1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103

SUB JECT : Technical S upport Document (TSD)

- Insignificance Findings for the Motor

Vehicle Emissions for the Redesignation Request s and Maintenance Plan s f or the West Virginia Porti on of the Steubenville

- Weirton, OH

- WV 1997 and 2006 Fine P articulate M atte r (PM 2.5 ) National Amb ient Air Quality Standard s (NAAQS) Nonattainment Area

FROM: Gregory Becoat /s/ 9/24/13

Environmental Scientist (3AP 30 )

TO: Administrative Record for the Insignificance Findings for the Motor Vehicle Emissions for the Redesignation Request s and Maintenance Pl an s f or the West Virginia Portion of the Steubenville

- Weirton, OH

- WV 1997 and 2006 PM 2.5 NAAQS Nonattainment Area

THRU: Cristina Fernandez

, Associate Director /s/ 9/24/13

Office of Air Program Planning (3AP 30 )

I. Background

T he State of West Virginia formal ly submitted Redesignation Request s and Maintenance Plan s for the Steubenville

- Weirton, OH

- WV 1997 PM 2.5 Nonattainment Area and 2006 PM 2.5 NAAQS Nonattainment Area (hereafter the Redesignation Request s and Maintenance Pla n s ) on April 13, 2012 and June 8, 2 012 , respectively

. The State Implementation Plan ( SIP ) revision included a request for a finding of insignificance by Environmental Protection Agency ( EPA ) for motor vehicle emissions for nitrogen oxides (NO x ) and direct particulate matter (PM)

.

Transpor tation conformity is required under section 176(c) of the Clean Air Act ( CAA ) to ensure that f ederally supported highway, transit projects, and other activities are consistent with (conform to) the purpose of the SIP. The CAA requires federal actions in n onattainment and maintenance areas to “conform to” the goals of SIP. This means that such actions will not cause or contribute to violations of a NAAQS; worsen the severity of an existing violation; or delay timely attainment of any NAAQS or any interim m ilestone. Actions involving Federal Highway Administration (FHWA) or Federal Transit Administration (FTA) funding or approval are2

subject to the Transportation Conformity R ule ( 40 CFR part 93 , subpart A). Under this rule, metropolitan planning organizati ons (MPOs) in nonattainment and maintenance areas coordinate with State air quality and transportation agencies, EPA, FHWA, and FTA to demonstrate that their metropolitan transportation plans and transportation improvement plans ( TIPs ) conform to applicabl e SIPs. This is typically determined by showing that estimated emissions from existing and planned highway and transit systems are less than or equal to the motor vehicle emissions budgets (MVEBs) contained in a SIP.

F or MVEBs to be approvable, they must meet, at a minimum, EPA’s adequacy criteria found at 40 CFR 93.118(e)(4). EPA’s adequacy criteria are: (1) the submitted control strategy implementation plan was endorsed by the Governor or designee and was subject to a State public hearing; (2) con sulta tion among F ederal, State, and local agencies occurred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, if any, were addressed before the control strategy implementation plan was su bmitted ; (3) the MVEBs are clearly i dentified and precisely quantified; (4) the MVEBs, when considered together wit h all other emissions sources, are consistent with applicable requirements for maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan; and (6) revisions to previously submitted maintenance plans explain and document any changes to previously submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins; and reasons for the changes (including the basis for any changes related to emission factors or estim ates of vehicle miles traveled).

In certain instances, the Transportation Conformity Rule allows area s to forgo establishment of a MVEB where it is demonstrated that the regional motor vehicle emissions for a particular pollutant or precursor are an insignificant contributor to the air quality problem in an area. The general criteria for insignificance d eterminations can be found in 40 CFR 93.109 (f). Insignificance determinations are based on a number of factors, including the percentage of motor vehicle emissions in the cont ext of the total SIP inventory; the current state of air quality as determined b y monitori ng data for the relevant NAAQS; the absence of SIP motor vehicle control measures; and the historical trends and future projections of the growth of motor vehicle emissions. EPA’ s rationale for providing for insignificance determinations is desc ribed in the July 1, 2004, revision to the Transportation Conformity Rule at 69 FR 40004

. Specifically, the rationale is explained on page 40061 under the subsection XXIII.B. entitled, “ Areas With Insignif icant Motor Vehicle Emissions.” Any insignificanc e determination under review of EPA is subject to the adequacy and approval process for EPA's action on the SIP.

