UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: November 7, 2013

SUBJECT: Technical Support Document for the Motor Vehicle Emissions Budgets for the

Lancaster 1997 8

- Hour Ozone Maintenance Area

FROM: Asrah Khadr, Environmental Engineer, EIT /s/

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND:

On November 19, 2012, the Pennsylva nia Department of Environmental Protection ( PA DEP) submitted a revision to the Commonwealth of Pennsylvania’s (Pennsylvania) State Implementation Plan (SIP). The SIP revision consists of updated Motor Vehicle Emissions Budgets (MVEBs) for nitrogen oxides (NO

x ) and volatile organic compounds (VOCs) for the

1997 8

- Hour Ozone National Ambient Air Quality Standard (NAAQS). The SIP revision also includes an updated point source inventory for NO

x and VOCs. The updated budgets were calculated using the Environm ental Protection Agency’s (EPA) Motor Vehicle Emission Simulator model (MOVES2010a). The intention of the revised SIP is to replace the approved

MOBILE6.2

- based MVEBs with budgets based on MOVES2010a and to ensure that the SIP revision still provides for attainment of the 1997 8

- Hour Ozone NAAQS.

On July 18, 1997 (62 FR 38856), EPA established the 1997 8

- Hour Ozone NAAQS. On April 30, 2004 (69 FR 23860), Lancaster County was designated as nonattainment for the 1997 8

- Hour Ozone NAAQS. On S eptember 20, 2006, PA DEP submitted a SIP revision which consisted of a maintenance plan, a 2002 base year inventory and MVEBs for transportation conformity purposes. On November 8, 2006, PA DEP supplemented their September 20, 2006 submittal. On July 6, 2007 (72 F R 36889), EPA approved the SIP revision as well as the redesignation request made by PA DEP and Lancaster County was redesignated as a maintenance area. 1

1 These are not the only rulemakings published by EPA for the Lancaster County 1997 8

- Hour Ozone NAAQS SIP. On August 8, 2013 (78 FR 48323), EPA published a direct final rulemaking notice to approve this SIP revision. But

due to a numerical data er ror in EPA’s publication, EPA withdrew the rulemaking. On September 26, 2013 (78 FR 59258) EPA withdrew the direct final rulemaking notice. On September 26, 2013 (78 FR 59317), EPA also withdrew the related proposed rulemaking notice. The numerical dat a error has been corrected in this rulemaking.2

The MVEBs are a mobile source inventory to which an area’s transportation improvement program (TIP) a nd long range transportation plan must conform. Conformity to MVEBs in a SIP means that transportation activities will not produce new air quality violations, worsen existing violations, or delay timely attainment of the NAAQS or any required interim mile stones. This January 31, 2013 SIP revision submittal provides updated MVEBs for NO

x and VOCs. The budgets were developed utilizing MOVES2010a. On March 2, 2010 (75 FR 9411), EPA published a notice of availability for the MOVES2010 model for use in SIP s ubmissions and started a two year grace period for the use of MOVES2010 for transportation conformity purposes. The two year grace period was scheduled to end on March 2, 2012. On February 27, 2012 (77 FR 11394), EPA published a final rule extending the grace period another year to March 2, 2013 to ensure adequate time for affected parties to adopt the model. On September 8, 2010, EPA released MOVES2010a, which is a minor update to MOVES2010. Pennsylvania utilized MOVES2010a in its November 19, 2012 SIP revision. MOVES2010a was used in order to ensure that the nonattainment area can demonstrate transportation conformity using

MOVES2010a once the 3

- year conformity grace period expires. Pennsylvania updated their

SIP

- approved MVEBs with the use of MOVES2 010a. The budgets were previously developed with the use of the Highway Mobile Source Emission Factor Model (MOBILE6.2).

MOBILE6.2 is a motor vehicle emissions factor model that was utilized for SIPs and transportation conformity. MOBILE6.2 was made available for use in SIPs and transportation conformity purposes on May 19, 2004 (69 FR 28830). MOBILE6.2 was merely an update to MOBILE6 that added the ability for the program to estimate direct exhaust and brake and tire wear particulate matter emission factors as well as exhaust emission factors for particulate matter

precursors.

