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 (EPA) a request to 

· redesignate the Allentown 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 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 opened a 30-day public comment period on 

April 5, 2014, on the proposed redesignation request, maintenance plan and comprehensive 

emissions inventory for the area. A public hearing was held on May 8, 2014. Comments were 

received from four people. 

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 1 P.O. Box 2063 1 Harrisburg, PA 17105-2063 

717.787.2814 a;:;, 

Printed on Recycled Paper ~Cf www.depweb.state.pa.us 
Mr. Shawn M. 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, by e-mail at jeepps@pa.gov or by telephone at 

717.787.9702. 

Sincerely, 

LcSLfc~~ E. Christopher Abruzzo 

Secretary 

Enclosures 
Commonwealth of Pennsylvania 

Redesignation Request 

Allentown Nonattainment Area 

2006 24-Hour Fine Particulate Matter 

National Ambient Air Quality Standard 

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. 
TABLE OF CONTENTS 

Introduction ......................................................................................................................................1

I. Demonstration of Attainment and Air Quality Trends Analysis .........................................3

A. Design Value Determination....................................................................................4

B. Air Quality Trends Analysis ....................................................................................4

C. Climate Trends Analysis ..........................................................................................7

1. Temperature Trends .....................................................................................8

2. Precipitation Trends ...................................................................................10

D. Additional Trends ..................................................................................................11

1. Population Trends ......................................................................................11

2. Economic Trends .......................................................................................11

E. Modeling Analysis .................................................................................................13

II. SIP Approvals and Applicable Requirements ....................................................................14

A. Section 110(a)(2) of the CAA ................................................................................15

B. Part D - Plan Requirements for Nonattainment Areas ...........................................16

1. Section 172(c) of the CAA ........................................................................16

2. Section 173 of the CAA .............................................................................16

3. Section 176 of the CAA .............................................................................17

4. Section 189(e) of the CAA ........................................................................18

C. Conclusion .............................................................................................................18

III. Demonstration of Permanent and Enforceable Improvement ............................................18

A. Baseline (2005) Emissions Inventory ....................................................................20

B. Attainment Year (2007) Emissions Inventory .......................................................21

C. Control Measures ...................................................................................................22

1. Stationary Point Sources ............................................................................24

2. Highway Vehicle Sources ..........................................................................30

3. Nonroad Sources ........................................................................................33

4. Stationary Area Sources .............................................................................34

IV. Maintenance Plan ...............................................................................................................34

Acronyms and Abbreviations ........................................................................................................36
TABLES 

Table I-1: Allentown Area Annual PM2.5 Concentrations ..............................................................5

Table I-2: Allentown Area 24-Hour PM2.5 Concentrations ............................................................5

Table I-3: Allentown Area Annual PM2.5 Design Values ...............................................................5

Table I-4: Allentown Area 24-Hour PM2.5 Design Values .............................................................6

Table I-5: Allentown Area Monthly Mean Temperature (°F) ........................................................9

Table I-6: Allentown Area Precipitation (inches) .........................................................................10

Table I-7: EPA’s Transport Rule Modeling Results for the PM2.5 Standard for the 

Allentown Area ..........................................................................................................14

Table III-1: 2005 Allentown Area Annual Emissions (Expressed in Tons per Year) ..................21

Table III-2: 2007 Allentown Area Annual Emissions (Expressed in Tons per Year) ..................22

Table III-3: Change in Allentown Area Annual Emissions (Tons per Year) from 2005 to 

2007 ............................................................................................................................23

Table III-4: Summary of Emission Totals (Tons) in 2007, 2017 and 2025 ..................................24

FIGURES 

Figure I-1: Pennsylvania’s 2006 24-Hour PM2.5 Nonattainment Areas .........................................3

Figure I-2: PM2.5 Annual Design Value Trend ...............................................................................6

Figure I-3: PM2.5 24-Hour Design Value Trend .............................................................................7

Figure I-4: Pie Chart of 2007 Allentown Speciation Data ..............................................................8

Figure I-5: Allentown Area Monthly Mean Temperature (°F) .......................................................9

Figure I-6: Allentown Area Annual Precipitation (inches)...........................................................10

Figure I-7: Allentown Area Population Trend ..............................................................................11

Figure I-8: Allentown Area Population and Labor Force Trends .................................................12

Figure I-9: Pennsylvania and National Coincident Indexes from the Philadelphia Federal 

Reserve Bank ..............................................................................................................13
- 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 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 Allentown Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 PM2.5 NAAQS. The Allentown Area was designated nonattainment 
- 2 - 

because the area violated the 2006 24-hour PM2.5 standard of 35 μg/m3based on 2006-2008 

monitoring data. 

The subsequent analyses described in this Request for Redesignation clearly demonstrate that the 

ambient air quality in the Allentown Area now meets the 2006 24-hour PM2.5 NAAQS and that 

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 Allentown Area has completed all criteria set forth in Section 107(d)(3)(E) of the Clean 

Air Act (CAA) and should be officially redesignated as attainment. 

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 

A Maintenance Plan with contingency measures has been fully approved under Section 175A 

(discussed in Section IV).

This Request for Redesignation describes how the Allentown 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 April 5, 2014, DEP 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 

conducted a public hearing on May 8, 2014. The public comment period closed May 9, 2014. 

The Department received comments from four commentators, which have been addressed in a 

Comment and Response document. 
- 3 - 

I. DEMONSTRATION OF ATTAINMENT AND AIR QUALITY TRENDS 

ANALYSIS 

On October 8, 2009, the EPA promulgated air quality designations for the 2006 24-hour 

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

were published in the Federal Register on November 13, 2009 (74 FR 58688). The EPA 

designated seven areas comprised of all or portions of 22 counties in Pennsylvania as 

PM2.5 nonattainment areas. The designations became effective on December 14, 2009. 

The Allentown Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 24-hour PM2.5 NAAQS. The Allentown Area was designated 

nonattainment because the area violated the 2006 24-hour PM2.5 standard of 35 μg/m3

based on 2006-2008 monitoring data. 

Figure I-1: Pennsylvania’s 2006 24-Hour PM2.5 Nonattainment Areas 

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

The Allentown Area’s PM2.5 design values have decreased over the 2001 to 2012 time 

frame. The Allentown Area’s annual and 24-hour design values for 2005 (based on 

2003-2005 monitoring data) were 14.1 μg/m3

and 36 μg/m,3respectively. The Allentown 

Area’s 2012 annual and 24-hour design values (based on 2010-2012 monitoring data) 

were 13.2 μg/m3and 32 μg/m3, respectively. 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. Concentrations are expected to remain lower than 15 μg/m3

and 35 μg/m3

over the next decade. 
- 4 - 

On March 29, 2012, the EPA determined that the Allentown 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 data 

(“Clean Data Determination”) (77 FR 18922). This final action suspended the 

requirements for this area to submit an attainment demonstration and associated 

reasonably available control measures, reasonable further progress plans, contingency 

measures and other planning SIP revisions related to the attainment of the 2006 PM2.5

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

The determination of attainment of the 24-hour PM2.5 NAAQS did not “redesignate” the 

area as “attainment.” The Allentown Area remains nonattainment for the 2006 PM2.5

NAAQS until the Commonwealth submits, and EPA approves, a Request for 

Redesignation and a Maintenance Plan showing the area can maintain the standard for at 

least 10 years. 

A. Design Value Determination 

The Allentown Area currently has two monitoring sites. The Freemansburg 

monitoring site in Northampton County has been in operation throughout the 

2001-2012 timeframe. In 2010, DEP established a new monitoring site in 

Northampton County on Schoenersville Road to satisfy federal monitoring 

program requirements for at least two PM2.5 monitoring sites in the AllentownBethlehem-Easton Metropolitan Statistical Area. The Schoenersville Road 

monitor has not been collecting data long enough to have complete and valid data 

for the 2010-2012 design value. Monitoring data from the Hanover Street 

monitoring site is also displayed in Table 1.1 (relating to Allentown Area annual 

PM2.5 concentrations). However, monitoring at that site was discontinued in 

2005.

