### ILLINOIS ENVIRONMENTAL

# PROnCIIO~ ACENCY

1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276. (217) 782-2829 James R. Thompson Center, 100 West Randolph, Suite 11-300, Chicago, IL 60601 • (312) 814-6026

PAT QUINN, GOVERNOIZ DOUGLAS P. SCOTT, DIRECTOR

217/782-7326 217/782-9143 (TDD)

May 26, 2010

Dr. Susan Hedman, Regional Administrator Office of the Regional Administrator, R-19J U. S. Environmental Protection Agency, Region 5 77 West Jackson Boulevard Chicago, Illinois 60604-3507

Re: 8-hour 

### Ozone Redesignation Request for Metro-East

Dear Dr. Hedman: 

### RECEIVED 

## JUN 0 1 

## 2010

LJ.':::'.

__ •.

_ OFFICE OF REGIONAL ADMINISTRAl'OR

The Illinois Environmental Protection Agency (Illinois EPA), on behalf of the State of Illinois, hereby requests that the Illinois portion of the St Louis ozone non attainment area, known as the Metro-East area, be redesignated to attainment of the 8-hour ozone standard promulgated in 1997

_ The Metro-East portion of the ozone nonattainment area consists of Madison, Monroe, St Clair, and Jersey counties in Illinois. The Illinois EPA understands that the State of Missouri is making a similar redesignation request. Ambient air monitoring data collected by the Illinois EPA in the Metro-East area from 2007 through 2009, as well as data collected in Missouri, demonstrates that the entire St. Louis nonattainment area is currently meeting the 1997 8-hour

ozone National Ambient Air Quality Standard (NAAQS). In addition, the Metro-East area has
met all of the relevant requirements under Section 107, Section 110, and Part D of the Clean Air Act (CAA), with the exception of revised RACT rules for certain source categories which will be submitted soon.

The Illinois EPA hereby submits a Maintenance Plan for the Metro-East ozone nonattainment

area pursuant to Sections 107(d)(3)(E), 11O(a)(2), and 175A of the CAA. Also included are revised year 2020 motor vehicle emissions budgets developed using the MOBILE model. The Maintenance Plan SIP submittal and the motor vehicle emissions budgets are required as part of the Illinois EPA's redesignation request. The Maintenance Plan provides the supporting information for this request, consistent with the criteria for redesignation set forth in Section l75A of the CAA.

The Maintenance Plan constitutes a revision of Illinois' SIP for ozone. Accordingly, the Illinois EPA held a public hearing in Collinsville on April 8, 2010, to accept comments on the draft Maintenance Plan. The Illinois EPA received no comments at the hearing or during the subsequent 30 day comment period.

Rockford. 4]02 N. Main St., Rockford, IL 61103 • (815) 987,7760 Elgin. 595 S. Stale, Elgin, IL 60123

.. (847) 608-3131 Bureau of land

- Peoria. 7620 N.**Univer~ity** 5t., Peoria, Il 61514. (309) 693-5462 Collinsville" .2009 Mall Slreet, Collinsville, IL 62234 • (618) 346-5120 1 Des Plaines. 9511 W. H'lrrison St., Des Plaines, IL 60016

- (847) 294-4000 Peoria- 5415N. University St., Peoria, IL 61614

- (309) 693-5463 Champaign

_ 2125 S. Fir5l SI., Champaign, il61820

- (217) 278-5800 Marion

- 2309 W. Main St., Suite 116, Marion, IL 62959

- (618) 993-7200

Prilllcd ot". Rc(:yclcd PUpelIn order to assist with your review of the Metro-East Maintenance Plan SIP submittal, the Illinois EPA has included the following documents:

Attachment I)

Attachment 2)

Attachment 3)

Attachment 4)

Attachment 5) Draft Maintenance Plan for the Metro-East Ozone Nonattainment Area for the 1997 8-Hour Ozone National Ambient Air Quality Standard, AQPSTR 10-01, Illinois EPA, February 24, 2010.

Notice of Public Hearing, March 5, 2010.

Hearing Sign-in Sheet.

Transcript of Public Hearing held on April 8, 2010.

Final Maintenance Plan for the Metro-East Ozone Nonattainment Area for the 1997 8-Hour Ozone National Ambient Air Quality Standard, AQPSTR 10-01, Illinois EPA, May 20, 2010.

Illinois EPA believes that this submittal, in conjunction with other submittals made to the United States Environmental Protection Agency (U.S. EPA) (e.g., attainment plan, rate of progress plan, and RACT submittals), will allow the U.S. EPA to expeditiously take the necessary actions to redesignate the Metro-East area to attainment for the 1997 8-hour ozone National Ambient Air Quality Standard.

If further information is required or should you have any questions, please feel free to contact Laurel L. Kroack, Chief of the Bureau of Air.

Very truly yours,

Attachments

cc: Cheryl L. Newton, U.S. EPA Region 5

2

# DRAFT

Maintenance Plan for the Metro- East Ozone N onattainment Are<i for the 1997 8- Hour Ozone National Ambient Air Quality Standard

AQPSTR 10-01

February 24, 2010

Illinois Environmental Protection Agency 1021 North Grand Avenue East Springfield, Illinois 62794-9276

.. 1 •• 1.

Attachment III

### i TABLE OF CONTENTS

Page

LIST OF TABLES . . . . . . . . . iii

LIST OF FIGURES . . . . . . . . . iv

EXECUTIVE SUMMARY

. . . . . . . . 5

1.0 INTRODUCTION . . . . . . . . 6 1.1 Regulatory Background . . . . . . 6 1.2 Status of Air Quality . . . . . . . 8

2.0 REDESIGNATION AND MAINTEN ANCE PLAN REQUIREMENTS 9

3.0 OZONE MONITORING . . . . . . . 11 3.1 Monitored Design Values . . . . . . 11 3.2 Quality Assurance . . . . . . . 13 3.3 Continued Monitoring . . . . . . 13

4.0 EMISSIONS INVENTORY . . . . . . . 14 4.1 Attainment Year Inventory – 2008 . . . . . 14 4.2 Air Quality Improvements and Emissions Controls . . . 15 4.3 Emissions Projections . . . . . . . 16 4.4 Demonstration of Maintenance . . . . . 16 4.5 Provisions for Future Updates . . . . . 17

5.0 CONTROL MEASURES AND REGULATIONS . . . 18 5.1 Attainment Demonstration Control Measures . . . 18 5.2 Reasonable Further Progress (RFP) . . . . 19 5.3 Reasonably Available Contro l Technology (RACT) . . . 19 5.4 Controls to Remain in Effect . . . . . . 20 5.5 Provisions for Permitting New or Modified Emissions Sources . 21 5.6 Transportation Conformity . . . . . . 21

6.0 CONTINGENCY MEASURES . . . . . . 23 6.1 Contingency Measures . . . . . . 23 6.2 Commitment to Revise Plan . . . . . . 25 6.3 Public Participation . . . . . . . 25 6.4 Legal Authority to Implement and Enforce . . . . 26

7.0 CONCLUSIONS . . . . . . . . 27

### ii TABLE OF CONTENTS (Continued)

APPENDIX A Summary of Am bient Air Monitoring Data (2007-2009)

APPENDIX B Transportation Conformity

### iii LIST OF TABLES

Page

Table 4.1 2008 Metro-East Ozone Nonattainment Area VOM and NOx Emissions . . . . . . 14

Table 4.2 2002 Metro-East Ozone Nonattainment Area VOM and NOx Emissions . . . . . . 15

Table 4.3 2013 Metro-East Ozone Nonattainment Area VOM and NOx Emissions . . . . . . 16

Table 4.4 2020 Metro-East Ozone Nonattainment Area VOM and NOx Emissions . . . . . . 17

Table 4.5 Comparison of 2008, 2013, and 2020 Emissions Estimates Metro-East Nonattainment Area . . . . . 17

Table 5.1 Proposed 2008 and 2020 Motor Vehicle Emissions Budgets Metro-East Nonattainment Area 8-H our Ozone Maintenance Plan. . 22

Table 6.1 Contingency Plan for the Metro-East 8-Hour Ozone Nonattainment Area . . . . . . . 24

### iv LIST OF FIGURES Page

Figure 1.1 8-Hour Ozone Nonattainment Ar ea St. Louis, MO-IL. . . 7

Figure 3.1 Ozone Monitors in the St. Louis Metropolitan Area . . . 11

Figure 3.2 Comparison of 8-Hour Ozone Design Values for the St. Louis Region Between 2001-2003 and 2007-2009 . . 12

### 5 EXECUTIVE SUMMARY

This document describes Illinois’ Maintenan ce Plan for the Illinoi s portion of the St. Louis ozone nonattainment area (NAA), hereafter referred to as the Metro-East NAA. A Maintenance Plan is required before an ar ea can be redesignated fr om nonattainment to attainment of a National Ambient Air Qua lity Standard (NAAQS). This document provides technical information required to s upport a request to redesignate the MetroEast NAA to attainment of the 1997 8-hour ozone NAAQS. Illinois intends to submit such a request to the U.S. Environmental Protection Agency (U.S. EPA). The Illinois Environmental Protection Agency (Illinois EPA) has prepared this plan in consultation with the Missouri Department of Natural Resources (MDNR) and the U.S. EPA. The MDNR is preparing a similar plan for the Missouri portion of the St. Louis nonattainment

area.
Ozone air quality has dramatically improve d in the St. Louis region as a result of implementation of State and Fe deral control measures sin ce the designation of the St. Louis area as nonattainment in 2004. The entire St. Louis nonattainment area has at least three years of complete, quality assured ambient air quality monitoring data for 2007- 2009 that demonstrates compliance with the 1997 8-hour ozone NAAQS. These air quality improvements are due to permanent and enforceable emissions control measures.

This Maintenance Plan provides for continue d attainment of the 1997 8-hour ozone air quality standard for the Metro-East nonattainment area for a period of ten years after U.S. EPA has formally redesignated the area to attain ment. The Plan also provides assurances that, even if there is a subse quent violation of the air quality standard, measures listed in the Plan will prevent any future occurrences through contingency measures that would be triggered upon such an occurrence. Finall y, the Plan includes on-road motor vehicle emissions budgets for the years 2008 and 2020 for use in transpor tation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of the 8- hour ozone standard during the ten-year maintenance period.

### 6 1.0 INTRODUCTION

This document describes Illinois’ 8-hour oz one Maintenance Plan for the Metro-East NAA. This Maintenance Plan is required before the area can be redesignated from nonattainment to attainment of the National Ambient Air Quality Standard (NAAQS) for ozone promulgated by the U.S. Environmenta l Protection Agency (U.S. EPA) in 1997. Illinois intends to submit such a request to the U.S. EPA in conjunction with this Maintenance Plan. The Illinois EPA has prep ared this plan in consultation with the Missouri Department of Natural Resources (MDNR) and U.S. EPA. The MDNR is preparing a similar plan for the Missouri portion of the St. Louis nonattainment area. The entire St. Louis nonattainment area has at least three years of complete, quality assured ambient air quality monitoring data for 2007- 2009, demonstrating a ttainment with the 0.080 ppm 8-hour ozone NAAQS promulgated in 1997.
This document provides the technical information needed to support a request to redesignate the St. Louis area to attainment. Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for a nonattainment area to be considered for redesignation. Before an area can be reclassified to attainment, U.S. EPA must make a determination that the area ha s attained the NAAQS based on at least three complete years of ambient monitoring data . U.S. EPA must have approved a State Implementation Plan (SIP) for the area under Section 110 and Part D of the CAA. The state must demonstrate that the improvement in air quality is due to permanent and enforceable reductions in emissions resulti ng from implementation of the SIP and other federal requirements. Finally, the state mu st submit, and U.S. EPA must approve, a Maintenance Plan under Section 175(A) of the CAA, including provisions for contingency measures that will be implemen ted if future violations of the NAAQS are measured.
This Maintenance Plan provides for the c ontinued attainment of the 8-hour ozone NAAQS for the Metro-East NAA for a period of ten years after U.S. EPA has formally redesignated the area to attainment. The Plan also provides assurances that even if a subsequent violation of the ozone NAAQS occu rs, provisions in the Plan will prevent any future occurrences through contingency m easures that would be triggered upon such

occurrence.

This document addresses the Maintenance Pl an requirements estab lished by the CAA and U.S. EPA, and includes additional informati on to support continued compliance with the 8-hour ozone NAAQS.
1.1 Regulatory Background
The CAA requires areas that fa il to meet the NAAQS for ozone to develop SIPs to expeditiously attain and maintain the NAAQS . Historically, exceedances of the ozone NAAQS have been monitored in Madison and St. Clair counties in Illinois and in the Missouri portion of the NAA.

The Metro-East NAA, which includes Madison, Monroe, St. Clair, and Jersey counties in Illinois, was originally designated as nonattainment in 2004 pursuant to the 1997

### 7 revisions to the ozone NAAQS. Several c ounties in Missouri were also designated as nonattainment of the 8-hour ozone NAAQS. Figure 1.1 depicts the current St. Louis Missouri-Illinois NAA.



## Figure 1.1

### 8 The following is a list of the counties contai ned in the St. Louis Missouri-Illinois 8-hour ozone nonattainment area:

 Madison County, IL

 St. Clair County, IL

 Monroe County, IL

 Jersey County, IL

 St. Louis County, MO

 St. Louis City, MO

 St Charles, MO

 Jefferson County, MO

 Franklin County, MO

As a result of the nonattainment designa tion and the accompanying classification as moderate, these areas were s ubject to new requirements, in cluding development of a plan demonstrating that the area would meet the federal 8-hour ozone NAAQS by June 15, 2010.

Recognizing the need for a regional soluti on, the States of Illi nois and Missouri have worked cooperatively to jointly develop and evaluate an effective regional attainment strategy to enable the St. Louis region to attain the 8-hour ozone NAAQS. The attainment strategy recognizes the importance of reducing both locally generated ozone precursor emissions, volatile organic material (VOM) and oxides of nitrogen (NOx), as well as incoming (transported) ozone and oz one precursor emissions. The emissions reductions needed to attain the 8-hour ozone NAAQS include both State and Federal measures that have reduced ozone precurs or emissions both loca lly and regionally. These measures have allowed the St. Loui s Missouri-Illinois NAA to attain the 8-hour ozone standard by the attainment d eadline established by the U.S. EPA.

1.2 Status of Air Quality

Ozone monitoring data for the most recent three-year period, 2007 through 2009, demonstrates that air quality has met th e 1997 8-hour ozone NAAQS in the St. Louis Missouri-Illinois NAA. Information regarding the air monitoring netw ork and air quality monitoring data in included in Section 3.0 and Appendix A.

### 9 2.0 REDESIGNATION AND MAIN TENANCE PLAN REQUIREMENTS

Sections 107 and 110 of the CAA list a number of requirements that must be met by nonattainment areas prior to c onsideration for redesignation to attainment. One of those requirements is the development of a Mainte nance Plan, which desc ribes a state’s plan for maintaining the NAAQS for a minimum te n-year period after redesignation to attainment. U.S. EPA has published guidance for the preparation of Maintenance Plans and redesignation requests, c ontained in a document entitled “Procedures for Processing Requests to Redesignate Areas to Attainment” (September 4, 1992).

Before a redesignation to attainment can be promulgated, U.S. EPA must:

 Determine that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must s how that violations of the NAAQS are no longer occurring. This showing must rely on three consecutive years of data. The ambient air monitoring data must be quali ty assured in accordance with 40 CFR 58.10, recorded in U.S. EPA’s Air Quality System (AQS) data base, and made available to the public.

 Approve the state’s plan for demonstrat ing attainment. The attainment plan, which is based on air quality modeli ng, must contain enforceable control measures and must be submitted as a re vision to the state’s SIP after a public hearing.

 Determine that the improvement in air quality between the year violations occurred and the year that attainment was achieved is based on permanent and enforceable emissions reductions.

 Approve the state’s Maintenance Plan. The requirements for the Maintenance Plan are discussed below.

 Determine that all other requirements appl icable to nonattainment areas have been
met.

A Maintenance Plan provides for the con tinued attainment of the 8-hour ozone NAAQS for a nonattainment area for a period of te n years after U.S. EPA has formally redesignated the area to attainment. The plan also provides assurances that even if a subsequent violation of the NAAQS occurs, provis ions in the plan will prevent any future occurrences through contingency measures that would be triggered upon such occurrence. To be approvable, the state is required to have a public hearing on the Maintenance Plan prior to adoption. The Ma intenance Plan must contain the following elements:

 A comprehensive emissions inventory of the precursors of ozone completed for the “attainment year”;

### 10  A projection of the emissions inventory forw ard to a year at least ten years after redesignation and a demons tration that the projected level of emissions is sufficient to maintain attainment of the ozone NAAQS;

 A commitment that, once redesignated, th e state will continue to operate an appropriate monitoring network to verify maintenance of the attainment status;

 A demonstration of legal authority to implement and enforce all control measures contained in the SIP;

 Provisions for future updates of the inve ntory to enable tracking of emissions levels, including an annual emissions statement from major sources;

 Motor vehicle emissions budgets for transp ortation conformity for the ten-year maintenance period;

 A commitment to submit a revised Ma intenance Plan eight years after redesignation;

 A commitment to enact and implement a dditional contingency control measures expeditiously in the event that futu re violations of the NAAQS occur;

 A list of potential contingency measures th at would be implemented in such an
event.

This Maintenance Plan has been prepared in accordance with the re quirements specified in U.S. EPA’s guidance document and additiona l guidance received from U.S. EPA staff.

The following sections of this document de scribe how U.S. EPA’s requirements have been met.

### 11 3.0 OZONE MONITORING
U.S. EPA’s published guidance document, “Procedures for Processing Requests to Redesignate Areas to Attainment” (Septemb er 4, 1992), details specific requirements regarding the collecti on and use of ambient air monito ring data needed to support a redesignation request. Before the Metro-Ea st NAA can be redesignated, Illinois must demonstrate that the 8-hour ozone NAAQS ha s been attained. Ozone monitoring data must show that violations of the NAAQS are no longer occurring within the nonattainment area. This showing must re ly on three complete, consecutive calendar years of quality assured data. Further, the air monitoring data must be quality assured in accordance with 40 CFR 58.10, recorded in U.S. EPA’s AQS data base, and made available to the public. Fi nally, Illinois must commit to continue to operate an appropriate monitoring network to verify the maintenance of the attainment status, once the area has been redesignated.
The following subsections describe how each of these requirements has been addressed.
3.1 Monitored Design Values
Currently there are 11 ozone monitors locate d in the nonattainment counties in the St. Louis region; 6 are located in Missouri and 5 are in Illinois. Miss ouri and Illinois also operate ozone monitors at locations upwi nd and downwind of the metropolitan area. Figure 3.1 shows the locations of these monitors.

Figure 3.1 Ozone Monitors in the St. Louis Area

### 12 To determine whether the NAAQS is being exceeded, the 8-hour ozone design value must be calculated. The current U.S. EPA method for calculating the ozone design value is to average each monitor’s 4 th 

### highest daily maximum 8-hour value for each year over the 3-year period and compare it to the calcu lated design values to the 0.080 ppm (or 85 ppb) level of the NAAQS. The calculated 8-hour ozone design values for the monitors in the St. Louis Missouri-Illinois NAA for 2007-2009 are included as Appendix A of this report. Figure 3.2 compares the design va lues for the 2001-2003 period for monitoring stations in the St. Louis re gion to the corresponding design values from 2007-2009. The data demonstrate that ozone air quality ha s improved dramatically throughout the St. Louis region and that the 1997 8-hour ozone NAAQS has been attained for the 2007- 2009 period at all locations.

Figure 3.2 Comparison of 8-Hour Ozone Design Values (ppb) for the St. Louis Region Between 2001-2003 and 2007-2009

2001-2003 2007-2009

### 13 3.2 Quality Assurance

Illinois EPA has quality assure d all monitoring data shown in Appendix A for all sites located in Illinois in accordance with 40 CFR 58.10 and the Illinois EPA ’s Quality Assurance Plan, which describes Illinois EP A’s standard operating procedures for operating the ambient monitoring network a nd validating the data. The Missouri DNR has a similar quality assurance plan. Illinois EPA has recorded the monitoring data in the U.S. EPA’s AQS database, whic h is available to the public.

3.3 Continued Monitoring

Illinois commits to continue monitoring ozone levels according to a U.S. EPA approved monitoring plan, as required to ensure maintenance of the ozone NAAQS. Should changes in the location of an ozone monito r become necessary, Illinois EPA will work with U.S. EPA to ensure the adequacy of the monitoring network. Illinois EPA will continue to quality assure th e monitoring data to meet the requirements of 40 CFR 58. Illinois EPA will continue to enter all data into AQS on a timely basis in accordance with federal guidelines.

### 14 4.0 EMISSIONS INVENTORY

A redesignation request must c ontain a demonstration that the improvement in air quality between the year that violati ons occurred and the year that attainment was achieved is based on permanent and enforceable emissions reductions. As described previously in Section 3.0, a three-year monitoring period is used to evaluate whether attainment has been achieved. In this Section, the “attainment year” refers to the mid-point year (2008) of the three-year period (2007-2009) used to de monstrate attainment. The request should also include a projection of th e emissions inventory to a year at least 10 years following redesignation, a demonstration that the projected level of emissions is sufficient to maintain the ozone NAAQS, and a commitment to provide future updates of the inventory to enable tracking of emissions le vels during the 10-year maintenance period.

4.1 Attainment Year Inventory, 2008

Illinois EPA has prepared a comprehensive em issions inventory for the Metro-East ozone nonattainment area, including point, area, and on-road and off-road mobile sources for precursors of ozone (VOM and NOx) for the attainment year, 2008. This inventory is based on actual or projected activity levels. Point source information was compiled from 2008 annual emissions reports submitted to the Illinois EPA by emissions sources and the U.S. EPA’s Clean Air Markets Division database for electri c utilities. Area source emissions were calculated using the most recently available methodologies and emissions factors from U.S. EPA along with activity da ta (typically population, employment, fuel use, etc.) specific to 2008. On-road mobile source emissions were calculated using U.S. EPA’s MOBILE6 emissions model with 2008 vehicle miles traveled (VMT) data provided by the Illinois Department of Trans portation (IDOT). Off-road mobile source emissions were calculated for summer 2008 using U.S. EPA’s NONROAD emissions model. Biogenic emissions are not included in these summaries.

Table 4.1 summarizes the 2008 emissions es timates for the Metro-East ozone nonattainment area.

Table 4.1 2008 Metro-East Ozone Nonattainment Area VOM and NOx Emissions (Emissions stated in tons per ozone season weekday) Source Category VOM NOx Point Sources 11.92 39.86 Area Sources 23.21 1.50 On-Road Mobile Sources 16.53 30.84 Off-Road Mobile Sources 12.66 39.25 Total 64.33 111.46

### 15 4.2 Air Quality Improvements and Emissions Controls

The Metro-East area was designated as nona ttainment of the 1997 8-hour ozone NAAQS in 2004, based on ozone air quality monitori ng data collected between 2001 and 2003. Since that time, permanent and enforceable re ductions of ozone precursor emissions have contributed to improvements in ozone air qu ality and to the attainment of the 8-hour ozone NAAQS. Some of these emissions redu ctions were due to the application of tighter federal emissions standards on motor vehicles and fuels, and some due to the requirements of the federal NOx SIP Call. Section 5.0 of this re port describes these reductions in more detail, along with an explan ation of their regulatory status. In this subsection, the 2008 attainment year emissions le vels are compared to the base year 2002 emissions levels.

U.S. EPA’s 8-hour Ozone Implementation Ru le required that states with ozone nonattainment areas prepare and submit a 2002 base year inventory of anthropogenic sources of ozone precursor emissions. This base year inventory in cluded emissions from point, area, on-road mobile and off-road mob ile emissions. Illinois EPA prepared and submitted this inventory in June 2006. Table 4.2 summarizes 2002 emissions by major source category and by pollutant for the Metro-East NAA.

Table 4.2 2002 Metro-East Ozone Nonattainment Area VOM and NOx Emissions (Emissions stated in tons per ozone season weekday) Source Category VOM NOx Point Sources 17.41 53.24 Area Sources 29.86 1.40 On-Road Mobile Sources 23.57 47.07 Off-Road Mobile Sources 12.04 36.79 Total 82.88 138.50

Comparing the 2002 inventory to that for 2008 in dicates that total VOM emissions in the Metro-East area decreased by about 18.55 tons per day (tpd), due largely to reductions from point and on-road mobile sources. NOx emissions in the Metro-East area decreased significantly, about 27.04 tpd, dur ing the same time period. Again, these reductions were primarily from point and on-road mobile source s. These sizeable emissions reductions in ozone precursor emissions, and corresponding reductions in the Missouri portion of the NAA, plus reductions in upwind areas in Illinoi s and other nearby stat es, resulted in a substantial improvement in ozone air quality in the St. Louis area, ultimately resulting in attainment of the 1997 8-hour ozone NAAQS.

### 16 4.3 Emissions Projections

A Maintenance Plan must contain a demonstrat ion that the level of emissions projected for the ten-year period following redesignati on are sufficient to maintain the NAAQS. Accordingly, Illinois EPA has projected VOM and NOx emissions for the Metro-East NAA for 2020. Illinois EPA has also projec ted emissions to 2013, to represent a midpoint during the ten-year maintenance peri od. Emissions for these two projection years are compared to emissions levels in 2008 to determine if emissions are sufficient to maintain the NAAQS during this period.

Metro-East area point and area source emi ssions for 2013 and 2020 were estimated using the 2008 base year inventory a nd growth factors appropriate for each source category. The effect of Illinois’ re cently adopted NOx RACT requirement on NOx emissions in future years was estimated and applied, as appr opriate, to the point source inventory. Off-road emissions projections were developed using the gr owth factors contained in U.S. EPA’s NONROAD model. On-road motor vehicle emissions were estimated using U.S. EPA’s MOBILE6 motor vehicle emissi ons model. The figures assume the continued use of reformulated gasoline, th e continued phase-in of the Tier 2 motor vehicle emissions standards, and operation of an enhanced vehicle inspection and maintenance program. Total vehicle mile s of travel (VMT) for 2013 and 2020 were assumed to increase at a rate of 1.5 percent per year from 2008.

Tables 4.3 and 4.4 include the VOM and NOx emissions estimates for the years 2013 and 2020, respectively, for the Metro-East nonattainment area.

Table 4.3 2013 Metro-East Ozone Nonattainment Area VOM and NOx Emissions (Emissions stated in tons per ozone season weekday) Source Category VOM NOx Point Sources 13.25 32.24 Area Sources 23.22 1.54 On-Road Mobile Sources 9.58 20.70 Off-Road Mobile Sources 10.30 37.80 Total 56.35 92.28

4.4 Demonstration of Maintenance

Table 4.5 demonstrates that the level of em issions projected for the ten-year period following redesignation is sufficient to main tain the ozone NAAQS. As shown in the table, both VOM and NOx emissions within the nonattainment area are expected to decrease significantly between 2008 and 2020. Projected VOM and NOx emissions for the mid-point year, 2013, are also less than the emissions levels in 2008. Based on these emissions trends it is expected that air quality will continue to meet the 1997 8-hour ozone NAAQS throughout the maintenance period.

### 17 Table 4.4 2020 Metro-East Ozone Nonattainment Area VOM and NOx Emissions (Emissions stated in tons per ozone season weekday) Source Category VOM NOx Point Sources 14.73 30.71 Area Sources 25.04 1.56 On-Road Mobile Sources 7.70 10.34 Off-Road Mobile Sources 7.73 33.56 Total 55.20 76.17

Table 4.5 Comparison of 2008, 2013 and 2020 Emissions Estimates Metro-East Nonattainment Area (Emissions stated in tons per ozone season weekday)

2008 2013 Difference (2008 – 2013) 2020 Difference (2008 – 2020)

VOM 64.33 56.35 7.98 55.20 16.28

NOx 111.46 92.28 19.18 76.17 35.29

In addition to the overall emissions re ductions projected to occur within the nonattainment area, significant reductions of statewide NOx emissions resulting from implementation of Illinois’ multi-pollutant st andards affecting electric utilities by 2012, will also help to ensure continued attainment of the 8-hour ozone NAAQS.

4.5 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Illinois commits to submit to U.S. EPA, eight years after redesignation, a revised version of this Ma intenance Plan. The revision will contain Illinois’ plan for maintaining the 8-hour ozone NAAQS for ten years beyond the first 10-year period after redesignation.

