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

**DATE:**
**SUBJECT:** Technical Support Document for the Update of the Motor Vehicle Emissions

Budgets and General Conformity Budgets for the Scranton/Wilkes

- Barre 1997 8

- Hour Ozone National Ambient Air Quality Standard Maintenance Area
**FROM:** Asrah Khadr, Environmental Engineer, EIT

Office of Air Program Planning
**TO:** File
**THRU:** Cristina Fernandez , Associate Director

Office of Air Program Planning

**A. BACKGROUND** On May 28 , 2014, the Pennsylvania Department of Environmental Protection (PADEP) submitted revision s to the Commonwealth of Pennsylvania’s (Penns yl vania) State Implementation Plan (SIP). The SIP revision s consists of updated motor vehicle emissions b udgets (MVEBs) for nitrogen oxides (NO x ) for the 1997 8

- Hour Ozone National Ambient Air Quality Standard (NAAQS) as well as a NO x general conformity budget for the construction of the Bell Bend Nuclear Power Plant. The upd ated budgets were calculated using the Environmental Protection Agency ’s (EPA) Motor Vehicle Emission Simulator model (MOVES2010a). The intention of the revised SIP is to replace the approved MOBILE6.2

- based MVEBs with budgets based on MOVES2010a and to e nsure that the SIP revision s still provide for attainment of the 1997 8

- Hour Ozone NAAQS. On July 18, 1997 (62 FR 38856), EPA established the 1997 8

- Hour Ozone NAAQS. On April 30, 2004 (69 FR 23858), Lackawanna, Luzerne, Wyoming , and Monroe Counties were designated as nonattainment for the 1997 8

- Hour Ozone NAAQS as the Scranton/Wilkes

- Barre 1997 8

- Hour Ozone NA AQS Nonattainment Area. On June 12 , 2007, PADEP submitted a SIP revision which consists of a maintenance plan, a 2002 base year inventory , an d MVEBs for transportation conformity purposes. On November 19, 2007 (72 FR 64948 ), EPA approved the SIP revision as well as the redesignation request made by PADEP. At that time, the Scranton/Wilkes

- B arre 1997 8

- Hour Ozone NAAQS Nonattainment Area w as r edesignated as the Scranton/Wilkes

- Barre 1997 8

- Hour Ozone N AAQS Maintenance Area (Scranton/Wilkes

Barre Maintenance Area).2

The MVEBs are a mobile source inventory to which an area’s transportation improvement program (TIP) and long range transportation plan must conform. Conformity to MVEBs in a SIP means that transportation activities will not produce new air quality violations, worsen existing violations, or delay

timely attainment of the NAAQS or any required interim milestones. This submittal prov ides updated MVEBs for NO x . The budgets were developed utilizing MOVES2010a. On March 2, 2010 (75 FR 9411), EPA published a notice of availability for the MOVES2010 model for use in SIP submissions and started a two y ear grace period for the use of MOVES 2010 for transportation conformity purposes. The two year grace period was scheduled to end on March 2, 2012. On February 27, 2012 (77 FR 11394), EPA published a final rule extending the grace period another ye ar to March 2, 2013 to ensure adequate time for affected parties to adopt the model. On September 8, 2010, EPA released MOVES2010a, which is a minor update to MOVES2010. Pennsylvania utilized MOVES2010a in its May 28, 2014 SI P revision. MOVES2010a was used in order to ensure that the nonattainment area can demonstrate transportation conformity using MOVES2010a once the 3

- ye ar conformity grace period expires. Pennsylvania updated their SIP

- approved MVEBs with the use of MOVES2010a. The budgets were previousl y developed with the use of the Highway Mobile Source Emission Factor Model (MOBILE6.2).
MOBILE6.2 is a motor vehicle emissions factor model that was utilized for SIPs and transportation conformity . MOBILE6.2 was made available for use in SIPs and transportation conformity

purposes on May 19, 2004 (69 FR 28830). MOBILE6.2 was merel y an update to MOBILE6 that added the ability for the program to estimate direct exhaust and brake and tire wear particulate matter emission factors as well as exhaust emission factors for particulate matter prec ursors. MOVES2010 improves upon MOBILE6.2 in many aspects. MOVES2010 utilizes a plethora of vehicle data that has been made available since the release of MOBILE6.2; this vehicle data includes emissions data for different kinds of vehicles. The new data has allo wed EPA to better understand on

