8' £;!!~~~~~E~A~~O~CTION SECRETARY 

December 3, 2014 

Mr. Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street (Mail Code: 3RAOO) 

Philadelphia, PA 19103-2029 

Dear Mr. Garvin: 

I am pleased to submit to the U. S. Environmental Protection Agency a request to redesignate the 

Johnstown 1997 annual and 2006 24-hour fine particulate matter (PM2.s) nonattainment area to 

attainment, and a revision to the State Implementation Plan (SIP) including a Maintenance Plan 

demonstrating that the area can maintain the 1997 and 2006 PM2.s National Ambient Air Quality 

Standard (NAAQS) for at least ten years after redesignation, as required under Section 175A(b) 

of the Clean Air Act (CAA). The SIP submittal also includes the comprehensive emissions 

inventory required under Section 1 72( c )(3) of the CAA. 

The Department of Environmental Protection (DEP) opened a 30-day public comment period on 

October 4, 2014, on the proposed redesignation request, maintenance plan and comprehensive 

emissions inventory for the area. The public hearing scheduled for November 5, 2014, was 

cancelled because no one expressed interest in presenting testimony or attending the hearing. No 

comments were received during the public comment period. 

The following documents are enclosed for your approval: 

1. Request for Redesignation to attainment; 

2. Maintenance Plan State Implementation Plan revision, which includes the 

comprehensive emissions inventory and a Motor Vehicle Emissions Budget for the 

purposes of transportation conformity; and 

3. Certification of public participation activities. 

A paper copy of each document and a disc containing electronic copies are enclosed. I certify 

that the electronic files are exact duplicates of the hard copies. The Commonwealth followed all 

of the applicable procedural requirements of the State's laws and constitution in conducting and 

completing the issuance of the SIP revision. 

Rachel Carson State Office Building I P.O. Box 2063 I Harrisburg, PA 17105-2063 

717.787.2814 r:AJ. Printed on Recycled Pa per ~CJ www.depweb.state.pa.us 
Mr. Shawn M. Garvin -2- December 3, 2014 

Thank you in advance for the expeditious processing of the redesignation request and SIP 

revision. Should you have any questions or need additional information, please contact 

Joyce E. Epps, Director, Bureau of Air Quality, bye-mail atjeepps@pa.gov or by telephone at 

717.787.9702. 

~ 

Sincerely, 

Dana K. Aunkst 

Acting Secretary 

Enclosures 
Commonwealth of Pennsylvania

State Implementation Plan Revision: 

Maintenance Plan and 

Comprehensive Inventory 

Johnstown Nonattainment Area

1997 and 2006 Fine Particulate Matter

National Ambient Air Quality Standards

December 2014

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

www.dep.state.pa.us
This page intentionally left blank.
- i -

TABLE OF CONTENTS

I. Introduction and Overview ..................................................................................................1

A. Health and Environmental Effects of Fine Particulate Matter (PM2.5)....................1

B. Sources of PM2.5 and Precursor Pollutants of Concern............................................2

C. Purpose and Structure of this SIP Revision .............................................................5

D. Public Participation..................................................................................................9

II. Emission Inventories............................................................................................................9

A. Baseline Year (2005) Emissions............................................................................10

B. Attainment Year (2007) Emissions........................................................................12

C. Growth Projection Methodologies for 2017 and 2025 ..........................................15

E. Interim Year (2017) Emissions..............................................................................20

F. Maintenance Year (2025) Emissions.....................................................................20

G. Maintenance Plan Emissions Test .........................................................................21

III. Permanent and Enforceable Control Measures..................................................................22

A. Permanent and Enforceable Control Measures......................................................22

1. Stationary Point Sources............................................................................25

2. Highway Vehicle Sources..........................................................................31

3. Nonroad Sources........................................................................................34

4. Stationary Area Sources.............................................................................35

B. Motor Vehicle Emission Budgets for Transportation Conformity ........................37

IV. Ambient Air Quality Monitoring Network........................................................................40

V. Verification of Continued Attainment ...............................................................................40

VI. Contingency Measures.......................................................................................................41

TABLES

Table II-1: Johnstown Area 2005 Annual Emissions (Tons per Year)........................................ 11

Table II-2: Johnstown Area 2007 Annual Emissions (Tons per Year)........................................ 15

Table II-3: Johnstown Area VMT (Miles) and Vehicle Emissions (Tons per Year)................... 19

Table II-4: Johnstown Area Projected 2017 Emissions (Tons per Year) .................................... 20

Table II-5: Johnstown Area Projected 2025 Emissions (Tons per Year) .................................... 21

Table II-6: Johnstown Area Maintenance Emissions Test .......................................................... 22

Table III-1: Summary of Emission Reductions (Tons) from 2007 to 2025 from Control 

Measures................................................................................................................... 24

Table III-2: Motor Vehicle Emission Budgets (Tons per Year).................................................. 38

Table III-3: Comparison of Safety Margin to Total Anticipated Emission Reductions in 

2017 and 2025 .......................................................................................................... 39

Table III-4: Comparison of 2025 On-Road Mobile VOC, NH3, and SO2 Emissions to the 

Total Projected 2025 Inventory ................................................................................ 39

FIGURES

Figure 1. Pie Chart of 2012 Johnstown Speciation Data ............................................................. 40
- ii -

APPENDICES

APPENDIX A: STATIONARY POINT SOURCES

A-1 Methodology – Preparation of Pennsylvania Point Source Inventories and 

Instructions for Completing the Annual Emissions Reporting Forms

A-2 2005 Emissions Inventory

A-3 Facility Annual Emissions – 2007, 2017, 2025

APPENDIX B: STATIONARY AREA SOURCES 

B-1 Pennsylvania 2007 Area Source Criteria Air Pollutant Emission Estimation 

Methods (Dec. 2009) 

B-2 Area Source Annual Emissions – 2007, 2017, 2025

B-3 Marcellus Shale Emissions Methodology

APPENDIX C: REGIONAL EMISSIONS INVENTORY AND PROJECTION

METHODOLOGY

C-1 Technical Support Document for the Development of the 2007Emission 

Inventories for Regional Air Quality Modeling in the Northeast/Mid-Atlantic 

Region Version 3.3 (AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012)

C-2 Technical Support Document for the Development of the 2017/2020 Emission 

Inventories for Regional Air Quality Modeling in the Northeast/Mid-Atlantic 

Region Version 3.3 (AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012)

C-3 Technical Support Document for the Development of the 2025 Emission 

Inventory for PM Nonattainment Counties in the MANE-VU Region 

Version 3.3 Rev. 1 (AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012)

C-4 Technical Memo Emission Factors for Condensable PM

APPENDIX D: HIGHWAY VEHICLE SOURCES INVENTORY INFORMATION

D-1 Mobile Source Highway Emissions Inventory – An Explanation of 

Methodology

D-2 Highway Emissions Estimates –2007, 2017, 2025

D-3 MOVES Input Parameter Summary

D-4 MOVES Input and Output Files

APPENDIX E: NONROAD SOURCES

E-1 Nonroad Source Emissions – 2007, 2017, 2025
- 1 -

I. INTRODUCTION AND OVERVIEW

A. Health and Environmental Effects of Fine Particulate Matter (PM2.5)

Particulate matter (PM) is a mixture of microscopic solids and liquid droplets 

suspended in air that include: acids (such as nitrates and sulfates), organic 

chemicals, metals, soil or dust particles and allergens (such as fragments of pollen 

or mold spores). Fine particulates or PM2.5 describes particulate matter that is less 

than or equal to 2.5 micrometers (μm) in diameter, approximately 1/30th the 

diameter of a human hair. Because of their small size, fine particles can penetrate 

deeply into the lungs.

Health studies have shown a significant association between exposure to fine 

particles and premature death from heart or lung disease. Fine particles can 

aggravate heart and lung diseases and have been linked to effects such as 

cardiovascular symptoms, cardiac arrhythmias, heart attacks, respiratory 

symptoms, asthma attacks, and bronchitis. These effects can result in increased 

hospital admissions, emergency room visits, absences from school or work, and 

restricted activity days. Individuals that may be particularly sensitive to fine 

particle exposure include people with heart or lung disease, older adults, and 

children. The article “Fine-Particulate Air Pollution and Life Expectancy in the 

United States” by C. Arden Pope, III, et al. published January 22, 2009, in the

New England Journal of Medicine evaluated the role PM2.5 reductions occurring

in the 1980s and 1990s had on the increased life expectancy observed over that 

period. The study found that a reduction of 10 micrograms per cubic meter 

(μg/m3) of PM2.5 was associated with an average increase in life expectancy of 

7.3 months.

PM2.5 has significant environmental impacts, including acid rain and stream 

eutrophication. PM2.5 also affects visibility (regional haze) through the scattering 

and absorption of light. Fine particles, similar in size to the wavelength of light, 

are most efficient, per unit of mass, at reducing visibility. Soiling and materials 

damage can also be caused by PM2.5 in the air.

The United States Environmental Protection Agency (EPA) promulgated PM2.5

National Ambient Air Quality Standards (NAAQS) in 1997 after evaluating 

hundreds of health studies and conducting an extensive peer review process. The 

EPA established an annual primary (health-based) and secondary (welfare-based) 

standard of 15.0 μg/m3, based on the 3-year average of annual mean PM2.5

concentrations. The EPA also established a primary and secondary 24-hour 

standard of 65 μg/m3determined by the 3-year average of the 98th percentile of 

24-hour concentrations. In 2006, the EPA promulgated a revised 24-hour PM2.5

standard of 35 μg/m3determined by the 3-year average of the 98th percentile of 

24-hour concentrations. The annual PM2.5 standard was not revised (71 FR 61144

(October 17, 2006)).
- 2 -

On December 17, 2004, the EPA issued air quality designations for the 1997 

PM2.5 standard based on 2001-2003 air quality monitoring data. The final 

designations were published in the Federal Register on January 5, 2005 

(70 FR 944). The designations became effective on April 5, 2005. The EPA 

designated eight areas comprised of all or portions of 21 counties in Pennsylvania 

as PM2.5 nonattainment areas. On April 5, 2005, the EPA published a 

supplemental notice changing the designation of certain areas from nonattainment 

to attainment based on newly available PM2.5 quality-assured and certified air 

quality data from 2002-2004. The EPA supplemental notice was published in the 

Federal Register on April 14, 2005 (70 FR 19844). Mercer County was the only 

county in the Commonwealth of Pennsylvania (Commonwealth or Pennsylvania) 

for which EPA changed the designation for the area from nonattainment to 

attainment based on the 2002-2004 air quality data.

The Johnstown Area, consisting of Cambria County and portions of Indiana 

County1, was one of eight areas in Pennsylvania designated by the EPA as 

nonattainment for the 1997 PM2.5 NAAQS. The Johnstown Area was designated 

nonattainment because the area violated the 1997 annual PM2.5 standard of 

15.0 μg/m3based on 2001-2003 monitoring data. The Johnstown Area did not 

violate the 1997 24-hour PM2.5 NAAQS of 65 μg/m3.

On October 8, 2009, the EPA promulgated air quality designations for the 2006 

PM2.5 standard based on 2006-2008 air quality monitoring data. The final 

designations were published in the Federal Register on November 13, 2009

(74 FR 58688). The EPA designated seven areas comprised of all or portions of 

22 counties in Pennsylvania as PM2.5 nonattainment areas. The designations 

became effective on December 14, 2009. 

The Johnstown Area was one of seven areas in Pennsylvania designated by the 

EPA as nonattainment for the 2006 PM2.5 NAAQS. The Johnstown Area was 

designated nonattainment because the area violated the 2006 24-hour PM2.5

standard of 35 μg/m3based on 2006-2008 monitoring data. 

On April 25, 2014, the EPA finalized a rule to classify areas currently designated 

nonattainment for the 1997 and 2006 PM2.5 NAAQS as “moderate.” The final 

rule was published in the Federal Register on June 2, 2014 (79 FR 31566). The 

EPA classification of the nonattainment areas as “moderate” was as a result of a 

decision of the U.S. Court of Appeals for the D.C. Circuit regarding Subpart 4 of 

Part D of the Clean Air Act, which is discussed in more detail later in this 

document.

B. Sources of PM2.5 and Precursor Pollutants of Concern

Fine particulate matter can be emitted directly or formed secondarily in the 

atmosphere. PM2.5 emitted directly into the air in a stable solid or liquid chemical 

 

1 Townships of West Wheatfield, Center, East Wheatfield, and Armagh Borough and Homer City Borough
- 3 -

form (including PM2.5 that is formed near its source by condensation) is referred 

to as “primary” PM2.5. PM2.5 is formed by chemical reactions of gases in the 

atmosphere is considered to be “secondary” PM2.5. The chemical composition of

PM2.5 in an area depends on the mix of emissions, location, time of year, and 

weather. The chemical composition of PM2.5 can include sulfate, nitrate, 

ammonium, particle-bound water, black (elemental) carbon, a great variety of 

organic compounds, and miscellaneous inorganic material, such as dust and 

metals.

Primary PM2.5 includes soot from diesel engines, condensed organic material 

from incomplete combustion and compounds from condensation during 

combustion or smelting.

The atmospheric chemistry of PM2.5 formation is complex. Formation of 

secondary PM2.5 depends on numerous factors, including the relative 

concentration of precursors, atmospheric conditions and the interactions of 

precursors with each other and with other particles, clouds or fog. The 

contribution of different precursors will vary by location.

The principal forms of secondary PM2.5 include:

 Sulfates, formed from emissions of sulfur dioxide (SO2) from power 

plants and industrial facilities;

 Nitrates, formed from emissions of nitrogen oxides (NOX) from power 

plants, vehicles, and other combustion sources;

 Ammonium, formed primarily from emissions of ammonia (NH3) from 

animal operations; and

 Secondary organic aerosol, formed from emissions of volatile organic 

compounds (VOCs) from incomplete combustion and evaporation from a 

wide diversity of sources.

Because of the complexity and variability of the process of particulate matter 

formation, the EPA recognizes that the chemical and physical properties of 

particulate matter vary greatly with time, region, meteorology and source 

category.2 Therefore, effective control measures for PM2.5 will vary among

nonattainment areas. 

By way of background, the EPA’s “Implementation Guidance for the 2006 

24-Hour Fine Particle National Ambient Air Quality Standard,” Office of Air 

Quality Planning and Standards, the EPA was issued on March 2, 2012 (later 

withdrawn). In the Implementation Guidance for the 2006 PM2.5 NAAQS, the 

EPA adopted the framework and policy approach the agency espoused in its 

implementation rule for the 1997 PM2.5 NAAQS, known as the “Clean Air Fine 

 

2 National Ambient Air Quality Standards for PM2.5, 71 FR 61144, October 17, 2006
- 4 -

Particle Implementation Rule” (72 FR 20586; April 25, 2007) (“Implementation 

Rule for the 1997 PM2.5 NAAQS”). 

In its Implementation Rule for the 1997 PM2.5 NAAQS, the EPA had established 

general presumptive policies for assessing which PM2.5 precursors should be 

evaluated for possible controls.3 In that earlier rule, the EPA required states to 

evaluate control measures for SO2 and primary PM2.5 in all locations. The EPA 

required states to evaluate control measures for NOX unless a technical 

demonstration is made to show that NOX emissions from sources in the state do 

not significantly contribute to PM2.5 concentrations in the nonattainment area. 

The EPA required states to evaluate measures for VOC and NH3 only if a 

technical demonstration is made to show VOC or NH3 emissions significantly 

contribute to PM2.5 in the nonattainment area. 

The EPA reaffirmed the appropriateness of these presumptions in the

Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS. Meanwhile, the 

U.S. Court of Appeals for the D.C. Circuit was considering a challenge to the 

Implementation Rule for the 1997 PM2.5 NAAQS, in Natural Resources Defense 

Council v. EPA, No. 08-1250. On January 4, 2013, the Court handed down its 

ruling in that case. The Court granted the petitions for review and remanded the 

case to the EPA to re-promulgate the rule pursuant to Subpart 4 of Part D of the 

Clean Air Act, rather than implementing it under Subpart 1, as the EPA had done 

(706 F.3d 428 at 437 (DC Cir. 2013)).

Shortly thereafter, the EPA withdrew its Implementation Guidance for the 2006 

24-hour PM2.5 NAAQS. According to the EPA’s June, 2013, withdrawal 

memorandum4, the EPA withdrew the guidance in response to the Court’s 

decision in Natural Resources Defense Council v. EPA, No. 08-1250.

This Maintenance Plan demonstrates maintenance of the standards consistent with 

the Court’s ruling. In general, the Court’s decision (for the 1997 NAAQS and to 

the extent it would be extrapolated to the 2006 24-Hour PM2.5 NAAQS) could 

affect an area’s nonattainment classification, certain deadlines, and the impacts of 

failing to attain timely, and could impose a deadline for implementation of 

reasonably available and best available control measures (706 F.3d at 436, n. 6).

Since the Johnstown Area is already attaining the 1997 annual and 2006 24-Hour 

PM2.5 NAAQS, however, those considerations are not relevant for this 

Maintenance Plan. The Court noted that PM2.5 precursors, including NH3 and 

VOCs, are presumptively regulated in PM2.5 nonattainment areas under Subpart 4, 

pointing specifically to Section 189(e), which applies to control of major 

 

3 The EPA’s definition of “PM2.5 attainment plan precursor” can be found in 40 CFR §51.1000, which reads: “PM2.5

attainment plan precursor means S02 and those other PM2.5 precursors emitted by sources in the State which the 

State must evaluate for emission reduction measures to be included in its PM2.5 nonattainment area or maintenance 

area plan.”

4 “Withdrawal of Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air 

Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013.
- 5 -

stationary sources of PM10 [the court stated that PM10 includes PM2.5 throughout 

Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to CAA 

Section 189(e), control requirements applicable for major stationary sources of 

PM10 also apply to major stationary sources of PM10 precursors, except where the 

Administrator determines that major stationary sources do not contribute 

significantly to PM10 levels that exceed the standard in the area; Section 189(e) 

also requires the EPA to issue guidelines regarding the application of 

Subsection (e). 

Pennsylvania assessed emissions of PM2.5, SO2, NOX, VOC and NH3 for the 

maintenance demonstration. 

This revision to the State Implementation Plan (SIP) provides emissions 

information for all pollutants (PM10, PM2.5, SO2, NOX, VOC and NH3), as 

required by the EPA’s guidance entitled, “Emissions Inventory Guidance for 

Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations.”

5

C. Purpose and Structure of this SIP Revision

In December 2004, after consultation with states and receipt of public input, the 

EPA designated eight areas in Pennsylvania, comprising all or parts of 

21 Pennsylvania counties, as PM2.5 nonattainment areas for the 1997 PM2.5

NAAQS based on 2001-2003 air quality monitoring data. Under Section 110 of 

the Clean Air Act (CAA), Pennsylvania is required to develop a revision to the 

SIP to demonstrate how the Johnstown Area will attain the 1997 standard by

April 2010, meet emission reduction requirements in the CAA and ensure that in 

the event of a future violation or failure to meet emission reduction milestones, 

the area is brought back to attainment as quickly as possible.

However, on September 25, 2009, the EPA determined that the Johnstown Area 

had attained the 1997 PM2.5 NAAQS based on quality assured, quality controlled 

and certified ambient air monitoring data that show the area had monitored 

attainment based on 2006-2008 data (“Clean Data Determination”)

(74 FR 48863). This final action suspended the requirements for Pennsylvania to 

submit an attainment demonstration for this area and and associated reasonably 

available control measures, reasonable further progress plans, contingency 

measures and other planning SIP revisions related to the attainment of the 1997 

PM2.5 NAAQS for so long as the area continues to attain the 1997 PM2.5

NAAQS6.

 

5 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations – EPA-454/R-05-001, August, 2005, updated November, 2005.

6 The EPA followed this action on July 29, 2011 (76 FR 45424) with a statutorily required determination under 

Section 179(c) of the CAA, that the Johnstown Area attained the 1997 PM2.5 NAAQS by the applicable attainment 

date of April 5, 2010. The EPA based this determination on complete, quality assured, and certified ambient air 

monitoring data that show the area monitored attainment for the 2007-2009 monitoring period.
- 6 -

On November 13, 2009, the EPA designated seven areas in Pennsylvania,

comprising all or parts of 22 Pennsylvania counties, as 2006 PM2.5 NAAQS

nonattainment areas based on 2006-2008 air quality monitoring data 

(74 FR 58688). Section 110 of the CAA requires Pennsylvania to develop a 

revision to the SIP to demonstrate how the Johnstown Area will attain the 

standard by December 2014, meet emission reduction requirements in the CAA 

and ensure that in the event of a future violation or failure to meet emission 

reduction milestones, the area is brought back to attainment as quickly as 

possible.

On March 29, 2012, the EPA determined that the Johnstown Area had attained the 

2006 PM2.5 NAAQS based on quality assured, quality controlled and certified 

ambient air monitoring data that show the area had monitored attainment based on 

2008-2010 data (“Clean Data Determination”) (77 FR 18922). The final Clean 

Data Determination suspended the requirements for this area to submit an 

attainment demonstration and associated reasonably available control measures, 

reasonable further progress plans, contingency measures and other planning SIP 

revisions related to the attainment of the 2006 PM2.5 NAAQS for so long as the 

area continues to attain the 2006 PM2.5 NAAQS.

The EPA’s determination of attainment and the Clean Data Determinations did

not “redesignate” the area as “attainment.” The Johnstown Area remains a 

designated nonattainment area for the 1997 and 2006 PM2.5 NAAQS until the 

Commonwealth submits, and the EPA approves, a Request for Redesignation and 

a Maintenance Plan showing the area can maintain the standards for at least 

10 years after redesignation. Nonattainment new source review continues to 

apply until the EPA redesignates the area to attainment (72 FR 20603).

Transportation conformity and general conformity also apply; they will continue 

to apply to the area even after redesignation by the EPA as attainment. The Clean 

Data Determinations do not suspend the CAA Section 172(c)(3) requirement to 

establish a comprehensive inventory for all pollutants considered potential 

precursors to PM2.5 and for direct emissions of PM2.5.

This SIP revision includes the Maintenance Plan for the Johnstown Area for the 

1997 and 2006 PM2.5 NAAQS and the 2007 comprehensive inventory required

under Section 172(c)(3) of the CAA for point, area, highway and nonroad sources 

of direct PM2.5, PM10 (particles less than 10 microns in diameter), SO2, NOX, 

VOC and NH3. The 2007 comprehensive inventory also serves as the attainment 

year inventory representing a level of emissions sufficient for the Johnstown Area 

to attain the 1997 and 2006 PM2.5 NAAQS.

To demonstrate maintenance of the PM2.5 NAAQS for this area, Pennsylvania is

showing that the future emissions of PM2.5 and its precursors will remain at levels 

that will provide for maintenance of the PM2.5 NAAQS for at least 10 years after 

redesignation, taking economic, population and travel growth into account (See, 

“Procedures for Processing Requests to Redesignate Areas to Attainment,” John 
- 7 -

Calcagni, EPA (September 4, 1992) (1992 Calcagni Memo)). This Maintenance 

Plan contains an attainment year inventory for 2007 and demonstrates that 

emissions will not be greater in 2017 and 2025 than the attainment year. The plan 

describes emission reduction measures that have been previously adopted; it 

neither changes existing measures nor adopts additional measures. The plan 

indicates how Maintenance Plan progress will be tracked and identifies measures

that would be available to promptly correct any NAAQS violation.

Section 107(d)(3)(E) of the CAA requires that a Maintenance Plan be fully 

approved by the EPA before an area can be redesignated as attainment. The 

Maintenance Plan is considered a SIP revision under Section 110 of the CAA. A 

state may submit the Request for Redesignation and the Maintenance Plan at the 

same time and federal rulemaking on both may proceed on a parallel track.

Pursuant to Section 107(d)(3)(E) of the CAA, the Request for Redesignation 

submitted concurrently with this Maintenance Plan indicates that the Johnstown 

Area has attained the NAAQS and that attainment was due to permanent and 

enforceable control measures. The Request for Redesignation also demonstrates 

that the Commonwealth has met all of the regulatory and planning requirements 

under the CAA for the Johnstown Area that were due before the date of the 

Request for Redesignation.

In Section 5 of the 1992 Calcagni Memo, the EPA recommends the following to 

ensure maintenance of the NAAQS:

 The state should continue to operate an appropriate air quality monitoring 

network in order to verify the area’s attainment status (addressed in 

Section IV of this Plan);

 The state should develop an emissions inventory to identify the level of 

emissions sufficient to attain the NAAQS. This “attainment year 

inventory” was developed for 2007;

 The state may demonstrate maintenance by showing that the future 

emissions of a pollutant or its precursors will not exceed the level of the 

attainment inventory over at least 10 years following redesignation, taking 

economic growth into account. The Pennsylvania Department of 

Environmental Protection (DEP or Department) has developed emission 

inventories for 2025 and for 2017, an interim year between the attainment 

year and the maintenance year (addressed in Section II of this Plan);

 The Commonwealth should ensure that it has the legal authority to 

implement and enforce all measures necessary to attain and maintain the 

NAAQS, and indicate how Maintenance Plan progress will be tracked 

(addressed in Sections III and V of this Plan and the Request for 

Redesignation); and
- 8 -

 The Commonwealth should identify measures that would be available to 

promptly correct any NAAQS violation (addressed in Section VI of this 

Plan).

The Maintenance Plan describes how the Commonwealth will meet those criteria.

This Maintenance Plan demonstrates that the 1997 and 2006 PM2.5 NAAQS will 

be maintained for at least 10 years after redesignation of the Johnstown Area to 

attainment of the standards, as required under Section 175A of the CAA. The

Maintenance Plan shows that emission levels of PM2.5 and its precursors over the 

10 years following redesignation remain at levels that will provide for 

maintenance of the PM2.5 NAAQS, even considering growth in population and 

vehicle miles traveled.