MOVES2010 improves upon MOBILE6.2 in many aspects. MOVES2010 utilizes a plethora of vehicle data that has been made available since the release of MOBILE6.2; this vehicle da ta
includes emissions data for different kinds of vehicles. The new data has allowed EPA to better

understand on

- road mobile source emissions and their contribution to emissions inventories as well as how effective different control strategies are. The M OVES2010 model offers more flexibility because the program has a database design that allows easier organization of input and output files and data. The database design of the MOVES2010 model allows much easier update of input data upon the release of new data. MOVES2010 also accounts for temperature and speed variations and allows the model to run at a higher resolution which allows for the input of more activity data.

Under section 176(c) of the Clean Air Act (CAA), any federal action is required to c onform to the applicable SIP. A part of this requirement for conformity is transportation conformity. Transportation conformity requires that any federally funded transportation plan, program or project conform to the applicable SIP for the transportatio n

- related criteria pollutants (ozone, carbon monoxide, fine particulate matter (PM 2.5 ), coarse particulate matter (PM 10 ), and nitrogen dioxide). The transportation conformity rules can be found at 40 CFR 93, Subpart A. One of the requirements found under 40 CFR 93, Subpart A is that any transportation plan, TIP or project not in a conforming TIP must conform to the MVEBs in the applicable SIP. In order for the MVEBs in a SIP to be used to determine conformity of a transportation plan, TIP or project, the MVEBs must be either approved or deemed adequate. In this case, the budgets must be3

approved because this SIP revisio n is revising already approved budgets. However, in reviewing such a submitted SIP it remains useful to apply the criteria used to make an adequacy finding. The requirements for adequacy are set forth in 40 CFR 93.118(e)(4)(i)

- (vi). The criteria for

ade quacy and how they are met by the Pennsylvania submittal are found below in Table 1.

Table 1. Adequacy Criteria for the Lancaster Maintenance Area

Criterion Submittal

(i) The submitted control strategy implementation plan

revision or maintenance plan was endorsed by the Governor (or his or her designee) and was subject to a State public hearing;  Letter addressed to Shawn M. Garvin, Regional Administrator, EPA Region

III from Michael L. K rancer, Secretary, PA DEP

.

 Public hearing documents were

submi tted

. (ii) Before the control strategy implementation plan or maintenance plan was submitted to EPA, 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;  N/A. T his revision does not accompany a control strategy implementation plan or maintenance plan

.

(iii) The motor vehicle emissions budget(s) is clearly identified and precisely quantified;  Appendix C

- 2 of the submittal provides detailed emission summary

tables

. (iv) The motor vehicle emissions budget(s), when considered together with all other emissions sources, is consistent with applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given implementation plan submission);  Maintenance plan for Lancaster County was already approved on July
6, 2007 ( 72 FR 36889) , no changes
to area and nonroad source emissions, point source emissions were updated

.

 Lancaster County continues to attain

the 1997 8

- Hr Ozone NAAQS as shown by the design value obtained

from 2009

- 2011 data

.

 Update of point source emissions

shows less emissions than those predicted in the maintenance plan

. (v) The motor vehicle emissions budget(s) is consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan revision or maintenance plan; and  The SIP revision shows no change in any control measures in the

pre viously submitted maintenance plan.

(vi) Revisions to previously submitted control strategy implementation plans or 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 (see § 93.101 for definition); and reasons for the changes (including the basis for any changes related to emission  Changes in MVEBs are clearly documented and explained in the

submittal. The higher emissions are

due to the use of MOVES2010a

which is a more accurate emissions

model and is based on more recent

data on vehicle emissions than4

factors or estimates of vehicle miles traveled). MOBILE6.2 . Update of point source emissions and addition of small safety margin are well explained.

B. STATE SUBMITTAL:

On November 19, 2012, PA DEP submitted a SIP revision which included an update to the

MVEBs for NO

x and VOCs for the years 2009 (interim year) and 2018 (maintenance year). The updated MVEBs were produced using the MOVES2010a model. The MVEBs were developed with guidance from the following EPA guidance documents: Policy Guidance on the Use of MOVES2010 for SIP Development, Transportation Conformity, and Other Purposes and Technical Guidance on the Use of MOVES2010 for Emission Invent ory Preparation in State Implementation Plans and Transportation Conformity. The submittal also includes an updated point source emissions inventory.

I. Methodology for Developing Data for Use in MOVES2010a

PA DEP utilized MOVES2010a to provide emissi ons rates for emissions of NO

x and VOCs. PPSUITE is a program that was utilized for the processing of highway information and to provide input files that are usable by the MOVES2010a model. PPSUITE was run utilizing CENTRAL; CENTRAL is a program that pro vides a process for the proper function of PPSUITE and MOVES2010a. The MVEBs were developed for NOx and VOCs since they are the two biggest contributors to the formation of ozone.

