SUBJECT: 

FROM: 

TO: 

THRU: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Technical Support Document (TSD) - Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the Maintenance Plan for the Allentown 2006 Fine 

Particulate (PM2.s) National Ambient Air Quality Standard (NAAQS) 

N onattainment Area 

Asrah 

Office 

Khadr, 

of Air Program 

Environmental 

Planning 

Engineer, 

(3AP30) 

Engineer in Training (EIT) ~ 1 1-. f' II~ 

~ 

Administrative Record for the Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the Maintenance Plan for the Allentown 2006 PM2.s 

NAAQS Nonattainment Area 

-r_._ I ~. !.2/;/Jy 

ristma F emandez Associa e Director 

Office of Air Program Planning (3AP30) 

I. Background 

On November 13,2009 (74 FR 58688), Lehigh and Northampton Counties were designated as 

nonattainment for the 2006 PM2.s NAAQS as a part of the Allentown 2006 PM2.s NAAQS 

Nonattainment Area. On March 29, 2012 (77 FR 18922), it was determined that the Allentown 

2006 PM2.s NAAQS Nonattainment Area had air quality data showing the 2006 PM2.s NAAQS 

was attained. Additional background information about the Allentown 2006 PM2.s NAAQS 

Nonattainment Area is available in the notice of proposed rulemaking (NPR) in this docket. On 

September 5, 2014, the Pennsylvania Department of Environmental Protection (PADEP) formally 

submitted a State Implementation Plan (SIP) revision to satisfy the redesignation requirements of 

the Clean Air Act (CAA) for the 2006 PM2.s NAAQS for the Allentown 2006 PM2.s NAAQS 

N onattainment Area. 

II. Transportation Conformity Requirements 

Under section 176(c) of the CAA, new transportation plans, programs, and projects, such as the 

construction of new highways, must "conform" to (i.e., be consistent with) the part of the state's 

air quality plan that addresses pollution from cars and trucks. The CAA requires federal actions in 

nonattainment and maintenance areas to "conform to" the goals of the SIP. This means that such 

actions will not cause or contribute to violations ofNAAQS; worsen the severity of an existing 

violation; or delay timely attainment of any NAAQS or any interim milestone. 

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For motor vehicle emissions budgets (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) consultation among Federal, State, and local agencies 

occurred; full implementation plan documentation was provided to EPA; and EPA's stated 

concerns, if any, were addressed before the control strategy implementation plan was submitted; 

(3) the MVEBs are clearly identified and precisely quantified; (4) the MVEBs, when considered 

together with 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 previously 

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 estimates of vehicle miles traveled). 

III. Review of the Submitted Modeling Utilizing the Motor Vehicle Emission Simulator 

(MOVES2010) 

To run the MOVES2010 model, a run specification (hereafter referred to as "RunSpec") must be 

created so the appropriate parameters are selected for the modeling run. The RunSpecs, inputs, 

and outputs were reviewed against the following EPA document: Technical Guidance on the use of 

MOVES201 0 for Emission Inventory Preparation in State Implementation Plans and 

Transportation Conformity. This guidance document provides guidance on the use of the MOVES 

model to develop inventories for SIPs as well as analysis of emissions for transportation 

conformity determinations. 

EPA carefully reviewed the inputs into the model to ensure that they are representative of each 

respective parameter for the area. Table 1 presents the input parameters and the state's submittal 

for each parameter. The RunSpec parameters were reviewed as well; Table 2 presents the 

RunSpec parameters and the state's submittal for each parameter. The RunSpecs, input files, and 

output files were reviewed and found to have followed the applicable EPA guidance provided in 

the Technical Guidance on the use of MOVES201 0 for Emission Inventory Preparation in State 

Implementation Plans and Transportation Conformity. 

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Table 1. Review of Inputs for RunSpecs for years 2007, 2017 and 2025 the Allentown 

2006 PM2.s NAAQS Nonattainment Area Redesignation Request 

Parameter State Submittal 

Age Distribution All source types were presented with respect to age (0-30 years), and 

the age fraction of each source type. 

Average Speed All source types were presented with respect to road type, hour of the 

Distribution day, average speed and average speed fraction. 

