Enclosure to Letter Dated April 9,2014 from Kate Kelly to Maia BellonTransportation Conformity Adequacy ReviewThe Kent, Seattle, Tacoma, WA Second 10-year Limited Maintenance Plan for PM10Submitted November 29, 2013Adequacy Determination of Motor Vehicle Emissions Budget 40 CFR 93.118 (e) (4)(4) EPA will not find a motor vehicle emissions budget in asubmitted control strategy implementation plan revision or maintenance plan to beadequate for transportation conformity purposes unless the following minimum criteria are satisfied:Adequacy Review Criteria Is thisCriterionSatisfied?Reference in SIP Documents/Comments(i) The submitted control strategy implementationplan revision or maintenance plan was endorsed by theGovernor (or his or her designee) and was subject to aState public hearing;Yes This plan was filed by the Governor of Washington’s designee, Maia D.Bellon, Director of the Washington State Department of Ecology(Ecology), on November 25, 2013. The plan was the subject of a publichearing held in Kent, WA on October 30, 2013. The certificate ofhearing is located in the Response to Comments document supplied byEcology, dated November 2013.(ii) Before the control strategy implementation plan ormaintenance plan was submitted to EPA, consultationamong federal, State, and local agencies occurred; fullimplementation plan documentation was provided toEPA; and EPA's stated concerns, if any, were addressed;Yes A draft of the Kent, Seattle, Tacoma WA Limited Maintenance Plan(KST LMP) and supporting documentation was reviewed by EPARegion 10 and discussed with Ecology, the Puget Sound RegionalCouncil (PSRC), and the Puget Sound Clean Air Agency (PSCAA) priorto state adoption by Ecology on November 20, 2013. In addition,informal consultations betweenEPA, Ecology, PSRC, and PSCAA wereheld as the draft plan was beingdeveloped. EPA concerns wereaddressed during this consultation process.(iii) The motor vehicle emissions budget(s) is clearlyidentified and precisely quantified;Yes Section 3 of the KST LMP demonstrates that the criteria of the EPALMP policy* are met. Documentation is provided both in this sectionand in Appendix A.(iv) The motor vehicle emissions budget(s), whenconsidered together with all other emissions sources, isconsistent with applicable requirements for reasonablefurther progress, attainment, or maintenance (whicheveris relevant to the given implementation plansubmission);Yes Section 3 of the KST LMP demonstrates no violation of the NAAQSwill occur due to reasonable growth projections of on-road emissions.Additional supporting material is located in Appendix A. Thus, the KSTLMP is consistent with the applicable requirement of continuedmaintenance.(v) The motor vehicle emissions budget(s) isconsistent with and clearly related to the emissionsinventory and the control measures in the submittedcontrol strategy implementation plan revision ormaintenance plan; andYes Although EPA policy states that an emission budget is not required forLMP areas, the KST LMP must be consistent with the requirements in40 CFR 93.113 which “provides for the timely completion orimplementation of all transportation control measures in the applicableimplementation plan.” Sections 6, 7, and 8 of the KST LMP list thecontrol measures in effect for the area, and discuss contingencymeasures.(vi) Revisions to previously submitted controlstrategy implementation plans or maintenance plansexplain and document any changes to previouslysubmitted budgets and control measures; impacts onpoint and area source emissions; any changes toestablished safety margins (see Sec. 93.101 fordefinition); and reasons for the changes (including thebasis for any changes related to emission factors orestimates of vehicle miles traveled).Yes The assumptions, methods and computations used to generate the designvalues and margin of safety calculations are described in detail inSection 3 of the KST LMP. Appendices A and C of the KST LMPprovide additional detail on on-road analyses conducted using theMOVES model and road dust emissions computations.93.118 (e) (5) Before determining the adequacy of asubmitted motor vehicle emissions budget, EPA willreview the State's compilation of public comments andresponse to comments that are required to be submittedwith any implementation plan. EPA will document itsconsideration of such comments and responses in a letterto the State indicating the adequacy of the submittedmotor vehicle emissions budget.Yes The State submitted a complete list of comments received during theircomment period, as well as the response to comments. No commentswere received regarding the on-road portion of the plan.*Memorandum:Limited Maintenance Plan Option for Moderate PM10Nonattainment Areas,August 21, 2001, Lydia Wegman, Director AQSSD