SUBJECT: 

FROM: 

TO: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Technical Support Document (TSD) - Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the Maintenance Plan for the Lancaster 1997 and 2006 F_ine 

Particulate (PM2.s) National Ambient Air Quality Standard (NAAQS) 

N onattainment Areas . () 11 ( -' -:" n .. Jr.v~ Asrah Khadr, Environmental Engineer, Engineer in Training (EIT) L~ 0 · 

Office of Air Program Planning (3AP30) ~ I z.- /1 )-

Administrative Record for the Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the Maintenance Plan for the Lancaster 1997 and 2006 

PM2.s NAAQS Nonattainment Areas 

~ <1. I().~!~ 5 THRU: Marilyn Powers, Acting Associate Director df / 1 

Office of Air Program Planning (3AP30) 

I. Background 

On January 5, 2005 (70 FR 944), Lancaster County was designated as nonattainment for the 1997 

PM2.s NAAQS as part of the Lancaster 1997 PM2.s NAAQS Nonattainment Area. On November 

13, 2009 (74 FR 58688), Lancaster County was designated as nonattainment for the 2006 PM2.s 

NAAQS as a part ofthe Lancaster 2006 PM2.s NAAQS Nonattainment Area. On September 25, 

2009 (74 ·FR 48863), it was determined that the Lancaster 1997 PM2.s NAAQS Nonattainment 

Area had air quality data showing the 1997 PM2.s NAAQS was attained. On March 29, 2012 (77 

FR 18922), it was determined that the Lancaster 2006 PM2.s NAAQS Nonattainment Area had air 

quality data showing the 2006 PM2.s NAAQS was attained. Additional background information 

about the Lancaster 1997 and 2006 PM2.s NAAQS Nonattainment Areas iS< available in the notice 

of proposed rulemaking (NPR) in this docket. On April30, 2014, the Pennsylvania Department of 

Environmental Protection (P ADEP) formally submitted a State Implementation Plan (SIP) revision 

to satisfy the redesignation requirements of the Clean Air Act (CAA) for the 1997 PM2.s NAAQS 

and the 2006 PM2.s NAAQS for the Lancaster 1997 and 2006 NAAQS Nonattainment Areas. 

II. Transportation Conformity Requirements 

Under section 176(c) of the CAA, new transportation plans, programs, and projects, such as the 

construction of new highways, must "conform" to (i.e., be consistent with) the part of the state's 

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air quality plan that addresses pollution from cars and trucks. The CAA requires federal actions in 

nonattainment and maintenance areas to "conform to" the goals of the SIP. This means that such 

actions will not cause or contribute to violations ofNAAQS; worsen the severity of an existing 

violation; or delay timely attainment of any NAAQS or any interim milestone. 

For motor vehicle emissions budgets (MVEBs) to be approvable, they must meet, at a minimum, 

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) consultation among Federal, 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 measures 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 estimates of vehicle miles traveled). 

III. Review of the Submitted Modeling Utilizing the Motor Vehicle Emission Simulator 

(MOVES2010) 

To run the MOVES2010 model, a run specification (hereafter referred to as "RunSpec") must be 

created so the appropriate parameters are selected for the modeling run. The RunSpecs, inputs, 

and outputs were reviewed against the following EPA document: Technical Guidance on the use of 

MOVES201 0 for Emission Inventory Preparation in State Implementation Plans and 

Transportation Conformity. This guidance document provides guidance on the use of the MOVES 

model to develop inventories for SIPs as well as analysis of emissions for transportation 

conformity determinations. 

EPA carefully reviewed the inputs into the model to ensure that they are representative of each 

respective parameter for the area. Table 1 presents the input parameters and the state's submittal 

for each parameter. The RunSpec parameters were reviewed as well; Table 2 presents the 

RunSpec parameters and the state's submittal for each parameter. The RunSpecs, input files, and 

output files were reviewed and found to have followed the applicable EPA guidance provided in 

the Technical Guidance on the use of MOVES201 0 for Emission Inventory Preparation in State 

Implementation Plans and Transportation Conformity. 

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Table 1. Review of Inputs for RunSpecs for years 2007, 2017 and 2025 for the 

Redesignation Request for the Lancaster 1997 and 2006 PM2.s NAAQS Nonattainment 

Areas 

Parameter State Submittal 

All source types were presented with respect to age (0-30 years), and 

Age Distribution the age fraction of each source type. 