- road mobile source emissions and their contribution to emissions inventories as well as how effective different control strategies are. The MOVES2010 model offers more flexibility because the program has a database design that allows easier organization of input and output files and data. The database design of the MOVES2010 model allows much easier update of input data upon the release of new data. MOVES2010 also accounts for temperature and speed variations and allows th e model to run at a higher resolution which allows for the input of more activity

data. Under section 176(c) of the Clean Air Act (CAA), any federal action is required to conform to the applicable SIP. A part of this requirement for conformity is transp ortation conformity

. Transportation conformity requires that an y federally funded transportation plan, program or project conform to the applicable SIP for the transportation

- related criteria pollutants (ozone, carbon monoxide, fine particulate matter (PM 2.5 ), coarse particulate matter (PM 10 ), and nitrogen dioxide). The transportation conformity rules can be found at 40 CFR 93, Subpart A. One of the requirements found under 40 CFR 93, Subpart A is that any transportation plan, TIP or project not in a con forming TIP must conform to the MVEBs in the applicable SIP. In order for the MVEBs in a SIP to be used to determine conformity of a transportation plan, TIP or project, the MVEBs must be either approved or deemed adequate. In this case, the budgets must be3

approved because these SIP revisions are revising already approved budgets. However, in reviewing such a submitted SIP it remains useful to apply the criteria used to make an adequacy finding. The requirements for adequacy are set forth in 40 CFR 93. 118(e)(4)(i)

- (vi). The criteria for adequacy

and how they

are met by

the Pennsylvania submittal are found below in Tab le 1.

**Table 1. Adequacy Criteria fo**  **r the Scranton/Wilkes/Barre Maintenance Area**

**Criterion Submittal**  (i) The submitted control strategy implementation plan revision or maintenance plan was endorsed by the Governor (or his or her designee) and was subject to a State public hearing;  Letter addressed to Shawn M. Garvin, Regional Administrator, EPA Region III from E. Christopher Abruz zo, Secretary, Pennsylvania DEP

.  Public hearing documents were submitted

. (ii) Before the control strategy implementation plan or maintenance plan was submitted to EPA, 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;  Not applicable (N/A ) , these revision s do not accompany a control strategy implementation plan or maintenance plan

. (iii) The motor vehicle emissions budget(s) is clearly identified and precisely quantified;  Appendix C

- 2 of the submittal provides detailed emission summary tables

. (iv) The motor vehicle emissions budget(s), when considered together with all other emissions sources, is consistent with applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given implementation plan submission);  Maintenance plan was already approved on November 19, 2007 (72 FR 64948 ) , no changes to nonroad emissions, point and area source emissions were updated

.  Scranton/Wilkes

- Barre Maintenance Area continues to attain the 1997 Ozone NAAQS as shown by the design value obtain ed from 2010

- 2012 data

.  Update of point and area source emissions still sho ws that maintenance of the 1997 Ozone NAAQS will be continued

. (v) The motor vehicle emissions budget(s) is consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan revision or maintenance plan; and  The SIP revision s show no change in any control measures in the previously submitted maintenance plan. (vi) Revisions to previously submitted control strategy implementation plans or 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 (see § 93.101 for definition); and reasons for the changes  Changes in MVEBs are clearly documented and explained in the submittal. The higher emissions are due to the use of MOVES2010a which is a more accurate emissions model and is based on more recent4

(including the basis for any changes related to emission factors or estimates of vehicle miles traveled). data on vehicle emissions than MOBILE6.2 . Update of point source emissions and addition of small safety margin are well explained.

