fit ~:~~~!~~E~A~~O~CTION SECRETARY 

September 5, 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 

Pennsylvania portion of the Philadelphia-Wilmington (PA-NJ-DE) 1997 annual and 2006 

24-hour fine particulate matter (PM2.5) nonattainment area to attainment, and a revision to the 

State Implementation Plan (SIP) including a Maintenance Plan demonstrating that the area can 

maintain the 1997 and 2006 PM2.5 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 

May 10, 2014, on the proposed redesignation request, maintenance plan and comprehensive 

emissions inventory for the area. The public hearing scheduled for June 12, 2014, was cancelled 

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

comments were received from two parties. 

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; 

3. Certification of public participation activities; and 

4. Comment and Response Document. 

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

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

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

completing the issuance of the SIP revision. 

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

717.787.2814 (JLz. Printed on Recycled Paper '\.6CJ www.depweb.state.pa.us 
Mr. Shawn Garvin -2- September 5, 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 at jeepps@pa.gov or by telephone at 

717.787.9702. 

Sincerely, 

E. Christopher Abruzzo 

Secretary 

Enclosures 
- 1 -

Comment and Response Document

Philadelphia Nonattainment Area

1997 and 2006 Fine Particulate Matter National Ambient Air Quality Standards

Redesignation Request and Maintenance Plan

On May 10, 2014, the Pennsylvania Department of Environmental Protection (DEP) requested 

written comments and provided notice of the opportunity for a public hearing on the proposed 

Redesignation Request and Maintenance Plan for the 1997 and 2006 Fine Particulate Matter 

National Ambient Air Quality Standards in the Philadelphia Nonattainment Area. A public 

hearing was scheduled for June 12, 2014 on the proposed redesignation request and plan 

revision, but the hearing was cancelled because no person requested a hearing. The comment 

period closed on June 13, 2014. 

Two commentators provided comments on the proposed SIP revision.

1. Diana Esher, Director

Air Protection Division

U.S. Environmental Protection Agency

1650 Arch Street

Philadelphia, PA 19103-2029

2. Diego Rincón

Deputy Director of Aviation, Capital Development

Philadelphia Division of Aviation

Philadelphia International Airport

Terminal D, Level 3

Philadelphia, PA 19153

COMMENTS AND RESPONSES. The identity of each commentator making the comment is 

indicated by the assigned numbers in parentheses after each comment.

1. Comment: In Table III-3: Comparison of Safety Margin to total Anticipated Emissions 

Reductions in 2017 and 2025, EPA identified the following calculation errors.

 The anticipated emissions reductions for PM2.5 from 2007-2017 should be 1,690, 

not 2,491.

 The anticipated emissions reductions for NOx from 2007-2017 should be 44,809, 

not 57,699.

 The anticipated emissions reductions from for NOx from 2007-2025 should be 

57,700, not 57,699. (1)

Response: DEP agrees and has corrected the calculation errors in Table III-3 in the final 

Maintenance Plan.

2. Comment: The commentator compared aircraft emissions in the Air Quality Technical 

Report for the Capacity Enhancement Program (CEP) at the Philadelphia International 

Airport (PHL) with the aircraft emissions in the proposed Maintenance Plan for 
- 2 -

Philadelphia and Delaware counties. PHL is situated in both counties. Because the 

proposed Maintenance Plan contains estimates for 2007, 2017 and 2025 and the CEP 

contains estimates for 2004, 2020 and 2025, the commentator adjusted the Maintenance 

Plan’s emissions to 2020 levels by assuming a linear growth model. The commentator 

concluded that the proposed Maintenance Plan underestimates aircraft emissions for 2017 

and 2025 as compared to the CEP estimate for NOx, SO2, PM10 and PM2.5. The 

differences are 12 percent for NOx, 7 percent for SO2, 69 percent for PM10 and 

70 percent for direct PM2.5. The commentator’s comparison chart also shows that the 

proposed Maintenance Plan contains 9 percent more emissions for VOC than the CEP. 

The commentator requests that the final Maintenance Plan include the emissions 

estimates from the CEP. (2)

Response: The Department agrees that the more general projections in the proposed 

Maintenance Plan may not adequately account for the implementation of the CEP. The 

final Maintenance Plan incorporates the commentator’s suggestions and includes a 

separate emissions category for the CEP, based on the emission estimates from the final 

Environmental Impact Statement (released August 2010) for the CEP. The Maintenance

Plan describes the revised methodology for estimating projected airport operations 

emissions.

Using the increased estimates for NOx, SO2, PM10 and PM2.5 does not affect the ability 

of the Pennsylvania portion of the nonattainment area to show that emissions in future 

years will be less than emissions in the attainment year. 

3. Comment: The final Maintenance Plan should include a sentence that states that any 

low emission initiatives that are undertaken by the City of Philadelphia at the 

Philadelphia International Airport are not accounted for in the SIP. In particular, any 

emission reductions resulting from the following low emission initiatives implemented at 

the Airport will be considered above and beyond the scope of the SIP and therefore 

eligible for Airport Emission Reduction Credits, as defined by the Federal Aviation 

Administration’s Voluntary Airport Low Emissions (VALE) Program:

 The use of electric ground service equipment (GSE) by the City or by tenant 

airlines.

 The installation and use of preconditioned air (PCA) and 400 Hz converter units 

on jetbridges or for use at remote aircraft parking positions, cargo aircraft loading 

aprons, or maintenance facilities.

 The use of electric or other alternative fuels for mobile equipment.

 Upgrades to central utility plants or other heating, air conditioning, and 

ventilation systems to operate more efficiently than required by law, including the 

use of geothermal wells. (2)

Response: The Department agrees that these low emission initiatives are not accounted 

for in the SIP. They are also not listed as potential contingency measures should the area 

violate the 1997 or 2006 NAAQS. Therefore, the final Maintenance Plan will clarify that 

these types of projects are eligible for the VALE program. 
Commonwealth of Pennsylvania

State Implementation Plan Revision: Maintenance Plan and 

Comprehensive Inventory 

Pennsylvania Portion of the

Philadelphia-Wilmington, PA-NJ-DE

Nonattainment Area

1997 and 2006 Fine Particulate Matter

National Ambient Air Quality Standards

August 2014

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

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

Table of Contents

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

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

B. Sources of PM2.5 and Precursor Pollutants of Concern............................................3

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

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

II. Emission Inventories..........................................................................................................10

A. Emissions Inventory Methodology for Baseline Year (2002) and 

Attainment Year (2007) Emissions........................................................................11

B. Baseline Year (2002) Annual Emissions (Tons per Year).....................................16

C. Attainment Year (2007) Annual Emissions (Tons per Year) ................................16

D. Growth Projection Methodologies for 2017 and 2025 ..........................................17

E. Interim Year (2017) Emissions..............................................................................22

F. Maintenance Year (2025) Emissions.....................................................................22

G. Maintenance Plan Emissions Test .........................................................................23

III. Permanent and Enforceable Control Measures..................................................................25

A. Permanent and Enforceable Control Measures......................................................25

1. Stationary Point Sources............................................................................28

2. Highway Vehicle Sources..........................................................................33

3. Nonroad Sources........................................................................................37

4. Stationary Area Sources.............................................................................37

B. Motor Vehicle Emission Budgets for Transportation Conformity ........................38

IV. Ambient Air Quality Monitoring Network........................................................................42

V. Verification of Continued Attainment ...............................................................................42

VI. Contingency Measures.......................................................................................................42

Table of Tables

Table II-1: 2002 Emissions (Tons per Year) ............................................................................... 16

Table II-2: 2007 Emissions (Tons per Year) ............................................................................... 17

Table II-3: VMT (Miles) and Vehicle Emissions (Tons per Year) ............................................. 20

Table II-4: Projected 2017 Emissions (Tons per Year) ............................................................... 22

Table II-5: Projected 2025 Emissions (Tons per Year) ............................................................... 23

Table II-6: Pennsylvania Maintenance Emissions Test............................................................... 24

Table II-7: PA, NJ, DE Maintenance Emissions Test (PM2.5, SO2 and NOx)............................. 24

Table II-8: PA, NJ, DE Maintenance Emissions Test (VOC and NH3) ...................................... 25

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

Measures................................................................................................................... 27

Table III-2: Motor Vehicle Emission Budgets (Tons per Year).................................................. 39

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

2017 and 2025 .......................................................................................................... 40

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

Total Projected 2025 Inventory ................................................................................ 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 Facility Annual Emissions – 2002

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

A-4 Banked Emissions Reduction Credits

APPENDIX B: STATIONARY AREA SOURCES 

B-1 Pennsylvania 2002 Area Source Criteria Air Pollutant Emission Estimation 

Methods (EH Pechan, Feb. 2004)

B-2 Pennsylvania 2007 Area Source Criteria Air Pollutant Emission Estimation 

Methods (Dec. 2009) 

B-3 Area Source Annual Emissions – 2002

B-4 Area Source Annual Emissions – 2007, 2017, 2025

APPENDIX C: REGIONAL EMISSIONS INVENTORY AND PROJECTION

METHODOLOGY

C-1 Technical Support Document for the Development of the 2007 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-2 Technical Support Document for the Development of the 2017/2020 Emission 

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

Region Version 3.3 (AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012)

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

Inventory for PM Nonattainment Counties in the MANE-VU Region 

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

International, Inc. for MARAMA, January 2012)

C-4 Technical Memo Emission Factors for Condensable PM

APPENDIX D: HIGHWAY VEHICLE SOURCES INVENTORY INFORMATION

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

Methodology

D-2 Highway Emissions Estimates – 2002, 2007, 2017, 2025

D-3 MOVES Input Parameter Summary

D-4 MOVES Input and Output Files

APPENDIX E: NONROAD SOURCES

E-1 Emissions Estimation Methodology – 2002

E-2 Nonroad Source Emissions – 2002

E-3 Nonroad Source Emissions – 2007, 2017, 2025

APPENDIX F: INVENTORY COMPARISON 2007/2008/2025 

F-1 Summary 

F-2 Point, Area and Nonroad – 2008

F-3 MOVES – 2008
- 1 -

I. INTRODUCTION AND OVERVIEW

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

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

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

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

or mold spores). Fine particle pollution or PM2.5 describes particulate matter that 

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

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

penetrate deeply into the lungs.

Health studies have shown a significant association between exposure to fine 

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

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

cardiovascular symptoms, cardiac arrhythmias, heart attacks, respiratory 

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

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

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

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

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

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

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

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

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

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

7.3 months.

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

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

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

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

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

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

national ambient air quality standards (NAAQS) in 1997 after evaluating 

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

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

standard of 15.0 μg/m,

3

based on the 3-year average of annual mean PM2.5

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

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

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

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

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

(October 17, 2006)).
- 2 -

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

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

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

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

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

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

supplemental notice changing the designation of certain areas from nonattainment 

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

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

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

county in the Commonwealth of Pennsylvania (Commonwealth or Pennsylvania) 

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

attainment based on the 2002-2004 air quality data.

The Philadelphia-Wilmington, PA-NJ-DE (Philadelphia) Area was one of eight 

areas in Pennsylvania, comprising all or parts of 21 Pennsylvania counties, 

designated by the EPA as nonattainment for the 1997 annual PM2.5 NAAQS. The 

Philadelphia Area was designated by EPA as nonattainment because it violated 

the 1997 annual standard of 15.0 μg/m3based on 2001-2003 monitoring data. 

The Philadelphia Area did not violate the 1997 24-hour standard of 65 μg/m.

3

 

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

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

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

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

22 counties in Pennsylvania as 24-hour PM2.5 nonattainment areas. The 

designations became effective on December 14, 2009. 

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

EPA as nonattainment for the 2006 24-hour PM2.5 NAAQS. The Philadelphia 

Area was designated nonattainment because the area violated the 2006 24-hour 

PM2.5 standard of 35 μg/m3based on 2006-2008 monitoring data.

The Pennsylvania portion of the nonattainment area consists of Bucks, Chester, 

Delaware, Montgomery and Philadelphia counties in Pennsylvania. The 

Delaware portion of the nonattainment area consists of New Castle County. The 

New Jersey portion of the nonattainment area consists of Burlington, Camden and 

Gloucester counties. The EPA redesignated the New Jersey portion of the 

nonattainment area for both the 1997 annual and the 2006 24-hour NAAQS on 

September 4, 2013 (78 FR 54396). The EPA proposed to redesignate the 

Delaware portion of the nonattainment area for both the 1997 annual and the 2006 

24-hour NAAQS on April 11, 2014 (79 FR 20139). 
- 3 -

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

Fine particle pollution can be emitted directly or formed secondarily in the 

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

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

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

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

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

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

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

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

metals.

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

from incomplete combustion and compounds from condensation during 

combustion or smelting.

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

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

concentration of precursors, atmospheric conditions and the interactions of 

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

contribution of different precursors will vary by location.

The principal forms of secondary PM2.5 include:

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

plants and industrial facilities;

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

plants, vehicles, and other combustion sources;

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

animal operations; and

 Secondary organic aerosol, formed from emissions of volatile organic 

compounds (VOCs) from incomplete combustion and evaporation from a 

wide diversity of sources.

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

formation, the EPA recognizes that effective control measures for PM2.5 will vary 

among nonattainment areas. This recognition was reflected in EPA’s 

“Implementation Guidance for the 2006 24-Hour Fine Particle National Ambient 

Air Quality Standard,” Office of Air Quality Planning and Standards, EPA, 

March 2, 2012 (“Implementation Guidance for the 2006 24-Hour PM2.5

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

adopted the framework and policy approach the agency espoused in its 

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

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

Rule for the 1997 PM2.5 NAAQS”). 
- 4 -

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

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

evaluated for possible controls.1 In that earlier rule, the EPA required states to 

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

required states to evaluate control measures for NOX unless a technical 

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

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

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

technical demonstration is made to show VOC or NH3 emissions significantly 

contribute to PM2.5 in the nonattainment area. 

The EPA reaffirmed the appropriateness of these presumptions in its 

Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS.2 Meanwhile, the 

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

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

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

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

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

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

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

Shortly thereafter, EPA withdrew its Implementation Guidance for the 2006 

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

memorandum (see second page of memorandum)3, EPA withdrew the guidance in 

response to the Court’s decision in Natural Resources Defense Council v. EPA, 

No. 08-1250. 

This Maintenance Plan demonstrates maintenance of the standards consistent with 

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

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

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

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

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

Since the Philadelphia Area is already attaining the 1997 annual and 2006 

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

Maintenance Plan. The court noted that PM2.5 precursors, including ammonia and 

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

 

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

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

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

maintenance area plan.”

2 EPA wrote: “The EPA believes that these same presumptions would be appropriately applied with respect to the 

2006 24-hour PM2.5 NAAQS as well.” See, Implementation Guidance for the 2006 24-hour PM2.5 NAAQS, page 3, 

footnote 8.

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

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

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

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

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

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

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

Administrator determines that major stationary sources do not contribute 

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

also requires EPA to issue guidelines regarding the application of Subsection (e). 

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

maintenance demonstration. 

This State Implementation Plan (SIP) revision provides emissions information for 

all pollutants (PM10, PM2.5, SO2, NOX, VOC and NH3), as required by EPA’s 

guidance entitled, “Emissions Inventory Guidance for Implementation of Ozone 

and Particulate Matter National Ambient Air Quality Standards (NAAQS) and 

Regional Haze Regulations.”4

C. Purpose and Structure of this SIP Revision

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

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

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

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

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

demonstrate how the Philadelphia Area will attain the 1997 standard by April 

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

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

area is brought back to attainment as quickly as possible.

However, on May 16, 2012, the EPA determined that the Philadelphia Area had 

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

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

based on 2007-2009 and 2008-2010 data (“Clean Data Determination”)

(77 FR 28782). This final action suspended the requirements for this area to 

submit an attainment demonstration and associated reasonably available control 

measures, reasonable further progress plans, contingency measures and other 

planning SIP revisions related to the attainment of the 1997 PM2.5 NAAQS for so 

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

5

On November 13, 2009 (74 FR 58688), after consultation with states and receipt 

of public input, the EPA designated seven areas in Pennsylvania, comprising all 

 

4 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.

5 In the same rulemaking, EPA also made a statutorily required determination under Section 179(c) of the CAA, that 

the Philadelphia Area attained the 1997 PM2.5 NAAQS by the applicable attainment date of April 5, 2010. EPA 

based this determination on complete, quality assured, and certified ambient air monitoring data that show the area 

monitored attainment for the 2007-2009 monitoring period.
- 6 -

or parts of 22 Pennsylvania counties, as 2006 PM2.5 NAAQS nonattainment areas 

based on 2006-2008 air quality monitoring data. Under Section 110 of the Clean 

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

demonstrate how the Pennsylvania portion of the Philadelphia Area will attain the 

standard by December 31, 2015, meet emission reduction requirements in the 

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

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

possible.

However, on January 7, 2013, the EPA determined that the Philadelphia Area had 

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

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

based on 2008-2010 and 2009-2011 data (“Clean Data Determination”) 

(78 FR 882). This final action suspended the requirements for this area to submit 

an attainment demonstration and associated reasonably available control 

measures, reasonable further progress plans, contingency measures and other 

planning SIP revisions related to the attainment of the 2006 PM2.5 NAAQS for so 

long as the area continues to attain the 2006 PM2.5 NAAQS.

EPA’s determinations of attainment and the Clean Data Determinations did not 

“redesignate” the area as “attainment.” The Pennsylvania portion of the 

Philadelphia Area remains a designated nonattainment area for the 1997 annual 

and 2006 24-hour PM2.5 NAAQS until the Commonwealth submits, and EPA 

approves, a Request for Redesignation and a Maintenance Plan showing the area 

can maintain the standards for at least 10 years after redesignation. 

Nonattainment new source review continues to apply until EPA redesignates the 

area as attainment (72 FR 20603). Transportation conformity and general 

conformity also apply; they will continue to apply to the area even after 

redesignation by EPA as attainment. The Clean Data Determinations do not 

suspend the CAA Section 172(c)(3) requirement to establish a comprehensive

inventory for all pollutants considered potential precursors to PM2.5 and for direct 

emissions of PM2.5.

This SIP revision includes the Maintenance Plan for the Pennsylvania portion of 

the Philadelphia Area for the 1997 and 2006 PM2.5 NAAQS and the 2007

comprehensive inventory required under Section 172(c)(3) of the CAA for the 

2006 NAAQS. The 2007 comprehensive inventory includes point, area, highway 

and nonroad sources of direct PM2.5, PM10 (particles less than 10 microns in 

diameter), SO2, NOX, VOC and NH3. The emissions inventory for 2002 was 

approved by EPA as meeting the requirements of Section 172(c)(3) for the 1997 

annual PM2.5 NAAQS on August 28, 2012 (77 FR 51930). The 2007 

comprehensive inventory is being submitted in this Plan to meet the requirements

of Section 172(c)(3) for the 2006 24-hour PM2.5 NAAQS. The 2007 

comprehensive inventory also serves as the attainment year inventory

representing a level of emissions sufficient for the Pennsylvania portion of the 

Philadelphia Area to attain the 1997 PM2.5 NAAQS. For the 2006 PM2.5 NAAQS, 
- 7 -

the 2007, 2008 and 2025 emission inventories were evaluated to show that the 

2007 emission inventory is an appropriate and representative emission inventory 

to use as a surrogate attainment emission inventory for the 2008 emission 

inventory, a year when attainment of the 2006 PM2.5 NAAQS was demonstrated. 

That evaluation is contained in Appendix F.

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

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

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

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

EPA, “Procedures for Processing Requests to Redesignate Areas to Attainment,” 

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

Plan contains an attainment year inventory for 2007 and demonstrates that 

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

describes emission reduction measures that have been previously adopted; it 

neither changes existing measures nor adopts additional measures. The plan 

indicates how Maintenance Plan progress will be tracked and identifies measures 

that would be available to promptly correct any NAAQS violation.

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

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

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

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

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

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

Redesignation submitted concurrently with this Maintenance Plan indicates that 

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

permanent and enforceable control measures. The Request for Redesignation also 

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

requirements under the CAA for the Philadelphia Area that were due before the 

date of the Request for Redesignation.

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

ensure maintenance of the NAAQS:

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

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

Section IV of this Plan);

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

emissions sufficient to attain the NAAQS. This “attainment year 

inventory” was developed for 2007;

 The state may demonstrate maintenance by showing that the future 

emissions of a pollutant or its precursors will not exceed the level of the 
- 8 -

attainment inventory over at least 10 years following redesignation, taking 

economic growth into account. The Pennsylvania Department of 

Environmental Protection (DEP or Department) has developed emission 

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

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

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

implement and enforce all measures necessary to attain and maintain the 

NAAQS, and indicate how Maintenance Plan progress will be tracked 

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

Redesignation); and

 The Commonwealth should identify measures that would be available to 

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

Plan).

This document describes how the Commonwealth will meet those criteria.

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

be maintained for at least 10 years after redesignation of the Pennsylvania portion 

of the Philadelphia Area to attainment of the standards. The Maintenance Plan 

shows that emission levels of PM2.5 and its precursors over the 10 years following 

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

NAAQS, even considering growth in population and vehicle miles traveled. In 

addition, this SIP revisions fulfills the requirement for a comprehensive inventory 

for the 2006 NAAQS for the Pennsylvania portion of the Philadelphia Area under 

40 CFR Section 51.1008 to meet the requirements of Section 172(c)(3) of the 

CAA.

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

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

 The Clean Air Interstate Rule (CAIR);

 Emission limits for large industrial boilers;

 State regulation of cement kilns, large stationary internal combustion 

engines, and smaller sources of NOX;

 State regulations incorporating by reference the federal Prevention of 

Significant Deterioration (PSD) regulations;

 State requirements for Best Available Technology (BAT);

 State regulation of the sulfur content of fuel oil;

 The Pennsylvania and federal new motor vehicle emission control 

programs for passenger and light-duty trucks;

 The Pennsylvania and federal heavy-duty diesel emission control 

programs;
- 9 -

 Federal fuel programs for highway vehicles and nonroad mobile 

equipment; and

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

equipment.

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

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

demonstration of maintenance. However, emission reductions from these 

measures may nonetheless assist the Philadelphia Area in maintaining air quality.

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

The Idling Act was approved by EPA as a SIP revision on August 1, 2011 

(76 FR 45705). 

 NOx and VOC emission reductions from Pennsylvania’s Outdoor Wood-Fired 

Boilers regulation. The Outdoor Wood-Fired Boiler regulation was published 

in the Pennsylvania Bulletin on October 2, 2010 (40 Pa.B. 5571) and 

approved by EPA as a SIP revision on September 20, 2011 (76 FR 58114).

 Pennsylvania’s regulation 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 EPA as a 

SIP revision on September 26, 2012 (77 FR 59090).

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

(79 FR 23414). 

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

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

maintenance of the standards and to evaluate emissions inventories periodically 

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

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

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

Eight years following redesignation, the Commonwealth will submit a revised 

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

D. Public Participation

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

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

Pollution Control Act. 35 P.S. Section 4007.5(b). On May 10, 2014, the 

Department provided notice of a public comment period and the opportunity for a 

hearing on the Maintenance Plan for the Pennsylvania portion of the Philadelphia 

Area for the 1997 and 2006 PM2.5 NAAQS, the 2007 comprehensive inventory 

required by Section 172(c)(3) of the CAA, and the Request to Redesignate the 

Pennsylvania portion of the Philadelphia Area to attainment for the 1997 and 

2006 PM2.5 standards. The Department scheduled the public hearing to occur on 

June 12, 2014, but no one expressed interest in presenting testimony or attending. 
- 10 -

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

closed June 13, 2014. The Department received comments from two 

commentators, which have been addressed in a Comment and Response 

Document.

II. EMISSION INVENTORIES

To demonstrate maintenance of the 1997 annual and 2006 24-hour PM2.5 NAAQS for the 

Pennsylvania portion of the Philadelphia Area, Pennsylvania is showing that the future 

emissions of PM2.5 and its precursors will remain at levels that will provide for 

maintenance of the PM2.5 NAAQS for at least 10 years, taking economic, population and 

travel growth into account. This Maintenance Plan contains an attainment year inventory 

for 2007 and demonstrates that emissions will not be greater than the attainment year in 

2017 and 2025.

6

This Maintenance Plan also contains a 2002 baseline inventory that 

represents the emissions present when the Philadelphia Area did not meet the 1997 and 

2006 PM2.5 NAAQS. On August 28, 2012 (77 FR 51930), EPA approved the base year 

emissions inventory for 2002 as part of the Attainment Plan for the Pennsylvania portion 

of the Philadelphia area for the 1997 PM2.5 NAAQS. The Attainment Plan also included 

the modeled attainment demonstration, motor vehicle budgets, and contingency 

measures. The motor vehicle budgets were subsequently amended and approved as a SIP 

revision on April 3, 2013 (78 FR 19992).

