Janice K. Brewer Governor 

## JAN 

# 11 2011
Mr. Jared Blumenfeld Regional Administrator 

## ARIZONA DEPARTMENT OF 

## ENVIRONMENTAL QUALITY 1110 West Washington Street· Phoenix, Arizona 85007 (602) 771-2300 • www.azdeq.gov



### U.S. Environmental Protection Agency, Region IX 75 Hawthorne Street, ORA-l San Francisco, CA 94105 Henry R. Darwin Acting Director



### RE: 

### ArizonaState Implementation Plan Revision, Exemption of Motorcyclesfrom Vehicle Emissions Inspections andMaintenance Program Requirements inAreaA

### -:rC\(~**;** Dear

# enfeld: Consistent with the provisions ofArizona Revised Statutes (ARS) Title 49, §§ 49-104 and 49- 404 (Enclosure 1) and the Code ofFederal Regulations (CFR) Title 40, §§ 51.102-51.104, the Arizona Department ofEnvironmental Quality (ADEQ) hereby adopts and submits to the U.S. Environmental Protection Agency (EPA) the December 2010,

### Addendum to theArizona State Implementation Plan Revision, Exemption of Motorcyclesfrom Vehicle Emissions Inspections andMaintenance Program Requirements in AreaA, October 2009, as a revision to the Arizona State Implementation Plan (SIP). In 2008 the Arizona Legislature passed House Bill 2280, which amended ARS § 49-542 to authorize the exemption ofmotorcycles from emissions testing requirements in Area A, the Phoenix testing area. The changes to ARS § 49-542 are selfimplementing and become effective ifapproved by EPA as a revision to the SIP on or before July 1,2012. ADEQ submitted a SIP revision entitled

### Arizona State Implementation Plan Revision, Exemption of Motorcyclesfrom Vehicle Emissions Inspections andMaintenance Program Requirements in AreaA, October 2009, to EPA on November 6,2009. As required under Clean Air Act Section 110(1), the SIP revision contained analyses ofemissions impacts due to the exemption and a request for EPA to approve the changes to Arizona's 

### 11M program. During its review ofthe exemption request, EPA asked for additional information regarding the impact ofthe exemption on attainment ofthe PM10 

### National Ambient Air Quality Standards (NAAQS). In addition, because ofa recent change in the ozone NAAQS, EPA requested a replacement measure to offset estimated increases in emissions ofvolatile organic compounds (VOC), an ozone precursor, due to the exemption. The enclosed Addendum summarizes the exemption's impact on the ozone precursor emissions, volatile organic compounds and oxides ofnitrogen, and includes a substitute measure that provides VOC emission reductions equal to those achieved by the testing and repair of Northern Regional Office 1801 W. Route 66 • Suite 117 • Flagstaff, AZ 86001 (928) 779-0313 Southern Regional Office 400 West Congress Street· Suite 433' Tucson, AZ 85701 (520) 628-6733 Printed on recvcled paper

### Mr. Jared Blumenfeld Page 2 of2
motorcycles. The Addendum also contains further analysis ofPM,o emission impacts expected from the change in the 11M program. Again, because ofthe high level ofinterest and support for this measure in Arizona, ADEQ continues to request expedited review and approval ofthis SIP reVISiOn. Enclosure 2 contains the SIP Completeness Checklist. Enclosure 3 contains two paper copies and one electronic copy ofthe SIP revision for your review and action. Ifyou have any questions, please contact Eric Massey, Director, Air Quality Division, at (602) 771-2308. Sincerely,

Acting Director Enclosures (3)

cc: Colleen McKaughan, EPA, w/o 

### enclosures Lindy Bauer, Maricopa Association ofGovernments, w/o 

### enclosures Jo Crumbaker, Maricopa County Air Quality Department, w/o 

### enclosures Don Gabrielson, Pinal County Air Quality Control District, w/o 

### enclosures

### ENCLOSURE 1 Arizona Revised Statutes 

### §§ 49-104 and 49-404

### 49- 104. Powers and duties of the department and director A. The department shall: 

### 1. Formulate policies, plans and programs to implement this title to protect the environment. 2. Stimulate and encourage all local, state, regional and federal governmental agencies and all private persons and enterprises that have similar and related objectives and purposes, cooperate with those agencies, persons and enterprises and correlate department plans, programs and operations with those of the agencies, persons and enterprises. 3. Conduct research on its own initiative or at the request of the governor, the legislature or state or local agencies pertaining to any department objectives. 4. Provide information and advice on request of any local, state or federal agencies and private persons and business enterprises on matters within the scope of the department. 5. Consult with and make recommendations to the governor and the legislature on all matters concerning department objectives. 6. Promote and coordinate the management of air resources to assure their protection, enhancement and balanced utilization consistent with the environmental policy of this state. 7
. Promote and**coordinat~** 

### the protection and enhancement of the quality of water resources consistent withthe environmental policy of this state. S. Encourage industrial, commercial, residential and community development that maximizes environmental benefits and minimizes the effects of less desirable environmental conditions. 9. Assure the preservation and enhancement of natural beauty and manmade scenic qualities. 10. Provide for the prevention and abatement of all water and air pollution including that related to particulates, ga' ses, dust, vapors, noise, radiation, odor, nutrients and heated liquids in accordance with article 3 of this chapter and chapters 2 and 3 of this title. 11. Promote and recommend methods for the recovery, recycling and reuse or, if recycling is not possible, the disposal of solid wastes consistent with sound health, scenic and environmental quality policies. 12. Prevent pollution through the regulation of the storage, handling and transportation of solids, liquids and gases that may cause or contribute to pollution. 13. Promote the restoration and reclamation of degraded or despoiled areas and natural resources. 14. Assist the department of health services in recruiting and training state, local and district health department personnel. 15. Participate in the state civil defense program and develop the necessary organization and facilities to meet wartime or other disasters

. 16. Cooperate with the Arizona-Mexico commission in the governor's office and with researchers at universities in this state to collect data and conduct projects in the United States and Mexico on issues that are within the scope of the department's duties and that relate to quality of life, trade and economic development in this state in a manner that will help the Arizona-

### Mexico commission to assess and enhance the economic competitiveness of this state and of the Arizona-Mexico region. 17. Unless specifically authorized by the legislature, ensure that state laws, rules, standards, permits, variances and orders are adopted and construed to be consistent with and no more stringent than the corresponding federal law that addresses the same subject matter. This provision shall not be construed to adversely affect standards adopted by an Indian tribe under federal law. B. The department, through the director, shall: 

### 1. Contract for the services of outside advisers, consultants and aides reasonably necessary or desirable to enable the department to adequately perform its duties. 2. Contract and incur obligations reasonably necessary or desirable within the general scope of department activities and operations to enable the department to adequately perform its duties. 3. Utilize any medium of communication, publication and exhibition when disseminating information, advertising and publicity in any field of its purposes, objectives or duties. 4. Adopt procedural rules that are necessary to implement the authority granted under this title, but that are not inconsistent with other provisions of this title. 5. Contract with other agencies, including laboratories, in furthering any department program. 6. Use monies, facilities or services to provide matching contributions under federal or other programs that further the objectives and programs of the department. 7. Accept gifts, grants, matching monies or direct payments from public or private agencies or private persons and enterprises for department services and publications and to conduct programs that are consistent with the general purposes and objectives of this chapter. Monies received pursuant to this paragraph shall be deposited in the department fund corresponding to the service, publication or program provided. 8. Provide for the examination of any premises ifthe director has reasonable cause to believe that a violation of any environmental law or rule exists or is being committed on the premises. The director shall give the owner or operator the opportunity for its representative to accompany the director on an examination of those premises. Within forty-five days after the date of the examination, the department shall provide to the owner or operator a copy of any report produced as a result of any examination of the premises. 9. Supervise sanitary engineering facilities and projects in this state, authority for which is vested in the department, and own or lease land on which sanitary engineering facilities are located, and operate the facilities, if the director determines

. that owning, leasing or operating is necessary for the public health, safety or welfare. 10. Adopt and enforce rules relating to approving design documents for constructing, improving and operating sanitary engineering and other facilities for disposing of solid, liquid or gaseous deleterious matter.

