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 1 3 , 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 p rovided a 30

- day public comment period

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

. Do cumentation accompanying the SI P 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 include s 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
consult ation 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 identi fied and precisely quantified on page 48 of the 2012 Nogales Attainment Plan . These budgets reflect
federal motor vehicle control measures that were alre ady 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

t ogether 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 PM 10 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 attainme nt demonstration.

EPA has concluded th at the budget for the year 2011 when considered together with
all other emission sources is consistent with the requirement to demonstrate
attainment of the 198 7 24

- hour PM 10 standard . This finding is based on review o f
the attai nment 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 PM 10 include emissions from re

- entrained road dust (paved a nd 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 so urces 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 t he 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
emiss ions; 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 emiss ions 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 purpos es.

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 A D EQ will compile any public comments submitted during the June 2 1, 20 12 public h earing and during the public comment period. Any written and verbal comments received during the public comment period and public hearing on the
201 2 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.