UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105

Memorandum

To: Nogales, Arizona PM-10 SIP Final Action Approval Docket, Docket ID EPA-R09-OAR2012-0458

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 the 

August 2012 ADEQ Nogales PM-10 179B Attainment Plan.

In June 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 was endorsed by the 

Governor (or designee) and was 

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 provided 

a 30-day public comment period, and held a public hearing prior to the adoption of the Plan on 

June 21, 2012. Documentation accompanying the SIP 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 was 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 included proof of publication for notices of the ADEQ public 

hearing. Evidence was provided that the hearings 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 was developed through 

consultation with federal, state and 

local agencies; full 

implementation plan 

documentation was provided and 

EPA’s stated concerns, if any, 

were 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 response, ADEQ revised the MVEB to incorporate road construction dust, vehicle brake 

wear, and vehicle tire wear 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 

ADOT 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 motor vehicle emissions budget for 2011 is clearly identified and precisely quantified on 

page 48 of the 2012 Nogales Attainment Plan; see Table 7-1. This budget reflects federal 

motor vehicle control measures that were already implemented at the time the ADEQ adopted 

the 2012 Nogales SIP on August 24, 2012 and was 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), when considered 

together with all other emission 

sources, is consistent with 

applicable requirements 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 PM10 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 proposed to approve the RFP demonstration; see 77 FR 38400, (June 27, 

2012).

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 attainment of the 1987 24-

hour PM10 standard. This finding is based on review of Arizona’s CAA Section 179B

attainment 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 motor vehicle emissions budget for PM10 include emissionsfrom re-entrained road dust 

(paved and unpaved), road construction dust, and vehicle brake wear, tire wear, and exhaust 

emissions. See 2012 Nogales SIP, pages 47-48, and Table 7-1.

Sec. 

93.118(e)(4)(v)

The plan shows 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 sources 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 safety 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 regulations 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

ADEQ compiled public comments submitted during the June 21, 2012 public hearing and 

during the May to June 2012 and July to August 2012 public comment periods. Any written 

and verbal comments received during the public comment period and public hearing on the 

2012 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.