FuelType and This parameter includes an input for alternative vehicle fuels and 

Technologies technologies, input of this parameter applies to areas that have 

vehicle fuels and technologies that are outside of the traditional 

inputs provided in the county data manager. There was no input 

provided for this parameter. 

Fuel (Includes inputs • For fuel formulation, the fuel formulation ID, Reid Vapor 

for fuel formulation and Pressure (RVP), and sulfur levels were included along with 

fuel supply) other data. 

• For Fuel Supply, the fuel formulation ID as well as the month 

group ID were included along with other parameters. 

Meteorology Data Meteorology data was provided for each hour of the day for each 

month. The meteorology data provided included temperature and 

relative humidity averages for each hour of a day for each month. 

Ramp Fraction The fractions of ramp driving times were provided for restricted 

access roadways. 

Road Type Distribution The vehicle miles traveled (VMT) fraction for each road type is 

provided for each source type and road type. 

Source Type The amount of vehicles for each source type are provided. 

Population 

Vehicle Type VMT • The daily VMT fractions were provided for respective days 

(includes inputs for and source types. 

daily VMT fraction, • The hourly VMT fractions were provided with respect to hour 

hourly VMT fraction, of the day and source type. 

and monthly VMT • The monthly VMT was provided with respect to source type 

fraction) and month. 

Inspection/Maintenance The liM programs were presented with respect to source types and 

(I/M) Programs compliance factors as well as other data. 

Table 2. RunSpec Reviews for the Allentown 2006 PM2.s NAAQS Nonattainment Area 

Redesignation Request for Years 2007,2017 and 2025 

Domain/Scale County scale was selected. This is acceptable for this air quality 

analysis. 

Calculation Type Inventory was selected which is acceptable for this analysis. 

Time Aggregation Level Hourly time aggregation was selected. Selection of hourly time 

aggregation level is acceptable for this analysis. 

Calendar Year Of The appropriate calendar year was selected. MOVES2010b can 

Evaluation model years 1990 and 1999-2050. 

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Month of Evaluation All 12 months were selected for evaluation. 

Type of Day of Weekdays and weekends were selected. 

Evaluation 

Hours of Evaluation Starting and ending hours create a whole day (from 0-24 hours). 

Geographic Bounds Lehigh County or Northampton County was selected. 

Vehicles/Equipment: On- Appropriate combinations of fuels and source use types were 

Road Vehicle Equipment made. 

Road Type Selection included all necessary road types. 

Pollutants and Processes Nitrogen oxides (NOx), sulfur dioxide (S02), ammonia (NH3), 

volatile organic compounds (VOCs) total gaseous hydrocarbons, 

non-methane hydrocarbons and all forms of primary PM2.s were 

selected, which is acceptable for this analysis; 

On-Road Retrofits N/A 

ROP N/A 

Output Database/Unit Mass units selected to be grams; energy units selected to be 

Selection million British Thermal Units (BTU); distance units selected to be 

miles. 

Output Emission Detail Emission detail was selected via user preference. 

in Emission Rate 

Calculations 

Advanced Performance N/A 

Features 

IV. Administrative Requirements for Making Adequacy Findings 

EPA followed the process for determining the adequacy of the submitted SIP MVEBs in 

accordance with the procedures listed in the January 2008 Conformity Regulations contained in 40 

CFR part 93, 118(f) "Adequacy review process for implementation plan submissions." EPA will 

be issuing a notice of proposed rulemaking (NPR) for a 30-day public comment period soliciting 

public comment for the approvability ofPennsylvania's SIP submission. EPA will also propose 

approval of the MVEBs for milestone year 2017 and the out-year 2025 for PM2.s and NOx. The 

MVEBs are presented below in Table 3. The NPR also proposes to find the MVEBs adequate or 

available for use for transportation conformity purposes. Following EPA's public comment · 

period, responses to any comments received on the proposed mobile budgets will be addressed in 

an amendment to this TSD. 