### 11. Define and prescribe reasonably necessary rules regarding the water supply, sewage disposal and garbage collection and disposal for subdivisions. The rules shall: (a) Provide for minimum sanitary facilities to be installed in the subeiivision and may require that water systems plan for future needs and be of adequate size and capacity to deliver specified minimum quantities of drinking water and to treat all sewage. (b) Provide that the design documents showing or describing the water supply, sewage disposal and garbage collection facilities be submitted with a fee to the department for review and that no lots in any subdivision be offered 

### for sale before compliance with the standards and rules has been demonstrated by approval of the design documents by the department. 12. Prescribe reasonably necessary measures to prevent pollution of water used in public or semipublic swimming pools and bathing places and to prevent deleterious conditions at such places. The rules shall prescribe minimum standards for the design of and for sanitary conditions at any public or semipublic swimming pool or bathing place and provide for abatement as public nuisances of premises and facilities that do not comply with the minimum standards. The rules shall be developed in cooperation with the director of the department of health services and shall be consistent with the rules adopted by the director of the department of health services pursuant to section 36-136, subsection H, paragraph 10. 13. Prescribe reasonable rules regarding sewage collection, treatment, disposal and reclamation systems to prevent the transmission of sewage borne or insect borne diseases. The rules shall: (a) Prescribe minimum standards for the design of sewage collection systems and treatment, disposal and reclamation systems and for operating the systems. (b) Provide for inspecting the premises, systems and installations and for abating as a public nuisance any collection system, process, treatment plant, disposal system or reclamation system that does not comply with the minimum standards. (c) Require that design documents for all sewage collection systems, sewage collection system extensions, treatment plants, processes, devices, equipment, disposal systems, on-site wastewater treatment facilities and reclamation systems be submitted with a fee for review to the department and may require that the design documents anticipate and provide for future sewage treatment needs. (d) Require that construction, reconstruction, installation or initiation of any sewage collection system, sewage collection system extension, treatment plant, process, device, equipment, disposaJ system, on-site wastewater treatment facility or reclamation system conform with applicable requirements. 14. Prescribe reasonably necessary rules regarding excreta storage, handling, treatment, transportation and disposal. The rules shall: (a) Prescribe minimum standards for human excreta storage, handling, treatment, transportation and disposal and shall provide for inspection of premises, processes and vehicles and for abating as public nuisances any

### premises, processes or vehicles that do not comply with the minimum standards. (b) Provide that vehicles transporting human excreta from privies, septic tanks, cesspools and other treatment processes shall be licensed by the department subject to compliance with the rules. 15. Perform the responsibilities of implementing and maintaining a data automation management system to support the reporting requirements of title III of the superfund amendments and reauthorization act of 1986 (P.L. 99-499) and title 26, chapter 2, article 3. 16. Approve remediation levels pursuant to article 4 of this chapter. C. 

### The department may: 

### 1. Charge fees to cover the costs of all permits and inspections it performs to ensure compliance with rules adopted under section 49-203, except that state agencies are exempt from paying the fees. Monies collected pursuant to this subsection shall be deposited, pursuant to sections 35-146 and 35-147, in the water quality fee fund established by section 49-210. 2. Contract with private consultants for the purposes of assisting the department in reviewing applications for licenses, permits or other authorizations to determine whether an applicant meets the criteria for issuance of the license, permit or other authorization. Ifthe department contracts with a consultant under this paragraph, an applicant may request that the department expedite the application review by requesting that the department use the services of the consultant and by agreeing to pay the department the costs of the consultant's services. Notwithstanding any other law, monies paid by applicants for expedited reviews pursuant to this paragraph are appropriated to the department for use in paying consultants for services. D. The director may: 

### 1. Ifthe director has reasonable cause to believe that a violation of any environmental law or rule exists or is being committed, inspect any person or property in transit through this state and any vehicle in which the person or property is being transported and detain or disinfect the person, property or vehicle as reasonably necessary to protect the environment if a violation exists. 2. Authorize in writing any qualified officer or employee in the department to perform any act that the director is authorized or required to do by law.

### 49-404. State implementation plan A. The director shall maintain a state implementation plan that provides for implementation, maintenance and enforcement of national ambient air quality standards and protection of visibility as required by the clean air act. B. The director may adopt rules that describe procedures for adoption of revisions to the state implementation plan. 

## e. The state implementation plan and all revisions adopted before September 30, 1992 remain in effect according to their terms, except to the extent otherwise provided by the clean air act, inconsistent with any provision of the clean air act, or revised by the administrator. No control requirement in effect, or required to be adopted by an order, settlement agreement or plan in effect, before the enactment of the clean air act in any area which is a nonattainment or maintenance area for any air pollutant may be modified after enactment in any manner unless the modification insures equivalent or greater emission reductions of the air pollutant. The director shall evaluate and adopt revisions to the plan in conformity with federal regulations and guidelines promulgated by the administrator for those purposes until the rules required by subsection B are effective.

### ENCLOSURE 2 State Implementation Plan 

### Completeness Checklist

## STATE IMPLEMENTATION PLAN COMPLETENESS CHECKLIST Submittal of 

### Addendumto theArizona StateImplementation Plan Revision, Exemption of Motorcycles from Vehicle EmissionsInspections andMaintenance Program Requirements in AreaA, October2009 December 2010

1. SUBMITTAL LETTER FROM GOVERNOR/DESIGNEE See cover letter. 2. EVIDENCE OF ADOPTION See cover letter. 3. STATE LEGAL AUTHORITY FOR ADOPTION/IMPLEMENTATION See Enclosure 1. 4. COMPLETE COPY OF REGULATION/DOCUMENT See Enclosure 3. 5. WRITTEN SUMMARY OF REGULATION CHANGE See Enclosure 3. 6. REGULATION CHANGES INDICATED BY UNDERLINING AND CROSS-OUTS See

### Arizona State Implementation Plan Revision, Exemption of Motorcyclesfrom Vehicle Emissions Inspections andMaintenance Program Requirements in AreaA, October 2009, Enclosure 3, Appendix A
. 7. EVIDENCE THAT ARIZONA ADMINISTRATIVE PROCEDURE ACT REQUIREMENTS WERE MET FOR PLAN See Enclosure 3, Appendix A. 8. EVIDENCE OF PUBLIC NOTICE AND HEARING See Enclosure 3, Appendix A.

### 9. PUBLIC COMMENTS AND AGENCY RESPONSE

. See Enclosure 3, Appendix A.
10. IDENTIFICATION OF POLLUTANTS REGULATED BY REGULATION/PLAN Ozone and Carbon Monoxide. 11. IDENTIFICATION OF SOURCES/ATTAINMENT STATUS See Enclosure 3. 12. REGULATION'S/PLAN'S EFFECT ON EMISSIONS See Enclosure 3. 13. DEMONSTRATION THAT NAAQS, PSD INCREMENTS AND RFP ARE PROTECTED See Enclosure 3. 14. MODELING SUPPORT See Enclosure 3. 15. EVIDENCE THAT EMISSIONS LIMITATIONS ARE BASED ON CONTINUOUS EMISSIONS REDUCTION TECHNOLOGY Not applicable. 16. IDENTIFICATION OF REGULATION SECTIONS CONTAINING EMISSION LIMITS, WORK PRACTICE STANDARDS, AND/OR RECORD KEEPING/REPORTING REQUIREMENTS Not applicable. 17. COMPLIANCE/ENFORCEMENT STRATEGIES Not applicable. 18. ECONOMIC TECHNICAL JUSTIFICATION FOR DEVIATION FROM EPA POLICIES No known deviation from EPA policy
.J 

### ENCLOSURE 3 

### Addendum to the ArizonaState Implementation Plan Revision Exemption of Motorcyclesfrom Vehicle Emissions Inspections andMaintenance Program Requirements inAreaA, October2009 December 2010

# ofEnvironmental Quality

# (~

Final Addendum 

# to the Arizona State Implementation Plan Revision Exemption of

# Motorcycles from Vehicle Emissions Inspections andMaintenance Program Requirements in AreaA October2009

Air Quality Division December 2010(This page intentionally left blank
.)TABLE OF CONTENTS

TABLE OF CONTENTS
................................... ..... ...... .... ........... .. ....... ...... ........... .......................... ............ ..i LIST OF FIGURES
............ .......................... .......... .. ... ..... ......... ..... ....... ........... .............. ................... ............ii LIST OF TABLES
.......................................'
... .... ... ........ ........... .. ... ................ ..... .............................. ............ii LIST OF APPENDICES
...................................................................................................................... ..... .. iii 1.0 INTRODUCTION
.... .... ................ .. .................... .............................. ........ ........................................ 1 2.0 DEMONSTRATION OF NONINTERFERENCE WITH ATTAINMENT OF THE OZONE NATIONAL AMBIENT AIR QUALITY STANDARDS
................................... .... .........3 2.1 VOC and NOx Emissions
................................................... .... .... ................ .. ........... ... ........4 2.2 Substitute Measure for VOC Emissions
.. .................. ...... .......... ..........................................6 3.0 DEMONSTRATION OF NONINTERFERENCE WITH ATTAINMENT OF THE PM 10 NATIONAL AMBIENT AIR QUALITY STANDARDS
.................................... .................8 

