UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105

Memorandum

To: Truckee Meadows (Washoe County, NV) Second 10-year Carbon Monoxide 

Maintenance Plan SIP Direct Final Approval Docket, Docket ID Number EPA-R09-

OAR-2016-0096

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

Date: August 5, 2016

RE: Adequacy Documentation for Plan Motor Vehicle Emission Budgets in November 2014

Truckee Meadows Carbon Monoxide Second 10-year Maintenance State Implementation 

Plan

Attached to this memorandum is the adequacy documentation for the motor vehicle emissions budgets 

(MVEBs or “budgets”) in the “Second 10-Year Maintenance Plan for the Truckee Meadows 8-Hour 

Carbon Monoxide Attainment area,” dated August 28, 2014, submitted to the U.S. Environmental 

Protection Agency (EPA) on November 7, 2014 as a revision to the State of Nevada’s state 

implementation plan (SIP).
 

Table 1. Evaluation of the Motor Vehicle Emissions Budgets in the 

2014 Truckee Meadows Carbon Monoxide Second 10-year Maintenance State Implementation Plan

August 2016 (reviewed by John Kelly)

Adequacy Review Criteria

(40 CFR part 93)

Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 

93.118(e)(4)(i)

The plan was endorsed by the 

Governor (or designee) and was 

subject to a public hearing.

Y

The “Second 10-Year Maintenance Plan for the Truckee Meadows 8-Hour Carbon 

Monoxide” State Implementation Plan, dated August 28, 2014 (hereinafter “2014 

Maintenance Plan” or “plan”) was submitted to the U.S. Environmental Protection 

Agency (EPA) on November 7, 2014 by the Administrator of the Nevada Division 

of Environmental Protection (NDEP), the Governor of Nevada’s designee for all 

SIP revision submittals. This SIP submittal documents that the Washoe County 

District Board of Health (Board), which is responsible for implementation of air 

quality management programs within the boundaries of Washoe County, held a 

public hearing on the plan on August 28, 2014, and adopted the plan on that same 

date.

Sec. 

93.118(e)(4)(ii)

The plan was developed through 

consultation with federal, state 

and local agencies; full 

implementation plan 

documentation was provided and 

EPA’s stated concerns, if any, 

were addressed.

Y

The plan was developed with consultation from federal, state, and local agencies. 

These agencies include: EPA Region IX; Federal Highway Administration; Federal 

Transit Administration; Nevada Department of Transportation; Nevada Division of 

Environmental Protection, Bureau of Air Quality Planning; Regional 

Transportation Commission (the Metropolitan Planning Organization of Washoe 

County, Nevada); Washoe County Air Quality Management District; and Truckee 

Meadows Regional Planning Agency. Issues raised by EPA Region IX staff on the 

administrative draft were addressed through this process prior to publication of the 

proposed plan for public review.

Sec. 

93.118(e)(4)(iii)

The motor vehicle emission 

budgets are clearly identified and 

precisely quantified.

Y

The motor vehicle emissions budgets are clearly identified and precisely quantified 

for years 2015, 2020, 2025 and 2030 on page 8 of the 2014 Maintenance Plan. 

These budgets reflect federal motor vehicle control measures that were already 

adopted at the time that Washoe County adopted the SIP on August 28, 2014 and 

were developed using the EPA’s MOVES2010b models. 
 

Table 1. Evaluation of the Motor Vehicle Emissions Budgets in the 

2014 Truckee Meadows Carbon Monoxide Second 10-year Maintenance State Implementation Plan

August 2016 (reviewed by John Kelly)

Adequacy Review Criteria

(40 CFR part 93)

Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 

93.118(e)(4)(iv)

The motor vehicle emissions 

budget(s), when considered 

together with all other emission 

sources, is consistent with 

applicable requirements for 

reasonable further progress and 

attainment.

Y

The 2014 Maintenance Plan describes how the level of emissions contained in the 

motor vehicle emission budgets, when combined with all other emission sources in 

the area, will show maintenance through the year 2030. See pages 8 and 9 of the 

plan for a discussion of the derivation of the motor vehicle emissions budgets and 

how they are consistent with the maintenance demonstration provided in Chapter 2

of the plan. Table B-1 in appendix B of the plan provides a detailed list of 

emissions from all major categories in the area, including on-road mobile source 

emissions. The plan uses a 2011 attainment emissions inventory to develop 

emissions budgets and to project emissions to 2015, 2020, 2025 and 2030, with 

safety margins, in order to show continued attainment and maintenance of the CO 

NAAQS.

Sec. 

93.118(e)(4)(v)

The plan shows a clear 

relationship among the emissions 

budget(s), control measures and 

the total emissions inventory.

Y

The plan includes a 2011 emissions inventory for all point, area, and motor vehicle 

sources in Table B-1 of appendix B. Summary information for the four major 

categories of emissions sources is presented in Chapter 2 of the plan (see Tables 2-

3 and 2-4 in the plan).
 

Table 1. Evaluation of the Motor Vehicle Emissions Budgets in the 

2014 Truckee Meadows Carbon Monoxide Second 10-year Maintenance State Implementation Plan

August 2016 (reviewed by John Kelly)

Adequacy Review Criteria

(40 CFR part 93)

Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 

93.118(e)(4)(vi)

Revisions to previously submitted 

control strategy or maintenance 

plans explain and document any 

changes to any previous 

submitted budgets and control 

measures; impacts on point and 

area source emissions; any 

changes to established safety 

margins (see §93.101 for 

definition), and reasons for the 

changes (including the basis for 

any changes to emission factors or 

estimates of vehicle miles 

traveled).

Y

Nevada’s 2005 SIP submittal, “Redesignation Request and Maintenance Plan for 

the Truckee Meadows Carbon Monoxide Non-Attainment Area (September 2005)” 

(2005 plan) included MVEBs for the area. EPA’s approval of the 2005 plan in 

2008 was therefore the first time MVEBs were approved by the EPA for the area. 

Those budgets, for years 2010 and 2016, were found adequate for transportation 

conformity decisions in a letter from the EPA to the NDEP on February 14, 2006.

The 2014 Maintenance Plan was submitted to the EPA as a required SIP revision. 

The Clean Air Act requires that an area provide for maintenance of the CO 

NAAQS for a 10-year period following the EPA’s redesignation of the area to 

attainment. The State is then required to submit a second maintenance plan in the 

8th year of the first plan period, demonstrating continued maintenance for the area 

for at least 10 years following the first 10-year period. The 2014 Maintenance Plan 

provides for maintenance of the CO NAAQS out to the year 2030 for the Truckee 

Meadows area. This plan’s budgets are for years 2015, 2020, 2025 and 2030 and 

were developed using updated planning assumptions and updated motor vehicle 

emission models.

Sec. 

93.118(e)(5)

EPA has reviewed the State’s 

compilation of public comments 

and response to comments that are 

required to be submitted with any 

implementation plan.

Y

The Board held a public hearing on the plan during their August 28, 2014 meeting. 

A notice of the public hearing was published in the Reno Gazette-Journal in each 

issue published between July 25 and August 22, 2014. The Board’s meeting and 

public hearing took place in Washoe County at the Washoe County Health District 

office in Reno, Nevada. No comments were made by members of the public at the 

hearing.