### 18 5.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures implemented in the Metro-East nonattainment area, including the measures that were part of Illinois’ Attainment Demonstration, Reasonable Fu rther Progress (RFP) demonstration, CAA requirements, and other state and federal m easures. The control measures required in past ozone SIP revisions have been fully implemented, and other, more recent control programs will continue to provide emissions reductions in future years. Illinois EPA commits to keep these measures in effect af ter redesignation, or to provide equivalent emissions levels using alternate measures. Illinois’ SIP contains acceptable provisions to provide for preconstruction re view of new emissions sour ces. After redesignation to attainment, Prevention of Significant Deterior ation (PSD) requirements will apply to the construction of new major sources and to sign ificant modifications of existing sources. Illinois has accepted delegation from U.S. EPA of this program. Illinois further commits to continue to require that all future tran sportation plans in the St. Louis area conform with the SIP.

5.1 Attainment Demonstration Control Measures

Illinois’ attainment demonstration for th e Metro-East nonattainment area identified control measures that had been promulgated at either the st ate or federal level that are sufficient to allow the region to meet the 1997 8-hour ozone NAAQS by the required attainment date. The attainment demonstration, which was submitted to U.S. EPA after a public hearing and public comment period, is described in the Illinois EPA’s document: “8-Hour Ozone Attainment Demonstration for the Metro-East Nonattainment Area” (Report Number AQPSTR 07-02, June 15, 2007) . The primary emissions reduction measures for demonstrating attainment of the ozone standard are as follows:

 NOx SIP Call and Clean Air Interstate Rule (CAIR)

 New Source Performance Standards (NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHA PS)/Maximum Achievable Control Technology (MACT) Standards

 VOM Solvent Categories: Aerosol Co atings, Architectural and Industrial Maintenance (AIM) Coatings , Consumer Solvents

 Vehicle Inspection & Maintenance Program

 Reformulated Gasoline

 Tier 2 Motor Vehicle Emissions Sta ndards and Gasoline Sulfur Control Requirements

### 19  On-Highway Heavy-Duty Engine and Ve hicle Standards and Highway Diesel Fuel Sulfur Control Requirements

 Federal Emissions Standards for Off-Road Equipment (e.g., Nonroad Diesel Engine Rule, Evaporative Large Sp ark Ignition and Recreational Vehicle Standards) incorporat ed into NONROAD Model

 Tier 4 Nonroad Diesel Engine Standa rds and Diesel Fuel Sulfur Content Restrictions

 Marine Compression-Ignition Engine Standards and Locomotive Engine Standards

 Consent Decrees---Dynegy and ConocoPhillips

5.2 Reasonable Further Progress (RFP)

Since the Metro-East area is classified as a moderate nonattainment area for the 8-hour ozone standard, a 15 percent net reduction in ozone precursor emissions from 2002 levels is required by 2008 in order to meet the RFP requirement. In the Metro-East attainment demonstration, the Illinois EPA relied on NOx substitution to meet the 15 percent RFP reduction requirement.

The control measures identifie d in the RFP document, incl uding those listed above, were projected to result in a 6.48 percent re duction in VOM emissions and a 10.01 percent reduction in NOx emissions from 2002 levels by the year 2008, a tota l reduction of 16.49 percent. All of the identif ied emissions control measures were implemented by 2008. These emissions reductions achieve the 15 perc ent RFP target for the Metro-East NAA.

5.3 Reasonably Available Control Technology (RACT)

Pursuant to Sections 172, 182(b) and (f) of the CAA, RACT is required for all existing major sources of the applicable criteria pol lutant and its precursors located in NAAs. U.S. EPA defines RACT as the lowest emissi ons limitation that a particular source is capable of meeting by the application of contro l technology that is reasonably available considering technological feasibil ity and economic reasonableness (70 FR 71612; November 29, 2005). The major source threshold for moderate NAAs is defined as 100 tons per year (tpy). A source generally consis ts of several units that emit pollutants. The sum of emissions from all units at the source determines if a unit is major and thus subject to RACT requirements.

RACT is not a new requirement under the C AA. Illinois previously addressed RACT requirements in the Metro-East area in devel oping attainment plans for the 1-hour ozone standard. The RACT requirement for NOx was previously waived under the 1-hour ozone standard, and Illinois has adopted new regulations to implement NOx RACT in the

### 20 NAA that were submitted to U.S. EPA in September 2009. Illinois has previously adopted RACT requirements for VOM emissions in the NAA. (See 35 Ill. Adm. Code Part 219) The Illinois EPA has evaluated the previously adopted regulations to determine if the RACT requirement is st ill being met for 8-hour ozone.

Sections 172, 182(b)(2), and 182(f) of the CAA require implementation of RACT for sources that are subject to Control Techniques Guidelines (CTGs) that are promulgated by U.S. EPA. The U.S. EPA has issued CT Gs defining RACT for those categories of sources that emit the greatest amounts of VOM emissions. Illinois EPA has proposed, or will soon be proposing, regulations to implement the revised CTGs issued by the U.S. EPA in 2006, 2007, and 2008. The 2006 CTG’s addr essed industrial cleaning solvents, offset lithographic printing and letterpress pr inting, flexible package printing, and flat wood paneling coatings. The 2007 CTG’s addres s paper, film, and foil coatings, large appliance coatings, and meta l furniture coatings. The 2008 CTG’s address miscellaneous metal and plastic parts coatings, fiberglass bo at manufacturing materials, miscellaneous industrial adhesives, and automobile and light -duty truck assembly coatings. Other than the above mentioned CTGs, Illinois has adopt ed applicable rules addressing all CTGs published by U.S. EPA for which there are existing sources in the Metro-East NAA.

Non-CTG sources are defined as major VOM s ources which are not subject to CTGs, but for which RACT is required. All major sources of ozone precursors located in the ozone NAA that are not subject to individual RACT ru les are subject to a generic RACT rule. These rules apply to non-CTG sources that have the potential to emit 100 tons or more per year of VOM. Thus, Illinois has met the obligation to implement RACT on non-CTG VOM sources in the NAA.

It should be noted that other regulatory re quirements also affect VOM emissions sources within the Metro-East ozone NAA. These in clude MACT, federal NSPS, and NESHAPs. These programs satisfy the RACT requirement s for specific source categories because these rules are more stringent than RACT. It is concluded from this review that Illinois’ existing VOM RACT rules fulfill U.S. EPA’s RACT requirements for VOM sources in the Metro-East NAA.

As mentioned previously, th e RACT requirement for NOx was previously waived under the 1-hour ozone NAAQS. The Illinois EP A has submitted final, fully adopted NOx RACT rules to U.S. EPA. It should be noted however that the attainment demonstration for the St. Louis NAA for the 1997 ozone NAAQS did not rely on emissions reductions from the Illinois EPA’s NOx RACT rules. The reductions resulting from this program, when implemented, will help the area to maintain the NAAQS in future years.

5.4 Controls to Remain in Effect

Illinois will maintain all of the control meas ures listed in this Section to ensure maintenance of the 8-hour ozone NAAQS. Any revisions to the control measures included as part of the Maintenance Plan will be submitted as a SIP revision to U.S. EPA

### 21 for approval, and will be accompanied by a showing that such changes will not interfere with maintenance of the NAAQS.

Illinois EPA has the necessary resources to en force any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emissions of ozone precursors in the Metro-East nonattainment area.

5.5 Provisions for Permitting New or Modified Emissions Sources

Illinois has longstanding and fully implement ed programs for the re view of new major sources and significant modifications of existing sources. The PSD program, which includes requirements for Best Availabl e Control Technology (BACT) on major new sources or significant modifications of existi ng sources, will be appl icable in the MetroEast area once the area has been redesignated to attainment. Illinois has been delegated full authority to implement the PSD program by U.S. EPA.

5.6 Transportation Conformity

The purpose of this section is to describe a nd establish the Metro-Ea st nonattainment area motor vehicle emissions budgets associated with the 8-hour ozone Maintenance Plan SIP. Average summer weekday motor vehicle emi ssions budgets are being proposed for the attainment year 2008 and for the final year of the Maintenance Plan, 2020, for the precursor pollutants VOM and NOx. These budge ts were developed consistent with the motor vehicle activity assumptions and emissions control strategies incorporated into the 8-hour ozone attainment demonstration analys is. The budgets reflect an emissions level determined using actual motor vehicle VMT for 2008 and VMT growth at an annual rate of 1.5% from year 2008 levels to 2020.

A motor vehicle emissions budget is that po rtion of the total allowable emissions allocated to highway and transit vehicle use that are defined in the SIP for a certain year. The rules governing transporta tion conformity require certain transportation activities to be consistent with motor vehicle emissi ons budgets contained in control strategy implementation plans (40 CFR § 93.118). S ection 93.101 of the rule defines a “control strategy [State] implementation plan revisi on” as a “plan which contains specific strategies for controlling the emissions and re ducing ambient levels of pollutants in order to satisfy CAA requirements of reasonable furt her progress and attainment.” In order to demonstrate conformity to the motor vehi cle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program must be less than or equal to th e budget level (40 CFR § 93.118(a)).

The motor vehicle emissions budgets establis hed and described herein were developed consistent with the methodology and control strategy assumptions used in the 8-hour ozone attainment demonstrati on. The effects of motor ve hicle control measures are incorporated into the emissions factors pr oduced by the U.S. EPA’s MOBILE6 model. These control measures include the implement ation of national motor vehicle emissions standards, the operati on of a vehicle inspec tion and maintenance (I/M) program, and the

### 22 required use of reformulated gasoline and low sulfur gasoline and diesel fuel.

The motor vehicle emissions budgets, whic h reflect the VMT and control program assumptions and methodology described here, are listed in Table 5.1.

Table 5.1 Proposed 2008 and 2020 Motor Vehicle Emissions Budgets Metro-East 8-hour Ozone Maintenance Plan (tons per ozone season weekday)

Year VOM NOx

2008 16.53 30.84

2020 7.70 10.33

Complete details on the derivation of the motor vehicle emissions budgets, including discussion of the MOBILE6 model inputs a nd assumptions are included in Appendix B of this report.

### 23 6.0 CONTINGENCY MEASURES

6.1 Contingency Measures

Section 175(A) of the CAA specifies the requ irements for Maintenance Plans, including provisions for contingency measures that will be implemented if violat ions of the 8-hour ozone NAAQS are measured after redesignati on to attainment. A list of potential contingency measures that w ould be implemented in such an event should also be included in the Maintenance Plan. Finall y, the plan should provide a commitment to submit a revised Maintenance Plan eight year s after redesignation to ensure continued maintenance for the next ten-year maintenance period.

Contingency measures are intended to provide further emissions reductions in the event that violations of the 8-hour ozone NAAQS occur after redesignation to attainment. While these measures do not need to be fu lly adopted by the Illinois Pollution Control Board (IPCB) prior to the occurrence of NAAQS violations, the contingency plan should ensure that the contingency measures are a dopted expeditiously once they are triggered. The Maintenance Plan must identify the tr iggers that determine when contingency measures will be adopted, and the meas ures that the state will consider.

Illinois EPA’s contingency plan for the Me tro-East NAA is desc ribed in Table 6.1. Consistent with this plan, Illinois agrees to adopt and implement, as expeditiously as practicable, the necessary corre ctive actions in the event th at violations of the 8-hour ozone NAAQS occur within the Metro-East maintenance area after redesignation to attainment. Further, Illinois commits to c ontinue to implement the control measures identified in the attainment demonstrati on and RFP demonstration. As described in Section 5.0 of this report, Illin ois has adopted and is continuing to implement a range of control measures that will greatly reduce precu rsor emissions, both locally and statewide. The contingency plan anticipates that these emissions reductions will be sufficient to mitigate exceedances or violations of th e NAAQS that may occur in the coming years without further re gulatory action.

The contingency plan provides for different le vels of corrective responses should ambient 8-hour ozone levels exceed the NAAQS in a ny year, if emissions in the NAA increase significantly above current attainment levels , or if the NAAQS is violated. A Level I response would occur in the ev ent that: 1) the f ourth highest 8-hour ozone concentration at any monitoring site in the St. Louis NAA (including sites in Mi ssouri and Illinois) exceeds 84 ppb in any year, or 2) if VOM or NOx emissions increase more than 5% above the levels contained in the attainment year (2008) emissions inventory. It should be noted that U.S. EPA does not require a st ate to implement contingency measures when occasional exceedances are recorded. Th e Illinois EPA’s voluntary commitment to initiate a Level I response is intended to pr event future violations of the NAAQS from ever occurring.

Illinois commits to compiling VOM and NOx em issions inventories for the Metro-East area every three years for the duration of th e Maintenance Plan to facilitate the

### 24 Table 6.1 Contingency Plan for the Metro-East 8-Hour Ozone Nonattainment Area

Contingency Measure Trigger Action to be Taken List of Potential Contingency Measures Level I Trigger

 Fourth highest monitored 8-hour average ozone concentration exceeding 84 ppb in any year at any monitoring station in the St. Louis MO-IL maintenance area.

 The Metro-East maintenance area’s NOx or VOM emissions inventories increase more than 5% above the levels included in the 2008 emissions inventories. IL will evaluate air quality, or determine if adverse emissions trends are likely to continue. If so, IL will determine what and where controls may be required, as well as level of emissions reductions needed, to avoid a violation of the NAAQS. The study shall be completed within 9 months. If necessary, control measures shall be adopted within 18 months of determination and implemented as expeditiously as practicable, taking into consideration the ease of implementation and the technical and economic feasibility of the selected

measures. Point Source Measures

 IL Multi-Pollutant Program for electric generating units

 Phase II of the Clean Air Interstate Rule, after repromulgation by USEPA

 Best Available Retrofit Technology (BART)

Mobile Source Measures

 Tier 2 Vehicle Standards and Low Sulfur Fuel

 Heavy Duty Diesel Standards and Low Sulfur Diesel Fuel

 High-enhanced I/M (OBDII)

 Federal railroad/locomotive standards

 Federal commercial marine vessel engine standards

 Portable fuel containers

Area Source Measures

 Architectural/Industrial Maintenance (AIM) Coatings

 Commercial and Consumer Products

 Aerosol coatings

 Broader geographic applicability of existing measures Level II Trigger

 A violation of the NAAQS at any monitoring station in the St. Louis MO-IL maintenance area. IL will conduct a thorough analysis to determine appropriate measures to address the cause of the violation. Analysis shall be completed within 6 months. Selected measures shall be implemented within 18 months of a violation.



### emissions trends analysis included in the c ontingency plan under Le vel I. The Illinois EPA will coordinate with the Missouri DNR to evaluate the causes of high ozone levels or the emissions trends and to determine appr opriate control measures needed to assure continued attainment of 8-hour ozone NAAQS. Under Level I, measures that could be implemented in a short time would be select ed so as to be in place quickly after the Illinois EPA is aware that co rrective measures have been triggered. Control measures selected under Level I will be adopted in most cases within 18 months after a determination is made, and implemented, gene rally, within 24 mont hs of adoption by the IPCB.

A Level II response would be implemented in the event that a violation of the 8-hour ozone NAAQS were to be measured at a monitoring site within the St. Louis maintenance area (including sites in Missouri and Illinois). In order to select appropriate

### 25 corrective measures, the Illi nois EPA will work with the Missouri DNR to conduct a comprehensive study to determine the causes of the violation and the control measures necessary to mitigate the problem. The an alysis will examine the following factors:

 the number, location, and severity of the ambient ozone exceedances;

 the weather patterns co ntributing to the elevated ozone levels;

 potential contributing emissions sources;

 the geographic applicab ility of possible contingency measures;

 emissions trends, including timeliness of implementation of scheduled control
measures;

 current and recently identified control technologies; and

 air quality contributi ons from outside the maintenance area.

Contingency measures will be selected from those listed in Table 6.1 or from any other measure deemed appropriate and effective at the time the selection is made. It is expected that implementation of only a few of these measures would be necessary. The selection between measures will be based upon cost-effectiveness, emissions reduction potential, ease and timing of implementa tion, and other appropriate factors. Implementation of necessary controls in respon se to a Level II trigger will take place as expeditiously as possible, but in no event later than 18 months after the Illinois EPA makes a determination, based on quality-assure d ambient data, that a violation of the NAAQS has occurred.

Adoption of additional control measures is s ubject to necessary administrative and legal processes. The Illinois EPA w ill solicit input from all interested and affected persons in the area prior to selecting appr opriate control measures. No contingency measure will be implemented without providing th e opportunity for full public pa rticipation. This process will include publication of notices, an opportun ity for public hearing, and other measures required by Illinois law.

6.2 Commitment to Revise Plan

As noted in Section 4.5 above, the Illinois EP A commits to review its Maintenance Plan eight years after redesignation, as re quired by Section 175(A) of the CAA

. The Maintenance Plan revision is intended to ensu re continued attainment of the 8-hour ozone NAAQS for an additional ten-year period.

6.3 Public Participation

In accordance with Section 110(a)(2) of the C AA, the Illinois EPA is required to hold a public hearing prior to adoption of this Maintenance Plan and submittal to U.S. EPA. Public participation in the SIP pr ocess is provided for as follows:

 Notice of availability of the Metro- East 8-Hour Ozone Maintenance Plan document and the time and date of the public hearing will be published in the

### 26 Belleville News Democrat, East St. L ouis Monitor, and Alton Telegraph on March 5, 2010 and in the Granite City Press Record Journal on March 7, 2010.

 The public hearing to receive comments on the Metro-East Maintenance Plan will be held at 10:30 a.m. on April 8, 2010 at the Illinoi s Department of Transportation’s Regional Conference Room at its District 8 Offices at 1102 Eastport Plaza Drive, Collinsville Illinois.

 A 30-day public comment period was also available after the public hearing to receive comments on the Maintenance Plan. A summary of the comments received and Illinois EPA’s responses ther eto is included as part of the submittal to U.S. EPA.

6.4 Legal Authority to Implement and Enforce

The Maintenance Plan must contain a demons tration that the Stat e of Illinois has the necessary legal authority to implement and enfo rce the measures relied upon to attain and maintain the NAAQS. Illinois has the legal authority to implement and enforce the requirements of this SIP submittal pursuant to the Illinois Environmental Protection Act.

### 27 7.0 CONCLUSIONS

The Metro-East nonattainment area has attained the 1997 0.080 ppm 8-hour ozone NAAQS and has complied with the applicab le provisions of the CAA required of moderate ozone NAAs. Illinois has submitted an attainment demonstration that was based on air quality modeling and contains enfo rceable control measures. The attainment demonstration included an RFP Plan which demonstrated the requi red 15% reduction in ozone precursor emissions. Illinois has perfor med an analysis that demonstrates that the Metro-East NAA has attained the 1997 8-hour ozone NAAQS and believes the air quality improvements are due to permanent and en forceable control measures. Supporting documentation is contained herein.

The Illinois EPA has prepared a Maintenance Plan that meets the requirement of the Clean Air Act. This Maintenance Plan provide s for the continued attainment of the 1997 8-hour ozone NAAQS for a period of ten years af ter U.S. EPA has formally redesignated the area to attainment. This Maintenance Pl an provides adequate contingency measures for potential, additional emissions reductions in the event that future violations of the 1997 8-hour ozone NAAQS are obs erved in the area.

The Illinois EPA has prepared a comprehensiv e emissions inventory of the precursors of ozone completed for the “attainment” year 2008, and has prepared projections of the emissions inventory to 2013 and to 2020. These emissions projections indicate that emissions levels in the Metro-East nonattainme nt area will continue to decrease from attainment year 2008 levels, thereby maintain ing the ozone NAAQS in future years. The Illinois EPA commits to continue to opera te an appropriate air quality monitoring network to verify the maintenance of the attainment status once the area has been redesignated. The Illinois EPA has the lega l authority to implement and enforce all control measures.

Finally, the Metro-East Maintenance Plan includes year 2008 and 2020 on-road motor vehicle emissions budgets for use in transportation conformity determinations to assure that any increases in emissions from this sect or do not jeopardize continued attainment of the 8-hour ozone standard during the ten-ye ar maintenance period. The Metro-East Maintenance Plan has been prepared in acco rdance with the requirements specified in U.S. EPA’s guidance document, and additional guidance received from U.S. EPA staff.

### 28 

## APPENDIX A

Summary of Ambient Air Monitoring Data (2007-2009)29Table A.12007-2009 8-hour Ozone Design Valuesfor Monitors in the St. Louis RegionState of MissouriCounty AQS Code Site Name Design Value 4th High 2007 4th High 2008 4th High 2009St. Charles 291831004 Orchard Farm 75 83 72 72St. Charles 291831002 West Alton 78 89 76 71St. Louis City 295100085 Blair St 75 87 73 65St. Louis 291890014 Maryland Hts 76 94 69 67St. Louis 291890005 Pacific 71 85 64 64Jefferson 290990019 Arnold/Arnold W 75 87 70 70State of IllinoisCounty AQS Code Site Name Design Value 4th High 2007 4th High 2008 4th High 2009Jersey 170831001 Jerseyville 70 75 69 68Madison 171190008 Alton 72 81 68 67Madison 171193007 Wood River 73 86 67 66Madison 171191009 Maryville 77 87 70 74St. Clair 171630010 E. St. Louis 70 77 64 69

### 30 

## APPENDIX B

Transportation Conformity

### 31 TRANSPORTATION CONFORMITY

This section describes the development of the Metro-East nonattainment area motor vehicle emissions budgets associated with the Maintenance Plan for the 1997 8-hour NAAQS. An average summer weekday mo tor vehicle emissions budget is being proposed for the attainment year 2008 and for the Maintenance Plan year 2020 for the precursor pollutants VOM and NOx. These budge ts were developed consistent with the motor vehicle activity assumptions (e.g., fl eet mix, registration distribution,...) and emissions control strategies incorporated in to the Metro-East 8-hour ozone Attainment Demonstration analysis.

Background Section 176(c)(4) of the Clean Air Act Amendments of 1990 requires that transportation plans, programs, and projects which are f unded or approved under Title 23 of the United States Code (USC) must be determined to conform with State or Federal air implementation plans. A motor vehicle em issions budget is that portion of the total allowable emissions allocated to highway and transit vehicle use that are defined in the SIP for a certain year. Section 93.101 of th e rule defines a “control strategy [State] implementation plan revision” as a “plan which contains specific strategies for controlling the emissions and reducing ambient levels of pollutants in order to satisfy Clean Air Act (CAA) requirements of reasonabl e further progress and attainment.” In order to demonstrate conformity to the mo tor vehicle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program (TIP) must be less than or equal to the budget level (40 CFR § 93.118(a)).

Transportation conformity will be determined based on these proposed on-road motor vehicle emissions budgets after the U.S. E nvironmental Protection Agency (U.S. EPA) determines that the budgets meet the adequacy criteria of the transportation conformity rule under §93.118(e). The motor vehicle emissions budgets in this submittal are adequate as each of the six criteria under §93.118(e) is sati sfied. These six criteria include:

1. The submitted control strategy implementation plan revision or Maintenance Plan was endorsed by the Governor (or his or he r designee) and was subject to a State public hearing.

2. Before the control strategy implementation plan or Maintenance Plan was submitted to U.S. EPA, consultation among federal, State, and local agencies occurred; full implementation plan documentation was pr ovided to U.S. EPA; and U.S. EPA’s stated concerns, if any, were addressed;

3. The motor vehicle emissions budgets(s) is cl early identified and precisely quantified;

### 32 4. The motor vehicle emissions budget(s), when considered together with all other emissions sources, is consistent with a ll applicable requirements for reasonable further progress, attainment, or maintenan ce (whichever is relevant to the given implementation plan submission);

5. The motor vehicle emissions budget(s) is cons istent with and clea rly related to the emissions inventory and the control measures in the submitted control strategy implementation plan revision or Maintenance Plan, and

6. Revisions to previously submitted control strategy implementation 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 (incl uding the basis for any changes related to emissions factors or estimates of vehicle miles traveled).

Regarding adequacy criterion #1, this Stat e Implementation Plan and the associated motor vehicle emissions budgets have been developed by the Illinois Environmental Protection Agency (Illinois EP A), the designated air quality agency for the State of Illinois. The required public hearing to accept public comment on the proposed budgets will be held on April 8, 2010 in the Regional Conference Room at the Illinois Department of Transportation’s District 8 offices at 1102 Ea stport Plaza Drive in Co llinsville, Illinois. Notification of this hearing will be publishe d in the Belleville News Democrat, East St. Louis Monitor, and Alton Telegraph on Ma rch 5, 2010 and in the Granite City Press Record Journal on March 7, 2010. Comments on the proposed Maintenance Plan and associated motor vehicle emissions budgets will be accepted for 30 days after the public hearing. A “Responsiveness Summary” which addresses the written comments received will be prepared and included in the final submission.

In compliance with criterion #2 above, an Inter-Agency Conformity Consultation Team meeting was held at the offices of the East-West Gateway Council of Governments on January 26, 2010. The Consultation Team in cludes representatives from the Federal Highway Administration, the U.S. EPA, the East-West Gateway Council of Governments (EWGCOG), the Missouri Department of Tr ansportation, the Miss ouri Department of Natural Resources, the Illinois Department of Transportation (IDOT), and the Illinois EPA. At this meeting the development of the proposed Maintenance Plan motor vehicle emissions budgets was discussed. The draft Ma intenance Plan was also forwarded to the U.S. EPA Region V representative for his review and comment.

The motor vehicle emissions budgets proposed and described herein were, in compliance with adequacy criterion #5, developed c onsistent with the methodology and control strategy assumptions used in the Metr o-East 1997 8-hour Ozone Attainment

### 33 Demonstration as well as the associated R easonable Further Progress (RFP) plan. The effects of these controls are incorporated into the emissions factors produced by the U.S. EPA’s MOBILE6 model. In response to ad equacy criteria 4 and 6, the narrative of the Metro-East 8-hour Ozone Mainte nance Plan discusses the emi ssions estimates from other sectors and any changes in regulations. Follo wing, in response to ad equacy criteria #3, is a discussion of the inputs and assumptions in corporated into the development of the proposed Maintenance Plan motor vehicle emissions budgets.

Vehicle Miles Traveled: The proposed Metro-East 8-hour Ozone Maintenance Plan attainment year 2008 motor vehicle emissions budgets were developed using actual 2008 county-level average weekday vehicle miles travelled (ADVMT) data from the IDOT. The 2008 ADVMT for the months of June, July, and August for the 4-county (Madison, Monroe, St. Clair and Jersey) Metro-East 8-hour ozone nonattainment area was 16.59 million miles. This figure was projected to the Maintenance Plan end year, 2020, using an annual growth rate of 1.5 percen t, yielding an ADVMT of 19.83 million.

To account for ozone season weekday traffic, the ADVMT estimates were multiplied by downstate Illinois facility type-specifi c Average-Daily-to-Average Summer Weekday conversion factors for 2008 supplied by IDOT. Applying these fact ors resulted in an average summer weekday VMT (ASWVMT) that is 10.8 percent greater than the ADVMT. Applying this summer weekday conv ersion factor result s in a 2008 ASWVMT of 18.26 million miles and a projected 2020 figur e of 21.83 million miles. Following is a summary of the information and MOBILE6 mo del assumptions used in the development of the draft motor vehicle emissions budgets.

Temperature: U.S. EPA guidance for the use of the MOBILE6 model calls for the use of representative summer daily temp eratures. For the year 2008, actual average June, July, and August minimum an d maximum temperatures of 68 o 

### F and 87 o 

### F, respectively, were obtained from National W eather Service data for St. Louis Lambert Airport. For the year 2020, the climatol ogical average minimu m and maximum summer temperatures of 68 o 

### F and 88 o 

### F, respectively, were used.

Absolute Humidity: U.S. EPA guidance calls for the use of the lowest absolute humidity on days corresponding to the summer climatological temperatures in the region as calculated from local c limatological data published by the National Weather Service. A climatological average summer weekday abso lute humidity value of 97 grains of water (vapor) per pound of dry air was ca lculated for Lambert Airport.

Motor Vehicle Emissions Controls: The primary motor vehicle emissions control programs that were in place in the Metro-East NAA in 2008 and are projected to still be required are a vehicle inspection and maintena nce (I/M) program and the required use of southern grade Reformulated Gasoline.