**B. STATE SUBMITTAL** On May 28 , 2014, PADEP submitted a SIP revision which included an update to the MVEBs for NO x for the years 2009 (interim y ear) and 2018 (maintenance y ear). The updated MVEBs were produced using the MOVES2010a model. The MVEBs were developed with guidance from the following EPA guidance documents: Policy Guidance on the Use of MOVES2010 for SIP Development, Transportation Conformity, and Other Purposes and Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. The submittal also included an update to the point so urce emissions inventory

. **I. Methodology for Developing Data for Use in MOVES2010a** PADEP utilized MOVES2010a to provide emissions rates for emissions of NO x . PPSUI TE is a program that was utilized for the processing of highway information and to prov ide input files that are usable b y the MOVES2010a model. PPSUITE was run utilizing CENTRAL ; CENTRALis a program that provides a process for the proper function of PPSUI TE and MOVES2010a. The M VEBs were developed for NO x since NO x is a precursor of ozone . The MVEBs for volatile organic compounds ( VOCs ) were not updated in these SIP revision s
. In PPSUITE, the Penns yl vania Department of Transportation (PennDOT) Roadway Management Sy stem (RMS) data among other data was utilized to produce vehicle miles tr aveled (VMT) estimates. The VMT produced via PPSUI TE was then imported into the county data manager (CDM) in MOVES2010a. Since VOCs and NOx emissions differ with respect to travel speed, travel speed is utilized as an input in MOVES2010a. To develop an a rray of travel speeds, PPSUI TE was utilized to develop vehicle hours of travel (VHT) by speed bin file which allows for the distribution of speeds across links into MOVES2010a speed bins. The travel speed calculations were completed with guidance from Tec hnical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity

. Road ty pe distribution was another traffic input for MOVES2010a. Road ty pe distribution was developed with the use of PPSUI TE. The five different road t ypes utilized by MOVES2010a are off network, rural restricted access, rural unrestricted access, urban restricted access and urban unrestricted access. In addition, ramps are not included in road type distribution so it is assumed that 8% of the roadway

VHT is ramp VHT. This traffic input assumption is consistent with EPA’s technical guidance. Before RMS data is utilized by PPSUITE to develop various traffic inputs, several adjustments must be made. The RMS VMT is adjusted to meet the Highway Performance Monitoring5

Sy stem (HPMS) VMT totals. HPMS VMT utilizes snapshots of RMS VMT to satisfy rep orting requirements established by the Federal Highway

Administration (FHWA). To make this adjustment, adjustment factors were calculated and utilized. Adjustments to average annual daily traffic (AADT) were completed because calculations for ozone prec ursors are based on a summer weekday, since that is when ozone formation tends to be the greatest. The RMS AADT volumes are adjusted by the use of a seasonal factor that was developed b y PennDOT’s Bureau of Planning and Research (BPR) to produce July traf fic volumes. The RMS data was also adjusted for differences in hourl y traffic volumes. The 24

- hour pattern data provided to PPSUI TE allowed PPSUI TE to provide roadway segment volumes by the hour. The 24

- hour pattern data was obtained from PennDOT’s PBR. Traffic volume forecasts had to be applied to estimate future emissions from vehicles. The growth rates utilized for these forecasts are the PennDOT PBR growth rate forecasting s ys tem, the regional travel model and an y applicable Marcellus Shale relate d activity growth. Additionally , count y specific growth rates were utilized from a 2005 PennDOT report titled Statistical Evaluation of Projected Traffic Growth, Traffic Growth Forecasting System: Final Report, March 14, 2005

. MOVES2010a utilizes 13 ve hicle source t ypes. Since HPMS utilizes different categories for vehicle t ypes, the RMS traffic volumes were disaggregated to the 13 vehicle source t yp es which were then combined into the 6 HPMS vehicle classes. Vehicle type data input into PPSUI TE is us ed to divide the roadway segment volumes with respect to the MOVES2010a source t yp es. The source t yp es are split into percentages among the 24

