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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

 January 28, 2014

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

Emissions Budgets in the Maintenance Plan for the West Virginia Portion of the 

Martinsburg-Hagerstown WV-MD 1997 Fine Particulate (PM2.5) National Ambient 

Air Quality Standard (NAAQS) Nonattainment Area 

FROM:

 /s/

Asrah Khadr, Environmental Engineer, Engineer in Training (EIT) 

Office of Air Program Planning (3AP30)

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

Emissions Budgets in the Maintenance Plan for the West Virginia Portion of the 

Martinsburg-Hagerstown WV-MD 1997 PM2.5 NAAQS Nonattainment Area 

 /s/

THRU: Cristina Fernandez, Associate Director 

Office of Air Program Planning (3AP30)

I. Background

On January 5, 2005, Berkeley County was designated as nonattainment for the 1997 PM2.5

NAAQS as the West Virginia portion of the Martinsburg-Hagerstown 1997 PM2.5 NAAQS 

Nonattainment Area. On November 20, 2009 (74 FR 60199), it was determined that the 

Martinsburg-Hagerstown WV-MD 1997 PM2.5 NAAQS Nonattainment Area had air quality data 

showing the 1997 PM2.5 NAAQS was attained. Additional background information about the

West Virginia portion of the Martinsburg-Hagerstown WV-MD 1997 PM2.5 NAAQS

Nonattainment Area is available in the notice of proposed rulemaking (NPR) in this docket. On 

August 5, 2013, the West Virginia Department of Environmental Protection (WVDEP) formally 

submitted a State Implementation Plan (SIP) revision to satisfy the redesignation requirements of 

the Clean Air Act (CAA) for the 1997 PM2.5 NAAQS for the West Virginia Portion of the 

Martinsburg-Hagerstown WV-MD 1997 PM2.5 NAAQS Nonattainment Area. 

II. Transportation Conformity Requirements

Under section 176(c) of the CAA, new transportation plans, programs, and projects, such as the 

construction of new highways, must “conform” to (i.e., be consistent with) the part of the state’s 

air quality plan that addresses pollution from cars and trucks. The CAA requires federal actions in 

nonattainment and maintenance areas to “conform to” the goals of the SIP. This means that such 

actions will not cause or contribute to violations of NAAQS; worsen the severity of an existing 

violation; or delay timely attainment of any NAAQS or any interim milestone. 
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For motor vehicle emissions budgets (MVEBs) to be approvable, they must meet, at a minimum, 

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) 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 before the control strategy implementation plan was submitted; 

(3) the MVEBs are clearly identified and precisely quantified; (4) the MVEBs, when considered 

together with 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 measures 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 changes 

to established safety margins; and reasons for the changes (including the basis for any changes 

related to emission factors or estimates of vehicle miles traveled).

III. Review of the Submitted Modeling Utilizing the Motor Vehicle Emission Simulator 

(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. 

WVDEP submitted MVEBs for the years 2017 and 2025 for the 1997 PM2.5 NAAQS. The 

RunSpecs, input files and output files were reviewed and found to have followed the applicable 

EPA guidance provided in the Technical Guidance on the use of MOVES2010 for Emission 

Inventory Preparation in State Implementation Plans and Transportation Conformity. Table 1 

presents the RunSpec parameters that were reviewed and each parameter’s respective component 

in WVDEP’s submittal. 

 

Table 1. RunSpec Reviews for the 1997 PM2.5 NAAQS for Years 2017 and 2025 

Domain/Scale County scale was selected. This 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 time 

aggregation level is acceptable for this analysis.

Calendar Year Of 

Evaluation

The appropriate calendar year was selected. 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.
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Hours of Evaluation Starting and ending hours create a whole day (from 0-24 hours).

Geographic Bounds Berkeley County was selected.

Vehicles/Equipment: OnRoad Vehicle Equipment Appropriate combinations of fuels and source use types were made.

Road Type Selection included all necessary road types.

