SUBJECT: 

FROM: 

TO: 

THRU: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Technical Support Document (TSD)- Insignificance Findings for the Motor 

Vehicle Emissions for the Redesignation Request and Maintenance Plan for the 

West Virginia Portion of the Huntington-Ashland, WV-KY-OH 1997 Fine 

Particulate Matter (PM2.s) Nonattainment Area 

111 ~ rh~ ll.. 

Environmental 

Gregory Becoat 

Scientist (3AP30) 

~ 

Administrative Record for the Insignificance Findings for the Motor Vehicle 

Emissions for the Redesignation Request and Maintenance Plan for West Virginia 

Portion ofthe Huntington-Ashland, WV-KY-OH 1997 PM2.5 Nonattainment Area 

Donna Mastro, Acting Associate Director ~ "1\,l\ av'\J (\o~\td.. Office of Air Program Planning (3AP30) 

I. Background 

The Clean Air Act (CAA) requires federal actions in nonattainment and maintenance areas to 

"conform to" the goals of State Implementation Plans (SIP). See, e.g., CAA section 176. 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 coordinate with state air 

quality and tr~~tion agencies, Environmental Protection Agency (EPA), FHW A, and FTA 

to demonstrate that their metropolitan transportation plans and transportation improvement 

programs (TIP) conform to applicable SIPs. This is typically determined by showing that 

estimated emissions from existing and planned highway and transit systems are less than or equal 

. to the motor vehicle emissions budgets (MVEBs) contained in a SIP. ~ 

For MVEBs to be approvable, they must meet, at a minimum, EPA's adequacy criteria found at 

40 CFR 93.118(e)(4). In certain instances, the Transportation Conformity Rule allows areas to 
forgo establishment of a MVEB where it is demonstrated that the regional motor vehiclt:? 

emissions 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(£). Insignificance determinations are based on a number of factors, including the 

percentage of motor vehicle emissions in context of the total SIP inventory; the current state of 

air quality as determined by monitoring 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 XXIII.B. entitled, "Areas With 

Insignificant 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. 

II. Administrative Requirements for Making Insignificance Findings 

EPA has followed the process for reviewing the submitted SIP 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 part 

93.1 02(b) - "Geographical applicability" and 40 CFR part 93 .118(f) - "Adequacy review process 

for implementation plan submissions." 

On June 30, 2011, the State of West Virginia formally submitted a Redesignation Request and 

Maintenance Plan for West Virginia Portion ofthe Huntington-Ashland, WV-KY-OH 1997 

PM2.s Nonattainment Area (hereafter the Redesignation Request and Maintenance Plan); The 

SIP included a request for a finding of insignificance by EPA for motor vehicle emissions for 

nitrogen oxides (NOx), direct particulate matter (PM), and sulfur dioxide (S02). 

III. Evaluation of the Request for an Insignificance Finding for Motor Vehicle Emissions 

in the Redesignation Request and Maintenance Plan for the West Virginia Portion of the 

Huntington-Ashland, WV-KY-OH 1997 PM2.s Nonattainment Area Submitted By The 

West Virginia Department of Environmental Protection 

In this 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 part 93.1 02(b )(2)(iv), 

93.102(b)(2)(v), 93.102(b)(3), and part 93.118(e)4 through 93.118(e)5. The evaluation is 

presented below. 

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Review of the Request for Insignificance Finding of Motor Vehicle Emissions in the 

Redesignation Request and Maintenance Plan for the West Virginia Portion of the 

Huntington-Ashland, WV-KY-OH FPM2.5 Nonattainment Area 

Transportation Conformity Rule Review Criteria Was the Criterion Satisfied? If 

40 CFR Part 93, 93.118 Yes, How was this Criteria 

Satisfied? 

93.1 02(b )(2)(iv) Has the EPA and the State The State has requested that NOx 

made a finding that NOx is be found an insignificant 

an insignificant contributor contributor to the mobile PM 

to the direct mobile PM emissions. This request is based 

emissions or does the on the fact that Onroad mobile 

implementation plan fail to source NOx constitutes six 

establish a NOx budget as percent or less of the area's total 

part ofthe PM 2.5 NOx emission in the 2015 and 

maintenance strategy? 2022 horizon years due to 

continuing fleet turnover even 

with future vehicle miles traveled 

(VMT) growth included in the 

emission projections. In addition, 

the area attained the standard in 

2009 based on three years of 

monitored data. 

