UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 6 th Avenue Seattle, Washington 98101

Technical Support Document (TSD) - Adequacy Finding s for the Motor Vehicle Emissions Budgets in the 2006 Fine Particulate Matt er (PM2.5) National Ambient Air Quality Standard (NAAQS) Maintenance Plan for t he Tacoma-Pierce County

(WA) 2006 PM2.5 Nonattainment Area
Submitted November 2014

I. Background On November 13, 2009 (74 FR 58688), the Environment al Protection Agency (EPA) published air quality area designations for the 2006 PM2.5 NAAQS. In that rulemaking action, EPA designated parts of Tacoma-Pierce County (the Area), nonattainment for the 2006 24-hour PM2.5 standard. On September 4, 2012 (77 FR 53772), EPA determined that the Area ha d clean data for the 2006 PM2.5 NAAQS based on quality-assured, quality-controlled and certified a mbient air monitoring data that showed the Area had monitored attainment based on 2009 through 2011 dat a.

II. Transportation Conformity Requirements Transportation conformity is required under section 176(c) of the Clean Air Act (CAA) to ensure that federally supported highway, transit projects, and other activities are consistent with (conform to) the purpose of the State Implementation Plan (SIP). The CAA requires federal actions in nonattainment and
maintenance areas 1 to "conform to" the goals of SIP. This means that such actions will not cause or contribute to violations of a NAAQS; worsen the sev erity of an existing violation; or delay timely attainment of any NAAQS or any interim milestone.

Actions involving Federal Highway Administration (F HWA) or Federal Transit Administration (FTA) funding or approval are subject to the Transp ortation Conformity Rule (40 CFR part 93, subpart A). Under this rule, metropolitan planning organiza tions (MPOs) in nonattainment and maintenance areas coordinate with state air quality and transportatio n agencies, EPA, FHWA, and FTA to demonstrate that their metropolitan transportation plans and transpo rtation improvement plans (TIPs) conform to applicable SIPs. This is typically determined by sh owing that estimated emissions from existing and planned highway and transit systems are less than o r equal to the MVEBs contained in a SIP.

For MVEBs to be approvable, they must meet, at a mi nimum, EPA's adequacy criteria found at 40 CFR 93.118(e)(4). EPA's adequacy criteria are: ( 1) the submitted control strategy implementation pl an was endorsed by the Governor or designee and was su bject to a State public hearing; (2) consultation among Federal

, State, and local agencies occurred; full implementa tion plan documentation was provided to EPA; and EPA's stated concerns, if any, were add ressed before the control strategy implementation plan was submitted; (3) the MVEBs are clearly ident ified and precisely quantified; (4) the MVEBs, when considered together with all other emissions source s, are consistent with applicable requirements for maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan; and (6) revisions to previousl y submitted maintenance plans explain and document an y changes to previously submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margin s;

1 The term “maintenance area” is used throughout thi s document to refer to a nonattainment area that redesignated back to attainment with an approved st ate implementation plan demonstrating continued maintenance of the NAAQS.and reasons for the changes (including the basis fo r any changes related to emission factors or estima tes

of vehicle miles traveled).

III. Review of the Submitted Modeling Utilizing the Motor Vehicle Emission Simulator (MOVES) The Washington Department of Ecology (Ecology) util ized MOVES2010b to produce MVEBs for years 2017 and 2026. To utilize the MOVES2010b model, a combination of data from the default database (version 20100410) and data from local sources were used by Ecology to develop the budgets.

The EPA released MOVES2014 on October 7, 2014 (79 F R 60343). The release indicates that MOVES2014 should be used for all SIP development mo ving forward. However, the release does
indicate that “... state and local agencies that have already complete d significant work on a SIP with a version of MOVES2010 (e.g., attainment modeling has already been completed with MOVES2010) can
continue to do so.” Because Ecology had nearly completed the developmen t of their Maintenance Plan at that point, they were not required to use MOVES2014 in the setting of these MVEBs.

EPA reviewed the modeling methodology utilized by E cology and all modeling related information to produce the MVEBs for years 2017 and 2026, provided in Appendices A through C of the Maintenance Plan. EPA found that all necessary and required mod eling procedures were followed in the production of the 2017 and 2025 MVEBs which were produced using M OVES2010b.

IV. Administrative Requirements for Making Adequacy Findings EPA followed the process for determining the adequa cy of the submitted SIP MVEBs in accordance with the procedures listed in the Conformity Regulations contained in 40 CFR part 93.118(f) "Adequacy review process for implementation plan submissions. "

A notice will be posted on EPA's web site located a t: http://www.epa.gov/otaq/stateresources/transconf/cu rrsips.htm , for the purpose of opening EPA's 30-day public comment period on the adequacy of the budgets in the Maintenance Plan for the TacomaPierce County, WA 2006 24-hour PM2

. 5 Nonattainment Area. The purpose of the notice is to inform the public of the availability of the Tacoma-Pierce Cou nty Maintenance Plan on its own website. EPA's website notice provides a link where interested mem bers of the public 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 T SD.