### 3.1 PM1oEmissions
...................................................................................................................8 4

.0 CONCLUSION
..... ........... ...... ....... ..... .......... ...................... .......................... .......... ........................ 14

Final 11M Program SIP Addendum 101220

### LIST OF FIGURES


### 1. Motorcycle Registration Data from 2003 to July 20I0
........ ...................................... ....... 11


### LIST OF TABLES


### 1. Change in On-Road VOC Emissions Due to Motorcycle Exemption in Area A .
.. .... .......... .... .......................... .............. .. .... ....................... ....... ..... .... 5 2
. Change in Total VOC Emissions Due to Motorcycle Exemption Relative to the 8-Hour Ozone Nonattainment Area
....................................................... ..... 5 3. Comparison ofthe Aerosol Coatings Rule VOC Emissions Reductions for the Phoenix Ozone Planning Area with the Change in Emissions Due to the Motorcycle Exemption
... .... ....:................. .... .... .... ... ......... ........... ... ... ...... .... ..... . 7 4
. Comparison ofFederal Highway Motorcycle Exhaust Emissions Standards
...... ..... ...... .......... ................... ... .......... ...... ... ....... .... ...... .. .......... ..... ........ .... ... .. ..... . 9 5. PM,o Emission Factors
.............. ........................................................................................ 12

Final 11M Program SIP Addendum 101220 II

### APPENDICES

A. State Implementation Plan Revision Public Comment and Hearing Documentation A.I Notice ofPublic Hearing A.2 Public Hearing Agenda A.3 Public Hearing Sign-In Sheet A.4 Public Hearing Officer Certification and Transcript A.S Responsiveness Summary

Final IIM Program SIP Addendum 101220 IIIThis page intentionally left blank.

### 1.0 INTRODUCTION This document is an addendum to a 2009 request to the U.S. Environmental Protection Agency (EPA) to exempt Phoenix motorcycles from the Arizona vehicle emissions inspection and maintenance program. It contains information requested by EPA including a substitute measure for control of volatile organic compound (VOC) emissions and additional analysis of the exemption's impact on emissions of particulate matter of size less than or equal to 10 microns (PMto). Some material included in this addendum can also be found in the 2009 exemption request but is repeated here to provide context. As background, vehicle emissions inspection and maintenance or IIM programs are required in certain areas that do not meet the carbon monoxide (CO) and ozone (03 ) National Ambient Air Quality Standards (NAAQS) with the purpose of reducing emissions and improving air quality. These programs help identify vehicles with excess emissions, provide information to assist with diagnosing malfunctions that cause excess emissions, and require repair ofvehicles to bring them into compliance with emissions standards. An enhanced 11M program is currently operated in the expanded Phoenix metropolitan area, known as Area A, located in portions of Maricopa, Pinal, and Yavapai Counties.' The IIM program requires periodic emissions inspection of motor vehicles registered or regularly operated within the area. The enhanced program is among the primary control measures used to help the Phoenix area attain and maintain the I-hour ozone, 1997 8-hour ozone, and carbon monoxide NAAQS? In 2008 the Arizona Legislature passed House Bill 2280, which amended Arizona Revised Statues (ARS) 

### § 49-542 to authorize the exemption of motorcycles from IIM program requirements in the Phoenix testing area. The changes to ARS 

### § 49-542 are self implementing and become effective ifapproved by EPA as a revision to the Arizona State Implementation Plan (SIP) on or before July 1, 2012 (as authorized by House Bill 2033 in April 2010)
. The Arizona Department of Environmental Quality (ADEQ) submitted 

### Final Arizona State Implementation Plan Revision, Exemption ofMotorcyclesfrom Vehicle Emissions Inspections and Maintenance Program Requirements in Area A, October 2009, to EPA on November 6, 2009. The SIP revision contained a request for EPA to approve the changes to Arizona's IIM program. Because revisions to SIP approved control measures must not interfere with the requirements ofthe Clean Air Act (CAA) [according to CAA Section ) 10(1)], the October 2009 submittal also evaluated the impact of exempting Phoenix area motorcycles on air quality and included a demonstration that the exemption will not interfere with the ability ofthe Phoenix area to attain or maintain the NAAQS or with any other requirement ofthe Clean Air Act. During its review ofthe exemption request, EPA asked for additional information regarding the impact of the exemption on attainment of the ozone and PMto NAAQS .3 Because of a recent

I See Arizona Revised Statutes §49-541 (1) for a description ofArea A
. 2 See Final SeriousArea Ozone State Implementation Planfor Maricopa County, December 2000; OneHour Ozone Redesignation Request andMaintenance Planfor the Maricopa County NonattainmentArea, March 2004; Eight-Hour Ozone Planfor the Maricopa NonattainmentArea,June 2007; MAG Eight-Hour O

zone Redesignation Request andMaintenance Planfor the Maricopa Nonattainment Area, February 2009;RevisedMAG 1999 Serious Area Carbon Monoxid e Planfor the Maricopa C ountyNonattainment Area, March 2001 ;and Carbon Monoxide Redesignation Request andMaintenance Planfor the Maricopa County Nonattainment Area , May 2003. 3 PM IO and Ozone are two ofthe common air pollutants for which EPA has established National Ambient Air Quality Standards (NAAQS) under the Clean Air Act. See http://www.epa.gov/air /criteria.htmlfor a complete list ofNAAQS.
Final 11M Program SIP Addendum 101220change in the ozone NAAQS, EPA also requested a replacement measure to offset estimated increases in emissions ofVOCs, an ozone precursor, due to the exemption. Section 2 ofthis document summarizes the exemption's impact on the ozone precursor emissions, VOC and NOx, and includes a substitute measure that provides VOC emission reductions equal to those achieved by the testing and repair ofmotorcycles. Section 3 contains further analysis of PM 10 emission impacts expected from the change in the 

### 11M program.

Final 11M Program SIP Addendum 101220 2

### 2.0 DEMONSTRATION OF NONINTERFERENCE WITH ATTAINMENT OFTHE OZONE NATIONAL AMBIENT AIR QUALITY STANDARDS The principal pollutants affected by IIM programs are carbon monoxide, hydrocarbons (HC) or volatile organic compounds (VOC), and to a lesser degree, oxides of nitrogen (NOx). Hydrocarbons and NOx are two ofthe principal pollutants that contribute to ground-level ozone formation. Phoenix area motorcycles are currently subject to "curb idle" test procedures and maximum allowable emissions standards for carbon monoxide and hydrocarbons.4 Vehicle emissions inspection and maintenance is an "applicable requirement" for the Phoenix ozone planning area. The resulting emissions reduction benefits have helped the Phoenix area meet the 1979 I-hour ozone standard and the 1997 8-hour ozone standard. The following summarizes the Phoenix area regulatory background for ozone and discusses the basis for EPA's request for a substitute VOC control measure. For a more complete history see 

### Final Arizona State Implementation Plan Revision, Exemption ofMotorcyclesfrom Vehicle Emissions Inspections andMaintenance Program Requirements inAreaA, October 2009. The Phoenix area was classified as moderate nonattainment for'the I-hour ozone standard under the 1990 Clean Air Act Amendments (later reclassified as serious). The level ofboth the primary standard (for protection of public health) and secondary standard (for protection of the environment) was set at 0.12 Palts per million (ppm).5 The area attained the standard in 1996 and following submittal ofa maintenance plan was redesignated to attainment on June 14,2005. In 1997, EPA completed an analysis of the I-hour ozone standard and adopted a new 8-hour standard, which better protects the public from longer periods ofexposure to ozone. The level of both the primary and secondary standards was set at 0.08 ppm.6 Effective June 15,2004, EPA designated the Phoenix area including much ofeastern Maricopa County and Apache Junction in Pinal County nonattainment for the 8-hour standard (69 FR 23857; April 30, 2004)
. An 8-hour ozone plan for the Phoenix nonattainment area was submitted to EPA on June 13, 2007. The plan demonstrated that the 1997 8-hour ozone standard would be met with measures that had been implemented before the 2008 ozone season. A review of air quality monitoring data indicates attainment of the 8-hoUl' standard was achieved by 2005
. A maintenance plan and request to redesignate the area to attainment for the 1997 standard was submitted to EPA on March 23, 2009. 7 These plans are pending EPA action. As required under anti-backsliding provisions for the transition to the 8-hour standard, the 

