UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: December 16, 2009

SUBJECT: Technical Support Document - Delaware; Reasonable Further Progress Plan, 

 2002 Base Year Emissions Inventory, Reasonably Available Control Measures, 

Contingency Measures, and Transportation Conformity Budgets for the Delaware 

Portion of the Philadelphia 1997 8-Hour Ozone Moderate Nonattainment Area

/s/

FROM: Rose Quinto, Environmental Engineer

Office of Air Program Planning

TO: File

/s/

THRU: Cristina Fernandez, Associate Director

Office of Air Program Planning

This document provides a technical review of a revision to the Delaware State 

Implementation Plan (SIP) submitted by the Delaware Department of Natural Resources and 

Environmental Control (DNREC) on June 13, 2007. This SIP revision addresses emissions 

inventory, reasonably available control measures (RACM), contingency measures, and 

reasonable further progress (RFP) requirements for the 1997 8-hour ozone national ambient air 

quality standard (NAAQS) for the Delaware portion of the Philadelphia moderate nonattainment 

area. The SIP revision also establishes a motor vehicle emissions budget (MVEB) for 2008.

A. BACKGROUND

General Requirements

Section 182 of the Clean Air Act (CAA) and the Environmental Protection Agency’s 

(EPA’s) 1997 8-hour ozone regulations (40 CFR 51.910) require each moderate and above 

8-hour ozone nonattainment area to submit an emissions inventory and RFP SIP revision that 

describes how the area will achieve actual emissions reductions of volatile organic compounds 

(VOC) and nitrogen oxides (NOx) from a baseline emissions inventory. An emissions inventory

is an estimation of actual emissions of air pollutants in an area. The emissions inventory for an 

ozone nonattainment area contains VOC and NOx emissions, which are precursors to ozone 

formation. In this case, the baseline emissions inventory is 2002.
2

Pursuant to section 172(c)(1) of the CAA, States are required to submit plans for 

nonattainment areas that provide for the implement of all reasonably available control measures 

(RACM) as expeditiously as practicable. Specifically, section 172(c)(1) states the following: 

‘‘Such plan provisions shall provide for the implementation of all reasonably available control 

measures as expeditiously as practicable (including such reductions in emissions from existing 

sources in the area as may be obtained through the adoption, at a minimum, of reasonably

available control technology) and shall provide for attainment of the national primary ambient air 

quality standards.’’ Control measures that would advance the attainment date are considered 

RACM and must be included in the SIP. RACM are necessary to ensure that the attainment date 

is achieved ‘‘as expeditious as practicable.’’ 

Phase 1 of the 8-hour ozone implementation rule, published on April 30, 2004 (69 FR 

23951), set out criteria for classifying nonattainment areas under the 1997 8-hour ozone standard. 

The Phase 1 rule also addressed revocation of the 1-hour NAAQS; how anti-backsliding 

principles will ensure continued progress toward attainment of the 8-hour ozone NAAQS; 

attainment dates; and the timing of emissions reductions needed for attainment. On November 

29, 2005, EPA published the Phase 2 final rule for implementation of the 8-hour standard. The 

Phase 2 rule addressed the RFP control and planning obligations as they apply to areas 

designated nonattainment for the 1997 8-hour ozone NAAQS (70 FR 71612). The Phase 2 final 

rule was revised on June 8, 2007 (72 FR 31727). Among other things, the Phase 1 and 2 rules 

outline the SIP requirements and deadlines for various requirements in areas designated as 

moderate nonattainment. The rules set a due date of June 15, 2007 for the required base year 

emission inventory, RFP plan, modeling and attainment demonstration, RACM, MVEB, and 

contingency measures (40 CFR 51.908(a), (c)).

