx) to evaluate
the impacts of the proposed emission reductions on future air quality
levels.  Base year emissions from 1996 were modeled for three ozone
episodes (June 12-24, 1995; July 5-15, 1995; and August 7-21, 1995) that
are representative of differing sets of meteorological conditions.  CAMx
was used to predict future year ozone values using relative reduction
factors under several base cases, including 1996, 2020 and 2030 emission
levels.  Results of this modeling show that under both the base case
(without new rules on nonroad land-based diesel engines) and under the
control scenario (with these new rules), ozone monitors in the Portland
Nonattainment Area would be meeting the 8-hour ozone NAAQS in both 2020
and 2030.

EPA Modeling Analysis for the CAIR Rulemaking

More recently, EPA conducted a similar modeling analysis as part of the
Clean Air Interstate Rule (CAIR) rulemaking.  In this analysis, EPA used
CAMx version 3.10 to model the 1995 ozone episode meteorology (June
12-24, 1995; July 5-15, 1995; and August 7-21, 1995) for 2010 and 2015
under several future control scenarios.  EPA’s modeling predicted
attainment of the 8-hour ozone NAAQS on a statewide basis for both the
base case (emissions reflecting the net effects of economic growth and
emissions reductions expected to result from existing and promulgated
control programs), and with future emission reductions from CAIR.

The modeled future average ambient and projected 2010 and 2015 base case
and CAIR control ozone concentrations for Maine as detailed in Appendix
E to the CAIR Technical Support Document are illustrated in Figure 10.
In each and every case, both the base case and CAIR control scenarios
predict continued attainment of the 8-hour ozone standard in the
Portland Nonattainment Area and other monitoring sites in Maine.

6.3	Air quality monitoring network

Once an area has been redesignated, the state must continue to operate
an appropriate air quality monitoring network in accordance with 40 CFR
Part 58, to verify the area's attainment status.  In cases where
measured mobile source parameters (for example, vehicle miles traveled)
have changed over time, the state may also need to perform a saturation
monitoring study to determine the need for and location of additional
permanent monitors.  Maine is committing to the continued operation and
maintenance of an acceptable air quality monitoring network for the
Portland Nonattainment Area.

County	Average Ozone

ppb

1999-2003	2010 Base Case	2010 CAIR	2015 Base Case	2015  CAIR

Cumberland	84.7	75.9	75.8	73.4	73.0

Hancock	92.0	80.7	80.5	77.2	76.8

Kennebec	77.7	68.1	68.0	65.3	64.9

Knox	83.3	73.7	73.6	70.7	70.4

Oxford	61.0	54.9	54.7	53.2	52.7

Penobscot	83.0	72.8	72.6	70.0	69.5

York	89.0	80.3	80.2	78.0	77.6

Average Ambient and Projected 2010 and 2015 Base and CAIR Control 8-hour
Ozone Concentrations

Figure  9

6.4	Verified continued attainment

Pursuant to EPA requirements, Maine must ensure that it has the legal
authority to implement and enforce all measures necessary to attain and
maintain the NAAQS.  Sections 110(a)(2)(B) and (F) of the Act, and
regulations promulgated in 40 CFR 51.110(k) suggest that one such
measure is the acquisition of air quality and source emission data to
demonstrate attainment and maintenance.  The state submittal must
indicate how the state will track the progress of the maintenance plan.
This is necessary due to the fact that the emission projections made for
the maintenance demonstration depend on assumptions of point and area
source growth.

One option for tracking the progress of the maintenance demonstration
would be to periodically update the emissions inventory.  In this case,
the maintenance plan should specify the frequency of any planned
inventory updates.  Such an update could be based, in part, on the
annual update of  EPA’s national emissions inventory (NEI) database,
and could indicate new source growth and other changes from the
attainment inventory (such as changes in vehicle miles traveled or in
traffic patterns).  As an alternative to a complete update of the
inventory, the state may choose to do a comprehensive review of the
factors that were used in developing the attainment inventory to show no
significant change.  If this review does show a significant change, the
state should then perform an update of the inventory.

The state of Maine has the legal authority to implement and enforce
specified measures necessary to attain and maintain the NAAQS.  Key
regulatory elements that the state will keep in place to maintain
attainment are as follows:

1.	Existing source regulatory program requiring controls for certain
source types for which EPA has defined reasonable available control
technology in guideline documents; and

	2.	Requirement for controls for all major sources.

In addition to maintaining key elements of its regulatory program in
place, the state will acquire ambient and source emission data to track
attainment and maintenance.

Maine will track the progress of the maintenance demonstration by
periodically updating the emissions inventory.  This tracking will be
performed annually in order to enable the state to implement contingency
measures as quickly as possible.  The update will be based, in part, on
the annual update of the NEI, and will indicate new source growth and
other changes from the attainment inventory, including changes in
vehicle miles traveled or in traffic patterns and changes in MOBILE6.2
or its successor.

The state will report the results of this tracking program to EPA every
three years.

6.5	Contingency plan

The maintenance plan must include contingency provisions, as necessary,
to promptly correct any NAAQS violation that occurs after redesignation
of an area.  It should include measures to be adopted, a schedule and
procedures for adoption and implementation, and a specific time limit
for action.  Specific triggers that would put the plan into motion must
be identified.  This plan is considered to be an enforceable part of the
SIP and should ensure that the contingency measures are adopted
explicitly once they are triggered.

As required by the EPA redesignation guidance, a contingency measure, (a
control program or set of controls), must be clearly defined and be
implemented within a reasonable time frame if there is a lapse in
attainment.

Despite the best efforts to demonstrate continued compliance with the
8-hour ozone NAAQS, the ambient ozone concentrations in this area may
exceed or violate the NAAQS in the future.  Therefore, as required by
section 175A of the Act, Maine has listed possible contingency measures
in the event of a future ozone air quality problem.  At the conclusion
of each ozone season, the Maine DEP will evaluate whether the design
value for the Portland nonattainment area is above or below the 8-hour
ozone standard.  If the design value is above the standard, the DEP will
evaluate the potential causes of this design value increase.  The DEP
will examine whether this increase is due to an increase in local
in-state emissions or an increase in upwind out-of-state emissions.  If
an increase in in-state emissions is determined to be a contributing
factor to the design value increase, Maine will evaluate the projected
in-state emissions for the Portland area for the ozone season in the
following year.  If in-state emissions are not expected to
satisfactorily decrease in the following ozone season in order to
mitigate the violation, Maine will implement one or more of the
contingency measures listed in this section, or substitute a new VOC or
NOx control measures to achieve additional in-state emissions
reductions.  The contingency measures(s) will be selected by the
Governor or the Governor’s designee within 6 months of the end of the
ozone season for which contingency measures have been determined
necessary.  Possible contingency measures include:

Adhesives

Establish VOC content limits for industrial and commercial application
of solvent-based adhesives and sealants based on California Air
Resources Board (CARB) suggested RACT controls (1998).

Asphalt Paving

Reduce the VOC content limit for cutback asphalt from 5% to 4%, and
lower current VOC content limits for emulsified asphalt by 20%.

Automobile Refinish Coatings

Adopt the VOC content limits captained in the Bay Area Air Quality
Management District (BAAQMD) regulations.

Consumer Products

Adopt and implement the July 20, 2005 California Air Resources Board
(CARB) regulations.

Rule Effectiveness Improvement

Increase enforcement of existing rules in order to increase
effectiveness.

Small Source Non-CTG VOC RACT

Reduce the major source and Chapter 134 non-CTG VOC RACT applicability
threshold from 40 to 10 tons per year of actual emissions.

7.	CONCLUSION

The Department has satisfied all applicable criteria for redesignation
of the Portland Nonattainment Area from marginal nonattainment to
attainment for the 8-hour ozone NAAQS.  The air quality monitoring data
indicate that the NAAQS for ozone has been attained and the standard
will be maintained in future years.  Precursor emissions generated in,
and transported to, the nonattainment area have decreased as
demonstrated by both emission inventories and ambient monitoring, and
should continue to decrease, ensuring that attainment of the standard
will be continue to be maintained.

This page intentionally left blankAppendix A

Monitored Data

This appendix presents the 8-hour ozone 4th high values from monitored
ozone data and calculations for all sites in the Portland Nonattainment
Area.

All data and calculations meet the criteria for data handling contained
in EPA’s December 1998 “Guideline on Data Handling Conventions for
the 8-Hour Ozone NAAQS.”  For this analysis, the most significant of
these data handling conventions are:

A valid ozone monitoring day consists of ‘at least 18 out of 24
possible 8-hour averaging periods’ unless ‘the daily maximum 8-hour
average concentration for the day is greater than 0.08 ppm.’

‘A valid year must have valid 8-hour daily maximum ozone
concentrations for at least 75% of the required monitoring days in the
ozone season’ unless the 4th high value is greater than 0.08 ppm.