### 11M program established for attainment of the I-hour ozone standard remains a component ofthe Arizona SIP
. Under CAA Section 110(1), revisions to SIP-approved control measures must not interfere with any applicable requirement concerning attainment of the air quality standards or reasonable further progress towards' attaining those standards. To ensure that the exemption ofmotorcycles will not interfere with continued attainment, modeling analyses in the 2009 maintenance plan and redesignation request demonstrate that the Phoenix area will maintain the 1997 8-hour ozone standards through 2025 

### without testing ofArea A motorcycles.

4 See Arizona Administrative Code Title 18, Chapter 2, Article 10. 5 The level ofthe primary and secondary standard was a one-hour average of0
.12 ppm. In the form or attainment test, three exceedances at a monitor were allowed in a three year period, the fourth exceedance constituted a violation
. 6 The level ofthe primary and secondary standards was set at 0.08 ppm averaged over 8 hours. The form or attainment test is the three-year average ofthe annual foul1h highest 8-hour average concentration, calculated for each monitor. 7 See Footnote 2
.
Final 1 1 M Program SIP Addendum 101220 3

### In 2008 EPA lowered the 8-hour ozone primary standard from 0.08 ppm (the level adopted in (997) to 0.075 ppm (73 FR 16436; March 27, 2008). The secondary standard was set at a level identical to the primary standard. Arizona submitted recommendations for areas ofthe State that meet (attainment) or do not meet (nonattainment) the revised standards on March 12, 2009. The only recommended nonattainment area was the greater Phoenix area including parts ofMaricopa and Pinal Counties
. Designation of attainment and nonattainment area boundaries is one ofthe first steps in the planning process for implementing new or revised NAAQS
. Once boundary designations have been made, states are required to develop plans for areas that do not meet the new standards including adoption ofany strategies and measures necessary to ensure attainment and maintenance of such standards. Due to EPA's reconsideration of the 2008 8-hour ozone standards, however, determination of final area boundaries for the 2008 NAAQS has been delayed. 

### In January 2010, based on its reconsideration, EPA proposed to set a different primary 8-hour standard than that promulgated in 2008
. The proposed standard currently falls within the range of 0
.060 to 0
.070 ppm, a level that would, according to EPA, provide more protection for children and other "at risk" populations from exposure to elevated levels ofozone pollution (75 FR 2938; January 19, 20 

### I0). EPA also proposed to set a new cumulative, seasonal secondary standard, within the range of 7 to 15 ppm-hours, to provide increased protection against damage to vegetation and ecosystems. EPA anticipates making a final decision on the proposed changes to the level and form ofthe NAAQS in mid 2011. Nonattainment area boundaries have not yet been established for either the 2008 or proposed 2010 standards. EPA has determined, however, that because several ambient monitors have recorded exceedances/violations ofthe 2008 ozone standards, a replacement measure is necessary to offset an expected increase in VOC emissions following implementation of the motorcycle exemptions
. Section 2.1 summarizes the expected impact on emissions of the ozone precursors, VOC and NOx, and Section 2.2 contains a substitute control measure to mitigate any increase in VOC emISSIOns.


### 2.1 VOC and NOx Emissions The following summarizes analyses presented in 

### Final Arizona State Implementation Plan Revision, Exemption ofMotorcycles from Vehicle Emissions Inspections and Maintenance Program Requirements in Area A, October 2009, and provides additional information on VOC and NOx emissions impacts due to the exemption.


### VOC Emissions According to the Maricopa County Air Quality Department's 

### 2005 Periodic Emission Inventory for Ozone Precursorsfor the Maricopa County, Arizona, Nonattainment Area, September 2008, on-road mobile sources comprise 17 percent of total VOC emissions in the Phoenix ozone planning area. Motorcycles make up approximately 3.5 percent oftested vehicles in Area A and represent 0.3 percent ofannual VOC emissions totals in the planning area.8

8 Vehicle Emissions Inspection Program data for 2007 / 2008

.
Final 1 1 M Program SIP Addendum 101220 4The reduction of emissions due to the repair of vehicles that exceed the prescribed emissions standards contained in AAC Title 18, Chapter 2, Article lOis called the IIM benefit. In August 2009 the Maricopa Association ofGovernments completed a modeling analysis to determine the emissions reduction benefits from testing and repair ofArea A motorcycles. The VOC emissions reduction benefit is shown in two different ways: comparison to Area A (see Table I) and comparison to the larger 8-hour ozone nonattainment area (see Table 2).9 The IIM benefit for subject vehicles is less than one tenth ofa metric ton per day which equates to less than one tenth of one percent of both on-road emissions in Area A and total emissions in the ozone planning area. 

### Table 1: Changein 

### On-Road VOC Emissions Due to Motorcycle Exemption in 

### AreaA 10 Testing BenefitlEmissions Change VOC liM Benefit (metric tons per day) 0.0560 On-Road Emissions in Area A (metric tons per day) 66.58 Relative Emissions Increase in Area A Due to Exemption 0.084% (percent ofon-road emissions in Area A) 

### Table 2: Change in 

### TotalVOC Emissions Due to Motorcycle Exemption Relative to the 8-HourOzone NonattainmentArea (1997 standard) Testing BenefitlEmissions Change VOC 

### 11M Benefit (metric tons per day) 0.0560 Total Emissions in the 8-Hour Ozone Nonattainment Area 606.69 (metric tons per day)11 Relative Emissions Increase Due to Exemption (percent of 0
.0092% total emissions in the 8-hour ozone nonattainment area) Committed and implemented control measures limit the projected emiSSIons growth for the Phoenix area. Emissions of volatile organic compounds from all sources are estimated to rise only slightly through 2025. In contrast, between 2005 and 2025 on-road mobile VOC emissions decline by more than one-third, due primarily to the replacement ofolder, high-polluting vehicles with new models that meet more stringent federal emission standards. 12 The VOC emission impacts from exempting motorcycles as shown in Tables I and 2 are based on 2010 estimates. The testing benefit is expected to decrease with time, however, as older motorcycles are replaced with newer models that meet more stringent federal emission standards for HC and NOx (see Section 3 for further discussion of the new exhaust emissions standards for highway motorcycles)
. Because of recorded exceedances of the 2008 ozone NAAQS, however, a substitute measure to mitigate the expected increase in VOC emissions due to the exemption of motorcycles is provided in Section 2.2.

9 Please note that HC is equivalent to VOC in the MOBILE6 model runs. 10 The year 20I0 was selected to estimate emissions impacts in the 2009 exemption request. II Total emissions for the eight-hour ozone nonattainment area are from the 2005 Periodic Emission Inventoryfor O zone Precursorsfor the Maricopa County , Ari zona, Nonattainment Area (Maricopa County Air Quality Department, 2008). The eight-hour ozone nonattainment area (4,880 square miles) is slightly larger than Area A (4,520 square miles). 12 See Footnote 2.

Final 11M Program SIP Addendum 101220 5

### NOx Emissions According to the Maricopa County Air Quality Department's 

### 2005 Periodic Emission Inventory for Ozone Precursorsfor the Maricopa County, Arizona, Nonattainment Area, September 2008, on-road mobile sources comprise 57 percent of total NOx emissions in the Phoenix ozone planning area. Motorcycles represent 0.2 percent ofannual NOx emissions totals. Although the Area A 11M program includes NOx testing for certain automobiles, the program does not include emissions standards or testing for motorcycles. No credit was taken for NOx reductions due to testing of motorcycles in the July 13, 2007, attainment demonstration or the March 23, 2009, maintenance plan for the Phoenix 8-hour ozone nonattainment area. As a result of committed and implemented control measures and despite projected population growth for the Phoenix area, overall emissions ofNOx are estimated to trend downward through 2025. Similar to VOC emissions trends, on-road NOx emissions are expected to be reduced nearly 30 percent between 2005 and 2025, due primarily to replacement ofolder, high-polluting vehicles with new models that meet more stringent federal emission standards. 13 New federal exhaust emission standards for highway motorcycles are expected to significantly reduce emissions ofNOx and HC from this source category (see Section 3). Additionally, research has shown that engine repairs to reduce CO emissions can increase NOx emissions. It is reported that changes in HC and CO emission rates are positively related but both are inversely related to changes in NOx emissions. For example, enleaning the air-fuel ratio (i.e., a repair aimed at a CO emissions failure where the air-fuel ratio is adjusted to provide less fuel per unit ofair, usually associated with carburetion) will increase NOx emissions. 14 Any change in NOx emissions due to the exemption relative to overall emissions is expected to be minimal and no replacement measure is provided.


