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

SUBJECT: Technical Support Document (TSD)- Insignificance Findings for the Motor Vehicle Emissions for the Redesignation Request and Maintenance Plan for the West Virginia Portion ofthe Parkersburg-Marietta, WV-OH 1997 Fine Particulate Matter (PM2.s) Nonattainment Area

FROM: Gregory Becoat

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TO: Administrative Record for the Insignificance Findings for the Motor Vehicle Emissions for the Redesignation Request and Maintenance Planfor West Virginia Portion ofthe Parkersburg-Marietta, WV-OH 1997 PM2.s Nonattainment Area

THRU: DonnaMastro, Acting Associate Director

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### V'\ I. Background

The Clean Air Act (CAA) requires federal actions innonattainment and maintenance areas to "conformto" the goals ofState Implementation Plans (SIP). See, e.g. , CAA section 176. This
means that such actions will not cause orcontribute to violations ofa national ambient air quality standard (NAAQS); worsen the severity ofan 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 rule (40 CFRpart 93, subpart A). Under this rule, metropolitan planning organizations (MPOs) in nonattainment and maintenance areas coordinate with state air quality and transportation agencies, Environmental Protection Agency (EPA), FHW A, and FT A to demonstrate that their metropolitan transportation plans and transportation improvement programs (TIP) conform to applicable SIPs. This is typically determined by showing that estimated emissions from existing andplanned highway and transit systems are less than or equal to the motor vehicle emissions budgets (MVEBs) contained in a SIP.
For MVEBs to be approvable, they must meet, at a minimum, EPA's adequacy criteria found at 40 CFR 93

. 118(e)(4). In certain instances, the Transportation Conformity Rule allows areas to

1forgo establishment ofa MVEB where itis demonstrated that the regional motor vehicle emissions for a particular pollutant or precursor are aninsignificant 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 offactors, including the percentage ofmotor vehicle emissions in the context ofthe total SIP inventory; the current state ofair quality as determinedby monitoring data for the relevant NAAQS; the absence ofSIP motor vehicle control measures; and the historical trends and future projections ofthe growth of motor vehicle emissions. EPA's rationale for providing for insignificance determinations is described in the July 1, 2004, revision to the Transportation Conformity Rule at 69 FR40004. Specifically, the rationale is explained onpage 40061 under the subsectionXXIII.B. entitled, "Areas With Insignificant Motor Vehicle Emissions." Any insignificance determination under review ofEPAis subjectto the adequacy and approval process for EPA's action on the SIP.

II. Administrative Requirements for Making Insignificance Findings

EPA has followed the process for reviewing the submitted SIP and determining ifan insignificance fmding for motor vehicle emissions is warranted in accordance withthe procedures listed in the January 2008 Conformity Regulations contained in 40 CFR 9
· 3.102(b)- "Geographical applicability" and 40 CFR 93 .118(f)

- "Adequacy review process for implementationplan submissions."

On March 8, 2012, the State ofWest Virginiaformally submitted a Redesignation Request and Maintenance Plan for West Virginia Portion ofthe Parkersburg-Marietta, WV-OH 1997 PM2
.5 Nonattainment Area (hereafter the Redesignation Request and Maintenance Plan). The SIP included a request for a finding ofinsignificance by EPA for motor vehicle emissions for nitrogen oxides (NOx), direct particulate matter (PM), and sulfur dioxide (S02).
III. Evaluation ofthe Request for an Insignificance Finding for Motor Vehicle Emissions in the Redesignation Request and Maintenance Plan for the West Virginia Portion ofthe Parkersburg-Marietta, WV-OH 1997 PM2.5 Nonattainment Area Submitted By The West Virginia Department ofEnvironmental Protection

Inthis TSD, EPA is evaluating the West Virginia Department ofEnvironmental Protection's request for aninsignificance finding for motor vehicle emissions associated withthe Redesignation Request and Maintenance Plan contained in the submittal. EPA is using the evaluation criteria detailed inthe Transportation Conformity Rule, 40 CFR 93.102(b)(2)(iv), (b)(2)(v), and (b)(3) and 93.118(e)(4) and (e)(5). The evaluation is presented below.

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### Review ofthe Request for Insignificance Finding ofMotorVehicle Emissions in the Redesignation Request and Maintenance Planfor the West Virginia Portion ofthe**Parkersbur~-Marietta,** 

### WV-OHPM2.s Nonattainment Area Transportation Conformity Rule Review Criteria 40 CPRPart 93, Section 93 .118
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 NOx budget as part ofthe PM 2.s maintenance strategy?

