UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 900 Seattle, WA 98101-3140

OFFICE OF AIR, WASTE AND TOXICS



### Mr. Dick Pedersen Director Oregon Department of Environmental Quality 811 SW Sixth Avenue Portland, Oregon 97204-1390

Re: Adequacy Finding for the Grants Pass PM Io Limited Maintenance Plan

Dear Mr. Pedersen:

The purpose of this letter is to inform you of the U.S. Environmental Protection Agency's determination of the adequacy for transportation conformity purposes of the motor vehicle emissions budgets in the Grants Pass PMjo Limited Maintenance Plan 

### for the PMIo national ambient air quality standard. As a result of our adequacy finding, the Rogue Valley Council of Governments, the Oregon Department of Environmental Quality, Oregon Department of Transportation, and the U.S. Department of Transportation are not required to conduct a regional emissions analysis for transportation conformity; however, other transportation conformity requirements still remain such as consultation, transportation control measures, and project level analysis.

The LMP was submitted to the EPA on April 22, 2015. We announced receipt of the LMP on the EPA's Office of Transportation and Air Quality web site on May 4, 2015, and requested public comment on the on-road portion of the LMP by no later than June 3, 2015. We received no comments on the on-road portion of the Plan during the comment period.

Because limited maintenance plans do not contain budgets, the adequacy review period for these maintenance plans serves to allow the public to comment on whether LMP option is appropriate for these areas. This letter transmits our decision that this LMP is adequate for transportation conformity decisions.

Pursuant to 40 CFR 93.118(e)(4) of the Transportation Conformity Rule (40 CFR part 93, subpart A), the EPA reviewed the submitted LMP. The state of Oregon received no public comments on the LMP during the public comment period or the associated hearing. We received no adverse comment regarding the LMP approach to on-road emissions. As a result of our review, we believe it is appropriate to find the LMP adequate for transportation conformity purposes while the EPA continues to review the other aspects of the LMP. We have determined that the LMP's approach to on-road emissions, when considered with all other emissions sources in the Grants Pass area, is consistent with applicable requirements for maintenance of the PM Io national ambient air quality standards through the year 2025. The LMP also meets the other adequacy criteria found in 40 CFR 93.118(e) as detailed in the enclosed "Transportation Conformity Adequacy Review." JUN 

## 2 4 2015

### A copy of this letter and its enclosure will be posted on the Internet at

http:l/www.epa.gov/otaglstateresources/transconf/adequacy.htm . The EPA's adequacy finding for purposes of transportation conformity is not dispositive of the EPA's ultimate approval or disapproval of the LMP.

The EPA intends to publish a notice of this adequacy determination in the Federal Register and the determination will become effective 15 days after the Federal Register publication. If you have any questions, please contact Karl Pepple of my staff at (206) 553-1778 or at pepple.karl@epa.gov

.

Enclosure

cc: Ms. Jazmin Marie Casas Federal Highway Administration

Mr. Ned Conroy Federal Transit Administration

Ms. Natalie Liljenwall Oregon Department of Transportation

Ms. Carole Newvine Oregon Department of Transportation

Mr. Johnathon David Rogue Valley Council of Governments

Ms. Michelle Eraut Federal Highway Administration

Mr. Dave Nordberg Oregon Department of Environmental Quality

Mr. David Collier Oregon Department of Environmental Quality

Mr. Dan Moore Rogue Valley Council of Governments

## Enclosure to Letter Dated June 24, 2015 from Kate Kelly to Dick Pedersen Transportation Conformity Adequacy Review

The Grants Pass PMro Limited Maintenance Plan



### Submitted April 22, 2015



### Adequacy Determination of Motor Vehicle Emissions Budget 40 CFR 93.118 (e) (4)

(4) EPA will not find a motor vehicle emissions budget in a submitted control strategy implementation plan revision or maintenance plan to be adequate for transportation conformity purposes unless the following minimum criteria are satisfied:

Adequacy Review Criteria Is this Criterion Satisfied? Reference in SIP Documents/Comments

(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; Yes This plan was filed by the Governor of Oregon's designee, Joni Hammond, Deputy Director of the Oregon Department of Environmental Quality (ODEQ), on April 22, 2015. The plan was the subject of a public hearing held in Grants Pass, OR on January 22, 2015. The details of the hearing can be located in the "Staff Report Agenda [team J of the April 15-16 EQC Meeting.pdf' document supplied by ODEQ. (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; Yes A draft of the Grants Pass, OR Limited Maintenance Plan (LMP) and supporting documentation was reviewed by EPA Region 10 and discussed with agencies such as ODEQ, the Rogue Valley Council of Governments (RVCOG), and the City of Grants Pass prior to state adoption by ODEQ on April 16, 2015. In addition, informal consultations between EPA, ODEQ, RVCOG, and other agencies were held as the draft plan was being developed. EPA concerns were addressed during this consultation process. (iii) The motor vehicle emissions budget(s) is clearly identified and precisely quantified; Yes Section 5 of the Grants Pass LMP discusses the criteria to meet the LMP requirements. Appendix C demonstrates that the criteria of the EPA LMP policy* are met for on-road purposes. (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 submission); Yes Sections 6 and 7 of the Grants Pass LMP demonstrate no violation of the 

### NAAQS will occur due to reasonable growth projections of on-road emissions, with supporting calculations found in Appendix C. Section 9 goes into detail about what actions will be taken by ODEQ if PA () levels reach 98 micrograms per cubic meter. Thus, the Grants Pass LMP is consistent with the applicable requirement of continued maintenance.(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 Yes Although EPA policy states that an emission budget is not required for LMP areas, the Grants Pass LMP must be consistent with the requirements in 40 CFR 93.113 which "provides for the timely completion or implementation of all transportation control measures in the applicable implementation plan." Sections 7 and 8 of the Grants Pass LMP list the control measures in effect for the area, and discuss contingency measures. (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 Sec. 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). Yes The assumptions, methods and computations used in the Grants Pass LMP area addressed in section 7, 8, and Appendix C. Section 7 indicates that no on-road control programs were modified from the previous 10- year maintenance plan submitted by ODEQ. Section 8 discusses contingency measures. Section 9 discusses verification of continued attainment moving forward. Appendices B and D of the Grants Pass LMP provides additional detail on inventory preparations.

93.118 (e) (5) Before determining the adequacy of a submitted motor vehicle emissions budget, EPA will review the State's compilation of public comments and response to comments that are required to be submitted with any implementation plan. EPA will document its consideration of such comments and responses in a letter to the State indicating the adequacy of the submitted motor vehicle emissions budget. Yes The State supplied proof of public notices and a public hearing. ODEQ received no comments on this LMP.

*Memorandum: 

### Limited Maintenance Plan Option for Moderate PMtoNonattainmen.t Areas, August 21, 2001, Lydia Wegman, Director AQSSD