1 

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE:

SUB JECT: July 2, 2013

Technical Support Document for the Review of the Clean Data Motor Vehicle Emissions Budgets (MVEBs) for Fine Particulate Matter (PM 2.5 

### ) and Nitrogen Oxide (NO

x 

### ) for the Determination of Attai nment of the 2006 24

- hour Fine Particulate Matter Standard for the Pittsburgh

- Beaver Valley Nonattainment Area

FROM: Gregory Becoat /s/

Office of Air Program Planning (3AP30)

TO: Administrative Record of the U.S. Environmental Protection Agency’s Revi ew of

the Clean Data Motor Vehicle Emissions Budgets (MVEBs) for Fine Particulate Matter (PM 2.5 

### ) and Nitrogen Oxide (NO

x 

### ) for the Determination of Attainment of

the 2006 24

- hour Fine Particulate Matter Standard for the Pittsburgh

- Beaver Valley Nonattainmen t Area

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning (3AP30)

I. Background

On January 17 , 2013, the U.S. Environmental Protection Agency (EPA) Region 3 received a request for the approval and establishment of MVEBs for PM 2.5 

### and NO

x 

### for the Pittsburgh

- Beaver Valley Area from the Pennsylvania Department of Environmental Protection ( PA DEP) for the year

2011 . The establishment of MVEBs for PM 2.5 

### and NO

x 

### is based on EPA’s determination of clean

data for the Pittsburgh

- Beaver Valley Area for meeting the 2006 24

- hour PM 2.5 

### national ambient air quality standard (NAAQS)

. The Pittsburgh

- Beaver Valley Area consists of Allegheny County (not including the townships part of the Liberty

- Clairton nonattainment area); Beaver, Butl er, and Westmoreland Counties; and portions of Armstrong, Greene, and Lawrence Counties. The Pittsburgh

- Beaver Valley Area was designated nonattainment for the 1997 annual (70 FR 944) and

2006 24

- hour PM 2.5 

### NAAQS (74 FR 58688). EPA has already determined that the Pittsburgh

Beaver Valley Area attained the 1997 annual PM 2.5 

### NAAQS (77 FR 62147) and that the monitors in the Pittsburgh

- Beaver Valley Area have shown compliance with the 2006 24

- hour PM 2.5 

### standard based on ambient air monitoring data for 20 10, 2011

, and 2012

.

I I

. Transportation Conformity Requirements Under section 176(c) of the Clean Air Act ( CAA ) , new transportation plans, programs, and2



### 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 State Implementation Plan ( SIP )

. This means that such actions will not cau se or contribute to violations of NAAQS; worsen the severity of an existing violation; or delay timely attainment of any NAAQS or any interim milestone.

To meet emission inventory requirements of section 172(c)(3) of the CAA, a regional mobile

source hi ghway inventory must be prepared for direct and precursor PM 2.5 

### emissions, which

includes PM 2.5 

### and the precursor emissions of volatile organic compounds (VOC), NO

x 

### , sulfur dioxide (SO 2 

### ), and ammonia (NH 3 

### ). PADEP provided an emission inventory for the 201 1 analysis year using the Motor Vehicle Emissions Simulator emissions model ( MOVES2010a )

. The
MOVES model is EPA’s state

- of

- the

- art tool for estimating highway emiss ions that incorporates

the latest emissions data

. EPA announced the release of MOVES2010 in March 2010 (75 FR 9411). EPA subsequently rele ased two minor model revisions: MOVES2010a in September 2010 and MOVES2010b in April 2012. Both of these minor revisions enhance model performance and do not significantly affect the criteria pollutant em issions results from MOVES2010. Upon the release of MOVES2010, EPA established a two

- year grace period before MOVES is required to be used for regional conformity analyses (75 FR 9411). EPA subsequently promulgated a final rule on February 27, 2012 to pr ovide an additional year before MOVES was required for these analyses (77 FR 11394). The MOVES grace period for regi onal conformity analyses applied to both the use of MOVES2010 and approved minor revisions (e.g ., MOVES2010a and MOVES2010b). The

grace pe riod ended on March 2 , 2013; therefore, the MOVES model is now required for new regional emissions analyses for transportation conformity determinations (“regional conformity analyses”) ou tside of California. For more information, see EPA’s “Policy Guidan ce on the Use of MOVES2010 and Subsequent Minor Model Revisions for State Implementation Plan Development, Transportation Conformity, and Other Purposes” (April 2012)

.

