1 **UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103** 

June 17, 2013

**SUB JECT**  : Supplemental Technical Support Document (TSD)

- In significance Findings for the

Motor Vehicle Emissions for the Redesignation Request and Maintenance Plan f or the West Virginia Portion of the Wheeling, WV

- OH 1997 Fine P articulate M atte r (PM 2.5 ) Nonattainment Area

**FROM:** /s/

Gregory Becoat Environmental Scientist (3AP 30 )

**TO:** Administrative Record for the In significance Findings for the Motor Vehicle Emissions for the Redesignation Request and Maintenance Plan for West Virginia Portion of the Wheeling, WV

- OH 1997 PM 2.5 Nonattainment Area

**THRU: /s/** 

Cristina Fernandez
, Associate Director Office of Air Program Planning (3AP 30 )

**I. Background**

On March 8, 2012, the State of West Virginia formally submitted a Redesignation Request and Maintenance Plan for West Virginia Portion of the Wheeling, WV

- OH 1997 PM 2.5 Nonattainment Area (hereafter the Redesignation Request and Maintenance Pla n)

. The SI P included a request for a finding of insignificance b y EPA for motor vehicle emissions for nitrogen oxides (NOx), direct particulate matter (PM) , and sulfur dioxide (SO 2 )

. Transportation conformity is required under section 176(c) of the Clean Air Act ( CAA ) to ensure that f ederally supported highway , transi t projects, and other activities are consistent with (conform to) the purpose of the State Implementation Plans ( SI P )

. The CAA requires federal actions in nonattainment and maintenance areas to “conform to” the goals of SIP. This means that such actions will not cause or contribute to violations of a national ambient air quality standard (NAAQS); worsen the severity of an existing violation; or delay timely attainment of
any NAAQS or any

interim milestone. Actions involving Federal Highway Administration (FHWA) or Federal Transit Administration (FTA) funding or approval are subject to the transportation conformity rule ( 40 CFR part 93 , subpart A). Under this rule, metropolitan planning organizations (MPOs) in nonattainment and maintenance areas coordinat e with State air quality and transportation agencies, EPA, FHWA, and FTA to demonstrate that their metropolitan transportation plans and TI Ps conform to applicable SI Ps. This is ty pically2

determined by

showing that estimated emissions from existing and pl anned highway and transit
sy stems are less than or equal to the motor vehicle emissions budgets (MVEBs) contained in a SI P.

F or 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 cri teria 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 occurred; full implementation plan documentatio n 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

em issions 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 estim ates of vehicle miles traveled).

Incertain instances, the Transportation Conformity Rule allows areas to forgo establishment of a MVEB where it is demonstrated that the regional motor vehicle e missions for a particular pollutant or precursor are an insignificant contributor to the air quality problem in an area. The general criteria for insignificance determinations can be found in 40 CFR 93.109 (f). In significance determinations are based on a number of factors, including the percentage of motor vehicle emissions in the cont ext of the total SI P inventory ; the current state of air quality as determined by

monitori ng data for the relevant NAAQS; the absence of SI P motor vehicle control measures; and the historical trends and future projections of the growth of motor vehicle emissions. EPA’ s rationale for providing for insignificance determinations is described in the July 1, 2004, revision to the Transportation Conformity Rule at 69 FR 40004

. Spe cifically , the rationale is explained on page 40061 under the subsection XXI II. B. entitled, “ Areas With In signif icant Motor Vehicle Emissions.” Any insignificance determination under review of EPA is subject to the adequacy and approval process for EPA's action on the SI P.

**I I**  **. Administrative Requirements for Making**  **Insignificance Findings** 

EPA ha s followed the process for reviewing the submitted SI P and determining if an insignificance finding for Motor Vehicle Emissions is warranted in accordance with the procedures listed in the January 2008 Conformity

Regulations contained in 40 CFR 93. 102 (b)

- “Geographical applicabil i ty” and 40 CFR 93. 118(f)

- “ Adequacy review process for implementation plan submissions

. ”

**II I** 

**. Evaluation**  **of the Request**  **for an I nsignificance Finding**  **for M**  **otor V**  **ehicle E**  **mission s**  **in t he**  **Redesignation Request and Maintenance Plan for**  **the West Virginia Portion of the**  **Wheeling, WV**

**- OH**  **1997 PM**  **2.5 Nonattainment Area**  **Submitted b y**  **T he**  **West Virginia**3

**Department of Environment al Protection** 

Inthis TSD, EPA is evaluating the West Virginia Department of Environmental Protection’s request for an insignificance finding for motor vehicle emissions associated with the Redesignation Request and Maintenance Plan contained in the submittal. EPA is using the evaluation criteria detailed in the Transportation Conformity Rule, 40 CFR 93.1 02(b)(2) ( iv), 93.102(b)(2)(v)
, 93.102(b)(3)
, and 93.118(e)4 through 93.118(e)5. The evaluation is presented below.