Inspection and Maintenance (I/M): The I/M program in effect since 2007 requires biennial On-Board Diagnostics II (O BD) testing on all model year (MY) 1996

### 34 and newer (MY96+) light duty gasoline vehicles , and biennial exhaust idle and gas cap testing on MY96+ heavy duty gasoline vehi cles including gasoline-powered buses, registered in the I/M testable area. Motorc ycles and diesel vehicles are not subject to I/M. The program includes a 4-year grace pe riod for new vehicles. This post-2007 I/M program was established when the Illinois legislature amended the Illinois Vehicle Inspection law in 2005 to (a) end dynamometer testing of vehicles, (b) require an OBDbased program beginning in February 2007, and (c) remove the requirement for testing compliant pre-MY-1996 vehicles.

Fuels: The use of federal Reformulated Ga soline (RFG) has been required in the Metro-East St. Louis NAA since 2007 and the St. Louis, Missouri area since 2001. Since the Metro-East NAA is a part of the St. Louis NAA, classified a “southern” area for purposes of motor fuel control programs, sout hern grade RFG is required and assumed to be used in the Metro-East area. The 8-hour ozone Attainment Demonstration assumed the use of southern grade RFG in 2008 and beyond.

Gasoline Sulfur: Gasoline sulfur levels were assumed to be 30 parts per million (ppm) in both 2008 and 2020 in accordance with the federal Tier 2 gasoline regulations which required the 30 ppm level beginning in 2006.

Diesel Sulfur: Diesel sulfur levels were assumed to be 15 parts per million in both 2008 and 2020 in accordance with th e U.S. EPA’s Highway Diesel Rule which was finalized in January 2001. This regulation required th e sale of on-road diesel fuel with no greater than 15 ppm of sulfur be ginning in June 2006.

Speeds: The Illinois EPA assumed an area-sp ecific vehicle speed distribution that appears in the VMT-by-Speed-Bin external f ile SVMTME04.DEF, which is described in more detail later in this document. The speed distribution in this f ile is for freeways and arterials only (local roads and ramps have a fixed speed in MOBILE6), and was based on transportation model output (modeled speeds on links of various classes of roads by modeling period) from the EWGCOG for th e year 2004. This speed distribution is assumed to remain valid for 2020.

VMT Mix: The regional VMT mix inputs used for 2020 were based on downstatespecific 2005 VMT-by-vehicle-type data supplie d by IDOT, modified to reflect expected changes in the ratio of cars to light trucks . This information is used in the MOBILE model to compute the average emissions factor s for certain combined vehicle classes, and the all-vehicle emissions rate.

Registration Distribution: A Metro-East area-specific ve hicle registration distribution profile based upon 2008 information data was developed by Illinois EPA’s Division of Mobile Source Programs from data provide d by the Illinois Secretary of State’s Department of Motor Vehicles. This pr ofile is assumed to remain valid for 2020

### 35 Emissions Computation: Illinois EPA calculates emi ssions budgets using the following formula:

1. No-I/M County Emissions by vehicle type (VT) and functional class (FC) = (County ASWVMT by FC) * (VMT Mix by VT and FC) * No-I/M emissions factors (EF) by pollutant, VT, and FC) * 1.102 (grams to ton conversion factor). For areas without I/M, this is the only calculation.

2. I/M Credits by VT and FC = (C ounty ASWVMT by FC) * (VMT Mix by VT and FC) * (No-I/M EF – I/M EF [both by pollutant, VT, and FC]) * I/M coverage factor * 1.102. This is for areas with I/M only.

3. Net County Emissions by VT and FC = (I/M County Emissions by VT and FC) – ( I/M Credits by VT and FC). This is for areas with I/M only.

The Illinois EPA performs these above calcu lations on a multi-page spreadsheet which automatically calculates emissions and I/M credits by county or township for each pollutant, VT, and FC, sums them by VT and FC , and aggregates them into area totals. Attachment A of this section provides a dditional details on the MOBILE6 model inputs used in the development of the 2008 and 2020 Metro-East NAA motor vehicle emissions budgets.

Motor Vehicle Emissions Budgets Using the above VMT and control program assumptions and methodology, following are the Attainment Year 2008 and Maintenan ce Plan Year 2020 Metro-East 8-hour ozone motor vehicle emissions budgets for use in determining transportation conformity.

Proposed Metro-East 8-hour Ozone Maintenance Plan 2008 and 2020 Motor Vehicle Emissions Budgets

(tons per ozone season weekday)
Year VOM NOx

2008 16.53 30.84

2020 7.70 10.33

### 36 

### Attachment A

Transportation Conformity MOBILE6.2 Input File Formats

External MOBILE6.2 Inputs:

In the examples of external files sh own below, the actual command lines are boldfaced ; the unbolded lines represent comments. The actu al text files have no such distinction in typefaces. The unbolded lines have been “commented out” and have no effect on the MOBILE model. They may therefore be omitted, but it is suggested that they remain in the files for documentation, and to make th e files easier for the user to read and understand.

The comments and other text in the Exte rnal Files have been shown in the Courier
New typeface. Actual command lines—the inputs that MOBILE actually uses—are shown in **Courier New Bold**

In certain cases (especially the VMT-by-Speed-Bin files) th e typeface has been reduced in size so that the lines woul d fit within the margins of the page. This makes them easier to read.



### Vehicle Inspection and Maintenance (I/M) Program

The external I/M files giving the inputs used in the MOBILE6 model in this exercise were ILLOBDIM.D (for 2002 and through 2006) and IM07ON.D (for 2007 and later years). When evaluating I/M credits for 2008, the residual effect of the ILLOBDIM program in the summer of 2008 is taken into account by assuming that 75% of the vehicle fleet subject to I/M has been tested under the IM07ON program by that time, and that the other 25% have been tested under the ILLOBD IM in late 2006 and have not yet come up for retesting under IM07ON by su mmer 2008 (both programs are biennial). The effective I/M emissions rate in 2008 is thus 25% of ILLOBDIM’s plus 75% of IM07ON’s. By summer 2009, all vehicles subject to I/M will have been tested under IM07ON, so this question does not arise when evaluating year s from 2009 on: the I/M emissions rate for 2009 and after is simply that for the IM07ON program.

The IM07ON.D File , used for the year 2008

The external I/M file IM07ON.D described be low represents an I/ M program with four components, chief of which is an OBD (on-boa rd diagnostics) test for vehicles of model year (MY) 1996 and newer. Illinois EPA begins IM07ON.D with identifying comments,

### 37 and adds other comment lines or blank lines to make the file easier to read and understand. Programs after the first need comparatively few comments because the commands are largely self-descriptive.

* ILLINOIS ENHANCED I/M DESCRIPTION

* Filename: IM07ON.D

* External input file for Illinois' OBD-only I/M program * from 2007 on. * OBD-only applies to light-duty vehicles only; HDVs still get * an Idle Test & Gas Cap Check. * All program start years set to 1986 per U.S. EPA guidance in * "Frequently Asked Questions on MOBILE6" from U.S. EPA/OTAQ.

* This represents the NEW I/M program in which only 1996 & * newer vehicles are tested with an OBD test; and the OBD test * applies only to LDVs. * This program came into effect in February 2007.

*------------------------------------------------- * Program description for post MY'96 LDV OBD I/M *=================================================

* FIRST I/M program--"Evaporative]" OBD for MY 1996+ LDVs 

### *------------------------------------------------- **I/M PROGRAM : 1 1986 2050 2 T/O EVAP OBD I/M MODEL YEARS : 1 1996 2050**  **I/M VEHICLES : 1 22222 11111111 1 I/M STRINGENCY : 1 20.0**  **I/M COMPLIANCE : 1 95.0 I/M WAIVER RATES : 1 0.5 2.2 '01 data**  **I/M EXEMPTION AGE : 1 25 I/M GRACE PERIOD : 1 4** 

In each case, the first number after the colon refers to the I/M program’s component number.

**I/M PROGRAM : 1 1986 2050 2 T/O EVAP OBD**

Testing began in 1986 and runs into the i ndefinite future (2050). The program is a biennial test-only (2 T/O, here and in other program components) program, in this case an Evaporative On-Board Diagnostics (OBD) test. The On-Board Diagnostic program in a vehicle engine’s computer records information from sensors in the engine and fuel system. Indications of ma lfunctions or out-ofspecification operations of th e engine or fuel and evaporative emissions control systems are stored in the engine com puter as “fault codes.” An OBD test consists of plugging a special scanner in to an output jack from the vehicle’s engine computer. The scanner queries th e computer and records any fault codes that the computer’s OBD system has sa ved. OBD tests are quick, dependable,

### 38 and clean, and, if a vehicle fails an OBD test, the fault codes that the scanner displays help mechanics diagnose the problem.

**I/M MODEL YEARS : 1 1996 2050**

This program component covers only vehicles manufactured between model year (MY) 1996 (start yea r) and the indefinite future (MY 2050, the end year). More and more vehicles are becoming subj ect to this test as new vehicles are bought and older (pre-MY-1996) on es are scrapped vehicles.

**I/M VEHICLES : 1 22222 11111111 1**

Only the five light-duty vehicle types (cars [LDGVs], and light trucks [LDGTs 1, 2, 3, and 4]) are covered by this progr am component (22222). Heavy-duty gasoline vehicles (HDGV) (e ight types) and gasoline buses are not covered by this program component (11111111 1), but rather by Programs 3 and 4, described below.

**I/M STRINGENCY : 1 20.0**

Stringency (exhaust inspection failure rate) is 20%. A Stringency entry is necessary for an Exhaust test, but not an Evaporative test, so this entry can be omitted or “commented out”. In this Evap test case, it will be ignored by the model, but is included for reference.

**I/M COMPLIANCE : 1 95.0**

Compliance rate (tested vehicles as percen t of all vehicles su bject to I/M) is 95%

**I/M WAIVER RATES : 1 0.5 2.2** '01 data

The Waiver Rate is the fraction of tested vehicles that get a waiver—i.e., do not pass the I/M test but, because repairs co st more than a specified amount, get a certificate of compliance. The waiver rate is 0.5% for MY 1980 and earlier vehicles (irrelevant now that pre-MY-96 vehicles are not te sted), and 2.2% for MY 1981 and later vehicles. These figur es are from VIM’s actual 2001 waiver statistics, and have been re presentative of the last few years, so are deemed representative of 2008 and 2020.

**I/M EXEMPTION AGE : 1 25**

Vehicles older than 25 years are not subjec t to this program. As the Illinois I/M program only requires testing for MY1996 and newer vehicles, exemptions will not occur until 2021. The default is 25, and the model doe s not calculate benefits for vehicles older than 25 y ears, so in essence this command has no effect. It could be omitted, but is included for completeness.

**I/M GRACE PERIOD : 1 4**

Vehicles less than 4 model years ol d—in this case MY2006, ’07, ’08, and ’09— are exempt from I/M testing.

### 39 Most of the inputs to the second and subsequent program components are the same as those for the first program, so the description of the components will be abbreviated and summarized as below, rather than after each command line as above.

* Second I/M program--"Exhaust" OBD for MY 1996+ LDVs *---------------------------------------------------- **I/M PROGRAM : 2 1986 2050 2 T/O OBD I/M I/M MODEL YEARS : 2 1996 2050**  **I/M VEHICLES : 2 22222 11111111 1 I/M STRINGENCY : 2 20.0**  **I/M COMPLIANCE : 2 95.0 I/M WAIVER RATES : 2 0.5 2.2**  '01 data **I/M EXEMPTION AGE : 2 25 I/M GRACE PERIOD : 2 4**  *

The second I/M program component is a biennial, test-only Exhaust OBD test

for MY 1996 and later LDGVs and LDGTs. In this OBD test, the scanner queries the vehicle’s computer for fau lt codes concerning exhaust emissions. Stringency, Compliance, Waiver Rates, Exemption Age, and Grace Period are the same as in the first program. An entry for I/M STRINGENCY (20%) is required for an Exhaust I/M program.

*------------------------------------------------------ * Program description for post MY'96 HDV Idle & GC I/M *======================================================

* Third I/M program--HDV IDLE for MY 1996+ HDVs *------------------------------------------------ **I/M PROGRAM : 3 1986 2050 2 T/O IDLE I/M MODEL YEARS : 3 1996 2050**  **I/M VEHICLES : 3 11111 22222222 2 I/M STRINGENCY : 3 20.0**  **I/M COMPLIANCE : 3 95.0 I/M WAIVER RATES : 3 1.2 1.5**  '01 data **I/M EXEMPTION AGE : 3 25 I/M GRACE PERIOD : 3 4** 

The third I/M program component is a bi ennial, test-only Idle test for MY 1996 and later HDGVs and Gas Buses (22222222 2). Light-duty vehicles are not subject to this component (11111), bu t rather to components 1 and 2. Stringency, Compliance, Exemption Age, and Grace Period are the same as in component 1, but the pre- and post-MY 1981 Waiver Rates (1.2% and 1.5%,

### 40 respectively), are slightly different fr om those in components 1 and 2. HDGVs are few in number, and most of them are commercial vehicles

.

* Fourth I/M program--Gas Cap Check for MY 1996+ HDVs *---------------------------------------------------- **I/M PROGRAM : 4 1986 2050 2 T/O GC I/M MODEL YEARS : 4 1996 2050**  **I/M VEHICLES : 4 11111 22222222 2 I/M COMPLIANCE : 4 95.0**  **I/M WAIVER RATES : 4 1.2 1.5** '01 data **I/M EXEMPTION AGE : 4 25 I/M GRACE PERIOD : 4 4** 

The fourth I/M program component is a biennial, test-only Gas Cap Check for MY 1996 and later HDVs. Compliance, Waiver Rates, Exemption Age, and Grace Period are the same as in the third program. Since a Gas Cap Check is an evaporative I/M test, the I/M STRINGE NCY command is not necessary and is not included here.

Illinois EPA includes additional notes and comments in the I/M file for documentation purposes, as shown below:

* NOTES

* This is a standard Illinois I/M input, describing the I/M * program with OBD Only as it is supposed to exist after * January 2007. It is the file to be used for regular M6 * I/M runs for 2007 and future years. * * This file was originally SB397.D, supplied 24.viij.05. * Original SB397.D has been slightly revised by * the addition of comments such as this one. The actual * inputs have not been changed. This was done to put the two * LDV OBD programs (exhaust and evaporative) together, and the * two HDV programs together too. The order of the programs in * the I/M file is not significant and has no effect in M6, but * the programs must be numbered sequentially. * DVIM verified that this file as shown correctly describes the * I/M program planned for introduction in January '07. * ---------------- * COMPARISON WITH ILLOBDIM.D: * The first three programs in ILLOBDIM.D, covering the idle * test for MY'68-'81 LDVs, IM240 for '81-'95 LDVs, and gas * cap check for MY'68-'95 LDVs have been eliminated from * IM07ON; and the two HDV programs now refer only to MY'96 * and later.



### The Registration Distribution

The Registration Distribution (RD) for a vehicl e type is an indicati on of the fraction of

### 41 the vehicle fleet of that type that is made up of vehicles of a given age.

The following Metro-East-specific RD file (MERD08AA.d) is based on 2008 registration data from the Illinois Secretary of State’s offi ce (ISOS). It and its contents are described in below.

**REG DIST**

*** MENAA M6 LDV RD = SOSLDV (Light-duty Vehicles--passenger cars) RD from** *** 08VADbyCounty.xls for Metro-East omitting '09 counts & '08 = 75% of '07 1 0.0422 0.0562 0.0568 0.0583 0.0574 0.0561 0.0654 0.0662 0.0680**  **0.0614 0.0523 0.0524 0.0467 0.0447 0.0355 0.0306 0.0256 0.0216 0.0175**  **0.0148 0.0114 0.0086 0.0074 0.0182 0.0247** 

*** MENAA M6 LDT1 RD = SOSLDT1 (ISOS "light" or type 1 LD trucks) RD from** *** 08VADbyCounty.xls for Metro-East omitting '09 counts & '08 = 75% of '07 2 0.0397 0.0529 0.0652 0.0822 0.0703 0.0684 0.0783 0.0651 0.0645**  **0.0576 0.0599 0.0489 0.0363 0.0316 0.0321 0.0266 0.0218 0.0202 0.0142**  **0.0144 0.0130 0.0089 0.0073 0.0055 0.0151** 

*** MENAA M6 LDT2 RD = Same as M6 LDT1 RD; see above. 3 0.0397 0.0529 0.0652 0.0822 0.0703 0.0684 0.0783 0.0651 0.0645**  **0.0576 0.0599 0.0489 0.0363 0.0316 0.0321 0.0266 0.0218 0.0202 0.0142**  **0.0144 0.0130 0.0089 0.0073 0.0055 0.0151** 

*** MENAA M6 LDT3 = SOSLDT21 (ISOS "heavy" or type 2 LD trucks) RD from** *** 08VADbyCounty.xls for Metro-East omitting '09 counts & '08 = 75% of '07 4 0.0439 0.0585 0.0592 0.0757 0.0922 0.0854 0.0750 0.0643 0.0588**  **0.0631 0.0418 0.0385 0.0372 0.0401 0.0335 0.0213 0.0194 0.0109 0.0126**  **0.0120 0.0098 0.0072 0.0075 0.0060 0.0261** 

*** MENAA M6 LDT4 = same as LDT3 RDs; see above. 5 0.0439 0.0585 0.0592 0.0757 0.0922 0.0854 0.0750 0.0643 0.0588**  **0.0631 0.0418 0.0385 0.0372 0.0401 0.0335 0.0213 0.0194 0.0109 0.0126**  **0.0120 0.0098 0.0072 0.0075 0.0060 0.0261** 

*** Above from 2008 Metro-East-area data from DVIM and calculated in accordance** *** with AW USEPA's recommendations in '02 training material,** *** viz., ignore MY09 counts and set MY'08 counts to 75% of 'MY07 counts.** *** This file is MERD08AA.d, made 27.j.09.**

* Heavy-Duty & MC RDs below are all assumed same as M6 default RD. * * HDV2B (Heavy-duty vehicles 2B--M6 Default RDs) **6 0.0503 0.0916 0.0833 0.0758 0.0690 0.0627 0.0571 0.0519 0.0472 0.0430 0.0391 0.0356 0.0324 0.0294 0.0268 0.0244 0.0222 0.0202 0.0184 0.0167**  **0.0152 0.0138 0.0126 0.0114 0.0499** * HDV3 (Heavy-duty vehicles3, same RD as HDV2B, M6 Default RDs) **7 0.0503 0.0916 0.0833 0.0758 0.0690 0.0627 0.0571 0.0519 0.0472 0.0430 0.0391 0.0356 0.0324 0.0294 0.0268 0.0244 0.0222 0.0202 0.0184 0.0167** 

### 42 **0.0152 0.0138 0.0126 0.0114 0.0499** * HDV4 (Heavy-duty vehicles 4, M6 default RDs) **8 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218**  **0.0204 0.0191 0.0178 0.0167 0.0797** * HDV5 (Heavy-duty vehicles 5, same RD as HDV4, M6 Default) **9 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218**  **0.0204 0.0191 0.0178 0.0167 0.0797** * HDV6 (Heavy-duty vehicles 6, same RD as HDV4, M6 Default) **10 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218**  **0.0204 0.0191 0.0178 0.0167 0.0797** * HDV7 (Heavy-duty vehicles 7, same RD as HDV4, M6 Default) **11 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218**  **0.0204 0.0191 0.0178 0.0167 0.0797** * HDV8A (Heavy-duty vehicles 8A same RD as HDV4, M6 Default) **12 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218**  **0.0204 0.0191 0.0178 0.0167 0.0797** * HDV8B (Heavy-duty vehicles 8B,same RD as HDV4, M6 Default) **13 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218**  **0.0204 0.0191 0.0178 0.0167 0.0797** * HDBS (HDV School buses; this M6 RD default is assumed) **14 0.0393 0.0734 0.0686 0.0641 0.0599 0.0559 0.0522 0.0488 0.0456 0.0426 0.0398 0.0372 0.0347 0.0324 0.0303 0.0283 0.0264 0.0247 0.0231 0.0216**  **0.0201 0.0188 0.0176 0.0165 0.0781** * HDBT (HDV Transit buses; this M6 RD default is assumed) **15 0.0307 0.0614 0.0614 0.0614 0.0614 0.0614 0.0614 0.0614 0.0614 0.0613 0.0611 0.0607 0.0595 0.0568 0.0511 0.0406 0.0254 0.0121 0.0099 0.0081**  **0.0066 0.0054 0.0044 0.0037 0.0114** * MC (Motorcycles; this M6 default RD is assumed) **16 0.1440 0.1680 0.1350 0.1090 0.0880 0.0700 0.0560 0.0450 0.0360 0.0290 0.0230 0.0970 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000**  **0.0000 0.0000 0.0000 0.0000 0.0000**



### This MERD08AA.d file is derived ul timately from REGDATA.D, the default MOBILE6 RD file, but more immediatel y derived from an original MERD08.D file calculated using 2008 registration counts by age fo r LDVs. Due to the time frame in which this data was set, co unts for MY'09 vehicles omitted as nonrepresentative, and counts for MY’08 vehicles set to 75% of those for MY’07 vehicles, in accordance with U.S. EPA practice as given in MOBILE6 training materials available from OTAQ on line. This file was created in January 2009.

This data is ultimately derived from ISOS registration data for LDVs subject to I/M in the Metro-East-area counties. Since more than 85 % of the light-duty gasoline vehicles in the Metro-East area ar e subject to I/M, we assume the RD for Metro-East area LDVs subject to I/M is re presentative of that for all Metro-Eastarea LDVs, whether subj ect to I/M or not.

The ISOS data were counts for what IS OS calls "LDVs", LDT1s", and "LDT2s" by model year. Those appear below as SLDV, SLDT1, and SLDT2 to distinguish them from M6 vehicle types.

### 43  SLDVs correspond to passenger cars, so SLDVs = M6 LDVs.

 SLDT1s correspond to M6 LDT1s and LDT2s. ISOS data do not distinguish between the two M6 categories. For this reason, the RDs for M6 LDT1 and LDT2 are assumed to be the same.

 Similarly, SLDT2s correspond to M6 LDT3s and LDT4s, and ISOS data do not distinguish between those two M6 categorie s either. Therefore, the RDs for M6 LDT3 and LDT4 are also assumed to be the same. Of course the SLDT1 (LDT12) and SLDT2 (LDT34) RDs are not the same.

The age distribution fractions have been rounded to 4 decimal places, and where the rounded fractions do not add up to 1.0000 exactl y, RD fractions for old (age 22 to 24 years) have at times been modified by +/ - 0.0001 so as to make the RDs add up to 1.0000. (This is a requirem ent of the MOBILE6.)

See the default M6 RD file REGDATA.D a nd especially the M6 Users Guide Section 2.8.7.1 (p. 63 ff) for more detailed information about RD files. See also the actual MOBILE6 source code \SOURCE\BD20.FOR an d Illinois EPA’s previous local-area RDs (e.g., MERD03.D and MERD01.D ) for further information.

In this RD file, the first number in each dist ribution is an integer th at indicates which of the 16 M6 vehicle classes are represented by the RD in question. That number is followed by 25 age fractions arranged in two rows of 10 values followed by a third row with the last 5 values. (This is similar to th e format used in M5b for RDs, and is the same format as the default REGDATA.D file.)

RDs for all vehicle classes are given in this file. This is for completeness even though only those vehicle classes whose RDs were changed from the REGDATA defaults need to be included in this file. Those RDs that were not changed from default values are so noted.

It is assumed that the RDs for diesel ve hicles are the same as the RDs for the corresponding gasoline vehicles ; in particular, LDDV and LDDT RDs are assumed the same as LDGV and LDGT RDs. Since the (default) HDV RDs are based more on diesel vehicles to start with, and HDGVs are ma ny fewer than HDDVs, (i.e, most heavy-duty trucks are diesels) especially in the higher weight classes, we fe el the default HDV RDs represent both HDGV and HDDV reasonably well.

Default RDs are assumed for the various HDV classes. Good area-specific HDV age distribution data are lacking—t he ISOS data covered only lig ht-duty vehicles subject to I/M—and besides, much Metro-East-area HDV VM T is from vehicles registered outside the Metro-East area and just passing through. The best choice, then, was to go with the HDV defaults. Similarly, accurate local-ar ea registration data for motorcycles are lacking, so the default MC RD is used.

### 44 

### External MOBILE6.2 Activity File Inputs: VMT by Facility Type, VMT by Hour, VMT by Speed Bin

.

VMT by Facility Type

The M6.2 default file is FVMT.D, provided with the MOBILE6 model. There is no good Metro-East-area -specific VMT-by-facility-type data available, so the default FVMT.D file is used. This is a very long file —about 750 lines—so for the purposes of this Attachment, only the data for vehicle types 1 is reflected. The first data line of FVMT.D is **1 0.392 0.457 0.117 0.034** 

### ; it signifies that, for LD GVs (type 1) at hour 6AM, 39.2% of VMT is on Freeways, 45.7% is on Arte rials, 11.7% is on Local Roads/Streets, and 3.4% is on Ramps. Note that, during the day, the fraction of VMT on Arterials reaches a maximum, and decreases after the work day ends

**VMT BY FACILITY** ***** *** This is FVMT.DEF, the "default" FVMT file supplied with the M6 model.** ***** *** VMT fractions are listed for 28 vehicle classes for each hour of** *** the day starting at 6AM. There are 24 sets of four values for** *** each vehicle type. The VMT fractions by hour are the same** *** for all vehicle classes.** ***** *** The four values in each line represent the VMT distribution on** *** freeway, arterial, local and ramps--in that order--as shown.** ***** *** See M6UG 2.8.5.1.f., p. 49, or CLASLIST.TXT for further information.** *** (The CLASLIST file describes the vehicle classes.)** ***** *** Veh Int& Arts& Local** ***Class Fwys Colls Rd/St Ramps** ***----- ---- ----- ----- -----** ***** **1 0.392 0.457 0.117 0.034 0.344 0.497 0.129 0.030**  **0.338 0.497 0.135 0.029 0.349 0.492 0.129 0.030**  **0.346 0.497 0.127 0.030 0.333 0.509 0.129 0.029**  **0.324 0.516 0.132 0.028 0.334 0.506 0.131 0.029**  **0.334 0.506 0.131 0.029 0.320 0.519 0.134 0.028**  **0.330 0.506 0.135 0.029 0.312 0.521 0.140 0.027**  **0.295 0.538 0.141 0.026 0.310 0.527 0.137 0.027**  **0.329 0.510 0.133 0.029 0.343 0.497 0.131 0.030**  **0.381 0.460 0.126 0.033 0.405 0.437 0.123 0.035**  **0.426 0.418 0.118 0.037 0.443 0.403 0.115 0.039**  **0.457 0.394 0.110 0.040 0.461 0.391 0.107 0.040** 

### 45 **0.453 0.400 0.108 0.039 0.418 0.434 0.112 0.036** 


### FVMT data for vehicle types 2 through 28 are omitted for reasons of space.

VMT by Hour of the Day

The MOBILE6.2 default file is HVMT.D. The most current Metro-East St. Louis area-specific file is HVMTME04.def, s hown below, derived from 2004 modeling output from EWGCOG. Again, this file contains “commented-out” data from the default for comparison purposes.

**VMT BY HOUR** ***** *** Filename: HVMTME04.DEF** *** Fraction of all vehicle miles traveled by hour of the day.** *** First hour is 6 a.m. These data are for the Metro-East area for** *** 2004, following EWGCOG TM output in NEWBUDGET.XLS as calculated** *** by Illinois EPA in MESVMT.XLS, July '02, page "VMT by Hr".** ***** **0.0518 0.0796 0.0704 0.0505 0.0491 0.0529 0.0553 0.0519 0.0544 0.0578 0.0967 0.0909**  **0.0624 0.0354 0.0280 0.0240 0.0176 0.0131 0.0098 0.0078 0.0074 0.0073 0.0089 0.0169**  ***** *** These following are the default values from HVMT.DEF** *** which are supplied for comparison.** *** 0.0569 0.0740 0.0655 0.0555 0.0540 0.0582** *** 0.0608 0.0571 0.0598 0.0636 0.0777 0.0730** *** 0.0501 0.0389 0.0308 0.0264 0.0194 0.0144** *** 0.0108 0.0086 0.0081 0.0080 0.0098 0.0186**


### All these Hourly-VMT files s how similar profiles, with mo rning and afternoon peaks, a noontime dip, and a minimum about 3AM - 4AM, which is to be expected.

