Air Resources Board 

Mary 0. Nichols, Chairman 

Lin& S. Adms f 001 I Street = P.Q. Box 2815 Amdd Schmnegwr Secmt~iry &r Sacramento, California 85812 * www.ar4.ca.gav Governor 

Envimram%nfat Pmtmtim 

March 26,2008 

Mr. Wayne Nastri 

RegionaD Administrator 

U.S. EnvironmenQl Prowon Agency 

Rqion 9 

75 Hawthorne Street 

San Francism, California 941 05 

Bear Mr. Nastri: 

The Air Resources Board (ARB or Board) is scheduled to consider approval af revised 

transpaflation cctnfomidW budgets for the PM2,5 and &hour ozone standards for thr; 

South Coast nonattainmnt area at its April 24,2088 meeting. Thew transportatian 

conformity budgets will rwlace the budgets submitfed as revisions to the State 

lmplemontation Plan (SIP) on November 28,2007. To ensure that the transpo~ation 

planning prams$ can continue without disruption, we are requesting hat the 

U.S. Enviranmental Pratection Agency (U.S. EPAf begin parailel processing of these 

budgets prior to ARB'S April action. 

Pubfic notices for the Board's wnsideration af these revisions were published in Icxal 

n~wspapem in the areas affected on March 20,2008. The ppro&la$ed wnfomi& 

budgets and an explanation of the proposed revisian vvere pubirshd an our website, at 

, an March 25,2008, We have discussed 

the proposed rovkions with the U.S. EPA, Rwion 9, Air Division staff. Vtle will infam 

your staff of any comments sent to ARB m this proposat in a timady mannor, and will 

notify U.S. EPA if there are any changes to the proposed budgets abr pasting to the 

web. We intend ta submit the approved confomity budgets promptiy after the Board 

takss action. 

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NOTICE OF PUBLIC HEARING TO CONSIDER APPROVAL OF MODIFIED 

TRANSPORTATION CONFORMITY BUDGETS CONTAINED IN THE 2007 AIR 

QUALITY MANAGEMENT PLAN FOR ATTAINING THE FEDERAL 8-HOUR OZONE 

AND PM2.5 STANDARDS IN 'THE SOUTH COAST AIR BASIN AND THE 

COACHELLA VALLEY 

The California Air Resources Board (ARB or Board) will conduct a public hearing to 

consider approval of modifications to the transportation conformity budgets contained in 

the 2007 Air Quality Management Plan for attaining the federal 8-hour ozone and PM2.5 

ambient air quality standards in the South Coast Air Basin, and the Federal 8-hour 

Ozone standard in the Coachella Valley. The plans were approved by the Board on 

September 27, 2007; the conformity budgets were approved by the Board on November 

15, 2007. If adopted, ARB will submit these modified elements to the 

U.S. Environmental Protection Agency for approval as a revision to the California State 

Implementation Plan. 

DATE OF HEARING: This item will be considered by the Board at a one-day hearing 

which will commence at 9:00 a.m. on April 24, 2008. Please consult the agenda for the 

meeting, which will be available at http://www.arb.ca.nov at least 10 days before April 

24, 2008, to see the order in which items will be considered. 

LOCATION: Caltrans Building, 11 1 Grand Avenue, Oakland, California 9461 2. 

Instructions on how to provide written and oral comments are included in the more 

detailed meeting notice available on ARB's website at 

htt~://www.arb.ca.qov/planninq/sip/sip.htm. The modified transportation conformity 

budgets and other supporting documents will also be posted on this website. Paper 

copies of these items may be obtained from ARB's Public Information Office at 

(91 6) 322-2990. Further inquiries regarding these items should be directed to 

Mr. Dennis Wade, Air Pollution Specialist, at (916) 327-2963. 

