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 nonattainment 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 PUpel
In 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.

Iffurther 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 Nonattainment 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 MAINTENANCE 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 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 Implement and Enforce . . . . 26 

7.0 CONCLUSIONS . . . . . . . . 27 

 
ii

TABLE OF CONTENTS (Continued) 

APPENDIX A Summary of Ambient 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-Hour 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 Area 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’ 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 technical information required to support 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 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 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 continued 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 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. 
6

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 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 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 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 counties 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 contained 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 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 federal 8-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 (VOM) 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 Quality

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. 

 
9

2.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS

Sections 107 and 110 of the CAA list a number of requirements that must be met by 

nonattainment 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 the NAAQS 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 CFR 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 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 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 “attainment year”; 
10

 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 of legal 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 of this document describe 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” (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 
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 4th 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 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 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. 
14

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) 

of the 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 10-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 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 

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 nonattainment of the 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 of the 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. 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 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 Illinois and other nearby states, 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 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 VOM and NOx emissions for the Metro-East 

NAA for 2020. Illinois 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. On-road motor vehicle emissions were estimated using 

U.S. EPA’s MOBILE6 motor vehicle emissions model. The figures assume the 

continued use of reformulated 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 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 emissions projected for the ten-year period 

following redesignation is sufficient to maintain 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 reductions projected to occur within the 

nonattainment area, significant reductions of statewide NOx emissions resulting from 

implementation of Illinois’ 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 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 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 conform 

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 Performance 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 

 Reformulated Gasoline 

 Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control 

Requirements 
19

 On-Highway Heavy-Duty Engine and Vehicle Standards and Highway Diesel 

Fuel Sulfur Control Requirements 

 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, 182(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 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 still 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 CTGs 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 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 light-duty 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 VOM 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 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 requirements also affect VOM 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 VOM RACT rules fulfill U.S. EPA’s RACT requirements for VOM sources in 

the Metro-East NAA. 

As mentioned previously, the RACT requirement for NOx was previously waived under 

the 1-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 
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 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 VOM 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 

demonstrate 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 model. 

These control measures include the implementation of national motor vehicle emissions 

standards, the operation of a vehicle inspection 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, 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 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 and 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 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 Illinois Pollution Control 

Board (IPCB) prior to the occurrence of NAAQS 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. 

Illinois EPA’s contingency plan for the Metro-East NAA is described in Table 6.1. 

Consistent with this plan, Illinois 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, Illinois 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) 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 state to implement contingency measures when 

occasional exceedances are recorded. The Illinois EPA’s voluntary commitment to 

initiate a Level I response is intended to prevent future violations of the NAAQS from 

ever occurring. 

Illinois commits to compiling VOM and NOx emissions inventories for the Metro-East 

area every three years for the duration of the 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 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 determine 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 

determination 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 
25

corrective 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 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 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 
26

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. 

 

 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 Implement 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. 
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 applicable provisions of the CAA required of 

moderate ozone NAAs. Illinois 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 of ten 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. 
28

APPENDIX A

Summary of Ambient Air Monitoring Data 

(2007-2009)
29

Table A.1 

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 

St. Charles 291831004 Orchard Farm 75 83 72 St. Charles 291831002 West Alton 78 89 76 

St. Louis City 295100085 Blair St 75 87 73 

St. Louis 291890014 Maryland Hts 76 94 69 

 St. Louis 291890005 Pacific 71 85 64  Jefferson 290990019 Arnold/Arnold W 75 87 70 State of Illinois 

County AQS Code Site Name Design Value 4th High 2007 4th High 2008 

Jersey 170831001 Jerseyville 70 75 69 

Madison 171190008 Alton 72 81 68 Madison 171193007 Wood River 73 86 67 Madison 171191009 Maryville 77 87 70 

 St. Clair 171630010 E. St. Louis 70 77 64 
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 motor 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 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 of the United 

States Code (USC) must be determined to conform with State or Federal air 

implementation plans. 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. 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 

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; 
32

4. 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 to established 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 Illinois Environmental 

Protection Agency (Illinois 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 of this 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 Illinois 

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 
33

Demonstration as well as the associated Reasonable 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 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 of 21.83 million miles. Following is a 

summary of the information and MOBILE6 model 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 temperatures. For the year 2008, actual average 

June, July, and August minimum and maximum temperatures of 68 o F and 87 o 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 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 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 (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 (OBD) 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 vehicles including gasoline-powered buses, 

registered in the I/M testable area. Motorcycles and diesel vehicles are not subject to 

I/M. The program includes a 4-year grace period 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 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), 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 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 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 
35

Emissions Computation: Illinois EPA calculates emissions 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 = (County 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 calculations 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 additional 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 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 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 shown below, the actual command lines are boldfaced; 

the unbolded lines represent comments. The actual 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 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 MOBILE 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 (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 ILLOBDIM in late 2006 and have not yet come up 

for retesting under IM07ON by summer 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 years 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 below represents an I/M 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 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 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 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 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. 

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 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. 

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 percent of all vehicles subject 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 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. 

I/M EXEMPTION AGE : 1 25

Vehicles older than 25 years are not subject 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 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. 

I/M GRACE PERIOD : 1 4 

Vehicles less than 4 model years old—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 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 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 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 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 from 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 STRINGENCY 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 vehicle type is an indication 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 office (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 ultimately from REGDATA.D, the default 

MOBILE6 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 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 are subject to I/M, we assume the RD for 

Metro-East area LDVs subject to I/M is representative of that for all Metro-Eastarea LDVs, whether subject to I/M or not. 

The ISOS data were counts for what ISOS 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 categories 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 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.) 

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 source code \SOURCE\BD20.FOR and 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 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 

I/M—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. 
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 LDGVs (type 1) at hour 6AM, 

39.2% of VMT 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 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, shown 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 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 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 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 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 = 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 1 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. 
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 ofPublic 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 ofthe 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 ofthe 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 ofthese 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 ofthis 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 ofthe 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 ofthe 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 ofthe 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.

