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

DATE:

SUB JECT : October 29, 2013

Technical Support Document (TSD)

- Insignificance Findings for the Motor
Veh icle Emissions for the Redesignation Request s and Maintenance Plan s f or the Charleston, West Virginia 1997 and 2006 Fine P articulate M atte r (PM 2.5 ) National Ambient Air Quality Standards (NAAQS) Nonattainment Area

FROM: Gregory Becoat /s/

Environmental Sc ientist (3AP 30 )

TO: Administrative Record for the Insignificance Findings for the Motor Vehicle
Emissions for the Redesignation Requests and Maintenance Plans f or the Charleston, West Virginia 1997 and 2006 Fine Particulate Matter PM 2.5 NAAQS
Nonattai nment Area

THRU: Cristina Fernandez

, Associate Director /s/

Office of Air Program Planning (3AP 30 )

I. Background

On December 6, 2012, the State of Wes t Virginia (WV) formally submitted Redesignation Request s and Maintenance Plan s for the Charleston, WV 1 997 and 2006 PM 2.5 Nonattainment

Area (hereafter the Redesignation Request s and Maintenance Pla n s )

. The State Implementation Plan ( SIP ) revision included a request for finding s of insignificance by Environmental Protection Agency ( EPA ) for motor vehicle emissions for nitrogen oxides (NOx) and direct particulate matter (PM).

Transportation 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 nonattainment 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 o f an existing violation; or delay timely attainment of any NAAQS or any interim milestone. Actions involving Federal Highway Administration (FHWA) or Federal Transit Administration (FTA) funding or approval are subject to the Transportation Conformity R ul e ( 40 CFR part 93 , subpart A). Under this rule, metropolitan planning organizations (MPOs) in nonattainment and maintenance areas coordinate2

with s tate air quality and transportation agencies, EPA, FHWA, and FTA to demonstrate that their metropolitan tran sportation plans and transportation improvement plans ( TIPs ) conform to applicable 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 emi ssions 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 sultation 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 th e control strategy implementation plan was su bmitted ; (3) the MVEBs are clearly identified 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 pre viously 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 mile s traveled).

In certain instances, the Transportation Conformity Rule allows areas 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 determinations 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 con t ext of the total SIP inventory; the current state of air quality as determined by 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

em issions. EPA’ s rationale for providing for insignificance determinations is described 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 insignificance 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 Fi ndings

EPA ha s followed the process for reviewing the submitted SIP and 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 nonattainment 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)

- “ Adequac y review process for implementation plan
submissions

, ” which describes the procedures for reviewing the adequacy of an implementation plan submittal.3

II I

. Evaluation of the Request for an Insignificance Finding for M otor V ehicle E mission s in t he Redesign ation Request s and Maintenance Plan s for the Charleston, WV 1997 and
2006 PM 2.5 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 Protect ion’s request for a n insignificance finding for motor vehicle emissions associated with the Redesignation Request s and Maintenance Pla n s con tained in the submittal. EPA is using the evaluation criteria detailed in the Transportation Conformity Rule, 40 CF R 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 s and Maintenance Plan s for Charleston, WV 1997 and 2006

PM 2.5 Nonattainment Area

Transportation Conformity Rule
40 CFR Part 93 Review Criteria Was the Criterion Satisfied?
If Yes

, How was this Criteria
Satisfied? 93.102(b)(2)(iv) Has the EPA and the State made a finding that NOx 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 maintenance strategy ? T he State has requested that NOx be found an insignificant
contributor to the m obile PM emissions. This request is
based on the State finding that

o nroad mobile source NOx
constitutes about twelve

perc ent (12%) and eight percent (8%) of the area’s total

NO
x emissions in the 2018 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 mad e a finding that the transportation

- related
emissions of NOx within the
nonattainment area are not a significant contributor to the
direct mobile PM emissions

. 93.102(b)(2)(v) Has the EPA or State made a finding that the precursors, Neither EPA nor WV has made any findings that VOC s4 V olatile O rganic C omp ounds (V OCs )

, sulfur dioxide ( S O 2 )

or Ammonia ( NH 3 ) are a significant contributor to the
mobile PM emissions or does
the implementation plan
submission establish a budget for VOCs, SO 2 or NH 3 as part of a PM 2.5 maintenance strategy ? or NH 3 are significant
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 that

o nroad mobile source SO 2 constitutes less than two tenths of one percent (<0.2%)
of the area’s total SO 2 emissions in the 2018 and 2025 horizon years

