1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

 October 6, 2011

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

Emissions Budgets in the Attainment Demonstration for the Pennsylvania Portion 

of the Philadelphia-Wilmington-New Jersey City 1997 Fine Particulate (PM2.5)

National Ambient Air quality Standard (NAAQS) Nonattainment Area 

FROM:

 /s/

Martin Kotsch, 

Office of Air Program Planning (3AP30)

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

Emissions Budgets in the Attainment Demonstration for the Pennsylvania Portion 

of the Philadelphia-Wilmington-New Jersey 1997 PM2.5 NAAQS Nonattainment 

Area 

 /s/

THRU: Cristina Fernandez, Associate Director,

Office of Air Program Planning (3AP30)

I. Administrative Requirements for Making Adequacy Findings 

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

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

procedures listed in the January 2008 Conformity Regulations contained in 40 CFR part 93,

118(f) “Adequacy review process for implementation plan submissions”.

On April 12, 2010, the Pennsylvania Department of Environmental Protection (PADEP) formally

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

attainment demonstration) for the Pennsylvania Portion of the Philadelphia-Wilmington-New 

Jersey PM2.5 Nonattainment Area as SIP revision. 

EPA will be issuing its own Notice of Proposed Rule making for a 30-day public comment 

period soliciting public comment as to the approvability of the Pennsylvania SIP submission. 

Concurrently with EPA’s Notice of Proposed Rulemaking, a notice will be posted on EPA’s 

website at http://www.epa.gov/otaq/stateresources/transconf/currsips.htm for the purpose of 

opening EPA’s 30-day public comment period on the adequacy/approvability of the budgets in 

the SIP revision. That notice will inform the public of the availability of the Pennsylvania SIP 

revision on its own website. EPA’s website notice will provide a link to the address for the 

website where interested members of the public could access the SIP revision. Following EPA’s 
2

public comment period, responses to any comments received on the proposed mobile budgets in 

the Pennsylvania SIP will be addressed in an amendment to this Technical Support Document 

(TSD).

Shown below in Table 1 are the 2 sets of budgets from the SIP submittal. 

Table 1

The Budgets of the Pennsylvania Portion of Philadelphia-Wilmington-Atlantic City 1997 

PM2.5 NAAQS Attainment Demonstration

Plan

Submittals

Milestone 

Year

Mobile 

Vehicle 

Emissions 

Budget for 

Direct PMTons Per Year

Mobile 

Vehicle 

Emissions 

Budget for 

NOx-Tons 

Per Year

Attainment Plan 

Demonstration

2009 699 36,318

II. Evaluation of the Adequacy of the MVEBs Budgets in the Attainment Demonstration 

for the Pennsylvania Portion of the Philadelphia-Wilmington-New Jersey 1997 NAAQS 

PM2.5 Nonattainment Area Submitted by PADEP on April 12 , 2010

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

plan contained in the April 12, 2010 SIP submittal, for conformity purposes. We are using the 

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

93.102(b)(2)(v), 93.102(b)(3), and part 93, 93.118(e)4 through 93.118(e)5. The evaluation is 

presented in Table 2, below.

Table 2

Adequacy of the MVEBs Contained in the Attainment Demonstration for the Pennsylvania 

Portion of Philadelphia-Wilmington-New Jersey City 1997 NAAQSPM2.5 Non-attainment

Area

Transportation Conformity

Rule

40 CFR Part 93, 93.118

Review Criteria Was the Criterion Satisfied? 

If Yes How was this Criteria 

Satisfied?

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

made a finding that NOx is 

an insignificant contributor 

to the direct mobile PM 

EPA and the State have not 

made such a finding.
3

emissions?

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

finding that VOCs, Sulfur 

Oxides (SOx) or Ammonia 

(NH3) as precursors to be a 

significant contributor to the 

mobile PM2.5 emissions?

Neither EPA or the State has 

made such a finding.

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

made a finding that reentrained road dust is a 

significant contributor to the 

PM mobile emissions?

Neither EPA or the State has 

made such a finding.

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

plan endorsed by the 

Governor (or his or her 

designee) and subject to a 

State public hearing?

Yes. The submitted and 

attainment demonstration was 

endorsed and submitted as a 

SIP revision by the 

Governor’s designee, the 

Secretary of the PADEP, and 

a public hearing was held.

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

demonstration was submitted 

to EPA, did consultation 

between federal, State and 

local agencies occur; was full 

implementation plan 

documentation provided to 

EPA, and was EPA’s stated 

concerns, if any, addressed?

Yes. Consultation has 

occurred among all required 

federal, state and local 

agencies.

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

emissions budget(s) clearly

identified and precisely

quantified?

Yes, the budgets are clearly

identified on page 22 of the 

April 12, 2010 submittal 

containing the attainment 

demonstration. 

Sec. 93.118(e)(4)(iv) Is the motor vehicle 

emissions budget(s), when 

considered together with all 

other emission reductions, 

consistent with applicable 

requirements for attainment 

demonstrations?

EPA believes the budgets can 

be declared adequate because 

in conjunction with the other 

emission reductions, they 

demonstrate attainment for 

2010. 
4

Sec. 93.118(e)(4)(v) Is the motor vehicle 

emissions budget(s) 

consistent with and clearly

related to the emissions 

inventory and the control 

measures in the Plan?

EPA believes that the budgets 

are clearly related to the 

emissions inventory and the 

control measures in the SIP 

submittal.

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

submitted attainment 

demonstrations: explain and 

document any changes to 

previously submitted budgets 

and control measures; 

impacts on point and area 

source emissions; any

changes to established safety

margins (see Sec. 93.101 for 

definition); and reasons for 

the changes (including the 

basis for any changes related 

to emission factors or 

estimates of vehicle miles 

traveled).

N/A

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

review public comments and 

the State’s responses to those 

comments with the submitted 

control strategy SIP?

There were no comments on 

the proposed mobile 

emissions budgets in the SIP. 

III. Findings - Based upon our review and evaluation of the MVEBs contained in PADEP’s 

April 12, 2010 submittal of the attainment plan for the Pennsylvania Portion of PhiladelphiaWilmington-New Jersey 1997 PM2.5 NAAQS nonattainment area, we find the said MVEBs 

adequate for conformity purposes.