1 **UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103** 

**SUB JECT**  : June 17, 2013

Supplemental Technical Support Document (TSD)

- In significance Findings for the Motor Vehicle Emissions for the Redesignation Request and Maintenance Plan f or the West Virginia P ortion of the Parkersburg

- Marietta , WV

- OH 1997 Fine P articulate M atte r (PM 2.5 ) Nonattainment Area

**FROM: /s/** 

Gregory Becoat Environmental Scientist (3AP 30 )

**TO:** Administrative Record for the In significance Findings for the Motor Vehicle Emis sions for the Redesignation Request and Maintenance Plan for West Virginia Portion of the Parkersburg

- Marietta , WV

- OH 1997 PM 2.5 Nonattainment Area

**THRU: /s/** 

Cristina Fernandez
, Associate Director Office of Air Program Planning (3AP 30 )

**I. Background**
On March 8, 2012, the State of West Virginia formally submitted a Redesignation Request and Maintenance Plan for West Virginia Portion of the Parkersburg

- Marietta, WV

- OH 1997 PM 2.5 Nonattainment Area (hereafter the Redesignation Request and Maintenance Plan)

. The State Implementation Plan (SI P) included a request for a finding of insignificance by EPA for motor vehicle emissions for nitrogen oxides (NOx), direct particulate matter (PM) , and sulfur dioxide (SO 2 )

. Transportation conformity i s required under section 176(c) of the Clean Air Act ( CAA ) to ensure that f ederally supported highway , transit projects, and other activities are consistent with (conform to) the purpose of the SI P. The CAA requires federal actions in nonattainment and

ma intenance areas to “conform to” the goals of SIP. This means that such actions will not cause or contribute to violations of a national ambient air quality standard (NAAQS); worsen the severity of an existing violation; or delay timely attainment of any

N AAQS or any

interim milestone. Actions involving Federal Highway Administration (FHWA) or Federal Transit Administration (FTA) funding or approval are subject to the transportation conformity rule ( 40 CFR part 93 , subpart A). Under this rule, metropolita n planning organizations (MPOs) in nonattainment and maintenance areas coordinate with State air quality and transportation2

agencies, EPA, FHWA, and FTA to demonstrate that their metropolitan transportation plans and TI Ps conform to applicable SIPs. This is ty pically determined by

showing that estimated emissions from existing and planned highway and transit sy stems are less than or equal to the motor vehicle emissions budgets (MVEBs) contained in a SIP.

F or MVEBs to be approvable, they must meet, at a mi nimum, EPA’s adequacy criteria found at 40 CFR 93.118(e)(4). EPA’s adequacy criteria are: (1) the submitted control strategy implementation plan was endorsed by the Governor or designee and was subject to a State public hearing; (2) con sultation among F e deral, State, and local agencies occurred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, if any , were addressed before the control strategy implementation plan was submitted ; (3) the MVEBs are clearly identified and precisely

quantified; (4) the MVEBs, when considered together with all other emissions sources, are consistent with applicable requirements for maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and the control m easures in the submitted control strategy implementation plan; and (6) revisions to previously submitted maintenance plans explain and document any changes to previously

submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins; and reasons for the changes (including the basis for any changes related to emission factors or estim ates of vehicle miles traveled).

Incertain instances, the Transportation Conformity Rule allows areas to forgo es tablishment of a MVEB where it is demonstrated that the regional motor vehicle emissions for a particular pollutant or precursor are an insignificant contributor to the air quality problem in an area. The general criteria for insignificance determinations can be found in 40 CFR 93.109 (f ). In significance determinations are based on a number of factors, including the percentage of motor vehicle emissions in the cont ext of the total SI P inventory ; the current state of air quality as determined by

monitori ng d ata for the relevant NAAQS; the absence of SI P motor vehicle control measures; and the historical trends and future projections of the growth of motor vehicle emissions. EPA’ s rationale for providing for insignificance determinations is described in the J uly 1, 2004, revision to the Transportation Conformity Rule at 69 FR 40004

. Specifically , the rationale is explained on page 40061 under the subsection XXI II. B. entitled, “ Areas With In signif icant Motor Vehicle Emissions.” Any insignificance determinatio n under review of EPA is subject to the adequacy and approval process for EPA's action on the SIP.