This TSD will be an enclosure to the letter from EP A to Ecology informing them of EPA's findings on th e MVEBs within the Tacoma-Pierce County Maintenance P lan. EPA will publish a Federal Register notice announcing the adequacy findings. The effective dat e of the adequacy findings will be 15 days after th e publication date of that notice. Once EPA has publi shed the Federal Register notice, the letter sent t o Ecology and this TSD will also be posted at the EPA website.

Shown in Table 1 are the budgets from the Tacoma-Pi erce County Maintenance Plan. Upon the effective date of EPA’s approval, the MVEBs in Table 1 for mi lestone year 2017 and the out-year 2026 for PM2.5 and NOx will be applied to all future transportatio n conformity determinations and analyses for the 20 06 24-hour PM2.5 NAAQS.

Table 1. On-Road MVEBs Contained in the Tacoma-Pierce County Maintenance Plan for the

2006 24-hour PM2.5 NAAQS (pounds per winter day)

Year PM2.5 NOx
2017 1,888 41,7902026 1,321 22,880

V. Evaluation of the Adequacy of the MVEBs in the T acoma-Pierce County Maintenance Plan for
the 2006 24-hour PM2.5 NAAQS In this TSD, we are evaluating the MVEBs associated with the Tacoma-Pierce County Maintenance Plan for conformity purposes. We are using the evaluatio n criteria detailed in the Transportation Conformity Rule part 93, specifically 40 CFR part 9 3.102(b)(2)(iv), 93.102(b)(2)(v), 93.102(b)(3), and 93.118(e)(4) through 93.118(e)(5). The evaluation i s presented in Table 2, below.

Table 2. Adequacy of the MVEBs Contained in the Tac oma-Pierce County Maintenance Plan for the 2006 24-hour PM2.5 NAAQS Transportation Conformity

Rule Section Applicability/Review Criteria Was the applicability requirement met? OR Was the Criterion Satisfied? If yes, how was this criteria satisfied?

93.102(b)(2)(iv) Does the SIP establish MVEBs for the applicable pollutants -

NOx and direct mobile PM2.5

emissions? Yes. The maintenance plan addresses both of these pollutants. Neither the

EPA nor the state have made an insignificance finding for either of these pollutants.

93.102(b)(2)(v) Are VOCs, Sulfur Oxides (SOx) and Ammonia (NH3) considered insignificant

contributors to the mobile

PM2.5 emissions? Yes. Neither EPA nor the State have made any findings that VOCs, SOx, or NH3 are significant contributors to the PM2.5 mobile emissions, and therefore, they have not been included
in the SIP. 93.102(b)(3) Has the EPA or the State made a finding that reentrained road dust is a significant
contributor to the PM mobile
emissions? Yes. Neither EPA nor the State have made such a finding.

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. This plan was filed by the Governor of Washington’s designee, Maia D. Bellon, Director of the Washington State Department of Ecology (Ecology), and received on November 3, 2014. The plan was the subject of a public hearing held in Tacoma, WA on September 30, 2014. The certificate of hearing is located in the Response to Comments Appendix F supplied by Ecology, dated October

2014.

93.118(e)(4)(ii) Before the maintenance plan was submitted to EPA, did consultation between federal, state and local agencies occur; Yes. A draft of the Tacoma-Pierce County Maintenance Plan and supporting documentation was reviewed by EPA Region 10 andwas full implementation plan documentation provided to EPA, and were EPA’s stated concerns, if any, addressed? discussed with Ecology, the Puget Sound Regional Council (PSRC), and the Puget Sound Clean Air Agency (PSCAA) prior to state adoption by Ecology on April 29, 2014. In addition, informal consultations between EPA, Ecology, PSRC, and PSCAA were held as the draft plan was being developed. EPA concerns were addressed during this consultation process.

93.118(e)(4)(iii) Was the motor vehicle emission budget(s) clearly identified and precisely quantified? Yes. Section 5 of the maintenance plan clearly establishes budgets for PM2.5 and NOx. Documentation is provided both in this section and in Appendix C.

93.118(e)(4)(iv) Is the motor vehicle emissions budget(s), when considered together with all other emission reductions, consistent with applicable requirements

for maintenance? Yes. EPA believes the budgets can be declared adequate because in conjunction with the other emission reductions, they demonstrate continued maintenance for years 2017 and 2026.

93.118(e)(4)(v) Is the motor vehicle emissions budget(s) consistent with and clearly related to the emissions inventory and the control measures in the plan? Yes. EPA believes that the budgets are clearly related to the emissions inventory and the control measures in

the SIP submittal.

93.118(e)(4)(vi) Revisions to previously

submitted attainment demonstrations: 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 (including the basis for any changes related to emission

factors or estimates of vehicle miles traveled). Not applicable. The Tacoma-Pierce Maintenance Plan provides new MVEBs for years 2017 and 2026 for

PM2.5 and NOx. The addition of safety margins to the MVEB is

consistent with continued attainment.

93.118(e)(5) Did they provide and we review public comments and the state’s responses to those Yes. The State submitted a complete list of comments received during theircomments with the submitted control strategy SIP? comment period, as well as the
response to comments.

VI. Findings Based upon our review and evaluation of the MVEBs c ontained in the Maintenance Plan for the Tacoma-Pierce County, WA 2006 24-hour PM2.5 NAAQS N onattainment Area, EPA finds the MVEBs adequate for conformity purposes.