This Maintenance Plan also shows that the following state and federal programs 

will ensure the continuing decrease of PM2.5, SO2, NOX and VOC emissions:

 The Clean Air Interstate Rule (CAIR);

 Emission limits for large industrial boilers;

 State regulation of cement kilns, large stationary internal combustion 

engines, and smaller sources of NOX;

 State regulations incorporating by reference the federal Prevention of 

Significant Deterioration (PSD) regulations;

 State requirements for Best Available Technology (BAT);

 State regulation of the sulfur content of fuel oil;

 State regulation of VOC emissions from adhesives, sealants, primers and 

solvents;

 State regulation of new natural gas compression and/or processing 

facilities;

 The Pennsylvania and federal new motor vehicle emission control 

programs for passenger and light-duty trucks;

 The Pennsylvania and federal heavy-duty diesel emission control 

programs;

 Federal fuel programs for highway vehicles and nonroad mobile 

equipment; and

 Federal regulation of offroad diesel and gasoline-powered vehicles and 

equipment.

The emission reductions from the following programs were not included in the 

2017 and 2025 emission inventories and, thus, were not relied upon for the 

demonstration of maintenance. However, emission reductions from these 

measures may nonetheless assist the Johnstown Area in maintaining the 1997 and 

2006 PM2.5 NAAQS.
- 9 -

 The Diesel-Powered Motor Vehicle Idling Act, Act 124 of 2008 (Idling 

Act) was approved by the EPA as a SIP revision on August 1, 2011 

(76 FR 45705). 

 NOX and VOC emission reductions from Pennsylvania’s Outdoor WoodFired Boilers regulation. The Outdoor Wood-Fired Boiler regulation was 

published in the Pennsylvania Bulletin on October 2, 2010 

(40 Pa.B. 5571), and approved by the EPA as a SIP revision on 

September 20, 2011 (76 FR 58114). 

 The federal Tier 3 Motor Vehicle Emission and Fuel Standards program 

(79 FR 23414). 

In this Maintenance Plan, the Department provides assurances that it will continue 

to operate the ambient air quality monitoring network in order to track 

maintenance of the standards and to evaluate emissions inventories periodically 

compared to the projections provided in the Plan. The Department also provides a 

list of potential contingency measures that it would consider to correct any 

violation of the NAAQS that occurs after redesignation of the area.

Eight years following redesignation, the Commonwealth will submit a revised 

plan that ensures attainment of the 1997 and 2006 PM2.5 NAAQS through 2035.

D. Public Participation

Requirements for a public comment process are set forth in Section 110(a)(2) of 

the CAA, 40 CFR §51.102(d) and Section 7.5 of the Pennsylvania Air Pollution 

Control Act (35 P.S. §4007.5(b)). On October 4, 2014, the Department provided 

notice of a public comment period and the opportunity for a hearing on the 

Johnstown Area Maintenance Plan for the 1997 and 2006 PM2.5 NAAQS, the 

2007 comprehensive inventory required by Section 172(c)(3) of the CAA, and the 

Request to Redesignate the Johnstown Area to attainment for the 1997 and 2006 

PM2.5 standards. The Department scheduled the public hearing to occur on 

November 5, 2014, but no one expressed interest in presenting testimony or

attending. Therefore, the Department cancelled the hearing. The public comment 

period closed November 7, 2014. No comments were received during the public 

comment period.

II. EMISSION INVENTORIES

To demonstrate maintenance of the 1997 and 2006 PM2.5 NAAQS for the Johnstown

Area, Pennsylvania is showing that the future emissions of PM2.5 and its precursors will 

remain at levels that will provide for maintenance of the PM2.5 NAAQS for at least 

10 years, taking economic, population and travel growth into account. This Maintenance 

Plan contains an attainment year inventory for 2007 and demonstrates that emissions will 
- 10 -

not be greater than the attainment year in 2017 and 2025.

7

This Maintenance Plan also 

contains a 2005 baseline inventory that represents the emissions present when the 

Johnstown Area did not meet the 1997 and 2006 PM2.5 NAAQS. In addition, this SIP 

revision fulfills the requirement for a comprehensive inventory for the Johnstown Area 

under 40 CFR §51.1008 to meet the requirements of Section 172(c)(3) of the CAA. As 

specified by the EPA, the pollutants inventoried by Pennsylvania include direct PM2.5, 

PM10, SO2, NOX, VOC, and NH3. Information on the manmade sources of these 

pollutants was compiled for:

 “Stationary point sources” (or “point” sources), which are sources for which the 

Department collects individual emissions-related information. Generally, they 

represent major stationary sources but may be smaller.

 “Stationary area sources,” which are industrial, commercial, and residential 

sources too small or too numerous to be handled individually. These include, but 

are not limited to, commercial and residential open burning, architectural and 

industrial maintenance coatings application and clean-up, consumer product use, 

and vehicle refueling at service stations. Where there is overlap between 

stationary point sources and stationary area sources, the area source values are 

adjusted to remove any double counting.

 “Highway vehicles,” which include passenger cars and light-duty trucks, other

trucks, buses and motorcycles.

 “Nonroad sources,” which encompass a diverse collection of engines, including,

but not limited to, outdoor power equipment, recreational vehicles, farm and 

construction machinery, lawn and garden equipment, industrial equipment, 

recreational marine vessels, commercial marine vessels, locomotives, ships, and 

aircraft.

Pennsylvania and other Northeastern and Mid-Atlantic states participated in a regional 

effort to refine the emissions inventory and to compile a regional emissions inventory. 

The Mid-Atlantic Regional Air Management Association (MARAMA) coordinated that 

regional effort, which allowed states to pool their resources to compile a regional

emissions inventory for the purpose of conducting the regional modeling analysis used in 

Pennsylvania’s air quality management planning efforts to attain the 8-hour ozone 

NAAQS and the PM2.5 NAAQS, and to prepare the regional haze plan.

A. Baseline Year (2005) Emissions

An emission inventory is an estimate of the emissions from sources in a particular 

area. The 2005 baseline year emissions inventory represents the emissions 

present during a time period when the Johnstown Area did not meet the 1997 and 

2006 PM2.5 NAAQS. The Department considered using 2002 as the baseline year; 

 

7 Throughout this document, emissions inventory data was rounded to the nearest tenth of a ton prior to 

summarizing the emissions inventory data.
- 11 -

however, emissions from the Homer City electric generating facility were 

uncharacteristically low in 2002, so the Department opted to use 2005 as the 

baseline year. The 2005 National Emissions Inventory (NEI) was the next 

available periodic emission inventory developed by the EPA. 

The 2005 NEI is a composite of emission estimates reported by state and local 

agencies and industry, as well as estimates generated by the EPA. The 2005 NEI 

was based in part on information submitted by the Department under the 

Consolidated Emissions Reporting Rule (CERR), which was published in the 

Federal Register on Monday, June 10, 2002 (67 FR 39602). The CERR required 

States to prepare and submit a comprehensive statewide inventory every three 

years. 

The 2005 baseline year inventory includes the pollutants PM10, PM2.5, SO2, NOX, 

VOC, and NH3. The inventory consists of sources in four sectors: electric 

generating units (EGUs), non-EGU point and stationary area sources, highway 

vehicle sources and nonroad sources. 

Highway vehicle emissions in the 2005 NEI were generated using the MOBILE6 

model. It is problematic to compare results generated by MOBILE6 to results 

generated by MOVES2010 (Motor Vehicle Emission Simulator). For the same 

Vehicle Miles Traveled (VMT) and other parameters, the MOBILE6 model 

predicts higher VOC and significantly lower NOX and PM2.5 emissions than 

MOVES2010, which was used to generate the 2007, 2017 and 2025 inventories. 

In addition, the Department’s MOVES2010 runs use more detailed road segment 

data necessary to properly apportion the emissions to the partial Indiana County 

portion of the nonattainment area. Therefore, the Department did not use the 

2005 NEI emission estimates for highway vehicle emissions. Instead, the 

Department linearly interpolated MOVES2010 emission estimates for the 

Johnstown Area that were available for 2002 and 2007.

The NEI data can be accessed at: 

http://www.epa.gov/ttnchie1/net/2005inventory.html. Appendix A-2 contains 

summary data for 2005. Table II-1 summarizes the emissions for 2005.

Table II-1: Johnstown Area 2005 Annual Emissions (Tons per Year)

Johnstown 2005 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 11,872.3 14,854.9 152,657.3 41,646.4 343.4 5.0

Area Sources 1,200.9 5,997.3 1,858.7 750.7 3,092.4 511.2

Highway Vehicle Sources 141.8 169.4 61.2 4,482.7 1,919.1 67.1

Non-Road Sources 84.2 89.2 111.8 1,363.8 944.8 0.8

Totals 13,299 21,111 154,689 48,244 6,300 584
- 12 -

B. Attainment Year (2007) Emissions

Stationary Point Sources. The 2007 stationary point source inventory was based 

on emissions reported to the Department by the owners and operators of facilities.

The Department requires owners and operators of larger facilities to submit 

annual production figures and emission calculations each year. Throughput data 

are multiplied by emission factors from the Factor Information Retrieval (FIRE) 

Data System and the EPA’s publication series AP-42 and are based on Source 

Classification Code (SCC). Each process has at least one SCC assigned to it. If 

the owners and operators of facilities provide more accurate emission data based 

upon other factors, these emission estimates supersede those calculated using 

SCC codes. Appendix A-1 includes information on stationary point source 

emission methodology, and Appendix A-3 includes the data set for facility 2007 

annual emissions, as well as projected facility emissions for 2017 and 2025.

Condensable PM is a vapor or gas at stack temperature that condenses to a liquid 

or solid at stack exit. Condensable emissions from electric generating units 

(EGUs) were not reported uniformly by all facilities. Because of the need to 

consider the effect of condensable emissions from EGUs on regional haze and 

fine particles, the 2007 inventory data was augmented, utilizing the condensable 

emission factors for EGUs developed for MARAMA in 2008 to calculate 

condensable PM emissions where that data was missing. Appendix C-4 contains 

the technical memorandum describing how the emission factors were developed. 

The general process is to use the emission factors and heat input to calculate the

condensable PM (PM-CON) emissions, and then to perform the gap filling for 

compounds missing from the facility-reported emissions.

Stationary Area Sources. Stationary area source emissions are generally 

estimated by multiplying an emission factor by some known indicator or 

collective activity for each area source category at the county level. Pennsylvania 

estimates emissions from stationary area sources using emission factors and SCC 

codes in a method similar to that used for stationary point sources. Emission 

factors may also be derived from research and guidance documents if those 

documents are more accurate than FIRE and AP-42 factors. Throughput 

estimates are derived from county-level activity data, by apportioning national or 

statewide activity data to counties, from census numbers, and from county 

employee numbers. County employee numbers are based upon North American 

Industry Classification System (NAICS) codes to establish that those numbers are 

specific to the industry covered.

The EPA emissions inventories and emission estimation tools were used to create 

the 2007 area source inventory. For many area source categories, the most recent 

EPA data was used. These categories included ammonia emissions from 

livestock and fertilizers which came from a recent application of the Carnegie 

Mellon University (CMU) ammonia model to produce 2007 emissions; output 

from a version of the Residential Wood Combustion (RWC) model developed by 
- 13 -

the EPA and run with updated 2007 data to produce emission estimates for that 

source category; and the EPA data on wildfire emissions developed as part of 

EPA’s SMARTFIRE system. The EPA develops area source emission estimation 

methodologies and estimates for the NEI on a three-year cycle. Where 2008 NEI 

data were used to fill in missing categories in the 2007 inventory, no growth 

adjustment was made to the emissions with the assumption that activity in 2008 

and 2007 was similar.

For fugitive dust area sources, the 2007 inventory was adjusted to apply the EPA 

PM “transport factors” to fugitive dust sources.

Appendix B-1 contains the methodology for the 2007 Pennsylvania area source 

inventory. Additional methodology information is available in the technical 

support document for the 2007 regional inventory which is contained in 

Appendix C-1. Appendix B-2 contains the stationary area source emissions data

for 2007, 2017 and 2025 for the Johnstown Area.

Highway Vehicle Sources. The EPA’s MOVES2010 is the official model for 

estimating air pollution emissions from onroad mobile sources including buses, 

cars, trucks and motorcycles. MOVES2010 replaces MOBILE6.2, the previous 

mobile source emissions model. Therefore, the Department employed 

MOVES2010 to estimate the onroad emissions inventory for 2007, 2017, and 

2025.

Additional information on highway emission methodology is available in 

Appendix D. Appendix D-1 summarizes the methodology and data inputs used to 

produce the mobile emissions inventory. Appendix D-2 provides the 2007 

attainment year and 2017 and 2025 projections of mobile (highway) VMT and 

annual PM2.5 direct and precursor emissions. Appendix D-3 describes the model

inputs used to generate emission factors for a specific area. Some examples of the 

inputs described in Appendix D-3 are the type and frequency of vehicle emission 

testing, the fuel types required in the area, temperatures by month, and fleet age. 

The summary in Appendix D-3 indicates when default information contained in 

the model is used rather than specific area information. 

Nonroad Sources. The 2007 inventory for the majority of nonroad categories 

was generated using the National Mobile Inventory Model (NMIM2008) of which 

the NONROAD model is a part. The NONROAD model estimates emissions for 

diesel, gasoline, liquefied petroleum gas, and compressed natural gas-fueled 

nonroad equipment types and includes growth factors. For nonroad vehicle the 

NMIM does not estimate emissions from aircraft, locomotives or commercial 

marine vessels. Emissions from aircraft, locomotives, and commercial marine 

vessels were estimated using the EPA guidance and best available information. If 

specific local operational data was available, that data was used to estimate 

emissions. State and national data was used if local data was unavailable. NMIM 

includes emissions from airport ground support equipment. However, emissions 
- 14 -

for airport ground support equipment calculated by NMIM were removed because 

the EPA considers the emissions calculated by the Emissions and Dispersion 

Modeling System (EDMS) to be better estimates of the emissions from airport 

ground support equipment. Growth estimates for source categories modeled by 

NMIM are included in the model. The EPA default values were used for most 

categories.

Aircraft. For airport emissions, Pennsylvania used the database developed by the 

EPA to support the 2008 NEI, as described in the technical support document for 

the development of the 2007 inventory in Appendix C-1.

Railroad Emissions. The Department used the emissions inventory developed by 

the Eastern Regional Technical Advisory Committee (ERTAC). Emissions from 

2007 and 2008 were considered to be identical. ERTAC completed a nationwide 

inventory with the assistance of the railroad associations and submitted the 

inventory to the EPA. The ERTAC inventory was the accepted inventory for the 

2008 NEI and was loaded into the EPA’s Emission Inventory System (EIS). The 

Department made slight modifications in cooperation with ERTAC that resulted 

in changes in emissions of smaller Class III railroads operating in Pennsylvania,

which included locomotive yard operations. The Department had developed its 

own inventory using information received from a statewide survey of railroad 

operational data. The Department determined that ERTAC’s methodology and 

inventory were similar to the Department’s method except in the cases of some 

smaller railroads mentioned above.

ERTAC developed an emissions inventory for Class I, II, and III line haul activity 

based on fuel use, tonnage carried by the railroad using each individual rail link, 

current in-use locomotive emission standards, and rail link use. Track grade and 

locomotive power settings were not considered. ERTAC based their yard 

locomotive emissions on (1) name and location of rail yards, (2) number of 

switchers operating per yard, (3) the tier/year of switchers, (4) annual fuel use 

(gallons/year) for switchers per yard, (5) approximate duty cycle or just percent of 

time in idle for operating switchers, and (6) temporal characteristics of the 

switcher’s use.

Summary of 2007 Emissions Inventory. An emissions inventory of 2007 

emissions of PM10, PM2.5, SO2, NOX, VOC, and NH3 for the Johnstown Area

identifies PM and PM precursor emissions during the period when the Johnstown 

Area was attaining the 1997 and 2006 PM2.5 NAAQS. Table II-2 summarizes the 

emissions for 2007.
- 15 -

Table II-2: Johnstown Area 2007 Annual Emissions (Tons per Year)

Johnstown 2007 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 3,091.4 4,989.5 143,322.4 41,875.4 242.3 35.4

Area Sources 719.1 1,683.5 858.3 607.2 2,415.3 408.3

Highway Vehicle Sources 131.4 159.1 29.9 4,011.0 1,770.2 63.0

Non-Road Sources 89.3 96.9 41.8 1,463.9 897.2 1.1

Totals 4,031 6,929 144,252 47,958 5,325 508

While care should be used in comparing the 2005 emissions inventory to the 

2007, 2017 and 2025 emissions inventories due to the methodology differences 

between those inventories, PM2.5, PM10, SO2, NOX, VOC, and NH3 emissions 

decreased by 70 percent, 67 percent, 7 percent, 1 percent, 15 percent, and 

13 percent, respectively, from 2005 to 2007.

C. Growth Projection Methodologies for 2017 and 2025

This section describes the data, methods, and assumptions utilized in developing 

estimates of emissions changes between 2007 and interim year 2017 and 

maintenance year 2025. Appendix C-2 contains the technical support document 

for the development of the 2017 emissions inventory. Appendix C-3 contains the 

technical support document for the development of the 2025 emissions inventory. 

The documents provide details on the specific factors, control assumptions, and 

implementation schedules used in the emission projection calculations for each 

source category. MARAMA coordinated development of the projection 

inventories for the regional inventory, consisting of the states in the 

Mid-Atlantic/Northeast Visibility Union and Virginia (MANE-VU+VA).

Significant infrastructure development to extract natural gas from the Marcellus 

Shale formation in some Pennsylvania counties has occurred. Point and area 

source emissions result from the placement of drilling equipment, gathering lines 

and compressor stations.

EGUs. Annual 2007 EGU point emissions were “grown” to 2017 and 2025 using 

growth factors based on AEO2011 Table 96 - Electricity Generation by 

Electricity Market Module Region and Fuel Source. The appropriate AEO2011 

growth factor was applied to the 2007 emissions to calculate a “growth only”

emission value for 2025. Post-2007 controls or shut downs were applied on a 

unit-by-unit basis. The control factors were applied to the grown emissions to 

calculate a “growth and control” emission value for 2025. The projected 2017 

and 2025 PM2.5 emissions for EGUs also include condensable PM emissions 

because they were projected from the 2007 inventory which was adjusted to 

account for condensable PM, as discussed in Section II-B above. A more detailed 

description of the methodology used to project emissions from EGUs is located in 

the technical support document for the development of the 2025 emissions 

inventory in Appendix C-3.
- 16 -

Non-EGU Point Sources and Stationary Area Sources. For non-EGU point 

sources and stationary area sources, the emission projections for the 2017 and 

2025 were based on Version 3.3 of the 2007 MANE-VU+VA inventory, which 

was adjusted to apply the EPA PM “transport factors” to fugitive dust area

sources.

The methodology for projecting emissions to 2017 and 2025 is documented in the 

technical support documents for the development of the 2017 and 2025 emissions 

inventories contained in Appendix C-2 and Appendix C-3, respectively. These 

documents were prepared for MARAMA as part of an effort to assist states in 

developing maintenance plans for fine particles. The documents describe the data 

sources, methods, and results for emission forecasts.

NonEGU point source and stationary area source growth factors were developed 

using:

 Annual Energy Outlook (AEO) fuel consumption forecasts;

 State-level employment projections by NAICS code; and

 Other state-specific emission projection data. 

Generally, AEO projection factors were used for fuel consumption sources and 

employment data for other source categories. The U.S. Energy Information 

Administration (EIA) publishes the AEO annually. The AEO contains long-term 

projections of energy supply, demand and prices. AEO2010 fuel-use forecasts 

were available during inventory development. After AEO2011 was published, 

MARAMA compared the AEO2010 and AEO2011 projections. Minor 

differences were found for most categories. Based on this analysis, the AEO2010 

fuel-use forecasts were used for all residential, commercial and industrial sector 

fuel use, except for industrial natural gas usage, where AEO2011 projections were 

used.

Predicted declines in fuel use and employment resulted in negative growth factors 

for some non-EGU point source and stationary area source categories. 

Consequently, for some categories, emissions are lower for the projected future 

years than for the base year, even before the application of control assumptions. 

Because of the possibility that facility owners and operators could register and sell 

Emission Reduction Credits (ERCs) approved and certified by the Department at

the level of the base year inventory, Pennsylvania opted for the conservative 

approach of assuming no growth (growth factor=1) for non-EGU point source 

categories with negative AEO or employment growth factors.

As discussed previously, because the 2005 stationary point source inventory was 

based on emissions reported to the Department by owners and operators of 

facilities and did not include condensable PM for many facilities, the emissions 
- 17 -

inventory shows an apparent increase of direct PM2.5 emissions from stationary 

point sources in 2007, 2017 and 2025 compared with 2005.

Unconventional Natural Gas Development (Marcellus Shale). The emissions 

growth due to a new emissions source, development of natural gas resources from 

Marcellus Shale (and other deep formations), is included in the area source 

inventory. Unconventional natural gas development is defined in Act 13 of 2012 

as “the development of a geological shale formation existing below the base of 

the Elk Sandstone or its geologic equivalent stratigraphic interval where natural 

gas generally cannot be produced at economic flow rates or in economic volumes 

except by vertical or horizontal well bores stimulated by hydraulic fracture 

treatments or by using multilateral well bores or other techniques to expose more 

of the formation to the well bore.” This unconventional natural gas development 

includes well drilling, onsite processing (dehydrating) and transport of the gas 

with the use of compressor stations to the larger pipelines. Note that highway 

vehicle emissions relating to gas development are accounted for in the highway 

vehicle inventory. 

Marcellus Shale natural gas extraction has taken place in Cambria and Indiana 

counties in the Johnstown nonattainment area since 2007, when this activity did 

not exist. By mid-2014, there were about 40 active unconventional well permits 

in Cambria and Indiana Counties (11 in the Johnstown Nonattainment Area).

8

 

Drilling rates are very low compared to other areas in the Marcellus Shale play. 

The Department used the number of wells drilled in 2012 to project emissions. 

The Department assumed that drilling activity will remain fairly constant in the 

foreseeable future. 

Activity of compressor stations will increase because the volume of natural gas 

being pumped will likely increase from the present to the maintenance year. 

While some compressor engines were approved to operate at a limit of 2.0 grams 

of NOX per brake horsepower-hour (g/bhp-hr), compressor engines coming online 

in the future are expected to be significantly cleaner, due to implementation of 

DEP’s General Permit BAQ-GPA/GP-5, Natural Gas Compression and/or 

Processing Facilities (GP-5) in February 2013.

9 GP-5 limits NOX emissions of 

compressor station lean-burn engines over 500 bhp, which is the engine type used 

predominately for compressors, at 0.50 g/bhp-hr. Emission standards are also 

established for carbon monoxide, non-methane non-ethane hydrocarbons and 

formaldehyde. GP-5 establishes standards for certain natural-gas fired turbines, 

for storage vessels and for glycol dehydrators. Furthermore, federal regulations 

(40 CFR Part 60, Subpart OOOO) will require that starting in January 2015, wells 

must capture gas at the wellhead instead of releasing it to the atmosphere or 

flaring it off. The EPA has estimated that VOC emissions from hydraulically 

 

8 PA DEP Oil and Gas Reporting website at 

https://www.paoilandgasreporting.state.pa.us/publicreports/Modules/Production/ProductionByCounty.aspx

9 Available at http://www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/gp.htm
- 18 -

fractured well completions would decrease by 95 perent as a result of this 

regulation.

The Department now requires annual emission reporting under 25 Pa. Code

Chapter 135 (relating to reporting of sources) of unconventional natural gas 

development companies. The initial annual source reporting for unconventional 

natural gas operations under 25 Pa. Code Chapter 135 began in 2012 for 

emissions during the 2011 calendar year. Annual source reports are now due for 

this sector by March 1 each year for emissions during the previous calendar year.

Emissions were projected to 2017 and 2025 based on the most recent emission 

inventory reports available (2013 for compressor engines and 2012 for all other 

sources). 

Emissions in the Indiana portion of the Johnstown Area were assumed to be 

12 percent of the emissions projected for the entire county, based on proportion of 

county land mass (not including water) in the nonattainment area.

See Appendix B-3 for more details on the methodology used for estimating 

Marcellus Shale development activity and for the emission totals by pollutant. 

Emission Reduction Credits. In accordance with 25 Pa. Code §127.207 

(relating to ERC generation and creation), ERCs can be created by an owner or 

operator of an existing facility if the emission reductions are surplus, permanent, 

quantifiable and federally enforceable. Following approval and registration of the 

credits, the ERCs can be either bought or sold to comply with the emission offset 

requirements for the construction of major new or modified stationary sources 

subject to nonattainment New Source Review. ERCs generated from the over 

control of emissions at an existing facility do not expire for use as emission 

offsets. The credits generated from the permanent curtailment of operations or 

the shutdown of a facility will expire for use as offsets ten years from the date of 

the shutdown or curtailment if they are not in use in a Plan Approval. There are 

currently no ERCs banked in Pennsylvania’s Emissions Reductions Credit 

Registry System in the Johnstown Area. 

Highway Vehicle Sources. The EPA’s approved highway vehicle emission 

model, MOVES2010, projects highway vehicle average fleet emission factors. 

State specific information was used where available and appropriate. Traffic 

forecasts were compiled using information from the Pennsylvania Department 

of Transportation’s (PennDOT) Traffic Information System and 

socioeconomic data. The Pennsylvania methodology for estimating highway 

vehicle emissions is consistent with the April 2010 guidance published by the 

EPA’s Office of Transportation and Air Quality (OTAQ) entitled, Technical 

Guidance on the Use of MOVES2010 for Emissions Inventory Preparation in 

State Implementation Plans and Transportation Conformity. Appendices D-1 

through D-3 of this Maintenance Plan include specific information on the
- 19 -

highway emissions inventory methodology, data files of emissions estimates

and MOVES input parameters.

As shown in Table II-3, VMT for the future analysis year increases 31 percent

from 1.29 billion VMT in 2007 to 1.68 billion VMT in 2025 within the 

nonattainment area. Despite the growth in VMT, emissions of the most 

significant vehicle-related precursor, NOX, are significantly lower in the future 

analysis year. The emissions shown in Table II-3 do not include a transportation 

conformity safety margin, which will be discussed later in this document. See,

Section III-B relating to motor vehicle emission budgets for transportation 

conformity.