For individuals with sensory disabilities, this document is available in Braille, large print, 

audiocassette or computer disk. Please contact ARB's Disability Coordinator at 

(91 6) 323-491 6 by voice or through the California Relay Services at 71 1, to place your 

request for disability services. If you are a person with limited English and would like to 

request interpreter services, please contact ARB's Bilingual Manager at (916) 323-7053. 
Proposed Revisions 

Transportation Conformity Budgets for South Coast Air Basin 

On November 15, 2007, the Air Resources Board (ARB or Board) adopted 

conformity budgets for the South Coast Air Basin. The conformity budgets the 

Board approved are consistent with plans for attaining the federal fine particulate 

matter (PM2.5) and &hour ozone standards in the South Coast Air Basin that the 

Board had approved on September 27,2007. However, staff at the U.S. 

Environmental Protection Agency (U.S. EPA) has expressed concerns about 

these budgets, stemming from U.S. EPA concerns about the State Strategy used 

in the attainment demonstration plans. 

Although ARB staff and staff of the South Coast Air Quality Management District 

(AQMD) do not believe that U.S. EPA's concerns are properly part of conformity 

budget review, ARB and AQMD staffs have worked with staff of the Southern 

California Association of Governments (SCAG) and U.S. EPA staff to identify 

budgets that reflect California's commitment to meeting the air quality standards, 

and address U.S. EPA concerns. 

Based on this effort, ARB staff is now recommending the adoption of two sets of 

conformity budgets for the South Coast Air Basin. The first set reflects the 2007 

State lrr~plementation Plan (SIP) submittal for the South Coast Air Basin, 

including the locally adopted 2007 Air Quality Management Plan (AQMP) and the 

2007 State Strategy adopted by ARB. The second set of budgets reflects control 

measures adopted as of October, 2006 -the rules that formed the baseline 

emission inventory used in the development of the 2007 SIP. Both the SIP and 

baseline-based budgets provides sufficient reductions to meet the Clean Air Act's 

reasonable further progress test. 

Staff recommends that ARB direct staff to forward the two sets of budgets to 

U.S. EPA with the request that both sets of budgets be considered 

simultaneously. Further, staff recommends that the Board request that EPA 

approve the all budgets based on the 2007 SIP, and that U.S. EPA should 

approve all the baseline budgets only if it cannot approve or find adequate in 

their entirety the budgets based on the 2007 SIP. The baseline budgets are less 

protective and constraining than SIP-based budgets since they do not reflect new 

measures committed to in the 2007 SIP. Therefore, the baseline budgets would 

be forwarded to U.S. EPA with a commitment that if U.S. EPA selects this 

approach, then staff of the AQMD, SCAG, ARB, U.S. EPA and the Federal 

Highway Administration (FHWA) would work together to resolve issues affecting 

budget adequacy, and submit updated transportation conformity budgets within 

the next 12 months to reflect such resolution. 

Finally, staffs proposal does make two revisions to the 2007 SIP budgets 

approved in November 2007. The first revision would restore the budgets 
proposed for 2008 and 2009 to the baseline levels; this was done at the request 

of U.S. EPA. The second is minor, and recalibrates the 2007 SIP budgets using 

the EMFAC2007 motor vehicle emissions model. EMFAC2007 is the basis for 

motor vehicle emission inventories used in the attainment demonstration and 

reasonable further progress plans, and will be used to compare the impacts of 

proposed transportation projects against the conformity budgets. 

The Need for the Dual Path Approach 

U.S. EPA's concerns and hesitancy to act on the already submitted budgets 

create a conformity timing problem. SCAG must to adopt its new Regional 

Transportation Plan (RTP) in May, 2008 to avoid a lapse in conformity. The 

adopted RTP must include a demonstration that the plan conforms to the SIP. If 

approved by the Board, the dual path approach allows SCAG staff to do 

conformity analyses comparing the impacts of the proposed RTP to both the 

SIP-based budgets and the baseline budgets, which will then allow SCAG to 

adopt the RTP. Finally, once U.S. EPA acts on one of the sets of budgets, that 

set will become the conformity budgets and the need to carry two sets of budgets 

will stop. 

Proposed Budgets 

SIP-Based Budsets 

The preferred budgets reflect emission reduction commitments made in the 

ARB's adopted 2007 State Strategy for attaining the national PM2.5 and 8-hour 

ozone standards, and local controls identified in the South Coast's 2007 Air 

Quality Management Plan. The SIP-based budgets differ from the budgets ARB 

adopted in November, 2007, as described below. 