- hours of the day . The vehicle source ty pe percentages are then utilized to adjust vehicle speeds in response to trucks. Vehicle population is also another important input for MOVES2010a. Vehicle population is input into MOVES2010a with respect to the 13 vehicle source typ es utilized by the model. County level vehicle registration data is utilized for light duty vehicles and school buses. Transit bus data is obtained from PennDOT’s National Transit Database (NTD); it is utilized to estimate county level transit bus counts. Heavy dut y vehicle population data is estimated by utilizing source t ype VMT and vehicle so urce and pattern data are utilized. Vehicle age is input into the model as well. The vehicle age is input into the model as a percentage of vehicles of the fleet between ages 0 and 31. Outside of vehicle and roadway data, environmental variables are utilized as inputs since evaporative emissions are dependent on the surrounding temperatures. The environmental variables used included hourly temperatures and humidity values. The temperatures were retrieved b y Weather Bank, Inc. Humidity values were pro duced according to EPA’s technical guidance. Minimum and maximum monthly temperatures were converted to hourly temperatures using EPA converters in the MOVES2010a model. Fuel parameters were also input since different fuels produce different emissions. The MOVES2010a default fuel formulation and supply data was utilized and updated with local volumetric fuel propert y data. Gasohol market penetration and RVP values were updated at the county level.6

Refueling emissions were not included as an input be cause Penns yl vania provides the refueling emissions in its area source inventory ; hence it is not required for the production of MVEBs. Additionally , MOVES2010a also includes input parameters for inspection and maintenance (I/M) programs. The inputs for the I/M program include: program start y ear, stringency level, first and last model y ears subject to the program, waiver rates, compliance rates, program ty pe and effectiveness, frequency of inspection, vehicle ty

pe coverage and test ty

pe. The defaults fo r an I/M program in MOVES2010a were modified to accuratel y represent the I/M program for each county

. **II. Running MOVES2010a** As stated in Section I , the data utilized to run MOVES2010a is a mixture of local and national data. Local data is utilized f or all inputs that have significant impact on the emissions rates that are calculated b y M OVES2010a. The local data utilized as inputs for MOVES2010a is categorized into five categories which include: traffic data, vehicle descriptions, fuel parameters, I/M programs, and environmental variables. The inputs for traffic data include vehicle t ype VMT, vehicle population, VMT fractions, road t ype distribution, and ramp fractions. The inputs for vehicle descriptions include vehicle typ e mix, vehicle age distribution, average speeds and hourly distributions of different vehicles. The inputs for fuel parameters include RVP, sulfur level and ethanol volume. The inputs for I/M programs include start and model years, the frequency of tests, test standards, source ty pes, stringency

of tests, the waiver rate, and compliance rates. The inputs for environmental variables include hourly temperatures and humidity

. MOVES2010a inputs that were prepared b y PPSUITE included vehicle type VMT, vehicle population, VMT frac tions, average speed distributions, road ty pe distribution and ramp fractions. These files were input into the MOVES2010a county data importer. Additional non

PPSUI TE inputs included fuel and vehicle ages, as well as temperatures and I/M programs. The c ounty data importer was run in batch mode. Running the count y data importer converts input files into a MYSQLformat which is accepted by MOVES2010a. Afterwards, a MOVES run specification file (.mrs) was created. This file includes options and different data locations for the execution of the model. MOVES2010a can be executed to provide an emissions rate or an emissions inventory . In this submittal, MOVES2010a was executed to provide an emissions inventory . The emissions estimates of NO x produced for the years 2004, 2009 and 2018 by MOVES2010a are provided in tons per summer day (tpsd) in Table 2. Summary of Motor Vehicle Emissions in tp s d ; also provided in Table 2 is the comparison between the emissions produced b y MOBILE6.2 and MOVES2010a. No new emissions estimates were produced for VOCs therefore their inclusion into the MOVES estimates portion in the table below is not applicable (N/A). After reviewing this submittal, EPA concurs with Pennsylvania that even though the emissions results produced by MOVES2010a are greater than those previousl y calculated using MOBILE6.2. EPA’s review of the SIP revision s indicate these higher emissions result from improvements in the MOVES model rather than from unanticipated growth or changes in control measures . The MOVES results are more accurate estimates of the emissions that actually

occurred in 2004 and 2009, rather than an indication that emissions are increasing.7

More importantly , the Scranton/Wilkes

- Barre Maintenance Area attained the 1997 8

- Hour Ozone NAAQS and was redesignated to a maintenance area o n November 19, 2007 (72 FR 64948 ). The Scranton/Wilkes

- Barre Maintenance Area continues to attain the 1997 8

- Hour Ozone NAAQS as shown by its 2010

- 2012 design values. The highest monitored 2010

- 20 12 desi gn value for the Scranton/Wilkes

- Barre Maintenance Area is 72 parts per billion (ppb). After reviewing this submittal , EPA finds this update to the MVEBs does not interfere with the Scranton/Wilkes

- Barre Maintenance Area’s ability to maintain its attainme nt of the1997 8

- Hour Ozone NAAQS.