Table II-3: Johnstown Area VMT (Miles) and Vehicle Emissions (Tons per Year)

Year VMT PM2.5 PM10 SO2 NOx VOC NH3

2002 1,248,787,910 157.4 184.8 108.3 5,190.2 2,142.5 73.2

2005 1,270,853,997 141.8 169.4 61.2 4,482.7 1,919.1 67.1

2007 1,285,564,721 131.4 159.1 29.9 4,011.0 1,770.2 63.0

2017 1,493,080,639 61.5 90.7 10.8 1,768.7 898.6 42.2

2025 1,680,215,868 44.4 76.9 10.7 1,089.5 577.6 40.7

Nonroad Sources. Nonroad Sources in NMIM. Projected emissions for the 

majority of nonroad emission source categories and pollutants were estimated 

using the NMIM, which contains default assumptions for projected years. The 

NMIM estimates emissions for diesel, gasoline, liquefied petroleum gas, and 

compressed natural gas-fueled nonroad equipment types and includes growth 

factors. Control measures due to finalized emission standards for nonroad 

vehicles and engines are also accounted for in NMIM. Baseline emissions are 

multiplied by growth and control factors to obtain projected emissions.

Aircraft Emissions Growth. Aircraft operations were projected to future years by 

applying activity growth using data on itinerant (ITN) operations at airports as 

reported in the FAA’s Terminal Area Forecast (TAF) System for 2009-2030 

(FAA 2010). The ITN operations are defined as aircraft take-offs or landings. 

This information is available for approximately 3300 individual airports. Actual 

take-offs and landings are reported for 2007 and projected take-offs and landings

are provided for all years up to 2030. New aircraft emission controls that will be 

used in the future were also taken into account.

Railroad Emissions Growth. MANE-VU+VA inventory development relied on 

AEO2010 growth projections published in May 2010. There are separate 

projections for passenger rail and freight rail energy use. Passenger rail data from 

AEO2010 Table A-7 was used to calculate the growth factor for 2007-2017 and

2007-2025. These growth factors were applied to inter-city passenger train 

locomotives and independent commuter rail systems. For freight rail, the data 

from AEO2010 Table A-7 was used to calculate the growth factor for 2007-2017 
- 20 -

and 2007-2025. Freight rail annual growth factors for Class I line haul, 

Class II/III line haul, and yard switch locomotives were used.

Additional information about nonroad emission projection methodologies can also 

be found in Appendices C-2 and C-3, the technical support documents for the 

development of the 2017 and 2025 inventories, respectively. The table of 

nonroad emissions data sorted by source category is available as Appendix E-1.

E. Interim Year (2017) Emissions

Table II-4 summarizes the emissions expected in 2017. These emissions take 

activity and emissions growth and/or controls from 2007 into account. 

Appendix C, relating to the regional emissions inventory and projection 

methodology, contains the technical support documents that describe the 

methodologies used to project the 2007 emissions to 2017.

Table II-4: Johnstown Area Projected 2017 Emissions (Tons per Year)

Johnstown 2017 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 2,788.6 4,520.6 132,127.7 37,562.2 234.2 34.2

Area Sources 692.1 1,669.8 683.6 576.1 2,219.0 412.7

Highway Vehicle Sources* 70.7 90.7 10.8 1,945.5 898.6 42.2

Non-Road Sources 52.2 57.2 1.2 910.0 526.2 1.2

Natural Gas Activities 1.7 1.7 0.1 52.1 46.6 0.0

Totals 3,605 6,340 132,823 41,046 3,925 490

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and NOX

has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in 

highway vehicles. The highway vehicle emissions in Table II-4 reflect inclusion of that safety margin.

F. Maintenance Year (2025) Emissions

Table II-5 summarizes the emissions expected in 2025. These emissions take 

activity and emissions growth and/or controls from 2007 into account. 

Appendix C, relating to the regional emissions inventory and projection 

methodology, contains the technical support documents that describe the 

methodologies used to project the 2007 emissions to 2025.
- 21 -

Table II-5: Johnstown Area Projected 2025 Emissions (Tons per Year)

Johnstown 2025 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 2,995.3 4,839.3 141,502.5 40,571.8 246.6 36.2

Area Sources 653.4 1,644.5 417.7 578.7 2,102.7 416.1

Highway Vehicle Sources* 51.1 76.9 10.7 1,198.4 577.6 40.7

Non-Road Sources 38.0 42.3 1.3 662.8 453.1 1.3

Natural Gas Activities 3.3 3.3 0.2 98.0 91.4 0.0

Totals 3,741 6,606 141,932 43,110 3,471 494

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and NOX has 

been set aside as a transportation conformity safety margin to accommodate unanticipated growth in 

highway vehicles. The highway vehicle emissions in Table II-5 reflect inclusion of that safety margin.

G. Maintenance Plan Emissions Test

To demonstrate maintenance of the 1997 and 2006 PM2.5 NAAQS for this area, 

Pennsylvania must show that the future emissions of PM2.5 and its precursors will

remain at levels that provide for maintenance of the PM2.5 NAAQS for at least 

10 years after redesignation, taking economic, population and travel growth into 

account.

The EPA’s Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS

adopted the same presumptions related to PM2.5 precursors as EPA’s 

Implementation Rule for the 1997 PM2.5 NAAQS. However, Pennsylvania 

recognizes the Court decision in Natural Resources Defense Council v. EPA, 

No. 08-1250, 706 F.3d 428 (D.C. Cir. 2013) and the EPA’s subsequent 

withdrawal of the Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS. 

The Court noted that PM2.5 precursors, including ammonia and VOCs, are 

presumptively regulated in PM2.5 nonattainment areas under Subpart 4, pointing 

specifically to section 189(e), which applies to control of major stationary sources 

of PM10 [the court stated that PM10 includes PM2.5 throughout Subpart 4]

(706 F.3d at 436, n. 7, and at 437, n. 10). According to CAA Section 189(e), 

control requirements applicable for major stationary sources of PM10 also apply to 

major stationary sources of PM10 precursors, except where the Administrator 

determines that major stationary sources do not contribute significantly to PM10

levels that exceed the standard in the area; Section 189(e) also requires the EPA to 

issue guidelines regarding the application of subsection (e). Pennsylvania 

assessed emissions of PM2.5, SO2, NOX,VOC and NH3 for the maintenance 

demonstration. 

This Maintenance Plan contains an attainment year inventory for 2007 and 

demonstrates that emissions of PM2.5, SO2, NOX and VOC, including emissions in 

the transportation conformity safety margin for PM2.5 and NOX, will not be 

greater in 2017 and 2025 than in the attainment year, as shown in Table II-7.

Emissions of PM2.5 are projected to decrease from 2007 to 2025 by approximately 

289 tons (7 percent). Emissions of SO2, NOX, VOC and NH3 also decrease from 
- 22 -

2007 to 2025 by approximately 2,320 tons (2 percent), 4,847 tons (10 percent),

1,854 tons (35 percent) and 14 tons (3 percent), respectively.

Table II-6: Johnstown Area Maintenance Emissions Test

Johnstown PM2.5 SO2 NOx VOC NH3

2007 4,031 144,252 47,958 5,325 508

2017* 3,605 132,823 41,046 3,925 490

2025* 3,741 141,932 43,110 3,471 494

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and 

NOX has been set aside as a transportation conformity safety margin to accommodate unanticipated 

growth in highway vehicles. The emissions in Table II-6 reflect inclusion of that safety margin.

III. PERMANENT AND ENFORCEABLE CONTROL MEASURES

A. Permanent and Enforceable Control Measures

Because of the complexity and variability of the process of particulate matter 

formation, the EPA recognizes that the chemical and physical properties of 

particulate matter vary greatly with time, region, meteorology and source 

category.10 Therefore, effective control measures for PM2.5 will vary among 

nonattainment areas. 

By way of background, the EPA’s “Implementation Guidance for the 2006 

24-Hour Fine Particle National Ambient Air Quality Standard,” Office of Air 

Quality Planning and Standards, the EPA was issued on March 2, 2012 (later 

withdrawn). In its Implementation Rule for the 1997 PM2.5 NAAQS, the EPA

established general presumptive policies for assessing which PM2.5 precursors 

should be evaluated for possible controls. In that earlier rule, the EPA required

states to evaluate control measures for SO2 and primary PM2.5 in all locations. 

The EPA required states to evaluate control measures for NOX unless a technical 

demonstration is made to show that NOX emissions from sources in the state do 

not significantly contribute to PM2.5 concentrations in the nonattainment area. 

The EPA required states to evaluate measures for VOC and NH3 only if a 

technical demonstration is made to show VOC or NH3 emissions significantly 

contribute to PM2.5 in the nonattainment area. 

The EPA reaffirmed the appropriateness of these presumptions in the 

Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS.11 Meanwhile, 

the Court of Appeals for the D.C. Circuit was considering a challenge to the 

Implementation Rule for the 1997 PM2.5 NAAQS, in Natural Resources Defense 

Council v. EPA, No. 08-1250. On January 4, 2013, the Court handed down its 

ruling in that case. The Court granted the petitions for review and remanded the 

case to the EPA to re-promulgate the rule pursuant to Subpart 4 of Part D of the 

 

10 See footnote 2, above.

11 See footnote 3, above.
- 23 -

Clean Air Act, rather than implementing it under Subpart 1, as the EPA had done 

(706 F.3d 428 at 437 (DC Cir. 2013)).

Shortly thereafter, the EPA withdrew its Implementation Guidance for the 2006 

24-hour PM2.5 NAAQS. According to the EPA’s June, 2013, withdrawal 

memorandum12, the EPA withdrew the guidance in response to the Court’s 

decision in Natural Resources Defense Council v. EPA, No. 08-1250.

This Maintenance Plan demonstrates maintenance of the standards consistent with 

the Court’s ruling. In general, the Court’s decision (for the 1997 PM2.5 NAAQS 

and to the extent it would be extrapolated to the 2006 24-Hour PM2.5 NAAQS) 

could affect an area’s nonattainment classification, certain deadlines, and the 

impacts of failing to attain timely, and could impose a deadline for 

implementation of reasonably available and best available control measures 

(706 F.3d at 436, n. 6). Because the Johnstown Area is already attaining the 1997 

annual and 2006 24-Hour PM2.5 NAAQS, those considerations are not relevant for 

this Maintenance Plan. The Court noted that PM2.5 precursors, including 

ammonia and VOCs, are presumptively regulated in PM2.5 nonattainment areas 

under Subpart 4, pointing specifically to Section 189(e), which applies to control 

of major stationary sources of PM10 [the court stated that PM10 includes PM2.5

throughout Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to 

Section 189(e) of the CAA, control requirements applicable for major stationary 

sources of PM10 also apply to major stationary sources of PM10 precursors, except 

where the Administrator determines that major stationary sources do not 

contribute significantly to PM10 levels that exceed the standard in the area; 

Section 189(e) also requires the EPA to issue guidelines regarding the application 

of Subsection (e). Pennsylvania assessed emissions of PM2.5, SO2, NOX, VOC 

and NH3 for the maintenance demonstration.

This section describes the federal and state measures that will provide direct 

PM2.5, SO2, NOX, and VOC emission reductions ensuring maintenance of the 

standard.

A summary of the quantity of emission reductions expected from 2007 to 2025 is 

included in Table III-1 (negative values indicate emission reductions). The 

emission change estimates account for any anticipated growth in the activity of 

sources regulated by the strategy and include emissions in the transportation 

conformity safety margin. Direct PM2.5, SO2, NOX, VOC, and NH3 emissions in 

2025 in the Johnstown Area are anticipated to be lower than they were in 2007. 

This means that the projected growth in emissions is smaller than anticipated 

emission reductions from control measures for all pollutants in the nonattainment 

area. Each control measure is explained in greater detail in the following 

sections.

 

12 See footnote 4, above.
- 24 -

Table III-1: Summary of Emission Reductions (Tons) from 2007 to 2025

from Control Measures

2007 to 2025 Difference PM2.5 SO2 NOx VOC NH3

Stationary Point Sources -96.1 -1,819.9 -1,303.6 4.3 0.8

Area Sources -65.7 -440.6 -28.5 -312.6 7.8

Highway Vehicle Sources* -80.3 -19.2 -2,812.6 -1,192.6 -22.3

Nonroad Sources -51.3 -40.5 -801.1 -444.1 0.2

Natural Gas Activities 3.3 0.2 98.0 91.4 0.0

TOTAL -290 -2,320 -4,848 -1,854 -14

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and 

NOX has been set aside as a transportation conformity safety margin to accommodate unanticipated 

growth in highway vehicles. The highway vehicle emissions in Table III-1 reflect inclusion of that 

safety margin.

Pursuant to 40 CFR Part 51, Subpart K (relating to source surveillance), the SIP 

revision is required to provide for monitoring of the status of compliance with any 

rules and regulations that set forth any portion of the control strategy. These 

include provisions, as applicable, for:

 emissions reports and recordkeeping for stationary sources;

 periodic testing and inspection of stationary sources;

 enforcement and complaint investigation of visible emission limitations;

 enforceable test methods for emission limits; and

 continuous emission monitoring for stationary sources.

Subpart K also requires monitoring of the implementation of transportation 

control measures (TCMs). There are no TCMs in this SIP revision.

The rules and regulations for stationary sources, which are part of the control 

strategy for attaining and maintaining the PM2.5 standard, as well as the 

Department’s comprehensive permitting program requirements in 25 Pa. Code

Chapter 127 and the Commonwealth’s SIP in 40 CFR §52.2020, meet the 

requirements of Subpart K. The EPA has approved the Department’s plan 

approval and operating permitting programs as part of the SIP; the Title V 

Operating Permits Program was approved under 40 CFR Part 70 on July 30, 1996 

(61 FR 39597).

There are many examples in Title 25 of the Pa. Code of provisions for monitoring 

the status of compliance with the Department’s rules and regulations. For 

example, 25 Pa. Code §127.12(a) (relating to the content of applications) contains

requirements for reporting and recordkeeping for plan approval applications. 

Similar requirements are found in §127.411(a) (relating to content of applications) 

for permit applications. Sections 145.145 and 145.146 contain the compliance 

demonstration, reporting and recordkeeping requirements for cement kilns that 

enable the Department to monitor the status of compliance with the regulations in 

Chapter 145 Subpart C (relating to emissions of NOX from cement 
- 25 -

manufacturing). The Department also monitors the status of compliance by 

conducting complaint investigations. The Department does visible emission 

inspections at regulated facilities and reports the results to the EPA AFS system 

as required under the Department’s grant. The Department conducts inspections 

of air contamination sources in accordance with the Compliance Monitoring 

Schedule which is approved by the EPA.

1. Stationary Point Sources

Background for Pennsylvania’s Stationary Source Permitting 

Programs. An owner or operator of a proposed new air contamination 

sources in the Commonwealth is required to receive a plan approval (preconstruction permit) from the Department prior to the construction, 

assembly, installation of new sources, modification of any existing 

stationary air contamination sources, or the installation of air pollution 

control equipment or devices. Following the construction of the new 

facility or air contamination source, the owner or operator must obtain an 

operating permit from the Department. The type of operating permit will 

depend on the quantity of regulated pollutants emitted from the air 

contamination sources. The Department will issue a “State-only 

Operating Permit” for minor air contamination stationary sources that are 

below the applicability thresholds for Title V facilities. A “Title V 

Operating Permit” is required for major facilities that have the potential to 

emit air contaminants exceeding the Title V thresholds. The Title V 

Permit, which is issued for a term of five years, incorporates all applicable 

requirements for the facility in a single federally enforceable operating 

permit. 

The requirements contained in 25 Pa. Code Chapter 127 (relating to the 

construction, modification, reactivation and operation of sources), and 

associated definitions in 25 Pa. Code §121.1 (relating to definitions), are a 

suite of programs regulating air contamination sources to improve and 

maintain air quality. Chapter 127 establishes requirements for the 

submission, review and approval of pre-construction and operating 

permits for both major and non-major air contamination sources. The 

provisions of Chapter 127 have been codified in the SIP at 40 CFR 

§52.2020(c)(1) at various times since May 31, 1972, and most recently on 

October 5, 2012, and are therefore all federally enforceable requirements.

Several key Chapter 127 programs are highlighted below as being 

particularly important for the maintenance of the PM2.5 standard.

Title V Permitting Program. The Title V Permitting Program, 

adopted pursuant to the Clean Air Act Amendments of 1990, is 

applicable to major stationary sources as defined in 25 Pa. Code

§121.1. The purpose of the Title V program is to consolidate all of

a facility’s applicable air quality requirements in a single permit 
- 26 -

document so that industry, the regulatory agency, and the public 

know exactly what regulations and requirements apply and how 

the facility’s owner or operator will monitor and demonstrate 

compliance with all applicable requirements. The Title V permit 

includes all sources at a site including all air pollution control 

devices as well as activities that were determined to be 

insignificant sources of emissions. Each source is described in 

detail within a section of the Title V permit. The requirements 

include general conditions applicable to all Title V facilities, 

emission restrictions, detailed monitoring, recordkeeping, and 

reporting requirements to assure compliance with the facility’s 

applicable federal and state requirements. The Title V Operating 

Permits Program requirements are codified in 25 Pa. Code

Chapter 127, Subchapters F and G (relating to operating permit 

requirements; and Title V operating permits). The program was 

fully approved by the EPA on July 30, 1996 (61 FR 39597).

Nonattainment New Source Review and Prevention of 

Significant Deterioration. Major facilities proposed in 

Pennsylvania will also be subject to New Source Review (NSR) 

requirements in nonattainment areas and Prevention of Significant 

Deterioration (PSD) requirements in areas of the Commonwealth 

designated attainment for National Ambient Air Quality Standards 

including carbon monoxide, PM, lead, nitrogen dioxide (NO2), 

ozone SO2. Generally, NSR permit requirements are applicable to 

the owner and operator of a facility located in a nonattainment area 

for a particular pollutant with a potential to emit 50 tor more tons 

per year (tpy) of volatile organic compounds or 100 tpy or more of 

NOX, SO2, PM, or carbon monoxide. It should be noted that the 

entire Commonwealth, included in the Ozone Transport Region by 

operation of law, is treated as a “moderate” ozone nonattainment 

area, irrespective of the area’s attainment status. Because NOX and 

VOC are precursors of PM2.5, NOX and VOC emission reductions 

required statewide under the nonattainment NSR program for 

ozone also allow Pennsylvania to make substantial progress in 

attaining and maintaining the PM2.5 NAAQS. Any new major 

stationary source or major modification subject to the NSR 

requirements must receive a plan approval. To receive approval 

from the Department, a person must show that the proposed source 

will, among other things, offset its potential to emit air 

contaminants including NOX, PM, and VOCs by securing emission 

reductions credits at the specified offset ratio, will employ the 

“lowest achievable emission rate” (LAER) for each regulated 

pollutant and conduct an alternative analysis. The nonattainment 

NSR requirements are codified in 25 Pa. Code Chapter 127, 
- 27 -

Subchapter E (relating to new source review) and approved as a 

SIP revision on December 9, 1997 (62 FR 64722).

The PSD program is a pre-construction review and permitting 

program applicable to new or modified major stationary sources 

subject to Title I, Parts C and D of the federal CAA. The PSD 

requirements are applicable to major sources in areas attaining the 

NAAQS. The federal PSD regulations codified in 40 CFR Part 52 

are incorporated by reference in their entirety in 25 Pa. Code

§127.83 (relating to adoption by reference). The Department’s 

PSD regulations, codified in 25 Pa. Code Chapter 127, 

Subchapter D (relating to prevention of significant deterioration of 

air quality), were approved by the EPA on August 21, 1984 and 

codified at 40 CFR §52.2058 (49 FR 33128).). PSD permit 

requirements may apply to the owner and operator of a facility

located in an attainment area for a standard with the potential to 

emit 100 tpy or 250 tpy of the six criteria pollutants including

carbon monoxide, lead, NO2, ozone, PM, and SO2,depending on 

the source category. Any major stationary source or major 

modification subject to the PSD requirements must conduct an 

analysis to establish the best available control technology (BACT). 

In addition, the owner or operator of a facility must conduct an 

ambient air quality analysis, analyze the impacts to soils, 

vegetation and visibility and make sure that the project will not 

adversely impact mandatory federal Class I areas including 

national parks greater than 6,000 acres and national wilderness 

areas and national memorial parks greater than 5,000 acres. 

Best Available Technology Program. The Department’s Best

Available Technology (BAT) Program, authorized under 

Section 6.6(c) of the Air Pollution Control Act, 35 P.S. §4006.6(c),

ensures that new stationary sources will prevent, reduce or control

emissions of air contaminants to the maximum degree possible. 

The Department determines BAT requirements on a case-by-case 

basis for both major and minor stationary sources taking into 

account energy, environmental benefits, and costs. Pursuant to 

25 Pa. Code §127.1 (relating to purpose), the emission of air 

pollutants from new sources in Pennsylvania must be controlled to 

the maximum extent, consistent with BAT as determined by the 

Department as of the date of issuance of the plan approval for the 

new source. Under 25 Pa. Code §127.12(a)(5) (relating to content 

of applications), an application for a plan approval must show that 

the emissions from a new source will be the minimum attainable 

through the use of BAT. Pennsylvania regulations define “best 

available technology” in 25 Pa. Code §121.1 as, “Equipment, 

devices, methods or techniques as determined by the Department 
- 28 -

which will prevent, reduce or control emissions of air contaminants 

to the maximum degree possible and which are available or may be 

made available.” The Department’s BAT regulations, codified in 

25 Pa. Code §§127.1 and 127.12(a)(5), were approved by the EPA 

on July 30, 1996, and codified in the SIP at 40 CFR 

§52.2020(c)(1).

NOX and SO2 Control Programs. In 1998, EPA promulgated the NOX

SIP Call as the EPA’s principal effort to reduce interstate transport of air 

pollution (63 FR 57356; October 27, 1998). In response to the federal 

NOX SIP call rule, Pennsylvania adopted the NOX Budget Trading 

Program regulations for EGUs and large industrial boilers, with emission 

reductions to commence May 1, 2003. The regulations were approved by 

EPA as a revision to the Commonwealth’s SIP on August 21, 2001 

(66 FR 43795). Additionally, in response to the NOX SIP Call, 

Pennsylvania adopted additional NOX control regulations covering cement 

plants and internal combustion engines, with emission reductions to 

commence May 1, 2005. These regulations were approved by the EPA as 

a SIP revision on September 29, 2006 (71 FR 57428).

Clean Air Interstate Rule (CAIR). In 2005, the EPA adopted 

CAIR (70 FR 25162; May 12, 2005, as amended) to address 

interstate transport of NOX and SO2. CAIR is now being 

implemented in Pennsylvania through the Department’s CAIR 

regulation, codified in 25 Pa. Code Chapter 145, Subchapter D

(relating to CAIR NOX and SO2 trading programs), with related 

amendments in Chapters 121, 129 and 145 (relating to general; 

standards for sources; and interstate pollution transport reduction). 

The EPA approved Pennsylvania’s CAIR SIP revision on 

December 10, 2009, codified at 40 CFR §52.2020(c)(1)

(74 FR 65446). In the CAIR SIP revision, Pennsylvania 

terminated the NOX Budget Trading Program and transitioned to 

the federal CAIR for EGUs.

The market-based CAIR is designed to reduce EGU emissions of 

NOX and SO2 below 2002 levels throughout the eastern United 

States. Pennsylvania and the other CAIR states were required to 

adopt a regulation implementing the requirements of the CAIR or 

an equivalent program. The large EGUs in Pennsylvania were 

initially regulated under CAIR Federal Implementation Plans (FIP)

promulgated by the EPA, but have been regulated under the SIP 

since the EPA approved Pennsylvania’s CAIR SIP revision. Under 

the SIP revision, Pennsylvania participates in the EPAadministered cap-and-trade programs for NOX annual, NOX ozone 

season, and SO2 annual emissions.
- 29 -

The EPA’s CAIR was remanded to the EPA for revisions by the 

United States Court of Appeals for the District of Columbia on 

December 23, 2008 (See, North Carolina v. EPA, 531 F.3d 896, 

modified, 550 F.3d 1176 (D.C. Cir. 2008)). Following remand, the 

EPA replaced CAIR with the Cross-State Air Pollution Rule 

(CSAPR), but in a separate legal challenge the court vacated 

CSAPR. In that ruling, the court ordered the EPA to continue 

administering CAIR pending the promulgation of a valid 

replacement (See, EME Homer City Generation L.P. v. EPA, 

696 F.3d 7 (D.C. Cir. 2012)). On April 29, 2014, the 

U.S. Supreme Court reversed the Court of Appeals’ decision that 

had vacated CSAPR. EPA v. EME Homer City Generation, L.P.,

134 S. Ct. 1584 (U.S. 2014). The Supreme Court remanded the 

case to the D.C. Circuit Court of Appeals for further proceedings. 

On October 23, 2014, the D.C Circuit granted the EPA’s motion 

requesting that the Court lift the stay of the CSAPR imposed by the 

Court in December 2011.

According to the EPA, emission reductions originally required 

under CAIR will be made permanent and enforceable through the 

implementation of CSAPR. See the EPA’s proposed rule, 

“Redesignation of the Harrisburg-Lebanon-Carlisle-York 

Nonattainment Areas to Attainment for the 1997 Annual and the 

2006 24-Hour Fine Particulate Matter Standard,” 79 FR 62389 

(October 17, 2014), in which the EPA wrote: “Provided that the 

stay is lifted and the EPA’s tolled compliance deadlines are put in 

place, the emission reductions associated with CAIR that helped 

the Areas achieve attainment of the 1997 annual and the 2006 

24-hour PM2.5 NAAQS would be permanent and enforceable for 

purposes of redesignation under Section 107(d)(3)(E)(iii) of the 

CAA, because CSAPR requires similar or greater emission 

reductions from relevant upwind areas starting in 2015 and 

beyond.” See 79 FR 62392.

Cross-State Air Pollution Rule (CSAPR). In 2011, the EPA 

promulgated the CSAPR to replace CAIR following the judicial 

remand of CAIR, as explained above. In CSAPR, EPA established 

emissions budgets for covered EGUs in 28 states and promulgated 

FIPs to achieve the reductions (76 FR 48208; August 8, 2011). 