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, Appendix N, “Interpretation of the 

National Ambient Air Quality Standards for Particulate Matter.” 

B. Air Quality Trends Analysis 

This section provides a brief summary of PM2.5 monitoring concentrations in the 

Allentown Area. 

Trends in PM2.5 concentrations were analyzed from 2001 through 2012. Table I-1 

displays annual PM2.5 concentrations monitored in the Allentown Area. Table I-2 

(relating to Allentown Area 24-hour PM2.5 concentrations) contains the 

98th percentile of 24-hour concentrations for each year. 
- 5 - 

Table I-1: Allentown Area Annual PM2.5 Concentrations 

Table I-2: Allentown Area 24-Hour PM2.5 Concentrations 

Tables I-3 (relating to Allentown Area PM2.5 design values) and I-4 (relating to 

Allentown Area PM2.5 design values) contain the Allentown Area’s annual and 

24-hour PM2.5 design values using the 2001 through 2012 monitoring data. 

Design values for the annual and 24-hour PM2.5 NAAQS show declining trends. 

The Allentown Area was designated as nonattainment for the 24-hour standard 

based on the 2006-2008 design value of 36 μg/m.3 Compared with the 2006-2008 

design value, the 24-hour design value for 2010-2012 has decreased by 

11 percent. 

Table I-3: Allentown Area Annual PM2.5 Design Values 

Site and AQS ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Freemansburg 

42-095-0025 15.3 14.1 14.3 13.7 14.2 12.7 13.3 12.3 11.9 13.7 14.5 11.5

Hanover Ave 

42-077-0004

15.1 13.1 15.0 14.0 14.5

Schoenersville Rd 

42-095-0027

9.8 11.2 10.9

Annual Mean

Site and AQS ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Freemansburg 

42-095-0025 42.9 46.2 37 35.2 36.2 38.3 37.9 33.1 30.1 33.3 35.2 27.6

Hanover Ave 

42-077-0004

42.8 40 36.6 35.9 36.7

Schoenersville Rd 

42-095-0027

27.6 29.8 26

Annual 98% Concentration

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

Freemansburg 

42-095-0025 14* 14.4* 14.6 14 14.1 13.6 13.4 12.8 12.5 12.6 13.4 13.2

Hanover Ave 

42-077-0004 13.8* 14.2* 14.4* 14.1* 14.5*

Schoenersville Rd 

42-095-0027 9.8* 10.5* 10.6*

Annual PM2.5 NAAQS = 15 ug/m3

Design Value
- 6 - 

Table I-4: Allentown Area 24-Hour PM2.5 Design Values 

The 2001 through 2012 trend lines for annual and 24-hour PM2.5 design values for 

the Freemansburg monitor are shown in Figures I-2 (relating to PM2.5 annual 

design value trend) and I-3 (relating to PM2.5 24-hour design value trend). As 

shown in Figures I-2 and I-3, the slope of the trend lines for the annual and 

24-hour PM2.5 concentrations are both negative, indicating decreasing 

concentrations. The Freemansburg monitor was chosen because it is currently the 

only Allentown Area monitor with valid design values. 

Figure I-2: PM2.5 Annual Design Value Trend 

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

Freemansburg 

42-095-0025 37 42 42 39 36 37 37 36 34 32 33 32

Hanover Ave 

42-077-0004 38 40 40 38 36

Schoenersville Rd 

42-095-0027 28* 29* 28*

2006 24-Hour PM2.5 NAAQS 3 year 98th% = 35 ug/m3

Design Value

y = -0.1517x + 14.536

11

11.5

12

12.5

13

13.5

14

14.5

15

15.5

200120022003200420052006200720082009201020112012

PM2.5 Design Value (ug/m3)

PM2.5 Annual Design Value Trend

Freemansburg Annual

DV

Level of Standard
- 7 - 

Figure I-3: PM2.5 24-Hour Design Value Trend 

C. Climate Trends Analysis 

PM2.5 formation in the eastern United States is a complex process involving local 

and regional meteorology, topography, chemistry and transport. Sulfates and 

nitrates are formed primarily through atmospheric reactions of precursor 

emissions of sulfur dioxide (SO2), oxides of nitrogen (NOX) and ammonia (NH3). 

Organic carbon is a combination of secondary organic particles formed from 

emissions of volatile organic compounds (VOC) and the organic portion of 

primary PM2.5 that is directly emitted or condenses near its source. Currently, our 

understanding of sulfate and nitrate chemistry and its impacts on PM2.5

concentrations far exceeds our understanding of contributions from anthropogenic 

VOCs. This is important because sulfates, nitrates, ammonium and organic 

carbon are major contributors to the total PM2.5, making up approximately 

78 percent of the annual PM2.5 concentration observed in the Allentown Area in 

2007.

y = -0.8077x + 41.667

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

Freemansburg 24-Hour

DV
- 8 - 

Figure I-4: Pie Chart of 2007 Allentown Speciation Data 

Attainment of the PM2.5 NAAQS involves the range of meteorological conditions 

throughout the year. PM2.5 chemistry favors sulfate formation during the warm 

summer months and nitrate formation during the colder winter months. In 

addition, local temperature inversions more common in the winter can concentrate 

emissions near the surface, leading to periods of elevated PM2.5 concentrations. 

To assess whether it is likely that unusual meteorological patterns have 

contributed to the lower PM2.5 concentrations observed in the Allentown 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 Lehigh Valley 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 (relating to Allentown Area monthly mean temperature (°F)) 

presents monthly mean temperature data for the Allentown Area for 2001 

through 2012. Figure I-5 graphically displays the data. 

Freemansburg

 Percentage of Total Mass

 Year 2007

Nitrate

12%

Sulfate

27%

Ammonium

13%

Organic carbon

26%

Elemental carbon

6%

Crustal component

3%

Other

13%
- 9 - 

Table I-5: Allentown Area Monthly Mean Temperature (°F)

Allentown Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2001 27.1 31.5 36.5 50.5 60.6 69.4 68.9 73.6 62.2 53.6 46.9 38.3

2002 34.2 36.1 40.8 52.3 57.4 69.8 75.6 75.0 66.4 51.6 40.8 29.7

2003 23.5 25.7 39.9 48.7 57.2 67.3 74.1 75.0 65.5 51.4 46.8 32.9

2004 21.9 30.6 41.2 51.1 65.8 67.8 72.3 71.6 66.2 52.0 44.6 32.7

2005 26.8 31.6 34.9 52.7 56.3 72.7 75.6 75.6 68.7 55.8 44.8 29.5

2006 36.5 31.8 41.4 52.3 61.0 69.4 75.9 72.7 62.2 51.6 47.5 39.0

2007 33.3 23.9 39.0 47.5 62.4 70.3 72.5 73.0 66.9 60.8 40.8 32.9

2008 31.6 31.3 39.7 52.3 56.3 71.8 74.5 69.4 65.8 50.5 41.2 32.5

2009 23.4 32.0 40.1 51.3 60.4 67.5 70.2 73.0 62.6 51.4 46.8 31.3

2010 28.8 28.9 45.5 53.6 63.1 72.1 76.5 73.2 66.6 53.1 42.3 28.9

2011 23.5 31.3 39.6 52.7 64.2 71.1 77.9 72.1 67.3 53.8 46.6 38.3

2012 33.3 36.7 49.8 51.3 66.2 69.4 77.5 73.4 65.3 54.7 39.6 37.6

Figure I-5: Allentown Area Monthly Mean Temperature (°F)

The Allentown Area was designated nonattainment for the 2006 PM2.5

NAAQS based on 2006 through 2008 monitoring data. These timeframes 

show typical year-to-year variation in temperature with no unusual 

conditions that would be expected to cause higher PM2.5 concentrations as 

experienced. The Allentown Area’s Clean Data Determination for the 

2006 24-hour PM2.5 NAAQS was based on 2008 through 2010 monitoring 

data. The Allentown 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. 

