1 

### UNITED STATES ENVIRONMEN TAL PROTECTION AGENCY

REGION 10

SUBJECT: Technical Support Document for Review of the Clean Data Motor Vehicle Emissions Budgets (MVEBs) for Fine Particulate Matter (PM 2.5 

### ) and Nitrogen Oxide (NO

x 

### ) for the Tacoma-Pierce County Fine Particulate Matter Nonattainment Area (Tacoma-Pierce County Area)

FROM: Jeff Hunt <signed 6/28/2013> Air Planning Unit

TO: Administrative Record of the U.S. Envi ronmental Protection Agency’s Review of the Clean Data Motor Vehicle Emissions Budgets (MVEBs) for Fine Particulate Matter (PM 2.5 

### ) and Nitrogen Oxide (NO

x 

### ) for the Tacoma-Pierce County Fine

Particulate Matter Nonattainment Area (Tacoma-Pierce County Area)

I. Background

The Environmental Protection Agency (EPA) designated the Tacoma-Pierce County Area as

nonattainment for the 2006 24-hour PM 2.5 

### National Ambient Air Qual ity Standard (NAAQS) on November 13, 2009 (74 FR 58688). On September 4, 2012, the EPA determined that the monitors in the Tacoma-Pierce County Ar ea showed attainment of the 2006 24-hour PM 2.5 

### standard based on ambient air monitoring data for 2009, 2010, and 2011 (77 FR 53772). Additional monitoring data for 2012 shows continued attainme nt with a preliminary 2010-2012 design value of 28 μg/m 3 

### . On November 29, 2012, the U.S. Environmental Protection Agency (EPA) Region 10 received from the Washingt on State Department of Ecology (Ecology) a request for approval and esta blishment of MVEBs for PM 2.5 

### and NO

x 

### for the Tacoma-Pierce County Area. In accordance with the transportati on conformity rule (77 FR 14982), a clean data area may choose to satisfy the regional conformity test by using on-road emissions from the most recent year of clean data as the budget. Ecology selected the year 2011 on-road emissions as the

MVEB.

II. Transportation Conformity Requirements

The Federal Clean Air Act Amendments (CAA) of 1990 established "transportation conformity". Federal and Washington State transportation conformity regulations require evaluation of emissions from transportati on plans, programs, and projects before they are implemented. These requirements apply to ozone, carbon monoxide, particulate matter, and nitrogen dioxide areas designated by EPA as nonattainment or maintenance.2 

### Transportation conformity addres ses air pollution from on-road mobile sources, which include cars, truck, and transit. The Federal 1990 CAA require that Federal funding and approval are given to transportation activities that are consistent with ai r quality goals. Transportation conformity links transportation and air quality planning processes, ensuring that the State Implementation Plan (SIP) achieves its goal to pr otect public health. Conforming to a SIP means that transportation activities wi ll not cause or contribute to any new violation, increase the frequency or severety of any exis ting violation, or delay the timely attainment of any air quality standard in any area.

Transportation plans and transportation impr ovement programs (TIPs), Federally funded projects, and regionally significant non-Federal projects ar e subject to transpor tation conformity. The SIP allocates emissions reductions among hi ghway and non-highway sources and creates an "emissions budget" for highway sources. Conform ity ensures the SIP budget as a ceiling, not to be exceeded. The US DOT, which includes the Federal Highways Administration (FHWA) and the Federal Transit Administration (FTA), and the metropolitan planning organizations (MPO) are responsible for transportation conformity. The MPO estimates emissions from all highway projects included in the tran sportation plan and TIPs. The FHWA and FTA approve the transportation plan, the TIPs, and the use of Fede ral funds for all Federally funded projects in the transportation plan and TIP. The US EPA determin es the adequacy of the emissions budget. In Washington State, the US EPA and the Wash ington Department of Ecology provide a

consultation role to the US DOT and MPO.

