1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

SUB JECT : Technical S upport Document (TSD)

- Adequacy Findings for the Motor Vehicle

Emissions Budgets in the 1997 Fine Particulate Matter (PM 2.5 ) Nation al Ambient Air Quality Standard (NAAQS) Maintenance Plan f or the Metropolitan Washington

, D.C. 1997 PM 2.5 Nonattainment Area (DC

- MD

- VA)

.

FROM: Gregory Becoat / s/ 2/11/14

Office of Air Program Planning (3AP30)

Asrah Khadr /s/ 2/11/14 Office of Air Program Planning (3AP30)

TO: Administrative Record for the Adequacy Findings for the Motor Vehicle Emissions Budgets in the 1997 Fine Particulate Matter (PM 2.5 ) National A mbient Air Quality Standard (NAAQS) Maintenance Plan f or the Metropolitan Washington

, D.C. 1997 PM 2.5 Nonattainment Area (DC

- MD

- VA)

.

THRU: Cristina Fernandez, Associate Director /s/ 2/11/14

Office of Air Program Planning (3AP30)

I. Background

On January 5, 2005 (70 FR 944, 1014), the Environmental Protection Agency ( EPA ) published air quality area designations for the 1997 PM 2.5 NAAQS

. In that rulemaking action, EPA designated the Metropolitan Washington, D.C. Area as nonattainmen t for the 1997 annual PM 2.5 standard. Th e Metropolitan Washington, D.C. Area includes the entire District of Columbia; Arlington, Fairfax, Loudoun, and Prince William Counties and the cities of Alexandria, Fairfax, Falls Church, Manassas, and Manassas Par k in Virginia and Charles, Frederick, Montgomery,

and Prince G eorge’s Counties in Maryland. See 40 CFR 81.309, 81.321

, and 81.347. Additional background information about the Metropolitan Washington, D.C. 1997 PM 2.5 Nonattainment Area (DC

- MD

- VA) (hereaft er, the Washington Area) is available in the notice of proposed rulemaking (NPR) in this docket.

By transmittal letters dated as shown in Table 1 , the State of Maryland, the Commonwealth of Virginia, and the District of Columbia each formally submitted as a State Implementation Plan2

(SIP) revision a combined 1997 PM 2.5 NAAQS Maintenance P lan (hereafter the Maintenance

Pla n) that included motor vehicle emissions budgets (MVEBs) for PM 2.5 and nitrogen oxides (NOx) for the Washington Area.

Table 1

. State SIP Submission Dates

Jurisdiction Submittal Date

Maryland July 10, 2013

Virginia June 3, 2013

District of

Columbia June 3, 2013

I I. Transportation Conformity Requirements

Transportation conf

ormity is required under section 176(c) of the Clean Air Act ( CAA ) to ensure
that f ederally supported highway, transit projects, and other activities are consistent with (conform to) the purpose of the State Implementation Plan ( SIP )

. The CAA requires fed eral actions in nonattainment and maintenance areas to “conform to” the goals of SIP. This means that such actions will not cause or contribute to violations of a NAAQS; worsen the severity of an existing violation; or delay timely attainment of any NAAQS or any interim milestone. Actions involving Federal Highway Administration (FHWA) or Federal Transit Administration (FTA) funding or approval are subject to the Transportation Conformity Rule ( 40 CFR part 93

, subpart A). Under this rule, metropolitan pl anning organizations (MPOs) in nonattainment and maintenance areas coordinate with state air quality and transportation agencies, EPA, FHWA, and FTA to demonstrate that their metropolitan transportation plans and transportation improvement plans (TIPs) con form to applicable SIPs. This is typically determined by showing that estimated emissions from existing and planned highway and transit systems are less than or equal to the MVEBs contained in a SIP.

