UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 8 

Ref: 8P-AR 

Bryce Bird, Director 

Utah Division of Air Quality 

P. 0 . Box 144820 

Salt Lake City, UT 84114-4820 

Dear Mr. Bird: 

1595 Wynkoop Street 

DENVER, CO 80202-1129 

Phone 800-227-8917 

http://www.epa.gov/region08 

MAR 2 4 2015 

On March 16, 2015, EPA received a letter dated March 9, 2015, from Governor Herbert which submitted 

the State Implementation Plan revisions "Utah Air Quality Rule R307-3 l 1; Utah County Trading of 

Emission Budgets for Transportation Conformity." In addition, we received your letter, dated March 11, 

2015, which provided the necessary administrative documentation to support the Governor's submittal. 

We have determined that these submitted revisions to the Utah State Implementation Plan are 

administratively and technically complete with respect to the provisions of section 110 of the Clean Air 

Act and the regulatory provisions in 40 CFR 51 Appendix V. We are now reviewing the submission to 

prepare a Notice of Proposed Rulemaking which will evaluate whether the state's submission can be 

approved. 

If members of your staff have any questions, please have them contact Tim Russ of my staff at 303-312-

6479 or email at russ.tim@epa.gov. 

WJ 

Carl 

Air Program 

Daly, Direc~ 

@ Printed on Recycled Paper 

Completeness Determination 

Completed by: Tim Russ, Air Program, USEP A, Region 8 

Date: March 16, 2015 

40 CFR 51 APPENDIX V CRITERIA 

2.1 Administrative Materials 

(a) A formal letter of submittal from 

the Governor or his designee, 

requesting EPA approval of the plan or 

revision thereof (hereafter "the 

plan"). 

(b) Evidence that the State has 

adopted the plan in the State code or 

body of regulations; or issued the 

permit, order, consent agreement 

(hereafter "document") in final form. 

That evidence shall include the date 

of adoption or final issuance as well 

as the effective date of the plan, if 

different from the adoption/issuance 

date. 

(c) Evidence that the State has the 

necessary legal authority under State 

law to adopt and implement the plan. 

(d) A copy of the actual regulation, 

or document submitted for approval and 

incorporation by reference into the 

plan, including indication of the 

changes made to the existing approved 

plan, where applicable. The submittal 

shall be a copy of the official State 

regulation/document signed, stamped, 

dated by the appropriate State 

official indicating that it is fully 

enforceable by the State. The 

effective date of the 

regulation/document shall, whenever 

possible, be indicated in the document 

itself. 

(e) Evidence that the State followed 

all of the procedural requirements of 

the State's laws and constitution in 

conducting and completing the 

adoption/issuance of the plan. 

SUBMITTAL ITEM 

Utah State Implementation Plan Approval Request; R307-

311, Utah County Trading of Emission Budgets for 

Transportation Conformity, as adopted by the Utah Air 

Quality Board (UAQB) on March 4, 2015. 

Submittal letter dated March 9, 2015 from Gary R. 

Herbert, Governor of Utah and Administrative Documents 

as submitted by a letter dated March 11, 2015 by Bryce 

Bird, Director, Utah Division of Air Quality (UDAQ), 

Utah Department of Environmental Quality (UDEQ) . 

The UAQB adopted the revisions to R307-311, Utah County 

Trading of Emission Budgets for Transportation 

Conformity, on March 4, 2015. The revisions became 

State effective on March 5, 2015. 

The State's legal authority is provided under the tab 

"CODES" of the Administrative Documents submi ttal. The 

CODES tab provides copies of "Title 19 Environmental 

Quality Code, Chapter 2, Air Conservation Act" and 

"Rl5, Administrative Services, Administrative Rules." 

The State's submittal contained the following 

documents: 

A.) 12/04/2014 version of the proposed revisions (new 

language shown) of the R307-311, Utah County Trading of 

Emission Budgets for Transportation Conformity. EPA 

notes that the Technical Support Document (TSD) was 

also proposed on January 12, 2015 and the public 

comment period was extended to February 12, 2015 . 

B.) 3/5/15 Effective Rule and TSD were provided with 

submittal. 

Effective date does not appear directly in the final 

version of the document itself, but the State provided 

documentation that the final version of the revisions 

became State effective on March 5, 2015. 

The "Certification Page" document is signed by Mark W. 

Berger, Rules Coordinator for the Utah Division of Air 

Quality, that all necessary State procedures were 

followed. The certification page is signed as of March 

11, 2015. 
40 CFR 51 APPENDIX V CRITERIA 

(f) Evidence that public notice was 

given of the proposed change 

consistent with procedures approved by 

EPA, including the date of publication 

of such notice. 

(g) Certification that public 

hearings(s) were held in accordance 

with the information provided in the 

public notice and the State's laws and 

constitution, if applicable. 

(h) Compilation of public comments 

and the State's response thereto . 

2.2 Technical Support 

(a) Identification of all regulated 

pollutants affected by the plan. 

(b) Identification of the locations 

of affected sources including the EPA 

attainment/ nonattainment designation 

of the locations and the status of the 

attainment plan for the affected 

areas (s) . 

(c) Quantification of the changes in 

plan allowable emissions from the 

affected sources; estimates of 

changes in current actual emission 

from affected sources or, where 

appropriate, quantification of changes 

in actual emission from affected 

sources through calculations of the 

differences between certain baseline 

levels and allowable emissions 

anticipated as a result of the 

revision. 

