# 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 (PM 2

. 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 PM 2

. 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.

R

ac h el C arson S tate 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.usMr. 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

# C ommonwealth 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 201 4

Bureau of Air Quality Pennsylvania Department of Environmental Protection

P.O. Box 8468 Harrisburg, PA 17105

- 8468

717

- 787

- 9495

www.dep.state.pa.usThis page intentionally left blank

.- i

- TABLE OF CONTENTS

I. Introduction and Overview

................................ ................................ ................................ .. 1

A. Health and Environmental Effects of Fine Particulate Matter (PM 2.5 )

.................... 1

B. Sources of PM 2.5 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 Y ear)

................................ .... 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 Mar gin to Total Anticipated Emission Reductions in

2017 and 2025

................................ ................................ ................................ .......... 39

Table III

- 4: Comparison of 2025 On

- Road Mobile VOC, NH 3 , and SO 2 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

- 2 200 5 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 North east/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 Countie s in the MANE

- V U 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. I NTRODUCTION AND O VERVIEW

A. Health and Environmental Effect s of Fine Particulate Matter (PM 2.5 )

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 o r PM 2.5 describes particulate matter th at 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 s hown 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, he art 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 sensitiv e 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 E ngland Journal of Medicine evaluate d the role PM 2.5 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/m 3 ) of PM 2.5 was associated with an average increase in life expectancy of

7.3 months.

PM 2.5 has significant environmental impacts, including acid rain and stream eutrophication. PM 2.5 also affects visibility (regional haze) through the scattering and absorption of l ight. 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 PM 2.5 in the air.

The United States Environmental Protection Agency (EPA) promulgated PM 2.5 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)

standa rd of 1 5.0 μg/m 3 , based on the 3

- year average of annual mean PM 2.5 concentrations. The EPA also established a primary and secondary 24

- hour

standard of 65 μg/m 3 determined by the 3

- year average of the 98th percent ile of

24

- hour concentrations. In 2006, t he EPA promulgated a revised 24

- hour PM 2.5 standard of 35 μg/m 3 determined by the 3

- year average of the 98th percent ile of

24

- hour concentrations. The annual PM 2.5 standard was not revised ( 71 F R 61 144 (October 17, 2006)).- 2

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

PM 2.5 standard based on 2001

- 2003 air qu ality monitoring data

. The final designations were published in the Federal Register on January 5, 2005 (70 FR 944). The designa tions became effective on April 5, 2005. The EPA designated eight areas c omprised of all or portions of 21 counties in Pennsylvania

as PM 2.5 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 PM 2.5 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 County 1

, was one of eight areas in Pennsylvania designated by t he EPA as nonattainment for the 1997 PM 2.5 N AAQS. The Johnstown Area w as designated

nonattainment because the area violated the 1997 annual PM 2.5 standard of

15.0 μg/m 3 based on 2001

- 20 03 monitoring data

. The Johnstown Area did not

violate the 1997 24

- hour PM 2.5 NAAQS of 65 μg/m 3

.

On October 8 , 200 9 , the EPA promulgated air quality designations for the 2006

PM 2.5 standard based on 200 6

- 200 8 air quality monitoring data

. The final designations were published in the Federal Register on November 13, 2009 (7 4 FR 58688 )

. The EPA designated seven areas c omprised of all or portions of

2 2 counties in Pennsylvania as PM 2.5 nonattainment areas. The designations

became effective on December 14, 2009

.

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

EPA as nonattainment for the 2006 PM 2.5 N AAQS. The Johnstown Area w as designated nonattainment because the area violated the 2006 24

- hour PM 2.5 standard of 3 5 μg/m 3 based on 200 6

- 20 0 8 monitoring data

.

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

nonattainment for the 1997 and 2006 PM 2.5 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 PM 2.5 and Precursor Pollutants of Concern

Fine particulate matter can be emitted directly or formed secondarily in the atmosphere. PM 2.5 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 PM 2.5 that is formed near its source by condensation) is referred

to as “ primary ” PM 2.5

. PM 2.5 is formed by chemical reactions of gases in the atmosphere is considered to be “ secondary ” PM 2.5 . The chemical composition of

PM 2.5 in an area depends on the mix of emissions, location, time of year, and

weather. The chemical composition of PM 2.5 can includ e 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 PM 2.5 includes soot from diesel engines, condensed organic material from incomplete combustion and compounds from condensation during combustion or smelting.

The atmospheric chemistry of PM 2.5 formation is complex. Formation of secondary PM 2.5 depends on numerous facto rs
, 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 pre cursors will vary by location.

The principal forms of secondary PM 2.5 include:

 Sulfates, formed from emissions of sulfur dioxide (SO 2 ) from power plants and industrial facilities ;

 Nitrates, formed from emissions of nitrogen oxides (NO X ) from power plants, vehicles, and other combustion sources ;

 Ammonium, formed primarily from emissions of ammonia (NH 3 ) from animal operations ; and

 Secondary organic aerosol

, formed from emissions of v olatile organic

c ompounds ( VOCs ) from incomplete combustion and evaporation fr om 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 PM 2.5 will vary among nonattainment areas

.

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

24

- Hour Fine Particle National Ambient Air Quality Standard, ” Office of Air Quality Planning and Standards, t he EPA was issued on March 2, 2012 (later withdrawn) . In the Implementation Guidance for the 2006 PM 2.5 NAAQS, the EPA adopted the framework and policy approach the agency espoused in its implementation rule for the 1997 PM 2.5 NAAQS, known as the “ Clean Air Fine

2 National Ambient Air Quality Standards for PM 2.5

, 71 FR 61144, October 17, 2006- 4

- Particle Implementation Rule ” (7 2 FR 20586 ; April 25, 2007) ( “ I mplementation

R ule for the 1997 PM 2.5 NAAQS ” )

.

In its I mplementation R ule for the 1997 PM 2.5 NAAQS, the EPA had established general presumptive policies for assessing which PM 2.5 precursors should be evaluated for possible controls. 3 In that earlier rule, t he EP A require d states to
evaluate control measures for SO 2 and primary PM 2.5 i n all locations. The EPA require d states to evaluate control measures for NO X unless a technical

demonstration is made to show that NO X emissions from sources in the state do not significantly contribute to PM 2.5 concentrations in the nonattainment area

. The EPA require d states to evaluate measures for VOC and NH 3 only if a technical dem onstration is made to show VOC or NH 3 emissions significantly

contribute to PM 2.5 in the nonattainment area.

The EPA reaffirmed the appropriateness of these presumptions in the Implemen tation Guidance for the 2006 24

- Hour PM 2.5 NAAQS. Meanwhile, the

U.S. Court of Appeals for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997 PM 2.5 NAAQS, in Natural Resources Defense

Council v. EPA , No. 08

- 1250 . On January 4, 2013, the Court handed down its ruling in that case

. T he C ourt 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) )

.

S hortly thereafter, the EPA withdrew its Implemen tation Guidance for the 2006

24

- hour PM 2.5 NAAQS

. According to the EPA ’ s June, 2013

, withdrawal

memorandum 4

, 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 standard s consistent with

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

the extent it would be extrapolated to the 2006 24

- Hour PM 2.5 NA AQS) 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 )

. S ince the Johnstown Area is already attaining the 1997 annual and 2006 24

- Hour

PM 2.5 NAAQS, however, those considerations are not relevant for this

M aintenance P lan . The C o urt noted that PM 2.5 precursors, including NH 3 and VOCs, are presumptively regulated in PM 2.5 nonattainment areas under Subpart 4, pointing specifically to S ection 189(e), which applies to control of major

3 The EPA ’ s definition of “ PM 2.5 attainment pla n precursor” can be found in 40 CFR § 51.1000, which reads: “ PM 2.5 attainment plan precursor means S0 2 and those other PM 2.5 precursors emitted by sources in the State which the

State must evaluate for emission reduction measures to be included in its PM 2.5 nonattainment area or maint enance area plan. ”

4 “Withdrawal of Implementation Guidance for the 2006 24

- Hour Fine Particle ( PM 2.5 ) National Ambient Air Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013.- 5

- stationary sources of PM 10 [the court stated that PM 10 includes PM 2.5 throughout Subpart 4] ( 706 F.3d at 436, n. 7, and at 437, n. 10 )

. A ccording to CAA

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

PM 10 also apply to major stationary sources of PM 10 precursors , except where the Administrator determines that major stationary sources do not contribute

si gnificantly to PM 10 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 PM 2.5 , SO 2 , NO X , VOC and NH 3 for the

maintenance demonstration

.

T his revision to the State Implementation Plan ( SIP) provides emissions information for all pollutants ( PM 10 , PM 2.5 , SO 2 , NO X , VOC and NH 3 ), 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 a nd Structure o f t his SIP Revision

In December 2004

, after consultation with states and receipt of public input, the EPA designated ei ght areas in Pennsylvania

, compris ing all or part s of

21 Pennsylvania counties

, as PM 2.5 nonattainment areas for the 1997 PM 2.5 NAAQS based on 2001

- 2003 air qu ality 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 miles tones, the area is brought back to atta inment as quickly as possible.

However, o n September 25, 2009

, the EPA determined that the Johnstown Area

had attained the 1997 PM 2.5 NAAQS based on quality assured, quality controlled and certified ambient air monitoring data that show the area ha d monitored

attainment based on 200 6

- 200 8 data ( “ Clean Data Determination ” ) (74 FR 48863)

. This final action suspended the requirements for Pennsy lvania 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 revision s related to the attainment of the 1997

PM 2.5 NAAQS for so long as the area continues to attain the 1997 PM 2.5 NAAQS 6

.

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 PM 2.5 NAAQS by the applicable attainment date of April 5, 2010. The EPA based this determination on complete, qual ity 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

, compris ing all or parts of 2 2 Pennsylvania counties

, as 2006 PM 2.5 NAAQS

nonattainment areas based on 200 6

- 200 8 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 e nsure that in the event of a future violation or failure to meet emission reduction milestones, the area is brought back to atta inment as quickly as possible.