.._---.._---- Attachment 112
Alec M. Davis

General Counsel

Illinois EPA Registration and Mailing List

E-mail address: DPi\,; 1O. r

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215 East Adams Street

Springfield, IL 62701

(217) 522-5512 Ext. 232

Fax: (217) 522-5518

adavis@ierg.org

Website: WWw.ierg.org

1~6

Organization you represent (if any): _ Organization you represent(if any): f) '1Mel';'" !7 c..of f-r

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IL 532-2838. •

ADM 231 Rev. 9/09
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Illinois EPA Registration and Mailing List

Name: f (a/OR: fi:.,o-+h ease pnnt or attach bllsmess C3id~

Mailing Address: //1-/4 um' V!?fS/lcl ~- 4JJ. 83

city:fdfA Joe{/Jtl/I!e

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908 N. Metter

Columbia, IL. 62236

E-mail address:

618-281-5460

'Iailing List

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Organization you represent (if any): _

I wish to make oral comments ask questions _ IL 532-2838

ADM 231 Rev. 9/09 Espaiiol a! reverse

Organization you represent (if any): ---

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IL 532-2838

ADM 231 Rev, 9/09 Espaiiol a! reverse
1 ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

2

3

4

5

6

7

8

9

10

MAINTENANCE PLAN FOR THE

METRO-EAST 8-HOUR OZONE

NON-ATTAINMENT AREA.

No. AQPSTR-10-01

11

12

13

14

15

16

17

18

19

20

21

22

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

..1 •• _

Attachment 114
 1 ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

 2 

 MAINTENANCE PLAN FOR THE ) 

 3 METRO-EAST 8-HOUR OZONE ) No. AQPSTR-10-01 

 NON-ATTAINMENT AREA. ) 

 4 

 5 

 6 

 7 

 APPEARANCES: 

 8 

 Dean Studer, Hearing Officer/Right-To-Know Coordinator 

 9 Illinois Environmental Protection Agency 

 1021 North Grand Avenue East 

 10 P. O. Box 12976 

 Springfield, IL 62794-9276 

 11 

 Dana Vetterhoffer 

 12 Illinois Environmental Protection Agency 

 Assistant Counsel 

 13 Division of Legal Counsel 

 14 David "Buzz" Asselmeier 

 Illinois Environmental Protection Agency 

 15 Emission Inventory Coordinator 

 Bureau of Air 

 16 

 Michael D. Rogers 

 17 Illinois Environmental Protection Agency 

 Environmental Protection Specialist 

 18 Division of Mobile Source Programs 

 19 Robert J. Kaleel 

 Illinois Environmental Protection Agency 

 20 Manager, Air Quality Planning Section 

 Bureau of Air 

 21 

 22 

 23 

 24 

 2 

 Keefe Reporting Company
 1 BE IT KNOWN that a record was made on April 8, 

 2 2010, at 1102 Eastport Plaza Drive, Collinsville, 

 3 Illinois, before Holly A. McCullough, an 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 transcribed 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 of gathering 

 19 public comments on the draft Maintenance Plan related 

 20 to the 1997 8-hour ozone National Ambient Air Quality 

 21 Standard, otherwise abbreviated as NAAQS, and the 

 22 associated draft motor vehicle emissions budgets. The 

 23 Illinois EPA intends to request that the United States 

 24 Environmental Protection Agency, USEPA, redesignate 

 3 

 Keefe Reporting Company
 1 the Metro-East non-attainment area, which includes 

 2 Jersey, Madison, Monroe and St. Clair Counties, to 

 3 attainment of the 1997 8-hour ozone NAAQS based on 

 4 ambient monitoring data from 2007 through 2009. The 

 5 draft Maintenance Plan contains the State's plan for 

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

 7 years after the U.S. Environmental Protection Agency 

 8 redesignates the area to attainment. The State 

 9 Implementation Plan, SIP, revisions will also 

 10 establish new motor vehicle emissions budgets for the 

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

 12 final, the Illinois EPA will submit both the 

 13 Maintenance Plan and the motor vehicle emissions 

 14 budgets to the USEPA as SIP revisions to meet the 

 15 requirements of the federal Clean Air Act, CAA. The 

 16 hearing will satisfy the requirements of 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 the provisions of 

 20 35 Illinois Administrative Code Part 164, Procedures 

 21 For Informational and Quasi-Legislative Public 

 22 Hearings. Copies of these procedures can be accessed 

 23 on the website for the Illinois Pollution Control 

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

 4 

 Keefe Reporting Company
 1 ready access to the web, they can be obtained 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 presentations. 

 11 Following this overview, I will allow the public to 

 12 ask questions or provide comments and ask questions. 

 13 You are not required to verbalize your comments as 

 14 written comments are given the same consideration and 

 15 may be submitted to the agency at any time within the 

 16 public comment period, which ends at midnight on 

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

 18 comments may do so as long as the statements are 

 19 relevant to the issues that are addressed at this 

 20 hearing and such person has indicated on 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 me in writing 

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

 5 

 Keefe Reporting Company
 1 ensure that they are included in the hearing record as 

 2 exhibits. 

 3 Please keep your comments and questions relative 

 4 to the issues at hand. If your comments fall outside 

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

 6 another issue. Remember, all written comments, 

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

 8 of the official hearing record and will be considered. 

 9 Cards are on the registration table, and you can fill 

 10 them out and indicate if you would like to comment 

 11 today. Anyone who fills out one of these cards will 

 12 also be notified by the Illinois EPA when the final 

 13 decision in this matter. The notification will also 

 14 contain information as to how you may access the 

 15 agency responsiveness summary. In this summary, 

 16 Illinois EPA staff will attempt to answer all relevant 

 17 and significant questions raised at the hearing or 

 18 submitted prior to the close of the comment period. 

 19 Again, the written record in this matter will 

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

 21 written comments are accepted as long as 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 hearing as exhibits. 

 6 

 Keefe Reporting Company
 1 Please send all written documents or data 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, Illinois 

 4 Environmental Protection Agency, 1021 North Grand 

 5 Avenue East, P. O. Box 19276, Springfield, Illinois 

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

 7 notice for the hearing today. 

 8 And for anyone wishing to make comment or ask 

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

 10 Court Reporter here today taking a verbatim record of 

 11 these proceedings for the purpose of making our 

 12 administrative record. For her benefit, please keep 

 13 the general background noise in this room to a minimum 

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

 15 you begin to speak, please state your name and, if 

 16 applicable, any governmental body organization or 

 17 association that you represent. If you are 

 18 representing yourself, you can state that you are an 

 19 interested citizen or a member of the public. Also, 

 20 for the benefit of the Court Reporter, please spell 

 21 your last name. People who have requested to speak 

 22 will be called upon in the order they have registered 

 23 to make a statement. 

