UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street San Francisco, CA 94105



### Memorandum

To: Phoenix, Arizona Carbon Monoxide Second Ten

- Year Maintenance Plan SIP Proposed Approval Doc ket, Docket ID EPA

- R09

- OAR

- 2015

- 0645

From: John J. Kelly , Air Planning Office, EPA Region 9

Date: September 29 , 2015

RE: Adequacy D ocumentation for Plan M otor V ehicle Emission Budgets in April 201 3

Phoenix CO Maintenance State Implementation Plan (SIP) Submittal

Attached to this memorandum is the adequacy documentation for the M otor V ehicle Emission Budget in

the plan developed by the Maricopa Association of Governments (MAG), titled MAG 2013 Carbon Monoxide Maintenance Plan for the Maricopa County Area , Maricopa County

, Arizona (April

201 3 )(“ 2013 Maintenance Plan ”)

. This maintenance plan is the second ten

- year CO maintenance plan for the area. EPA approved the first ten

- year maintenance plan for the area in 2005.

The 2013 Maintenance Plan was adopted by the Arizona Department of Environmental Quality ( ADEQ )

and submitted t o EPA on April 2, 2013

. MAG is the State’s delegated Agency with authority to develop SIPs for Maricopa County. The 2013 Maintenance Plan identifies a M otor Vehicle Emission Budget ( MVEB ) for the Phoenix CO maintenance area for 2025

. W e are not announcing receipt of the 2013

Maintenance Plan on the Internet . Instead, our Federal Register notice of proposed rulemaking for the

2013 Maintenance Plan will serve to notify the public that EPA is reviewing the implementation plan submission for adequacy and will start a public comment period of 30 days. See 40 CFR 93.118(f)(2)

.

This memo contains our analysis of the MVEB i n t he 2013 Maintenance Plan for the Phoenix

maintenance area portion of Maricopa County, Arizona . The budget is listed in the following table , and our evaluation of the MVEB is in Table 1, below

.

Budget Year CO ( metric t ons per day )

2025 559 .4

## Table 1. Evaluation of the 2025 Motor Vehi cle Emissions Budget in the

Phoenix Maintenance Area Second Ten

- Year Maintenance Plan ( April 2013 )
September 201 5 (reviewed by John J. Kelly )

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 The 2013 Maintenance Plan was submitted to EPA on April 2, 2013 by Eric Massey, Director, ADEQ Air Quality Division , the Governor of

Arizona ’s designee for all SIP revision submittals. The SIP was developed by the Maricopa Association of Governments (MAG). This SIP submittal documents that

MAG , which is responsible under Ari zona law for SIP development within the

boundaries of Maricopa County, Arizona

, adopted the plan on March 27, 2013.

2013 Maintenance Plan , Appendix B, Exhibit 2, Certification of Adoption. MAG held a p ublic hearing on the plan on February 19 , 2013

. 2013 Maintenance Plan

, Appendix B, Exhibit 1, Public Hearing Process Documentation.

## Table 1. Evaluation of the 2025 Motor Vehi cle Emissions Budget in the

Phoenix Maintenance Area Second Ten

- Year Maintenance Plan ( April 2013 )
September 201 5 (reviewed by John J. Kelly )

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 Regarding consultation, MAG developed t he 2013 Maintenance Plan in

co nsultation with Federal, State, and local agencies. These agencies include: EPA Region IX; Federal Highway Administration; Federal Transit Administrati on; Arizona Department of Transportation; Arizona Department of Environmental Quality (ADEQ)

, Air Quality Division ; and other State and Local entities. Letter to above parties from Lindy Bauer, Environmental Director, MAG, subject

“Transmittal of the draf t MAG 2013 Carbon Monoxide Maintenance Plan for the Maricopa County Area,” dated January 18, 2013, 2013 Maintenance Plan

, Appendix B, Exhibit 1, Public Hearing Process Documentation. See also, MAG

1992 i nteragency c onsultation m emorandum of a greement , “ Air Quality Memorandum of Agreement .”

MAG also consults on SIPs with the MAG Air Quality Technical Advisory Committee, composed largely of parties external to MAG. The TAC consists of representatives from MAG member agencies; citizens; environmental interests; health interests; construction firms; utilities; public transit; architecture; agriculture; the business community; the automobile, fuel, trucking, rock products,

and housing industries; parties to the Air Quality Memorandum of Agreement, and various state and federal agencies.