0

10

20

30

40

50

60

70

80

90

degrees Fahrenheit

Monthly Mean Temperature
- 10 - 

2. Precipitation Trends 

Table I-6 (relating to Allentown Area precipitation inches) presents 

monthly and annual precipitation data for the Allentown Area for 2001 

through 2012. Figure I-6 graphically displays the annual precipitation 

data. 

Table I-6: Allentown Area Precipitation (inches) 

Figure I-6: Allentown Area Annual Precipitation (inches) 

The 2006 through 2008 timeframe has typical annual precipitation data. 

Examination of the precipitation data from 2006 through 2012 shows yearto-year variation in precipitation amounts. There is no indication from the 

data that unusual precipitation patterns contributed to the lower PM2.5

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Annual 

Total

2001 2.7 2.4 4.2 1.6 4.4 5.6 4.6 2.5 4.2 0.8 1.1 1.9 35.9

2002 1.5 0.6 3.6 3.8 4.4 4.7 1.1 2.2 2.4 6.8 3.3 5.0 39.4

2003 1.4 3.1 3.6 2.2 3.2 8.3 5.4 5.1 11.1 5.1 3.4 5.0 57.0

2004 2.3 2.5 1.9 3.9 3.8 3.2 8.1 4.5 9.6 3.1 5.0 3.9 51.6

2005 5.4 2.7 3.7 6.6 1.2 4.3 4.2 2.1 0.8 13.2 3.6 3.6 51.4

2006 5.2 2.4 0.9 3.2 1.8 9.1 8.2 2.4 5.8 3.5 4.5 2.3 49.3

2007 2.8 2.0 3.3 5.9 2.4 4.0 5.3 3.5 0.6 6.2 4.4 5.0 45.4

2008 1.3 7.6 5.1 2.9 3.9 3.0 6.1 1.3 8.1 3.0 2.4 6.8 51.5

2009 2.0 0.8 1.7 2.6 4.6 6.8 5.9 4.9 2.9 4.9 1.1 6.3 44.6

2010 2.4 4.2 5.8 3.4 3.9 2.2 8.9 1.7 7.5 4.9 3.0 2.9 50.6

2011 2.7 3.5 6.4 6.0 4.4 4.8 3.9 13.5 13.0 4.5 4.9 4.2 71.8

2012 3.0 1.1 1.0 2.9 5.6 4.4 4.0 3.7 4.8 5.1 1.0 4.3 41.1

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Precipitation (inches)

Annual Precipitation
- 11 - 

concentrations in recent years in which the Allentown Area monitored 

attainment of the PM2.5 NAAQS. 

D. Additional Trends 

1. Population Trends 

The Allentown Area, which consists of Lehigh and Northampton County, 

has had significant population growth over the last decade as shown in 

Figure 1-7 (relating to Allentown Area population trend). The population 

of the Allentown Area increased approximately 11.6 percent between the 

2000 and 2010 Censuses. According to the Bureau of the Census, the 

population of the Allentown Area was 580,153 in 2000 and 647,232 in 

2010. Lehigh and Northampton counties ranked the 11th and 13th largest 

in population in Pennsylvania. 

Population increases correspond with increased emissions from some 

types of emission sources and, therefore, can result in increased pollution 

levels. While the Allentown Area’s population has grown approximately 

11.6 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-7: Allentown Area Population Trend 

2. Economic Trends 

Economic trends could have impacts on emissions and consequently affect 

PM2.5 concentrations in the Allentown Area. The two factors considered 

here include estimated labor force changes in the Allentown Area and 

540,000

560,000

580,000

600,000

620,000

640,000

660,000

Allentown Area Population Trend

Population
- 12 - 

overall economic activity in Pennsylvania as measured by the Coincident 

Index. The labor force data was obtained from the U.S. Department of 

Labor, Bureau of Labor Statistics, Mid-Atlantic Information Office. The 

Coincident Index data was obtained from the Philadelphia Reserve Bank. 

Figure I-8 (relating to Allentown Area population and labor force trends) 

shows the Allentown 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 area’s labor force also contribute to overall 

increases in economic activity (greater family income/spending). The 

Philadelphia Federal Reserve Bank has tracked economic activity in 

Pennsylvania over the last 25 years. 

Figure I-8: Allentown 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 (relating to Pennsylvania and National Coincident Indexes from 

the Philadelphia Federal Reserve Bank). In spite of these upward trends, 

air quality continues to improve in the Allentown Area. 

0

100000

200000

300000

400000

500000

600000

700000

19901992199419961998200020022004200620082010

Allentown Area Population and Labor 

Force Trends

Nonfarm Employment

Population
- 13 - 

Figure I-9: 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)1(Transport Rule) were examined to determine if the model 

results support redesignating the Allentown Area to attainment. EPA’s analysis 

indicates that the Allentown Area would attain the 2006 PM2.5 NAAQS in 2014, 

even in the absence of either the Clean Air Interstate Rule (CAIR) or the 

Transport Rule.

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 

 

1 “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
- 14 - 

removal of ozone, secondary and directly emitted PM2.5, and their precursor 

species on national, regional, and local scales for short-term episodes up to annual 

time periods. Using this model, EPA simulated the emissions from many 

different sources of pollution (such as electric generating units (EGU), and mobile 

sources). All of the Transport Rule 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 Allentown Area) displays the results of EPA’s analysis for the 

Allentown Area. EPA’s analysis indicates that the Allentown Area would attain 

the 2006 PM2.5 NAAQS in 2014, even in the absence of either CAIR or the 

Transport Rule. The results support redesignating the Allentown Area to 

attainment for the PM2.5 NAAQS. 

Table I-7: EPA’s Transport Rule Modeling Results for the PM2.5 Standard 

for the Allentown 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 EPA under Section 110(k) of the CAA. In addition, 

the state must have met all requirements applicable to the area under Section 110 of the 

CAA and Part D-Plan Requirements for Nonattainment Areas. The specific requirements 

applicable to the Allentown 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). The 

U.S. Court of Appeals for the District of Columbia Circuit has also recently held that 

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

420770004 Lehigh Annual 14.50 14.50 12.48 12.48 12.13 12.13

420950025 Northampton Annual 13.68 14.07 11.72 12.06 11.38 11.72

420770004 Lehigh 24-hour 36.4 36.4 31.4 31.4 30.4 30.4

420950025 Northampton 24-hour 36.7 37.4 30.6 31.1 29.6 30.3

PM2.5 Design Values (μg/m3)
- 15 - 

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 Allentown Area. 

A. Section 110(a)(2) of the CAA 

Section 110(a) of the CAA contains the general requirements for a SIP. 

Pennsylvania concludes that, as EPA has stated in previous rulemaking in another 

state2, 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 CAA Section 110(a)(2) of the CAA that are statewide 

requirements and that are not linked to the PM2.5 nonattainment status of the 

Allentown Area are not applicable requirements for purposes of review of the 

Commonwealth’s PM2.5 Redesignation Request. However, EPA requires that the 

Commonwealth’s Prevention of Significant Deterioration (PSD) requirements be 

approved prior to redesignation, because PSD requirements will apply after 

redesignation. Sections 110(a)(2)(C) and 110(a)(2)(J) of the CAA require state 

plans to meet the requirements of CAA, Subchapter I, Part C, which contains PSD 

requirements. In addition, Section 110(a)(2)(I) requires that a plan revision for an 

area designated as a nonattainment area meet the applicable requirements of 

CAA, Subchapter I, Part D (relating to nonattainment areas). Therefore, 

Pennsylvania has concluded that only the parts of Sections 110(a)(2)(C), 

110(a)(2)(I) and 110(a)(2)(J) that relate to Part D applicable requirements or PSD 

are applicable for purposes of redesignation. 

EPA has previously approved provisions of Pennsylvania’s SIP addressing 

Section 110 requirements, including provisions addressing PM2.5. Pennsylvania’s 

SIP measures meeting Section 110(a)(2)(C) and 110(a)(2)(J) requirements are 

fully approved under Section 110(k) of the CAA. The Maintenance Plan 

associated with this Request for Redesignation for the Allentown 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). 