In addition, this SIP revision fulfills the requirement for a comprehensive inventory for 

the 2006 PM2.5 NAAQS for the Philadelphia Area under 40 CFR Section 51.1008 to meet 

the requirements of Section 172(c)(3) of the CAA. As specified by the EPA, the 

pollutants inventoried by Pennsylvania include direct PM2.5, PM10, SO2, NOX, VOC, and 

NH3. Information on the manmade sources of these pollutants was compiled for:

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

Department collects individual emissions-related information. Generally, they 

represent major stationary sources but may be smaller.

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

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

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

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

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

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

adjusted to remove any double counting.

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

trucks, buses and motorcycles.

 

6 Due to rounding, numbers presented throughout this document may not add up precisely to the totals provided.
- 11 -

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

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

construction machinery, lawn and garden equipment, industrial equipment, 

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

aircraft.

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

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

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

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

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

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

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

Please note that all emission inventory information provided is for the Pennsylvania 

portion of the Philadelphia Area.

A. Emissions Inventory Methodology for Baseline Year (2002) and Attainment 

Year (2007) Emissions

As noted above, EPA has already approved the 2002 inventory as a SIP revision

for the 1997 annual NAAQS. 

Stationary Point Sources. The 2002 and 2007 stationary point source 

inventories were based on emissions reported to the Department by 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 Factor Information Retrieval (FIRE) Data 

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

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

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

upon other factors, these emission estimates supersede those calculated using 

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

emission methodology, and Appendix A-2 is the data set for facility 2002 annual 

emissions. Appendix A-3 includes the data set for facility 2007 annual emissions,

as well as projected facility emissions for 2017 and 2025. Appendix A-4 is a 

table documenting the banked emissions reduction credits for the Philadelphia 

Area in the 2017 and 2025 emission projections.

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

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

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

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

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

emission factors for EGUs developed for MARAMA in 2008 to calculate 

condensable PM emissions where that data was missing. The 2002 inventory did 
- 12 -

not include condensable PM for many facilities and was not augmented. 

Appendix C-4 contains the technical memorandum describing how the emission 

factors were developed. The general process is to use the emission factors and 

heat input to calculate the condensable PM (PM-CON) emissions, and then to 

perform the gap filling for compounds missing from the facility-reported 

emissions.

Stationary Area Sources. Stationary area source emissions are generally 

estimated by multiplying an emission factor by some known indicator or 

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

estimates emissions from stationary area sources using emission factors and SCC 

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

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

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

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

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

employee numbers. County employee numbers are based upon North American 

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

specific to the industry covered.

Pennsylvania’s 2002 stationary area source emissions inventory was developed in 

accordance with EPA guidance7and was submitted to the National Emissions 

Inventory (NEI) to satisfy the requirements of the Consolidated Emissions 

Reporting Rule.

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

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

EPA data was used. These categories included ammonia emissions from 

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

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

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

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

source category; and 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 missing 

categories in the 2007 inventory, no growth adjustment was made to the 

emissions with the assumption that activity in 2008 and 2007 was similar.

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

PM “transport factors” to fugitive dust sources.

 

7 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.
- 13 -

More specific information on the procedure used for each industry type is 

contained in Pennsylvania 2002 Area Source Criteria Air Pollutant Emission 

Estimation Methods, (E.H. Pechan & Associates, Inc., February 2004), which is 

contained in Appendix B-1. Appendix B-2 contains the methodology for the 

2007 Pennsylvania area source inventory. Additional methodology information is 

available in the technical support document for the 2007 regional inventory which 

is contained in Appendix C-1. Appendix B-3 is a table containing stationary area 

source emissions data for 2002 for the Pennsylvania portion of the Philadelphia 

Area. Appendix B-4 contains the stationary area source emissions data for 2007, 

2017 and 2025 for the Pennsylvania portion of the Philadelphia Area.

Highway Vehicle Sources. EPA’s MOVES2010 (Motor Vehicle Emission 

Simulator) 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 model. Therefore, the 

Department employed MOVES2010 to estimate the onroad emissions inventory 

for 2002, 2007, 2017 and 2025.

Additional information on highway emission methodology is available in 

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

produce the mobile emissions inventory. Appendix D-2 provides the 2002 base 

year, 2007 attainment year and 2017 and 2025 projections of mobile (highway) 

vehicle miles travelled (VMT) and annual PM2.5 direct and precursor emissions. 

Appendix D-3 describes the model inputs used to generate emission factors for a 

specific area. Some examples of the inputs described in Appendix D-3 are the

type and frequency of vehicle emission testing, the fuel types required in the area, 

temperatures by month, and fleet age. The summary in Appendix D-3 indicates 

when default information contained in the model is used rather than specific area 

information. 

Nonroad Sources.

The 2002 Emissions Inventory. The 2002 emissions for the majority of nonroad 

emission source categories and pollutants were estimated using the EPA 

NONROAD 2005 model. The NONROAD model estimates emissions for diesel, 

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

equipment types and includes growth factors. The National Mobile Inventory 

Model (NMIM) was used to estimate emissions of ammonia from sources 

contained in the NONROAD model. The NONROAD model does not estimate 

emissions from aircraft, locomotives or commercial marine vessels. Emissions 

from aircraft, locomotives, and commercial marine vessels were estimated using 

EPA guidance and best available information. If specific local operational data 

was available, that data was used to estimate emissions. State and national data 

was used if local data was unavailable. 
- 14 -

Appendix E-1 is the technical document providing the methodology and 

description of the procedures used to generate 2002 county-level pollutant 

emission estimates for nonroad mobile engines included in the EPA’s 

NONROAD2005 model, locomotive engines, and aircraft operations. The table 

of 2002 nonroad emissions data sorted by source category is available as 

Appendix E-2.

Aircraft Emissions in 2002. The Department worked with the staff of the 

Philadelphia Division of Aviation to obtain accurate operational information for 

emission sources at Philadelphia International Airport (PHL). The Division of 

Aviation operates PHL as well as the Northeast Philadelphia Airport. The 2002 

PHL Inventory includes aircraft and aircraft-related equipment from the EPAapproved model, Emissions and Dispersion Modeling System (EDMS), and also 

additional on-airport highway, stationary and area source emissions. 

For 2002 aircraft emissions from the Northeast Philadelphia Airport, the 

Department estimated emissions using operations data obtained from the Federal 

Aviation Administration’s (FAA) Terminal Area forecast and modeling the 

emissions directly with the EDMS. 

Railroad Emissions. For 2002 locomotive emissions, the Department projected 

emissions from a 1999 survey when the Department obtained fuel use statistics 

from Class II and III railroads. For Class I railroads, which produce most of the 

emissions in the Commonwealth, the Department conducted a 2002 inventory of 

all railroads that operate in Pennsylvania because the 1999 fuel use data for 

Class I railroads was skewed by gridlock caused by the acquisition of Conrail by 

CSX and Norfolk Southern. Both Conrail and Norfolk Southern suffered major 

gridlock in Pennsylvania and beyond during 1999. Consequently, fuel 

consumption and air emissions for these two railroads were greatly reduced in 

1999. The Department requested and received 2002 fuel usage from these 

railroad companies and developed a 2002 emissions inventory for them. 

Emissions were generated using EPA emission factors.

Commercial Marine Vessels. The Philadelphia Area contains the Port of 

Philadelphia. The port is home to several refineries where large oil tankers often 

call and shipping terminals. All air emissions from commercial marine vessel 

(CMV) traffic in the Port of Philadelphia were estimated using the methodology 

outlined in the EPA’s publication Commercial Marine Activity for Deep Sea Ports 

in the United States, Final Report. Additional understanding of the port’s 

operations was obtained from conversations with tugboat operators in the port and 

ship traffic data provided by the Philadelphia Regional Port Authority. Emission 

estimates were based on port activity data provided by the United States Army 

Corps of Engineers Waterborne Commerce Statistics Center and best available 

EPA nonroad emissions factors. Fuel use and emissions factors for CMV were 

based on the most current data available. 
- 15 -

The 2007 Emissions Inventory. The 2007 inventory for the majority of nonroad 

categories was generated using NMIM2008 of which the NONROAD model is a 

part. The NONROAD model estimates emissions for diesel, gasoline, liquefied 

petroleum gas, and compressed natural gas-fueled nonroad equipment types and 

includes growth factors. For nonroad vehicle the NMIM does not estimate 

emissions from aircraft, locomotives or commercial marine vessels. Emissions 

from aircraft, locomotives, and commercial marine vessels were estimated using 

EPA guidance and best available information. If specific local operational data 

was available, that data was used to estimate emissions. State and national data 

was used if local data was unavailable. NMIM includes emissions from airport 

ground support equipment. However, emissions for airport ground support 

equipment calculated by NMIM were removed because EPA considers the 

emissions calculated by the EDMS to be better estimates of the emissions from 

airport ground support equipment. Growth estimates for source categories 

modeled by NMIM are included in the model. The EPA default values were used 

for most categories.

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

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

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

Railroad Emissions. The Department used the emissions inventory developed by 

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

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

inventory with the assistance of the railroad associations and submitted the 

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

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

Department made slight modifications in cooperation with ERTAC that resulted 

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

which included locomotive yard operations. The Department had developed its 

own inventory using information received from a statewide survey of railroad 

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

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

smaller railroads mentioned above.

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

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

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

locomotive power settings were not considered. ERTAC based their yard 

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

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

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

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

switcher’s use.
- 16 -

Commercial Marine Vessels. The size of propulsion and auxiliary power engines 

as well as typical fuel used was considered in estimating emissions. Growth and 

control factors were developed using methodology and data that EPA used in 

developing regulations for these vessels. The emission estimation methodology 

commercial marine vessels is described in more detail in Appendix C-2. 

B. Baseline Year (2002) Annual Emissions (Tons per Year)

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

area. The Department developed an emission inventory for 2002 in accordance 

with EPA guidance8. The 2002 emissions inventory represents the emissions 

present when the Philadelphia Area did not meet the 1997 and 2006 PM2.5 

NAAQS. On August 28, 2012 (77 FR 51930), EPA approved the base year 

emissions inventory for 2002 as part of the Attainment Plan for the 1997 PM2.5 

NAAQS for the Pennsylvania portion of the Philadelphia Area. The Attainment 

Plan also included the modeled attainment demonstration, motor vehicle budgets, 

and contingency measures. The motor vehicle budgets were subsequently 

amended and approved as a SIP revision on April 3, 2013 (78 FR 19992). The 

2002 baseline year inventory includes the pollutants PM10, PM2.5, SO2, NOX, 

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

sources, stationary area sources, highway vehicle sources and nonroad sources. 

The 2002 inventory is not directly comparable to the 2007, 2017 and 2025 

inventories because of changes in inventory methodology and the adjustment 

made to account for condensable PM emissions from EGUs in the 2007, 2017 and 

2025 emission inventories. Table II-1 (relating to 2002 Annual Emissions (Tons 

per Year)) summarizes the emissions for 2002.

Table II-1: 2002 Emissions (Tons per Year)

Philadelphia 2002 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 2,139 3,430 23,745 22,124 8,183 256

Area Sources 10,020 55,224 13,153 13,029 59,227 4,821

Highway Vehicle Sources 2,905 3,497 1,848 90,879 32,150 1,451

Non-Road Sources 1,535 1,611 1,640 21,619 21,589 14

Totals 16,598 63,763 40,387 147,651 121,149 6,542

C. Attainment Year (2007) Annual Emissions (Tons per Year)

An emissions inventory of 2007 emissions of PM10, PM2.5, SO2, NOX, VOC, and 

NH3 for the Pennsylvania portion of the Philadelphia Area identifies PM and PM 

precursor emissions during the period when the Philadelphia Area was attaining

the 1997 PM2.5 NAAQS. It also represents a surrogate attainment inventory for 

the 2006 NAAQS. Table II-2 (relating to 2007 Annual Emissions (Tons per 

 

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.
- 17 -

Year)) summarizes the emissions for 2007. While, as noted above, the 2002 

emissions inventory is not directly comparable to the 2007, 2017 and 2025 

inventories due to changes in inventory methodology and the adjustment made to 

account for condensable PM emissions from EGUs in the 2007, 2017 and 2025 

emission inventories, PM2.5, SO2, NOX, VOC, and NH3 emissions decreased by 

15 percent, 5 percent, 16 percent, 16 percent and 19 percent, respectively, from 

2002 to 2007. 

The 2002 inventory was based on emissions reported to the Department by the 

owners and operators of the facilities. The 2002 reports did not include 

condensable PM for many facilities. The 2007 EGU inventory was augmented 

utilizing condensable PM emission factors for EGUs developed for MARAMA in 

2008 to calculate condensable PM emissions where that data was missing. The 

projected 2017 and 2025 PM2.5 emissions for EGUs also include condensable PM 

emissions because they were projected from the 2007 inventory.

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

Philadelphia 2007 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 2,444 3,442 19,633 20,744 6,281 743

Area Sources 7,722 23,546 15,005 12,925 47,568 3,293

Highway Vehicle Sources 2,386 2,985 508 69,327 29,293 1,270

Non-Road Sources 1,562 1,663 3,375 20,393 18,751 23

Totals 14,114 31,635 38,520 123,390 101,894 5,329

D. Growth Projection Methodologies for 2017 and 2025

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

estimates of emissions changes between 2007 and interim year 2017 and 

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

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

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

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

implementation schedules used in the emission projection calculations for each 

source category. MARAMA coordinated development of the projection

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

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

Significant infrastructure development to extract natural gas from the Marcellus 

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

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

and compressor stations. The Philadelphia Area has not experienced any 

Marcellus Shale development and is not expected to experience any of this 

development in the future.
- 18 -

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

growth factors based on AEO2011 Table 96 - Electricity Generation by 

Electricity Market Module Region and Fuel Source. The appropriate AEO2011 

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

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

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

calculate a “growth and control” emission value for 2025. A more detailed 

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

the technical support document for the development of the 2025 emissions 

inventory in Appendix C-3.

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

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

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

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

sources.

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

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

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

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

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

sources, methods, and results for emission forecasts.

NonEGU point source and stationary area source growth factors were developed 

using:

 Annual Energy Outlook (AEO) fuel consumption forecasts;

 State-level employment projections by NAICS code; and

 Other state-specific emission projection data. 

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

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

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

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

were available during inventory development. After AEO2011 was published, 

MARAMA compared the AEO2010 and AEO2011 projections. Minor 

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

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

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

used.

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

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

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

years than for the base year, even before the application of control assumptions. 
- 19 -

Because of the possibility that facilities could apply for and sell Emission 

Reduction Credits (ERCs) at the level of the base year inventory, Pennsylvania 

opted for the conservative approach of assuming no growth (growth factor=1) for 

non-EGU point source categories with negative AEO or employment growth 

factors.

As discussed previously, because the 2002 stationary point source inventory was 

based on emissions reported to the Department by facilities and did not include 

condensable PM for many facilities, the emissions inventory shows an apparent 

increase of direct PM2.5 emissions from stationary point sources in 2007, 2017 

and 2025 compared with 2002.

Emission Reduction Credits (ERCs). ERCs can be created by a facility owner 

or operator if the emission reductions are surplus, permanent, quantifiable and 

federally enforceable. These ERCs can be either bought or sold to meet offset 

requirements for the construction of major new or modified stationary sources

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

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

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

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

or curtailment if they are not in use in a Plan Approval. To account for this 

potential increase, ERCs banked in Pennsylvania’s Emissions Reductions Credit 

Registry System were added to the projected inventories. 

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

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

State specific information was used where available and appropriate. Traffic 

forecasts were compiled using information from the Pennsylvania Department 

of Transportation’s (PennDOT) Traffic Information System and 

socioeconomic data. The Pennsylvania methodology for estimating highway 

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

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

Guidance on the Use of MOVES2010 for Emissions Inventory Preparation in 

State Implementation Plans and Transportation Conformity. Appendices D-1 

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

highway emissions inventory methodology, data files of emissions estimates

and MOVES input parameters.

As shown in Table II-3 (relating to VMT (Miles) and Vehicle Emissions (Tons 

per Year)), VMT for the future analysis year increases 36 percent from 

4.26 billion VMT in 2007 to 5.78 billion VMT in 2025 within the Pennsylvania

portion of the Philadelphia Area. Despite the growth in VMT, emissions of the 

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

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

transportation conformity safety margin, which will be discussed later in this 
- 20 -

document. See, Section III-B relating to motor vehicle emission budgets for 

transportation conformity.

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

Year VMT PM2.5 PM10 SO2 NOx VOC NH3

2002 25,092,544,276 2,905 3,497 1,848 90,879 32,150 1,451

2007 26,288,139,003 2,386 2,985 508 69,327 29,293 1,270

2017 31,316,315,077 1,460 2,534 248 34,475 16,349 903

2025 37,043,541,066 1,145 2,385 259 23,056 11,222 908

Nonroad Sources.

Nonroad Sources in NMIM. Projected emissions for the majority of nonroad 

emission source categories and pollutants were estimated using the NMIM, which 

contains default assumptions for projected years. The NMIM estimates emissions 

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

nonroad equipment types and includes growth factors. Control measures due to 

finalized emission standards for nonroad vehicles and engines are also accounted 

for in NMIM. Baseline emissions are multiplied by growth and control factors to 

obtain projected emissions.

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

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

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

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

This information is available for approximately 3300 individual airports. Actual 

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

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

used in the future were also taken into account.

In addition to those general projections, the Department has included in the 2017 

and 2025 inventories specific emissions expected to result from construction of

the Capacity Enhancement Program (CEP) at the Philadelphia International 

Airport (PHL) in future years. The CEP will be an effort to reduce ground delays 

at the airport and throughout the nationwide air traffic system. 

To make adjustments in the 2017 and 2025 inventories for the CEP, aircraft

emissions from PHL, which is located in both Delaware and Philadelphia 

counties, were removed in the final Maintenance Plan from the summary of 

projected nonroad emissions in Tables II-4 and II-5 for 2017 and 2025. (The 

nonroad inventory in Delaware and Philadelphia counties still contains the 

airport-related emissions produced by auxiliary power units and ground support 

equipment.) An additional category, PHL CEP, is provided in the emission 

summaries for relevant pollutants; these emissions are those contained in the Final 

Environmental Impact Statement for the proposed CEP, released by the 
- 21 -

U.S. Federal Aviation Administration (FAA) on August 27, 2010.9 Because the 

final EIS projected emissions to 2020 rather than 2017, the Department used the 

2020 emissions, which is the conservative approach. The final EIS did contain 

emission estimates for 2025.

The Record of Decision on the EIS for the CEP was finalized by the FAA in 

December 2010, approving Alternative A of the EIS. The air quality analysis for 

the CEP used Emissions and Dispersion Modeling System Version 5.0.2, 

supplemented with emissions from other sources where necessary, such as AP-42, 

Compilation of Air Pollutant Emission Factors. 

No specific emission-reducing initiatives that may be undertaken at PHL have 

been included in the emission estimates for 2017 or 2025 in this SIP revision; no 

specific initiatives are being relied upon for maintenance. Therefore, emission 

reductions resulting from low emission initiatives, such as those listed below, that 

are implemented at the Airport will be considered eligible for Airport Emission 

Reduction Credits, as defined by the FAA's Voluntary Airport Low Emissions 

Program.

10 These low emission initiatives include but are not limited to:

 The use of electric ground support equipment by the City or by tenant 

airlines.

 The installation and use of preconditioned air and 400 Hz converter units 

on jetbridges or for use at remote aircraft parking positions, cargo aircraft 

loading aprons, or maintenance facilities.

 The use of electric or other alternative fuels for mobile equipment.

 Upgrades to central utility plants or other heating, air conditioning, and 

ventilation systems to operate more efficiently than required by law, 

including the use of geothermal wells.

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

AEO2010 growth projections published in May 2010. There are separate 

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

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

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

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

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

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

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

Commercial Marine Vessels. Table A-7 of the AEO2010 for international 

shipping was used to calculate the growth factors for commercial marine vessel 

diesel and residual oil port emissions and CMV diesel and residual oil underway 

 

9 Philadelphia International Airport Capacity Enhancement Program, Final Environmental Impact Statement,

August 2010, available at www.phl-cep-eis.com. 

10 Guidance on Airport Emission Reduction Credits for Early Measures Through Voluntary Airport Low Emission 

Programs, EPA, September 2004
- 22 -

emissions. Reductions in emissions due to EPA rules for diesel fuel and engines 

were then estimated.

Additional information about nonroad emission projection methodologies can also 

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

development of the 2017 and 2025 inventories, respectively.

The table of nonroad emissions data sorted by source category is available as 

Appendix E-3.

E. Interim Year (2017) Emissions

Table II-4 (relating to Projected 2017 Emissions (Tons per Year)) summarizes the 

emissions expected in 2017 in the Pennsylvania portion of the Philadelphia Area. 

These emissions take activity and emissions growth and/or controls from 2007 

into account. Appendix C, relating to the regional emissions inventory and 

projection methodology, contains the technical support documents that describe 

the methodologies used to project the 2007 emissions to 2017.

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

Philadelphia 2017 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 1,788 2,458 5,870 11,366 6,438 814

Area Sources 7,383 23,830 12,844 12,461 45,239 3,375

Highway Vehicle Sources* 1,679 2,534 248 37,922 16,349 903

Non-Road Sources 1,019 1,097 305 10,332 11,224 26

PHL CEP 83 83 355 3,337 828 0

Emission Reduction Credits 726 980 9,839 7,150 463 0

Totals 12,678 30,981 29,460 82,567 80,540 5,117

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

set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. 

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

F. Maintenance Year (2025) Emissions

Table II-5 (relating to Projected 2025 Emissions (Tons per Year)) summarizes the 

emissions expected in 2025 in the Pennsylvania portion of the Philadelphia Area. 

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.
- 23 -

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

Philadelphia 2025 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 1,808 2,441 5,858 11,316 6,508 789

Area Sources 7,047 24,138 9,186 12,675 44,530 3,436

Highway Vehicle Sources* 1,316 2,385 259 25,361 11,222 908

Non-Road Sources 837 911 123 7,990 11,058 29

PHL CEP 102 102 435 3,910 1,027 0

Emission Reduction Credits 726 980 9,839 7,150 463 0

Totals 11,837 30,957 25,701 68,402 74,808 5,162

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

set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. 

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

G. Maintenance Plan Emissions Test

To demonstrate maintenance of the 1997 annual and 2006 24-hour PM2.5 NAAQS 

for this area, Pennsylvania must show that the future emissions of PM2.5 and its 

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

NAAQS for at least 10 years after redesignation, taking economic, population and 

travel growth into account.

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

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

for the 1997 PM2.5 NAAQS. However, Pennsylvania recognizes the Court 

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

706 F.3d 428 (D.C. Cir. 2013) and EPA’s subsequent withdrawal of the 

Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS. The court noted 

that PM2.5 precursors, including ammonia and VOCs, are presumptively regulated 

in PM2.5 nonattainment areas under Subpart 4, pointing specifically to 

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

PM10 [the court stated that PM10 includes PM2.5 throughout Subpart 4] (706 F.3d 

at 436, n. 7, and at 437, n. 10). According to CAA Section 189(e), control 

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

stationary sources of PM10 precursors, except where the Administrator determines 

that major stationary sources do not contribute significantly to PM10 levels that 

exceed the standard in the area; section 189(e) also requires EPA to issue 

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

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

For the Pennsylvania portion of the Philadelphia area, this Maintenance Plan 

contains an attainment year inventory for 2007 and demonstrates that emissions of 

PM2.5, SO2, NOX, VOC and NH3, including emissions in the transportation 

conformity safety margin for PM2.5 and NOX, will not be greater in 2017 and 

2025 than in the attainment year, as shown in Table II-6.
- 24 -

For the Pennsylvania portion of the Philadelphia Area, emissions of SO2 and NOx 

are projected to decrease from 2007 to 2025 by approximately 12,820 tons 

(33 percent) and 54,988 tons (45 percent). Emissions of PM2.5, VOC, and NH3

also decrease from 2007 to 2025 by approximately 2,278 tons (16 percent),

27,085 tons (27 percent), and 167 tons (3 percent), respectively. 