Section 182(b)(1) of the CAA and EPA’s 1997 8-hour ozone implementation rule (40 

CFR 51.910) require each 8-hour ozone nonattainment area designated moderate and above to 

submit for review and approval into its SIP an emissions inventory and RFP plan that describes 

how the area will achieve actual emissions reductions of VOC and NOx from a baseline 

emissions inventory. For a moderate 8-hour ozone nonattainment area with an attainment date 

more than 5 years after designation, a 15 percent RFP reduction in ozone precursor emissions is 

required within 6 years (2002-2008). For a moderate area with an approved 15 percent rate-ofprogress (ROP) plan under the 1-hour standard, States can use reductions from VOC or NOx or a 

combination of either. For a moderate area without an approved ROP plan, a 15% reduction in 

VOC is required. These VOC reductions can be obtained from the part of the area with an 

approved 1-hour ROP. Table 1 outlines these requirements.
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Table 1. RFP Requirements for a Moderate 8-Hour Ozone Nonattainment with an 

Attainment Date More than 5 Years after Designation

Area Portion Requirement 40 CFR Reference

Portion with approved 

15% VOC ROP plan

15% VOC and/or NOx reductions 

(2002 – 2008)

51.910(a)(1)(iii)(B)(2) & 

51.910(b)(2)(b)(ii)

Portion without approved 

15% VOC ROP plan 

 

15% VOC reductions (2002 -2008). The 

reductions may come from anywhere 

within the 8-hour nonattainment area.

51.910(a)(1)(iii)(B)(1)

In addition, RFP plans must include contingency measures, which are additional controls 

that would be implemented if the area fails to make reasonable further progress. (See CAA 

section 172(c)(9)). Implementation of these measures would provide additional emissions 

reductions of up to 3 percent of the adjusted base year inventory (or lesser percentage that will 

make up the identified shortfall). RFP plans must also include a MVEB, which is the allowable 

on-road mobile emission an area can produce and continue to demonstrate RFP. (See 40 CFR 

93).

The State of Delaware

In 1997, EPA revised the health-based NAAQS for ozone, setting it at 0.08 parts per 

million (ppm) averaged over an 8-hour time frame. EPA set the 8-hour ozone standard based on 

scientific evidence demonstrating that ozone causes adverse health effects at lower ozone 

concentrations and over longer periods of time, than was understood when the pre-existing 

1-hour ozone standard was set. EPA determined that the 8-hour standard would be more 

protective of human health, especially children and adults who are active outdoors, and 

individuals with a pre-existing respiratory disease, such as asthma.

On April 30, 2004 (69 FR 23951), EPA finalized its attainment/nonattainment 

designations for areas across the country with respect to the 8-hour ozone standard. These 

actions became effective on June 15, 2004. Among those nonattainment areas is the 

Philadelphia-Wilmington-Atlantic City (PA-NJ-MD-DE) moderate nonattainment area (NAA). 

This NAA includes the three counties in Delaware, five counties in eastern Pennsylvania, one 

county in Maryland, and eight counties in southern New Jersey. 

Pursuant to Phase 1 of the 8-hour ozone implementation rule, published on 

April 30, 2004 (69 FR 23951), an area was classified under Subpart 2 of the CAA based on its 

8-hour design value if that area had a 1-hour design value at or above 0.121 ppm (the lowest 

1-hour design value in Table 1 of Subpart 2). Based on this criterion, Delaware, as part of the 

Philadelphia area was classified under Subpart 2 as a moderate nonattainment area. On 

November 29, 2005 (70 FR 71612), as revised on June 7, 2007 (72 FR 31727), EPA published 

the Phase 2 final rule for implementation of the 8-hour standard that addressed the RFP control 

and planning obligations as they apply to areas designated nonattainment for the 1997 8-hour 
4

ozone NAAQS. The Phase 1 and 2 rules outline the SIP requirements and deadlines for various 

requirements in areas designated as moderate nonattainment. For such areas, reasonably

available control technology (RACT) plans were due by September 2006 (40 CFR 51.912(a)(2)). 

The rules further require that modeling and attainment demonstrations, reasonable further 

progress plans, reasonably available control measures, projection year emission inventories, 

motor vehicle emissions budgets and contingency measures were all due by June 15, 2007 

(40 CFR 51.908(a), (c)). 

Section 182(b)(1) of the CAA and EPA’s 1997 8-hour ozone implementation rule 

(40 CFR 51.910) require each 8-hour ozone nonattainment area designated moderate and above 

to submit an emissions inventory and RFP plan, for review and approval into its SIP, that 

describes how the area will achieve actual emissions reductions of VOC and NOx from a 

baseline emissions inventory.