 24 Before we start with the Illinois EPA's 

 7 

 Keefe Reporting Company
 1 presentation, I'd like to record a few exhibits in the 

 2 official record. For the record, Exhibit No. 1 is a 

 3 copy of the public notice -- is the notice 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 today. 

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

 8 (No response.) 

 9 MR. STUDER: "No". Okay. With that, I'm going to 

 10 ask that the agency staff introduce themselves 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 Kaleel. I'm the 

 14 Manager of the Air Quality Planning Section within the 

 15 Bureau of Air. My section is responsible for most of 

 16 the -- 

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

 18 MR. KALEEL: The planning section is responsible 

 19 for most of the state implementation plans that were 

 20 prepared by the agency and submitted to USEPA, 

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

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

 23 known as Buzz. And I work for Rob Kaleel as the 

 24 Manager of inventory and data support unit of Air 

 8 

 Keefe Reporting Company
 1 Quality Planning Section, and my main task is to 

 2 compile emission inventories, primarily point and area 

 3 sources, use mobile sources others provide to me and 

 4 compile that information from the reports 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 estimates and 

 9 was involved in the preparation of the proposed motor 

 10 vehicle emissions budgets that are being adopted or 

 11 proposed to be adopted for transportation conformity 

 12 purposes. 

 13 MS. VETTERHOFFER: My name is Dana Vetterhoffer, 

 14 and I'm here as Assistant Counsel for the Illinois 

 15 EPA. 

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

 17 proceed with the presentation from Illinois EPA staff, 

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

 19 directions on asking questions and making comments 

 20 this morning. 

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

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

 23 through a power-point presentation that hopefully 

 24 summarizes the Maintenance Plan document that is 

 9 

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 1 available on the website. Most of -- Well, 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 through. I'd ask 

 5 that we hold questions until we've worked our way 

 6 through the whole presentation. There are copies of 

 7 the presentation. If you didn't grab one, 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 are in the wrong 

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

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

 14 little bit. So -- The information is correct. 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 start it out with 

 21 discussion about just what the Maintenance Plan is 

 22 intended to do and what the requirements are. 

 23 The requirements are specified by USEPA, what 

 24 constitutes an approval maintenance plan. And I guess 

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 1 before I get too far, the reason why we're doing this 

 2 is that the Agency intends to make a request 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 points 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 revised the standard 

 11 to .075 parts per million. And as probably most of 

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

 13 ozone standard even further. This Maintenance Plan 

 14 does not address the 2008 version of the standard, 

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

 16 address the proposed ozone standards that EPA is 

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

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

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

 20 issues. What we're really trying to accomplish here 

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

 22 the bureaucratic requirements of the state relative to 

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

 24 non-attainment for this standard -- whatever version 

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 1 of the standard the EPA finalizes this year. So, it 

 2 will be a transition from non-attainment for the 1997 

 3 standard more than likely into non-attainment 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 recognize 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 considered 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 to 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 least 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 date. The idea 

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

 21 gotten here and redesignate to attainment, we can't 

 22 let it all unravel. We have to maintain the measures 

 23 -- the control measures and the programs that have 

 24 gotten us here." 

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 1 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 the plan, 

 4 contingency measures if you will, that will be 

 5 triggered upon those violations. So, it's a 

 6 commitment on the part of the State of Illinois to 

 7 take corrective actions if for some unplanned, unknown 

 8 reason air quality violations occur again in the 

 9 future. 

 10 These are some of the requirements in the 

 11 Maintenance Plan. One is having a comprehensive 

 12 emissions inventory that represents the level of 

 13 emissions in the quote -- it's in quotations in the 

 14 presentation -- attainment year. Attainment 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, actually the entire 

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

 19 reached attainment looking at three years of our 

 20 quality data, 2007, 2008, 2009. For the purpose of 

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

 22 three years, 2008, to represent our attainment year. 

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

 24 project emissions out at least ten years to be able to 

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 1 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 and as a result 

 5 of control measures that are already adopted or 

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

 7 emissions are consistent with maintaining the level of 

 8 the air quality standard. 

 9 Another commitment that the State is making today 

 10 is that we will continue to operate our monitoring 

 11 network. We have a number of ozone monitors 

 12 throughout the Metro-East area. The State of 

 13 Missouri, obviously, has monitors throughout 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 that we have the 

 18 legal authority to implement and enforce the control 

 19 measures that have been used to demonstrate attainment 

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

 21 future updates of our emissions inventory 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 emission report to 

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 1 the Agency. 

 2 There's another element that Mike Rogers will talk 

 3 about, that relates to transportation conformity, a 

 4 program within the Clean Air Act, to ensure that any 

 5 transportation planning considers the control measures 

 6 that are included in our attainment plan, and that 

 7 process is called "conformity". 

 8 We're committing today to submit a revised plan 

 9 eight years after USEPA has redesignated the area to 

 10 attainment. We not only have to maintain 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 years, 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 air quality 

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

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

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

 22 Maintenance Plan a list of potential measures that 

 23 would be implemented if such violations occur. 

 24 This graphic depicts measured air quality in the 

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 1 region. The region we're talking about, of course, 

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

 3 and Monroe Counties. Those are highlighted here. I 

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

 5 of a brownish, goldish, yellowish. Anyway, you can 

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

 7 Louis non-attainment area. The corresponding counties 

 8 on the Missouri side of the river are also shown. 