Table II-6: Pennsylvania Maintenance Emissions Test

Philadelphia PM2.5 PM10 SO2 NOx VOC NH3

2007 14,114 31,635 38,520 123,390 101,894 5,329

2017* 12,678 30,981 29,460 82,567 80,540 5,117

2025* 11,837 30,957 25,701 68,402 74,808 5,162

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

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

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

The Plan also demonstrates that for the entire Philadelphia Area, including 

portions of Delaware and New Jersey, emissions of PM2.5, SO2, and NOX will not 

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

Emissions information for New Jersey was obtained from the State 

Implementation Plan Revision for the Attainment and Maintenance of the PM2.5 

NAAQS Final Redesignation Request and Maintenance Plan for the Annual 

15 μg/m3and Daily 35 μg/m3PM2.5 National Ambient Air Quality Standards, 

December 2012, Tables 5, 6, and 7.11 Emissions information for Delaware was 

obtained from the Final Redesignation and Maintenance Plans for the 1997 

Annual and 2006 24-hr PM2.5 NAAQS, November 27, 2012, Table 8-1.12

Table II-7: PA, NJ, DE Maintenance Emissions Test (PM2.5, SO2 and NOx) 

PM2.5 SO2 NOx

2007 2017 2025 2007 2017 2025 2007 2017 2025

PA portion 14,114 12,678 11,837 38,520 29,460 25,701 123,390 82,567 68,402

NJ portion 5,159 4,549 4,102 4,965 1,579 1,880 41,718 26,057 17,870

DE portion 3,193 2,844 2,893 15,228 6,995 6,958 23,084 14,475 13,797

Totals 22,466 20,071 18,832 58,713 38,034 34,539 188,192 123,099 100,069

Emissions information was not available for all sectors for all states for 

comparable years for VOC and NH3. Therefore, the Department has used 

information from EPA’s Regulatory Impact Analysis (RIA) for the 2012 PM2.5

NAAQS to show that these emissions also continue to decrease for the interstate 

Philadelphia Area, as shown in Table II-8. While the RIA emissions inventories 

are only projected out to 2020, there is no reason to believe that this downward 

trend would not continue through 2025. Given that the Philadelphia Area is 

already attaining the 1997 annual and 2006 24-hour PM2.5 NAAQS even with the 

 

11 www.regulations.gov, docket #EPA-R02-2012-0889

12 www.regulations.gov, docket #EPA-R03-2014-0022
- 25 -

current level of emissions from sources in the area, the downward trend of 

emissions inventories would be consistent with continued attainment.

Table II-8: PA, NJ, DE Maintenance Emissions Test (VOC and NH3) 

VOC NH3

2007 2020 2007 2020

PA portion 95,255* 75,861 5,229* 4,903

NJ portion 36,108 27,510 1,677 1,526

DE portion 14,326 9,242 984 850

Totals 145,689 112,613 7,890 7,279

* 2007 emissions may be different in this table than other tables in the 

document due to the different source of the data.

III. PERMANENT AND ENFORCEABLE CONTROL MEASURES

A. Permanent and Enforceable Control Measures

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

formation, the EPA recognizes that effective control measures for PM2.5 will vary 

among nonattainment areas. This was reflected in EPA’s “Implementation 

Guidance for the 2006 24-Hour Fine Particle National Ambient Air Quality 

Standard,” Office of Air Quality Planning and Standards, EPA, March 2, 2012 

(“Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS”). In the 

Implementation Guidance for the 2006 PM2.5 NAAQS, EPA adopted the 

framework and policy approach the agency espoused in its implementation rule 

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

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

the 1997 PM2.5 NAAQS”). 

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

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

possible controls. In that earlier rule, the EPA required states to evaluate control 

measures for SO2 and primary PM2.5 in all locations. The EPA required states to 

evaluate control measures for NOX unless a technical demonstration is made to 

show that NOX emissions from sources in the state do not significantly contribute 

to PM2.5 concentrations in the nonattainment area. The EPA required states to 

evaluate measures for VOC and NH3 only if a technical demonstration is made to 

show VOC or NH3 emissions significantly contribute to PM2.5 in the 

nonattainment area. 

The EPA reaffirmed the appropriateness of these presumptions in its 

Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS.13 Meanwhile, 

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

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

 

13 See footnote 2, above.
- 26 -

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

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

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

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

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

Shortly thereafter, EPA withdrew its Implementation Guidance for the 2006 

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

memorandum (see second page of memorandum),

14 EPA withdrew the guidance 

in response to the Court’s decision in Natural Resources Defense Council v. EPA, 

No. 08-1250. 

This Maintenance Plan demonstrates maintenance of the standards consistent with 

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

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

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

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

implementation of reasonably available and best available control measures 

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

1997 and 2006 24-Hour PM2.5 NAAQS, those considerations are not relevant for 

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

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

Subpart 4, pointing specifically to section 189(e), which applies to control of 

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

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

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

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

where the Administrator determines that major stationary sources do not 

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

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

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

NH3 for the maintenance demonstration.

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

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

standards.

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

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

reductions. The emission change estimates account for any anticipated growth in 

the activity of sources regulated by the strategy and include emissions in the 

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

emissions in 2025 in the Pennsylvania portion of the Philadelphia 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 

 

14 See footnote 3, above.
- 27 -

measures for all pollutants. Each control measure is explained in greater detail in 

the following sections. Based on 2010-2012 monitoring data, the Philadelphia 

Area currently has an annual design value of 13.4 μg/m3and a 24-hour design 

value of 31 μg/m3, which is significantly lower than the 1997 annual PM2.5

NAAQS of 15 μg/m3and the 2006 24-hour NAAQS of 35 μg/m.

3

 

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

from Control Measures

2007 to 2025 Difference PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 90 -21 -3,936 -2,279 690 46

Area Sources -674 592 -5,818 -250 -3,039 143

Highway Vehicle Sources* -1,070 -599 -249 -43,966 -18,071 -363

Nonroad Sources -624 -650 -2,817 -8,493 -6,666 6

TOTAL -2,278 -678 -12,820 -54,988 -27,085 -167

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

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

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

safety margin.

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

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

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

include provisions, as applicable, for:

 emissions reports and recordkeeping for stationary sources;

 periodic testing and inspection of stationary sources;

 enforcement and complaint investigation of visible emission limitations;

 enforceable test methods for emission limits; and

 continuous emission monitoring for stationary sources.

Subpart K also requires monitoring of the implementation of transportation 

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

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

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

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

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

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

and operating permitting programs as part of the State Implementation Plan; the 

Title V Operating Permits Program was approved under 40 CFR Part 70 on 

July 30, 1996 (61 FR 39597).

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

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

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

requirements for reporting and recordkeeping for plan approval applications. 
- 28 -

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. The Department also monitors the status of 

compliance by conducting complaint investigations. The Department does visible 

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

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

inspections of air contamination sources in accordance with the Compliance 

Monitoring Schedule which is approved by EPA.

1. Stationary Point Sources

Background for Pennsylvania’s Stationary Source Permitting 

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

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

assembly, installation of new sources, modification of any existing 

stationary air contamination sources, or the installation of air pollution 

control equipment or devices. Following the construction of the new 

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

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

depend on the quantity of regulated pollutants emitted from the air 

contamination sources. DEP will issue a “State-only Operating Permit” 

for minor air contamination stationary sources that are below the 

applicability thresholds for Title V facilities. A “Title V Operating 

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

contaminants exceeding the Title V thresholds. The Title V Permit, which 

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

for the facility in a single federally enforceable operating permit. 

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

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

associated definitions in 25 Pa. Code Chapter 121.1, are a suite of 

programs regulating air contamination sources to improve and maintain air 

quality. Chapter 127 establishes requirements for the submission, review 

and approval of pre-construction and operating permits for both major and 

non-major air contamination sources. The provisions of Chapter 127 have 

been codified in the SIP at 40 CFR § 52.2020(c)(1) at various times since 

May 31, 1972 and most recently on October 5, 2012, and are therefore all 

federally enforceable. Several aspects of Chapter 127 are highlighted 

below as being particularly important for the maintenance of the PM2.5

standard.

Title V Permitting Program. The Title V Permitting Program, 

adopted pursuant to the Clean Air Act Amendments of 1990, is 
- 29 -

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

Section 121.1. The purpose of the Title V program is to detail a 

facility’s air quality requirements in a single permit document so 

that industry, the regulatory agency, and the public know exactly 

what regulations and requirements apply and how the facility’s

owner or operator will monitor and demonstrate compliance with 

all applicable requirements. The Title V permit includes all 

sources at a site including all air pollution control devices as well 

as activities that were determined to be insignificant sources of 

emissions. Each source is described in detail within a section of 

the Title V permit. The requirements include general conditions 

applicable to all Title V facilities, emission restrictions, detailed 

monitoring, recordkeeping, and reporting requirements to assure 

compliance with the facility’s applicable federal and state 

requirements. The Title V Operating Permits Program 

requirements are codified in 25 Pa. Code Chapter 127, 

Subchapters F and G. The program was fully approved by EPA on 

July 30, 1996 (61 FR 39597).

Nonattainment New Source Review and Prevention of 

Significant Deterioration. Major facilities proposed in 

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

requirements in nonattainment areas and Prevention of Significant 

Deterioration (PSD) requirements in areas of the Commonwealth 

designated attainment for National Ambient Air Quality Standards 

including carbon monoxide, particulate matter (PM), lead, nitrogen 

dioxide (NO2), ozone and sulfur dioxide (SO2). Generally, NSR 

permit requirements are applicable to a facility located in a 

nonattainment area for a particular pollutant with a potential to 

emit 50 tons or more per year (tpy) of volatile organic compounds 

or 100 tpy or more of NOx, SO2, PM or carbon monoxide. It 

should be noted that the entire Commonwealth, included in the 

Ozone Transport Region by operation of law, is treated as a 

“moderate” ozone nonattainment area, irrespective of the area’s 

attainment status. Because NOx and VOC are precursors of PM2.5, 

NOx and VOC emission reductions required statewide under the 

nonattainment NSR program for ozone also allow Pennsylvania to 

make substantial progress in attaining and maintaining the PM2.5

NAAQS. Any major stationary source or major modification 

subject to the NSR requirements must receive a plan approval. To 

receive approval from the Department, a person must show that the 

proposed source will, among other things, offset its potential to 

emit air contaminants including NOx, PM and VOCs by securing 

emission reductions credits at the specified offset ratio, will 

employ the “lowest achievable emission rate” (LAER) for each 

regulated pollutant and conduct an alternative analysis. The 
- 30 -

nonattainment NSR requirements are codified in 25 Pa. 

Chapter 127, Subchapter E and approved as a SIP revision on 

December 9, 1997 (62 FR 64722).

The PSD program is a pre-construction review and permitting 

program applicable to new or modified major stationary sources 

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

requirements are applicable to major sources in areas attaining the 

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

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

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

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

Subchapter D, 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 a facility located in an attainment area 

for a standard with the potential to emit 100 tpy or 250 tpy of the 

six criteria pollutants including carbon monoxide, lead, NO2, 

ozone, PM and SO2, depending on the source category. Any major 

stationary source or major modification subject to the PSD 

requirements must conduct an analysis to establish the best 

available control technology (BACT). In addition, the owner or 

operator of a facility needs to conduct an ambient air quality 

analysis, analyze the impacts to soils, vegetation and visibility and 

make sure that the project will not adversely impact mandatory 

federal Class I areas including national parks greater than 

6,000 acres and national wilderness areas and national memorial 

parks greater than 5,000 acres. 

Best Available Technology Program. The Department’s Best 

Available Technology (BAT) Program ensures that new stationary 

sources will prevent, reduce or control emissions of air

contaminants to the maximum degree possible. The Department 

determines BAT requirements on a case-by-case basis for both 

major and minor stationary sources taking into account energy, 

environmental benefits and costs. Pursuant to 25 Pa. Code

§ 127.1, the emission of air pollutants from new sources in 

Pennsylvania must be controlled to the maximum extent, 

consistent with the best available technology 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), an application for 

a plan approval must show that the emissions from a new source 

will be the minimum attainable through the use of the best 

available technology. Pennsylvania regulations define “best 

available technology” in 25 Pa. Code § 121.1 as, “Equipment, 

devices, methods or techniques as determined by the Department 

which will prevent, reduce or control emissions of air contaminants 
- 31 -

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 EPA on 

July 30, 1996, and codified in the SIP at 40 CFR § 52.2020(c)(1).

NOx and SO2 Control Programs. In 1998, EPA promulgated the NOX

SIP Call as the EPA’s principal effort to reduce interstate transport of 

pollution (63 FR 57356; October 27, 1998). In response to the federal 

NOX SIP call rule, Pennsylvania adopted the NOX Budget Trading 

Program regulations for EGUs and large industrial boilers, with emission 

reductions to commence May 1, 2003. The regulations were approved by 

EPA as a revision to the Commonwealth’s SIP on August 21, 2001 

(66 FR 43795). Additionally, in response to the NOX SIP Call, 

Pennsylvania adopted additional NOX control regulations covering cement 

plants and internal combustion engines, with emission reductions to 

commence May 1, 2005. These regulations were approved by EPA as a 

SIP revision on September 29, 2006 (71 FR 57428).

Clean Air Interstate Rule (CAIR). In 2005, EPA adopted CAIR 

(70 FR 25162; May 12, 2005, as amended) to address interstate 

transport of NOX and SO2. CAIR is now being implemented in 

Pennsylvania through the Department’s CAIR regulation, codified 

in 25 Pa. Code Chapter 145, Subchapter D, with related 

amendments in Chapters 121, 129 and 145. EPA approved 

Pennsylvania’s CAIR SIP revision on December 10, 2009, codified 

at 40 CFR § 52.2020(c)(1) (74 FR 65446). In the CAIR SIP 

revision, Pennsylvania terminated the NOX Budget Trading 

Program and transitioned to the federal CAIR for large electric 

generating units (EGU).

The market-based CAIR is designed to reduce EGU emissions of 

NOX and SO2 below 2002 levels throughout the eastern United 

States. Pennsylvania and the other CAIR states were required to 

adopt a regulation implementing the requirements of the CAIR or 

an equivalent program. The large EGUs in Pennsylvania were 

initially regulated under CAIR FIPs promulgated by EPA, but have 

been regulated under the SIP since EPA approved Pennsylvania’s 

CAIR SIP revision. Under the SIP revision, Pennsylvania 

participates in the EPA-administered cap-and-trade programs for 

NOX annual, NOX ozone season, and SO2 annual emissions.

EPA’s CAIR was remanded to 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, 

EPA replaced CAIR with the Cross-State Air Pollution Rule 
- 32 -

(Transport Rule), but in a separate legal challenge the court 

vacated the Transport Rule. In that ruling, the court ordered EPA 

to continue administering CAIR pending the promulgation of a 

valid replacement (See, EME Homer City Generation L.P. v. EPA, 

696 F.3d 7 (D.C. Cir. 2012).) On April 29, 2014, the Supreme 

Court of the United States reversed the Court of Appeals’ decision 

that had vacated the Transport Rule. The Supreme Court 

remanded the case to the Court of Appeals for further proceedings. 

At the time of submittal of this SIP revision, the Transport Rule is 

under a stay previously imposed by the Court of Appeals and

CAIR continues to be implemented.

NOX Budget Trading Program limits on non-EGUs. The CAIR 

SIP revision also established emission limits for the non-EGUs and 

other units that were subject to the Commonwealth’s NOX Budget 

Trading Program but are not subject to the CAIR NOX Ozone 

Season Trading Program. These units must continue monitoring 

NOX emissions and must meet an emissions cap. Each unit has an 

allowable emission rate, calculated by January 31 of each year, 

based on the previous ozone season’s heat input. If the combined 

NOX ozone season emissions from all of these units exceed the 

statewide ozone season emission cap of 3,438 tons, each unit that 

exceeds its individual allowable emissions limit for that ozone 

season must surrender to the Department one CAIR NOX ozone 

season allowance and one CAIR NOX annual allowance for each 

ton of emissions over its allowable limit. In addition, the 

Department has set aside 181 tons of NOX, including tons that will 

be retired each year to compensate for sources that were exempted 

under the “twenty-five ton exemption” in section 145.4(b) 3. The 

balance of tons remaining in the set aside is available to the 

Department annually for accounting corrections. The Department

retires any unused amount from this set aside each year.

It is unlikely that the 3,438-ton statewide NOX ozone season 

emission limitation will be exceeded. Pennsylvania’s non-EGU 

sources’ total emissions during each of the years they were trading 

under the NOX Budget Trading Program never exceeded the 

statewide cap of 3,438 tons.

The Department’s regulation, codified in 25 Pa. Code § 145.8(d), 

was approved by 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 updating the 

cement manufacturing and large stationary internal combustion 
- 33 -

engine regulations that were adopted pursuant to the NOX SIP Call. 

Until 2009, cement kilns and large stationary internal combustion 

engines that were subject to the NOX SIP Call were required to 

surrender NOX SIP Call allowances if they exceeded their NOX

emission limits set forth in Department regulations. Because the 

Department discontinued the NOX Budget Trading Program 

beginning 2009, at which point NOX SIP Call allowances were 

replaced by CAIR NOX ozone season allowances, the Department 

modified the regulations to require surrender of CAIR NOX ozone 

season and CAIR NOX annual allowances for emission limit 

exceedances.

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 

EPA as a SIP revision on December 10, 2009, and codified at 

40 CFR § 51.2020(c)(1). An amendment to the Department’s 

regulation for cement kilns to reduce NOX emissions effective 

April 15, 2011, codified in 25 Pa. Code Chapter 145, 

Subchapter C, was subsequently approved by EPA as a SIP 

revision on July 19, 2011, and codified at 40 CFR § 51.2020(c)(1).

Federal Standards for Hazardous Air Pollutants. Federal standards to 

control hazardous air pollutants (HAPs) require Maximum Achievable 

Control Technology (MACT) at units located at major sources of HAPs. 

The EPA has promulgated a series of MACT regulations that are 

applicable to sources in Pennsylvania. These MACT standards are 

adopted and incorporated by reference in Section 6.6 of Pennsylvania’s 

Air Pollution Control Act and implementing regulations in 25 Pa. Code

§ 127.35 (relating to maximum achievable control technology standards 

for hazardous air pollutants). The standards are also included in federally 

enforceable plan approvals and operating permits issued by the

Department for affected sources.

2. Highway Vehicle Sources

Even with increases in VMT that occur from 2007 through 2025, highway 

vehicle emissions will continue to decrease. As more vehicles subject to 

cleaner new car standards replace older vehicles subject to less stringent 

new vehicle standards, the fleet as a whole emits fewer emissions, 

compensating for the increase in vehicle miles traveled. These decreases

can be attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) and 

Pennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established 
- 34 -

by the CAA Amendments of 1990 include NOX and VOC limits for lightduty gasoline vehicles (LDGVs) and light-duty gasoline trucks (LDGTs). 

The phase in of these standards began in 1994. Evaporative VOC 

emissions were reduced in gasoline-powered cars starting with Model 

Year (MY) 1998.

In 1998, under the authority of section 177 of the CAA, the Department 

adopted the Pennsylvania Clean Vehicles Program (28 Pa.B. 5973, Dec. 5, 

1998). The Pennsylvania Clean Vehicles Program incorporates by 

reference certain California Low Emission Vehicle (CA LEV) emission 

standards for passenger cars and light-duty trucks. As required under 

Section 177 of the CAA, these provisions are identical to the low emission 

standards adopted by California. The regulation does not incorporate by 

reference the California zero emissions vehicle (ZEV) or emissions 

control warranty systems statement provisions.

In the same rulemaking, the Department adopted the National Low 

Emission Vehicle (NLEV) program as a compliance alternative to the 

Pennsylvania Clean Vehicles Program. The NLEV program became 

effective in the Ozone Transport Region (OTR) in 1999. Pennsylvania’s 

New Motor Vehicle Emissions Control Program regulations in 25 Pa. 

Code Sections 126.401-126.441, in addition to including the Clean 

Vehicles Program, allowed automobile manufacturers to comply with 

NLEV instead of the CA LEV program through MY 2005. These 

regulations affected vehicles 6,000 pounds and less and were the 

regulations in effect for new motor vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV 

(Tier 2), starting with MY 2004 (65 FR 6698; Feb. 10, 2000) The NLEV 

program was replaced for MY 2004 and later by the more stringent Tier 2 

regulations, and vehicle manufacturers operating under the NLEV 

program became subject to the Tier 2 requirements.

Pennsylvania amended the former New Motor Vehicle Emissions Control 

Program in 2006. The Clean Vehicles Program continues to incorporate 

the California Low Emission Vehicle Program by reference. As amended, 

the program affects MY 2008 and newer passenger cars and light-duty 

trucks vehicles (36 Pa.B. 7424; Dec. 9, 2006), corrected 37 Pa.B. 209 

(Jan. 12, 2007, eff. Dec. 9, 2006). EPA approved Pennsylvania’s Clean 

Vehicle Program as a revision to the Commonwealth’s SIP on January 24, 

2012 (77 FR 3386).

Heavy-Duty Diesel 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 
- 35 -

required, among other terms, that diesel engines made by these companies 

comply with these 2004 standards two model years early, in MY 2002. 

The emission reductions from these programs are reflected in the future 

year emission inventories, as provided in the MOVES model.

In 2002, the Department adopted the Heavy-Duty Diesel Emissions 

Control Program for model years starting after May 2004. The program 

incorporates California standards by reference and requires MY 2005 and 

subsequent new heavy-duty diesel highway engines to be those certified 

by California. California standards were more stringent than federal 

standards for the two model years between expiration of the consent 

decrees discussed above (MYs 2005 and 2006) and the implementation of 

more stringent federal standards affecting MY 2007 and beyond. 

However, 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 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 2007 to 2010 for NOX and VOCs. For gasoline 

engines, the standards were phased in during MY 2008 and 2009. Federal 

and California standards were virtually identical for MY 2007. For 

MY 2008, California adopted requirements for idling restriction engine 

programming and an optional “clean NOX idle” standard. However, there 

is no EPA-approved methodology to estimate emission reductions from 

this requirement. Therefore, the emission estimates use assumptions of 

the federal rule for MY 2007 through 2010.

Because the new engine standards are adversely affected by sulfur in fuel, 

the EPA also required most highway diesel fuel to contain no more than 

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

was a temporary compliance option allowing refiners to continue to 

produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

2010. The Department used MOVES defaults to estimate the effects of 

the phase-in provision.

Vehicle Emission Inspection/Maintenance Program. The Pennsylvania 

portion of the Philadelphia area has had a vehicle emissions inspection 

program since 1984. In early 2004, Pennsylvania revised the 

implementation of its Vehicle Emission Inspection/Maintenance (I/M) 

Program in the five-county Philadelphia area. The program applies to 

gasoline-powered vehicles 9,000 pounds and under, MY 1975 and newer. 

For vehicles MY 1996 and newer, the program consists of an annual onboard diagnostics test and a gas cap pressure test. For subject vehicles 

MY 1995 and older, the program consists of an annual tailpipe test, visual 
- 36 -

inspection of pollution control devices to ensure they are present, 

connected and the proper type for the vehicle and a gas cap pressure test. 

For vehicles older than 25 years, the program is a visual inspection and 

gas cap test. These regulations can be found in 67 Pa. Code Chapter 177. 

Pennsylvania submitted the revised emissions program as a SIP revision 

on December 1, 2003. The EPA approved the SIP revision on October 6, 

2005. (70 FR 58313).

Low Sulfur Gasoline. Sulfur is a natural component in crude oil that 

ends up in gasoline and diesel unless removed. Sulfur in gasoline impairs 

the effectiveness of emission control systems and contributes to air 

pollution. By removing most sulfur from gasoline, new advanced 

emission controls will work longer and more efficiently, and air pollution 

will be reduced.

The 1999 federal Tier 2 regulations (65 FR 6698; Feb. 10, 2000) reduced

the sulfur content of gasoline by up to 90 percent, enabling the use of new 

emission control technologies in cars and trucks that reduce harmful air 

pollution. The emission inventory analysis in this Maintenance Plan uses 

the default assumptions provided in MOVES2010 to account for the 

implementation of the federal standards for low sulfur gasoline. 

Requirements for use of low-sulfur gasoline enabled use of advanced 

emission control systems in light-duty vehicles beginning in model year 

2004. Vehicles meeting Tier 2 emission standards are 77 to 95 percent 

cleaner than earlier models.

On March 3, 2014, 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. 

(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 parts per million, starting January 1, 2017. By 2018, EPA estimates 

that SO2 emissions from gasoline vehicles will be reduced by 56 percent. 

When fully implemented, this program, by 2030, will increase the 

effectiveness of vehicle emission controls even further and reduce onroad 

emissions of NOx by 25 percent, direct particulate matter by 10 percent 

and VOCs by 16 percent. The rule will also significantly reduce 

emissions of carbon monoxide and hazardous air pollutants including 

acrolein, benzene, formaldehyde and acetaldehyde. Emission reductions 

from the federal Tier 3 program have not been included in future year 

inventories and, therefore are not relied upon in the maintenance 

demonstration. Emission reductions from the federal Tier 3 program may 

nonetheless assist the Philadelphia Area in maintaining the PM2.5 NAAQS.
- 37 -

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.

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, EPA adopted a rule establishing a comprehensive 

national program to reduce emissions from nonroad diesel engines 

(69 FR 38958). The rule phased in requirements for reducing the sulfur 

content of diesel used in nonroad diesel engines. The reduction in fuel 

sulfur content prevents damage to the more advanced emission control 

systems needed to meet the engine standards; it will also reduce fine 

particulate emissions from diesel engines. In 2007, fuel sulfur levels were 

limited to 500 ppm for nonroad applications other than ocean-going 

marine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur 

concentration as in highway fuel, 15 ppm; this requirement began 

applying in 2012 to locomotive and marine diesel fuel. EPA adopted 

technical amendments to the program in rules published in the Federal 

Register on November 22, 2005 (70 FR 70498) and May 1, 2006 

(71 FR 25706). On April 30, 2010 (75 FR 22896), 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. 