B. STATE SUBMITTAL

I. Base Year Emissions Inventory

An emissions inventory is a comprehensive, accurate, current inventory of actual 

emissions from all sources and is required by section 172(c)(3) of the CAA. For ozone 

nonattainment areas, the emissions inventory needs to contain VOC and NOx emissions because 

these pollutants are precursors to ozone formation. EPA recommended 2002 as the base year 

emissions inventory, and is therefore the starting point for calculating RFP. Delaware submitted 

its 2002 base year emissions inventory on June 13, 2007. A summary of the 2002 base year 

VOC and NOx emissions inventory are included in Tables 2 and 3 in this document.

Table 2. Delaware 2002 Base Year VOC Emissions in tons per day (tpd)

Source Sector Kent New Castle Sussex State Total

Point 0.49 9.42 13.35 23.26

Stationary Area 5.75 20.02 7.31 33.08

Non-Road Mobile 5.17 12.24 9.36 26.77

On-Road Mobile 5.45 16.98 9.95 32.38

Total Emissions 16.86 58.66 39.97 115.49

Table 3. Delaware 2002 Base Year NOx Emissions in tpd

Source Sector Kent New Castle Sussex State Total

Point 5.06 44.09 24.95 74.10

Stationary Area 0.45 1.95 0.77 3.17

Non-Road Mobile 15.02 24.62 13.15 52.79

On-Road Mobile 13.97 36.56 18.50 69.03

Total Emissions 34.50 107.22 57.37 199.09
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II. Adjusted Base Year Inventory and 2008 RFP Target Levels

The process for determining the emissions baseline from which the RFP reductions are 

calculated, is described in section 182(b)(1) of the CAA and 40 CFR 51.910. This baseline value 

has been determined to be the 2002 adjusted base year inventory. Sections 182(b)(1)(B) and (D) 

require the exclusion from the base year inventory of emissions benefits resulting from the 

Federal Motor Vehicle Control Program (FMVCP) regulations promulgated by January 1, 1990, 

and the Reid Vapor Pressure (RVP) regulations promulgated June 11, 1990 (55 FR 23666). The 

FMVCP and RVP emissions reductions are determined by the State using EPA’s on-road mobile 

source emissions modeling software, MOBILE6. The FMVCP and RVP emission reductions are 

then removed from the base year inventory by the State, resulting in an adjusted base year 

inventory. The emission reductions needed to satisfy the RFP requirement are then calculated 

from the adjusted base year inventory. These reductions are then subtracted from the adjusted 

base year inventory to establish the emissions target for the RFP milestone year (2008).

For moderate areas like Delaware, the CAA specifies a 15 percent reduction in ozone 

precursor emissions over an initial 6-year period. In the Phase 2 rule, EPA interpreted this 

requirement for areas that were also designated nonattainment and classified as moderate or 

higher for the 1-hour ozone standard. In the Phase 2 rule, EPA provided that an area classified as 

moderate or higher that has the same boundaries as an area, or is entirely composed of several 

areas or portions of areas, for which EPA fully approved a 15 percent plan for the 1-hour 

NAAQS, is considered to have met the requirements of section 182(b)(1) of the CAA for the 

8-hour NAAQS. In this situation, a moderate nonattainment area is subject to RFP under section 

172(c)(2) of the CAA and shall submit, no later than 3 years after designation for the 8-hour 

NAAQS, a SIP revision that meets the requirements of 40 CFR 51.910(b)(2). The RFP SIP

revision must provide for a 15 percent emission reduction (either NOx and/or VOC) accounting 

for any growth that occurs during the 6-year period following the baseline emissions inventory

year, that is, 2002-2008. The sections 182 and 172 requirements differ in that section 182(b)(1) 

specifies that it must be a 15 percent VOC reduction, where section 172(c)(2) provides that the 

15 percent reduction can be either a VOC and/or NOx reduction.

According to EPA’s Phase 2 Implementation Rule (70 FR 71612), Delaware must 

achieve 15 percent VOC emission reduction in Sussex County from its 2002 baseline level, and 

15 percent VOC and/or NOx emission reduction in Kent and New Castle Counties from their 

combined 2002 baseline level before the end of 2008. 

According to section 182(b)(1)(D) of the CAA, emission reductions that resulted from the 

FMVCP and RVP rules promulgated prior to 1990 are not creditable for achieving RFP emission 

reductions. Therefore, the 2002 base year inventory is adjusted by subtracting the VOC and 

NOX emission reductions that are expected to occur between 2002 and the future milestone years 

due to the FMVCP and RVP rules. The FMVCP/RVP VOC and NOx emission reductions that 

are expected between 2002 and 2008 were determined using EPA’s MOBILE6.2 model. The 

input and output files of the MOBILE6.2 runs for the adjustments, the emission factors 
6

generated, and relevant calculations for emission projections are found in Appendix 4-1 of the 

Delaware SIP submittal. The adjustments are presented in Table 4 for Sussex County and Table 

5 for Kent and New Castle Counties.