 9 And what's depicted on the two graphics, 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 whether or not 

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

 14 air quality standard. The little red triangles 

 15 represent the locations of all the monitors in the 

 16 areas, and the numbers next to those triangles 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 through 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, even some in the 

 23 90's. The units we're talking about now, instead of 

 24 parts per million, we're more used to talking about 

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 1 them in the context of parts per billion. So, instead 

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

 3 numbers, but -- Values above 85 parts per billion are 

 4 considered violations of the standard, and back in 

 5 2001 through 2003, we had a number of those. 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, 2007 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 believe the 

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

 13 the Illinois side is 77 parts per billion, which is 

 14 well below the 85 ppb level of the standard. So, 

 15 clearly the area -- air quality is improved 

 16 dramatically over this period of time and 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 based 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 quality. There's a 

 24 series of these that provided substantial emission 

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 1 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 read through 

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

 5 source control measures and motor vehicle control 

 6 measures and even some that would relate to what we 

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

 8 These have greatly reduced emissions over this time 

 9 period. And I think Buzz Asselmeier has a chart in a 

 10 little while that will quantify the effects 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 will help us 

 15 maintain the attainment status for this air quality 

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

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

 18 appear in both places because some of these measures 

 19 are not fully mature. We expect them to 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 

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 1 in attainment during the next ten-year period. 

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

 3 who will discuss and summarize our emission 

 4 inventories. 

 5 MR. ASSELMEIER: As Rob said, my name 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 spell 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 inventory is, again, 

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

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

 16 full, complete inventory for the 2008 year, and that 

 17 includes the different point area, on-road and 

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

 19 you've got industry, big companies, things like that, 

 20 where we get our data from them typically 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 

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 1 solvents, your house painting, your traffic 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 auto body 

 5 ventures fall into this category, also. USEPA has 

 6 emission factors you can use to calculate emissions 

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

 8 be so many emissions per person in the county or 

 9 emissions per employee at the company for that type of 

 10 industry. 

 11 On-road, again, cars, trucks, motorcycles. USEPA 

 12 has a computer model that feeds a bunch of information 

 13 into there and calculates emissions. 

 14 Off-road motor vehicle sources, again, 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 locomotives, 

 18 commercial marine vessels on the river -- Kaskaskia 

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

 20 in -- and also aircraft. For the common off-road 

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

 22 USEPA modeled that. It combines the information, 

 23 calculates emission. For the things that I have 

 24 marked there for locomotives, commercial marine and 

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 1 aircraft, those are not done by the non-road model, 

 2 but there are, again, standard methodologies, emission 

 3 factors typically, to calculate those emissions. 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 units 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 did the same 

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

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

 17 happened between 2002 and 2008 with some of the 

 18 control measures like Rob pointed out earlier. 

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

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

 21 for the transportation conformity, and they go through 

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

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

 24 happen in future years with that, but there are what 

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 1 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 point sources, you 

 4 take what happened in 2008, and based upon 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, which means decline 

 9 in emissions. So, it depends what industry 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 doing this. Not 

 14 as many have been truly constructed, but 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 shutting down and this 

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

 21 refinery is the consent decrees. So, there was also 

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

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

 24 the plan, also, in the future inventory. 

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 1 The automobile sources and off road for the 

 2 MOBILE6 and non road are very nice. They have 

 3 predictions of what sleep turnover is. We have our 

 4 inputs of fuel volatility, what the fuels will be in 

 5 future years, things like that. That gets 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 landings 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-America/Scott Air 

 12 Force Base, we know certainly there's not a lot of 

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

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

 15 accounted for that maybe a little bit more than we 

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

 17 the future. 

 18 So, when all these get thrown in there and the 

 19 growth gets applied, we have this result 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 solvents or the 

 23 architectural maintenance coating ones where there are 

 24 rules that have been passed, we do reduce those 

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 1 emissions in the inventory. So, we also take credits 

 2 for reduction and the new rules we have passed. 

 3 So, again, we have more the hard core numbers 

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

 5 this case to show a little bit more actually where the 

 6 emission reductions are coming from or how the growth 

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

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

 9 only place NOx comes from is fuel combustion. Again, 

 10 point sources, relatively the same life and percentage 

 11 overall, again, where the on-road reduction 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 area sources. 

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

 18 emissions may be increasing a little bit 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, the on-road 

 22 sources, again, have the biggest reduction in VOM 

 23 emissions for the area, and that's, again, why the 

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

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 1 probably grow a little bit, but not certainly, you 

 2 know, outflank everything. 

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

 4 little bit more of chart type information, and that 

 5 will actually show how emissions do decrease from 2008 

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

 7 emissions. So, again, a little bit representative. 

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

 9 purple area shows a large reduction between 2008 and 

 10 2020. 

 11 And, again, the same for VOM emissions. So, you 

 12 can see how that -- The 2013 on there for 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 going 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 like we've done 

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

 20 So, again, I'll be going through that again 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 

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 1 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 want to talk for 

 5 a minute about the contingency measure as part of our 

 6 Maintenance Plan. Again, the idea of contingency 

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

 8 remarks -- it's intended to provide some sort of 

 9 corrective action in the event of violations of the 

 10 air quality standard should occur again in the future. 

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

 12 a Level 1 and a Level 2 contingency measure, 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 required by USEPA. 

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

 17 response prior to actually getting violations of the 

 18 air quality standard with the whole set so we can 

 19 avoid any future violations by taking earlier actions. 

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

 21 Level 2 response is what we do in the event that 

 22 there's an actual violation of an air quality 

 23 standard. The way the standard is written right now, 

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

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 1 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 before about the 

 4 level of the standard being .08 parts per million or 

 5 85 parts per billion. So, it would really take 

 6 multiple exceedances of the 85 ppb level before you 

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

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

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

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

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

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

 13 try to figure out what happened. Is there something 

 14 wrong with our plan? Is it just adverse meteorology 

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

 16 can do to forestall two more years of high level of 

 17 ozone, which would ultimately result in a new 

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

 19 requirement. It's a voluntary action on our part. 

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

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

 22 Our initial response to either a Level 1 or a 

 23 Level 2 trigger is to look at the circumstances that 

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

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 1 unusual year of meteorology, looking at weather 

 2 patterns? Is it an extremely ozone conducive summer 

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

 4 upwind areas, better known as long range transport? 

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

 6 going against what we're expecting today? We're 

 7 starting to see emissions going up rapidly 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 going to take us 

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

 13 Level 1 trigger to actually forestall the second and 

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

 15 we can implement measures and weigh more heavily in 

 16 our response, those measures that can be done quickly. 

 17 We'll continue to evaluate new controls 

 18 technologies that may yield better emission reductions 

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

 20 suitability of either limiting the geographic 

 21 applicability or perhaps even expanding the 

 22 geographical applicability of a contingency measure, 

 23 again, depending on what is causing the problem. 

