UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX 75 Hawthorne Street San Francisco, CA 94105

September 21 , 2016

Memorandum

To: Docket for the Approval and Promulgation of Implementation Plans; State of California;

Coachella Valley; Attainment Plan for 1997 8

- Hour Ozone Standard (Docket Number:

EPA

- R09

- OAR

- 2016

- 0244 )

From: Tom Kelly , Air Planning Office, EPA Region 9

RE: Motor Vehicle Emissi ons Budget Adequacy D ocumentation for Coachella Valley 1997 8

-

Hour Ozone Standard State Implementation Plan

This memorandum documents the adequacy of the motor vehicle emission s budgets in the Staff Report, Proposed Updates to the 1997 8

- Hour Ozone Standa rd, State Implementation Plans; Coachella Valley and Western Mojave Desert ( CARB, Release Date: September 22, 2014 ). Additionally, a table of emissions budgets for the Coachella Valley is also included.Evaluation of the Motor Vehicle Emissions Budget Adequacy

Adequacy Review Criteria (40 CFR par t 93) Criterion
Satisfied ? Reference in SIP Document/Comments

Sec. 93.118(e)(4)(i) The plan was endorsed by

the Governor (or designee) and was subject to a public hearing. Yes The California Air Resources Board (CARB) conducted a public hearing on October 24, 2014, as noted in many documents including the transcript of the
Board’s Octob er 24, 2014

, hearing.

CARB notified the public of the hearing and the opportunity to provide public

comment, either in person at the meeting, in writing at the meeting, or in writing prior to the meeting.

The plan was submitted in a letter signed by Ri chard Corey, the Executive Officer of CARB and dated November 6, 2014.

Sec. 93.118(e)(4)(ii) The plan was developed

through consultation with federal, state and local agencies; full implementation plan documentation was provided
and EPA ’ s stated concerns, if any, were addressed. Yes Members of the Transportation Conformity Working Group of the South California Association of Governments (EPA, SCAQMD, CARB, South Coast Association of Governments (SCAG), Federal Highway Administration, Caltrans and many others) discussed the development and release of CARB’s 2014 SIP Update in August and September 2014 meetings/conference calls. CARB also further coordinated with SCAG on
motor vehicle emission s budgets and the (off

- model) adjustments.

CARB provided publ ic notice of their implementation plan on September 22,

2014

, posted the implementation plan at https://www.arb.ca.gov/planning/sip/planarea/antvllysip.htm ( see 2014 Updates to the 1997 8

- Hour Ozone Standard SIPs: Coachella Valley and Western Mojave Desert 8

- Hour Ozone Nonattainment Areas) and provided access to the implementation plan in a link to the meeting agenda (see https://www.arb.ca.gov/board/ma/2014/ma102314.pdf ).Sec.

93.118(e)(4)(ii i ) The motor vehicle emission s

budgets are clearly identified and precisely quantified. Yes The motor vehicle emissi ons budgets for 2017 and 20 18 are clearly identified and precisely quantified in Appendix E (Table D

- 1 ) of the 201 4 SIP Update. These budgets reflect control measures that were already adopted by September 2012, as noted in the emissions inventory of Appen dix A. The budgets were quantified with California’s approved ( 78 FR 14533

, March 16,

2013 ) emissions factor

– 2011 model (or EMFAC2011), with one off

- model adjustment for California’s Advanced Clean Car program, which has been incorporated into the Califo rnia SIP ( 81 FR 39424

, June 18, 2016)

.

Sec. 93.118(e)(4)(iv ) The motor vehicle emissions

budgets, when considered together with all other emission sources, are consistent with applicable requirements for reasonable further progress and
attainment. Yes EPA has preliminarily concluded that the budgets for the year s 2017 and

20 18, when considered together with all other emission sources and controls, are consistent with the requirement to demonstrate RFP for the 1997 8

- hour ozone standard. This finding is based on a thorough review of the revised RFP demonstrations in Appendix C (T able C

- 1) of the 201 4 SIP Update

. This
document supports the proposed approv al of the RFP demonstration.

EPA has preliminarily concluded that the budgets for the year 2018, when considered together with all other emission sources and controls, are
consis tent with the requirement to demonstrate expeditious attainment of the
1997 8

- hour ozone standard. This finding is based on review of the updated attainment demonstration in Appendix B of the 2014 SIP Update. EPA ’s proposed rulemaking for the Coachella Val ley also proposes to approve attainment of the 1997 ozone standard, as discussed in Section IV.C of EPA’s proposed rulemaking.

