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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

 January 7, 2010

SUBJECT: Technical Support Document (TSD) - Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the 2009 Attainment Plan for the Delaware Portion of the 

Philadelphia 1997 Fine Particulate Matter(PM2.5) National Ambient Air Quality

Standard (NAAQS) Nonattainment Area 

FROM:

 /s/

Martin T. Kotsch 

Environmental Engineer (3AP30)

TO: Administrative Record for the Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the 2009 Attainment Plan for the Delaware portion of the 

Philadelphia 1997 PM2.5 NAAQS Nonattainment Area

THRU:

 /s/

Cristina Fernandez, Associate Director

Office of Air Program Planning (3AP30)

I. Administrative Requirements for Making Adequacy Findings 

We have followed the process for determining the adequacy of the submitted State 

Implementation Plan (SIP) Motor Vehicle Emissions Budgets (MVEBs) in accordance with the 

procedures listed in the January 2008 Conformity Regulations contained in 40 CFR Part 93.102 

(“Geographical applicability”) and 40 CFR Part 93.118(f) (“Adequacy review process for 

implementation plan submissions”).

By transmittal letter dated April 3, 2008, the State of Delaware formally submitted a 

2009 PM2.5 Attainment Demonstration Plan for the 1997 PM2.5 NAAQS (hereafter the 2009 

attainment plan) with mobile emissions budget for Nitrogen Oxides (NOx) and direct Particulate 

Matter (PM) for the Delaware portion of the Philadelphia 1997 PM2.5 NAAQS nonattainment 

area (hereafter, “the Delaware area”). 

Shown below in Table 1 are the budgets from the 2009 attainment plan submittal. 
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Table 1.

The Budgets of the Delaware 2009 Attainment Plan

Plan

Submittal

Milestone 

Year

Mobile Vehicle 

Emissions 

Budget for NOxTons Per Year

Mobile

Vehicle 

Emissions 

Budget for 

Direct PMTons Per 

Year

Attainment Plan 2009 4,904.0 87.0

II. Evaluation of the Adequacy of the MVEBs in the 2009 Attainment Plan for the 

Delaware Portion of the Philadelphia 1997 PM2.5 NAAQS Non-attainment Area Submitted 

By the Delaware Department of Natural Resources and Environmental Control

In this TSD, we are evaluating the MVEBs associated with the 2009 attainment plan and 

2010 Contingency Plan contained in the submittals for conformity purposes. We are using the 

evaluation criteria detailed in the Transportation Conformity Rule, 40 CFR Part 93.102(b)(2)(iv),

93.102(b)(2)(v), 93.102(b)(3) and Part 93.118(e)4 through 93.118(e)5. The evaluation is 

presented in Table 2, below.

Table 2.

Adequacy of the MVEBs Contained in the 2009 Attainment Plan for the Delaware Portion 

of the Philadelphia 1997 PM2.5 NAAQS

Transportation Conformity Rule

40 CFR Part 93, 93.118

Review Criteria Was the Criterion Satisfied? If 

Yes, How was this Criteria 

Satisfied?

93.102(b)(2)(iv) Has the EPA and the State 

made a finding that NOx is 

an insignificant contributor 

to the direct mobile PM 

emissions or does the

implementation plan fail to 

establish a NOx budget as 

part of the PM 2.5 attainment?

Neither EPA nor the State have 

made any findings that NOx is an

insignificant contributor to the 

PM2.5 mobile emissions and 

therefore it has been included in 

the SIP as a proposed mobile 

emissions budget for 2009.

93.102(b)(2)(v) Has the EPA or State made a 

finding that Volatile Organic 

Compounds (VOCs), Sulfur 

Oxides (SOx) or Ammonia 

(NH3) as precursors to be a 

significant contributor to the 

Neither EPA nor the State have 

made any findings that VOC’s, 

SOx or NH3 are a significant 

contributor to the PM2.5 mobile 

emissions and therefore it has not 

been included in the SIP as a 
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mobile PM emissions or does

the implementation plan 

submission establish a 

budget for VOCs, SOx or 

NH3 as part of a PM 2.5 

attainment strategy?

proposed mobile

93.102(b)(3) Has the EPA or the State 

made a finding that reentrained road dust is a 

significant contributor to the 

PM mobile emissions or does 

the implementation plan 

establish a budget that 

includes re-entrained road 

dust as part of a PM 2.5

attainment strategy?

Neither EPA nor the State have 

made any findings that reentrained road dust is a significant 

contributor to the PM2.5 mobile 

emissions, and therefore, it has 

not been included in the SIP as a 

proposed mobile emissions 

budget.

Sec. 93.118(e)(4)(i) Was the submitted revised 

plan endorsed by the 

Governor (or his or her 

designee) and subject to a 

State public hearing?

Yes. The submitted 2009 

Attainment Plan was endorsed and 

submitted as a SIP revision by the 

Governor’s designee, the 

Secretary of Delaware Department 

of Natural resources and 

Environmental Control. A public 

hearing on the SIP proposal was 

held by the State.

Sec. 93.118(e)(4)(ii) Before the attainment 

demonstration was submitted 

to EPA, did consultation 

between federal, State and 

local agencies occur; was full 

implementation plan 

documentation provided to 

EPA, and was EPA’s stated 

concerns, if any, addressed?

Yes. Consultation has occurred 

among all required Federal, State 

and local agencies.

Sec. 93.118(e)(4)(iii) Was the motor vehicle 

emissions budget(s) clearly

identified and precisely

quantified?

Yes, the budgets are clearly

identified on page 101 of the SIP 

submittal containing the 2009 

Attainment Plan.
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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 attainment 

demonstrations?

EPA believes the budgets can be 

declared adequate because in 

conjunction with the other 

emission reductions, they 

demonstrate attainment for 2009.

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 Plan?

EPA believes that the budgets are 

clearly related to the emissions 

inventory and the control 

measures in the SIP submittal.

Sec. 93.118(e)(4)(vi) Revisions to previously

submitted attainment 

demonstrations: 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).

N/A The area was designated 

nonattainment for this NAAQS 

for the first time in 2005 and this 

was the initial control strategy SIP 

submitted by the state to address 

the NAAQS.

Sec. 93.118(e)(5) Did they provide and we 

review public comments and 

the State’s responses to those 

comments with the submitted 

control strategy SIP?

There were no comments on the 

SIP related to the proposed mobile 

vehicle emissions budgets.

III. Findings - Based upon our review and evaluation of the MVEBs contained in the submittal 

of the 2009 attainment plan for the Delaware Portion of the Philadelphia 1997 PM2.5 NAAQS

nonattainment area, we find the said MVEBs adequate for conformity purposes. 
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IV. The Applicable Motor Vehicle Emissions Budgets for Purposes of Demonstrating 

Conformity for 2009 in the Delaware Area - The applicable motor vehicle emissions budgets

for purposes of demonstrating conformity are 4904.0 tons/year of NOx and 87.0 tons/year Direct 

PM for 2009.