In accordance with the transportation conformity regulations at 40 CFR 93.102(b)(1) and (2)(iv) and (v), only MVEBs for PM 2.5 

### and NO

x 

### for the 2011 attainment year are applicable for meeting conformity requirements in the Tacoma-Pierce C ounty Area. The transportation conformity rule requires that before a state implementation plan is submitted the area must address direct PM 2.5 

### emissions and must also address NOx emissions unless EPA and state have made a finding that transportation-related emissions of NOx are not a significant contributor to the area’s PM 2.5 

### problem. Therefore, the state ha s requested that motor vehicle emissions budgets be established

for on-road emissions of direct PM 2.5 

### and NOx. With regard to the remaining PM 2.5 

### precursors (VOCs, SO 2 

### and NH 3 

### ) the transportation conformity rule indicates that before a SIP is submitted these precursors must be addressed only if eith er EPA or the state air agency makes a finding that on-road emissions of any of these precursor s is a significant contributor to the area’s PM 2.5 

### problem. Neither EPA nor the state air agency ha s made such a finding with regard to any of these precursors. Therefore, consistent with the transportation conformity rule, the state did not request that motor vehicle emissions budgets be established for VOCs, SO 2 

### or NH 3



### .

As described in 40 CFR 93.109(c)(5) of the trans portation conformity rule and the preamble of the Transportation Conformity Restructuri ng Amendments (77 FR 14982, March 14, 2012), any

nonattainment area that EPA determines has air quality monitoring data that meet the requirements of 40 CFR parts 50 and 58 and that show attainment of a NAAQS (clean data), must satisfy one of the following requirements: (1) the budget test and/or interim emissions tests as required by section 93.118 a nd 93.119; (2) the budget test as required by section 93.118, using the adequate or approved motor vehicle emissions budgets in the submitted or applicable control3 

### strategy implementation plan for the NAAQS for which the area is designated nonattainment; or (3) the budget test as required by section 93.118, using the motor vehicle emissions in the most recent year of attainment as motor vehicle emi ssions budgets, if the stat e or local air quality agency requests that the motor vehicle emissions in the most recent year of attainment be used as budgets, and EPA approves the request in the rule making that determines that the area has attained the NAAQS for which the area is designated nonattainment. The Tacoma-Pierce County Area may establish MVEBs under 40 CFR 93.109(c)(5)(iii) based upon EPA’s determination of clean data, Ecology has not submitted a maintenance plan, and EPA has determined (through the Clean Data rulemaking) that the Tacoma-Pierce County Area is not subject to the CAA reasonable further progress and attainment demonstr ation requirements.

Table 1 below demonstrates how the document prepared by Washington State satisfies the requirements for clean data MVEBs.

TABLE 1. EPA’S EVALUATION OF THE CLEAN DATA MOTOR VEHICLE EMISSIONS

BUDGETS SUBMITTED BY THE WASHINGTON DEPARTMENT OF ECOLOGY FOR

THE TACOMA-PIERCE COUNTY AREA TO EPA ON NOVEMBER 28, 2012

CRITERIA APPLICABLE TO CLEAN DATA BUDGETS

SECTION

OF

40 CFR PART

93 CRITERIA Y/N COMMENTS

93.110 Are the budgets based upon the latest planning assumptions? Y All planning assumptions used were the latest available. The highway mobile source emission inventory was developed using available travel data and EPA’s

MOVES emission model. A mix of local

data and national default data was used for this analysis (based on EPA’s MOVES technical guidance). Local data was used for the primary data items that have a significant impact on emissions. These include the following: vehicle miles of travel (VMT) by vehicle type, average speed distribution, vehicle type mixes, source type population (for light-duty vehicles), vehicle age distribution, hourly distributions, meteorology data, Inspection/Maintenance program, and fuel supply. Most local data inputs to the analysis process reflect the latest planning assumptions based on 2011 data obtained from the Washington Department of4 Transportation (WDOT), the Bureau of Motor Vehicles, and other local/national

sources.

93.111 Are the budgets based upon the latest emissions

model? Y The inventory reflects the highway mobile source emission estimations using EPA’s MOVES2010b emission model, the most up to date model available. EPA’s MOVES model was officially released on March 2,

2010 and was followed with a revised version, MOVES2010a, in August 2010, and MOVES2010b in April 2012. MOVES has been integrated with local traffic, vehicle fleet, environmental, fuel, and control strategy data to estimate emissions. The MOVES inputs that were prepared included vehicle type VMT, vehicle population, VMT fractions, average speed distributions, road type distribution and ramp fractions. These files were input into the MOVES county data importer. Additional inputs included fuel and vehicle ages, as well as temperatures and I/M programs.

