UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street· 

Philadelphia, Pennsylvania 19103 

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

Emissions Budgets in the 1997 Fine Particulate Matter (PM2.s) National Ambient 

Air Quality Standard (NAAQS) Maintenance Plan for the Maryland Portion of the 

Martinsburg-Hagerstown, WV -MD 1997 PM2.s Nonattainment Area 

FROM: Gregory Becoat ~- t\ 1 ~ /1 ~ Office of Air Program Planning (3AP30) 

/1 /1 --J //7 f7 yjs 1 1~1 AsrahKhadr 

Office of Air Program 

L;Cv~ 

Planning (3AP30) 

~ 

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

Emissions Budgets in the 1997 Fine Particulate Matter (PM2.s) National Ambient 

Air Quality Standard (NAAQS) Maintenance Plan for the Maryland Portion of the 

Martinsburg-Hagerstown, WV -MD 1997 PM2.s Nonattainment Area 

THRU: Cristina Fernandez, Associate Director 

Office of Air Program Planning (3AP30) 

I. Background 

On January 5, 2005 (70 FR 944, 1014), the Environmental Protection Agency (EPA) published 

air quality area designations for the 1997 PM2.s NAAQS. In that rulemaking action, EPA 

designated the Martinsburg-Hagerstown, WV-MD Area as nonattainment for the 1997 annual 

PM2.s standard. On January 10, 2012 (77 FR 1411), it was determined that the MartinsburgHagerstown WV -MD 1997 PM2.s NAAQS Nonattainment Area had attained the 1997 annual 

PM2.s NAAQS by their applicable attainment date of AprilS, 2010. The MartinsburgHagerstown, WV-MD 1997 annual PM2.s N onattainment Area consists of Washington County in 

Maryland and Berkley County in West Virginia. Additional background information about the 

Maryland portion of the Martinsburg-Hagerstown, WV-MD 1997 PM2.s NAAQS Nonattainment 

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

II. Transportation Conformity Requirements 
Transportation conformity is required under section 176(c) of the Clean Air Act (CAA) to ensure 

that federally supported highway, transit projects, and other activities are consistent with 

(conform to) the purpose of the State Implementation Plan (SIP). The CAA requires federal 

actions in nonattainment and maintenance areas to "conform to" the goals of SIP. This means 

that such actions will not cause or contribute to violations of a NAAQS; worsen the severity of 

an existing violation; or delay timely attainment of any NAAQS or any interim milestone. 

Actions involving Federal Highway Administration (FHW A) or Federal Transit Administration 

(FTA) funding or approval are subject to the Transportation Conformity Rule (40 CFR part 93, 

subpart A). Under this rule, metropolitan planning organizations (MPOs) in nonattainment and 

maintenance areas coordinate with state air quality and transportation agencies, EPA, FHW A, 

and FT A to demonstrate that their metropolitan transportation plans and transportation 

improvement plans (TIPs) conform to applicable SIPs. This is typically determined by showing 

that estimated emissions from existing and planned highway and transit systems are less than or 

equal to the MVEBs contained in a SIP. 

For 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) 

Maryland Department of the Environment (MDE) utilized MOVES2010a to produce MVEBs for 

:years 2017 and 2025. To utilize the MOVES2010a model, several different models were used to 

provide the necessary inputs into MOVES20 1 Oa. One of the models, PPSUITE, was utilized to 

provide inputs as well as to post-process the output files from MOVES2010a. 

The appropriate traffic related inputs which were processed by PPSUITE were input into 

MOVES2010a. Additional traffic related inputs as well as non-traffic related inputs were 

provided as well. The data was input into MOVES2010a via the county data manager. The 

county data manager is a function of the MOVES2010b model which allows county specific data 

inputs to be converted into a usable form by MOVES20 1 Ob. At that point a RunSpecification 

(RunSpec), which is a function ofMOVES2010b that allows the user to input necessary 

parameters into the model, was created and run in batch mode. The outputs were provided as an 

inventory because vehicle miles traveled (VMT) and vehicle population were provided to 

2 
MOVES2010b. 

EPA reviewed the modeling methodology utilized by MDE and all modeling related information 

to produce the MVEBs for years 2017 and 2025. EPA found that all necessary and required 

modeling procedures were followed in the production of the 2017 and 2025 MVEBs which were 

produced using MOVES2010a. 