4. Stationary Area Sources

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

rule to reduce the sulfur content of fuel oil in Pennsylvania. This final 

rule, published in the Pennsylvania Bulletin February 9, 2013 

(43 Pa.B. 806), corrected April 20, 2013 (43 Pa.B. 2140), will limit the 

sulfur content of No. 2 fuel oil to 500 ppm, No. 4 fuel oil to 2,500 ppm 

and Nos. 5 and 6 fuel oils to 5,000 ppm. Compliance with the lower sulfur 

content limits will be required beginning July 1, 2016. The Department 

estimates statewide SO2 emission reductions of approximately 25,000 tons 

per year from this rule. These emission reductions will allow the 

Commonwealth to attain and maintain the PM2.5 standards and improve 

visibility. The final-form regulation was submitted to EPA for approval as 

a SIP revision on February 26, 2013. On February 20, 2014, EPA 
- 38 -

proposed approval, as a revision to the SIP, Pennsylvania’s regulation for 

the “Control of Commercial Fuel Oil Sulfur Limits for Combustion Units” 

(79 FR 9701). EPA issued a final rule approving the SIP revision on 

July 10, 2014 (79 FR 39330).

Consumer Products. This regulation applies statewide to any person 

who sells, supplies, offers for sale, or manufactures certain consumer 

products on or after January 1, 2005, for use in the Commonwealth. The 

Consumer Products program is codified in 25 Pa. Code Chapter 130, 

Subchapter B. It was submitted to the EPA as a SIP revision on March 26, 

2003, and approved on December 8, 2004 (69 FR 70895). Amendments 

to the Consumer Products regulations were adopted on October 11, 2008,

submitted to the EPA for approval as a SIP revision on March 11, 2009,

and approved by EPA as a SIP revision on October 18, 2010 

(75 FR 63717).

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. 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 

agency in the Pennsylvania Portion of the Philadelphia Area is the Delaware 

Valley Regional Planning Commission, the designated Metropolitan Planning 

Organization (MPO) under federal transportation planning requirements.

In this Maintenance Plan, Pennsylvania establishes budgets for highway 

emissions for direct PM2.5 and NOX in order to ensure that transportation 

emissions do not impede clean air goals in the next decade and beyond. The 

highway emission budgets include a safety margin, which was created by setting 

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

emissions of PM2.5 and NOX to accommodate unanticipated growth in highway 

vehicles.

Amendments to the 40 CFR part 93 transportation conformity regulations to 

address the 1997 PM2.5 standard were published in the Federal Register on May 6, 

2005 (70 FR 24280), to account for PM2.5 and its precursors.15 The 

Implementation Rule did not amend these regulations. In the transportation 

 

15 The Federal transportation conformity regulations were again amended on March 14, 2012 (77 FR 14979) to 

restructure several sections so that they apply to any new or revised NAAQS and make several clarifications to 

improve implementation. 
- 39 -

conformity regulations, section 93.102 requires conformity determinations to be 

applicable to direct emissions of PM2.5 and NOX (unless a determination is made 

that transportation-related emissions are not significant contributors to PM2.5), but 

to emissions of SO2, VOC, and NH3 only if a finding is made that transportationrelated emissions of these pollutants are significant contributors to PM2.5. EPA 

approved Pennsylvania’s SIP revision establishing transportation conformity 

requirements in the Commonwealth on April 29, 2009 (74 FR 19451). 

This Maintenance Plan SIP revision establishes motor vehicle emission budgets

for PM2.5 and NOX. The information in Table III-2 (relating to Motor Vehicle 

Emission Budgets (Tons per Year)), once the EPA approves it for purposes of 

conformity, will establish transportation conformity budgets for the Pennsylvania 

portion of the Philadelphia Area. 

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

Philadelphia PM2.5 NOx

2007 2,386 69,327

2017 Predicted 1,460 34,475

Safety Margin 219 3,447

2017 Budget 1,679 37,922

2025 Predicted 1,145 23,056

Safety Margin 171 2,305

2025 Budget 1,316 25,361

The highway emission budgets include a safety margin to accommodate 

unanticipated growth in highway vehicles. The safety margins were created by 

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

year emissions of PM2.5 and NOX. Table III-3 (relating to Comparison of Safety 

Margin to Total Anticipated Emission Reductions in 2017 and 2025) shows that 

the amount of emission reductions anticipated between 2007 and 2017 and 

between 2007 and 2025 easily accommodates the safety margins granted. 
- 40 -

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

Emission Reductions in 2017 and 2025

Philadelphia PM2.5 NOx

2007 14,114 123,390

2017 12,459 79,120

2025 11,665 66,096

2007 - 2017 Anticipated 

Emission Reductions 1,656 44,270

Margin Granted 219 3,447

2007 - 2025 Anticipated 

Emission Reductions 2,449 57,294

Margin Granted 171 2,305

For informational purposes, DEP analyzed the projected 2025 inventory and 

found that highway emissions of VOC, NH3, and SO2 account for 15 percent, 

18 percent, and 1 percent of the total projected 2025 inventory, respectively, as 

shown in Table III-4 (relating to Comparison of 2025 On-Road Mobile VOC, 

NH3, and SO2 Emissions to the Total Projected 2025 Inventory).

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

to the Total Projected 2025 Inventory

2025 SO2 VOC NH3

On-Road Mobile Source 

Projected Inventory (Tons) 259 11,222 908

Total Projected 2025 

Inventory (Tons) 25,701 74,808 5,162

Percent of Total Projected 

2025 Inventory (%) 1.01 15.00 17.58

The motor vehicle emission budgets include PM from vehicle exhaust, brake 

wear, and tire wear, which are estimated by the MOVES model. The Department 

has included direct PM2.5 re-entrained road dust emissions from paved and 

unpaved roads in the area source inventory, not in the motor vehicle emission 

budgets. Appendices B-3 and B-4, relating to area source annual emissions, 

contain estimates of the PM2.5 emissions attributable to paved and unpaved roads.

In addition to monitors that measure PM2.5 mass, the Chester and New Garden

monitoring sites are equipped with speciation monitors that collect data on the

chemical constituents of PM2.5 in the Philadelphia Area. Transportation 

construction-related fugitive dust emissions are not a significant contributor to the 

PM2.5 concentrations observed at these monitors. The crustal component was 

found to be small compared to other components of PM2.5 (See Figure 1). Given 
- 41 -

that construction-related fugitive dust is one of many source categories 

contributing to the crustal material observed at the monitor, and transportation 

construction is a small subset of all construction, it is reasonable to conclude that 

transportation construction-related fugitive emissions are insignificant.

Figure 1. Pie Charts of 2007 Philadelphia Speciation Data

New Garden

 Percentage of Total Mass

 Year 2007

Nitrate

19%

Sulfate

27%

Ammonium

16%

Organic carbon

24%

Elemental carbon

4%

Crustal component

2%

Other

8%

 Chester 

 Percentage of Total Mass

 Year 2007

Nitrate

11%

Sulfate

26%

Ammonium

12%

Organic carbon

22%

Elemental carbon

5%

Crustal component

4%

Other

20%
- 42 -

IV. AMBIENT AIR QUALITY MONITORING NETWORK

The DEP and the Philadelphia County Health Department will continue to operate the air 

monitoring network in accordance with 40 CFR Part 58 to verify the attainment status of 

the Philadelphia Area for the 1997 annual and 2006 24-hour PM2.5 NAAQS, with no 

reductions in the number of sites from those in the existing network unless pre-approved 

by EPA. The DEP has concurrently submitted a request for redesignation of the 

Pennsylvania portion of the Philadelphia Area that contains analysis of ambient air 

quality data and related factors.

V. VERIFICATION OF CONTINUED ATTAINMENT

The DEP will track the attainment status of the 1997 and 2006 PM2.5 NAAQS in the

Philadelphia Area by reviewing air quality and emissions data during the maintenance 

period. The DEP will perform an annual evaluation of two key factors, VMT data and 

emissions reported from stationary sources, and compare them to the assumptions about 

these factors used in this plan. The DEP will also evaluate the periodic (every three 

years) emission inventories prepared under EPA’s Air Emission Reporting Requirements 

(40 CFR 51, Subpart A) to see if they exceed the attainment year inventory (2007) by 

more than 10 percent. Based on these evaluations, the DEP will consider whether any 

further emission control measures should be implemented. 

VI. CONTINGENCY MEASURES

The Commonwealth will adopt and expeditiously implement corrective actions, as 

necessary and appropriate, in the following circumstances:

A first level response will be prompted if the annual mean PM2.5 concentration exceeds 

15.5 μg/m3in a single calendar year within the maintenance area, if the 98th percentile 

24-hour PM2.5 concentration exceeds 35.0 μg/m3in a single calendar year within the 

maintenance area or if the periodic emissions inventory for the Philadelphia Area exceeds 

the attainment year inventory (2007) by more than 10 percent. The first level response 

will consist of a study to determine whether the PM2.5 value indicates a trend toward 

higher PM2.5 values and whether emissions appear to be increasing. If there appears to be 

an increasing trend, the study will evaluate whether the trend is likely to continue and, if 

so, the necessary and appropriate control measures to reverse the trend. Implementation 

of necessary and appropriate controls would take place as expeditiously as possible.

A second level response will be prompted if the 2-year average of the annual mean PM2.5

concentrations exceeds 15.0 μg/m3or if the 2-year average of 98th percentile 24-hour 

PM2.5 concentrations exceeds 35.0 μg/m3 within the maintenance area. If this trigger 

point occurs, the DEP will evaluate whether additional emission control measures should 

be implemented in order to prevent a violation of the air quality standards. The 

Department will analyze the conditions leading to the PM2.5 levels and evaluate what 

measures might be most effective in correcting the PM2.5 levels. The Department will 

also analyze the potential emissions effect of federal, state and local measures that have 
- 43 -

been adopted but not yet implemented at the time the second level response is triggered. 

The Department will then begin the process of adopting any selected measures that are 

necessary and appropriate so that in the event of a violation, the measures can be 

implemented as expeditiously as practicable.

If a violation of the PM2.5 NAAQS occurs, the Commonwealth will propose and adopt 

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

practicable in accordance with the implementation schedule in this section, the CAA, the

Pennsylvania Air Pollution Control Act, other Pennsylvania statutory requirements, and 

the Department’s Policy for Development, Approval and Availability of Regulations in 

order to return the area to attainment with the standards.

Additional emission reduction measures to be considered for adoption if a violation of the 

NAAQS occurs in the Philadelphia Area would be based on criteria including the 

following:

 air quality analysis indicating nature of violation [cause, location, source];

 emission reduction potential, including extent to which emission generating 

sources occur in the nonattainment area;

 timeliness of implementation in terms of the potential to return the area to 

attainment as expeditiously as practicable; and

 costs, equity and cost-effectiveness.

Additional emission reduction measures the Department would consider pursuing for 

promulgation if a violation of the NAAQS occurs in the Philadelphia Area include the 

following:

Regulatory measures:

 A regulation based on the OTC Model Rule to update requirements for consumer 

products;

 A regulation based on the Control Techniques Guidelines (CTG) for industrial 

cleaning solvents; and

 Other regulatory measures identified based on the above-listed criteria.

Non-regulatory measures:

 Voluntary diesel projects:

o Diesel retrofit (including replacement, repowering or alternative fuel use) 

for public or private local onroad or offroad fleets;

o Idling reduction technology for Class 2 yard locomotives; and

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

other freight-handling facilities.
- 44 -

 Promotion of accelerated turnover of lawn and garden equipment, especially 

commercial equipment.

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

use.

Once the Department’s Bureau of Air Quality has obtained an approved request to initiate 

a rulemaking, the rulemaking may proceed as follows:

Within 2 months: Review by Air Quality Technical Advisory Committee 

(AQTAC), Citizens Advisory Council and other advisory committees,

16 as 

appropriate.

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

Within 7 months: Publication in the Pennsylvania Bulletin for comment as 

proposed rulemaking.

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

rule closes.

Within 10 months: Independent Regulatory Review Commission (IRRC) 

comment on proposed rule.

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

committees, as appropriate, review responses to comments and draft final 

rulemaking.

Within 15 months: EQB meeting/action.

Within 16 months: IRRC action on final rulemaking.

Within 17 months: Attorney General review/action.

Within 18 months: Publication in the Pennsylvania Bulletin as final rulemaking 

and submission to the EPA as a SIP revision. The regulation would 

become effective upon publication in the Pennsylvania Bulletin.

 

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

Committee.
- 45 -

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

DEP Pennsylvania Department of Environmental Protection

EDMS Emissions and Dispersion Modeling System

EGAS Economic Growth Analysis System

EGU Electric Generating Unit

EIA Energy Information Administration

EIS Emission Inventory System

EPA The United States Environmental Protection Agency

EQB Environmental Quality Board

ERC Emission Reduction Credit

ERTAC Eastern Regional Technical Advisory Committee

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FIRE Factor Information Retrieval 

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

HAP Hazardous Air Pollutant

I/M Inspection and Maintenance

IRRC Independent Regulatory Review Commission

ITN Itinerant

LDGV Light Duty Gasoline Vehicles

LDGT Light Duty Gasoline Trucks

MACT Maximum Achievable Control Technology

MANE-VU Mid-Atlantic/Northeast Visibility Union

MARAMA Mid-Atlantic Regional Air Management Association

MOVES Motor Vehicle Emission Simulator

MPO Metropolitan Planning Organization

MY Model Year

NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NEI National Emissions Inventory

NH3 Ammonia

NLEV National Low Emission Vehicle (program)
- 46 -

NMIM National Mobile Inventory Model

NOX Oxides of Nitrogen

NSR New Source Review

OTAQ Office of Transportation and Air Quality

OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood-fired Boiler

PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates 

PM10 Particulate Matter less than 10 microns in diameter

PSD Prevention of Significant Deterioration

RIA Regulatory Impact Analysis

RWC Residential Wood Combustion

SCC Source Classification Code

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TSD Technical Support Document 

μg/m3 Microgram per cubic meter

μm Micrometer

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

WOE Weight of Evidence

ZEV Zero Emissions Vehicle
Commonwealth of Pennsylvania

Redesignation Request

Pennsylvania Portion of the

Philadelphia-Wilmington, PA-NJ-DE Nonattainment Area

1997 and 2006 Fine Particulate Matter

National Ambient Air Quality Standards

August 2014

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

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

TABLE OF CONTENTS

Introduction......................................................................................................................................1

I. Demonstration of Attainment and Air Quality Trends Analysis .........................................4

A. Design Value Determination....................................................................................6

B. Air Quality Trends Analysis....................................................................................7

C. Climate Trends Analysis........................................................................................11

1. Temperature Trends...................................................................................13

2. Precipitation Trends...................................................................................14

D. Additional Trends ..................................................................................................16

1. Population Trends......................................................................................16

2. Economic Trends.......................................................................................16

E. Modeling Analysis.................................................................................................18

II. SIP Approvals and Applicable Requirements....................................................................20

A. Section 110(a)(2) of the CAA................................................................................21

B. Part D - Plan Requirements for Nonattainment Areas...........................................22

1. Section 172(c) of the CAA ........................................................................22

2. Section 173 of the CAA.............................................................................22

3. Section 176 of the CAA.............................................................................23

4. Section 189(e) of the CAA ........................................................................24

C. Conclusion .............................................................................................................24

III. Demonstration of Permanent and Enforceable Improvement............................................24

A. Baseline (2002) Emissions Inventory ....................................................................26

B. Attainment Year (2007) Emissions Inventory .......................................................27

C. Control Measures...................................................................................................28

1. Stationary Point Sources............................................................................30

2. Highway Vehicle Sources..........................................................................36

3. Nonroad Sources........................................................................................39

4. Stationary Area Sources.............................................................................40

IV. Maintenance Plan...............................................................................................................40

Acronyms and Abbreviations ........................................................................................................42
- ii -

TABLES

Table I-1: Philadelphia Area (PA, DE, NJ) Annual PM2.5 Concentrations....................................7

Table I-2: Philadelphia Area 24-Hour PM2.5 Concentrations.........................................................8

Table I-3: Philadelphia Area Annual PM2.5 Design Values............................................................9

Table I-4: Philadelphia Area 24-Hour PM2.5 Design Values........................................................10

Table I-5: Philadelphia Area Monthly Mean Temperature (°F)...................................................13

Table I-6: Philadelphia Area Precipitation (inches)......................................................................15

Table I-7: EPA’s Transport Rule Modeling Results for the PM2.5 Standard for the 

Philadelphia Area .....................................................................................................20

Table III-1: 2002 Pennsylvania portion of the Philadelphia Area Annual Emissions (Tons 

per Year)...................................................................................................................27

Table III-2: 2007 Pennsylvania Portion of the Philadelphia Area Annual Emissions 

(Tons per Year) ........................................................................................................28

Table III-3: Change in the Pennsylvania Portion of the Philadelphia Area Annual 

Emissions (Tons per Year) from 2002 to 2007 ........................................................29

Table III-4: Summary of Emission Totals (Tons) in 2007, 2017 and 2025..................................30

FIGURES

Figure I-1: Pennsylvania’s 1997 Annual PM2.5 Nonattainment Areas...........................................5

Figure I-2: Pennsylvania’s 2006 24-Hour PM2.5 Nonattainment Areas .........................................5

Figure I-3: PM2.5 Annual Concentration Trend.............................................................................11

Figure I-4: PM2.5 24-Hour Concentration Trend ..........................................................................11

Figure I-5: Pie Charts of 2007 Philadelphia Area Speciation Data ..............................................12

Figure I-6: Philadelphia Area Monthly Mean Temperature (°F)..................................................14

Figure I-7: Philadelphia Area Annual Precipitation (inches) .......................................................15

Figure I-8: Population Trend for the Pennsylvania Portion of the Philadelphia Area..................16

Figure I-9: Philadelphia Area Population and Labor Force Trends..............................................17

Figure I-10: Pennsylvania and National Coincident Indexes from the Philadelphia 

Federal Reserve Bank...............................................................................................18
- 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 particle pollution or PM2.5

describes particulate matter that is less than or equal to 2.5 micrometers (μm) in diameter, 

approximately 1/30th the diameter of a human hair. Because of their small size, fine particles 

can penetrate deeply into the lungs.

Health studies have shown a significant association between exposure to fine particles and 

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

and have been linked to effects such as cardiovascular symptoms, cardiac arrhythmias, heart 

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

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

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

include people with heart or lung disease, older adults, and children. The article, “FineParticulate Air Pollution and Life Expectancy in the United States” by C. Arden Pope, III, et al. 

published January 22, 2009 in the New England Journal of Medicine evaluated the role PM2.5 

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

that period. The study found that a reduction of 10 micrograms per cubic meter (μg/m3) of PM2.5 

was associated with an average increase in life expectancy of 7.3 months.

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

PM2.5 also affects visibility (regional haze) through the scattering and absorption of light. Fine 

particles, similar in size to the wavelength of light, are most efficient, per unit of mass, at 

reducing visibility. Soiling and materials damage can also be caused by PM2.5 in the air.

The United States Environmental Protection Agency (EPA) issued PM2.5 national ambient air 

quality standards (NAAQS) in 1997 after evaluating hundreds of health studies and conducting 

an extensive peer review process. The EPA established an annual primary (health-based) and 

secondary (welfare-based) standard of 15.0 micrograms per cubic meter (μg/m3), based on the 

3-year average of annual mean PM2.5 concentrations. The EPA also established a primary and 

secondary 24-hour standard of 65 μg/m3determined by the 3-year average of the 98th percentile 

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

35 μg/m3determined by the 3-year average of the 98th percentile of 24-hour concentrations. The 

annual standard was not revised. (71 FR 61144 (October 17, 2006))

On December 17, 2004, the EPA issued air quality designations for the PM2.5 standard based on 

air quality monitoring data from 2001-2003. The final designations were published in the 

Federal Register on January 5, 2005 (70 FR 944). The designations became effective on April 5, 

2005. On April 5, 2005, the EPA issued a supplemental notice changing the designation of 

certain areas from nonattainment to attainment based on newly available air quality data 

(70 FR 19844; April 14, 2005). The April 5, 2005, supplemental notice only affected Mercer 

County in the Commonwealth of Pennsylvania.
- 2 -

The Philadelphia-Wilmington, PA-NJ-DE (Philadelphia) Area was one of eight areas in 

Pennsylvania, comprising all or parts of 21 Pennsylvania counties, designated by the EPA as 

nonattainment for the 1997 annual PM2.5 NAAQS. The Philadelphia Area was designated by 

EPA as nonattainment because it violated the 1997 annual standard of 15.0 μg/m3based on 

2001-2003 monitoring data. The Philadelphia Area did not violate the 1997 24-hour standard of 

65 μg/m.

3

 The Pennsylvania portion of the nonattainment area consists of Bucks, Chester, 

Delaware, Montgomery and Philadelphia counties in Pennsylvania. The Delaware portion of the 

nonattainment area consists of New Castle County. The New Jersey portion of the 

nonattainment area consists of Burlington, Camden and Gloucester counties. The EPA 

redesignated the New Jersey portion of the nonattainment area for both the 1997 annual and the 

2006 24-hour NAAQS on September 4, 2013 (78 FR 54396). The EPA proposed to redesignate 

the Delaware portion of the nonattainment area for both the 1997 annual and the 2006 24-hour 

NAAQS on April 11, 2014 (79 FR 20139). 

On October 8, 2009, the EPA promulgated air quality designations for the 2006 24-hour PM2.5

standard based on 2006-2008 air quality monitoring data. The final designations were published 

in the Federal Register on November 13, 2009 (74 FR 58688). The EPA designated seven areas 

comprised of all or portions of 22 counties in Pennsylvania as 24-hour PM2.5 nonattainment 

areas. The designations became effective on December 14, 2009.

The Philadelphia Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 24-hour PM2.5 NAAQS. The Philadelphia Area, consisting of the 

same counties as those listed above for the 1997 NAAQS, was designated nonattainment because 

the area violated the 2006 24-hour PM2.5 standard of 35 μg/m

3

based on 2006-2008 monitoring 

data.

The subsequent analyses described in this Request for Redesignation clearly demonstrate that the 

ambient air quality in the Philadelphia Area now meets the 1997 and 2006 PM2.5 NAAQS. The 

emission reductions responsible for the improvements in PM2.5 air quality are both permanent 

and enforceable. These analyses and the Maintenance Plan submitted concurrently demonstrate 

that the Department has completed all criteria set forth in Section 107(d)(3)(E) of the Clean Air 

Act (CAA) for the Pennsylvania portion of Philadelphia Area and so the Area should be 

officially redesignated as attainment for both the 1997 and 2006 PM2.5 NAAQS.

Section 107(d)(3)(E) of the CAA states that an area may be redesignated to attainment if the 

following conditions are met:

● The NAAQS has been attained (discussed in Section I);

● The applicable implementation plan has been fully approved under Section 110(k) of the 

CAA and the state has met all applicable requirements for the area under Section 110 and 

Part D (discussed in Section II);

● The improvement in air quality is due to permanent and enforceable reductions in 

emissions (discussed in Section I and Section III); and
- 3 -

A Maintenance Plan with contingency measures has been fully approved under Section 175A 

(discussed in Section IV).

This Request for Redesignation describes how the Philadelphia Area satisfies each of the CAA’s 

Section 107(d)(3)(E) criteria for redesignation to attainment.

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

40 CFR Section 51.102(d) and Section 7.5 of the Pennsylvania Air Pollution Control Act. 

35 P.S. Section 4007.5(b). On May 10, 2014, the Department provided notice of a public 

comment period and the opportunity for a hearing on the Maintenance Plan, 2007 comprehensive 

inventory required by Section 172(c)(3) of the CAA, and this Request for Redesignation. The 

Department scheduled the public hearing to occur on June 12, 2014, but no one expressed 

interest in presenting testimony or attending. Therefore, the Department cancelled the hearing. 

The public comment period closed June 13, 2014. Comments were received from two 

commentators and have been addressed in a Comment and Response Document. 
- 4 -

I. DEMONSTRATION OF ATTAINMENT AND AIR QUALITY TRENDS 

ANALYSIS

On December 17, 2004, the EPA issued air quality designations for the 1997 PM2.5

annual standard based on 2001-2003 air quality monitoring data. The final designations 

were published in the Federal Register on January 5, 2005 (70 FR 944). The 

designations became effective on April 5, 2005. On April 5, 2005, the EPA issued a 

supplemental notice changing the designation of certain areas from nonattainment to 

attainment based on newly available air quality data (70 FR 19844; April 14, 2005). The 

April 5, 2005 supplemental notice only affected Mercer County in the Commonwealth of 

Pennsylvania (Commonwealth or Pennsylvania).