1. The budgets for 2008 (PM2.5) and 2009 (ozone) reflect the baseline program: 

they do not include any reductions from new measures adopted as part of the 

2007 SIP. 

2. The budgets have been recalibrated using ARB's EMFAC2007 motor vehicle 

emissions model, which has been approved for the SIP and which is the tool 

that will be used to compare the impacts of new projects to the conformity 

budgets. The budgets approved in November were calculated using the 

South Coast's Controlled Emission Projection Algorithm (CEPA) program. 

SIP-based transportation conformity budgets, shown in Attachment 1, are 

provided for the South Coast Air Basin for the following years: 

o Annual PM2.5 Standard: 2009,2012, 2014,2023, and 2030 

o 8-Hour Ozone Standard: 2008, 201 1, 2014, 2017, 2020, and 2023 
Baseline Buduets 

The proposed baseline budgets reflect rules that were adopted as of October, 

2006 - the baseline program prior to the development of the 2007 SIP. Because 

these budgets would not reflect the PM2.5 or 8-hour ozone attainment 

demonstrations, these budgets would be forwarded to U.S. EPA with a 

commitment that AQMD, SCAG, ARB, EPA, and FHWA will work together to 

resolve AQMP issues affecting budget adequacy, and submit an updated 

transportation conformity budgets within the next 12 months to reflect such 

resolution. These budgets were also calculated using the EMFAC2007 motor 

vehicle emissions model. 

Baseline transportation conformity budgets, shown in Attachment 2, are provided 

for the South Coast Air Basin for all milestone years up to the attainment year as 

follows: 

o Annual PM2.5 standard: 2009 and 201 2. 

o 8-hour Ozone standard: 2008,201 1,2014,2017, and 2020. 

Transportation conformity budgets identified for 2012 and 2020 will be used as 

the PM 2.5 and ozone transportation conformity budgets for PM2.5 and ozone, 

respectively, for all subsequent milestone years. Under U.S. EPA's conformity 

regulations, the agency has the option of approving only some of the budgets 

submitted. Should U.S. EPA approve conformity budgets for select years, e.g. 

for 2008 and 2009 only, emission budgets for all future milestone years will 

remain the same as the last rr~ilestone year approved. 

Coachella Valley 

Based on U.S. EPA's anticipated approval of the 2012 Coachella Valley 

conformity budgets in the Early Progress Plan approved ARB approved on 

February 28, 2008, no further action is needed on the Coachella Valley budgets. 

Staff Recommendation 

ARB staff recommends that the Board approve the dual path approach at its 

April 24, 2008 hearing, and direct staff to forward the revised budgets to 

U.S. EPA with a request that 1) U.S. EPA give primary consideration to the SIPbased budgets, and 2) U.S. EPA approve the baseline budgets only if U.S. EPA 

staff determines that it would recommend disapproval of the SIP-based budgets 

in their entirety. 

Revised on March 28, 2008 to correct typographical errors. 
Attachment 1 

South Coast Air Basin 

Transportation Conformity Emission Budgets: PM2.5 

SIP Based 

(Annual Average - Tons Per Day) 

2009 2012 2014 2023 2030 

ROG Baseline Inventory 196.2 162.6 146.1 101.9 85.4 

State Strategy Reductions NIA -2331) -24.0 -12.1 -9.2 

Adjustments to Baseline* -0.2 -0.5 -0.7 -1.4 -2.1 

Conformity Budget*** 196 - 139 122 89 75 

2009 2012 2014 2023 2030 

NOx Baseline Inventory 427.1 350.8 305.7 174.7 141.8 

1 

State Strategy Reductions NIA -60.9(2) -91.9 -33.7 -9.4 

Conformity Budget** 413 276 201 131 121 

2009 2012 2014 2023 2030 

PM2.5 Baseline Inventory 17.8 17.5 17.2 16.4 17.0 

Re-entrained Road Dust (paved) 18.6 18.8 19.0 20.8 21.4 

Re-entrained Road Dust (unpaved) 1.0 1 .O 1 .O 1 .O 1 .O 

Road Construction Dust 0.2 0.2 0.2 0.2 0.3 

State Strategy Reductions NIA -0.6 -4.6 -1.6 -0.4 

Adjustments to Baseline* -0.2 -0.2 -0.28 -0.4 -0.5 

Adiusted Inventory 37.4 36.7 32.5 36.4 38.7 

Conformity Budget** 38 37 33 37 39 

* Reductions from rules adopted prior to December, 2006 that are not reflected 

in EMFAC2007. 