 24 These are some potential contingency measures, and 

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 1 some of these measures have already been 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 slides that Buzz 

 5 showed that show continued emission reductions between 

 6 2008 and 2020, these are some of the measures that 

 7 Buzz has accounted for that have resulted in that 

 8 downward trend, but there are some others here that -- 

 9 in particular Phase 2 of USEPA's CAIR rule, 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 months, and, 

 13 obviously, the Illinois EPA will adopt appropriate 

 14 measures to address that once USEPA has promulgated. 

 15 I mentioned earlier some other commitments that 

 16 the State is formally making and consistent with this 

 17 Maintenance Plan. One is to redo the Maintenance Plan 

 18 eight years after USEPA has redesignated the area. 

 19 This would provide a new maintenance plan for a 

 20 subsequent ten-year period. Buzz mentioned 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 emission trends and 

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

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 1 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-blown 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 continue 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, and 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 monitoring network are 

 15 always available in advance of the change to the 

 16 public and must be approved by USEPA, but we will 

 17 continue to operate an adequate monitoring network. 

 18 We have the authority and will continue to enforce 

 19 the applicable requirements in our state 

 20 implementation plan, and we commit to implement the 

 21 contingency measures appropriate with the Level 1 and 

 22 Level 2 triggers that I talked about earlier. 

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

 24 transportation conformity. 

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 1 MR. ROGERS: Good morning. My name is Mike 

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

 3 Environmental Protection Agency's Division of Mobile 

 4 Source Programs. I prepared the transportation 

 5 conformity discussion of the Maintenance Plan dealing 

 6 with the establishment of the proposed motor vehicle 

 7 emissions budgets. 

 8 Transportation conformity is required under 

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

 10 to ensure that federally supported highway and transit 

 11 project activities are consistent with or confirm to 

 12 the purpose of the state air quality implementation 

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

 14 means that transportation activities will not cause or 

 15 contribute to new air quality violations, worsen 

 16 existing violations or delay timely attainment of the 

 17 relevant national ambient air quality standard. This 

 18 is done by requiring that motor vehicle emissions of 

 19 applicable pollutants, in this case volatile organic 

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

 21 than or equal to the budget levels established in the 

 22 SIP. This Maintenance Plan SIP is establishing VOM 

 23 and NOx motor vehicle emissions budgets for the years 

 24 2008 and 2020. The year 2008 is the attainment year, 

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 1 and 2020 is the final year of the Maintenance Plan. 

 2 As described in detail in the Maintenance Plan 

 3 document, the motor vehicle emissions budgets were 

 4 developed using assumptions that are consistent with 

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

 6 8-Hour Ozone Attainment Demonstration and the 

 7 Reasonable Further Progress plans. The major 

 8 assumptions included the projected growth rate of 

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

 10 vehicle inspection program and the characteristics of 

 11 the motor vehicle fleet. 

 12 The proposed 2008 motor vehicle emissions budget 

 13 was developed using average summer weekday vehicle 

 14 miles traveled, or VMT, estimates for Jersey, 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. Louis summer 

 18 weekday total was 18.26 million miles. The 2020 

 19 emissions budget was developed by growing the 2008 VMT 

 20 level by 1.5 percent per year for a projected level of 

 21 21.83 million miles. 

 22 Other key elements involved in the development of 

 23 the proposed motor vehicle emissions budgets are the 

 24 type of fuel to be used in the region and the 

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 1 parameters of the vehicle emissions testing program. 

 2 The Maintenance Plan assumes the continued use of 

 3 southern grade reformulated gasoline or RFG, which has 

 4 been required in the area since July, 2007. 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 registered within the 

 9 test area to pass an on-board diagnostics test every 

 10 two years as a condition of renewing their license 

 11 plates. 

 12 The main control programs responsible for reducing 

 13 motor vehicle emissions both in the Metro-East St. 

 14 Louis area and nationwide are the USEPA's national 

 15 Tier 2 light-duty engine emissions standards 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 engine emissions and 

 19 diesel sulfur limits. The Tier 2 standards, which 

 20 apply to model year 2004 and later gasoline and 

 21 diesel-powered light-duty gasoline vehicles, including 

 22 cars, sport utility vehicles, minivans and pickup 

 23 trucks, established more stringent emissions standards 

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

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 1 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 pre-regulation 

 4 level of 300 parts per million. This cleaner fuel 

 5 allows engine manufacturers to use advanced emissions 

 6 control equipment, which would not function properly 

 7 in the presence of the higher sulfur concentrations. 

 8 The 2007 Heavy-Duty Highway Rule established more 

 9 stringent NOx and PM emission standards for heavy-duty 

 10 trucks and buses. The standards were based on the use 

 11 of high efficiency catalytic exhaust emission control 

 12 devices and a 97 percent reduction in the sulfur 

 13 content of diesel fuel. The USEPA heavy-duty engine 

 14 standards, which took effect in 2007, were expected to 

 15 result in PM and NOx emissions levels that 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 limited 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 combination of Tier 2 

 23 standards, the Heavy-Duty Highway Rule and the 

 24 associated fuel sulfur limits result in significant 

 34 

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 1 further reduction in motor vehicle emissions between 

 2 2008 and 2020. 

 3 The Metro-East Maintenance Plan proposed motor 

 4 vehicle emissions budgets were developed using USEPA's 

 5 MOBILE6.2 emissions factor model. In December, 2009, 

 6 the USEPA released its new motor vehicle 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 model. The 

 11 Illinois EPA intends to recalculate the motor vehicle 

 12 emissions budgets proposed in the Maintenance Plan 

 13 using MOVES2010 within the next 18 months. 

 14 Incorporating the above assumptions results in the 

 15 following 2008 and 2020 motor vehicle emissions 

 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 are: 16.53 tons 

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

 21 proposed 2020 motor vehicle emissions budgets are: 

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

 23 NOx. 

 24 MR. KALEEL: That concludes our power-point 

 35 

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 1 presentation, and we're available to answer any 

 2 questions that you may of. 

 3 MR. STUDER: Thank you. Before I go ahead and 

 4 open the floor for questions, I just want 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 questions of 5 to 

 8 10 minutes. I'm going to allow up to 15. 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 that 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 you can stay 

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

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

 17 said to get an accurate administrative record. When 

 18 you speak, please state your name and spell 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 just indicate 

 22 that you're an interested citizen or indicate that 

 23 you're just a member of the public. 

