Ref: 8P-AR U N ITED S T AT ES E N V I RON M ENTAL PROTECT I O N AGE N CY REG I O N S 1595 Wynkoop Street DENVER , CO 80202-1129 Phone 800-227-8917 http ://www

. epa

. gov / region08

Christopher E. Urbina , M.D. , MPH Executive Director/ChiefMedical Officer Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, Colorado 80246
Re: Greeley , Ca rbon Monoxide Second 10-year Limited Maintenance Plan; Transportation Conformity Adequacy
Dear Mr. Urbina:
E PA has revi ewed the Greeley carbon monoxide (CO) Clean Air Act (CAA) s ection 175A(b)
seco nd I 0

- year Limit ed Maintenance Plan (LMP) State Implementation Plan (SIP) rev ision that was submitted to EPA by a letter dated March 3 1 , 201 0 from Martha E. Rudolph, then Executive Director ofthe Colorado Department ofPublic Health and Environment (CDPHE) , on behalf ofthe Governor.
We have found the Greeley

. CO LMP adequate for transportation conformity purposes. Our finding i s based primarily on the Greeley CO maintenance area as meeting the criteria for a LMP and as meeting the applicable procedures and criteria for adequacy review pursuant to section 93. 1 18 of the Transportation Conformity Rule (40 CFR 93, Subpart A). We will announce this adequacy finding by pub lishing a Notice in the Federal Register; this adequacy finding will then become Federally

- effective 15 days after the publication ofthe Notice.
As part of our adequacy review, we announced receipt ofthe Greeley CO second 10

- year L MP and posted an announcement of availability on EPA's Office ofTransportation and Air Quality (OTAQ) webs ite at: http: / /www. e pa
. gov/otag/ stater esour ce s/ tran scon f/currs ips. htm

. We requested public comments by no later than December 10, 2010. We did not receive any comments. In addit ion, and as part of our review which is summarized in Enclosure 1 , we also reviewed the Governor's SIP revision s ubmittal for any comments about the maintenance p lan that may have been submitted during the Colorado Air Quality Control Commission (AQCC) public hearing process. There were no adverse comments from the public.
EPA notes that for the Greeley CO maintenance area, the prior EPA-approved motor vehicle emi ssion budgets (MVEB) were 62 tons of CO per day for 201 0 through 2014 and 60 tons per day of CO for 2015 (see 70 FR 48650 , August 19, 2005). With respect to the se pri or EPA-approved MVEB s, we note that the second 10-year CO LMP SIP submittal will not replace the current full maintenance plan and its MVEB s for the time period covered by those SIP MVEBs. Consistency to the MVEBs in the first maintenance plan must continu e to be demonstrated for as Long as any of the MVEBs arewithin the timeframe of the transportation plans. Eventually in the future , no regional emissions analyses would be required for the regional transportation plan (RTP) or the transportation improvement program (TIP) transportation plan when these transportation plans cover the years 2016 and beyond. In such a case, there would no need to show consistency with the first maintenance plan's 2015 MVEB since this MVEB would no longer be in the timeframe ofthe transportation plan and no analysis years would be required beyond 2015 due to the adequate CO LMP. Therefore, once our transportation confonnity adequacy finding is published in the Federal Register and becomes effective for the Greeley CO LMP second I 0-year maintenance period, regional emissions analyses would not be required for the years in the North Front Range Metropolitan Planning Organization (NFRMPO) transportation plans that are covered by the LMP (i.e., any analysis years that would nonnally be required beyond 20 15 ). This reflects**th~** provis ions in our CO LMP policy and 40 CFR 93 .l09(£). However, as we noted above, consistency must continue to be demonstrated to the 2014 and 2015 budgets in the approved first maintenance plan under 40 CFR 93

. 118( d)(2), as long as such years are within the timeframe ofthe transportation plan

. This adequacy finding affects future CO RTP and TIP confonnity detenninations as prepared and approved by the NFRMPO, the Colorado Department of Transportation (CDOT), and the Federal Highway Administration (FHWA) and Federal Transit Administration (FTA).
Please note that this adequacy finding is separate from EPA's subsequent rulemaking action on the Greeley second 10-year CO LMP SIP revision and should not be used to prejudge EPA's approval or d isapproval ofthe SIP revision.
If there are any questions , please contact Tim Russ ofmy staff at (303) 312-6479.