VMT by Speed Bin

The MOBILE6.2 default file is SVMT.D. The Me tro-East-area-specific Speed-bin file is VbySpd07.DEF, shown below. It repres ents 2004 EWGCOG transportation model output, deemed representative for future year s. Since it is a “wide” file (at least 90 columns), it is shown here in a smaller-than- usual typeface to make it easier to read

SPEED VMT 1 1 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 2 0.0000 0.0108 0.0020 0.0146 0.0095 0.0710 0.0497 0.1262 0.0838 0.0676 0.1530 0.2308 0.1810 0.0000 1 3 0.0000 0.0108 0.0020 0.0146 0.0095 0.0710 0.0497 0.1262 0.0838 0.0676 0.1530 0.2308 0.1810 0.0000 1 4 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 5 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 6 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 7 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 8 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 9 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 10 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000

### 46 1 11 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 12 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 13 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 14 0.0000 0.0000 0.0000 0.0000 0 0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 15 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 16 0.0000 0.0092 0.0078 0.0017 0.0063 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 17 0.0000 0.0092 0.0078 0.0017 0.0063 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 18 0.0000 0.0092 0.0078 0.0017 0.0063 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 19 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 20 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 21 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 22 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 23 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 24 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 2 1 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 2 0.0011 0.0025 0.0166 0.0664 0.1148 0.2216 0.2188 0.1577 0.0912 0.0910 0.0183 0.0000 0.0000 0.0000 2 3 0.0011 0.0025 0.0166 0.0664 0.1148 0.2216 0.2188 0.1577 0.0912 0.0910 0.0183 0.0000 0.0000 0.0000 2 4 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 5 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 6 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 7 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 8 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 9 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 10 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 11 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 12 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 13 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 14 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 15 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 16 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 17 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 18 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 19 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 20 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 21 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 22 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 23 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 24 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 * * Speed Bins: * 2.5 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0 50.0 55.0 60.0 65.0+



### Speed bins extend 2.5 mph on either side of the bin name (i.e., the 30-mph speed bin encompasses speeds from 27.5 to 32.5 mph), except for the first (2.5 mph) bin (0 to 2.5 mph) and the last (65+ mph) bin (62.5 mph and above).

The information in this file strictly speak ing represents a speed distribution for 2004, but is assumed, after discussion with the EWGC OG, to be reasonably valid throughout the period in question.

The above data are for the Metro-East area, and for Freeways and Arterials only. See M6 User's Guide Sec. 2.8.8.2.c and Appendix B, Table 5: "Average Speed Ranges for Speed Bins (SPEED VMT Command)" for further information about this file and its use. See also the default VMT-by-speed file SVMT .DEF for more information and comments.

The first number in each line is roadway type : 1 = Freeways; 2 = Arte rials. Locals and Ramps have a fixed speed in built into the M6 model, and therefore are not affected by this file. The second number is the hour of the day, hour 1 being [hour beginning at] 6 AM, and hour 24 being [hour begi nning at] 5 AM the next day. The third and subsequent numbers are the fractions of VMT in that hour that occur within the specified speed bins.

### 47 Note that, for Freeways, most VMT is in the 45-50-55-60-mph speed bins, with lower speeds more common during Peak hours, which is reasonable. Much the same holds for Arterials, where most VMT is in the 30-35- 40-45 mph speed bins, also reasonable.ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

Notice of Public Hearing for State Implementation Plan (SIP) Submittals For the Metro-East Ozone Nonattainment Area

The Illinois Environmental Protection Agency (Illinois EPA) will hold a public hearing on April 8,2010, at 10:30 a.m. in the Regional Conference Room at the Illinois Department of Transportation

- District 8 Offices, 1102 Eastport Plaza Drive, Collinsville, Illinois.

The hearing will be held by the Illinois EPA Bureau of Air for the purpose of gathering public
comments on the draft Maintenance Plan related to the 1997 8-hour ozone National Ambient Air Quality Standard (NAAQS) and the associated draft motor vehicle emissions budgets. The Illinois EPA intends to request that United States Environmental Protection Agency (US. EPA) redesignate the Metro-East nonattainment area, which includes Jersey, Madison, Monroe, and St. Clair Counties, to attainment of the 1997 8-hour ozone NAAQS based on ambient monitoring data from 2007 through 2009. The draft Maintenance Plan contains the State's plan for maintaining the 8-hour ozone NAAQS for at least 10 years after the US. EPA redesignates the

area to attainment. The SIP revisions will also establish new motor vehicle emissions budgets for the years 2008 and 2020 for the nonattainment area. When final, the Illinois EPA will submit both the Maintenance Plan and the motor vehicle emissions budgets to the U.S. EPA as SIP revisions to meet the requirements of the federal Clean Air Act (CAA). The hearing will satisfy the requirements of Section 110(1) ofthe CAA (42. US.C. 7401(1) (public notice for SIP submittals)).

Copies of these draft SIP submittals for the Metro-East nonattainment area may be viewed by the public prior to the hearing during regular business hours (Monday through Friday 8:30 a.m. until 4:30 p.m, except for State holidays) at the Illinois EPA's offices at 1021 North Grand Avenue East, Springfield, Illinois, and 2009 Mall Street, Collinsville, Illinois, as well as on Illinois EPA's website at http://www.epa.state.il.us. No walk-in requests for copies of this material will be accommodated. Requests and public inquiries should be directed to Dana Vetterhoffer at the address below.

The hearing will be held under the provisions of the Illinois EPA's "Procedures for Information and Quasi-Legislative Public Hearings" (35 Ill. Adm. Code 164). Any questions about the hearing procedures, requests for copies of the hearing rules, or requests for special need interpreters should be directed to the address below. Requests for special needs interpreters must be made by March 25,2010.

Closure of the Hearing Record. The Hearing Record will close on May 8, 2010. Comments need not be notarized, but must be postmarked by midnight May 8, 2010, and mailed to Dana Vetterhoffer, Illinois EPA, 1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276, telephone number 217/782-5544 or TDD 217.782-9143

.



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### Espaiiol a! reverse1 ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

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9

10 MAINTENANCE PLAN FOR THE METRO-EAST 8-HOUR OZONE NON-ATTAINMENT AREA. No. AQPSTR-10-01

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23

24 RECORD OF PROCEEDINGS

April 8, 2010

Reported by Holly A. McCullough, C.S.R., C.C.R., R.P.R.

1
Keefe Reporting Company

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1 ••

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Attachment 1141 ILLINOIS ENVIRONMENTAL PROTECTIO N AGENCY

2 MAINTENANCE PLAN FOR THE ) 3 METRO-EAST 8-HOUR OZONE ) No. AQPS TR-10-01 NON-ATTAINMENT AREA. ) 4

5

6

7 APPEARANCES: 8 Dean Studer, Hearing Officer/Right-To-K now Coordinator 9 Illinois Environmental Protection Agenc y 1021 North Grand Avenue East 10 P. O. Box 12976 Springfield, IL 62794-9276 11 Dana Vetterhoffer 12 Illinois Environmental Protection Agenc y Assistant Counsel 13 Division of Legal Counsel

14 David "Buzz" Asselmeier Illinois Environmental Protection Agenc y 15 Emission Inventory Coordinator Bureau of Air 16 Michael D. Rogers 17 Illinois Environmental Protection Agenc y Environmental Protection Specialist 18 Division of Mobile Source Programs

19 Robert J. Kaleel Illinois Environmental Protection Agenc y 20 Manager, Air Quality Planning Section Bureau of Air 21

22

23

24

2 Keefe Reporting Company1 BE IT KNOWN that a record was made on April 8,

2 2010, at 1102 Eastport Plaza Drive, Col linsville,

3 Illinois, before Holly A. McCullough, a n Illinois CSR,

4 a Missouri CCR and a RPR. Also, it is stipulated and

5 agreed that this record may be taken in stenotype by

6 Holly A. McCullough and thereafter tran scribed into

7 typewriting.

8

9 * * * * *

10

11 MR. STUDER: Let's go ahead and get started. It

12 is 10:30. So, we'll go on the record. I thank

13 everyone for coming out this morning on this beautiful

14 what at least was a sunny morning.

15 My name is Dean Studer, and I'm the hearing

16 officer for the Illinois Environmental Protection

17 Agency, otherwise abbreviated Illinois EPA. This

18 hearing is being held for the purpose o f gathering

19 public comments on the draft Maintenanc e Plan related

20 to the 1997 8-hour ozone National Ambie nt Air Quality

21 Standard, otherwise abbreviated as NAAQ S, and the

22 associated draft motor vehicle emission s budgets. The

23 Illinois EPA intends to request that th e United States

24 Environmental Protection Agency, USEPA, redesignate

3 Keefe Reporting Company1 the Metro-East non-attainment area, whi ch includes

2 Jersey, Madison, Monroe and St. Clair C ounties, to

3 attainment of the 1997 8-hour ozone NAA QS based on

4 ambient monitoring data from 2007 throu gh 2009. The

5 draft Maintenance Plan contains the Sta te's plan for

6 maintaining the 8-hour ozone NAAQS for at least ten

7 years after the U.S. Environmental Prot ection Agency

8 redesignates the area to attainment. T he State

9 Implementation Plan, SIP, revisions wil l also

10 establish new motor vehicle emissions b udgets for the

11 years 2008 and 2020 for the non-attainm ent area. When

12 final, the Illinois EPA will submit bot h the

13 Maintenance Plan and the motor vehicle emissions

14 budgets to the USEPA as SIP revisions t o meet the

15 requirements of the federal Clean Air A ct, CAA. The

16 hearing will satisfy the requirements o f Section

17 110(l) of the CAA, otherwise 42 U.S.C. 7401(l),

18 (public notice for SIP submittals).

19 This hearing is being held under th e provisions of

20 35 Illinois Administrative Code Part 16 4, Procedures

21 For Informational and Quasi-Legislative Public

22 Hearings. Copies of these procedures c an be accessed

23 on the website for the Illinois Polluti on Control

24 Board at www.ipcb.state.il.us, or if yo u do not have

4 Keefe Reporting Company1 ready access to the web, they can be ob tained from me

2 by request.

3 I point out that the hearing notice in this matter

4 indicates that the close of the comment period is

5 May 8th, 2010. However, since May 8th, 2010 falls on

6 a weekend, comments will be accepted as long as they

7 are postmarked by May 10th, 2010, which is the first

8 business day following May 8th.

9 Illinois EPA staff members present today will

10 introduce themselves and make presentat ions.

11 Following this overview, I will allow t he public to

12 ask questions or provide comments and a sk questions.

13 You are not required to verbalize your comments as

14 written comments are given the same con sideration and

15 may be submitted to the agency at any t ime within the

16 public comment period, which ends at mi dnight on

17 May 10th, 2010. Any person who wants t o make oral

18 comments may do so as long as the state ments are

19 relevant to the issues that are address ed at this

20 hearing and such person has indicated o n the

21 registration card that he or she would like to

22 comment. If you have lengthy comments or questions,

23 it might be helpful to submit them to m e in writing

24 before the close of the comment period, and I will

5 Keefe Reporting Company1 ensure that they are included in the he aring record as

2 exhibits.

3 Please keep your comments and quest ions relative

4 to the issues at hand. If your comment s fall outside

5 the scope of this hearing, I may ask yo u to proceed to

6 another issue. Remember, all written c omments,

7 whether or not you say them out loud, w ill become part

8 of the official hearing record and will be considered.

9 Cards are on the registration table, an d you can fill

10 them out and indicate if you would like to comment

11 today. Anyone who fills out one of the se cards will

12 also be notified by the Illinois EPA wh en the final

13 decision in this matter. The notificat ion will also

14 contain information as to how you may a ccess the

15 agency responsiveness summary. In this summary,

16 Illinois EPA staff will attempt to answ er all relevant

17 and significant questions raised at the hearing or

18 submitted prior to the close of the com ment period.

19 Again, the written record in this m atter will

20 close at midnight on May 10th, 2010. T herefore, all

21 written comments are accepted as long a s they are

22 postmarked on or before May 10th, 2010. During the

23 comment period, all relevant comments, documents or

24 data will also be placed into the heari ng as exhibits.

6 Keefe Reporting Company1 Please send all written documents or da ta to the

2 following address: Dana Vetterhoffer, and that's

3 D-A-N-A, V-E-T-T-E-R-H-O-F-F-E-R, Illin ois

4 Environmental Protection Agency, 1021 N orth Grand

5 Avenue East, P. O. Box 19276, Springfie ld, Illinois

6 62794-9276. This address is also liste d on the public

7 notice for the hearing today.

8 And for anyone wishing to make comm ent or ask

9 questions, I'd like to inform you that there is a

10 Court Reporter here today taking a verb atim record of

11 these proceedings for the purpose of ma king our

12 administrative record. For her benefit , please keep

13 the general background noise in this ro om to a minimum

14 so she can hear everything that is said . Also, when

15 you begin to speak, please state your n ame and, if

16 applicable, any governmental body organ ization or

17 association that you represent. If you are

18 representing yourself, you can state th at you are an

19 interested citizen or a member of the p ublic. Also,

20 for the benefit of the Court Reporter, please spell

21 your last name. People who have reques ted to speak

22 will be called upon in the order they h ave registered

23 to make a statement.

24 Before we start with the Illinois E PA's

7 Keefe Reporting Company1 presentation, I'd like to record a few exhibits in the

2 official record. For the record, Exhib it No. 1 is a

3 copy of the public notice -- is the not ice of the

4 public hearing. The draft Maintenance Plan is

5 Exhibit 2. And other documents may be entered into

6 the record as exhibits as we progress t oday.

7 Are there any questions on how we'l l proceed?

8 (No response.)

9 MR. STUDER: "No". Okay. With tha t, I'm going to

10 ask that the agency staff introduce the mselves and if

11 they could give a sentence or two as to their

12 involvement in this proceeding.

13 MR. KALEEL: My name is Robert Kale el. I'm the

14 Manager of the Air Quality Planning Sec tion within the

15 Bureau of Air. My section is responsib le for most of

16 the --

17 MR. STUDER: Please speak up so tha t we can hear.

18 MR. KALEEL: The planning section i s responsible

19 for most of the state implementation pl ans that were

20 prepared by the agency and submitted to USEPA,

21 including the one that we're talking ab out here today.

22 MR. ASSELMEIER: My name is David A sselmeier. I'm

23 known as Buzz. And I work for Rob Kale el as the

24 Manager of inventory and data support u nit of Air

8 Keefe Reporting Company1 Quality Planning Section, and my main t ask is to

2 compile emission inventories, primarily point and area

3 sources, use mobile sources others prov ide to me and

4 compile that information from the repor ts and numbers

5 and progress you'll see here.

6 MR. ROGERS: My name is Mike Rogers . I'm with the

7 Illinois EPA Division of Mobile Source Programs. I

8 deal with the motor vehicle emissions e stimates and

9 was involved in the preparation of the proposed motor

10 vehicle emissions budgets that are bein g adopted or

11 proposed to be adopted for transportati on conformity

12 purposes.

13 MS. VETTERHOFFER: My name is Dana Vetterhoffer,

14 and I'm here as Assistant Counsel for t he Illinois

15 EPA.

16 MR. STUDER: Thank you. With that, I think we'll

17 proceed with the presentation from Illi nois EPA staff,

18 and following the presentation, I'll gi ve a few more

19 directions on asking questions and maki ng comments

20 this morning.

21 MR. KALEEL: I'll go ahead and kick things off.

22 Again, my name is Rob Kaleel. We'll wo rk our way

23 through a power-point presentation that hopefully

24 summarizes the Maintenance Plan documen t that is

9 Keefe Reporting Company1 available on the website. Most of -- W ell, all the

2 material that's in this power-point is available

3 within the Maintenance Plan itself. So , we'll go

4 ahead and get started and walk it throu gh. I'd ask

5 that we hold questions until we've work ed our way

6 through the whole presentation. There are copies of

7 the presentation. If you didn't grab o ne, feel free

8 to go ahead and have it with you, write notes or

9 whatever.

10 I do want to apologize. There's a couple of

11 slides that are in that handout that ar e in the wrong

12 order. So, if you're going to follow d irectly from

13 that, then you'll see where we've chang ed things a

14 little bit. So -- The information is c orrect. It's

15 just the slides are in the wrong order in the handout.

16 So --

17 What I will do here is start things off. We're

18 going to do a tag team with Mike Rogers and Buzz

19 Asselmeier to present various parts of this

20 Maintenance Plan. I'll go ahead and st art it out with

21 discussion about just what the Maintena nce Plan is

22 intended to do and what the requirement s are.

23 The requirements are specified by U SEPA, what

24 constitutes an approval maintenance pla n. And I guess

10 Keefe Reporting Company1 before I get too far, the reason why we 're doing this

2 is that the Agency intends to make a re quest to USEPA

3 to redesignate the Metro-East counties, the four

4 counties that constitute the eight-hour ozone

5 non-attainment area.

6 Now, I want to be -- A couple of po ints there that

7 I want to make. What we're addressing today is the

8 version of the ozone standard that was promulgated by

9 USEPA in 1997. It's the .08 parts per million ozone

10 standard. A couple years ago EPA revis ed the standard

11 to .075 parts per million. And as prob ably most of

12 you are aware, USEPA this year proposed to tighten the

13 ozone standard even further. This Main tenance Plan

14 does not address the 2008 version of th e standard,

15 which EPA has more or less stayed, and it does not

16 address the proposed ozone standards th at EPA is

17 expected to finalize yet this year. We 're not making

18 any statements here in terms of a re-de signation. The

19 Metro-East area no longer has any ozone air quality

20 issues. What we're really trying to ac complish here

21 is to finish up the -- I guess the best word would be

22 the bureaucratic requirements of the st ate relative to

23 the 1997 standard. We fully expect the area will be

24 non-attainment for this standard -- wha tever version

11 Keefe Reporting Company1 of the standard the EPA finalizes this year. So, it

2 will be a transition from non-attainmen t for the 1997

3 standard more than likely into non-atta inment in the

4 future for a revised standard. I just want to make

5 that clear, that we're really trying to just put the

6 1997 standard to bed, and we fully reco gnize that

7 there's going to be more work to do in the future.

8 The Maintenance Plan is an element of a submittal

9 -- a required element of any submittal to USEPA to

10 redesignate the area, and it is conside red a revision

11 of our state implementation plan. Thus , we're

12 required to have a public hearing on it

.

13 The idea of a Maintenance Plan is t o provide

14 measures and commitments on the part of the State to

15 maintain the attainment status for this particular air

16 quality standard for a period of at lea st ten years.

17 It's taken a lot of hard work to reach the air quality

18 improvements and to reach the level of air quality

19 that we've achieved in the region to da te. The idea

20 of the Maintenance Plan is, "Okay. Now that we've

21 gotten here and redesignate to attainme nt, we can't

22 let it all unravel. We have to maintai n the measures

23 -- the control measures and the program s that have

24 gotten us here."

12 Keefe Reporting Company1 Part of the Maintenance Plan is to provide

2 assurances that if a violation were to occur in the

3 future, that there are provisions in th e plan,

4 contingency measures if you will, that will be

5 triggered upon those violations. So, i t's a

6 commitment on the part of the State of Illinois to

7 take corrective actions if for some unp lanned, unknown

8 reason air quality violations occur aga in in the

9 future.

10 These are some of the requirements in the

11 Maintenance Plan. One is having a comp rehensive

12 emissions inventory that represents the level of

13 emissions in the quote -- it's in quota tions in the

14 presentation -- attainment year. Attai nment is

15 actually evaluated from air monitoring data using

16 three years of data, and in the case of our present

17 situation, the Metro-East area, actuall y the entire

18 St. Louis Metropolitan area, both sides of the river,

19 reached attainment looking at three yea rs of our

20 quality data, 2007, 2008, 2009. For th e purpose of

21 our Maintenance Plan, we're using the m iddle of those

22 three years, 2008, to represent our att ainment year.

23 In the Maintenance Plan, we're also required to

24 project emissions out at least ten year s to be able to

13 Keefe Reporting Company1 evaluate whether or not we foresee any problems with

2 maintaining our attainment status. So, we projected

3 emissions out to the year 2020, try to see what we

4 expect to occur as a result of growth a nd as a result

5 of control measures that are already ad opted or

6 expected in the future, whether or not those levels of

7 emissions are consistent with maintaini ng the level of

8 the air quality standard.

9 Another commitment that the State i s making today

10 is that we will continue to operate our monitoring

11 network. We have a number of ozone mon itors

12 throughout the Metro-East area. The St ate of

13 Missouri, obviously, has monitors throu ghout the St.

14 Louis Metropolitan area. Once the area is

15 redesignated to attainment, the states are committing

16 to maintaining that monitoring network.

17 We have to make a demonstration tha t we have the

18 legal authority to implement and enforc e the control

19 measures that have been used to demonst rate attainment

20 in the area. We are making commitments to provide for

21 future updates of our emissions invento ry to allow us

22 to track emission level throughout this ten-year

23 period. Part of that is a requirement on the part of

24 major sources to provide an annual emis sion report to

14 Keefe Reporting Company1 the Agency.

2 There's another element that Mike R ogers will talk

3 about, that relates to transportation c onformity, a

4 program within the Clean Air Act, to en sure that any

5 transportation planning considers the c ontrol measures

6 that are included in our attainment pla n, and that

7 process is called "conformity".

8 We're committing today to submit a revised plan

9 eight years after USEPA has redesignate d the area to

10 attainment. We not only have to mainta in the standard

11 for ten years, we have to maintain the standard

12 perpetually from this date forward. So , our plan is

13 for a ten-year period, and in eight yea rs, we'll come

14 up with another plan for the subsequent ten-year

15 period.

16 We're making a commitment to enact and implement

17 any contingency measures as quickly as possible to

18 correct any future violations of the ai r quality

19 standard that may occur. We don't expe ct that, but it

20 could happen, and we are committing to address that in

21 the future should it happen. We've inc luded in our

22 Maintenance Plan a list of potential me asures that

23 would be implemented if such violations occur.

24 This graphic depicts measured air q uality in the

15 Keefe Reporting Company1 region. The region we're talking about , of course,

2 for the Metro-East areas is Jersey, Mad ison, St. Clair

3 and Monroe Counties. Those are highlig hted here. I

4 don't know what color you'd call that, but it's kind

5 of a brownish, goldish, yellowish. Any way, you can

6 see it for yourself. That's just a por tion of the St.

7 Louis non-attainment area. The corresp onding counties

8 on the Missouri side of the river are a lso shown.

9 And what's depicted on the two grap hics, the two

10 slides are the monitored design values for ozone.

11 These would be the values that are used to compare to

12 the air quality standard to determine w hether or not

13 you're attaining or whether or not you' re violating

14 air quality standard. The little red t riangles

15 represent the locations of all the moni tors in the

16 areas, and the numbers next to those tr iangles are the

17 actual measured design values. You'll notice the

18 graphic on the left is the ozone levels in the area

19 during the three-year period of 2001 th rough 2003.

20 That's a three-year period of data that got us in the

21 non-attainment to begin with. And you' ll notice

22 eight-hour ozone values in the 80's, ev en some in the

23 90's. The units we're talking about no w, instead of

24 parts per million, we're more used to t alking about

16 Keefe Reporting Company1 them in the context of parts per billio n. So, instead

2 of having a decimal point there, you're seeing whole

3 numbers, but -- Values above 85 parts p er billion are

4 considered violations of the standard, and back in

5 2001 through 2003, we had a number of t hose. Thus,

6 the area was designated non-attainment.

7 The image on the right are the most recent three

8 years of data that we have available, 2 007 through

9 2009, and you'll notice a great deal of improvement in

10 the measured ozone levels. Instead of having values

11 of in the upper 80's or low 90's, I bel ieve the

12 highest one in the area right now is -- actually, on

13 the Illinois side is 77 parts per billi on, which is

14 well below the 85 ppb level of the stan dard. So,

15 clearly the area -- air quality is impr oved

16 dramatically over this period of time a nd does qualify

17 for re-designation for attainment.

18 Mike Rogers just pointed out, there is a 78 over

19 in St. Charles County. So, that would represent the

20 highest value in the region right now b ased on the

21 three most recent years of data.

22 Now, this is a list of some of the control

23 measures that help to improve air quali ty. There's a

24 series of these that provided substanti al emission

17 Keefe Reporting Company1 reductions of ozone precursor emissions , whether it's

2 a volatile organic compound, VOC's, or nitrogen

3 oxides, also called NOx. And I won't r ead through

4 this whole list, but there's a combinat ion of point

5 source control measures and motor vehic le control

6 measures and even some that would relat e to what we

7 call area sources. So, there's a range of measures.

8 These have greatly reduced emissions ov er this time

9 period. And I think Buzz Asselmeier ha s a chart in a

10 little while that will quantify the eff ects of the

11 control measures and show you what the actual numbers

12 look like.

13 In terms of control measures, from this point

14 forward, the measures that we believe w ill help us

15 maintain the attainment status for this air quality

16 standard. Again, I won't go through th e whole list.

17 Some of these appeared on the previous list, and they

18 appear in both places because some of t hese measures

19 are not fully mature. We expect them t o continue to

20 provide greater emission reductions in future years

21 all the way out to the year 2020. So, we believe

22 these measures -- and this is probably not a complete

23 list, but these measures are sufficient to maintain

24 the level of emissions in the area and keep the area

18 Keefe Reporting Company1 in attainment during the next ten-year period.

2 I'd like to turn it over now to Buz z Asselmeier,

3 who will discuss and summarize our emis sion

4 inventories.

5 MR. ASSELMEIER: As Rob said, my na me is Buzz

6 Asselmeier, and that's spelled A-S-S-E- L-M-E-I-E-R.

7 And I deal with inventories and numbers most of my day

8 at work here. The next slide --

9 MR. KALEEL: You're not going to sp ell Buzz; are

10 you?

11 MR. ASSELMEIER: Two Z's with Buzz. Sometimes

12 people spell it with one.

13 Part of my job with doing the inven tory is, again,

14 for the attainment year was -- 2008 was the one that

15 was selected, and, as Rob said, we're r equired to do a

16 full, complete inventory for the 2008 y ear, and that

17 includes the different point area, on-r oad and

18 off-road sources. Again, point sources , definitely

19 you've got industry, big companies, thi ngs like that,

20 where we get our data from them typical ly through

21 annual emission reports. Or if they're real small

22 companies, they may be from what we had from permit

23 applications, things like that.

24 Area sources, think of it as maybe your consumer

19 Keefe Reporting Company1 solvents, your house painting, your tra ffic line

2 marking on the roads, things like that. They're more

3 population based or spread over a large area. A lot

4 of times things like dry cleaners and a uto body

5 ventures fall into this category, also. USEPA has

6 emission factors you can use to calcula te emissions

7 from those. So, again, they'll say, "W ell, there will

8 be so many emissions per person in the county or

9 emissions per employee at the company f or that type of

10 industry.

11 On-road, again, cars, trucks, motor cycles. USEPA

12 has a computer model that feeds a bunch of information

13 into there and calculates emissions.

14 Off-road motor vehicle sources, aga in, lawnmowers,

15 tractors, combines, doesn't really work here for ozone

16 season, but snowmobiles, basically any engine that's

17 off road. It also does include locomot ives,

18 commercial marine vessels on the river -- Kaskaskia

19 River doesn't really hit us here with t he area we're

20 in -- and also aircraft. For the commo n off-road

21 types, there's what's called non-road m odel. Again,

22 USEPA modeled that. It combines the in formation,

23 calculates emission. For the things th at I have

24 marked there for locomotives, commercia l marine and

20 Keefe Reporting Company1 aircraft, those are not done by the non -road model,

2 but there are, again, standard methodol ogies, emission

3 factors typically, to calculate those e missions. So,

4 again, using all that together, we came together and

5 calculated the full non-attainment area inventory for

6 2008.

7 And from that, you can see at least at the bottom

8 there, those are the numbers that came up for 2008

9 numbers. Those -- It doesn't have unit s on there, but

10 those units are tons per day. When we' re dealing with

11 the ozone standard, we use tons per day and hot,

12 bright, sunny, summer days where ozone formation is

13 conducive.

14 Just for information up there, we d id the same

15 thing for initial base year inventory f or 2002. So,

16 again, kind of give a little comparison there of what

17 happened between 2002 and 2008 with som e of the

18 control measures like Rob pointed out e arlier.