Pollutants and Processes Nitrogen oxides (NOx), sulfur dioxide (SO2), ammonia (NH3), 

volatile organic compounds (VOCs) total gaseous hydrocarbons, 

non-methane hydrocarbons and all forms of primary PM2.5 were 

selected, which is acceptable for this analysis. 

On-Road Retrofits N/A

ROP N/A

Output Database/Unit 

Selection

Mass units selected to be grams; energy units selected to be million 

British Thermal Units (BTU); distance units selected to be miles.

Output Emission Detail in 

Emission Rate 

Calculations

Emission detail was selected via user preference. 

Advanced Performance 

Features 

N/A

IV. Administrative Requirements for Making Adequacy Findings 

EPA followed the process for determining the adequacy 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 an NPR for a 30-day public comment period soliciting public comment for the

approvability of West Virginia’s SIP submission. The NPR also proposes approval of the MVEBs 

for milestone year 2017 and the out-year 2025 for Berkeley County for PM2.5 and NOx. The 

MVEBs are presented below in Table 2. On December 20, 2013, a notice was posted on EPA’s 

website 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 

SIP revision. The notice informed the public of the availability of the West Virginia SIP revision 

on its own website. EPA’s website notice provides a link where interested members of the public 

could access the SIP revision. 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.

Table 2. MVEBs Contained in the Maintenance Plan for the 1997 PM2.5 NAAQS

Year Motor Vehicle Emissions 

Budget for Direct PM-Tons 

Per Year

Mobile Vehicle Emissions 

Budget for NOx-Tons Per 

Year

2017 83 2,621

2025 50 1,660
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V. Evaluation of the Adequacy of the MVEBs in the Maintenance Plan for the 1997 PM2.5 

NAAQS

In this TSD, we are evaluating the MVEBs associated with the maintenance plan contained in the 

August 5, 2013 SIP revision, for conformity purposes. We are using the evaluation 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 

3, below.

Table 3. Adequacy of the MVEBs Contained in the Maintenance Plan for the 1997 PM2.5 

NAAQS

Transportation Conformity 

Rule

40 CFR Part 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 

made a finding that NOx is 

an insignificant contributor 

to the direct mobile PM 

emissions?

Neither EPA nor the State 

has made such a finding.

93.102(b)(2)(v) Has EPA or State made a 

finding that VOCs, Sulfur 

Oxides (SOx) or Ammonia 

(NH3) as precursors to be a 

significant contributor to the 

mobile PM2.5 emissions?

Neither EPA nor the State 

has made such a finding.

93.102(b)(3) Has the EPA or the State 

made a finding that reentrained road dust is a 

significant contributor to the 

PM mobile emissions?

Neither EPA nor the State 

has made such a finding.

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 

maintenance plan was

endorsed and submitted as a 

SIP revision by the 

Governor’s designee, the 

Secretary of WVDEP, and a 

notice of public hearing was 

published in the West 

Virginia Register, the 
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Charleston Gazette and the 

Martinsburg Journal on June 

14, 2013. 

Sec. 93.118(e)(4)(ii) Before the attainment 

demonstration was submitted 

to EPA, did consultation 

between federal, State and 

local agencies occur; was full 

implementation plan 

documentation provided to 

EPA, and was 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 budgets are clearly 

identified on pages 41-42 in 

the maintenance plan. 

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 attainment 

demonstrations?

EPA believes the budgets can 

be declared adequate because 

in conjunction with the other 

emission reductions, they 

demonstrate attainment for 

years 2017 and 2025. 

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 Plan?

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 

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 

Yes, the maintenance plan 

provides new MVEBs for 

years 2017 and 2025. The 

addition of safety margins to 

the MVEBs is consistent with 

continued attainment. 
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basis for any changes related 

to emission factors or 

estimates of vehicle miles 

traveled).

Sec. 93.118(e)(5) Did they provide 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 evaluation of the MVEBs contained in WVDEP’s August 5, 2013

submittal of the maintenance plan to satisfy the requirements of the 1997 PM2.5 NAAQS, we find 

the MVEBs to be adequate for conformity purposes and recommend that the MVEBs be SIP 

approved. 

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