 24 With that, are there any questions?

 36 

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 1 (Raise of hands.) 

 2 MR. STUDER: Okay. The first person 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 clearly. I'm 

 8 sorry. Jack Norman you were first. 

 9 MR. JACK NORMAN: Thank you, Mr. Studer. 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 our passports. 

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

 14 know. 

 15 My first question is, in giving assurances to EPA 

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

 17 assurances are they after? We have general 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 government has 

 22 provided us with certain guidance documents -- I don't 

 23 know if they're actually included within the 

 24 Maintenance Plan, but they're referenced there -- that 

 37 

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 1 specify what it is we need to address in the context 

 2 of a maintenance plan. You know, obviously, we work 

 3 for the legislature. If the legislature were to undo 

 4 some of the things that are contained in our state 

 5 implementation plan, USEPA would expect the State of 

 6 Illinois to take corrective action. Say if the 

 7 legislature hypothetically were to undo one control 

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

 9 commitment is to keep the emission levels -- keep them 

 10 from trending upward during this ten-year period and 

 11 to take corrective action if we have new 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, yes. 

 17 MR. JACK NORMAN: A lot depends apparently on the 

 18 monitoring station readings, and in turn 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 of the regional 

 24 ozone monitors does not change, could reported 

 38 

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 1 compliance with the national air quality 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 plans to build a 

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

 6 maybe I can get it back here -- that showed 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 didn't get into 

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

 13 emitted say by a new highway that's running through 

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

 15 chemical reactions that occur in the atmosphere in the 

 16 presence of sunlight. The chemicals that 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 react, to form 

 20 ozone. It could take, you know, depending 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 summertime, but at least 

 24 some movement of those precursor emissions while 

 39 

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 1 they're reacting over that one or two hours that it 

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

 3 ozone levels right down in the urbanized area. You 

 4 usually see them downwind of the area. 

 5 More of a focal point in our monitor locations, at 

 6 monitor locations north of the downtown area, and 

 7 that's kind of in recognition of the fact that on 

 8 these high summer days, typically you have a southerly 

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

 10 circumstance where we are going to have violations of 

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

 12 monitoring network. Usually high ozone isn't really 

 13 real localized. It's going to be almost an air mass 

 14 the size of the urban area that would have the high 

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

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

 17 at the air quality standards, we also run models, and 

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

 19 advantage to models is you can do things at a much 

 20 higher resolution and a much lower cost than you can 

 21 through monitoring. So, I think perhaps by 

 22 maintaining a reasonably good monitoring network and 

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

 24 something that we're missing with the monitoring, 

 40 

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 1 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 hearing is 

 4 because of the time lapse and the chemistry 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 because it's not 

 9 dramatic. 

 10 MR. KALEEL: You gave a more concise 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 anticipated economic 

 16 growth in the region, you gave us a percentage 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 throughout the 

 21 region? 

 22 MR. KALEEL: I'd let Buzz address that. 

 23 MR. ASSELMEIER: The growth factors themselves, 

 24 what you read in the model, are specific for the St. 

 41 

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 1 Louis area. So, if I -- Not a true example here, but 

 2 if I have a steel plant in Madison County and a steel 

 3 plant in Monroe County, the growth factor will be 

 4 outputted the same because, again, it's looked at more 

 5 as an economic region. Now, again, a growth 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 would be the key? 

 11 MR. ASSELMEIER: Right. So, yes. Again, how Rob 

 12 was talking, my inventory will have, "Okay. Here's 

 13 where the plants are located. Here's how 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 little bit, they're 

 19 not all just economic factors that are considered in 

 20 the growth. A lot of them are population based and, 

 21 in the case of motor vehicles, the growth and vehicle 

 22 miles traveled. So, they consider even in the future 

 23 through the transportation model that East West 

 24 Gateway runs, even consider future lane changes. 

 42 

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 1 Those would all be considered in the changes 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. Again, Alec Davis, 

 6 D-A-V-I-S. I represent the Illinois Environmental 

 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 indicate the 

 10 timing regarding when they intend to make that 

 11 request, and then based on that, if they can provide a 

 12 guess of when that would actually finalize. 

 13 MR. KALEEL: We would submit the re-designation 

 14 request in conjunction with the final Maintenance 

 15 Plan. As the hearing officer announced, we have a 

 16 32-day comment period. While we consider comments 

 17 that are submitted by the public, we would then issue 

 18 a final Maintenance Plan -- probably will be at least 

 19 a couple of weeks after the end of the comment period. 

 20 And then once the Maintenance Plan is final, 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 Maintenance Plan, which, 

 24 obviously, is one of the key requirements to a 

 43 

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 1 re-designation request. There are other things that 

 2 are required of us before EPA will redesignate, and 

 3 one of those requirements is making sure you have a 

 4 complete SIP, state implementation plan, and one of 

 5 those elements is reasonably available control 

 6 technology for volatile organic compounds, and there's 

 7 three regulatory proposals now before the Pollution 

 8 Control Board that have to be finalized and submitted 

 9 to EPA before we will have completed that requirement. 

 10 I don't expect the Board to finish action on those 

 11 three rulemakings, at least not all of them, within 

 12 the same 45-day period that I kind of outlined for the 

 13 Maintenance plan. So, I would expect we'll make the 

 14 request to USEPA in 45 days. I don't expect USEPA to 

 15 complete action on the re-designation until those 

 16 rules are completed through the Pollution 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 interaction between 

 20 Illinois and Missouri. The non-attainment area, 

 21 obviously, is comprised of counties in both states, 

 22 and I am aware of the fact that Illinois and Missouri 

 23 work cooperatively on various measures to improve the 

 24 air quality, and you've also shown and mentioned that 

 44 

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 1 on the Missouri side of the river has measured 

 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 work 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 maintenance plan for the 

 11 Missouri side of the non-attainment area, 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 in the same boat 

 15 that we are with respect to the VOC rules that I 

 16 outlined. We might even be a little ahead of them as 

 17 far as having a proposal being considered by the 

 18 Pollution Control Board. They have a similar board on 

 19 the Missouri side that is responsible for promulgating 

 20 rules, and I don't believe Missouri has made those 

 21 proposals yet. So, they likely are behind Illinois. 

