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 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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REGION 8
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1595 Wynkoop Street
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DENVER, CO   80202-1129
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Phone 800-227-8917
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http://www.epa.gov/region08
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Ref:  8P-AR

Metro-Denver/NFR 2008 8-hour Ozone "Moderate" Area NAA Plan Adequacy Evaluation
                                       
                        Transportation Review Criteria
                            Is Criterion Satisfied?
                     Reference in SIP Document / Comments
Sec. 93.118(e)(4)(i)
The plan was endorsed by the Governor (or designee) and was subject to a public hearing.
                                       Y
May 16, 2017 Letter from Larry Wolk, Exec. Director of CDPHE (on behalf of the Governor.) SIP revision submittal was received by Region 8 of the EPA on Amy 31, 2017. By operation of law (CAA section 110(k)), the SIP submittal was deemed complete on December 1, 2017.
The submittal includes evidence of a public hearing that occurred on November 17, 2016.
Public Hearing Notice:  Colorado's State Implementation Plan and Associated Regulations; Moderate Ozone Nonattainment Area SIP Element; Public Hearing notice dated August 29, 2016, signed by Michael Silverstein, Administrator, Colorado Air Quality Control Commission (AQCC).  Affidavit of publication:  The Public Hearing notice was published in the Denver Post on August 7, 2016 and on the AQCC Commission website.  Note:  In a letter dated October 2, 2002, Casey Shpall, Colorado AG's office stated there is no State Requirement to publish a notice in a newspaper for a Notice of AQCC rulemaking. 
Sec. 93.118(e)(4)(ii)
The plan was developed through consultation with federal, state and local agencies; full implementation plan documentation was provided and EPA's stated concerns, if any, were addressed.
                                       Y
The submittal includes the Air Pollution Control Division's (APCD) statement of October 13, 2016. EPA provided public comments, regarding the Moderate Area Ozone Plan, in a letter dated November 1, 2016. The Colorado Air Pollution Control Division (APCD) provided sufficient responses to EPA's comments.
Sec. 93.118(e)(4)(iii)
The MVEBs are clearly identified and precisely quantified.
                                       Y
The NOx and VOC MVEBs are clearly identified in Chapter 11 of the Moderate Area Ozone Plan. Chapter 11 also identifies the Total NAA MVEBs along with the Northern Sub-Area MVEBs and Southern Sub-Area MVEBs. The MVEBs are as follows:  Total NAA NOx MVEB = 73 tpd; Total NAA VOC MVEB = 55 tpd. Northern Sub-Area NOx MVEB = 12 tpd; Northern Sub-Area VOC MVEB = 8 tpd. Southern Sub-Area NOx MVEB = 61 tpd; Southern Sub-Area VOC MVEB = 47 tpd.
Sec. 93.118(e)(4)(iv)
The motor vehicle emissions budget(s), when considered together with all other emission sources, is consistent with applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given plan).
                                       Y
The 2017 NOx and VOC MVEBs are consistent with the Moderate Area Ozone Plan's attainment demonstration (Chapter 5) and RFP demonstration (Chapter 4). The MVEBs are also consistent with the emission inventories located in Chapter 4.        
Sec. 93.118(e)(4)(v)
The plan shows a clear relationship between the emissions budget(s), control measures and the total emissions inventory.
                                       Y
The relationship of the NOx and VOC MVEBs in the Moderate Area Ozone Plan are clearly discussed and presented in Chapters 4, 5, 6, 7 & 11 of the Ozone Plan.
Sec. 93.118(e)(4)(vi)
Revisions to previously submitted control strategy or maintenance plans explain and document any changes to any previous submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins (see 93.101 for definition), and reasons for the changes (including the basis for any changes to emission factors or estimates of vehicle miles traveled).
                                       Y
Mobile source emissions and NOx and VOC MVEBs were originally documented in Metro-Denver/NFR Marginal NAA Ozone Plan that EPA approved on August 5, 2011 (76 FR 47443).  EPA has reviewed the previously approved MVEBs for 2015 of: Total NAA NOx MVEB = 122.9; Total NAA VOC MVEB = 109.2 tpd; Northern Sub-Area NOx MVEB = 20.5 tpd; Northern Sub-Area VOC MVEB = 19.5 tpd; Southern Sub-Area NOx MVEB = 102.4 tpd; and Southern Sub-Area VOC MVEB = 89.7 tpd.  
The May, 2017 submitted Moderate NAA Ozone Plan SIP revision sufficiently documents the reasons for the reduced 2017 attainment year NOx and VOC Total NAA MVEBs and Sub-Area MVEBs.
Sec. 93.118(e)(5)
EPA has reviewed the State's compilation of public comments and response to comments that are required to be submitted with any implementation plan.
                                       Y
The Governor's submittal indicates the public comments and EPA comments were responded to by the Colorado APCD. All of the APCD responses to comments were provided with the SIP submittal.
Reviewers: Tim Russ, USEPA, Region 8
Date Review Prepared: December 1, 2017



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