 

2 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). 
- 16 - 

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 March 29, 2012, the EPA determined that the 

Allentown Area had attained the 2006 PM2.5 NAAQS based on quality 

assured, quality controlled and certified ambient air monitoring data that 

show the area had monitored attainment based on 2008-2010 data (“Clean 

Data Determination”) (77 FR 18922). This final action suspended the 

requirements for 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. The 2007 inventory is appropriate to use as an attainment 

year inventory because, considering 2007-2009 ambient air quality 

monitoring data, the area had air quality data that met the 2006 24-hour 

PM2.5 NAAQS. 

2. Section 173 of the CAA 

Section 173 of the CAA outlines requirements related to permitting of air 

pollution sources in nonattainment areas. 

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); 
- 17 - 

● 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 

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. 
- 18 - 

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), DEP considered Section 189(e) of the CAA. According to 

Section 189(e) of the CAA 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 Allentown Area. 

C. Conclusion 

The requirements of Section 110(a) and Subpart D of the CAA have been fulfilled 

in the Allentown Area for the 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 Allentown Area was monitoring nonattainment of the PM2.5 NAAQS and at the time 

when this area attained the PM2.5 NAAQS.3 A 2005 (baseline) inventory of PM2.5 and 

PM2.5 precursor emissions is used to represent emissions during the PM2.5 nonattainment 

designation period. A 2007 inventory is used to identify PM2.5 and PM2.5 precursor 

emissions during a period when the Allentown 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”) 

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 

 

3 Due to rounding, numbers presented throughout this document may not add up precisely to the totals provided. 
- 19 - 

VOC and NH3 only if a technical demonstration is made to show they significantly 

contribute to PM2.5 in that area. 

The EPA reaffirmed the appropriateness of these presumptions in its Implementation 

Guidance for the 2006 24-Hour PM2.5 NAAQS. Meanwhile, the U.S. Court of Appeals 

for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997 

PM2.5 NAAQS, in Natural Resources Defense Council v. EPA, No. 08-1250. On 

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

The Court granted the petitions for review and remanded the case to EPA to 

re-promulgate the rule pursuant to Subpart 4 of Part D of the Clean Air Act, rather than 

implementing it under Subpart 1, as EPA had done (706 F.3d 428, 437 (D.C. Cir. 2013)). 

Shortly thereafter, the EPA withdrew its Implementation Guidance for the 2006 24-Hour 

PM2.5 NAAQS. According to EPA’s June, 2013 withdrawal memorandum (see second 

page of memorandum),4

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 standard 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 Allentown Area is already attaining the 

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) 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 

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) of the CAA 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 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 

 

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

Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013. 
- 20 - 

Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.”

5 Section III 

first describes the PM2.5 and PM2.5 precursor emission estimates for the Allentown 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 Allentown 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 

standard. 

A. Baseline (2005) Emissions Inventory 

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

particular area. The 2005 baseline year emissions inventory represents the 

emissions present when the Allentown Area did not meet the 2006 24-hour PM2.5

standard. 

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

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

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

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

on Monday, June 10, 2002 (67 FR 39602). The CERR required States to prepare 

and submit a comprehensive statewide inventory every three years. 

The 2005 emissions inventory data was obtained from the EPA’s web site for the 

2005 NEI. The data can be accessed at: 

http://www.epa.gov/ttnchie1/net/2005inventory.html. 

Appendix A-2 contains Tier 1 summary data of the 2005 NEI. 

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

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

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

vehicle sources and nonroad sources. The 2005 inventory is not directly 

comparable to the 2007, 2017 and 2025 inventories because of changes in 

inventory methodology. Highway vehicle emissions in the 2005 NEI were 

generated using the MOBILE6 model. For the same VMT and other parameters, 

the MOBILE6 model predicts significantly lower NOX and PM emissions than the 

current model, MOVES2010. In addition, MARAMA adjusted PM emissions to 

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

emission inventories. This results in higher PM emissions in the 2007 inventory 

than were reported by facilities to the Department in 2007. Table III-1(relating to 

2005 Allentown Area annual emissions (expressed in tons per year)) summarizes 

the emissions for 2005. 

 

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

Standards (NAAQS) and Regional Haze Regulations – EPA-454/R-05-001, August, 2005, updated November, 2005. 
- 21 - 

Table III-1: 2005 Allentown Area Annual Emissions (Expressed in Tons per Year) 

Allentown 2005 PM2.5 PM10 SO2 NOX VOC NH3

EGU 2,991 3,582 48,760 10,485 101 71

Non-EGU + Stationary Area 3,747 19,342 14,712 10,360 11,976 1,049

Highway Vehicles 196 286 255 10,653 7,472 506

Non-Road 273 288 310 3,243 2,928 3

Totals 7,207 23,498 64,036 34,742 22,477 1,629

B. Attainment Year (2007) Emissions Inventory 

A 2007 inventory of PM10, PM2.5, SO2, NOX, VOC and NH3 emissions for the 

Allentown Area is used to identify emissions during the period when attainment 

of the PM2.5 NAAQS was demonstrated for the Allentown Area. 

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. 

The inventory contains information for these sectors: 

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

DEP 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. 

● “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. 
- 22 - 

A Summary of the 2007 inventory is provided in Table III-2 (relating to 2007 

Allentown Area annual emissions expressed in tons per year). 

Table III-2: 2007 Allentown Area Annual Emissions (Expressed in Tons per Year) 

Allentown 2007 PM2.5 PM10 SO2 NOX VOC NH3

Stationary Point Sources 3,565 4,641 54,071 13,663 1,151 31

Area Sources 2,150 6,415 2,552 1,987 8,266 582

Highway Vehicle Sources 536 647 118 15,857 6,936 245

Non-Road Sources 256 272 158 3,177 2,685 3

Totals 6,507 11,975 56,900 34,685 19,038 861

Inventory methodology differences exist between the 2005 and 2007 emission 

inventories. Highway vehicle emissions in the 2005 NEI were generated using 

the MOBILE6 model. For the same VMT and other parameters, the MOBILE6 

model predicts significantly lower NOX emissions than the current model, 

MOVES2010. The MOBILE6 model also predicts lower direct PM2.5 emissions 

than MOVES2010. In addition, MARAMA adjusted PM emissions to account for 

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

inventories. This results in higher PM emissions in the 2007 inventory than were 

reported by facilities to the Department in 2007. 

While the 2005 emissions inventory is not directly comparable to the 2007, 2017 

and 2025 inventories, PM2.5, SO2, NOX, VOC, and NH3 emissions decreased by 

10%, 11%, 0.2%, 15% and 47% respectively, from 2005 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 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 that provided PM2.5, SO2, NOX and 

VOC emission reductions from 2002 to 2007 to bring the Allentown Area into 

attainment and measures that will assure maintenance of the standard. 

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, DEP recognizes the Court decision in 

Natural Resources Defense Council v. EPA, No. 08-1250, 706 F.3d 428 
- 23 - 

(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 

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 Allentown 

Area is already attaining the 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) 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 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) of the CAA 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 Allentown Area decreased 

by 10 percent, 11 percent, 0.2 percent, 15 percent and 47 percent, respectively, 

from 2005 to 2007. The permanent and enforceable reductions of direct PM2.5, 

SO2, NOX and VOC emissions, as described in more detail in Section III, 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 2005 to 2007 is included in Table III-3 (relating to 

change in Allentown Area annual emissions (expressed in tons per year) from 

2005 to 2007. The negative values in Table III-3 indicate emission reductions. 

Table III-3: Change in Allentown Area Annual Emissions (Tons per Year) 

from 2005 to 2007 

Change from 2005 to 2007 PM2.5 SO2 NOX VOC NH3

Point and Area Sources -1,023 -6,848 -5,194 -2,660 -507

Highway Vehicle Sources 340 -136 5,204 -536 -261

Nonroad Sources -17 -151 -66 -243 0

TOTAL -699 -7,136 -57 -3,439 -768
- 24 - 

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 

standard. 