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 a notice of proposed rulemaking (NPR) for a 30-day public comment period 

soliciting public comment for the approvability of the State of Maryland's SIP submission. The 

NPR also proposes approval of the MVEBs for milestone year 2017 and the out-year 2025 for the 

Maryland portion ofthe Martinsburg-Hagerstown, WV-MD 1997 PM2.s Nonattainment Area for 

PM2.s and nitrogen oxides (NOx). 

On February 12,2014, notices were posted on EPA's web site located at: 

http://www.epa.gov/otag/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 Maintenance 

Plan for the Maryland portion of the Martinsburg-Hagerstown WV-MD, 1997 PM2.s 

Nonattainment Area. The purpose of the notice is to inform the public ofthe availability of the 

Maintenance Plan 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. 

This TSD will be an enclosure to the letter from EPA to MDE informing of EPA's findings on 

the MVEBs within the Maintenance Plan. EPA will publish a Federal Register notice 

announcing the adequacy findings. The effective date of the adequacy findings will be 15 days 

after the publication date ofthat notice. Once EPA has published the Federal Register notice, the 

letter sent to MDE and this TSD will also be posted at the EPA website. 

Shown in Table 1 are the budgets from the Maintenance Plan. The MVEBs in Table 1 for 

milestone year 2017 and the out-year 2025 for PM2.s and NOx will be applied to all future 

tninsportation conformity determinations and analyses for the 1997 annual PM2.s NAAQS. 

3 
i . 

Table 1. On-Road MVEBs Contained in the Maryland portion of the MartinsburgHagerstown, WV-MD 1997 PM2.s Nonattainment Area Maintenance Plan for the 1997 

PM2.sNAAQS 

Year Motor Vehicle Emissions Mobile Vehicle Emissions 

Budget for PM2.s On-Road Budget for NOxOn-Road 

Emissions (tons per year) Emissions (tons _ger _y_ear) 

2017 149.63 4,057.00 

2025 93.35 2,774.63 

V. Evaluation of the Adequacy of the MVEBs in the Maintenance Plan for the 1997 PM2.s 

NAAQS 

In this TSD, we are evaluating the MVEBs associated with the Maintenance Plan 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 2, below. 

Table 2. Adequacy of the MVEBs Contained in the Maintenance Plan for the 1997 PM2.s 

NAAQS 

Transportation Conformity Review Criteria Was the Criterion Satisfied? 

Rule If Yes How was this Criteria 

40 CFR Part 93, 93.118 Satisfied? 

93.102(b)(2)Qv) Have EPA and the State Neither EPA nor the State 

made a finding that N Ox is have made such a finding. 

an insignificant contributor 

to the direct mobile PM 

emissions? 

93.1 02(b )(2)(v) Has EPA or State made a Neither EPA nor the State 

finding that VOCs, Sulfur have made any findings that 

Oxides (SOx) or Ammonia VOCs, SOx, or NH3 are 

(NH3) as precursors to be a significant contributors to the 

significant contributor to the PM2.s mobile emissions, and 

mobile PM2.s emissions? therefore, they have not been 

included in the SIP. 

93.102(b)(3) Has the EPA or the State Neither EPA nor the State 

made a finding that re- have made such a finding. 

entrained road dust is a 

significant contributor to the 

PM mobile emissions? 

4 
Sec. 93.118(e)(4)(i) Was the submitted revised Yes. The submitted 

plan endorsed by the Maintenance Plan was 

Governor (or his or her endorsed and submitted as a 

designee) and subject to a SIP revision by the 

State public hearing? Governor's designee, the 

Secretary of Maryland 

Department of the 

Environment. A public 

hearing on the SIP proposal 

was held on October 8, 2013 . 

Sec. 93.118(e)(4)(ii) Before the maintenance plan Yes. Consultation has 

was submitted to EPA, did occurred among all required 

consultation between federal, federal, state and local 

State and local agencies agenctes. 

occur; was full 

implementation plan 

documentation provided to 

EPA, and was EPA's stated 

concerns, if any, addressed? 