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

2006 PM 2.5 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 Determ i nation suspended the require ments 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 PM 2.5 NAAQS for s o long as the

area continues to attain the 2006 PM 2.5 NAAQS.

The EPA ’ s determination of attainment and the Clean Data Determination s d id

not “ redesignate ” the area as “ attainment. ” The Johnstown Area remain s a designated nonattainment area for the 1997 and 2006 PM 2.5 NAAQS until the Commonwealth submits, and the EPA approves, a Request for R edesignation and

a Maintenance P lan showing the area can mainta in the standard s for at least

10 years after redesignation

. N onattainment new source review continue s to apply until the EPA redesignates the area to attainment ( 72 FR 20603 )

. Transportation conformity and genera l conformity also apply ; they will continue to apply to the area even after redesignation by the EPA as attainment

. The C lean

D ata D etermination s do not suspend the CAA Sec tion 172(c)(3) requirement to
establish a comprehensive inventory for all pollutants considered potential

precursor s to PM 2.5 and for direct emissions of PM 2.5.

This SIP revision includes the Maintenance P lan for the Johnstown Area for the

1997 and 2006 PM 2.5 NAAQS and the 200 7 comprehensive inventory required

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

of direct PM 2.5 , PM 10 (particles less than 10 microns in diameter), SO 2 , NO X , VOC and NH 3

. 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 PM 2.5 NAAQS.

To demonstrate maintenance of the PM 2.5 NAAQS for this area, Penns ylvania is

show ing that the future emissions of PM 2.5 and its precursors w ill remain at levels that will provide for maintenance of the PM 2.5 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

P lan contains a n attainment year inventory for 2007 and demonstrates that emissions will not be greater i n 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 M aintenance P lan progress will be tr acked 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 R equest 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, t he R equest for Redesignation submitted concurrently with this Maintenance Plan indicates that the Johnstown

Area has attained the NAAQS and that attainment wa s due to permanent and

enforceable control measures. The R equest for Redesignation a lso demonstrates

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

under the CAA for the Johnstown Area that we re due before the date of the

R equest for R edesignation

.

In Section 5 of the 1992 Calcagni Memo, the EPA re commends 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 th is Plan);

 The state should develop an emissions inventory to identify the level of emissions sufficient to attain the NAAQS. This “ attainment year

i nventory ” was developed for 2007 ;

 The state may demonstrate maintenance by show ing that the future emissions of a pollutant or its p recursors 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 Protectio n ( DEP o r Department) has develop ed emission

invento ries 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 th e legal authority to imp lement and enforce all measures necessary to atta in and maintain the NAAQS, and indicate how Maintenance Plan progress will be tracked (addressed in Sections III and V of this Plan and the R equest 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).

Th e Maintenance Plan describes how the Commonwealth will meet those criteria.

Th is Maintenance Plan demonstrates that the 1997 and 2006 PM 2.5 NAAQS will

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

attainment of the standard s , as required under Section 175A of the CAA. T he

Maintenance Plan shows that emission leve ls of PM 2.5 and its precursors over the

1 0 years following redesignation remain at levels that will provide for

maintenance of the PM 2.5 NAAQS

, even considering growth in populatio n and

vehicle miles traveled.

Th is Maintenance Plan also shows that t he following state and federal programs will ensure the continuing dec rease of PM 2.5 , SO 2 , NO X 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 smal ler sources o f NO X ;

 State regulations incorporating by reference the federal Prevention of Significant De terioration (PSD) regulations;

 State requirements for Best Available Technology ( BAT ) ;

 State regulation of the sulfur content of fuel oil ;

 State regulation of VOC emissions from a dhesives, s ealants, p rimers and

s olvents;

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

facilities ;

 The Pennsylvania and federal new motor vehicle emission control programs for p assenger and light

- duty trucks;

 The Pennsylvania and federal heavy

- duty di esel emission control

programs;

 Federal fuel programs for highway vehicles and nonroad mobile equipment; an d

 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 t he Johnstown Area in maintaining the 1997 and

2006 PM 2.5 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).

 NO X 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

Se ptember 20, 2011 (76 FR 58114).

 The federal Tier 3 Motor Vehicle Emission and Fuel Standards program (79 FR 23414).

In th is Maintenance Plan, the Department provide s assurances that it will continue to operate the ambient air quality monitoring netwo rk in order to track

maintenance of the standard s and to evaluate emissions inventories periodically compared to the projections provided in the Plan

. The Department also provide s a list of potential contingency measures that it would consider to correct any violation of the NAAQS that occurs af ter redesignation of the area.

Eight years following redesignation, the Commonwealth will submit a revised plan that ensures attainment of the 1997 and 2006 PM 2.5 NAAQS through 2035

.

D. Public P articipation

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, t he Department provided

not ice of a public comment period and the opportunity for a hearing on the

Johnstown Area Maintenance Plan for the 1997 and 2006 PM 2.5 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

PM 2. 5 standard s

. 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

. E MISSION I NVENTORIES

To demonstrate maintenance of the 1997 and 2006 PM 2.5 NAAQS for th e Johnstown

A rea, Pennsylvania is show ing that the future emissions of PM 2.5 and its precursors w ill remain at levels that will provide for maintenance of the PM 2.5 NAAQS for at least

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

P lan contains a n attainment year inventory for 2007 and demonstrates that emissions will- 10

-

not be greater than the attainment year in 2017 and 2025

. 7 This Mainte nance Plan also

contains a 200 5 baseline inventory that represen ts the emissions present when the

Johnstown Area did not meet the 1997 and 2006 PM 2.5 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 S ection 172(c)(3) of the CAA

. As specified by the EPA, the pollutants inventoried by Pennsylvania include direct PM 2.5 , PM 10 , SO 2 , NO X , VOC, and NH 3

. Information on the manmade sources of these pollutants was compiled for:

 “ Stationary point sour ces ” (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 a rea sources
, ” which are industrial

, commercial , and reside ntial 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 vehic le 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

construct ion 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 refi ne 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 inventor y for the purpose of conducting the regional modeling analysis used in Pennsylvania ’ s air quality management p lanning efforts to attain the 8

- hour ozone NAAQS and the PM 2.5 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 PM 2.5 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 emi ssions 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 Inv entory (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 PM 10 , PM 2.5 , SO 2 , NO X , VOC, and NH 3 . The inventory consists of sources in four sectors: electric generating units (EGUs), non

- EGU point and stationary area sources, highway

vehicl e 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

V ehicle M iles T raveled (VMT) and other parameters, the MOBILE6 model predicts higher VOC and significantly lower NO X and PM2.5 emissions than

MOVES2010 , which was used to generate the 2007, 2017 and 2025 i nventories

. 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 Departm ent linearly interpolated MOVES 2010 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 20 05 Annual Emissions (Tons per Year)

Johnstown 2005 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 inventor y 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 Informat ion 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 bas ed 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 we ll as projected facility emissions for 2017 and 2025.

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

or solid at stack exit. Condensable emissions from electric generating units ( EGU s ) 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

cond ensable PM ( PM

- CON ) emissions, and then to perform the gap filling for compounds missing from the facility

- reported emissions

.

Stationary Area Sources

. Stationary a rea source emissions are generally estimated by multiplying an emission factor by some kno wn 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 m ethod similar to that used for stationary point s ources. Emiss ion 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

spe cific to the industry covered.

The EPA emissions i nventories 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 t hat

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 assu mption 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 co ntains the methodology for the 2007 Pennsylvania area sour ce inve ntory. Additional methodology information is available in the technical support document for the 2007 regional inventory wh ich is contained in Appendix C

- 1 . Appendix B

- 2 contains the stationary area source emissions data

for 2007 , 2017 and 2025 fo r 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, t he Department employ ed MOVES2010 to estimate the onroad emissions inventory for 2007, 2017

, and

2025

.

Additional information on highway emission method ology is available in Appendix D. Appendix D

- 1 summarizes the methodology and data inputs used to produce the mobile emissi ons inventory. Appendix D

- 2 provides the 2007 attainment year and 2017 and 2025 projections of mobile (highway) VMT and

annual PM 2.5 direct and prec ursor emissions. Appendix D

- 3 describes the model inputs used to generate emission factors for a specific area. Some examples of th e 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 a ge. The summary in Appendix D

- 3 indicates when default information contained in the model is used rather than specific area i nformation.

Nonroad Sources

. The 2007 inventory for the majority of nonroad cat egories was generated using the National Mobile Inventory Model ( NMIM 2008 ) of which

the NONROAD m odel is a part. The NONROAD model estimates emissions for diesel, gas oline, 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

emis sions. 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 e missions 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 va lues 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 2 007 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 assista nce 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 cooperatio n with ERTAC that resulted in changes in emissi ons 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 ra ilroad operational data. The Department determined that ERTAC ’ s methodology and inventory were similar to the Department ’ s method except in the cases of some

smal ler 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 y ard 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 (gal lons /y ear ) 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 PM 10 , PM 2.5 , SO 2 , NO X , VOC, and NH 3 for the Johnstown Area identifies PM and PM precurs or emissions during the period when the Johnstown

Area was attaining the 1997 and 2006 PM 2.5 NAAQS. Table I I

- 2 summarizes the

emissions for 2007

.- 15

- Table II

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

Johnstown 2007 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 47,95 8 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, PM 2.5 , PM 10 , SO 2, NO X , V OC, and NH 3 emissions decreased by 70 percent, 67 percent, 7 percent, 1 percent, 15 percent

, and

13 percent, respectively, from 200 5 to 2007.

C

. Growth Projection Methodologies for 2017 and 202 5

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

estimates o f emissions changes between 2007 and interim year 2017 and maintenance year 2025

. Appendix C

- 2 contains the technical support document

for the d evelopment of the 2017 e mission s inventory . Appendix C

- 3 contains the technical support document for the development of the 2025 emissions inventory.

The document s prov ide details on the specific factors, control assumptions, and implementation schedules used in the emission projection calcula tions for each source category. MARAMA coordinat ed development of the projection inventories for the regional inventory, consisting of the states in the

Mid

- Atlantic/Northeast Visibility U nion 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 a rea source emissions result from the placement of drilling equipment, gathering lines and compressor stations.