### 2.2 Substitute Measure for VOC Emissions Clean Air Act Section 183(e) requires EPA to control VOC emissions from certain categories of consumer and commercial products to help reduce emissions contributing to ozone pollution. On March 24, 2008, EPA issued new national emissions standards for aerosol coatings (spray paints and coatings) under Section 183(e) (73 FR 15604; March 24, 2008; Docket ID No
. EPA-HQOAR-2006-0971)
. The compliance date for the new rule, set in a subsequent notice, was July I, 2009
. The rule established nationwide reactivity-based standards for aerosol coatings that better control a product's contribution to ozone formation by requiring the use of less reactive VOC ingredients. The rule is applicable to manufacturers, processors, distributors, or importers of aerosol coatings used by both the general public and industrial applications
. In the final rule EPA estimated that the"
... rule will reduce nationwide emissions ofVOC from the use of aerosol coatings by an estimated 17,130 tons (15,570 Mg) from the 1990 baseline
. This represents a 19.4 percent reduction from the 1990 baseline of 88,300 tons (80,270 Mg) of VOC emissions from the product category." EPA further stated, "While we believe that the

13 See Footnote 2
. 14 See Costs, Emissions Reductions, and Vehicle Repair: Evidencefrom Arizona, Resources/or the Future, Revised October 1999
.
Final 11M Program SIP Addendum [0[220 6above numbers accurately assess the impacts of the final rule for SIP credit purposes, we recognize,that significant reductions have already occurred as the result ofthe implementation of the CARS aerosol coatings regulations. Because many manufacturers sell 'CARB compliant' coatings across the country, some ofthese VOC emission reductions have already been achieved outside ofCalifornia. We estimate that approximately 18 percent ofthe total products sold are not currently compliant with this rule's limits. Therefore, we estimate that this rule will result in additional VOC reductions equivalent to 3,I00 tons per year (i.e., 18 percent of 17, 130 tons per year). The reduction of 3, 100 tons per year of VOC emissions represents new reductions. However, for ozone SIP purposes, we are providing States that do not currently have aerosol coating regulations in place full credit for the 19.4 percent reduction from the 1990 baseline. This 19.4 percent reduction is equivalent to a 0.114 pound ofVOC reduction per capita." 15 At the time ofpromulgation there were no national regulations addressing VOC emissions from aerosol coatings and California, Oregon, and Washington were the only states that regulated this product category (73 FR 15609). In addition, this measure was not used for numeric emissions reduction credit in 

### Eight-Hour Ozone Planfor the Maricopa NonattainmentArea, June 2007, or 

### MAG Eight-Hour Ozone Redesignation Request and Maintenance Plan for the Maricopa NonattainmentArea, February 2009. Table 3 shows the estimated VOC emissions increase for the motorcycle exemption relative to the emissions reduction credit provided by the aerosol coatings rule. Forthe Phoenix ozone planning area (1997 8-hour ozone nonattainment area) the allowed credit equates to 217.85 tons [per year].**Tabl~** 

### 3: Comparison ofthe Aerosol Coatings RuleVOC Emissions Reductions for the Phoenix Ozone PlanningAreawith the Change in Emissions Due to the Motorcycle Exemption Calculated Emission

Annual Emissions Increase NonattainmentArea (1997 Reduction from Aerosol Due to Exemptionl6 standard) Population* Coatings Rulel ? (population x 0.114 pound)
22.53 (short) tons per year 3,821,974 217.85 (short) tons per year 

## * 2004 population estimate from 2005 Periodic Emission Inventoryfor Ozone Precursorsfor the Maricopa County,Ari zona, NonattainmentArea (Maricopa County Air Quality Department, 2008)
. Arizona applies emissions reduction credit of 22.53 tons per year of the 217.85 tons per year reduction from the national aerosol coatings rule for the 2008 8-hour ozone NAAQS. This substitute measure provides emission reductions equivalent to that obtained from the testing of motorcycles in Area A.

15 CARB is the California Air Resources Board
. 16 The emissions change due to the exemption was estimated to be 0
.0560 metric tons per day (see Table 1) or 20.44 metric tons per year which equates to 22
.53 short tons per year. 17 The 2004 nonattainment area population of3,821,974 multiplied by 0.114 pound equals 435,705.04 pounds or 217
.85 short tons per year. This is equivalent to 197
.6 metric tons.
Final IIM Program SIP Addendum 101220 7

### 3.0 DEMONSTRATION OF NONINTERFERENCE WITH ATTAINMENT OF THE PMIO 

### NATIONAL AMBIENT AIR QUALITY STANDARDS Particulate matter 10 micrometers in diameter and smaller is referred to as PM 10. In 1991, EPA designated portions of Maricopa County and Pinal County as a moderate PM IO nonattainment area under the Clean Air Act (CAA) Amendments of 1990. The planning area was reclassified to serious effective June 10, 1996, because it did not meet a December 31, 1994, attainment deadline (61 FR 21372; May 10, 1996). Progress toward attainment ofthe PM IO air quality standards has been addressed through several SIP revisions. Most recently, the 

### RevisedMAG 

### 1999 Serious Area Particulate Planfor PM-10 for the Maricopa County Nonattainment Area, February 2000, was submitted to EPA on February 16, 2000. The plan contained approximately seventy-seven committed control measures from the State and local agencies designed to demonstrate attainment of the PM 10 standard by December 31, 2006. Due to continued exceedances, however, the 

### MAG 2007 Five Percent Planfor PM-10for the Maricopa County Nonattainment Area, December 2007, was submitted on December 21, 2007. 

### 11M programs are not designed to reduce direct PM emissions. As noted above, the Area A IIM program, depending on vehicle type, includes emissions standards for CO, HC, and NOx but does not contain specific standards ortesting for PM10. Oxides ofnitrogen are a presumptive precursor for PM2 .5 and a secondary contributor to PM IO• Although NOx testing is required for certain automobiles, motorcycles are only subject to emissions standards and testing for CO and He. In addition, MOBILE6 does not assign any PM lo emissions reduction credit for 

### 11M programs and therefore, no modeled emissions reductions were used for credit in the Maricopa PM IO planning area SIP. Nevertheless, because motorcycle emissions contribute a portion ofthe area's emissions inventory and attainment ofthe PM IO NAAQS has not yet been achieved, EPA requested additional analysis ofthe impacts ofexempting motorcycles from the IIM program. Section 3.1 evaluates how PM10 contributions from motorcycles may change as a result ofthe motorcycle exemption.


### 3.1 PM IO

### Emissions According to EPA's final 2004 motorcycle rule, "Highway motorcycles contribute to ambient pal1iculate matter in two ways. First, they contribute through direct emissions of particulate matter in the exhaust. Second, they contribute through the indirect formation of PM (namely ammonium nitrate and organic carbonaceous PM2s) in the atmosphere through their NOx and organic carbon emissions, especially HC.,,18, 19 Direct emissions include elemental carbon, organic carbon, and sulfates. The Maricopa County Air Quality DepaJ1ment's 

### 2008 PM,o Periodic Emissions Inventoryfor the Maricopa County, Arizona, Nonattainment Area, June 2010, estimates that on-road mobile sources comprise 42 percent oftotal PM IO emissions in the Phoenix planning area. Motorcycles represent 0.008 percent ofannual PM 10 emissions totals.20

18 See 69 FR 2398; January 15, 2004. 19 Please note that PM25 is a subset ofPM IO• 20 Emissions estimates include exhaust, tire wear, and brake wear emissions
.
Final IIM Program SIP Addendum 101220 8The 2008 Emissions Inventory attributes approximately 6.2 tons per year of PM IO from motorcycles to the Maricopa County PM)o nonattainment area?) This figure is an increase of 1
. 1 tons per year of PM 10 from the 2005 inventory published three years earlier. The increase in PM)o is likely due to an increase in motorcycle ownership in the PM)o nonattainment area. Even though the fleet is growing in size, however, recent growth is associated with 2006-20I0 model year motorcycles, which are required to meet stricter federal emissions standards for HC and NOx. Motorcycle ownership trends also indicate that motorcycle ownership per person, also called motorcycle density, has trended downward slightly since 2005. This means that community-average exposure to motorcycle exhaust, including PM)o, is decreasing slightly, since motorcycle density is decreasing
. . The evaluation of expected PM IO impacts below begins with a review of the new federal motorcycle emission standards and follows with an examination of: I) motorcycle density and ownership trends within the PM IO nonattainment area; 2) motorcycle fleet turnover by replacement ofolder vehicles with motorcycles meeting new federal emissions standards; and 3) modeled emissions changes that may be attributable to the exemption
.
New Federal Exhaust Emissions Standards for Motorcycles In January 2004 EPA adopted revised exhaust emission standards for highway motorcycles of50 cubic centimeters (cc) displacement and above (Control of Emissions From Highway Motorcycles; Final Rule: 69 FR 2398; January 15, 2004). At the same time EPA established new exhaust emission standards for motorcycles ofless than 50 cubic centimeters displacement, which had not previously been regulated. See Table 4 for a comparison ofold and new standards. The federal rule also includes, beginning in 2008, new permeation evaporative emission standards to reduce fuel loss through fuel tanks and fuel hoses. The revised and new regulations are applicable to motorcycle manufacturers and commercial importers ofvehicles and parts. Table