Although CSAPR allows emissions trading, it also maintains statespecific limits by means of assurance provisions designed to 

ensure that the necessary emission reductions occur within each 

covered state. The CSAPR FIPs for Pennsylvania are codified in 

40 CFR §§52.2040 and 52.2041.
- 30 -

As explained above, CSAPR was challenged in court in 2011, in 

EPA v. EME Homer City Generation, L.P., 134 S. Ct. 1584 (U.S. 

2014). In December 2011, the D.C. Circuit imposed a stay on 

CSAPR. On October 23, 2014, however, the court lifted the stay.

NOX Budget Trading Program limits on non-EGUs. The CAIR 

SIP revision also established emission limits for the non-EGUs and 

other units that were subject to the Commonwealth’s NOX Budget 

Trading Program but are not subject to the CAIR NOX Ozone 

Season Trading Program. These units must continue monitoring 

NOX emissions and must meet an emissions cap. Each unit has an 

allowable emission rate, calculated by January 31 of each year, 

based on the previous ozone season’s heat input. 

The Department’s regulation, codified in 25 Pa. Code §145.8(d)

(relating to transition to CAIR NOX trading programs), was 

approved by the EPA as a SIP revision on December 10, 2009, and 

codified at 40 CFR §52.2020(c)(1).

Cement kilns and large stationary internal combustion engines. 

The CAIR SIP revision also included regulations in 25 Pa. Code

Chapter 145, Subchapters B and C (relating to emissions of NOX

from stationary internal combustion engines; and emissions of 

NOX from cement manufacturing), updating the large stationary 

internal combustion engine and cement manufacturing regulations, 

respectively, that were adopted pursuant to the NOX SIP Call. 

The Department’s regulations for large stationary internal 

combustion engines and cement kilns, codified in 25 Pa. Code

Chapter 145, Subchapters B and C, respectively, were approved by 

the EPA as a SIP revision on December 10, 2009, and codified at 

40 CFR §51.2020(c)(1). An amendment to the Department’s 

regulation for cement kilns to reduce NOX emissions effective 

April 15, 2011, codified in 25 Pa. Code Chapter 145, 

Subchapter C, was subsequently approved by the EPA as as a SIP 

revision on July 19, 2011, and codified at 40 CFR §51.2020(c)(1).

Federal Standards for Hazardous Air Pollutants. Federal standards to 

control hazardous air pollutants (HAPs) require Maximum Achievable 

Control Technology (MACT) at units located at major sources of HAPs. 

The EPA has promulgated a series of MACT regulations that are 

applicable to sources in Pennsylvania. These MACT standards are 

adopted and incorporated by reference in their entirety in Section 6.6 of 

Pennsylvania’s Air Pollution Control Act and implementing regulations in 

25 Pa. Code §127.35 (relating to maximum achievable control technology 

standards for hazardous air pollutants). The standards are also included in 
- 31 -

federally enforceable plan approvals and operating permits issued by the 

Department for affected sources.

2. Highway Vehicle Sources

Even with increases in VMT that occur from 2007 through 2025, highway 

vehicle emissions will continue to decrease. As more vehicles subject to 

cleaner new car standards replace older vehicles subject to less stringent 

new vehicle standards, the fleet as a whole emits fewer emissions, 

compensating for the increase in vehicle miles traveled. These decreases

can be attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) and 

Pennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established 

by the CAA Amendments of 1990 include NOX and VOC limits for lightduty gasoline vehicles (LDGVs) and light-duty gasoline trucks (LDGTs). 

The phase in of these standards began in 1994. Evaporative VOC 

emissions were reduced in gasoline-powered cars starting with Model 

Year (MY) 1998.

In 1998, pursuant to Section 177 of the CAA, the Department adopted the 

Pennsylvania Clean Vehicles Program (28 Pa.B. 5973, December. 5, 

1998). The Pennsylvania Clean Vehicles Program incorporates by 

reference certain California Low Emission Vehicle (CA LEV) emission 

standards for passenger cars and light-duty trucks. As required under 

Section 177 of the CAA, these provisions are identical to the low emission 

standards adopted by California. The regulation does not incorporate by 

reference the California zero emissions vehicle (ZEV) or emissions 

control warranty systems statement provisions.

In the same rulemaking, the Department adopted the National Low 

Emission Vehicle (NLEV) program as a compliance alternative to the 

Pennsylvania Clean Vehicles Program. The NLEV program became 

effective in the Ozone Transport Region (OTR) in 1999. Pennsylvania’s 

New Motor Vehicle Emissions Control Program regulations in 25 Pa. 

Code §§126.401-126.441 (relating to Pennsylvania Clean Vehicles 

Program), in addition to including the Clean Vehicles Program, allowed 

automobile manufacturers to comply with NLEV instead of the CA LEV 

program through MY 2005. These regulations affected vehicles 

6,000 pounds and less and were the regulations in effect for new motor 

vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV 

(Tier 2), starting with MY 2004 (65 FR 6698; Feb. 10, 2000). The NLEV 

program was replaced for MY 2004 and later by the more stringent Tier 2 
- 32 -

regulations, and vehicle manufacturers operating under the NLEV 

program became subject to the Tier 2 requirements.

Pennsylvania amended the former New Motor Vehicle Emissions Control 

Program in 2006. The Clean Vehicles Program continues to incorporate 

CA LEV by reference. As amended, the program affects MY 2008 and 

newer passenger cars and light-duty trucks vehicles (36 Pa.B. 7424; 

December 9, 2006), corrected 37 Pa.B. 209 (January 12, 2007, eff. 

December 9, 2006). The EPA approved Pennsylvania’s Clean Vehicle

Program as a revision to the Commonwealth’s SIP on January 24, 2012 

(77 FR 3386).

Heavy-Duty Diesel Emissions Control Programs. The EPA

promulgated more stringent national regulations for heavy-duty engines 

and vehicles (over 14,000 pounds) starting with MY 2004. In addition, 

federal consent decrees with seven of the largest heavy-duty engine 

manufacturers required, among other terms, that diesel engines made by 

these companies comply with these 2004 standards two model years early, 

in MY 2002. The emission reductions from these programs are reflected 

in the future year emission inventories, as provided in the MOVES model.

In 2002, the Department adopted the Heavy-Duty Diesel Emissions 

Control Program for model years starting after May 2004. The program 

incorporates California standards by reference and requires MY 2005 and 

subsequent new heavy-duty diesel highway engines to be those certified 

by California. California standards were more stringent than federal 

standards for the two model years between expiration of the consent 

decrees discussed above (MYs 2005 and 2006) and the implementation of 

more stringent federal standards affecting MY 2007 and beyond. 

However, the EPA’s MOVES model already assumed that the engines 

would comply with consent decree standards, even without an 

enforcement mechanism. The Department has used MOVES defaults to 

calculate emissions from MY 2005 and 2006 heavy-duty highway engines.

The EPA adopted new emission standards for heavy-duty engines and 

vehicles for MY 2007 and subsequent. For diesel engines, the standards 

were phased in from MY 2007 to 2010 for NOX and VOCs. For gasoline 

engines, the standards were phased in during MY 2008 and 2009. Federal 

and California standards were virtually identical for MY 2007. For 

MY 2008, California adopted requirements for idling restriction engine 

programming and an optional “clean NOX idle” standard. However, there 

is no EPA-approved methodology to estimate emission reductions from 

this requirement. Therefore, the emission estimates use assumptions of 

the federal rule for MY 2007 through 2010.
- 33 -

Because the new engine standards are adversely affected by sulfur in fuel, 

the EPA also required most highway diesel fuel to contain no more than 

15 parts per million (ppm) of sulfur, beginning in the fall of 2006. There 

was a temporary compliance option allowing refiners to continue to 

produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

2010. The Department used MOVES defaults to estimate the effects of 

the phase-in provision.

Vehicle Emission Inspection/Maintenance Program. In early 2004, 

Pennsylvania expanded its Vehicle Emission Inspection/Maintenance 

(I/M) Program into Cambria County. The program applies to gasolinepowered vehicles 9,000 pounds and under, MY 1975 and newer. The 

program consists of an annual visual inspection of pollution control 

devices to ensure they are present, connected, and the proper type for the 

vehicle and a gas cap pressure test. While Indiana County is not required 

to have a separate I/M program, vehicles are subject to the visual 

inspection as part of their safety inspection.

These regulations can be found in 67 Pa. Code Chapters 175 and 177 

(relating to vehicle equipment and inspection; and emission inspection 

program). The Department submitted the expanded safety and emission 

inspection programs to the EPA as a SIP revision on December 1, 2003. 

The EPA approved the SIP revision on October 6, 2005 (70 FR 58313).

Low Sulfur Gasoline. Sulfur is a natural component in crude oil that 

ends up in gasoline and diesel unless removed. Sulfur in gasoline impairs 

the effectiveness of emission control systems and contributes to air 

pollution. By removing most sulfur from gasoline, new advanced 

emission controls will work longer and more efficiently, and air pollution 

will be reduced.

The 1999 federal Tier 2 regulations (65 FR 6698; February 10, 2000)

reduced the sulfur content of gasoline by up to 90 percent, enabling the 

use of new emission control technologies in cars and trucks that reduce 

harmful air pollution. The emission inventory analysis in this 

Maintenance Plan uses the default assumptions provided in MOVES2010 

to account for the implementation of the federal standards for low sulfur 

gasoline. Requirements for use of low-sulfur gasoline enabled use of 

advanced emission control systems in light-duty vehicles beginning in 

MY 2004. Vehicles meeting Tier 2 emission standards are 77 to 

95 percent cleaner than earlier models.

On March 3, 2014, the EPA signed a regulation adopting more stringent 

vehicle standards and reducing sulfur limits in gasoline further with the 

Tier 3 Motor Vehicle Emission and Fuel Standards program. The 

regulation was published in the Federal Register on April 28, 2014 
- 34 -

(79 FR 23414) and takes effect in 2017. The Tier 3 program requires the 

annual average content of sulfur in gasoline to be reduced to 10 ppm, 

starting January 1, 2017. By 2018, the EPA estimates that SO2 emissions 

from gasoline vehicles will be reduced by 56 percent. When fully 

implemented, this program, by 2030, will increase the effectiveness of 

vehicle emission controls even further and reduce onroad emissions of 

NOX by 25 percent, direct particulate matter by 10 percent and VOCs by 

16 percent. The rule will also significantly reduce emissions of carbon 

monoxide and hazardous air pollutants including acrolein, benzene, 

formaldehyde, and acetaldehyde. Emission reductions from the Tier 3 

program have not been included in future year inventories and, therefore 

are not relied upon in the maintenance demonstration. Emission 

reductions from the federal Tier 3 program may nonetheless assist the 

Johnstown Area in maintaining the PM2.5 NAAQS.

3. Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel-powered 

(“compression ignition”) and gasoline-powered (“spark ignition”) nonroad 

engines of various sizes (horsepower) and applications. Information on 

these federal rules, including their implementation dates, can be found at 

www.epa.gov/nonroad. The Department used the assumptions built into 

the nonroad model (NONROAD2005) and NMIM to estimate emissions 

for all milestone years.

On June 29, 2004, the EPA adopted a rule establishing a comprehensive 

national program to reduce emissions from nonroad diesel engines 

(69 FR 38958). The rule phased in requirements for reducing the sulfur 

content of diesel used in nonroad diesel engines. The reduction in fuel 

sulfur content prevents damage to the more advanced emission control 

systems needed to meet the engine standards; it will also reduce fine 

particulate emissions from diesel engines. In 2007, fuel sulfur levels were 

limited to 500 ppm for nonroad applications other than ocean-going 

marine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur 

concentration as in highway fuel, 15 ppm; this requirement began 

applying in 2012 to locomotive and marine diesel fuel. The EPA adopted 

technical amendments to the program in rules published in the Federal 

Register on November 22, 2005 (70 FR 70498) and May 1, 2006 

(71 FR 25706). On April 30, 2010 (75 FR 22896), the EPA adopted 

changes to the nonroad diesel fuel program to allow for the production and 

sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 

marine vessels. This requirement does not impact the Johnstown Area 

because the Johnstown Area does not have emissions from commercial 

marine vessels.
- 35 -

On June 30, 2008, the EPA promulgated standards to reduce emissions of 

diesel PM and NOX from locomotives and marine diesel engines 

(73 FR 37096). The regulation tightens emissions standards for existing 

locomotives and large marine diesel engines when they are 

remanufactured, sets near-term engine-out emissions standards, referred to 

as Tier 3 standards, for newly-built locomotives and marine diesel 

engines, and sets longer-term standards, referred to as Tier 4 standards, for 

newly-built locomotives and marine diesel engines that reflect the 

application of high-efficiency aftertreatment technology.

4. Stationary Area Sources

Low Sulfur Fuel Oil. The Environmental Quality Board has adopted a 

rulemaking to reduce the sulfur content of fuel oil in Pennsylvania. This 

final rulemaking, published in the Pennsylvania Bulletin February 9, 2013 

(43 Pa.B. 806), and corrected April 20, 2013 (43 Pa.B. 2140), will limit 

the sulfur content of No. 2 fuel oil to 500 ppm, No. 4 fuel oil to 2,500 ppm 

and Nos. 5 and 6 fuel oils to 5,000 ppm. Compliance with the lower sulfur 

content limits will be required beginning July 1, 2016. The Department 

estimates statewide SO2 emission reductions of approximately 25,000 tpy

from this rule. The final-form regulation was submitted to the EPA for 

approval as a SIP revision on February 26, 2013. The EPA issued a final 

rule approving the SIP revision on July 10, 2014 (79 FR 39330). 

Consumer Products. The Consumer Products regulation applies 

statewide to any person who sells, supplies, offers for sale, or 

manufactures certain consumer products on or after January 1, 2005, for 

use in the Commonwealth. The Consumer Products regulation is codified 

in 25 Pa. Code Chapter 130, Subchapter B (relating to consumer 

products). It was submitted to the EPA as a SIP revision on March 26, 

2003, and approved on December 8, 2004 (69 FR 70895). Amendments 

to the Consumer Products regulation were adopted on October 11, 2008,

submitted to the EPA for approval as a SIP revision on March 11, 2009,

and approved by the EPA as a SIP revision on October 18, 2010 

(75 FR 63717).

Adhesives, Sealants, Primers and Solvents. Pennsylvania adopted a 

regulation in 2010 to control VOC emissions from Adhesives, Sealants, 

Primers and Solvents. This regulation was published in the Pennsylvania 

Bulletin on December 25, 2010 (40 Pa.B. 7340) and approved by the EPA 

as a SIP revision on September 26, 2012 (77 FR 59090).

General Permit for Air Pollution Control in Natural Gas Compression 

and/or Processing Facilities (GP-5). In accordance with Section 6.1(f) of the 

Air Pollution Control Act and 25 Pa. Code §§127.514 and 127.611 (relating to 

general operating permits at Title V facilities; and general plan approvals and 
- 36 -

general operating permits), the Department has issued General Plan Approvals 

and General Operating Permits (hereinafter referred to as General Permits or GP)

to specific categories of sources that are similar in design and operation, and can 

be adequately regulated with standardized specifications and conditions.The 

Department first issued a General Permit for Natural Gas, Coal Bed Methane or 

Gob Gas Production or Recovery Facilities (GP-5) on March 10, 1997, and 

revised it periodically. 

The Department revised GP-5 on February 2, 2013, to cover various 

aspects of the natural gas compression and processing operations. The use 

of this General Permit may be authorized by the Department solely for 

minor sources.

GP-5 establishes BAT requirements for the construction or modification 

of a natural gas compression and/or processing facility and any air 

cleaning devices that meet the BAT requirements established under 25 Pa. 

Code §§127.1 and 127.12(a)(5). GP-5 also requires the owners and 

operators of existing engines to comply with applicable Standards of 

Performance (NSPS) in 40 CFR Part 60, Subpart JJJJJ and the National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Stationary Spark Ignition Internal Combustion Engines specified in 

40 CFR Part 63, Subpart ZZZZ. New engines must also comply with 

40 CFR Part 60, Subpart OOOO. GP-5 also requires compliance with 

other NSPS or NESHAPs as appropriate.

An owner or operator proposing to use a General Plan Approval or 

General Operating Permit (General Permit), must obtain the Department’s 

prior written approval. A general permit is issued by the Department for 

sources that can adequately regulated under standardized specifications 

and conditions. 

When an owner or operator of affected sources seeks an authorization to 

use the GP-5, the applicant must demonstrate to the Department that the 

affected sources comply with the requirements specified by the General 

Permit. If authorization is granted, the Department provides a written 

authorization to use the GP-5 and issues a notice to that effect in the 

Pennsylvania Bulletin. An applicant can review the general permit 

qualifying criteria, terms and conditions, and then apply to the Department 

for coverage under the general permit. The Department reviews the 

applicant’s information to confirm the applicant meets the qualifications, 

and the Department issues the authorization to use the general permit. The 

terms and conditions of the general permit are as stringent as the terms and 

conditions for an individual plan approval and/or operating permit. 

The Department has used the terms and conditions in GP-5 to project 

emissions from this source category to 2017 and 2025. 
- 37 -

Requirements for BAT contained 25 Pa. Code Chapter 127, 

Sections 127.1 and 127.12(a), were approved as part of the SIP in July 

1996 (61 FR 39597). Authority to issue general plan approvals and 

operating permits is codified in 25 Pa. Code §§127.611, 127.612, 127.621, 

127.622, 127.631 and 127.632. These provisions were also approved by 

the EPA as part of the SIP in July 1996 (61 FR 39594). The Department 

has incorporated the EPA’s NSPS and NESHAPs (which are used in 

GP-5) by reference (25 Pa. Code Chapters 122 and 124, respectively). 

If a source located at the facility cannot be regulated under GP-5, a plan 

approval and/or an operating permit issued in accordance with 25 Pa. 

Code, Chapter 127, Subchapters B and F (relating to plan approval 

requirements; and operating permit requirements) will be required. Major 

sources would also be subject to the Title V Operating Permit 

requirements in Subchapter G (relating to Title V operating permits). 

More information on GP-5 is available on the DEP website at: 

http://www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/gp.htm.

B. Motor Vehicle Emission Budgets for Transportation Conformity

Section 176 of the CAA provides a mechanism by which federally funded or 

approved highway and transit plans, programs, and projects are determined not to 

produce new air quality violations, worsen existing violations, or delay timely 

attainment of the NAAQS. The EPA regulations issued to implement 

transportation conformity provide that motor vehicle emission “budgets” establish 

caps of these emissions that cannot be exceeded by the predicted transportation 

system emissions in the future. Transportation agencies in Pennsylvania are 

responsible for making timely transportation conformity determinations. The 

responsible agencies in the Johnstown Area are the Johnstown Area 

Transportation Study for Cambria County and the Southwestern Planning 

Commission for Indiana County. These are the designated Metropolitan Planning 

Organizations (MPO) under federal transportation planning requirements.

In this Maintenance Plan, Pennsylvania establishes budgets for highway 

emissions for direct PM2.5 and NOX in order to ensure that transportation 

emissions do not impede clean air goals in the next decade and beyond. The 

highway emission budgets include a safety margin, which was created by setting 

aside a portion of the difference between attainment year and maintenance year 

emissions of PM2.5 and NOX to accommodate unanticipated growth in highway 

vehicles.

Amendments to the 40 CFR Part 93 transportation conformity regulations to 

address the 1997 PM2.5 standard were published in the Federal Register on May 6, 
- 38 -

2005 (70 FR 24280), to account for PM2.5 and its precursors.13 The 

Implementation Rule did not amend these regulations. In the transportation 

conformity regulations, 40 CFR §93.102 requires conformity determinations to be 

applicable to direct emissions of PM2.5 and NOX (unless a determination is made 

that transportation-related emissions are not significant contributors to PM2.5), but 

to emissions of SO2, VOC, and NH3 only if a finding is made that transportationrelated emissions of these pollutants are significant contributors to PM2.5. The 

EPA approved Pennsylvania’s SIP revision establishing transportation conformity 

requirements in the Commonwealth on April 29, 2009 (74 FR 19451). 

This Maintenance Plan SIP revision establishes motor vehicle emission budgets

for PM2.5 and NOX. The information in Table III-2, once the EPA approves it for 

purposes of conformity, will establish transportation conformity budgets for the 

Johnstown Area. 

Table III-2: Motor Vehicle Emission Budgets (Tons per Year)

County Year PM2.5 NOx County Year PM2.5 NOx

Cambria 

County

2007 111.61 3,460.17

Indiana 

County 

(Partial)

2007 19.76 550.78

2017 

Predicted 54.60 1,551.85 2017 Predicted 6.91 216.82

Safety 

Margin 8.19 155.18 Safety Margin 1.04 21.68

2017 

Budget 62.79 1,707.03 2017 Budget 7.95 238.50

2025 

Predicted 40.62 979.51 2025 Predicted 3.81 109.98

Safety 

Margin 6.09 97.95 Safety Margin 0.57 11.00

2025 

Budget 46.71 1077.46 2025 Budget 4.38 120.98

The highway emission budgets include a safety margin to accommodate 

unanticipated growth in highway vehicles. The safety margins were created by 

setting aside a portion of the difference between attainment year and maintenance 

year emissions of PM2.5 and NOX. Table III-3 shows that the amount of emission 

reductions anticipated between 2007 and 2017 and between 2007 and 2025 easily 

accommodates the safety margins granted. 

 

13 The Federal transportation conformity regulations were again amended on March 14, 2012 (77 FR 14979) to 

restructure several sections so that they apply to any new or revised NAAQS and make several clarifications to 

improve implementation. 
- 39 -

Table III-3: Comparison of Safety Margin to Total Anticipated

Emission Reductions in 2017 and 2025

Johnstown PM2.5 NOx

2007 4,031.2 47,957.5

2017 3,596.2 40,869.1

2025 3,734.4 43,000.8

2007 - 2017 Anticipated 

Emission Reductions 435 7,088

Margin Granted 9.23 176.86

2007 - 2025 Anticipated 

Emission Reductions 297 4,957

Margin Granted 6.66 108.95

For informational purposes, DEP analyzed the projected 2025 inventory and 

found that highway emissions of VOC, NH3, and SO2 account for 16.64 percent, 

8.23 percent, and 0.01 percent of the total projected 2025 inventory, respectively, 

as shown in Table III-4.

Table III-4: Comparison of 2025 On-Road Mobile VOC, NH3, and SO2 Emissions

to the Total Projected 2025 Inventory

Johnstown 2025 SO2 VOC NH3

On-Road Mobile Source Projected Inventory (Tons) 11 578 41

Total Projected 2025 Inventory (Tons) 141,932 3,471 494

Percent of Total Projected 2025 Inventory (%) 0.01 16.64 8.23

The motor vehicle emission budgets include PM from vehicle exhaust, brake 

wear, and tire wear, which are estimated by the MOVES model. The Department 

has included direct PM2.5 re-entrained road dust emissions from paved and 

unpaved roads in the area source inventory, not in the motor vehicle emission 

budgets. Appendix B-2, relating to area source annual emissions, contain 

estimates of the PM2.5 emissions attributable to paved and unpaved roads.

The Johnstown monitoring site includes a monitor that measures PM2.5 mass and a 

speciation monitor that collects data on the chemical constituents of PM2.5 in the 

Johnstown Area. Transportation construction-related fugitive dust emissions are 

not a significant contributor to the PM2.5 concentrations observed at the 

Johnstown monitor. At the Johnstown monitor, the crustal component was found 

to be small compared to other components of PM2.5 (See Figure 1). Given that 

construction-related fugitive dust is one of many source categories contributing to 

the crustal material observed at the monitor, and transportation construction is a 

small subset of all construction, it is reasonable to conclude that transportation 

construction-related fugitive emissions are insignificant.
- 40 -

Figure 1. Pie Chart of 2012 Johnstown Speciation Data

IV. AMBIENT AIR QUALITY MONITORING NETWORK

The Department will continue to operate the air monitoring network in accordance with 

40 CFR Part 58 to verify the attainment status of the Johnstown Area for the 1997 and 

2006 PM2.5 NAAQS, with no reductions in the number of sites from those in the existing 

network unless pre-approved by the EPA. The Department has concurrently submitted a 

request for redesignation of the Johnstown Area that contains analysis of ambient air 

quality data and related factors.

V. VERIFICATION OF CONTINUED ATTAINMENT

The Department will track the attainment status of the 1997 and 2006 PM2.5 NAAQS in 

the Johnstown Area by reviewing air quality and emissions data during the maintenance 

period. The Department will perform an annual evaluation of three key factors, VMT 

data, emissions reported from stationary sources, and unconventional gas production and 

compare them to the assumptions about these factors used in this Plan. The Department 

will also evaluate the periodic (every three years) emission inventories prepared under the 

EPA’s Air Emission Reporting Requirements (40 CFR 51, Subpart A) to see if they 

Nitrate

7%

Sulfate

20%

Ammonium

7%

Organic carbon

19%

Elemental carbon

7%

Crustal component

8%

Other

32%

Johnstown

AIRS Code 420210011 POC 5 (ROUTINE)

Date(s): 1/4/2012 - 12/29/2012

Average Concentration (μg/m3)
- 41 -

exceed the attainment year inventory (2007) by more than 10 percent. Based on these 

evaluations, the Department will consider whether any further emission control measures 

should be implemented. 

VI. CONTINGENCY MEASURES

The Department will adopt and expeditiously implement corrective actions, as necessary 

and appropriate, in the following circumstances:

A first level response will be prompted if the annual mean PM2.5 concentration exceeds 

15.5 μg/m3in a single calendar year within the maintenance area, if the 98th percentile 

24-hour PM2.5 concentration exceeds 35.0 μg/m3in a single calendar year within the 

maintenance area, or if the periodic emissions inventory for the Johnstown Area exceeds 

the attainment year inventory (2007) by more than 10 percent. The first level response 

will consist of a study to determine whether the PM2.5 value indicates a trend toward 

higher PM2.5 values and whether emissions appear to be increasing. If there appears to be 

an increasing trend, the study will evaluate whether the trend is likely to continue and, if 

so, the necessary and appropriate control measures to reverse the trend. Implementation 

of necessary and appropriate controls would take place as expeditiously as possible.