F or MVEBs to be approvable, they must meet, at a minimu m, EPA’s adequacy criteria found at 40 CFR 93.118(e)(4). EPA’s adequacy criteria are: (1) the submitted control strategy implementation plan was endorsed by the Governor or designee and was subject to a State public hearing; (2) con sultation among F edera l, State, and local agencies occurred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, if any, were addressed

before the control strategy implementation plan was su bmitted ; (3) the MVEBs are clearly identified and pre cisely quantified; (4) the MVEBs, when considered together wit h all other emissions sources, are consistent with applicable requirements for maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and the control measu res in the

submitted control strategy implementation plan; and (6) revisions to previously submitted maintenance plans explain and document any changes to previously submitted budgets and control measures; impacts on point and area source emissions; any ch anges to established safety margins; and reasons for the changes (including the basis for any changes related to emission3

factors or estim ates of vehicle miles traveled).

III. Review of the Submitted Modeling Utilizing the Motor Vehicle Emission Simulato r (MOVES2010)

To run the MOVES2010 model, a run specification (hereafter referred to as “RunSpec”) must be created so the appropriate parameters are selected for the modeling run. The RunSpecs were reviewed against the following EPA document: Technical Guidance on the use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. This guidance document provides guidance on the use of the MOVES model to develop inventories for SIPs as well as analysis of emissions for transportation conformity

determinations.

MVEBs were submitted for the years 2017 and 2025 for the 1997 PM 2.5 NAAQS which are consistent with the rest of the emissions inventory in the Washington Area Maintenance Plan.

The ten counties/cit ies which comprise the Washington Area were modeled using an individual RunSpec for each county/city. The Virginia counties/cities include Alexandria City, Arlington County, Fairfax County, and Loudon County. The Maryland counties include Charles County, Frederick County, Montgomery County, Prince George’s County, and Prince William County.

The District of Columbia was modeled as its own individual area. The submitted RunSpecs, input files and output files were reviewed and found to have followed the app licable EPA guidance provided in the Technical Guidance on the use of MOVES2010 for Emission I nventory Preparation in State Im

plementation Plans and Transportation Conformity

. Table 2 presents the RunSpec parameters that were reviewed and each parameter ’s respective component in the

submittal.

Table 2. RunSpec Reviews for the 1997 PM 2.5 NAAQS for Years 2017 and 2025 for the Washington Area

Domain/Scale Co unty scale was selected. County scale also accommodates independent cities, which were present in t hese modeling runs. Selection of county scale is acceptable for this air quality analysis. Calculation Type Inventory was selected which is acceptable for this analysis. Time Aggregation Level Hourly time aggregation was selected. Selection of hourly

t ime aggregation level is acceptable for this analysis.

Calendar Year Of Evaluation The appropriate calendar year s were selected for each RunSpec; each RunSpec had 2017 or 2025 as the sele cted calendar year. MOVES2010b can model years 1990 and

1999

- 2050.

Month of Evaluation All 12 months were selected for evaluation. Type of Day of Evaluation Weekdays and weekends were selected , which is appropriate for the evaluation of pollutant emissions related to PM 2.5

. Hours of Evaluation Starting and ending hours create a whole day (from 0

- 24 hours). Geographic Bounds The appropriate county/city were selected for each Runspec

.4 The following counties/cities were selected: Alexandria City, Arlington County, Fairfax County, Loudon County, Charles County, Fr ederick County, Montgomery County, Prince George’s County, Prince William County

, and the

District of Columbia. Vehicles/Equipment: On

Road Vehicle Equipment Appropriate combinations of fuels and source use types were

made. Road Type Selection inclu ded all necessary road types.

Pollutants and Processes NO
x , sulfur dioxide (SO 2 ) and all forms of primary PM 2.5 were selected. Only emissions of NO
x and PM 2.5 are necessary for the analysis of PM 2.5 emissions.

On

- Road Retrofits N/A

ROP N/A Outp ut Database/Unit

Selection Mass units selected to be U.S. Tons; energy units selected to

be Joules ; distance units selected to be miles. Output Emission Detail in

Emission Rate Calculations Emission detail was selected via user preference . The output

em issions detail does not affect the results of the modeling runs, therefore user preference is acceptable.

