# ffi,* South

Coast ffi Air Quality ManagementDistrict

21865 Copley Drive, Diamond Bar, CA 91765-4178 (949) 396-20OO' vwwv.aqmc{.gov

BOARDMEETINGDATE: April 4,2008 AGENDANO. 14
PROPOSAL: Request o 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 reflectSIPemission reductions, an alternate

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

budget adequacy findingsbased

on futurebaseline 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 2008and2009 transportation

conformity emission

budgets for the purpose

of U.S. EPA's initial conformity budget adequacy findings, andrecommend

U.S. EPA's approval

of the preferred

conformity budgets

based on the2007

SIP. 2) Request

CARB to provide

an alternative

approach for transportation

confor*ity emission budgets based on the 2007SIP baseline emissions

for all milestone

years up to the attainment

years, in the event

that U.S. EPA cannot approve or find adequate the budgets

based on the 2007SIP, 3) Continue

to work with CARB,SCAG, FHWA, and

U.S.EPA to resolve

issuesaffectingbudget

adequacy

andripdate

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 emissionbudgets which were subsequentlyforwarded to CARB for approval and incorporation into the 2007 StateImplementation Plan (SIP). On November 15, 2007,CARB approved the modified transportation conformity emissionbudgets

to reflect the additional on-road mobile source emission reductionsassociated with the revised Statewide Strategy. The2007 SIP for the South CoastAir Basin and the CoachellaValley, 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 submittedto 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 TransportationPlan (RTP) expires on June 7, 2008. SCAG is currently in the process of developing the 2008 RTP which must conform to the transportation conformity emissionbudgets 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 determinationwhich is contingent upon U.S. EPA's adequacy

findings of the 2007 SIP transportation conformity emissionbudgets.

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., FederalFunding to Mitigate Locomotive Emissions)in the 2007 SIP will result in the disapproval of the PM2.5 attainment demonstration. U.S. EPA has also receivedpublic 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 emissionsreductions claimed for two 2007AQMP on-road control measures for 2008 and 2009: Control MeasuresMOB05 (A8923 Light-Duty Vehicle High Emitter Identification Program) and MOB-06 (ABg23 Medium-Duty Vehicle High Emitter Identification Program). The purposeof thesemeasures

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 determinethe efficacy of the program. MOB-06 requires legislative authority since the measure applies to vehiclesthat are not currently subject to the Smog Check Program and would not beimplemented until after

2010. However,

emission reductions

wereinadvertently

assigned in 2008 and

2009 which werereflected

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 perdayof VOC and

NOx reductions

in 2009. For MOB-06,

the estimated

reductions

are0.1 ton per day of VOC andNOx 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 hasrequested

thatthe emission

reductions

for AQMP conffol measures MOB-05 and MOB-06 be removed

from the 2008and

2009 transportation

conformity

budgets because of uncertainties

associated

with achieving

these reductions.

Due to otherSIP approvability issues described

earlier, U.S. EPA staff is also

contemplating

the use of baseline

emissionsasthe operating

emissions

budgets for an interim approach

and makea final determination on the emissions

budgets (e.g., within one

year) aspart of its SIP approvalprocess. 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 andMOB-06from the 2008and 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 20L5or the federal 8-hour ambient air quality standard

by 2024. Staff is not proposing to remove

anyof the2007SIP control measures and theAQMD's SIP reduction commitment

will not change

since the commitmentis to achieve

the overallequivalent

reductions

through the application

of alternative or substitute

measures,

asprovided

in the 2007

AQMP. During the past

several weeks, staff has been workingwith staffs

from the U.S. EPA, CARB, andSCAG

to address

issues related to the 2007SIP 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

andtransmittal

etter would indicate

thatthe two sets

of budgets

are beingsubmitted

because of U.S. EPA indications

thatthe preferred

budgets, which reflectthe SIP revisions approved by the Board, may not be approvable

to U.S.EPA. CARB's resolution wouldrequest

that U.S. EPA not consider

the alternate

path budgets if it finds the preferred

pathbudgets 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

32009 state and local measures

that impact the on-roademissions, and 2) to reflect EMFAC 2007 calculations including external baseline adjustments. Preferred Path Budgetsare provided for the following milestone years: o South

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

Coast: 8-Hour Ozone

Standard:

2008, 2AL1,2014,2011 ,2020,2023
BaselineBudgets (Alternate Path): Submit revised transportation budgets that reflect the 2007 SIP baseline emissions

(reflecting rules adoptedas of October 20Aq. Thesebaseline

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 usedfor subsequent milestone years for PM2.5 and ozone,respectively.Should U.S. EPA only approveemission budgets for certain milestone years, emission budgets

for all future milestone years will remain the same

as the last milestoneyear approved.

U.S. EPA has raisedthe possibility that that any conformity budget which relies
on new strategies

adoptedas part of the 2007 AQMP/State Strategy may be disapproved because

of attainmentdemonstration concerns. The alternative path would not include 2007 AQMP/State Strategy emissions

reductions in excess

of already adopted regulationsin the baseline emissions,

allowing U.S. EPA to approvethose budgets and SCAG to prepare

conformity analyses

for its 2008 RTP.
SCAG will prepare

two conformity

determinations:

oneagainst

he preferred

path and theother against he 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

transportationconformity budgets within the next 12 months to reflect such resolution.

With respect

to Coachella

Valley conformity budgets, U.S. EPA is currently in the processof issuing a finding of budget adequacy for the budgets

in the Early Progress

Plan (EPP) approvedby CARB in February 2008. Basedon U.S. EPA's anticipatedapproval of the 2012 Coachella

Valley conformity budgetsin the Early Progress Plan, no further action is needed

on these budgets.

4CEQA and Socioeconomic Impacts CEQA and

socioeconomic

impacts for all controlmeasures

were already analyzed aspart of the 2007

AQMP and

there is no need

for any additional

analysis asa result

of the proposed revision.
AQMP and Legal Mandates The proposed

revision to thetransportation

conformity

emission budget will not impact the 2007SIP attainment

demonstration

or the overall SIP reduction commitment.
Resource

lmpacts The proposed

revision to thetransportation

conformity

emission budget will require

no additional

staff resources

and funding.

5