A second level response will be prompted if the 2-year average of the annual mean PM2.5

concentrations exceeds 15.0 μg/m3or if the 2-year average of 98th percentile 24-hour 

PM2.5 concentrations exceeds 35.0 μg/m3 within the maintenance area. If this trigger 

point occurs, the Department will evaluate whether additional emission control measures 

should be implemented in order to prevent a violation of the air quality standards. The 

Department will analyze the conditions leading to the PM2.5 levels and evaluate what 

measures might be most effective in correcting the PM2.5 levels. The Department will 

also analyze the potential emissions effect of federal, state, and local measures that have 

been adopted but not yet implemented at the time the second level response is triggered. 

The Department will then begin the process of adopting any selected measures that are 

necessary and appropriate so that in the event of a violation, the measures can be 

implemented as expeditiously as practicable.

If a violation of the PM2.5 NAAQS occurs, the Department will propose and adopt 

additional emission reduction measures, as necessary and appropriate, as expeditiously as 

practicable in accordance with the implementation schedule in this section, the CAA, the 

Pennsylvania Air Pollution Control Act, other Pennsylvania statutory requirements, and 

the Department’s Policy for Development, Approval and Availability of Regulations in 

order to return the area to attainment with the standards.

Additional emission reduction measures to be considered for adoption if a violation of the 

NAAQS occurs in the Johnstown Area would be based on criteria including the 

following:

 air quality analysis indicating nature of violation [cause, location, source];
- 42 -

 emission reduction potential, including extent to which emission generating 

sources occur in the nonattainment area;

 timeliness of implementation in terms of the potential to return the area to 

attainment as expeditiously as practicable; and

 costs, equity and cost-effectiveness.

Additional emission reduction measures the Department would consider pursuing for 

promulgation if a violation of the NAAQS occurs in the Johnstown Area include the 

following:

Regulatory measures:

 A regulation based on the OTC Model Rule to update requirements for consumer 

products;

 A regulation based on the Control Techniques Guidelines (CTG) for industrial 

cleaning solvents; and

 Other regulatory measures identified based on the above-listed criteria.

Non-regulatory measures:

 Voluntary diesel projects:

o Diesel retrofit (including replacement, repowering or alternative fuel use) 

for public or private local onroad or offroad fleets;

o Idling reduction technology for Class 2 yard locomotives; and

o Idling reduction technologies or strategies for truck stops, warehouses and 

other freight-handling facilities.

 Promotion of accelerated turnover of lawn and garden equipment, especially 

commercial equipment.

 Additional promotion of alternative fuels for fleets, home heating and agricultural 

use.

Once the Department’s Bureau of Air Quality has obtained an approved request to initiate 

a rulemaking, the rulemaking may proceed as follows:

Within 2 months: Review by Air Quality Technical Advisory Committee 

(AQTAC), Citizens Advisory Council and other advisory committees,

14

as 

appropriate.

Within 5 months: Environmental Quality Board (EQB) meeting/action.

Within 7 months: Publication in the Pennsylvania Bulletin for comment as 

proposed rulemaking.

Within 9 months: Public hearing takes place and comment period on proposed 

rulemaking closes.

 

14 Other committees could include the Small Business Compliance Advisory Committee and Agriculture Advisory 

Committee.
- 43 -

Within 10 months: Independent Regulatory Review Commission (IRRC) 

comment on proposed rulemaking.

Within 12 months: AQTAC, Citizens Advisory Council and other advisory 

committees, as appropriate, review responses to comments and draft final 

rulemaking.

Within 15 months: EQB meeting/action on final rulemaking.

Within 16 months: IRRC action on final rulemaking.

Within 17 months: Attorney General review/action on final rulemaking.

Within 18 months: Publication in the Pennsylvania Bulletin as final-form 

regulationand submission to the EPA as a SIP revision. The regulation 

would become effective upon publication in the Pennsylvania Bulletin.
- 44 -

ACRONYMS AND ABBREVIATIONS

AEO Annual Energy Outlook

AQTAC Air Quality Technical Advisory Committee

BACT Best Available Control Technology

BAT Best Available Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CA LEV California Low Emission Vehicle (program)

CF Control Factor

CFR Code of Federal Regulations

CMU Carnegie Mellon University

CMV Commercial Marine Vessel

CSAPR Cross-State Air Pollution Rule

DEP Pennsylvania Department of Environmental Protection

EDMS Emissions and Dispersion Modeling System

EGAS Economic Growth Analysis System

EGU Electric Generating Unit

EIA Energy Information Administration

EIS Emission Inventory System

EPA The United States Environmental Protection Agency

EQB Environmental Quality Board

ERC Emission Reduction Credit

ERTAC Eastern Regional Technical Advisory Committee

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FIRE Factor Information Retrieval 

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

HAP Hazardous Air Pollutant

I/M Inspection and Maintenance

IRRC Independent Regulatory Review Commission

ITN Itinerant

LDGV Light Duty Gasoline Vehicles

LDGT Light Duty Gasoline Trucks

MACT Maximum Achievable Control Technology

MANE-VU Mid-Atlantic/Northeast Visibility Union

MARAMA Mid-Atlantic Regional Air Management Association

MOVES Motor Vehicle Emission Simulator

MPO Metropolitan Planning Organization

MY Model Year

NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NEI National Emissions Inventory

NH3 Ammonia
- 45 -

NLEV National Low Emission Vehicle (program)

NMIM National Mobile Inventory Model

NOX Oxides of Nitrogen

NSR New Source Review

OTAQ Office of Transportation and Air Quality

OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood-fired Boiler

PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates 

PM10 Particulate Matter less than 10 microns in diameter

PSD Prevention of Significant Deterioration

RWC Residential Wood Combustion

SCC Source Classification Code

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TSD Technical Support Document 

μg/m3 Microgram per cubic meter

μm Micrometer

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

WOE Weight of Evidence

ZEV Zero Emissions Vehicle
Commonwealth of Pennsylvania

Redesignation Request

Johnstown Nonattainment Area

1997 and 2006 Fine Particulate Matter

National Ambient Air Quality Standards

December 2014

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

www.dep.state.pa.us
This page intentionally left blank.
- i -

TABLE OF CONTENTS

Introduction......................................................................................................................................1

I. Demonstration of Attainment and Air Quality Trends Analysis.........................................4

A. Design Value Determination....................................................................................6

B. Air Quality Trends Analysis....................................................................................7

C. Climate Trends Analysis..........................................................................................9

1. Temperature Trends...................................................................................10

2. Precipitation Trends...................................................................................12

D. Additional Trends ..................................................................................................13

1. Population Trends......................................................................................13

2. Economic Trends.......................................................................................14

E. Modeling Analysis.................................................................................................15

II. SIP Approvals and Applicable Requirements....................................................................16

A. Section 110(a)(2) of the CAA................................................................................17

B. Part D - Plan Requirements for Nonattainment Areas...........................................18

1. Section 172(c) of the CAA ........................................................................18

2. Section 173 of the CAA.............................................................................18

3. Section 176 of the CAA.............................................................................19

4. Section 189(e) of the CAA ........................................................................20

C. Conclusion .............................................................................................................20

III. Demonstration of Permanent and Enforceable Improvement............................................20

A. Baseline (2005) Emissions Inventory ....................................................................22

B. Attainment Year (2007) Emissions Inventory .......................................................24

C. Control Measures...................................................................................................24

1. Stationary Point Sources............................................................................26

2. Highway Vehicle Sources..........................................................................31

3. Nonroad Sources........................................................................................35

4. Stationary Area Sources.............................................................................35

IV. Maintenance Plan...............................................................................................................36

Acronyms and Abbreviations ........................................................................................................38
- ii -

TABLES

Table I-1: Johnstown Area Annual PM2.5 Concentrations..............................................................7

Table I-2: Johnstown Area 24-Hour PM2.5 Concentrations............................................................7

Table I-3: Johnstown Area Annual PM2.5 Design Values ..............................................................7

Table I-4: Johnstown Area 24-Hour PM2.5 Design Values.............................................................8

Table I-5: Johnstown Area Monthly Mean Temperature (°F)......................................................11

Table I-6: Johnstown Area Precipitation (inches) ........................................................................12

Table I-7: EPA’s CSAPR Modeling Results for the PM2.5 Standard for the Johnstown 

Area ..........................................................................................................................16

Table III-1: 2005 Johnstown Area Annual Emissions (Tons per Year) .......................................23

Table III-2: 2007 Johnstown Area Annual Emissions (Tons per Year) .......................................24

Table III-3: Change in Johnstown Area Annual Emissions (Tons per Year) from 2005 to 

2007..........................................................................................................................25

Table III-4: Summary of Emission Totals (Tons) in 2007, 2017 and 2025..................................26

FIGURES

Figure I-1: Pennsylvania’s 1997 PM2.5 Nonattainment Areas........................................................5

Figure I-2: Pennsylvania’s 2006 PM2.5 Nonattainment Areas........................................................5

Figure I-3: PM2.5 Annual Concentration Trend...............................................................................8

Figure I-4: PM2.5 24-Hour Concentration Trend ............................................................................9

Figure I-5: Pie Chart of 2012 Johnstown Speciation Data ...........................................................10

Figure I-6: Johnstown Area Monthly Mean Temperature (°F).....................................................11

Figure I-7: Johnstown Area Annual Precipitation (inches) ..........................................................12

Figure I-8: Johnstown Area Population Trend..............................................................................13

Figure I-9: Johnstown Area Population and Labor Force Trends.................................................14

Figure I-10: Pennsylvania and National Coincident Indexes from the Philadelphia 

Federal Reserve Bank...............................................................................................15
- 1 -

INTRODUCTION

Particulate matter (PM) is a mixture of microscopic solids and liquid droplets suspended in air 

that include: acids (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles 

and allergens (such as fragments of pollen or mold spores). Fine particulate matter or PM2.5

describes particulate matter that is less than or equal to 2.5 micrometers (μm) in diameter, 

approximately 1/30th the diameter of a human hair. Because of their small size, fine particles 

can penetrate deeply into the lungs.

Health studies have shown a significant association between exposure to fine particles and 

premature death from heart or lung disease. Fine particles can aggravate heart and lung diseases 

and have been linked to effects such as cardiovascular symptoms, cardiac arrhythmias, heart 

attacks, respiratory symptoms, asthma attacks, and bronchitis. These effects can result in 

increased hospital admissions, emergency room visits, absences from school or work, and 

restricted activity days. Individuals that may be particularly sensitive to fine particle exposure 

include people with heart or lung disease, older adults, and children. The article “FineParticulate Air Pollution and Life Expectancy in the United States” by C. Arden Pope, III, et al. 

published January 22, 2009 in the New England Journal of Medicine evaluated the role PM2.5 

reductions occurring in the 1980s and 1990s had on the increased life expectancy observed over 

that period. The study found that a reduction of 10 micrograms per cubic meter (μg/m3) of PM2.5 

was associated with an average increase in life expectancy of 7.3 months.

PM2.5 has significant environmental impacts, including acid rain and stream eutrophication. 

PM2.5 also affects visibility (regional haze) through the scattering and absorption of light. Fine 

particles, similar in size to the wavelength of light, are most efficient, per unit of mass, at 

reducing visibility. Soiling and materials damage can also be caused by PM2.5 in the air.

The United States Environmental Protection Agency (EPA) promulgated PM2.5 National 

Ambient Air Quality Standards (NAAQS) in 1997 after evaluating hundreds of health studies 

and conducting an extensive peer review process. The EPA established an annual primary 

(health-based) and secondary (welfare-based) standard of 15.0 micrograms per cubic meter 

(μg/m3), based on the 3-year average of annual mean PM2.5 concentrations. The EPA also 

established a primary and secondary 24-hour standard of 65 μg/m3determined by the 3-year 

average of the 98th percentile of 24-hour concentrations. In 2006, the EPA promulgated a 

revised 24-hour PM2.5 standard of 35 μg/m3determined by the 3-year average of the 

98th percentile of 24-hour concentrations. The annual PM2.5 standard was not revised. 

(71 FR 61144 (October 17, 2006)).

On December 17, 2004, the EPA issued air quality designations for the PM2.5 standard based on 

air quality monitoring data from 2001-2003. The final designations were published in the 

Federal Register on January 5, 2005 (70 FR 944). The designations became effective on April 5, 

2005. On April 5, 2005, the EPA issued a supplemental notice changing the designation of 

certain areas from nonattainment to attainment based on newly available air quality data 

(70 FR 19844; April 14, 2005). The April 5, 2005, supplemental notice only affected Mercer 

County in the Commonwealth of Pennsylvania.
- 2 -

The Johnstown Area was one of eight areas in Pennsylvania, comprising all or parts of 

21 Pennsylvania counties, designated by the EPA as nonattainment for the 1997 PM2.5 NAAQS. 

The Johnstown Area, consisting of Cambria County and parts of Indiana County1in 

Pennsylvania, was designated by the EPA as nonattainment because it violated the 1997 annual 

standard of 15.0 μg/m3based on 2001-2003 monitoring data. The Johnstown Area did not 

violate the 1997 24-hour standard of 65 μg/m3.

On October 8, 2009, the EPA promulgated air quality designations for the 2006 24-hour PM2.5

standard based on 2006-2008 air quality monitoring data. The final designations were published 

in the Federal Register on November 13, 2009 (74 FR 58688). The EPA designated seven areas 

comprised of all or portions of 22 counties in Pennsylvania as PM2.5 nonattainment areas. The 

designations became effective on December 14, 2009.

The Johnstown Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 PM2.5 NAAQS. The Johnstown Area was designated nonattainment 

because the area violated the 2006 24-hour PM2.5 standard of 35 μg/m

3

based on 2006-2008

monitoring data.

On April 25, 2014, the EPA finalized a rule to classify areas currently designated nonattainment 

for the 1997 and 2006 PM2.5 NAAQS as “moderate.” The final rule was published in the 

Federal Register on June 2, 2014 (79 FR 31566). The EPA classification of the nonattainment 

areas as “moderate” was as a result of a decision of the U.S. Court of Appeals for the D.C.

Circuit regarding Subpart 4 of Part D of the Clean Air Act, which is discussed in more detail

later in this document.

The analyses described in this Request for Redesignation clearly demonstrate that the ambient air 

quality in the Johnstown Area now meets the 1997 and 2006 PM2.5 NAAQS. The emission 

reductions responsible for the improvements in PM2.5 air quality are both permanent and 

enforceable. These analyses and the Maintenance Plan submitted concurrently demonstrate that 

the Johnstown Area has completed all criteria set forth in Section 107(d)(3)(E) of the Clean Air 

Act (CAA) and should be officially redesignated as attainment for both the 1997 and 2006 PM2.5

NAAQS.

Section 107(d)(3)(E) of the CAA states that an area may be redesignated to attainment if the 

following conditions are met:

● The NAAQS has been attained (discussed in Section I);

● The applicable implementation plan has been fully approved under Section 110(k) of the 

CAA and the state has met all applicable requirements for the area under Section 110 and 

Part D (discussed in Section II);

● The improvement in air quality is due to permanent and enforceable reductions in 

emissions (discussed in Section I and Section III); and

 

1 Townships of West Wheatfield, Center, East Wheatfield, and Armagh Borough and Homer City Borough
- 3 -

A Maintenance Plan with contingency measures has been fully approved under Section 175A 

(discussed in Section IV).

This Request for Redesignation describes how the Johnstown Area satisfies each of the CAA’s 

Section 107(d)(3)(E) criteria for redesignation to attainment.

Requirements for a public comment process are set forth in Section 110(a)(2) of the CAA, 

40 CFR §51.102(d) and Section 7.5 of the Pennsylvania Air Pollution Control Act (35 P.S. 

§4007.5(b)). On October 4, 2014, the Department provided notice of a public comment period 

and the opportunity for a hearing on the Johnstown Area Maintenance Plan for the 1997 and 

2006 PM2.5 NAAQS, 2007 comprehensive inventory required by Section 172(c)(3) of the CAA, 

and this Request for Redesignation of the Johnstown Area to attainment for the 1997 and 2006 

PM2.5 standards. The Department scheduled the public hearing to occur on November 5, 2014, 

but no one expressed interest in presenting testimony or attending. Therefore, the Department

cancelled the hearing. The public comment period closed November 7, 2014. No comments 

were received during the public comment period.
- 4 -

I. DEMONSTRATION OF ATTAINMENT AND AIR QUALITY TRENDS 

ANALYSIS

On December 17, 2004, the EPA issued air quality designations for the 1997 PM2.5

annual standard based on 2001-2003 air quality monitoring data. The final designations 

were published in the Federal Register on January 5, 2005 (70 FR 944). The 

designations became effective on April 5, 2005. On April 5, 2005, the EPA issued a 

supplemental notice changing the designation of certain areas from nonattainment to 

attainment based on newly available air quality data (70 FR 19844; April 14, 2005). The 

April 5, 2005 supplemental notice only affected Mercer County in the Commonwealth of 

Pennsylvania (Commonwealth or Pennsylvania).

The Johnstown Area was one of eight areas in Pennsylvania, comprising all or parts of 

21 Pennsylvania counties, designated by the EPA as nonattainment for the 1997 PM2.5

NAAQS. The Johnstown Area, consisting of Cambria County and portions of Indiana 

County in Pennsylvania, was designated as nonattainment because it violated the 1997 

annual standard of 15.0 μg/m3based on 2001-2003 monitoring data. The Johnstown 

Area did not violate the 1997 24-hour standard of 65 μg/m3.

On October 8, 2009, the EPA promulgated air quality designations for the 2006 PM2.5

standard based on 2006-2008 air quality monitoring data. The final designations were 

published in the Federal Register on November 13, 2009 (74 FR 58688). The EPA 

designated seven areas comprised of all or portions of 22 counties in Pennsylvania as 

PM2.5 nonattainment areas. The designations became effective on December 14, 2009. 

The Johnstown Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 PM2.5 NAAQS. The Johnstown Area was designated 

nonattainment because the area violated the 2006 24-hour PM2.5 standard of 35 μg/m3

based on 2006-2008 monitoring data.
- 5 -

Figure I-1: Pennsylvania’s 1997 PM2.5 Nonattainment Areas

Figure I-2: Pennsylvania’s 2006 PM2.5 Nonattainment Areas
- 6 -

Air quality in the Johnstown Area has improved since the EPA’s original designations. 

The Johnstown Area’s annual PM2.5 design value has decreased over the 2001 to 2013

time frame. Based on 2001-2003 air quality monitoring data, the Johnstown Area’s 

annual and 24-hour design values for 2003 were 15.8 μg/m3and 41 μg/m3, respectively. 

Based on 2011-2013 air quality monitoring data, the Johnstown Area’s 2013 annual and 

24-hour design values were 12.3 μg/m3and 30 μg/m3. Following the EPA criteria, 

annual PM2.5 design values below 15.0 μg/m3and 24-hour design values below 35 μg/m3

are considered to be attainment for the 1997 annual and 2006 24-hour NAAQS. Annual 

and 24-hour concentrations are expected to remain lower than 15 μg/m3and 35 μg/m3

over the next decade.

On September 25, 2009, the EPA determined that the Johnstown Area had attained the 

1997 PM2.5 NAAQS based on quality assured, quality controlled and certified ambient air 

monitoring data that show the area had monitored attainment based on 2006-2008 data 

(“Clean Data Determination”) (74 FR 48863). This final action suspended the 

requirements for this area to submit an attainment demonstration and associated 

reasonably available control measures, reasonable further progress plans, contingency 

measures and other planning SIP revisions related to the attainment of the 1997 PM2.5

NAAQS for so long as the area continues to attain the 1997 PM2.5 NAAQS2.

On March 29, 2012, the EPA determined that the Johnstown Area had attained the 2006 

PM2.5 NAAQS based on quality assured, quality controlled and certified ambient air 

monitoring data that show the area had monitored attainment based on 2008-2010 data 

(“Clean Data Determination”) (77 FR 18922). This final action suspended the 

requirements for Pennsylvania to submit an attainment demonstration for this area and 

associated reasonably available control measures, reasonable further progress plans, 

contingency measures and other planning SIP revisions related to the attainment of the 

2006 PM2.5 NAAQS for so long as the area continues to attain the 2006 PM2.5 NAAQS.

The determination of attainment did not “redesignate” the area as “attainment.” The 

Johnstown Area remains nonattainment for the 1997 and 2006 PM2.5 NAAQS until the 

Commonwealth submits, and the EPA approves, a Request for Redesignation and a 

Maintenance Plan showing the area can maintain these standards for at least 10 years.

A. Design Value Determination

The ambient air quality analysis is based on PM2.5 data measured at the 

Johnstown Area monitoring site. The ambient air quality data analysis for PM2.5

was completed using the appropriate regulations and guidance documents. 

Monitoring procedures were determined in accordance with 40 CFR Part 58. The 

PM2.5 design values were calculated in accordance with 40 CFR Part 50, 

 

2 The EPA followed this action on July 29, 2011 (76 FR 45424) with a statutorily required determination under 

Section 179(c) of the CAA, that the Johnstown Area attained the 1997 PM2.5 NAAQS by the applicable attainment 

date of April 5, 2010. The EPA based this determination on complete, quality assured, and certified ambient air 

monitoring data that show the area monitored attainment for the 2007-2009 monitoring period.
- 7 -

Appendix N, “Interpretation of the National Ambient Air Quality Standards for 

Particulate Matter.”

B. Air Quality Trends Analysis

This section provides a brief summary of PM2.5 monitoring concentrations in the

Johnstown Area. 

Trends in PM2.5 design values were analyzed from 2001 through 2013. Table I-1 

displays annual PM2.5 concentrations monitored in the Johnstown Area. Table I-2 

contains the 98th percentile of 24-hour concentrations for each year. 

Table I-1: Johnstown Area Annual PM2.5 Concentrations

Table I-2: Johnstown Area 24-Hour PM2.5 Concentrations

Tables I-3 and I-4 contain the Johnstown Area’s annual and 24-hour PM2.5 design 

values calculated using the 2001 through 2013 monitoring data. Design values

for the annual and 24-hour PM2.5 NAAQS show a declining trend. The 

Johnstown Area was designated as nonattainment for the 1997 annual standard

based on the 2001 through 2003 annual design value of 15.8 μg/m3. The 24-hour 

design value for that time period was 41 μg/m3. Compared with the 2001 through 

2003 design values, the annual design value for 2011 through 2013 has decreased 

by 22 percent and the 24-hour design value by 27 percent. The annual and 

24-hour PM2.5 design values for the Johnstown Area are shown below in 

Tables I-3 and I-4, respectively.

Table I-3: Johnstown Area Annual PM2.5 Design Values

Site and AQS ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Johnstown 

420210011 15.8 16.1 15.5 14.4 16.8 14.8 14.4 13.9 11.9 11.9 13.4 11.6 11.9

Annual Mean

Site and AQS ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Johnstown 

420210011

40.1 46.6 36.8 36.2 43.2 39 34.6* 32.2 28.7 30.2 32.5 28 29.6

Annual 98% Concentration

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

2011-

2013

Johnstown 

420210011 15.3 15.8 15.8 15.3 15.6 15.3 15.3 14.4 13.4 12.6 12.4 12.3 12.3

Annual PM2.5 NAAQS = 15 ug/m3

Design Value
- 8 -

Table I-4: Johnstown Area 24-Hour PM2.5 Design Values

The 2001 through 2013 trend lines for annual and 24-hour PM2.5 concentrations

are shown in Figures I-2 and I-3. As shown in Figures I-2 and I-3, the slope of 

the trend lines for the annual and 24-hour PM2.5 concentrations are both negative, 

indicating decreasing concentrations. 

Figure I-3: PM2.5 Annual Concentration Trend

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

2011-

2013

Johnstown 

420210011 35* 40 41 40 39 39 39 35* 32 30 30 30 30

2006 24-Hour PM2.5 NAAQS 3 year 98th% = 35 ug/m3

Design Value

y = -0.3434x + 16.696

0

2

4

6

8

10

12

14

16

18

2001200220032004200520062007200820092010201120122013

PM2.5 Design Value (ug/m3)

PM2.5 Annual Design Value Trend

Johnstown Annual DV

Level of Standard
- 9 -

Figure I-4: PM2.5 24-Hour Concentration Trend

C. Climate Trends Analysis

PM2.5 formation in the eastern United States is a complex process involving local 

and regional meteorology, topography, chemistry and transport. Sulfates and 

nitrates are formed primarily through atmospheric reactions of precursor 

emissions of sulfur dioxide (SO2), oxides of nitrogen (NOX) and ammonia (NH3). 

Organic carbon is a combination of secondary organic particles formed from 

emissions of volatile organic compounds (VOC) and the organic portion of 

primary PM2.5 that is directly emitted or condenses near its source. Currently, our 

understanding of sulfate and nitrate chemistry and its impacts on PM2.5

concentrations far exceeds our understanding of contributions from anthropogenic 

VOCs. 

25

27

29

31

33

35

37

39

41

43

45

2001200220032004200520062007200820092010201120122013

PM2.5 Design Value (ug/m3)

PM2.5 24-Hour Design Value Trend

Level of Standard

Johnstown 24-Hour DV
- 10 -

Figure I-5: Pie Chart of 2012 Johnstown Speciation Data

Attainment of the PM2.5 NAAQS involves the range of meteorological conditions 

throughout the year. PM2.5 chemistry favors sulfate formation during the warm 

summer months and nitrate formation during the colder winter months. In 

addition, local temperature inversions more common in the winter can concentrate 

emissions near the surface, leading to periods of elevated PM2.5 concentrations.

To assess whether it is likely that unusual meteorological patterns have 

contributed to the lower PM2.5 concentrations observed in the Johnstown Area, 

temperature and precipitation trends over the last 10 years were examined.

The data used in the trends analysis is from the Global Historical Climatology 

Network (GHCN) database for the Johnstown Airport. The monthly summary 

data was obtained from the NOAA National Climatic Data Center at: 

www.ncdc.noaa.gov/cdo-web/search#t=secondTabLink

1. Temperature Trends

Table I-5 presents monthly mean temperature data for the Johnstown Area 

for 2001 through 2013. Figure I-5 graphically displays the data.