 22 My understanding, though, is that USEPA can still move 

 23 forward with the Illinois re-designation request once 

 24 our SIP is complete, even if the Missouri SIP is not. 

 45 

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 1 So, there wouldn't necessarily be a linkage 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 result of the 

 6 monitored increase in ozone, to what extent does 

 7 consideration of the source of any emissions that 

 8 might be causing that increased measured value, for 

 9 example, if you were to find an increase 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 coming from across 

 13 the state line, to what extent would that 

 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 understand 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 continue to work 

 21 with Missouri D and R as we perform the evaluation 

 22 that's specified in the Maintenance Plan to try to 

 23 figure out what would be the most effective corrective 

 24 action. So, we would work with Missouri to try to 

 46 

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 1 identify what caused it and develop a plan 

 2 appropriately. Whatever we come up with, it is our 

 3 intent to do that in a very public way and to seek 

 4 public comment on the corrective measure 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 questions? 

 11 (No response.) 

 12 MR. STUDER: All right. Let the record indicate 

 13 that no one raised their hand. I do want to point out 

 14 that the record in this matter is open until the 10th 

 15 of May, and you can submit written comments any time 

 16 prior to that date. I also want to remind you that if 

 17 you have not registered and you do want to be notified 

 18 of the final action in this matter, please 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 hearing is 

 23 adjourned. 

 24 * * * * * 

 47 

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 1 

 2 I, HOLLY A. McCULLOUGH, an Illinois CSR, a 

 3 Missouri CCR and a RPR, do HEREBY CERTIFY that the 

 4 foregoing record was made before me on April 8, 2010, 

 5 at 1102 Eastport Plaza Drive, Collinsville, Illinois. 

 6 IN WITNESS WHEREOF, I have hereunto set my 

 7 hand the 8th day of April, 2010. 

 8 

 9 

 10 _____________________________ 

 HOLLY A. McCULLOUGH 

 11 Notary Public 

 CSR #084-004265 

 12 RPR #821968 

 CCR #1011 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 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 ofAir 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 ofMamtenance 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

30
LIST 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 24
Figure 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

12
EXECUTIVE SUMMARY

This document describes Illinois' Maintenance Plan for the Illinois portion ofthe 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 ofNatural Resources (MDNR) and the U.S. EPA. The

MDNR is preparing a similar plan for the Missouri portion ofthe 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 ofthe 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 ofthe 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 ifthere is a subsequent violation ofthe 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 ofthe 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 ofthe 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 ofNatural Resources (MDNR) and U.S. EPA. The MDNR is

preparing a similar plan for the Missouri portion ofthe 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 ofthe 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 ofthe CAA. The

state must demonstrate that the improvement in air quality is due to permanent and

enforceable reductions in emissions resulting from implementation ofthe SIP and other

federal requirements. Finally, the state must submit, and U.S. EPA must approve, a

Maintenance Plan under Section 175(A) ofthe CAA, including provisions for

contingency measures that will be implemented iffuture violations ofthe NAAQS are

measured.

This Maintenance Plan provides for the continued attainment ofthe 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 ofthe 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 ofthe ozone

NAAQS have been monitored in Madison and St. Clair counties in lllinois and in the

Missouri portion: ofthe 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

6
revisions to the ozone NAAQS. Several counties in Missouri were also designated as

nonattainment ofthe 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

7
The following is a.1ist ofthe 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 ofIllinois 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 ofreducing 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 ofAir 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.

8
2.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS

Sections 107 and 110 ofthe CAA list a number ofrequirements that must be met by

nonattaimnent areas prior to consideration for redesignation to attainment. One ofthose

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 ofMaintenance 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 ofthe 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 ofthe 8-hour ozone NAAQS

for a 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 a

subsequent violation ofthe 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 ofthe precursors of ozone completed for

the "attaimnent year";

9
• A projection ofthe 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 ofthe ozone NAAQS;

• A commitment that, once redesignated, the state will continue to operate an

appropriate monitoring network to verify maintenance ofthe attainment status;

• A demonstration oflegal authority to implement and enforce all control measures

contained in the SIP;

• Provisions for future updates ofthe 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 ofthe 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 ofthe 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 ofthe attainment status, once

the area has been redesignated.

The following subsections describe how each ofthese 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 ofthe metropolitan area.

Figure 3.1 shows the locations ofthese 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

11
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 4th 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 ofthe 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 ofthis

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 ofthe 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 ofthe 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 ofthe 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 ofthe

inventory to enable tracking of emissions levels during the 1O-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 ofTransportation (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 ofthese emissions reductions were due to the application of

tighter federal emissions standards on motor vehicles and fuels, and some due to the

requirements ofthe federal NOx SIP Call. Section 5.0 ofthis report describes these

reductions in more detail, along with an explanation oftheir 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 Nonattainment 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 ofthe

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 ofthe 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 ofIllinois' 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 ofthe Tier 2 motor

vehicle emissions standards, and operation of an enhanced vehicle inspection and

maintenance program. Total vehicle miles oftravel (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 ofMaintenance

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 ofstatewide NOx emissions resulting from

implementation oflllinois' multi-pollutant standards affecting electric utilities by 2012,

will also help to ensure continued attainment ofthe 8-hour ozone NAAQS.

4.5 Provisions for Future Updates

As required by Section 175A(b) ofthe CAA, Illinois commits to submit to U.S. EPA,

eight years after redesignation, a revised version ofthis 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 ofIllinois'

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 emissionssources. After redesignation to

attainment, Prevention of Significant Deterioration (PSD) requirements will apply to the

construction ofnew major sources and to significant modifications of existing sources.

Illinois has accepted delegation from U.S. EPA ofthis 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 ofthe 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 ofthe 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, 182(b) and (f) ofthe CAA, RACT is required for all existing

major sources ofthe 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 ofmeeting 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 ofseveral 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

19
NAA 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

ifthe RACT requirement is still being met for 8-hour ozone.

Sections 172, 182(b)(2), and 182(t) ofthe 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 ofthe control measures listed in this Section to ensure

maintenance ofthe 8-hour ozone NAAQS. Any revisions to the control measures

included as part ofthe Maintenance Plan will be submitted as a SIP revision to U.S. EPA

20
for approval, and will be accompanied by a showing that such changes will not interfere

with maintenance ofthe NAAQS.