For 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)

con sultation among F ederal, State, and local agencies occ urred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, if any, were addressed before the control strategy implementation plan was su bmitted ; (3) the MVEBs are clearly identified and precisely quantified; (4) the MVEBs , when considered together wit h 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

str ategy 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 marg ins; and reasons for the changes (including the basis for any changes related to emission factors or estim ates of vehicle miles traveled)

.3



### As described in 40 CFR 93.109(c)(5) of the transportation conformity rule and the preamble of the Transportation Conf

ormity Restructuring Amendments (77 FR 1498 2, March 14, 2012) , any nonattainment area that EPA determines has air quality monitoring data that meet the requirements of 40 CFR parts 50 and 58 and that show attainment of a NAAQS (clean data), must satisfy on e of the following requirements: (1) the budget test and/or interim emissions tests as required by section 93.118 and 93.119; (2) the budget test as required by section 93.118, using the adequate or approved motor vehicle emissions budgets in the submitte d or applicable control strategy implementation plan for the NAAQS for which the area is designated nonattainment; or (3) the budget test as required by section 93.118, using the motor vehicle emissions in the most recent year of attainment as motor vehicl e emissions budgets, if the state or local air quality agency requests that the motor vehicle emissions in the most recent year of attainment be used as budgets, and EPA approves the request in the rulemaking that determines that the area has

attained the NAAQS for which the area is designated nonattainment. The Pittsburgh

- Beaver Valley Area may establish clean data MVEBs under 40 CFR 93.109(c)(5)(iii) because the following criteria were met: (1) t he state requested that budgets be established in conjunct ion with EPA's determination of attainment (Clean Data) rulemaking for the 2006 24

- hour PM 2.5 

### NAAQS, and EPA approved the request; and, (2) the Pittsburgh

- Beaver Valley Area has not submitted a maintenance plan for the 2006 24

- hour PM 2.5 

### NAAQS and EPA has determined that the Area is not subject to the CAA reasonable further progress and attainment demonstration requirements for the 2006 24

- hour PM 2.5 

### NAAQS. Table 1 below demonstrates how the document prepared by PADEP satisfies the requirements for clean d ata MVEBs

.

TABLE 1. EPA’S EVALUATION OF THE CLEAN DATA MOTOR VEHICLE EMISSIONS

BUDGETS SUBMITTED BY THE PENNSYLVANIA DEPARTMENT OF

ENVIRONMENTAL PROTECTION FOR THE PITTSBURGH

- BEAVER VALLEY AREA TO

EPA ON JANUARY 17, 2013

CRITERIA APPLICABLE TO CLEAN DAT A BUDGETS

SECTION

OF

40 CFR PART

93 CRITERIA Y/N COMMENTS

93.110 Are the budgets based upon

the latest planning assumptions? Y All planning assumptions used were the

latest available. The hi ghway mobile source emission inventory was developed using
available travel data and EPA’s

MOVES2010a emission model. A mix of

local dat a and national default data was used for this analysis (based on EPA’s MOVES technical guidance). Local data

was used f

or the primary data items that have a significant impact on emissio ns

.4 These include the following: vehicle miles of travel (VMT) by vehicle type, average speed distribution, vehicle type mixes, source type population (for light

- duty vehicles)

, vehicle ag e distribution, hourly

distributions , m eteorology data

, Inspection/Maintenance program , and fuel supply. Most local data inputs to the analysis process reflect the latest planning assumptions based on 2008 data obtained from the Pennsylvania Department of Transportation (PennDOT), the Bureau of Motor Vehicles, and other local/national

sour ces. Newer data was available and was used for control strategies ( e.g. Inspection

Maintenance programs), vehicle age

distributions and fuel characteristics.

PPSUITE wa s used to calculate hourly congested speeds for each roadway link, apply vehicle type fractions, aggregate VMT, prepare MOVES2010a traffic

related input files, and process MOVES2010a outputs. CENTRAL was used to execute the PPSUITE and MOVES2010a processe s in order to allow users to execute runs for a variety of input options and integrates custom MYSQL steps into the process.

93.111 A re the budgets based upon

the latest emissions model? Y The inventory reflects the highway mobile

source emiss ion estimations using EPA’s

MOVES2010a emission model. EPA’s MOVES model was officially released on March 2, 2010 and was followed with a revised version (MOVES2010a) in August 2010. MOVES2010a has been integrated with local traffic, vehicle fleet,

enviro nmental, fuel, and control strategy

data to estimate emissions. The MOVES2010a inputs that were prepared by PPSUITE included vehicle type VMT, vehicle population, VMT fractions, average speed distributions, road type distribution5 and ramp fractions. Thes e files were input into the MOVES2010a county data importer. Additional non

- PPSUITE inputs included fuel and vehicle ages, as well as temperatures and I/M programs.

