UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105·3901 

James Goldstene, Executive Officer 

California Air Resources Board 

1001 I Street, P .0. Box 2815 

Sacramento, CA 95812 

JUL 16 2009 

Re: Adequacy Status of Sacramento 8-Hour Ozone Reasonable Further Progress (RFP) and 

Attainment Plan Motor Vehicle Emissions Budgets 

Dear Mr. Goldstene: 

We have found adequate for transportation conformity purposes certain motor vehicle 

emissions budgets (MVEBs) in the Sacramento Regional 8-Hour Ozone Attainment and 

Reasonable Further Progress Plan (March 27, 2009), ("2009 Sacramento Ozone Plan") and 

have found inadequate certain other MVEBs in this plan. As a result of our finding, Sacramento 

Area Council of Governments (SACOG) and the U.S. Department ofTransportation must use the 

adequate budgets and cannot use the inadequate budgets in future transportation conformity 

analyses once the finding becomes effective. 

On January 21, 2009, the California Air Resources Board (CARB) submitted a request to 

EPA for parallel processing of the MVEBs in the final, but not yet adopted, 2009 Sacramento 

Ozone Plan. Following adoption of the plan by the five applicable air pollution control districts 

in the Sacramento region, CARB adopted the plan and submitted it to EPA on April 17, 2009 as 

a revision to the California State Implementation Plan (SIP). The plan includes new control 

measures and demonstrations of RFP and attainment for the 1997 8-hour ozone National 

Ambient Air Quality Standard (NAAQS). The plan identifies MVEBs for reactive organic gases 

(ROG) and nitrogen oxides (NOx) for each RFP milestone year through 2017 and for the 

attainment year 2018. Acting in response to CARB's request for parallel processing, we 

announced availability of the plan and related MVEBs on the Internet on March 18, 2009, and 

requested public comment by April 17, 2009. We received no comments on the budgets and plan 

during that comment period. 

This letter transmits our decision that the motor vehicle emissions budgets for 2011, 2014 

and 2017 contained in the 2009 Sacramento Ozone Plan are adequate for transportation 

conformity decisions. These budgets are consistent with the plan's RFP demonstrations for 

milestone years 2011, 2014, and 2017, and these budgets are based on control measures, that 

have already been adopted and implemented. The budgets also meet the other adequacy criteria, 

therefore, these budgets meet the transportation conformity adequacy criteria found in 40 CFR 

93 .118( e)( 4 ). The adequate budgets are as follows: 

Print~d on Recycl~d Paptr 

---~-----
Adequate Motor Vehicle Emissions Budgets (Summer planning) 

Budget Year Reactive Organic Gases 1 Nitrogen Oxides 

(tons per day) (tons per day) 

2011 38 78 

2014 32 61 

2017 29 48 

1 Reactive Organic Gases (ROG) is the term used in the plan and is comparable to 

the Federal term, volatile organic compounds (VOC). 

This letter also transmits our finding that the motor vehicle emissions budgets for 2018 

are inadequate for transportation conformity purposes. The 2018 budgets include estimated 

emission reductions associated with a number of commitments for future rule adoption that lack 

specificity. As such, the SACOG would not be able to accurately quantify future emission 

reductions associated with the commitments. Without additional specificity, it is also unclear 

how the 2018 budgets are precisely quantified or related to the overall emissions inventory and 

other measures. Therefore, the 2018 budgets do not meet the adequacy criteria found in 40 CFR 

93.118(e)(4)(iii), (iv), and (v). 

Inadequate Motor Vehicle Emissions Budgets (Summer planning) 

Budget Year Reactive Organic Gases 1 Nitrogen Oxides 

(tons per day) (tons per day) 

2018 24 34 

1 Reactive Organic Gases (ROG) is the term used in the plan and is comparable to 

the Federal term, volatile organic compounds (VOC). 

We have detailed our adequacy findings in the enclosure. A copy of this letter and its 

enclosure will soon be posted on the Internet at: 

http://www.epa.gov/otaq/stateresources/transconfi'adequacy.htm. We will also announce the 

adequacy findings in the Federal Register. The findings will become effective 15 days after the 

Federal Register announcement pursuant to 40 CFR 93.118(t). 

If you have any questions regarding these adequacy findings or would like copies of the 

comments received, please contact Kerry Drake at (415) 947-4157 or John Kelly at (415) 947-

4151. 

