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 inthe Maintenance Plan for the Lancaster 1997 and 2006 F

_ ine Particulate (PM2

.s) National Ambient Air Quality Standard (NAAQS) Nonattainment Areas

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..**Jr.v~** Asrah Khadr, Environmental Engineer, Engineer in Training (EIT)

## L~ 0 · Office ofAir Program Planning (3AP30)

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Administrative Record for the Adequacy Findings for the Motor Vehicle Emissions Budgets in the Maintenance Plan for the Lancaster 1997 and 2006 PM2

.sNAAQS Nonattainment Areas

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## I().~!~5 THRU: Marilyn Powers, Acting Associate Director 

### df / 1 Office ofAir 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 ofthe Lancaster 1997 PM2.s NAAQS Nonattainment Area. OnNovember 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
· FR48863), itwas 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

.sNAAQS 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 ofproposed rulemaking (NPR) in this docket. On April30, 2014, the Pennsylvania Department of Environmental Protection (PADEP) formally submitted a State Implementation Plan (SIP) revision to satisfy the redesignation requirements ofthe Clean Air Act (CAA) for the 1997 PM2.s NAAQS and the 2006 PM2

.sNAAQS for the Lancaster 1997 and 2006 NAAQS Nonattainment Areas.

II. Transportation Conformity Requirements
Under section 176(c) ofthe CAA, new transportation plans, programs, and projects, such as the construction ofnewhighways, must "conform" to (i.e., be consistent with) the part ofthe state's

1air quality plan that addresses pollution from cars and trucks. The CAA requires federal actions in nonattainment and maintenance areas to "conform to" the goals ofthe SIP. This means that such actions will not cause or contribute to violations ofNAAQS; worsen the severity ofan existing violation; or delay timely attainment ofany 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 at40 CFR 93.118(e)(4). EPA's adequacy criteria are: (1) the submitted control strategy implementationplan was endorsed bythe Governor or designee and was subject to a State public hearing; (2) consultation among Federal, State, and local agencies occurred; full implementationplan documentation was provided to EPA; and EPA's stated concerns, ifany, 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 implementationplan; and (6) revisions to previously submitted maintenance plans explain and document any changes to previously submittedbudgets and control measures; impacts onpoint 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 ofvehicle miles traveled).



### III. Review ofthe Submitted Modeling Utilizing the Motor Vehicle Emission Simulator (MOVES2010)
To run the MOVES2010 model, a run specification (hereafterreferred 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 MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. This guidance document provides guidance on the use ofthe MOVES model to develop inventories for SIPs as well as analysis ofemissions for transportation conformity determinations.
EPA carefully reviewed the inputs into the model to ensure that they are representative ofeach respective parameter for the area. Table 1presents 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 eachparameter. 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 MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity.

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### Table 1. Review ofInputs 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 respectto age (0-30 years), and Age Distribution the age fraction ofeach source type. Average Speed All source types were presented withrespect to road type, hour ofthe Distribution day, average speed and average speed fraction. FuelType and This parameter includes an input for alternative vehicle fuels and Technologies technologies, input ofthis parameter applies to areas that have vehicle fuels andtechnologies that are outside ofthe 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 otherparameters
. Meteorology Data Meteorology data was provided for each hour ofthe day for each month. The meteorology dataprovided includedtemperature and relative humidity averages for each hour ofa day for each month. Ramp Fraction The fractions oframp driving times were provided for restricted
access roadways
. Road Type Distribution The vehicle miles traveled (VMT) fraction for eachroad type is provided for each source type and road type
. Source Type The amount ofvehicles 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, ofthe 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 withrespect 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 Hourlytime aggregation was selected. Selection ofhourly time
3Level 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 ofEvaluation All12 months were selected for evaluation. Type ofDay of Weekdays and weekends were selected. Evaluation Hours ofEvaluation Starting and ending hours create a whole day (from 0-24 hours). Geographic Bounds Lancaster County was selected. Vehicles/Equipment: Appropriate combinations offuels 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 ofprimary 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. OutputEmission Detail Emission detail was selected viauser 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 ofthe submitted SIP MVEBs in accordance with the procedures listed in the January 2008 Conformity Regulations contained in 40 CFR part 93, 118(f) "Adequacyreview process for implementationplan submissions." EPA will be issuing anNPRfor a 30-day public commentperiod 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'spublic commentperiod, 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 NonattainmentAreas 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 ofthe Adequacy ofthe 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 conformitypurposes. We are using the evaluation criteria detailed inthe 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 ofthe MVEBs Contained in the Maintenance Plan for the Lancaster 1997 and 2006 

### PM2.s NAAQS NonattainmentAreas Transportation Conformity Review Criteria Rule 40 CFRPart 93, 93.118
93.102(b)(2)(iv) Have EPA and the State made a finding that NOx 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. ·

93.102(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) orAmmonia (NH3) as precursors to be a significant contributor to the mobile PM2.s emissions?

93.102(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 contributorto the PM mobile emissions?

593.118(e)(4)(i) Was the submitted revised Yes, the submitted plan endorsed by the maintenance plan was Governor (or his orher endorsed and submitted as a designee) and subjectto a SIP revision by the State public hearing? Governor's designee, the Acting Secretary, and a notice ofpublic hearing was
-' published inThe PatriotNews onMarch4, 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 implementationplan documentation provided to EPA, and was EPA's stated concerns, ifany, addressed?
93.118(e)(4)(iii) Was themotorvehicle Yes, the budgets are clearly emissions budget(s) clearly identified onpage 3 7 inthe identified and precisely maintenance plan. quantified?
93.118(e)(4)(iv) Is the motor vehicle EPAbelieves the budgets can emissions budget(s), when be declared adequate because considered together with all in conjunction withthe other other emissionreductions, 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 newMVEBs for demonstrations: explain and years 2017 and 2025. The document any changes to addition ofsafety margins to

6previously submitted budgets the MVEBs is consistent with and control measures; continued attainment. impacts onpoint and area source emissions; any changes to established safety margins (see Sec. 93.101 for definition); andreasons for the changes (including the basis for any changes related to emission factors or estimates ofvehicle miles traveled).

Sec. 93.118(e)(5) Did theyprovide and we Yes reviewpublic comments and the State's responses to those comments with the submitted control strategy SIP?



### VI. Findings
Based upon ourreview and evaluation ofthe MVEBs contained in PADEP's April30, 2014 submittal ofthe maintenance planto satisfythe requirements ofthe1997 and 2006 PM2

.s NAAQS, we find the MVEBs to be adequate for conformitypurposes and recommend that the MVEBs for the Lancaster 1997 and 2006 PM2.s NAAQS Nonattainment Areas be SIP approved.

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