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

21 Pennsylvania counties, designated by the EPA as nonattainment for the 1997 annual 

PM2.5 NAAQS. The Philadelphia Area was designated as nonattainment because it 

violated the 1997 annual standard of 15.0 μg/m3based on 2001-2003 monitoring data. 

The Philadelphia Area did not violate the 1997 24-hour standard of 65 μg/m.

3

On October 8, 2009, the EPA promulgated air quality designations for the 2006 24-hour 

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

were published in the Federal Register on November 13, 2009 (74 FR 58688). The EPA 

designated seven areas comprised of all or portions of 22 counties in Pennsylvania as 

24-hour PM2.5 nonattainment areas. The designations became effective on December 14, 

2009. 

The Philadelphia Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 24-hour PM2.5 NAAQS. The Philadelphia Area was 

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

35 μg/m3based on 2006-2008 monitoring data.
- 5 -

Figure I-1: Pennsylvania’s 1997 Annual PM2.5 Nonattainment Areas

Figure I-2: Pennsylvania’s 2006 24-Hour PM2.5 Nonattainment Areas
- 6 -

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

The Philadelphia Area’s annual and 24-hour PM2.5 design values have decreased over the 

2001 to 2012 time frame. Based on 2001-2003 air quality monitoring data, the 

Philadelphia Area’s annual and 24-hour design values for 2003 were 16.2 μg/m3and 

43 μg/m,

3

respectively. The Philadelphia Area’s annual and 24-hour design values were

13.1 μg/m3and 31 μg/m3based on 2010-2012 air quality monitoring data. Following 

EPA criteria, annual PM2.5 design values below 15.0 μg/m3and 24-hour design values 

below 35 μg/m3are considered to be attainment. Annual and 24-hour concentrations are 

expected to remain lower than 15 μg/m3and 35 μg/m3over the next decade.

On May 16, 2012, the EPA determined that the Philadelphia Area had attained the 1997 

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

air monitoring data that show the area had monitored attainment based on 2007–2009 and 

2008–2010 data. (“Clean Data Determination”) (77 FR 28782). This final action 

suspended the requirements for this area to submit an attainment demonstration and 

associated reasonably available control measures, reasonable further progress plans, 

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

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

NAAQS1.

On January 7, 2013, the EPA determined that the Philadelphia Area had attained the 2006 

24-hour PM2.5 NAAQS based on quality assured, quality controlled and certified ambient 

air monitoring data that show the area had monitored attainment based on 2008-2010 and 

2009-2011 data (“Clean Data Determination”) (78 FR 882). This final action suspended 

the requirements for this area to submit an attainment demonstration and associated 

reasonably available control measures, reasonable further progress plans, contingency 

measures and other planning SIP revisions related to the attainment of the 2006 PM2.5

NAAQS for so long as the area continues to attain the 2006 PM2.5 NAAQS.

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

Pennsylvania portion of the Philadelphia Area remains nonattainment for the 1997 and 

2006 PM2.5 NAAQS until the Commonwealth submits, and EPA approves, a Request for 

Redesignation and a Maintenance Plan showing the area can maintain these standards for 

at least 10 years.

A. Design Value Determination

The ambient air quality analysis is based on PM2.5 data measured at several 

Philadelphia Area monitoring sites. The ambient air quality data analysis for 

PM2.5 was completed using the appropriate regulations and guidance documents. 

Monitoring procedures were determined in accordance with 40 CFR Part 58. The 

PM2.5 design values were calculated in accordance with 40 CFR Part 50, 

 

1 In the same rulemaking, EPA also made a statutorily required determination under Section 179(c) of the CAA, that 

the Philadelphia Area attained the 1997 PM2.5 NAAQS by the applicable attainment date of April 5, 2010. EPA 

based this determination on complete, quality assured, and certified ambient air monitoring data that show the area 

monitored attainment for the 2007-2009 monitoring period.
- 7 -

Appendix N, “Interpretation of the National Ambient Air Quality Standards for 

Particulate Matter.”

B. Air Quality Trends Analysis

This section provides a brief summary of PM2.5 data from monitors in the 

Philadelphia Area, including data from monitoring sites located in New Jersey 

and Delaware portions of the Philadelphia area. 

To assess trends, PM2.5 monitoring data from 2001-2012 were analyzed. 

Table I-1 displays annual PM2.5 concentrations monitored in the Philadelphia 

Area. Table I-2 contains the 98th percentile of 24-hour concentrations for each 

year. 

Table I-1: Philadelphia Area (PA, DE, NJ) Annual PM2.5 Concentrations

*This data is shown in EPA’s Air Quality System (AQS) as incomplete. Additional statistical analysis was done to 

ensure the Philadelphia Area meets the completeness requirement for the Clean Data Determination.

Site and AQS ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Bristol 

420170012

14.5 14.2 14.4 13.0* 14.3 12.2* 13.0* 12.7* 10.8 10.5 11.5 10.7

New Garden 

420290100

14.6 15.6 14.2* 15.9 12.6* 14.1* 13.7* 14.1 13.8 13.3* 9.8

Chester 

420450002

15.9 14.7 15.6 14.9 16.5 13.7 14.7 13.9 12.4 13.5 12.9 12.8*

Norristown 

420910013

14.9 13.6 13.9 12* 12.5* 12.1 13.1 11.7 10.4 9.5 10.4 9.7

AMS Laboratory 

421010004 16.5 14.4 14.8 13.9 14.2* 13.6* 13.7 13.0 10.8 10.7 8.9 9.7*

Broad St 

421010047 17.0 15.6 16.1 14.4* 15.1 15.5 14.3 13.5 11.1 11.0 11.4 10.2

Ritner 

421010055 13.5 11.3 11.3 11.4 10.3

Spring Garden St 

421010057 12.0* 13.3 11.1 10.9 11.4 10.1

Baxter 

421011002 9.0 10.3

Bellefonte 

100031003 15.6 14.0 14.8 13.9 14.3 12.3* 13.4 13* 10.2 10.2 9.4* 9.3

Lums Pond 

100031007 14.5 13* 13.3* 13.2 13.8 11.4 12.5 11.5 10.0* 10.0 8.8 8.5

Newark 

100031012 15.8 14.7 14.8* 14.5 14.4 12.7* 13.4 12.5 10.6 10.4* 10.4* 9.5

MLK 

100032004 17.6 15.4 15.5 14.9 15.0 14.6 14.4 13.5 11.2 10.6 10.3 10.3

Camden Spruce St 

340070002 9.7*

Pennsauken 

340071007 14.2* 13.9* 13.9* 13.2 14.3 12.4 13.8 11.9 9.5 9.5 10.1 9.0

Gibbstown 

340150004 13.3 11.5 9.3 9.0* 9.4 9.4

Annual Mean
- 8 -

Table I-2: Philadelphia Area 24-Hour PM2.5 Concentrations

*This data is shown in EPA’s AQS as incomplete. Additional statistical analysis was done to ensure the 

Philadelphia Area meets the completeness requirement for the Clean Data Determination.

Tables I-3 and I-4 contain the Philadelphia Area’s annual and 24-hour PM2.5

design values for each monitoring site calculated from 2001-2012 monitoring 

data. The highest design value for each year is shown in bold type. The highest 

design value does not always occur at the same monitor. The Philadelphia Area 

was designated as nonattainment for the 1997 annual standard based on the 

2001-2003 annual design value of 16.2 μg/m.

3

 The 24-hour design value for that 

time period was 43 μg/m.

3

 Compared with the 2001-2003 design values, the 

annual design value for 2010-2012 has decreased by 19 percent and the 24-hour 

design value by 28 percent. The annual and 24-hour PM2.5 design values for the 

Philadelphia Area are shown below in Tables I-3 and I-4, respectively.

Site and AQS ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Bristol 

420170012

38.5 40.6 39.6 29.9* 35.4 34.2* 35* 30.9* 25.8 28.3 29.7 28.2

New Garden 

420290100

33.7 38.5 32.7* 33.7* 38.3 38.1 32* 31.1 35.1 33.8* 24.1

Chester 

420450002

39.5 40.1 37.8 30.5 37 36.7 34 28.6 27.9 32.8 28.6 31.1*

Norristown 

420910013

47.6 37.4 37.5 28.8* 32* 36.4 30.1 23.7 27.2 25.9 27.6 21.8

AMS Laboratory 

421010004

40.2 40.9 39.9 34.3 35.9 38.6 35.4 34.5 25.9 27.6 23.7 21.1*

Broad St 

421010047

39.6 38.7 42.3 31.5* 39.4 48 35.2 32.8 27.2 27.6 27.5 21.8

Ritner 

421010055

34.5 28.6 28.9 30.6 24.8

Spring Garden St 

421010057 33.1* 32.8 28.3 27.9 30.5 23.3

Baxter 

421011002 19.3 23.5

Bellefonte 

100031003 40.7 39 35.8 32.5 34.8 30.9* 32.3 31.6* 23.2 24.3 22.4* 21.5

Lums Pond 

100031007 35.9 42.1 36.5 30.8 36.2 28.8 29.6 28.1 20.6* 27.5 21 21.1

Newark 

100031012 40.9 42.4 36.4 29.1 35 30.5* 31 28.6 23.4 24.9* 22.2* 21.3

MLK 

100032004 43.2 46.1 38.3 33.8 37.7 38.7 33.6 34.8 28.4 27.9 24.7 24.2

Camden Spruce St 

340070002 21.5*

Pennsauken 

340071007 37.8 36.7 44.5 34.8 37.2 37.8 35.1 28 25 23.4 24.3 19.8

Gibbstown 

340150004 31.3 23.9 21.9 21.6* 22.2 21.8

Annual 98% Concentration
- 9 -

Table I-3: Philadelphia Area Annual PM2.5 Design Values

*This data is shown in EPA’s AQS as incomplete. Additional statistical analysis was done to ensure the 

Philadelphia Area meets the completeness requirement for the Clean Data Determination.

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

Bristol 

420170012 13.4* 14.1* 14.3 13.9* 13.9* 13.2* 13.2* 12.6* 12.2* 11.3* 10.9 10.9

New Garden 

420290100 14.6* 15.1* 14.8* 15.2 14.2* 14.2* 13.4* 13.9* 13.8* 13.7* 12.3*

Chester 

420450002 15* 15.5 15.4 15.1 15.7 1 5 1 5 14.1 13.7 13.3 12.9 13.1*

Norristown 

420910013 13.8* 14* 14.1 13.2* 12.8* 12.2* 12.5* 12.3 11.7 10.5 10.1 9.8

AMS Laboratory 

421010004 15.3 15.3 15.2 14.4 14.3* 13.9* 13.8* 13.4* 12.5 11.5 10.1 9.8*

Broad St 

421010047 16.6 16.6 16.2 15.4 15.2 15* 1 5 14.5 13 11.9 11.2 10.9

Ritner 

421010055 13.5* 12.4* 12 11.4 11

Spring Garden St 

421010057 12* 12.7* 12.1* 11.7 11.1 10.8

Baxter 

421011002 9* 9.6*

Bellefonte 

100031003 15.1 15 14.8 14.2 14.3 13.5* 13.4* 12.9* 12.2* 11.1* 9.9* 9.6*

Lums Pond 

100031007 14.1* 13.9* 13.6* 13.2* 13.4* 12.8 12.6 11.8 11.3* 10.5* 9.6* 9.1

Newark 

100031012 15.5* 15.3 15.1 14.7* 14.6* 13.9* 13.5* 12.9* 12.2 11.2* 10.5* 10.1*

MLK 

100032004 16.6 16.5 16.2 15.3 15.1 14.8 14.7 14.2 13 11.7 10.7 10.4

Camden Spruce St 

340070002 9.7*

Pennsauken 

340071007 14.6* 14.5* 14* 13.7* 13.8* 13.3 13.5 12.7 11.7 10.3 9.7 9.5

Gibbstown 

340150004 13.3* 12.4* 11.4 10* 9.3* 9.3*

Annual PM2.5 NAAQS = 15 ug/m3

Design Value
- 10 -

Table I-4: Philadelphia Area 24-Hour PM2.5 Design Values

*This data is shown in EPA’s AQS as incomplete. Additional statistical analysis was done to ensure the 

Philadelphia Area meets the completeness requirement for the Clean Data Determination.

The 2001 through 2012 trend lines of the Philadelphia Area’s highest annual and 

24-hour PM2.5 design values are shown in Figures I-3 and I-4. As shown in 

Figures I-3 and I-4, the slope of the trend lines for the annual and 24-hour PM2.5

design values are both negative, indicating decreasing concentrations. 

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

Bristol 

420170012 37 39 40 37 35* 33* 35* 33* 31* 28* 28 29

New Garden 

420290100 34* 36* 35* 35* 35* 37 36 34* 33* 33* 31*

Chester 

420450002 37 39 39 36 35 35 36 33 30 30 30 31*

Norristown 

420910013 37 39 41 35* 33* 32* 33* 30 27 26 27 25

AMS Laboratory 

421010004 4 0 41 40 38 37 36 37 36 32 29 26 24*

Broad St 

421010047 37 39 40 38 38 4 0 4 1 3 9 32 29 27 26

Ritner 

421010055 35* 32* 31 29 28

Spring Garden St 

421010057 33* 33* 31* 30 29 27

Baxter 

421011002 19* 21*

Bellefonte 

100031003 37 39 39 36 34 33* 33* 32* 29* 26* 23* 23*

Lums Pond 

100031007 35* 38 38 36 35 32 32 29 26* 25* 23* 23

Newark 

100031012 38 41 40 36 34 32* 32* 30* 28 26* 24* 23*

MLK 

100032004 4 0 4 3 4 3 3 9 37 37 37 36 32 30 27 26

Camden Spruce St 

340070002 22*

Pennsauken 

340071007 36 37 40 3 9 3 9 37 37 34 29 25 24 23

Gibbstown 

340150004 31* 28* 26 22* 22* 22*

2006 24-Hour PM2.5 NAAQS 3 year 98th% = 35 ug/m3

Design Value
- 11 -

Figure I-3: PM2.5 Annual Concentration Trend

Figure I-4: PM2.5 24-Hour Concentration Trend

C. Climate Trends Analysis

PM2.5 formation in the eastern United States is a complex process involving local 

and regional meteorology, topography, chemistry and transport. Sulfates and 

nitrates are formed primarily through atmospheric reactions of precursor 

emissions of sulfur dioxide (SO2), oxides of nitrogen (NOX) and ammonia (NH3). 

Organic carbon is a combination of secondary organic particles formed from 

emissions of volatile organic compounds (VOC) and the organic portion of 

primary PM2.5 that is directly emitted or condenses near its source. Currently, our 

y = -0.3234x + 17.061

10

11

12

13

14

15

16

17

18

200120022003200420052006200720082009201020112012

PM2.5 Design Value (ug/m3)

PM2.5 Annual Design Value Trend

Philadelphia Area

Annual DV

Level of Standard

y = -0.9895x + 44.348

25

27

29

31

33

35

37

39

41

43

45

200120022003200420052006200720082009201020112012

PM2.5 Design Value (ug/m3)

PM2.5 24-Hour Design Value Trend

Level of Standard

Philadelphia Area 24-

Hour DV
- 12 -

understanding of sulfate and nitrate chemistry and its impacts on PM2.5

concentrations far exceeds our understanding of contributions from anthropogenic 

VOCs. This is important because sulfates, nitrates, ammonium and organic 

carbon are major contributors to the total PM2.5, making up approximately 71 and 

86 percent PM2.5 concentration observed at the Chester and New Garden PM2.5 

monitoring sites in the Philadelphia Area in 2007. Data from these sites was 

assessed because the Chester and New Garden monitoring sites are equipped with 

speciation monitors that collect data on the chemical constituents of PM2.5 in the 

Philadelphia Area.

Figure I-5: Pie Charts of 2007 Philadelphia Area Speciation Data

 Chester 

 Percentage of Total Mass

 Year 2007

Nitrate

11%

Sulfate

26%

Ammonium

12%

Organic carbon

22%

Elemental carbon

5%

Crustal component

4%

Other

20%

New Garden

 Percentage of Total Mass

 Year 2007

Nitrate

19%

Sulfate

27%

Ammonium

16%

Organic carbon

24%

Elemental carbon

4%

Crustal component

2%

Other

8%
- 13 -

Attainment of the PM2.5 NAAQS involves the range of meteorological conditions 

throughout the year. PM2.5 chemistry favors sulfate formation during the warm 

summer months and nitrate formation during the colder winter months. In 

addition, local temperature inversions more common in the winter can concentrate 

emissions near the surface, leading to periods of elevated PM2.5 concentrations.

To assess whether it is likely that unusual meteorological patterns have 

contributed to the lower PM2.5 concentrations observed in the Philadelphia 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 Philadelphia International 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 Philadelphia 

Area for 2001 through 2012. Figure I-5 graphically displays the data.

Table I-5: Philadelphia Area Monthly Mean Temperature (°F)

Philadelphia Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2001 32.5 37.4 41.0 54.9 64.6 75.2 75.4 79.9 68.4 59.2 52.9 43.7

2002 39.2 41.2 45.5 57.2 63.3 73.9 79.7 79.5 72.1 57.6 45.9 35.4

2003 28.6 29.8 44.8 52.7 60.4 71.2 78.8 78.3 70.0 55.9 50.7 36.7

2004 26.1 35.4 45.1 54.3 69.3 71.8 76.3 75.0 70.5 56.1 47.8 37.8

2005 31.8 36.1 39.6 55.2 59.5 74.7 78.8 79.7 73.8 58.8 49.3 34.3

2006 40.8 35.6 44.4 56.7 64.6 72.9 79.3 78.1 67.1 56.1 51.3 42.8

2007 38.1 27.9 43.7 50.7 66.0 73.8 77.4 77.0 72.0 64.6 45.7 37.6

2008 35.8 36.9 44.8 56.3 61.2 76.5 79.3 74.7 70.3 56.5 45.5 38.7

2009 29.1 37.0 43.7 55.6 64.9 71.1 75.9 78.1 68.0 56.3 50.9 36.3

2010 33.3 31.8 48.4 58.5 67.5 78.3 81.7 79.0 72.9 59.0 48.2 32.7

2011 29.3 37.2 44.1 56.8 67.3 75.4 82.4 76.1 71.1 57.7 51.3 43.3

2012 37.9 41.0 52.2 55.6 68.2 73.6 81.7 78.6 70.3 59.4 44.2 43.2

2013 36.5 35.1 41.2 54.9 64.8 74.7 80.6 74.7 68.0 60.6 45.5 38.7
- 14 -

Figure I-6: Philadelphia Area Monthly Mean Temperature (°F)

The Philadelphia Area was designated nonattainment for the 1997 PM2.5

NAAQS based on 2001-2003 monitoring data and nonattainment for the 

2006 PM2.5 NAAQS based on 2006-2008 monitoring data. These 

timeframes show typical year-to-year variation in temperature with no 

unusual conditions that would be expected to cause higher PM2.5

concentrations as experienced. The Philadelphia Area’s Clean Data 

Determinations for the 1997 and 2006 PM2.5 NAAQS were based on 

2007-2010, and 2008-2011 monitoring data, respectively. The 

Philadelphia Area continues to monitor attainment. Examination of the 

temperature data from 2006 through 2012 shows normal variation in 

seasonal temperatures but no evidence of unusual patterns that would be

expected to repress PM2.5 formation.

2. Precipitation Trends

Table I-6 presents monthly and annual precipitation data for the 

Philadelphia Area for 2001-2013. Figure I-6 graphically displays the

annual precipitation data.

0

10

20

30

40

50

60

70

80

90

degrees Fahrenheit

Monthly Mean Temperature
- 15 -

Table I-6: Philadelphia Area Precipitation (inches)

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Annual 

Total

2001 2.8 3.0 5.4 1.5 4.0 5.9 1.3 1.0 2.6 0.8 0.6 2.1 31.0

2002 2.4 0.6 4.0 2.2 3.6 3.7 2.1 2.5 3.7 5.9 4.7 4.1 39.4

2003 1.9 5.0 4.1 2.2 4.2 8.1 2.0 3.3 4.7 4.5 2.6 5.5 48.0

2004 1.7 2.5 3.5 6.0 3.6 4.6 7.9 4.2 5.2 2.2 4.6 3.2 49.2

2005 4.5 2.6 3.7 5.3 1.3 3.3 4.3 2.6 0.2 8.7 2.9 3.0 42.3

2006 4.3 1.5 0.9 3.7 2.2 7.9 4.3 3.9 6.0 6.4 4.9 2.1 48.2

2007 3.4 1.7 3.8 9.0 2.7 4.0 3.4 2.9 0.6 4.7 1.5 4.4 42.1

2008 1.7 3.9 3.7 2.2 4.6 2.9 3.4 2.4 4.3 1.6 4.0 5.6 40.4

2009 2.7 0.8 1.6 4.0 4.8 4.8 3.4 10.3 3.7 5.5 2.1 8.9 52.5

2010 2.2 5.8 7.3 2.6 2.5 2.1 6.3 2.2 3.5 5.0 1.8 3.2 44.5

2011 3.4 2.7 4.3 5.3 1.9 2.6 2.7 19.3 10.3 3.7 3.9 4.4 64.4

2012 2.6 1.8 0.8 2.5 3.4 2.9 1.5 5.4 5.5 4.1 1.1 4.4 36.0

2013 3.3 2.1 2.4 2.3 2.3 10.6 13.2 5.9 3.3 2.5 2.7 5.2 55.9

Figure I-7: Philadelphia Area Annual Precipitation (inches)

Examination of the precipitation data within the 2001-2003 and 

2006-2011 time periods shows year-to-year variation in precipitation 

amounts. There is no indication from the data that unusual precipitation 

patterns contributed to the lower PM2.5 concentrations in recent years in 

which the Philadelphia Area monitored attainment of the PM2.5 NAAQS.

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

2001 2003 2005 2007 2009 2011 2013

Precipitation (inches)

Annual Precipitation
- 16 -

D. Additional Trends

1. Population Trends

The Pennsylvania portion of the Philadelphia Area, which consists of

Bucks, Chester, Delaware, Montgomery and Philadelphia counties, has 

experienced population growth over the last decade. The population of the 

Pennsylvania portion of the Philadelphia Area increased approximately 

4 percent between the 2000 and 2010 Censuses. Population increases 

correspond with increased emissions from some types of emission sources 

and, therefore, can result in increased pollution levels. While the 

Pennsylvania portion of the Philadelphia Area’s population has grown 

approximately 4 percent over the last decade, this growth has not resulted 

in increased PM2.5 concentrations. In fact, the area’s PM2.5 concentrations 

have declined in spite of the increase in population.

Figure I-8: Population Trend for the Pennsylvania Portion of the Philadelphia Area

2. Economic Trends

Economic trends could have impacts on emissions and consequently affect 

PM2.5 concentrations in the Philadelphia Area. The two factors considered 

here include estimated labor force changes in the Pennsylvania portion of 

the Philadelphia 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, MidAtlantic Information Office. The Coincident Index data was obtained 

from the Philadelphia Reserve Bank.

 3,750,000

 3,800,000

 3,850,000

 3,900,000

 3,950,000

 4,000,000

 4,050,000

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Population of the Pennsylvania Portion of 

the Philadelphia Area

Population
- 17 -

Figure I-8 shows the Pennsylvania portion of the Philadelphia Area’s 

population change and estimated labor force change since 1990. A larger 

labor force could lead to more driving and increased infrastructure 

demands. This in turn could lead to higher emissions. Increases in the 

county’s labor force also contribute to overall increases in economic 

activity (greater family income/spending). The Philadelphia Federal 

Reserve Bank has tracked economic activity in Pennsylvania over the last 

25 years. Pennsylvania’s Economic Activity Index is graphically depicted 

in Figure I-9. In spite of these upward trends, air quality continues to 

improve in the Philadelphia Area.

Figure I-9: Philadelphia Area Population and Labor Force Trends

Data Source:

U.S. Department of Labor, Bureau of Labor Statistics, Mid-Atlantic Information Office

The database containing “State and local industry employment and earnings – monthly” data was accessed 

from the following site: www.bls.gov/ro3/data.htm

Pennsylvania’s Economic Activity Index is graphically depicted in 

Figure I-9. In spite of these upward trends, air quality continues to 

improve in the Philadelphia Area.