A summary of the total emissions in 2007 and projected estimates for 2017 and 

2025 is included in Table III-4 (relating to summary of emission totals (tons) in 

2007, 2017 and 2025). The emission estimates account for any anticipated 

growth in the activity of sources and include a transportation conformity safety 

margin for PM2.5 and NOX. For all pollutants, emissions in 2017 and 2025 in the 

Allentown Area are anticipated to be lower than they were in 2007. This means 

that the projected growth in emissions is smaller than anticipated emission 

reductions from control measures for all pollutants in the nonattainment area. 

Based on 2010-2012 monitoring data, the Allentown Area has a 24-hour design 

value of 32 μg/m,3 which is significantly lower than the 2006 PM2.5 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 

Allentown PM2.5 SO2 NOX VOC NH3

2007 6,507 56,900 34,685 19,038 861

2017* 5,825 27,731 20,471 14,627 809

2025* 5,745 26,850 17,218 13,133 807

*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.
- 25 - 

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 1, 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 
- 26 - 

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 

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 
- 27 - 

determines BAT requirements on a case-by-case basis for both 

major and minor stationary sources taking into account energy, 

environmental 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 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 
- 28 - 

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 

(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. 
- 29 - 

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 

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 
- 30 - 

enforceable plan approvals and permits issued by DEP for affected 

sources. 

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.

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 
- 31 - 

manufacturers operating under the NLEV program became subject to the 

Tier 2 requirements. 

Pennsylvania amended the former New Motor Vehicle Control Program in 

2006. The Clean Vehicles Program continues to incorporate the 

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. 
- 32 - 

Because the new engine standards are adversely affected by sulfur in fuel, 

the EPA also required most highway diesel fuel to contain no more than 

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

was a temporary compliance option allowing refiners to continue to 

produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

2010. The Department used MOVES defaults to estimate the effects of 

the phase-in provision. 

Vehicle Emission Inspection/Maintenance Program. In early 2004, 

Pennsylvania expanded its Vehicle Emission Inspection/Maintenance 

(I/M) Program into the Allentown Area. The program applies to gasolinepowered vehicles 9,000 pounds and under, model years 1975 and newer. 

For vehicles 1996 and newer, the program consists of an annual on-board 

diagnostics test and a gas cap pressure test. For subject vehicles 1995 and 

older, the program consists of an annual visual inspection of pollution 

control devices to ensure they are present, connected and the proper type 

for the vehicle and a gas cap pressure test. These regulations can be found 

in 67 Pa. Code Chapter 177. The Department submitted the expanded 

emissions program to EPA as a SIP revision on December 1, 2003. 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.

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 
- 33 - 

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 Allentown 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. This requirement does not impact the Allentown Area because 

the Allentown Area does not have emissions from commercial marine 

vessels. 
- 34 - 

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). 

Adhesives, Sealants, Primers and Solvents. The EQB adopted a 

regulation in 2010 to control VOC emissions from adhesives, sealants, 

primers and solvents. This regulation was published in the Pennsylvania 

Bulletin on December 25, 2010 (40 Pa.B. 7340) and approved by EPA as a 

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

IV. MAINTENANCE PLAN 

The Maintenance Plan for the Allentown Area is being submitted to EPA for approval as 

a SIP revision concurrently with this Request for Redesignation. The Maintenance Plan 

shows that the 2006 PM2.5 NAAQS will be maintained for at least 10 years after 

redesignation. Eight years following redesignation, the Commonwealth will submit a 

revised plan that ensures attainment through 2035. 

The Maintenance Plan 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 Allentown Area has a 24-hour design value of 32 μg/m,3 which is 

significantly lower than the 2006 NAAQS of 35 μg/m.3 In addition, based on 2010-2012 

monitoring data, the Allentown Area currently has an annual design value of 13.2 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); 
- 35 - 

● State regulation of the sulfur content of fuel oil; 

● State regulation of VOC emissions from adhesives, sealants, primers and solvents; 

● The Pennsylvania and federal new motor vehicle emission control programs for 

passenger and light-duty trucks; 

● The Pennsylvania and federal heavy-duty diesel emission control programs; 

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

● Federal regulation of off-road diesel and gasoline-powered vehicles and 

equipment. 

Emission reductions from Pennsylvania’s Diesel-Powered Motor Vehicle Idling Act, 

Act 124 of 2008 (Idling Act) were not included in the 2017 and 2025 emission 

inventories, and, thus, were not relied upon for the demonstration of maintenance. The 

Idling Act was approved by EPA as a SIP revision on August 1, 2011 (76 FR 45705). 

Similarly, NOX and VOC emission reductions from Pennsylvania’s Outdoor Wood-Fired 

Boilers regulation were not included in the 2017 and 2025 emission inventories, and were 

not relied upon for the demonstration of maintenance. 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). Emission reductions from the federal Tier 3 Motor Vehicle Emission and 

Fuel Standards program were also not included in the future year inventories and were 

not relied upon for the demonstration of maintenance. However, emission reductions 

from these measures may nonetheless assist the Allentown Area in maintaining air 

quality. 

DEP has provided in the Maintenance Plan for the 2006 PM2.5 NAAQS assurances that it 

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

maintenance of the standard and to evaluate emissions inventories periodically compared 

to the projections provided in the plan. DEP has also provided in the Maintenance Plan a 

list of contingency measures that it would consider to correct any violation of the 2006 

PM2.5 NAAQS that might occur after redesignation of the area. 
- 36 - 

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 
- 37 - 

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 
Commonwealth of Pennsylvania 

State Implementation Plan Revision: 

Maintenance Plan and 

Comprehensive Inventory 

Allentown Nonattainment Area 

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
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- i - 

Table of Contents 

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

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

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

C. Purpose and Structure of this SIP Revision .............................................................4

D. Public Participation ..................................................................................................8

II. Emission Inventories ............................................................................................................8

A. Baseline Year (2005) Annual Emissions Inventory (Tons per Year) ......................9

B. Attainment Year (2007) Annual Emissions (Tons per Year) ................................10

C. Growth Projection Methodologies for 2017 and 2025 ..........................................14

D. Interim Year (2017) Emissions ..............................................................................17

E. Maintenance Year (2025) Emissions .....................................................................17

F. Maintenance Plan Emissions Test .........................................................................18

III. Permanent and Enforceable Control Measures ..................................................................19

A. Permanent and Enforceable Control Measures ......................................................19

1. Stationary Point Sources ............................................................................22

2. Highway Vehicle Sources ..........................................................................27

3. Nonroad Sources ........................................................................................30

4. Stationary Area Sources .............................................................................31

B. Motor Vehicle Emission Budgets for Transportation Conformity ........................32

IV. Ambient Air Quality Monitoring Network ........................................................................35

V. Verification of Continued Attainment ...............................................................................35

VI. Contingency Measures .......................................................................................................36

Table of Tables 

Table II-1: Allentown Area 2005 Annual Emissions (Tons per Year) ........................................ 10

Table II-2: Allentown Area 2007 Annual Emissions (Tons per Year) ........................................ 13

Table II-3: Allentown Area VMT (Miles) and Vehicle Emissions (Tons per Year) ................... 16

Table II-4: Allentown Area Projected 2017 Emissions (Tons per Year) ..................................... 17

Table II-5: Allentown Area Projected 2025 Emissions (Tons per Year) ..................................... 18

Table II-6: Allentown Area Maintenance Emissions Test ........................................................... 19

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

Measures ................................................................................................................... 21

Table III-2: Motor Vehicle Emission Budgets (Tons per Year) .................................................. 33

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

2017 and 2025 .......................................................................................................... 34

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

Total Projected 2025 Inventory ................................................................................ 34
- ii - 

APPENDICES 

APPENDIX A: STATIONARY POINT SOURCES

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

Instructions for Completing the Annual Emissions Reporting Forms

A-2 2005 NEI Tier 1 Summary 

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

A-4 Banked Emissions Reduction Credits 

APPENDIX B: STATIONARY AREA SOURCES 

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

Methods (Dec. 2009) 

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

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 –2007, 2017, 2025 

D-3 MOVES Input Parameter Summary 

D-4 MOVES Input and Output Files 

APPENDIX E: NONROAD SOURCES

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

I. INTRODUCTION AND OVERVIEW 

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

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

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

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

or mold spores). Fine 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,3based 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/m3

determined by the 3-year average of the 98th percentile of 

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

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

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

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

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

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

became effective on December 14, 2009. 