Sec. 93.118(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly 

emissions budget(s) clearly identified on pages 23-24 of 

identified and precisely the Maintenance Plan 

quantified? prepared by the Maryland 

Department of the 

Environment. 

Sec. 93.118(e)(4)(iv) Is the motor vehicle EPA believes the budgets can 

emissions budget( s ), when be declared adequate because 

considered together with all in conjunction with the other 

other emission reductions, emission reductions, they 

consistent with applicable demonstrate continued 

requirements for maintenance for years 201 7 

maintenance? and 2025. 

Sec. 93.118(e)(4)(v) Is the motor vehicle EPA believes that the budgets 

emissions budget(s) are clearly related to the 

consistent with and clearly emissions inventory and the 

related to the emissions control measures in the SIP 

inventory and the control submittal. 

measures in the Plan? 

Sec. 93.118(e)(4)(vi) Revisions to previously Yes, the Maintenance Plan 

submitted attainment provides new MVEBs for 

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demonstrations: explain and years 2017 and 2025. The 

document any changes to addition of safety margins to 

previously submitted budgets the MVEBs is consistent with 

and control measures; continued attainment. 

impacts on point and area 

source emissions; any 

changes to established safety 

margins (see Sec. 93 .1 0 1 for 

definition); and reasons for 

the changes (including the 

basis for any changes related 

to emission factors or 

estimates of vehicle miles 

traveled). 

Sec. 93.118(e)(5) Did they provide and we Yes 

review public comments and 

the State's responses to those 

comments with the submitted 

control strategy SIP? 

VI. Findings 

Based upon our review and evaluation of the MVEBs contained in the Maintenance Plan for the 

Maryland portion of the Martinsburg-Hagerstown, WV-MD 1997 PMz.s NAAQS Nonattainment 

Area, EPA finds the MVEBs adequate for conformity purposes and recommends that the MVEBs 

be SIP approved. 

6 
MDES Summers____,,..----,--

MDEDS Kinsey tkldf< 

MDEDS Costello ---::::l..,....,.=-::--

MDEARMA Aburn ~ 

Date: 26-Nov-13 

MARYLAND DEPARTMENT OF THE ENVIRONMENT 

OFFICE OF THE SECRETARY 

TRACKING SHEET 

ISSUE/DESCRIPTION: The attached State Implementation Plan requests that the United States 

Environmental Protection Agency (USEPA) redesignate the Washington County, MD 1997 fine particulate 

(PM2.5) matter nonattainment area to attainment for this standard pursuant to the provisions under§ 107 of the 

federal Clean Air Act (CAA). We are also requesting that USEPA concurrently approve, as a revision to the 

state implementation plan (SIP), the related§ 175A maintenance plan. This plan ensures that good PM2.5 air 

quality will be maintained through 2025. 

PRINCJP AL ADMINISTRATION/LEADER: ARMA/ Aburn/Fr~fs/Hug 

PURPOSE OF SUBMITTING TRACKING SHEET TO SECRETARY'S OFFICE: Request signature to 

submit the SIP to USEP A. 

BACKGROUND ON ISSUE (IDENTIFY CONTROVERSIES): Since the designations for the National 

Ambient Air Quality Standards (NAAQS) for this pollutant were published (Federal Register, Vol. 70, No.3, 

1/5/2005), the area's PM2.5 air quality has improved due to permanent and enforceable emission reductions. Air 

quality in the area is significantly better than required by this standard. Due to the improvement in PM2.5 air 

quality, the USEPA finalized a clean data determination for the Washington County area on February 9, 2012 

(Federal Register, Vol. 77, No.6, 1/10/2012). 

RECOMMENDATIONS FOR SECRETARY'S ACTIONS: Please sign the enclosed submittal letter and 

return to ARMA Planning. 

PERMIT/ENFORCEMENT IMPLICATIONS (IF APPLICABLE): N/ A 

SMART GROWTH IMPLICATIONS (IF APPLICABLE): N/A 

INTERESTED PARTIES OR GOVERNMENTS, ETC.: USEPA, MDOT, local governments, West 

Virginia, The Hagerstown I Eastern Panhandle Metropolitan Planning Organization, environmental 

organizations, businesses, and citizen's groups. 

DUE DATES OR MILESTONES: 

SECRETARY'S COMMENTS: