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 I o 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 PMI o 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 I o 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