**Table 2 . Summary of Motor Vehicle Emissions**  **in tpsd for the**  **Scranton/Wilkes**
**- Barre Maintenance Area**  Model MOBILE6.2 MOVES2010a Year 2004 2009 2018 2004 2009 2018 VOCs 31.6 23.3 14.3 N/A N/A N/A NO x 66.1 46.9 21.6 77.0 57.3 28.5

**III. Review of MOVES Modeling** To run the MOVES2010 a 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 MOVES2010 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 anal ys is of emissions for transportation confor mity determinations. MVEBs were submitted for the ye ars 2009 and 2018 for the 1997 Ozone NAAQS which are consistent with the rest of the emissions inventory i n the maintenance plan. The submitted 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 MOVES2010 for Emission I

nventory Preparation in State Im plem entation Plans and Transportation Conformity

. Table 3 presents the RunSpec parameters that were reviewed and each parameter ’s respective component in the submittal.
**Table 3. RunSpec Reviews for the 1997 Ozone NAAQS f**  **o r Years 2009 and 2018 for**  **Lackawann a**  **, Luzerne, Wyoming, and Monroe**  **Counties** Domain/Scale Co unty scale was selected. Selection of county scale is acceptable for this air quality

anal ys is. Calculation Ty

pe Inventory

was selected which is acceptable for this anal ys is. Time Aggregation Level Hourly time aggregation was selected. Selection of hourly time aggregation level is acceptable for this anal ys is. Calendar Year Of Evaluation The appropriate calendar year was selected for each RunSpec; each RunSpec has 2009 or 2018 as the selected calendar year. MOVES2010a can model years 1990 and 1999

- 2050.8

Month of Evaluation July was selected to be the month of evaluation

. This is acceptable for ozone precursor analy sis. Ty pe of Day of Evaluation Wee kday s were selected, which is appropriate for the evaluation of pollutant emissions related to ozone. Hours of Evaluation Starting and ending hours create a whole day (from 0

- 24 hours). Geographic Bounds The appropriate count y was selected for each RunSpe c. The four counties modeled were Lack awanna, Luzerne, Monroe, and Wyoming Counties. Vehicles/Equipment: On

Road Vehicle Equipment Appropriate combinations of fuels and source use ty pes were made. Road Ty pe Selection included all necessary road t ype s. Pollutants and Processes NO x , total gaseous h ydrocarbons, non

- methane hydrocarbons, and VOCs were selected. On

- Road Retrofits N/A ROP N/A Output Database/Unit Selection Mass units selected to be grams; energy units selected to be million British Thermal Unit (BTU) ; distance units selected to be miles. Output Emission Detail in Emission Rate Calculations Emission detail was selected via user preference . The output emissions detail does not affect the results of the modeling runs, therefo re user preference is acceptable. Advanced Performance Features N/A

**IV. Safety Margins, Allotment of MVEBs for each Planning Organization**  **, and General Conformity Budget for the Construction of the Bell Bend Nuclear Power Plant**  Since there is a significant difference between the projected emissions for the maintenance year and the attainment year a small portion of that difference was made into a safet y margin. In other terms, the emissions for the attainment ye ar are much great er than the emissions for the interim (2009) and maintenance (2018) ye ars, which allows for a portion of those excess emissions to become a safety margin. A two tp s d safet y margin was added for NO x emissions for the 2009 and 2018 MVEBs. The MVEBs are pre sented below in Table 4