Enclosure Deborah Lebow Aal, Acting Director Air and Radiation Program

cc: Cliff Davidson, Executive Director, NFRMPO Paul Tourangeau, Director, Air Pollution Control Division, CDPHE Donald Hunt, Executive Director, CDOT Bill Haas, Colorado Division, FHW A Kistin Kenyon, Region 8, FT A



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### Enclosure 1: Greeley Carbon Monoxide Limited Maintenance Plan Adequacy Evaluation
Transportation Review Criteria Is Criterion Reference in 

### SIP Document 

### I Satisfied? Comments Sec. 93 .118( e)( 4)(i) The plan was y March 31 , 20 1 0 Letter from
endorsed by the Martha E. Rudolph, Exec. Director Governor (or ofCDPHE (on behalf ofthe designee) and was Governor.) subject to a public hearing. The submittal includes evidence of a public hearing that occurred on December 17, 2009.
Public Hearing Notice : The Greeley Ca rbon Monoxide Maintenance P lan (CO 2 "d T enyear Maintenance Plan); Public Hearing notice dated October 5, 2009, signed b y Douglas Lempke, Administrator, Colorado Air Quality Control Commission (AQCC). Affidavit ofpublication: The Public Hearing notice was

. published in the Denver Post on

10

/ 12 /09 and on the AQCC Commission website. Note: In a letter dated Oc t ober 2, 2002, Casey Shpall , Colorado AG's office stated there is no State Requirement to publish a notice in a newspaper for a Notice ofAQCC rulemaking. Sec. 93

. 1 1 8(e)(4)(ii) The plan was y The submittal includes parties that developed through applied for party

- status (Su;z:ette consultation with Mallette on behalf ofthe North federal , state· and Front Range Metropolitan local agencies; full Planning Organization

- implementation NFRMPO) , a li sting ofparties that plan documentation applied for party status and/or was provided and submitted public comments and EPA's stated included local governments and concerns, if any, entities. NFRMPO s ubmitted a were addressed. 11/10/09letter in support ofthe 

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### Transportation Review Criteria Is Criterion Reference in SIP Document 

### I Satisfied? Comments maintenance plan. EPA was consulted many times during the development ofthe revised, Limited Maintenance P lan and submitted comments on draft vers1ons. Sec. 93 .118( e)( 4)(iii) The MVEBs are 

### y Table 2 , page 5 , ofthe document clearly identified shows emissions for 2007, but and precisely does not project future emissions. quantified. Area qualified for and State used EPA's Limited Maintenance Plan (LMP) policy which only requires a base year ofemissions and no projections. Sec. 93. 118(e) (4)(iv)**Th~** motor vehicle 

### y EPA has reviewed the 2007 emissions emissions inventory on page 5 of budget(s ) , when the maintenance plan and considered together considered the data as meeting the with all other requirements ofEPA 's LMP em1ss10n sources, policy. is consistent with app licable requirements for reaso nable further progress, attainment, or maintenance (whichever is relevant to the given plan). Sec. 93.118(e)(4)(v) The plan shows a 

### y The Greeley CO LMP discusses clear relationship emissions on page 5 in the section between the ent itled "Emission Inventories" emissions and discusses the relevant control budget(s) , control measures on pages 5 & 6 in the
measures and the section ent itled "Enforceable total emissions Control Measures for the inventory. Maintenance Period". Sec. 93.118( e)( 4)(vi) Revisions to 

### y Mobile source emissions and previously motor vehicle emissions budgets subm itted control (MVEBs) were originally strategy or documented in the revised Greeley maintenance plans CO maintenance plan that was 4

### Transportation Review Criteria 

### Is Criterion Reference in SIP Document 

### I Satisfied? Comments explain and approved by EPA on 8/19/05 (70 document any FR 48650). EPA has reviewed changes to any these previously approved previous s ubmitted MVEBs, and the language and budgets and control how these prior-approved MVEBs measures; impacts are addressed , on page 6 ofthe on point and area currently-submitted LMP in the
source emissions; section en titled "Transporta tion any changes to Conformity Determination". We established safety agree with the language and the margins (see analysis. 93.101 for definition), and reasons for the changes (including the basis for any changes to emission factors or estimates ofvehicle miles traveled). Sec. 93.118(e)(5) EPA has reviewed 

### y The Governor 's s ubmitt al does not the State's indicate there were any public compilation of comments at the public hearing

. public comments and response to comments that are required to be subm itted with any implementation plan. Reviewers: T im Russ , USEP A, Region 8 Date of Review: November 4, 2010



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