### 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) Nonattainment Area

Asrah Khadr, Environmental Engineer, Engineerin Training (EIT)

# ~**~** Office ofAir Program Planning (3AP30) 11-. 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 Femandez Associa e Director Office ofAir Program Planning (3AP30)



### I. Background

OnNovember 13,2009 (74 FR 58688), Lehigh andNorthampton Counties were designated as nonattainment for the 2006 PM2

.sNAAQS as a part ofthe Allentown 2006 PM2

.sNAAQS Nonattainment Area. On March 29, 2012 (77 FR 18922), it was determined that the Allentown 2006 PM2.s NAAQS Nonattainment Areahad 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 inthe notice ofproposed rulemaking (NPR) in this docket. On September 5, 2014, the PennsylvaniaDepartment ofEnvironmental 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 Nonattainment Area.



### II. Transportation Conformity Requirements

Under section 176(c) ofthe CAA, newtransportationplans, programs, and projects, such as the construction ofnewhighways, must "conform"to (i.e., be consistent with) the part ofthe state's air quality planthat addresses pollution from cars and trucks. The CAA requires federal actions in nonattainment and maintenance areas to "conformto" the goals ofthe SIP. This means that such actions will not cause or contribute to violations ofNAAQS; worsen the severity ofan existing violation; or delay timely attainment ofany NAAQS or any interim milestone.

1Formotor 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 subjectto a State public hearing; (2) consultation among Federal, State, and local agencies occurred; full implementationplan documentation was provided to EPA; and EPA's stated concerns, ifany, 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 onpoint 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 ofvehicle miles traveled).



### III. Review ofthe 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 MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. This guidance documentprovides guidance on the use ofthe MOVES model to develop inventories for SIPs as well as analysis ofemissions for transportation conformity determinations.

EPA carefully reviewed the inputs into the model to ensure thatthey are representative ofeach respective parameter for the area. Table 1presents the input parameters and the state's submittal for eachparameter. 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 MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity.

2Table 

### 1. Review ofInputs for RunSpecs for years 2007, 2017 and 2025 the Allentown 2006 PM2.s NAAQS NonattainmentArea Redesignation Request Parameter State Submittal Age Distribution All source types were presented with respect to age (0-30 years), and the age fraction ofeach source type. Average Speed All source types were presented with respect to road type, hour ofthe Distribution day, average speed and average speed fraction. FuelType and This parameter includes an input for alternative vehicle fuels and Technologies technologies, input ofthis parameter applies to areas thathave vehicle fuels and technologies that are outside ofthe 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 otherparameters. Meteorology Data Meteorology data was provided for eachhour ofthe day for each month. The meteorology dataprovided includedtemperature and relative humidity averages for each hour ofa day for each month. Ramp Fraction The fractions oframp driving times were provided for restricted

access roadways. Road Type Distribution The vehicle miles traveled (VMT) fraction for eachroad type is provided for each source type and road type. Source Type The amount ofvehicles 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, ofthe day and source type. and monthly VMT 

## • The monthly VMT was provided with respect to source type fraction) and month. Inspection/Maintenance The liMprograms were presented withrespect to source types and (I/M) Programs compliance factors as well as other data.

Table2. 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 ofhourly 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.

3Month ofEvaluation All 12 months were selected for evaluation. Type ofDay of Weekdays and weekends were selected. Evaluation Hours ofEvaluation Starting and ending hours create a whole day (from 0-24 hours). Geographic Bounds Lehigh County orNorthampton County was selected. Vehicles/Equipment: On- Appropriate combinations offuels 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 ofprimary 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 viauserpreference. in Emission Rate Calculations Advanced Performance N/A Features



### IV. AdministrativeRequirements for MakingAdequacyFindings

EPA followed the process for determining the adequacy ofthe submitted SIP MVEBs in accordance with the procedures listed in the January 2008 Conformity Regulations contained in 40 CFRpart 93, 118(f) "Adequacy reviewprocess for implementationplan submissions." EPA will be issuing a notice ofproposed rulemaking (NPR) for a 30-daypublic commentperiod soliciting public comment for the approvability ofPennsylvania's SIP submission. EPA will also propose approval ofthe MVEBs for milestone year 2017 andthe out-year 2025 for PM2.s and NOx. The MVEBs are presented below in Table 3. TheNPR also proposes to find the MVEBs adequate or available for use for transportation conformitypurposes. Following EPA'spublic comment · period, responses to any comments received onthe proposed mobile budgets will be addressed in

an amendment to this TSD.



### Table 3. MVEBs Contained in the MaintenancePlan for the Allentown 2006 

### PM2.s NAAQS Nonattainment Area Year Motor Vehicle Emissions Mobile Vehicle Emissions Budgetfor 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 ofthe Adequacy ofthe MVEBs in the Maintenance Plan for the Allentown 2006 

### PM2.s NAAQS NonattainmentArea

In this TSD, we are evaluating the MVEBs associated withthe 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 CFRpart 93.102(b)(2)(v), 93.102(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.



### Table4. Adequacy ofthe MVEBs Contained in the Maintenance Plan for the Allentown 2006 

### PM2.sNAAQS NonattainmentArea Transportation Conformity Review

.Criteria Rule 40 CFRPart93, 93.118

93.102(b)(2)(iv) Have EPA and the State made a finding that NOx is
aninsignificant contributor to the direct mobile PM emissions?

93.102(b)(2)(v) Has EPA or State made a finding thatVOCs, Sulfur Oxides (SOx) or Ammonia (NH3) as precursors to be a significant contributor to the mobile PM2

.semissions?

93.102(b)(3) Has the EPA orthe State made a finding that reentrained road dust is a significant contributorto the PM mobile emissions?
93.118(e)(4)(i) Was the submitted revised plan endorsed by the Governor (or his orher designee) and subject to a State public hearing?

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### Was the Criterion Satisfied? If

### Yes How was this Criteria Satisfied?

Neither EPAnorthe State has made such a finding.

Neither EPA northe State has made such a finding.

Neither EPAnorthe State has made such a finding.

Yes, the submitted maintenance plan was endorsed and submitted as a SIP revisionby the Governor's designee, the Acting Secretary, and a notice ofpublic hearing was published in The MorningCall 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 implementationplan documentationprovided to EPA, and was EPA's stated concerns, ifany, addressed?

93.118(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly emissions budget(s) clearly identified onpage 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 inconjunction withthe other other emission reductions, emission reductions, they consistentwith applicable demonstrate attainment for requirements for attainment years 2017 and 2025. demonstrations?
93.118(e)(4)(v) Is the motor vehicle EPAbelieves thatthe budgets emissions budget(s) are clearly related to the consistentwith and clearly emissions inventory and the related to the emissions control measures inthe 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 newMVEBs for demonstrations: explain and years 2017 and 2025. The document any changes to addition ofsafety margins to previously submitted budgets the MVEBs is consistent with and control measures; continued attainment. impacts onpoint and area
source emtsswns; any changes to 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

6traveled). 93.118(e)(5) Did they provide and we Yes reviewpublic comments and the State's responses to those comments with the submitted control strategy SIP?



### VI. Findings

Based upon our review and evaluation oftheMVEBs contained inPADEP's September 5, 2014 submittal ofthe maintenance planto satisfy the requirements ofthe 2006 PM2.s NAAQS, we find the MVEBs to be adequate for conformity purposes and recommend thatthe MVEBs for the Allentown 2006 PM2

.sNAAQS Nonattainment Areabe SIP approved.



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