Enclosure 

Sincerely, 

Deborah 

/)Jw~ Jordan 

Director, Air Division 

2 
cc: Larry Greene, Executive Director, Sacramento Metropolitan AQMD 

Mike McKeever, Executive Director, Sacramento Area COG 

Steve Luxenberg, Federal Highway Administration 

Ted Madey, Federal Transit Administration 

3 
Enclosure 1: Transportation Conformity Adequacy Review 

an was endorsed by the 

nor (or designee) and was 

t to a public hearing. 

y 

4 

Date of SIP Revision Receipt by EPA: April 1 7, 2009 

The April 17, 2009 transmittal letter submitting the 2009 Sacramento Ozone Plan 

was sent by CARB's Executive Officer, James Goldstene, the Governor's 

designee. The transmittal letter indicates that the CARB formally adopted the plan on March 26, 2009 through a Board Resolution (09-19). Local air districts 

(Sacramento Metro AQMD, Yolo-Solano AQMD, Feather River AQMD, Placer 

County APCD, ElDorado County AQMD) released their draft plan on September 

10, 2008 and held public workshops September 22-25, 2008, requesting that 

public comments be received prior to or at their Board adoption hearings. District 

Board hearings were held between January 22 and February 19, 2009. CARB 

issued the public notice on February 24, 2009 and requested public comments at 

or before the public hearing held on March 26, 2009. Here is a link to the notice: 
an was developed through y Consultation with federal, state and local agencies was undertaken. Section 2.6 of 

tation with federal, state and the 2009 Sacramento Ozone Plan describes the participation among the various 

gencies; full implementation agencies in development of the plan. The consultation process for conformity 

ocumentation was provided budgets occurs in Sacramento via the Sacramento Area Council of Governments 

PA's stated concerns, if any, hosted Regional Planning Partnership. The Regional Planning Partnership 

ddressed. membership includes SACOG staff, local transportation agencies, Federal 

Highway Administration, EPA, CARB, California Dept. ofTransportation, the 

local air quality management districts, and local environmental groups including 

Environmental Council of Sacramento. The meetings are open to the public. 

Meeting notices are posted on the SACOG website. Consultation on the Draft 

2009 Sacramento Ozone Plan, including the conformity budgets, occurred on 

September 17, 2008. The materials for that meeting can be found at the following 

link: httQ://www.sacog.orgcalendar 200S/09i241£QQ/Qdf!04-SIP .gdf 

EPA received a copy of the draft 2009 Sacramento Ozone Plan and EPA's 

comments were addressed. 

otor vehicle emission budget( s) YIN The motor vehicle emissions budgets for 2011, 2014, and 2017 are clearly 

rly identified and precisely identified and precisely quantified in appendix F of the 2009 Sacramento Ozone 

fied. Plan. The budget for 2018 is not precisely quantified because the new emission 

reductions from the 2007 State Strategy, as adopted by CARB for attainment of 

the ozone NAAQS in the Sacramento region, do not result from adequately 

specified control measures. More specifically, the emissions reduction 

commitment by CARB for the Sacramento region is an aggregate reduction 

commitment that may be satisfied by various measures, some of which relate to 

on-road sources and others of which relate to nonroad sources and consumer 

products. Since the precise emissions reduction commitment by CARB from the 

on-road source category is indefinite, the portion of the State's emissions 

reduction commitment that is included in the budget cannot be precisely 

quantified. The budget for 2018 lists the on-road portion of the State's 

commitment as 3.4 tons per day ofROG and 11.2 tons per day ofNOx (see table 

F-4 in Appendix F), but such estimates are merely assumptions and do not reflect 

specific commitments by the State. In contrast, the budgets for the years 2011, 

2014 and 2017 reflect control measures that are already adopted or from a specific 

on-road mobile source incentive program. See tables F-1, F-2, and F-3 in appendix 

F of the 2009 Sacramento Ozone Plan, and see resolution of plan adoption by the 

Sacramento Metropolitan AQMD (Resolution No. 2009-001 ). 