EGUs

. A nnual 2007 EGU point emissions were “ grown ” to 2017 an d 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 202 5. P ost

- 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 PM 2.5 emissions for EGUs also include condensable PM emissions

bec ause they were projected from the 2007 inventory which was adjusted to account for condensable PM, as discussed in Sectio n II

- B above

. A more detailed description of the methodology used to project emissions from EGUs i s located in the technical support document for the development of the 2025 emi ssions 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 20 17 a nd

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 f ine particles. The documents describe the data sources, methods, and r esults for emission forecasts.

NonEGU point source and stationary area source grow th factors were developed using :

 Annual Energy Outlook (AEO) fuel c onsumption 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 c ompared the AEO2010 and AEO2011 projections. Minor differences were found for most categories. Based on this analysis, t he AEO 2010

fuel

- use forecasts were used for all residential, commercial and industrial sector fuel use, except for industri al natural gas usage, where AEO 2011 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, eve n before the application of control assumptions. Because of the possibility that facilit y owners and operators could register and sell Emission Reduction Credits (ERCs ) approved and certified by th e 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 , b ecause the 200 5 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

- invento ry shows an apparent increase of direct PM 2.5 emissions from stationary point sources in 2007, 2017 and 2025 compared with 200 5

.

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 geolog ic 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, wh en this activity did

not exist. By mid

- 201 4 , the re were about 40 active unconventional well permits

in C ambria 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

.

A ctivity of compressor stations will increase because the volume of na tural gas being pumped will likely increase from the present to the maintenance year. While some compressor engines were approv ed to operate at a limit of 2.0 grams of NO X p er brake horsepower

- hour (g/bhp

- hr), c ompressor engines coming online

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

DEP ’ s General Permit BAQ

- GPA/GP

- 5, N atural Gas Compression and/or Processing Facilities (GP

- 5) in February 2013

. 9 GP

- 5 limits NO X emissions of compressor statio n lean

- burn engines over 500 bhp, which is the engine type used predomi nately 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. Furth ermore, federal regulations (40 CFR Part 60, Subpart OOOO) will require that starting in January 2015, wells must capture gas at the wellhead instead of releasin g it to the atmosphere or flaring it off. The EPA has estimated that VOC emissions fr om hydraulically

8 PA DEP Oil and Gas Reporting website at https://www.paoilandgasreporting.state.pa.us/publicreports/Modules/Produ ction/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 emis sion inventory reports available (2013 for compressor engines and 2012 for all other sources).

Emissions in the Indiana portion of the Johns town Area were assumed to be

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

c ounty 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 ac cordance 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 bou ght 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 ov er 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 shutd own 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 a pproved highway vehicle emission model, MOVES 2010 , 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 Depar tment 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 MO VES2010 for Emissions Inventory Preparation in State Implementation Plans and Transportation Conformity

. Appendi ces D

- 1 throug h D

- 3 of this Maintenance Plan i nclude s pecific information on the- 1 9

- highway emission s inventory methodology , data files of emissions estimates

and MOVES input paramete rs

.

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, NO X , are significantly lower in the future

a nalysis 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

, S ection 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 c ontrol 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 f or 2007

- 2017 and

2007

- 2025. These growth factors were applied to inter

- city p assenger train locomotives and independent commuter rail systems. For freight ra il, the data

from AEO2010 Table A

- 7 was used to calculate the growth factor for 2007

- 2017- 20

- and 2007

- 2025. F reight rail annual growth factors for Class I line haul

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

.

Additional information about nonroad emission projection methodologies can also be found in Appendi ces C

- 2 and C

- 3, the technical support documents for the development of the 2017 and 2025 inventories, respectively. The t able of nonroad emissions data sorted by source category is available as Appendix E

- 1

.

E

. Interim Year (2017 ) Emissions

Tab le II

- 4 sum marize s the emissions expected in 2017 . These emissions take activity and emissions growth and/or controls fro m 2007 in to accoun t. Appendix C , re lating to the regional emissions inventory and projection methodology , contains the technical support documents that describe the methodologies used to projec t the 2007 emissions to 201 7

.

Table II

- 4 : Johnst own Area Projected 2017 Emissions (Tons per Year)

Johnstown 2017 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 PM 2.5 and NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. The hig hway vehicle emissions in Table II

- 4 reflect inclusion of that safety margin

.

F

. Maintenance Year (202 5 ) Emissions

T able II

- 5 su mmarize s the emissio ns 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 1,19 8.4 577.6 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 3,74 1 6,606 141,932 43,110 3,471 494
*A portion of the difference between attainment year and maintenance year emissions of PM 2.5 and NO X 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 PM 2.5 NAAQS for this area, Pennsylvania must show that the future emissions of PM 2.5 and its precursors will remain at levels that provide for maintenance of the PM 2.5 NAAQS for at least

10 years after redesi gnation , taking economic, population a nd travel growth into

account.

The EPA ’ s Implementation Guidance for the 2006 24

- Hour PM 2.5 NAAQS adopted the same presumptions related to PM 2.5 precursors as EPA ’ s Implementation Rule for the 1997 PM 2.5 NAAQS. Howev er, 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 PM 2.5 NAAQS

. The C ourt noted that PM 2.5 precursors, including ammonia and VOCs, are presumptively regulate d in PM 2.5 nonattainment areas under Subpart 4 , pointing specifically to section 189(e), which applies to control of major stationary sources

of PM 10 [the court stated that PM 10 i ncludes PM 2.5 throughout Subpart 4] ( 706 F.3d at 436, n. 7, and at 437, n. 10 )

. According to CA A Section 189(e), control requirements applicable for major stationary sources of PM 10 also apply to major stationary sources of PM 10 precursors , except where the Administrator determines that major stationary sources do not contribute significantly to PM 10 levels that exceed the standard in the area; Section 189(e) also requires the EPA to issue guidelines regarding the application of subsection (e). Pennsylva nia

assessed emissions of PM 2.5 , SO 2 , NO X , VOC and NH 3 for the maintenance

demonstration.

This Maintenance Plan contains an attainment year inventory for 2007 and

demonstrates that emissions of PM 2.5 , SO 2 , NO X and VOC, including emissions in the transpor tation conformity safety margin for PM 2.5 and NO X , will not be greater in 2017 and 2025 than in the attainment year, as shown in Table II

- 7.

Emissions of PM 2.5 are projected to decrease from 2007 to 2025 by approximately

289 tons ( 7 percent ). Emissions of SO 2

, NO X , VOC and NH 3 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 PM 2.5 SO 2 NOx VOC NH 3 2007 4,031 144,252 47,95 8 5,325 508

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

2025* 3,74 1 141,932 43,110 3,471 494
*A portion of the difference between attainment year and maintenance year emissions of PM 2.5 and

NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehic les. The emissions in Table II

- 6 reflect inclusion of that safety margin.

I II

. P ERMANENT AND E NFORCEABLE C ONTROL M EASURES

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 s ource category. 10 Therefore, effective control measures for PM 2.5 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 Qual ity Planning and Standards, the EPA was issued on March 2, 2012 (later withdrawn). In its I mplementation R ule for the 1997 PM 2.5 NAAQS, the EPA established general presumptive policies for assessing which PM 2.5 precursors should be evaluated for possible controls. In that earlier rule, t he EP A require d

states to evaluate control measures for SO 2 and primary PM 2.5 i n all locations. The EPA require d states to evaluate control measures for NO X unless a technical

d emonstration is made to show that NO X emissions from sources in the state do not significantly contribute to PM 2.5 concentrations in the nonattainment area

. The EPA require d states to evaluate measures for VOC and NH 3 only if a technical demonstration is made to show VOC or NH 3 emissions significantly

contribute to PM 2.5 in the nonattainment area.

The EPA reaffirmed the appropriateness of these presumptions in the Implemen tation Guidance for the 2006 24

- Hour PM 2.5 NAAQS. 11 Meanwhile, the Court of Appeals for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997 PM 2.5 NAAQS, in Natural Resources Defense

Council v. EPA , No. 08

- 1250 . On January 4, 2013, the Court handed down its ruling in that case

. T he C ourt 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 Implemen tation Guidance for the 2006

24

- hour PM 2.5 NAAQS

. According to the EPA ’ s June, 2013

, withdrawal

memorandum 12

, 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 standard s consistent with

the Court ’ s ruling. In general, the C ourt ’ s decision (for the 1997 PM 2.5 NAAQS and to the extent it would be extrap olated to the 2006 2 4

- Hour PM 2.5 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 PM 2.5 NAAQS, those considerations are not relevant for

this M aintenance P lan . The C o urt noted that PM 2.5 precursors, including ammonia and VOCs, are presumptively regulated in PM 2.5 nonattainment areas under Subpart 4, pointing specifically to S ection 189(e), which applies to control of major stationary sources of PM 10 [the court stated that PM 10 includes PM 2.5 throughout Subpart 4] ( 706 F.3d at 436, n. 7, and at 437, n. 10 )

. A ccording to

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

sources of PM 10 also apply to major stationary sources of PM 10 precursors , except
where the Administrator determines that major stationary sources do not contribute significantly to PM 10 levels that exceed th e standard in the area;

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

of Subsection (e). Pennsylvania assessed emissions of PM 2.5 , SO 2 , NO X , VOC

and NH 3 for the maintenance demonstration

.

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

PM 2.5 , SO 2 , NO X , and VOC emission reductions ensuring maintenance of the

st andard.

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

included in Table III

- 1 ( n egative valu e s 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 PM 2.5 , SO 2 , NO X , VOC

, and NH 3 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 pollutant s 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: Sum mary of Emission Reductions (Tons) from 2007 to 2025

from Control Measures

2007 to 2025 Difference PM 2.5 SO 2 NOx VOC NH 3 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

- 4,84 8

- 1,854

- 14
*A portion of the difference between attainment year and maintenance year emissions of PM 2.5 and

NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. The highway v ehicle emissions in Table II I

- 1 reflect inclusion of that safety margin.

