SACRAMENTO METROPOLITAN 

AIR QUALITY 

MANAGEM ENT D ISTRICT 

November 14, 2014 

John Ungvarsky 

Office of Air Planning (AIR-2) 

U.S. Environmental Protection Agency, Region IX 

Docket No: EPA-R09-0AR-2014-0178 

75 Hawthorne Street, San Francisco, CA 94105 

Larry Greene 

AIR POLLUTION CONTROL OFFICER 

Re: Comment on Approval and Promulgation of the Implementation Plans; State of 

California; Sacramento Metro Area; Attainment Plan for 1997 8-Hour Ozone Standard 

Dear Mr. Ungvarsky, 

Thank you for the opportunity to review and comment on the proposed approval of the 

state implementation plan (SIP) revision submitted by the state of California to provide 

for attainment of the 1997 8-hour ozone ambient air quality standard for the 

Sacramento Federal Nonattainment Area. 

In the Sacramento Ozone Plan (2013 Revision), the region identified a small buffer of 

additional emission reductions as part of the attainment demonstration for 2018. This 

buffer totaled 1.0 tons per day (tpd) NOx and 3.0 tpd VOC reductions from proposed 

but unadapted regional and local measures. The buffer was intended for use, if 

necessary, in demonstrating general conformity for future federal projects. 

EPA did not include the reductions from the unadapted state and local control measures 

in its proposed attainment demonstration. As a result, the proposed attainment 

demonstration shows a general conformity buffer of only 0.1 tpd NOx. 

The most recent transportation conformity analysis completed by the Sacramento Area 

Council of Governments (SACOG), which is the metropolitan planning organization for 

our region, uses motor vehicle emission budgets (MVEBs) that were found to be 

adequate for transportation conformity purposes by EPA (79 FR 46436) and that are 

proposed for approval in this rule. These budgets incorporate a safety margin of 3.0 

tpd NOx that was not used for demonstrating conformity for 2018 and remains surplus 

to the proposed attainment demonstration. 

To ensure that the region can continue to meet air quality requirements for improved 

transportation and economic development, SACOG and the District request that EPA 

reallocate a nominal amount- 0.9 tons per day - from the 2018 MVEB NOx safety 

margin to the general conformity NOx buffer in their final plan approval. This would 

leave a transportation buffer of 2.1 tpd and a general conformity buffer of 1.0 tpd NOx. 
EPA's proposal to approve the Sacramento Ozone Plan marks a milestone in the 

combined efforts of local businesses, the regional air districts, the MPO, and state and 

federal agencies in providing clean healthy air for our citizens. Thank you for your 

consideration of our comment. Please do not hesitate to contact me at (916) 874-4802, 

or Charles Anderson at (916) 874-4831, if you need more information regarding our 

comment. 

Sincerely, 

Larry 

~~ Greene 

Executive Director/Air Pollution Control Officer 

Sacramento Metropolitan Air Quality Management District 

Mike McKeever 

Chief Executive Officer 

Sacramento Area Council of Governments 

777 12th Street, 3rd Floor • Sacramento, CA 95814-1908 

916/874-4800 • 916/874-4899 fax 

www.airquality.org 

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