19 For the future year, what we do is, like Rob said,

20 we wanted to at least forecast out at l east ten years

21 for the transportation conformity, and they go through

22 that every year. So, that's why we hav e 2020 picked

23 out. Again, you don't know what's goin g to exactly

24 happen in future years with that, but t here are what

21 Keefe Reporting Company1 USEPA calls growth factors or economic based

2 predictions of what will happen in the future. So,

3 what you do is, you take -- for the poi nt sources, you

4 take what happened in 2008, and based u pon the model

5 of what the predicted economic activity , you used that

6 factor and multiply by 2008 to get your future year.

7 That factor could be greater than one, which means

8 growth; it could be less than one, whic h means decline

9 in emissions. So, it depends what indu stry what's

10 happened.

11 We also take into account as to the best of our

12 knowledge what new plants are coming in . Ethanol

13 plants were in fashion when we were doi ng this. Not

14 as many have been truly constructed, bu t we have kept

15 those in the inventory just to account for them. The

16 coke plants, any modifications we know about, things

17 like that. New rules with the NOx and CAIR rules, how

18 those will affect future year emissions , particularly

19 NOx in this case, if anybody is shuttin g down and this

20 changes. And, also, the one we do have is -- for the

21 refinery is the consent decrees. So, t here was also

22 the more formal action that said, "Here 's how the

23 emissions will be reduced." So, we inc lude that in

24 the plan, also, in the future inventory

.

22 Keefe Reporting Company1 The automobile sources and off road for the

2 MOBILE6 and non road are very nice. Th ey have

3 predictions of what sleep turnover is. We have our

4 inputs of fuel volatility, what the fue ls will be in

5 future years, things like that. That g ets fed into

6 the model in numbers, and the emissions are spit out.

7 For anything off road, FAA usually has kind of a

8 predicted of what the flights and landi ngs and

9 takeoffs will look like in future years . We use that,

10 again, for the larger airports. There' s not as many

11 here in this area. Again, for Mid-Amer ica/Scott Air

12 Force Base, we know certainly there's n ot a lot of

13 commercial traffic in there, but we do know that they

14 have been going for more cargo type thi ngs, and we've

15 accounted for that maybe a little bit m ore than we

16 needed to, but just to be safe on how t hat may grow in

17 the future.

18 So, when all these get thrown in th ere and the

19 growth gets applied, we have this resul t from what

20 happens between 2008 and 2020.

21 I probably should also mention that for a lot of

22 area sources, like the consumer solvent s or the

23 architectural maintenance coating ones where there are

24 rules that have been passed, we do redu ce those

23 Keefe Reporting Company1 emissions in the inventory. So, we als o take credits

2 for reduction and the new rules we have passed.

3 So, again, we have more the hard co re numbers

4 here. Page on to the next one and see a pie chart in

5 this case to show a little bit more act ually where the

6 emission reductions are coming from or how the growth

7 happens. Here, you'll see, for NOx, an d the area

8 sources really don't matter too much. Probably the

9 only place NOx comes from is fuel combu stion. Again,

10 point sources, relatively the same life and percentage

11 overall, again, where the on-road reduc tion of NOx are

12 going to be coming big in the future.

13 Next slide. Same kind of chart for VOM emissions.

14 Again, VOM we pick up a little bit more in area

15 sources in this case. Again, as I said , it's your

16 consumer solvents. It's just large are a sources.

17 Again, primarily based on population. So, while the

18 emissions may be increasing a little bi t because the

19 models predict population growths, new rules coming

20 in, we'll probably reduce that fraction a little bit

21 more of how those contribute. Again, t he on-road

22 sources, again, have the biggest reduct ion in VOM

23 emissions for the area, and that's, aga in, why the

24 area seem to -- the area sources seem t o grow. They

24 Keefe Reporting Company1 probably grow a little bit, but not cer tainly, you

2 know, outflank everything.

3 The next slide. And if you want to look down a

4 little bit more of chart type informati on, and that

5 will actually show how emissions do dec rease from 2008

6 to 2020, and in this case, this is for the NOx

7 emissions. So, again, a little bit rep resentative.

8 You can see how area doesn't play a rol e, but the

9 purple area shows a large reduction bet ween 2008 and

10 2020.

11 And, again, the same for VOM emissi ons. So, you

12 can see how that -- The 2013 on there f or the year is

13 just, again, to have a midpoint in the year -- that's

14 kind of midpoint between 2008 and 2018, just to have a

15 comment and look to see where we're goi ng and what we

16 predicted for the midpoint and where we 're at.

17 As the matter of requirements from USEPA, we are

18 required to do a full-blown inventory l ike we've done

19 for 2008, we're required to do that eve ry three years.

20 So, again, I'll be going through that a gain in 2011,

21 2014. We'll probably do 2013, also, to take a look

22 for our midpoint to see how we're doing against our

23 predictions. And, again, that can also serve as a

24 clue of whether we are having problems of meeting the

25 Keefe Reporting Company1 requirements, if the rules we proposed or the rules

2 enacted are helping us.

3 I think that's it for me.

4 MR. KALEEL: Thank you, Buzz. I wa nt to talk for

5 a minute about the contingency measure as part of our

6 Maintenance Plan. Again, the idea of c ontingency

7 measures -- I talked about them briefly in my earlier

8 remarks -- it's intended to provide som e sort of

9 corrective action in the event of viola tions of the

10 air quality standard should occur again in the future.

11 We've built into our plan or our approa ch what we call

12 a Level 1 and a Level 2 contingency mea sure, and I'll

13 talk a little bit more about what those are. I guess

14 the point I'd like to make right now is that it's only

15 the second level that's actually requir ed by USEPA.

16 We've -- We're voluntarily performing a first level of

17 response prior to actually getting viol ations of the

18 air quality standard with the whole set so we can

19 avoid any future violations by taking e arlier actions.

20 Here's a better explanation of what I mean. The

21 Level 2 response is what we do in the e vent that

22 there's an actual violation of an air q uality

23 standard. The way the standard is writ ten right now,

24 it actually requires -- it's taken over three years,

26 Keefe Reporting Company1 as I mentioned before. It's an average of the fourth

2 highest values over three years. That' s what's called

3 the form of the standard. We talked be fore about the

4 level of the standard being .08 parts p er million or

5 85 parts per billion. So, it would rea lly take

6 multiple exceedances of the 85 ppb leve l before you

7 violate the standard. But what we're c ommitting to do

8 is a first-level response in the event that we have

9 four values above 85 ppb in any one yea r. The idea

10 there is, obviously, there's something wrong with our

11 planning if we're starting to see value s above 85 ppb

12 repeatedly in the same year, and at tha t point we will

13 try to figure out what happened. Is th ere something

14 wrong with our plan? Is it just advers e meteorology

15 in a particular year? And see if there 's something we

16 can do to forestall two more years of h igh level of

17 ozone, which would ultimately result in a new

18 violation. So, again, the Level 1 resp onse is not a

19 requirement. It's a voluntary action o n our part.

20 It's voluntary for the State of Illinoi s to do this.

21 Again, it's to try to head off any futu re violations.

22 Our initial response to either a Le vel 1 or a

23 Level 2 trigger is to look at the circu mstances that

24 have caused the high ozone. Is it just due to an

27 Keefe Reporting Company1 unusual year of meteorology, looking at weather

2 patterns? Is it an extremely ozone con ducive summer

3 that is unlikely to occur? Is it due t o impacts from

4 upwind areas, better known as long rang e transport?

5 Is it due to emission trends in the are a that are

6 going against what we're expecting toda y? We're

7 starting to see emissions going up rapi dly within the

8 non-attainment area itself. We'll look also at how

9 quickly we can implement new measures, especially in

10 that Level 1 trigger. If we find that there's

11 something going on locally, but it's go ing to take us

12 five years to address it, then there's no way under a

13 Level 1 trigger to actually forestall t he second and

14 third year problems. So, we will look at how quickly

15 we can implement measures and weigh mor e heavily in

16 our response, those measures that can b e done quickly.

17 We'll continue to evaluate new cont rols

18 technologies that may yield better emis sion reductions

19 and are currently in our plan, and we'l l look at the

20 suitability of either limiting the geog raphic

21 applicability or perhaps even expanding the

22 geographical applicability of a conting ency measure,

23 again, depending on what is causing the problem.

24 These are some potential contingenc y measures, and

28 Keefe Reporting Company1 some of these measures have already bee n adopted by

2 the State of Illinois or by the USEPA. We expect

3 these will continue to provide emission reductions in

4 the future. If you recall the two slid es that Buzz

5 showed that show continued emission red uctions between

6 2008 and 2020, these are some of the me asures that

7 Buzz has accounted for that have result ed in that

8 downward trend, but there are some othe rs here that --

9 in particular Phase 2 of USEPA's CAIR r ule, CAIR being

10 the Clean Air Interstate Rule, that has not yet been

11 adopted. We expect USEPA to propose a new CAIR rule

12 within the matter of the next few month s, and,

13 obviously, the Illinois EPA will adopt appropriate

14 measures to address that once USEPA has promulgated.

15 I mentioned earlier some other comm itments that

16 the State is formally making and consis tent with this

17 Maintenance Plan. One is to redo the M aintenance Plan

18 eight years after USEPA has redesignate d the area.

19 This would provide a new maintenance pl an for a

20 subsequent ten-year period. Buzz menti oned that we do

21 emission inventories every three years. We're going

22 to commit to continue to do that every three years.

23 This would allow us to evaluate emissio n trends and

24 make sure that we're still on the downw ard slope in

29 Keefe Reporting Company1 the coming ten-year period.

2 MR. ASSELMEIER: Let me also point out, that's the

3 full-blown inventory every three years. We also do

4 the point source inventory -- a full-bl own point

5 source inventory every year. So, there we can also

6 see where we might be having problems.

7 MR. KALEEL: Okay. We will continu e to operate an

8 adequate monitoring network. It doesn' t mean that

9 from time to time a particular monitor may need to be

10 moved. We typically have our monitors on rooftops of

11 buildings that the State doesn't own, a nd from time to

12 time they either don't want us there or the building

13 is torn down or for whatever reason we have to move

14 the site. Those changes in our monitor ing network are

15 always available in advance of the chan ge to the

16 public and must be approved by USEPA, b ut we will

17 continue to operate an adequate monitor ing network.

18 We have the authority and will cont inue to enforce

19 the applicable requirements in our stat e

20 implementation plan, and we commit to i mplement the

21 contingency measures appropriate with t he Level 1 and

22 Level 2 triggers that I talked about ea rlier.

23 I'll turn it over to Mike Rogers to talk about

24 transportation conformity.

30 Keefe Reporting Company1 MR. ROGERS: Good morning. My name is Mike

2 Rogers, R-O-G-E-R-S. I'm with the Illi nois

3 Environmental Protection Agency's Divis ion of Mobile

4 Source Programs. I prepared the transp ortation

5 conformity discussion of the Maintenanc e Plan dealing

6 with the establishment of the proposed motor vehicle

7 emissions budgets.

8 Transportation conformity is requir ed under

9 Section 176 of the Clean Air Act, and i ts purpose is

10 to ensure that federally supported high way and transit

11 project activities are consistent with or confirm to

12 the purpose of the state air quality im plementation

13 plan or SIP. Conformity to the purpose of the SIP

14 means that transportation activities wi ll not cause or

15 contribute to new air quality violation s, worsen

16 existing violations or delay timely att ainment of the

17 relevant national ambient air quality s tandard. This

18 is done by requiring that motor vehicle emissions of

19 applicable pollutants, in this case vol atile organic

20 materials, VOM, and oxides of nitrogen, NOx, are less

21 than or equal to the budget levels esta blished in the

22 SIP. This Maintenance Plan SIP is esta blishing VOM

23 and NOx motor vehicle emissions budgets for the years

24 2008 and 2020. The year 2008 is the at tainment year,

31 Keefe Reporting Company1 and 2020 is the final year of the Maint enance Plan.

2 As described in detail in the Maint enance Plan

3 document, the motor vehicle emissions b udgets were

4 developed using assumptions that are co nsistent with

5 those used in both the previous Metro-E ast St. Louis

6 8-Hour Ozone Attainment Demonstration a nd the

7 Reasonable Further Progress plans. The major

8 assumptions included the projected grow th rate of

9 vehicle miles of travel, the fuel used, the type of

10 vehicle inspection program and the char acteristics of

11 the motor vehicle fleet.

12 The proposed 2008 motor vehicle emi ssions budget

13 was developed using average summer week day vehicle

14 miles traveled, or VMT, estimates for J ersey, Madison,

15 Monroe and St. Clair Counties converted from actual

16 2008 annual VMT data from the Illinois Department of

17 Transportation. The Metro-East St. Lou is summer

18 weekday total was 18.26 million miles. The 2020

19 emissions budget was developed by growi ng the 2008 VMT

20 level by 1.5 percent per year for a pro jected level of

21 21.83 million miles.

22 Other key elements involved in the development of

23 the proposed motor vehicle emissions bu dgets are the

24 type of fuel to be used in the region a nd the

32 Keefe Reporting Company1 parameters of the vehicle emissions tes ting program.

2 The Maintenance Plan assumes the contin ued use of

3 southern grade reformulated gasoline or RFG, which has

4 been required in the area since July, 2 007. The plan

5 also assumes the continued operation of the vehicle

6 inspection and maintenance program or I and M program.

7 The I and M program requires all model year 1996 and

8 newer gasoline-powered vehicles registe red within the

9 test area to pass an on-board diagnosti cs test every

10 two years as a condition of renewing th eir license

11 plates.

12 The main control programs responsib le for reducing

13 motor vehicle emissions both in the Met ro-East St.

14 Louis area and nationwide are the USEPA 's national

15 Tier 2 light-duty engine emissions stan dards and

16 gasoline sulfur levels that took effect in 2004 and

17 the 2007 Heavy-Duty Highway Rule, which established

18 national heavy-duty truck and bus engin e emissions and

19 diesel sulfur limits. The Tier 2 stand ards, which

20 apply to model year 2004 and later gaso line and

21 diesel-powered light-duty gasoline vehi cles, including

22 cars, sport utility vehicles, minivans and pickup

23 trucks, established more stringent emis sions standards

24 for VOM, NOx and particulate matter or PM. This

33 Keefe Reporting Company1 program also established limits on the amount of

2 sulfur and gasoline, limiting it to an average of

3 30 parts per million compared to the pr e-regulation

4 level of 300 parts per million. This c leaner fuel

5 allows engine manufacturers to use adva nced emissions

6 control equipment, which would not func tion properly

7 in the presence of the higher sulfur co ncentrations.

8 The 2007 Heavy-Duty Highway Rule es tablished more

9 stringent NOx and PM emission standards for heavy-duty

10 trucks and buses. The standards were b ased on the use

11 of high efficiency catalytic exhaust em ission control

12 devices and a 97 percent reduction in t he sulfur

13 content of diesel fuel. The USEPA heav y-duty engine

14 standards, which took effect in 2007, w ere expected to

15 result in PM and NOx emissions levels t hat are

16 90 percent and 95 percent, respectively , below

17 pre-regulation levels. To enable these technologies,

18 the sulfur limit in diesel fuel was lim ited to

19 15 parts per million beginning in June, 2006. The use

20 of this ultra-low sulfur diesel is also now required

21 in off-road equipment applications such as in

22 construction equipment. The combinatio n of Tier 2

23 standards, the Heavy-Duty Highway Rule and the

24 associated fuel sulfur limits result in significant

34 Keefe Reporting Company1 further reduction in motor vehicle emis sions between

2 2008 and 2020.

3 The Metro-East Maintenance Plan pro posed motor

4 vehicle emissions budgets were develope d using USEPA's

5 MOBILE6.2 emissions factor model. In D ecember, 2009,

6 the USEPA released its new motor vehicl e emission

7 model named MOVES2010. USEPA guidance allows states

8 and Metropolitan planning organizations a two-year

9 grace period to continue to use MOBILE6 .2 before being

10 required to switch to the MOVES2010 mod el. The

11 Illinois EPA intends to recalculate the motor vehicle

12 emissions budgets proposed in the Maint enance Plan

13 using MOVES2010 within the next 18 mont hs.

14 Incorporating the above assumptions results in the

15 following 2008 and 2020 motor vehicle e missions

16 estimates, which we are proposing to be established as

17 motor vehicle emissions budgets for the purposes of

18 conducting transportation conformity. The proposed

19 2008 motor vehicle emissions budgets ar e: 16.53 tons

20 per day for VOM and 30.84 tons per day for NOx. The

21 proposed 2020 motor vehicle emissions b udgets are:

22 7.70 tons per day for VOM and 10.34 ton s per day for

23 NOx.

24 MR. KALEEL: That concludes our pow er-point

35 Keefe Reporting Company1 presentation, and we're available to an swer any

2 questions that you may of.

3 MR. STUDER: Thank you. Before I g o ahead and

4 open the floor for questions, I just wa nt to go over a

5 few preliminary points. We only have a handful of

6 people here. So, normally I put a time limit on those

7 that are making comments and asking que stions of 5 to

8 10 minutes. I'm going to allow up to 1 5. We'll go

9 through -- There's only a couple people that have

10 indicated they want to speak. We'll go through those

11 few people. Anyone else in the room th at hasn't

12 spoken that wants to will be given that opportunity,

13 and then we'll come back to those that ran out of

14 time. When you come forward, I guess y ou can stay

15 seated. We're small enough. I just as k that you

16 speak up. We have to be able to hear w hat is being

17 said to get an accurate administrative record. When

18 you speak, please state your name and s pell your last

19 name, and then if you are representing a group, please

20 indicate that when you give your name. Also, if you

21 are not representing a group, you can j ust indicate

22 that you're an interested citizen or in dicate that

23 you're just a member of the public.

24 With that, are there any questions?

36 Keefe Reporting Company1 (Raise of hands.)

2 MR. STUDER: Okay. The first perso n that I'm

3 going to call is Jack Norman, and we'll come back to

4 you. I'm assuming your question wasn't on the

5 procedures.

6 MR. ALEC DAVIS: Correct.

7 MR. STUDER: I didn't state that cl early. I'm

8 sorry. Jack Norman you were first.

9 MR. JACK NORMAN: Thank you, Mr. St uder. My name

10 is Jack Norman. I'm a citizen. I just applied for a

11 copy of my birth certificate if anybody wants to

12 challenge that because we can't find ou r passports.

13 That's not relevant to this topic, but just so you

14 know.

15 My first question is, in giving as surances to EPA

16 that this is all going to work out, wha t kind of

17 assurances are they after? We have gen eral simply

18 policies involved potentially. We have budget

19 considerations involved. What are they looking for in

20 the way of assurance?

21 MR. KALEEL: Well, the federal gove rnment has

22 provided us with certain guidance docum ents -- I don't

23 know if they're actually included withi n the

24 Maintenance Plan, but they're reference d there -- that

37 Keefe Reporting Company1 specify what it is we need to address i n the context

2 of a maintenance plan. You know, obvio usly, we work

3 for the legislature. If the legislatur e were to undo

4 some of the things that are contained i n our state

5 implementation plan, USEPA would expect the State of

6 Illinois to take corrective action. Sa y if the

7 legislature hypothetically were to undo one control

8 measure, we'd have to substitute someth ing else. Our

9 commitment is to keep the emission leve ls -- keep them

10 from trending upward during this ten-ye ar period and

11 to take corrective action if we have ne w violations of

12 the standard, and we'll have to respond if

13 circumstances change.

14 MR. JACK NORMAN: That sounds like a variety of

15 adaptive management perhaps.

16 MR. KALEEL: That's a good term, ye s.

17 MR. JACK NORMAN: A lot depends app arently on the

18 monitoring station readings, and in tur n it seems to

19 me that might depend on where they are. Let me give

20 you an example and see what you have to say about it.

21 When a shift occurs in the location of vehicle

22 emissions, for instance, when the new I -70 bridge

23 opens to traffic, but if the location o f the regional

24 ozone monitors does not change, could r eported

38 Keefe Reporting Company1 compliance with the national air qualit y standards

2 change? And if not, why not?

3 MR. KALEEL: That's an interesting question, and

4 we are aware of the proposal or the pla ns to build a

5 new bridge downtown. If you recall the one slide --

6 maybe I can get it back here -- that sh owed the

7 location of the monitors --

8 MR. JACK NORMAN: Yeah.

9 MR. KALEEL: -- we do have a number of monitors

10 throughout the area. Ozone is -- We've maybe had some

11 presentations on this in the past. I d idn't get into

12 it today. Ozone isn't a pollutant that 's directly

13 emitted say by a new highway that's run ning through

14 the middle of the urbanized area. It's a result of

15 chemical reactions that occur in the at mosphere in the

16 presence of sunlight. The chemicals th at are directly

17 emitted are known as precursors, and we 've talked

18 about the two key ones, the VOM and NOx . It takes a

19 little while for those emissions to rea ct, to form

20 ozone. It could take, you know, depend ing on the

21 circumstances, anywhere from an hour to two hours, and

22 normally there's at least some level of wind, maybe

23 not a lot in St. Louis in the summertim e, but at least

24 some movement of those precursor emissi ons while

39 Keefe Reporting Company1 they're reacting over that one or two h ours that it

2 takes to form ozone. So, you usually d on't see high

3 ozone levels right down in the urbanize d area. You

4 usually see them downwind of the area.

5 More of a focal point in our monito r locations, at

6 monitor locations north of the downtown area, and

7 that's kind of in recognition of the fa ct that on

8 these high summer days, typically you h ave a southerly

9 wind flow. So, I guess I'd be surprise d if there's a

10 circumstance where we are going to have violations of

11 an ozone standard that wouldn't be pick ed up by this

12 monitoring network. Usually high ozone isn't really

13 real localized. It's going to be almos t an air mass

14 the size of the urban area that would h ave the high

15 ozone. I guess I wouldn't expect that.

16 The other side of this is, as we co ntinue to look

17 at the air quality standards, we also r un models, and

18 a lot of people don't like models, but the one

19 advantage to models is you can do thing s at a much

20 higher resolution and a much lower cost than you can

21 through monitoring. So, I think perhap s by

22 maintaining a reasonably good monitorin g network and

23 the modeling exercises that we do, that if there's

24 something that we're missing with the m onitoring,

40 Keefe Reporting Company1 we'll see it with the models. I don't know if that

2 directly answered your question, but --

3 MR. JACK NORMAN: Well, what I'm he aring is

4 because of the time lapse and the chemi stry involved

5 here and the mixing that goes on anyway , it would be

6 hard to anticipate what effect, if any, a shift in the

7 location of the emissions would have. You wouldn't

8 expect it to be hardly identifiable bec ause it's not

9 dramatic.

10 MR. KALEEL: You gave a more concis e and better

11 answer than I did, but I guess that's a better

12 reflection of what I was trying to say.

13 MR. JACK NORMAN: I've got one more quickly.

14 MR. STUDER: Sure.

15 MR. JACK NORMAN: In the anticipate d economic

16 growth in the region, you gave us a per centage that

17 the plan you base on -- an anticipatory percentage.

18 Now, is the assumption that that would be uniform, or

19 would that be perhaps site specific, a bunch happening

20 in Madison County, but not generally th roughout the

21 region?

22 MR. KALEEL: I'd let Buzz address t hat.

23 MR. ASSELMEIER: The growth factors themselves,

24 what you read in the model, are specifi c for the St.

41 Keefe Reporting Company1 Louis area. So, if I -- Not a true exa mple here, but

2 if I have a steel plant in Madison Coun ty and a steel

3 plant in Monroe County, the growth fact or will be

4 outputted the same because, again, it's looked at more

5 as an economic region. Now, again, a g rowth factor

6 for a steel plant will not be the same as a growth

7 factor for chemical manufacturing, not the same as for

8 a refinery. The industry specific type growth factors

9 are different from each other.

10 MR. JACK NORMAN: Site location wou ld be the key?

11 MR. ASSELMEIER: Right. So, yes. Again, how Rob

12 was talking, my inventory will have, "O kay. Here's

13 where the plants are located. Here's h ow we think

14 they will grow." That can be fed into the model, and

15 that's how the actual specific location gets

16 incorporated.

17 MR. JACK NORMAN: Thank you.

18 MR. KALEEL: To add to that a littl e bit, they're

19 not all just economic factors that are considered in

20 the growth. A lot of them are populati on based and,

21 in the case of motor vehicles, the grow th and vehicle

22 miles traveled. So, they consider even in the future

23 through the transportation model that E ast West

24 Gateway runs, even consider future lane changes.

42 Keefe Reporting Company1 Those would all be considered in the ch anges in the

2 inventory that we're projecting.

3 MR. JACK NORMAN: Thank you.

4 MR. STUDER: Thank you, Mr. Norman. Alec Davis.

5 MR. ALEC DAVIS: That's right. Aga in, Alec Davis,

6 D-A-V-I-S. I represent the Illinois En vironmental

7 Regulatory Group. My first question is , to mention

8 now twice, the re-designation requests, I was

9 wondering if the agency would care to i ndicate the

10 timing regarding when they intend to ma ke that

11 request, and then based on that, if the y can provide a

12 guess of when that would actually final ize.

13 MR. KALEEL: We would submit the re -designation

14 request in conjunction with the final M aintenance

15 Plan. As the hearing officer announced , we have a

16 32-day comment period. While we consid er comments

17 that are submitted by the public, we wo uld then issue

18 a final Maintenance Plan -- probably wi ll be at least

19 a couple of weeks after the end of the comment period.

20 And then once the Maintenance Plan is f inal, then we

21 would submit the request to USEPA.

22 In terms of when we expect them to act on that,

23 we've talked today about the Maintenanc e Plan, which,

24 obviously, is one of the key requiremen ts to a

43 Keefe Reporting Company1 re-designation request. There are othe r things that

2 are required of us before EPA will rede signate, and

3 one of those requirements is making sur e you have a

4 complete SIP, state implementation plan , and one of

5 those elements is reasonably available control

6 technology for volatile organic compoun ds, and there's

7 three regulatory proposals now before t he Pollution

8 Control Board that have to be finalized and submitted

9 to EPA before we will have completed th at requirement.

10 I don't expect the Board to finish acti on on those

11 three rulemakings, at least not all of them, within

12 the same 45-day period that I kind of o utlined for the

13 Maintenance plan. So, I would expect w e'll make the

14 request to USEPA in 45 days. I don't e xpect USEPA to

15 complete action on the re-designation u ntil those

16 rules are completed through the Polluti on Control

17 Board. Probably sometime this Summer.

18 MR. ALEC DAVIS: Okay. Thank you. My next I

19 guess question has to do with the inter action between

20 Illinois and Missouri. The non-attainm ent area,

21 obviously, is comprised of counties in both states,

22 and I am aware of the fact that Illinoi s and Missouri

23 work cooperatively on various measures to improve the

24 air quality, and you've also shown and mentioned that

44 Keefe Reporting Company1 on the Missouri side of the river has m easured

2 attainment, as well. Do you happen to know what the

3 status is of Missouri's SIP and whether or not they'll

4 be similarly pursuing a re-designation, as well?

5 MR. KALEEL: Obviously, I don't wor k for Missouri

6 D and R. So, I can only share with you what I

7 understand to be their situation, and I may be not a

8 hundred percent accurate, but I believe this is true.

9 I know they've announced publicly that they are

10 working on the same kind of a maintenan ce plan for the

11 Missouri side of the non-attainment are a, and that

12 they will have public hearings soon. I don't know how

13 to define "soon," but they are working on the same

14 kind of a request. I believe they're i n the same boat

15 that we are with respect to the VOC rul es that I

16 outlined. We might even be a little ah ead of them as

17 far as having a proposal being consider ed by the

18 Pollution Control Board. They have a s imilar board on

19 the Missouri side that is responsible f or promulgating

20 rules, and I don't believe Missouri has made those

21 proposals yet. So, they likely are beh ind Illinois.

22 My understanding, though, is that USEPA can still move

23 forward with the Illinois re-designatio n request once

24 our SIP is complete, even if the Missou ri SIP is not.

45 Keefe Reporting Company1 So, there wouldn't necessarily be a lin kage there if

2 one state completes its process before the other one.

3 MR. ALEC DAVIS: So, I guess in the context of how

4 the triggers and the analysis and then any contingency

5 measure that might come about as a resu lt of the

6 monitored increase in ozone, to what ex tent does

7 consideration of the source of any emis sions that

8 might be causing that increased measure d value, for

9 example, if you were to find an increas e in Jersey

10 County where there may not be any more local source

11 that you can kind of directly relate to an increase

12 where you might assume that it was comi ng from across

13 the state line, to what extent would th at

14 consideration play into a determination of what, if

15 any, contingency measures to take? You understand the

16 gist of my question?

