1

**MEMORANDUM**

Date: February

15 , 2012 Subject: Summary

of EPA Regional Office Survey about MOVES Transition for Regional Conformity

Anal ys es From: Meg Patulski, State Measures and Transportation Planning Center , OTAQ To: Docket EPA

- HQ
- OAR
- 2011
- 0393

In February

2011 , EPA’s Office of Transportation and Air Qualit y (OTAQ) survey ed its EPA R egional O ffices to determine the status of state and local agenc y transition to using MOVES in regional conformity anal ys es . This survey

was based on a cursory

review of existing information alread y available to the EPA Regions including :

 The status of d iscussions about the transition to MOVES through the interagency consultation process ,  Whether state and local agencies had gained competency and technical expertise in using MOVES for either regional conformit y anal ys es or SIP development, and
 Any possible or anticipated revisions to SIP motor vehicle emissions budgets with MOVES
. T he information below s ummarizes the results of OTAQ’s informal survey. Overview: In February

2011 , there were approximately 100 nonattainment and maintenance areas for the 1997 ozone national ambient air qualit y standard (NAAQS ) and 37 nonattainment areas for the 1997 annual PM 2.5 NAAQS in states outside of California. 1 Under the trans portation conformity

rule at that time, these areas were required to begin using MOVES in regional conformity

anal ys es when the MOVES grace period ended in March 2012 . Many of these areas had alread y submitted state implementation plans (SIPs) based on MO BILE6.2. EPA had alread y approved maintenance plans for nearl y 70 ozone areas.

1 Please note that EPA had already released guidance indicating that nonattainment areas for the 2006 PM 2.5 NAAQS should prepare their SIPs using MOVES. In addition, all areas in California were excluded from this survey because they use the EMFAC model to calculate on

- road mobile source emissions instead of EPA’s MOBILE or MOVES model.2

1997 O zone NAAQS Areas: Based on the results of the informal survey , a pproximately

80 % o f ozone areas (80 areas) needed additional transition time for regional conformity anal ys es with MOVES

. The remaining ozone areas (about 20 areas ) involved miscellaneous situations, e.g., isolated rural areas that did not anticipate making a conformity determination in the near future. 1997 Annual PM 2.5 NAAQS Areas : Based on the results of the informal survey , approximately 81% of PM 2.5 areas (30 areas) needed additional transition time for regional conformity anal ys es with MOVES. The remaining PM 2.5 areas involved miscellaneous situations, e.g., EPA had previousl y f ound regional emissions to be insignificant so a regional conformity anal ys es was no longer required

. Additional D etails: The majority

of ozone and PM 2.5 areas had not yet begun to use MOVES for conformity purposes for several reasons. Start

- up issues included: building technical capacity in

- house at an MPO or obtaining staff elsewhere (e.g., from state DOT); other constraints on emissions modeling staff; and data collection and reformatting MOBILE data for use in MOVES. Re

planning issues included having the necessary time (after a MOVES regional conformit y anal ys is was completed) to either update the transportation plan and transportation improvement pr ogram and/or revise an existing approved or adequate MOBILE

- based SIP motor vehicle emissions budget with MOVES. Many Regions believed it would take at least a year (and sometimes longer) for states to update an y S IP budgets with MOVES, once MOVES was use d for regional conformity

anal ys es. States have different processes for developing SIPs depending on state law and other factors (e.g., accommodating interagency consultation and public involvement).