### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX 

### 75 Hawthorne Street San Francisco, CA 94105-3901



### April 23,2010

James Goldstene, Executive Officer California Air Resources Board 1001 I Street, P.O. Box 2815 Sacramento, CA 958 12

RE: Adequacy Status of San Joaquin Valley PM2.5 ReasonableFurther Progress and Attainment Plan Motor Vehicle Emissions Budgets

Dear Mr. Goldstene:

We have found adequate for transportationconformity purposes certain motor vehicle emissions budgets (MVEBs) in the 

### San Joaquin Valley 2008 PM2.5 Plan ("SJV PM2.5 Plan") as adopted by the San Joaquin Valley Air Pollution Control District on April 30,2008 and by the California Air Resources Board (CARB) on May 22,2008. As a result of our adequacy finding, Metropolitan Planning Organizations (MPOs) in the San Joaquin Valley and the U.S. Department of Transportation must use the adequate budgets in future conformity analyses once the finding becomes effective.

CARB submitted the SJV PM2.5 Plan on to EPA on June 30,2008 as a revision to the California State Implementation Plan (SIP).Theplan includes new control measures and demonstrations ofreasonable furtherprogress (RFP) and attainment for the 1997 annual and 24- hour PM-2.5 national ambient air quality standards. The plan identifies subregional MVEBs, applicable for both the annual and 24-hour PM2.5 standard, for each county in the nonattainment

area for PM2.5 and nitrogen oxides (NO,) for the RFP milestone years of 2009 and 2012 and for the attainment year of 2014. We announced receipt of the plan on the Internet on August 19, 2008, and requested public commentby September 18,2008.We received no comments on the budgets and plan during this comment period.

This letter transmits our decision that the motor vehicle emissions budgets for 2009 and 2012 as contained in the SJV PM2.5 Plan are adequate for transportation conformity decisions. These budgets are consistent with the State's RFP demonstrations for milestone years of 2009 and 2012, and these budgets are based on control measures that have already been adopted and implemented. The budgets also meet the other adequacy criteria, therefore, these budgets meet the transportation conformity adequacy criteria found in 40 CFR 93.1 18(e)(4). The adequate budgets which apply to both the annual and 24-hour PM2.5, for each county in the nonattainment
area, are as follows:

Printed on Recycled Paper

### This letter also transmits our findingthat the motor vehicle emissionsbudgets for the attainment year of 2014 are inadequate for transportation conformity purposes. These 2014 budgets include estimated emissionreductions associated with a number of commitments for future rule adoption. Although these rules, for the most part, have been adopted and in aggregate achieve the expected reductions, the State has not yet revised the budgets to reflect the precise reductions expected from the adopted rules. Without these revisions, the 2014 budgets in the SJV PM2.5 Plan are not precisely quantified orrelated to the overall emissions inventory and other

measures and therefore, they do not meet the adequacy criteria found in 40 

### CFR 93.1 18(e)(4)(iii), (iv), and (v).

### We have detailed our adequacy/inadequacyfindings in the enclosures. A copy of this letter and its enclosureswill soon be posted on the Internet at http://www.epa.gov/otaq/stateresources/ 

### transconf7adequacy.htm. We will also announce the adequacy findings in the Federal Register. The findings will become effective 15 

### days after the Federal Register announcement pursuant to 40 

### CFR 93.118(f).



### If you have any questions regarding these adequacy findings or would like copies of the comments received, please contact Kerry Drake at (415) 947-4157 

### or Frances Wicher at (415) 972-3957.



### Sincerely, 

## n 

# m6

Deborah Jordan Director, Air Division

Enclosure

cc: Errol Villegas, SJVUAPCD Tony Boren, Fresno COG Ronald Brummett, Kern COG Terri King, Kings COG Patricia Taylor, Madera CTC Jesse Brown, Merced COG Andrew Chesley, SJCOG Vince Harris, Stanislaus,COG Ted Smalley, Tulare COG Sue Kaiser, FHWA Ted Matley, FTA

### Enclosure 1: 

### Transportation ConformityAdequacy Review

Plan (~~ri12008) Reviewers: Frances Wicher 

# I Date: 1/15/10 Control Strategy State Implementation Plan (SIP)Under Review: San Joaquin Valley (SJV) 2008 PM2.5 Plan: Reasonable Further Progress and Attainment

~ov&nor (or designee) &d was subject to a public hearing. 