Illinois EPA has the necessary resources to enforce any violations ofits 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 ofthis 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 ofthe 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 ofthe 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 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 ofpollutants in order

to satisfy CAA requirements ofreasonable 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 ofmotor 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

21
required use ofrefonnulated 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 ofthe motor vehicle emissions budgets, including

discussion ofthe MOBILE6.2 model inputs and assumptions are included in Appendix B

ofthis report.

22
6.0 CONTINGENCY MEASURES

6.1 Contingency Measures

Section 175(A) ofthe CAA specifies the requirements for Maintenance Plans, including

provisions for contingency measures that will be implemented ifviolations ofthe 8-hour

ozone NAAQS are measured after redesignation to attainment. A list ofpotential

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 ofthe 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 ofthe 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 ofthis 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 ofthe 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 ifthe 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 ofthe NAAQS from

ever occurrmg.

lllinois commits to compiling YOM and NOx emissions inventories for the Metro-East

area every three years for the duration ofthe Maintenance Plan to facilitate the

23
Table 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. Ifso, IL will • Phase II ofthe Cleao Air

average ozone detennine what aod where controls Interstate RuIe, after

concentration may be required, as well as level of repromuIgation by USEPA

exceeding 84 ppb io emissions reductions needed, to avoid a • Best Available Retrofit

aoy year at aoy violation ofthe 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 ofthe 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 ofthe detennine appropriate measures to Maiotenance (AIM) Coatiogs NAAQSataoy address the cause ofthe 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 ofthe 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

24
corrective measures, the Illinois EPA will work with the Missouri DNR to conduct a

comprehensive study to determine the causes ofthe violation and the control measures

necessary to mitigate the problem. The analysis will examine the following factors:

• the number, location, and severity ofthe ambient ozone exceedances;

• the weather patterns contributing to the elevated ozone levels;

• potential contributing emissions sources;

• the geographic applicability ofpossible contingency measures;

• emissions trends, including timeliness ofimplementation ofscheduled 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 ofthese measures would be necessary. The

selection between measures will be based upon cost-effectiveness, emissions reduction

potential, ease and timing ofimplementation, 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 ofthe

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 ofnotices, 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) ofthe 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 11O(a)(2) ofthe CAA, the Illinois EPA is required to hold a

public hearing prior to adoption ofthis Maintenance Plan and submittal to U.S. EPA.

Public participation in the SIP process is provided for as follows:

• Notice of availability ofthe Metro-East 8-Hour Ozone Maintenance Plan

document and the time and date ofthe public hearing will be published in the

25
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.

• 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 ofthe comments

received and Illinois EPA's responses thereto is included as part ofthe submittal

to U.S. EPA.

6.4 Legal Authority to hnplement and Enforce

The Maintenance Plan must contain a demonstration that the State ofIllinois 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 ofthis 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 ofthe 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 ofthe

Clean Air Act. This Maintenance Plan provides for the continued attainment ofthe 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 ofthe

1997 8-hour ozone NAAQS are observed in the area.

The Illinois EPA has prepared a comprehensive emissions inventory ofthe precursors of

ozone completed for the "attainment" year 2008, and has prepared projections ofthe

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 ofthe 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 ofIIliuois

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

30
TRANSPORTATION CONFORMITY

This section describes the development ofthe 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) ofthe 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 ofpollutants in order to satisfy

Clean Air Act (CAA) requirements ofreasonable 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 ofthe transportation conformity

rule under §93.118(e). The motor vehicle emissions budgets in this submittal are

adequate as each ofthe 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;

31
4. 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; anychanges taestablished safety

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

emissions factors or estimates ofvehicle 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

ofTransportation'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 ofthe East-West Gateway Council ofGovernments 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 ofTransportation (IDOT), and the lllinois

EPA. At this meeting the development ofthe 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

32
Demonstration 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 ofthe

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 ofthe inputs and assumptions incorporated into the development ofthe

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 ofJune, 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 of19.83 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 ofthe information and MOBILE6.2 model assumptions used in the

development ofthe draft motor vehicle emissions budgets.

Temperature: U.S. EPA guidance for the use ofthe MOBILE6.2 model calls for

the use ofrepresentative summer daily temperatures. For the year 2008, actual average

June, July, and August minimum and maximum temperatures of68 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 ofthe 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 ofwater

(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

33
and 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 ofvehicles, (b) require an OBDbased program beginning in February 2007, and (c) remove the requirement for testing

compliant pre-MY-1996 vehicles.

Fuels: The use offederal 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 ofthe St. Louis NAA, classified a "southern" area for

purposes ofmotor 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 ofsouthern 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 ofsulfur 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 ofroads 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 ofMotor Vehicles. This profile is assumed to remain valid for 2020

34
Emissions 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 bycounty or township for each

pollutant, VT, and FC, sums them by VT and FC, and aggregates them into area totals.

Attachment A ofthis section provides additional details on the MOBILE6.2 model inputs

used in the development ofthe 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 ofthe 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 ofthe ILLOBDIM

program in the sunnner of2008 is taken into account by assuming that 75% ofthe 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, chiefofwhich is an OBD (on-board diagnostics) test for vehicles ofmodel

year (MY) 1996 and newer. Illinois EPA begins IM070N.D with identifying connnents,

36
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 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 ofmalfunctions or out-ofspecification operations ofthe engine or fuel and evaporative emissions control

systems are stored in the engine computer as "fault codes." An OBD test

consists ofplugging 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,

37
and 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 oftested 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 ofthe 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.

38
Most ofthe inputs to the second and subsequent program .components are the

same as those for the first program, so the description ofthe 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%,

39
respectively), are slightly different from those in components 1 and 2. HDGVs

are few in number, and most ofthem 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 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 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 ofthe fraction of

40
the vehicle fleet ofthat type that is made up ofvehicles 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

41
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

* 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% ofthose 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% ofthe 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 ofthat 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 ofthe 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

44
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 ofspace.

VMT by Hour ofthe 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

45
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 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 ofthe 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 ofthe 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 ofVMT in that hour that occur within the specified speed bins.

46
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.

47