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

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

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

NAAQS of 35 μg/m3

based on 2006-2008 monitoring data. 

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 
- 3 - 

 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 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.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(DC Cir. 2013)). 

Shortly thereafter, EPA withdrew its Implementation Guidance for the 2006 

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

 

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.
- 4 - 

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 standard 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 Allentown Area is already attaining the 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, 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 

Clean Air Act (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) of the CAA 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 

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 

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 CAA, 

Pennsylvania is required to develop a revision to the SIP to demonstrate how the 

Allentown Area will attain the standard by December 2014, meet emission 

reduction requirements in the CAA and ensure that in the event of a future 

violation or failure to meet emission reduction milestones, the area is brought 

back to attainment as quickly as possible. 

 

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. 

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 - 

However, on March 29, 2012, the EPA determined that the Allentown Area had 

attained the 2006 PM2.5 NAAQS based on 2008-2010 quality assured, quality 

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

monitored attainment (“Clean Data Determination”) (77 FR 18922). This final 

action suspended the requirements for this area to submit an attainment 

demonstration and associated reasonably available control measures, reasonable 

further progress plans, contingency measures and other planning SIP revisions 

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

continues to attain the 2006 PM2.5 NAAQS. 

EPA’s determination of attainment and the Clean Data Determination did not 

“redesignate” the area as “attainment.” The Allentown Area remains a designated 

nonattainment area for the 2006 PM2.5 NAAQS until the Commonwealth submits, 

and EPA approves, a Request for Redesignation and a Maintenance Plan showing 

the area can maintain the standard 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 Allentown Area for the 

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

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

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

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

inventory representing a level of emissions sufficient for the Allentown Area to 

attain the 2006 PM2.5 NAAQS. 

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

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

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

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

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. 
- 6 - 

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 Allentown 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 Allentown 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 

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. 
- 7 - 

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

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

attainment of the standard. The Maintenance Plan shows that emission levels of 

PM2.5 and its precursors over the 10 years following redesignation remain at levels 

that will provide for maintenance of the PM2.5 NAAQS, even considering growth 

in population and vehicle miles traveled. 

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

will ensure the continuing 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; 

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

solvents; 

 The Pennsylvania and federal new motor vehicle emission control 

programs for passenger and light-duty trucks; 

 The Pennsylvania and federal heavy-duty diesel emission control 

programs;

 Federal fuel programs for highway vehicles and nonroad mobile 

equipment; and 

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

equipment. 

Emission reductions from Pennsylvania’s Diesel-Powered Motor Vehicle Idling 

Act, Act 124 of 2008 (Idling Act), were not included in the 2017 and 2025 

emission inventories, and, thus, were not relied upon for the demonstration of 

maintenance. The Idling Act was approved by EPA as a SIP revision on 

August 1, 2011 (76 FR 45705). Similarly, NOX and VOC emission reductions 

from Pennsylvania’s Outdoor Wood-Fired Boilers regulation were not included in 

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

demonstration of maintenance. 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). 

Emission reductions from the federal Tier 3 Motor Vehicle Emission and Fuel 

Standards program (79 FR 23414) were not included in the future year inventories 

and were not relied upon for the demonstration of maintenance. Emission 

reductions from these measures may nonetheless assist the Allentown Area in 

maintaining the PM2.5 NAAQS. 
- 8 - 

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 standard 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 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 April 5, 2014, DEP 

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

the Allentown Area Maintenance Plan for the 2006 PM2.5 NAAQS, 2007 

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

Request to Redesignate the Allentown Area to attainment for the 2006 PM2.5

standard. The Department conducted a public hearing on May 8, 2014. The 

public comment period closed May 9, 2014. The Department received comments 

from four commentators, which have been addressed in a Comment and Response 

Document. 

II. EMISSION INVENTORIES 

To demonstrate maintenance of the 2006 PM2.5 NAAQS for the Allentown 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 2025.5

 This Maintenance Plan also 

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

Allentown Area did not meet the 2006 PM2.5 NAAQS. In addition, this SIP revision 

fulfills the requirement for a comprehensive inventory for the Allentown 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. 

 

5 Due to rounding, numbers presented throughout this document may not add up precisely to the totals provided. 
- 9 - 

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

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

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

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

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

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

adjusted to remove any double counting. 

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

trucks, buses and motorcycles. 

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

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

construction machinery, lawn and garden equipment, industrial equipment, 

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

aircraft. 

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

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

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

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

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

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

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

A. Baseline Year (2005) Annual Emissions Inventory (Tons per Year) 

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

area. The 2005 baseline year emissions inventory represents the emissions 

present during a time period when the Allentown Area did not meet the 2006 

PM2.5 NAAQS. 

The 2005 National Emissions Inventory (NEI) is a composite of emission 

estimates reported by state and local agencies and industry, as well as estimates 

generated by EPA. The 2005 NEI was based in part on information submitted by 

DEP under the Consolidated Emissions Reporting Rule (CERR), which was 

published in the Federal Register on Monday, June 10, 2002 (67 FR 39602). The 

CERR required States to prepare and submit a comprehensive statewide inventory 

every three years. 

The 2005 emissions inventory data was obtained from the EPA’s web site for the 

2005 NEI. The data can be accessed at: 

http://www.epa.gov/ttnchie1/net/2005inventory.html. 

Appendix A-2 contains Tier 1 summary data of the 2005 NEI. 
- 10 - 

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

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

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

vehicle sources and nonroad sources. The 2005 inventory is not directly 

comparable to the 2007, 2017 and 2025 inventories because of changes in 

inventory methodology. Highway vehicle emissions in the 2005 NEI were 

generated using the MOBILE6 model. For the same VMT and other parameters, 

the MOBILE6 model predicts significantly lower NOx and PM2.5 emissions than 

the current model, MOVES2010. In addition, MARAMA adjusted PM emissions 

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

emission inventories. This results in higher PM emissions in the 2007 inventory 

than were reported by facilities to the Department in 2007. Table II-1 summarizes 

the emissions for 2005. 

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

Allentown 2005 PM2.5 PM10 SO2 NOx VOC NH3

EGU 2,991 3,582 48,760 10,485 101 71

Non-EGU + Stationary Area 3,747 19,342 14,712 10,360 11,976 1,049

Highway Vehicles 196 286 255 10,653 7,472 506

Non-Road 273 288 310 3,243 2,928 3

Totals 7,207 23,498 64,036 34,742 22,477 1,629

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

Stationary Point Sources. The 2007 stationary point source inventories were 

based on emissions reported to DEP by facilities. DEP 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 2005 annual emissions (NEI Tier 1). 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 Allentown 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 
- 11 - 

emission factors for EGUs developed for MARAMA in 2008 to calculate 

condensable PM emissions where that data was missing. [Earlier inventories did 

not include condensable PM for many facilities.] 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. 

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. 

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

inventory. Additional methodology information is available in the technical 

support document for the 2007 regional inventory which is contained in 

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

emissions data for 2002 for the Allentown Area. Appendix B-2 contains the 

stationary area source emissions data for 2007, 2017 and 2025 for the Allentown 

Area. 
- 12 - 

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. DEP employed 

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

2025.

More information on highway emission methodology is available in Appendix D. 

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

mobile emissions inventory. Appendix D-2 provides the 2007 attainment year 

and 2017 and 2025 projections of mobile (highway) 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 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 
- 13 - 

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. 

Commercial Marine Vessels. The Allentown Area does not have emissions from 

commercial marine vessels. 