93.118

93.118 (e)(4)(i)

93.118(e)(4)(ii) Did the state or local air

quality agency request that

the motor vehicle emissions in the most recent year of

attainment be used as budgets, and did EPA

approve the r equest in the rulemaking that determines

that the area has attained the NAAQS for which the area is designated

nonattainment ?

Was the request for the

establishment of the clean data budgets endorsed by the Governor (or his or her designee) ?

Before the request that clean data budgets be

established was submitted to EPA, consultation among federal, State, and local agencies occurred; full implementation plan

documentation was provided to EPA; and Y

Y

Y PADEP requested for approval and

establishment of MVEBs for PM 2.5 and

NO

x for the Pittsburgh

- Beaver V alley Area for the attainment year 2011. EPA has

determined that the Pittsburgh

- Beaver Valley Area has clean data for the 2006 24

- hour PM 2.5 NAAQS. MOVES2010a was executed to provide a highway mobile source emission inventory. For the 1997 annual (70 FR 944) and 2006 24

- hour (74 FR 58688) PM 2.5 NAAQS for the Pittsburgh

- Beaver Valley Nonattainment Area, the highway vehicle emissions of

direct PM 2.5 and NO

x for the analysis year 2011 are as follows (short tons/year):

2011 Analysis Year Budget 28,973.05 (N O

x ) 961.71 (PM 2.5 )

Letter addressed to Shawn M. Garvin, Regional Administrator, EPA Region III from Michael L. Krancer, Secretary, Pennsylvania DEP

This conformity analysis does not accompany a control strategy implementation plan or maintenance p lan; therefore, documentation of consultation is not applicabl e for a clean data budget request. However, consultation has occurred among all required Federal, State, and local agencies to discuss the PM 2.5 clean data budgets before submittal of the6

93.118(e )(4)(iii)

93.118(e)(4)(iv)

93.118(e)(4)(v)

93.118(e)(4)(vi) EPA's stated concerns, if

any, were addressed;

Were the motor vehicle emissions budget(s) (MVEBs) clearly identified and precisely quantified?

Are the motor vehicle emissions budget(s), when considered together with all other emissions sources, consistent with applicable requirements for

attainm ent ?

Are the motor vehicle emissions budget(s) consistent with and clearly

related to the emissions inventory and the control

measures in the submitted conformity analysis?

Revisions to previously

submitted maintenance plan: explain and document any changes to previously submitted budgets and control measures; impacts on point and area source emissions; any changes to Y

Y

Y

N/A reque st.

Appendix A

- 2 of the submittal provides detailed emission summary tables for the Pittsburgh

- Beaver Valley Area for analysis year 2011.

EPA believes that the MVEBs are consistent with the applicable requirements

for attainment because the budgets are based on the motor vehicle emissions in the most recent year of attainment and EPA has

made a determination of clean data for the Pittsburgh

- Beaver Valley Area for meeting

the 2006 24

- hour PM 2.5 NAAQS. EPA has

determined that the monitors in the

Pitt sburgh

- Beaver Valley Area have shown compliance with the 2006 24

- hour PM 2.5 standard based on ambient air monitoring data for 2009, 2010, and 2011.

E PA believes that the motor vehicle

emissions are clearly related to the emissions inventory and none of t he control measures have changed

.

This section does not apply because the budgets are not being established through

an attainment demonstration or maintenance plan. The newly established MVEBs are clean data budgets and are not required to be submitted with a n attainment

demonstration or a maintenance plan.7 established safety margins (see Sec. 93.101 for definition); and reasons for the changes (including the basis for any changes

rela ted to emission factors

or estimates of vehicle miles traveled).



### CONCLUSION

Based upon our review and evaluati on of the clean data MVEBs estimated in the Pittsburgh

Beaver Valley Area conformity analysis, EPA finds that the conformity analysis meet s the requirem ents of the CAA and the applicable regulations promulgated at 40 CFR part 93

. Therefore, EPA is proposing to approve the establishment of the clean data MVEBs for the year 2011 for the Pittsburgh

- Beaver Valley Area 

### . EPA can conclude that the devel opment methodology

of the MVEBs is consistent with applicable guidance documents intended for the development of

on

- road inventories and MVEBs. EPA has also reviewed the ambient air monitoring data fo r 2010, 2011, and 2012 and has determined clean data for the P ittsburgh

- Beaver Valley Area for meeting the 2006 24

- hour PM 2.5 

### NAAQS. As a result, the Pittsburgh

- Beaver Valley Area may establish MVEBs under 40 CFR 93.109(c)(5)(iii) . By establishing clean data MVEBs, the Southwestern Pennsylvania Commission, the 

### Metr opolitan Planning Organization for the Pittsburgh

- Beaver Valley Area, can compare emissions estimated for future transportation planning

to the 2011 clean data MVEB s that were developed using MOVES2010a

.