For purposes of determining attainment status, ‘all three years must
average at least 90% data completeness.’  In the event that the 3-year
average of the 4th high values exceeds 0.08 ppm then years with less
than 75% data recovery are included in the calculations.

Design values are calculated by taking the average of 3 consecutive
years’ 4th high values (which meet the data handling conventions sited
above).  The year cited for the design value is the final year of the
3-year average.

Table A-1 contains data for the current Portland Nonattainment Area
since 1981.   The data includes the 4th high value for each year, the
valid design value and recovery rates both for individual years and 2006
threshold values.

Threshold values are the 4th high value needed in 2006 to cause the
design value calculation to exceed the ozone NAAQS.  Threshold values
help to determine the likelihood of a given site/area meeting (or
exceeding) the ozone NAAQS in the following ozone season.   Table A-1
clearly demonstrates that the Portland Nonattainment Area’s monitored
4th high values have not exceeded the current thresholds for 2006 since
1991 (4th high values that exceed the threshold are colored orange).
Therefore, the likelihood that the current Portland Nonattainment Area
would maintain a redesignated attainment status is great.

Table A-1: 4th high values, design values, recovery rates and threshold
analysis for each site in the Portland nonattainment area.

MONITOR	8-HR OZONE PARAMETER	1981	1982	1983	1984	1985	1986	1987	1988
1989	1990	1991	1992	1993	1994	1995

YORK COUNTY

Kittery 23-031-3002	VALID 4TH HIGH

	Kittery 23-031-3002	SEASON RECOVERY RATE
 	 	 	 	62%

Kittery 23-031-3002	VALID DESIGN VALUE
 	 	 	***

Kittery 23-031-3002	3-YR RECOVERY RATE
 	 	 	***

Kennebunkport 23-031-2002	VALID 4TH HIGH

	126	98	112	127	112	106	111	100	95	91	103

Kennebunkport 23-031-2002	SEASON RECOVERY RATE	 	 	73%	74%	88%	91%	95%
86%	86%	91%	97%	100%	91%	90%	99%

Kennebunkport 23-031-2002	VALID DESIGN VALUE	 	 	***	***	115	112	112
112	117	115	109	105	102	95	96

Kennebunkport 23-031-2002	3-YR RECOVERY RATE	 	 	***	***	79%	84%	91%
91%	89%	88%	91%	96%	96%	94%	94%

Hollis 23-031-0037	VALID 4TH HIGH

	Hollis 23-031-0037	SEASON RECOVERY RATE

Hollis 23-031-0037	VALID DESIGN VALUE

Hollis 23-031-0037	3-YR RECOVERY RATE

West Buxton 23-031-0038	VALID 4TH HIGH

	West Buxton 23-031-0038	SEASON RECOVERY RATE

West Buxton 23-031-0038	VALID DESIGN VALUE

West Buxton 23-031-0038	3-YR RECOVERY RATE

CUMBERLAND COUNTY

	Cape Elizabeth 23-005-2003	VALID 4TH HIGH	101	105	117	108	123	99	116
122	101	92	109	97	89	88	96

Cape Elizabeth 23-005-2003	SEASON RECOVERY RATE	89%	94%	98%	91%	87%	96%
98%	96%	92%	92%	97%	97%	96%	98%	99%

Cape Elizabeth 23-005-2003	VALID DESIGN VALUE	***	***	107	110	116	110
112	112	113	105	100	99	98	91	91

Cape Elizabeth 23-005-2003	3-YR RECOVERY RATE	***	***	94%	94%	92%	91%
94%	97%	95%	93%	94%	95%	97%	97%	98%

SAGADAHOC COUNTY

	Phippsburg 23-023-0003	VALID 4TH HIGH

90	99

Phippsburg 23-023-0003	SEASON RECOVERY RATE
 	 	 	59%	96%	90%

Phippsburg 23-023-0003	VALID DESIGN VALUE
 	 	***	***	92

Phippsburg 23-023-0003	3-YR RECOVERY RATE
 	 	***	***	82%

Reid State Park 23-023-0004	VALID 4TH HIGH

	Reid State Park 23-023-0004	SEASON RECOVERY RATE

Reid State Park 23-023-0004	VALID DESIGN VALUE

Reid State Park 23-023-0004	3-YR RECOVERY RATE

PORTLAND NONATTAINMENT AREA	4TH HIGH MAX	101	105	117	108	126	99	116	127
112	106	111	100	95	91	103

PORTLAND NONATTAINMENT AREA	DESIGN VALUE MAX	 	 	107	110	116	112	112
112	117	115	109	105	102	95	96

Table A-1 continued: 4th high values, design values, recovery rates and
threshold analysis for each site in the Portland nonattainment area.

MONITOR	8-HR OZONE PARAMETER	1996	1997	1998	1999	2000	2001	2002	2003
2004	2005	ACTIVE Monitors	Historical exceedance %	last 10 years
exceedance

YORK COUNTY	 	 	 	 	 	 	 	 	 	 	2006 THRESHOLD	of the 2006
Threshold	of the 2006 Threshold

Kittery 23-031-3002	VALID 4TH HIGH	79	92	89	85	70	90	94	80	80	72	103
0.00%	0%

Kittery 23-031-3002	SEASON RECOVERY RATE	96%	99%	99%	96%	93%	97%	98%	99%
95%	98%

	Kittery 23-031-3002	VALID DESIGN VALUE	***	86	86	88	81	81	84	88	84	77

	Kittery 23-031-3002	3-YR RECOVERY RATE	***	86%	98%	98%	96%	95%	96%	98%
97%	97%

	Kennebunkport 23-031-2002	VALID 4TH HIGH	84	101	86	89	73	96	101	76	76
71	108	23.81%	0%

Kennebunkport 23-031-2002	SEASON RECOVERY RATE	94%	98%	96%	98%	97%	94%
98%	99%	98%	79%

	Kennebunkport 23-031-2002	VALID DESIGN VALUE	92	96	90	92	82	86	90	91	84
74

	Kennebunkport 23-031-2002	3-YR RECOVERY RATE	95%	97%	96%	98%	97%	97%
96%	97%	98%	92%

	Hollis 23-031-0037	VALID 4TH HIGH

77	72

Hollis 23-031-0037	SEASON RECOVERY RATE	 	94%	99%

	Hollis 23-031-0037	VALID DESIGN VALUE	 	***	***

	Hollis 23-031-0037	3-YR RECOVERY RATE	 	31%	64%

	West Buxton 23-031-0038	VALID 4TH HIGH

80	66

83	69	75	76	104	0.00%	0%

West Buxton 23-031-0038	SEASON RECOVERY RATE	 	 	 	100%	97%	67%	100%
100%	100%	98%

	West Buxton 23-031-0038	VALID DESIGN VALUE	 	 	 	***	***	***	***	***
75	73

	West Buxton 23-031-0038	3-YR RECOVERY RATE	 	 	 	***	***	88%	88%	89%
100%	99%

	CUMBERLAND COUNTY

	Cape Elizabeth 23-005-2003	VALID 4TH HIGH	83	103	89	76	67	97	96	73	68
73	114	16.00%	0%

Cape Elizabeth 23-005-2003	SEASON RECOVERY RATE	99%	98%	99%	96%	99%	98%
99%	100%	97%	99%

	Cape Elizabeth 23-005-2003	VALID DESIGN VALUE	89	94	91	89	77	80	86	88
79	71

	Cape Elizabeth 23-005-2003	3-YR RECOVERY RATE	99%	99%	99%	98%	98%	98%
99%	99%	99%	99%

	SAGADAHOC COUNTY

	Phippsburg 23-023-0003	VALID 4TH HIGH	89	98	91	87	75

Phippsburg 23-023-0003	SEASON RECOVERY RATE	98%	92%	97%	93%	99%

	Phippsburg 23-023-0003	VALID DESIGN VALUE	92	95	92	92	84

	Phippsburg 23-023-0003	3-YR RECOVERY RATE	95%	93%	95%	94%	97%

	Reid State Park 23-023-0004	VALID 4TH HIGH

	96	74	69	68	118	0.00%	0%

Reid State Park 23-023-0004	SEASON RECOVERY RATE	 	 	 	 	 	 	90%
90%	100%	83%

	Reid State Park 23-023-0004	VALID DESIGN VALUE	 	 	 	 	 	 	***
***	79	70

	Reid State Park 23-023-0004	3-YR RECOVERY RATE	 	 	 	 	 	 	***
***	93%	91%

	PORTLAND NONATTAINMENT AREA	4TH HIGH MAX	89	103	91	89	75	97	101	80	80
76

	PORTLAND NONATTAINMENT AREA	DESIGN VALUE MAX	92	96	92	92	84	86	90	91	84
77

Appendix B

Chemical Analysis

Photochemical assessment monitoring station (PAMS) sites monitor
chemicals associated with ozone formation, ozone and meteorological
data.  The data from sites in Maine and Massachusetts has been analyzed
by MEDEP staff meteorologists.   Massachusetts sites were included
because they are upwind of Maine.  The meteorological portion of the
analysis is presented in Appendix C.