Table 4. Mobile Source FMVCP/RVP Adjustments for Sussex County in tpd

Adjusted On-Road Mobile Source Emissions VOC NOx Note

Adjusted for 2002 16.66 20.24 A

Adjusted for 2008 15.51 18.81 B2008

Mobile Source Adjustments for 2002 Baseline

2002-2008 1.15 1.42 C2008 = A – B2008

Table 5. Mobile Source FMVCP/RVP Adjustments for Kent & New Castle Counties in tpd

Adjusted On-Road Mobile Source Emissions VOC NOx Note

Adjusted for 2002 42.16 56.02 a

Adjusted for 2008 39.18 51.64 b2008

Mobile Source Adjustments for 2002 Baseline

2002-2008 2.98 4.38 c2008 = a – b2008

The mobile source adjustments in Tables 4 and 5 are the non-creditable emission reductions 

due to the pre-1990 FMVCP and RVP rules. Subtracting these adjustments from the 2002 base 

year emissions inventory (i.e., the State total emissions in Tables 2 and 3) will give the 2002 

adjusted base year emissions inventory relative to the subject milestone year, as presented in 

Table 6 for Sussex County and Table 7 for Kent and New Castle Counties.

Table 6. The 2002 Adjusted Base Year Emissions Inventory for Sussex County in tpd

VOC NOx Note

2002 Base Year Emissions Inventory 39.97 57.37 E

Mobile Source Adjustments for 2002-2008 1.15 1.42 C2008

2002 Adjusted Baseline Relative to 2008 38.82 55.95 F2008 = E – C2008

Table 7. The 2002 Adjusted Base Year Emissions Inventory for Kent & New Castle 

Counties in tpd

VOC NOx Note

2002 Base Year Emissions Inventory 75.52 141.72 e

Mobile Source Adjustments for 2002-2008 2.98 4.38 c2008

2002 Adjusted Baseline Relative to 2008 72.54 137.34 f2008 = e – c2008
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By the end of 2008, Delaware is required to reduce 15 percent in its 2002 adjusted base 

year emissions inventory. According to the Phase 2 rule (70 FR 71612), Sussex County must 

achieve this 15 percent reduction in its VOC emission, since it did not have a 15 percent VOC 

ROP plan approved by EPA under the 1-hour ozone standard. For Kent and New Castle 

Counties, their 15 percent emission reductions can be achieved from VOC emissions and/or from 

NOx emissions. 

The 15 percent VOC emission reduction and emission target in 2008 in Sussex County are 

calculated as follows:

Sussex 2002 adjusted VOC baseline relative to 2008 is 38.82 tpd.

Required 15 percent emission reduction: 38.82 x 15% = 5.82 tpd.

2008 VOC emission target: 38.83 – 5.82 = 33.00 tpd.

The 15 percent VOC emission reduction and emission target in 2008 in Kent and New 

Castle Counties are calculated as follows:

Kent/New Castle 2002 adjusted VOC baseline relative to 2008 is 72.54 tpd.

Required 15 percent emission reduction: 72.54 x 15% = 10.88 tpd.

2008 VOC emission target: 72.54 – 10.88 = 61.66 tpd.

III. Control Measures and Emission Reductions for RFP

The only post-2002 point source VOC control in Sussex County is Regulation No. 24, 

Section 46, Control of Crude Oil Lightering Operations. Since there were no new VOC controls 

for point sources, non-point source sector, and non-road mobile source sector for VOC emissions 

between 2008 and 2009, Delaware’s 2008 emission reductions and projections are estimated by

interpolating the 2002 base year emissions and the 2009 projections. Kent and New Castle 

Counties applied for and obtained total VOC and NOx emission reductions from facility/unit 

shutdown or modification. The 2008 on-road mobile source VOC emissions were projected 

using EPA’s MOBILE6.2 for obtaining factors and the Peninsula Travel Demand Model 

(PTDM) for predicting future vehicle miles traveled (VMT). Tables 8 and 9 summarize the total 

2008 VOC emission projection for the RFP requirements for Sussex County, and Kent and New 

Castle Counties, respectively.
8

Table 8. Sussex County Total VOC Emission Projection in tpd

Point Source Sector 10.71

Area Source Sector 6.32

Non-Road Mobile Sector 8.01

On-Road Mobile Sector 7.09

Total 2008 Emission Projection 32.13

The total VOC emission projection meets the 2008 emission target under the 15 percent

RFP requirements (33.00 tpd). Therefore, the 2008 RFP in Sussex County is demonstrated.