17 MR. KALEEL: Yeah, I think I unders tand your

18 question. We would work with Missouri, and I didn't

19 say it today, but it is clearly in the Maintenance

20 Plan document itself, that we would con tinue to work

21 with Missouri D and R as we perform the evaluation

22 that's specified in the Maintenance Pla n to try to

23 figure out what would be the most effec tive corrective

24 action. So, we would work with Missour i to try to

46 Keefe Reporting Company1 identify what caused it and develop a p lan

2 appropriately. Whatever we come up wit h, it is our

3 intent to do that in a very public way and to seek

4 public comment on the corrective measur e that we would

5 take. So --

6 MR. ALEC DAVIS: Thank you. That's all I've got.

7 MR. STUDER: That's it?

8 MR. ALEC DAVIS: Yeah.

9 MR. STUDER: Thank you, Mr. Davis. Is there

10 anyone else that has any comments or qu estions?

11 (No response.)

12 MR. STUDER: All right. Let the re cord indicate

13 that no one raised their hand. I do wa nt to point out

14 that the record in this matter is open until the 10th

15 of May, and you can submit written comm ents any time

16 prior to that date. I also want to rem ind you that if

17 you have not registered and you do want to be notified

18 of the final action in this matter, ple ase fill out a

19 registration card, and we'll make sure that you are

20 advised of the final action in this.

21 If there's nothing further, I thank everyone for

22 being here this morning, and this heari ng is

23 adjourned.

24 * * * * *

47 Keefe Reporting Company1

2 I, HOLLY A. McCULLOUGH, an Ill inois CSR, a

3 Missouri CCR and a RPR, do HEREBY CERTI FY that the

4 foregoing record was made before me on April 8, 2010,

5 at 1102 Eastport Plaza Drive, Collinsvi lle, Illinois.

6 IN WITNESS WHEREOF, I have her eunto set my

7 hand the 8th day of April, 2010.

8

9

10 ________________

_____________ HOLLY A. McCULLO UGH 11 Notary Public CSR #084-004265 12 RPR #821968 CCR #1011 13

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48 Keefe Reporting Company

# Maintenance Plan for the Metro-East St. Louis Ozone Nonattainment Area for the 1997 8- Hour Ozone National Ambient Air Quality Standard

AQPSTR 10-01

May 20,2010

Illinois Environmental Protection Agency 1021 North Grand Avenue East Springfield, Illinois 62794-9276

.. 1 •• 1

..

Attachment 1/5

### TABLE OF CONTENTS



### Page

LIST OF TABLES

.

LIST OF FIGURES

.

EXECUTIVE SUMMARY

. 111

IV



### 5

1.0 INTRODUCTION. 6 1.1 

### Regulatory Background 6 1.2 

### Status of Air Quality

. 8

2.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS 9

3.0 OZONE MONITORING 11 

### 3.1 Monitored Design Values 11 3.2 

### Quality Assurance 13 3.3 Continued MonitorirIg 13

4.0 EMISSIONS INVENTORY. 14 4.1 

### Attainment Year Inventory

- 2008 14 4.2 

### Air Quality InJprovements and Emissions Controls 15 

### 4.3 Emissions Projections. 16 4.4 

### Demonstration of Mamtenance 16 4.5 

### Provisions for Future Updates 17

5.0 CONTROL MEASURES AND REGULATIONS 18 5.1 

### Attainment Demonstration Control Measures 18 

### 5.2 Reasonable Further Progress (RFP) 19 5.3 Reasonably Available Control Technology (RACT)

. 19 5.4 

### Controls to Remain in Effect

. 20 

### 5.5 Provisions for Permitting New or Modified Emissions Sources 21 5.6 

### Transportation Conformity 21

6.0 CONTINGENCY MEASURES 23 6.1 

### Contingency Measures 23 6.2 

### Commitment to Revise Plan 25 

### 6.3 Public Participation

. 25 6.4 

### Legal Authority to InJplement and Enforce 26

7.0 CONCLUSIONS 27

### TABLE OF CONTENTS (Continued)

APPENDIX A Summary of Ambient Air Monitoriug Data (2007-2009)

.

APPENDIX B Transportation Conformity

. 

### 28

30LIST OF TABLES

Page

Table 4.1 2008 Metro-East Ozone Nonattainment Area YOM and NOx Emissions 14

Table 4.2 2002 Metro-East Ozone Nonattainment Area YOM and NOx Emissions 15

Table 4.3 2013 Metro-East Ozone Nonattainment Area YOM andNOx Emissions 16

Table 4.4 2020 Metro-East Ozone Nonattainment Area YOM and NOx Emissions 17



### Table 4.5 Comparison of2008, 2013, and 2020 Emissions Estimates Metro-East Nonattainment Area 17

Table 5.1 Proposed 2008 and 2020 Motor Vehicle Emissions Budgets Metro-East 8-Hour Ozone Maintenance Plan 22

Table 6.1 Contingency Plan for the Metro-East 8-Hour Ozone Nonattainment Area 24Figure 1.1

Figure 3.1

Figure 3.2 LIST OF FIGURES

8-Hour Ozone Nonattainment Area 81. Louis, MO-IL.

Ozone Monitors in the 81. Louis Metropolitan Area

. Comparison of 8- Hour Ozone Design Values for the 81. Louis Region Between 2001-2003 and 2007-2009 Page

7

11

12EXECUTIVE SUMMARY

This document describes Illinois' Maintenance Plan for the Illinois portion of the St. Louis ozone nonattainment area (NAA), hereafter referred to as the Metro-East NAA. A Maintenance Plan is required before an area can be redesignated from nonattainment to attainment of a National Ambient Air Quality Standard (NAAQS). This document provides teclrnical information required to support a request to redesignate the MetroEast NAA to attainment ofthe 1997 8-hour ozone NAAQS. Illinois intends to submit such a request to the U.S. Environmental Protection Agency (U.S. EPA). The Illinois Environmental Protection Agency (Illinois EPA) has prepared this plan in consultation with the Missouri Department of Natural Resources (MDNR) and the U.S. EPA. The MDNR is preparing a similar plan for the Missouri portion of the St. Louis nonattainment

area.

Ozone air quality has dramatically improved in the St. Louis region as a result of implementation of State and Federal control measures since the designation of the St. Louis area as nonattainrnent in 2004. The entire St. Louis nonattainment area has at least three years of complete, quality assured ambient air quality monitoring data for 2007- 2009 that demonstrates compliance with the 1997 8-hour ozone NAAQS. These air quality improvements are due to permanent and enforceable emissions control measures.

This Maintenance Plan provides for continued attainment of the 1997 8-hour ozone air quality standard for the Metro-East nonattainment area for a period often years after U.S. EPA has formally redesignated the area to attainment. The Plan also provides assurances that, even if there is a subsequent violation of the air quality standard, measures listed in the Plan will prevent any future occurrences through contingency measures that would be triggered upon such an occurrence. Finally, the Plan includes on-road motor vehicle emissions budgets for the years 2008 and 2020 for use in transportation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of the 8-hour ozone standard during the ten-year maintenance period.



### 5

### 1.0 INTRODUCTION

This document describes Illinois' 8-hour ozone Maintenance Plan for the Metro-East NAA. This Maintenance Plan is required before the area can be redesignated from nonattainment to attainment of the National Ambient Air Quality Standard (NAAQS) for

ozone promulgated by the U.S. Environmental Protection Agency (U.S. EPA) in 1997. Illinois intends to submit such a request to the U.S. EPA in conjunction with this Maintenance Plan. The Illinois EPA has prepared this plan in consultation with the Missouri Department of Natural Resources (MDNR) and U.S. EPA. The MDNR is preparing a similar plan for the Missouri portion of the St. Louis nonattainment area. The entire St. Louis nonattainment area has at least three years of complete, quality assured ambient air quality monitoring data for 2007-2009, demonstrating attainment with the 0.080 ppm 8-hour ozone NAAQS promulgated in 1997.

This document provides the technical information needed to support a request to redesignate the St. Louis area to attainment. Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for a nonattainment area to be considered for redesignation. Before an area can be reclassified to attainment, U.S. EPA
must make a determination that the area has attained the NAAQS based on at least three complete years of ambient monitoring data. U.S. EPA must have approved a State Implementation Plan (SIP) for the area under Section 110 and Part D of the CAA. The
state must demonstrate that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. Finally, the state must submit, and U.S. EPA must approve, a Maintenance Plan under Section 175(A) of the CAA, including provisions for contingency measures that will be implemented if future violations of the NAAQS are measured.

This Maintenance Plan provides for the continued attainment of the 8-hour ozone NAAQS for the Metro-East NAA for a period often years after U.S. EPA has formally redesignated the area to attainment. The Plan also provides assurances that even if a subsequent violation of the ozone NAAQS occurs, provisions in the Plan will prevent any future occurrences through contingency measures that would be triggered upon such

occurrence.

This document addresses the Maintenance Plan requirements established by the CAA and U.S. EPA, and includes additional information to support continued compliance with the 8-hour ozone NAAQS.

1.1 Regulatory Background

The CAA requires areas that fail to meet the NAAQS for ozone to develop SIPs to expeditiously attain and maintain theNAAQS. Historically, exceedances of the ozone NAAQS have been monitored in Madison and St. Clair counties in lllinois and in the Missouri portion: of the NAA.

The Metro-East NAA, which includes Madison, Momoe, St. Clair, and Jersey counties in Illinois, was originally designated as nonattainment in 2004 pursuant to the 1997

6revisions to the ozone NAAQS. Several counties in Missouri were also designated as nonattainment of the 8-hour ozone NAAQS. Figure 1.1 depicts the current St. Louis Missouri-lllinois NAA.



## Figure 1.1


# 8-Hour Ozone Nonattainment Area St. Louis, MO-IL



# IL ModeI3te 

# -(MO 

# (-\\L

1_

Source: USEPA, Office of Air QuaLity Plaoning and Standards, Green Book, August 03, 2004

7The following is a.1ist of the counties contained in the St. Louis Missouri-lllinois 8-hour

ozone nonattainment area:



## • Madison County, 

### IL



## • St. Clair County, 

### IL



# • Monroe County, 

### IL



## • Jersey County, 

### IL



## • St. Louis County, MO



# • St. Louis City, MO



## • St Charles, MO



# • Jefferson County, MO



## • Franklin County, MO

As a result ofthe nonattainment designation and the accompanying classification as

. moderate, these areas were subject to new requirements, including development of a plan demonstrating that the area would meet the federal8-hour ozone NAAQS by June 15, 2010.

Recognizing the need for a regional solution, the States of Illinois and Missouri have worked cooperatively to jointly develop and evaluate an effective regional attainment strategy to enable the St. Louis region to attain the 8-hour ozone NAAQS. The attainment strategy recognizes the importance of reducing both locally generated ozone precursor emissions, volatile organic material (YOM) and oxides of nitrogen (NOx), as well as incoming (transported) ozone and ozone precursor emissions. The emissions reductions needed to attain the 8-hour ozone NAAQS include both State and Federal

measures that have reduced ozone precursor emissions both locally and regionally. These measures have allowed the St. Louis Missouri-Illinois NAA to attain the 8-hour

ozone standard by the attainment deadline established by the U.S. EPA.

1.2 Status of Air Ouality

Ozone monitoring data for the most recent three-year period, 2007 through 2009, demonstrates that air quality has met the 1997 8-hour ozone NAAQS in the St. Louis Missouri-Illinois NAA. Information regarding the air monitoring network and air quality monitoring data in included in Section 3.0 and Appendix A.

82.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS

Sections 107 and 110 of the CAA list a number of requirements that must be met by nonattaimnent areas prior to consideration for redesignation to attainment. One of those requirements is the development of a Maintenance Plan, which describes a state's plan for maintaining theNAAQS for a minimum ten-year period after redesignation to attainment. U.S. EPA has published guidance for the preparation of Maintenance Plans and redesignation requests, contained in a document entitled "Procedures for Processing Requests to Redesignate Areas to Attainment" (September 4, 1992).

Before a redesignation to attainment can be promulgated, U.S. EPA must:

• Determine that the NAAQS for ozone, as published in 40 CPR 50.4, has been attained. Ozone monitoring data must show that violations of the NAAQS are no longer occurring. This showing must rely on three consecutive years of data. The ambient air monitoring data must be qUality assured in accordance with 40 CPR 58.10, recorded in U.S. EPA's Air Quality System (AQS) data base, and made available to the public.

• Approve the state's plan for demonstrating attainment. The attainment plan, which is based on air quality modeling, must contain enforceable control

measures and must be submitted as a revision to the state's SIP after a public hearing.

• Determine that the improvement in air quality between the year violations occurred and the year that attainment was achieved is based on permanent and enforceable emissions reductions.

• Approve the state's Maintenance Plan. The requirements for the Maintenance Plan are discussed below.

• Determine that all other requirements applicable to nonattainment areas have been
met.

A Maintenance Plan provides for the continued attainment of the 8-hour ozone NAAQS for a nonattainment area for a period of ten years after U. S. EPA has formally redesignated the area to attainment. The plan also provides assurances that even if a subsequent violation of the NAAQS occurs, provisions in the plan will prevent any future

occurrences through contingency measures that would be triggered upon such

occurrence. To be approvable, the state is required to have a public hearing on the Maintenance Plan prior to adoption. The Maintenance Plan must contain the following elements:

• A comprehensive emissions inventory of the precursors of ozone completed for the "attaimnent year";

9• A projection of the emissions inventory forward to a year at least ten years after redesignation and a demonstration that the projected level of emissions is sufficient to maintain attainment of the ozone NAAQS;

• A commitment that, once redesignated, the state will continue to operate an appropriate monitoring network to verify maintenance of the attainment status;

• A demonstration oflegal authority to implement and enforce all control measures contained in the SIP;

• Provisions for future updates of the inventory to enable tracking of emissions levels, including an annual emissions statement from major sources;

• Motor vehicle emissions budgets for transportation conformity for the ten-year maintenance period;

• A commitment to submit a revised Maintenance 

### Plan eight years after redesignation;

• A commitment to enact and implement additional contingency control measures expeditiously in the event that future violations of the NAAQS occur;

• A list of potential contingency measures that would be implemented in such an event.

This Maintenance 

### Plan has been prepared in accordance with the requirements specified in U.S. EPA's guidance document and additional guidance received from U.S. EPA staff.

The following sections ofthis document describe how U.S. EPA's requirements have been met.

10

### 3.0 OZONE MONITORING

U.S. EPA's published guidance document, "Procedures for Processing Requests to Redesignate Areas to Attainment" (September 4, 1992), details specific requirements regarding the collection and use of ambient air monitoring data needed to support a redesignation request. Before the Metro-East NAA can be redesignated, Illinois must demonstrate that the 8-hour ozone NAAQS has been attained. Ozone monitoring data
must show that violations of the NAAQS are no longer occurring within the nonattainment area. This showing must rely on three complete, consecutive calendar years of quality assured data. Further, the air monitoring data must be quality assured in accordance with 40 CFR 58.10, recorded in U.S. EPA's AQS data base, and made available to the public. Finally, Illinois must commit to continue to operate an appropriate monitoring network to verify the maintenance of the attainment status, once the area has been redesignated.

The following subsections describe how each of these requirements has been addressed.

3.1 Monitored Design Values
Currently there are 11 ozone monitors located in the nonattainment counties in the St. Louis region; 6 are located in Missouri and 5 are in Illinois. Missouri and Illinois also operate ozone monitors at locations upwind and downwind of the metropolitan area. Figure 3.1 shows the locations of these monitors.



### Figure 3.1 Ozone Monitors in 

### the St. Louis Area

ROIIII

Clinton**Mont~omery**

Legend

.... Ozone Monitors RlIlltlolph ..... Maryville Nilwood

.....

Maeoupill

St. Clllir

,-----'-----uc:f.=:::r------

.... Houston Alton

Wood River 1\'lodisou Green!'



# L--

Bonne>**Te~** SIc:. Genevieve**\Va.~hinglon** I<nmldin Pike Missouri -.....,c-----J

Crawford

# r--L---,----~ ""moo

11To determine whether the NAAQS is being exceeded, the 8-hour ozone design value
must be calculated

.. The current 

## u.s. EPA method for calculating the ozone design value is to average each monitor's 

### 4 th highest daily maximum 8-hour value for each year over the 3-year period and compare it to the calculated design values to the 0.080 ppm (or 85 ppb) level of the NAAQS. The calculated 8-hour ozone design values for the monitors in the St. Louis Missouri-Illinois NAA for 2007-2009 are included as Appendix A of this report. Figure 3.2 compares the design values for the 2001-2003 period for monitoring stations in the St. Louis region to the corresponding design values from 2007-2009. The data demonstrate that ozone air quality has improved dramatically throughout the St. Louis region and that the 1997 8-hour ozone NAAQS has been attained for the 2007- 2009 period at all locations.

Figure 3.2 Comparison of SCHour Ozone Design Values (Ppb) for the St. Louis Region Between 2001-2003 and 2007-2009

D1inois 2001-2003

12 2007-2009

L

_**\l~mg"m"}'** 

## I

I
,

# ~C~

------'3.2 Quality Assurance

Illinois EPA has quality assured all monitoring data shown in Appendix A for all sites located in Illinois in accordance with 40 CFR 58.10 and the Illinois EPA's Quality Assurance Plan, which describes Illinois EPA's standard operating procedures for operating the ambient monitoring network and validating the data. The Missouri DNR has a similar quality assurance plan. Illinois EPA has recorded the monitoring data in the U.S. EPA's AQS database, which is available to the public.

3.3 Continued Monitoring

Illinois commits to continue monitoring ozone levels according to a U.S. EPA approved monitoring plan, as required to ensure maintenance of the ozone NAAQS. Should changes in the location of an ozone monitor become necessary, Illinois EPA will work with U. S. EPA to ensure the adequacy of the monitoring network. Illinois EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58. Illinois EPA will continue to enter all data into AQS on a timely basis in accordance with federal guidelines.

13

### 4.0 EMISSIONS INVENTORY



### A redesignation request must contain a demonstration that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emissions reductions. As described previously in Section 3.0, a three-year monitoring period is used to evaluate whether attainment has been achieved. In this Section, the "attainment year" refers to the mid-point year (2008) ofthe three-year period (2007-2009) used to demonstrate attainment. The request should also include a projection of the emissions inventory to a year at least 10 years following redesignation, a demonstration that the projected level of emissions is sufficient to maintain the ozone NAAQS, and a commitment to provide future updates of the inventory to enable tracking of emissions levels during the 1 O-year maintenance period.

4.1 Attainment Year Inventory, 2008

Illinois EPA has prepared a comprehensive emissions inventory for the Metro-East ozone nonattainment area, including point, area, and on-road and off-road mobile sources for precursors of ozone (VOM and NOx) for the attainment year, 2008. This inventory is based on actual or projected activity levels. Point source information was compiled from 2008 annual emissions reports submitted to the Illinois EPA by emissions sources and the U.S. EPA's Clean Air Markets Division database for electric utilities. Area source emissions were calculated using the most recently available methodologies and emissions factors from U.S. EPA along with activity data (typically population, employment, fuel
use, etc.) specific to 2008. On-road mobile source emissions were calculated using U.S. EPA's MOBILE6.2 emissions model with 2008 vehicle miles traveled (VMT) data provided by the Illinois Department of Transportation (IDOT). Off-road mobile source emissions were calculated for summer 2008 using U.S. EPA's NONROAD emissions model. Biogenic emissions are not included in these summaries.

Table 4.1 summarizes the 2008 emissions estimates for the Metro-East ozone nonartainment area.

Table 4.1 2008 Metro-East Ozone Nonattainment Area YOM and NOx Emissions 

### (Emissions stated in tons per ozone season weekday) Source Category YOM NOx 

### Point Sources 11.92 39.86 Area Sources 23.21 1.50 On-Road Mobile Sources 16.53 30.84 Off-Road Mobile Sources 12.66 39.25 Total 64.33 111.46

14

### 4.2 Air Ouality Improvements and Emissions Controls

The Metro-East area was designated as nonattainment ofthe 1997 8-hour ozone NAAQS in 2004, based on ozone air 

### quality monitoring data collected between 2001 and 2003. Since that time, permanent and enforceable reductions of ozone precursor emissions have contributed to improvements in ozone air quality and to the attainment ofthe 8-hour

ozone NAAQS. Some of these emissions reductions were due to the application of tighter federal emissions standards on motor vehicles and fuels, and some due to the requirements of the federal NOx SIP Call. Section 5.0 of this report describes these reductions in more detail, along with an explanation of their regulatory status. In 

### this subsection, the 2008 attainment year emissions levels are compared to the base year 2002 emissions levels.

U.S. EPA's 8-hour Ozone Implementation Rule required that states with ozone nonattainment areas prepare and submit a 2002 base year inventory of anthropogenic

sources of ozone precursor emissions. This base year inventory included emissions from point, area, on-road mobile and off-road mobile emissions. lllinois EPA prepared and submitted this inventory in June 2006. Table 4.2 summarizes 2002 emissions by major

source category and by pollutant for the Metro-East NAA.

Table 4.2 2002 Metro-East Ozone N onattainment Area YOM and NOx Emissions 

### (Emissions stated in tons per ozone season weekday) Source Category YOM 

### NOx Point Sources 17.41 53.24 Area Sources 29.86 1.40 On-Road Mobile Sources 23.57 47.07 Off-Road Mobile Sources 12.04 36.79 Total 82.88· 138.50

Comparing the 2002 inventory to that for 2008 indicates that total VOM emissions in the Metro-East area decreased by about 18.55 tons per day (tpd), due largely to reductions from point and on-road mobile sources. NOx emissions in the Metro-East area decreased significantly, about 27.04 tpd, during the same time period. Again, these reductions were primarily from point and on-road mobile sources

.. These sizeable emissions reductions in

ozone precursor emissions, and corresponding reductions in the Missouri portion of the NAA, plus reductions in upwind areas in lllinois and other nearby states, resulted in a substantial improvement in ozone air quality in the S1. Louis area, ultimately resulting in attainment of the 1997 8-hour ozone NAAQS.

15

### 4.3 Emissions Projections

A Maintenance Plan must contain a demonstration that the level of emissions projected for the ten-year period following redesignation are sufficient to maintain the NAAQS. Accordingly, Illinois EPA has projected YOM and NOx emissions for the Metro-East NAA for 2020. lllinois EPA has also projected emissions to 2013, to represent a midpoint during the ten-year maintenance period. Emissions for these two projection
years are compared to emissions levels in 2008 to determine if emissions are sufficient to maintain the NAAQS during this period.

Metro-East area point and area source emissions for 2013 and 2020 were estimated using the 2008 base year inventory and growth factors appropriate for each source category. The effect of Illinois' recently adopted NOx RACT requirement on NOx emissions in future years was estimated and applied, as appropriate, to the point source inventory. Off-road emissions projections were developed using the growth factors contained in U.S. EPA's NONROAD model. Oncroad motor vehicle emissions were estimated using U.S. EPA's MOBILE6.2 motor vehicle emissions model. The figures assume the continued use ofrefonnulated gasoline, the continued phase-in of the Tier 2 motor vehicle emissions standards, and operation of an enhanced vehicle inspection and maintenance program. Total vehicle miles of travel (VMT) for 2013 and 2020 were assumed to increase at a rate of 1.5 percent per year from 2008.

Tables 4.3 and 4.4 include the YOM and NOx emissions estimates for the years 2013 and 2020, respectively, for the Metro-East nonattaimnent area.

Table 4.3 2013 

### Metro-East Ozone Nonattainment Area YOM and 

### NOx Emissions (Emissions stated in tons per ozone season weekday) Source Category YOM NOx Point Sources 13.25 32.24 Area Sources 23.22 1.54 On-Road Mobile Sources 9.58 20.70 Off-Road Mobile Sources 10.30 37.80 Total 56.35 92.28

4.4 Demonstration of Maintenance

Table 4.5 demonstrates that the level of emissions projected for the ten-year period following redesignation is sufficient to maintain the ozone NAAQS. As shown in the table, both YOM and NOx emissions within the nonattainment area are expected to decrease significantly between 2008 and 2020. Projected YOM and NOx emissions for the mid-point year, 2013, are also less than the emissions levels in 2008. Based on these emissions trends it is expected that air quality will continue to meet the 1997 8-hour

ozone NAAQS throughout the maintenance period.

16

### Table 4.4 2020 Metro-East Ozone Nonattainment Area YOM and NOx Emissions (Emissions stated in tons per ozone season weekday) Source Category YOM NOx Point Sources 14.73 30.71 Area Sources 25.04 1.56 On-Road Mobile Sources 7.70 10.34 Off-Road Mobile Sources 7.73 33.56 Total 55.20 76.17

Table 4.5 Comparison of 2008, 2013 and 2020 Emissions Estimates Metro-East Nonattainment Area (Emissions stated in tons per ozone season weekday) Difference Difference 2008 2013 (2008

- 2013) 2020 (2008

- 2020)

YOM 64.33 56.35 7.98 55.20 16.28

NOx 111.46 92.28 19.18 76.17 35.29

In 

### addition to the overall emissions reductions projected to occur within the nonattainment area, significant reductions of statewide NOx emissions resulting from implementation oflllinois' multi-pollutant standards affecting electric utilities by 2012, will also help to ensure continued attainment of the 8-hour ozone NAAQS.

4.5 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Illinois commits to submit to U.S. EPA, eight years after redesignation, a revised version of this Maintenance Plan. The revision will contain lllinois' plan for maintaining the 8-hour ozone NAAQS for ten years beyond the first 10-year period after redesignation.

17
(5.0 CONTROL MEASURES AND REGULATIONS

This section provides specific infonnation on the control measures implemented in the Metro-East nonattainment area, including the measures that were part of Illinois' Attainment Demonstration, Reasonable Further Progress (RFP) demonstration, CAA requirements, and other state and federal measures. The control measures required in past ozone SIP revisions have been fully implemented, and other, more recent control programs will continue to provide emissions reductions in future years. Illinois EPA commits to keep these measures in effect after redesignation, or to provide equivalent emissions levels using alternate measures. Illinois' SIP contains acceptable provisions to provide for preconstruction review of new emissions sources. After redesignation to attainment, Prevention of Significant Deterioration (PSD) requirements will apply to the construction of new major sources and to significant modifications of existing sources. Illinois has accepted delegation from U.S. EPA of this program. Illinois further commits
to continue to require that all future transportation plans in the St. Louis area confonn with the SIP.

5.1 Attainment Demonstration Control Measures

Illinois' attainment demonstration for the Metro-East nonattainment area identified control measures that had been promulgated at either the state or federal level that are sufficient to allow the region to meet the 1997 8-hour ozone NAAQS by the required attainment date. The attainment demonstration, which was submitted to U.S. EPA after a public hearing and public comment period, is described in the Illinois EPA's document: "8-Hour Ozone Attainment Demonstration for the Metro-East Nonattainment Area" (Report Number AQPSTR 07-02, June 15, 2007). The primary emissions reduction

measures for demonstrating attainment of the ozone standard are as follows:

• NOx SIP Call and Clean Air Interstate Rule (CAIR)

• New Source Perfonnance Standards (NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHAPS)/Maximum Achievable Control Technology (MACT) Standards

• VOM Solvent Categories: Aerosol Coatings, Architectural and Industrial Maintenance (AIM) Coatings, Consumer Solvents

• Vehicle Inspection & Maintenance Program

• Refonnulated Gasoline

• Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements

18• On-Highway Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requir€IIlents

• Federal Emissions Standards for Off-Road Equipment (e.g., Nonroad Diesel Engine Rule, Evaporative Large Spark Ignition and Recreational Vehicle Standards) incorporated into NONROAD Model

• Tier 4 Nonroad Diesel Engine Standards and Diesel Fuel Sulfur Content Restrictions

• Marine Compression-Ignition Engine Standards and Locomotive Engine Standards

• Consent Decrees---Dynegy and ConocoPhillips

5.2 Reasonable Further Progress (RFP)

Since the Metro-East area is classified as a moderate nonattainment area for the 8-hour

ozone standard, a 15 percent net reduction in ozone precursor emissions from 2002 levels is required by 2008 in order to meet the RFP requirement. In the Metro-East attainment demonstration, the Illinois EPA relied on NOx substitution to meet the 15 percent RFP reduction requirement.