BACKGROUND INFORMATION:

The Clean Air Act Amendments of 1990 required EPA to promulgate
regulations for the "enhanced" monitoring of ozone and its precursors
for ozone nonattainment areas classified as serious, severe or extreme.
Both Congress and EPA recognized the need for an improved understanding
of the ozone problem, and better feedback mechanisms for evaluating the
effectiveness of ozone control strategies. In 1993, EPA published the
final rule detailing the minimum requirements for PAMS, which includes
measurements of nitrogen oxides (NOx), speciated volatile organic
compounds (VOCs), and meteorological parameters. These monitoring
regulations provide for the collection of an "enhanced" ambient air
quality database which can be used to better characterize the nature and
extent of the ozone problem, aid in tracking VOC and NOx emission
inventory reductions, assess air quality trends, make
attainment/nonattainment decisions, and evaluate photochemical
grid-model performance.

There are four different types of PAMS sites, each serving a specific
monitoring purpose: a Type 1 is upwind of the urban area and represents
background concentrations coming into the area; a Type 2 is on the
downwind fringe of the urban area and represents maximum precursor
concentrations from the area; a Type 3 is located in an area with
maximum ozone concentrations; and a Type 4 is at extreme downwind
location to represent long-range transport from the area. Therefore,
PAMS sites required for an area will not necessarily all be located
within the boundaries of the non-attainment area. Thus Maine, with no
serious, severe or extreme non-attainment areas itself, has three PAMS
sites in operation.

Figure B-1 displays the sites included within the analysis.  The number
following each site name indicates the type of site it is while the
color of the circle indicates the area it is related to.  There are no
Type 1 sites included within the analysis.

The distinguishing features that make PAMS sites truly "enhanced" ozone
monitoring stations is that they collect meteorological, ozone and its
precursors (oxides of nitrogen and VOCs) data simultaneously.  Gaining a
better understanding of how these variables interact with each other in
actual real-world instances is necessary in order to effectively address
Maine's and the nation's continuing ozone problem.

Figure B-1

ANALYSIS DESCRIPTION:

There are five sites within the geographical region of study; Kittery,
Cape Elizabeth, Cadillac Mountain, Newbury and Lynn are in
Massachusetts.  The sites are listed below along with the years of data
used in the analysis and the state agency responsible for maintaining
the site.

Top of CADILLAC MOUNTAIN, Maine

1995-2004 data downloaded from AQS

site operator - MEDEP

CAPE ELIZABETH, Maine

1993-2004 data downloaded from AQS

site operator - MEDEP

KITTERY, Maine

1995-2003 data downloaded from AQS

site operator - NHDES

some data from this site is questionable and therefore not included in
every aspect of the analysis

NEWBURY, Massachusetts

1994-2003 data downloaded from AQS

site operator - MADEP

LYNN, Massachusetts

1993-2003 data downloaded from AQS

site operator - MADEP

Analysis of the wealth of data is extensive and ongoing.  Only the most
pertinent graphs are included herein.  Listed below is a sampling of the
extent of the analysis:

PAMS Season (June 1 to August 31) Data Summary Statistics for all 5
sites

averages and maximums for all compounds

data recovery rates

% of data below minimum detect levels (MDL)

50th , 70th and 90th Percentiles

Plots

1993-2004 event averaged plots for all compounds (5-sites plotted)

1997-2003 and 1997-2002 event averaged plots for all compounds (5-sites
plotted)

Multi-year PAMS season hourly plots for all compounds (1-site plotted)

Ozone pollution roses averaged for all 1993-2004  PAMS season hours >
64ppb, >81ppb

MAP

Elevated 1-hr avg Ozone concentration (>64ppb and >81ppb) wind direction
frequencies (all data @ 5 sites) (found in Appendix C)

The compounds of greatest pertinence to ozone are oxides of nitrogen
(NOx), PAMS target compounds (PAMHC) and total non-methane organic
carbons (TNMOC).   The trends of these focus compounds are displayed in
Figures B-2 through B-4.   For the  Portland Nonattainment Area and
sites upwind these compounds are all trending downward so the area is
not likely to exceed the ozone NAAQS in the future.

Figure B-2

Figure B-3

Figure B-4

--

Appendix C

Meteorological Data Analyses

  TOC \o "1-2" \h \z \u    HYPERLINK \l "_Toc124039871"  Executive
Summary of the Meteorological Analyses:	  PAGEREF _Toc124039871 \h  43

  HYPERLINK \l "_Toc124039872"  Regional Temperature Versus Ozone Graphs
  PAGEREF _Toc124039872 \h  44

  HYPERLINK \l "_Toc124039873"  Figure C-1 Temperature vs Ozone
PAGEREF _Toc124039873 \h  44

  HYPERLINK \l "_Toc124039874"  Trajectory Analysis	  PAGEREF
_Toc124039874 \h  46

  HYPERLINK \l "_Toc124039875"  Figure C-2 Trajectory by hour	  PAGEREF
_Toc124039875 \h  47

  HYPERLINK \l "_Toc124039876"  Figure C-3 Trajectory by height
PAGEREF _Toc124039876 \h  48

  HYPERLINK \l "_Toc124039878"  Streamline Analysis	  PAGEREF
_Toc124039878 \h  49

  HYPERLINK \l "_Toc124039879"  Figure C-4 Ozone Potential	  PAGEREF
_Toc124039879 \h  50

  HYPERLINK \l "_Toc124039880"  PAMS – Meteorological Data	  PAGEREF
_Toc124039880 \h  51

  HYPERLINK \l "_Toc124039881"  Figure C-5 Wind Frequency	  PAGEREF
_Toc124039881 \h  51

  HYPERLINK \l "_Toc124039882"  Figure C-6 Wind Speed	  PAGEREF
_Toc124039882 \h  52

  HYPERLINK \l "_Toc124039883"  Anomaly Plots	  PAGEREF _Toc124039883 \h
 53

  HYPERLINK \l "_Toc124039884"  Figure C-7 SURFACE PRESSURE ANOMALIES
PAGEREF _Toc124039884 \h  55

  HYPERLINK \l "_Toc124039885"  Figure C-8 SURFACE TEMPERATURE ANOMALIES
  PAGEREF _Toc124039885 \h  56

  HYPERLINK \l "_Toc124039886"  Figure C-9 SURFACE WIND SPEED ANOMALIES
 PAGEREF _Toc124039886 \h  57

  HYPERLINK \l "_Toc124039887"  Figure C-10 SURFACE PRECIPITATION
ANOMALIES	  PAGEREF _Toc124039887 \h  58

  HYPERLINK \l "_Toc124039888"  Figure C-11 850mb WIND SPEED ANOMALIES
PAGEREF _Toc124039888 \h  59

  HYPERLINK \l "_Toc124039889"  Figure C-12 850mb HEIGHT ANOMALIES
PAGEREF _Toc124039889 \h  60

  HYPERLINK \l "_Toc124039890"  Figure C-13 850mb TEMPERATURE ANOMALIES
 PAGEREF _Toc124039890 \h  61

  HYPERLINK \l "_Toc124039891"  Figure C-13 850mb TEMPERATURE ANOMALIES
 PAGEREF _Toc124039891 \h  61

  HYPERLINK \l "_Toc124039892"  Figure C-14 JET STREAM WIND SPEED
ANOMALIES	  PAGEREF _Toc124039892 \h  62

  HYPERLINK \l "_Toc124039893"  Table C-1 Summary of Anomaly Plot Data
with Ozone exceedance data	  PAGEREF _Toc124039893 \h  63

Executive Summary of the Meteorological Analyses

Meteorology is a major factor in the formation and transport of ozone
and its precursors.  High ozone concentrations in southern Maine occur
most often when low pressure systems approach from the Great Lakes or
southern Canada while high pressure is situated just off the eastern
seaboard.  When such a scenario is in place, it provides warm
temperatures, clear skies, and southwesterly winds to allow the
transport of precursors into the Northeast.

These meteorological data analyses illustrate that exceedance days in
Maine occur when the surface wind has a southwesterly component along
with a westerly wind component at the 850 mb level.  These directions
indicate that ozone and its precursors are transported from larger
metropolitan areas into York, Cumberland, and Sagadahoc counties on
exceedance days.  These conclusions have been well-known and documented
for years.

Historically, ozone levels have exceeded the standard even during
marginally favorable transport conditions.  As ozone precursors are
reduced, through a variety of point, area and mobile source controls,
wind direction becomes a more critical factor for ozone buildup in
Maine.  Thus, Maine now requires a ‘direct hit’ of ozone and
precursors from large urban areas to cause ozone exceedances.

In the event that meteorological conditions during future summers again
favor transport to Maine, ozone levels in the Portland Nonattainment
Area are less likely to exceed the standard due to the fact that the NOx
SIP call and other emission control programs have reduced emissions of
NOx and VOC in the region.

