Medford's LMP for CO SIP Submitted to EPA

DETP/19/27146

''Wednesday, July 24, 2019 at 4:00:50 PM (GMT+07:00) Goldstein, Meyer:'' Rule Caption: Medford Carbon Monoxide Limited Maintenance Plan Adm. Order No.: DEQ 14-2015 Filed with Sec. of State: 12-10-2015 Certified to be Effective: 12-10-15 Notice Publication Date: 9-1-2015 Rules Amended: 340-200-0040 Subject: In the 1970s and 1980s the Medford area violated the national air quality standard for carbon monoxide (CO). State and federal regulations applied measures that reduced CO concentrations. In 2002 the EPA redesignated Medford as meeting the CO standard. The redesignation included approval of the first Medford CO Maintenance Plan which demonstrated how the area would continue to meet the standard in the coming decade. EPA required the plan to include a budget for the amount of CO that vehicles operating on the future highway system could emit in coming decades. Each time a new transportation plan is adopted, planners must show that estimated CO emissions from the new highway system will remain within the budgeted amount. A second CO maintenance plan is now due under the Clean Air Act to address how the area will continue to meet the CO standard through September 23, 2022, the final maintenance plan period. In addition, DEQ recently discovered that the instructions by EPA’s consultant for calculating the motor vehicle emissions budget in the original plan were incorrect and the budget was set too low. When future vehicle emissions are estimated and compared to the emissions budget they exceed the allowable amount. This error prevents Medford from adopting a new transportation plan under the original maintenance plan. The situation can be corrected by revising the budget in the original plan or by adopting a new CO maintenance plan. Since a second CO maintenance plan is already due a new plan is the preferred way of correcting the error. CO monitoring was discontinued in Medford in 2009 because CO levels were well below the federal CO health standard, which is 27 percent of the federal CO limit. This low level of CO allows Medford to use the streamlined requirements of a “limited maintenance plan.” Under these streamlined requirements, a vehicle emissions budget is no longer required when preparing future transportation plans. DEQ, in consultation with EPA and the Rouge Valley Metropolitan Planning Organization (RVMPO), is presenting this new limited maintenance plan as the most efficient way to ensure continued compliance with the CO standard while supporting Medford’s transportation planning process and schedule. A significant benefit of this limited maintenance plan is that an emissions budget is no longer needed and the RVMPO can demonstrate conformity without a regional analysis. DEQ estimates this change will save the Rogue Valley MPO approximately $10,000 in unnecessary analysis costs every two years. Under this plan Medford will continue to meet the federal CO standard, while eliminating administrative requirements that are no longer needed to protect air quality. The limited maintenance plan updates Medford’s existing air quality plan, imposes no new control measures and saves the cost of emissions analyses that are no longer useful.