**Enclosure** 

### Transportation Conformity Adequacy Review Control Strategy State Implementation Plan (SIP) Under Revi ew **:** Five Percent Plan for PM

- 10 for the Maricopa County Nonattainment Area (May 2012) 

### Date of SIP Revision Receipt by EPA: 5 / 25 /1 2
Reviewer: Greg Nudd Date: 11 /20 / 1 3 Transportation Review Criteria Is Criterion Satisfied? Y/N Reference in SIP Document/Comments

Sec. 9 3.118(e)(4)(i) The plan was endorsed by the Governor (or designee) and was subject to a public hearing. Y The cover letter transmitting the SIP , dated May 25, 2012, wa s from Henry Darwin, Director, Arizona Department of Environmental Quality (ADEQ ) to Jared Blumenfeld, Regional Administrator, US EPA Region 9. There was documentation in the package demonstrating that ADEQ has b een designated by the Governor of Arizona to submit such plans to EPA. There w as also information in the SIP package demonstrating that the Maricopa Association of Governments (MAG) was the appropriate agency to develop the plan for the areas of Maricopa C ounty within the PM

- 10 nonattainment area. A public hearing was held by MAG on April 12, 2012. Documentation of this hearing may be found in Appendix E of the submitted plan. Sec. 93.118(e)(4)(ii) The plan was developed through consultation with federal, state and local agencies; full implementation plan documentation was provided and EPA’s stated concerns, if any, were addressed. Y During the development of the plan, the structure, approach and control measures were discussed and coordinated in m eetings of the MAG Air Quality Technical Ad visory Committee. The almost

- final version of the plan was discussed at an April 26, 2012 . The Air Quality Technical Advisory Committee includes representatives from EPA, Federal Highway Administration, Arizona De partm ent of Transportation, and local governments such as Maricopa County, Phoenix, Mesa and smaller cities. Sec. 93.118(e)(4)(iii) The motor vehicle emission budget(s) is clearly identified and precisely quantified. Y Chapter 6 of the plan clearly quantifies and identifies the motor vehicle emissions budget (pp 6

- 42 through 6

- 43). MAG used MOVES 2010a to calculate PM

- 10 emissions from exhaust, tire and brake wear. They used the January 2011 version of AP

- 42 ’s appropriate methods to calculate re

- entrained dust emissions from paved roads and dust emissions from unpaved roads. Sec. 93.118(e)(4)(iv) The motor vehicle emissions budget(s), when considered together with all other emission sources, is consistent with applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given plan). Y EPA has determined that the M VEB , w hen considered together with all other emission sources, are consistent with requirement to demonstrate five percent reductions until attainment, reasonable further progress and attainment of the PM

10 standard. (See Chapters 4, 5 and 6 of the plan)Sec. 93.118(e)(4)(v) The plan shows a clear relationship among the emissions budget(s), control measures and the total emissions inventory. Y The on

- road control measures include the use of PM

- 10 certified street sweepers, paving and stabilizing unpaved roads and alley and shoulders, reduced speed limits and overlaying highways with rubberized asphalt. These w ere implemented as advanced contingency measures and the reductions were not considered in demonstrating 5% reductions, RFP or attainment , but these controls are assumed in the calculation of the MVEB. (Chapter 4) There w ere some ancillary benefits to the on

- road emissions due to increased compliance with Maricopa county rules for stabilizing private unpaved roads and alleys. These benefits were included in the emissions inventory for the 5% reductions, RFP and attainment demonstrations and in the MVEBs . (Chapters 5 and 6) Sec. 93.118(e)(4)(vi) Revisions to previously submitted control strategy or maintenance plans explain and document any changes to any previous 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 to emission factors or estimates of VMT. Y The previous MVEB under the approved Serious Area Plan for PM

- 10 w as 59.7 metric tons per day of PM

- 10 . Th e budget in this plan is 54.9 , w hich is lower due to changes in methodology , im provem ents in rule compliance and reductions due to paving of roads, alleys and shoulders and from improved street sweepers. 84.6% of the on

- road emissions are f rom re - entrained dust and dust from unpaved roads and alleys. These emissions are calculated using methods from AP

- 42. EPA has revie wed the AP

- 42 m ethod, resulting in a more accurate, but low er estimate of emissions for the Maricopa County PM

- 10 Nonattainm ent Area. This calculation is discussed on in Chapter 5 of the 2008 Maricopa County Emissions Inventory which is included as Appendix A of the plan. As a result of these changes , the a smaller emissions budget is appropriate for the area , even though vehicle miles traveled is increasing. The other required reductions for the demonstrations in the plan were made by im proving compliance with dust control regulations for construction projects and undeveloped lands. The area is also making good progress reducing road

- related emissions by improved street sweeping and a program to pave or stabilize roads, alleys and shoulders. Sec. 93.118(e)(5) EPA has reviewed the State’s compilation of public comments and response to comments that are required to be submitted with any im plementation plan. Y MAG accepted and responded to verbal and w ritten public comments on the plan as part of their public hearing process documented in Appendix E of the plan. MAG addressed all public comments in detail and submitted both the comments and their responses as part of Appendix E. EPA has reviewed these comments and responses and has considered them in our finding that the MVEBs are adequate.