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: Arizona State Implementation Plan Revision, Exemption of Motorcycles from Vehicle 

Emissions Inspections and Maintenance Program Requirements in Area A 

-:rC\(~ ; 

Dear enfeld: 

Consistent with the provisions of Arizona Revised Statutes (ARS) Title 49, §§ 49-104 and 49-

404 (Enclosure 1) and the Code of Federal Regulations (CFR) Title 40, §§ 51.102-51.104, the 

Arizona Department of Environmental Quality (ADEQ) hereby adopts and submits to the U.S. 

Environmental Protection Agency (EPA) the December 2010, Addendum to the Arizona State 

Implementation Plan Revision, Exemption of Motorcycles from Vehicle Emissions Inspections 

and Maintenance Program Requirements in Area A, 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 of motorcycles from emissions testing requirements in Area A, the 

Phoenix testing area. The changes to ARS § 49-542 are self implementing and become effective 

if approved 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 Motorcycles from 

Vehicle Emissions Inspections and Maintenance Program Requirements in Area A, October 

2009, to EPA on November 6,2009. As required under Clean Air Act Section 110(1), the SIP 

revision contained analyses of emissions impacts due to the exemption and a request for EPA to 

approve the changes to Arizona's 11M program. 

During its review of the exemption request, EPA asked for additional information regarding the 

impact of the exemption on attainment of the PM 10 National Ambient Air Quality Standards 

(NAAQS). In addition, because of a recent change in the ozone NAAQS, EPA requested a 

replacement measure to offset estimated increases in emissions of volatile 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 of nitrogen, 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 of the high level of interest and support for 

this measure in Arizona, ADEQ continues to request expedited review and approval of this SIP 

reVISiOn. 

Enclosure 2 contains the SIP Completeness Checklist. Enclosure 3 contains two paper copies 

and one electronic copy of the SIP revision for your review and action. If you 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 of Governments, 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 with the 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 if the 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. If the 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. If the 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 

Addendum to the Arizona State Implementation Plan Revision, Exemption of Motorcycles from 

Vehicle Emissions Inspections and Maintenance Program Requirements in Area A, October 2009 

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. REGULA TION CHANGES INDICATED BY UNDERLINING AND CROSS-OUTS 

See Arizona State Implementation Plan Revision, Exemption of Motorcycles from Vehicle 

Emissions Inspections and Maintenance Program Requirements in Area A, 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 

Arizona State Implementation Plan Revision 

Exemption of Motorcycles from Vehicle Emissions Inspections and Maintenance 

Program Requirements in Area A, October 2009 

December 2010 

of Environmental Quality (~ 

Final 

Addendum 

to the 

Arizona State Implementation Plan Revision 

Exemption of Motorcycles from Vehicle 

Emissions Inspections and Maintenance 

Program Requirements in Area A 

October 2009 

Air Quality Division 

December 2010 
(This page intentionally left blank.) 
T ABLE 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 20 I 0 ..................................................... 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 of the 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 of Federal 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 of Public 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 III 
This 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 

(PM to). 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 of vehicles 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 if approved 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 of Motorcycles from 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 of the 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 of the Phoenix area 

to attain or maintain the NAAQS or with any other requirement ofthe Clean Air Act. 

During its review of the 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 of Area A. 

2 See Final Serious Area Ozone State Implementation Planfor Maricopa County, December 2000; OneHour Ozone Redesignation Request and Maintenance Plan for the Maricopa County Nonattainment Area, 

March 2004; Eight-Hour Ozone Planfor the Maricopa Nonattainment Area, June 2007; MAG Eight-Hour 

Ozone Redesignation Request and Maintenance Plan for the Maricopa Nonattainment Area, February 

2009; Revised MAG 1999 Serious Area Carbon Monoxide Planfor the Maricopa County Nonattainment 

Area, March 2001 ; and Carbon Monoxide Redesignation Request and Maintenance Planfor the Maricopa 

County Nonattainment Area, May 2003. 

3 PM IO and Ozone are two of the 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 101220 
change in the ozone NAAQS, EPA also requested a replacement measure to offset estimated 

increases in emissions of VOCs, an ozone precursor, due to the exemption. 

Section 2 of this 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 of motorcycles. 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 OF THE 

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 of the 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 of Motorcycles from Vehicle Emissions Inspections 

and Maintenance Program Requirements in Area A, 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 of both 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 of a 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 of exposure 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 of eastern 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 of the 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 of motorcycles 

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 of Area A motorcycles. 

4 See Arizona Administrative Code Title 18, Chapter 2, Article 10. 

5 The level of the primary and secondary standard was a one-hour average of 0.12 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 of the primary and secondary standards was set at 0.08 ppm averaged over 8 hours. The form or 

attainment test is the three-year average of the annual foul1h highest 8-hour average concentration, 

calculated for each monitor. 

