UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105

Memorandum

To: Nogales 179B SIP Proposed Approval Docket, Docket ID EPA-R09-OAR-2012-0458

From: Wienke Tax, Air Planning Office, EPA Region 9

Date: June 13, 2012

RE: Adequacy documentation for Nogales PM-10 MVEBs in June 2012 ADEQ Nogales PM-10 

179B State Implementation Plan

Attached to this memorandum is the adequacy documentation for the Nogales PM-10 MVEBs in June 2012 

ADEQ Nogales PM-10 179B Attainment Plan.
 

Table 1. Evaluation of the Motor Vehicle Emissions Budget in the 2012 Nogales SIP

June 2012 (reviewed by Wienke Tax)

Adequacy Review Criteria

(40 CFR part 93)

Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 

93.118(e)(4)(i)

The plan was endorsed by the 

Governor (or designee) and was 

subject to a public hearing.

Y

ADEQ has satisfied applicable statutory and regulatory requirements for reasonable 

public notice and hearing prior to adoption and submittal of the State 

Implementation Plan - Nogales PM10 Nonattainment Area, May 2012 (“2012 

Nogales Attainment Plan”). The State provided a 30-day public comment period, 

and held a public hearing prior to the adoption of the Plan on June 21, 2012. 

Documentation accompanying the SIP describes a public and agency outreach 

effort. See, e.g., http://www.azdeq.gov/environ/air/plan/notmeet.html#nog and 

http://www.azdeq.gov/download/calendar/051612pn1.pdf. 

The SIP submittal includes proof of publication for notices of the ADEQ public 

hearing as evidence that all hearings were properly noticed.

Sec. 

93.118(e)(4)(ii)

The plan was developed through 

consultation with federal, state 

and local agencies; full 

implementation plan 

documentation was provided and 

EPA’s stated concerns, if any, 

were addressed.

Y

Consultation with federal, state and local agencies was undertaken; this 

consultation included EPA, ADEQ, and ADOT in March and April of 2012. EPA 

received several draft versions of the 2012 Nogales Attainment Plan and provided 

comments. EPA concerns were addressed in the final SIP that was adopted. 

Sec. 

93.118(e)(4)(iii)

The motor vehicle emission 

budgets are clearly identified and 

precisely quantified.

Y

The motor vehicle emissions budget for 2011 is clearly identified and precisely 

quantified on page 48 of the 2012 Nogales Attainment Plan. These budgets reflect 

federal motor vehicle control measures that were already adopted at the time the 

ADEQ adopted the 2012 Nogales SIP on June 21, 2012 and were developed using 

EPA’s MOVES model. 
 

Table 1. Evaluation of the Motor Vehicle Emissions Budget in the 2012 Nogales SIP

June 2012 (reviewed by Wienke Tax)

Adequacy Review Criteria

(40 CFR part 93)

Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 

93.118(e)(4)(iv)

The motor vehicle emissions 

budget(s), when considered 

together with all other emission 

sources, is consistent with 

applicable requirements for 

reasonable further progress and 

attainment.

Y

EPA has concluded that the budget for the year 2011 when considered together with 

all other emission sources is consistent with the requirement to demonstrate 

attainment for the 1987 24-hour PM10 standard. This finding is based on a review of 

the attainment demonstration in the 2012 Nogales Attainment Plan. As documented 

in the notice, EPA is proposing to approve the attainment demonstration.

EPA has concluded that the budget for the year 2011 when considered together with

all other emission sources is consistent with the requirement to demonstrate 

attainment of the 1987 24-hour PM10 standard. This finding is based on review of 

the attainment demonstration in the 2012 Nogales Attainment Plan. As documented 

in the Federal Register notice, EPA is proposing to approve the CAA 179B

attainment demonstration.

The budgets for PM10 include emissionsfrom re-entrained road dust (paved and 

unpaved). See 2012 Nogales SIP, page 47.

Sec. 

93.118(e)(4)(v)

The plan shows a clear 

relationship among the emissions 

budget(s), control measures and 

the total emissions inventory.

Y

The emission inventories for all point, area, and mobile sources are contained in 

Chapter 3, pages 14 and 15, and Appendix B of ADEQ’s 2012 Nogales Attainment 

Plan. The relationship of the emission inventory to control measures and the 

reductions from the measures are described in Chapter 5 – Control Measures of the 

2012 Nogales Attainment Plan. 
 

Table 1. Evaluation of the Motor Vehicle Emissions Budget in the 2012 Nogales SIP

June 2012 (reviewed by Wienke Tax)

Adequacy Review Criteria

(40 CFR part 93)

Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 

93.118(e)(4)(vi)

Revisions to previously submitted 

control strategy or maintenance 

plans explain and document any 

changes to any previous submitted 

budgets and control measures; 

impacts on point and area source 

emissions; any changes to 

established safety margins (see 

§93.101 for definition), and 

reasons for the changes (including 

the basis for any changes to 

emission factors or estimates of 

vehicle miles traveled).

Y

On June 14, 1993, ADEQ submitted the “Final State Implementation Plan for the 

Nogales PM10 Nonattainment Area,” to 

EPA.<http://www.azdeq.gov/environ/air/plan/download/nogpm10sip_061993.pdf>.

The 1993 SIP did not contain motor vehicle emissions budgets, as EPA had not 

promulgated the conformity regulations required by the 1990 Clean Air Act 

Amendments in 1993. So while the 2012 Nogales SIP revises and updates the 1993 

Nogales SIP, it did not update or revise any budgets for conformity purposes. 

Sec. 

93.118(e)(5)

EPA has reviewed the State’s 

compilation of public comments 

and response to comments that are 

required to be submitted with any 

implementation plan.

Y

ADEQ will compile any public comments submitted during the June 21, 2012

public hearing and during the public comment period. Any written and verbal 

comments received during the public comment period and public hearing on the 

2012 Nogales Attainment Plan will be submitted with the final SIP documents. EPA

will review any comments that ADEQ receives on the SIP and ADEQ’s responses, 

and will take into account comments that substantively change the level of the 

budgets or affect our adequacy finding.