**Review of the Request for Insignificance Finding**  **o f M**  **otor V**  **ehicle E**  **missions in the**  **Redesignation Request and Maintenance Plan for**  **the West Virginia Portion of the** 

**Wheeling, WV**

**- OH**  **PM 2.5**  **Nonattainment Area**

Transportation Conformity Rule 40 CFR Part 93, 93.118 Review Criteria Was the Criterion Satisfied? If Yes
, How was this Criteria Satisfied? 93.102(b)(2)(iv) Has the EPA and the State made a finding that NOx is an insignificant contributor to the direct mobile PM emissions or does the implementation plan fail to establish a NOx budget as part of the P M 2.5 maintenance strategy ? T he State has requested that NOx be found an insignificant contributor to the m obile PM emissions. This request is based

on the fact that Onroad mobile source NOx constitutes less than twelve and a half percent of the area’s t otal NOx emission in the 2015 and 2022 horizon years due to continuing fleet turnover even with future vehicle miles traveled (VMT) growth included in the emission projections. 93.102(b)(2)(v) Has the EPA or State made a finding that V olatile O rganic C ompounds (V OCs )
, Sulf ur Dioxide ( S O 2 ) or Ammonia (NH 3 ) as pr e cursors to be a significant contributor to the mobile PM emissions or does the implementation plan submission establish a budget for VOCs, SOx or (NH 3 ) as part of a PM 2.5 maintenance strategy ? N either EPA nor the S tate has made any findings that VOC s, S O 2 , or (NH 3 ) is a significant contributor to the PM 2.5 mobile emissions
, and therefore
, it has not been included in the SI P

. Onroad mobile source SO 2 constitutes less than 0.1% of the area’s total SO 2 emissions in the 2015 and 2022 horizon years.

93.102(b)(3) Has the EPA or the State made a finding that direct PM is a significant contributor to the PM mobile The State has requested that direct PM be found an insignificant contributor to the mobile PM emissions. This request is based4 emissions or does the implementation plan establish a budget that includes direct PM as part of a PM 2.5 maintenance strategy ? on the fact that Onroad mobile source PM 2.5 constitutes less than two and a half pe rcent of the area’s total PM 2.5 emissions in the 2015 and 2022 horizon years due to continuing fleet turnover even with future VMT growth included in the emission projections.

Sec. 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? Yes. The submitted Redesignation Request and Maintenance Plan w as endorsed and submitted as a SI P revision by the Governor ’ s designee, the Secretar y of the West Virginia D epartment of Enviro nment al Protection

. A public hearing on the SI P proposal was held on February 28, 2012

. Sec. 93.118(e)(4)(ii) Before the maintenance plan was submitted to EPA, did consultation between federal, State and local agencies occur; was full implementation plan documentation provided to EPA, and was EPA ’ s stated concerns, if any , addressed? Yes. Consultation has occurred among all required F ederal, S tate , and local agencies.

Sec. 93.118(e)(4)(iii) W ere the MVEBs clearly identified and precisely quantified? As there was a request for an insignificance finding, no MVEBs were identified in the SI P. Sec. 93.118(e)(4)(iv) Are the motor vehicle emissions, when considered together with all other emission reductions, consistent with applicable requirements for maintenance strategies ? EPA believes th at motor vehicle emissions can be declared insignificant contributors because in compar ing the mo tor vehicle emissions to the overall emissions inventory , the mo tor vehicle emissions comprise only

a small portion of the o ver PM 2.5 emissions for the nonattainment

area and are projected to continue to significantly

decline due to fleet5 turnover

.

Sec. 93.118(e)(4)(v) Is the motor vehicle emissions consistent with and clearly

related to the emissions inventory

and the control measures in the Plan? EPA believes that the motor vehicle emissions have clearly related to the emissions inventory in the SI P submittal.

Sec. 93.118(e)(4)(vi) Revisions to previously submitted maintenance plan: explain and document any changes to pre viously submitted budgets and control measures; impacts on point and area source emissions; 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 fac tors or estimates of vehicle miles traveled). There are no revisions to the maintenance plan because this is the initial redesignation request, along with the associated maintenance plan for West Virginia Portion of the Wheeling, WV

- OH Area.

Sec. 93 .118(e)(5) Did they provide and we review public comments and the State ’ s responses to those comments with the submitted control strategy

SI P? There were no comments on the

SI P related to the proposed insignificance finding request.

**IV. Conclusion**

Ba sed upon our review and evaluati on of the motor vehicle emissions contained in the Redesignation Request and Maintenance Plan for the West Virginia Portion of the Wheeling, WV

- OH 1997 PM 2.5 Nonattainment Area
, EPA finds that the SI P submittal meets the cri teria in the transportation conformity rules fo r an insignificance finding for NO x , PM 2.5 , and SO 2 contribution from motor vehicles. Weighing all the factors for an insignificance finding, particularly

the minor contribution of mobile source PM 2.5 , and SO 2 , EPA has determined that the PM 2.5 and SO 2 contribution from motor vehicles emissions to the Annual PM 2.5 pollution for the West Virginia portion of the Nonattainment Area are insignificant. With respect to transportation conformity , the larger NOx contribution of less than twelve and a half percent of the area’s total NOx emission in the 2015 and 2022 horizon years requires further justification to request an insignificant finding. 40 CFR 93.109 (f ) bases insignificance on emission percentages,6

emission trends , and the effectiveness of the pollutant in forming PM. For the Wheeling area, there is a significant emission decrease projected for the highway sector and total emissions inventory in years 2008, 2015, and 2022

. Given the relatively small contri bution of the highway emissions to the total SI P inventory , highway emissions are not likely

to contribute significantly to local PM 2.5
. Additionally , NOx reductions are significantly less effective in reducing PM concentrations than are reductions in dir ect PM and SO 2 . Consequently , NOx percent emission contribution may

be higher than direct PM and SO 2 without adversely affecting air quality

. Based on the analy sis of local historical trends and growth patterns in order to develop the long range transpor

tation plan and transportation improvement program for transportation conformity purposes, there is no reason to expect highway motor vehicle emissions growth that would lead to a violation of the PM 2.5 standard. Although vehicle miles traveled increases, NOx emissions decrease dramatically

from 4505.4 tons/year in 2002 to 665.7 tons/year in 2030. This demonstrates that highway emissions will remain insignificant in the future. Upon review of the further justification for requesting an insignificant find ing for NOx, EPA has determined that NOx contribution from motor vehicles emissions to the Annual PM 2.5 pollution for the West Virginia portion of the Nonattainment Area is insignificant

.