1,500,000.00

2,000,000.00

2,500,000.00

3,000,000.00

3,500,000.00

4,000,000.00

4,500,000.00

19901992199419961998200020022004200620082010

Population and Labor Force Trends 

Nonfarm Employment

Population
- 18 -

Figure I-10: Pennsylvania and National Coincident Indexes from the

Philadelphia Federal Reserve Bank

Data downloaded on 5/24/2012 from: The Federal Reserve Bank of Philadelphia at: 

www.philadelphiafed.org/research-and-data/regional-economy/indexes/coincident/

The Federal Reserve Bank of Philadelphia produces a monthly coincident 

index for each of the 50 states. The coincident indexes combine 

four state-level indicators to summarize current economic conditions in a 

single statistic. The four state-level variables in each coincident index are 

nonfarm payroll employment, average hours worked in manufacturing, the 

unemployment rate, and wage and salary disbursements deflated by the 

consumer price index (U.S. city average). The trend for each state’s index 

is set to the trend of its gross domestic product (GDP), so long-term 

growth in the state’s index matches long-term growth in its GDP.

E. Modeling Analysis

Modeling results for the EPA’s Cross-State Air Pollution Rule (76 FR 48207;

August 8, 2011)2(CSAPR or Transport Rule) were examined to determine if the 

model results support redesignating the Philadelphia Area to attainment. EPA’s 

analysis indicates that the Philadelphia Area would attain the 2006 PM2.5 NAAQS 

in 2014, even in the absence of either the Clean Air Interstate Rule (CAIR) or 

CSAPR.

EPA used the Comprehensive Air Quality Model with Extension (CAMx) 

version 5.3. CAMx is a three-dimensional Eulerian grid-based photochemical 

model designed to simulate the formation, chemical transformation, transport, and 

removal of ozone, secondary and directly emitted PM2.5, and their precursor 

 

2 “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
- 19 -

species on national, regional, and local scales for short-term episodes up to annual 

time periods. Using this model, EPA simulated the emissions from many 

different sources of pollution (such as electric generating units (EGU), and mobile 

sources). All of the CSAPR CAMx simulations used meteorology for 2005 

derived from simulations of the Pennsylvania State University/National Center for 

Atmospheric Research Mesoscale Model (MM5) version 3.7.4. The 2005 

emissions of SO2, NOX, VOC, NH3 and direct PM2.5 were modeled. The 

modeling was based on the annual PM2.5 design values for the 2003 through 2007 

base period.

EPA outlined the model results in the Air Quality Modeling Final Rule Technical 

Support Document for the Transport Rule. 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 Transport Rule modeling results for the PM2.5 

Standard for the Philadelphia Area) displays the results of EPA’s analysis for the 

Philadelphia Area. EPA’s analysis indicates that the Philadelphia Area would 

attain the 2006 PM2.5 NAAQS in 2014, even in the absence of either CAIR or the 

Transport Rule. The results support redesignation the Philadelphia Area to 

attainment for the PM2.5 NAAQS.
- 20 -

Table I-7: EPA’s Transport Rule Modeling Results for the PM2.5 Standard for the 

Philadelphia Area

Source: Air Quality Modeling Final Rule Technical Support Document for the Transport Rule

(http://www.epa.gov/airtransport/pdfs/AQModeling.pdf)

II. SIP APPROVALS AND APPLICABLE REQUIREMENTS

In order for EPA to redesignate a nonattainment area to attainment, the applicable SIP 

revision must be fully approved by the EPA under Section 110(k) of the CAA. In 

addition, the state must have met all requirements applicable to the area under 

Section 110 and Part D-Plan Requirements for Nonattainment Areas. The specific 

requirements applicable to the Philadelphia Area can be found in Sections 110(a)(2), and 

Part D Sections 172(c) (relating to nonattainment plan provisions), 173 (relating to permit 

requirements) and 176 (relating to limitations on certain federal assistance) of the CAA. 

The U.S. Court of Appeals for the District of Columbia circuit has also recently held that 

EPA must implement the PM2.5 NAAQS pursuant to Subpart 4 of Part D – see Section III 

below for more information.

These requirements have been fulfilled for the Pennsylvania portion of the Philadelphia 

Area.

Site ID County

Form of 

Standard

2003-2007 

Average 

Ambient 

Values

2003-2007 

Maximum 

Ambient 

Values

2012 Base 

Case 

Average 

Values

2012 Base 

Case 

Maximum 

Values

2014 Base 

Case 

Average 

Values

2014 Base 

Case 

Maximum 

Values

420170012 Bucks Annual 13.42 13.93 11.32 11.74 10.98 11.38

420290100 Chester Annual 15.22 15.22 12.88 12.88 12.54 12.54

420450002 Delaware Annual 15.23 15.69 12.85 13.23 12.51 12.88

421010047 Philadelphia Annual 15.19 15.19 12.90 12.90 12.52 12.52

100031003 New Castle Annual 13.73 14.33 11.48 11.97 11.16 11.64

100031007 New Castle Annual 12.92 13.41 10.74 11.16 10.45 10.86

100031012 New Castle Annual 13.69 13.88 11.46 11.62 11.15 11.30

100032004 New Castle Annual 14.87 15.11 12.51 12.72 12.17 12.37

340070003 Camden Annual 13.31 13.40 11.20 11.28 10.89 10.96

340071007 Camden Annual 13.51 13.78 11.31 11.52 10.96 11.17

340155001 Gloucester Annual 13.46 13.46 11.28 11.28 10.97 10.97

420170012 Bucks 24-hour 34.0 34.8 28.5 29.0 27.0 27.4

420290100 Chester 24-hour 36.7 36.7 31.0 31.0 30.0 30.0

420450002 Delaware 24-hour 35.2 35.9 29.3 30.0 28.3 29.1

421010004 Philadelphia 24-hour 36.5 36.7 29.7 30.0 28.5 28.9

421010024 Philadelphia 24-hour 35.9 35.9 28.9 28.9 27.3 27.3

421010047 Philadelphia 24-hour 37.3 37.7 30.2 30.6 29.2 29.5

100031003 New Castle 24-hour 34.3 34.3 28.0 28.0 27.1 27.1

100031007 New Castle 24-hour 32.6 34.5 24.6 25.6 23.5 24.3

100031012 New Castle 24-hour 33.5 33.5 27.7 27.7 26.8 26.8

100032004 New Castle 24-hour 36.6 36.7 29.5 29.7 28.4 28.6

340070003 Camden 24-hour 36.5 38.6 29.3 31.2 28.1 30.1

340071007 Camden 24-hour 37.3 38.8 29.7 30.8 28.3 29.3

PM2.5 Design Values (μg/m3)
- 21 -

A. Section 110(a)(2) of the CAA

Section 110(a) of the CAA contains the general requirements for a SIP. 

Pennsylvania concludes that, as EPA has stated in previous rulemaking in another 

state3, only the Section 110 and Part D requirements that are linked with a 

particular area’s designation are the relevant measures to consider in evaluating a 

redesignation request. Further, Pennsylvania believes that the other Section 110 

elements that are not connected with nonattainment plan submissions and not 

linked with an area’s attainment status are also not applicable requirements for 

purposes of redesignation. A state remains subject to these requirements after an

area is redesignated to attainment.

The requirements of Section 110(a)(2) of the CAA that are statewide 

requirements and that are not linked to the PM2.5 nonattainment status of the 

Philadelphia Area are not applicable requirements for purposes of review of the 

Commonwealth’s PM2.5 Request for Redesignation. However, EPA requires that 

the Commonwealth’s Prevention of Significant Deterioration (PSD) requirements 

be approved prior to redesignation, because PSD requirements will apply after 

redesignation. Sections 110(a)(2)(C) and 110(a)(2)(J) of the CAA require state 

plans to meet the requirements of CAA, Subchapter I, Part C, which contains PSD 

requirements. In addition, Section 110(a)(2)(I) requires that a plan revision for an 

area designated as a nonattainment area meet the applicable requirements of 

CAA, Subchapter I, Part D (relating to nonattainment areas). Therefore, 

Pennsylvania has concluded that only the parts of Sections 110(a)(2)(C), 

110(a)(2)(I) and 110(a)(2)(J) that relate to Part D applicable requirements or PSD 

are applicable for purposes of redesignation.

EPA has previously approved provisions of Pennsylvania’s SIP addressing 

Section 110 requirements, including provisions addressing PM2.5. Pennsylvania’s 

SIP measures meeting Section 110(a)(2)(C) and 110(a)(2)(J) requirements are 

fully approved under Section 110(k) of the CAA. The Maintenance Plan 

associated with this Request for Redesignation for the Philadelphia Area is a SIP 

revision for an area designated as a nonattainment area and meets the applicable 

requirements of Part D of Subchapter I of the CAA. Therefore, the Maintenance 

Plan associated with this Request for Redesignation meets the requirements of 

Section 110(a)(2)(I). Please see the discussion below concerning Part D (plan 

requirements for nonattainment areas).

 

3 See EPA’s proposed approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland 

nonattainment area for the 1997 PM2.5 NAAQS (76 FR 79593). On December 31, 2012, EPA published final 

approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland nonattainment area for the 

1997 PM2.5 NAAQS (77 FR 76883).
- 22 -

B. Part D - Plan Requirements for Nonattainment Areas

1. Section 172(c) of the CAA

Section 172 of the CAA contains the general provisions required to be 

included in SIP revisions for nonattainment areas. These include 

attainment demonstrations, reasonably available control measures, 

reasonable further progress, inventory data, and permitting requirements.

As stated above, on May 15, 2012, the EPA determined that the 

Philadelphia Area had attained the 1997 PM2.5 NAAQS (“Clean Data 

Determination”) (77 FR 28782). EPA’s Clean Data Determination was 

based on quality-assured, quality-controlled and certified ambient air 

monitoring data that show the area had monitored attainment since the 

2007-2009 and 2008-2010 monitoring periods. The Clean Data 

Determination suspended the requirements for this area to submit an 

attainment demonstration, associated reasonably available control 

measures, a reasonable further progress plan, contingency measures, and 

other planning SIP revisions related to attainment of the 1997 PM2.5

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

On January 7, 2013, the EPA determined that the Philadelphia Area had 

attained the 2006 PM2.5 NAAQS based on quality assured, quality 

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

monitored attainment based on 2008-2010 and 2009-2011 data (“Clean 

Data Determination”) (78 FR 882). This final action suspended the 

requirements for this area to submit an attainment demonstration and 

associated reasonably available control measures, reasonable further 

progress plans, contingency measures and other planning SIP revisions 

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

continues to attain the 2006 PM2.5 NAAQS.

Submittal of a comprehensive inventory is required by 40 CFR

Section 51.1008 to meet the requirements of Section 172(c)(3) of the 

CAA. This requirement was not suspended by the Clean Data 

Determination. In fulfillment of this requirement, the 2007 inventory, 

which also serves as the attainment year inventory, is being submitted as 

part of the Maintenance Plan, submitted concurrently with this Request for 

Redesignation.

2. Section 173 of the CAA

Section 173 of the CAA outlines requirements related to permitting of air 

pollution sources in nonattainment areas.
- 23 -

Stationary air pollution sources are subject to the regulations of the 

Commonwealth of Pennsylvania, Pennsylvania Code in Title 25 

Environmental Resources (25 Pa. Code Chapters 121-145). These 

regulations include:

● Standards of Performance for New Stationary Sources 

promulgated by EPA under the Clean Air Act (25 Pa. Code

Chapter 122);

● Standards for Contaminants (25 Pa. Code Chapter 123);

● National Emission Standards for Hazardous Air Pollutants (25 Pa. 

Code Chapter 124);

● Construction, Modification, Reactivation and Operation of 

Sources, including plan approval, prevention of significant 

deterioration, new source review, operating permit program 

(25 Pa. Code Chapter 127);

● Standards for Sources (25 Pa. Code Chapter 129); and

● Annual Emission Statements and required reporting to the 

Department (25 Pa. Code Chapter 135).

These permitting, stationary source monitoring and reporting, 

preconstruction review, offset ratios and enforceable emission limitations 

requirements were adopted to implement the federally mandated 

requirements in Sections 110, 172, 173 and 182(a) of the CAA. EPA has 

approved all of these regulations as SIP revisions, as indicated in 

Section III of this document.

3. Section 176 of the CAA

Section 176(c) of the CAA contains the provision prohibiting federal 

financing of projects or activities that do not conform to an approved 

implementation plan.

The Commonwealth adopted and incorporated EPA’s General Conformity 

rule (40 CFR Part 93, Subpart B) by reference in its entirety in 25 Pa. 

Code Section 127.802. The General Conformity regulation describes 

procedures to determine if federally-financed, non-transportation projects 

are in conformity with air quality plans.

EPA and the U.S. Department of Transportation (DOT) have issued 

regulations regarding criteria and procedures for demonstrating and 

assuring conformity of transportation improvement programs (TIP or 
- 24 -

program), long range plans (LRP or plan), and individual transportation 

projects with the requirements of the CAA and the SIP for the specific 

nonattainment area. Affected transportation planning organizations are 

complying with all federal laws, regulations and guidance for 

transportation conformity.

4. Section 189(e) of the CAA

In light of a recent court decision, Natural Resources Defense Council v. 

EPA, No. 08-1250, 706 F.3d 428 (D.C. Cir. 2013) (see discussion in 

Section III), the Department considered Section 189(e) of the CAA. 

According to Section 189(e) and the court decision, control requirements 

in nonattainment areas applicable for major stationary sources of PM also 

apply to major stationary sources of PM precursors. Pennsylvania 

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

maintenance demonstration. Please see Section III-C-1 relating to control 

measures for stationary sources for a discussion of the stationary source 

control measures in place in the Philadelphia Area.

C. Conclusion

The requirements of Section 110(a) and Subpart D of the CAA have been fulfilled

in the Philadelphia Area for the 1997 and 2006 PM2.5 NAAQS. 

III. DEMONSTRATION OF PERMANENT AND ENFORCEABLE IMPROVEMENT

This section provides an assessment of the PM2.5 and PM2.5 precursor emissions at a time 

the Philadelphia Area was monitoring nonattainment of the PM2.5 NAAQS and at the 

time when this area attained the PM2.5 NAAQS.4 A 2002 (baseline) inventory of PM2.5

and PM2.5 precursor emissions is used to represent emissions during the PM2.5

nonattainment designation period. A 2007 inventory is used to identify PM2.5 and PM2.5

precursor emissions during a period when the Philadelphia Area demonstrated that it 

attained the PM2.5 NAAQS. Detailed information is presented in the Maintenance Plan 

by sector.

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

the EPA recognizes that effective control measures for PM2.5 will vary among 

nonattainment areas. This recognition was reflected in EPA’s “Implementation Guidance 

for the 2006 24-Hour Fine Particle National Ambient Air Quality Standard,” Office of 

Air Quality Planning and Standards, EPA, March 2, 2012 (“Implementation Guidance for 

the 2006 24-Hour PM2.5 NAAQS”). In the Implementation Guidance for the 2006 PM2.5

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

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

Implementation Rule (72 FR 20586; April 25, 2007) (the Implementation Rule for the 

1997 PM2.5 NAAQS”).

 

4 Due to rounding, numbers presented throughout this document may not add up precisely to the totals provided.
- 25 -

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

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

possible controls. In that earlier rule, the EPA required states to evaluate control 

measures for SO2 and primary PM2.5 in all locations. The EPA required states to evaluate 

control measures for NOX unless a technical demonstration is made to show NOX does 

not significantly contribute to PM2.5. The EPA required states to evaluate measures for 

VOC and NH3 only if a technical demonstration is made to show they significantly 

contribute to PM2.5 in that area.

The EPA reaffirmed the appropriateness of these presumptions in its Implementation 

Guidance for the 2006 24-Hour PM2.5 NAAQS. Meanwhile, the U.S. Court of Appeals 

for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997 

PM2.5 NAAQS, in Natural Resources Defense Council v. EPA, No. 08-1250. On 

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

The Court granted the petitions for review and remanded the case to EPA to repromulgate the rule pursuant to Subpart 4 of Part D of the Clean Air Act, rather than 

implementing it under Subpart 1, as EPA had done (706 F.3d 428, 437 (D.C. Cir. 2013)). 

Shortly thereafter, the EPA withdrew its Implementation Guidance for the 2006 24-Hour 

PM2.5 NAAQS. According to EPA’s June, 2013 withdrawal memorandum (see 

second page of memorandum)5, EPA withdrew the guidance in response to the Court’s 

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

The Maintenance Plan accompanying this Request for Redesignation demonstrates 

maintenance of the standards consistent with the Court’s ruling.

In general, the Court’s decision (for the 1997 PM2.5 NAAQS and to the extent it would be 

extrapolated to the 2006 24-Hour PM2.5 NAAQS) could affect an area’s nonattainment 

classification, certain deadlines, and the impacts of failing to attain timely, and could 

impose a deadline for implementation of reasonably available and best available control 

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

1997 and 2006 PM2.5 NAAQS, those considerations are not relevant for this Request for 

Redesignation and the Maintenance Plan. The Court noted that PM2.5 precursors, 

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

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

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

Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to Section 189(e) of the 

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

major stationary sources of PM10 precursors, except where the Administrator determines 

that major stationary sources do not contribute significantly to PM10 levels that exceed 

the standard in the area; Section 189(e) also requires EPA to issue guidelines regarding 

 

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

Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013.
- 26 -

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

VOC and NH3 for the maintenance demonstration. 

This Request for Redesignation provides emissions information for all pollutants (PM10, 

PM2.5, SO2, NOX, VOC and NH3), as required by EPA’s guidance entitled, “Emissions 

Inventory Guidance for Implementation of Ozone and Particulate Matter National 

Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.”

6

Section III

first describes the PM2.5 and PM2.5 precursor emission estimates for the Philadelphia 

Area. These inventories have been developed in accordance with EPA emission 

inventory preparation guidance. The section then presents information about the 

permanent and enforceable control measures that have been implemented in the 

Philadelphia Area to produce the PM2.5 and PM2.5 precursor emission reductions that 

have occurred between these years and that will provide emission reductions ensuring 

maintenance of the PM2.5 standards.

A. Baseline (2002) Emissions Inventory

An emissions inventory for 2002, which is being used as a base year inventory for 

both the 1997 and 2006 NAAQS, was developed for PM10, PM2.5, SO2, NOX, 

VOC and NH3 in accordance with EPA guidance. On August 28, 2012 

(77 FR 51930), EPA approved the base year emissions inventory for 2002 as part 

of the 1997 annual PM2.5 NAAQS attainment plan for the Pennsylvania portion of 

the Philadelphia area which also included the modeled attainment demonstration, 

motor vehicle budgets, and contingency measures. The motor vehicle budgets 

were subsequently amended and approved as a SIP revision on April 3, 2013 

(78 FR 19992). The baseline year inventory represents the emissions present 

when the Philadelphia Area did not meet the 1997 annual and 2006 24-hour PM2.5

standards. The inventory contains information 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.

● “Area sources,” which are industrial, commercial, and residential sources 

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

are not limited to commercial and residential open burning, architectural 

and industrial maintenance coatings application and clean-up, consumer 

product use, and vehicle refueling at service stations. Where there is 

overlap between stationary point sources and stationary area sources, the 

area source values are adjusted to remove any double counting.

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

other trucks, buses and motorcycles. 

 

6 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.
- 27 -

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

including but not limited to outdoor power equipment, recreational 

vehicles, farm and construction machinery, lawn and garden equipment, 

industrial equipment, recreational marine vessels, commercial marine 

vessels, locomotives, ships, and aircraft.

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

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

emissions inventory. The Mid-Atlantic Regional Air Management Association

(MARAMA) coordinated that regional effort, which allowed states to pool their 

resources to compile a regional emissions inventory for the purpose of conducting 

the regional modeling analysis used in Pennsylvania’s air quality management 

planning efforts to attain the 8-hour ozone NAAQS and the PM2.5 NAAQS, and to

prepare the Regional Haze SIP revision.

Table III-1: 2002 Pennsylvania portion of the Philadelphia Area Annual Emissions

(Tons per Year)

Philadelphia 2002 PM2.5 PM10 SO2 NOX VOC NH3

Stationary Point Sources 2,139 3,430 23,745 22,124 8,183 256

Area Sources 10,020 55,224 13,153 13,029 59,227 4,821

Highway Vehicle Sources 2,905 3,497 1,848 90,879 32,150 1,451

Non-Road Sources 1,535 1,611 1,640 21,619 21,589 14

Totals 16,598 63,763 40,387 147,651 121,149 6,542

A summary of the 2002 inventory is shown in Table III-1. The 2002 inventory, 

which is being used as a base year inventory for both the 1997 and 2006 NAAQS,

is not directly comparable to the 2007, 2017 and 2025 inventories because of 

changes in inventory methodology and the adjustment made to account for 

condensable PM emissions from EGUs in the 2007, 2017 and 2025 emission 

inventories. The Technical Appendices to the Maintenance Plan contain more 

detailed information about the 2002 emissions for each sector.

B. Attainment Year (2007) Emissions Inventory

A 2007 inventory of PM10, PM2.5, SO2, NOX, VOC and NH3 emissions for the 

Pennsylvania portion of the Philadelphia Area is used to identify emissions during 

the period when attainment of the 1997 PM2.5 NAAQS was demonstrated for the 

Philadelphia Area. For the 2006 PM2.5 NAAQS, the 2007, 2008 and 2025 

emission inventories were evaluated to show that the 2007 emission inventory is 

an appropriate and representative emission inventory to use as a surrogate 

attainment emission inventory for the 2008 emission inventory, a year when 

attainment of the 2006 PM2.5 NAAQS was demonstrated. That evaluation is 

contained in Appendix F of the Maintenance Plan.
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A summary of the 2007 inventory is provided in Table III-2.

Table III-2: 2007 Pennsylvania Portion of the Philadelphia Area Annual Emissions

(Tons per Year)

Philadelphia 2007 PM2.5 PM10 SO2 NOX VOC NH3

Stationary Point Sources 2,444 3,442 19,633 20,744 6,281 743

Area Sources 7,722 23,546 15,005 12,925 47,568 3,293

Highway Vehicle Sources 2,386 2,985 508 69,327 29,293 1,270

Non-Road Sources 1,562 1,663 3,375 20,393 18,751 23

Totals 14,114 31,635 38,520 123,390 101,894 5,329

PM2.5, SO2, NOX, VOC, and NH3 emissions decreased by 15 percent, 5 percent, 

16 percent, 16 percent and 19 percent, respectively, from 2002 to 2007. The

permanent and enforceable reductions of direct PM2.5, SO2, NOX and VOC 

emissions between 2002 and 2007, as described in more detail in Section III-C, 

led to the improvement in air quality observed in that time period. 

The 2002 inventory was based on emissions reported to the Department by 

facilities and did not include condensable PM for many facilities. The 2007 EGU 

inventory was augmented utilizing the updated condensable emission factors for 

EGUs developed for MARAMA in 2008 to calculate condensable PM emissions 

where that data was missing.

The Maintenance Plan describes how the 2007 inventory was compiled. The 

Technical Appendices to the Maintenance Plan contain more detailed information 

for each sector.

C. Control Measures

Along with the analysis of ambient air quality and contributing factors in 

Section I of this Request for Redesignation, this section describes the permanent 

and enforceable federal and state measures in the Pennsylvania portion of the 

Philadelphia Area that provided PM2.5, SO2, NOX and VOC emission reductions 

from 2002 to 2007 to bring the Philadelphia Area into attainment and measures 

that will assure maintenance of the standards. 

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

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

for the 1997 PM2.5 NAAQS. However, Pennsylvania recognizes the Court 

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

706 F.3d 428 (D.C. Cir. 2013) and EPA’s subsequent withdrawal of the 

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

In general, the Court’s decision (for the 1997 PM2.5 NAAQS and to the extent it 

would be extrapolated to the 2006 24-Hour PM2.5 NAAQS) could affect an area’s 
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nonattainment classification, certain deadlines, and the impacts of failing to attain 

timely, and could impose a deadline for implementation of reasonably available 

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

Philadelphia Area is already attaining the 1997 and 2006 24-Hour PM2.5 NAAQS, 

however, those considerations are not relevant for this Redesignation Request or 

the accompanying Maintenance Plan.

The Court noted that PM2.5 precursors are presumptively regulated in PM2.5

nonattainment areas under Subpart 4, pointing specifically to Section 189(e), 

which applies to control of major stationary sources of PM10 [the court stated that 

PM10 includes PM2.5 throughout Subpart 4]. (706 F.3d at 436, n. 7, and at 

437, n. 10). According to CAA Section 189(e), control requirements applicable 

for major stationary sources of PM10 also apply to major stationary sources of 

PM10 precursors, except where the Administrator determines that major stationary 

sources do not contribute significantly to PM10 levels that exceed the standard in 

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

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

NOX, VOC and NH3 for the maintenance demonstration.

Emissions of PM2.5, SO2, NOX, VOC and NH3 in the Pennsylvania portion of the 

Philadelphia Area decreased by 15 percent, 5 percent, 16 percent, 16 percent and 

19 percent, respectively, from 2002 to 2007. The permanent and enforceable 

reductions of direct PM2.5, SO2, NOX and VOC emissions, as described in more 

detail in the following sections, led to the improvement in air quality observed in 

that time period. As noted above, the decrease in PM2.5 emissions is a 

conservative estimate because the 2007 inventory was augmented to account for 

condensable PM. A summary of the quantity of emission reductions from 2002 to 

2007 is included in Table III-3. The negative values in Table III-3 indicate 

emission reductions.