7 See Footnote 2. 

Final 11M 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 of the 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 of Maricopa 

and Pinal Counties. Designation of attainment and nonattainment area boundaries is one of the 

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 of any 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 of ozone pollution (75 FR 2938; 

January 19, 20 I 0). 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 of the 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 of the 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 of Motorcycles 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 Precursors for 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 of tested vehicles in Area A and 

represent 0.3 percent of annual VOC emissions totals in the planning area.

8 

8 Vehicle Emissions Inspection Program data for 2007/2008 . 

Final 11M Program SIP Addendum 101220 4 
The 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 of Governments completed a modeling analysis to determine the 

emissions reduction benefits from testing and repair of Area 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 of a 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: Change in On-Road VOC Emissions Due to Motorcycle 

Exemption in Area A 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 of on-road emissions in Area A) 

Table 2: Change in Total VOC Emissions Due to Motorcycle Exemption 

Relative to the 8-Hour Ozone Nonattainment Area (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 of older, 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 20 10 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 20 I 0 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 

Inventory for Ozone Precursors for the Maricopa County, Arizona, 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 Precursors for 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 of annual 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 of NOx 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 of older, 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 of NO x 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 of air, 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 1 83(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 of VOC 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 6 
above numbers accurately assess the impacts of the final rule for SIP credit purposes, we 

recognize, that significant reductions have already occurred as the result of the implementation of 

the CARS aerosol coatings regulations. Because many manufacturers sell 'CARB compliant' 

coatings across the country, some of these VOC emission reductions have already been achieved 

outside of California. We estimate that approximately 18 percent of the 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, I 00 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 of VOC reduction per capita." 15 

At the time of promulgation 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 Plan for the Maricopa Nonattainment Area, June 2007, or 

MAG Eight-Hour Ozone Redesignation Request and Maintenance Plan for the Maricopa 

Nonattainment Area, 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. For the Phoenix ozone planning 

area (1997 8-hour ozone nonattainment area) the allowed credit equates to 217.85 tons [per year]. 

Tabl~ 3: Comparison of the Aerosol Coatings Rule VOC Emissions Reductions for the 

Phoenix Ozone Planning Area with the Change in Emissions Due to the Motorcycle 

Exemption 

Calculated Emission 

Annual Emissions Increase Nonattainment Area (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 Inventory for Ozone Precursors for the Maricopa 

County, Arizona, Nonattainment Area (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 of 3,821,974 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 PMIO 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 of the PMIO air quality standards has been addressed through several 

SIP revisions. Most recently, the Revised MAG 1999 Serious Area Particulate Plan for 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 Plan for PM-10 for 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 or testing for PM 10. Oxides of nitrogen are a presumptive precursor 

for PM2.5 and a secondary contributor to PMIO • 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 PMlo emissions reduction credit for 11M programs and 

therefore, no modeled emissions reductions were used for credit in the Maricopa PMIO planning 

area SIP. 

Nevertheless, because motorcycle emissions contribute a portion of the area's emissions inventory 

and attainment of the PMIO NAAQS has not yet been achieved, EPA requested additional analysis 

of the impacts of exempting motorcycles from the IIM program. Section 3.1 evaluates how PM 10 

contributions from motorcycles may change as a result ofthe motorcycle exemption. 

3.1 PMIO 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 Inventory for the 

Maricopa County, Arizona, Nonattainment Area, June 2010, estimates that on-road mobile 

sources comprise 42 percent of total PMIO emissions in the Phoenix planning area. Motorcycles 

represent 0.008 percent of annual PM 10 emissions totals. 20 

18 See 69 FR 2398; January 15, 2004. 

19 Please note that PM25 is a subset of PM IO• 

20 Emissions estimates include exhaust, tire wear, and brake wear emissions. 

Final IIM Program SIP Addendum 101220 8 
The 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 2006-20 I 0 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 PMIO 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 PMIO nonattainment area; 2) motorcycle fleet turnover by 

replacement of older 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 of 50 

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 of less than 50 cubic centimeters displacement, which 

had not previously been regulated. See Table 4 for a comparison of old 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 of vehicles and parts. 

Table 4: Comparison of Federal Hi2hway Motorcycle Exhaust Emissions 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" of the 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 

21 See Footnote 16. 

Final 11M Program SI P Addendum 101220 9 
implement 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 of less 

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 PMIO nonattainment area 

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

73,427 in 20 I 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 of model year 2005 and older 

have decreased steadily since 2006. "Old standard" motorcycle ownership has dropped from a 

maximum of 56,680 units registered in 2006 to 44,011 units in 20 I O. 

