SUBJECT: 

FROM: 

TO: 

THRU: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Technical Support Document (TSD)- Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the Maintenance Plans for the Delaware Portion of the 

Philadelphia-Wilmington PA-NJ-DE 1997 and 2006 Fine Particulate (PM2.5) 

National Ambient Air Quality Standards (NAAQS) Noriattainment Area 

Asrah Khadr, Environmental Engineer, EIT ;'/ /J 1 / fA ,.J} o // ..:r8 /11 

Office of Air Program Planning (3AP30) · P ~ 

Administrative Record for the Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the Maintenance Plan for the Delaware Portion of the 

Philadelphia-Wilmington PA-NJ-DE 1997 and 2006 PM2.5 NAAQS 

N onattainment Area 

~ -r:._~ Ot l_oJ;>/ 1.1-/ 

t fisft.na Fernandez, As ociate Director 

Office of Air Program Planning (3AP30) 

I. Background 

On January 5, 2005, New Castle County was designated as nonattainment for the 1997 PM2.5 

NAAQS as the Delaware portion ofthe Philadelphia-Wilmington PA-NJ-DE 1997 PM2.5 NAAQS 

Nonattainment Area. On November 13, 2009, New Castle County was designated as 

nonattainment for the 2006 PM2.

5 NAAQS as the Delaware portion of the PhiladelphiaWilmington PA-NJ-DE 2006 PM2.5 NAAQS Nonattainment Area. The Philadelphia-Wilmington 

PA-NJ-DE 1997 and 2006 PM2.5 NAAQS Nonattainment Areas both consist of the following 

Pennsylvania, New Jersey and Delaware Counties respectively: Bucks County, Montgomery 

County, Chester County, Delaware County, Philadelphia County, Gloucester County, Burlington 

County, Camden County, and New Castle County. The air quality data submitted by the State of 

Delaware shows that Delaware attained the 1997 and 2006 PM2.5 NAAQS. On May 16, 2012 (77 

FR 28782), EPA determined the Delaware portion ofthe Philadelphia-Wilmington PA-NJ-DE 

1997 PM2.5 NAAQS Nonattainment Area had air quality data demonstrating that Delaware 

attained the 1997 PM2.5 NAAQS. On January 7, 2013 (78 FR 882), EPA determined the Delaware 

portion ofthe Philadelphia-Wilmington PA-NJ-DE 2006 PM2.5 NAAQS Nonattainment Area had 

air quality data demonstrating that Delaware attained the 2006 PM2.5 NAAQS. Additional 

background information about the Delaware Portion ofthe Philadelphia-Wilmington PA-NJ-DE 

1997 and 2006 PM2.s NAAQS Nonattainment Areas is available in the notice of proposed 

rulemaking (NPR) in this docket. On December 12, 2012, the Delaware Department ofNatural 

Resources and Environmental Control (DNREC) formally submitted State Implementation Plan 

(SIP) revisions to satisfy the redesignation requirements of the Clean Air Act (CAA) for the 1997 
and 2006 PM2.s NAAQS for the Philadelphia-Wilmington PA-NJ-DE 1997 PM2.5 NAAQS 

Nonattainment Area and the Philadelphia-Wilmington PA-NJ-DE 2006 PM2.5 NAAQS 

Nonattainment Area. On September 13,2013, DNREC submitted a formal supplement to the SIP 

revisions that were submitted on December 12, 2012, in order to clarify the modeled motor vehicle 

emiSSlOnS. 

II. Transportation Conformity Requirements 

Under section 176(c) of the CAA, new transportation plans, programs, and 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 the SIP. This means that such 

actions will not cause or contribute to violations ofNAAQS; worsen the severity of an existing 

violation; or delay timely attainment of any NAAQS or any interim milestone. 

For motor 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 

subject to a State public hearing; (2) consultation among Federal, State, and local agencies 

occurred; full implementation plan documentation 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 emissions sources, are consistent with applicable requirements for 

maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and 

the coptrol 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 estimates of vehicle miles traveled). 

III. Review of the 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 were 

reviewed against the following EPA document: Technical Guidance on the use of MOVES201 0 for 

Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. 

This guidance document provides guidance on the use of the MOVES model to develop 

inventories for SIPs as well as analysis of emissions for transportation conformity determinations. 

DNREC submitted MVEBs for the years 2017 and 2025 for the 1997 and 2006 PM2.s NAAQS. 

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 MOVES201 0 for 

Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. 

Table 1 presents the RunSpec parameters that were reviewed and each parameter's respective 

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component in DNREC's submittal. 

Table 1. RunSpec Reviews for the 1997 and 2006 PM2.5 NAAQS for Years 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 of hourly 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. 

Month ofEvaluation All 12 months were selected for evaluation. 

Type of Day of Weekdays and weekends were selected. 

Evaluation 

Hours of Evaluation Starting and ending hours create a whole day (from 0-24 hours). 

Geographic Bounds New Castle County was selected. 

Vehicles/Equipment: On- Appropriate combinations of fuels and source use types were made. 

Road Vehicle Equipment 

Road Type Selection included all necessary road types. 

Pollutants and Processes Nitrogen oxides (NOx), sulfur dioxide (S02), and all forms of 

primary PM2.5 were selected, which is acceptable for this analysis. 