Even though temperatures during the peak of the 2005 Ozone season were
above normal, ozone levels in Maine were similar to the cooler summers
of 1996, 2000, 2003 and 2004.  This was a result of reduced ozone and
precursors available to be transported to Maine along with less
favorable transport conditions.  There has been a clear decline in the
number of ozone exceedances in Maine over the last 17 years.  Thus,
monitored attainment of the Portland Nonattainment Area is not primarily
due to unusual meteorological conditions.

Regional Temperature Versus Ozone Graphs

Since ozone exceedances are typically associated with hot sunny summer
days, Maine Department of Environmental Protection’s Bureau of Air
Quality (MEDEP-BAQ) staff meteorologists thought it might be useful to
look at graphs of temperature versus ozone in New England.  Maximum
daily temperature data for Hartford, Connecticut; Worcester and Boston,
Massachusetts; Manchester, New Hampshire; as well as Augusta and Bangor,
Maine was downloaded from the National Weather Service’s web site for
the months of April through September for 2000 to 2005.  With the
exception of Boston, the cities chosen were major cities unaffected by
sea breezes.  Formulas were then written to count the number of days
during each year’s ozone season that the maximum daily temperature
fell into a given range.   In Figure C-1, these counts are represented
by the blue shaded bars.  Next the number of ozone exceedances days that
occurred within that state for each year is graphed using a red line.
The scale of these graphs is consistent for each state so that quick
comparisons can be made.

Figure C-1 Temperature vs Ozone

By viewing these charts together, the differences between northern and
southern New England become apparent.  The summer of 2005 was warmer
than the two preceding summers across the region and there were an
increased number of ozone exceedances recorded by every state.  However,
it is also apparent that the number of ozone exceedances was
considerably fewer for the northern New England states both compared
with the southern New England states and also with the previous high
years of 2001 and 2002.  Thus, hot sunny days are not the sole factor
for ozone exceedances in northern New England or more specifically,
Maine.  These charts also illustrate that even for southern New England
the number of exceedances was lower than the high years of 2001 and 2002
even though the number of hot days was greater.   The NOx SIP Call went
into effect in 2003 and this may have contributed to the observed
decrease in the number of ozone exceedances.

Trajectory Analysis

A trajectory is a three dimensional representation of the path an air
parcel followed based on forecast or archived meteorological data.  A
backward trajectory is the path the parcel took to reach a specific
point in time and space, while a forward trajectory is the path the
parcel followed upon leaving a specific time and place.

MEDEP-BAQ staff meteorologists conducted a trajectory analysis of ozone
exceedances from the 2000 through 2005 ozone seasons.  When an 8-hour
ozone exceedance was recorded in the Portland Nonattainment Area, the
analysis included every hour ozone levels were equal to or greater than
85 ppb.  The time of the ozone value was converted from Eastern Standard
Time (EST) to Universal Time Code (UTC) by adding 5 hours.

The National Oceanic and Atmospheric Administration (NOAA)’s Air
Resources Laboratory HYSPLIT (HYbrid Single-Particle Lagrangian
Integrated Trajectory) is a computer model used to create and map
trajectories.  The model uses gridded meteorological data.  For more
information about HYSPLIT please refer to the following document:
“Description of the HYSPLIT 4 Modeling System by Draxler and Hess.”

MEDEP-BAQ staff meteorologists used HYSPLIT to create the trajectories
included in this analysis.  The model was set to create 24-hour back
trajectories from 10 meters (m) above ground level at each site and to
include vertical velocity.  The archived ETA Data Assimilation System
(EDAS) meteorological (MET) data set was used for most trajectories
because this was the most consistently available MET data set.  EDAS
data at 80km spacing was available prior to 2004.  The trajectories
created for 2004 and 2005 events utilized the EDAS 40km MET files.
There were several days when the EDAS MET file was missing data.  When
this occurred, the Global Final Analysis (FNL) MET data set was used.

For each run, the HYSPLIT model generates both a graphical presentation
of the trajectories and a text file.  The text file contains information
about the hourly endpoints along each trajectory path including the
location in time and space.  Hundreds of endpoint text files were
subsequently loaded into an Access database, which was then mapped in
ARCMAP, a geographical mapping tool used within the MEDEP.

The maps visually display thousands of endpoints allowing the viewer to
readily identify the transport patterns which result in high levels of
ozone in Maine.  Two maps have been created for the Portland
Nonattainment Area.  Figure C-2 displays the endpoints based on time of
day: red depicts the solar peak, green depicts night-time hours and
orange and yellow are the transitions between the two.  Figure C-3
displays the endpoints based on vertical height using both color and
size to differentiate between the various heights.

Utilizing both means of displaying the endpoints resulted in a greater
understanding of the transport patterns during high ozone events than
would have been gained by either alone.  Figure C-3 shows that southwest
transport at the surface is the largest contributor to high
concentrations of ozone.  Frequently, transport from a more westerly
direction is that of sinking air which is then caught in surface flow
and transported to the monitors.  Other parcels traveled across
neighboring states before reaching the Portland Nonattainment Area.
Both figures illustrate that high concentrations of ozone are not caused
by sources within the state of Maine.  Thus, high ozone events are
predominantly due to southwest surface winds bringing ozone and its
precursors into Maine.

Figure C-2 Trajectory by hour

Figure C-3 Trajectory by height

Streamline Analysis

MEDEP-BAQ staff meteorologists utilize many different tools to analyze
ozone behavior in Maine.   Streamlines are one of these important tools.
 Streamline graphics depict the wind field at a given time and place.

Most ozone analyses focus on ozone exceedances in Maine, however, it is
equally important to study occasions when conditions were favorable for
ozone production in New England, yet Maine did not record exceedances.

A streamline analysis was performed for the 2000 through 2005 ozone
seasons, when conditions that favor ozone production were present (high
temperatures with bright sunshine).  Therefore, the criteria for
choosing which dates to analyze when Maine DID NOT record ozone
exceedances were as follows:

Days when either Augusta or Bangor, Maine recorded temperatures 85(F or
higher, and/or

Days when major cities in New England recorded temperatures of 90(F or
higher, and/or

Days when ozone exceedances occurred elsewhere in New England.

Using these criteria, 135 days were identified for the streamline
analysis.

The streamline graphics for New England were generated and downloaded
from the National Oceanic and Atmospheric Administration’s (NOAA)
Real-time Environmental Applications and Display sYstem (READY) web site
(  HYPERLINK "http://www.arl.noaa.gov/ready/ametus.html"
http://www.arl.noaa.gov/ready/ametus.html ) using archived
meteorological files.  The most detailed meteorological data available
for each date was used to generate the streamline graphics at 18z (2 PM
EDT) for each day and both temperature and streamlines were displayed.
EDAS meteorological data was used for all but one date due to lack of
data.  [EDAS data was available at 80km spacing through 2003.  Beginning
with the 2004 season, EDAS data at 40km spacing became available.]

Approximately 73% of the streamline graphics clearly demonstrated that,
while temperatures were high (as defined above) in the region and/or
ozone exceedances occurred in Southern New England, the winds were not
conducive to transport ozone and/or its precursors to Maine.  On 37 days
(the remaining 27%), the graphics displayed southwest winds over at
least some part of Maine as well as meeting at least one of the criteria
above.  These days warranted further analysis and are referred to as
‘ozone potential days’.  Of these ozone potential days, there were
few or no ozone exceedances recorded in the region approximately 60% of
the time, so there was less ozone and its precursors available to be
transported to Maine.  Another 13% of the time, either clouds or wind
shifts prevented ozone exceedances in Maine.  Conditions may have
contributed to ozone exceedances in Maine the next day 19% of the time.
Ozone potential days were categorized in the following manner:

No exceedances in the region,

Little ozone in the region – only a few sites recorded exceedances
(often in Connecticut),

Transport shutdown – incoming front shifted winds before transport
could cause exceedances in Maine,

Clouds – clouds moved into Maine during the afternoon effectively
reducing ozone concentrations,

ME exceed next day – conditions on these days were not conducive to
same day ozone exceedances in Maine, however likely contributed to
exceedances which occurred the following day, and

Other – three days defied categorization, each was a special case in
and of itself.

Ozone potential days’ percentages are displayed by category in Figure
C-4.

Figure C-4 Ozone Potential

In summary, the streamline analysis further demonstrates that high
temperatures and bright sunshine are not the sole cause of ozone
exceedances in Maine.  Ozone and its precursors must be brought into the
state, namely from the highly populated areas to the southwest of Maine.

PAMS – Meteorological Data

Photochemical assessment monitoring sites (PAMS) monitor chemicals
associated with ozone formation, ozone and meteorological data.