93.1 02(b )(2)(v) Has the EPA or State made a Neither EPA nor the State have 

finding that Volatile Organic made any findings that VOC's, 

Compounds (VOCs), Sulfur S02, or NH(3) are a significant 

Dioxide (S02) or Ammonia contributor to the PM2.5 mobile 

~H(3)) as precursors to be a emissions, and therefore, it has 

significant contributor to the not been included in the SIP. 

mobile PM emissions or does Onroad mobile source S02 

the implementation plan constitutes less than 0.1% of the 

submission establish a area's total so2 emissions in the 

budget for VOCs, SOx or 2015 and 2022 horizon years. 

NH(3) as part of a PM 2.5 

maintenance strategy? 

93.102(b)(3) Has the EPA or the State The State has requested that direct 

made a finding that direct PM be found an insignificant 

PM is a significant contributor to the mobile PM 

contributor to the PM mobile emissions. This request is based 

emissions or does the on the fact that Onroad mobile 

implementation plan source PM2.s constitutes less than 

establish a budget that three percent of the area's total 

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includes direct PM as part of PM2.s emissions in the 2015 and 

a PM z.s maintenance 2022 horizon years due to 

strategy? continuing fleet turnover even 

with future VMT growth included 

in the emission projections. In 

addition, the area attained the 

standard in 2009 based on three 

years of monitored data. 

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

plan endorsed by the Redesignation Request and 

Governor (or his or her Maintenance Plan was endorsed 

designee) and subject to a and submitted as a SIP revision by 

State public hearing? the Governor's design_ee, the 

Secretary of the West Virginia 

Department of Environmental 

Protection. A public hearing on . 

the SIP proposal was held. 

Sec. 93.118( e)( 4)(ii) Before the maintenance plan Yes, Consultation has occurred 

was submitted to EPA, did among all required Federal, State, 

consultation between federal, and local agencies. 

State and 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 MVEBs clearly As there was a request for an 

identified and precisely insignificance finding, no MVEBs 

quantified? were identified in the SIP. 

Sec. 93.118(e)(4)(iv) Are the motor vehicle EPA believes that motor vehicle 

emissions, when considered emissions can be declared 

together with all other insignificant contributors because 

emission reductions, in comparing the motor vehicle 

consistent with applicable emissions to the overall emissions 

requirements for inventory, the motor vehicle 

maintenance strategies? emissions comprise only a small 

portion of the over PMz.s 

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 EPA believes that the motor 

emissions consistent with vehicle emissions have clearly 

and clearly related to the related to the emissions inventory 

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emissions inventory and the in the SIP submittal. 

control measures in the Plan? 

Sec. 93.118(e)(4)(vi) Revisions to previously N/A 

submitted maintenance plan: This is a new NAAQS that the 

explain and document any area was designated as 

changes to previously nonattainment for and this is the 

submitted budgets and initial control strategy SIP 

control measures; impacts on submitted by the state to address 

point and area source the new NAAQS. 

emissions; any changes to 

established safety margins 

(see Sec. 93.101 for 

definition); and reasons for 

I the changes (including the 

basis for any changes related 

I to emission factors or 

estimates of vehicle miles 

traveled). 

Sec. 93.118(e)(5) Did they provide and we There were no comments on the 

review public comments and SIP related to the proposed 

the State's responses to those insignificance finding request. 

comments with the submitted 

control strategy SIP? 

IV. Findings 

Based upon our review and evaluation of the motor vehicle emissions contained in the 

Redesignation Request and Maintenance Plan for the West Virginia Portion of the Huntington-

. Ashland, WV-KY-OH 1997 PM2.5 Nonattainment Area, EPA finds that the SIP submittal meets 

the criteria in the transportation conformity rules for an insignificance finding for NOx, PM2.s, 

and S02 contribution from motor vehicles. Weighing all the factors for an insignificance finding, 

particularly the minor contributio"n of mobile source NOx, PM2.s, and S02, EPA has determined 

that the NOx, PM2.s, and S02 contribution from motor vehicles emissions to the Annual PM2.s 

pollution for the West Virginia portion of the Nonattainment Area are insignificant. 

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