Summary of 2007 Emissions Inventory. An emissions inventory of 2007 

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

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

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

for 2007. Inventory methodology differences exist between the 2005 and 2007 

emission inventories. Highway vehicle emissions in the 2005 NEI were generated 

using the MOBILE6 model. For the same VMT and other parameters, the 

MOBILE6 model predicts significantly lower NOx emissions than the current 

model, MOVES2010. The MOBILE6 model also predicts lower direct PM2.5

emissions than MOVES2010. In addition, MARAMA adjusted PM emissions to 

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

emission inventories. This results in higher PM emissions in the 2007 inventory 

than were reported by facilities to the Department in 2007. While the 2005 

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

inventories, PM2.5, SO2, NOX, VOC, and NH3 emissions decreased by 10 percent, 

11 percent, 0.2 percent, 15 percent and 47 percent, respectively, from 2005 to 

2007.

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

Allentown 2007 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 3,565 4,641 54,071 13,663 1,151 31

Area Sources 2,150 6,415 2,552 1,987 8,266 582

Highway Vehicle Sources 536 647 118 15,857 6,936 245

Non-Road Sources 256 272 158 3,177 2,685 3

Totals 6,507 11,975 56,900 34,685 19,038 861
- 14 - 

C. Growth Projection Methodologies for 2017 and 2025

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

estimates of emissions changes between 2007 and interim year 2017 and 

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

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

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

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

implementation schedules used in the emission projection calculations for each 

source category. MARAMA coordinated development of the projection 

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

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

Significant infrastructure development to extract natural gas from the Marcellus 

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

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

and compressor stations. The Allentown Area has not experienced any Marcellus 

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

the future. 

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. 
- 15 - 

NonEGU point source and stationary area source growth factors were developed 

using: 

 Annual Energy Outlook (AEO) fuel consumption forecasts; 

 State-level employment projections by NAICS code; and 

 Other state-specific emission projection data. 

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

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

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

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

were available during inventory development. After AEO2011 was published, 

MARAMA compared the AEO2010 and AEO2011 projections. Minor 

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

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

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

used. 

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

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

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

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

Because of the possibility that 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. 

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 
- 16 - 

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, VMT for the future analysis year increases 38 percent 

from 4.97 billion VMT in 2007 to 6.87 billion VMT in 2025 within the 

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

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

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

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

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

conformity. 

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

Year VMT PM2.5 PM10 SO2 NOx VOC NH3

2007 4,966,652,963 536 647 118 15,857 6,936 245

2017 5,839,859,951 258 378 43 7,346 3,791 175

2025 6,865,965,228 203 358 47 4,821 2,410 174

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 

LTOs are reported for 2007 and projected LTOs are provided for all years up to 

2030. New aircraft emission controls that will be used in the future were also 

taken into account. 

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

AEO2010 growth projections published in May 2010. There are separate 
- 17 - 

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. 

Additional information about nonroad emission projection methodologies can also 

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

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

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

D. Interim Year (2017) Emissions 

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

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

Appendix C, relating to the regional emissions inventory and projection 

methodology, contains the technical support documents that describe the 

methodologies used to project the 2007 emissions to 2017.

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

Allentown 2017 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 3,229 4,203 9,753 7,963 1,209 42

Area Sources 2,069 6,491 2,087 1,921 7,966 588

Highway Vehicle Sources* 297 378 43 8,081 3,791 175

Non-Road Sources 169 182 7 1,764 1,647 3

Emission Reduction Credits 60 145 15,841 743 14 0

Totals 5,825 11,399 27,731 20,471 14,627 809

*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. 

E. Maintenance Year (2025) Emissions 

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

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

Appendix C, relating to the regional emissions inventory and projection 

methodology, contains the technical support documents that describe the 

methodologies used to project the 2007 emissions to 2025.
- 18 - 

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

Allentown 2025 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 3,365 4,319 9,837 7,951 1,243 37

Area Sources 1,958 6,545 1,118 1,936 7,876 592

Highway Vehicle Sources* 234 358 47 5,303 2,410 174

Non-Road Sources 128 139 7 1,284 1,591 4

Emission Reduction Credits 60 145 15,841 743 14 0

Totals 5,745 11,506 26,850 17,218 13,133 807

*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. 

F. Maintenance Plan Emissions Test 

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

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

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

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

account. 

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 (DC 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 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) of the CAA 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 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. Emissions of SO2 and NOx are projected to decrease from 2007 to 

2025 by approximately 30,050 tons (53 percent) and 17,467 tons (50 percent). 

Emissions of PM2.5, VOC and NH3 are also projected to decrease from 2007 to 
- 19 - 

2025 by approximately 763 tons (12 percent), 5,905 tons (31 percent), and 54 tons 

(6 percent), respectively. 

Table II-6: Allentown Area Maintenance Emissions Test 

Allentown PM2.5 SO2 NOx VOC NH3

2007 6,507 56,900 34,685 19,038 861

2017* 5,825 27,731 20,471 14,627 809

2025* 5,745 26,850 17,218 13,133 807

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

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

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

III. PERMANENT AND ENFORCEABLE CONTROL MEASURES 

A. Permanent and Enforceable Control Measures 

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

formation, the EPA recognizes that 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.6 Meanwhile, the 

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

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

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

 

6 See footnote 2, above. 
- 20 - 

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(DC 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),7EPA withdrew the guidance in 

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

No. 08-1250. 

This Maintenance Plan demonstrates maintenance of the standard 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). Since the Allentown Area is already attaining the 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, 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 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) of the CAA 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 

standard. 

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

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

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

sources regulated by the strategy and include emissions in the transportation 

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

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

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

emission reductions from control measures for all pollutants in the nonattainment 

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

 

7 See footnote 3, above. 
- 21 - 

sections. The Allentown Area currently has an annual design value of 13.2 μg/m3 

and a 24-hour design value of 32 μg/m,3based on 2010- 2012 monitoring data, 

which is significantly lower than 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 SO2 NOx VOC NH3

Stationary Point Sources -140 -28,394 -4,969 106 6

Area Sources -192 -1,434 -51 -390 10

Highway Vehicle Sources* -303 -71 -10,554 -4,526 -71

Nonroad Sources -128 -151 -1,893 -1,095 1

TOTAL -763 -30,050 -17,467 -5,905 -54

*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 SIP; the Title V Operating 

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

(61 FR 39597). 

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

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

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

requirements for reporting and recordkeeping for plan approval applications. 

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

applications) for permit applications. Sections 145.145 and 145.146 contain the 
- 22 - 

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 

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 
- 23 - 

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 

nonattainment NSR requirements are codified in 25 Pa. 
- 24 - 

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, 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 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 to the 

maximum degree possible and which are available or may be made 
- 25 - 

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 

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 
- 26 - 

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 

engine regulations that were adopted pursuant to the NOX SIP Call. 
- 27 - 

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 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 

by the CAA Amendments of 1990 include NOX and VOC limits for light-
- 28 - 

duty 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.

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 

required, among other terms, that diesel engines made by these companies 

comply with these 2004 standards two model years early, in MY 2002. 
- 29 - 

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. In early 2004, 

Pennsylvania expanded its Vehicle Emission Inspection/Maintenance 

(I/M) Program into the Allentown Area. The program applies to gasolinepowered vehicles 9,000 pounds and under, model years 1975 and newer. 

For vehicles 1996 and newer, the program consists of an annual on-board 

diagnostics test and a gas cap pressure test. For subject vehicles 1995 and 

older, the program consists of an annual visual inspection of pollution 

control devices to ensure they are present, connected and the proper type 

for the vehicle and a gas cap pressure test. These regulations can be found 

in 67 Pa. Code Chapter 177. The Department submitted the expanded 
- 30 - 

emissions program to EPA as a SIP revision on December 1, 2003. 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 Allentown 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 
- 31 - 

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. This requirement does not impact the Allentown Area because 

the Allentown Area does not have emissions from commercial 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 and determined by EPA on March 28, 

2013 to be administratively complete. On February 20, 2014, EPA 

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).
- 32 - 

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). 