Pursuant to 40 CFR Part 51, Subpart K (relatin g 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 monitori ng 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 PM 2.5 standard, as well as the Department ’ s comprehensive permit ting 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 program s as part of the SIP ; the Title V Operating Permit s 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) contain s requirements for reporting and recordkeeping for plan approval appli cations. 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 NO X from cement- 25

- manufacturing). The Department als o monitors the status of compli ance 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 (pre

construction 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

con trol 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 pollut ants 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 contaminati on 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 PM 2.5 standard.

Title V Permitting Program. The Title V Permitting Program, adopted pursuant to the Clean Air Act Amendments of 1990, is applicable to major station ary 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 wha t 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 a s well a s 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 pro posed 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 Sta ndards including carbon monoxide, PM, lead, nitrogen dioxide (NO 2 ),

ozone SO 2 . 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

NO X , SO 2 , 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 ” ozo ne nonattainment area, irrespective of the area ’ s attainment status. Because NO X and VOC are precursors of PM 2.5 , NO X 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 PM 2.5 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 NO X , PM

, and VOCs by securing emission reductions credits at the specified offset ratio, will employ the

“ l owest achievable emission rate ” (LAER) for each regulated

po llutant and conduct an alternative analysis. The nonattainment NSR requirements are codified in 25 Pa. Code Chap ter 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 p re

- 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, NO 2 , ozone, PM

, and SO 2 , depending on the source category. Any major stationary source or major

modificatio n 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 a nd 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 T

echnology Program. The Department ’ s Best Available Technology (BAT) Program, authorized under

Section 6.6(c) of the Air P ollution 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 tak ing into account energy, environmental benefits

, and costs. Pursuant to

25 Pa. Code §127.1 (re lating 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 approva l 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 avail able. ” 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).

NO X and SO 2 Control Programs

. In 1998, EPA promulgated the NO X SIP Ca ll as the EPA ’ s principal effort to reduce interstate transport of air pollution (63 FR 57356; October 27, 1998). In response to the federal

NO X SIP call rule, Pennsylvania adopted the NO X 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 NO X SIP Call, Pennsy lvania adopted additional NO X 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 NO X and SO 2 . 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 NO X and SO 2 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 NO X Budget Trading Program and transitioned to

the federal CAIR for EGU s

.

The market

- based CAIR is designed to reduce EGU emissions of

NO X and SO 2 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 p articipates in the EPA

administered cap

- and

- trade programs for NO X annual, NO X ozone season, and SO 2 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, EM

E 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 P articulate Matter Standard, ” 79 FR 62389 (October 17, 2014), in which the EPA wrote: “ Pro vided 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 PM 2.5 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

rema nd of CAIR, as explained above. In CSAPR, EPA established emissions budgets for covered EGUs in 28 s tates and promulgated

FIPs to achieve the reductions (76 FR 482 08; August 8, 2011)

. Although CSAPR allows emissi ons trading, it also maintains s tate

specific limits by means of assurance provisions designed to ensure that the necessary emission reductions occur within each

covered state. The CSAPR FIPs for Pennsylva nia 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 G eneration, 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.

NO X 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 NO X Budget Trading Program but are not subject to the CAIR NO X Ozone Season Trading Program. T hese units must continue monitoring

NO X emissions and must meet an emiss ions 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 NO X trading progr ams)

, 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 NO X from stationary internal combustion engines; and emissions of

NO X from cement manufacturing), updating the large stationary internal combustion engine and cement manufacturing regulations

, respectively, tha t were adopted pursuant to the NO X 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 revisi on 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 NO X 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 Pennsylva nia. 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

standar ds for hazardous air pollutants) . The standards are also included in- 31

- federally enforceable plan approvals and operating permits issued by the

De partment for affected sources.

2

. Highway Vehicle Sources

Even with increases in VMT t hat occur from 2007 thr ough 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 incr ease in vehicle miles traveled. These decreases can be attributed to the programs des cribed below.

Federal Motor Vehicle Control Programs (FMVCP) and Pennsylvania Clean Vehicle Program for passenger vehicles and light

duty trucks and cleaner gasoline. Tier 1 tailpipe standards established by the CAA Amendments of 1990 include NO X and VOC limits for light

duty gasoline vehicles (LDGVs) and light

- duty gasoline trucks (LDGTs).

The phase in of the se standards began in 1994. Evaporative VOC

emis sions were reduced in gasoline

- powered cars starting with M odel

Y ear (MY) 1998.

In 1998, pursuant to Section 177 of the CAA, the Department adopted the Pennsylvania Clean Vehicles Program (28 Pa. B. 5973 , Dec ember

. 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 t he low emission standards adopted by California

. T he 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 N ational 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

vehicl es 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)

. T he N LEV 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 subje ct to the Tier 2 requirements.

Pennsylvania amended the former New Motor Vehic le 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 ; Dec ember 9, 2006 ) , corrected 37 Pa. B. 209 (Jan uary 12, 2007, eff.

Dec ember 9, 2006)

. The EPA approved Pennsylvania ’ s Clean Vehicle Program as a revis ion to the Commonwealth ’ s SIP o n 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, th at 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 ce rtified by California. California standards we re 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 affecti ng 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 NO X 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 option al “ cl ean NO X 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 require d most highway diesel fuel to contain no more than

15 parts per million (ppm) of sulfur , beginning in the fall of 2006. There

wa s 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 u sed MOVES defaults to estimate the effects of the phase

- in provision.

Vehicle Emission Inspection/Maintenance Program. I n early 2004, Pennsylvania expanded its Vehicle Emission Inspection/Maintenance (I/M) Program into Cambria County. The program applies to gasoline

powered vehicles 9,000 pounds and under, MY 1975 and newer. The program consists of an annual visual inspecti on 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 p art 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 c rude 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; Feb ruary 10, 2000)

reduce d 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 SO 2 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

NO X 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. Em ission 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 PM 2.5 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 prevent s damage t o 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

marin e vessels. In 2010, fuel sulfur levels were reduced to the same sulfur concentration as in highway fue l, 15 ppm; this requirement began applying in 2012 to locomotive and marine diesel fuel. The EPA ado pted

technical a mendments 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 a nd 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 stan dards to reduce emissions of

diesel PM and NO X 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 locomo tives and marine diesel engines, and set s longer

- term standards, referred to as Tier 4 standards, for newly

- built locomotives and marine diesel engines t hat reflect the application of high

- efficiency aftertreatment technology.

4

. Stationary Area Sources

Low Sulfur Fuel Oil. The Environmental Quality Board has adopted a

rule making to reduce the sulfur content of fuel oil in Pennsylvania

. This

final rule making , 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 req uired beginning July 1, 2016. The Department

estimates statewide SO 2 emission reductions of approximately 25,000 tpy
from this rule. The final

- form regulation was submitted to the EPA for

approva l 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. Th e Consumer Products regulation applies statewide to any person who sells, supplies, offers for sale, or

manufactures certain consum er 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 t he 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

a nd/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 G eneral P ermits or GP)

to s pecific 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 authoriz ed 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 e stablished 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 compli ance with

other NSPS or NESHAPs as appropriate.

An own er 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 B ulletin

. 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 q ualifications, 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

- Re quirements 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). A uthority to issue general plan approvals and

oper ating 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 19 96 (61 FR 39594). The Departm ent 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 facili ty cannot be regulated under GP

- 5, a plan approval and/or an operating perm it issued in accordance with 25 Pa.

Code , Chapter 127, Subchapter s 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 (relati ng 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 agenc ies 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 Organization s (MPO) under federal transportation pla nning requirements.

In this Maintenance Plan, Pennsylvania establish es budgets for highway

emissions for direct PM 2.5 and NO X in order to ensure that transportation emissions do not impede clean air goals in the next decade and beyond. The highway emissi on budgets include a safety margin, which was created by setting

aside a portion of the difference between attainment year and maintenance year

emissions of PM 2.5 and NO X to accommodate unanticipated growth in highway

vehicles.

Amendments to the 40 CFR Part 93 transportation conformity regulations to

address the 1997 PM 2.5 standard were published in the Federal Register on May 6,- 38

- 2005 (70 FR 24280)

, to account for PM 2.5 and its precursors. 13 The

I mplementation R ule did not amend these regulations. In th e transportation conformity regulations, 40 CFR § 93.102 requires conformity determinations to be applicable to direct emissions of PM 2.5 and NO X (unless a determination is made that transportation

- related emissions are not significant contributors to PM 2.5 ), but

to emissions of SO 2 , VOC, and NH 3 only if a finding is made that transportation

related emissions of these pollutants are significant contributors to PM 2.5

. The EPA approved Pennsylvania ’ s SIP revision establishing transportation conformity requiremen ts in the Commonwealth on April 29, 2009 (74 FR 19451).

T his Maintenance Plan SIP revision establishes motor vehicle emission budget s for PM 2.5 and NO X

. The informatio n in Table III

- 2 , once t he 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 PM 2.5 NOx County Year PM 2.5 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 PM 2.5 and NO X

. 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 c larifications to improve implementation.- 39

- Table III

- 3 : Comparison of Saf ety 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, NH 3 , and SO 2 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

, NH 3 , and SO 2 Emissions

to the Total Projected 2025 Inventory

Johnstown 2025 SO 2 VOC NH 3 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 exh aust, brake wear, and tire wear, which are estimated by the MOVES model. The Department

has included direct PM 2.5 re

- entrained road dust emissions from paved and unpaved roads in the area source inventory , not in the motor vehicle emission budgets. Appendi x B

- 2 , rela ting to area source annual emissions, contain

estimates of the PM 2.5 emissions attributable to paved and unpaved roads.

