SUBJECT:

FROM:

TO:

THRU: 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 PennsylvaniaPortion ofthe Philadelphia-Wilmington, PA-NJ-DE 1997 and 2006 Fine Particulate (PM2.s) National Ambient Air Quality Standard (NAAQS) Nonattainment Areas

Asrah Khadr, Environmental Engineer, Engineer in Training (EIT Office ofAir Program Planning (3AP30)

Administrative Record for the Adequacy Findings for the Motor Vehicle Emissions Budgets inthe Maintenance Plan for the PennsylvaniaPortion ofthe Philadelphia-Wilmington, PA-NJ-DE 1997 and 2006 PM2

.sNAAQS Nonattainment Areas 

# -rc. 

# · , z- =

-- 

# o fc)/11/11 Cristina



### Fe **rnc:'nd;z~te** Director Office ofAir Program Planning (3AP30)

I. Background

On January 5, 2005 (70 FR944), Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties were designated as the Pennsylvaniaportion ofPhiladelphia-Wilmington, PA-NJ-DE 1997 PM2.sNAAQS NonattainmentArea. OnNovember 13, 2009 (74 FR 58688), Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties were designated as nonattainment for the Pennsylvaniaportion ofthe Philadelphia-Wilmington, PA-NJ-DE 2006 PM2.s NAAQS Nonattainment Area. Additional background information aboutthe Pennsylvaniaportion of Philadelphia-Wilmington, PA-NJ-DE 1997 PM2.sNAAQS Nonattainment Areas is available in the notice ofproposed rulemaking (NPR) in this docket. On September 5, 2014, the Pennsylvania Department ofEnvironmental Protection (PADEP) formally submitted a State Implementation Plan (SIP) revision to satisfy the redesignation requirements ofthe Clean Air Act (CAA) for the 1997 and 2006 PM2.s NAAQS for the Pennsylvaniaportion ofthe Philadelphia-Wilmington, PANJ-DE 1997 and 2006 PM2.s NAAQS Nonattainment Areas.

II. Transportation Conformity Requirements

Under section 176(c) ofthe CAA, newtransportationplans, programs, and projects, such as the construction ofnewhighways, must "conform"to (i.e., be consistentwith) the part ofthe state's 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 ofthe SIP. This means that such actions will not cause or contribute to violations ofNAAQS; worsen the severity ofan existing

1violation; 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 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 Statepublichearing; (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 implementationplan 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 consistentwith and clearly related to the emissions inventory and the control measures inthe 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 MotorVehicle Emission Simulator (MOVES2010)

To runthe 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 MOVES2010 for Emission InventoryPreparation in State Implementation Plans and Transportation Conformity. This guidance document provides guidance ort the use ofthe MOVES model to develop inventories for SIPs as well as analysis ofemissions for transportation conformity determinations.

EPA carefully reviewedthe inputs into the model to ensure that they are representative ofeach respective parameter for the area. Table 1presents the inputparameters and the state's submittal for eachparameter. 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 MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity.

2Table 1. Review ofInputs for RunSpecs for years 2007, 2017, and 2025 for the Pennsylvania Portion ofthe Philadelphia-Wilmington, PA-NJ-DE 1997 and 2006 PM2.s NAAQS Nonattainment Areas

**Redesi~nation** Request Parameter State Submittal Age Distribution All source types were presented with respect to age (0-30 years), and 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 parameterincludes an input for alternative vehicle fuels and Technologies technologies, input ofthis parameter applies to areas that have vehicle fuels and technologies that are outside ofthe traditional inputs provided in the county datamanager. 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. 

## • ForFuel 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 ofthe day for each month. The meteorology dataprovided included temperature and relative humidity averages for eachhour ofa day for eachmonth. 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 providedfor each source type and road type. Source Type The amount ofvehicles for each source type are provided. Population Vehicle Type VMT 

## • The daily VMTfractions were provided for respective days (includes inputs for and source types. daily VMT fraction, 

# • The hourly VMT fractions were provided withrespect to hour hourly VMT fraction, ofthe day and source type. and monthly VMT 

## • The monthly VMTwas provided with respectto source type fraction) and month. Inspection/Maintenance The I/Mprograms were presented withrespect to source types and (I/M) Programs compliance factors as well as other data.

Table 2. RunSpec Reviews for the Pennsylvania Portion ofthe Philadelphia-Wilmington,

PA-NJ-DE 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 Level Hourly time aggregation was selected. Selection ofhourlytime aggregation level is acceptable for this analysis.