The control measures identified in the RFP document, including those listed above, were projected to result in a 6.48 percent reduction in VOM emissions and a 10.01 percent reduction in NOx emissions from 2002 levels by the year 2008, a total reduction of 16.49 percent. All of the identified emissions control measures were implemented by 2008. These emissions reductions achieve the 15 percent RFP target for the Metro-East NAA.

5.3 Reasonably Available Control Technology (RACT)

Pursuant to Sections 172, 1 82(b) and (f) of the CAA, RACT is required for all existing major sources of the applicable criteria pollutant and its precursors located in NAAs. U.S. EPA defines RACT as the lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological feasibility and economic reasonableness (70 FR 71612; November 29,2005). The major source threSHold for moderate NAAs is defined as 100
tons per year (tpy). A source generally consists of several units that emit pollutants. The

sum of emissions from all units at the source determines if a unit is major and thus subject to RACT requirements.

RACT is not a new requirement under the CAA. Illinois previously addressed RACT requirements in the Metro-East area in developing attainment plans for the I-hour ozone standard. The RACT requirement forNOx was previously waived under the I-hour

ozone standard, and Illinois has adopted new regulations to implement NOx RACT in the

19NAA that were submitted to 

## u.s. EPA in September 2009. Illinois has previously adopted RACT requirements for YOM emissions in the NAA. (See_ 35 

### Ill. Adm. Code Part 219) The Illinois EPA has evaluated the previously adopted regulations to detennine if the RACT requirement is still being met for 8-hour ozone.

Sections 172, 182(b)(2), and 182(t) of the CAA requite implementation ofRACT for

sources that are subject to Control Techniques Guidelines (CTGs) that are promulgated by U.S. EPA. The U.S. EPA has issued CTGs defining RACT for those categories of

sources that emit the greatest amounts ofVOM emissions. lllinois EPA has proposed, or will soon be proposing, regulations to implement the revised CTGs issued by the U.S. EPA in 2006, 2007, and 2008. The 2006 CTG's addressed industrial cleaning solvents, offset lithographic printing and letterpress printing, flexible package printing, and flat wood paneling coatings. The 2007 CTG's address paper, film, and foil coatings, large appliance coatings, and metal furniture coatings. The 2008 CTG's address miscellaneous metal and plastic parts coatings, fiberglass boat manufacturing materials, miscellaneous industrial adhesives, and automobile and lightcduty truck assembly coatings. Other than the above mentioned CTGs, Illinois has adopted applicable rules addressing all CTGs published by U.S. EPA for which there are existing sources in the Metro-East NAA.

Non·CTG sources are defined as major YOM sources which are not subject to CTGs, but for which RACT is required. All major sources of ozone precursors located in the ozone NAA that are not subject to individual RACT rules are subject to a generic RACT rule. These rules apply to non-CTG sources that have the potential to emit 100 tons or more per year ofVOM. Thus, Illinois has met the obligation to implement RACT on non-CTG YOM sources in the NAA.

It should be noted that other regulatory requirements also affect YOM emissions sources within the Metro-East ozone NAA. These include MACT, federal NSPS, and NESHAPs. These programs satisfy the RACT requirements for specific source categories because these rules are more stringent than RACT. It is concluded from this review that Illinois' existing YOM RACT rules fulfill U.S. EPA's RACT requirements for YOM sources in the Metro-East NAA.

As mentioned previously, the RACT requirement for NOx was previously waived under the I-hour ozone NAAQS. The Illinois EPA has submitted final, fully adopted NOx RACT rules to U.S. EPA. It should be noted however that the attainment demonstration for the St. Louis NAA for the 1997 ozone NAAQS did not rely on emissions reductions from the Illinois EPA's NOx RACT rules. The reductions resulting from this program, when implemented, will help the area to maintain the NAAQS in future years.

5.4 Controls to Remain in Effect

Illinois will maintain all of the control measures listed in this Section to ensure maintenance of the 8-hour ozone NAAQS. Any revisions to the control measures included as part of the Maintenance Plan will be submitted as a SIP revision to U.S. EPA

20for approval, and will be accompanied by a showing that such changes will not interfere with maintenance of the NAAQS.

Illinois EPA has the necessary resources to enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emissions of ozone precursors in the Metro-East nonattainment area.

5.5 Provisions for Permitting New or Modified Emissions Sources

Illinois has longstanding and fully implemented programs for the review of new major

sources and significant modifications of existing sources. The PSD program, which includes requirements for Best Available Control Technology (BACT) on major new

sources or significant modifications of existing sources, will be applicable in the MetroEast area once the area has been redesignated to attainment. Illinois has been delegated full authority to implement the PSD program by U.S. EPA.

5.6 Transportation Conformity

The purpose of this section is to describe and establish the Metro-East nonattainment area motor vehicle emissions budgets associated with the 8-hour ozone Maintenance Plan SIP. Average summer weekday motor vehicle emissions budgets are being proposed for the attainment year 2008 and for the final year of the Maintenance Plan, 2020, for the precursor pollutants YOM and NOx. These budgets were developed consistent with the
motor vehicle activity assumptions and emissions control strategies incorporated into the 8-hour ozone attainment demonstration analysis. The budgets reflect an emissions level determined using actual motor vehicle VMT for 2008 and VMT growth at an annual rate of 1.5% from year 2008 levels to 2020.

A motor vehicle emissions budget is that portion of the total allowable emissions allocated to highway and transit vehicle use that are defined in the SIP for a certain year. The rules governing transportation conformity require certain transportation activities to be consistent with motor vehicle emissions budgets contained in control strategy implementation plans (40 CFR § 93.118). Section 93.101 of the rule defines a "control strategy [State] implementation plan revision" as a "plan which contains specific strategies for controlling the emissions and reducing ambient levels of pollutants in order
to satisfy CAA requirements of reasonable further progress and attainment." In order to demmistrate conformity to the motor vehicle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program must be less than or equal to the budget level (40 CFR § 93.118(a)).

The motor vehicle emissions budgets established and described herein were developed consistent with the methodology and control strategy assumptions used in the 8-hour

ozone attainment demonstration. The effects of motor vehicle control measures are incorporated into the emissions factors produced by the U.S. EPA's MOBILE6.2 model. These control measures include the implementation of national motor vehicle emissions standards, the operation of a vehicle inspection and maintenance (11M) program, and the

21required use of refonnulated gasoline and low sulfur gasoline and diesel fuel.

The motor vehicle emissions budgets, which reflect the VMT and control program assumptions and methodology described here, are listed in Table 5.1.



### Table 5.1 Proposed 2008 and 2020 Motor Vehicle Emissions Budgets Metro-East 8-hour Ozone Maintenance Plan (tons per ozone season weekday)



### Year YOM NOx

2008 16.53 30.84



### 2020 7.70 10.34

Complete details on the derivation of the motor vehicle emissions budgets, including discussion of the MOBILE6.2 model inputs and assumptions are included in Appendix B of this report.

22

### 6.0 CONTINGENCY MEASURES

6.1 Contingency Measures

Section 175(A) of the CAA specifies the requirements for Maintenance Plans, including provisions for contingency measures that will be implemented if violations of the 8-hour

ozone NAAQS are measured after redesignation to attainment. A list of potential contingency measures that would be implemented in such an event should also be included in the Maintenance Plan. Finally, the plan should provide a commitment to submit a revised Maintenance Plan eight years after redesignation to ensure continued maintenance for the next ten-year maintenance period.

Contingency measures are intended to provide further emissions reductions in the event that violations of the 8-hour ozone NAAQS occur after redesignation to attainment. While these measures do not need to be fully adopted by the lllinois Pollution Control Board (IPCB) prior to the occurrence ofNAAQS violations, the contingency plan should

ensure that the contingency measures are adopted expeditiously once they are triggered. The Maintenance Plan must identify the triggers that determine when contingency

measures will be adopted, and the measures that the state will consider.

lllinois EPA's contingency plan for the Metro-East NAA is described in Table 6.1. Consistent with this plan, lllinois agrees to adopt and implement, as expeditiously as practicable, the necessary corrective actions in the event that violations of the 8-hour

ozone NAAQS occur within the Metro-East maintenance area after redesignation to attainment. Further, lllinois commits to continue to implement the control measures identified in the attainment demonstration and 

## RFP demonstration. As described in Section 5.0 of this report, Illinois has adopted and is continuing to implement a range of control measures that will greatly reduce precursor emissions, both locally and statewide. The contingency plan anticipates that these emissions reductions will be sufficient to mitigate exceedances or violations of the NAAQS that may occur in the coming years without further regulatory action.

The contingency plan provides for different levels of corrective responses should ambient 8-hour ozone levels exceed the NAAQS in any year, if emissions in the NAA increase significantly above current attainment levels, or if the NAAQS is violated. A Level I response would occur in the event that: 1) the fourth highest 8-hour ozone concentration
at any monitoring site in the St. Louis NAA (including sites in Missouri and Illinois) exceeds 84 ppb in any year, or 2) ifVOM or NOx emissions increase more than 5% above the levels contained in the attainment year (2008) emissions inventory. It should be noted that U.S. EPA does not require a state to implement contingency measures when occasional exceedances are recorded. The lllinois EPA's voluntary commitment to initiate a Level I response is intended to prevent future violations of the NAAQS from

ever occurrmg.

lllinois commits to compiling YOM and NOx emissions inventories for the Metro-East

area every three years for the duration of the Maintenance Plan to facilitate the

23Table 6.1 Contingency Plan for the Metro-East 8-Hour Ozone Nonattainment Area

Contingency Measure Action to be Taken List of Potential Contingency Measures Tril!l!er Levell Trigger Point Source Measures IL will evaluate air quality, or 

## • IL Multi-Pollutant Program for



### • Fourth highest detennine if adverse emissions trends electric generating units monitored 8-hour are likely to continue. If so, IL will 

### • Phase II of the Cleao Air average ozone detennine what aod where controls Interstate RuIe, after concentration may be required, as well as level of repromuIgation by USEP A exceeding 84 ppb io emissions reductions needed, to avoid a 

### • Best Available Retrofit aoy year at aoy violation of the NAAQS. The study Technology (BART) monitoring station in shall be completed within 9 months. If the St. Louis MO-IL necessary, control measures shall be Mobile Source Measures maintenance area. adopted withio 18 months of 

### • Tier 2 Vehicle Standards and Low detennination and implemented as Sulfur Fuel expeditiously as practicable, taking into 

### • Heavy Duty Diesel Standards and


### • The Metro-East consideration the ease of Low Sulfur Diesel Fuel maintenance area's implementation and the technical and 

### • High-enhanced I/M (OBDII) NOxorVOM economic feasibility of the selected 

### • Federal railroad/locomotive emissions inventories measures. standards increase more than 

## • Federal commercial marine vessel 5% above the levels engioe standards iocluded.io the 2008 

### • Portable fuel contaioers emissions inventories.

Area Source Measures Level II Trigger IL will conduct a thorough analysis to 

### • ArchitecturallIndustriai 

## • A violation of the detennine appropriate measures to Maiotenance (AIM) Coatiogs NAAQSataoy address the cause of the violation. 

### • Commercial and Consumer monitoring station in Analysis shall be completed within 6 Products the St. Louis MO-IL months. Selected measures shall be maintenance area. implemented withiu 18 months of a 

### • Aerosol coatiogs

violation. 

### • Broader geographic applicability of existing measures

emissions trends analysis included in the contingency plan under Level I. The Illinois EPA will coordinate with the Missouri DNR to evaluate the causes of high ozone levels

or the emissions trends and to detennine appropriate control measures needed to assure continued attainment of 8-hour ozone NAAQS. Under Level I, measures that could be implemented in a short time would be selected so as to be in place quickly after the Illinois EPA is aware that corrective measures have been triggered. Control measures selected under Level I will be adopted in most cases within 18 months after a detennination is made, and implemented, generally, within 24 months of adoption by the IPCB.

A Level II response would be implemented in the event that a violation of the 8-hour

ozone NAAQS were to be measured at a monitoring site within the St. Louis maintenance area (including sites in Missouri and Illinois). In order to select appropriate

24corrective measures, the Illinois EPA will work with the Missouri DNR to conduct a comprehensive study to determine the causes of the violation and the control measures necessary to mitigate the problem. The analysis will examine the following factors:

• the number, location, and severity of the ambient ozone exceedances;

• the weather patterns contributing to the elevated ozone levels;

• potential contributing emissions sources;

• the geographic applicability of possible contingency measures;

• emissions trends, including timeliness of implementation of scheduled control
measures;

• current and recently identified control technologies; and .' air quality contributions from outside the maintenance area.
Contingency measures will be selected from those listed in Table 6.1 or from any other

measure deemed appropriate and effective at the time the selection is made. It is expected that implementation of only a few of these measures would be necessary. The selection between measures will be based upon cost-effectiveness, emissions reduction potential, ease and timing of implementation, and other appropriate factors. Implementation of necessary controls in response to a Level II trigger will take place as expeditiously as possible, but in no event later than 18 months after the Illinois EPA makes a determination, based on quality-assured ambient data, that a violation of the NAAQS has occurred.

Adoption of additional control measures is subject to necessary administrative and legal processes. The Illinois EPA will solicit input from all interested and affected persons in the area prior to selecting appropriate control measures. No contingency measure will be implemented without providing the opportunity for full public participation. This process will include publication of notices, an opportunity for public hearing, and other measures required by Illinois law.

6.2 Commitment to Revise Plan

As noted in Section 4.5 above, the Illinois EPA commits to review its Maintenance Plan eight years after redesignation, as required by Section 175(A) of the CAA. The Maintenance Plan revision is intended to ensure continued attainment ofthe 8-hour ozone NAAQS for an additional ten-year period.

6.3 Public Participation

In accordance with Section 11 

### O( a)(2) of the CAA, the Illinois EPA is required to hold a public hearing prior to adoption of this Maintenance Plan and submittal to U. S. EPA. Public participation in the SIP process is provided for as follows:

• Notice of availability of the Metro-East 8-Hour Ozone Maintenance Plan document and the time and date of the public hearing will be published in the

25Belleville News Democrat, East St. Louis Monitor, and Alton Telegraph on March 5, 2010 and in the Granite City Press Record Journal on March 7, 2010.

• The public hearing to receive comments on the Metro-East Maintenance Plan will be held at 10:30 a.m. on April 8, 2010 at the Illinois Department of Transportation's Regional Conference Room at its District 8 Offices at 1102 Eastport Plaza Drive, Collinsville Illinois.

• A 30-day public comment period was also available after the public hearing to receive comments on the Maintenance Plan. A summary of the comments received and Illinois EPA's responses thereto is included as part of the submittal
to U.S. EPA.

6.4 Legal Authority to hnplement and Enforce

The Maintenance Plan must contain a demonstration that the State of Illinois has the
necessary legal authority to implement and enforce the measures relied upon to attain and maintain the NAAQS. Illinois has the legal authority to implement and enforce the requirements of this SIP submittal pursuant to the illinois Environmental Protection Act.



### 26

### 7.0 CONCLUSIONS

The Metro-East nonattainment area has attained the 19970.080 ppm 8-hour ozone NAAQS and has complied with the applicable provisions of the CAA required of moderate ozone NAAs. lllinois has submitted an attainment demonstration that was based on air quality modeling and contains enforceable control measures. The attainment demonstration included an RFP Plan which demonstrated the required 15% reduction in

ozone precursor emissions. Illinois has performed an analysis that demonstrates that the Metro-East NAA has attained the 1997 8-hour ozone NAAQS and believes the air quality improvements are due to permanent and enforceable control measures. Supporting documentation is contained herein.

The Illinois EPA has prepared a Maintenance Plan that meets the requirement of the Clean Air Act. This Maintenance Plan provides for the continued attainment of the 1997 8-hour ozone NAAQS for a period often years after u.S. EPA has formally redesignated the area to attainment. This Maintenance Plan provides adequate contingency measures for potential, additional emissions reductions in the event that future violations of the 1997 8-hour ozone NAAQS are observed in the area.

The Illinois EPA has prepared a comprehensive emissions inventory of the precursors of

ozone completed for the "attainment" year 2008, and has prepared projections of the emissions inventory to 2013 and to 2020. These emissions projections indicate that emissions levels in the Metro-East nonattainment area will continue to decrease from attainment year 2008 levels, thereby maintaining the ozone NAAQS in future years. The Illinois EPA commits to continue to operate an appropriate air quality monitoring network to verify the maintenance of the attainment status once the area has been redesignated. The Illinois EPA has the legal authority to implement and enforce all control measures.
Finally, the Metro-East Maintenance Plan includes year 2008 and 2020 on-road motor vehicle emissions budgets for use in transportation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of the 8-hour ozone standard during the ten-year maintenance period. The Metro-East Maintenance Plan has been prepared in accordance with the requirements specified in U. S. EPA's guidance document, and additional guidance received from u.S. EPA staff.

27

## APPENDIX A

Summary of Ambient Air Monitoriug Data (2007-2009)

28

### TableA.l 2007-2009 8-hour Ozone Design Values

for Monitors in 

### the St. Louis Region

State of Missouri County AQS Code Site Name Design Value 4th High 2007 4th High 2008 4th High 2009 SI. Charles 291831004 Orchard Farm 75 83 72 72 51. Charles 291831002 West Alton 78 89 76 71 ,51. Louis City 295100085 Blair 5t 75 87 73 65 51. Louis 291890014 Maryland Hts 76 94 69 67 51. Louis 291890005 Pacific 71 85 64 64 Jefferson 290990019 Arnold/Arnold W 75 87 70 70



### State of IIliuois County AQS Code Site Name Design Value 4th High 2007 4th High 2008 4th High 2009 Jersey 170831001 Jerseyville 70 75 69 68 Madison 171190008 Alton 72 81 68 67 Madison 171193007 Wood River 73 86 67 66 Madison 171191009 Maryville 77 87 70 74 51. Clair 171630010 E. 51. Louis 70 77 64 69



### 29

## APPENDIXB

Transportation Conformity

30TRANSPORTATION CONFORMITY

This section describes the development of the Metro-East nonattainment area motor vehicle emissions budgets associated with the Maintenance Plan for the 1997 8-hour NAAQS. An average summer weekday motor vehicle emissions budget is being proposed for the attainment year 2008 and for the Maintenance Plan year 2020 for the precursor pollutants YOM and NOx. These budgets were developed consistent with the
motor vehicle activity assumptions (e.g., fleet mix, registration distribution,

... ) and emissions control strategies incorporated into the Metro-East 8-hour ozone Attainment Demonstration analysis.

Background

Section 176(c)(4) of the Clean Air Act Amendments of 1990 requires that transportation plans, programs, and projects which are funded or approved under Title 23 ofthe United States Code (USC) must be determined to conform with State or Federal air implementation plans. A motor vehicle emissions budget is that portion ofthe total allowable emissions allocated to highway and transit vehicle use that are defined in the SIP for a certain year. Section 93.101 ofthe rule defines a "control strategy [State] implementation plan revision" as a "plan which contains specific strategies for controlling the emissions and reducing ambient levels of pollutants in order to satisfy Clean Air Act (CAA) requirements of reasonable further progress and attainment." In order to demonstrate conformity to the motor vehicle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program (TIP) must be less than or equal to the budget level (40 CFR § 93.118(a)).

Transportation conformity will be determined based on these proposed on-road motor vehicle emissions budgets after the U.S. Environmental Protection Agency (U.S. EPA) determines that the budgets meet the adequacy criteria of the transportation conformity rule under §93.118(e). The motor vehicle emissions budgets in this submittal are adequate as each of the six criteria under §93 .118( e) is satisfied. These six criteria include:

1. The submitted control strategy implementation plan revision or Maintenance Plan

was endorsed by the Governor (or his or her designee) and was subject to a State public hearing.

2. Before the control strategy implementation plan or Maintenance Plan was submitted
to U.S. EPA, consultation among federal, State, and local agencies occurred; full implementation plan documentation was provided to U.S. EPA; and U.S. EPA's stated concerns, if any, were addressed;

3. The motor vehicle emissions budgets(s) is clearly identified and precisely quantified;

314. The motor vehicle emissions budget(s), when considered together with all other emissions sources, is consistent with all applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given implementation plan submission);

5. The motor vehicle emissions budget(s) is consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan revision or Maintenance Plan, and

6. Revisions to previously submitted control strategy implementation plans explain and document any changes to previously submitted budgets and control measures, impacts on point and area source emissions; any changes taestablished safety margins; and reasons for the changes (including the basis for any changes related to emissions factors or estimates of vehicle miles traveled).

Regarding adequacy criterion #1, this State Implementation Plan and the associated
motor vehicle emissions budgets have been developed by the lllinois Environmental Protection Agency (lllinois EPA), the designated air quality agency for the State of Illinois. The required public hearing to accept public comment on the proposed budgets will be held on April 8, 2010 in the Regional Conference Room at the Illinois Department of Transportation's District 8 offices at 1102 Eastport Plaza Drive in Collinsville, Illinois. Notification ofthis hearing will be published in the Belleville News Democrat, East St. Louis Monitor, and Alton Telegraph on March 5, 2010 and in the Granite City Press Record Journal on March 7,2010. Comments on the proposed Maintenance Plan and associated motor vehicle emissions budgets will be accepted for 30 days after the public hearing. A "Responsiveness Summary" which addresses the written comments received will be prepared and included in the final submission.

In compliance with criterion #2 above, an Inter-Agency Conformity Consultation Team meeting was held at the offices of the East-West Gateway Council of Governments on January 26,2010. The Consultation Team includes representatives from the Federal Highway Administration, the U.S. EPA, the East-West Gateway Council of Governments (EWGCOG), the Missouri Department of Transportation, the Missouri Department of Natural Resources, the Illinois Department of Transportation (IDOT), and the lllinois EPA. At this meeting the development of the proposed Maintenance Plan motor vehicle emissions budgets was discussed. The draft Maintenance Plan was also forwarded to the U.S. EPA Region V representative for his review and comment.

The motor vehicle emissions budgets proposed and described herein were, in compliance with adequacy criterion #5, developed consistent with the methodology and control strategy assumptions used in the Metro-East 1997 8-hour Ozone Attainment

32Demonstration as well as the associated Reasonable Further Progress (RFP) plan. The effects ofthese controls are incorporated into the emissions factors produced by the U.S. EPA's MOBILE6.2 model. In response to adequacy criteria 4 and 6, the narrative of the Metro-East 8-hour Ozone Maintenance Plan discusses the emissions estimates from other
sectors and any changes in regulations. Following, in response to adequacy criteria #3, is

a discussion of the inputs and assumptions incorporated into the development of the proposed Maintenance Plan motor vehicle emissions budgets.

Vehicle Miles Traveled: The proposed Metro-East 8-hour Ozone Maintenance Plan attainment year 2008 motor vehicle emissions budgets were developed using actual 2008 county-level average weekday vehicle miles travelled (ADVMT) data from the IDOT. The 2008 ADVMT for the months of June, July, and August for the 4-county (Madison, Monroe, St. Clair and Jersey) Metro-East 8-hour ozone nonattainment area was 16.59 million miles. This figure was projected to the Maintenance Plan end year, 2020, using

an annual growth rate of 1.5 percent, yielding an ADVMT of 19.83 million.

To account for ozone season weekday traffic, the ADVMT estimates were multiplied by downstate Illinois facility type-specific Average-Daily-to-Average Summer Weekday conversion factors for 2008 supplied by IDOT. Applying these factors resulted in an average summer weekday VMT (ASWVMT) that is 10.8 percent greater than the ADVMT. Applying this summer weekday conversion factor results in a 2008 ASWVMT of 18.26 million miles and a projected 2020 figure of21.83 million miles. Following is a summary of the information and MOBILE6.2 model assumptions used in the development of the draft motor vehicle emissions budgets.

Temperature: U.S. EPA guidance for the use of the MOBILE6.2 model calls for the use of representative summer daily temperatures. For the year 2008, actual average June, July, and August minimum and maximum temperatures of 68 0 F and 87 0 F, respectively, were obtained from National Weather Service data for St. Louis Lambert Airport. For the year 2020, the climatological average minimum and maximum summer temperatures of 68 0 F and 88 OF, respectively, were used.

Absolute Humidity: U.S. EPA guidance calls for the use of the lowest absolute humidity on days corresponding to the summer climatological temperatures in the region

as calculated from local climatological data published by the National Weather Service. A climatological average summer weekday absolute humidity value of 97 grains of water (vapor) per pound of dry air was calculated for Lambert Airport.

Motor Vehicle Emissions Controls:The primary motor vehicle emissions control programs that were in place in the Metro-East NAA in 2008 and are projected to still be required are a vehicle inspection and maintenance (11M) program and the required use of southern grade Reformulated Gasoline.

Inspection and Maintenance (I/M): The liM program in effect since 2007 requires biennial On-Board Diagnostics II (OBD) testing on all model year (MY) 1996

33and newer (MY96+) light duty gasoline vehicles, and biennial exhaust idle and gas cap testing on MY96+.heavy duty gasoline vehicles including gasoline-powered buses, registered in the IIM testable area. Motorcycles and diesel vehicles are not subject to 11M. The program includes a 4-yeargrace period for new vehicles. This post-200? IIM
program was established when the Illinois legislature amended the Illinois Vehicle Inspection law in 2005 to (a) end dynamometer testing of vehicles, (b) require an OBDbased program beginning in February 2007, and (c) remove the requirement for testing compliant pre-MY-1996 vehicles.

Fuels: The use of federal Reformulated Gasoline (RFG) has been required in the Metro-East St. Louis NAA since 2007 and the St. Louis, Missouri area since 2001. Since the Metro-East NAA is a part of the St. Louis NAA, classified a "southern" area for
purposes of motor fuel control programs, southern grade RFG is required and assumed to be used in the Metro-East area. The 8-hour ozone Attainment Demonstration assumed the use of southern grade RFG in 2008 and beyond.

Gasoline Sulfur: Gasoline sulfur levels were assumed to be 30 parts per million (ppm) in both 2008 and 2020 in accordance with the federal Tier 2 gasoline regulations which required the 30 ppm level beginning in 2006.

Diesel Sulfur: Diesel sulfur levels were assumed to be 15 parts per million in both 2008 and 2020 in accordance with the U.S. EPA's Highway Diesel Rule which was finalized in January 2001. This regulation required the sale of on-road diesel fuel with no greater than 15 ppm of sulfur beginning in June 2006.

Speeds: The Illinois EPA assumed an area-specific vehicle speed distribution that
appears in the VMT-by-Speed-Bin external file SVMTME04.DEF, which is described in

more detail later in this document. The speed distribution in this file is for freeways and arterials only (local roads and ramps have a fixed speed in MOBILE6.2), and was based

on transportation model output (modeled speeds on links of various classes of roads by modeling period) from the EWGCOG for the year 2004. This speed distribution is assumed to remain valid for 2020.

VMT Mix: The regional VMT mix inputs used for 2020 were based on downstatespecific 2005 VMT -by-vehicle-type data supplied by mOT, modified to reflect expected changes in the ratio of cars to light trucks. This information is used in the MOBILE6.2 model to compute the average emissions factors for certain combined vehicle classes, and the all-vehicle emissions rate.

Registration Distribution: A Metro-East area-specific vehicle registration distribution profile based upon 2008 information data was developed by Illinois EPA's Division of Mobile Source Programs from data provided by the Illinois Secretary of State's Department of Motor Vehicles. This profile is assumed to remain valid for 2020

34Emissions Computation: Illinois EPA calculates emissions budgets using the following fonnula:

1. No- 

### VM County Emissions by vehicle type (VT) and functional class (FC)

= (County ASWVMT by FC) 

## * (VMT Mix by VT and FC) 

## * No-11M emissions factors (EF) by pollutant, VT, and FC) 

## * 1.102 (grams to ton conversion factor). For areas without 

### VM, this is the only calculation.

2. 11M Credits by VT and FC
= (County ASWVMT by FC) 

## * (VMT Mix by VT and FC) 

## * (No-11M EF

- 

### VM EF [both by pollutant, VT, and FC]) 

## * 11M coverage factor 

## * 1.102. This is for areas with 

### 11M only.

3. Net County Emissions by VT and FC
= (lIM County Emissions by VT and FC) - ( 

### VM Credits by VT and FC). This is for areas with 

### VM only.

The Illinois EPA perfonns these above calculations on a multi-page spreadsheet which automatically calculates emissions and 

### VM credits by county or township for each pollutant, VT, and FC, sums them by VT and FC, and aggregates them into area totals. Attachment A of this section provides additional details on the MOBILE6.2 model inputs used in the development of the 2008 and 2020 Metro-East NAA motor vehicle emissions budgets.