**I I**  **. Administrative Requirements for Making**  **Insignificance Findings** 

EPA ha s followed the process for reviewing the submitted SI P and determining if an in significance finding for motor vehicle e missions is warranted in accordance with the procedures listed in the January 2008 Conformity

Regulations contained in 40 CFR 93. 102 (b)

- “Geographical applicabil i ty” and 40 CFR 93. 118(f)

- “ Adequacy review process f

or implementation plan submissions

. ”

**II I** 

**. Evaluation**  **of the Request**  **for an Insignificance Finding for**  **M otor**  **V ehicle**  **E mission**  **s in t**  **he Redesignation Request and Maintenance Plan**  **for the**  **West Virginia Portion of the**3

**Parkersburg**

**- Marietta**  **, WV**

**- OH**  **1997 PM**  **2.5 Nonattainment Area**  **Submitted b y**  **T he**  **West Virginia**  **Department of Environment al Protection** 

Inthis TSD, EPA is evaluating the West Virginia Department of Environmental Protection’s request for an insignificance finding for motor vehicle emissions associated with the Redesignation Request and Maintenance Plan contained in the submittal. EPA is using the evaluation criteria detailed in the Transportation Conformity Rule, 40 CFR 93.1 02(b)(2) ( iv), ( b)(2)(v)
, and (b)(3) and 93.118(e) ( 4 ) and (e) ( 5 )

. The evalu ation is presented below.

**Review of the Request for Insignificance Finding**  **of M otor**  **V ehicle**  **E missions**  **in the Redesignation Request and Maintenance Plan**  **for the**  **West Virginia Portion of the**

**Parkersburg**

**- Marietta**  **, WV**

**- OH**  **PM 2.5**  **Nonattainment Area**

Transportat ion Conformity Rule 40 CFR Part 93 Review Criteria Was the Criterion Satisfied? I f Yes , How was this Criteria Satisfied? 93.102(b)(2)(iv) Has the EPA and the State made a finding that NOx is an insignificant contributor to the direct mobile PM emission s or does the implementation plan fail to establish a NOx budget as part of the PM 2.5 maintenance strategy ? T he State has requested that NOx be found an insignificant contributor to the m obile PM emissions. This request is based

on the State finding that Onroad mobile source NOx constitutes less than twelve percent of the area’s total NOx emission s in the 2015 and 2022 horizon years due to continuing fleet turnover even with future vehicle miles traveled (VMT) growth included in the emission projections. EPA has also made a finding that the transportation

- related emissions of NOx within the nonattainment area are not a significant contributor to the direct mobile PM emissions

. 93.102(b)(2)(v) Has the EPA or State made a finding that the precursors, V olatile O rganic C ompounds (V OCs )
, S O 2 or Ammonia (NH 3 ) are a significant contributor to the mobile PM emissions or does the implementation plan submission establish a budget for VOCs, SOx or Neither EPA nor the S tate has made any findings that VOC s, S O 2 , or NH 3 is a significant contributor to the PM 2.5 mobile emissions
, and therefore
, it has not been included in the SI P

. Onroad mobile source SO 2 emissions constitute less than 0.1% of the area’s total SO 2 emissio ns in the 2015 and 20224 NH 3 as part of a PM 2.5 maintenance strategy ? horizon years.
93.102(b)(3) Has the EPA or the State made a finding that direct PM is a significant contributor to the PM mobile emissions or does the implementation plan establish a budget that includes direct PM as part of a PM 2.5 maintenance strategy ? The State has requested that direct PM be found an insignificant contributor to the mobile PM emissions. This request is based on the State finding that Onroad mobile source PM 2.5 constitutes less than 2.1% of the area’s t otal PM 2.5 emissions in the 2015 and 2022 horizon years due to continuing fleet turnover even with future VMT growth included in the emission projections.

Sec. 93.118(e)(4)(i) Was the submitted revised plan endorsed by

the Governor (or his or her designe e) and subject to a State public hearing? Yes. The submitted Redesignation Request and Maintenance Plan w as endorsed and submitted as a SI P revision by the Governor ’ s designee, the Secretar y of the West Virginia D epartment of Environment al Protection

. A public hearing on the SI P proposal was held on February 23, 2012

. Sec. 93.118(e)(4)(ii) Before the maintenance plan was submitted to EPA, did consultation between federal, State and local agencies occur; was full implementation plan documentation provi ded to EPA, and was EPA ’ s stated concerns, if any , addressed? Yes. Consultation has occurred among all required F ederal, S tate , and local agencies.