Final 11M 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 • Model Year 2006-2009 0 Model Year 2005 and older 

Modeled Estimations 

Because the 11M program does not include emissions standards for PM 10 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 fo llowing analysis, however, is 

intended to provide an estimation of the change in the PM 10 emission rate that may be associated 

with the change in gaseous HC emissions fo llowing implementation of the motorcycle 

exemption. 

The change in the rate of PM 10 production, in grams (g) of PM10 per mi le, was projected for the 

PMIO nonattainment area using MOBILE6. The base case included motorcycles in the 11M testing 

program and the projected case excluded motorcycles from IIM. MOBILE6 is capable of 

quantifying the speciation of particulate emissions. Total particulate exhaust includes elemental 

carbon (ECARBON), organ ic carbon (OCARBON), sulfate (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, su lfate and lead. 

GASPM includes elemental carbon, organic carbon and residue carbon. 

22 MOBILE6 provides estimates of direct PM emissions. There are no reliable models for estimating 

secondary organic particulates. 

Final 11M Program SIP Addendum 101220 I I 
Scenario 20 I 0 summer without I/M was modeled using MOBILE6. Table 5 shows the PMIO 

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 Exhaust PMIO 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 of elemental and organic carbon. Since MOBILE6 does not 

specify the emission factors of elemental 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 of the 2009 submittal, the I/M impact on 

emissions of HC 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 GAS PM is similar to that of He. 

MCincrease (OCARBON) = 0.0164 x 0.1250/3.16 = 0.0006487 g/mile 

By exempting motorcycles, the emission factor of OCARBON 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 of motorcycles is 3.61 x 10.4 

23 The organic PM emission factors are proportionally based on the gaseous HC emissions component. 

24 Source: SPECIA TE Data Browser, http://cfpub.epa.gov/si/speciate/index.cfm, October 14, 2010. 

25 Emissions values were provided by leesuck Jung, Maricopa Association of Governments. 

Final 11M Program SIP Addendum 101220 12 
percent (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 PM 10 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 of the analysis no ambient impacts are expected. 

Final 11M 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 of the 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 PMIO 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 of Arizona's SIP. 

Final 11M Program SIP Addendum 101220 14 
Appendix A 

State Implementation Plan Revision Public Comment and Hearing Documentation 

Appendix A.1 

Notice of Public Hearing 

}4~~8::c 

AFFIDA VIT OF PUBLICA TION 

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 

of 

A~!Q~ Environmental Quality~ P.ublic Hearing Agenda 

AIR QUALITY DIVISION 

PUBLIC HEARING 

ON A PROPOSED ADDENDUM TO THE 

ARIZONA STATE IMPLEMENTATION PLAN (SIP) REVISION 

TO EXEMPT PHOENIX MOTORCYCLES FROM ARIZONA'S VEHICLE EMISSIONS 

INSPECTION PROGRAM 

PLEASE NOTE THE MEETING LOCATION AND TIME: 

Arizona Department of Environmental 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 of the Oral Proceeding 

3. Procedure for Making Public Comment 

4. Brief Overview of the proposed SIP revision 

5. Question and Answer Period 

6. Oral Comment Period 

7. Adjournment of Oral 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 contacting ADEQ TDD phone number at (602) 771-4829. 

Printed on recvcled paper 

Appendix A.3 

Public Hearing Sign In Sheet 

I 

·if 

~ 

~! ADE-.· 

Arizona Department 

!l' 

Air 0uality Division 

/ 

of Environmental Oua1litv / Sign-In Sheet 

Please Sign In 

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NAME ORGANIZATION . PHONE FAX E-MAIL 

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25. ________________ ~---------------------------------------------------------

26. __________________________________________________________________________________ __ 

27. __ ~ __________________________ ~ ________ ~ __________________________________ _ 

28. ___________________ ----:---_______ __ 

29. __________________________ ~~ ____________________________________________ ___ 

30. __________________________________________________________________________ ___ 

31. __________________ ~ ______________________________________________________ ___ 

32. ______________________________________________________________________________ _ 

33. ________________________________________________________________ ~ ________ ___ 

34. ________________________________________________________________________________ _ 

35. ______________________________________________________________________________ _ 

36. ______________________________________________________________________________ _ 

37. __________________________________________________________________________ ___ 

38. __________________________________________________________________________ ___ 

Appendix A.4 

Public Hearing Officer Certification and Transcript 

Air Quality Division 

Public Hearing Presiding Officer Certification 

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 Motorcycles from 

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 of the public record through concluding remarks and adjournment, 

and the transcript provided contains a full, true, and correct record of the above-referenced public 

hearing. . 