. Although the State requested insignficance, SO 2 isn’t considered to be a signi ficant
contributor to mobile 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 plementati on plan establish a budget 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

o nroad mob ile source PM 2.5 constitutes less than two percent (<2%) of the area’s
total PM 2.5 emissions in the
2018 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 th e 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 w ere endorsed and submitted as a
SIP revision by the Governor ’ s designee, t he Cabinet5 Secretar y of the West Virginia

D epartment of Environment al
Protection

. A public hearing on the SIP proposal was held

on November 27, 2012

. Sec. 93.118(e)(4)(ii) Before the maintenance plan was submitted to EPA, did
consultation between federa l, 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 occurred 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
emissio n reductions, consistent with applicable requirements for maintenance strategies ? EPA believes th at motor vehicle emissions can be
declared insignificant
contributors because 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 due to
fleet turnover

. Sec. 93.118(e)(4)(v) Are the motor vehicle
emissions consistent w ith 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 emissions inventory and control

measures in the SIP submittal.

Sec. 93.118(e)(4)(vi) Revi sions to previously
submitted maintenance plan: explain and document any changes to previously submitted budgets and There are no revisions to the maintenance plan s because this is the initial redesignation request, along with the
associate d maintenance plan s6 control measures; impacts on point and area source emissions; any changes to established safety margins (see Sec. 93.101 for definition); a nd reasons for the changes (including the basis for any changes related
to emission factors or
estimates of vehicle miles traveled). for the Charleston, WV Area.

Sec. 93.118(e)(5) Did they provide and we review public comments and
the State ’ s responses to those
comments with the submitted control strategy SIP? There were no comments on the SIP related to the p roposed insignificance finding request.

IV

. Conclusions

Based upon our review and evaluati on of the motor vehicle emissions contained in the West Virginia Redesignation Request s and Maintenance Plan s for the Charleston, WV 1997 and 2006

PM 2.5 NAAQS N onattainment Area

, EPA finds that the SIP submittal meets the criteria in the transportation conformity rules fo r an insignificance finding for NOx and PM 2.5 contribution
from motor vehicles. Weighing all the factors for an insignificance finding, particu larly the
minor contribution of mobile source PM 2.5 and NOx

, EPA has determined that the PM 2.5 and
NOx contribution from m otor vehicle emissions to the PM 2.5 pollution for the Charleston, WV
Nonattainment Area is insignificant. In particular, for the 2008 base year

, the direct PM o nroad
mobile source constitutes 3.62% of the area’s total PM 2.5 emissions and decreases significantly in later analysis years to 1.89% (2018) and 1.40% (2025)

. With respect to transp ortation conformity, the NO
x contribution is t welve percent (12%) and eight percent (8%) of the area’s
total NOx emissions in the 2018 and 2025 horizon years and requires further justification to request an insignificant finding

. The requirements under 40 CFR 93.109 (f ) bases insignificance
on emissio n percentages, emission trends , and the effectiveness of the pollutant in forming PM.
For the Charleston A rea, there is a significant emission decrease projected for the highway sector
and total emissions source inventory in years 2008, 2018, and 2025

. G iven the relatively small contribution of the highway mobile emissions to the total SIP inventory, highway mobile emissions are not likely to contribute significantly to local PM 2.5

. Additionally, NOx reductions are significantly less effective in reducin g PM concentrations than are reductions in direct PM
and NOx . Consequently, NOx percent age emission contribution may be higher than direct PM
and NOx without adversely affecting air quality. Based on t he analysis of local historical trends and growth pat terns 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 emissions growth to lead to a violation of the 1997 and 2006 PM 2.5 standard. Although vehicle miles traveled increases over time , NOx o nroad emissions are7

projected to decrease dramatically from 10,776 tons/year in 200 5 to 2,134 tons/year in 204 0. This demonstrates that highway emissions will remain insignificant in th e future. Upon review of the further justification for requesting an insignificant finding for direct PM and NOx, EPA
has determined that direct PM and NOx contribution from motor vehicle emissions to the PM 2.5 pollution for the Charleston, WV 1997 and 2006 PM 2.5 standards is insign ificant

.