### 4: Comparison ofFederalHi2hwayMotorcycleExhaustEmissions Standards* New Standards Old Standards Engine Size (cc) Implementation HC (g/km) HC+NOx HC 

### (g/km) HC+NOx Date (New) 

### (g/km) (g/km) less than 50 2006 1.0


### - - - 50-169 2006 1.0


### - 5.0


### - 170-279 2006 1.0


### - 5.0
-

. 280 and above 2006 (Tier I)


### - 1.4 5.0


### - 2010 (Tier II)


### - 0.8 Source: u .S. Environmental ProtectIOn Agency. *Standards are applicable for the "useful life" ofthe vehicle (see 69 FR 2398; January 15,2004). Emission reductions may be accomplished through increased use of technologies such as secondary air injection, electronic fuel injection systems, and catalytic convel1ers. EPA estimates that the rule will reduce HC and NOx emissions by about 54,000 tons per year and prevent approximately 12 million gallons of fuel loss annually from fuel hoses and fuel tanks. EPA projects that when fully implemented, the rule will reduce exhaust and permeation emissions of HC and NOx by more than 50 percent. Although PM reductions are not quantified in the final rule, EPA affirms emissions reductions will occur and notes that "By reducing HC and NOx emissions from highway motorcycles, the standards we are finalizing will assist states as they

2 1 See Footnote 16.
Final 11 M Program SIP Addendum 101220 9implement local controls to reduce PM2.5 levels and help ensure long term maintenance with the NAAQS." The federal standards also achieve new emISSIOn reductions for vehicles not regulated by Arizona's 11M program. Under the Area A program vehicles with an engine displacement ofless than 90cc are exempt from inspection requirements. For 11M exempt vehicles with engine displacement of 50 to 89cc allowable HC emissions are reduced from 5.0 gram per kilometer (g/km) to 1
.0 g/km. As noted above, the same standards were adopted in the federal rule as a new requirement for motorcycles less than 50cc
. 

### Motorcycle Density Motorcycles are widely used throughout Europe and Asia and their popularity is no less diminished in the United States. Unlike many crowded European and Asian urban areas, however, transportation in U
.S
. cities is largely dominated by passenger vehicles rather than motorcycles. According to the Maricopa County 2005 periodic emissions inventory, Vehicle Miles Traveled (VMT) from motorcycles was approximately 

### I

### % of VMT for Light Duty Gasoline Vehicles (LDGV). The density of motorcycles to population, however, shows a slight decrease from 2005 to 2008. In 2005 there were 9.9 motorcycles per 1000 people in the nonattainment area and by 2008 that number saw a small decrease to 9.8 motorcycles per 1000 people. 

### Motorcycle Fleet With EPA's new emission standards for motorcycles, 2006 and newer motorcycles are required to meet stricter emissions standards than their 2005 and older counterparts. As the motorcycle fleet changes and older motorcycles are replaced with newer units, the net expected benefit is a reduction in pollution contributions from motorcycles and a resultant improvement in air quality. Figure I presents motorcycle registration data for the Maricopa County PM IO nonattainment area from 2003 to July 20I

### O. Total motorcycle registrations have increased from 43,119 in 2003 to 73,427 in 20I

### O. Although motorcycle ownership trends indicate that the nonattainment area fleet is growing in size, the growth is largely associated with 2006 and newer motorcycles, which have more stringent emissions standards than earlier models, while those ofmodel year 2005 and older have decreased steadily since 2006. "Old standard" motorcycle ownership has dropped from a maximum of56,680 units registered in 2006 to 44,011 units in 20I

### O
.

Final 1 1 M Program SIP Addendum 101220 10

### Figure 1: Motorcycle Registration Data from 2003 to July 2010 80000
70000
60000

r/) <1l 50000 U >.**~** 0


### .... 40000 0**~** 4-. 0

.... <1l 30000 

## "E ::l ;z. 20000
10000
0 2003 2004 2005 2006 2007 2008 2009 2010 Year


### o Model Year 2010 • ModelYear 2006-2009 0 Model Year2005 and ol der



### Modeled Estimations Because the 11M program does not include emissions standards for PM 1 0 and EPA's MOBILE6 emissions model does not assign PM emission reduction credit for 11M programs the exemption's impact on PM emissions cannot be directly assessed
. The following analysis, however, is intended to provide an estimation ofthe change in the PM 10 emission rate that may be associated with the change in gaseous HC emissions following implementation of the motorcycle exemption. The change in the rate of PM 10 production, in grams (g) of PM 10 per mile, was projected for the PM IO nonattainment area using MOBILE6
. The base case included motorcycles in the 11M testing program and the projected case excluded motorcycles from IIM
. MOBILE6 is capabl e of quantifying the speciation of particulate emissions. Total particulate exhaust includes elemental carbon (ECARBON), organic carbon (OCARBON), sul fate (S04) and lead. 22 For diesel vehicles, MOBILE6 breaks down PM emissions to elemental carbon, organic carbon, sulfate and lead, however, for gasoline vehicles, PM emissions are broken down to GASPM, sulfate and lead
. GASPM includes elemental carbon, organic carbon and residue carbon.

22 MOBILE6 provides estimates ofdirect PM emissions. There are no reliable models for estimating secondary organic particulates.
Final 1 1 M Program SIP Addendum 101220 I IScenario 20 I0 summer without I/M was modeled using MOBILE6
. Table 5 shows the PM IO emission factors?3



### Table 5: PMlO 

### Emission Factors (in glmile) LDGV LDGT HDGV LDDV LDDT HDDV MC GASPM 0.004 0.0041 0.0272 N/A N/A N/A 0.0205 ECARBON N/A N/A N/A 0.0413 0.0163 0
.0532 N/A OCARBON N/A N/A N/A 0.0116 0.0235 0.0271 N/A S04 0.0003 0.0005 0.0017 0.0002 0.0003 0.0009 0.0001 Total ExhaustPMIO 0.0043 0.0046 0
.0289 0
.0531 0.0402 0.0812 0.0206 Table 5 indicates that motorcycles are all powered by gasoline and their GASPM is 0.0205 g/mile. To be conservative, it is assumed that the residue carbon in GASPM is negligible since no information is available to determine the quantity of residue carbon
. By neglecting residue carbon, GASPM is only composed ofelemental and organic carbon. Since MOBILE6 does not specify the emission factors ofelemental and organic carbon for gasoline powered vehicles, the ratio of ECARBON to OCARBON for motorcycles is assumed to be one part ECARBON to every four parts OCARBON.24 OCARBON (motorcycle) = GASPM (motorcycle) x 4/5 = 0.0164 g/mile The 2009 exemption request included modeled (MOBILE6) emission factors for no 11M and calculated a benefit or impact for testing motorcycles (an estimated HC emission reduction due to the I/M program)
. According to Table 4 in Appendix B ofthe 2009 submittal, the I/M impact on emissions ofHC is 0.1250 g/mile, while the emission factor for HC without liM is 3.16 g/mile. It is assumed that the 11M impact for organic carbon in GASPM is similar to that ofHe. MCincrease (OCARBON) = 0.0164 x 0.1250/3.16 = 0.0006487 g/mile By exempting motorcycles, the emission factor ofOCARBON may change by 0.0006487 g/mile. The maximum estimated mass emission increases for PM 10 by the motorcycle 11M exemption are shown as follows, EIMC = MCincrease (OCARBON) x VDMC x VMTtotal
= 0.0006487 g/mile x 0.0046 x 97,488,505 miles/day
= 282.72 g/day = 0.00028272 metric tons/day Where, EIMC = the mass emission increases by the exemption of motorcycles from the 11M program in Area A, VDMC = vehicle miles traveled (VMT) distribution for motorcycles (0
.0046), and VMTtotal = daily total VMT in Area A (97,488,505 miles/day). The total on-road portion of PM 10 emissions is 78.22 metric tons/day in area A and total PM 10 emissions are 235.02 metric tons/day in the 8-hour ozone nonattainment area for 2010. 25 Thus, the relative increase in on-road PM 10 emissions due to the exemption ofmotorcycles is 3.61 x 10.4