I I . Administrative Requirements for Making Insignificance Findings

EPA ha s followed the process for reviewing the submitted SIP revision a nd determining if a n insignificance finding for motor vehicle e missions is warranted in accordance with the procedures listed in the January 2008 Conformity Regulations contained in 40 CFR 93. 102 (b)

- “Geographical applicabil i ty,” which applies to all nona ttainment and maintenance areas for transportation

- related criteria pollutants for which the area is designated nonattainment or has a maintenance plan, and 40 CFR 93. 118(f)

- “ Adequacy review process for implementation plan3

submissions

, ” which describes t he procedures for reviewing the adequacy of an implementation plan revision submittal.

II I

. Evaluation of the Request for an Insignificance Finding for M otor V ehicle E mission s in t he Redesignation Request and Maintenance Plan for the Steubenville

- Weirton , OH

- WV 1997 and 2006 PM 2.5 NAAQS Nonattainment Area Submitted b y t he West Virginia Department of Environment al Protection

In this TSD, EPA is evaluating the West Virginia Department of Environmental Protection’s request for a n insignificance finding for motor vehicle emissions associated with the Redesignation Request and Maintenance Pla n con tained in the submittal. EPA is using the evaluation criteria detailed in the Transportation Conformity Rule, 40 CFR 93.1 02(b)(2) ( iv), ( b)(2)(v)

, and (b)(3) and 93. 118(e) ( 4 ) and (e) ( 5 )

. A summary of EPA’s evaluation and the required review criteria of sections 93.1 02(b)(2)(iv), (b)(2)(v), and (b)(3) and 93.118(e)(4) and (e)(5) are presented in Table 1 below.

Table 1. Review of the Request for Insignificance Finding of M otor V ehicle E missions in the Redesignation Request and Maintenance Plan for Steubenville

- Weirton, OH

- WV 1997 and 2006 PM 2.5 NAAQS Nonattainment Area

Transportation Conformity Rule 40 CFR Part 93 Review Criteria Was the Criterion Satisfied? If Ye s , How was this Criteria Satisfied? 93.102(b)(2)(iv) Has the EPA and the State made a finding that NO x is an insignificant contributor to the direct mobile PM emissions or does the implementation plan fail to establish a NO x budget as part of the PM 2.5
ma intenance strategy ? T he State has requested that NO x be found an insignificant contributor to the m obile PM emissions. This request is based on the State finding that

o nroad mobile source NO x constitutes about twelve percent (12%) and less than five per cent (5 %) of the area’s total NO x emissions in the 2015 and 2025 horizon years, respectively due to continuing fleet turnover even with future vehicle miles traveled (VMT) growth included in the emission projections. EPA has also made a finding that the
tr ansportation

- related emissions of NO x within the nonattainment area are not a significant contributor to the direct mobile PM emissions

.4

93.102(b)(2)(v) Has the EPA or State made a finding that the precursors, V olatile O rganic C ompounds (V OCs )

, S O 2 or Am monia ( NH 3 ) are a significant contributor to the mobile PM emissions or does the implementation plan submission establish a budget for VOCs, SOx or NH 3 as part of a PM 2.5 maintenance strategy ? Neither EPA nor WV has made any findings that VOC s

or NH 3 are s ignificant contributor s to the PM 2.5 mobile emissions

, and therefore

, they have not been included in the SIP

. The State has requested that SO 2 be found an insignificant contributor to the mobile PM emissions. This request is based on the State finding th at

o nroad mobile source SO 2 constitutes less than one tenth of one percent (<0.1 %) of the area’s total SO 2 emissions in the 2015 and 2025 horizon
years

. Although the State requested insignficance , SO 2 isn’t considered to be a significant contributor to

mo bile PM and therefore does not have to be part of a PM 2.5 maintenance strategy

. 93.102(b)(3) Has the EPA or the State made a finding that direct PM is a significant contributor to the PM mobile emissions or does the im plementation plan establish a bud get that includes direct PM as part of a PM 2.5 maintenance strategy ? WV has requested that direct PM be found an insignificant contributor to the mobile PM emissions. This request is based on the State finding that Onroad mobile source PM 2.5 constit utes less than two percent (<2%) of the area’s total PM 2.5 emissions in the 2015 and 2025 horizon
years due to continuing fleet turnover even with future VMT growth included in the emission projections.

Sec. 93.118(e)(4)(i) Was the submitted revised plan endorsed by the Governor (or his or her designee) and subject to a State public hearing? Yes. The submitted Redesignation Request s and Maintenance Plan s were endorsed and submitted as a SIP revision by the Governor ’ s5 designee, the Cabinet Secretar y of the West Virginia D epartment of Environment al Protection

. P ublic hearing s on the SIP proposal w ere held on April 3, 2012 and May 15, 2012 for the 1997 PM 2.5 NAAQS Nonattainment Area and 2006 PM 2.5 NAAQS Nonattainment Area

, respectively

. Sec. 93.118(e)(4 )(ii) Before the maintenance plan was submitted to EPA, did consultation between federal, State and local agencies occur; was full implementation plan documentation provided to EPA, and was EPA ’ s stated concerns, if any, addressed? Yes. Consultation has

o ccurred among all required F ederal, S tate
, and local agencies.