. The differences between the 2004 attainment year and the 2009 interim year and 2018 maintenance y ear for NO x are found below in Table 5. NOx Emissions and Di fferences for Years 2004, 2009, and 2018 in tp s d . Table 5 presents decreases in emissions which are significant in some categories between the attainment, interim and maintenance ye ars. Because the 2009 and 2018 emissions are less than the 2004 attainment year emissions, a small portion of the excess emissions can be allocated to safet y margins while the area can continue to attain the 1997 8

- Hour Ozone NAAQS. Additionally , there are three metropolitan planning organizat ions (MPOs) and one regional planning organization (RPO) that serve the four counties that comprise the Scranton/Wilkes

Barre Maintenanc e Area. To simpl if y the transportation conformity process for these MPOs, separate budgets will be given to each MPO. Table 6. MVEBs for Each MPO presents how the MVEBs will be allotted to each MPO.9

A nuclear power plant will be constructed and will be known as the Bell Bend Nuclear Power Plant. Building this nuclear power plant will cause a significant amount of NO x emissions because of all of the nonroad equipment used for construction. These s ignificant NO x emissions will trigger the general conformity requirements of 40 CFR 93(B). The de minimus NO x threshold would be exceeded by the projected NO x emissions of this project; therefore this project is subject to the requirements of general conf ormity . The maximum emissions are expected to occur during the second ye ar of construction; the maximum emissions are expected to be 167.7 tons per year (tpy) of NO x . The de minimus VOC emission threshold will not be exceeded b y this project because the maximum VOC emissions that are expected to occur are 14.3 tpy which is much less than the de mi nimus emissions of 50 tpy . These SIP revision s include a general conformity budget for NOx

. The general conformity budget is set for 1.0 tp s d. This 1.0 tp s d b udget is factored into all of the inventory totals found in Table 5. With the addition of MVEBs, safety margins, and the general conformit y budget the total emissions for 2009 and 2018 are significantly less than the attainment y ear emissions.

**Table 5. NO x**  **Emissions and Differences for Years 2004, 2009 , and**  **2018 in tp s**  **d for the Scranton/Wilkes/Barre Maintenance Area**  Category 2004 2009 2004

- 2009 2018 2004

- 2018 Point 7.0 7.7 0.7 5.8

- 1.2 Area 4.0 4.2 0.2 7.5 3.5 Nonroad 10 .9 8.9

- 2.0 5 .6

- 5.3 Mobile 77.0 59.3

- 17.7 30.6

- 46.4 Total 98.9 81.1 *

- 17.8 * 50.5 *

- 48.4 * *Totals include the 1.0 tp s d general conformit y budget for the construction of the Bell Bend Nuclear Power Plant

**Table 6 . MVEBs for Each MPO**  **in tp s**  **d fo**  **r the Scranton/Wilkes/Barre Maintenance Area** 
MPO Scranton/Wilkes

- Barre

MPO NEPA MPO Northern Tier RPO Year 2009 2018 2009 2018 2009 2018 VOCs 17.99 11.80 6.19 4.64 0.99 0.54 NOx 42.67 21.90 14.10 7.10 2.50 1.60 **Table 4. Rev**  **ised MVEBs in tp**  **s d**  **for the Scranton/Wilkes/Barre**  **Maintenance Area** Year 2009 2018 VOCs N/A N/A NO x 59.3 30.510

**C . EPA EVALUATION AND CONCLUSION**  EPA thoroughl y evaluated the submittal made by Pennsylvania through PADEP. EPA’s detailed review has led us to conclude that the development methodology of the MVEBs is consistent with applicable guidance documents intended to guide the development of on

- road inventories and MVEBs. EPA also reviewed the MVEBs using the adequacy criteria set forth in 40 CFR 93.118(e)(4)(i)

- (vi), and as documented above we found that the budgets meet all of the adequacy criteria. EPA also reviewed the general conformity budget that will be utilized for the construction of the Bell Bend Nuclear Power Plant and found it to be consistent with continued attainment of the 1997 Ozone NAAQS. Based on the results of EPA’s in depth review of the SIP revision s , the Scranton/Wilkes Barre Maintenance Area’s continued atta inment of the 1997 8

- Hour Ozone NAAQS and the results of EPA’s review of the MVEBs using the adequacy criteria in the transportation conformity rule, EPA is proposing to approve the se SIP revision s
.