Nitrate

7%

Sulfate

20%

Ammonium

Organic 7%

carbon

Elemental 19%

carbon

7%

Crustal 

component

8%

Other

32%

Johnstown

AIRS Code 420210011 POC 5 

(ROUTINE)

Date(s): 1/4/2012 - 12/29/2012

Average Concentration (μg/m3)
- 11 -

Table I-5: Johnstown Area Monthly Mean Temperature (°F)

Figure I-6: Johnstown Area Monthly Mean Temperature (°F)

The Johnstown Area was designated nonattainment for the 1997 PM2.5

NAAQS based on 2001 through 2003 monitoring data and nonattainment 

for the 2006 PM2.5 NAAQS based on 2006 through 2008 monitoring data. 

These timeframes show typical year-to-year variation in temperature with 

no unusual conditions that would be expected to cause higher PM2.5

concentrations as experienced. The Johnstown Area’s Clean Data 

Determinations for the 1997 and 2006 PM2.5 NAAQS were based on 2006

through 2008, and 2008 through 2010 monitoring data, respectively. The 

Johnstown Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2001 25.7 30.7 30.9 49.8 56.5 64.9 65.7 70.0 59.0 50.5 46.0 34.9

2002 33.1 31.1 36.9 48.9 55.0 66.9 71.4 70.5 64.8 47.3 37.4 26.6

2003 17.8 22.5 37.4 48.0 54.1 62.4 67.8 68.9 59.4 47.5 43.9 29.5

2004 18.0 26.2 37.6 47.7 61.7 63.0 67.1 65.7 62.2 49.8 42.6 30.0

2005 27.9 28.9 30.4 48.6 52.3 67.6 71.1 70.0 64.2 50.9 41.2 24.6

2006 34.3 26.6 35.8 49.6 55.0 63.3 70.0 69.4 57.4 47.8 42.4 35.8

2007 29.3 17.1 37.8 43.5 61.0 66.0 67.1 69.6 63.5 57.0 37.8 30.9

2008 28.6 26.6 35.2 48.9 53.6 66.7 69.4 65.5 62.1 47.8 36.7 29.5

2009 19.4 28.4 37.6 47.3 57.2 63.9 64.9 68.2 59.5 47.5 43.5 26.8

2010 21.9 21.9 39.9 52.2 59.4 67.1 71.2 68.5 61.9 50.2 39.9 21.4

2011 19.9 28.4 34.2 48.7 60.1 65.3 72.9 67.3 61.3 48.4 44.6 34.3

2012 29.1 31.8 47.5 45.9 62.6 64.6 71.6 67.5 59.7 50.0 36.0 34.3

2013 28.4 24.6 29.8 47.5 57.2 64.9 69.3 65.7 58.6 51.6 34.2 30.6

0

10

20

30

40

50

60

70

80

degrees Fahrenheit

Monthly Mean Temperature (degrees F)
- 12 -

Johnstown Area continues to monitor attainment. Examination of the 

temperature data from 2006 through 2013 shows normal variation in 

seasonal temperatures but no evidence of unusual patterns that would be

expected to repress PM2.5 formation.

2. Precipitation Trends

Table I-6 presents monthly and annual precipitation data for the

Johnstown Area for 2001 through 2013. Figure I-6 graphically displays 

the annual precipitation data.

Table I-6: Johnstown Area Precipitation (inches)

Figure I-7: Johnstown Area Annual Precipitation (inches)

Johnstown Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Annual 

Total

2001 1.6 1.2 2.5 4.8 2.8 3.9 2.0 3.7 2.6 1.8 3.4 2.0 32.2

2002 1.8 1.6 4.6 4.9 5.3 4.7 1.3 2.6 3.8 3.8 2.6 2.5 39.4

2003 2.9 2.2 2.3 2.2 6.3 5.7 4.6 8.1 4.6 3.7 4.2 2.6 49.4

2004 4.1 2.0 3.0 5.9 4.1 5.3 6.6 4.2 6.0 2.4 2.5 2.2 48.1

2005 5.5 1.9 2.9 1.8 2.3 2.3 3.2 3.4 1.0 4.6 4.1 1.6 34.7

2006 3.4 0.8 1.5 3.6 3.0 5.4 5.0 2.9 4.2 4.3 3.6 1.4 39.1

2007 2.7 0.2 0.9 3.1 1.5 4.1 4.5 8.9 1.8 2.5 3.3 4.2 37.8

2008 1.9 3.0 3.4 1.8 6.6 4.5 3.7 2.3 5.8 1.5 1.9 6.5 42.9

2009 1.9 1.3 1.3 2.6 4.7 2.7 4.3 3.0 2.6 4.0 1.8 3.3 33.6

2010 2.2 3.9 3.3 2.9 5.7 4.3 5.8 3.6 5.1 0.8 4.7 1.3 43.4

2011 1.3 3.9 3.8 6.8 4.1 1.5 2.3 6.7 11.3 5.2 3.4 3.2 53.6

2012 2.8 2.1 3.5 1.6 6.1 2.5 8.1 2.0 4.8 5.7 0.6 4.2 44.0

2013 2.8 1.3 2.0 2.1 3.2 5.9 2.6 5.6 4.1 2.6 2.3 3.2 37.7

0.0

10.0

20.0

30.0

40.0

50.0

60.0

2001200220032004200520062007200820092010201120122013

Precipitaion (inches)

Annual Precipitation
- 13 -

Examination of the 2001 through 2003 and 2006 through 2008

precipitation data indicates both drier and wetter than usual years within 

those timeframes. Examination of the precipitation data from 2006

through 2013 also shows variation in precipitation amounts. There is no 

indication from the data that unusual precipitation patterns contributed to 

the lower PM2.5 concentrations in recent years in which the Johnstown 

Area monitored attainment of the PM2.5 NAAQS.

D. Additional Trends

1. Population Trends

The Johnstown Area, which consists of Cambria County and portions of 

Indiana County, has had negative population growth over the last decade. 

The population of the Johnstown Area decreased approximately 5 percent

between the 2000 and 2010 Censuses. Based on data from the Bureau of 

the Census, the population of the Johnstown Area was 171,158 in 2000 

and 162,459 in 2010. Approximately 20 percent of the population of 

Indiana County is in the nonattainment area.

Population decreases correspond with decreased emissions from some 

types of emission sources and, therefore, can result in decreased pollution 

levels. While the Johnstown Area’s population has decreased

approximately 5 percent over the last decade, there is no evidence that the 

moderate decrease in population is driving the substantial improvement in 

air quality experienced in the Johnstown area.

Figure I-8: Johnstown Area Population Trend

158000

160000

162000

164000

166000

168000

170000

172000

Johnstown Area Population 

Population
- 14 -

2. Economic Trends

Economic trends could have impacts on emissions and consequently affect 

PM2.5 concentrations in the Johnstown Area. The two factors considered 

here include estimated labor force changes in the Johnstown Area and 

overall economic activity in Pennsylvania as measured by the Coincident 

Index. The labor force data was obtained from the U.S. Department of 

Labor, Bureau of Labor Statistics, Mid-Atlantic Information Office. The 

Coincident Index data was obtained from the Philadelphia Reserve Bank.

Figure I-9 shows the Johnstown Area’s population change and estimated 

labor force change since 1990. A larger labor force could lead to more 

driving and increased infrastructure demands. This in turn could lead to 

higher emissions. Increases in the Johnstown Area’s labor force also 

contribute to overall increases in economic activity (greater family 

income/spending). The Philadelphia Federal Reserve Bank has tracked 

economic activity in Pennsylvania over the last 25 years. Pennsylvania’s 

Economic Activity Index is graphically depicted in Figure I-10. In spite 

of these upward trends, air quality continues to improve in the Johnstown 

Area.

Figure I-9: Johnstown Area Population and Labor Force Trends

Data Source:

U.S. Department of Labor, Bureau of Labor Statistics, Mid-Atlantic Information Office

The database containing “State and local industry employment and earnings – monthly”

data was accessed from the following site: www.bls.gov/ro3/data.htm
- 15 -

Figure I-10: Pennsylvania and National Coincident Indexes from the

Philadelphia Federal Reserve Bank

Data downloaded on 5/24/2012 from: The Federal Reserve Bank of Philadelphia at: 

www.philadelphiafed.org/research-and-data/regional-economy/indexes/coincident/

The Federal Reserve Bank of Philadelphia produces a monthly coincident 

index for each of the 50 states. The coincident indexes combine 

four state-level indicators to summarize current economic conditions in a 

single statistic. The four state-level variables in each coincident index are 

nonfarm payroll employment, average hours worked in manufacturing, the 

unemployment rate, and wage and salary disbursements deflated by the 

consumer price index (U.S. city average). The trend for each state’s index 

is set to the trend of its gross domestic product (GDP), so long-term 

growth in the state’s index matches long-term growth in its GDP.

E. Modeling Analysis

Modeling results for the EPA’s Cross-State Air Pollution Rule (76 FR 48207; 

August 8, 2011)3(CSAPR or Transport Rule) were examined to determine if the 

model results support redesignating the Johnstown Area to attainment. EPA’s 

analysis indicates that the Johnstown Area would attain the 1997 and 2006 PM2.5

NAAQS in 2014, even in the absence of either the Clean Air Interstate Rule 

(CAIR) or CSAPR.

EPA used the Comprehensive Air Quality Model with Extension (CAMx) 

version 5.3. CAMx is a three-dimensional Eulerian grid-based photochemical 

model designed to simulate the formation, chemical transformation, transport, and 

 

3 “Federal Implementation Plans: Interstate Transport of Fine Particulate Matter and Ozone and Correction of SIP 

Approvals.”

0.00

20.00

40.00

60.00

80.00

100.00

120.00

140.00

160.00

180.00

Jan-79

Feb-81

Mar-83

Apr-85

May-87

Jun-89

Jul-91

Aug-93

Sep-95

Oct-97

Nov-99

Dec-01

Jan-04

Feb-06

Mar-08

Apr-10

Coincident Index

Pennsylvania and National Coincident 

Indexes

PA

US
- 16 -

removal of ozone, secondary and directly emitted PM2.5, and their precursor 

species on national, regional, and local scales for short-term episodes up to annual 

time periods. Using this model, EPA simulated the emissions from many 

different sources of pollution (such as electric generating units (EGU), and mobile 

sources). All of the CSAPR CAMx simulations used meteorology for 2005 

derived from simulations of the Pennsylvania State University/National Center for 

Atmospheric Research Mesoscale Model (MM5) version 3.7.4. The 2005 

emissions of SO2, NOX, VOC, NH3 and direct PM2.5 were modeled. The 

modeling was based on the annual PM2.5 design values for the 2003 through 2007 

base period.

EPA outlined the model results in the Air Quality Modeling Final Rule Technical 

Support Document for CSAPR. Air quality modeling was performed to simulate 

ozone and PM2.5 concentrations for the 2005 base year, a 2012 “no CAIR” base 

case, a 2014 “no CAIR” base case, and the 2014 remedy scenario. Table I-7

(relating to EPA’s CSAPR modeling results for the PM2.5 Standard for the 

Johnstown Area) displays the results of EPA’s analysis for the Johnstown Area. 

EPA’s analysis indicates that the Johnstown Area would attain the 1997 and 2006 

PM2.5 NAAQS in 2014, even in the absence of either CAIR or CSAPR. The 

results support redesignating the Johnstown Area to attainment for the PM2.5

NAAQS.

Table I-7: EPA’s CSAPR Modeling Results for the PM2.5 Standard for the Johnstown Area

Source: Air Quality Modeling Final Rule Technical Support Document for the Transport Rule

(http://www.epa.gov/airtransport/pdfs/AQModeling.pdf)

II. SIP APPROVALS AND APPLICABLE REQUIREMENTS

In order for EPA to redesignate a nonattainment area to attainment, the applicable SIP 

revision must be fully approved by the EPA under Section 110(k) of the CAA. In 

addition, the state must have met all requirements applicable to the area under 

Section 110 and Part D-Plan Requirements for Nonattainment Areas. The specific 

requirements applicable to the Johnstown Area can be found in Sections 110(a)(2), and 

Part D Sections 172(c) (relating to nonattainment plan provisions), 173 (relating to permit 

requirements) and 176 (relating to limitations on certain federal assistance) of the CAA. 

The U.S. Court of Appeals for the D.C. Circuit has also recently held that EPA must 

implement the PM2.5 NAAQS pursuant to Subpart 4 of Part D – see Section III below for 

more information.

Site ID County

Form of 

Standard

2003-2007 

Average 

Ambient 

Values

2003-2007 

Maximum 

Ambient 

Values

2012 Base 

Case 

Average 

Values

2012 Base 

Case 

Maximum 

Values

2014 Base 

Case 

Average 

Values

2014 Base 

Case 

Maximum 

Values

420210011 Cambria Annual 15.40 15.55 13.61 13.74 13.22 13.34

420210011 Cambria 24-Hour 39.0 39.4 34.3 34.7 32.8 33.3

PM2.5 Design Values (μg/m3)
- 17 -

These requirements have been fulfilled for the Johnstown Area.

A. Section 110(a)(2) of the CAA

Section 110(a) of the CAA contains the general requirements for a SIP. 

Pennsylvania concludes that, as EPA has stated in previous rulemaking in another 

state,

4

only the Section 110 and Part D requirements that are linked with a 

particular area’s designation are the relevant measures to consider in evaluating a 

redesignation request. Further, Pennsylvania believes that the other Section 110 

elements that are not connected with nonattainment plan submissions and not 

linked with an area’s attainment status are also not applicable requirements for 

purposes of redesignation. A state remains subject to these requirements after an 

area is redesignated to attainment.

The requirements of Section 110(a)(2) of the CAA that are statewide 

requirements and that are not linked to the PM2.5 nonattainment status of the 

Johnstown Area are not applicable requirements for purposes of review of the 

Commonwealth’s PM2.5 redesignation request. However, EPA requires that the 

Commonwealth’s Prevention of Significant Deterioration (PSD) requirements be 

approved prior to redesignation, because PSD requirements will apply after 

redesignation. Sections 110(a)(2)(C) and 110(a)(2)(J) of the CAA require state 

plans to meet the requirements of CAA, Subchapter I, Part C, which contains PSD 

requirements. In addition, Section 110(a)(2)(I) requires that a plan revision for an 

area designated as a nonattainment area meet the applicable requirements of 

CAA, Subchapter I, Part D (relating to nonattainment areas). Therefore, 

Pennsylvania has concluded that only the parts of Sections 110(a)(2)(C), 

110(a)(2)(I) and 110(a)(2)(J) that relate to Part D applicable requirements or PSD 

are applicable for purposes of redesignation.

EPA has previously approved provisions of Pennsylvania’s SIP addressing 

Section 110 requirements, including provisions addressing PM2.5. Pennsylvania’s 

SIP measures meeting Section 110(a)(2)(C) and 110(a)(2)(J) requirements are 

fully approved under Section 110(k) of the CAA. The Maintenance Plan 

associated with this Request for Redesignation for the Johnstown Area is a SIP 

revision for an area designated as a nonattainment area and meets the applicable 

requirements of Part D of Subchapter I of the CAA. Therefore, the Maintenance 

Plan associated with this Request for Redesignation meets the requirements of 

Section 110(a)(2)(I). Please see the discussion below concerning Part D (plan 

requirements for nonattainment areas).

 

4 See the EPA’s proposed approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland 

nonattainment area for the 1997 PM2.5 NAAQS (76 FR 79593). On December 31, 2012, the EPA published final 

approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland nonattainment area for the 

1997 PM2.5 NAAQS (77 FR 76883).
- 18 -

B. Part D - Plan Requirements for Nonattainment Areas

1. Section 172(c) of the CAA

Section 172 of the CAA contains the general provisions required to be 

included in SIP revisions for nonattainment areas. These include 

attainment demonstrations, reasonably available control measures, 

reasonable further progress, inventory data, and permitting requirements.

As stated above, on September 25, 2009, the EPA determined that the 

Johnstown Area had attained the 1997 PM2.5 NAAQS (“Clean Data 

Determination”) (73 FR 49949). EPA’s Clean Data Determination was 

based on quality-assured, quality-controlled and certified ambient air 

monitoring data that show the area had monitored attainment since the 

2006 through 2008 monitoring period. The Clean Data Determination 

suspended the requirements for this area to submit an attainment 

demonstration, associated reasonably available control measures, a 

reasonable further progress plan, contingency measures, and other 

planning SIP revisions related to attainment of the 1997 PM2.5 NAAQS for 

so long as the area continues to meet the 1997 PM2.5 NAAQS.

On March 29, 2012, the EPA determined that the Johnstown Area had 

attained the 2006 PM2.5 NAAQS based on quality assured, quality 

controlled and certified ambient air monitoring data that show the area had 

monitored attainment based on 2008 through 2010 data (“Clean Data 

Determination”) (77 FR 18922). This final action suspended the 

requirements for this area to submit an attainment demonstration and 

associated reasonably available control measures, reasonable further 

progress plans, contingency measures and other planning SIP revisions 

related to the attainment of the 2006 PM2.5 NAAQS for so long as the area 

continues to attain the 2006 PM2.5 NAAQS.

Submittal of a comprehensive inventory is required by 40 CFR

Section 51.1008 to meet the requirements of Section 172(c)(3) of the 

CAA. This requirement was not suspended by the Clean Data 

Determination. In fulfillment of this requirement, the 2007 inventory, 

which also serves as the attainment year inventory, is being submitted as 

part of the Maintenance Plan, submitted concurrently with this Request for

Redesignation.

2. Section 173 of the CAA

Section 173 of the CAA outlines requirements related to permitting of air 

pollution sources in nonattainment areas.
- 19 -

Stationary air pollution sources are subject to the regulations of the 

Commonwealth of Pennsylvania, Pennsylvania Code in Title 25 

Environmental Resources (25 Pa. Code Chapters 121-145). These 

regulations include:

● Standards of Performance for New Stationary Sources 

promulgated by EPA under the Clean Air Act (25 Pa. Code

Chapter 122);

● Standards for Contaminants (25 Pa. Code Chapter 123);

● National Emission Standards for Hazardous Air Pollutants (25 Pa. 

Code Chapter 124);

● Construction, Modification, Reactivation and Operation of 

Sources, including plan approval, prevention of significant 

deterioration, new source review, operating permit program 

(25 Pa. Code Chapter 127);

● Standards for Sources (25 Pa. Code Chapter 129); and

● Annual Emission Statements and required reporting to the 

Department (25 Pa. Code Chapter 135).

These permitting, stationary source monitoring and reporting, 

preconstruction review, offset ratios and enforceable emission limitations 

requirements were adopted to implement the federally mandated 

requirements in Sections 110, 172, 173 and 182(a) of the CAA. EPA has 

approved all of these regulations as SIP revisions, as indicated in 

Section III of this document.

3. Section 176 of the CAA

Section 176(c) of the CAA contains the provision prohibiting federal 

financing of projects or activities that do not conform to an approved 

implementation plan.

The Commonwealth adopted and incorporated EPA’s General Conformity 

rule (40 CFR Part 93, Subpart B) by reference in its entirety in 25 Pa. 

Code Section 127.802. The General Conformity regulation describes 

procedures to determine if federally-financed, non-transportation projects 

are in conformity with air quality plans.

EPA and the U.S. Department of Transportation (DOT) have issued 

regulations regarding criteria and procedures for demonstrating and 

assuring conformity of transportation improvement programs (TIP or 
- 20 -

program), long range plans (LRP or plan), and individual transportation 

projects with the requirements of the CAA and the SIP for the specific 

nonattainment area. Affected transportation planning organizations are 

complying with all federal laws, regulations and guidance for 

transportation conformity.

4. Section 189(e) of the CAA

In light of a recent court decision, Natural Resources Defense Council v. 

EPA, No. 08-1250, 706 F.3d 428 (D.C. Cir. 2013) (see discussion in 

Section III), the Department considered Section 189(e) of the CAA. 

According to Section 189(e) and the court decision, control requirements 

in nonattainment areas applicable for major stationary sources of PM also 

apply to major stationary sources of PM precursors. Pennsylvania 

assessed emissions of PM2.5, SO2, NOX, VOC and NH3 for the 

maintenance demonstration. Please see Section III-C-1 relating to control 

measures for stationary sources for a discussion of the stationary source 

control measures in place in the Johnstown Area.

C. Conclusion

The requirements of Section 110(a) and Subpart D of the CAA have been fulfilled

in the Johnstown Area for the 1997 and 2006 PM2.5 NAAQS. 

III. DEMONSTRATION OF PERMANENT AND ENFORCEABLE IMPROVEMENT

This section provides an assessment of the PM2.5 and PM2.5 precursor emissions at a time 

the Johnstown Area was monitoring nonattainment of the PM2.5 NAAQS and at the time 

when this area attained the PM2.5 NAAQS.5 A 2005 (baseline) inventory of PM2.5 and 

PM2.5 precursor emissions is used to represent emissions during the PM2.5 nonattainment 

designation period. A 2007 inventory is used to identify PM2.5 and PM2.5 precursor 

emissions during a period when the Johnstown Area demonstrated that it attained the 

PM2.5 NAAQS. Detailed information is presented by sector in the Maintenance Plan 

submitted concurrently with this Request to Redesignate.

Because of the complexity and variability of the process of particulate matter formation, 

the EPA recognizes that the chemical and physical properties of particulate matter vary 

greatly with time, region, meteorology and source category.6 Therefore, effective control 

measures for PM2.5 will vary among nonattainment areas. 

By way of background, EPA issued its “Implementation Guidance for the 2006 24-Hour 

Fine Particle National Ambient Air Quality Standard,” on March 2, 2012 (later 

withdrawn). In the Implementation Guidance for the 2006 PM2.5 NAAQS, EPA adopted 

 

5 Throughout this document, emissions inventory data was rounded to the nearest tenth of a ton prior to

summarizing the emissions inventory data.

6 National Ambient Air Quality Standards for PM2.5, 71 FR 61144, October 17, 2006
- 21 -

the framework and policy approach the agency espoused in its implementation rule for 

the 1997 PM2.5 NAAQS, known as the “Clean Air Fine Particle Implementation Rule

(72 FR 20586; April 25, 2007) (the Implementation Rule for the 1997 PM2.5 NAAQS”)

In its Implementation Rule for the 1997 PM2.5 NAAQS, EPA established general 

presumptive policies for assessing which PM2.5 precursors should be evaluated for 

possible controls. In that earlier rule, the EPA required states to evaluate control 

measures for SO2 and primary PM2.5 in all locations. The EPA required states to evaluate 

control measures for NOX unless a technical demonstration is made to show NOX does 

not significantly contribute to PM2.5. The EPA required states to evaluate measures for 

VOC and NH3 only if a technical demonstration is made to show they significantly 

contribute to PM2.5 in that area.

The EPA reaffirmed the appropriateness of these presumptions in its Implementation 

Guidance for the 2006 24-Hour PM2.5 NAAQS. Meanwhile, the U.S. Court of Appeals 

for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997 

PM2.5 NAAQS, in Natural Resources Defense Council v. EPA, No. 08-1250. On 

January 4, 2013, the Court handed down its ruling in that case. 

The Court granted the petitions for review and remanded the case to EPA to 

re-promulgate the rule pursuant to Subpart 4 of Part D of the Clean Air Act, rather than 

implementing it under Subpart 1, as EPA had done (706 F.3d 428, 437 (D.C. Cir. 2013)). 

Shortly thereafter, the EPA withdrew its Implementation Guidance for the 2006 24-Hour 

PM2.5 NAAQS. According to EPA’s June 6, 2013, withdrawal memorandum (see second

page of memorandum)7, EPA withdrew the guidance in response to the Court’s decision 

in Natural Resources Defense Council v. EPA, No. 08-1250.

The Maintenance Plan accompanying this Request for Redesignation demonstrates 

maintenance of the standards consistent with the Court’s ruling.

In general, the Court’s decision (for the 1997 PM2.5 NAAQS and to the extent it would be 

extrapolated to the 2006 24-Hour PM2.5 NAAQS) could affect an area’s nonattainment 

classification, certain deadlines, and the impacts of failing to attain timely, and could 

impose a deadline for implementation of reasonably available and best available control 

measures (706 F.3d at 436, n. 6). Because the Johnstown Area is already attaining the 

1997 and 2006 PM2.5 NAAQS, those considerations are not relevant for this Request for 

Redesignation and the Maintenance Plan. The Court noted that PM2.5 precursors, 

including ammonia and VOCs, are presumptively regulated in PM2.5 nonattainment areas 

under Subpart 4, pointing specifically to Section 189(e), which applies to control of 

major stationary sources of PM10 [the court stated that PM10 includes PM2.5 throughout 

Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to Section 189(e) of the 

CAA, control requirements applicable for major stationary sources of PM10 also apply to 

major stationary sources of PM10 precursors, except where the Administrator determines 

 

7 “Withdrawal of Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air 

Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013.
- 22 -

that major stationary sources do not contribute significantly to PM10 levels that exceed 

the standard in the area; Section 189(e) also requires the EPA to issue guidelines 

regarding the application of Subsection (e). 

Pennsylvania assessed emissions of PM2.5, SO2, NOX, VOC and NH3 for the maintenance 

demonstration. 

This Request for Redesignation provides emissions information for all pollutants (PM10, 

PM2.5, SO2, NOX, VOC and NH3), as required by the EPA’s guidance entitled, 

“Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter 

National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.”

8

Section III first describes the PM2.5 and PM2.5 precursor emission estimates for the 

Johnstown Area. These inventories have been developed in accordance with the EPA 

emission inventory preparation guidance. The section then presents information about 

the permanent and enforceable control measures that have been implemented in the 

Johnstown Area to produce the emission reductions that have occurred between these 

years and that will provide emission reductions ensuring maintenance of the PM2.5

standards.

A. Baseline (2005) Emissions Inventory

An emissions inventory is an estimate of the emissions from sources in a 

particular area. The 2005 baseline year inventory represents the emissions present 

when the Johnstown Area did not meet the PM2.5 standards. The Department 

considered using 2002 as the baseline year; however, emissions from the Homer 

City electric generating facility were uncharacteristically low in 2002, so the 

Department opted to use 2005 as the baseline year. The 2005 National Emissions 

Inventory (NEI) was the next available periodic emissions inventory developed by 

the EPA.

