Ref: 8P-AR 

UNITED STAT ES ENVIRONMENTAL PROTECTION AGENCY 

REGION 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/Chief Medical Officer 

Colorado Department of Public Health and Environment 

4300 Cherry Creek Drive South 

Denver, Colorado 80246 

Re: Greeley, Carbon Monoxide Second 10-year Limited Maintenance Plan; Transportation 

Conformity Adequacy 

Dear Mr. Urbina: 

EPA has reviewed the Greeley carbon monoxide (CO) Clean Air Act (CAA) section 175A(b) 

second I 0-year Limited Maintenance Plan (LMP) State Implementation Plan (SIP) revision that was 

submitted to EPA by a letter dated March 31, 201 0 from Martha E. Rudolph, then Executive Director 

of the Colorado Department of Public Health and Environment (CDPHE), on behalf of the Governor. 

We have found the Greeley. CO LMP adequate for transportation conformity purposes. Our 

finding is 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 93.118 of the 

Transportation Conformity Rule (40 CFR 93, Subpart A). We will announce this adequacy finding by 

publishing a Notice in the Federal Register; this adequacy finding will then become Federally-effective 

15 days after the publication of the Notice. 

As part of our adequacy review, we announced receipt ofthe Greeley CO second 10-year LMP 

and posted an announcement of availability on EPA's Office ofTransportation and Air Quality 

(OTAQ) website at: http://www.epa.gov/otag/stateresources/transconf/currsips.htm. We requested 

public comments by no later than December 10, 2010. We did not receive any comments. In addition, 

and as part of our review which is summarized in Enclosure 1, we also reviewed the Governor's SIP 

revision submittal for any comments about the maintenance plan 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 

emission 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 these prior EPA-approved MVEBs, 

we note that the second 10-year CO LMP SIP submittal will not replace the current full maintenance 

plan and its MVEBs for the time period covered by those SIP MVEBs. Consistency to the MVEBs in 

the first maintenance plan must continue to be demonstrated for as Long as any of the MVEBs are 
within 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 of the 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~ provisions in our CO LMP 

policy and 40 CFR 93 .l 09(£). 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 of the 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 disapproval of the SIP revision. 

If there are any questions, please contact Tim Russ of my 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 of CDPHE (on behalf of the 

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 Carbon Monoxide 

Maintenance Plan (CO 2"d Tenyear Maintenance Plan); Public 

Hearing notice dated October 5, 

2009, signed by Douglas Lempke, 

Administrator, Colorado Air 

Quality Control Commission 

(AQCC). Affidavit of publication: 

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 October 2, 2002, Casey 

Shpall, Colorado AG's office 

stated there is no State 

Requirement to publish a notice in 

a newspaper for a Notice of AQCC 

rulemaking. 

Sec. 93.118(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 of the North 

federal, state· and Front Range Metropolitan 

local agencies; full Planning Organization -

implementation NFRMPO), a listing of parties 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 submitted 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 of the revised, 

Limited Maintenance Plan and 

submitted comments on draft 

vers1ons. 

Sec. 93 .118( e)( 4)(iii) The MVEBs are y Table 2, page 5, of the 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 of emissions 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 of EPA's LMP 

em1ss10n sources, policy. 

is consistent with 

applicable 

requirements for 

reasonable 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 entitled "Emission Inventories" 

emissions and discusses the relevant control 

budget(s), control measures on pages 5 & 6 in the 

measures and the section entitled "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 

submitted 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 submitted MVEBs, and the language and 

budgets and control how these prior-approved MVEBs 

measures; impacts are addressed, on page 6 of the 

on point and area currently-submitted LMP in the 

source emissions; section entitled "Transportation 

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 of vehicle 

miles traveled). 

Sec. 93.118(e)(5) EPA has reviewed y The Governor's submittal 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 

submitted with any 

implementation 

plan. 

Reviewers: Tim Russ, USEP A, Region 8 Date of Review: November 4, 

2010 

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