The Johnstown monitoring site includes a monitor that measures PM 2.5 mass and a speciation monitor that collects data on the chemical constituents of PM 2.5 in the

Johnstown Area

. Transportation construction

- related fugitive dust emissions are not a significant contributor to the PM 2.5 concentrations observed at the

Johnstown monitor . At the Johnstown monitor, the crustal component was found to be small compared to other components of PM 2.5 ( 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 transpor tation

construction

- related fugitive emissi ons are insignificant.- 40

- Figure 1. Pie Chart of 2012 Johnstown Speciation Data

I V

. AMBIENT AIR QUALITY MONITORING NETWORK

The Department will continue to operate the air monitorin g network in accordance with

40 CFR Part 58 to verify the attainment status of the Johnstown A rea for the 1997 and

2006 PM 2.5 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 A rea that contains analysis of ambient air quality data and related factors.

V

. V ERIFICATION OF C ONTINUED A TTAINMENT

The Department will track the attainment status of the 1997 and 2 006 PM 2.5 NAAQS in

the Johnstown A rea 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 unconventiona l 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

E PA ’ s Air Emiss ion 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

. C ONTINGENCY M EASURES

The D epartment 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 PM 2.5 concentration exceeds

15.5 μ g/m 3 in a single calendar year within the maintenance area , if the 98 th percentile

24

- hour PM 2.5 concentration exceeds 35.0 μg/m 3 in a single calendar year within the

maintenance area

, or if the periodic emissions inventory for the Johnstown Area exceeds

the a ttainment year inventory (2007) by more than 10 percent . The first level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values and whether emissions appear to be increasing. If there appears to be an increasing trend, the study will evalu ate 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 expeditiousl y as possible.

A second level res ponse will be prompted if the 2

- year average of the annual mean PM 2.5 concentrations exceeds 1 5.0 μ g/m 3 or if the 2

- year average of 98 th percentile 24

- hour

PM 2.5 concentrations exceeds 35.0 μg/m 3 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 standard s

. The Department will analyze the condi tions leading to the PM 2.5 levels and evaluate what measures might be most effective in correcting the PM 2.5 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 adop ting 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 PM 2.5 NAAQS occurs, the Department will propose and adopt

additional emission reduction measures , as necessary and appropriate, as expeditiously as practic able 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

or der to return the area to attainment with the standard s

.

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 analysi s 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

at tainment 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 identifie d base d 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 technolo gy for Class 2 yard locomotives; and

o Idling reduction technologies or strategies for truck stops, warehouses and

ot her freight

- handling facilities.

 Promotion of a ccelerated turnover of lawn and garden equipment, e specially commercial equipment.

 Additional promotion of alternative fuel s for fleets, home heating and agricultural

use.

O nce 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 Qu ality Technical Advisory Committee (AQTAC), Citizens Advisory Council and other advisory committees

, 14 as appropriate.

Within 5 months: Environmental Qual ity Board (EQB) meeting/action.

Within 7 months: Publi cation in the Pennsylvania Bulletin for c omment as proposed rulemaking.

Within 9 months: Public hearing takes place and comment period on proposed

rule making closes.

14 Other committees could include the Small Business Compliance Advisory Committee and Agriculture Advisory

Committee.- 43

- Within 10 months : Independent Regulatory Review Commission (IR RC) comment on proposed rule making

. Within 12 months: AQTAC, Citizens Advisory Council and other advisory

committee s, as appropriate, review responses to comme nts and draft final rulemaking.

Within 15 months: EQB meeting/action on final rulemaking

. Within 16 months: IRRC action on final rulemaking.

Within 1 7 months: Attorney General review/acti on on final rulemaking

. Within 18 months: Publi cation in the Pennsylvania Bulletin as final

- form regulation and submi ssion 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 U nited S tates Environmental Protection Agency EQB Environmental Quality B oard

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 V ehicles

LDGT Light Duty Gasoline T rucks

MACT Maximum Achievable Control Technolog y MANE

- VU Mid

- Atlanti c/ 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

NH 3 Ammonia- 45

-

NLEV National Low Emission Vehicle (program)

NMIM National Mobile Inventory Model

NO X Oxides of Nitrogen

NSR New Source Review OTAQ Office of Transportation and Air Qualit y OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood

- fired Boiler

PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM 2.5 Particulate Matter less than 2.5 microns in diameter or Fine P articulates

PM 10 Particul ate Matter less than 10 microns in diameter

PSD Prevention of Significant Deterioration

RWC Residential Wood Combustion

SCC Source Classification Code

SIP State Implementation Plan

SO 2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TSD Technical Support Document

μ g/m 3 M icrogram per cubic meter

μm Micrometer

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

WOE Weight of Evidence

ZEV Zero Emissions Vehicle

# C ommonwealth of Pennsylvania

Redesignation Request

Johnstown Nonattainment Area

1997 and 2006 Fine Particulate Matter National Ambient Air Quality Standard s

December 2014

Bureau of Air Quality Pennsylvania Department of Environmental Protection

P.O. Box 8468 Harrisburg, PA 17 105

- 8468

717

- 787

- 9495

www.dep.state.pa.usThis page intentionally left blank

.- i

- TABLE OF CONTENTS

Introduction

................................ ................................ ................................ ................................ ...... 1

I. Demonstration of Atta inment 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. Popul ation 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 PM 2.5 Concentrations

................................ .............................. 7

Table I

- 2: Johnstown Area 24

- Hour PM 2.5 Concentrations

................................ ............................ 7

Table I

- 3: Johnstown Area Annual PM 2.5 Design Values

................................ .............................. 7

Table I

- 4: Johnstown Area 24

- Hour PM 2.5 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 PM 2.5 Standard for the Johnstown

Area

................................ ................................ ................................ .......................... 16

Table III

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

................................ ....... 23

Ta ble 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 PM 2.5 Nonattainment Areas

................................ ........................ 5

Figure I

- 2: Pennsylvania’s 2006 PM 2.5 Nonattainment Areas

................................ ........................ 5

Figure I

- 3: PM 2.5 Annual Concentration Trend

................................ ................................ ............... 8

Figure I

- 4: PM 2.5 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 PM 2.5 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 f

rom 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 r esult 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, an d 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 evaluate d the role PM 2.5 reductions occurring in the 1980s an d 1990s had on the increased life expectancy observed over that period. The study found that a reduction of 10 micrograms per cubic meter (μg/m 3 ) of PM 2.5 was associated with an average increase in life expectancy of 7.3 months.

PM 2.5 has significant env ironmental impacts, including acid rain and stream eutrophication.

PM 2.5 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 m ass, at reducing visibility

. Soiling and materials damage can also be caused by PM 2.5 in the air.

The United States Environmental Protection Agency (EPA) promulgat ed PM 2.5 N ational

A mbient A ir Q uality S tandards (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/m 3 ), based on the 3

- yea r average of annual mean PM 2.5 concentrations. The EPA also established a primary and secondary 24

- hour standard of 65 μg/m 3 determined by the 3

- year average of the 98th percent ile of 24

- hour concentrations. In 2006, the EPA promulgated a

revised 24

- hour PM 2.5 standard of 35 μg/m 3 determined by the 3

- year average of the

98th percent ile of 24

- hour concentrations. The annual PM 2.5 standard was not revised. ( 71 FR 61 144 (October 17, 2006))

.

On December 17, 2004, the EPA issued air quality designations for the PM 2.5 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 th e Commonwealth of Pennsylvania.- 2

-

The Johnstown Area was one of eight areas in Pennsylvania, comprising all or parts of

21 Pennsylvania counties , designated by t he EPA as nonattainment for the 1997 PM 2.5 N AAQS.

The Johnstown Area, consisting of Cambria County and parts of Indiana County 1 in Pennsylvania, was designated by the EPA as nonattainment because it violated the 1997 annual

standard of 15.0 μg/m 3 based on 2001

- 20 03 monitoring data . The Johnstown Area did not

violate the 1997 24

- hour standard of 65 μg/m 3

.

On October 8 , 200 9 , the EPA promulgated air quality designations for the 2006 24

- hour PM 2.5 standard based on 200 6

- 200 8 air quality monitoring data

. The final designations were published

in the Federal Register on November 13, 2009 (7 4 FR 58688 )

. The EPA designated seven areas comprised of all or portions of 2 2 counties in Pennsylvania as PM 2.5 nonattainment areas. The designations became effective on December 14, 2009

.

The Johnstown Area was one of seven areas in Pennsylvania designated by t he EPA a s nonattainment for the 2006 PM 2.5 N AAQS. The Johnstown Area w as designated nonattainment

because the area violated the 2006 24

- hour PM 2.5 standard of 3 5 μg/ m 3 based on 200 6

- 20 0 8 monitoring data

.

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

for the 1997 and 2006 PM 2.5 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 PM 2.5 NAAQS

. T he emission

reductions responsible for the improvements in PM 2.5 air quality are both permanent and

enforceable. These analyse s 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 PM 2.5 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 T ownships of West Wheatfield, Center, East Wheatfield, and Armagh Borough and Homer City Borough- 3

-

A Maintenance P lan 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 C AA ’s

Section 107(d)(3)(E) cri teria 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))

. O n October 4 , 2014, t he Department provided not ice of a public comment period and the opportunity for a hearing on the Johnstown Area Maintenance Plan for the 1997 and

2006 PM 2.5 NAAQS , 2007 comprehensive inventory required by Section 172(c)(3) of the CAA,

and this Request for Re designation of the Johnstown Area to attainment for the 1997 and 2006

PM 2. 5 standards . The Department scheduled the publ ic 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 ATT AINMENT AND AIR QUAL ITY TRENDS

ANALYSIS

On December 17, 2004, the EPA issued air quality designations for the 1997 PM 2.5 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 eff

ective 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 suppleme ntal 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 t he EPA as nonattainm ent for the 1997 PM 2.5 N AAQS. 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/m 3 based on 2001

- 20 03 monitoring data

. The Johnstown

Area did not violate the 1997 24

- hour standard of 65 μg/m 3

.

On October 8 , 200 9 , the EPA promulgated air quality designations for the 2006 PM 2.5 standard based on 200 6

- 200 8 air quality monitoring data

. The final designations were published in the Federal Register on November 13, 2009 (7 4 FR 58688 )

. The EPA designated seven areas comprised of all or portions of 2 2 counties in Pennsylvania as

PM 2.5 nonattainment areas. The designations became effective on December 14, 2009

.

