1 **UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103** 

**DATE:** April 10, 2014
**SUBJECT:** Technical Support Document for the Update of the Motor Vehicle E missions

Budgets for the Allentown

- Bethlehem

- Easton 1997 8

- Hour Ozone National Ambient Air Quality

Standard Maintenance Area
**FROM:** Asrah Kha dr, Environmental Engineer, EIT /s/

Office of Air Program Planning
**TO:** File
**THRU:** Cristina Fernandez, Associate Director /s/

Off ice of Air Program Planning

**A. BACKGROUND** On March 7, 2014 , the Pennsylvania Department of Environmental Protection (PADEP) submitted a revision to the Commonwealth of Pennsylvania’s (Penns yl vania) State Implementation Plan (SIP). The SIP revision consists of updated Motor Vehicle Emissions Budgets (MVEBs) for nitrogen oxides (NO x ) for the 1997 8

- Hour Ozone National Ambient Air Quality Standard (NAAQS). The SIP revision also includes an updated point source inventory for NO x . The updated budgets w ere calculated using the Environmental Protection Agency ’s (EPA) Motor Vehicle Emission Simulator model (MOVES2010a). The intention of the revised SIP is to replace the approved MOBILE6.2

- based MVEBs with budgets based on MOVES2010a and to ensure that the SIP revision still provides for attainment of the 1997 8

- Hour Ozone NAAQS. On July 18, 1997 (62 FR 38856), EPA established the 1997 8

- Hour Ozone NAAQS. On April 30, 2004 (69 FR 23858), Lehigh, Northampton and Carbon Counties were designated as nonattainment for the 1997 8

- Hour Ozone NAAQS as the Allentown

- Bethlehem

- Easton 1997 8

- Hour Ozone NAAQS Nonattainment Area . On June 26 , 2007, PADEP submitted a SIP revision which consists of a maintenance plan, a 2002 base y ear inventory and MVEBs for transportation conformity

purposes. On March 2, 2008 (73 FR 11557 ), EPA approved the SIP revision as well as the redesi gnation request made b y PADEP. The Allentown

- Bethlehem

- Easton 1997 8

- Hour Ozone NAAQS Nonattainment Area was redesignated as the Allentown

- Bethlehem

- Easton 1997 8

- Hour Ozone NAAQS Maintenance Area (Allentown Maintenance Area)

. The MVEBs are a mobile source inventory to which an area’s transportation improvement program (TIP) and long range transportation plan must conform . Conformity to MVEBs in a SIP2

means that transportation activities will not produce new air quality violations, worsen existing violations, or delay

timely attainment of the NAAQS or any required interim milestones. This March 7, 2014 SI P revision submi ttal provides updated MVEBs for NO x . The budgets were developed utilizing MOVES2010a. On March 2, 2010 (75 FR 9411), EPA published a notice of availability

for the MOVES2010 model for use in SIP submissions and started a two y ear grace period for the use of MOVES2010 for transportation conformity purposes. The two y ear grace period was scheduled to end on March 2, 2012. On February 27, 2012 (77 FR 11394), EPA published a final rule extending the grace period another year to March 2, 2013 to ensure adequ ate time for affected parties to adopt the model. On September 8, 2010, EPA released MOVES2010a, which is a minor update to MOVES2010. Pennsylvania utilized MOVES2010a in its November 19, 2012 SIP revision. MOVES2010a was used in order to ensure that th e nonattainment area can demonstrate transportation conformity using MOVES2010a once the 3

- ye ar conformity

grace period expires. Pennsylvania updated their SIP

- approved MVEBs with the use of MOVES2010a. The budgets were previously developed with the use of the Highway Mobile Source Emission Factor Model (MOBILE6.2). MOBILE6.2 is a motor vehicle emissions factor model that was utilized for SIPs and transportation conformity . MOBILE6.2 was made available for use in SIPs and transportation conformity

purposes on May

19, 2004 (69 FR 28830). MOBILE6.2 was merel y an update to MOBILE6 that added the ability for the program to estimate direct exhaust and brake and tire wear particulate matter emission factors as well as exhaust emission factors for particula te matter precursors. MOVES2010 improves upon MOBILE6.2 in many aspects. MOVES2010 utilizes a plethora of vehicle data that has been made available since the release of MOBILE6.2; this vehicle data includes emissions data for different kinds of vehicles . The new data has allowed EPA to better understand on