Average Speed All source types were presented with respect to road type, hour of the 

Distribution day, average speed and average speed fraction. 

FuelType and This parameter includes an input for alternative vehicle fuels and 

Technologies technologies, input of this parameter applies to areas that have 

vehicle fuels and technologies that are outside of the traditional 

inputs provided in the county data manager. There was no input 

provided for this parameter. 

Fuel (Includes inputs • For fuel formulation, the fuel formulation ID, Reid Vapor 

for fuel formulation and Pressure (RVP), and sulfur levels were included along with 

fuel supply) other data. 

• For Fuel Supply, the fuel formulation ID as well as the month 

group ID were included along with other parameters. 

Meteorology Data Meteorology data was provided for each hour of the day for each 

month. The meteorology data provided included temperature and 

relative humidity averages for each hour of a day for each month. 

Ramp Fraction The fractions of ramp driving times were provided for restricted 

access roadways. 

Road Type Distribution The vehicle miles traveled (VMT) fraction for each road type is 

provided for each source type and road type. 

Source Type The amount of vehicles for each source type are provided. 

Population 

Vehicle Type VMT • The daily VMT fractions were provided for respective days 

(includes inputs for and source types. 

daily VMT fraction, • The hourly VMT fractions were provided with respect to hour 

hourly VMT fraction, of the day and source type. 

and monthly VMT • The monthly VMT was provided with respect to source type 

fraction) and month. 

Inspection/Maintenance The 1/M programs were presented with respect to source types and 

(I/M) Programs compliance factors as well as other data. 

Table 2. RunSpec Reviews for the Lancaster 1997 and 2006 PM2.s NAAQS 

Nonattainment Areas Redesignation Request for Years 2007,2017 and 2025 

Domain/Scale County scale was selected. This is acceptable for this air quality 

analysis. 

Calculation Type Inventory was selected which is acceptable for this analysis. 

Time Aggregation Hourly time aggregation was selected. Selection of hourly time 

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Level aggregation level is acceptable for this analysis. 

Calendar Year Of The appropriate calendar year was selected. MOVES2010b can 

Evaluation model years 1990 and 1999-2050. 

Month of Evaluation All12 months were selected for evaluation. 

Type of Day of Weekdays and weekends were selected. 

Evaluation 

Hours of Evaluation Starting and ending hours create a whole day (from 0-24 hours). 

Geographic Bounds Lancaster County was selected. 

Vehicles/Equipment: Appropriate combinations of fuels and source use types were made. 

On-Road Vehicle 

Equipment 

Road Type Selection included all necessary road types. 

Pollutants and Nitrogen oxides (NOx), sulfur dioxide (S02), ammonia (NHJ), 

Processes volatile organic compounds (VOCs), total gaseous hydrocarbons, 

non-methane hydrocarbons and all forms of primary PM2.s were 

selected, which is acceptable for this analysis. 

On-Road Retrofits NIA 

ROP N/A 

Output Database/Unit Mass units selected to be grams; energy units selected to be million 

Selection British Thermal Units (BTU); distance units selected to be miles. 

Output Emission Detail Emission detail was selected via user preference. 

in Emission Rate 

Calculations 

Advanced Performance N/A 

Features 

IV. Administrative Requirements for Making Adequacy Findings 

EPA followed the process for determining the adequacy of the submitted SIP MVEBs in 

accordance with the procedures listed in the January 2008 Conformity Regulations contained in 

40 CFR part 93, 118(f) "Adequacy review process for implementation plan submissions." EPA 

will be issuing an NPR for a 30-day public comment period soliciting public comment for the · 

approvability ofPennsylvania's SIP submission. EPA will also propose approval ofthe MVEBs 

for milestone year 2017 and the out-year 2025 for PM2.s and NOx. The MVEBs are presented 

below in Table 3. The NPR also proposes to find the MVEBs adequate or available for use for 

transportation conformity purposes. Following EPA's public comment period, responses to any 

comments received on the proposed mobile budgets will be addressed in an amendment to this 

TSD. 

