Evaluation of relative response factor methodology for demonstrating attainment of ozone in Houston, Texas

In 2007, the U.S. Environmental Protection Agency (EPA) released guidance on demonstrating attainment of the federal ozone (O3) standard. This guidance recommended a change in the use of air quality model (AQM) predictions from an absolute to a relative way. This was accomplished by using a ratio, and not the absolute difference of AQM O3 predictions from a historical year to an attainment year. This ratio of O3 concentrations, labeled the relative response factor (RRF), is multiplied by an average of observed concentrations at every monitor. In this analysis, whether the methodology used to calculate RRFs is severing the source-receptor relationship for a given monitor was investigated. Model predictions were generated with a regulatory AQM system used to support the 2004 Houston-Galveston-Brazoria State Implementation Plan. Following the procedures in the EPA guidance, an attainment demonstration was completed using regulatory AQM predictions and measurements from the Houston ground-monitoring network. Results show that the model predictions used for the RRF calculation were often based on model conditions that were geographically remote from observations and counter to wind flow. Many of the monitors used the same model predictions for an RRF, even if that O3 plume did not impact it. The RRF methodology resulted in severing the true source-receptor relationship for a monitor. This analysis also showed that model performance could influence RRF values, and values at monitoring sites appear to be sensitive to model bias. Results indicate an inverse linear correlation of RRFs with model bias at each monitor (R2 = 0.47), resulting in a change in future O3 design values up to 5 parts per billion (ppb). These results suggest that the application of RRF methodology in Houston, TX, should be changed from using all model predictions above 85 ppb to a method that removes any predictions that are not relevant to the observed source-receptor relationship.