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 D ocumentation for Plan M otor 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 m otor vehicle e mission s b udgets (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, 2 014 as a revision to the State of Nevada’s s tate
i mplementation p lan (SIP)

.

## Table 1. Evaluation of the Motor Vehi cle 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 su bmitted 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 responsi ble for implementation of air quality management programs within the boundaries of Washoe County , held a

p ublic 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 de veloped with consultation from f ederal, s tate, and local agencies. These agencies i nclude: 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 Pl anning 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 pre cisely 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 a lre ady adopted at the time that Washoe County adopted the SIP on August 28, 2014 and were developed using the EPA’s MOVES2010b model s

.

## Table 1. Evaluation of the Motor Vehi cle 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 m aintenance 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 dem onstration provided in Chapter 2 of the p lan. 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 em issions inventory to develop
emission s budget s and to project emissions to 2015 , 2020, 2025 and 2030, with safety margins, in order to show cont inu ed 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

sou rces 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 Vehi cle 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 R equest 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

8 th year of the first plan perio d, 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. Th is plan’s budgets are fo r 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.