The Johnstown Area was one of seven areas in Pennsylvania designated by t he EPA as nonattainment for the 2006 PM 2.5 N AAQS. The Johnstown Area w as designated

nonattainment because the area violated the 2006 24

- hour PM 2.5 standard of 3 5 μg/m 3

based on 200 6

- 20 0 8 monitoring data

.- 5

- Figure I

- 1: Pennsylvania’s 1997 PM 2.5 Nonattainment Areas

Figure I

- 2: Pennsylvania’s 2006 PM 2.5 Nonattainment Areas- 6

-

Air quality in the Johnstown Area has improved since the EPA’s original designations.

The Johnstown Area’s annual PM 2.5 design value has decreased over the 2001 to 201 3

time frame. Based on 2001

- 2003 air quality monitoring data, t he Johnstown Area’s

annual and 24

- hour design value s for 2003 were 15.8 μ g/m 3 and 41 μg/m 3

, respectively

. Based on 2011

- 2013 air quality monitoring data, t he Johnstown Area’s 201 3 annual and

24

- hour design value s w ere 12.3 μ g/m 3 and 30 μg/m 3

. Following the EPA criteria,

annual PM 2.5 design value s below 15.0 μ g/m 3 and 24

- hour design values below 35 μg/m 3

are considered to be attainment for the 1997 annual and 2006 24

- hour NAAQS

. Annual

and 24

- hour c oncentrati ons are expected to remain lower than 15 μ g/m 3 and 35 μg/m 3

over the next decade.

On September 25, 2009, the EPA determined that the Johnstown Area had attained the

1997 PM 2.5 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 fi nal 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 attainme nt of the 1997 PM 2.5 NAAQS for so long as the area continues to attain the 1997 PM 2.5 NAAQS 2

.

On March 29, 2012, the EPA determined that the Johnstown Area had attained the 2006

PM 2.5 NAAQS based on quality assured, quality controlled and certified ambien t 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

ass ociated reasonably available control measures, reasonable further progress plans, contingency measures and other planning SIP revisions related to the attainment of the

2006 PM 2.5 NAAQS for so long as the area continues to attain the 2006 PM 2.5 NAAQS.

The determination of attainment did not “ redesignate ” the area as “attainment.” The

Johnstown Area remains nonattainment for the 1997 and 2006 PM 2.5 NAAQS until the Commonwealth submits, and the EPA approves, a Request for R edesignation and a Maintenance Plan showing the area can maintain the se standard s for at least 10 years.

A. Design Value Determination

The ambient air quality analysis is based on PM 2.5 data measured at the

Johnstown Area monitoring site. The ambient ai r quality data analysis for PM 2.5 was completed using the appropriate regulations and guidance documents. Monitoring procedures were determined in accordance with 40 CFR Part 58

. The

PM 2.5 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 PM 2.5 NAAQS by the applicable attainment date of April 5, 2010. The EPA base d 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

T his section provides a brief summary of PM 2.5 monitoring concentrations in t he

Johnstown Area

.

Trends in PM 2.5 design values were analyzed from 2001 through 201 3

. Table I

- 1 displays annual PM 2.5 concentrations monitored in the Johnstown Area. Table I

- 2

contains the 98 th percent ile of 24

- hour concentrations for each year

.

Table I

- 1: Johnstown Area Annual PM 2. 5 Concentrations

Table I

- 2: Johnstown Area 24

- Hour PM 2.5 Concentrations

Tables I

- 3 and I

- 4 contain the Johnstown Area ’ s annual and 24

- hour PM 2.5 design

values calculated using the 2001 through 201 3 monitoring data. Design values

for the annual and 24

- hour PM 2.5 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/m 3

. The 24

- hour design value for that time period was 41 μg/m 3

. 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 PM 2.5 design values for the Johnstown Area are shown below in

Tables I

- 3 and I

- 4, respectively.

Table I

- 3: Johnstown Area Annual PM 2.5 Design Values- 8

- Table I

- 4 : Johnstown Area 24

- Hour PM 2.5 Design Values

The 2001 through 201 3 trend lines for annual and 24

- hour PM 2.5 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 PM 2.5 concentrations are both negative, indicating decreasing concentrations.

Figure I

- 3 : PM 2.5 Annual Concentration Trend

y =

- 0.3434x + 16.696

0 2 4 6 8 10 12 14 16 18

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 PM2.5 Design Value (ug/m3) 

## PM2.5 Annual Design Value Trend

Johnstown Annual DV

Level of Standard- 9

- Figure I

- 4 : PM 2.5 24

- Hour Concentration Trend

C

. Climate Trends Analysis

PM 2.5 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 at mospheric reactions of precursor

emissions of sulfur dioxide ( SO 2 )

, oxides of nitrogen ( NO X ) and ammonia ( NH 3 )

. Organic carbon is a combination of secondary organic particles formed from

emissions of volatile organic compounds ( VOC ) and the organic portion of primary PM 2.5 that is directly emitted or condenses near its source. Currently, our understanding of sulfate and nitrate chemistry and its impacts on PM 2.5 concentrations far exceeds our understanding of contributions from anth ropogenic

VOCs. 25 27 29 31 33 35 37 39 41 43 45

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 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 20 12 Johnstown Speciation Data

Attainment of the PM 2.5 NAAQS involves the range of meteorological conditions throughout the year. PM 2.5 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 PM 2.5 concentrations.

To assess whether it is likely that unusual meteorological patterns have

contributed to the lower PM 2.5 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 A rea for 2001 through 2013 . Figure I

- 5 graphically displays the data. 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)- 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 PM 2.5 NAAQS based on 2001 through 2003 monitoring data and nonattainment

for the 2006 PM 2.5 NAAQS based on 2006 through 2008 monitoring data

. These timeframe s show typical year

- to

- year variation in temperature with

no unusual conditions that would be expected to cause higher PM 2.5 concentrations as experienc ed . The Johnstown Area’s C lean D ata

D etermination s for the 1997 and 2006 PM 2.5 NAAQS w ere based on 200 6 through 200 8

, and 2008 through 2010 monitoring data, respectively. T he 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 200 6 through 201 3 shows normal variation in seasonal temperatures but no evidence of unusual patterns that would be expected to repress PM 2.5 formation.

2. Precipitation Trends

Table I

- 6 presents monthly and annual precipitation data for the

Johnstown A rea 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)

0.0 10.0 20.0 30.0 40.0 50.0 60.0

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Precipitaion (inches) 

## Annual Precipitation- 13

- Examination of the 2001 through 2003 and 2006 through 2008 precipitation data indicates both drier and wetter than usual year s within

th ose timeframe s . Examination of the precipitation data from 200 6 through 201 3 also shows variation in precipitation amounts. There is no indication from the data that unusual precipitation patterns contribute d to
the lower PM 2.5 concentrations in recent years in which the Johnstown

Area monitored attainment of the PM 2.5 NAAQS

.

D

. Additional Trends

1. Population Trends

The Johnstown Area

, which consists of Cambria County and portions of Indiana County

, has had negative populatio n 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, t he 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 o ver 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. E conomic Trends

Economic trends could have impacts on emissions and consequently affect

PM 2.5 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 John s town Area ’s population change and estimated labor force change since 19 9 0 . A lar ger 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/s pending). 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 Popul ation 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 employm ent 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 sta te’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

. M odeling Analysi s

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 PM 2.5 NAAQS in 2014, even in the absen ce 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 t ransformation, 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 R esearch Mesoscale Model (MM5) version 3.7.4. The 2005

emissions of SO 2 , NO X , VOC, NH 3 and direct PM 2.5 were modeled. The modeling was based on the annual PM 2.5 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 PM 2.5 Standard for the Johnstown Area) displays the results of EPA’s analysis for the Johnstown Area. EPA’s analysis indicates that the Johnstown Area wo uld attain the 1997 and 2006

PM 2.5 NAAQS in 2014, even in the absence of either CAIR or CSAPR . The results support redesignating the Johnstown Area to attainment for the PM 2.5 NAAQS.

Table I

- 7: EPA’s CSAPR Modeling Results for the PM 2.5 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 )

I I

. SIP APPROVALS A ND APPLICABLE REQUIREME NTS

In order for EPA to redesignat e 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 S ections 110(a)(2), and

Part D S ections 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. C ircuit has also recently held that EPA must implement the PM 2.5 NAAQS pursuant to Subpart 4 of Part D

– s ee Section III below for

more information.- 17

-

These requirements have been fulfilled for the Johnstown A rea.

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 sta ted 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 rema ins 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 PM 2.5 nonattainment status of the

Johnstown Area are not applica ble requirements for purposes of review of the

Commonwealth’s PM 2.5 redesignation request. However, EPA requires that the

Commonwealth’s Prevention of Significant Deterioration (PSD) requirements be approved prior to redesignation, because PSD requirement s 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 revisio n for an

area de signated 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 PM 2.5

. 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 . T herefore, 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 PM 2.5 NAAQS (76 FR 79593). On December 31, 2012, the EPA published f inal approval of Ohio’s redesignation request for the Ohio portion of the Huntington

- Ashland nonattainment area for the

1997 PM 2.5 NAAQS (77 FR 76883).- 18

-

B. Part D

- Plan Requirements for Nonattainment Areas

1. Sect ion 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, o n September 25, 200 9

, the EPA determined that the

Johnstown Area had attained the 1997 PM 2.5 NAAQS (“Clean Data Determination”) (7 3 FR 49949 ) . EPA’s Clean Data Determination was based on quality

- assured, quality

- controlled and certified ambient air monitoring data that show the ar ea ha d monitored attainment since the

200 6 through 200 8 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 PM 2.5 NAAQS for so long as the area continues to meet the 1997 PM 2.5 NAAQS.

