

                               January 16, 2020

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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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0
Ref: 8P-AR

MEMORANDUM							

SUBJECT: 	Columbia Falls, Kalispell and Libby Motor Vehicle Regional Emissions Analysis

FROM:	James Hou
		Environmental Engineer

TO: 		File					

According to the Limited Maintenance Plan (LMP) Option for Moderate PM10 Nonattainment Areas (NAA) memo, in order to qualify for the LMP option, "The final criterion is related to mobile source emissions. The area should expect only limited growth in on-road motor vehicle PM10 emissions (including fugitive dust) and should have passed a motor vehicle regional emissions analysis test. It is important to consider the impact of future transportation growth in the LMP, since the level of PM-10 emissions (especially from fugitive dust) is related to the level of growth in vehicle miles traveled (VMT).

The following methodology can be found in Attachment B of the LMP Option memo, and is used to determine whether increased emissions from on-road mobile sources could, in the next 10 years, increase concentrations in the area and threaten the assumption of maintenance that underlies the LMP policy.  

The equation set forth is:
                         DV + (VMTpi * DVmv) < MOS
Where:
      DV = design value in μg/m3
      VMTpi = projected increase in vehicle miles traveled (VMT) over the next 10 years
      DVmv = product of the design value and the fraction of the inventory represented by on-road mobile sources in the attainment year; and
      MOS = margin of safety for the relevant PM10 standard for a given area: 40 μg/m3 for the
      annual standard or 98 μg/m3 for the 24-hour standard.

Columbia Falls Motor Vehicle Regional Emissions Analysis Calculation:
Utilizing a DV of 67; a projected 31.04% VMT increase; and a 0.35 fraction of the inventory represented by on-road mobile sources in the attainment year the results are as follows:

                       67+ (0.3104 * (67)(0.35)) <= 98
                              OR, as calculated:
                                  74.3 <= 98

Based on the above methodology, as outlined in the LMP option memo, the projected 31.04% VMT increase does not indicate that increased emissions from on-road mobile source could in the Columbia Falls PM10 NAAA, in the next 10 years, increase concentrations in the area and threaten the assumption of maintenance.

Kalispell Motor Vehicle Regional Emissions Analysis Calculation:
Utilizing a DV of 89; a projected 29.01% VMT increase; and a 0.80 fraction of the inventory represented by on-road mobile sources in the attainment year the results are as follows:

                       89+ (0.2901 * (89)(0.80)) <= 124
                              OR, as calculated:
                                 109.7 <= 124

Based on the above methodology, as outlined in the LMP option memo, the projected 29.01% VMT increase does not indicate that increased emissions from on-road mobile source could in the Kalispell PM10 NAA, in the next 10 years, increase concentrations in the area and threaten the assumption of maintenance.

Libby Motor Vehicle Regional Emissions Analysis Calculation:
Utilizing a DV of 92; a projected 11.56% VMT increase; and a 0.78 fraction of the inventory represented by on-road mobile sources in the attainment year the results are as follows:

                      92+ (0.1156 * (92)(0.78)) <= 139.9
                              OR, as calculated:
                                100.3 <= 139.9

Based on the above methodology, as outlined in the LMP option memo, the projected 11.56% VMT increase does not indicate that increased emissions from on-road mobile source in the Libby PM10 NAA could, in the next 10 years, increase concentrations in the area and threaten the assumption of maintenance.