Dated this day of 

State of Arizona ) 

) ss. 

County of Maricopa ) 

Subscribed and swam to before me on this 

8 OfFICIAL SEAL 

LAURA MoFARLANO . NOTARV PUBUC • stat& of Amona MARIOO~A COUNTY 

OOftInt, _" I 1.1018 

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 implementation plan, SIP, revision to exempt Phoenix motorcycles from Arizona's vehicle 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 John Englander and I have been appointed by the Director of ADEQ 

1 8 to preside at this hearing. 

1 9 

20 The purposes of this proceeding are to provide the public an opportunity to: 

2 1 (1) hear about the substance of the 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 of comments 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: 

3 0 He's not here today. 

3 1 

32 John Englander: 

33 He's not here? Alright, sorry. Deborrah Martinkovic and Bruce Friedl of the Planning Section. 

34 

35 Public notice was published in The Arizona Republic on November 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 of Motorcycles 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 at the sign-in table, and give it to me. 

43 Using speaker slips allows everyone the opportunity to be heard and allows us to match the 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 of this hearing or 6 p.m. today, 

1 
1 December 15,2010, whichever is later. All written comments must be postmarked if sent via U.S. 

2 mail or received, if sent via e-mail, at ADEQ by December 15, 2010. Written comments can be 

3 mailed to Bruce Friedl, Air Quality Planning Section, Arizona Department of Environmental Quality, 

4 1110 W. Washington Street, Phoenix, Arizona 85007 or friedl.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 of a responsiveness summary in which the Department responds in writing to written and 

10 oral comments made during the formal comment period. 

11 

1 2 The agenda for this hearing is simple. Firs, I will present a brief overview of the proposed revision 

1 3 to the state implementation plan. 

1 4 

15 Second, I will conduct a question and answer period. The purpose of the question and answer period 

16 is to provide information that may help you in making comments on the 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 consider must be given either in writing or on the record during the oral comment period of 

23 this proceeding. At this time, I will give a brief overview of the 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 information to assist with diagnosing malfunctions that cause excess emissions, 

29 and require repair of vehicles to bring them into compliance with emissions standards. The Phoenix 

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 Arizona Legislature passed House Bill 2280, which amended Arizona Revised Statutes, 

35 or ARS, § 49-542 to authorize the exemption of motorcycles from emissions testing requirements 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 of Motorcycles from Vehicle Emissions Inspections and Maintenance Program 

41 Requirements in Area A, October 2009, to EPA on November 6, 2009. The SIP revision contained a 

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

43 approved control measures must not interfere with the requirements ofthe Clean Air Act, according 

44 to CAA Section 11 O(i), 

45 

2 
1 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 of the Phoenix area to attain or maintain the National Ambient Air Quality Standards, 

8 NAAQS, or with any other requirement of the Clean Air Act. 

9 

1 0 Inspection and maintenance programs are not designed to reduce direct particulate matter emissions. 

11 Nevertheless, motorcycle emissions do contribute a portion of the area's emissions inventory. 

1 2 During its review of the exemption request, EPA asked for additional information regarding the 

1 3 impact of the exemption on attainment of the PMIO NAAQS. In addition, because of a recent 

1 4 change in the ozone NAAQS, EPA requested a replacement measure to offset estimated increases in 

1 5 emissions of volatile 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 of motorcycles. The Addendum also 

20 contains further analysis of PM 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. 

2 4 

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

26 implementation plan. Are there any questions before we move to the oral comment period? Alright, 

27 hearing none, this concludes the question and answer period of this proceeding on the 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 of the ADEQ, for all you put into it. It was an enormous 

4 3 amount of work that you've done and I just 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 

3 
1 John Englander: 

2 Alright, thank you for your comment. Are there any other comments before we go ahead and move 

3 on? Alright, this concludes the oral comment period of this proceeding. 

4 

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

6 Again, the comment period 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 

Addendum to the Arizona State Implementation Plan Revision, Exemption of Motorcycles from 

Vehicle Emissions Inspections and Maintenance Program Requirements in Area A 

The oral proceeding on the November 20 I ° proposal Addendum to the Arizona State Implementation 

Plan Revision, Exemption of Motorcycles from Vehicle Emissions Inspections and Maintenance Program 

Requirements in Area A, October 2009, was held on Wednesday, December 15,20 I 0, 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, 20 I 0, and closed on 

Wednesday, December 15, 20 I 0, 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 of motorcycles from emissions testing. 

No changes were made in response to public comments received, however, during its final review of the 

proposed State Implementation Plan revision, ADEQ made minor corrections' for clarity, grammar and 

formatting.