Table 3. MVEBs Contained in the Maintenance Plan for the Allentown 2006 PM2.s 

NAAQS Nonattainment Area 

Year Motor Vehicle Emissions Mobile Vehicle Emissions 

Budget for PM2.s-Tons Per Budget for NOx-Tons Per 

Year Year 

2017 297 8,081 

2025 234 5,303 

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V. Evaluation of the Adequacy of the MVEBs in the Maintenance Plan for the Allentown 

2006 PM2.s NAAQS Nonattainment Area 

In this TSD, we are evaluating the MVEBs associated with the maintenance plan contained in the 

September 5, 2014, SIP revision for conformity purposes. We are using the evaluation criteria 

detailed in the Transportation Conformity Rule, 40 CFR part 93.1 02(b )(2)(v), 93.1 02(b )(2)(v), 

93.102(b)(3), and part 93, 93.118(e)(4) through 93.118(e)(5). The evaluation is presented in 

Table 4, below. 

Table 4. Adequacy of the MVEBs Contained in the Maintenance Plan for the Allentown 

2006 PM2.sNAAQS Nonattainment Area 

Transportation Conformity Review. Criteria 

Rule 

40 CFR Part 93, 93.118 

93.1 02(b )(2)(iv) Have EPA and the State 

made a finding that NOx is 

an insignificant contributor 

to the direct mobile PM 

emissions? 

93.1 02(b )(2)(v) Has EPA or State made a 

finding that VOCs, Sulfur 

Oxides (SOx) or Ammonia 

(NH3) as precursors to be a 

significant contributor to the 

mobile PM2.s emissions? 

93.1 02(b )(3) Has the EPA or the State 

made a finding that reentrained road dust is a 

significant contributor to the 

PM mobile emissions? 

93.118(e)(4)(i) Was the submitted revised 

plan endorsed by the 

Governor (or his or her 

designee) and subject to a 

State public hearing? 

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Was the Criterion 

Satisfied? If Yes How was 

this Criteria Satisfied? 

Neither EPA nor the State 

has made such a finding. 

Neither EPA nor the State 

has made such a finding. 

Neither EPA nor the State 

has made such a finding. 

Yes, the submitted 

maintenance plan was 

endorsed and submitted as a 

SIP revision by the 

Governor's designee, the 

Acting Secretary, and a 

notice of public hearing was 

published in The Morning 
Call on April2, 2014. 

93.118(e)(4)(ii) Before the attainment Yes. Consultation has 

demonstration was submitted occurred among all required 

to EPA, did consultation federal, state and local 

between federal, State and agenctes. 

local agencies occur; was full 

implementation plan 

documentation provided to 

EPA, and was EPA's stated 

concerns, if any, addressed? 

93 .118( e)( 4 )(iii) Was the motor vehicle Yes, the budgets are clearly 

emissions budget(s) clearly identified on page 33 in the 

identified and precisely maintenance plan. 

quantified? 

93.118(e)(4)(iv) Is the motor vehicle EPA believes the budgets can 

emissions budget( s ), when be declared adequate because 

considered together with all in conjunction with the other 

other emission reductions, emission reductions, they 

consistent with applicable demonstrate attainment for 

requirements for attainment years 2017 and 2025. 

demonstrations? 

93.118(e)(4)(v) Is the motor vehicle EPA believes that the budgets 

emissions budget(s) are clearly related to the 

consistent with and clearly emissions inventory and the 

related to the emissions control measures in the SIP 

inventory and the control submittal. 

measures in the Plan? 

93.118(e)(4)(vi) Revisions to previously Yes, the maintenance plan 

submitted attainment provides new MVEBs for 

demonstrations: explain and years 2017 and 2025. The 

document any changes to addition of safety margins to 

previously submitted budgets the MVEBs is consistent with 

and control measures; continued attainment. 

impacts on point and area 

source emtsswns; any 

changes to established safety 

margins (see Sec. 93 .1 0 1 for 

definition); and reasons for 

the changes (including the 

basis for any changes related 

to emission factors or 

estimates of vehicle miles 

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traveled). 

93.118(e)(5) Did they provide and we Yes 

review public comments and 

the State's responses to those 

comments with the submitted 

control strategy SIP? 

VI. Findings 

Based upon our review and evaluation ofthe MVEBs contained in PADEP's September 5, 2014 

submittal of the maintenance plan to satisfy the requirements of the 2006 PM2.s NAAQS, we find 

the MVEBs to be adequate for conformity purposes and recommend that the MVEBs for the 

Allentown 2006 PM2.s NAAQS Nonattainment Area be SIP approved. 

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