Sec. 93.118(e)(4)(iii) W ere the MVEBs clearly identified and precisely quantified? As there was a request for an insignificance finding, no MVEBs were identified in the SIP. Sec. 93.118(e)( 4)(iv) Are the motor vehicle emissions, when considered together with all other emission reductions, consistent with applicable requirements for maintenance strategies ? EPA believes th at motor vehicle emissions can be declared insignificant contributors be cause in
compar ing the mo tor vehicle emissions to the overall emissions inventory, the mo tor vehicle emissions comprise only a small portion of the

over all PM 2.5 emissions for the nonattainment area and are projected to continue to significantly decline du e to fleet turnover

. Sec. 93.118(e)(4)(v) Are the motor vehicle emissions consistent with and clearly related to the emissions inventory and the control measures in the Plan? EPA believes that the motor vehicle emissions have clearly related to the emi ssions inventory and control

measures in the SIP submittal.6

Sec. 93.118(e)(4)(vi) Revisions to previously submitted maintenance plan: explain and document any changes to previously submitted budgets and control measures; impacts on point and area source

e missions; any changes to established safety margins (see Sec. 93.101 for definition); and reasons for the changes (including the basis for any changes related to emission factors or estimates of vehicle miles traveled). There are no revisions to the mainte nance plan because this is the initial redesignation request, along with the associated maintenance plan for the Steubenville

- Weirton, OH

- WV Area.

Sec. 93.118(e)(5) Did they provide and we review public comments and the State ’ s responses to those

co mments with the submitted control strategy SIP? There were no comments on the SIP revision related to the proposed insignificance finding request.

IV

. Conclusions

Based upon our review and evaluati on of the motor vehicle emissions contained in the We st Virginia Redesignation Request s and Maintenance Plan s for the Steubenville

- Weirton, OH

- WV 1997 and 2006 PM 2.5 NAAQS nonattainment a rea , EPA finds that the SIP revision submittal meets the criteria in the transportation conformity rules fo r an insignific ance finding for NO x and PM 2.5 contribution from motor vehicles. Weighing all the factors for an insignificance finding, particularly the minor contribution of mobile source PM 2.5 and NO x , EPA has determined that the PM 2.5 and NO x contribution from m otor vehicle emissions to the PM 2.5 pollution for the West Virginia portion of the Steubenville

- Weirton, OH

- WV nonattainment a rea for the 1997 and 2006 standards is insignificant. In particular, for the 2008 base year

, the direct PM o nroad mobile source consti tutes 3.59 % of the area’s total PM 2.5 emissions and decreases significantly in later analysis yea rs to 1.84% (2015) and 1.21 % (2025)

. With respect to transportation conformity, the NO x contribution is about twelve percent (12%) of onroad mobile sources bu t is less than five percent (5%) of the area’s total NO x emissions in the 2015 and 2025 horizon years requires further justification to request an insignificant finding. The requirements under 40 CFR 93.109 (f ) bases insignificance on emission percentages, emission trends , and the effectiveness of the pollutant in forming PM. For the W est Virginia portion of the Steubenville

- Weirton, OH

WV 1997 and 2006 PM 2.5 NAAQS nonattainment a rea , there is a significant emission decrease projected for the highway secto r and total emissions source inventory in years 2015 and 2025

. Given the relatively small contribution of the highway mobile emissions to the total SIP7

inventory, highway mobile emissions are not likely to contribute significantly to local PM 2.5
. Additio nally, NO x reductions are significantly less effective in reducing PM concentrations than are reductions in direct PM and NO x . Consequently, NO x percent age emission contribution may be higher than direct PM and NO x without adversely affecting air quality. Based on t he analysis of local historical trends and growth patterns in order to develop the long range transportation plan and transportation improvement program for transportation conformity purposes, EPA has no reason to expect highway motor vehicle e missions growth to lead to a violation of the 1997 and 2006 PM 2.5 standard s

. Although vehicle miles traveled increases over time , NO x o nroad emissions are projected to decrease dramatically from 787.5 tons/year in 2008 to 176.6 in 2035, which is less than one

- fourth of the 2008 level. This demonstrates that highway emissions will remain insignificant in the future. Upon review of the further justification for requesting an insignificant finding for direct PM and NO x , EPA has determined that direct PM and NO x contribution from motor vehicle emissions to the PM 2.5 pollution for the Steubenville

- Weirton, OH

- WV nonattainment a rea for the 1997 and 2006 PM 2.5 standards is insignificant

.