3Calendar Year Of The appropriate calendar year was selected. MOVES2010b can Evaluation model years 1990 and 1999-2050. Month ofEvaluation All 12 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 Bucks, Montgomery, Chester, Delaware, orPhiladelphia County
was selected. Vehicles/Equipment: On- Appropriate combinations offuels and source use types were Road Vehicle Equipment made. Road Type Selection included all necessary road types. Pollutants and Processes Nitrogen oxides (NOx), sulfur dioxide (S02), ammonia (NH3), volatile organic compounds (VOCs) total gaseous hydrocarbons, non-methane hydrocarbons and all forms ofprimary PM2

.swere selected, which is acceptable for this analysis. On-Road Retrofits N/A ROP N/A Output Database/Unit Mass units selected to be grams; energy units selected to be Selection million BritishThermal Units (BTU); distance units selected to be miles. Output Emission 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 CFRpart 93, 118(f) "Adequacyreviewprocess for implementation plan submissions." EPA will be issuing a notice ofproposedrulemaking (NPR) for a 30-daypublic 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

.sand 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 onthe proposed mobile budgets will be addressed in

an amendment to this TSD.

4Table 3. MVEBs Contained in the MaintenancePlan for the Pennsylvania Portion ofthe Philadelphia-

**Wilmin~ton,** PA-NJ-DE 1997 and 2006 PM2.s NAAQS NonattainmentAreas Year Motor Vehicle Emissions Mobile Vehicle Emissions Budget for PM2.s-Tons Per Budget for NOx-Tons Per Year Year 2017 1,679 37,922 2025 1,316 25,361

V. Evaluation ofthe Adequacy ofthe MVEBs in the Maintenance Plan for the Pennsylvania Portion ofthe Philadelphia-Wilmington, PA-NJ-DE 1997 and 2006 PM2.s NAAQS NonattainmentAreas

In this TSD, we are evaluating the MVEBs associated with the maintenance plan contained in the September 5, 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.

Table4. Adequacy ofthe MVEBs Contained in the Maintenance Plan for the Pennsylvania Portion ofthe Philadelphia-Wilmington,PA-NJ-DE 1997 and 2006 PM2.s NAAQS NonattainmentAreas Transportation Conformity Review Criteria Was the Criterion Rule Satisfied? IfYes How was 40 CFRPart93, 93.118 this Criteria Satisfied?

93.102(b)(2)(iv) Have EPA and the State Neither EPA nor the State made a finding thatNOx is has made such a finding.
an insignificant contributor to the direct mobile PM emissions?

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) or Ammonia (NH3) as precursors to be a significant contributorto the mobile PM2.s emissions?

93.102(b)(3) Has the EPA orthe State Neither EPA nor the State made a finding that re- has made such a finding. entrained road dust is a significant contributorto the



### 5PM mobile emissions?
93.118(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 subject to a SIP revision by the State public hearing? Governor's designee, the Acting Secretary, and a notice ofpublic hearing was published in the Bucks County Courier Times on May 8, 2014. 93.118(e)(4)(ii) Before the attainment Yes. Consultationhas 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 documentationprovided to EPA, and was EPA's stated concerns, ifany, addressed?
93.118(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly emissions budget(s) clearly identified onpage 3 9 in the 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, emissionreductions, they consistent with applicable demonstrate attainment for requirements for attainment years 2017 and 2025. demonstrations?
93.118(e)(4)(v) Is the motor vehicle EPA believes thatthe 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 inthe Plan?
93.118(e)(4)(vi) Revisions to previously Yes, the maintenance plan submitted attainment provides newMVEBs for demonstrations: explain and years 201 7 and 2025. The document any changes to addition ofsafety margins to

6previously submittedbudgets the MVEBs is consistent with and control measures; continued attainment. impacts onpoint and area source em1sswns; 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 ofvehicle miles traveled). 93.118(e)(5) Didthey provide and we Yes reviewpublic comments and the State'sresponses to those comments with the submitted control strategy SIP?



### VI. Findings

Based upon ourreview and evaluation ofthe MVEBs contained 

### in PADEP's September 5, 2014 submittal ofthe maintenance planto satisfy the requirements ofthe 1997 and 2006 PM2.s NAAQS, we find the MVEBsto be adequate for conformity purposes and recommend that the MVEBs for the Pennsylvaniaportion ofthe Philadelphia-Wilmington, PA-NJ-DE 1997 and 2006 PM2

.sNAAQS Nonattainment Areas be SIP approved.



### 7