ffi,* South Coast

ffi Air Quality Management District

21865 Copley Drive, Diamond Bar, CA 91765-4178

(949) 396-20OO' vwwv.aqmc{.gov

BOARD MEETING DATE: April 4,2008 AGENDA NO. 14

PROPOSAL: Requesto Modify 2007 AQMP Transportation Conformity Emission Budgets and Provide Alternative Approach in Response to U.S.

EPA's Request

In response to a request from U.S. EPA, staff is proposing to request

CARB to remove the emission reductions associated with AQMD's

on-road control measures in the 2007 AQMP from the 2008 and

2009 transportation conformity emission budgets for the purpose of

U.S. EPA's initial conformity budget adequacy findings. This revision will not impactthe2007 SIP control measures and the AQMD's

SIP reduction commitment will not change. As an alternative to the

preferred conformity budgets which reflect SIP emission reductions,

an alternate path is also being provided for U.S. EPA's consideration

for conformity budget adequacy findings based on future baseline

emissions.

SYNOPSIS:

COMMITTEE: Not Applicable

RECOMMENDED ACTION:

Direct the Executive Officer to:

1) Request CARB to remove emission reductions associated with AQMD's on-road

control measures in2007 AQMP from the 2008 and 2009 transportation conformity emission budgets for the purpose of U.S. EPA's initial conformity budget

adequacy findings, and recommend U.S. EPA's approval of the preferred conformity budgets based on the 2007 SIP.

2) Request CARB to provide an alternative approach for transportation confor*ity

emission budgets based on the 2007 SIP baseline emissions for all milestone years

up to the attainment years, in the event that U.S. EPA can not approve or find adequate the budgets based on the 2007 SIP,

3) Continue to work with CARB, SCAG, FHWA, and U.S. EPA to resolve issues affecting budget adequacy and ripdate fransportation conformity budgets within 12

montfisfo.reflect-su

Barry R. Walldstein, D.Env.

Executive Officer

EC:FIH:JC:?
Background

At its July 13, 2007 meeting, the Board adopted the2007 Final Air Quality Management

Plan (AQMP) transportation conformity emission budgets which were subsequently forwarded to CARB for approval and incorporation into the 2007 State Implementation Plan

(SIP). On November 15, 2007, CARB approved the modified transportation conformity

emission budgets to reflect the additional on-road mobile source emission reductions associated with the revised Statewide Strategy. The2007 SIP for the South Coast Air Basin and the Coachella Valley, which include the modified transportation conformity emission budgets (for South Coast Air Basin) were subsequently forwarded by CARB to the

U.S. EPA for approval on November 28,2007. The conformity budgets for Coachella

Valley were submitted to U.S. EPA following CARB's approval of the Early Progress

Plan for transport-impacted ozone nonattainment areas in February 2008.

Under the U.S. EPA transportation conformity rule (40 CFR parts 51 and 93), the on-road

motor vehicle emission budgets established in SIPs serve as a "ceiling" for ensuring the

conformity of transportation plans and programs with the SIP attainment demonstration.

Exceedances of the budget indicate an inconsistency with the SIP and could jeopardize

the flow of federal funds for transportation improvements in the region. The federal conformity findings on the current (2004) Regional Transportation Plan (RTP) expires on

June 7, 2008. SCAG is currently in the process of developing the 2008 RTP which must

conform to the transportation conformity emission budgets in the 2007 SIP. SCAG's Regional Council will be considering approval of the 2008 RTP on May 8, 2008. The 2008

RTP would also include SCAG's conformity determination which is contingent upon

U.S. EPA's adequacy findings of the 2007 SIP transportation conformity emission budgets.

As part of its conformity budget adequacy determination for the2007 SIP, U.S. EPA staff

has expressed concerns over the approvability of the 2007 SIP attainment demonstration

and control measures. Specifically, U.S. EPA staff has indicated that the inclusion of a

federal assignment (i.e., Federal Funding to Mitigate Locomotive Emissions) in the 2007

SIP will result in the disapproval of the PM2.5 attainment demonstration. U.S. EPA has

also received public comments from environmental orgarizations requesting disapproval

of the transportation conformity budgets on the basis of SIP approvability issues. In addition, U.S. EPA recently expressed concerns over the emissions reductions claimed for

two 2007 AQMP on-road control measures for 2008 and 2009: Control Measures MOB05 (A8923 Light-Duty Vehicle High Emitter Identification Program) and MOB-06

(ABg23 Medium-Duty Vehicle High Emitter Identification Program). The purpose of

these measures is to identify high-emitting vehicles through remote sensing and achieve

further reductions through off-cycle repairs or vehicle retirement. MOB-05 is a voluntary

control measure and is currently being implemented as a pilot program to determine the

efficacy of the program. MOB-06 requires legislative authority since the measure applies

to vehicles that are not currently subject to the Smog Check Program and would not be
implemented until after 2010. However, emission reductions were inadvertently assigned

in 2008 and 2009 which were reflected in the 2008 and 2009 emission budgets. The estimated reductions from MOB-05 are 0.16 ton per day of VOC and NOx each in 2008

and 0.31 and 0.15 tons per day of VOC and NOx reductions in 2009. For MOB-06, the

estimated reductions are 0.1 ton per day of VOC and NOx each in 2008 and 0.16 and

0.17 tons per day of VOC and NOx reductions in 2009.