93.118 Did the state or local air quality agency request that

the motor vehicle

emissions in the most recent year of attainment be used as budgets, and did EPA approve the request in the rulemaking that

determines that the area has attained the NAAQS

for which the area is designated nonattainment? Y Ecology requested for approval and

establishment of MVEBs for PM 2.5 and

NO

x for the Tacoma-Pierce County Area for the attainment year 2011. EPA

determined clean data for the TacomaPierce County Area on September 4, 2012 for meeting the 2006 24-hour PM 2.5 NAAQS (77 FR 53772). MOVES was executed to provide a highway mobile source emission inventory. For the 2006

24-hour PM 2.5 NAAQS for the TacomaPierce County Area, the highway vehicle

emissions of direct PM 2.5 and NO

x for the analysis year 2011 are listed below:

2011 Emissions (pounds per winter day) 3,002 (PM 2.5 ) 71,598 (NO

x )5 93.118(e)(4)(i) Was the request for the

establishment of the clean data budgets endorsed by the Governor (or his or her designee)? Y Letter addressed to Dennis M. McLerran, Regional Administrator, EPA Region 10 from Ted Sturdevant, Director, Washington State Department of Ecology.

93.118(e)(4)(ii) Before the request that clean data budgets be

established 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; Y Letter addressed to Ted Sturdevant, Director, Washington State Department of Ecology from Puget Sound Regional Council. EPA Region 10 was part of the consultation process and raised no

concerns.

93.118(e)(4)(iii) Were the motor vehicle emissions budget(s) (MVEBs) clearly identified and precisely quantified? Y The submittal provides emission tables for the Tacoma-Pierce County Area for analysis year 2011.

93.118(e)(4)(iv) Are the motor vehicle emissions budget(s), when considered together with all other emissions sources, consistent with applicable requirements for

attainment? Y EPA believes that the MVEBs are consistent with the applicable requirements for attainment because the budgets are

based on the motor vehicle emissions in the most recent year of attainment and EPA

has made a determination of clean data for the Tacoma-Pierce County Area meeting

the 2006 24-hour PM 2.5 NAAQS, based on ambient air monitoring data for 2009, 2010, and 2011.

93.118(e)(4)(v) Are the motor vehicle emissions budget(s) consistent with and clearly

related to the emissions inventory and the control

measures in the submitted conformity analysis? Y EPA believes that the motor vehicle emissions are clearly related to the emissions inventory. The most recent control measures approved to curtail PM 2.5 emissions in the Tacoma-Pierce County

Area address residential wood combustion and have no impact on state or local motor

vehicle related control measures.6 93.118(e)(4)(vi) Revisions to previously

submitted maintenance plan: 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). N/A This section does not apply because the budgets are not being established through

an attainment demonstration or maintenance plan. The newly established MVEBs are clean data budgets and are not required to be submitted with an attainment demonstration or a maintenance plan.



### CONCLUSION

Based upon our review and evaluatio n of the clean data MVEBs estimated in the Tacoma-Pierce County Area analysis, the EPA finds that the conformity analysis meets the requirements of the CAA and the applicable regulati ons promulgated at 40 CFR part 93. Therefore, the EPA is proposing to approve the establis hment of the clean data MVEBs for the year 2011 for the Tacoma-Pierce County Area 

### . The development methodology of the MVEBs is consistent with applicable guidance documents intended for th e development of on-road inventories and MVEBs. EPA reviewed the ambient air monitoring data for 2009, 2010, 2011, and 2012 and

determined clean data for the Tacoma-P ierce County Area, meeting the 2006 24-hour PM 2.5 

### NAAQS. As a result, the Tacoma-Pierce County Area may establish MVEBs under 40 CFR 93.109(c)(5)(iii). By establishing clean data MVEBs, the Puget Sound Regional Council, the 

### Metropolitan Planning Orga nization for the Tacoma-Pierce County Area, can compare emissions estimated for future transportation planning to the 2011 clean data MVEBs that were developed using MOVES.