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Table 3. MVEBs Contained in the Maintenance Plan for the Lancaster 1997 and 2006 

PM2.s NAAQS Nonattainment Areas 

Year Motor Vehicle Emissions Mobile Vehicle Emissions 

Budget PM2.s -Tons Per Year Budget for NOx-Tons Per 

Year 

2017 249 6,916 

2025 185 4,447 

V. Evaluation of the Adequacy of the MVEBs in the Maintenance Plan for the Lancaster 

1997 and 2006 PM2.s NAAQS Nonattainment Areas 

In this TSD, we are evaluating the MVEBs associated with the maintenance plan contained in the 

April30, 2014, SIP revision for conformity purposes. We are using the evaluation criteria 

detailed in the Transportation Conformity Rule, 40 CFRpart 93.102(b)(2)(v), 93.102(b)(2)(v), 

93.102(b)(3), and part 93, 93.118(e)4 through 93.118(e)5. The evaluation is presented in Table 

4, below. 

Table 4. Adequacy of the MVEBs Contained in the Maintenance Plan for the Lancaster 

1997 and 2006 PM2.s NAAQS Nonattainment Areas 

Transportation Conformity Review Criteria 

Rule 

40 CFR Part 93, 93.118 

93.102(b)(2)(iv) Have EPA and the State 

made a finding that N Ox is 

an insignificant contributor 

to the direct mobile PM 

emissions? 

Was the Criterion 

Satisfied? If Yes How was 

this Criteria Satisfied? 

Neither EPA nor the State 

has made such a finding. · 

93.1 02(b )(2)(v) Has EPA or State made a Neither EPA nor the State 

finding that VOCs, Sulfur has made such a finding. 

Oxides (SOx) or Ammonia 

(NH3) as precursors to be a 

significant contributor to the 

mobile PM2.s emissions? 

93.1 02(b )(3) Has the EPA or the State Neither EPA nor the State 

made a finding that re- has made such a finding. 

entrained road dust" is a 

significant contributor to the 

PM mobile emissions? 

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93.118(e)(4)(i) Was the submitted revised Yes, the submitted 

plan endorsed by the maintenance plan was 

Governor (or his or her endorsed and submitted as a 

designee) and subject to a SIP revision by the 

State public hearing? Governor's designee, the 

Acting Secretary, and a 

notice of public hearing was 

-' published in The PatriotNews on March 4, 2014. 

93 .118( e)( 4 )(ii) Before the attairunent Yes. Consultation has 

demonstration was submitted occurred among all required · 

to EPA, did consultation federal, state and local 

between federal, State and agencies. 

local agencies occur; was full 

implementation plan 

documentation provided to 

EPA, and was EPA's stated 

concerns, if any, addressed? 

93.118(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly 

emissions budget(s) clearly identified on page 3 7 in the 

identified and precisely maintenance plan. 

quantified? 

93.118(e)(4)(iv) Is the motor vehicle EPA believes the budgets can 

emissions budget(s), when be declared adequate because 

considered together with all in conjunction with the other 

other emission reductions, emission reductions, they 

consistent with applicable demonstrate attairunent for 

requirements for attairunent years 2017 and 2025. 

demonstrations? 

93.118(e)(4)(v) Is the motor vehicle EPA b~lieves that the budgets 

emissions budget(s) are clearly related to the 

consistent with and clearly emissions inventory and the 

related to the emissions control measures in the SIP 

inventory and the control submittal. 

measures in the Plan? 

93.118(e)(4)(vi) Revisions to previously Yes, the maintenance plan 

submitted attairunent provides new MVEBs for 

demonstrations: explain and years 2017 and 2025. The 

document any changes to addition of safety margins to 

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previously submitted budgets the MVEBs is consistent with 

and control measures; continued attainment. 

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). 

Sec. 93.118(e)(5) Did they provide and we Yes 

review public comments and 

the State's responses to those 

comments with the submitted 

control strategy SIP? 

VI. Findings 

Based upon our review and evaluation ofthe MVEBs contained in PADEP's April30, 2014 

submittal of the maintenance plan to satisfy the requirements ofthe1997 and 2006 PM2.s 

NAAQS, we find the MVEBs to be adequate for conformity purposes and recommend that the 

MVEBs for the Lancaster 1997 and 2006 PM2.s NAAQS Nonattainment Areas be SIP approved. 

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