Wind frequency plots using the PAMS data build upon the trajectory and
streamline analyses presented previously.  In Figure C-5, the wind
direction frequency at various ozone levels is plotted using Excel then
superimposed over the site on a map for easy visual reference.  Wind
direction during high ozone events clearly demonstrates that it is
southwest winds from urban areas outside of Maine that contribute to the
exceedances.

Figure C-5 Wind Frequency

In Figure C-6, the wind speed during ozone event days is compared with
the seasonal average wind speed.  Both are graphed by hour of day.
There is one site (Cape Elizabeth) in the graph from the Portland
Nonattainment Area.  While all sites show an increase in wind speed
during the afternoon for all days, there is little difference between
ozone events and the seasonal average.  As with the previously presented
analyses this graph clearly demonstrates that it is not stagnant
conditions which cause ozone buildup in Maine, but rather wind is
required to bring ozone and its precursors into the state.

Figure C-6 Wind Speed

Anomaly Plots

Annual anomaly plots were created for June, July and August of 1988
through 2005 online at   HYPERLINK
"http://www.cdc.noaa.gov/cgi-bin/Composites/"
http://www.cdc.noaa.gov/cgi-bin/Composites/   (NOAA CIRES Climate
Diagnostics Center in Boulder Colorado).  These anomaly plots are
presented following the discussion.  Meteorological parameters affecting
ozone concentrations were chosen for review as outlined below.

Surface variables affecting ozone concentrations

Wind Speed and Pressure – surface transport indicator

Temperature - More ozone production with higher temperatures

Precipitation– lower levels allow more ozone production

Upper air variables affecting ozone concentrations

850mb (just above the surface layer) heights and Wind Speed and 250mb
(jet stream height) Wind Speed – long range transport aloft and air
mass movement indicators

850mb Temperature– Fewer clouds and more ozone production with higher
temperatures

The 2005 Ozone Season was characterized by some parameters favoring
ozone production and transport and some which did not, as listed below:

Conducive to ozone in Maine

Surface and 850mb Temperatures – Above normal temperatures similar to
Ozone Seasons with many exceedances

850mb heights, jet stream location– more sunshine, fewer showers and
thunderstorms and slow moving air masses

Not conducive to ozone in Maine

Surface Pressure and winds – Higher pressures over Maine and
especially east and northeast of Maine resulting in more southerly
component of the surface wind (tropical “clean” air mass)

Transport aloft (850mb winds) – lighter than normal resulting in less
ozone and ozone precursors being transported to Maine

Table C-1 compares the various meteorological parameters with ozone
exceedance days for each year for the months of June, July and August.
The A’s in the table identify those parameters which favored ozone for
that year.  Red indicates strongly favorable.  The B’s in the table
identify those parameters which did NOT favor ozone for that year.  Blue
indicates strongly unfavorable.

Each year some parameters will favor ozone build up in Maine while
others will not.   The sole exception to that statement is 2004 which
ranged from slightly unfavorable to strongly unfavorable and resulted in
the fewest ozone exceedances on record for Maine.

When comparing 2002 (14 exceedances) and 2005 (3 exceedances) the
greatest differences between the two years relate to wind direction at
the surface.  It is important to note that in 1988, the year with the
greatest number of exceedances, the wind direction was not as conducive
to ozone transport as other high years (1991, 1993, 1995 and 2002).
When ozone precursors are reduced, as mandated by emissions control
programs at the state and federal levels, wind direction becomes a more
critical factor for ozone buildup in Maine.

As demonstrated in table C-1, many meteorological conditions favored
ozone buildup in 2005.  Thus, it was not unusual meteorological
conditions that allowed the Portland Nonattainment Area to monitor
attainment.

Figure C-7 SURFACE PRESSURE ANOMALIES

Figure C-8 SURFACE TEMPERATURE ANOMALIES

Figure C-9 SURFACE WIND SPEED ANOMALIES

Figure C-10 SURFACE PRECIPITATION ANOMALIES

Figure C-11 850mb WIND SPEED ANOMALIES

Figure C-12 850mb HEIGHT ANOMALIES

Figure C-13 850mb TEMPERATURE ANOMALIES

Figure C-14 JET STREAM WIND SPEED ANOMALIES

Table C-1 Summary of Anomaly Plot Data with Ozone exceedance data

number of monitors	6	6	10	10	10	11	14	14	13	15	16	16	16	15	15	16	17	17

EXCEEDANCE DAYS	29	8	12	15	9	13	9	13	5	11	7	8	2	10	14	5	1	3

EXCEEDANCE MONITORS	131	30	39	70	35	41	30	48	15	41	26	22	4	43	52	17	2	4

EXCEEDANCES PER MONITOR	21.8	5.0	3.9	7.0	3.5	3.7	2.1	3.4	1.2	2.7	1.6	1.4
0.3	2.9	3.5	1.1	0.1	0.2

EXCEEDANCE HOURS	1092	227	272	508	217	189	143	281	98	259	208	148	18	297
325	90	7	24

EXCEEDANCE HOURS PER MONITOR	182.0	37.8	27.2	50.8	21.7	17.2	10.2	20.1
7.5	17.3	13.0	9.3	1.1	19.8	21.7	5.6	0.4	1.4

MODERATE AQI DAYS	44	27	26	32	29	26	33	31	32	24	35	32	17	26	28	25	21	22

MODERATE MONITORS	261	90	120	184	143	134	159	193	140	151	149	158	76	156
195	137	85	107

MODERATES PER MONITOR	43.5	15.0	12.0	18.4	14.3	12.2	11.4	13.8	10.8	10.1
9.3	9.9	4.8	10.4	13.0	8.6	5.0	6.3

MET (UNADJUSTED)	6	-6	2	6	-4	2	6	4	-6	-6	-6	8	-4	6	6	-4	-10	2

MET (ADJUSTED)	14	-6	2	16	-16	2	14	12	-10	-10	-12	14	-10	4	18	-12	-22	6

Surface Parameters:	1988	1989	1990	1991	1992	1993	1994	1995	1996	1997
1998	1999	2000	2001	2002	2003	2004	2005

PRESSURE (ANOMOLY)	B	A	A	A	B	A	A	A	A	B	B	A	A	A	A	B	B	B

PRESSURE (ORIENTATION)	A	B	B	A	A	B	A	B	B	A	B	A	B	A	A	A	B	B

TEMPERATURE	A	B	B	A	B	A	A	A	B	B	A	A	B	A	A	B	B	A

WIND SPEED	A	B	A	A	A	B	A	A	B	B	B	A	A	B	B	B	B	B

SOIL MOISTURE	A	B	A	A	B	A	B	B	B	A	B	A	A	A	A	B	B	A

850mb HEIGHT	B	A	B	A	B	A	A	A	A	B	B	A	B	A	A	B	B	A

850mb TEMPERATURE	A	B	A	A	B	A	A	A	B	B	A	A	B	A	A	A	B	A

850mb WIND SPEED	A	B	B	B	A	B	A	B	B	B	B	B	B	B	B	B	B	B

250mb WIND SPEED	A	B	A	B	B	B	B	A	B	B	B	A	B	A	A	B	B	A

1000-500mb THICKNESS	A	B	A	A	B	A	A	A	B	B	B	A	B	A	A	A	B	A

AREA TO LOOK: Midwest and major cities in the east	A	B

PRESSURE (ANOMOLY)	above normal 	below normal

PRESSURE (ORIENTATION)	SW-NE orientation	NW-SE orientation

TEMPERATURE	above normal  	below normal

WIND SPEED	average or slightly above normal	below normal

SOIL MOISTURE	average or below normal	above normal

850mb HEIGHT	higher than normal	below normal

850mb TEMPERATURE	higher than normal	below normal

850mb WIND SPEED	normal or higher than normal	below normal

250mb WIND SPEED	higher than normal north of USA	higher than normal over
or south of the region

1000-500mb THICKNESS	higher than normal	below normal

Appendix D

Methodology Used to Prepare

State of Maine

2006 Ozone Redesignation Inventories

Revision of April 13, 2006

	In the first quarter of 2006, the Air Toxics and Emissions Inventory
Program began the development of multi-year, ozone redesignation and
maintenance plan inventories for nine Maine counties.  The purpose of
these inventories was to support the redesignation of two, 8-hour ozone
nonattainment areas and four, 1-hour nonattainment areas to attainment
status and provide a long-term demonstration that attainment could be
maintained.

	In its letter to James Brooks on December 6, 2005, EPA outlined the
requirements of this inventory:

2002 summer, daily emissions inventories for NOx and VOC which would
serve as the base year for the four, 1-hour nonattainment area
maintenance plans;

2005 summer, daily emissions inventories for NOx and VOC which would
serve as the base year for the two, 8-hour nonattainment area
maintenance plans;

2009 summer, daily emissions inventories for NOx and VOC which would
serve as an interim year for all six maintenance plans;

2016 summer, daily emissions inventories for NOx and VOC which would
serve as the end year for all six maintenance  plans; and

On-road mobile source emission projections, by town, for each 8-hour non
attainment area.  This projection will serve as the NOx and VOC
emissions budgets for transportation conformity purposes.

