	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

	REGION III

1650 Arch Street

	Philadelphia, Pennsylvania  19103-2029

February 9, 2007

SUBJECT:	

Technical Support Document - Findings for Motor Vehicle Emission
Budgets; 2009 and 2018 Motor Vehicle Emissions Budgets in the
Maintenance Plan for the Berks County, Pennsylvania 8-Hour Ozone
Nonattainment Area





      FROM: 	

Martin Kotsch, 3AP23	





TO:	

Administrative Record for Review of the 2009 and 2018 Motor Vehicle
Emission Budgets in the Maintenance Plan for the Berks County,
Pennsylvania 8-Hour Ozone Nonattainment Area	





THRU:	

Carol Febbo, Chief 

Energy, Radiation and Indoor Environment Branch (3AP23)	





I.   Administrative Requirements For Making Adequacy Findings  

The adequacy and approvability of the 2009 and 2018 Motor Vehicle
Emissions Budgets contained in the Maintenance Plan submitted by the
Pennsylvania  Department of the Environment (PADEP) on January 25, 2007
for the Berks County, Pennsylvania 8-Hour Non-attainment Area  was
reviewed in accordance with the procedures and criteria of the
Transportation Conformity Rule contained in 40 CFR Part 93, Sections
93.106(a)(1) 106(a)(2)(i), 93.110, 93.113(b) 118 (e) (4) through (5) and
the following guidance: 

-  January 18, 2002 EPA memorandum from John Seitz and Margo Oge
entitled: (Policy Guidance on the Use of MOBILE6 for SIP Development and
Transportation Conformity(, and

-  February 12, 2003 EPA memorandum from Tom Helms and Leila Cook
entitled: (Clarification of Policy Guidance for MOBILE6 SIPs in
Mid-course Review Areas(, and

- March 8, 2005 EPA memorandum from Suzanne Rudzinski and Lydia Wegman
entitled  (Guidance for Determining the "Attainment Year" for
Transportation Conformity in New 8-Hour Ozone and PM2.5 Nonattainment
Areas(, and 

- May 2005  Reference document entitled  (Complete Transportation
Conformity Regulations that Incorporate Recent Conformity Final Rule
Amendments (Through May 2005)(. 

On January 25, 2007, the Pennsylvania Department of the Environmental
Protection (PADEP) submitted its motor vehicle emission budgets to the
Environmental Protection Agency (EPA) as a part of its State
Implementation Plan (SIP) revision.  The Pennsylvania  public comment
period on the SIP revision closed on December 22, 2006.

EPA will be issuing its own Notice of  Proposed Rule Making for a 30-day
public comment period  soliciting public comment as to the approvability
of the Pennsylvania SIP submission.  Concurrently with the EPA Notice of
Proposed Rulemaking, a notice will be  posted on EPA(s website at
http://www.epa.gov/otaq/stateresources/transconf/currsips.htm  for the
purpose of opening EPA(s 30-day public comment period on the
adequacy/approvability of the budgets in the SIP revision.  That notice
will inform  the public of the availability of the Pennsylvania  SIP
revision on its own website.  EPA(s  website notice will provide a link
to the address for the  website where interested members of the public
could access the SIP revision. Following  EPA(s public comment period,
responses to any comments received on the proposed mobile budgets in the
Pennsylvania SIP will be addressed in an amendment to this TSD.

II.  Evaluation of the Budgets 

Table 1 - The Budgets 

Clean Air Act Requirement	

Milestone Year	

Mobile Vehicle Emissions Budget for NOx in Tons Per Day	

Mobile Vehicle Emissions Budget for VOCs in Tons Per Day



Maintenance Plan	

2009	

21.3	

13.1



	

2018	

9.0	

7.5



Table 2

Adequacy/Approvability of the Motor Vehicle Emissions Budgets in the
Maintenance Plan Submitted by PADEP on January25,  2007 for the Berks
County, Pennsylvania  8-Hour Ozone Nonattainment Area 



Transportation Conformity Rule

	

Review Criteria	

Was the Criterion Satisfied?    If (Yes( How was this Criterion
Satisfied?



93.106(a)(1)	

Are the budget years correct?	

Yes



93.106(a)(2)(i)	

Does the plan quantify and document the demographic and employment
factors influencing transportation demand?	

Yes



93.110	

Are the emissions budgets based upon the latest planning assumptions?

(a)   Are the emission budgets, with respect to all other applicable
criteria in ((93.111 - 93.119, based upon the most recent planning
assumptions in force at the time of the development of the budgets?

(b) Are the assumptions derived from the estimates of current and future
population, employment, travel, and congestion most recently developed
by the MPO or other designated agency and are the budgets based upon the
latest assumptions about current and future background concentrations?

	

Yes

Yes

Yes



	

(e)  Do the budgets include the latest existing information regarding
the effectiveness of TCMs and other implementation plan measures which
have already been implemented.

(f) Are key assumptions specified and included in the draft documents
and supporting materials used for the interagency and public
consultation required by (93.105?	

There are no previous TCMs.

Yes



 93.111	

Are the budgets based upon the latest emissions model?	

Yes, MOBILE6.2, the latest EPA emissions model was utilized.



93.113(b)	

Have previously committed TCM's been implemented?	

There were no TCMS in the previously approved SIP



Sec. 93.118(e)(4)(ii)	

Before the control strategy implementation plan was submitted to EPA,
did consultation between  federal, State and local agencies occur; was
full implementation plan documentation provided to EPA, and were EPA(s
stated concerns, if any, addressed?	

Yes



Sec. 93.118(e)(4)(iii)	

Were the motor vehicle emissions budgets clearly identified and
precisely quantified?	

Yes



Sec. 93.118(e)(4)(iv)	

Is the motor vehicle emissions budget(s), when considered together with
all other emission reductions, consistent with applicable  requirements
for the control strategy implementation 

plan?	

Yes



Sec. 93.118(e)(4)(v)	

Is the motor vehicle emissions budget(s) consistent with and clearly
related to the emissions inventory and the control measures in the
submitted control strategy? implementation plan?	

Yes



Sec. 93.118(e)(4)(vi)	

Revisions to previously submitted control strategy implementation plan: 
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).	

The new budgets have been changed to reflect a new emissions inventory
and a new baseyear which were required in the development of the new
maintenance plan under the 8-hour ozone standard.



Sec. 93.118(e)(5)	

Did they provide and did  we review the State(s responses to the public
comments?	

There were no comments submitted relevant to the mobile vehicle
emissions budgets in the SIP during the State comment period.





III.  Recommendation

Based upon our review and evaluation of the motor vehicle emission
budgets contained in the Maintenance Plan submitted by PADEP for the
Berks County, Pennsylvania 8-Hour Ozone Non-attainment Area submitted on
January 25, 2007, we recommend that the mobile emission budgets be found
adequate and approved. 

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