- road mobile source emissions and their contribution to emissions inventories as well as how effective different control strategies are. The MOVES2010 model offers more flexibility because the program has a database design that allows easier organization of input and output files and data. The database design of the MOVES2010 model allows much easier update of input data upon the release of new data. MOVES2010 also accounts for temperature and speed variations and allows the model to run at a higher resolution which allows for the input of more activity

data. Under s ection 176(c) of the Clean Air Act (CAA), any federal action is required to conform to the applicable SIP. A part of this requirement for conformity is transportation conformity

. Transportation conformity requires that an y federally funded transportation plan, program or project conform to the applicable SIP for the transportation

- related criteria pollutants (ozone, carbon monoxide, fine particulate matter ( PM 2.5 ), coarse particulate matter ( PM 10 ) , and nitrogen dioxide). The transportation conformity rul es can be found at 40 CFR 93, Subpart A. One of the requirements found under 40 CFR 93, Subpart A is that any transportation plan, TIP or project not in a conforming TIP must conform to the MVEBs in the applicable SIP. In order for the MVEBs in a SIP to be used to determine conformity of a transportation plan, TIP or project, the MVEBs must be either approved or deemed adequate. In this case, the budgets must be approved because this SIP revision is revising already approved budgets. However, in reviewi ng such a submitted SIP it remains useful to appl y the criteria used to make an adequacy finding.3

The requirements for adequacy are set forth in 40 CFR 93.118(e)(4)(i)

- (vi). The criteria for adequacy and how they

are met by

the Penns yl vania submittal are found below in Tab le 1. Adequacy Criteria

.
**Table 1. Adequacy Criteria**

Criterion Submittal (i) 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;  Letter addressed to Shawn M. Garvin, Regional Administrator, EPA Region III from E. Christopher Abruzzo , Secretary, Pennsylvania DEP

.  Public hearing documents were submitted

. (ii) Before the control strategy implementation plan or maintenance plan was submitted to EPA, consultation among federal, State, and local agencies occurred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, if any, were addressed;  N/A, this revision does not accomp any a control strategy implementation plan or maintenance plan

. (iii) The motor vehicle emissions budget(s) is clearly identified and precisely quantified;  Appendix C

- 2 of the submittal provides detailed emission summary tables

. (iv) The motor vehicle emissions budget(s), when considered together with all other emissions sources, is consistent with applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given implementation plan submissio n);  Maintenance plan was already approved on March 2, 2008 (73 FR 11557 ) , no changes to nonroad and area source emissions, point source emissions were updated

.  Allentown Maintenance Area continues to attain the 1997 Ozone NAAQS as shown by the preliminary design value obtain ed from 2011

- 2013 data

.  Update of point source emissions shows less emissions than those predicted in the maintenance plan

. (v) 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  The SIP revision shows no change in any control measures in the previously submitted maintenance plan. (vi) Revisions to previously submitted control strategy implementation plans or maintenance plans explain and document any changes to previously submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins (see § 93.101 for definition); and reasons for the changes (including the basis for any changes related to emission factors or estimates of vehicle miles traveled).  Changes in MVEBs are clearly documented and explained in the submittal. The higher emissions are due to the use of MOVES2010a which is a more accurate emissions model and is based on more recent data on vehicle emissions than MOBILE6.2 . Update of point source4 emissions and addition of small safety margin are well explained.

**B. STATE SUBMITTAL** On March 7, 2014 , PADEP submitted a SIP revision which included an update to the MVEBs for NO x for the y ears 2009 (interim y ear) and 2018 (maintenance y ear). The updated MVEBs were produced using the MOVES2010a model. The MVEBs were developed with guidance from the following EPA guidance documents: Policy Guidance on the Use of MOVES2010 for SIP D evelopment, Transportation Conformity, and Other Purposes and Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. The submittal a lso included an update to the point source emissions inventory

. **I. Methodology for Developing Data for Use in MOVES2010a** PADEP utilized MOVES2010a to provide emissions rates for emissions of NO x . PPSUI TE is a program that was utilized for the processing of highway information and to pr ovide input files that are usable b y the MOVES2010a model. PPSUITE was run utilizing CENTRAL ; CENTRALis a program that provides a process for the proper function of PPSUI TE and MOVES2010a. The MVEBs were developed for NOx and volatile organic compounds ( VOCs ) since they are the two biggest contributors to the formation of ozone. The MVEBs for VOCs were not updated in this SIP revision. In PPSUITE, the Penns yl vania Department of Transportation (PennDOT) Roadway Management Sy stem (RMS) data among other data was utilized to produce vehicle miles traveled (VMT) estimates. The VMT produced via PPSUI TE was then imported into the county data manager (CDM) in MOVES2010a. Since VOCs and NOx emissions differ with respect to travel speed, travel speed is utiliz ed as an input in MOVES2010a. To develop an array of travel speeds, PPSUI TE was utilized to develop vehicle hours of travel (VHT) by speed bin file which allows for the distribution of speeds across links into MOVES2010a speed bins. The travel speed calcu lations were completed with guidance from Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity

. Road ty pe distribution was another traffic input for MOVES2010a. Road ty pe distribution was developed with the use of PPSUI TE. The five different road t ypes utilized by MOVES2010a are off network, rural restricted access, rural unrestricted access, urban restricted access and urban unrestricted access. In addition, ramps are not included in road t ype distribution so it is assumed that 8% of the roadway

VHT is ramp VHT. This traffic input assumption is consistent with EPA’s technical guidance. Before RMS data is utilized by PPSUITE to develop various traffic inputs, severa l adjustments must be made. The RMS VMT is adjusted to meet the Highway Performance Monitoring Sy stem (HPMS) VMT totals. HPMS VMT utilizes snapshots of RMS VMT to satisfy reporting5

requirements established by the Federal Highway

Administration (FHWA). T o make this adjustment, adjustment factors were calculated and utilized. Adjustments to average annual daily traffic (AADT) were completed because calculations for ozone precursors are based on a summer weekday, since that is when ozone formation tends t o be the greatest. The RMS AADT volumes are adjusted by the use of a seasonal factor that was developed b y PennDOT’s Bureau of Planning and Research (BPR) to produce July traffic volumes. The RMS data was also adjusted for differences in hourl y traffic v olumes. The 24

- hour pattern data provided to PPSUI TE allowed PPSUI TE to provide roadway segment volumes by the hour. The 24

- hour pattern data was obtained from PennDOT’s PBR. Traffic volume forecasts had to be applied to estimate future emissions from vehicles. The growth rates utilized for these forecasts are the PennDOT PBR growth rate forecasting s ys tem, the regional travel model and an y applicable Marcellus Shale related activity growth. Additionally , count y specific growth rates were utilized fro m a 2005 PennDOT report titled Statistical Evaluation of Projected Traffic Growth, Traffic Growth Forecasting System: Final Report, March 14, 2005

. MOVES2010a utilizes 13 vehicle source t ypes. Since HPMS utilizes different categories for vehicle t ypes, the RMS traffic volumes were disaggregated to the 13 vehicle source typ es which were then combined into the 6 HPMS vehicle classes. Vehicle type data input into PPSUI TE is used to divide the roadway segment volumes with respect to the MOVES2010a source t yp es. The source t yp es are split into percentages among the 24

- hours of the day . The vehicle source ty pe percentages are then utilized to adjust vehicle speeds in response to trucks. Vehicle population is also another important input for MOVES2010a. V ehicle population is input into MOVES2010a with respect to the 13 vehicle source t yp es utilized by the model. County level vehicle registration data is utilized for light duty vehicles and school buses. Transit bus data is obtained from PennDOT’s National Transit Database (NTD); it is utilized to estimate county level transit bus counts. Heavy dut y vehicle population data is estimated by utilizing source t ype VMT and vehicle source and pattern data are utilized. Vehicle age is input into the model as well . The vehicle age is input into the model as a percentage of vehicles of the fleet between ages 0 and 31. Outside of vehicle and roadway data, environmental variables are utilized as inputs since evaporative emissions are dependent on the surrounding t emperatures. The environmental variables used included hourly temperatures and humidity values. The temperatures were retrieved b y Weather Bank, Inc. Humidity values were produced according to EPA’s technical guidance. Minimum and maximum monthly temper atures were converted to hourly temperatures using EPA converters in the MOVES2010a model. Fuel parameters were also input since different fuels produce different emissions. The MOVES2010a default fuel formulation and supply data was utilized and updated with local volumetric fuel propert y data. Gasohol market penetration and RVP values were u pdated at the county level.6

Refueling emissions were not included as an input because Penns yl vania provides the refueling emissions in its area source inventory ; hence it is not required for the production of MVEBs. Additionally , MOVES2010a also includ es input parameters for inspection and maintenance (I/M) programs. The inputs for the I/M program include: program start y ear, stringency level, first and last model y ears subject to the program, waiver rates, compliance rates, program ty pe and effectiven ess, frequency of inspection, vehicle ty

pe coverage and test ty

pe. The defaults for an I/M program in MOVES2010a were modified to accuratel y represent the I/M program for each county