	The purpose of this document is to provide a general overview of how
each inventory was developed.

Point

	Maine once again used the 2002 inventory from the recent SIP amendment,
15% VOC emission reduction plan (approved by EPA, FR14815, March 24,
2006).  For later years, the Point Source Inventory data is grown out
from 2004, using SIC growth factors from EGAS 5.0 Beta, for developing
the 2006 Ozone Redesignation Inventories.

	Wyman Station data for 2002 and 2004 is from EPA’s Acid Rain Program.

Nonpoint

	Maine used its final submission to the 2002 National Emissions
Inventory (February 2005, with state edits, May 1, 2005) as the basis
for developing the 2006 Ozone Redesignation Inventory.  Documentation
detailing the development of 2002 NEI emissions estimates can be found
in “Methodology Use to Prepare the State of Maine 2002 Emissions
Inventory,” (September 12, 2005) which is located on Maine DEP’s
website at   HYPERLINK
"http://www.state.me.us/dep/air/emissions/docs/ME_2002_NEI_Narrative_fin
al.pdf"
http://www.state.me.us/dep/air/emissions/docs/ME_2002_NEI_Narrative_fina
l.pdf .

	The following additions and corrections were made to this data set.

Petroleum and Petroleum Storage: Gasoline Service Stations: Stage 1:
Submerged (SCC:<PHONE_NUMBER>) and Stage 1: Balanced Submerged (SCC:
2501060053) have been corrected for the ozone summer season.  Annual
emission estimate use average daily VMT to calculate emissions, however,
summer daily VMT must to used to accurately calculate summer ozone
season estimates.  The ozone season estimates use summer-weighted VMT to
allocate fuel distribution.  All other parts of the calculation are
consistent.

Petroleum and Petroleum Storage: Gasoline Service Stations: Stage 2:
Total (SCC:<PHONE_NUMBER>) was deleted from the Nonpoint inventories.
These emission estimates are now included with the Onroad sector.  It
was included in the nonpoint sector with the 2002 NEI because E.H.
Pechan, who had developed Maine’s Onroad estimates, had specifically
excluded Stage 2 emissions from the MOBILE model runs.  For these
inventories, however, we have left Stage 2 emissions with the Onroad
estimates.

Petroleum and Petroleum Transport: Marine Vessels (SCCs: Crude Oil –
2505020030; Residual Oil –<PHONE_NUMBER>; Distillate Oil –<PHONE_NUMBER>;
and Gasoline –<PHONE_NUMBER>) emission estimates were changed after the
2002 NEI submission.  In May 2005, Maine learned that all ballast is not
segregated and zeroed out emissions from non-segregated ballasts.

Emission estimates for Commercial Bakeries (SCC:<PHONE_NUMBER>) and
Breweries (SCC:<PHONE_NUMBER>) were added to the ozone redesignation
inventories.  These categories were include in Maine’s recently
approved 15% Plan inventory, but were not included in the 2002 NEI.
Emissions of wineries and distilleries were once again confirmed to be
de minimis

Two Nonroad sources have been grouped with the Nonpoint sector.  They
include the following categories and SCCs:

Marine Vessels; Port and Underway Emissions	SCCs: 228002100,<PHONE_NUMBER>,
2280002200, and<PHONE_NUMBER>

Aircraft	SCCs:<PHONE_NUMBER>,<PHONE_NUMBER>,<PHONE_NUMBER>, and<PHONE_NUMBER>

Other Combustion: Prescribed Burning of Rangeland (SCC:<PHONE_NUMBER>) was
miscoded in Maine’s 15% Plan as Other Combustion: Prescribed Burning
for Forest Management (SCC:<PHONE_NUMBER>).  There is no prescribed burning
for forest management in Maine’s ozone nonattainment areas.  Maine DEP
then looked at the raw data and realized that the prescribed burning did
not occur during the summer season.  Therefore, Prescribed Burning of
Rangeland was removed from these inventories.

EPA-generated data for 11 Solvent Categories was added or substituted
for Maine data.  This data was not available for Maine to use in its
2002 NEI submission. However, with some exceptions, we are using a
majority of the data here since it is morecomplete.  The 11 Solvent
Categories included VOC data for 43 SCCs.  Where Maine had submitted
state-calculated, VOC emission estimates for SCCs included in the 11
Solvent Categories, we deleted our state-calculated values in favor of
the EPA estimates.  The following is a list of exceptions to our
acceptance of the EPA-generated data for the 11 Solvent Categories:

Emissions estimates for Dry Cleaning – Coin-Operated Cleaners (SCC:
2420020370) were deleted because we have verified, through inspection
and survey, that no such facilities exist in Maine.

Emissions estimate for Rubber/Plastics (SCC:<PHONE_NUMBER>) was deleted
because it was determined during our review of the 2002 Draft NEI that
these emissions were included in the Point source inventory.

Emissions from four SCCs in the Miscellaneous Non-Industrial: Consumer
and Commercial Products categories (SCCs:<PHONE_NUMBER>,<PHONE_NUMBER>,
2460400000, and<PHONE_NUMBER>) for which Maine has submitted data were
reported under different SCCs (SCCs:<PHONE_NUMBER>,<PHONE_NUMBER>,<PHONE_NUMBER>,
and<PHONE_NUMBER>) by EPA in the 11 Solvent Category data.  The State data
was deleted from the inventory to prevent double counting.

	Growth factors were developed using the EGAS model, version 5.0 beta.
Growth factor projections assumed a 2002 base year.  New SCCs created
for the 11 Solvent Categories were not reflected in the EGAS model.
Growth factors, based on similar SCCs, were used where the EGAS model
provided none.

	Annual emissions were apportioned to tons per summer weekday using
EIIP, Volume III, “Introduction to Area Source Emission Inventory
Development,” Chapter 1, Section 4.2.6, “Seasonal Activity” and
Section 4.2.8, “Calculations for Temporal Adjustments” (January
2001).  See   HYPERLINK
"http://www.epa.gov/ttnchie1/eiip/techreport/volume03/iii01_apr2001.pdf"
 http://www.epa.gov/ttnchie1/eiip/techreport/volume03/iii01_apr2001.pdf
.  SCC-specific, apportionment factors can be found in the
tblAnnual_to_TPSD table of the 2006RedesignationArea.mdb database.

	Maine did take advantage of controls which were currently in effect or
would become effective in future years.  The following table lists the
SCCs and control efficiencies expected in future years.

SCC	Pollutant Code	2002 Control Efficiency	2005 Control Efficiency	2009
Control Efficiency	2016 Control Efficiency	Rule Citation

06-096 CMR

2401001000	VOC	0	0	0.35	0.35	CH 151

2401005000	VOC	0	0.38	0.38	0.38	CH 153

2401100000	VOC	0	0	0.35	0.35	CH 151

2415030000	VOC	0	0.66	0.66	0.66	CH 130

2415045000	VOC	0	0.66	0.66	0.66	CH 130

2415065000	VOC	0	0.66	0.66	0.66	CH 130

2415100000	VOC	0	0.66	0.66	0.66	CH 130

2415100385	VOC	0	0.66	0.66	0.66	CH 130

2415300000	VOC	0	0.66	0.66	0.66	CH 130

2415300370	VOC	0	0.66	0.66	0.66	CH 130

2415300385	VOC	0	0.66	0.66	0.66	CH 130

2460100000	VOC	0	0.142	0.142	0.142	CH 152

2460200000	VOC	0	0.142	0.142	0.142	CH 152

2460400000	VOC	0	0.142	0.142	0.142	CH 152

2460600000	VOC	0	0.142	0.142	0.142	CH 152

2460800000	VOC	0	0.142	0.142	0.142	CH 152

2461021000	VOC	0.8	0.8	0.8	0.8	CH 131

Nonroad

	Maine used the NONROAD2005 Emission Inventory Model (November 2005) for
the nonroad engine emissions modeling.  The following table summarizes
the inputs.

 	2002	2005+

	South	SUM	SUM	All redesignation plan counties

Fuel RVP	7.8	7.8	except Hancock and Waldo

Oxygen Weight %	0.64	0.5

	Gas sulfur %	0.0197	0.0339

	Diesel Sulfur % (default)	0.25	0.2284

	CNG/LPG (default)	0.003	0.003

	Min Temp	63	63

	Max Temp	90	90

	Avg Temp	75	75

	Altitude 	LOW 	LOW

	Stage II Control Factor	0.0	0.0

	North	SUM	SUM	Hancock and Waldo Counties

Fuel RVP	9	9	only

Oxygen Weight %	0.64	0.5

	Gas sulfur %	0.0197	0.0339

	Diesel Sulfur % (default)	0.25	0.2284

	CNG/LPG (default)	0.003	0.003

	Min Temp	63	63

	Max Temp	90	90

	Avg Temp	75	75

	Altitude 	LOW 	LOW

	Stage II Control Factor	0.0	0.0

Notes:

	2002 RVP, Oxygen Weight % and Gas sulfur % calculated from 2002 Fuels
report.

0.25 Diesel Sulfur % for 2002 supplied by Pechan

NONROAD defaults used for 2005 and later years

	Additionally, rail road fuel use data became available after the
submission of the 2002 NEI, so the Locomotive emissions were
recalculated using the following methodology:

Fuel usage totals were obtained from the major rail companies that did
business in Maine in 2002, except for the Montreal, Maine & Atlantic
Railway company.  Montreal did not respond to our repeated requests for
fuel use data.