Motor Vehicle Emissions Budgets Using the above VMT and control program assumptions and methodology, following are the Attainment Year 2008 and Maintenance Plan Year 2020 Metro-East 8-hour ozone motor vehicle emissions budgets for use in determining transportation conformity.

Proposed Metro-East 8-hour Ozone Maintenance Plan 2008 and 2020 Motor Vehicle Emissions Budgets

(tons per ozone season weekday)

Year YOM NOx

2008 16.53 30.84

2020 7.70 10.34

35

### Attachment A

Transportation Conformity MOBILE6.2 Input File Formats

External MOBILE6.2 Inputs:

In the examples of external files shown below, the actual connnand lines are boldfaced; the unbolded lines represent connnents. The actual text files have no such distinction in typefaces. The unbolded lines have been "commented out" and have no effect on the MOBILE6.2 model. They may therefore be omitted, but it is suggested that they remain in the files for documentation, and to make the files easier for the user to read and understand.

The comments and other text in the External Files have been shown in the 

### Courier New typeface. Actual command lines-the inputs that MOBILE6.2 actually uses-are shown in 

### courier New Bold

In certain cases (especially the VMT -by-Speed-Bin files) the typeface has been reduced in size so that the lines would fit within the margins of the page. This makes them easier
to read.



### Vehicle Inspection and Maintenance aIM) 

### Program

The external 11M files giving the inputs used in the MOBILE6.2 model in this exercise

were ILLOBDIM.D (for 2002 and through 2006) and IM070N.D (for 2007 and later years). When evaluating 11M credits for 2008, the residual effect of the ILLOBDIM program in the sunnner of2008 is taken into account by assuming that 75% of the vehicle fleet subject to 11M has been tested under the IM070N program by that time, and that the other 25% have been tested under the ILLOBDIM in late 2006 and have not yet come up for retesting under IM070N by summer 2008 (both programs are biennial). The effective 11M emissions rate in 2008 is thus 25% ofILLOBDIM's plus 75% ofIM070N's. By

summer 2009, all vehicles subject to 11M will have been tested under IM070N, so this question does not arise when evaluating years from 2009 on: the 11M emissions rate for 2009 and after is simply that for the IM070N program.

The IM070N.D File, used for the year 2008

The external 11M file IM070N.D described below represents an 11M program with four components, chief of which is an OBD (on-board diagnostics) test for vehicles of model
year (MY) 1996 and newer. Illinois EPA begins IM070N.D with identifying connnents,

36and adds other comment lines or blank lines to make the file easier to read and understand

.. Programs after the first need comparatively few comments because the commands are largely self-descriptive.

* ILLINOIS ENHANCED r/M DESCRIPTION

* Filename: IM070N.D

* External input file for Illinois' OBD-onlyI/M program
* from 2007 on. * OED-only applies to light-duty vehicles only; HDVs still get

* an Idle Test & Gas Cap Check.

* All program start years set to 1986 per U.S. EPA guidance in

* lIFreque:htly Asked**Quest~ons** on MOBILE6" from U.S. EPA/OTAQ.

* This represents the NEW r/M program in which only 1996 &

* newer vehicles are tested with an OBD test; and the OED test

* applies only to LDVs.

* This program came into effect in February 2007.

*-------------------------------------------------

* Program description for post My r 96 LDV OBD 

### riM *=====================================:===========

* FIRST 11M program--llEvaporative]11 OBD for MY 1996+ LDVs *------------------------------------------------- 

### I/M PROGRAM I/M MODEL YEARS I/M VEHICLES I/M STRINGENCY I/M COMPLIANCE I/M WAIVER RATES I/M EXEMPTION AGE I/M GRACE PERIOD 1 1986 2050 2 T/O EVAP OBD 1 1996 2050 1 22222 11111111 1 1 20.0 1 95.0 1 0.5.2.2 '01 data
1 

### 25 1 4

In each case, the first number after the colon refers to the IIM program's component number.



### I/M PROGRAM : 1 1986 2050 2 T/O EVAP OBD

Testing began in 1986 and runs into the indefinite future (2050). The program is a biennial test-only (2 

### T/O, here and in other program components) program, in this case an Evaporative On-Board Diagnostics (OBD) test. The On-Board Diagnostic program in a vehicle engine's computer records information from

sensors in the engine and fuel system. Indications of malfunctions or out-ofspecification operations of the engine or fuel and evaporative emissions control systems are stored in the engine computer as "fault codes." An OBD test consists of plugging a special scanner into an output jack from the vehicle's engine computer. The scanner queries the computer and records any fault codes that the computer's OBD system has saved. OBD tests are qnick, dependable,

37and clean, and, if a vehicle fails an OBD test, the fault codes that the scanner displays help mechanics diagnose the problem.

liM MODEL YEARS : 1 1996 2Q50

This program component covers only vehicles manufactured between model
year (MY) 1996 (start year) and the indefinite future (MY 2050, the end year). More and more vehicles are becoming subject to this test as new vehicles are bought and older (pre-MY -1996) ones are scrapped vehicles.

liM VEHICLES : 1 22222 11111111 1

Only the five light-duty vehicle types (cars [LDGVs], and light trucks [LDGTs 1,2,3, and 4]) are covered by this program component (22222). Heavy-duty gasoline vehicles (HDGV) (eight types) and gasoline buses are not covered by this program component (11111111 1); but rather by Programs 3 and 4, described below.

liM STRINGENCY : 1 20.0

Stringency (exhaust inspection failure rate) is 20%. A Stringency entry is necessary for

an Exhaust test, but not an Evaporative test, so this entry can be omitted or "commented out". In this Evap test case, it will be ignored by the model, but is included for reference.

liM COMPLIANCE : 1 95.0

Compliance rate (tested vehicles as percent of all vehicles subject to 

### 11M) is 95%

liM WAIVER RATES : 1 0.5 2.2 '01 data

The Waiver Rate is the fraction of tested vehicles that get a waiver-i.e., do not pass the 11M test but, because repairs cost more than a specified amount, get a certificate of compliance. The waiver rate is 0.5% for MY 1980 and earlier vehicles (irrelevant now that pre-MY -96 vehicles are not tested), and 2.2% for MY 1981 and later vehicles. These figures are from VIM's actual 2001 waiver statistics, and have been representative of the last few years, so are deemed representative of 2008 and 2020.

liM EXEMPTION AGE : 1 25

Vehicles older than 25 years are not subject to this program. As the Illinois 11M program only requires testing for MYI996 and newer vehicles, exemptions will
not occur until 2021. The default is 25, and the model does not calculate benefits for vehicles older than 25 years, so in essence this command has no effect. It could be omitted, but is included for completeness.

liM GRACE PERIOD : 1 4

Vehicles less than 4 model years old-in this case MY2006, '07, '08, and '09-

are exempt from 

### 11M testing.

38Most of the inputs to the second and subsequent program .components are the

same as those for the first program, so the description of the components will be abbreviated and summarized as below, rather than after each command line as above.



## * Second 11M program--nExhaust n OED for MY 1996+ LDVs
*---------------------------------------------------- 11M 

### PROGRAM 2 1986 2050 2 

## Tlo OED 11M 11M 

### MODEL YEARS 2 1996 2050 11M 

### VEHICLES 2 22222 11111111 1 11M 

### STRINGENCY 2 20.0 11M 

### COMPLIANCE 2 95.0 11M 

### WAIVER RATES 2 0.5 2.2 '01 data 11M 

### EXEMPTION AGE 2 25 11M 

### GRACE PERIOD 2 4



## *

The second 11M program component is a biennial, test-only Exhaust OBD test

for MY 1996 and later LDGVs and LDGTs. In this OBD test, the scanner queries the vehicle's computer for fault codes concerning exhaust emissions. Stringency, Compliance, Waiver Rates, Exemption Age, and Grace Period are the same as in the first program. An entry for 

### 11M STRINGENCY (20%) is required for an Exhaust 

### 11M program.

*------------------------------------------------------



## * Program description for post MY'96 HDV Idle 

### & GC 11M***;~~===================================================**



## * Third 11M program--HDV IDLE for MY 1996+ HDVs
*------------------------------------------------ 11M 

### PROGRAM 3 

### 1986 2050 2 

## Tlo IDLE 11M 

### MODEL YEARS 3 

### 1996 2050 11M 

### VEHICLES 3 

### 11111 22222222 2 11M 

### STRINGENCY 3 

### 20.0 11M 

### COMPLIANCE 3 

### 95.0 11M 

### WAIVER RATES 3 

### 1.2 1.5 '01 data 11M 

### EXEMPTION AGE 3 

### 25 11M 

### GRACE PERIOD 3 4

The third liM program component is a biennial, test-only Idle test for MY 1996 and later HDGVs and Gas Buses (22222222 2). Light-duty vehicles are not subject to this component (11111), but rather to components I and 2. Stringency, Compliance, Exemption Age, and Grace Period are the same as in component I, but the pre- and post-MY 1981 Waiver Rates (1.2% and 1.5%,

39respectively), are slightly different from those in components 1 and 2. HDGVs

are few in number, and most of them are commercial vehicles.



## * Fourth 11M program--Gas Cap Check for MY 1996+ HDVs 

## *----------------------------------------------------
11M PROGRAM 4 1986 2050 2 

## Tlo GC 11M MODEL YEARS 4 1996 2050 11M VEHICLES 4 11111 22222222 2 11M COMPLIANCE 4 95.0 11M WAIVER RATES 4 1.2 1.5 '01 data 11M EXEMPTION AGE 4 25 11M GRACE PERIOD 4 4

The fourth 11M program component is a biennial, test-only Gas Cap Check for MY 1996 and later HDV s. Compliance, Waiver Rates, Exemption Age, and Grace Period are the same as in the third program. Since a Gas Cap Check is an evaporative 11M test, the 11M STRINGENCY command is not necessary and is
not included here.

Illinois EPA includes additional notes and comments in the 11M file for documentation purposes, as shown below:

* NOTES

* This is a standard Illinois 

### rIM input, describing the riM

* program with OED Only as it is supposed to exist after

* January 2007. It is the file to be used for regular M6

* riM runs for 2007 and future years.

*
* This file was originally SB397.D, supplied 24.viij.OS.

* Original SB397.D has been slightly revised by
* the addition of comments such as this one. The actual

* inputs have not been changed. This was done to put the two

* LDV OBD programs (exhaust and evaporative) together, and the

* two HDV programs together too. The order of the programs in

* the 11M file is not significant and has no effect in M6, but

* the programs must be numbered sequentially.

* DVIM verified that this file as shown correctly describes the

* 11M program planned for introduction in January '07.

*

---------------- * COMPARISON WITH ILLOBDIM.D:

* The first three programs in ILLOBDIM.D, covering the idle

* test for MY'68-'81 LDVs, IM240 for 181-'95 LDVs, and gas * cap check for MY'68- 1 95 LDVs have been eliminated from

* IM070N; and the two HDV programs now refer only to MY'96

* and later.



### The Registration Distribution

The Registration Distribution (RD) for a vehicle type is an indication of the fraction of

40the vehicle fleet of that type that is made up of vehicles of a given age.

The following Metro-East-specific RD file (MERD08AA.d) is based on 2008 registration data from the Illinois Secretary of State's office (IS0S). It and its contents are described in below.

REG DIST

* MENAA MG LOV RD = SOSLDV (Light-duty vehicles--passenger cars) RD from

* OSVADbyCounty.xls for Metro-East omitting '09 counts & '08 = 75% of '07

1 0.0422 0.0562 0.0568 0.0583 0.0574 0.0561 0.0654 0.0662 0.0680 0.0614 0.0523 0.0524 0.0467 0.0447 0.0355 0.0306 0.0256 0.0216 0.0175 0.0148 0.0114 0.0086 0.0074 0.0182 0.0247

* MENAA M6 LDTI RD = SOSLDTI (ISOS "light" or type 1. LD trucks) RD from

* 08VADbyCounty.xls for Metro-East omitting '09 counts & lOB = 7S%-of '07

2 0.0397 0.0529 0.0652 0.0822 0.0703 0.0684 0.0783 0.0651 0.0645 0.0576 0.0599 0.0489 0.0363 0.0316 0.0321 0.0266 0.0218 0.0202 0.0142 0.0144 0.0130 0.0089 0.0073 0.0055 0.0151

* MENAA M6 LDT2 RD = Same as M6 LDTI RDi see above.

3 0.0397 0.0529 0.0652 0.0822 0.0703 0.0684 0.0783 0.0651 0.0645 0.0576 0.0599 0.0489 0.0363 0.0316 0.0321 0.0266 0.0218 0.0202 0.0142 0.0144 0.0130 0.0089 0.0073 0.0055 0.0151

* MENAA. M6 LDT3 = SOSLDT21. (ISOS I'heavyl' or type 2 LD trucks) RD from

* 08VADbyCounty.xls for Metro-East omitting '09 counts & '08 = 75% of '07

4 0.0439 0.0585 0.0592 0.0757 0.0922 0.0854 0.0750 0.0643 0.0588 0.0631 0.0418 0.0385 0.0372 0.0401 0.0335 0.0213 0.0194 0.0109 0.0126 0.0120 0.0098 0.0072 0.0075 0.D060 0.0261

* MENAA M6 LDT4 = same as LDT3 RDs; see above.

5 0.0439 0.0585 0.0592 0.0757 0.,0922 0.0854 0.0750 0.0643 0.0588 0.0631 0.0418 0.0385 0.0372 0.0401 0.0335 0.0213 0.0194 0.0109 0.0126 0.0120 0.0098 0.0072 0.0075 0.0060 0.0261

* Above from 2008 Metro-East-area data from DVIM and calculated in accordance

* with AW USEPA's recommendations in '02 training material,

* viz., ignore MY09 counts and set MYIOS counts to 75% of IMY07 counts.

* This file is MERDOSAA.d, made 27.j.09.

* Heavy-Duty & Me RDs below are all assumed same as M6 default RD

. 

### •

0.0519 0.0472 0.0430 0.0202 0.0184 0.0167

as HDV2B, M6 Default 0.0627 0.0571 0.0519 0.0244 0.0222 0.0202 * HDV2B (Heavy-duty vehicles 2B--M6 Default RDs)

6 0.0503 0.0916 0.0833 0.0758 0.0690 0.0627 0.0571 0.0391 0.0356 0.0324 0.0294 0.0268 0.0244 0.0222 0.0152 0.0138 0.0126 0.0114 0.0499

* HDV3 (Heavy-duty vehicles3, same RD

7 0.0503 0.0916 0.0833 0.0758 0.0690 0.0391 0.0356 0.0324 0.0294 0.0268 RDS) 0.0472 0.0184 0.0430 0.0167

410.0152 0.0138 0.0126 0.0114 0.0499

* HDV4 (Heavy-duty vehicles 4, M6 default RDs)

8 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218 0.0204 0.0191 0.0178 0.0167 0.0797

* HDVS (Heavy-duty vehicles 5, same RD as HDV4, M6 Default)

9 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 ·0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218 0.0204 0.0191 0.0178 0.0167 0.0797

* HDV6 (Heavy-duty vehicles 6, same RD as HDV4, M6 Default) 10 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218 0.0204 0.0191 0.0178 0.0167 0.0797

* HDV7 (Heavy-duty vehicles 7, same RD as HDV4, M6 Default) 11 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218 0.0204 0.0191 0.0178 0.0167 0.0797

* HDV8A(Heavy-duty vehicles SA same RD as HDV4, M6 Default) 12 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218 0.0204 0.0191 0.0178 0.0167 0.0797

* HDV8B (Heavy-duty vehicles BB,same RD as HDV4, M6 Default) 13 0.0388 0.0726 0.0679 0.0635 0.0594 0.0556 0.0520 0.0486 0.0455 0.0425 0.0398 0.0372 0.0348 0.0326 0.0304 0.0285 0.0266 0.0249 0.0233 0.0218 0.0204 0.0191 0.0178 0.0167 0.0797

* HDBS (HDV School buses; this M6 RD default is assumed) 14 0.0393 0.0734 0.0686 0.0641 0.0599 0.0559 0.0522 0.0488 0.0456 0.0426 0.0398 0.0372 0.0347 0.0324 0.0303 0.0283 0.0264 0.0247 0.0231 0.0216 0.0201 0.0188 0.0176 0.0165 0.0781

* HDBT (HDV Transit buses; thisM6 RD default is assumed) 15 0.0307 0.0614 0.0614 0.0614 0.0614 0.0614 0.0614 0.0614 0.0614 0.0613 0.0611 0.0607 0.0595 0.0568 0.0511 0.0406 0.0254 0.0121 0.0099 0.0081 0.0066 0.0054 0.0044 0.0037 0.0114

* Me (Motorcycles; this M6 default RD is assumed) 16 0.1440 0.1680 0.1350 0.1090 0.0880 0.0700 0.0560 0.0450 0.0360 0.0290 0.0230 0.0970 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

This MERD08AA.d file is derived ultimately from REGDATA.D, the default MOBILE6.2 RD file, but more immediately derived from an original MERD08.D file calculated using 2008 registration counts by age for LDVs. Due to the time frame in which this data was set, counts for MY'09 vehicles omitted as nonrepresentative, and counts for MY'08 vehicles set to 75% of those for MY'07 vehicles, in accordance with U.S. EPA practice as given in MOBILE6.2 training materials available from OTAQ on line. This file was created in January 2009.

This data is ultimately derived from ISOS registration data for LDVs subject to 11M in the Metro-East-area counties. Since more than 85% of the light-duty gasoline vehicles in the Metro-East area are subject to 11M, we assume the RD for Metro-East area LDVs subject to 11M is representative of that for all Metro-Eastarea LDVs, whether subject to 11M or not.

The ISOS data were counts for what ISOS calls "LDVs", LDTls", and "LDT2s" by model year. Those appear below as SLDV, SLDTl, and SLDT2 to distinguish them from M6 vehicle types.

42• SLDVs correspond to passenger cars, so SLDVs = M6 LDVs.

• SLDTls correspond to M6 LDTls and LDT2s. ISOS data do not distinguish between the two M6 categories. For this reason, the RDs for M6 LDTl and LDT2 are assumed to be the same.

• Similarly, SLDT2s correspond to M6 LDT3s and LDT4s, and ISOS data do not distinguish between those two M6 categories either. Therefore, the RDs for M6 LDT3 and LDT4 are also assumed to be the same. Of course the SLDTI (LDTl2) and SLDT2 (LDT34) RDs are not the same.

The age distribution fractions have been rounded to 4 decimal places, and where t):le rounded fractions do not add up to 1.0000 exactly, RD fractions for old (age 22 to 24 years) have at times been modified by +/" 0.0001 so as to make the RDs add up to 1.0000. (This is a requirement of the MOBILE6.2 model.)

See the default M6 RD file REGDATA.D and especially the M6 Users Guide Section 2.8.7.1 (p. 63 ff) for more detailed information about RD files. See also the actual MOBILE6.2 source code \SOURCE\BD20.FOR and Illinois EPA's previous local-area RDs (e.g., MERD03.D and MERDOI.D) for further information.

In this RD file, the first number in each distribution is an integer that indicates which of the 16 M6 vehicle classes are represented by the RD in question. That number is followed by 25 age fractions arranged in two rows of 10 values followed by a third row with the last 5 values. (This is similar to the format used in M5b for RDs, and is the same format as the default REGDATA.D file.)

RDs for all vehicle classes are given in this file. This is for completeness even though only those vehicle classes whose RDs were changed from the REGDATA defaults need
to be included in this file. Those RDs that were not changed from default values are so noted.

It is assumed that the RDs for diesel vehicles are the same as the RDs for the corresponding gasoline vehicles; in particular, LDDV and LDDT RDs are assumed the

same as LDGV and LDGT RDs. Since the (default) HDV RDs are based more on diesel vehicles to start with, and HDGVs are many fewer than HDDVs, (i.e, most heavy-duty trucks are diesels) especially in the higher weight classes, we feel the default HDV RDs represent both HDGV and HDDV reasonably well.

Default RDs are assumed for the various HDV classes. Good area-specific HDV age distribution data are lacking-the ISOS data covered only light-duty vehicles subject to lIM-and besides, much Metro-East-area HDV VMT is from vehicles registered outside the Metro-East area and just passing through. The best choice, then, was to go with the HDV defaults. Similarly, accurate local-area registration data for motorcycles are lacking, so the default MC RD is used.

43

### External MOBILE6.2 Activity File Inputs: VMT by Facility Type, VMT by Hour, VMT by Speed Bin.

VMT by Facility Type

The M6.2 default file is FVMT.D, provided with the MOBILE6.2 model. There is no good Metro-East-area -specific VMT-by-facility-type data available, so the default FVMT.D file is used. This is a very long file -about 750 lines-so for the purposes of this Attachment, only the data for vehicle types 1 is reflected. The first data line of FVMT.Dis 1 0.392 0.457 0.117 0.034;itsignifiesthat,forLDGVs(typel)athour 6AM, 39.2% ofVMT is on Freeways, 45.7% is on Arterials, 11.7% is on Local Roads/Streets, and 3.4% is on Ramps. Note that, during the day, the fraction ofVMT on Arterials reaches a maximum, and decreases after the work day ends

VMT BY FACILITY


### •

* This is FVMT.DEF, the "default" FVMT file supplied with the M6 model.


### •

* V,MT fractions are listed for 28 vehicle classes for each hour of

* the day starting at 6AM. There are 24 sets of four values for

• each vehicle type. The VMT fractions by hour are the same
* for all vehicle classes.


## •

* The four values in each line represent the VMT distribution on
* freeway, arterial, local and ramps--in that order--as shown. 

## •

* See M6UG 2.8.5.1.£., p. 49, or CLASLIST.TXT for further information.

* (The CLASLIST file describes the vehicle classes.)


### •
* Veh Int& Arts& Local**~Class** Fwys ColIs Rd/St Ramps *-----



### • 1 0.392 0.344 0.338 0.349 0.346 0.333 0.324 0.334 0.334 0.320 0.330 0.312 0.295 0.310 0.329 0.343 0.381 0.405 0.426 0.443 0.457 0.461 0.457 0.497 0.497 0.492 0.497 0.509 0.516 0.506 0.506 0.519 0.506 0.521 0.538 0.527 0.510 0.497 0.460 0.437 0.418 0.403 0.394 0.391 0.117 0.129 0.135 0.129 0.127 0.129 0.132 0.131 0.131 0.134 0.135 0.140 0.141 0.137 0.133 0.131 0.126 0.123 0.118 0.115 0.110 0.107 0.034 0.030 0.029 0.030 0.030 0.029 0.028 0.029 0.029 0.028 0.029 0.027 0.026 0.027 0.029 0.030 0.033 0.035 0.037 0.039 0.040 0.040

440.453 0.400 0.108 0.039 0.418 0.434 0.112 0.036

FVMT data for vehicle types 2 through 28 are omitted for reasons of space.

VMT by Hour of the Day

The MOBILE6.2 default file is HVMT.D. The most current Metro-East St. Louis area-specific file is HVMTME04.def, shown below, derived from 2004 modeling output from EWGCOG. Again, this file contains "commented-out" data from the default for comparison purposes.

VM'I' BY HOUR


### •

* Filename: HVMTME04.DEF
* Fraction of all vehicle miles traveled by hour of the day.

• First hour is 6 a.m. These---data are for the Metro-Bast-area for

* 2004, following EWGCOG TM output in NEWBUDGET.XLS as calculated
* by Illinois EPA in MESVMT.XLS, July '02, page "VMT by Hr".


### • 0.0518 0.0796 0.0704 0.0505 0.0491 0.0529 0.0553 0.0519 0.0544 0.0578 0.0967 0.0909 0.0624 0.0354 0.0280 0.0240 0.0176 0.0131 0.0098 0.0078 0.0074 0.0073 0.0089 0.0169


### •
• These following are the default values from HVMT.DEF


### • which are supplied for comparison.


### • 0.0569 0.0740 0.0655 0.0555 0.0540 0.0582


### • 0.0608 0.0571 0.0598 0.0636 0.0777 0.0730


### • 0.0501 0.0389 0.0308 0.0264 0.0194 0.0144


### • 0.0108 0.0086 0.0081 0.0080 0.0098 0.0186

All these Hourly- VMT files show similar profiles, with morning and afternoon peaks, a noontime dip, and a minimum about 3AM

- 4AM, which is to be expected.

VMT by Speed Bin

The MOBILE6.2 default file is SVMT.D. The Metro-East-area-specific Speed-bin file is VbySpd07.DEF, shown below. It represents 2004 EWGCOG transportation model output, deemed representative for future years. Since it is a "wide" file (at least 90 columns), it is shown here in a smaller-than-usual typeface to make it easier to read

SPEED VMT 1 1 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 b.1210 0.0957 0.0735 0.5818 0.0000 1 2 0.0000 0.0108 0.0020 0.0146 0.0095 0.0710 0.0497 0.1262 0.0838 0.0676 0.1530 0.2308 0.1810. 0.0000 1 3 0.0000 0.0108 0.0020 0.0146 0.0095 0.0710 0.0497 0.1262 0.0838 0.0676 0.1530 0.2308 0.1810 0.0000 1 4 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 5 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 6 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 7 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 8 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 9 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 10 0.0000 0.000'0 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000

451 11 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 12 0.0000 0.0000 0.0000 o.oooa 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 13.0.0000 0.0000 0.0000 O.DOOO 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 1. 0.0000 0.0000 0.0000 0.0000 o 0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 15 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 16 0.0000 0.0092 0.0078 0.0017 0.0063- 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 17 0.0000 0.0092 0.0078 0.0017 0.0063- 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 18 0.0000 0.0092 0.0078 0.0017 0.0063 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 19 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 20 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 21 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 22 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 23 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 2. 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 2 1 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 2 0.0011 0.0025 0.0166 0.0664 0.1148 0.2216 0.2188 0.1577 0.0912 0.0910 0.0183 0.0000 0.0000 0.0000 2 3 0.0011 0.0025 0.0166 0.0664 0.1148 0.2216 0.2188 0.1577 0.0912 0.0910 0.0183 0.0000 0.0000 0.0000 2 

# • 0.0000 0.0000 D" 0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 5 0.00'00 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 6 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 7 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 8 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 9 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 10 0.0000 0.0000 0.0-017 0.0197 0.0988 0.2301 0;2287 0.2461 0.0967 0.0782 0.00-00 0.0000 0.0000 0.0000 2 11 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 12 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 13 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 14 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 15 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 16 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 17 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 18 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 o.booo 0.0000 0.0000 0.0000 2 19 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 20 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 21 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 22 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 23 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 2. 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 

### •
• Speed Bins;


### • 2.5 5.0 10.0 15.0 20.0 -25.0 30.0 35.0 40.0 45.0 50.0 55.0 60.0 65.0+

Speed bins extend 2.5 mph on either side of the bin name (i.e., the 30-mph speed bin
encompasses speeds from 27.5 to 32.5 mph), except for the first (2.5 mph) bin (0 to 2.5 mph) and the last (65+ mph) bin (62.5 mph and above).

The information in this file strictly speaking represents a speed distribution for 2004, but is assumed, after discussion with the EWGCOG, to be reasonably valid throughout the period in question.

The above data are for the Metro-East area, and for Freeways and Arterill1s only. SeeM6 User's Guide Sec. 2.8.8.2.c and Appendix B, Table 5: "Average Speed Ranges for Speed Bins (SPEED VMT Command)" for further information about this file and its use. See also the default VMT -by-speed file SVMT.DEF for more information and comments.

The first number in each line is roadway type: I = Freeways; 2 = Arterials. Locals and Ramps have a fixed speed in built into the M6 model, and therefore are not affected by this file. The second number is the hour of the day, hour I being [hour beginning at] 6 AM, and hour 24 being [hour beginning at] 5 AM the next day. The third and subsequent numbers are the fractions of VMT in that hour that occur within the specified speed bins.

46Note that, for Freeways, most VMT is in the 45-50-55-60-mph speed bins, with lower speeds more common during Peak hours, which is reasonable. Much the same holds for Arterials, where most VMT is in the 30-35-40-45 mph speed bins, also reasonable.



### 47