For the purpose of U.S. EPA initial conformity budget adequacy findings, U.S. EPA staff

has requested that the emission reductions for AQMP conffol measures MOB-05 and

MOB-06 be removed from the 2008 and 2009 transportation conformity budgets because

of uncertainties associated with achieving these reductions. Due to other SIP approvability issues described earlier, U.S. EPA staff is also contemplating the use of baseline emissions as the operating emissions budgets for an interim approach and make a final determination on the emissions budgets (e.g., within one year) as part of its SIP approval process. It should be noted that baseline emissions are higher than the proposed emission

budgets submitted by CARB.

Proposal

In response to U.S. EPA's request, staff is recofirmending that a request be made to

CARB to remove the emission reductions for the two 2007 AQMP control measures

MOB-05 and MOB-06 from the 2008 and 2009 transportation conformity emission

budgets. The proposed revision will not impact the affainment demonstration of the federal annual PM2.5 ambient air quality standard by 20L5 or the federal 8-hour ambient air

quality standard by 2024. Staff is not proposing to remove any of the2007 SIP control

measures and the AQMD's SIP reduction commitment will not change since the commitment is to achieve the overall equivalent reductions through the application of alternative or substitute measures, as provided in the 2007 AQMP.

During the past several weeks, staff has been working with staffs from the U.S. EPA,

CARB, and SCAG to address issues related to the 2007 SIP conformity budgets. Accordingly, staffs frorn CARB, SCAG, and AQMD have mutually developed the following approach for U.S. EPA's consideration:

o Two sets of Conformity budgets would be approved and forwarded to U.S. EPA as

proposed revisions to the SIP. CARB's report to their Board and transmittaletter

would indicate that the two sets of budgets are being submitted because of U.S. EPA

indications that the preferred budgets, which reflect the SIP revisions approved by the

Board, may not be approvable to U.S. EPA. CARB's resolution would request that

U.S. EPA not consider the alternate path budgets if it finds the preferred path budgets

to be adequate.

o SlP-based Budgets (Preferred Path): The existing budgets (reflecting the approved

AQMP/State Strategy) would be revised to 1) remove the impacts of 2008 and

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2009 state and local measures that impact the on-road emissions, and 2) to reflect

EMFAC 2007 calculations including external baseline adjustments. Preferred

Path Budgets are provided for the following milestone years:

o South Coast: Annual PM2.5 Standard: 20A9,2012,2014,2023,2030

o South Coast: 8-Hour Ozone Standard: 2008, 2AL1,2014,2011 ,2020,2023

Baseline Budgets (Alternate Path): Submit revised transportation budgets that reflect the 2007 SIP baseline emissions (reflecting rules adopted as of October

20Aq. These baseline emissions (VOC and NOx) have met the RPF requirements.

Alternative Path Budgets are provided for all milestone years up to the attainment

year, as follows:

o South Coast: Annual PM2.5 Standard: 2009,2012

o South Coast: 8-Hour Ozone Standard: 2008, 2OlI,2Ot4,2017 ,2020

Emission levels fuom2012 and2020 will be used for subsequent milestone years

for PM2.5 and ozone, respectively. Should U.S. EPA only approve emission

budgets for certain milestone years, emission budgets for all future milestone years

will remain the same as the last milestone year approved.

U.S. EPA has raised the possibility that that any conformity budget which relies

on new strategies adopted as part of the 2007 AQMP/State Strategy may be disapproved because of attainment demonstration concerns. The alternative path would

not include 2007 AQMP/State Strategy emissions reductions in excess of already

adopted regulations in the baseline emissions, allowing U.S. EPA to approve those

budgets and SCAG to prepare conformity analyses for its 2008 RTP.

SCAG will prepare two conformity determinations: one againsthe preferred path and

the other againsthe alternate path, and will include an explanation of the difference

between the two.

o AQMD, SCAG, CARB, FHWA, and U.S. EPA will work together to resolve AQMP

issues affecting budget adequacy and submit an updated transportation conformity

budgets within the next 12 months to reflect such resolution.

With respect to Coachella Valley conformity budgets, U.S. EPA is currently in the process of issuing a finding of budget adequacy for the budgets in the Early Progress Plan

(EPP) approved by CARB in February 2008. Based on U.S. EPA's anticipated approval

of the 2012 Coachella Valley conformity budgets in the Early Progress Plan, no further

action is needed on these budgets.

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CEQA and Socioeconomic Impacts

CEQA and socioeconomic impacts for all control measures were already analyzed as part

of the 2007 AQMP and there is no need for any additional analysis as a result of the proposed revision.

AQMP and Legal Mandates

The proposed revision to the transportation conformity emission budget will not impact

the 2007 SIP attainment demonstration or the overall SIP reduction commitment.

Resource lmpacts

The proposed revision to the transportation conformity emission budget will require no

additional staff resources and funding.

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