Table III-3: Change in the Pennsylvania Portion of the Philadelphia Area Annual 

Emissions (Tons per Year) from 2002 to 2007

Change from 2002 to 2007 PM2.5 PM10 SO2 NOX VOC NH3

Stationary Point Sources 305 11 -4,112 -1,380 -1,903 487

Area Sources -2,298 -31,678 1,852 -105 -11,659 -1,529

Highway Vehicle Sources -518 -512 -1,340 -21,552 -2,856 -181

Non-Road Sources 27 51 1,735 -1,226 -2,838 9

Total -2,484 -32,128 -1,866 -24,262 -19,256 -1,213

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

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

standards.

A summary of the total emissions in 2007 and projected estimates for 2017 and 

2025 is included in Table III-4. The emission estimates account for any 
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anticipated growth in the activity of sources and include a transportation 

conformity safety margin for PM2.5 and NOX. For all pollutants, emissions in

2017 and 2025 in the Philadelphia Area are anticipated to be lower than they were 

in 2007. This means that the projected growth in emissions is smaller than 

anticipated emission reductions from control measures for all pollutants. In 

addition, the Philadelphia Area currently has an annual design value based on 

2010-2012 monitoring data of 13.1 μg/m,

3 which is significantly lower than the 

1997 NAAQS of 15 μg/m.

3

 Based on 2010-2012 monitoring data, the 

Philadelphia Area also has a 24-hour design value of 31 μg/m3 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

Philadelphia PM2.5 PM10 SO2 NOX VOC NH3

2007 14,114 31,635 38,520 123,390 101,894 5,329

2017* 12,643 30,947 29,432 82,028 80,645 5,117

2025* 11,795 30,916 25,674 67,996 74,916 5,162

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

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

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

1. Stationary Point Sources

Background for Pennsylvania’s Stationary Source Permitting 

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

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

assembly, installation of new sources, modification of any existing 

stationary air contamination sources, or the installation of air pollution 

control equipment or devices. Following the construction of the new 

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

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

depend on the quantity of regulated pollutants emitted from the air 

contamination sources. DEP will issue a “State-only Operating Permit” 

for minor air contamination stationary sources that are below the 

applicability thresholds for Title V facilities. A “Title V Operating 

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

contaminants exceeding the Title V thresholds. The Title V Permit, which 

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

for the facility in a single federally enforceable operating permit.

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

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

associated definitions in 25 Pa. Code Chapter 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 
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and approval of pre-construction and operating permits for both major and 

non-major air contamination sources. The provisions of Chapter 127 have 

been codified in the SIP at 40 CFR § 52.2020(c)(1) at various times since 

May 31, 1972 and most recently on October 5, 2012, and are therefore all 

federally enforceable. 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

Section 121.1. The purpose of the Title V program is to detail a 

facility’s air quality requirements in a single permit document so 

that industry, the regulatory agency, and the public know exactly 

what regulations and requirements apply and how the facility’s 

owner or operator will monitor and demonstrate compliance with 

all applicable requirements. The Title V permit includes all 

sources at a site including all air pollution control devices as well 

as activities that were determined to be insignificant sources of 

emissions. Each source is described in detail within a section of 

the Title V permit. The requirements include general conditions 

applicable to all Title V facilities, emission restrictions, detailed 

monitoring, recordkeeping, and reporting requirements to assure 

compliance with the facility’s applicable federal and state 

requirements. The Title V Operating Permits Program 

requirements are codified in 25 Pa. Code Chapter 127, 

Subchapters F and G. The program was fully approved by EPA on 

July 30, 1996 (61 FR 39597).

Nonattainment New Source Review and Prevention of 

Significant Deterioration. Major facilities proposed in 

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

requirements in nonattainment areas and Prevention of Significant 

Deterioration (PSD) requirements in areas of the Commonwealth 

designated attainment for National Ambient Air Quality Standards 

including carbon monoxide, particulate matter (PM), lead, nitrogen 

dioxide (NO2), ozone and sulfur dioxide (SO2). Generally, NSR 

permit requirements are applicable to a facility located in a 

nonattainment area for a particular pollutant with a potential to 

emit 50 tons or more per year (tpy) of volatile organic compounds 

or 100 tpy or more of NOX, SO2, PM or carbon monoxide. It 

should be noted that the entire Commonwealth, included in the 

Ozone Transport Region by operation of law, is treated as a 

“moderate” ozone nonattainment area, irrespective of the area’s 

attainment status. Because NOX and VOC are precursors of PM2.5, 

NOX and VOC emission reductions required statewide under the 

nonattainment NSR program for ozone also allow Pennsylvania to 
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make substantial progress in attaining and maintaining the PM2.5

NAAQS. Any major stationary source or major modification 

subject to the NSR requirements must receive a plan approval. To 

receive approval from the Department, a person must show that the 

proposed source will, among other things, offset its potential to 

emit air contaminants including NOX, PM and VOCs by securing 

emission reductions credits at the specified offset ratio, will 

employ the “lowest achievable emission rate” (LAER) for each 

regulated pollutant and conduct an alternative analysis. The 

nonattainment NSR requirements are codified in 25 Pa. 

Chapter 127, Subchapter E and approved as a SIP revision on 

December 9, 1997 (62 FR 64722).

The PSD program is a pre-construction review and permitting 

program applicable to new or modified major stationary sources 

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

requirements are applicable to major sources in areas attaining the 

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

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

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

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

Subchapter D, were approved by the EPA on August 21, 1984 and 

codified at 4 CFR § 52.2058 (49 FR 33128).). PSD permit 

requirements may apply to 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, nitrogen 

dioxide, ozone, particulate matter and sulfur dioxide depending on 

the source category. Any major stationary source or major 

modification subject to the PSD requirements must conduct an 

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

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

ambient air quality analysis, analyze the impacts to soils, 

vegetation and visibility and make sure that the project will not 

adversely impact mandatory federal Class I areas including 

national parks greater than 6,000 acres and national wilderness 

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

Best Available Technology Program. The Department’s Best 

Available Technology (BAT) Program ensures that new stationary 

sources will prevent, reduce or control emissions of air

contaminants to the maximum degree possible. The Department 

determines BAT requirements on a case-by-case basis for both 

major and minor stationary sources taking into account energy, 

environmental benefits and costs. Pursuant to 25 Pa. Code

§ 127.1, the emission of air pollutants from new sources in 

Pennsylvania must be controlled to the maximum extent, 
- 33 -

consistent with the best available technology 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), an application for 

a plan approval must show that the emissions from a new source 

will be the minimum attainable through the use of the best 

available technology. Pennsylvania regulations define “best 

available technology” in 25 Pa. Code § 121.1 as, “Equipment, 

devices, methods or techniques as determined by the Department 

which will prevent, reduce or control emissions of air contaminants 

to the maximum degree possible and which are available or may be 

made available.” The Department’s BAT regulations, codified in 

25 Pa. Code §§ 127.1 and 127.12(a)(5), were approved by EPA on 

July 30, 1996, and codified in the SIP at 40 CFR § 52.2020(c)(1).

NOX and SO2 Control Programs. In 1998, EPA promulgated the NOX

SIP Call as the EPA’s principal effort to reduce interstate transport of air 

pollution (63 FR 57356; October 27, 1998). In response to the federal 

NOX SIP call rule, Pennsylvania adopted the NOX Budget Trading 

Program regulations for EGUs and large industrial boilers, with emission 

reductions to commence May 1, 2003. The regulations were approved by 

EPA as a revision to the Commonwealth’s SIP on August 21, 2001 

(66 FR 43795). Additionally, in response to the NOX SIP Call, 

Pennsylvania adopted additional NOX control regulations covering cement 

plants and internal combustion engines, with emission reductions to 

commence May 1, 2005. These regulations were approved by EPA as a 

SIP revision on September 29, 2006 (71 FR 57428).

Clean Air Interstate Rule (CAIR). In 2005, EPA adopted CAIR 

(70 FR 25162; May 12, 2005, as amended) to address interstate 

transport of NOX and SO2. CAIR is now being implemented in 

Pennsylvania through the Department’s CAIR regulation, codified 

in 25 Pa. Code Chapter 145, Subchapter D, with related 

amendments in Chapters 121, 129 and 145. EPA approved 

Pennsylvania’s CAIR SIP revision on December 10, 2009, codified 

at 40 CFR § 52.2020(c)(1) (74 FR 65446). In the CAIR SIP 

revision, Pennsylvania terminated the NOX Budget Trading 

Program and transitioned to the federal CAIR for large electric 

generating units (EGU).

The market-based CAIR is designed to reduce EGU emissions of 

NOX and SO2 below 2002 levels throughout the eastern United 

States. Pennsylvania and the other CAIR states were required to 

adopt a regulation implementing the requirements of the CAIR or 

an equivalent program. The large EGUs in Pennsylvania were 

initially regulated under CAIR FIPs promulgated by EPA, but have 

been regulated under the SIP since EPA approved Pennsylvania’s 
- 34 -

CAIR SIP revision. Under the SIP revision, Pennsylvania 

participates in the EPA-administered cap-and-trade programs for 

NOX annual, NOX ozone season, and SO2 annual emissions.

EPA’s CAIR was remanded to 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, 

EPA replaced CAIR with the Cross-State Air Pollution Rule 

(Transport Rule), but in a separate legal challenge the court 

vacated the Transport Rule. In that ruling, the court ordered EPA 

to continue administering CAIR pending the promulgation of a 

valid replacement (See, EME Homer City Generation L.P. v. EPA, 

696 F.3d 7 (D.C. Cir. 2012). On April 29, 2014, the Supreme 

Court of the United States reversed the Court of Appeals’ decision 

that had vacated the Transport Rule. The Supreme Court 

remanded the case to the Court of Appeals for further proceedings. 

At the time of submittal of this SIP revision, the Transport Rule is 

under a stay previously imposed by the Court of Appeals and

CAIR continues to be implemented.

NOX Budget Trading Program limits on non-EGUs. The CAIR 

SIP revision also established emission limits for the non-EGUs and 

other units that were subject to the Commonwealth’s NOX Budget 

Trading Program but are not subject to the CAIR NOX Ozone 

Season Trading Program. These units must continue monitoring 

NOX emissions and must meet an emissions cap. Each unit has an 

allowable emission rate, calculated by January 31 of each year, 

based on the previous ozone season’s heat input. If the combined 

NOX ozone season emissions from all of these units exceed the 

statewide ozone season emission cap of 3,438 tons, each unit that 

exceeds its individual allowable emissions limit for that ozone 

season must surrender to the Department one CAIR NOX ozone 

season allowance and one CAIR NOX annual allowance for each 

ton of emissions over its allowable limit. In addition, the 

Department has set aside 181 tons of NOX, including tons that will 

be retired each year to compensate for sources that were exempted 

under the “twenty-five ton exemption” in section 145.4(b) 3. The 

balance of tons remaining in the set aside is available to the 

Department annually for accounting corrections. The Department

retires any unused amount from this set aside each year.

It is unlikely that the 3,438-ton statewide NOX ozone season 

emission limitation will be exceeded. Pennsylvania’s non-EGU 

sources’ total emissions during each of the years they were trading 
- 35 -

under the NOX Budget Trading Program never exceeded the 

statewide cap of 3,438 tons.

The Department’s regulation, codified in 25 Pa. Code § 145.8(d), 

was approved by 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 updating the 

cement manufacturing and large stationary internal combustion 

engine regulations that were adopted pursuant to the NOX SIP Call. 

Until 2009, cement kilns and large stationary internal combustion 

engines that were subject to the NOX SIP Call were required to 

surrender NOX SIP Call allowances if they exceeded their NOX

emission limits set forth in Department regulations. Because the 

Department discontinued the NOX Budget Trading Program 

beginning 2009, at which point NOX SIP Call allowances were 

replaced by CAIR NOX ozone season allowances, the Department 

modified the regulations to require surrender of CAIR NOX ozone 

season and CAIR NOX annual allowances for emission limit 

exceedances.

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 

EPA as a SIP revision on December 10, 2009, and codified at 

40 CFR § 51.2020(c)(1). An amendment to the Department’s 

regulation for cement kilns to reduce NOX emissions effective 

April 15, 2011, codified in 25 Pa. Code Chapter 145, 

Subchapter C, was subsequently approved by EPA as a SIP 

revision on July 19, 2011, and codified at 40 CFR § 51.2020(c)(1).

Federal Standards for Hazardous Air Pollutants. Federal standards to 

control hazardous air pollutants (HAPs) require Maximum Achievable 

Control Technology (MACT) at units located at major sources of HAPs. 

The EPA has promulgated a series of MACT regulations that are 

applicable to sources in Pennsylvania. These MACT standards are 

adopted and incorporated by reference in Section 6.6 of Pennsylvania’s 

Air Pollution Control Act and implementing regulations in 25 Pa. Code

§ 127.35 (relating to maximum achievable control technology standards 

for hazardous air pollutants). The standards are also included in federally 

enforceable plan approvals and permits issued by DEP for affected 

sources.
- 36 -

2. Highway Vehicle Sources

Even with increases in vehicle miles travelled (VMT) that occurred 

between 2002 and 2007, and are anticipated to occur from 2007 through 

2025, highway vehicle emissions will continue to decrease. As more 

vehicles subject to cleaner new car standards replace older vehicles subject 

to less stringent new vehicle standards, the fleet as a whole emits fewer 

emissions, compensating for the increase in VMT. These decreases can be 

attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) and 

Pennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established 

by the CAA Amendments of 1990 include NOX and VOC limits for lightduty gasoline vehicles (LDGVs) and light-duty gasoline trucks (LDGTs). 

These standards began to be phased in 1994. Evaporative VOC emissions 

were reduced in gasoline-powered cars starting with Model Year 

(MY) 1998.

In 1998, under the authority of Section 177 of the CAA, the Pennsylvania 

Environmental Quality Board (EQB) adopted the Pennsylvania Clean 

Vehicles Program (28 Pa.B. 5873; Dec. 5, 1998). The Pennsylvania Clean 

Vehicles Program incorporates by reference certain California Low 

Emission Vehicle (CA LEV) emission standards for passenger cars and 

light-duty trucks. As required under Section 177 of the CAA, these 

provisions are identical to the low emission standards adopted by 

California. The regulation does not incorporate by reference the 

California zero emissions vehicle (ZEV) or emissions control warranty 

systems statement provisions.

In the same rulemaking, the EQB adopted the National Low Emission 

Vehicle (NLEV) program as a compliance alternative to the Pennsylvania 

Clean Vehicles Program. The NLEV program became effective in the 

Ozone Transport Region (OTR) in 1999. Pennsylvania’s New Motor 

Vehicle Emissions Control Program regulations in 25 Pa. Code

§§ 126.401-126.441 allowed automobile manufacturers to comply with 

NLEV instead of the CA LEV program through MY 2005. These 

regulations affected vehicles 6,000 pounds and less and were the 

regulations in effect for new motor vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV 

(Tier 2), starting with MY 2004. The NLEV program was replaced for 

MY 2004 and later by the more stringent Federal “Tier 2” vehicle 

emissions regulations (65 FR 6698; Feb. 10, 2000), and vehicle 

manufacturers operating under the NLEV program became subject to the 

Tier 2 requirements.
- 37 -

Pennsylvania amended the former New Motor Vehicle Control Program in 

2006. The Clean Vehicles Program continues to incorporate the 

California Low Emission Vehicle Program (CA LEV II) by reference. As 

amended, the program affects MY 2008 and newer passenger cars and 

light-duty trucks vehicles (36 Pa.B. 7424; Dec. 9, 2006, corrected 

37 Pa.B. 209; Jan. 12, 2007, eff. Dec. 9, 2006). EPA approved 

Pennsylvania’s Clean Vehicle Program as a revision to the 

Commonwealth’s SIP on January 24, 2012 (77 FR 3386).

Heavy-Duty Diesel Control Programs. The EPA promulgated more 

stringent national regulations for heavy-duty engines and vehicles (over 

14,000 pounds) starting with MY 2004. In addition, consent decrees with 

seven of the largest heavy-duty engine manufacturers required, among 

other terms, that diesel engines made by these companies comply with 

these 2004 standards two model years early, in MY 2002. The emission 

reductions from these programs are reflected in the future year emission 

inventories, as provided in the Motor Vehicle Emission Simulator

(MOVES) model.

In 2002, the EQB adopted the Heavy-Duty Diesel Emissions Control 

Program for model years starting after May 2004. The program 

incorporates California standards by reference and requires MY 2005 and 

subsequent new heavy-duty diesel highway engines to be those certified 

by California. California standards were more stringent than federal 

standards for the two model years between expiration of the consent 

decrees discussed above (MYs 2005 and 2006) and the implementation of 

more stringent federal standards affecting MY 2007 and beyond. 

However, 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 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 2007 to 2010 for NOX and VOCs. For gasoline 

engines, the standards were phased in during MY 2008 and 2009. Federal 

and California standards are virtually identical for MY 2007. For 

MY 2008, California adopted requirements for idling restriction engine 

programming and an optional “clean NOX idle” standard. However, there 

is no EPA-approved methodology to estimate emission reductions from 

this requirement. Therefore, the emission estimates use assumptions of 

the federal rule for MY 2007 through 2010.

Because the new engine standards are adversely affected by sulfur in fuel, 

the EPA also required most highway diesel fuel to contain no more than 
- 38 -

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

was a temporary compliance option allowing refiners to continue to 

produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

2010. The Department used MOVES defaults to estimate the effects of 

the phase-in provision.

Vehicle Emission Inspection/Maintenance Program. The Pennsylvania 

portion of the Philadelphia Area has had a vehicle emissions inspection 

program since 1984. In early 2004, Pennsylvania revised the 

implementation of its Vehicle Emission Inspection/Maintenance (I/M) 

Program in the five-county Philadelphia area. The program applies to 

gasoline-powered vehicles 9,000 pounds and under, MY 1975 and newer. 

For vehicles MY 1996 and newer, the program consists of an annual onboard diagnostics test and a gas cap pressure test. For subject vehicles 

MY 1995 and older, the program consists of an annual tailpipe test, 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. 

For vehicles older than 25 years, the program is a visual inspection and 

gas cap test. These regulations can be found in 67 Pa. Code Chapter 177. 

Pennsylvania submitted the revised emissions program as a SIP revision 

on December 1, 2003. The EPA approved the SIP revision on October 6, 

2005. (70 FR 58313).

Low sulfur gasoline. Sulfur is a naturally occurring component of crude 

oil that ends up in gasoline and diesel unless removed. Sulfur in gasoline 

impairs the effectiveness of emission control systems and contributes to 

air pollution. By removing most sulfur from gasoline, new advanced 

emission controls will work longer and more efficiently, and air pollution 

will be reduced.

The 1999 federal Tier 2 regulations (65 FR 6698; Feb. 10, 2000) reduced

the sulfur content of gasoline by up to 90 percent, enabling the use of new 

emission control technologies in cars and trucks that reduce harmful air 

pollution. The emission inventory analysis in the Maintenance Plan 

submitted concurrently with this Request for Redesignation uses the 

default assumptions provided in MOVES2010 to account for the 

implementation of the federal standards for low sulfur gasoline. 

Requirements for use of low-sulfur gasoline enabled use of advanced 

emission control systems in light-duty vehicles beginning in MY 2004. 

Vehicles meeting Tier 2 emission standards are 77 to 95 percent cleaner 

than earlier models.

EPA signed a regulation adopting more stringent vehicle standards and 

reducing sulfur limits in gasoline further with the Tier 3 Motor Vehicle 

Emission and Fuel Standards program on March 3, 2014. (79 FR 23414). 

The rule takes effect in 2017. The Tier 3 program requires the annual 
- 39 -

average content of sulfur in gasoline to be reduced to 10 parts per million, 

starting January 1, 2017. By 2018, EPA estimates that SO2 emissions 

from gasoline vehicles will be reduced by 56 percent. When fully 

implemented, this program, by 2030, will increase the effectiveness of 

vehicle emission controls even further and reduce onroad emissions of 

NOX by 25 percent, direct particulate matter by 10 percent and VOCs by 

16 percent. The rule will also significantly reduce emissions of carbon 

monoxide and hazardous air pollutants including acrolein, benzene, 

formaldehyde and acetaldehyde. Emission reductions from the federal 

Tier 3 program have not been included in future year inventories and, 

therefore are not relied upon in the maintenance demonstration. Emission 

reductions from the federal Tier 3 program may nonetheless assist the 

Philadelphia Area in maintaining the PM2.5 NAAQS.

3. Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel-powered 

(“compression ignition”) and gasoline-powered (“spark ignition”) nonroad 

engines of various sizes (horsepower) and applications. Information on 

these federal rules, including their implementation dates, can be found at 

www.epa.gov/nonroad. The Department used the assumptions built into 

the nonroad model (NONROAD2005) and NMIM to estimate emissions 

for all milestone years.

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, EPA adopted a rule establishing a comprehensive 

national program to reduce emissions from nonroad diesel engines 

(69 FR 38958). The rule phased in requirements for reducing the sulfur 

content of diesel used in nonroad diesel engines. The reduction in fuel 

sulfur content prevents damage to the more advanced emission control 

systems needed to meet the engine standards; it will also reduce fine 

particulate emissions from diesel engines. In 2007, fuel sulfur levels were 

limited to 500 ppm for nonroad applications other than ocean-going 

marine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur 

concentration as in highway fuel, 15 ppm; this requirement began 

applying in 2012 to locomotive and marine diesel fuel. EPA adopted 

technical amendments to the program in rules published in the Federal 

Register on November 22, 2005 (70 FR 70498), and May 1, 2006 

(71 FR 25706). On April 30, 2010 (75 FR 22896), 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. 
- 40 -

4. Stationary Area Sources

Consumer Products. This regulation applies statewide to any person 

who sells, supplies, offers for sale, or manufactures certain consumer 

products on or after January 1, 2005, for use in the Commonwealth. The 

Consumer Products program is codified in 25 Pa. Code Chapter 130, 

Subchapter B. It was submitted to the EPA as a SIP revision on March 26, 

2003, and approved on December 8, 2004 (69 FR 70895). Amendments 

to the Consumer Products regulations were adopted on October 11, 2008, 

submitted to the EPA as a SIP revision on March 11, 2009, and approved 

on October 18, 2010 (75 FR 63717).

IV. MAINTENANCE PLAN

The Maintenance Plan for the Philadelphia Area is being submitted to EPA for approval 

as a SIP revision concurrently with this Request for Redesignation. The Maintenance 

Plan shows that the 1997 PM2.5 NAAQS will be maintained for at least 10 years after 

redesignation. Eight years following redesignation, the Commonwealth will submit a 

revised plan that ensures attainment through 2035.

The Maintenance Plan shows that emission levels of PM2.5, SO2, NOX, VOC and NH3 

over the 10 years following redesignation will remain below the emissions level in 2007, 

while allowing for growth in population and vehicle miles traveled. Based on 2010-2012 

monitoring data, the Philadelphia Area currently has an annual design value of 

13.1 μg/m,

3 which is significantly lower than the 1997 NAAQS of 15 μg/m.3

 In addition, 

based on 2010-2012 monitoring data, the Philadelphia Area has a 24-hour design value of 

31 μg/m3 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 SO2, NOX, direct PM2.5

and VOC emissions:

● Clean Air Interstate Rule;

● Emission limits for large industrial boilers;

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

smaller sources of NOX;

● State regulations incorporating by reference the federal Prevention of Significant 

Deterioration (PSD) regulations; 

● State requirements for Best Available Technology (BAT);

● State regulation of the sulfur content of fuel oil;

● The Pennsylvania and federal new motor vehicle emission control programs for 

passenger and light-duty trucks;
- 41 -

● The Pennsylvania and federal heavy-duty diesel emission control programs;

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

● Federal regulation of off-road diesel and gasoline-powered vehicles and 

equipment.

The emission reductions from the following programs were not included in the 2017 and 

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

maintenance. However, emission reductions from these measures may nonetheless assist 

the Philadelphia Area in maintaining air quality.

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

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

(76 FR 45705). 

 NOx and VOC emission reductions from Pennsylvania’s Outdoor Wood-Fired 

Boilers regulation. The Outdoor Wood-Fired Boiler regulation was published in 

the Pennsylvania Bulletin on October 2, 2010 (40 Pa.B. 5571) and approved by 

EPA as a SIP revision on September 20, 2011 (76 FR 58114). 

 Pennsylvania’s regulation 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 EPA as a SIP revision on 

September 26, 2012 (77 FR 59090).

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

(79 FR 23414).