SUBMITTAL ITEM 

Evidence was provided, in the Administrative Documents , 

of the Public Notice as was provided in Utah State 

Bulletin dated January 1, 2015. 

The Administrative Documents state that on December 4, 

2014, the UAQB proposed for public comment the 

revisions to R307-311, Utah County Trading of Emission 

Budgets for Transportation Conformity. The 

Administrative Documents state that a public comment 

period was held from January 1, 2015 to February 12, 

2015. The only comments received were from EPA Region 

8 dated February 12, 2015. 

The Administrative Documents state that the public 

comments from EPA Region 8 only addressed concerns with 

the TSD and not R307-311. The EPA comments were 

addressed by the UDAQ in a memorandum, dated February 

19, 2015, from Bryce Bird, UDAQ, to the UAQB. 

The TSD was proposed for public comment from January 

12, 2015 to February 12, 2015 . The final TSD was 

provided with the Administrative Documentation for the 

effective rule. 

In SIP revision Utah Air Quality Rule R307-311 

addresses PM1o and NOx. The TSD addresses PM10 and NOx. 

For purposes of CAA section 110(1), the TSD also 

addresses PM2.s , CO, and N02. 

Locations of sources (vehicles) affected by R307-311 

are in Utah County, UT. The SIP revision is designed 

to address trading of PM10 and NOx Motor Vehicle 

Emission Budgets (MVEB) for purposes of Transportation 

Conformity. R307-311 was prepared for use by the 

Metropolitan Planning Organization (MPO), which is 

Mountainland Association of Governments (MAG) ,for use 

in transportation conformity determinations. The Utah 

County PM10 element of the SIP was last updated by EPA 

on 12/23/2002 (67 FR 78181) with approved revisions to 

the nonattainment area's plan. 

The Governor's March 9, 2015 SIP revis ion submittal and 

the March 11, 2015 Administrative Documents submittals 

identified the trading ratios for PM10 to NOx . The TSO 

provided the necessary information for the derivation 

of the trading ratios and an evaluation of the 

potential effects on other pollutants. 
40 CFR 51 APPENDIX V CRITERIA 

(d) The State's demonstration that 

the national ambient air quality 

standards, prevention of significant 

deterioration increments, reasonable 

further progress demonstration, and 

visibility, as applicable, are 

protected if the plan is approved and 

implemented. 

(e) Modeling information required to 

support the proposed revision, 

including input data, output data, 

models used, justification of model 

selections, ambient monitoring data 

used, meteorological data used, 

justification for use of offsite data 

(where used) , modes of models used, 

assumptions, and other information 

relevant to the determination of 

adequacy of the modeling analysis. 

(f) Evidence, where necessary, that 

emission limitations are based on 

continuous emission reduction 

technology. 

(g) Evidence that the plan contains 

emission limitations, work practice 

standards and recordkeeping/ reporting 

requirements, where necessary, to 

ensure emission levels. 

(h) Compliance/enforcement 

strategies, including how compliance 

will be determined in practice . 

(i) Special economic and 

technological justifications required 

by any applicable EPA policies. 

SUBMITTAL ITEM 

The TSD provided with the effective R307 - 311 prov ides 

information and data to support the MVEB PM1o and NOx 

trading provisions. In addition, the TSD provides a 

CAA section 110(1) analysis of potential implications 

to other pollutants of concern . 

The TSD provided with the effective R307-311 provides 

information and data to support the MVEB PM10 and NOx 

trading provisions. Much of the data to support the 

derivation of the MVEB trading ratios was extracted by 

the UDAQ from relevant information contained in the 

Utah County PM2.s Impracticability Demonstration 

nonattainment plan . That plan was submitted to EPA by 

the Governor on 12 / 16 / 14. In addition , the TSD 

provides a CAA section 110(1) analysis of potential 

implications to other pollutants of concern . 

Not Applicable . 

The trading of the PM1o and NOx MVEBs is to be fully 

documented by MAG when the provisions of R307-311 are 

utilized for a transportation conformity determination . 

The specific requirements that are to be documented by 

MAG are presented in the section of the Rule entitled 

"R307-311-4, Trading Between Emission Budgets." 

Specific compliance and enforcement strategies are not 

presented in R307-311. However, trading of the PM1o and 

NOx MVEBs is to be fully documented by MAG when the 

provisions of R307-311 are utilized for a 

transportation conformity determination . The specific 

requirements that are to be documented by MAG are 

presented in the section of the Rule entitled "R307-

311-4, Trading Between Emission Budgets . " In addition , 

when a transportation conformity determination is 

submitted to FHWA by MAG for a finding, both EPA and 

FHWA will also be reviewing the transportation 

conformity determination to ensure that the aspects of 

R307-311 are appropriately used by MAG (if MAG elects 

to use R307-311) . 

EPA notes that R307- 311 was prepared by UDAQ to address 

the provisions contained in 40 CFR 93.124(b). We note 

that a similar MVEB emission trading rule was approved 

by EPA on July 1 , 2002 (67 FR 44065) for Salt Lake 

County for use by the Wasatch Front Regional Council 

which is the MPO for that area . Refer to Utah Rule 

R307-310 .