Regarding addressing EPA’s concerns, the EPA was afforded the opportunity to comment on the draft plan and provided comments which were addres sed in the plan’s public participation section. 2013 Maintenance Plan , Appendix B, Exhibit 1, Public Hearing Process Documentation.

## Table 1. Evaluation of the 2025 Motor Vehi cle Emissions Budget in the

Phoenix Maintenance Area Second Ten

- Year Maintenance Plan ( April 2013 )
September 201 5 (reviewed by John J. Kelly )

Adequacy Review Criteria (40 CFR part 93) Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 93.118(e)(4)(iii) The motor vehicle emission budgets are clearly identified and precisely quantified. Y The MVEB is clearly identified and pre cisely quantified for the year 202 5 . In the plan ’s T able 3

- 3, “Average Weekday Emissions During the Winter Season in the Carbon Monoxide Maintenance Area,” CO emissions are provided in metric tons per day for Point, Area, Non

- ro ad, and On

- road source categories. Emissions numbers are provided for a model year, 2008, and the relevant projected future year for the maintenance plan, the last year of the ten

- year duration of the plan, the year 2025. A safety margin of 90% of the di fference between the 2008 and 2025 CO emissions (200 mtpd) was added to th e on

- road emissions projected in 2025 to
derive the 2025 MVEB . The 2025 MVEB provided in the plan is 559.4 mtpd

. 2013 Maintenance Plan , Transportation Conformity Budget section, pa ge 3

- 22.

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, attainment, or maintenance (whichever is relevant to a given implementation plan submission)

. Y The 2013 Maintenance Plan describes how the MVEB

, when considered together

with all other emission sources

, is consistent with maintenance of the CO NAAQS

in the Phoenix metropolitan area through 2025

. The 2025 MVEB is less than the MVEBs for previous years, and when taken together with other source categories, the total CO emissions for the maintenance area are projected to decline from 901.6 mtpd in 2008 to 639.6 mtpd in 2025. 2013 M aintenance Plan , Table 3

- 3, “Average Weekday Emissions During the Winter Season in the Carbon Monoxide Maintenance Area,” page 3

- 4.

Sec. 93.118(e)(4)(v) The plan shows a clear relationship among the emissions budget(s), control measures and

the total emis sions inventory. Y The 2013 Maintenance Plan includes an emissions inventory section that includes

modeled MVEBs and a detailed discussion of control measures. Control measures are listed in order of the amount of emissions reductions they achieve, and the plan clearly indicates which of the control measures were credited with reductions.

## Table 1. Evaluation of the 2025 Motor Vehi cle Emissions Budget in the

Phoenix Maintenance Area Second Ten

- Year Maintenance Plan ( April 2013 )
September 201 5 (reviewed by John J. Kelly )

Adequacy Review Criteria (40 CFR part 93) Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec.

93.11 8(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 margi ns (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 EPA approved the 2003 Maintenance Plan in 2005. The 2013 Maintenance Plan is the required seco nd maintenance plan for the area. Where the first plan had MVEBs for 2006 and 2015, the second added the last year of the plan period, the year 2025. The 2013 Maintenance Plan clearly indicates changes to control

measures. It details the deletion of the VEI program for motorcycles, a previous control measure, which took place in a separate EPA action, and the addition of a contingency measure under the 2003 plan, “Expansion of Area A Boundaries,” as an implemented control measure under the 2013 plan. Th e VEI exemption for motorcycles is also presented in the 2013 plan as a contingency measure. 2013 Maintenance Plan: Maintenance Plan Control Measures section; Emissions Inventories section; Technical Support Document, Appendix A, Exhibit 2, section

IV

- 6, p age IV

- 38, “Transportation Conformity Budget.”

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 A notice of the initial public comment period and hearing on the 2013 Maintenance

Plan was published in The Arizona Republic on January 18, 2013

. A hearing on the plan was held on February 19, 2013. The only public comment s MAG received on

the draft maintenance plan regarded the area’s monitoring network. MAG responded to the comments by describing monitoring program requirements. No

other adverse comments were made at the public hearing from members of the public. The 2013 Maintenance Plan submittal includes a copy of EPA’s comments on the draft plan and MAG’s response to those comments. 2013 Maintenance Plan

, Appendix B, Exhibit 1, Public Hearing Process Documentation.