**UNITED STA TES ENVIRONMENTA**  **L PROTECTION A GENCY** 

**REGION IX 75 Hawthorne Street**  **San Francisco, CA**

**94105**



### Memorandum To: Nogales , Arizona PM

- 10 SIP Final Action Approval Docket, Docket ID EPA
- R09
- OAR
2012
- 0458 From: Jerry

Wamsley , Air Planning Office, EPA Region 9 Date: August 24, 2012 RE: Adequacy

documentation for Nogales PM

- 10 MVEBs in August 2012 ADEQ Nogales PM
- 10 179B State Implementation Plan Attached to this memorandum is the adequacy documentation for the Nogales PM

- 10 MVEB in th e August 2012 ADEQ Nogales PM

- 10 179B Attainment Plan. InJune 2012, Wienke Tax provided an adequacy review of the May

2012 proposed Nogales PM

- 10 State Implementation Plan. Portions of that information are incorporated here for reference and continuity
.

## Table 1. **Evaluation of the Motor Vehicle Emissions Budget in the 2012 Nogales SIP August**  **2012 (reviewed by Jerry Wamsley)**  Adequacy Review Criteria (40 CFR part 93) Is Criterion Satisfied? Reference in SIP Document/Comments

Sec. 93.118(e)(4)(i) The plan w as endorsed by the

Governor (or designee) and w as subject to a public hearing. Y ADEQ has satisfied applicable statutory and regulatory requirements for reasonable public notice and hearing prior to adoption and submittal of the State Implementation Plan

- Nogales PM10 Nonattainment Area , May 2012 (“2012 Nogales Attainment Plan”) . The State p rovided a 30
- day public comment period , and held a public hearing prior to the adoption of the Plan on June 21, 2012 . Do cumentation accompanying the SI P describes a public and agency outreach effort. See, e.g., http://www.azdeq.gov/environ/air/plan/notmeet .html#nog and http://www.azdeq.gov/download/calendar/051612pn1.pdf
. As result of comments received on the May 2012, 2012 Nogales Attainment Plan , ADEQ revised the MVEB in the 2012 Nogales Attainment Plan and provided a second 30 day comment period, starting July 24, 2012. Consistent with state and federal statute, ADEQ offered to hold a public hearing if one w as requested by the August 15, 2012. ADEQ did not receive a request for a public hearing, so no hearing was held. Both of the SIP submittal include d proof of publication for notices of the ADEQ public hearing . Evidence was provided that the hearing s were properly noticed. See the plan appendices within each submittal. See appendix K of the submitted plan.

## Table 1. **Evaluation of the Motor Vehicle Emissions Budget in the 2012 Nogales SIP August**  **2012 (reviewed by Jerry Wamsley)**  Adequacy Review Criteria (40 CFR part 93) Is Criterion Satisfied? Reference in SIP Document/Comments

Sec. 93.118(e)(4)(ii) The plan w as developed through

consultation with federal, state and local agencies; full implementation plan documentation was provided and EPA’s stated concerns, if any, we re addressed. Y Consultation with federal, state and local agencies was undertaken; this consultation included EPA , ADEQ, and ADOT in March and April of 2012
. EPA received several draft versions of the 2012 Nogales Attainment Plan and provided comments. As part of EPA’s review of the May 2012 draft plan, we recommended that road construction dust be included within the MVEB. See 77 FR 38418

- 38419; ( June 27, 2012); and, our letter from Lisa Hanf, EPA to Eric Massey, ADEQ, dated June 21, 2012. In resp onse, ADEQ revised the MVEB to incorporate road construction dust, vehicle brake we ar, and vehicle tire w ear emissions. These changes to the MVEB were the subject of the 30
- day public comment period beginning July 24, 2012. ADEQ consulted with EPA and AD OT as part of revising this MVEB. EPA concerns were addressed in the final SIP that was adopted and submitted. Sec. 93.118(e)(4)(iii) The motor vehicle emission

budgets are clearly identified and precisely quantified. Y The mo tor vehicle emissions budget for 2011 is clearly identi fied and precisely quantified on page 48 of the 2012 Nogales Attainment Plan; see Table 7

- 1
. Th is budget reflect s federal mo tor vehicle control measures that were alre ady implemented at the time th e ADEQ adopted the 2012 Nogales SIP on August 24, 2012 and wa s developed using EPA’s MOVES model.

