Mr. Dick Pederson 

UNITED STATES ENVIRONMENTAL PROTECTION 

AGENCY 

REGION 10 

1200 Sixth Avenue, Suite 900 

Seattle, WA 98101-3140 

APR 11 2014 

Mr. Tom Hughes 

Oregon Department of Environmental Quality 

811 Southwest Sixth A venue 

Ms. Carlotta Collette 

600 Northeast Grand 

Portland, Oregon 97204 Portland, Oregon 97232 

Dear Mr. Pederson, Mr. Hughes and Ms. Collette: 

OFFICE OF THE 

REGIONAL 

ADMINISTRATOR 

Thank you for your concurrence letters from the Oregon Department of Environmental Quality 

on January 14, 2014, and from the Oregon Metro metropolitan planning organization on 

January 8, 2014, requesting the Environmental Protection Agency's concurrence on substitution 

of the transit service increase Transportation Control Measure for the Portland Area Carbon 

Monoxide Maintenance Plan. The proposed substitution would replace the "existing transit 

service increase TCM" 1 with a "substitute transit service increase TCM"2 containing an 

equivalent method for assessing the transit service increase. 

The Safe, Accountable, Flexible, and Efficient Transportation Equity Act: A Legacy for Users, 

signed into law on August 10, 2005, revised the Clean Air Act's Section 176(c) transportation 

conformity provisions including procedures to use in substituti_ng or adding TCMs to approved 

State Implementation Plans. The CAA, as amended, requires that the replacement TCM must 

achieve equal or greater emission reductions; be implemented on a consistent schedule; and be 

supported by adequate resources and authority to be implemented, monitored and enforced. The 

TCM must also have been developed though a collaborative process involving all affected 

jurisdictions, the EPA, and the public. Qualifying TCMs can be substituted into an approved SIP 

without a formal rulemaking process. 

The EPA reviewed the methodology and the material used by the ODEQ to demonstrate 

equivalency between the original and substitute TCMs. The EPA also reviewed the comments 

received during the public comment process, and the responses to these comments from ODEQ. 

Based on a review of the analysis and the responses to comments, the EPA concurs with the 

state's analysis and determination that the substitute TCM is expected to provide an equivalent 

emission reduction to the original TCM. Additionally, the emission reductions from the 

1 Existing Transit Service Increase TCM: Regional transit service revenue hours (weighted by capacity) shall be 

increased 1.0% per year. The increase shall be assessed on the basis of a five-year rolling average between 2006 and 

2017. Assessments made for the period through 2008 shall include the 2004 opening oflnterstate Metropolitan Area 

Express (MAX). 2 Substitute Transit Service Increase TCM: Regional transit service revenue hours (weighted by capacity) shall be 

increased 1.0% per year. The increase shall be assessed on the basis of cumulative average of actual hours for 

assessment conducted for the entire second ten-year Portland Area Carbon Monoxide Maintenance Plan period 

(2007-20 17). A transit service increase will be assessed on the basis of fiscal year (July 1- June 30) beginning with 

FY 2008. 
substitute TCM occur on a schedule consistent with the TCM being replaced. These concurrence 

letters attest that the proposed TCM substitution for the Portland Area CO Maintenance plan 

meets the CAA TCM substitution requirements as delineated in section 176(c)(8) of the CAA. 

This letter transmits the EPA's concurrence regarding the TCM substitution submitted by the 

ODEQ. In reaching this decision, we have reviewed the technical information for the substitute 

TCM provided by the ODEQ and have determined that the substitute TCM meets the CAA 

Section 176(c)(8) requirements for substitute TCMs. 

The substitute TCM is now part of the federally enforceable SIP. We have received the substitute 

TCM and support materials for incorporation in the federally approved SIP within 90 days as 

required by CAA, Section 17 6( c )(8). The EPA will proceed to update the Code ofF ederal 

Regulations to reflect the changes to the SIP to clarify that the substitute TCM is a part of the 

federally enforceable SIP. If you have any questions regarding this letter, please contact 

Karl Pepple, Air Planning Unit in the Office of Air, Waste and Toxics at pepple.karl@epa.gov or 

(206) 553-1778. 

Sincerely, 

r--d--9- ~\. ~-- Dennis J. McLerran 

Regional Administrator 

cc: Mr. Uri Papish 

ODEQ Interim Air Quality Administrator 

Mr. David Collier 

ODEQ Air Quality Planning Manager 

Mr. Dave Nordberg 

ODEQ Transportation Conformity Contact 

Ms. Andrea Gartenbaum 

ODEQ SIP Coordinator 

Mr. Tom Kloster 

Metro Transportation Planning Manager 

2