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

January 7 , 20 10

**SUB JECT**  : Technical Support Document (TSD)

- Adequacy Findings for the Motor Vehicle Emissions Budgets in the 200 9 Attainment Plan f or the Delaware P ortion of the Philadelphia 1997 Fine P articulate M atter (PM 2.5 ) N ational Ambient A ir Q uality S tandard (NAAQS) Non attainment Area

**FROM: /s/** 

Martin T. Kotsch Environmental Engineer (3AP 30 )

**TO:** Administrative Record for the Adequacy Findings for the Motor Vehicle Emissions Budgets in the 200 9 Attainment Pl an for the Delaware portio n of the Philadelphia 1997 PM 2.5 NAAQS Nonattainment Area

**THRU: /s/** 

C ristin a F ernandez
, Associate Director Office of Air Program Planning (3AP 30 )

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

We have follow ed the process for determining the adequacy of the submitted S tate Implementation P lan (SIP) Motor Vehicle Emissions B udgets (MVEBs) in accordance with the procedures listed in the January 2008 Conformity

Regulations contained in 40 CFR Part 93

. 102 (“Geogr aphical applicabil i ty”) and 40 CFR Part 93

. 118(f) ( “ Adequacy review process for implementation plan submissions ” )

. By transmittal letter dated April 3 , 200 8
, the State of Delaware formally submitted a 200 9 PM 2.5 A ttainment D emonstration P lan for the 19 97 PM 2.5 NAAQS (hereafter the 2009 attainment plan) with mobile emissions budget for Nitrogen Oxides (NOx) and direct Particulate Matter (PM) for the Delaware portion of the Philadelphia 1997 PM 2.5 NAAQS nonattainment area (hereafter, “the D elaware area”)

.

Shown below in Table 1 are the budgets from the 200 9 attainment plan submittal.2 **Table 1** 

**. The Budgets of the**  **D elaware**  **200 9**  **Attainment Plan** 

Plan Submittal Milestone

Year Mobile V ehicle

Emissions Budget for N O x
Tons Per Year Mobile

V ehicle E missions Budget for Direct PM

T ons Per Year Attainment Plan 200 9 4, 9 04.0 87.0

**I I** 

**. Evaluation of the Adequacy of the MVEBs in the**  **200 9**  **Attainment Plan**  **for the**  **D elaware**  **Portion of the Philadelphia 1997 PM**  **2.5 NAAQS**  **Non**

**- attainment Area**  **Submitted By**  **the Delaware Department of Natural Resources and Environmental Control** 

Inthis TSD, we are evaluating the MVEBs associated with the 200 9 attainment p lan and 2010 Contingency

Plan contained in the submittal s for conformity purposes. We are using the evaluati on criteria detailed in the Transportation Conformity Rule, 40 CFR Part 93.1 02(b)(2) ( iv), 93.102(b)(2)(v)
, 93.102(b)(3) and Part 93.118(e)4 through 93.118(e)5. The evaluation is presented in Table 2 , below.

**Table 2** 

**. Adequacy of the MVEBs**  **Contained in the 200**  **9 Attainment**  **Plan for the**  **Delaware Portion of the Philadelphia 1997**  **PM 2.5**  **NAAQS**

Transportation Conformity Rule 40 CFR Part 93, 93.118 Review Criteria Was the Criterion Satisfied? I f Yes , How was this Criteria Satisfied? 93.102(b)(2)(iv) Has the E PA and the State made a finding that NOx is an insignificant contributor to the direct mobile PM emissions or does the implementation plan fail to establish a NOx budget as part of the PM 2.5 attainment ? Neither EPA nor the State have made any findings that NOx is an in significant contributor to the PM 2.5 mobile emissions and therefore it has been included in the SIP as a proposed mobile emissions budget f

o r 2009.
93.102(b)(2)(v) Has the EPA or State made a finding that V olatile O rganic C ompounds (V OCs )
, S ulf ur Oxides ( S O x ) or Ammonia (NH 3 ) as pr e cursors to be a significant contributor to the Neither EPA nor the State have made any findings that VOC’s, S O x or NH 3 are a significant contributor to the PM 2.5 mobile emissions and therefore it has not been included in the SIP as a3 mobile PM emissions or does the implementation plan submission establish a budget for VOCs, SOx or NH 3 as part of a PM 2.5 attainment strategy? proposed mobile

93.102(b)(3) Has the EPA or the State made a finding that re

entrained road dust is a significant contributor to the PM mobile emissions or does the implementation plan establish a budget that includes re

- entrained road dust as part of a PM 2.5 attainment strategy ? Neither EPA nor the State have made any findings that re

entrained road dust is a significant contributor to the PM 2.5 mobile emissions
, and therefore
, it has not been included in the SIP as a proposed mobile emissions budget

.

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

the Governor (or his or her designee) and subject to a State public hearing? Yes. The submitted 2009 Attainment Plan w as endorsed and submitted as a SI P revision by the Governor ’ s designee, the Secretar y of Delaware D epartment of Natural resources and E nvironment a l Control

. A public hearing on the SIP proposal was held by the State

. Sec. 93.118(e)(4)(ii) Before the attainment demonstration was submitted to EPA, did consultation between federal, State and local agencies occur; was full implementation plan documentation pr ovided 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) Was the motor vehicle emissions budget(s) clearly identified and precisely quanti fied? Yes, the budgets are clearly identified on page 1 0 1 of the SIP submittal containing the 2009 Attainment Plan

.4

Sec. 93.118(e)(4)(iv) Is the motor vehicle emissions budget(s), when considered together with all other emission reductions, consistent wi th applicable requirements for attainment demonstrations? EPA believes the budgets can be declared adequate because in conjunction with the other emission reductions, they demonstrate attainment for 200 9

.

Sec. 93.118(e)(4)(v) Is the motor vehicle emiss ions budget(s) consistent with and clearly related to the emissions inventory and the control measures in the Plan? EPA believes that the budgets are clearly related to the emissions inventory and the control measures in the SIP submittal.

Sec. 93.118(e) (4)(vi) Revisions to previously submitted attainment demonstrations: 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 (see Sec. 93. 101 for definition); and reasons for the changes (including the basis for any

changes related to emission factors or estimates of vehicle miles traveled). N/A T he area was designated nonattainment for this NAAQS for the first time in 2005 and this was the initial control strategy SI P submitted by

the state to address the NAAQS

.

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

SIP related to the proposed mobile vehicle emissions budgets.

**III. Findings** 

- Based upon our review and evaluati on of the MVEBs contained in the submittal of the 200 9 attainment p lan for the Delaware Portion of the Philadelphia 1997 PM 2.5 NAAQ S nonattainment area, we find the said MVEBs adequate for conformity purposes.5

**IV. The Applicable Motor Vehicle Emissions Budgets for Purposes of Demonstrating Conformity for 200**  **9 in the**  **D elaware**  **Area**

**-** The applicable motor vehicle emissions budgets for purposes of demonstrating conformity are 4904.0 ton s/year of NOx and 87.0 tons/year Direct PM for 2009

.