### Motor Vehicle Emission Budgets

- - Approvability Review

Note: On November 23, 2011, EPA found the MVEBs in the Sacramento PM10 Maintenance Plan to be adequate. See 76 FR 72404. We are now using the adequacy criteria as part of our review to determine if the motor vehicle emissions budgets are approvable.

Control Strategy State Implementation Plan (SIP) Under Review : PM 10 Implementation/Maintenance Plan and Redesignation Request for Sacramento County Date of SIP Revision Receipt by EPA: 12/10/10 . Additi onal clarification letters provided by the State ( June 18, 2013 ) and the Sacramento Metropolitan Air Quality Management District ( June 2 8

, 2013 )

. Reviewer: John Ungvarsky Date: 7 / 12 / 1 3

Transportation Review Criteria Is Criterion

Satisfied?

Y/N Reference in SIP Document/Comments

Sec. 9 3.118(e)(4)(i) The plan was endorsed by the Governor (or designee) and was subject to a public hearing. Y The December 7, 2010 transmittal letter submitting the Sacramento PM 10 Plan was sent by the California Air Resources Board’s (CARB’s) Executive Officer, James Goldstene, the Governor’s designee. The notice for the Sacramento Metropolitan Air Quality Management District ( SMAQMD ) Board hearing was published in the Sacramento B ee on September 27, 2010 and sent to over 2000 e

mail addresses. The Draft Plan was made available on the District's website and was available for viewing at the District office on and after September 27, 2010.

The Board of Directors for the SMAQMD h eld a public hearing prior to considering approval of this PM 10 plan.

SMAQMD a pproved the Plan at a public hearing on October 28, 2010 and

transmitted the Board Resolution (2010

- 046) with the plan and other supporting

documentation to C ARB on November 2, 2010. CARB adopted the p lan, including a supporting PM 10 transportation conformity budget, as a revision to the

C alifornia State Implementation Plan (SIP) , at a public hearing on November 18,

2010. See CARB Resolution 10

- 37, which was included as enclosure IV in the SIP submittal package.

Sec. 93.118(e)(4)(ii) The plan was developed through consultation with federal, state and local agencies; full implementation plan documentation was provided

and EPA’s stated concerns, if any,

were addressed. Y The Plan uses information provided by the Sacramento Area Council of Governments (SACOG) and C ARB. Staff consulted with SACOG during Plan preparations because SACOG provides vehicle activity data needed for plan development, and the plan sets motor vehicle emissions budgets that SACOG will have to meet when approving future transportation plans.

The public review process also included consultation with SACOG's Regional Planning Partnership (RPP) and SACOG's Climate and Air Quality Committee. SACOG’s RPP is an advisory group with representatives from U

. S

. EPA, Federal2 Highway Administration, CalTrans, city and county transportation agencies, as well as business, environmental, and minority organizations and a ssociations. The RPP serves as the interagency consultation process to provide comments on transportation conformity budgets.

CARB and SMAQMD staff addressed questions from EPA in letters provided in

June 2013. Sec. 93.118(e)(4)(iii) The motor vehicle emission budget(s) is clearly identified and precisely quantified. Y Section 8, Transportation Conformity Budgets

, in the Plan clearly identifies the MVEBs and the information used, including references, to develop the MVEBs. Additional information provided in CARB’s June 18, 2013 letter and SMAQMD’s

June 2 8 , 2013 lette r further clarified and documented that when using the latest methodology for calculating PM 10 from paved roads, the MVEBs are adequate for

maintenance.

Sec. 93.118(e)(4)(iv) The motor vehicle emissions budget(s), when considered together with all other emission sources, is consistent with applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given pl an). Y EPA has determined that the MVEBs , when considered together with all other emission sources, are consistent with applicable requirements for maintenance of

the PM 10 N ational A mbient A ir Q uality S tandard

. The MVEBs include a safety margin which is e xplained on pages 8

- 3 and 8

- 4 of the plan. The safety margins

were included in the emissions estimates used in the maintenance demonstration. See page 6

- 2 of the plan.

CARB’s June 13, 2013 letter provide d new information regarding PM 10 emissions from paved roads and the MVEBs. EPA had requested that CARB recalculate the paved road dust emissions using the latest emission factors in EPA’s Compilation of Air Pollutant Emission Factors (AP

- 42) and growth in vehicle miles traveled

. As indic ated in the June 18 letter, the recalculation resulted in a slightly lower emissions inventory for the paved road dust category. I n their June 2 8 , 2013 letter

, SMAQMD indicated in the new information in the CARB letter d id not change

the overall MVEBs in t he Plan. SMAQMD indicated in their letter that t he slight

reduction s in emissions of 1.3 tons per day (tpd) in the 2012 inventory and 0.9 tpd in the 2022 inventory for paved roads should be used towards safety margins in

the 2012 and 2022 MVEBs. T he overal l MVEBs in the Plan were unchanged and

remain consistent with maintenance. Sec. 93.118(e)(4)(v) The plan shows a clear relationship among the emissions budget(s),

control measures and the total emissions inventory. Y Emissions inventory estimates are documented in Section 4, Emissions Inventory and appendix A of the plan, and the control measures in Section 5, Control

Measures and appendix B of the plan. The documentation in these portions of the plan clearly shows the relationship among the inventories, control measures, and

MVEBs.3 Additional information provided in CARB’s June 18, 2013 letter and SMAQMD’s

June 2 8 , 2013 letter further clarified and documented the relationship between paved road dust emissions and the MVEBs. Sec. 93.118(e)(4)(vi) Revisions to previously submitted control strategy or maintenance plans explain and document any changes to any previous 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 (including the basis for any changes to emission

factors or estimates of VMT. Y On November 23 , 2011, EPA found the MVEBs in the Sacramento PM10

Maintenance Plan to be ad equate. See 76 FR 72404.

CARB’s June 13, 2013 letter provided new information regarding PM 10 emissions from paved roads and the MVEBs. EPA had requested that CARB recalculate the paved road dust emissions using the latest emission factors in EPA’s Compila tion of Air Pollutant Emission Factors (AP

- 42) and vehicle miles traveled. As indicated in the June 18 letter, the recalculation resulted in a slightly lower emissions inventory for the paved road dust category. In their June 2 8 , 2013 letter, SMAQMD indica ted in the new information in the CARB letter did not change the overall MVEBs in the Plan. SMAQMD indicated in their letter that the slight reductions in emissions of 1.3 tons per day (tpd) in the 2012 inventory and 0.9 tpd in the 2022 inventory for paved roads should be used towards safety margins in the 2012 and 2022 MVEBs. The overall MVEBs in the Plan were unchanged and

remain consistent with maintenance. Sec. 93.118(e)(5) EPA has reviewed the State’s compilation of public comments and

response to comments that are required to be submitted with any implementation plan. Y We have reviewed the comments and responses. Only one comment letter was received by SMAQMD on the plan. Both the comment letter and SMAQMD’s response was included in the submittal package. The comment did not relate to the MVEBs and does not affect EPA’s adequacy finding. No comments were received by CARB during the State review process for the plan.