93.102(b)(2)(v)

93.102(b)(3) Has the EPA or State made a finding thatthe precursors, Volatile Organic Compounds (VOCs), S02 or Ammonia {NH3) are a significant contributorto the mobile PM emissions or does the implementationplan submission establish a budget for VOCs, SOx or NH3 as part ofa PM 2.s maintenance strategy? Has the EPA or the State made a finding that direct PM is a significant contributor to the PM mobile emissions or does the implementationplan establish a budget that

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### Was the Criterion Satisfied? If Yes, How was this Criteria Satisfied? The State has requested that NOx be found an insignificant contributorto the mobile PM emissions. This request is based
on the State finding that Onroad mobile source NOx constitutes less than twelve percent ofthe area's total NOx emissions 

### inthe 20 15 and 2022 horizon years due to continuing fleet turnover even with future vehicle miles traveled (VMT) growth included in the emission projections. EPA has also made a fmding thatthe transportation-related emissions of NOx within the nonattainment
area are not a significant contributorto .the direct mobile PM
·emissions. Neither EPA nor the State has made any findings thatVOCs, S02, orNH3 is a significant contributor to the PM2.s mobile emissions, and therefore, it has not been included in the SIP. Onroad mobile source S02 emissions constitute less than 0.1% ofthe area's total so2 emissions

### · inthe 2015 and 2022 horizon years.
The State has requested that direct PM be found an insignificant contributor to the mobile PM emissions. This request is based
onthe State fmding that Onroad mobile source PM2.s constitutes less than 2.1% ofthe area's totalincludes direct PM as part of PM2.s emissions in the 20 15 and
a PM 2.5 maintenance 2022 horizonyears due to strategy? continuing fleet turnover even with future VMT growth included in the emission projections

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Sec. 93 .118(e)(4)(i) Was the submitted revised Yes. The submitted plan endorsed by the Redesignation Request and Governor (or his orher Maintenance Plan was endorsed designee) and subject to a and submitted as a SIP revision by State public hearing? the Governor's designee, the Secretary ofthe West Virginia Department ofEnvironmental Protection. A public hearing on the SIP proposal was held

. Sec. 93.118(e)(4)(ii) Before the maintenance plan Yes. Consultation has occurred
was submitted to EPA, did among all required Federal, State, consultation between federal, and local agencies. State and local agencies occur; was full implementationplan documentationprovided to EPA, and was EPA's stated concerns, ifany, addressed? Sec. 93.118(e)(4)(iii) Were the MVEBs clearly As there was a request for an identified and precisely insignificance finding, no MVEBs quantified? were identified inthe SIP. Sec

. 93.118(e)(4)(iv) Are the motor vehicle EPA believes that motor vehicle emissions, when considered emissions canbe declared together with all other insignificant contributors because emission reductions, in comparing the motor vehicle consistent with applicable emissions to the overall emissions ' requirements for inventory, the motor vehicle maintenance strategies? emissions comprise only a small portion ofthe over PM2.s 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 EPA believes that the motor emissions consistent with vehicle emissions have clearly and clearly related to the related to the emissions inventory

4emissions inventory and the and control measures inthe SIP control measures inthe Plan? submittal.

Sec. 93.118(e)(4)(vi) Revisions to previously There are no revisions to the submitted maintenance plan: maintenance planbecause this is explain and document any the initial redesignation request, changes to previously along with the associated submitted budgets and maintenance planfor West control measures; impacts on Virginia Portion ofthe point and area source Parkersburg-Marietta, WV-OH emissions; any changes to Area. 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 ofvehicle miles traveled). Sec. 93.118(e)(5) Did they provide and we There were no comments on the review public comments and SIP related to the proposed the State's responses to those insignificance finding request. comments with the submitted control strategy SIP?



### IV. Findings

Based upon our review and evaluation ofthe motor vehicle emissions contained inthe West Virginia Redesignation Request and Maintenance Plan for the West Virginia Portion ofthe Parkersburg-Marietta, WV-OH 1997 PM2.s Nonattainment Area, EPA finds that the SIP submittal meets the criteria in the transportation conformity rules for an insignificance finding for NOx, PM2.5, and S02 contribution from motor vehicles. Weighing all the factors for an insignificance finding, particularly the minor contribution ofmobile sourcePM2.s and S02, EPA has determined that the PM2.s and S02contribution from motor vehicle emissions to the annual PM2

.5pollution for the West Virginiaportion ofthe Nonattainment Area are insignificant. With respect to transportation conformity, the largerNOx contribution ofless than twelve and a half percent ofthe area's total NOx emissions inthe 2015 and 2022 horizon years requires further justification to request an insignificant finding. 40 CFR 93.109(±) bases insignificance on emission percentages, emission trends, and the effectiveness ofthe pollutant in forming PM. For the Parkersburg-Marietta area, there is a significant emission decrease projected for the highway sector and total emissions source inventory in years 2008, 2015, and 2022. Given the relatively small contribution ofthe highway mobile emissions to the total SIP inventory, highwaymobile

5emissions are not likely to contribute significantly to local PM 2

.5• Additionally, NOx reductions
are significantly less effective in reducing PM concentrations than are reductions indirect PM and S02
. Consequently, NOxpercentage emission contribution may be higher than direct PM and S02 without adversely affecting air quality. Based onthe analysis oflocal 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 emissions growthto lead to a violation ofthe annual PM2.s standard. Although vehicle miles traveled increases over time, NOx emissions are projected to decrease dramatically from 4505.4 tons/year in 2002 to 665.7 tons/year in 2030. This demonstrates that highway emissions will remain insignificant in the future. Upon review ofthe further justification for requesting aninsignificant finding for NOx, EPA has determined thatNOx contribution from motdr vehicle emissions to the annual PM2
.5pollution for the West Virginia portion ofthe NonattainmentArea is insignificant.

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