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

**SUB JECT**  : June 5, 2012

Technical Support Document (TSD)

- In significance Findings for the Motor Vehicle Emissions for the Redesignation Request and Maintenance Plan f or the West Virgi nia 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 Emissio ns for the Redesignation Request and Maintenance Plan for West Virginia Portion of the Wheeling, WV

- OH 1997 PM 2.5 Nonattainment Area

**THRU:** /s/

Donna Mastro
, Acting Associate Director Office of Air Program Planning (3AP 30 )

**I. Background** 

The Clean Air Act ( CAA ) requires federal actions in nonattainment and maintenance areas to “conform to” the goals of S tate Implementation P lans ( SI P ). See
, e.g., CAA section 176. This means that such actions will not cause or contribute to v iolations 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 Admini stration (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 coordinate with state air quality and tran sport ation agencies, Environmental Protection Agency (EPA), FHWA
, and FTA to demonstrate that their metropolitan transportation plans and transportation improvement programs (TIP) conform to applicable SIPs. This is ty pically determined by

showing that

es timated emissions from existing and planned highway and transit sy stems are less than or equal to the motor vehicle emissions budgets (MVEBs) contained in a SIP

. For MVEBs to be approvable, th ey must meet, at a minimum, EPA’ s adequacy criteria found at 40 CFR 93.118 (e)(4). Incertain instances, the Transportation Conformity Rule allows areas to2

forgo establishment of a MVEB where it is demonstrated that the regional motor vehicle emissions for a particular pollutant or precursor are an insignificant contri butor 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 c ont 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 SIP 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

. Specifically
, 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 SIP.

**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

. ”

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

- OH 1997 PM 2.5 Nonattainment Area (hereafter the Redesignation Request and Maintenance P lan)

. Th e SIP included a request for a finding of insignificance by EPA for motor vehicle emissions for nitrogen oxides (NOx), direc t particulate matter (PM) , and sulfur dioxide (SO 2 )

.

**II I** 

**. Evaluation**  **of the Request**  **for an Insignificance 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 By**  **T he**  **West Virginia 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 assoc iated 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 93.11 8(e)5. The evaluation is presented below.3

**Review of the Request for Insignificance Finding**  **of 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? I f 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 PM 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 total 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 ? Neither 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 ha s not been included in the SIP

. 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 emissions or does the implementation plan establish a budget that includes direct PM as part of a PM 2.5 maintenance strategy ? The State has requested that direct PM be found an insignificant contributor to the mobile PM emissions. T his request is based on the fact that Onroad mobile source PM 2.5 constitutes less than two and a half percent 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 th e emission projections.4

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 submitt ed as a SIP revision by the Governor ’ s designee, the Secretar y of the West Virginia D epartment of Environment al Protection

. A public hearing on the SIP proposal was held

. Sec. 93.118(e)(4)(ii) Before the maintenance plan was submitted to EPA, did consul tation 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.

Se c. 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 SIP. Sec. 93.118(e)(4)(iv) Are the motor vehicle emissions, when considered together w ith 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 emis sions inventory , the mo tor vehicle emissions comprise only

a small portion of the over PM 2.5 emissions for the nonattainment

area and are projected to continue to significantly

decline due to fleet turnover

. Sec. 93.118(e)(4)(v) Is the motor vehicle emiss ions 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 SIP submittal.

Sec. 93.118(e)(4)(vi) Revision s to previously N/A5 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 established safety

margins (see Sec. 93.101 for definition); and r easons for the changes (including the basis for any

changes related to emission factors or estimates of vehicle miles traveled). This is a new NAAQS that the area was designated as nonattainment for and this is the initial control strategy

SI P submitt ed by

the state to address the new NAAQS

.

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 propose d insignificance finding request.

**IV**

**. Findings** 
Based 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 Nonattainme nt Area
, EPA finds that the SI P submittal meets the criteria 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, particularl y 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 re spect 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, 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 2 008, 2015, and 2022

. Given the relatively small contribution 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 i n reducing PM concentrations than are reductions in direct 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 transportation plan and transportation improvement program for transportation conformity purposes, there is no reason to expect highway motor vehicle emissions growth that would lead6

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 finding 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

.