** Rounded up to the nearest ton. 

(I) Originally noticed as -24.6 tons ROG reduction; ROG conformity budget 

originally noticed as 138 tons 

(2) Originally noticed as -61.6 tons NOx reduction 
Attachment 1 (cont.'d) 

South Coast Air basin 

Transportation Conformity Emission Budgets: 8 Hour Ozone 

SIP Based 

(Summer Planning - Tons Per Day) 

2008 2011 2014 2017 2020 2023* 

ROG Baseline Inventory 2 14.2 176.0 150.1 13 1.1 1 17.0 106.1 

State Strategy Reductions N/A -14.0(1) -24.6 -20.2 -1 5.6 - 12.4 

Adjustments to Baseline** -0.1 -0.4 -0.7 -1.0 -1.2 -1.5 

2008 2011 2014 2017 2020 2023* 

NOx Baseline Inventory 441.3 367.7 299.9 243.5 200.2 171.8 

State Strategy Reductions N/A -33.6(2) -9 1.4 -65.3 -45.7 -33.5 

Adjustments to Baseline** -14.7 -14.3 -13.4 -12.0 -10.4 -10.5 

Conformity Budget ** * 427 320 196 167 145 128 

* 2023 budget is applicable to all future years beyond 2023. 

** Reductions from rules adopted prior to December, 2006 that are not reflected 

in EMFAC2007. 

*** Rounded up to the nearest ton. 

(1) Originally noticed as -14.9 tons ROG reduction; ROG conformity budget 

originally noticed as 16 1 tons 

(2) Originally noticed as -34.1 tons NOx reduction 
Attachment 2 

South Coast Air Basin 

Transportation Conformity Emission Budgets: PM2.5 

Baseline Based 

(Annual Average - Tons Per Day) 

2009 2012 

ROG Baseline Inventory 196.2 162.6 

State Strategy Reductions NIA NIA 

Adjustments to Baseline* -0.2 -0.5 

Conformity Budget** 196 163 

2009 2012 

NOx Baseline Inventory 427.1 350.8 

State Strategy Reductions NIA NIA 

Adjustments to Baseline* -14.6 - 14.0 

Conformity Budget ** 413 337 

2009 2012 

PM2.5 Baseline Inventory 17.8 17.5 

Re-entrained Road Dust (paved) 1 8.6 18.8 

Re-entrained Road Dust (unpaved) 1.0 1 .O 

Road Construction Dust 0.2 0.2 

State Strategy Reductions NIA NIA 

0 

Adjustments to Baseline* -0.2 -0.2 

Conformity Budget ** 38 38 

* Reductions from rules adopted prior to December, 2006 that are not 

reflected in EMFAC2007. 

** Rounded up to the nearest ton. 
Attachment 2 (cont.'d) 

South Coast Air basin 

Transportation Conformity Emission Budgets: 8 Hour Ozone 

Baseline Based 

(Summer Planning - Tons Per Day)* 

2008 2011 2014 2017 2020 

ROG Baseline Inventory 214.2 176.0 150.1 13 1.1 1 17.0 

State Strategy Reductions NIA NIA NIA NIA NIA 

Adjustments to Baseline** -0.1 -0.4 -0.7 -1.0 -1.2 

2008 2011 2014 2017 2020 

NOx Baseline Inventory 441.3 367.7 299.9 243.5 200.2 

State Strategy Reductions NIA NIA NIA NIA NIA 

Adjustments to Baseline** -14.7 -14.3 -13.4 -12.0 -10.4 

Conformity Budget *** 427 354 287 232 190 

* No reductions assumed for California's 2007 SIP on-road measures. 

** Reductions from rules adopted prior to December, 2006 that are not 

reflected in EMFAC2007. 

*** Rounded up to the nearest ton.