On-Road Retrofits NIA 

ROP NIA 

Output Database/Unit Mass units selected to be grams; energy units selected to be million 

Selection British Thermal Units (BTU); distance units selected to be miles. 

Output Emission Detail in Emission detail was selected via user preference. 

Emission Rate 

Calculations 

Advanced Performance NIA 

Features 

IV. Administrative Requirements for Making Adequacy Findings 

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 

CFR part 93, 118(f) "Adequacy review process for implementation plan submissions." EPA will 

be issuing an NPR for a 30-day public comment period soliciting public comment for the 

approvability of Delaware's SIP submission. The NPR also proposes approval of the MVEBs for 

milestone year 2017 and the out-year 2025 for New Castle County for PM2.5 and NOx. The 

MVEBs are presented below in Table 2. On December 19, 2013, a notice was posted on EPA's 

website at http://www.epa.gov/otag/stat~resources/transconf/currsips.htn1 for the purpose of 

opening EPA's 30-day public comment period on the adequacy/approvability ofthe budgets in the 

SIP revision. The notice informed the public ofthe availability of the Delaware SIP revision on its 

own website. EPA's website notice will provide a link where interested members of the public 

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could access the SIP revision. Following EPA's public comment period, responses to any 

comments received on the proposed mobile budgets will be addressed in an amendment to this 

TSD. 

Table 2. MVEBs Contained in the Maintenance Plans for the 1997 and 2006 PM2.5 

NAAQS 

Year Motor Vehicle Emissions Mobile Vehicle Emissions 

Budget for Direct PM-Tons Budget for NOx-Tons Per 

Per Year Year 

2017 199 6,273 

2025 199 6,273 

V. Evaluation of the Adequacy of the MVEBs in the Maintenance Plans for the 1997 and 

2006 PM2.s NAAQS 

In this TSD, we are evaluating the MVEBs associated with the maintenance plans contained in 

the December 12, 2012 SIP revision, for confmmity purposes. We are using the evaluation 

criteria detailed in the Transportation Conformity Rule, 40 CFR part 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 3, below. 

Table 3. Adequacy of the MVEBs Contained in the .Maintenance 'Plans for the 1997 and 

2006 PM2.s NAAQS 

Transportation Conformity Review Criteria Was the Criterion Satisfied? 

Rule If Yes How was this Criteria 

40 CFR Part 93, 93.118 Satisfied? 

93.1 02(b )(2)(iv) Have EPA and the State Neither EPA nor the State 

made a finding that NOx is has made such a finding. 

an insignificant contributor 

to the direct mobile PM 

emissions? 

93.102(b)(2)(v) Has EPA or State made a Neither EPA nor the State 

finding that VOCs, Sulfur has made such a finding. 

Oxides (SOx) or Ammonia 

(NH3) as precursors to be a 

significant contributor to the 

mobile PM2.5 emissions? 

93.1 02(b )(3) Has the EPA or the State Neither EPA nor the State 

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made a finding that re- has made such a finding. 

entrained road dust is a 

significant contributor to the 

PM mobile emissions? 

Sec. 93.118(e)(4)(i) Was the submitted revised Yes, the submitted 

plan endorsed by the maintenance plans were 

Governor (or his or her endorsed and submitted as 

designee) and subject to a SIP revisions by the 

State public hearing? Governor's designee, the 

Secretary of the DNREC, and 

a public hearing was held on 

October 23, 2012. 

Sec. 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 agenc1es. 

local agencies occur; was full 

implementation plan 

documentation provided to 

EPA, and was EPA's stated 

concerns, if any, addressed? 

Sec. 93.118(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly 

emissions budget(s) clearly identified on page 46 of the 

identified and precisely maintenance plan for the 

quantified? 1997 PM2.5 NAAQS and on 

page 51 of the maintenance 

plan for the 2006 PMz.s 

NAAQS. 

Sec. 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 in conjunction with the other 

other emission reductions, emission reductions, they 

consistent with applicable demonstrate attainment for 

requirements for attainment years 201 7 and 2025. 

demonstrations? 

Sec. 93.118(e)(4)(v) Is the motor vehicle EPA believes that the budgets 

emissions budget(s) are clearly related to the 

consistent with and clearly emissions inventory and the 

related to the emissions control measures in the SIP 

inventory and the control submittal. 

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measures in the Plan? 

Sec. 93.118(e)(4)(vi) Revisions to previously Yes, the maintenance plans 

submitted attainment provide new MVEBs for 

demonstrations: explain and years 2017 and 2025. 

document any changes to 

previously 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 factors or 

estimates of vehicle miles 

traveled). 

Sec. 93.118(e)(5) Did they provide and we Yes 

review public comments and 

the State's responses to those 

comments with the submitted 

control strategy SIP? 

VI. Findings 

Based upon our review and evaluation of the MVEBs contained in DNREC's December 12, 

2012 submittal of the maintenance plans to satisfy the requirements of the 1997 PM2.s NAAQS 

and the 2006 PM2.s NAAQS, we find the MVEBs to be adequate for conformity purposes and 

recommend that the MVEBs be SIP approved. 

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