DEP has provided in the Maintenance Plan for the PM2.5 NAAQS assurances that it will 

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

maintenance of the standards and to evaluate emissions inventories periodically 

compared to the projections provided in the plan. DEP has also provided in the 

Maintenance Plan a list of contingency measures that it would consider to correct any 

violation of the 1997 PM2.5 NAAQS that might occur after redesignation of the area.
- 42 -

ACRONYMS AND ABBREVIATIONS

AEO Annual Energy Outlook

AQS EPA’s Air Quality System

AQTAC DEP’s Air Quality Technical Advisory Committee

BACT Best Available Control Technology

BAT Best Available Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CA LEV California Low Emission Vehicle (program)

CAMx Comprehensive Air Quality Model with Extension

CFR Code of Federal Regulations

CMV Commercial Marine Vessel

DEP Pennsylvania Department of Environmental Protection

DOT U.S. Department of Transportation

EGU Electric Generating Unit

EIA Energy Information Administration

EIS Emission Inventory System

EPA U.S. Environmental Protection Agency

EQB Environmental Quality Board

ERC Emission Reduction Credit

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

GDP Gross Domestic Product

GHCN Global Historical Climatology Network

HAP Hazardous Air Pollutant

I/M Inspection and Maintenance

IRRC Independent Regulatory Review Commission

LDGV Light Duty Gasoline Vehicles

LDGT Light Duty Gasoline Trucks

LRP Long Range Plan

MACT Maximum Achievable Control Technology

MARAMA Mid-Atlantic Regional Air Management Association

MM5 Mesoscale Model

MOVES Motor Vehicle Emission Simulator

MPO Metropolitan Planning Organization

MY Model Year

NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NEI National Emissions Inventory

NH3 Ammonia

NLEV National Low Emission Vehicle (program)

NMIM National Mobile Inventory Model
- 43 -

NOAA National Oceanic and Atmospheric Administration

NONROAD Nonroad Model

NOX Oxides of Nitrogen

NSR New Source Review

OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood-fired Boiler

PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates 

PM10 Particulate Matter less than 10 microns in diameter

ppm parts per million

PSD Prevention of Significant Deterioration

RWC Residential Wood Combustion

SCC Source Classification Code

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TIP Transportation Improvement Program

TSD Technical Support Document 

μg/m3 Microgram per cubic meter

μm Micrometer

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

ZEV Zero Emissions Vehicle
Department -oT 

<EnvlrOAmenta' P.rote~ 

COMMONWEALTH OF PENNSYLVANIA 

8TD-521 REV. 06-2010 INVOICE NO. 

PUBLICATIONS AUTHORIZATION AND INVOICE it Resource Management 

PUBLICATIONS AUTHORIZATION '(To be comp1eted by agency): Div,S on TO: (NAME AND ADDRESS OFNEWSPAPERj I FEDERAL !.D. NO.lSOC. SEC. NO. FROM: (NAME AND ADDRESS OF AGENOY) AGENCY I TELEPHONE NO. 

~~~k~~~~~%~~~~~~~~imes !m<~.~.~?~~<~<?..~.~.w ..... w............................................... ~~e~~;~sBureau of Air Quality l .. ".?~.?.:?..~.!.~?~.~.~ ......................................... .. 

Doylestown, PA 18901 400 Market Street ~ 12th FI 

HEREWITH IS ENCLOSED COpy FOR PUBLICATION OF ADVERTISEMENT FOR PROPOSALS TO 

o EMPLOY 0 PURCHASE 0 CONTRACT 0 SELL 

PUBLISH ADVERTISEMENT (NO. OF TIMES) MAXIMUM NO. OF LINES 

1x Only 

DATES OF INSERTION 

Between May 8, 2014, and May 10,2014 

TYPE OF AD 

o CLASSIFIED I8l LEGAL NOTICE 

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 % 

7027313000 3522710000 6343200 

[/0 V16414000000 

INVOICE (To be completed by publisher): 

DATE OF INSERTION ACTUAL NO. OF PRINTED LINES COST PER LINE TOTAL AMOUNT 

1st Ad L 

2nd Ad (Jl) 

3rd Ad au 

GRAND TOTAL-+ SL/O 14-2-

common~~nnSYIVanla 

County of ~~IIIC.-_ Before me, the subscriber, a Notary Public in and for sai~o~nt¥, personal! 

who eing duly swo~doth depose and say that h~ is* f ~\ \ \. . Do n '\ 0. 

the \.:)'("" ~ \\ a general newspaper published at _---.:::L::::.300e_I_2 ..... \.....Iili~~{~,;,ilIoI.LO.L._ _______________ _ 

that the advertisement, of which tearsheet is attached hereto, was published in th~ regular advertising columns of said newspap' 

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. 

z..o~ 

NSYlVANIA 

SIGNATURE OF AFFIANT 
NOTICE OF 

PUBLIC HEARINGS 

PA DEPARTMENT OF 

BUREAU OF AIR QUALITY 

Proposed State Implementation 

Plan Revision 

Redesignation Request and 

Maintenance Plan for the 

Pennsylvania Portion of the 

Philadelphia-Wilmington, PA-NJDE Nonattainment Area for the 

1997 Annual and 2006 24-Hour 

Fine Particulate Matter National 

Ambient Air Quality Standards; 

Particulate matter (PM) includes 

both solid and liquid particles suspended in the air. Fine particle pollution describes particulate matter 

that is less than or equal to 2.5 micrometers in diameter (PM2.5). 

PM2.5 concentrations above the 

federal health-based standard pose 

a serious human health threat. 

With significant improvements in air 

quality in the Philadelphia Area, this 

nonattainment area now meets the 

1997 annual and the 2006 24-hour 

PM2.5 National Ambient Air Quality 

Standards (NAAQS). Therefore, 

the Department of Environmental 

Protection (DEP) intends to submit 

a request to the U.S. Environmental 

Protection Agency (EPA) to 

redesignate the area to attainment. 

DEP is seeking public comments 

on the redesignation request and a 

proposed revision to the State Implementation Plan (SIP) containing 

the 2007 comprehensive inventory 

as required under Section 172(c)(3) 

of the federal Clean Air Act (CAA) 

and a maintenance plan demonstrating that the area can maintain 

the 2006 24-hour PM2.5 healthbased NAAQS for the next 10 years 

as required under Section 175A(a) 

of the CAA (42 U.S.C.A. § 7505a). 

Upon EPA approval, the maintenance plan· will also establish new 

motor vehicle emission budgets for 

transportation conformity purposes. 

The request to redesignate the 

area to attainment and the proposed SIP revision are available on 

DEP's website at www.dep. 

state.pa.us (select "Air," then "Bureau of Air Quality," then 

"Regs/Plans," then "Clean Air 

Plans") or through the contact persons listed below. 

DEP will hold a public hearing to 

receive comments on the proposal 

on Thursday, June 12, 2014, at 

1 :00 p.m., at the DEP Southeast 

Regional Office, 2 East Main Street, 

Norristown, PA 19401. 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. Witnesses should 

keep testimony to ten minutes and 

should provide two written copies of 

their statement at the hearing. 

If by Tuesday, June 10, 2014, no 

person 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: w w w . 

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 

;(717) 787-9495 or alehaas@pa. 

'gQY. 

Persons with a disability who wish 

to attend the hearing and require an 

auxiliary aid, service or other accommodation to participate in the 

proceeding should contact Alex 

Haas at 717.787.9495 or 

alehaas@pa.gov. TOO 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 June 13, 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 "Philadelphia 

! PM2.5 Redesignation" as the subject line in written communication. 

E. CHRISTOPHER ABRUZZO, 

Secretary 

,3tM 8 

Department of 

Environmental Protection 

JUN 0 3 2014 

Air Resource Management 

Division . 

Pat Vigneau Being duly 

affirined according to law, deposes and says that he/she is the 

Billing Manager 

(Manager or Designated Agent) 

of the COURIER TIMES INCORPORATED, Publisher of The 

Bucks County Courier Times, a newspaper of general 

circulation, published and having its place of business at 

Levittown, Bucks County, Pa.; that said newspaper was 

established in 1910; that securely attached hereto is a printed 

notice which is exactly as printed and published in said 

newspaper on 

May 8th, 2014 

and is a true copy thereof; and that this affiant is not interested in 

said subject matter of advertising; and that all of the allegations 

in this statement as to the time, place and character of 

publication are true. 

Billing Manager 

Affirmed and subscribed to me before me 

This 28 th day of May 

A.D. 2014 

eQMM~w~un.~U .. ~l.~·~~~~ - Notarial Seal 

Karen McGovern, Notary Public 

Tullytown Boro, Bucks County 

My Commission Expires Feb. 19, 2017 

..... ,.,u" 1 LV"""M ASSOCIAll0N OF NOTARIES 
COMMONWEALTH OF PENNSYLVANIA 

STD-521 REV. 06-2010 INVOICE NO. 

PUBLICATIONS AUTHORIZATION AND INVOICE 

PUBLICATIONS AUTHORIZATION (To be completed by agency): 

TO: (NAME AND ADDRESS OF NEWSPAPER) 

Delaware County Daily Times 

500 Mildred Avenue 

Primos, PA 19018 

FEDERAL 1.0. NO.lSOC. SEC. NO. 

13-3405136 

FROM: (NAME AND ADDRESS OF AGENCy) AGENCY 

Alex Haas 

PA DEP - Bureau of Air Quality 

400 Market Street - 12th FI 

Hrtrrkhllrn PA 171()1-?~01 a 

TYPE OF AD 

TELEPHONE NO. 

717-787-9495 

HEREWITH IS ENCLOSED COPY FOR PUBLICATION OF ADVERTISEMENT FOR PROPOSALS TO 

o EMPLOY 0 PURCHASE 0 CONTRACT 0 SELL o CLASSIFIED I8J LEGAL NOTICE 

PUBLISH ADVERTISEMENT (NO. OF TIMES) 

1xOnly 

MAXIMUM NO. OF LINES 

DATES OF INSERTION 

Between May 8, 2014, and May 10,2014 

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 % 

7027313000 3522710000 6343200 

I/O V16414000000 

INVOICE (To be completed by publisher): 

DATE OF INSERTION ACTUAL NO. OF PRINTED LINES COST PER LINE TOTAL AMOUNT 

1stAd :S/9/1 LJ Q XCo&~ \3C, L(l9 !~ 2nd Ad 

3rd Ad 

GRAND TOTAL 0+ I 

Commonwealth of Pennsylvania 

County of Oela \.vQ re L ;J J I / 

Before me, the subscriber, a Notary Public in and for said County p. rS9naily came 'i1J!J t5e T!C1Je1' wh~in~~sworn, dofu depose and sayfu~he ~* _~~~/~~e~r~(~~~~~~~.~~~~~~~~~~~~_ the ill ll-u I h'tS a general newspaper published at ~CO~..:....w..i 1.!::!!.ln~~e'-7' i....L..!'I':......:I..:...:ny;,~--'-.L.L..L.L.l.o:2..l"'--~~~~~_ 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 chargl 

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. ir I J ' 

da 0 ~ ~ 20 ...... I-I_f--_ . Sworra ajld subscribed before me this ~ '* Jl ' - -pr~~'~~~~~ '[IV 

I~'--- No~"~~ 

*This affidavit must be made by the Owner, Publisher, or the designated agent of the owner or publisher. 

Kathleen RaCJnI, NotIry Public 

Upper DIfby iwp., Delaware County 

My Co~ ExpIres March 2, 2015 

MEMBER, PENNSYLVANIA .ASSOCTATIOM f)F W'ITI\IUFf" 
Copy of Notice or Publication 

- -~m Be"isian 

r~e' Plan far the ~i1mingtan, PA-NJ.-

,~'!1 and 

lianal Ambient, Air 

t 

~ and liquid particles 

i1escribes particulate 

i;>meters in diameter 

~deral health-based 

ieat. With significant 

:~delphia Area, this 

~al and the ,2, 0.0.6 24-

Jtandards (NAAQS). 

181 Protection (DEP) 

i.'i.uonmental Protection 

iDment. . 

. Idesignatio~ reqIJest 

JnentationPlan (SIP) 

tyas required under 

j

"'r Act (CAA)' and a, 

',. ,e,',a. c.an. ma,.intain. the . r the next 10. years 

1M (4? U.S.C.A. § ~;~ance plan will also 

rets for transportation " ' J¥3 :, _ t attainment an.d ,:the 

" DEP's ,website at 

:,ureau of Air Quality," 

~r through the contact 

f 

f,te' .comments on', the 

~:Qo. p.m., at the DEP 

fStreet, Norristpwn, PA, 

fmony at the hearing 

~468, Harrisburg" PA 

J: or via email at I '~1nesses should ke~p r two written copies of I 

iJ~ , ~n . has exp~essedan, ,.ring will be cancelled. 

:BureauoL Air Quality - Keyword, "Air") if the' 

contact the DEP to,find '\' 

19 Alex Haas at , 

i 

;attend the heari'ng and-; 

ther accommodation to~ 

~ct Alex Haas at .: users may contact .the i 

) 'discu?s how DEP can -

:0 June 13, 20.14. Written 

-) of Nancy Herb, Bure.au r 

urg, PA 171o.5-8468,or -5 Redesignation" as, the I 

I 

. I 

AISTOPHER ABRUZZO,.: 

-------,. 

Proof of Publication of Notice in Delaware County Daily Times 

Under Newspaper Advertising Act. No. 587. Approved May 16, 1929 

State of Pennsylvania, 

County of Delaware, 

LYNN D. BETTCHER 

} ss. 

designated agent of CENTRAL STATES PUBLISHING, INC., 

being duly sworn, deposes and says that the DELAWARE COL::-.iTY DAILY TIMES, a daily newspaper of general circulation 

as defined in the above-mentioned Act, published at Primos, Delaware County, Pennsylvania, was established September 7, 

1876, and issued and published continuously thereafter for a period of 100 years and for a period of more than six months 

immediately prior hereto, (under the name Chester Times prior to November 2, 1959) in the City of Chester, County of 

Delawnre and further says that the pdnted nqtice or publication attached hereto is an exact copy of a notice or publication 

printed and published in the J'egulnr edition nnd issues of the DELAWARE COUNTY DAILY TIMES on the following dates, 

viz ................................................................................................................. . 

May 9, A.D. 20 14 

and that said advertising was inserted in all respect~ as ordered . 

Affiant further deposes that he is the proper person duly authorized by CE~TRAL ST~TES 

PUBLISHING, INC. publisher of said DELAWARE COUNTY DAILY TIIVIES, a newspaper of general circulation, to verify 

the foregoing statement under oath and that affiant is not interested in the subject matter of the aforesaid notil'l~ or 

advertisement, and that all allegations in the foregoing statements as to time, place' and character of publication arc true. 

9th 20 14 

Notary Public 

r4EMBER, PENNSYLVANIA ASSOCIATION OF NOTAruF.~ 
Copy of Notice or Publication 

Proposed State Implementation Plan Revision 

,. Redesignation Request" and . Maintenance Plan for the 

Pennsylvania Portion of the Philadelphia-Wilmington, PA-NJDE (Nonattainment Area for the 1997 Annual and . 

2006 24-Hour· Fine Particulate Matter National Ambient· Air .~uality Standa~ds;·· .', 

Public Hearing 

Particulate matter (PM) includes' both solid and liquid particles 

suspended in the 'air. Fine particle pollution describes particuli;3.te : 

matter that .is less than or equaHo 2.5 micrometers in diameter' 

(PM2.5). PM2.5 concentrations .. above the federal health~based' 

.~ staljldard -pose a serious human health threat. With significant 

imp,rovements in. air quality in the Philadelphia Area, this 

non attainment area now meets the 1997 annual and the 20.0.6 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 

AgE;lncy (EPA) to redesignate the area to attair:HTIent. 

DEP is seeking public comments on theredesignation reqLJest 

and a proposed revision to the State Implementation Plan (SIP) 

containing the 20.0.7 comprehensive inventory' as required under 

Seqtion 172(c)(3) of the federal Clean Air Act (CAA) and a 

maintenance plan demonstrating. that the area can maintain the 

20.0.6 24-hour, PM2.5 health-based NMQS forIhe next 10. years 

as -required under Section 175A(a)of the eM (4,2 U,S.C.A.§ 

75o.5a). Upon EPA approval, :the maintenance plan will also 

establish, new motorvehicle emission budgets for transportation 

conformity purposes. ' . , .' 

The request to redesignate ·thearea to. attainment· and the 

,proposed SIP revision.- are available on DEP's website at .J www~dep.state.pa.us~ (select "Air," thEm "Bureau of Air Quality," 

1 then ''Regs/Plans,''then "qleanAir.Plans", or through the contact 

1 persons listed below. ' , 

J DEP will hold a public hearing - to receive ,comments on. the 

. proposal .on Thursday, June 12, 20.14, at 1 :0.0. p.m., at the DEP 

Southeast Regional· Office,·2' East 'Main . Street, Norristpwn, PA 

1940.1. Persons wishing to present testimony at the hearing j 

should contact Alex Haas at P.O. Box 8468, Harrisburg, PA i 

1710.5, by phone at 717.787.9495 .or via. email at I' 

alehaas@pa.gov to reserve atime.Wiinesses should ke~p 

testimony to ten minutes and should provide two written copies of 

their statement 1(.t the hearing.. . . . i 

If by Tuesday, June 1o.,2o.14,no person has exp~essed an 

. interest in .testifyingat the hearing, the hearing will be cancelled. ; 

DEP will provide public notice on the· Bureau ·of Air Quality 

,«ebpa,ge at: www.dep.state.pa.us (D'EP Keyword, "Air") if the: 

hearing. is cancelled.Persons.mayalso.contact the DEPtofind I 

out if the hearing is cancelled by contacting Alex Haas at 

(71;7) 767-9495 or alehaas@pa.gov. i 

Pe~sons with a disability who wish to· attend the hearing and- i 

reqqire an auxiliary aid, service .brother accommodation to. 

participate ih the proceeding should. contact Alex Haas at. . . I 

'717.787.9495 or alehaas@pa.gov. TDD users may contact ,the I 

AT&T Relay Service at 80.0..654.5984 todiscu$s how DEP can' 

be~t accommodate their needs .. 

DEP must receive comments no later than June 13, 2o.14 .. Written 

.' cOmments should be sent to the attention of Nancy Herb; Bure.au , 

of .Air Quality, P.O .. Box 8468, Harrisburg, PA 171o.5-8468,or : 

nherp@pa.gov. Use. "Philadelphia PM2.S Redesignation" as the i 

subject line in written communication., I 

E. CHRISTOPHER ABRUZZO, ' 

DOT, fy1ay 9, a-1 

Proof oj 

State of Penns: 

County of Del: 

LYNN D. BE; 

being duly sworn, dell 

as defined in the abo 

1876, and issued and 

immediately prior h{ 

Delaware and furthe: 

printed and publishe( 

viz ............................. .. 

and that said advcrti: 

PUBLISHING, INC;. 

the foregoing staten 

advertisement, and t 

Sworn to and subscr 

9th 
Department of . """ 

!nvironmentat Protectaon 

CLASSIFIED ADVERTISING INVOICE 

ACCOUNT INFORMATION 

DELAWARE COUNTY TIMES 

P.O. BOX 347 

PRIMOS, PA 19018 

PHONE NO: 

ACCOUNT NO: 

DATE: 

717 -787 -9495 

893-0657493 

05/09/2014 

Address Service Requested MAY 1 5 2014 TERMS: PAYABLE ON RECEIPT 

CUSTOMER NAME AND ADDRESS: 

PA DEP/BUREAU OF AIR QUALITY 

400 MARKET STREET 

12TH FLOOR 

PO BOX 8468 

HARRISBURG, PA 17105-8468 

AI ... · Resource, Management 

Division 

CLE 

FIRST NOTICE 

Page 1 of 1 

INVOICE I REP I CL"S I ;m; DESCRIPTION I DOCKET I PO NUMBER I START I STOP I TIMES I LINES I AMOUNT NO. till hl !II DATE DATE 

00425702 MTW 086 ED STATE IMPLEMENTA 

14, MTW, ALEXANDER HAAS EMAIL 

DCW 

DEP BUREAU OF AIR 

redesignation reques 05/09/14 05/09/14 

*** THANK YOU FOR YOUR PROMPT PAYMENT *** 

BILLING INQUIRIES 877-573-0236 MON-FRI8:30 AM - 5PM 

CLASSIFIED ADVERTISING 610-622-8800 MON-FRI 8:30 AM - 5PM 

DISPLAY ADVERTISING 610-622-8865 MON-FRI 9:00 AM - 5PM 

02 

SUBSCRIPTIONS 888-799-6299 MON-FRI6:00 AM - 5PM SAT/SUN 6-12:00PM 

WEB SITE DELCOTIMES.COM 

136.00 

TOTAL AMOUNT INCLUDES SURCHARGE OF $8.00 PER PROOF. 

DELAWARE COUNTY TIMES 

P.O. BOX 347 

PRIMOS, PA 19018 

Detach and return this portion with your payment. 

Please do NOT include correspondence 

or write on this remittance form. 

FIRST NOTICE 

PHONE NO: 717-787-9495 

ACCOUNT NO: 893-0657493 

ACCOUNT NAME: PA DEP/BUREAU OF AIR QUALITY 

AMOUNT PAID: $ 

CHECK# 

CLE 

MAIL PROMPTLY TO: 

111.11 •• 1.1 •• 1.11111'11111 ••• 111 •• 1.1 ••• 11 ••• 11'111111.11 ••• 11 

DELAWARE COUNTY DAILY TIMES 

P.O. BOX 1877 

ALBANY, NY 12201-1877 

893000CLE000000657493000000657493000000425702000041950000041950050920147 

419.50 
NOTICES

Proposed State Implementation Plan Revision; Redesignation Request and 

Maintenance Plan for the Pennsylvania Portion of the PhiladelphiaWilmington, PA-NJ-DE Nonattainment Area for the 1997 Annual and 2006 

24-Hour Fine Particulate Matter National Ambient Air Quality Standards; 

Public Hearing

[44 Pa.B. 2808]

[Saturday, May 10, 2014]

Particulate matter includes both solid and liquid particles suspended in the air. Fine 

particle pollution describes particulate matter that is less than or equal to 2.5 micrometers in 

diameter (PM2.5). PM2.5 concentrations above the Federal health-based standard pose a 

serious human health threat. With significant improvements in air quality in the 

Philadelphia Area, this nonattainment area now meets the 1997 annual and the 2006 24-

hour PM2.5 National Ambient Air Quality Standards (NAAQS). Therefore, the Department 

of Environmental Protection (Department) intends to submit a request to the United States 

Environmental Protection Agency (EPA) to redesignate the area to attainment.

The Department is seeking public comments on the redesignation request and a proposed 

revision to the State Implementation Plan (SIP) containing the 2007 comprehensive 

inventory as required under section 172(c)(3) of the Federal Clean Air Act (CAA) (42 

U.S.C.A. § 7502(c)(3)) and a maintenance plan demonstrating that the area can maintain 

the 2006 24-hour PM2.5 health-based NAAQS for the next 10 years as required under 

section 175A(a) of the CAA (42 U.S.C.A. § 7505a(a)). Upon the EPA approval, the 

maintenance plan will also establish new motor vehicle emission budgets for transportation 

conformity purposes.

The request to redesignate the area to attainment and the proposed SIP revision are 

available on the Department's web site at www.dep.state.pa.us (select ''Air,'' then ''Bureau of 

Air Quality,'' then ''Regs/Plan,'' then ''Clean Air Plans'') or through the contact persons listed 

as follows.

The Department will hold a public hearing to receive comments on the proposal on 

Thursday, June 12, 2014, at 1 p.m. at the DEP Southeast Regional Office, 2 East Main 

Street, Norristown, PA 19401. Persons wishing to present testimony at the hearing should 

contact Alex Haas at P. O. Box 8468, Harrisburg, PA 17105, (717) 787-9495 or 

alehaas@pa.gov to reserve a time. Witnesses should keep testimony to 10 minutes and 

should provide two written copies of their statement at the hearing.

If by Tuesday, June 10, 2014, no person has expressed an interest in testifying at the 

hearing, the hearing will be cancelled. The Department will provide public notice on the 

PA Bulletin, Doc. No. 14-986 Page 1 of 2

http://www.pabulletin.com/secure/data/vol44/44-19/986.html 5/13/2014
Bureau of Air Quality web page at www.dep.state.pa.us (DEP Keyword: ''Air'') if the 

hearing is cancelled. Persons may also contact the Department to find out if the hearing is 

cancelled by contacting Alex Haas.

Persons with a disability who wish to attend the hearing and require an auxiliary aid, 

service or other accommodation to participate in the proceeding should contact Alex Haas. 

TDD users may contact the Pennsylvania 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 June 13, 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 ''Philadelphia PM2.5 Redesignation'' as 

the subject line in written communication.

E. CHRISTOPHER ABRUZZO,

Secretary

[Pa.B. Doc. No. 14-986. Filed for public inspection May 9, 2014, 9:00 a.m.]

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