Advanced Performance

Features N/A

I V. Administrative Requirements for Making Adequacy Findings

EPA followed the process for determining the a dequacy of the submitted SIP MVEBs in

accordance with the procedures listed in the January 2008 Conformity Regulations contained in 40 CFR part 93, 118(f) “ Adequacy review process for implementation plan submissions .” EPA will be issuing a notice of propo sed rulemaking ( NPR ) for a 30

- day public comment period soliciting public comment for the approvability of the State of Maryland’s, the Commonwealth of Virginia’s, and the District of Columbia’s SIP submission. The NPR also proposes approval

of the MVEBs for milestone year 2017 and the out

- year 2025 for the Washington Area for PM 2.5 and NO
x .

On February 5, 2014

, notices were posted on EPA ’s web site located at: http://www.epa.gov/otaq/stateresources/transconf/currsips.htm

, for the purpose of opening EPA ’ s 30

- day public comment period on the adequacy/approvability of the budgets in the Washington

Area Maintenance Plan. The notices were posted separately for the State of Maryland, the Commonwealth of Virginia, and the District of Columbia. The purpose of the notices is to

inform the public of the availability of the Washington Area Maintenance Plan on its own website. EPA’s website notice provides a link where interested members of the public could

access the Washington Area Maintenance Plan . Following EPA’s public comment period, responses to any comments received on the proposed mobile budgets will be addressed in an

amendment to this TSD.

T his TSD will be an enclosure to the letter s from EPA to the Maryland Department of the5

Environment (MDE), the Vi rginia Department of Environmental Quality (VADEQ)

, and the District of Columbia Department of the Environment (DCDOE) informing the jurisdictions of

EPA’s findings on MVEBs of the Washington Area Maintenance Plan. EPA will publish a Federal Register noti ce announcing the adequacy findings. The effective date of the adequacy findings will be 15 days after the publication date of that notice . Once EPA has published the Federal Register notice, the letter s sent to MDE , VADEQ

, and DCDOE

, and this TSD will a lso be posted at the EPA website

.

Shown in Table 3 and Table 4 are the budgets from the Washington Area Maintenance Plan . The Washington Area Maintenance Plan includes a Tier 1 and Tier 2 approach for MVEBs and will be applied to all future transportatio n conformity determinations and analyses for the 1997

annual PM 2.5 NAAQS. The Tier 1 MVEBs shown in Table 3 will be the applicable motor vehicle emissions budgets after the adequacy findings are effective. The Tier 2 MVEBS shown in Table 4 adds a twenty percent (20%) transportation buffer to the mobile emissions inventory projections for PM 2.5 and NOx in 2017 and 2025. The Tier 2 MVEBs will become effective only

if it is determined that technical uncertainties due to model changes and to vehicle fleet tu rnover, which may affect future motor vehicle emissions inventories, lead to motor vehicle emissions estimates above the Tier 1 MVEBs. The determination will be made through the interagency consultation process and fully documented within the first confor mity analysis that uses the Tier

2 MVEBs.

Table 3

. Tier 1 On

- road MVEBs Contained in the Washington Area Maintenance Plan

for the 1997 PM 2.5 NAAQS

Year Motor Vehicle Emissions Budget for PM 2.5 On

- Road Emissions (tons per year) Mobile Vehicle Emissio ns Budget for NO x On

- Road Emissions (tons per year)

2017 1,787 41,709

2025 1,350 27,400

Table 4

. Tier 2 On

- road MVEBs Contained in the Washington Area Maintenance Plan

for the 1997 PM 2.5 NAAQS

Year Motor Vehicle Emissions Budget for PM 2.5 On

- Road Emissions (tons per year) Mobile Vehicle Emissions Budget for NO x On

- Road Emissions (tons per year)

2017 2,144 50,051

2025 1,586 32,880

V

. Evaluation of t he Adequacy of the MVEBs in the Washington Area Maintenance Plan

for the 1997 PM 2.5 NA AQS

In this TSD, we are evaluating the MVEBs associated with the Washington Area Maintenance

Plan for conformity purposes. We are using the e valuation criteria detailed in the Transportation Conformity Rule, 40 CFR part 93.102(b)(2)(v), 93.102(b)(2)(v), 93.102(b)(3), and part 93, 93.118(e)4 through 93.118(e)5. The evaluation is presented in Table 5 , below.6

Table 5. Adequacy of the MVEBs Contained in the Washington Area Maintenance Plan

for the 1997 PM 2.5 NAAQS

Transportation Conformity

Rule

40 CFR Pa rt 93, 93.118 Review Criteria Was the Criterion Satisfied?

If Yes How was this Criteria

Satisfied?

