Enclosure to Letter Dated April 9, 2014 from Kate Kelly to Maia Bellon 

Transportation Conformity Adequacy Review 

The Kent, Seattle, Tacoma, WA Second 10-year Limited Maintenance Plan for PM10 

Submitted November 29, 2013 

Adequacy Determination of Motor Vehicle Emissions Budget 40 CFR 93.118 (e) (4) (4) EPA will not find a motor vehicle emissions budget in a submitted control strategy implementation plan revision o

adequate for transportation conformity purposes unless the following minimum criteria are satisfied: Adequacy Review Criteria Is this 

Criterion Satisfied? 

Reference in SIP Documents/Comments 

 (i) The submitted control strategy implementation plan revision or maintenance plan was endorsed by the Governor (or his or her designee) and was subject to a State public hearing; 

Yes This plan was filed by the Governor of Washington’s des

Bellon, Director of the Washington State Department of E(Ecology), on November 25, 2013. The plan was the subjhearing held in Kent, WA on October 30, 2013. The certihearing is located in the Response to Comments documenEcology, dated November 2013. 

 (ii) Before the control strategy implementation plan or maintenance plan was submitted to EPA, consultation among federal, State, and local agencies occurred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, if any, were addressed; 

Yes A draft of the Kent, Seattle, Tacoma WA Limited Mainte

(KST LMP) and supporting documentation was reviewed 

Region 10 and discussed with Ecology, the Puget Sound Council (PSRC), and the Puget Sound Clean Air Agency to state adoption by Ecology on November 20, 2013. In informal consultations between EPA, Ecology, PSRC, anheld as the draft plan was being developed. EPA concern

addressed during this consultation process. 

 (iii) The motor vehicle emissions budget(s) is clearly identified and precisely quantified; 

Yes Section 3 of the KST LMP demonstrates that the criteria 

LMP policy* are met. Documentation is provided both in and in Appendix A. 

 (iv) The motor vehicle emissions budget(s), when considered together with all other emissions sources, is consistent with applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given implementation plan submission); 

Yes Section 3 of the KST LMP demonstrates no violation of t

will occur due to reasonable growth projections of on-roaAdditional supporting material is located in Appendix A. LMP is consistent with the applicable requirement of con

maintenance. 
 (v) The motor vehicle emissions budget(s) is 

consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan revision or maintenance plan; and 

Yes Although EPA policy states that an emission budget is no

LMP areas, the KST LMP must be consistent with the req40 CFR 93.113 which “provides for the timely completioimplementation of all transportation control measures in implementation plan.” Sections 6, 7, and 8 of the KST Lcontrol measures in effect for the area, and discuss continmeasures. 

 (vi) Revisions to previously submitted control strategy implementation plans or maintenance plans explain and document any changes to previously 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 factors or estimates of vehicle miles traveled). 

Yes The assumptions, methods and computations used to gene

values and margin of safety calculations are described in Section 3 of the KST LMP. Appendices A and C of the Kprovide additional detail on on-road analyses conducted uMOVES model and road dust emissions computations. 

93.118 (e) (5) Before determining the adequacy of a submitted motor vehicle emissions budget, EPA will review the State's compilation of public comments and response to comments that are required to be submitted with any implementation plan. EPA will document its consideration of such comments and responses in a letter to the State indicating the adequacy of the submitted motor vehicle emissions budget. 

Yes The State submitted a complete list of comments received 

comment period, as well as the response to comments. No were received regarding the on-road portion of the plan. 

*Memorandum: Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas, August 21, 2001, Lydia We