To estimate Montreal's fuel consumption, average fuel consumption per
track mile value was calculated from the three large railways that had
supplied data.  One company had supplied both the line fuel usage, and
yard engine fuel usage.  This percentage (15% in rail yards) was used to
estimate the amount of fuel that Montreal burned in its yard engines,
which was added to the value estimated for line work.

The number of switch yards and track miles per company and county were
derived from GIS databases.  Railroad tracks leased from the state were
apportioned to each company, resulting in a 5% fuel usage increase per
company.  We assumed that each rail yard had one yard locomotive.

To calculate emissions from Yard Locomotives, we multiplied the amount
of fuel used in yard engines by the emission factors in Table 7 of the
Sierra Document.  This was double checked against using the number of
switch yards per company, (and the assumption of one yard locomotive per
yard) and multiplying this by the emission factor in Table 8 of the
Sierra Document.  We also made an estimate of fuel use from switch yard
engines by using  the  226 gallons of fuel per day per engine
consumption value in Sierra.

The amount of variability in emissions from these three methods, and the
lack of cooperation by the rail road companies in volunteering fuel
consumption data, points to the need to amend DEP’s regulations to
compel railroad companies to file emission statements

The Sierra Report shows large drop in the sulfur content in locomotive
fuel in 2008, and variable emission factors over time.  Additionally, we
grew out railroad use from 2002 using EGAS growth factors

Once the per company emissions had been determined, these emissions were
apportioned based on the the amount of track in each county, and the
number of switch yards, as determined from the GIS database.

Onroad

	Maine used MOBILE6.2.03 (September 24,2003) to generate emission factor
for the redesignation inventories.  The following table summarizes the
command inputs used in the input files.

Evaluation Month	7 (July)

Fuel Program	1 (Conventional Gasoline East)

Fuel RVP	7.8 for Kennebec, Androscoggin, Knox, Lincoln, Cumberland,
Sagadahoc and York counties

9.0 for Waldo and Hancock counties

Min/Max Temp	63. and 90.

Anti-Tampering Program	For Cumberland County (catalyst removal and gas
cap)

ANTI-TAMP PROG     :

99 83 20 22222 11111111 1 11<PHONE_NUMBER>2

For all other counties (catalyst removal only)

ANTI-TAMP PROG     :

99 83 20 22222 11111111 1 11<PHONE_NUMBER>1

Stage II Refueling	Stage II refueling is only applicable to three
counties: Cumberland, Sagadahoc and York counties.

For Cumberland County

STAGE II REFUELING :

95 3 45. 4.

For Sagadahoc County

STAGE II REFUELING :

95 3 41. 3.

For York County

STAGE II REFUELING :

95 3 35. 3.

Inspection/Maintenance Programs	I/M Programs is only applicable to
Cumberland County.

I/M PROGRAM        : 1 1999 2025 1 TRC GC

I/M MODEL YEARS    : 1 1974 2025

I/M VEHICLES       : 1 22222 11111111 1

I/M COMPLIANCE     : 1 96.0

I/M GRACE PERIOD   : 1 1

Maine LEV II Program	Data files specific for Maine’s LEV II Program
were developed and supplied by EPA.

94+ LDG IMP        : MELEV2.D

T2 EXH PHASE-IN    : LEV2EXH.D

T2 EVAP PHASE-IN   : LEV2EVAP.D

T2 CERT            : LEV2CERT.D

Maine created two MOBILE6 input files for each county – one which used
the National LEV Program input file and one which used the Maine LEV II
Program input files (listed above).  Maine is approved to take only 90%
of the Maine LEV II credit and both files were needed to calculate those
values.  90% of the Maine LEV II credit is taken for all years and all
planning areas included in the demonstrations.

Appendix E

Department Rules Incorporated in the State Implementation Plan

As of 6/1/06

State citation	Title/subject	State effective date	EPA approval date
Explanations

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch1.pdf"  Chapter
1  	Regulations for the Processing of Applications.	05/20/85	03/23/93,
58 FR 15430.	Portions of Chapter 1

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch100.pdf"
Chapter 100   	Definitions.	07/25/95	10/15/96,61

FR 53639.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch101.pdf"
Chapter 101   	Visible Emissions.	10/10/79	02/17/82, 47

FR 6829.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch102.pdf"
Chapter 102   	Open Burning.	01/31/72	05/31/72,

37 FR 10842.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch103.pdf"
Chapter 103   	Fuel Burning Equipment Particular Emission Standard.
01/24/83	02/26/85,

50 FR 7770.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch104.pdf"
Chapter 104   	Incinerator Particulate Emission Standard.	01/31/72
05/31/72,

37 FR 10842.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch105.pdf"
Chapter 105   	General Process Source Particulate Emission Standard.
01/31/72	05/31/72,

37 FR 10842.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch106.pdf"
Chapter 106   	Low Sulfur Fuel Regulations.	02/08/78	01/08/82,

47 FR 947.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch107.pdf"
Chapter 107   	Sulfur Dioxide Emission Standards for Sulfate Pulp
Mills.	01/31/72	05/31/72,

37 FR 10842.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch109.pdf"
Chapter 109   	Emergency Episode Regulation.	08/14/91	01/12/95,

60 FR 2887.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2004_ME_ch110.pdf"
Chapter 110   	Ambient Air Quality Standards.	07/24/96	03/22/04,

69 FR 13227.	Adopts PSD increments based on PM10, in place of increments
based on TSP.

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch111.pdf"
Chapter 111   	Petroleum Liquid Storage Vapor Control.	09/27/89
02/03/92,

57 FR 3948.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch112.pdf"
Chapter 112   	Gasoline Bulk Terminals.	07/19/95	10/15/96,

31 FR 53639.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch113.pdf"
Chapter 113   	Growth Offset Regulation.	06/22/94	02/14/96,

61 FR 5694.	Part of New Source Review Program

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch114.pdf"
Chapter 114   	Classification of Air Quality Control Regions.	04/27/94
08/30/95,

60 FR 45060.	Revision to Remove Presque Isle as nonattainment for PM10.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch115.pdf"
Chapter 115    	Emission License Regulation.	06/22/94	02/14/96,

61 FR 5694.	Part of New Source Review Program

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch116.pdf"
Chapter 116   	Prohibited Dispersion Techniques.	10/25/89	03/23/93,

58 FR 15430.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch117.pdf"
Chapter 117   	Source Surveillance.	08/09/88	03/21/89,

54 FR 11525.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch118.pdf"
Chapter 118   	Gasoline Dispensing Facilities.	07/19/95 	10/15/96,

61 FR 53639.	Stage II vapor recovery requirements added.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch119.pdf"
Chapter 119   	Motor Vehicle Fuel Volatility Limit.	06/01/00	03/06/02,

67 FR 10100.	Controls fuel volatility in the state. 7.8 psi RVP fuel
required in 7 southern counties.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch120.pdf"
Chapter 120   	Gasoline Tank Trucks.	06/22/94	06/29/95,

60 FR 33734.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch123.pdf"
Chapter 123   	Paper Coater Regulation.	09/27/89	02/03/92,

57 FR 3949.	The operating permits for S.D. Warren of Westbrook, Eastern
Fine Paper of Brewer, and Pioneer Plastics of Auburn incorporated by
reference at 40 CFR § 52.1020 (c)(11), (c)(11), and (c)(18),
respectively, are withdrawn.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch126.pdf"
Chapter 126

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch126_AppendixA.p
df"  Chapter 126 Appendix A  	Capture Efficiency Test Procedures.
05/22/91	03/22/93,

58 FR 15282.

  HYPERLINK "http://www.epa.gov/region1/topics/air/sips/me/ME_ch127.pdf"
 Chapter 127  	New Motor Vehicle Emission Standards.	12/31/00	04/28/05,

70 FR 21959.	Including Basis Statements and Appendix A. Low emission
vehicle program, with no ZEV requirements. Program achieves 90% of full
LEV benefits.