Table 9. Kent & New Castle Counties Total VOC Emission Projection in tpd

Point Source Sector 10.51

Area Source Sector 21.64

Non-Road Mobile Sector 13.81

On-Road Mobile Sector 14.75

Total 2008 Emission Projection 60.71

The total VOC emission projection meets the 2008 emission target under the 15 percent

RFP requirements (61.66 tpd). Therefore, the 2008 RFP in Kent and New Castle Counties is 

demonstrated.

IV. Contingency Measures

The CAA requires States with nonattainment areas to implement specific control 

measures if the area fails to make RFP (CAA section 172(c)(9)). This CAA provision is a 

requirement for States with moderate and above ozone nonattainment areas to include sufficient 

contingency measures in their RFP so that, upon implementation of such measures, additional 

emission reductions of at least 3 percent of the adjusted 2002 baseline emissions (or a lesser 

percentage that will make up the identified shortfall) would be achieved in the year after the 

failure has been identified. Under the same provision of the CAA, EPA also requires that the 

contingency measures must be fully adopted control measures or rules, so that upon failure to 

meet milestone requirements, the contingency measures can be implemented without any further 

rulemaking activities by the States and/or EPA. For more information on contingency measures, 

see the April 16, 1992 General Preamble (57 FR 13512) and the November 29, 2005 Phase 2 

8-hour ozone implementation rule (70 FR 71612).

To meet the requirements for contingency emission reductions, EPA allows States to 

use NOx emission reductions to substitute for VOC emission reductions in their contingency

plans. The condition set forth by EPA for NOx substitution is that States must achieve a 
9

minimum of 0.3 VOC reductions of the total 3 percent contingency reduction, and the remaining 

2.7 percent reduction can be achieved through NOx emission controls. Delaware included both 

VOC and NOx emission controls as contingency measures in this 8-hour ozone RFP. 

Based on the CAA and EPA requirements on contingency measures, the contingency

VOC reduction for Delaware for the 2008 milestone year is as follows:

The 2002 VOC baseline (statewide) adjusted to 2008 (see Tables 6 and 7 in this 

document) is 111.36 tpd, therefore, contingency VOC emission reduction in 2008 is 111.36 x 3 

percent = 3.34 tpd.

Analysis in Chapter 5.5, page 29 of the Delaware SIP, indicates that the three counties 

in Delaware will have a VOC emission reduction surplus of 1.82 tpd in 2008 [i.e., (33.00 + 

61.66) – (32.13 + 60.71) = (94.66 – 92.84) = 1.82]. Therefore there is 3.34 – 1.82 = 1.52 tpd 

contingency VOC reduction shortfall in 2008. 

Delaware’s 2002 VOC-to-NOx baseline (with respect to 2008) ratio is (38.82 + 72.54): 

(55.95 + 137.34) = 111.36:193.29 = 1:1.74 (Section 4, Tables 4-3 and 4-4 in the Delaware SIP). 

Therefore, the contingency VOC reduction shortfall is equivalent to 1.52 x 1.74 = 2.64 tpd NOx 

reduction shortfall. 

 

Delaware has implemented numerous controls leading to NOx reductions in 2008 that 

are greater than the identified 2.64 contingency shortfall (see subsections 5.4 and 6.4 of the 

Delaware SIP). Therefore, there is no need to specify additional contingency measures for the 

2008 milestone year.

V. RACM Analysis and Determination

Section 172(c)(1) of the CAA and 40 CFR 51.912(d) impose a RACM requirement for 

areas designated nonattainment for the 8-hour NAAQS. Delaware must demonstrate that it has 

adopted all RACM controls necessary to move toward attainment as expeditiously as practicable 

and to meet all RFP requirements.