In PPSUITE, the Pennsylvania Department of Transportation (PennDOT) Roadw ay Management System (RMS) data among other data was utilized to produce vehicle miles traveled (VMT) estimates. The VMT produced via PPSUITE was then imported into the county data manager (CDM) in MOVES2010a. Since VOCs and NOx emissions differ with res pect to travel speed, travel speed is utilized as an input in MOVES2010a. To develop an array of travel speeds, PPSUITE was utilized to develop vehicle hours of travel (VHT) by speed bin file which allows for the distribution of speeds across links into MO VES2010a speed bins. The travel speed calculations were completed with guidance from Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity

.

Road type distribution was an other traffic input for MOVES2010a. Road type distribution was developed with the use of PPSUITE. The five different road types utilized by MOVES2010a are off network, rural restricted access, rural unrestricted access, urban restricted access and urban unrestricted access. In addition, ramps are not included in road type distribution so it is assumed that 8% of the roadway VHT is ramp VHT. This traffic input assumption is consistent with EPA’s technical guidance.

Before RMS data is utilized by PPSUITE to develop various traffic inputs, several adjustments must be made. The RMS VMT is adjusted to meet the Highway Performance Monitoring System (HPMS) VMT totals. HPMS VMT utilizes snapshots of RMS VMT to satisfy rep orting5

requirements established by the Federal Highway Administration (FHWA). To make this adjustment, adjustment factors were calculated and utilized.

Adjustments to average annual daily traffic (AADT) were completed because calculations for

ozone prec ursors are based on a summer weekday, since that is when ozone formation tends to be the greatest. The RMS AADT volumes are adjusted by the use of a seasonal factor that was developed by PennDOT’s Bureau of Planning and Research (BPR) to produce July traf fic volumes. The RMS data was also adjusted for differences in hourly traffic volumes. The 24

- hour pattern data provided to PPSUITE allowed PPSUITE to provide roadway segment volumes by the hour. The 24

- hour pattern data was obtained from PennDOT’s PBR.

Traffic volume forecasts had to be applied to estimate future emissions from vehicles. The growth rates utilized for these forecasts are the PennDOT PBR growth rate forecasting system, the regional travel model and any applicable Marcellus Shale related activity growth. Additionally, county specific growth rates were utilized from a 2005 PennDOT report titled

Statistical Evaluation of Projected Traffic Growth, Traffic Growth Forecasting System: Final Report, March 14, 2005

.

MOVES2010a utilizes 13 veh icle source types. Since HPMS utilizes different categories for vehicle types, the RMS traffic volumes were disaggregated to the 13 vehicle source types which were then combined into the 6 HPMS vehicle classes. Vehicle type data input into PPSUITE is

use d to divide the roadway segment volumes with respect to the MOVES2010a source types. The source types are split into percentages among the 24

- hours of the day. The vehicle source type percentages are then utilized to adjust vehicle speeds in response to trucks.

Vehicle population is also another important input for MOVES2010a. Vehicle population is input into MOVES2010a with respect to the 13 vehicle source types utilized by the model. County level vehicle registration data is utilized for light duty v ehicles and school buses. Transit bus data is obtained from PennDOT’s National Transit Database (NTD); it is utilized to estimate county level transit bus counts. Heavy duty vehicle population data is estimated by utilizing source type VMT and vehicle sou rce and pattern data are utilized. Vehicle age is input into the model as well. The vehicle age is input into the model as a percentage of vehicles of the fleet between ages 0 and 31.

Outside of vehicle and roadway data, environmental variables are uti lized as inputs since evaporative emissions are dependent on the surrounding temperatures. The environmental variables used included hourly temperatures and humidity values. The temperatures were retrieved by Weather Bank Inc. Humidity values were produce d according to EPA’s technical guidance. Minimum and maximum monthly temperatures were converted to hourly temperatures using EPA converters in the MOVES2010a model.