O n March 29, 2012, the EPA determined that the Johnstown Area had

attained the 2006 PM 2.5 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”) (7 7 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 PM 2.5 NAAQS for so long as the area

continues to attain the 2006 PM 2.5 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, t he 2007 inventory

, which also serves as the attainment year inventory, is being submitted as part of the Maintenance P lan, su bmitted 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 signif icant 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 fed erally mandated requirements in S ections 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 G eneral C onformity rule (40 CFR Part 93, Subpart B) by reference in its entirety in 25 Pa.

Code Section 127.802 . The G eneral C onformity regulation describes procedures to determine if federally

- financed, non

- transportation projects

are in con formity 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 th e 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 II I ), 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 PM 2.5 , SO 2 , NO X , VOC and NH 3 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 Johnstow n Area for the 1997 and 2006 PM 2.5 NAAQS.

I II

. DEMONSTRATION OF PER MANENT AND ENFORCEAB LE IMPROVEMENT

This section provides an assessment of the PM 2.5 and PM 2.5 precursor emissions at a time

the Johnstown A rea was monitoring nonattainment of the PM 2.5 NAAQS and at the time

when this area attained the PM 2.5 NAAQS. 5 A 200 5 ( baseline ) inventory of PM 2.5 and

PM 2.5 precursor emissions is used to represent emissions during the PM 2.5 nonattain ment designation period. A 2007 inventory is used to identify PM 2. 5 and PM 2.5 precursor emissions during a period when the Johnstown A rea demonstrated that it attained the

PM 2.5 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, effec tive control

measures for PM 2.5 will vary among nonattainment areas.

By way of background, EPA issued it s “Implementation Guidance for the 2006 24

- Hour Fine Particle National Ambient Air Quality Standard,” on March 2, 2012 (later withdrawn) . In the Imp lementation Guidance for the 2006 PM 2.5 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 PM 2.5

, 71 FR 61144, October 17, 2006- 21

-

the framework and policy approach the agency espoused in its implementation rule for

the 1997 PM 2.5 NAAQS, known as the “ Clean Air Fine Particle Implementation Rule (72 FR 20586 ; April 25, 2007) (the Implementation Rule for the 1997 PM 2.5 NAAQS” )

In its Implementation Rule for the 1997 PM 2.5 NAAQS, EPA established general presumptive policies for assessing which PM 2.5 precursors should be evaluated for possible controls. In that earlie r rule, t he EP A require d states to evaluate control

measures for SO 2 and primary PM 2.5 in all locations. The EPA require d states to evaluate

control measures for NO X unless a technical demonstration is made to show NO X does not significantly contribute to PM 2.5 . The EPA require d states to evaluate measures for

VOC and NH 3 only if a technical demonstration is made to show they significantly

contribute to PM 2.5 in that area.

The EPA reaffirmed the appropriateness of the se presumptions in its Implementation

Guidance for the 2006 24

- Hour PM 2.5 NAAQS. Meanwhile, the U.S. Court of Appeals for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997

PM 2.5 NAAQS, in Natural Resources Defense Counci l v. EPA, No. 08

- 1250. On January 4, 2013, the Court handed down its ruling in that case.

The C ourt 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

PM 2.5 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.

T he M aintenance P lan accompanying this Request for Redesignation demonstr ates
maintenance of the standard s consistent with the C ourt’s ruling.

In general, the C ourt’s decision (for the 1997 PM 2.5 NAAQS and to the extent it would be extrapolated to the 2006 24

- Hour PM 2.5 NAAQS) could affect an area’s nonattainment

classificatio n, 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 PM 2.5 NAAQS, those considerations are not relevant for this Request for Redesignation and the M aintenance P lan. The C ourt noted that PM 2.5 precursors, including ammonia and VOCs, are presumptively regulate d in PM 2.5 nonattainment areas

under Subpart 4, pointing specifically to Section 189(e), which applies to control of major stationary sources of PM 10 [the court stated that PM 10 includes PM 2.5 throughout Subpart 4] ( 706 F.3d at 436, n. 7, and at 437, n. 10 )

. According to Section 189(e) of t he CAA, control requirements applicable for major stationary sources of PM 10 also apply to major stationary sources of PM 10 precursors, except where the Administrator determines

7 “Withdrawal of Implementation Guidance for the 2006 24

- Hour Fine Particle ( PM 2.5 ) National Ambient Air Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013.- 22

-

that major stationary sources do not contribute significantly to PM 10 levels t hat 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 PM 2.5 , SO 2 , NO X , VOC and NH 3 for the maintenance

demonstration.

T his Request for Redesignation provides emissions information for all pollutants ( PM 10 , PM 2.5 , SO 2 , NO X , VOC and NH 3 )

, 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 PM 2.5 and PM 2.5 precursor emission estimates for the

Johnstown A rea. These inventories have been developed in accordance with the EPA emission inventory prepar ation guidance. The section then presents information about the permanent and enforceable control measures that have been implemented in the

Johnstown A rea to produce the emission reductions that have occurred between these

years and that will provide emi ssion reductions ensuring maintenance of the PM 2.5 standard s

.

A. Baseline (200 5 ) 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 PM 2. 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.

T he inventory contains information for the pollutants PM 10 , PM 2.5 , SO 2 , NO X , VOC, and NH 3 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 refuel ing 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,

oth er 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

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

V ehicle M iles T raveled (VMT) and other parameters, the MOBILE6 model predicts higher VOC and significantly lower NO X and PM 2.5 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 T able III

- 1.

Table III

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

Johnstown 2005 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 PM 10 , PM 2.5 , SO 2 , NO X , VOC and NH 3 emissions for the

Johnstown A rea is used to identify emissions during the period when attainment

of the PM 2.5 NAAQS was demonstrated for the Johnstown A rea. 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 47,95 8 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,

PM 2.5 , PM 10 , SO 2, NO X , V OC, and NH 3 emissions decreased by 70 percent,

67 percent, 7 percent, 1 percent, 15 percent and 13 percent, respectively, from

200 5 to 2007, a s 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 c ontributing factors in

Section I of th is Request for Redesignation , this section describes the permanent
and enforceable federal and state measures that provided PM 2.5 , SO 2 , NO X and

VOC emission reductions from 2005 to 2007 to bring the Johnstown Area into

attainment and measures that will assure maintenance of the standard s

.

The EPA’s Implementation Guidance for the 2006 24

- Hour PM 2.5 NAAQS adopted the same presumptions related to PM 2.5 precursors as the EPA’s Implementation Rule for the 1997 PM 2.5 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 PM 2.5 NAAQS

.

In general, the C ourt’s decision (for the 1997 PM 2.5 NAAQS and to the extent it

would be extr apolated to the 2006 24

- Hour PM 2.5 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 PM 2.5 NAAQS, however,

those considerations are not relevant for this Redesignation Request or the accompanying M aintenance P lan.

The C ourt noted that PM 2.5 precursors are presumptively regulated in PM 2.5 nonattainment areas under Subpart 4 , pointing spec ifically to S ection 189(e), which applies to control of major stationary sources of PM 10 [the C ourt stated that

PM 10 includes PM 2.5 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 PM 10 also apply to major stationary sources of

PM 10 precursors , except where the Administrator determines that major stationary sources do not contribute significantly to PM 10 levels that exceed the standard in the area; Section 189(e) also requires the EP A to issue guidelines regarding the application of Subsection (e) . Pennsylvania assessed emissions of PM 2.5 , SO 2 , NO X , VOC and NH 3 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 PM 2.5 , PM 10 , SO 2, NO X , VOC, and NH 3 emis sions 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 200 5 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 200 5 to 2007

Change from 2005 to 2007 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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

PM 2.5 , SO 2 , NO X and VOC emission reductions

, ensuring maintenance of the

standard s

.

A summary of the total emission s 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 PM 2.5 and NO X . For all pollutants

, emissions in

2017 and 2025 in the Johnstown A rea are anticipated to b e 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 pollutant s
, in the

nonattainment area

. In addition, the Johnstown Area currently has an annual design value based on 201 1

- 201 3 monitoring data of 12. 3 μg/m 3 , which is significantly lower than the 1997 NAAQS of 15 μg/m 3

. Based on 201 1

- 201 3 monitoring data, t he Johnstown Area has a 24

- hour design value of 3 0 μg/m 3
which is significantly lower than the 2006 PM NAAQS of 35 μg/m 3

. 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 PM 2.5 SO 2 NOx VOC NH 3 2007 4,031 144,252 47,95 8 5,325 508

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

2025* 3,74 1 141,932 43,110 3,471 494
*A portion of the difference between attainment year and maintenance year emissions of PM 2.5 and

NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. The emissions in Table II I

- 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 (pre

construction permit) from the Department prior to the construction, assembly, installat ion 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 mus t 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 stat ionary sources that are below the applicability thresholds for Title V facilities. A “ Title V O perating

P ermit ” 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, reactiva tion 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

approva l 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, 2 012, 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 requiremen ts 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 (6 1 FR 3959 7 ).

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 (PS D) requirements in areas of

the Commonwealth designated attainment for National Ambient Air Quality Standards including carbon monoxide, PM, lead, nitrogen dioxide (NO 2 ), ozone and SO 2 . Generally, NSR permit requirements are applicable to the owner and operator of a facility located in a nonattainment area for a particular pollut ant with a potential to emit 50 or

more tons per year (tpy) of volatile organi c compounds or 100 tpy or more
of NO X , SO 2 , PM

, or carbon monoxide. It should be note d 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 (NO X ) and volatile organ ic compounds (VOCs). Because NO X and VOC

are also precursors of PM 2.5 , NO X 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

P M 2.5 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 potentia l to emit air contaminants including NO X , 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 no nattainment 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 inc orporated 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 emi t 100 tpy or 250 t py of the six criteria pollutants including carbon monoxide , lead, NO 2 , ozone, PM

, and SO 2 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 availabl e 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 fede ral 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 en ergy, 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 w ill 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 em issions 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 th e SIP at 40 CFR §52.2020(c)(1).