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch129.pdf"
Chapter 129

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch129_Appendix.pd
f"  Chapter 129 Appendix A  	Surface Coating Facilities.	01/06/93
06/17/94,

59 FR 31157.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2005_ME_Ch130.pdf"
Chapter 130  	Solvent Cleaners.	06/17/04	05/26/05,

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch131.pdf"
Chapter 131   	Cutback and Emulsified Asphalt.	01/06/93	06/17/94,

59 FR 31157.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch132.pdf"
Chapter 132   	Graphic Arts: Rotogravure and Flexography.	01/06/93
06/17/94,

59 FR 31157.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch133.pdf"
Chapter 133   	Gasoline Bulk Plants.	06/22/94	06/29/95,

60 FR 33734.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch134.pdf"
Chapter 134   	Reasonably Available Control Technology for Facilities
that Emit Volatile Organic Compounds.	02/08/95	04/18/00,

65 FR 20753.	Regulations fully approved for the following counties:
York, Sagadahoc, Cumberland, Androscoggin, Kennebec, Knox, Lincoln,
Hancock, Waldo, Aroostock, Franklin, Oxford, and Piscataquis. Regulation
granted a limited approval for Washington, Somerset, and Penobscot
Counties.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch137.pdf"
Chapter 137   	Emission Statements.	11/10/93	01/10/95,

60 FR 2526.

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch138.pdf"
Chapter 138   	Reasonably Available Control Technology for Facilities
that Emit Nitrogen Oxides.	08/03/94	09/09/02,

67 FR 57154.	Affects sources in York, Cumberland, Sagadahoc,
Androscoggin, Kennebec, Lincoln, and Knox counties

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch141.pdf"
Chapter 141

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_ch141_Supplement_
FederalRegisterGeneralConformity.pdf"  Chapter 141 Supplement - Federal
Register 11/30/93 General Conformity Rule   	Conformity of General
Federal Actions.	09/11/96	09/23/97,

62 FR 49611.

  HYPERLINK "http://www.epa.gov/region1/topics/air/sips/me/ME_ch145.pdf"
 Chapter 145  	NOx Control Program 	06/21/01 	03/10/05

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2005_ME_Ch148.pdf"
Chapter 148  	Emissions from Smaller-Scale Electric Generating Resources
	07/15/04	05/26/05

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2006_ME_ch151.pdf"
Chapter 151 	Architectural and Industrial Maintenance (AIM) Coatings
10/06/05	03/17/06

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2005_ME_ch152.pdf"
Chapter 152  	Control of Emissions of Volatile Organic Compounds from
Consumer Products 	08/19/04	10/24/05

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2005_ME_Ch153.pdf"
Chapter 153 	Mobile Equipment	02/05/04	05/26/05

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2005_ME_ch155.pdf"
Chapter 155    	Portable Fuel Container Spillage Control	07/14/04
02/07/05

  ]

  HYPERLINK
"http://www.epa.gov/region1/topics/air/sips/me/2003_ME_MaineVehicleInspe
ction.pdf"  Vehicle I/M   	Vehicle Inspection and Maintenance.	07/09/98
01/10/01,

66 FR 1875.	"Maine Motor Vehicle Inspection Manual," revised in 1998,
pages 1-12 through 1-14, and page 2-14, D.1.g. Also, Authorizing
legislation effective July 9, 1998 and entitled L.D. 2223, "An Act to
Reduce Air Pollution from Motor Vehicles and to Meet Requirements of the
Federal Clean Air Act."

Appendix F

Mobile Sources Emissions Budget

8 Hour Conformity Budgets

Revised 07/06 to parse emissions to town level

Planning Area 1

 57 Towns within the Portland 8-hour nonattainment area

all emissions expressed in tons per summer week day

2005	2005	2009	2009	2016	2016

Category	Subcategory	VOC	NOx	VOC	NOx	VOC	NOx

Point

3.669	8.210	3.931	8.676	4.627	10.118

Nonpoint

33.433	5.207	34.268	5.376	38.118	5.596

Mobile	Onroad	22.476	46.776	16.659	32.837	11.032	16.098

Mobile	Nonroad	17.401	10.556	15.124	8.177	13.146	5.545

Mobile	Locomotives	0.015	0.423	0.014	0.388	0.013	0.342

	Total	76.994	71.172	69.996	55.454	66.936	37.699

	Safety margin	10.058	33.473

 The other 8-hour ozone nonattainment area is the Hancock, Knox, Lincoln
and Waldo Counties “Subpart 1, Basic” nonattainment area consisting
of coastal towns and islands in these counties.

 The threshold value is the 4th high monitored daily maximum 8-hour
ozone value during the 2006 ozone season which would cause the 2004-2006
design value to exceed the 8-hour ozone NAAQS.

 The emission rate at this facility was reduced from 0.476 lb/mm Btu to
230 ppmv bubble.

 Units 1, 2, 3 and 5 installed low-NOx burners.

  All boilers at the PNSY were reduced from a 0.5 lb/mm Btu emission
rate to a 0.35 lb/mm Btu emission rate.

 Emission rates on boilers 17, 18, 19 and 20 were reduced from 0.45
lb/mm Btu to 0.30 lb/mm Btu.

 The Courts have ruled that in the event a statutory deadline is missed,
the effective deadline becomes “as expeditiously as practicable”,
hence the 2005 demonstration date of Maine’s updated 15% Plan.

 This rule is applicable in York, Cumberland, Sagadahoc, Androscoggin,
Kennebec, Lincoln, and Knox counties.

 This rule is applicable in York, Cumberland and Sagadahoc counties.

 This rule is applicable in Androscoggin, York, Cumberland, Knox,
Lincoln, Kennebec, and Sagadahoc counties

 There are two phases of on-road standards, the first in 2004 and the
second in 2007.

 See http://www.otcair.org/interest.asp?Fview=stationary#: “Status
Report on OTC States’ Efforts to Promulgate Regulations Based on OTC
Model Rules”

 The NOx SIP Call superseded Phase III of the OTC NOx Budget Program.

 For comparison, NOx Budget Program sources in the 22-states NOx SIP
Call region emitted 1,222,000 tons during the 2000 ozone season.

In areas that are not contained within an MPO, the state Department of
Transportation is responsible for conformity determinations.  In Maine,
due to its rural nature, only four urban areas are served by
metropolitan planning organizations (Kittery, Portland, Lewiston/Auburn
and Bangor).

 40 CFR Part 93, Transportation Conformity Rule Amendments for the New
8-hour Ozone and

PM2.5 National Ambient Air Quality Standards and Miscellaneous Revisions
for Existing Areas; Transportation Conformity Rule Amendments: Response
to Court Decision and Additional Rule Changes, at 69 FR 40003.

 Final approval for this plan was published in the Federal Register on
March 24, 2006.

 Maine Department of Transportation provided VMT estimates (by vehicle
class) for each town; these VMT estimates were then applied to the 2007
emission factors as modeled by Mobile 6.2.03.

 The motor vehicle emission budgets established for the Portland
maintenance plan provide an adequate safety margin as defined in EPA’s
Transportation Conformity Regulations at 40 CFR 93.101.  These safety
margins are documented in Appendix F.

  The 2005 inventory is also a standard periodic (i.e., every three
years) inventory as required pursuant to section172(c)(3) of the Act

 The maintenance plan must show that emissions 10 years after the date
on which EPA approves the redesignation request will be lower than they
were in the base year (2005) of the maintenance plan.  The additional
time is needed for EPA to complete its review and approval process.

 “Technical Support Document for the Nonroad Land-based Diesel Engines
Standards Air Quality Modeling Analyses”, U.S. EPA Office of Air
Quality Planning and Standards, April 2003.

 “Technical Support Document for the Final Clean Air Interstate Rule,
Air Quality Modeling”, U.S. EPA Office of Air Quality Planning and
Standards, March 2005.

 Sierra Research, Inc. “Revised Inventory Guidance for Locomotive
Emissions, prepared for the Southeastern States Air Resource Managers,
Inc. (Sierra Research, Inc. 1801 J Street, Sacramento, CA 95814), June
2004

 Point source emissions within the 57 town nonattainment region are
based on actual physical location of the source.

 Nonpoint (area) source emissions are population based and calculated on
the population for the nonattainment region.

Onroad mobile source emissions are estimated with Mobile 6.2.03 based on
VMT.

 Nonroad mobile source emissions are also population based and
calculated using the NONROAD2005 Emission Inventory Model.

 Locomotive emissions are based on the miles of track in the
nonattainment region.

 PAGE

 PAGE   7

 PAGE   38

DRAFT

 PAGE

 PAGE   75

DRAFT

Portland Nonattainment Area Yearly 4th High Ozone (parts per billion)

60

70

80

90

100

110

120

130

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

Kittery 23-031-3002

Kennebunkport 23-031-2002

West Buxton 23-031-0038

Cape Elizabeth 23-005-2003

Phippsburg 23-023-0003

Reid State Park 23-023-0004

Hollis 23-031-0037

Standard

Portland Nonattainment Area 8-hr Ozone Design Values (parts per billion)

70

80

90

100

110

120

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

PORTLAND NONATTAINMENT AREA

Standard