Fuel parameters were also input since different fuels produce different emissions. The

M OVES2010a default fuel formulation and supply data was utilized and updated with local volumetric fuel property data. Gasohol market penetration and RVP values were updated at the county level. Other fuel parameters were obtained through the MOVES2010a de fault data.6

Refueling emissions were not included as an input because Pennsylvania provides the refueling emissions in its area source inventory; hence it is not required for the production of MVEBs. Additionally, MOVES2010a also includes input parameter s for inspection and maintenance (I/M) programs. The inputs for the I/M program include: program start year, stringency level, first and last model years subject to the program, waiver rates, compliance rates, program type and effectiveness, frequency of inspection, vehicle type coverage and test type. The defaults for an I/M program in MOVES2010a were modified to accurately represent the I/M program for Lancaster County.

II. Running MOVES2010a

As stated in Section I, the data utilized to run MOVES201 0a is a mixture of local and national data. Local data is utilized for all inputs that have significant impact on the emissions rates that are calculated by MOVES2010a. The local data utilized as inputs for MOVES2010a is categorized into five categories which include: traffic data, vehicle descriptions, fuel parameters, I/M programs, and environmental variables. The inputs for traffic data include vehicle type VMT, vehicle population, VMT fractions, road type distribution, and ramp fractions. The inputs for vehicle descriptions include vehicle type mix, vehicle age distribution, average speeds and hourly distributions of different vehicles. The inputs for fuel parameters include RVP, sulfur level and ethanol volume. The inputs for I/M programs include s tart and model years, the frequency of tests, test standards, source types, stringency of tests, the waiver rate, and compliance rates. The inputs for environmental variables include hourly temperatures and humidity.

MOVES2010a inputs that were prepared by PPSUITE included vehicle type VMT, vehicle population, VMT fractions, average speed distributions, road type distribution and ramp fractions. These files were input into the MOVES2010a county data importer. Additional non

PPSUITE inputs inclu ded fuel and vehicle ages, as well as temperatures and I/M programs. The county data importer was run in batch mode. Running the county data importer converts input files into a MYSQL format which is accepted by MOVES2010a. Afterwards, a MOVES run speci fication file (.mrs) was created. This file includes options and different data locations for the execution of the model. MOVES2010a can be executed to provide an emissions rate or an emissions inventory. In this submittal, MOVES2010a was executed to pr ovide an emissions inventory. The emissions estimates of VOCs and NO

x produced for the years 2004, 2009 and 2018 by MOVES2010a are provided in Table 2. The emissions estimates are provided in tons per day (tpd); also provided in Table 2 is the comparison between the emissions produced by MOBILE6.2 and MOVES2010a. The revised MVEBs produced with MOVES2010a are found below in Table 3. After reviewing this submittal, EPA concurs with Pennsylvania that even though the emissions results produced by MOVES2010 a are greater than those previously calculated using MOBILE6.2. EPA’s review of the SIP revision indicates these higher emissions result from improvements in the MOVES model rather than from unanticipated growth or changes in control measures. The MOVES r esults are more accurate estimates of the emissions that actually occurred in 2002 and 2009, rather than an indication that emissions are increasing. More importantly, Lancaster county attained the 1997 8

- Hour Ozone NAAQS and was redesignated to a mainten ance area on July 6, 2007 (72 FR 36889). Lancaster County continues7

to attain the 1997 8

- Hour Ozone NAAQS as shown by its 2009

- 2011 design values. The two air quality monitors in Lancaster County are providing design values of 76 parts per million (ppm) and 77 ppm, which are below the 1997 8

- Hour Ozone NAAQS of 0.08 ppm. Therefore, EPA finds this update to the MVEBs does not interfere with Lancaster County’s ability to maintain its

attainment of the1997 8

- Hour Ozone NAAQS.

Table 2. Summary of Motor Ve hicle Emissions for the Lancaster

Maintenance Area

Model MOBILE6.2 MOVES2010a

Year 2004 2009 2018 2004 2009 2018
VOCs (tpd) 19.75 14.33 7.77 16.41 14.29 8.14

NO

x (tpd) 32.33 22.32 8.99 42.10 33.18 18.57

Table 3. Revised MVEBs

for the Lancaster

Maintenance Area

Year 2009 2018
VOCs (tpd) 14.29 10.14

NO

x (tpd) 35.18 20.57

III. Revision of Point Source Emissions

In addition to revising the MVEBs for the Lancaster County Maintenance Area, PA DEP submitted revisions to its inventory of point source emissions. The change accounts for a decrease in point source emissions. The point source emissions were projected for the 2009 interim year in the 2006 maintenance plan SIP submittal and the actua l emissions were less than the projected emissions at the time. Company