NO X and SO 2 Control Programs. In 1998, the EPA promulgated the

NO X 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

NO X SIP call rule, Pennsylvania adopted the NO X 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 NO X SIP Call, Pennsylvania adopted additional NO X control regulations covering cement plants and internal combustion engines, with emission reductions to commence May 1, 2005. These regulations we re 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 NO X and SO 2 . 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 NO X and SO 2 trading programs) , with related amendments in Chapters 121, 129 and 145 (relating to general; standards fo r 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

NO X Budget Trading Pr ogram and transitioned to the federal CAIR for large electric generating units (EGU).

The market

- based CAIR is designed to reduce EGU emissions of NO X and

SO 2 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 NO X annual, NO X ozone season, and SO 2 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 H omer 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

. C ircuit 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 P articulate 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 redu ctions associated with CAIR that helped the Areas achieve attainment of the 1997 annual and the 2006

24

- hour PM 2.5 NAAQS would be permanent and enforceable for purposes of redesignation under Section 107(d)(3)(E)(iii) of the CAA, because CSAPR requires sim ilar 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 s tates and promulgated FIPs to achieve the reductions (76 FR 48208; August 8, 2011) . Although CSAPR allows emissi ons trading, it also maintains s tate

- specifi c limits by means of assurance provisions designed to ensure that the necessary emission reductions oc cur 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. Ci rcuit imposed a stay on CSAPR. On

October 23, 2014, however, the court lifted the stay.

NO X 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 Commo nwealth’s NO X Budget Trading Program but are not subject to the CAIR NO X Ozone Season Trading Program.- 31

- T hese units must continue monitoring NO X emissions and must meet an emissions cap. Each unit has an allowable emission rate, calculated by January 31 o f 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 NO X trading programs) , was approved by EPA on

December 10, 2009, and codified in the SIP at 40 C FR §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 NO X 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 NO X from stationary internal combustion engines; and emi ssions of NO X 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 NO X emissions effective April 15, 2011, co dified in 25 Pa. Code Chapter 145, Subchapter C (relating to emissions of NO X 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 stand ards 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 s tandards 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 t hat 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,

compensa ting for the increase in VMT . These decreases can be attributed

t o the programs described below.- 32

- Federal Motor Vehicle Control Programs (FMVCP) and Pennsylvania Clean Vehicle Program for passenger vehicles and light

duty trucks and cleaner gasoline. Tier 1 tailpipe standards established by the CAA Amendments of 1990 include NO X and VOC limits for light

duty 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 car s 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 ; Dec ember 5, 1998). The Pe nnsylvania 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 e mission 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 Emi ssion 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

vehicl es in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV (Tier 2), starting with MY 2004. T he NLEV program was replaced for

MY 2004 and later by the more stringent Federal “Tier 2” vehicle emissions regulations ( 65 FR 6698 ; Feb ruary 10, 2000), and vehicle manufacturers operating under the NLEV program became subje ct 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 ; Dec ember 9, 2006, corrected 37 Pa. B. 209 ; Jan uary 12, 2007, eff. Dec ember 9, 2006).

The EPA approved Pennsylvania’s Clean Vehicle Program as a revis ion to

the Commonwealth’s SIP o n 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 comp anies 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 E QB 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 20 07 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

- du ty 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 NO X and VOCs. For gasoline engines, the standards w ere 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 NO X 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 sulfu r in fuel, the EPA also required most highway diesel fuel to contain no more than

15 parts per million (ppm) of sulfur, beginni ng in the fall of 2006. There

wa s 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 u sed MOVES defaults to estimate the effects of the phase

- in provision.

Vehicle Emission Inspection/Maintenance Program. I n early 2004, Pennsylvania expanded its Vehicle Emission Inspection/Maintena nce (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 natural ly 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 w ill work longer and more efficiently, and air pollution

will be reduc ed.

The 1999 federal Tier 2 regulations (65 FR 6698 ; Feb ruary 1 0, 2000)

reduce d 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 p rovided 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 me eting 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, 201 4

. 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 SO 2 emissions from gasoline vehicles will be reduced by 56 percent. When fully implemented, this program, by 2030, will increase the effectiveness

of vehicle e mission controls even further and reduce onroad emissions of

NO X by 25 percent, direct partic ulate 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 Ti er 3 program may nonetheless assist the Johnstown Area in maintaining the PM 2.5 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 i mplementation 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 m ilestone 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 prevent s 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 fue l, 15 ppm ; this requirement began applying in 2012 to locomotive and marine diesel fuel. The EPA adopted technical amendments to the pr ogram 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. Th e 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 co difie d 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 Mar ch 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).

I V

. MAINTENANCE PLAN

The 1997 and 2006 PM 2.5 NAAQS Maintenance Plan for the Johnstown Area is being

submitted to the EPA for approval as a S tate I mplementation P lan (SIP) revision concurrently with this R equest for R edesignation. The Maintenance Plan shows that the

1997 and 2006 PM 2.5 NAAQS will be maintained for at least 10 years after redesignation. Eight years foll owing redesignation, the Commonwealth will submit a revised plan that

e nsures attainment through 2035.

T he Maintenance Plan demonstrates that emission levels of PM 2.5 , SO 2 , NO X , VOC and

NH 3 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

201 1

- 201 3 monitoring data, the Johnstown Area currently has an annual design value of

12. 3 μg/m 3 , whi ch is significantly lower than the 1997 NAAQS of 15 μg/m 3

. In addition,

based on 201 1

- 201 3 monitoring data, t he Johnstown Area has a 24

- hour design value of

3 0 μg/m 3 which is significantly lower than the 2006 NAAQS of 35 μg/m 3

. The following

state and federal programs will ensure the continuing decline of SO 2 , NO X , direct PM 2.5 and VOC emissions:

● C lean A ir I nterstate R ule ;

● Emission limits for large industrial boilers;

● State regulation of cement kilns, large stationary internal combustion engine s , and

smaller sources of NO X ;

● 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

p assenger and light

- duty trucks;

● The Pennsylvania and federal heavy

- duty di es el emission control programs;

● Federal fuel programs for highway vehicles an d nonroad mobile equipment; and

● Federal regulation of off

- road diesel and gasoline

- powered vehicles and equipment.

The emission reductions from the following programs were no t 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

- P owered 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).

 NO X 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 PM 2.5 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 PM 2.5 NAAQS that might occur af ter redesignation of the area.- 38

-

ACRONYMS AND ABBREVI ATIONS

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 Qualit y 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 V ehicles

LDGT Light Duty Gasoline T rucks

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 Or ganization

MY Model Year NAAQS National Ambient Air Quality Standard (s)

NAICS North American Industry Classification System

NEI National Emissions Inventory

NH 3 Ammonia

NLEV National Low Emission Vehicle (program)- 39

-

NMIM National Mobile Inventory Model

NOAA National Oceanic and Atmospheric Administration

NONROAD Nonroad Model

NO X 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

PM 2.5 Particulate Matter less than 2.5 microns in diameter or Fine P articulates

PM 10 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

SO 2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TIP Transportation Improvement Program

TSD Technical Support Document

μ g/m 3 M icrogram per cubic meter

μm Micro meter

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 Nona ttainment Area for the 1997 Annual and

2006 24-Hour Fine Particulat e Matter National Ambient Air Quality Standards; Public Hearing

[44 Pa.B. 6291] [Saturday, October 4, 2014]

Particulate matter (PM) includes bot h solid and liquid particles suspe nded in the air. Fine particle pollution describes particulate matter that is le ss than or equal to 2.5 micrometers in diameter (PM 2.5 ). PM 2.5 concentrations above the Federal heal th-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 PM 2.5 National Ambient Air

Quality Standards (NAAQS). Theref ore, the Department of Envir onmental Protection (Department) intends to submit a request to the United Stat es Environmental Protecti on Agency (EPA) for the redesignation of the Johnstown Area to attainment of the 1997 and 2006 PM 2.5 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 Cl ean 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 PM 2.5 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 tr ansportation conformity purposes.

The Department's proposed reque st to the EPA for the redesigna tion 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 (choos e ''Air,'' choose ''Bureau of Air Qual ity,'' 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 Offi ce, 286 Industrial Park Road, Ebensburg, PA 15931-4119. Persons wishing to present testimony at the hearing should contact Alex Haas, P. O. Box 8468, Harris burg, 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 stat ement at the hearing.

If by Monday, November 3, 2014, no person has expres sed an interest in testifying at the hearing, the hearing will be cancelled. The Depart ment 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 al so 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 re quire an auxiliary aid, service or Page 1 of 2 PA Bulletin, Doc. No. 1 4 -2070

11 / 20 / 201 4 htt p ://www. p abulletin.com/secure/data/vol44/4 4 -40/2070.htm lother accommodation to participat e in the proceeding should cont act 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 ''Johnsto wn 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.

Due to the limitations of HTML or differences in display capabilit ies of different browsers, this version may differ slightly from the official printed version.

webmaster@PaBulletin.com Page 2 of 2 PA Bulletin, Doc. No. 1 4 -2070

11 / 20 / 201 4 htt p ://www. p abulletin.com/secure/data/vol44/4 4 -40/2070.htm lCOMMONWEALTH 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

Nota ri a l S ea l

M Vivian Ohs, Notary Public City o f J o hnst o wn, cambria county

* This affidavit must be made by the Owner, Publisher, or the designated agent of he 0

. ilr es**~~~N60;~~~ARt~** MEMBt:R. PENN YI.VANI A ASSOCl

.

### J ohn-s}own

P&A**~** };sl,.J 

### Tr :**~** 

### "'''
e.

- Del"" 0," ,-"./- 

### Dc .).0 

## ber :$ I Z 0 I L{

Propo sed**St~te** Implem entat ion Plan ' Revision

Redesig nation Request and Maintenance Plan for the Johnst own Nonattainment Area for the 1997 Annual "and 2006 24-Hour Fi ne Particulate Matter National

Ambient Air Qua lity Standards; Public Hearing

Parti c u late matter (PM) inc ludes both solid and liquid particles suspended in the air

. Fine particle pollution describes particu late 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 nonattainme nt a r ea 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 ' si ve 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 P2,5hea l th -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. Pennsy lvan ia'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 "A ir," 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

09/30/2014 400 MARKET ST., 12TH FLR.

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 

# )