Je veux savoir à propos de…

khammond on DSKJM1Z7X2PROD with RULES

Federal Register / Vol. 86, No. 156 / Tuesday, August 17, 2021 / Rules and Regulations Comment B4: A commenter raises a number of concerns with regard to the sensitivity analysis that was provided as part of the States non-interference demonstration. The commenter asserts that the wrong inventory was used, stating that Tennessee used the outdated and inappropriate 2014
National Emission Inventory NEI for base year and future year emission assumptions, which the commenter claims is contrary to EPA guidance. The commenter states that EPA and others have concluded that 2014 is not useful for ozone sensitivity simulations, specifically asserting that 2014 was not conducive to ozone formation and did not contain high ozone periods adequate for an assessment of the impact of control technologies and air quality response. The commenter asserts that newer modeling platforms have been released with vastly improved estimates specifically citing to a 2016 NEI.27 The commenter specifically points to differences in NOX and VOC estimates in the later-released platforms, and provides a comparative analysis between the 2014 NEI and a 2016 NEI
for Hamilton County and the Middle Tennessee Area. The commenter acknowledges that the 2014 NEI was the most current version at the time that Tennessee conducted its analysis. The commenter recommends the analysis be revised using the most current modeling platform and associated emission projections, and specifically references the 2016 NEI. The commenter also recommends modeling be conducted using a meteorological and associated base year inventory that meets the requirements of EPA guidance for the determination of impact of control strategies and air quality response.
The commenter also claims that old and inappropriate assumptions were used, expressing concerns that the ozone sensitivity study was based on the 2007 SEMAP data projected to 2018.
The commenter asserts that the noninterference analysis misuses the SEMAP study and points toward language in the report stating that these factors should not be used for anything other than identical conditions to those in the SEMAP analysis. The commenter asserts that the demonstration assumes a similar response in 2022, and that there is no basis for this assumption. The commenter characterizes the information from the SEMAP report as brute force factors that are not 27 The commenters phrase 2016 NEI appears to refer to the 2016v1 emissions modeling platform produced by the National Emissions Inventory Collaborative.

VerDate Sep<11>2014

16:18 Aug 16, 2021

Jkt 253001

applicable because the factors are not tailored to the I/M removals in Hamilton County and the Middle Tennessee Area.
The commenter points to differences between SEMAP projections and actual emissions as reported in the 2016 NEI, expressing concern about the ratios of NOX and VOC used in the noninterference demonstration. The commenter further asserts that the SEMAP data underestimates the contribution of vehicles to the inventory as compared to the 2016
NEI. The commenter also asserts that recent modeling indicates that on-road emission increasesand specifically Tennessees motor vehicle source categoryhave a greater impact on regional air quality than what the demonstration calculates in part, due to the assumption that each ton of a precursor has an equal impact on ozone formation. The commenter concludes that the sensitivity factors used in the demonstration are not directly applicable to todays ozone conditions and likely not representative of the air quality change due to the removal of the I/M programs. The commenter further states that Tennessees recognition that its use of the scaling analysis would yield erroneous results should be adequate enough for the agency to reconsider using its analysis as a weight-of evidence approach to removal of the I/M program. If the analysis does not use air quality simulation, the commenter recommends an impact factor-like application to determine the impact of the removal of the I/M
program, with county and motor vehicle specific factors.
Response B4: As discussed above and in EPAs April 2021 SNPRM, EPA is not relying on Tennessees sensitivity analysis in its determination that removal of the I/M program will not interfere with any applicable requirement under the CAA. To the extent the commenter is asserting that the emissions comparison analysis should be conducted with more recent data, such as later versions of the NEI, EPA disagrees with the commenter. The 2014 NEI was the latest available emissions data and served as the baseline data for both Middle Tennessee Area and the Chattanooga Area. In addition, the 2014 NEI matches the base year used, which was the 2014
attainment year. While subsequent emissions data are available since EPA
received these SIP submissions, both areas continue to attain the NAAQS.
The 2014 NEI was developed consistent with EPA guidance and sufficiently serves as the basis for this demonstration. EPAs conclusion that
PO 00000

Frm 00027

Fmt 4700

Sfmt 4700

45881

removal satisfies CAA section 110l is based on the technical analysis as described in detail in the April 2021
SNPRM and summarized above.
Comment B5: A commenter discusses and compares a Georgia analysis to relax RVP requirements with the analysis to support removal of the Tennessee I/M
program. The commenter points to two aspects of the Georgia analysis that differ from the Tennessee analysis: The substitution of quantifiable, permanent, surplus, enforceable, and contemporaneous measures to achieve equivalent emissions reductions to offset potential emissions increases; and a demonstration that emissions are well below and will not exceed motor vehicle emissions budgets MVEBs. The commenter asserts that Tennessees analysis to remove the I/M program does not include offsets nor does the analysis calculate and provide additional support of meeting current and future year MVEBs. The commenter further asserts that the MVEBs for Hamilton County were never calculated, and that concern was expressed about the Middle Tennessee Area meeting the old MVEBs at the Nashville Area Interagency Consultation Group meetings. The commenter concludes that the request to remove the I/M
program does not have a supporting analysis comparable to Georgias and may fall short for EPA approval.
Response B5: EPA disagrees with these comments. With respect to the EPA-approved analysis to relax RVP
requirements in Georgia, EPA notes that section 110l analyses are case-specific, and in the case of Georgias request to relax RVP requirements for Atlanta, offsets were needed given the facts in that situation. See 84 FR 49470
September 20, 2019. Unlike Georgia, Tennessee has no areas designated as nonattainment or maintenance for the ozone NAAQS and does not currently have any violating ozone monitors. As discussed in the April 2021 SNPRM, EPA is concluding that removal of the I/M program from the Tennessee SIP
will not interfere with attainment or maintenance of the NAAQS or any other applicable requirement of the CAA.
In addition, motor vehicle emission budgets sometimes referred to in practice as MVEBs are a component of the regional emissions analysis for implementing transportation conformity requirements. See 40 CFR 93.101 and 93.118. These comments are not relevant to this rulemaking because neither Hamilton County nor the Middle Tennessee Area are required to demonstrate transportation conformity for any pollutant, and therefore, no such
E:FRFM17AUR1.SGM

17AUR1