93.102(b)(2)(iv) Have EPA and the State s made a finding that NO
x is an insignificant contributor to

the direct mobile PM

emissions? Neither EPA nor the State s h ave made such a finding.

93.102(b)(2)(v) Has EPA or States made a finding that VOCs, Sulf

u r Oxides (SO
x ) or Ammonia (NH 3 ) as precursors to be a significant contributor to the

mobile PM 2.5 emissions? Neither EPA nor the States

have made any findi ngs that

VOCs or NH 3 are significant

contributor s to the PM 2.5 mobile emissions

, and

therefore

, they have not been

included in the SIP

. The States have requested that

SO 2 be found an insignificant

contributor to the mobile PM emissions. This request is

b ased on the States finding

that onroad mobile source

SO 2 constitutes less than two percent ( 2%) of the area’s

total SO 2 emissions in the

2017 and 2025 horizon years

. Although the State requested insignficance, SO 2 isn’t considered to be a significant

cont ributor to mobile PM and

therefore does not have to be part of a PM 2.5 maintenance
strategy. 93.102(b)(3) Has the EPA or the State s made a finding that re

entrained road dust is a significant contributor to the

PM mobile emissions? Neither EPA nor the State s h ave made such a finding.7

Sec. 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. The submitted Washington Area

Maintenance Plan w ere endorsed and s ubmitted as a

SIP revision by the

Governor ’ s designee, the

Secretar ies of M aryland

D epartment of the

E nvironment and Virginia Department of Environmental Quality and the Director of

District of Columbia Department of the

Environment. A public hearing on th e SIP proposal

was held in all three jurisdictions

. Sec. 93.118(e)(4)(ii) Before the maintenance plan was submitted to EPA, did consultation between federal, State and local agencies occur; was full implementation plan documentation provided to EPA, and w as EPA ’ s stated concerns, if any, addressed? Yes. Consultation has occurred among all required federal, state and local agencies.

Sec. 93.118(e)(4)(iii) Was the motor vehicle emissions budget(s) clearly identified and precisely quantified? Yes, the budge ts are clearly identified on page s 8

- 12 of

the Washington Area

Maintenance Plan prepared by the Metropolitan Washington Council of

Governments and submitted by the State of Maryland, the Commonwealth of Virginia,

and the District of Columbia.
Sec. 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 ? EPA believes the budgets can be declared adequate because in conjunction with the oth er emission reductions, they

demonstrate continued

maintenance for years 2017

and 2025.8

Sec. 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 Pla n? EPA believes that the budgets are clearly related to the emissions inventory and the

control measures in the SIP

submittal.

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

submitted attainment demonstrations: explain and document any changes to

pre viously submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins (see Sec. 93.101 for definition); and reasons for the changes (including the basis for any changes related

to emission fac tors or
estimates of vehicle miles traveled). Yes, the Washington Area

Maintenance Plan provides new MVEBs for years 2017

and 2025. The addition of safety margins to the MVEBs

is consistent with continued

attainment.

Sec. 93.118(e)(5) Did they prov ide and we review public comments and

the State ’ s responses to those

comments with the submitted control strategy SIP? Yes

VI

. Findings

Based upon our review and evaluati on of the MVEBs contained in the three jurisdictions

submittal s of the Maintenanc e Plan f or the Metropolitan Washington

, D.C. 1997 PM 2.5 Nonattainment Area

, EPA find s the MVEBs adequate for conformity purposes and recommends that the MVEBs be SIP approved.