23 The organic PM emission factors are proportionally based on the gaseous HC emissions component. 24 Source: SPECIATE Data Browser, http://cfpub.epa.gov/si /speciate/index.cfm, October 14, 2010. 25 Emissions values were provided by leesuck Jung, Maricopa Association ofGovernments.
Final 11M Program SIP Addendum 101220 12percent (0
.000361 

### %) in Area A, and the relative increase in total PM IO emissions in the nonattainment area is 1
.20 x 10.5 percent (0.000012 

### %). Summary of

### PM10 

### Impacts With recent federal exhaust emission standards for motorcycles, motorcycle ownership trends, and mobile source modeling the following conclusions are established:

• The fleet is getting newer as old model year motorcycles are replaced by newer models meeting more stringent federal emission standards, • The new federal emissions standards will reduce allowable 

### He and NOx emissions and consequently PM emissions, • The modeled change in the particulate matter emissions rate without 11M is estimated at 0
.0006487 glmile or a 0.000012 percent change in the planning area. The estimated emissions change is minimal and can be considered "noise" in the model. Given the results ofthe analysis no ambient impacts are expected
.

Final 1 1 M Program SIP Addendum 101220 13

### 4.0 CONCLUSION Emissions analyses contained in this addendum show a minimal effect on PM 10 emissions due to the exemption of motorcycles from 11M program requirements in Area A and any change represents a small fraction ofthe overall emissions inventories in the planning area. Additionally, new federal motorcycle standards provide emissions reductions not achieved by the Area A 11M program. This document also includes a replacement measure to offset estimated increases in VOC emissions, an ozone precursor, that may**oc~ur** following exemption. The information provided here and in 

### Final Arizona State Implementation Plan Revision, Exemption of Motorcycles from Vehicle Emissions Inspections and Maintenance Program Requirements in Area A, October 2009, demonstrate that the requested changes to the 11M program will not interfere with the areas' abilities to attain and maintain the ozone or PM IO NAAQS. With this submittal, ADEQ requests that the changes to Arizona's vehicle emissions inspections and maintenance program to exempt motorcycles from the Phoenix testing area be approved as a component ofArizona's SIP
.

Final 1 1 M Program SIP Addendum 101220 14

### Appendix A
State Implementation Plan Revision Public Comment and Hearing Documentation

### Appendix A.1
Notice ofPublic Hearing

## }4~~8::c AFFIDAVIT OF PUBLICATION 

# ADEQ AIR QUALITY DIVISION 

## 10 NOV 

# 1 8 AH 

# 10: If 

# THE ARIZONA REPUBLIC

STATE OF ARIZONA } COUNTY OF MARICOPA SS

.


### Mark Gilmore, being first duly sworn, upon oath deposes and says: That he is a legal advertising representative of the Arizona Business Gazette, a newspaper of general circulation in the county of Maricopa, State of Arizona, published at Phoenix, Arizona, by Phoenix Newspapers Inc., which also publishes The Arizona Republic, and that the copy hereto attached is a true copy of the advertisement published in the said paper on the dates as indicated.

November 15, 16, 2010

Sworn to before me this 16TH day of November A.D. 2010 The Arizona Republic

### Appendix A.2
Public Hearing Agenda

# A~!Q~ ofEnvironmental

# Quality~ P.ublic Hearing Agenda

AIR QUALITYDIVISION PUBLIC HEARING ONAPROPOSEDADDENDUM TO THE ARIZONASTATE IMPLEMENTATION PLAN (SIP) REVISION TO EXEMPT PHOENIX MOTORCYCLES FROMARIZONA'S VEHICLE EMISSIONS INSPECTION PROGRAM PLEASE NOTE THE MEETING LOCATIONAND TIME: Arizona Department ofEnvironmental Quality Conference Room 145 1110 West Washington Street, Phoenix,Arizona Wednesday, December 15, 2010, 4:30 p.m. Pursuant to 40 CFR 

### § 51.102 notice is hereby given that the above referenced meeting is open to the public.
I

. 

### Welcome and Introductions 2
. Purposes ofthe Oral Proceeding 3. Procedure for Making Public Comment 4. BriefOverview ofthe proposed SIP revision 5. Question and Answer Period 6. Oral Comment Period 7. Adjournment ofOral Proceeding Copies of the proposal are available for review at the Arizona Department of Environmental Quality (ADEQ) Records Center, 1110 W. Washington St., Phoenix, Arizona and ADEQ's website at http://wwW.azdeq.gov/cgi-bin/vertical.pl. For additional information regarding the hearing please call Bruce Friedl, ADEQ Air Quality Division, at (602) 771-2259 or 1-800-234-5677, Ext. 771-2259. Persons with a disability may request a reasonable accommodation, such as a sign language interpreter, by contacting Dan Flukas at (602) 771-4795 or 1-800

-234-5677, Ext. 771-4795. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation
. This document is available in alternative formats by contactingADEQ TDD phone number at (602) 771-4829.

Printed on recvcled paper

### Appendix A.3
Public 

### Hearing Sign In 

### Sheet

# I



# · if**~ ~!**  

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# Air 

# 0uality Division / ofEnvironmental

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### ____________________________________________ ___ 30.
__________________________________________________________________________ ___ 31.

__________________**~**

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### 32.
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________________________________________________________________**~**

### ________ ___ 34.
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### 35.
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______________________________________________________________________________ _ 37.
__________________________________________________________________________ ___ 38.
__________________________________________________________________________ ___

### Appendix A.4
Public Hearing Officer Certification and Transcript

### Air Quality Division

Public 

### HearingPresiding OfficerCertification
I, John Englander, the designated Presiding Officer, do hereby certify that the public hearing held by the Arizona Department of Environmental Quality on the November 2010, 

### Proposed Addendum to the Arizona State Implementation Plan Revision, Exemption of Motorcyclesfrom Vehicle Emissions Inspections and Maintenance Program Requirements in Area A,
.October 

### 2009 , was conducted on December 15, 2010, at the Arizona Department of Environmental Quality, Conference Room 145, 1110 West Washington Street, Phoenix, Arizona, in accordance with public notice requirements by publication in 

### The Arizona Republic and other locations beginning November 15, 2010. Furthermore, I do hereby certify that the public hearing was recorded from the opening ofthe public record through concluding remarks and adjournment, and the transcript provided contains a

### full, true, and correct record ofthe above-referenced public hearing.
. Dated this day of

State ofArizona ) ) ss. County ofMaricopa ) Subscribed and swamto before me on this 

# 8 OfFICIAL SEAL 

### LAURA MoFARLANO

. NOTARVPUBUC •stat&ofAmona**MARIOO~A** COUNTY OOftInt, _" I1.1018 

# Je, dayof

# ~J 0 010

.