### Date of SIP Revision Receipt by EPA: June 2008

Sec. 93.118(e)(4)(ii) The plan was developed through consultation with federal, state and local agencies; full implementation plan documentationwas provided and EPA's stated concerns, if any, were addressed.

quantified. Sec. 93.118(e)(4)(iii) by CARB's Executive Oficer, James Goldstene, the Governor's designee. The transmittal letter indicates that the CARB formally adopted the plan on May 22, 2008 through a Board Resolution (08-28). CARB released the plan on April 25, 2008 and requested public commentsby May 2 1,2008or at the public hearing held on May 22,2009. The plan relies upon reduction cornrnitments.fkom the 2007 State Strategy, which was previously submittedto EPA as a SIP revision on November 16,2007.CARB released the 2007 State Strategy on April 26,2007

The motor vehicle emission budgets

are clearly identified and precisely and May 7,2007 and requested public commentsby the public hearing held on September 27,2007. Consultationwith federal, state and local agencies was undertaken; this consultation took place with the San Joaquin Valley interagency consultation working group (theModel Coordinating Committee). Members of the consultation group include: EPA, FHWA, FTA, CARB, Caltrans,the San JoaquinValley Unified Air Pollution Control District (SJWAPCD), and each county's Metropolitan Planning Organization (GO). EPA received a copy ofthe draft SJV 2008 PM2.5 Plan and draft State Strategy but provided no written comments. The motor vehicle emissions budgets for 2009 and 2012 are clearly identified and precisely quantified on page 7-8 of the plan and in Appendix C. These budgets reflect control measures that were already adopted and implementedat the time the SJVAPCD adopted the plan on April 30,2008. Thebudgets for 2014 are not precisely quantified because they reflect CARB's commitmentsto reduce emissions ofPM2.5 and NOx in the SJV. While CARB (and the California Bureau ofAutomotive Repair (BAR)) has now adopted rules to achieve these reductions, it has not revised the 2014 budgets to reflect the precise emissionsSec. 93.1 18(e)(4)(iv)

-

Sec. 93.118(e)(4)(v) 

# I

Sec. 93.1 18(e)(4)(vi) 

### YIN

YI N

NIA The motor vehicle emissions budget(s), when consideredtogether with all other emission sources, is consistentwith applicable requirements for reasonable further progress and attainment.

The plan shows a clear relationship among the emissionsbudget@), control measures and the total emissionsinventory.

Revisionsto previously submitted control strategyor maintenance plans explain and document any changes to reductions expected fi-omeach of these rules.

EPA has preliminarily concluded that the budgets for the years 2009 and 20 12, when considered together

### with all other emission sources, are consistent with the requirementto demonstrate reasonable further progress for the annual and 24-hour PM2.5 standards. This finding is based on review of the plan's RFP demonstrations in Chapter 8 which show a generally linearreduction in emissions

as required by EPA's PM2.5 implementationrule (See40 CFR 5 1.1009). Other relevant materials includethe District's controlmeasure strategy in chapter 6 of the SJV PM2.5 Plan. The attainment year 2014 motor vehicle emissionsbudgets reflect emission reductions fi-omCAFE3 commitmentsto achieve PM2.5 and NOx reductions in the SJV and not fi-omspecified controlmeasures that have been drafted or adopted in regulatory form. As discussedbefore, CAFE3 (and BAR) have adopted rules that will achieve these reductions but has not yet revised the budgets to reflect the precise emissions reductions expected fi-omeach of the adopted rules. The MVEBs for PM2.5 do not include emissionsfi-omre-entrained road dust (paved and unpaved) or roadltransit construction activitiesbecause neither are significant contributors to PM2.5 emissions in the SJV. See SJV PM2.5 plan, pp. 7-5 & 7-6. The SJV PM2.5 Plan includes budgets only for directlyemittedPM2.5 and NOx. It does not include budgets for the other potential PM2.5 precursors because onroad vehicles are an insignificant contributorto PM2.5 levels in the SJV (sulfur dioxide and volatile organic compounds) or controls on them would be ineffective
at reducing PM2.5 levels in the SJV (ammonia). See SJV PM2.5 plan, pp. 7-4 & 7-5. The emission inventory for all stationary, area, on-road mobile, and nomoad mobile sources, and their relation to controlmeasures and the reductions fi-om existing measures are described in Appendix A of 2007 StateStrategy. The final inventories incorporating the reductions fi-omexisting measures are given in TablesB-1 and B-2 in Appendix B to the SJV 2008 PM2.5 Plan. As stated elsewhere, the 20 14 budgets incorporateemissions reduction commitments fi-om the State's strategy and the State has not revised the budgetsto reflect the reductions fi-ommeasures that have been adopted to fulfill these commitments. There are no previously submitted budgets. The SJV 2008 PM2.5 Plan is the first plan submittedby California to addressPM2.5 standardsin the SJVThe 2008 PM2.5 Plan contains public comments and SJVUAPCDresponsesin appendix J to the plan. Additional verbal comments were received duringthe adoptionpublic hearings held by the SJVUAPCD and CARB and are also included as attachmentsto the November 2007 SIP submittal. We have reviewed the compilation ofcomments and responsesand find the responses to be acceptable. No issues that might have affected our adequacyfinding remain unanswered. Y Sec. 93.1 18(e)(5) any previous submitted budgets and control measures; impacts on point and area source emissions; any changes to established safetymargins (see 593.10 1 for definition), and

reasons for the changes (including the basis for any changes to emission factors or estimates of vehicle miles traveled). EPA has reviewed the State's compilation ofpublic comments and
response to comments that are required to be submitted with any implementationplan.