## Table 1. **Evaluation of the Motor Vehicle Emissions Budget in the 2012 Nogales SIP August**  **2012 (reviewed by Jerry Wamsley)**  Adequacy Review Criteria (40 CFR part 93) Is Criterion Satisfied? Reference in SIP Document/Comments

Sec. 93.118(e)(4)(iv) The motor vehicle emissions

budget(s), w

hen considered together with all other emission sources, is consistent with applicable require ments for reasonable further progress and attainment. Y EPA has concluded that the budget for the year 2011 when considered together with all other emission sources is consistent with the requirement to demonstrate reasonable further progress for the 1987 24

- hour PM 10 standard. This finding is based on a review of the RFP demonstration in the 2012 Nogales Attainment Plan. As documented in the notice of proposed rule

- making , EPA is propos ed to approve the RFP demonstration ; see 77 FR 38400, (June 27, 2012)
. EPA has concluded th at the budget for the year 2011 when considered together with all other emission sources is consistent with the requirement to demonstrate attainment of the 198 7 24
- hour PM 10 standard . This finding is based on review of Ar izona’s CAA Section 179B attai nment demonstration in the 2012 Nogales Attainment Plan . As documented in the Federal Register notice , EPA proposed to approve Arizona’s CAA section 179B attainment demonstration ; see 77 FR 38400, (June 27, 2012)
. The mo tor vehicle emissions budget for PM 10 include emissions from re

- entrained road dust (paved and unpaved) , road construction dust, and vehicle brake wear, tire w ear, and exhaust emissions. See 2012 Nogales SIP, pages 47

- 48, and Table 7

- 1.
Sec. 93.118(e) (4)(v) The plan show s a clear

relationship among the emissions budget(s), control measures and the total emissions inventory. Y The emission inventories for all point, area, and mobile so urces within the Nogales nonattainment area are contained in Chapter 3, pages 13
- 15, and Appendix B of ADEQ’s 2012 Nogales Attainment Plan
. The relationship of the emission inventory to control measures and the reductions from the measures are described in Chapter 5

– Control Measures of the 2012 Nogales Attainment Plan.

## Table 1. **Evaluation of the Motor Vehicle Emissions Budget in the 2012 Nogales SIP August**  **2012 (reviewed by Jerry Wamsley)**  Adequacy Review Criteria (40 CFR part 93) Is Criterion Satisfied? Reference in SIP Document/Comments

Sec. 93.118(e)(4)(vi) Revisions to previously submitted

control strategy or maintenance plans explain and document any changes to any previous submitted budgets and control measures; impacts on point and area source emissions; any changes to established sa fety margins (see §93.101 for definition), and reasons for the changes (including the basis for any changes to emission factors or estimates of vehicle miles traveled). Y On June 14, 1993 

### , ADEQ submitted the “Final State Implementation Plan for the Nogales PM10 Nonattainment Area.” For the document please see the following URL <http://www.azdeq.gov/environ/air/plan/download/nogpm10sip_061993.pdf> The 1993 SIP did not contain motor vehicle emissions budgets, as EPA had not promulgated the conformity regul ations required by the 1990 Clean Air Act Amendments in 1993. So while the 2012 Nogales SIP revises and updates the 1993 Nogales SIP, it did not update or revise any budget for conformity purposes.

Sec. 93.118(e)(5) EPA has reviewed the State’s

compilation of public comments and response to comments that are required to be submitted with any implementation plan. Y AD EQ compile d public comments submitted during the June 2 1, 20 12 public hearing and during the May to June 2012 and July to August 201 2 public comment period s . Any wr itten and verbal comments received during the public comment period and public hearing on the 201 2 Nogales Attainment Plan were submitted with the final SIP documents ; see appendix K of the submitted plan
. EPA will review any comments that ADEQ receives on the SIP and ADEQ’s responses, and will take into account comments that substantively change the level of the budgets or affect our adequacy finding.