# ~~~**. ~UbllC**  My commission expires:

# ~ J

# ~1 

### ARIZONA AIR QUALITY STATE IMPLEMENTATION PLAN REVISION TO EXEMPT 2 

### PHOENIX MOTORCYCLES FROM THE ARIZONA VEHICLE EMISSIONS INSPECTION 3 

### PROGRAM 4 5 6 7 8 9 10 

### John Englander: Oral Proceeding Transcript December 15, 2010

11 

### Good afternoon and thank you for coming. I now open this hearing on a proposed state 1 2 

### implementationplan, SIP, revisionto exemptPhoenixmotorcycles from Arizona'svehicle emissions 13 

### inspection and maintenance program. 14 15 

### It 

### is now Wednesday, December 15, 2010, and the time is 4:36 p.m. The location is the Arizona 1 6 

### Department of Environmental Quality, Conference Room 145, 1110 West Washington Street, 1 7 

### Phoenix, Arizona. My name is JohnEnglanderand Ihave been appointed by the DirectorofADEQ 1 8 

### to preside at this hearing. 1 9 20 

### The purposes ofthis proceeding are to provide the public an opportunity to: 2 1 

### (1) hear about the substance ofthe proposed SIP revision, 22 

### (2) ask questions regarding the proposal, and 23 

### (3) present oral argument, data, and views regarding the proposal in the form ofcomments on the 2 4 

### record
. 25 26 

### Representing the Department are Eric Massey, Director of the Air Quality Division, Leonard 27 

### Montenegro, Evaluation Unit Supervisor, John Walls, 28 29 

### Bruce Friedl: 30 

### He's not here today. 3 1 32 

### John Englander: 33 

### He's not here? Alright, sorry. Deborrah Martinkovic and Bruce Friedl ofthe Planning Section. 34 35 

### Publicnoticewas published in 

### TheAri zonaRe publiconNovember 15 and 16, 2010,and onADEQ's 36 

### website. Copies of the November 2010 proposal titled, 

### Addendum to the Arizona State 37 

### Implementation Plan Revision, Exemption o fMotorcycles from Vehicle Emissions Inspections and 38 

### Maintenance Program Requirements in Area A, October 2009,were made available at the ADEQ 39 

### Phoenix office and on ADEQ's website on November 15,2010
. 40 4 1 

### The procedure for making a public comment on the record is straightforward. If you wish to 42 

### comment,you need to fill out a speaker slip,which is available atthe sign-in table,and give itto me. 43 

### Using speakerslips allows everyonethe opportunityto be heard and allowsus to matchthe name on 44 

### the official record with the comment. You may also submit written comments to me today. Please 45 

### note the comment period for the proposal ends at the conclusion ofthis hearing or 6 p.m. today, 11 

### December 15,2010,whichever is later. All written comments mustbe postmarked ifsentvia U.S
. 2 

### mail or received, ifsent via e-mail, at ADEQ by December 15, 2010. Written comments can be 3 

### mailed to BruceFriedl, Air QualityPlanning Section, ArizonaDepartmentofEnvironmental Quality, 4 

### 1110 W. Washington Street, Phoenix, Arizona 85007 orfriedl.bruce@azdeg.gov. Comments may 5 

### also be faxed to (602) 771-2366. 6 7 

### Comments made during the formal comment period are required by law to be considered by the 8 

### Department when preparing the final state implementation plan
. This is done through the 9 

### preparation ofa responsiveness summaryinwhichthe Departmentresponds in writingto written and 10 

### oral comments made during the formal comment period. 11 1 2 

### The agendafor this hearing is simple. Firs,Iwill presenta briefoverviewofthe proposed revision 1 3 

### to the state implementation plan. 1 4 15 

### Second, Iwill conducta question and answerperiod. Thepurposeofthe question and answerperiod 16 

### is to provide information that may help you in making comments onthe proposed revision. 17 18 

### Thirdly, I will conduct the oral comment period. At that time, I will begin to call speakers in the 19 

### order that I have received speaker slips. 20 2 1 

### Please be aware that any comments you make at today's hearing that you want the Department to 22 

### formally considermustbe given eitherin writing oronthe record duringthe oral commentperiod of 23 

### this proceeding. Atthis time, I will give a briefoverview ofthe proposal. 24 25 

### Vehicle emissions inspection and maintenance programs, or 

### 11M programs, are required in certain 26 

### areas that do not meet the carbon monoxide and ozone air quality standards with the purpose of 27 

### reducing emissions and improving air quality
. These programs help identify vehicles with excess 28 

### emissions, provide informationto assistwith diagnosing malfunctionsthatcause excess emissions, 29 

### and require repairofvehicles to bringthem into compliancewith emissions standards. ThePhoenix 30' 

### 11M program is included as a control measure in the Arizona SIP and is among the primary control 3 1 

### measures used to help the Phoenix area meet and maintain the ozone and carbon monoxide air 32 

### quality standards. 33 34 

### In 2008 the ArizonaLegislaturepassedHouse Bill 2280, which amended ArizonaRevised Statutes, 35 

### orARS, 

### §49-542 to authorizethe exemptionofmotorcycles from emissionstestingrequirements in 36 

### Area A, the Phoenix testing area. The changes to ARS 

### § 49-542 will become effective only upon 37 

### approval by the U.S. Environmental Protection Agency, EPA, as a revision to the SIP
. 38 39 

### ADEQ submitted a SIP revision entitled 

### Final Arizona State Implementation Plan Revision, 40 

### Exemption ofMotorcycles from Vehicle Emissions Inspections and Maintenance Program 41 

### Requirements inAreaA, October2009, to EPAonNovember 6, 2009. The SIP revisioncontained

### a 42 

### request for EPA to approve the changes to Arizona's 11M program. Because revisions to SIP 43 

### approved control measures mustnotinterfere withtherequirements oftheCleanAirAct, according 44 

### to CAA Section 11O(i), 45 

### 21 

### Bruce Friedl: 2 

### (1)
. 3 4 

### John Englander: 5 

### 0), sorry, the October 2009 submittal also evaluated the impact of exempting Phoenix area 6 

### motorcycles on air quality and included a demonstration that the exemption will not interfere with 7 

### the ability ofthe Phoenix area to attain or maintain the National Ambient Air Quality Standards, 8 

### NAAQS, orwith any other requirement ofthe Clean Air Act. 9 1 0 

### Inspection and maintenanceprograms are not designed to reduce directparticulate matteremissions. 11 

### Nevertheless, motorcycle emissions do contribute a portion of the area's emissions inventory. 1 2 

### During its review ofthe exemption request, EPA asked for additional information regarding the 1 3 

### impact ofthe exemption on attainment ofthe PMIO NAAQS. In addition, because ofa recent 1 4 

### change inthe ozoneNAAQS,EPArequested a replacement measure to offset estimatedincreasesin 1 5 

### emissions ofvolatile organic compounds, VOCs, an ozone precursor, due to the exemption. 16 1 7 

### The proposed Addendum summarizes the exemption's impact on the ozone precursor emissions, 1 8 

### VOC and oxides of nitrogen, and includes a substitute measure that provides VOC emission 1 9 

### reductions equal to those achieved by the testing and repair ofmotorcycles. The Addendum also 20 

### contains further analysis ofPM 10 

### emission impacts expected from the change in the 11M program. 2 1 22 

### Analysis ofPMIO emissions impacts and the VOC replacement measure are more fully described in 23 

### the proposed Addendum. 24 25 

### This concludes the explanation portion of this proceeding on the proposed revision to the state 26 

### implementationplan. Are there any questions before we moveto the oral commentperiod? Alright, 27 

### hearing none,this concludesthe question and answerperiod ofthis proceedingonthe proposed state 28 

### implementation plan revision. 29 3 0 

### I now open this proceeding for oral comments. 3 1 32 

### Um, I have one comment card at this time. So, Sky Pilot? 33 34 

### Sky Pilot: 35 

### Sky Pilot. 36 37 

### John Englander: 38 

### Sky Pilot, alright. Um, you can go ahead and make your comment. 39 40 

### Sky Pilot: 41 

### Okay. I just, on the behalf of the Arizona Confederation of Motorcycle Clubs and other 42 

### motorcyclists, we thank you, members ofthe ADEQ, for all you put into it. It

### was an enormous 43 

### amount ofwork that you've done and Ijust want to praise and thank you for, including doing this 44 

### contingency thing that you had to come up with. We really appreciate the hard work and efforts. 45 

### 31 

### John Englander: 2 

### Alright, thank you for your comment. Are there any othercomments before we go ahead and move 3 

### on? Alright, this concludes the oral comment period ofthis proceeding. 4 5 

### If you have not already submitted written comments, you may submit them to me at this time. 6 

### Again, the commentperiod for this proposed revision to the state implementation plan ends today, 7 

### December 15,2010. B 9 

### Thank you for attending. The time is now 4:46 and I will close this oral proceeding.

4

### Appendix A.S 

### Responsiveness Summary

### RESPONSIVENESS SUMMARY to Testimony Taken at Oral Proceeding and Written Comments Received on 

### Addendumto theArizonaState Implementation Plan Revision, Exemption of Motorcyclesfrom Vehicle EmissionsInspections andMaintenance Program Requirements inAreaA The oral proceeding on the November 20I

# ° proposal 

### Addendum to the Arizona State Implementation Plan Revision, Exemption of Motorcyclesfrom Vehicle Emissions Inspections andMaintenance Program Requirements in AreaA, October 2009, was held on Wednesday, December 15,20I0, at 4:36 p.m., at the Arizona Department of Environmental Quality (ADEQ), Conference Room 145, II lOWest Washington Street, Phoenix, Arizona. The public comment period began on November 15, 20I0, and closed on Wednesday, December 15, 20I0, at 6:00 p.m. ADEQ received one verbal and one written comment in support of exempting motorcycles from emissions testing in Area A. ADEQ appreciates the positive comments regarding the exemption ofmotorcycles from emissions testing. No changes were made in response to public comments received, however, during its final review ofthe proposed State Implementation Plan revision, ADEQ made minor corrections' for clarity, grammar and formatting.