November 14, 2008

SUBJECT: Technical Support Document -Adequacy Findings for the Motor Vehicle

Emissions Budgets in the 2008 Reasonable Further Progress Plan for the

Pennsylvania Portion ofthe Philadelphia-Wilmington-Atlantic City 8-Hour Ozone

Nonattainment Area

FROM: Martin T. Kotsch

Environmental Engineer (3AP23)

TO: Administrative Record for the Adequacy Findings for the Motor Vehicle

Emissions Budgets in the 2008 Reasonable Further Progress Plan for the

Pennsylvania Portion of the Philadelphia-Wilmington-Atlantic City 8-Hour Ozone

Nonattainment Area

THRU: Carol Febbo,Chief

Energy, Radiation and Indoor Environment Branch (3AP23)

I. Administrative Requirements for Making Adequacy Findings

We have followed the process for determining the adequacy ofthe submitted State

Implementation Plan (SIP) Motor Vehicle Emissions Budgets (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 pian submissions”.

On August 29, 2007, the Pennsylvania Department of Environmental Protection (PADEP)

formally submitted a combined 2008 Reasonable Further Progress Plan (hereafter the 2008 RFP

Plan) and 2009 8-Hour Ozone Attainment Demonstration Plan (hereafter the 2009 attainment

demonstration) for the Pennsylvania Portion of the Philadelphia-Wilmington-Atlantic City 8-

Hour Ozone Nonattainment Area as State Implementation Plan (SIP) revision.

This TSD is only addressing the MVEBs contained in the 2008 Reasonable Further Progress

Plan.
EPA’s public comment period closed on April 21, 2008. EPA received no comments on the

proposed MVEBs.

This TSD will be an enclosure to the letter from EPA to the PADEP informing the State of ourfindings on MVEBs of the 2008 RFP Plan for the area submitted on August 29, 2007.

We will publish a Federal Register notice announcing our 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 we sent to PADEP and its enclosure, this TSD will

also be posted at the EPA website.Shown below in Table 1 is the 2 MVEBs from the SIP submittal.

Table 1

The Budgets of the Pennsylvania Portion of Philadelphia-Wilmington-Atlantic City 8-Hour

Ozone Nonattainment Area 2008 RFP Plan

Plan Milestone Mobile MobileSubmittals Year Vehicle Vehicle

Emissions Emissions

Budget for Budget forVOC-Tons Per NOx-Tons

. Day PerDay

Reasonable Further 2008 61.09 108.78Progress Plan

IL Evaluation of the Adequacy of the MVEBs Budgets in the 2008 RFP Plan for thePennsylvania Portion of the Philadelphia-Wilmington-Atlantic CIty 8-Hour Ozone

Nonattainment Area 8-Hour Ozone Non-attainment Area Submitted By the PADEP onAugust 29 , 2007In this TSD, we are evaluating the MVEBs associated with the 2008 RFP Plan contained in the

June 4, 2007 SIP submittal, for conformity purposes only. We are using the evaluation criteriadetailed in the Transportation Conformity Rule, 40 CFR Part 93, § 93.11 8(e)(4) through §93.1 18(e)(5). The evaluation is presented in Table 2, below.
40 CFR Part 93, § 93.118 Criteria Satisfied?

Sec. 93.1 1 8(e)(4)(i) Was the submitted revised Yes. The submitted RFP

plan endorsed by the Plan was endorsed and

Governor (or his or her submitted as a SIP revision

designee) and subject to a by the Governor’s designee, State public hearing? the Secretary ofthe PADEP,

and a public hearing was

held.

Sec. 93.1 18(e)(4)(ii) Before the attainment Yes. Consultation has

demonstration was submitted occurred among all required

to EPA, did consultation federal, state and local

between federal, State and agencies.

local agencies occur; was full

implementation plan

documentation provided to

EPA, and was EPA’s stated

concerns, if any, addressed?

Sec. 93.1 18(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly

emissions budget(s) clearly identified on page 48 ofthe

identified and precisely August 29, 2007 submittalquantified? containing the, 2008 RFP

Plan.

Sec. 93.1 1 8(e)(4)(iv) Is the motor vehicle EPA believes the budgets can

emissions budget(s), when be declared adequate becauseconsidered together with all in conjunction with the other

other emission reductions, emission reductions, they

consistent with applicable demonstrate reasonable

requirements for attainment further progress for 2008.demonstrations? These budgets serve to

strengthen the SIP through

continued progress towards

attainment and ensure that
emissions budget(s) budgets are clearly related to

consistent with and clearly the emissions inventory and

related to the emissions the control measures in the

inventory and the control SIP submittal.

measures in the Plan?

Sec. 93.1 1 8(e)(4)(vi) Revisions to previously Yes. The SIP submission

submitted attainment explains that the reviseddemonstrations: explain and MVEBs are in response to

document any changes to EPA’s 1997 revision to the

previously submitted budgets previous ozone standard.and control measures; This revision revoked the

impacts on point and area previous 1 -hour ozone

source emissions; any standard and replaced with a

changes to established safety more stringent 8 hour ozonemargins (see Sec. 93.101 for standard.

definition); and reasons for

the changes (including the

basis for any changes relatedto emission factors or

estimates of vehicle miles

traveled).

Sec. 93.1 1 8(e)(5) Did they provide and we There was one comment on

review public comments and the proposed mobile

the State’s responses to those emissions budgets in the SIP.

comments with the submitted The PAIJEP responded in ancontrol strategy SIP? adequate manner to the one

.

comment.

III. Findings -Based upon our review and evaluation ofthe MVEBs contained in PADEP’s

August 29, 2007 submittal of the 2008 REP Plan for the Pennsylvania Portion of Philadelphia

Wilmington-Atlantic City 8-Hour Ozone nonattainment area, we find the said MVEBs adequate

for conformity purposes. These budgets serve to strengthen the SIP through continued progress

towards attainment and ensure that motor vehicle emissions remain consistent with the emissionslevels provided for in the SIP.