The 2005 NEI is a composite of emission estimates reported by state and local 

agencies and industry, as well as estimates generated by the EPA. The 2005 NEI 

was based in part on information submitted by the Department under the 

Consolidated Emissions Reporting Rule (CERR), which was published in the 

Federal Register on Monday, June 10, 2002 (67 FR 39602). The CERR required 

States to prepare and submit a comprehensive statewide inventory every three 

years. 

The inventory contains information for the pollutants PM10, PM2.5, SO2, NOX, 

VOC, and NH3 for these sectors:

● “Stationary sources” (or “point” sources), which are sources for which the 

Department collects individual emissions-related information. Generally, 

they represent major stationary sources but may be smaller.

 

8 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations – EPA-454/R-05-001, August, 2005, updated November, 2005.
- 23 -

● “Area sources,” which are industrial, commercial, and residential sources 

too small or too numerous to be handled individually. These sources 

include, but are not limited to, commercial and residential open burning, 

architectural and industrial maintenance coatings application and clean-up, 

consumer product use, and vehicle refueling at service stations. Where 

there is overlap between stationary point sources and stationary area 

sources, the area source values are adjusted to remove any double 

counting.

● “Highway vehicles,” which include passenger cars and light-duty trucks, 

other trucks, buses and motorcycles. 

● “Nonroad sources,” which encompass a diverse collection of engines, 

including, but not limited to, outdoor power equipment, recreational 

vehicles, farm and construction machinery, lawn and garden equipment, 

industrial equipment, recreational marine vessels, commercial marine 

vessels, locomotives, ships, and aircraft.

Highway vehicle emissions in the 2005 NEI were generated using the MOBILE6 

model. It is problematic to compare results generated by MOBILE6 to results 

generated by MOVES2010 (Motor Vehicle Emission Simulator). For the same 

Vehicle MilesTraveled (VMT) and other parameters, the MOBILE6 model 

predicts higher VOC and significantly lower NOX and PM2.5 emissions than 

MOVES2010, which was used to generate the 2007, 2017 and 2025 inventories. 

In addition, the Department’s MOVES2010 runs use more detailed road segment 

data necessary to properly apportion the emissions to the partial Indiana County 

portion of the nonattainment area. Therefore, the Department did not use the 

2005 NEI emission estimates for highway vehicle emissions. Instead, the 

Department linearly interpolated MOVES2010 emission estimates for the 

Johnstown Area that were available for 2002 and 2007.

A summary of the 2005 inventory is shown in Table III-1. 

Table III-1: 2005 Johnstown Area Annual Emissions (Tons per Year)

Johnstown 2005 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 11,872.3 14,854.9 152,657.3 41,646.4 343.4 5.0

Area Sources 1,200.9 5,997.3 1,858.7 750.7 3,092.4 511.2

Highway Vehicle Sources 141.8 169.4 61.2 4,482.7 1,919.1 67.1

Non-Road Sources 84.2 89.2 111.8 1,363.8 944.8 0.8

Totals 13,299 21,111 154,689 48,244 6,300 584
- 24 -

B. Attainment Year (2007) Emissions Inventory

A 2007 inventory of PM10, PM2.5, SO2, NOX, VOC and NH3 emissions for the 

Johnstown Area is used to identify emissions during the period when attainment 

of the PM2.5 NAAQS was demonstrated for the Johnstown Area. A summary of 

the 2007 inventory is provided in Table III-2. The Maintenance Plan describes 

how the 2007 inventory was compiled. The Technical Appendices to the 

Maintenance Plan contain more detailed information for each sector.

Table III-2: 2007 Johnstown Area Annual Emissions (Tons per Year)

Johnstown 2007 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 3,091.4 4,989.5 143,322.4 41,875.4 242.3 35.4

Area Sources 719.1 1,683.5 858.3 607.2 2,415.3 408.3

Highway Vehicle Sources 131.4 159.1 29.9 4,011.0 1,770.2 63.0

Non-Road Sources 89.3 96.9 41.8 1,463.9 897.2 1.1

Totals 4,031 6,929 144,252 47,958 5,325 508

While care should be used in comparing the 2005 emissions inventory to the 2007 

emissions inventory due to methodology differences between those inventories, 

PM2.5, PM10, SO2, NOX, VOC, and NH3 emissions decreased by 70 percent, 

67 percent, 7 percent, 1 percent, 15 percent and 13 percent, respectively, from 

2005 to 2007, as shown in Table III-2.

The permanent and enforceable reductions of emissions between 2005 and 2007, 

as described in more detail throughout this Section III, led to the improvement in 

air quality observed in that time period. 

C. Control Measures

Along with the analysis of ambient air quality and contributing factors in 

Section I of this Request for Redesignation, this section describes the permanent 

and enforceable federal and state measures that provided PM2.5, SO2, NOX and 

VOC emission reductions from 2005 to 2007 to bring the Johnstown Area into 

attainment and measures that will assure maintenance of the standards.

The EPA’s Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS

adopted the same presumptions related to PM2.5 precursors as the EPA’s 

Implementation Rule for the 1997 PM2.5 NAAQS. However, Pennsylvania 

recognizes the Court decision in Natural Resources Defense Council v. EPA, 

No. 08-1250, 706 F.3d 428 (D.C. Cir. 2013) and the EPA’s subsequent 

withdrawal of the Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS. 

In general, the Court’s decision (for the 1997 PM2.5 NAAQS and to the extent it 

would be extrapolated to the 2006 24-Hour PM2.5 NAAQS) could affect an area’s 

nonattainment classification, certain deadlines, and the impacts of failing to attain 
- 25 -

timely, and could impose a deadline for implementation of reasonably available 

and best available control measures (706 F.3d at 436, n. 6). Since the Johnstown

Area is already attaining the 1997 and 2006 24-Hour PM2.5 NAAQS, however, 

those considerations are not relevant for this Redesignation Request or the 

accompanying Maintenance Plan.

The Court noted that PM2.5 precursors are presumptively regulated in PM2.5

nonattainment areas under Subpart 4, pointing specifically to Section 189(e), 

which applies to control of major stationary sources of PM10 [the Court stated that 

PM10 includes PM2.5 throughout Subpart 4]. (706 F.3d at 436, n. 7, and at 

437, n. 10). According to CAA Section 189(e), control requirements applicable 

for major stationary sources of PM10 also apply to major stationary sources of 

PM10 precursors, except where the Administrator determines that major stationary 

sources do not contribute significantly to PM10 levels that exceed the standard in 

the area; Section 189(e) also requires the EPA to issue guidelines regarding the 

application of Subsection (e). Pennsylvania assessed emissions of PM2.5, SO2, 

NOX, VOC and NH3 for the maintenance demonstration.

The permanent and enforceable reductions of emissions between 2005 and 2007, 

as described in more detail throughout this Section III, led to the improvement in 

air quality observed in that time period. Emissions of PM2.5, PM10, SO2, NOX, 

VOC, and NH3 emissions decreased by 70 percent, 67 percent, 7 percent, 

1 percent, 15 percent and 13 percent, respectively, from 2005 to 2007. A

summary of the change in emissions from 2005 to 2007 is included in Table III-3. 

(Negative values indicate emission reductions.)

Table III-3: Change in Johnstown Area Annual Emissions (Tons per Year)

from 2005 to 2007

Change from 2005 to 2007 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources -8,780.9 -9,865.4 -9,334.9 229.0 -101.1 30.4

Area Sources -481.8 -4,313.8 -1,000.4 -143.5 -677.1 -102.9

Highway Vehicle Sources -10.4 -10.3 -31.3 -471.7 -148.9 -4.1

Non-Road Sources 5.1 7.7 -70.0 100.1 -47.6 0.3

Total -9,268 -14,182 -10,437 -286 -975 -76

This section also describes the federal and state measures that will provide direct 

PM2.5, SO2, NOX and VOC emission reductions, ensuring maintenance of the 

standards.

A summary of the total emissions in 2007 and projected estimates for 2017 and 

2025 is included in Table III-4. The emission estimates account for any 

anticipated growth in the activity of sources and include a transportation 

conformity safety margin for PM2.5 and NOX. For all pollutants, emissions in

2017 and 2025 in the Johnstown Area are anticipated to be lower than they were 

in 2007. This means that the projected growth in emissions is smaller than 
- 26 -

anticipated emission reductions from control measures for all pollutants, in the 

nonattainment area. In addition, the Johnstown Area currently has an annual

design value based on 2011-2013 monitoring data of 12.3 μg/m3, which is 

significantly lower than the 1997 NAAQS of 15 μg/m3. Based on 2011-2013

monitoring data, the Johnstown Area has a 24-hour design value of 30 μg/m3 

which is significantly lower than the 2006 PM NAAQS of 35 μg/m3. Each 

measure is explained in greater detail in the following sections.

Table III-4: Summary of Emission Totals (Tons) in 2007, 2017 and 2025

Johnstown PM2.5 SO2 NOx VOC NH3

2007 4,031 144,252 47,958 5,325 508

2017* 3,605 132,823 41,046 3,925 490

2025* 3,741 141,932 43,110 3,471 494

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and 

NOX has been set aside as a transportation conformity safety margin to accommodate unanticipated 

growth in highway vehicles. The emissions in Table III-4 reflect inclusion of that safety margin.

1. Stationary Point Sources

Background for Pennsylvania’s Stationary Source Permitting 

Programs. An owner or operator of a proposed new air contamination 

sources in the Commonwealth is required to receive a plan approval (preconstruction permit) from the Department prior to the construction, 

assembly, installation of new sources, modification of any existing 

stationary air contamination sources, or the installation of air pollution 

control equipment or devices. Following the construction of the new 

facility or air contamination source, the owner or operator must obtain an 

operating permit from the Department. The type of operating permit will 

depend on the quantity of regulated pollutants emitted from the air 

contamination sources. DEP will issue a “State-only Operating Permit” 

for minor air contamination stationary sources that are below the 

applicability thresholds for Title V facilities. A “Title V Operating 

Permit” is required for major facilities that have the potential to emit air 

contaminants exceeding the Title V thresholds. The Title V Permit, which 

is issued for a term of five years, incorporates all applicable requirements 

for the facility in a single federally enforceable operating permit. 

The requirements contained in 25 Pa. Code Chapter 127 (relating to the 

construction, modification, reactivation and operation of sources), and 

associated definitions in 25 Pa. Code §121.1, are a suite of programs 

regulating air contamination sources to improve and maintain air quality. 

Chapter 127 establishes requirements for the submission, review and 

approval of pre-construction and operating permits for both major and 

non-major air contamination sources. The provisions of Chapter 127 have 

been codified in the SIP at 40 CFR §52.2020(c)(1) at various times since 

May 31, 1972, and most recently on October 5, 2012, and are therefore all 
- 27 -

federally enforceable. Several aspects of Chapter 127 are highlighted 

below.

Title V Permitting Program. The Title V Permitting Program, 

adopted pursuant to the Clean Air Act Amendments of 1990, is 

applicable to major stationary sources as defined in 25 Pa. Code

§121.1. The purpose of the Title V program is to consolidate a 

facility’s air quality requirements in a single permit document so 

that industry, the regulatory agency, and the public know exactly 

what regulations and requirements apply and how the facility’s 

owner or operator will monitor and demonstrate compliance with 

all applicable requirements. The Title V permit includes all 

sources at a site including all air pollution control devices as well 

as activities that were determined to be insignificant sources of 

emissions. Each source is described in detail within a section of 

the Title V permit. The requirements include general conditions 

applicable to all Title V facilities, emission restrictions, detailed 

monitoring, recordkeeping, and reporting requirements to assure 

compliance with the facility’s applicable federal and state 

requirements. The Title V Operating Permits Program 

requirements are codified in 25 Pa. Code Chapter 127, 

Subchapters F and G (relating to operating permit requirements; 

and Title V operating permits). The program was fully approved 

by the EPA on July 30, 1996 (61 FR 39597).

Nonattainment New Source Review and Prevention of Significant 

Deterioration. Major facilities proposed in Pennsylvania will also be 

subject to New Source Review (NSR) requirements in nonattainment areas 

and Prevention of Significant Deterioration (PSD) requirements in areas of 

the Commonwealth designated attainment for National Ambient Air 

Quality Standards including carbon monoxide, PM, lead, nitrogen dioxide 

(NO2), ozone and SO2. Generally, NSR permit requirements are 

applicable to the owner and operator of a facility located in a 

nonattainment area for a particular pollutant with a potential to emit 50 or 

more tons per year (tpy) of volatile organic compounds or 100 tpy or more 

of NOX, SO2, PM, or carbon monoxide. It should be noted that the entire 

Commonwealth, included in the Ozone Transport Region by operation of 

law, is treated as a “moderate” ozone nonattainment area, irrespective of 

the area’s attainment status for the ozone precursors, nitrogen oxides 

(NOX) and volatile organic compounds (VOCs). Because NOX and VOC 

are also precursors of PM2.5, NOX and VOC emission reductions required 

statewide under the nonattainment NSR program for ozone also allow 

Pennsylvania to make substantial progress in attaining and maintaining the 

PM2.5 NAAQS. Any major stationary source or major modification 

subject to the NSR requirements must receive a plan approval. To receive 

approval from the Department, a person must show that the proposed 
- 28 -

source will, among other things, offset its potential to emit air 

contaminants including NOX, PM, and VOCs by securing emission 

reductions credits at the specified offset ratio, will employ the “lowest 

achievable emission rate” (LAER) for each regulated pollutant and 

conduct an alternative analysis. The nonattainment NSR requirements are 

codified in 25 Pa. Code Chapter 127, Subchapter E (relating to new source 

review) and approved as a SIP revision on December 9, 1997 

(62 FR 64722).

The PSD program is a pre-construction review and permitting program 

applicable to new or modified major stationary sources subject to Title I, 

Parts C and D of the federal CAA. The PSD requirements are applicable 

to major sources in areas attaining the NAAQS. The federal PSD 

regulations codified in 40 CFR Part 52 are incorporated by reference in 

their entirety in 25 Pa. Code §127.83 (relating to adoption by reference). 

The Department’s PSD regulations, codified in 25 Pa. Code Chapter 127, 

Subchapter D (relating to prevention of significant deterioration of air 

quality), were approved by the EPA on August 21, 1984 and codified at 

40 CFR §52.2058 (49 FR 33128).). PSD permit requirements may apply 

to the owner and operator of a facility located in an attainment area for a 

standard with the potential to emit 100 tpy or 250 tpy of the six criteria 

pollutants including carbon monoxide, lead, NO2, ozone, PM, and SO2

depending on the source category. Any major stationary source or major 

modification subject to the PSD requirements must conduct an analysis to 

establish the best available control technology (BACT). In addition, the 

owner or operator of a facility needs to conduct an ambient air quality 

analysis, analyze the impacts to soils, vegetation and visibility and make 

sure that the project will not adversely impact mandatory federal Class I 

areas including national parks greater than 6,000 acres and national 

wilderness areas and national memorial parks greater than 5,000 acres. 

Best Available Technology Program. The Department’s Best Available 

Technology (BAT) Program ensures that new stationary sources will 

prevent, reduce or control emissions of air contaminants to the maximum 

degree possible. The Department determines BAT requirements on a 

case-by-case basis for both major and minor stationary sources taking into 

account energy, environmental benefits, and costs. Pursuant to 25 Pa. 

Code §127.1 (relating to purpose), the emission of air pollutants from new 

sources in Pennsylvania must be controlled to the maximum extent, 

consistent with BAT as determined by the Department as of the date of 

issuance of the plan approval for the new source. Under 25 Pa. Code

§127.12(a)(5) (relating to content of applications), an application for a 

plan approval must show that the emissions from a new source will be the 

minimum attainable through the use of BAT. Pennsylvania regulations 

define “best available technology” in 25 Pa. Code §121.1 as, “Equipment, 

devices, methods or techniques as determined by the Department which 
- 29 -

will prevent, reduce or control emissions of air contaminants to the 

maximum degree possible and which are available or may be made 

available.” The Department’s BAT regulations, codified in 25 Pa. Code

§§127.1 and 127.12(a)(5), were approved by the EPA on July 30, 1996, 

and codified in the SIP at 40 CFR §52.2020(c)(1).

NOX and SO2 Control Programs. In 1998, the EPA promulgated the 

NOX SIP Call as the EPA’s principal effort to reduce interstate transport of 

air pollution (63 FR 57356; October 27, 1998). In response to the federal 

NOX SIP call rule, Pennsylvania adopted the NOX Budget Trading 

Program regulations for EGUs and large industrial boilers, with emission 

reductions to commence May 1, 2003. The regulations were approved by 

the EPA as a revision to the Commonwealth’s SIP on August 21, 2001 

(66 FR 43795). Additionally, in response to the NOX SIP Call, 

Pennsylvania adopted additional NOX control regulations covering cement 

plants and internal combustion engines, with emission reductions to 

commence May 1, 2005. These regulations were approved by the EPA as 

a SIP revision on September 29, 2006 (71 FR 57428).

Clean Air Interstate Rule (CAIR). In 2005, the EPA adopted CAIR 

(70 FR 25162; May 12, 2005, as amended) to address interstate transport 

of NOX and SO2. CAIR is now being implemented in Pennsylvania 

through the Department’s CAIR regulation, codified in 25 Pa. Code

Chapter 145, Subchapter D (relating to CAIR NOX and SO2 trading 

programs), with related amendments in Chapters 121, 129 and 145

(relating to general; standards for sources; and interstate pollution 

transport reduction). The EPA approved Pennsylvania’s CAIR SIP 

revision on December 10, 2009, codified at 40 CFR §52.2020(c)(1)

(74 FR 65446). In the CAIR SIP revision, Pennsylvania terminated the 

NOX Budget Trading Program and transitioned to the federal CAIR for 

large electric generating units (EGU).

The market-based CAIR is designed to reduce EGU emissions of NOX and 

SO2 below 2002 levels throughout the eastern United States. 

Pennsylvania and the other CAIR states were required to adopt a 

regulation implementing the requirements of the CAIR or an equivalent 

program. The large EGUs in Pennsylvania were initially regulated under 

CAIR federal implementation plans (FIP) promulgated by the EPA, but 

have been regulated under the SIP since the EPA approved Pennsylvania’s 

CAIR SIP revision. Under the SIP revision, Pennsylvania participates in 

the EPA-administered cap-and-trade programs for NOX annual, NOX

ozone season, and SO2 annual emissions.

The EPA’s CAIR was remanded to the EPA for revisions by the United 

States Court of Appeals for the District of Columbia on December 23, 

2008 (See, North Carolina v. EPA, 531 F.3d 896, modified, 550 F.3d 1176 
- 30 -

(D.C. Cir. 2008)). Following remand, the EPA replaced CAIR with the 

Cross-State Air Pollution Rule (CSAPR), but in a separate legal challenge 

the court vacated CSAPR. In that ruling, the court ordered the EPA to 

continue administering CAIR pending the promulgation of a valid 

replacement (see, EME Homer City Generation L.P. v. EPA, 696 F.3d 7 

(D.C. Cir. 2012)). On April 29, 2014, the Supreme Court of the United 

States reversed the Court of Appeals’ decision that had vacated the 

CSAPR. EPA v. EME Homer City Generation, L.P., 134 S. Ct. 1584 

(U.S. 2014). The Supreme Court remanded the case to the D.C. Circuit 

Court of Appeals for further proceedings. On October 23, 2014, the D.C.

Circuit granted the EPA’s motion requesting that the Court lift the stay of 

the CSAPR imposed by the Court in December 2011.

According to the EPA, emission reductions originally required under 

CAIR will be made permanent and enforceable through the 

implementation of CSAPR. See the EPA’s proposed rule, “Redesignation 

of the Harrisburg-Lebanon-Carlisle-York Nonattainment Areas to

Attainment for the 1997 Annual and the 2006 24-Hour Fine Particulate 

Matter Standard,” 79 FR 62389 (October 17, 2014), in which the EPA 

wrote: “Provided that the stay is lifted and the EPA’s tolled compliance 

deadlines are put in place, the emission reductions associated with CAIR 

that helped the Areas achieve attainment of the 1997 annual and the 2006 

24-hour PM2.5 NAAQS would be permanent and enforceable for purposes 

of redesignation under Section 107(d)(3)(E)(iii) of the CAA, because 

CSAPR requires similar or greater emission reductions from relevant 

upwind areas starting in 2015 and beyond.” See 79 FR 62392.

Cross-State Air Pollution Rule (CSAPR). In 2011, the EPA promulgated 

the CSAPR to replace CAIR following the judicial remand of CAIR, as 

explained above. In CSAPR, EPA established emissions budgets for 

covered EGUs in 28 states and promulgated FIPs to achieve the reductions 

(76 FR 48208; August 8, 2011). Although CSAPR allows emissions 

trading, it also maintains state-specific limits by means of assurance 

provisions designed to ensure that the necessary emission reductions occur 

within each covered state. The CSAPR FIPs for Pennsylvania are codified 

in 40 CFR §§52.2040 and 52.2041.

As explained above, CSAPR was challenged in court in 2011, in EPA v. 

EME Homer City Generation, L.P., 134 S. Ct. 1584 (U.S. 2014). In 

December 2011, the D.C. Circuit imposed a stay on CSAPR. On 

October 23, 2014, however, the court lifted the stay.

NOX Budget Trading Program limits on non-EGUs. The CAIR SIP 

revision also established emission limits for the non-EGUs and other units 

that were subject to the Commonwealth’s NOX Budget Trading Program 

but are not subject to the CAIR NOX Ozone Season Trading Program. 
- 31 -

These units must continue monitoring NOX emissions and must meet an 

emissions cap. Each unit has an allowable emission rate, calculated by 

January 31 of each year, based on the previous ozone season’s heat input. 

The Department’s regulation, codified in 25 Pa. Code §145.8(d) (relating 

to transition to CAIR NOX trading programs), was approved by EPA on 

December 10, 2009, and codified in the SIP at 40 CFR §52.2020(c)(1).

Cement kilns and large stationary internal combustion engines. The 

CAIR SIP revision also included regulations updating the cement 

manufacturing and large stationary internal combustion engine regulations 

that were adopted pursuant to the NOX SIP Call. 

The Department’s regulations for large stationary internal combustion 

engines and cement kilns, codified in 25 Pa. Code Chapter 145, 

Subchapters B and C (relating to emissions of NOX from stationary 

internal combustion engines; and emissions of NOX from cement 

manufacturing), respectively, were approved by the EPA on December 10, 

2009, and codified at 40 CFR §51.2020(c)(1). An amendment to the 

Department’s regulation for cement kilns to reduce NOX emissions 

effective April 15, 2011, codified in 25 Pa. Code Chapter 145, 

Subchapter C (relating to emissions of NOX from cement manufacturing), 

was approved by the EPA on July 19, 2011 and codified at 40 CFR 

§51.2020(c)(1).

Federal Standards for Hazardous Air Pollutants. Federal standards to

control hazardous air pollutants (HAPs) require Maximum Achievable 

Control Technology (MACT) at units located at major sources of HAPs. 

The EPA has promulgated a series of MACT regulations that are 

applicable to sources in Pennsylvania. These MACT standards are 

adopted and incorporated by reference in Section 6.6 of Pennsylvania’s 

Air Pollution Control Act and implementing regulations in 25 Pa. Code

§127.35 (relating to maximum achievable control technology standards for 

hazardous air pollutants). The standards also included in federally 

enforceable plan approvals and operating permits issued by the 

Department for affected sources.

2. Highway Vehicle Sources

Even with increases in VMT that occurred between 2002 and 2007, and

are anticipated to occur from 2007 through 2025, highway vehicle 

emissions will continue to decrease. As more vehicles subject to cleaner 

new car standards replace older vehicles subject to less stringent new 

vehicle standards, the fleet as a whole emits fewer emissions, 

compensating for the increase in VMT. These decreases can be attributed 

to the programs described below.
- 32 -

Federal Motor Vehicle Control Programs (FMVCP) and 

Pennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established 

by the CAA Amendments of 1990 include NOX and VOC limits for lightduty gasoline vehicles (LDGVs) and light-duty gasoline trucks (LDGTs). 

These standards began to be phased in 1994. Evaporative VOC emissions 

were reduced in gasoline-powered cars starting with Model Year 

(MY) 1998.

In 1998, pursuant to Section 177 of the CAA, the Pennsylvania 

Environmental Quality Board (EQB) adopted the Pennsylvania Clean 

Vehicles Program (28 Pa.B. 5873; December 5, 1998). The Pennsylvania 

Clean Vehicles Program incorporates by reference certain California Low 

Emission Vehicle (CA LEV) emission standards for passenger cars and 

light-duty trucks. As required under Section 177 of the CAA, these 

provisions are identical to the low emission standards adopted by 

California. The regulation does not incorporate by reference the 

California zero emissions vehicle (ZEV) or emissions control warranty 

systems statement provisions.

In the same rulemaking, the EQB adopted the National Low Emission 

Vehicle (NLEV) program as a compliance alternative to the Pennsylvania 

Clean Vehicles Program. The NLEV program became effective in the 

Ozone Transport Region (OTR) in 1999. Pennsylvania’s New Motor 

Vehicle Emissions Control Program regulations in 25 Pa. Code

§§126.401-126.441 (relating to Pennsylvania Clean Vehicles Program)

allowed automobile manufacturers to comply with NLEV instead of the 

CA LEV program through MY 2005. These regulations affected vehicles 

6,000 pounds and less and were the regulations in effect for new motor 

vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV 

(Tier 2), starting with MY 2004. The NLEV program was replaced for 

MY 2004 and later by the more stringent Federal “Tier 2” vehicle 

emissions regulations (65 FR 6698; February 10, 2000), and vehicle 

manufacturers operating under the NLEV program became subject to the 

Tier 2 requirements.

Pennsylvania amended the former New Motor Vehicle Control Program in 

2006. The Clean Vehicles Program continues to incorporate the CA LEV

by reference. As amended, the program affects MY 2008 and newer 

passenger cars and light-duty trucks vehicles (36 Pa.B. 7424; December 9, 

2006, corrected 37 Pa.B. 209; January 12, 2007, eff. December 9, 2006). 