. **II. Running MOVES2010a** As stated in Section I , the data utilized t o run MOVES2010a is a mixture of local and national data. Local data is utilized for all inputs that have significant impact on the emissions rates that are calculated b y M OVES2010a. The local data utilized as inputs for MOVES2010a is categorized into fi ve categories which include: traffic data, vehicle descriptions, fuel parameters, I/M programs, and environmental variables. The inputs for traffic data include vehicle type VMT, vehicle population, VMT fractions, road t ype distribution, and ramp fraction s. The inputs for vehicle descriptions include vehicle typ e mix, vehicle age distribution, average speeds and hourly distributions of different vehicles. The inputs for fuel parameters include RVP, sulfur level and ethanol volume. The inputs for I/M pro grams include start and model y ears, the frequency of tests, test standards, source t ypes, stringency of tests, the waiver rate, and compliance rates. The inputs for environmental variables include hourly temperatures and humidity

. MOVES2010a inputs th at were prepared b y PPSUITE included vehicle type VMT, vehicle population, VMT fractions, average speed distributions, road ty pe distribution and ramp fractions. These files were input into the MOVES2010a count y data importer. Additional non

PPSUI TE inputs included fuel and vehicle ages, as well as temperatures and I /M programs. The county data importer was run in batch mode. Running the count y data importer converts input files into a MYSQLformat which is accepted by MOVES2010a. Afterwards, a MOVES r un specification file (.mrs) was created. This file includes options and different data locations for the execution of the model. MOVES2010a can be executed to provide an emissions rate or an emissions inventory . In this submittal, MOVES2010a was execut ed to provide an emissions inventory . The emissions estimates of NO x produced for the years 2004, 2009 and 2018 by MOVES2010a are provided in Table 2. Summary of Motor Vehicle Emissions in tpd . The emissions estimates are provided in tons per day (tpd); also provided in Table 2 is the comparison between the emissions produced b y MOBILE6.2 and MOVES2010a. No new emissions estimates were produced for VOCs therefore their inclusion into the MOVES estimates portion in the table below is not applicable (N/A) . After reviewing this submittal, EPA concurs with Penns yl vania that even though the emissions results produced by MOVES2010a are greater than those previously calculated using MOBILE6.2. EPA’s review of the SIP revision indicates these higher emissions result from improvements in the MOVES model rather than from unanticipated growth or changes in control measures. The MOVES results are more accurate estimates of the emissions that a ctually occurred in 2004 and 2009, rather than an indication that emissi ons are increasing. More importantly , the Allentown Maintenance Area7

attained the 1997 8

- Hour Ozone NAAQS and was redesignated to a maintenance area on March 2, 2008 (73 FR 11557). The Allentown Maintenance Area co ntinues to attain the 1997 8

- Hour Ozone NAAQS as shown by its 2011

- 2013 preliminary design values. The preliminary 2011

- 2013 design value for the Allentown Maintenance Area is 74 parts per billion (ppb )

. Therefore, EPA finds this update to the MVEBs does not interfere with the Allentown Maintenance Area ’s ability to maintain its attainment of the1997 8

- Hour Ozone NAAQS.

**Table 2 . Summary of Motor Vehicle Emissions**  **in tpd** Model MOBILE6.2 MOVES2010a Year 2004 2009 2018 2004 2009 2018 VOCs 30.54 22.80 13.28 N/A N/A N/A NO x 48.33 33.89 14.44 59.38 44.08 21.95
**III. Review of MOVES Modeling** To run the MOVES2010 a model, a run specification (hereafter referred to as “RunSpec”) must be created so the appropriate parameters are selected for the modeling run. The RunSpecs were reviewed against the following EPA document : Technical Guidance on the use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. This guidance document provides guidance on the use of the MOVES model to develop inventories for SIPs as well as anal ys is of emissions for transportation confor mity determinations. MVEBs were submitted for the ye ars 2009 and 2018 for the 1997 Ozone NAAQS which are consistent with the rest of the emissions inventory i n the maintenance plan. The submitted RunSpecs, input files and output files were reviewed and found to have followed the applicable EPA guidance provided in the Technical Guidance on the use of MOVES2010 for Emission I

nventory Preparation in State Im plem entation Plans and Transportation Conformity

. Table 3

. RunSpec Reviews for the 1997 8

- Hour Ozone NAAQS for Years 2009 and 2018 for Lehigh, Northampton, and Carbon Counties , presents the RunSpec parameters that were reviewed and each parameter ’s respectiv e component in the submittal.
**Table 3. RunSpec Reviews for the 1997 Ozone NAAQS f**  **or Years 2009 and 2018 for Lehigh,**  **Northampton, and Carbon**  **Counties** Domain/Scale Co unty scale was selected. Selection of count y scale is acceptable for this air quality

anal ys is. Calculation Ty

pe Inventory

was selected which is acceptable for this anal ys is. Time Aggregation Level Hourly time aggregation was selected. Selection of hourly time aggregation level is acceptable for this anal ys is. Calendar Year Of Evaluation The appropriate calendar year was selected for each RunSpec; each RunSpec has 2009 or 2018 as the selected calendar year. MOVES2010b can model y ears 1990 and 1999