Sec. 93.118(e)(4)( v) The plan shows a clear

relationship among the emissions budgets, the
control measures and the
total emissions inventory. Yes The emission inventories for all point, area, and mobile sources are contained

in Appendix A of the 2014 SIP Update . The control strategy relied upon for
the SIP

- based budgets is set out in the 2014 SIP Update . It consists of the

e xisting rules submitted by SCAQMD by September 2012

, as noted on page A

- 1 of the SIP Update , and CARB rules listed in Appendix E

. The sole off

mode l adjustment to the Emissions Factor 2011 (or EMFAC2011) model was for CARB’s Advanced Clean Car program, whi ch was incorporated in to the SIP (81 FR 39424 , June 16, 2016).Sec.

93.118(e)(4)(v i ) Revisions to previously

submitted control strategy implementation or maintenance plans explain and document any changes to any previous submitted budgets and control

measures , impacts on point
and area source emissions

, any changes to established safety margins, and reasons for the changes (including the basis for any changes
related to emission factors or
estimates of vehicle miles traveled). Yes The previous submitta l of the control strategy for the 1997 8

- hour ozone standard was the South Coast 2007 Air Quality Management Plan

. a The motor vehicle emissions budgets were submitted separately in the 2008 Early Progress Plan

, b which was approved on May 7, 2008 ( 7 3 FR 256 94 ). The early progress plan was submitted when EPA was changing its requirements for Reasonable Further Progress, therefore, it was intended to show “ some progress toward attainment,” (see the Background on page 1 of the Early Progress Plan ) but did not p rovide emission s budgets beyond 2012 (see the Coachella Transportation Conformity Budget on page 8 of the Early Progress
Plan ).

The motor vehicle emission inventories in the Early Progress Plan are based

on an earlier emissions model, EMFAC200 7, and motor vehicle emission
inventories in the South Coast 2007 AQMP

. The 2014 SIP Update was
modeled with EMFAC2011. The F ederal R egister notice for the approval of EMFAC2011 ( 78 FR 14533, March 16, 2013 ) details the basis for the
emission factor changes from the earlier EMFAC2007 model

. The 2014 SIP Update also includes an updated emissions inventory from the 2007 AQMP. Appendix D lists State of California rules reducing emissions from motor vehicles. Another difference is that the 2014 SIP Update include s a 1 ton per day safety margin, and the 2008 Early Progress Plan did not.

The net result of the changes between the 2012 budgets in the 2008 Early Progress Plan and the 2014, 2017 and 2018 budgets in the 2014 SIP Update is a 4 ton per day reduction of volatile (or reactive) organic compounds (7 tpd in 2012 to 4 tpd in 2018) and 14 tons per day of NOx (26 tpd in 2012 to 12 tpd in 2018).

Sec. 93.118(e)(5) EPA has reviewed the State ’ s

compilation of public comments and response to comments that are required to be submitted with any implementation plan. Yes The public comments begin on page 2 of the transcript for the California Air Resources Board meeting on October 24, 2014. No members of the public commented on the plan. One board member thanked the Board staff and proposed Board Resolution 14

- 29, which was unanimously supported b y all Board members. No further public comments are noted in the transcript.

a “Final 2007 Air Quality Management Plan,” South Coast Air Quality Management District, June 2007.

b “Early Progress Plans Demonstrating Progress Toward Attaining the 8

- hour N ational Air Quality Standard for Ozone and Setting Transportation Conformity Budgets for Ventura County, Antelope Valley

- Western Mojave Desert, Coachella Valley, Eastern Kern County, and ImperialCounty” (revised), CARB (February 27, 2008).

Coachella Valley Motor V ehicle Emissions Budgets in the 2014 SIP Update (tpd, average summer weekday) a

NO x VOC

2014 2017 2018 2014 2017 2018

On

- Road Inventory 14.7 9 11.3 9 10.7 4 3.7 2 3. 07 2.9 3 Safety Margin 1 1 1 1 1 1

MVEBs b 16 13 12 5 5 4

a Source: Table D

- 1, 2014 SIP Update

. b Rounded up to the nearest ton

.