Sec. 93.118(e)(4)(iii) W ere the MVEBs clearly identified and precisely quantified? As there was a request for an insignificance finding, no MVEBs were identified in the SIP. Sec. 93.118(e)(4)(iv) Are the motor vehicle emissions, when considered together with all other emission reductions, consistent with applicable E PA believes th at motor vehicle emissions can be declared insignificant contributors because in compar ing the mo tor vehicle emissions to the overall emissions5 requirements for maintenance strategies ? inventory , the mo tor vehicle emissions comprise only

a small portion of the over PM 2.5 emissions f

or the nonattainment

area and are projected to continue to significantly

decline due to fleet turnover

. Sec. 93.118(e)(4)(v) Are the motor vehicle emissions consistent with and clearly

related to the emissions inventory

and the control measures in the Plan? EPA believes that the motor vehicle emissions have clearly related to the emissions inventory and control measures in the SI P submittal.

Sec. 93.118(e)(4)(vi) Revisions to previously submitted maintenance plan: explain and document any changes to pr eviously submitted budgets and control measures; impacts on point and area source emissions; any

changes to established safety

margins (see Sec. 93.101 for definition); and reasons for the changes (including the basis for any

changes related to emission fa ctors or estimates of vehicle miles traveled). There are no revisions to the maintenance plan because this is the initial redesignation request, along with the associated maintenance plan for West Virginia Portion of the Parkersburg

- Marietta, WV

- OH Area.

Sec. 93.118(e)(5) Did they provide and we review public comments and the State ’ s responses to those comments with the submitted control strategy

SI P? There were no comments on the

SI P related to the proposed insignificance finding request.

**IV**

**. Co**  **nclusion**
Based upon our review and evaluati on of the motor vehicle emissions contained in the West Virginia Redesignation Request and Maintenance Plan for the West Virginia Portion of the Parkersburg

- Marietta , WV

- OH 1997 PM 2.5 Nonattainment Area
, EPA fin ds that the SI P submittal meets the criteria in the transportation conformity rules fo r an insignificance finding for NO x , PM 2.5 , and SO 2 contribution from motor vehicles. Weighing all the factors for an6

insignificance finding, particularly the minor contribution of mobile source PM 2.5 and SO 2 , EPA has determined that the PM 2.5 and SO 2 contribution from m otor vehicle emissions to the annual PM 2.5 pollution for the West Virginia portion of the Nonattainment Area are insignificant. With respect to transport ation conformity , the larger NOx contribution of less than twelve and a half percent of the area’s total NOx emission s in the 2015 and 2022 horizon years requires further justification to request an insignificant finding. The requirements under 40 CFR 93. 109 (f ) bases insignificance on emission percentages, emission trends , and the effectiveness of the pollutant in forming PM. For the Parkersburg

- Marietta area, there is a significant emission decrease projected for the highway sector and total emissions so urce inventory in years 2008, 2015, and 2022

. Given the relatively small contribution of the highway mobile emissions to the total SI P inventory , highway mobile emissions are not likely to contribute significantly to local PM 2.5 . Additionally , NOx reduct ions are significantly less effective in reducing PM concentrations than are reductions in direct PM and SO 2 . Consequently , NOx percent age emission contribution may be higher than direct PM and SO 2 without adversely affecting air quality

. Based on the an aly sis of local historical trends and growth patterns in order to develop the long range transportation plan and transportation improvement program for transportation conformity purposes, EPA has no reason to expect highway motor vehicle emissions growth t o lead to a violation of the annual PM 2.5 standard. Although vehicle miles traveled increases over time , NOx emissions are projected to decrease dramatically from 4505.4 tons/year in 2002 to 665.7 tons/year in 2030. This demonstrates that highway emissio ns will remain insignificant in the future. Upon review of the further justification for requesting an insignificant finding for NOx, EPA has determined that NOx contribution from motor vehicle emissions to the annual PM 2.5 pollution for the West Virginia portion of the Nonattainment Area is insignificant

.