- 2050. Month of Evaluation July was selected to be the month of evaluation

. This is acceptable for ozone precursor analy sis.8

Ty pe of Day of Evaluation Wee kday s were selected, which is appropriate for the evaluation of pollutant emissions related to ozone. Hours of Evaluation Starting and ending hour s create a whole day (from 0

- 24 hours). Geographic Bounds The appropriate count y w as selected for each RunSpec. The three counties modeled were Lehigh, Northampton, and Carbon Counties

. Vehicles/Equipment: On

Road Vehicle Equipment Appropriate combi nations of fuels and source use ty pes were made. Road Ty pe Selection included all necessary road t ypes. Pollutants and Processes NO x , total gaseous h ydrocarbons, non

- methane hydrocarbons, and VOCs were selected. On

- Road Retrofits N/A ROP N/A Output Database/Unit Selection Mass units selected to be grams; energy units selected to be million British Thermal Unit (BTU) ; distance units selected to be miles. Output Emission Detail in Emission Rate Calculations Emission detail was selected via use r preference . The output emissions detail does not affect the results of the modeling runs, therefore user preference is acceptable. Advanced Performance Features N/A

**IV. Safety Margins and Allotment of MVEBs for each MPO**  Since there is a significant difference between the projected emissions for the maintenance year and the attainment year a small portion of that difference was made into a safet y margin. In other terms, the emissions for the attainment ye ar are much great er than the emissions for the interim (2009) and maintenance (2018) ye ars, which allows for a portion of those excess emissions to become a safety margin. A two tpd safet y margin was added for NO x emissions for the 2009 and 2018 MVEBs. The MVEBs are pres ented below in Table 4. Revised MVEBs in tpd . The differences between the 2004 attainment y ear and the 2009 interim year and 2018 maintenance ye ar for NO x are found below in Table 5. NOx Emissions and Di fferences for Years 2004, 2009, and 2018 in tpd

. Table 5 presents decreases in emissions which are significant in some categories between the attainment, interim and maintenance ye ars. Because the 2009 and 2018 emissions are less than the 2004 attainment y ear emissions, a small portion of the excess emissions can be allocated to safet y margins while the area can continue to attain the 1997 8

- Hour Ozone NAAQS. Additionally , there are two metropolitan planning organizations (MPOs) that serve the three counties that are a part of the Allentown Maintenance Area. The Lehigh Valley MPO serves Lehigh and Northampton Counties while the Northeastern Penns yl vania Alliance (NEPA) MPO serves Carbon Count y. To simply the transportation conformity process f or these MPOs, separate budgets will be given to each MPO. Table 6. MVEBs for Each MPO presents how the MVEBs will be allotted to each MPO.

**Table 4. Rev ised MVEBs** 9

**Table 5. NO x**  **Emissions and Differences for Years 2004, 2009 ,**  **and 2018 in tpd**  Category 2004 2009 2004

- 2009 2018 2004

- 2018 Point 58.8 27.0 31.8 26.1 32.7 Area 2.9 3.1

- 0.2 3.2

- 0.3 Nonroad 12.9 11.0 1.90 6.6 6.30 Mobile 59.4 44.1 15.3 22.0 37.4 Total 134.0 85.2 48.8 59.9 74.1

**Table 6 . MVEBs for Each MPO**  MPO Lehigh Valley MPO NEPA MPO Year 2009 2018 2009 2018 VOCs 20.6482 12.4328 3.4372 2.263 NOx 39.1787 20.4058 6.8977 3.541

**C. EPA EVALUATION AND CONCLUSION**  EPA thoroughl y evaluated the submittal made by Pennsylvania through PADEP. EPA’s detailed review has led us to conclude that the development methodology of the MVEBs is consistent with applicable guidance documents intended to guide the development of on

- road inventories and MVEBs. EPA also reviewed the MVEBs using the adequacy criteria set forth in 40 CFR 93. 118(e)(4)(i)

- (vi), and as documented above we found that the budgets meet all of the adequacy criteria. Based on the results of EPA’s in depth review of the SIP revision, the area’s continued attainment of the 1997 8

- Hour Ozone NAAQS and the results of E PA’s review of the MVEBs using the adequacy criteria in the transportation conformity rule, EPA is proposing to approve the SIP revision. **in tpd** Year 2009 2018 VOCs N/A N/A NO x 46.08 14.9