5 
otor vehicle emissions YIN EPA has preliminarily concluded that the budgets for the years 20 II, 2014 and 

(s), when considered together 2017, when considered together with all other emission sources, are consistent 

l other emission sources, is with the requirement to demonstrate reasonable further progress for the 1997 8-

tent with applicable hour ozone standard. This finding is based on review of the plan's ozone RFP 

ements for reasonable further demonstration (chapter 13 of the plan, specifically table 13-1, and also table G-1 

ss, attainment, or maintenance of appendix G) that reasonably demonstrates the required 3% annual rate of 

hever is relevant to the given progress (averaged over each three-year period) without reliance on new measures 

(i.e., RFP is demonstrated based on emissions reductions from existing measures 

plus certain emissions reductions credits (ERC). EPA cannot determine that the 

2018 motor vehicle emissions budgets, when considered together with all other 

emission sources, are consistent with the requirement to demonstrate attainment 

because the control strategy does not include sufficient State and local measures 

and commitments to achieve the full emissions reductions needed to be 

implemented by 2018 but relies to a limited extent on future EPA action to reduce 

locomotive emissions. This conclusion is based on a comparison of the new State 

and Federal SIP Measures expected to be implemented in 2018 in the Sacramento 

region (page 7-4 of the plan) with CARB's related aggregate emissions reduction 

commitment to achieve 13 tons per day ofNOx and II tons per day ofROG by 

2018 in the Sacramento region (see page 4 ofCARB Resolution No. 09-19). 

an shows a clear relationship YIN The plan shows a clear relationship among the budgets for years 20 II, 2014 and 

 the emissions budget(s), 2017, the control measures and the total emissions inventories in those RFP 

l measures and the total milestone years. The planning emissions inventories for all stationary, area, on

ons inventory. road mobile, and nonroad mobile sources are shown in tables 5-2 and 5-3 of the 

plan. The MVEBs that are shown on page 11-8, and that are documented in 

Appendix F, are consistent with the on-road emissions estimates in table 5-2 and 

5-3. The inventories (including the budgets) are then combined with emissions 

reduction credits (ERCs) in tables 5-4 and 5-5 to provide the basis for 

demonstrating RFP in years 2011, 2014, and 2017as shown in table 13-1 of the 

plan without reliance on emissions reductions from new measures. As stated 

elsewhere, the 2018 budget incorporates new emission reductions from the State's 

strategy that do not result from specified on-road control measures, and thus, the 

plan does not show a clear relationship among the 2018 budgets, the control 

measures, and the total emissions inventory. 

6 
ons to previously submitted y Chapter 11 of the 2009 Sacramento Ozone Plan addresses prior plans. The most 

l strategy or maintenance plans recent conformity budgets found adequate by EPA on March 14, 2006 (71 FR 

n and document any changes to 13124) were established as part of the Reasonable Further Progress Plan for the 

evious submitted budgets and 2008 milestone year ("Sacramento Regional Nonattainment Area 8-hour Ozone 

l measures; impacts on point Rate-of-Progress Plan- Final Report", February 2006). The Reasonable Further 

ea source emissions; any Progress Plan for the 2011 milestone year ("Sacramento Regional8-Hour Ozone 

es to established safety margins 2011 Reasonable Further Progress Plan", May 2008) was submitted in May 2008, 

93.101 for defmition), and but has not yet been acted on by EPA. The 2011 RFP was prepared before final 

s for the changes (including the approval ofSACOG's recent "Metropolitan Transportation Plan for 2035", which 

or any changes to emission contained updated motor vehicle activity and used a prior version ofCARB's 

 or estimates of vehicle miles motor vehicle emission factor model (EMF AC2002). The 2009 Sacramento 8-

d). Hour Ozone Attainment and RFP Plan uses the updated motor vehicle activity data 

and CARB's current model (EMF AC2007). The budgets under consideration 

replace the budgets proposed in the previous 2011 RFP submittal. A discussion of 

the changes in the EMF AC model is discussed in Section 5.3 .3 of the Plan and 

changes in the budgets is discussed in Section 11.7 of the Plan. EMF AC2007 was 

approved by EPA in January 2008 (73 FR 3464, January 18, 2008), and EPA's 

January 2008 notice of availability for EMF AC2007 details the basis for the 

changes to the emission factors. 

as reviewed the State's y Public comments were supportive of the Districts' and State's adoptions. Public 

ation of public comments and comments are either included or paraphrased and are addressed by each District. 

se to comments that are Each District provided these comments and responses as an attachment to their 

d to be submitted with any transmittal of their Board resolutions which they adopted in January and February 

mentation plan. 2009. Specifically, comments and responses were included in transmittal letters 

from each District's APCO to James Goldstene, CARB's Executive Officer 

(SMAQMD letter dated 2/9/09, YSAQMD 3/4/09, FRAQMD 2/17/09, PCAPCD 

2/20/09, EDCAQMD 2/17/09) .. We have reviewed the compilation of comments 

and responses and find the responses to be acceptable. No issues that might have affected our adequacy finding rema_in unanswered. -------

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