- reported point source emissions were utilized to update the 2009 interim year inventory. The previously estimated and the actual interim year inventories are provided in Table 4. The update to the 2018 maintenance year was produced by linear extrapolation between the point source emissions for 2007 and 2020. These point source emissions were produced by the Mid

- Atlantic Regional Air Management Association, Inc. (MARAMA). The emissio ns data for the years 2007 and 2020 were obtained from the

MARAMA document titled MARAMA 2007, 2017, and 2020 Baseline and Projected
Inventories, Version 3 . The emissions provided by this MARAMA document utilize the most recent growth assumptions, which a re more recent than the growth assumptions utilized by

PA DEP in the Lancaster County Maintenance Plan that was submitted in 2006. The main reason the point source emissions were updated, is because some growth factors decreased while others increased, but overall there is a decrease in projected emissions from the previous 2018 inventory and the 2018 inventory in this submittal. The previously submitted 2018 point source emissions inventory currently in the maintenance plan and the updated 2018 point source emissions inventory are provided below in Table 5. Th e update to the point source emissions has been reviewed and found to be reasonable, an additional technical support document in this8

docket addresses the revision of the point source emissions. The document is titled Technical Support Document for Emissio ns Inventories for the State Implementation Plan Revision: NO

x and VOC Motor Vehicle Emission Budget Revision

Based on MOVES2010a.

Table 4. 2009 Point Source

Emissions for the Lancaster

Maintenance Area

Estimated Actual
VOCs (tpd) 8.7 5.5

NO

x ( tpd) 4.1 3.2

Table 5. 2018 Point Source Emissions for

the Lancaster Maintenance Area

Maintenance Plan Updated
VOCs (tpd) 11 7.7

NO

x (tpd) 4.6 3.6

IV. Safety Margins

Since there is a significant difference between the projected emissions for the maintenance year and the attainment year a small portion of that difference was made into a safety margin. A 2 tpd safety margin was added for VOCs and NO

x emissions for the 20 18 MVEBs and a 2 tpd safety margin was added for NO

x for the 2009 MVEBs. The differences between the 2004 attainment year and the 2009 interim year and 2018 maintenance year for NO

x are found below in Table 6.

The differences between the 2004 attainment year and the 2009 interim year and 2018 maintenance year for VOCs are found below in Table 7. Tables 6 and 7 show that there are decreases which are significant in some categories between the attainment, interim and maintenance years. Because the 2009 and 2018 emissions are less than the 2004 attainment year emissions, the excess emissions can be allocated to the MVEBs while the area can continue to

attain the 1997 8

- Hour Ozone NAAQS.

Table 6

. NOx Emissions and Differences for Years 2004, 2009 and

2018 for the Lancaster Maintenance Area
Category 2004 2009 2004

- 2009 2018 2004

- 2018
Point (tpd) 3.89 3.2 0.79 3.6 0.29
Area (tpd) 2.6 2.8

- 0.2 2.9

- 0.3
Nonroad (tpd) 13.2 10.8 2.4 6.8 6.4

Mobile (tpd) 42.1 33.18 8.92 18.57 23.53
Total (tpd) 61.79 49.98 11.91 31.87 29.929

Table 7. VOCs Emissions and Differences for Years 2004, 2009 &

2018
Category 2004 2009 2004

- 2009 2018 2004

- 2018
Point (tpd) 8.1 5.5 2.6 7.74 0.36
Area (tpd) 24.4 24.2 0.2 27.2

- 2.8
Nonroad (tpd) 17.3 15 2.3 11.9 5.4
Mobile (tpd) 16.41 14.29 2.12 8.14 8.27
Total (tpd) 66.21 58.99 7.22 54.98 11.23

C. EPA EVALUATION AND CONCLUSION:

EPA thoroughly evaluated the submittal made by Pe nnsylvania through PA DEP. Our detailed review has led us to conclude that the development methodology of the MVEBs is consistent with applicable guidance documents intended to guide the development of on

- road inventories and MVEBs. We also reviewed the MVEBs using the adequacy criteri a set forth in 40 CFR 93.118(e)(4)(i)

- (vi), and as documented above we found that the budgets meet all of the adequacy criteria. Based on the results of our in depth review of the SIP revision, the area’s

continued attainment of the 1997 8

- Hour Ozone NAA QS and the results of our review of the MVEBs using the adequacy criteria in the transportation conformity rule, EPA is proposing to approve the SIP revision.