Section III of this document, demonstrates that the RFP requirements for Delaware 

have been met. Control measures under RACT, constitute a major group of RACM control 

measures for stationary sources. To meet the CAA’s RACT requirements under the 8-hour 

ozone standard, Delaware submitted a RACT SIP revision on October 2, 2006, which certifies 

that all relevant RACT controls have been implemented in Delaware for attaining the 8-hour 

ozone standard. EPA approved Delaware’s 8-hour RACT SIP revision on July 23, 2008 (73 FR 

42681). On May 2, 2007, Delaware submitted a new VOC control from crude oil lightering 

operations. EPA approved this rule on September 13, 2007 (72 FR 52285).
10

In addition to those RACT control measures, Delaware adopted a number of other 

VOC and NOx RACM measures. A summary of the other control measures that Delaware 

adopted are listed in Table 10.

Table 10. Summary of Other Control Measures

Control Measures Date submitted 

to EPA

Approval Date

Regulation 1113 – Tightening of Delaware’s 

Open Burning Regulation

05/02/07 09/20/07 (72 FR 53686)

Regulation 1144 – Control of Stationary

Generator Emissions

11/01/07 04/29/08 (73 FR 23101)

Regulation 1148 – Control of Stationary

Combustion Turbine Emissions

09/11/07 11/10/08 (73 FR 66554)

Regulation 1145 – Restrictions on Excessive 

Idling of Heavy Duty Vehicles

Brandywine School Districts Clean School Bus 

USA grant

Voluntary and mandatory Ozone Action Day

initiatives

There are no additional RACM measures or group of RACM measures that Delaware 

could adopt to advance the attainment date from 2009 to 2008, therefore Delaware has met the 

RACM requirements of the CAA.

VI. Transportation Conformity Budgets

Section 176 of the CAA requires that highway transportation activities in ozone 

nonattainment areas must: (1) establish in their SIP, mobile source VOC and NOx emission 

budgets for each of the milestone years up to the attainment year and submit the mobile budgets 

to EPA for approval; (2) upon adequacy determination or approval of EPA, States must conduct 

transportation conformity analysis for their Transportation Improvement Programs (TIPs) and 

long range transportation plans to ensure highway vehicle emissions will not exceed relevant 

mobile budgets; and (3) failure of demonstrating such transportation conformity lapses resulting 

in freezing of Federal highway funds and all Federal highway projects in the lapsed area. 

The mobile emission budgets for 2008 RFP milestone are based on the projected 2008 

mobile source emissions, accounting for all relevant mobile source controls including all Federal 

controls and Delaware specific controls. The 2008 mobile emissions are projected using EPA’s 

MOBILE6.2 for obtaining emission factors and the “Peninsula Travel Demand Model” for 
11

predicting future vehicle miles traveled (VMT). Table 11 is a summary of the 2008 VOC and 

NOx motor vehicle emissions budgets for the three counties in Delaware. 

Table 11. Motor Vehicle Emission Budgets for 2008

County FIPS 2008 Emissions (tpd)

VOC NOx

Kent 10001 4.14 9.68

New Castle 10003 10.61 21.35

Sussex 10005 7.09 12.86

State Total 21.84 43.89

 On March 21, 2008, EPA posted the availability of these budgets for Delaware on 

EPA’s conformity website for the purpose of soliciting public comments. The public comment 

period closed on April 21, 2008 and no comments were received. On December 19, 2008 (73 FR

77682), EPA published a notice of adequacy for the Delaware 2008 RFP MVEBs. In this notice, 

EPA found that Delaware’s RFP MVEBs are adequate for transportation conformity purposes. 

As a result of EPA’s finding, Delaware shall use the MVEBs from the June 13, 2007 RFP plan 

for future conformity determinations for the 8-hour standard.

 

D. SUMMARY AND RECOMMENDATIONS:

DNREC has used acceptable techniques and methodologies to develop the base year and 

milestone year inventories, the emission reductions for the milestone year, and the effects of noncreditable reductions and pre-1990 CAA rule corrections. VOC and NOx emissions for the 

period between 2002 and 2008 were well below the target level for 2008, and emissions in 2008 

will be below the rate-of-progress target level. Therefore, we recommend approval of the 

Delaware RFP plan, contingency measures, RACM analysis, and the 2002 base year inventory. 

In addition, we recommend the approval of the MVEBs which are based on the RFP plan.