The EPA approved Pennsylvania’s Clean Vehicle Program as a revision to 

the Commonwealth’s SIP on January 24, 2012 (77 FR 3386).
- 33 -

Heavy-Duty Diesel Emissions Control Programs. The EPA 

promulgated more stringent national regulations for heavy-duty engines 

and vehicles (over 14,000 pounds) starting with MY 2004. In addition, 

consent decrees with seven of the largest heavy-duty engine manufacturers 

required, among other terms, that diesel engines made by these companies 

comply with these 2004 standards two model years early, in MY 2002. 

The emission reductions from these programs are reflected in the future 

year emission inventories, as provided in the Motor Vehicle Emission 

Simulator (MOVES) model.

In 2002, the EQB adopted the Heavy-Duty Diesel Emissions Control 

Program for model years starting after May 2004. The program 

incorporates California standards by reference and requires MY 2005 and 

subsequent new heavy-duty diesel highway engines to be those certified 

by California. California standards were more stringent than federal 

standards for the two model years between expiration of the consent 

decrees discussed above (MYs 2005 and 2006) and the implementation of 

more stringent federal standards affecting MY 2007 and beyond. 

However, the EPA’s MOVES model already assumed that the engines 

would comply with consent decree standards, even without an 

enforcement mechanism. The Department has used MOVES defaults to 

calculate emissions from MY 2005 and 2006 heavy-duty highway engines.

The EPA adopted new emission standards for heavy-duty engines and 

vehicles for MY 2007 and subsequent. For diesel engines, the standards 

were phased in from MY 2007 to 2010 for NOX and VOCs. For gasoline 

engines, the standards were phased in during MY 2008 and 2009. Federal 

and California standards are virtually identical for MY 2007. For 

MY 2008, California adopted requirements for idling restriction engine 

programming and an optional “clean NOX idle” standard. However, there 

is no EPA-approved methodology to estimate emission reductions from 

this requirement. Therefore, the emission estimates use assumptions of 

the federal rule for MY 2007 through 2010.

Because the new engine standards are adversely affected by sulfur in fuel,

the EPA also required most highway diesel fuel to contain no more than 

15 parts per million (ppm) of sulfur, beginning in the fall of 2006. There 

was a temporary compliance option allowing refiners to continue to 

produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

2010. The Department used MOVES defaults to estimate the effects of 

the phase-in provision.

Vehicle Emission Inspection/Maintenance Program. In early 2004, 

Pennsylvania expanded its Vehicle Emission Inspection/Maintenance 

(I/M) Program into the Johnstown Area. The program applies to gasoline-
- 34 -

powered vehicles 9,000 pounds and under, MY 1975 and newer. For 

vehicles 1996 and newer, the program consists of an annual on-board 

diagnostics test and a gas cap pressure test. For subject vehicles 1995 and 

older, the program consists of an annual visual inspection of pollution 

control devices to ensure they are present, connected, and the proper type 

for the vehicle and a gas cap pressure test. These regulations can be found 

in 67 Pa. Code Chapters 175 and 177 (relating to vehicle equipment and 

inspection; and emission inspection program). The Department submitted 

the expanded safety and emission inspection programs to the EPA as a SIP 

revision on December 1, 2003. The EPA approved the SIP revision on 

October 6, 2005 (70 FR 58313).

Low sulfur gasoline. Sulfur is a naturally occurring component of crude 

oil that ends up in gasoline and diesel unless removed. Sulfur in gasoline 

impairs the effectiveness of emission control systems and contributes to 

air pollution. By removing most sulfur from gasoline, new advanced 

emission controls will work longer and more efficiently, and air pollution 

will be reduced.

The 1999 federal Tier 2 regulations (65 FR 6698; February 10, 2000)

reduced the sulfur content of gasoline by up to 90 percent, enabling the 

use of new emission control technologies in cars and trucks that reduce 

harmful air pollution. The emission inventory analysis in the Maintenance 

Plan submitted concurrently with this Request for Redesignation uses the 

default assumptions provided in MOVES2010 to account for the 

implementation of the federal standards for low sulfur gasoline. 

Requirements for use of low-sulfur gasoline enabled use of advanced 

emission control systems in light-duty vehicles beginning in MY 2004. 

Vehicles meeting Tier 2 emission standards are 77 to 95 percent cleaner 

than earlier models.

The EPA signed a regulation adopting more stringent vehicle standards 

and reducing sulfur limits in gasoline further with the Tier 3 Motor 

Vehicle Emission and Fuel Standards program on March 3, 2014. The 

EPA published the regulation the Federal Register on April 28, 2014. 

(79 FR 23414). The rule takes effect in 2017. The Tier 3 program

requires the annual average content of sulfur in gasoline to be reduced to 

10 ppm, starting January 1, 2017. By 2018, the EPA estimates that SO2

emissions from gasoline vehicles will be reduced by 56 percent. When 

fully implemented, this program, by 2030, will increase the effectiveness 

of vehicle emission controls even further and reduce onroad emissions of 

NOX by 25 percent, direct particulate matter by 10 percent and VOCs by 

16 percent. The rule will also significantly reduce emissions of carbon 

monoxide and hazardous air pollutants including acrolein, benzene, 

formaldehyde, and acetaldehyde. Emission reductions from the federal 

Tier 3 program have not been included in future year inventories and, 
- 35 -

therefore, are not relied upon in the maintenance demonstration. Emission 

reductions from the Tier 3 program may nonetheless assist the Johnstown

Area in maintaining the PM2.5 NAAQS.

3. Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel-powered 

(“compression ignition”) and gasoline-powered (“spark ignition”) nonroad 

engines of various sizes (horsepower) and applications. Information on 

these federal rules, including their implementation dates, can be found at 

www.epa.gov/nonroad. The Department used the assumptions built into 

the nonroad model (NONROAD2005) and (National Mobile Inventory 

Model (NMIM) to estimate emissions for all milestone years.

While the EPA has published a notice of proposed rulemaking for more 

stringent standards for locomotives and large commercial marine diesel 

engines, the agency has not finalized any new standards.

On June 29, 2004, the EPA adopted a rule establishing a comprehensive 

national program to reduce emissions from nonroad diesel engines 

(69 FR 38958). The rule phased in requirements for reducing the sulfur 

content of diesel used in nonroad diesel engines. The reduction in fuel 

sulfur content prevents damage to the more advanced emission control 

systems needed to meet the engine standards; it will also reduce fine 

particulate emissions from diesel engines. In 2007, fuel sulfur levels were 

limited to 500 ppm for nonroad applications other than ocean-going 

marine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur 

concentration as in highway fuel, 15 ppm; this requirement began 

applying in 2012 to locomotive and marine diesel fuel. The EPA adopted 

technical amendments to the program in rules published in the Federal 

Register on November 22, 2005 (70 FR 70498), and May 1, 2006 

(71 FR 25706). On April 30, 2010 (75 FR 22896), the EPA adopted 

changes to the nonroad diesel fuel program to allow for the production and 

sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 

marine vessels. This requirement does not impact the Johnstown Area 

because the Johnstown Area does not have emissions from commercial 

marine vessels.

4. Stationary Area Sources

Consumer Products. The Consumer Products regulation applies 

statewide to any person who sells, supplies, offers for sale, or 

manufactures certain consumer products on or after January 1, 2005, for 

use in the Commonwealth. The program is codified in 25 Pa. Code

Chapter 130, Subchapter B. It was submitted to the EPA as a SIP revision 

on March 26, 2003, and approved on December 8, 2004 (69 FR 70895). 
- 36 -

Amendments to the Consumer Products regulations were adopted on 

October 11, 2008, submitted to the EPA as a SIP revision on March 11, 

2009, and approved on October 18, 2010 (75 FR 63717).

Adhesives, Sealants, Primers and Solvents. The EQB adopted a 

regulation in 2010 to control VOC emissions from adhesives, sealants, 

primers and solvents. This regulation was published in the Pennsylvania 

Bulletin on December 25, 2010 (40 Pa.B. 7340) and approved by the EPA 

as a SIP revision on September 26, 2012 (77 FR 59090).

IV. MAINTENANCE PLAN

The 1997 and 2006 PM2.5 NAAQS Maintenance Plan for the Johnstown Area is being 

submitted to the EPA for approval as a State Implementation Plan (SIP) revision 

concurrently with this Request for Redesignation. The Maintenance Plan shows that the 

1997 and 2006 PM2.5 NAAQS will be maintained for at least 10 years after redesignation. 

Eight years following redesignation, the Commonwealth will submit a revised plan that 

ensures attainment through 2035.

The Maintenance Plan demonstrates that emission levels of PM2.5, SO2, NOX, VOC and 

NH3 over the 10 years following redesignation will remain below the emissions level in 

2007, while allowing for growth in population and vehicle miles traveled. Based on 

2011-2013 monitoring data, the Johnstown Area currently has an annual design value of 

12.3 μg/m3, which is significantly lower than the 1997 NAAQS of 15 μg/m3. In addition, 

based on 2011-2013 monitoring data, the Johnstown Area has a 24-hour design value of 

30 μg/m3 which is significantly lower than the 2006 NAAQS of 35 μg/m3. The following 

state and federal programs will ensure the continuing decline of SO2, NOX, direct PM2.5

and VOC emissions:

● Clean Air Interstate Rule;

● Emission limits for large industrial boilers;

● State regulation of cement kilns, large stationary internal combustion engines, and

smaller sources of NOX;

● State regulations incorporating by reference the federal Prevention of Significant 

Deterioration (PSD) regulations; 

● State requirements for Best Available Technology (BAT);

● State regulation of the sulfur content of fuel oil;

● State regulation of VOC emissions from adhesives, sealants, primers and solvents;
- 37 -

● The Pennsylvania and federal new motor vehicle emission control programs for 

passenger and light-duty trucks;

● The Pennsylvania and federal heavy-duty diesel emission control programs;

● Federal fuel programs for highway vehicles and nonroad mobile equipment; and

● Federal regulation of off-road diesel and gasoline-powered vehicles and 

equipment.

The emission reductions from the following programs were not included in the 2017 and 

2025 emission inventories and, thus, were not relied upon for the demonstration of 

maintenance. However, emission reductions from these measures may nonetheless assist 

the Johnstown Area in maintaining air quality.

 The Diesel-Powered Motor Vehicle Idling Act, Act 124 of 2008 (Idling Act). The 

Idling Act was approved by EPA as a SIP revision on August 1, 2011 

(76 FR 45705). 

 NOX and VOC emission reductions from Pennsylvania’s Outdoor Wood-Fired 

Boilers regulation. The Outdoor Wood-Fired Boiler regulation was published in 

the Pennsylvania Bulletin on October 2, 2010 (40 Pa.B. 5571) and approved by 

the EPA as a SIP revision on September 20, 2011 (76 FR 58114). 

 The federal Tier 3 Motor Vehicle Emission and Fuel Standards program. 

(79 FR 23414).

DEP has provided in the Maintenance Plan for the 1997 and 2006 PM2.5 NAAQS

assurances that it will continue to operate the ambient air quality monitoring network in 

order to track maintenance of the standard and to evaluate emissions inventories 

periodically compared to the projections provided in the plan. DEP has also provided in 

the Maintenance Plan a list of contingency measures that it would consider to correct any 

violation of the 1997 PM2.5 NAAQS that might occur after redesignation of the area.
- 38 -

ACRONYMS AND ABBREVIATIONS

AEO Annual Energy Outlook

AQS EPA’s Air Quality System

AQTAC DEP’s Air Quality Technical Advisory Committee

BACT Best Available Control Technology

BAT Best Available Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CA LEV California Low Emission Vehicle (program)

CAMx Comprehensive Air Quality Model with Extension

CFR Code of Federal Regulations

CMV Commercial Marine Vessel

CSAPR Cross-State Air Pollution Rule

DEP Pennsylvania Department of Environmental Protection

DOT U.S. Department of Transportation

EGU Electric Generating Unit

EIA Energy Information Administration

EIS Emission Inventory System

EPA U.S. Environmental Protection Agency

EQB Environmental Quality Board

ERC Emission Reduction Credit

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

GDP Gross Domestic Product

GHCN Global Historical Climatology Network

HAP Hazardous Air Pollutant

I/M Inspection and Maintenance

IRRC Independent Regulatory Review Commission

LDGV Light Duty Gasoline Vehicles

LDGT Light Duty Gasoline Trucks

LRP Long Range Plan

MACT Maximum Achievable Control Technology

MARAMA Mid-Atlantic Regional Air Management Association

MM5 Mesoscale Model

MOVES Motor Vehicle Emission Simulator

MPO Metropolitan Planning Organization

MY Model Year

NAAQS National Ambient Air Quality Standard(s)

NAICS North American Industry Classification System

NEI National Emissions Inventory

NH3 Ammonia

NLEV National Low Emission Vehicle (program)
- 39 -

NMIM National Mobile Inventory Model

NOAA National Oceanic and Atmospheric Administration

NONROAD Nonroad Model

NOX Oxides of Nitrogen

NSR New Source Review

OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood-fired Boiler

PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates 

PM10 Particulate Matter less than 10 microns in diameter

ppm parts per million

PSD Prevention of Significant Deterioration

RWC Residential Wood Combustion

SCC Source Classification Code

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TIP Transportation Improvement Program

TSD Technical Support Document 

μg/m3 Microgram per cubic meter

μm Micrometer

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

ZEV Zero Emissions Vehicle
NOTICES

Proposed State Implementation Plan Revision; Redesignation Request and 

Maintenance Plan for the Johnstown Nonattainment Area for the 1997 Annual and 

2006 24-Hour Fine Particulate Matter National Ambient Air Quality Standards; 

Public Hearing

[44 Pa.B. 6291]

[Saturday, October 4, 2014]

Particulate matter (PM) includes both solid and liquid particles suspended in the air. Fine particle 

pollution describes particulate matter that is less than or equal to 2.5 micrometers in diameter 

(PM2.5). PM2.5 concentrations above the Federal health-based standard pose a serious human 

health threat. With significant improvements in air quality in the Johnstown Area, this 

nonattainment area now meets the 1997 annual and the 2006 24-hour PM2.5 National Ambient Air 

Quality Standards (NAAQS). Therefore, the Department of Environmental Protection (Department) 

intends to submit a request to the United States Environmental Protection Agency (EPA) for the 

redesignation of the Johnstown Area to attainment of the 1997 and 2006 PM2.5 NAAQS.

The Department is seeking public comments on the proposed redesignation request, a proposed 

revision to the State Implementation Plan (SIP) containing the 2007 comprehensive inventory as 

required under section 172(c)(3) of the Federal Clean Air Act (CAA) (42 U.S.C.A. § 7502(c)(3)) 

and a maintenance plan demonstrating that the area can maintain the 1997 and 2006 PM2.5 healthbased NAAQS for the next 10 years as required under section 175A(a) of the CAA (42 U.S.C.A. §

7505a(a)). Upon EPA approval of the SIP revision, the maintenance plan will also establish new 

motor vehicle emission budgets for transportation conformity purposes.

The Department's proposed request to the EPA for the redesignation of the Johnstown Area to 

attainment and the proposed SIP revision are available on the Department's web site at 

www.dep.state.pa.us (choose ''Air,'' choose ''Bureau of Air Quality,'' choose ''Regs/Plan,'' choose 

''Clean Air Plans'') or through the following contact persons.

The Department will hold a public hearing to receive comments on the proposal on Wednesday, 

November 5, 2014, at 11 a.m. at the Department's Ebensburg District Office, 286 Industrial Park 

Road, Ebensburg, PA 15931-4119. Persons wishing to present testimony at the hearing should 

contact Alex Haas, P. O. Box 8468, Harrisburg, PA 17105, (717) 787-9495, alehaas@pa.gov to 

reserve a time. Witnesses should keep testimony to 10 minutes and should also provide two written 

copies of their statement at the hearing.

If by Monday, November 3, 2014, no person has expressed an interest in testifying at the 

hearing, the hearing will be cancelled. The Department will provide public notice on the Bureau of 

Air Quality web page at www.dep.state.pa.us (choose ''Air,'' choose ''Bureau of Air Quality'') if the 

hearing is cancelled. Persons may also contact the Department to find out if the hearing is cancelled 

by contacting Alex Haas.

Persons with a disability who wish to attend the hearing and require an auxiliary aid, service or 

PA Bulletin, Doc. No. 14-2070 Page 1 of 2

http://www.pabulletin.com/secure/data/vol44/44-40/2070.html 11/20/2014
other accommodation to participate in the proceeding should contact Alex Haas. TDD users may 

contact the AT&T Relay Service at (800) 654-5984 to discuss how the Department can best 

accommodate their needs.

The Department must receive comments no later than Friday, November 7, 2014. Written 

comments should be sent to the attention of Nancy Herb, Bureau of Air Quality, P. O. Box 8468, 

Harrisburg, PA 17105-8468, nherb@pa.gov. Use ''Johnstown PM2.5 Redesignation'' as the subject 

line in written communication.

E. CHRISTOPHER ABRUZZO,

Secretary

[Pa.B. Doc. No. 14-2070. Filed for public inspection October 3, 2014, 9:00 a.m.]

No part of the information on this site may be reproduced for profit or sold for profit. 

This material has been drawn directly from the official Pennsylvania Bulletin full text database. 

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PA Bulletin, Doc. No. 14-2070 Page 2 of 2

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COMMONWEALTH OF PENNSYLVANIA 

STD-521 REV. 06-2010 INVOICE NO. 

PUBLICATIONS AUTHORIZATION AND INVOICE 

PUBLICATIONS AUTHORIZATION (To be completed by agency): 

TO: (NAME AND ADDRESS OF NEWSPAPER) 

Johnstown Tribune-Democrat 

425 Locust Street 

PO Box 340 

Johnstown. PA 15907 

FEDERAL I.D. NO.lSOC. SEC. NO. 

31-1498625 

HEREWITH IS ENCLOSED COPY FOR PUBLICATION OF ADVERTISEMENT FOR PROPOSALS TO 

FROM: (NAME AND ADDRESS OF AGENCy) AGENCY TELEPHONE NO. 

Alex Haas 717-787-9495 

PA DEP - Bureau of Air Quality 

400 Market Street - 12th FI 

H~rric:;hllrn PA 171 ()1-?~()1 

TYPE OF AD 

o EMPLOY D PURCHASE o CONTRACT o SELL D CLASSIFIED [8J LEGAL NOTICE 

PUBLISH ADVERTISEMENT (NO. OF TIMES) 

1xONLY 

MAXIMUM NO. OF LINES 

DATES OF INSERTION SIGNATU FOR AGENC~ J 

Friday, October 3, 2014 OR Saturday, October 4, 2014 _ {/o." 

You, as vendor, are authorized to publish this advertisement in your newspaper, subject to the terms of this order, as follows: 

Advertisement to be published in regular advertising columns, no position specified; caption of two lines and signature to be in 

capitals and subject matter and title of officer to be set solid in type regularly used by your newspaper for public (legal) notice 

advertising; charge to be made at the rate charged to and paid by commercial advertisers for matter similarly set and occupying 

similar space; advertisement to be run in the editions specified above. Vendor agrees that, in the performance of any contract 

awarded to it hereunder, said vendor will not discriminate against any employee or other persons on account of race, color, sex, 

religious creed, ancestry, age or national origin and that the Commonwealth, upon receipt of satisfactory evidence of such discrimination, shall have the right to cancel said contract. Return this copy at once if you will not accept this advertisement under 

the terms set forth. 

Return original and two copies (signed by the editor or publisher) to the agency listed above. Proof of advertising 

in the form of a tear sheet must be stapled to original and copies. Original must be notarized. 

Commonwealth to be billed only for actual number of printed lines published. 

SAP FUND COST CENTER GENERAL LEDGER ACCOUNT CODE % '-

7027300000 3522710000 6343200 

110 V16414000000 BP 2014 

INVOICE (To be completed by publisher): 

DATE OF INSERTION TOTAL AMOUNT 

1stAd 

2nd Ad 

3rd Ad 

GRAND TOTAL ~ 

I 7 ) ~ 

cou~~;;on~ c~nia : . - , " . Ci ~ ~ . MI\'V I"r: I+-

Before me, the subscriber, a Notary ublic in and for said Co~nty, personally came ~ L~ ( \~~ J\/cp ~ wh~g 1luly sworn~oth depR¥' anil ~~ !l1i jl he is' ~UY$ 't!.V1 Lfl-- . ~. r/L ( '-'<O-fL-- the'"' ~ ()\. J.!'-1 t - ' (W.c.J- ' a gen newspaper published at __ r--..\ ....:.. 01J :...:....!.....:......:=-- l- · ~:::..:...~-L---I:......-______ _ 

that the advertisement, of which tearsheet is attached hereto, was published in the regular advertising columns of said newspapl 

in the editions of. said newspaper, in all respects as ordered and invoiced above; and that the Commonwealth is not charg' 

therefor at a rate higher than is charged any ordinary advertiser for a similar amount of matter occupying similar space and set ir 

similar matter, in said newspaper. '- c'S 

Sworn and subscrib d b fore me this S '--. ,- . / / / 

day of V G - .20 1;Z Il (JA 

COMMONWEALTH OF pEN 

Notarial Seal 

M Vivian Ohs, Notary Public 

City of Johnstown, cambria county 

*This affidavit must be made by the Owner, Publisher, or the designated agent of he 0 . ilres ~~~N60;~~~ARt~ MEMBt:R. PENN YI.VANIA ASSOCl . 
J ohn-s}own 

P&A ~ };sl,.J 

Tr: ~ "''' e. - Del"" 0," ,-"./-

Dc .).0 ber :$ I Z 0 I L{ 

Proposed St~te Implementation Plan' Revision 

Redesignation Request and Maintenance Plan for the 

Johnstown Nonattainment Area for the 1997 Annual 

"and 2006 24-Hour Fine Particulate Matter National 

Ambient Air Quality Standards; Public Hearing 

Particulate matter (PM) includes both solid and liquid 

particles suspended in the air. Fine particle pollution 

describes particulate matter that is less than or equal to 

2.5 micrometers in diameter (PM2.5). PM2.5 

concentrations above the federal health-based standard 

pose a serious human health threat. With significant 

improvements in air quality in the Johnstown Area, this 

nonattainment area now meets the 1997 annual and the 

2006 24-hour PM2.5 National Ambient Air Quality 

Standards (NAAQS). Therefore, the Department of 

Environmental Protection (DEP) intends to submit a 

request to the U.S. Environmental Protection Agency 

(EPA) for the redesignation of the Johnstown Area to 

attainment of the 1997 and 2006 PM2.5 NAAQS. 

DEP is seekil')g public comments on the proposed 

redesignation request, a proposed revision to the State 

Implementation PI'!.n (SIP) containing the 2007 

comprehen'sive inventorY as required under Section 

(c)(3)the federal Clean Air Act (CAA) and a maintenance 

plan demonstrating that the area can maintain the 1997 

and 2006 P2,5health-based NAAQS for the next 10 years 

as required under SectionA(a) of the CAA (42 U.S.C.A. § 

7505a). Upon EPA approval of the SIP revision, the 

maintenance plan will also establish new motor vehicle 

emission budgets for transportation conformity purposes. 

Pennsylvania's proposed request to EPA for the 

redesignation of the 'Johnstown Area to attainment and the 

proposed SIP revision are available on DEP's website at 

www.dep.state.pa.us (select "Air," then "Bureau of Air 

,Quality," then "Regs/Plans," then "Clean Air Plans") or 

through the contact persons listed below. 

DEP will hold a public hearing to receive comments on the 

proposal on Wednesday, November 5, 2014, at 11 :00 

a.m., at the DEP Ebensburg District Office, 286 Industrial 

Park Road, Ebensburg, PA 15931-4119. Persons wishing 

to present testimony. at the hearing should contact Alex 

Haas at P.O. Box 8468, Harrisburg, PA 17105, by phone 

at (717) 787-9495 or via email at alehaas@pa.gov to 

reserve a time. should keep testimony to ten minutes or 

less and should also provide two written copies of their 

statement at the hearing. 

If by Monday, November 3, 2014, no persqn has 

expressed an interest in testifying at -the hearing, the 

hearing will be cancelled, DEP will provide public notice 

on the Bureau of Air Quality webpage at: 

www.dep.state.pa us (DEP Keyword, "Air") if the hearing is 

cancelled. Persons may also contact the DEP to find out if 

the hearing is cancelled by contacting Alex Haas at (71 '1) 

787-9495 or alehaas@pa.gov. ' 

Persons with a disability who wish to attend the nearing . and require an auxiliary aid, service or other 

accommodation to participate in the proceeding should 

. contact Alex Haas at (717) 787-or alehaas@pa.gov. TDD 

users may contact the AT&T Relay Service at (800) 654-

5984 to discuss how DEP can best accommodate their 

needs. 

DEP must receive comments no later than Friday, 

November 7, 2014. Written comments should be sent to 

the attention of Nancy Herb, Bureau of Air Quality, P.O. 

Box 8468, Harrisburg, PA 17105-8468, or nherb@pa.gov. 

Use "Johnstown PM2.5 Redesignation" as the subject line 

in written communication. 

E. CHRISTOPHER-ABRUZZO 

, Sec;retary 
Advertising 

Receipt 

BUREAU OF AIR QUALITY 

P.O. BOX 8468 

The Tribune-Democrat 

PO Box 340 

Johnstown, PA 15907-0340 

Phone: 814-532-5038 

Fax: 814-532-5104 

Acct #: 

Ad#: 

Phone: 

Date: 

02118083 

00195902 

(717)787 -9495 

400 MARKET ST., 12TH FLR. 09/30/2014 

HARRISBURG, PA 17105 Ad taker: KF Salesperson: 

Sort Line: Proposed State Implementation Ad Notes: 

Classification 105 

Description 

01 Tribune-Democrat 

CF Clerical Fee 

Oath Oath form for Legals 

Ad Text: 

Start Stop 

10103/2014 10103/2014 

Department of 

Environmental Protection 

OCT 0 8 2014 

Air ReSource Management 

Division 

Cost/Day 

1 350.00 

Payment Reference: 

Total: 

Tax: 

Net: 

Prepaid: 

( Total Due 

Total 

350.00 

2.50 

5.00 

357.50 

0.00 

357.50 

0.00 

357.50 )