Adhesives, Sealants, Primers and Solvents. Pennsylvania adopted a 

regulation in 2010 to control VOC emissions from Adhesives, Sealants, 

Primers and Solvents. This regulation was published in the Pennsylvania 

Bulletin on December 25, 2010 (40 Pa.B. 7340) and approved by EPA as a 

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

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 Allentown Area is the Lehigh Valley Transportation Study 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 2006 PM2.5 standard were published in the Federal Register on 

March 24, 2010 (75 FR 14260), to account for PM2.5 and its precursors.8 In the 

 

8 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. 
- 33 - 

transportation 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 transportation-related 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, once the EPA approves it for 

purposes of conformity, will establish transportation conformity budgets for the 

Allentown Area. 

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

Allentown PM2.5 NOx

2007 536 15,857

2017 Predicted 258 7,346

Safety Margin 39 735

2017 Budget 297 8,081

2025 Predicted 203 4,821

Safety Margin 31 482

2025 Budget 234 5,303

The highway emission budgets include a safety margin to accommodate 

unanticipated growth in highway vehicles. The safety margins were created by 

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

year emissions of PM2.5 and NOX. Table III-3 shows that the amount of emission 

reductions anticipated between 2007 and 2017 and between 2007 and 2025 easily 

accommodates the safety margins granted. 
- 34 - 

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

Emission Reductions in 2017 and 2025 

Allentown Area Total Emissions PM2.5 NOx

2007 6,507 34,685

2017 5,786 19,737

2025 5,714 16,736

2007 – 2017 Anticipated Emission Reductions 721 14,948

Margin Granted 39 735

2007 - 2025 Anticipated Emission Reductions 793 17,949

Margin Granted 31 482

For informational purposes, DEP analyzed the projected 2025 inventory and 

found that highway emissions of VOC, NH3, and SO2 account for approximately 

18 percent, 22 percent, and 0.2 percent of the total projected 2025 inventory, 

respectively, as shown in Table III-4. 

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

to the Total Projected 2025 Inventory 

2025 SO2 VOC NH3

On-Road Mobile Source Projected Inventory (Tons) 47 2,410 174

Total Projected 2025 Inventory (Tons) 26,850 13,133 807

Percent of Total Projected 2025 Inventory (%) 0.18 18.35 21.55

The motor vehicle emission budgets include PM from vehicle exhaust, brake 

wear, and tire wear, which are estimated by the MOVES model. The Department 

has included direct PM2.5 re-entrained road dust emissions from paved and 

unpaved roads in the area source inventory, not in the motor vehicle emission 

budgets. Appendix B-2, relating to area source annual emissions, contains 

estimates of the PM2.5 emissions attributable to paved and unpaved roads. 

The Freemansburg monitoring site located in Northampton County includes a 

monitor that measures PM2.5 mass and a speciation monitor that collects data on 

the chemical constituents of PM2.5 in the Allentown Area. Transportation 

construction-related fugitive dust emissions are not a significant contributor to the 

PM2.5 concentrations observed at the Allentown monitor. At the Allentown 

monitor, the crustal component was found to be small compared to other 

components of PM2.5 (See, Figure 1). Given that construction-related fugitive 

dust is one of many source categories contributing to the crustal material observed 

at the monitor, and transportation construction is a small subset of all 

construction, it is reasonable to conclude that transportation construction-related 

fugitive emissions are insignificant. 
- 35 - 

Figure 1. Pie Chart of 2007 Allentown Speciation Data 

IV. AMBIENT AIR QUALITY MONITORING NETWORK 

The DEP will continue to operate the air monitoring network in accordance with 40 CFR 

Part 58 to verify the attainment status of the Allentown Area for the 2006 PM2.5 NAAQS, 

with no reductions in the number of sites from those in the existing network unless preapproved by EPA. The DEP has concurrently submitted a request for redesignation of 

the Allentown Area that contains analysis of ambient air quality data and related factors.

V. VERIFICATION OF CONTINUED ATTAINMENT 

The Department will track the attainment status of the 2006 PM2.5 NAAQS in the 

Allentown Area by reviewing air quality and emissions data during the maintenance 

period. The Department 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 Department 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 Department will 

consider whether any further emission control measures should be implemented. 

Freemansburg

 Percentage of Total Mass

 Year 2007

Nitrate

12%

Sulfate

27%

Ammonium

13%

Organic carbon

26%

Elemental carbon

6%

Crustal component

3%

Other

13%
- 36 - 

VI. CONTINGENCY MEASURES 

The Department will adopt and expeditiously implement corrective actions, as necessary 

and appropriate, in the following circumstances: 

A first level response will be prompted if the 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 Allentown 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 98th percentile 24-hour 

PM2.5 concentrations exceeds 35.0 μg/m3 within the maintenance area. If this trigger 

point occurs, the Department will evaluate whether additional emission control measures 

should be implemented in order to prevent a violation of the air quality standard. The 

Department will analyze the conditions leading to the PM2.5 levels and evaluate what 

measures might be most effective in correcting the PM2.5 levels. The Department will 

also analyze the potential emissions effect of federal, state and local measures that have 

been adopted but not yet implemented at the time the second level response is triggered. 

The Department will then begin the process of adopting any selected measures that are 

necessary and appropriate so that in the event of a violation, the measures can be 

implemented as expeditiously as practicable. 

If a violation of the PM2.5 NAAQS occurs, the Department will propose and adopt 

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

practicable in accordance with the implementation schedule in this section, the CAA, the 

Pennsylvania Air Pollution Control Act, other Pennsylvania statutory requirements, and 

the Department’s Policy for Development, Approval and Availability of Regulations in 

order to return the area to attainment with the standard. 

Additional emission reduction measures to be considered for adoption if a violation of the 

NAAQS occurs in the Allentown 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. 
- 37 - 

Additional emission reduction measures the Department would consider pursuing for 

promulgation if a violation of the NAAQS occurs in the Allentown Area include the 

following: 

Regulatory measures: 

 A regulation based on the OTC Model Rule to update requirements for consumer 

products; 

 A regulation based on the Control Techniques Guidelines (CTG) for industrial 

cleaning solvents; and 

 Other regulatory measures identified based on the above-listed criteria. 

Non-regulatory measures: 

 Voluntary diesel projects: 

o Diesel retrofit (including replacement, repowering or alternative fuel use) 

for public or private local onroad or offroad fleets; 

o Idling reduction technology for Class 2 yard locomotives; and

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

other freight-handling facilities. 

 Promotion of accelerated turnover of lawn and garden equipment, especially 

commercial equipment. 

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

use. 

Once the Department’s Bureau of Air Quality has obtained an approved request to initiate 

a rulemaking, the rulemaking may proceed as follows: 

Within 2 months: Review by Air Quality Technical Advisory Committee 

(AQTAC), Citizens Advisory Council and other advisory committees,9as 

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. 

 

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

Committee. 
- 38 - 

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.
- 39 - 

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) 
- 40 - 

NMIM National Mobile Inventory Model 

NOX Oxides of Nitrogen 

NSR New Source Review 

OTAQ Office of Transportation and Air Quality 

OTC Ozone Transport Commission 

OTR Ozone Transport Region 

OWB Outdoor Wood-fired Boiler 

PennDOT Pennsylvania Department of Transportation 

PM Particulate Matter 

PM2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates 

PM10 Particulate Matter less than 10 microns in diameter 

PSD Prevention of Significant Deterioration 

RWC Residential Wood Combustion 

SCC Source Classification Code 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

TAF Terminal Area Forecast 

TCM Transportation Control Measures 

TSD Technical Support Document 

μg/m3 Microgram per cubic meter 

μm Micrometer 

VMT Vehicle Miles Traveled 

VOC Volatile Organic Compound 

WOE Weight of Evidence 

ZEV Zero Emissions Vehicle 
- 1 - 

Comment and Response Document 

Allentown Nonattainment Area 

2006 Fine Particulate Matter National Ambient Air Quality Standards 

Redesignation Request and Maintenance Plan 

On April 5, 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 Allentown Nonattainment Area 2006 Fine 

Particulate Matter National Ambient Air Quality Standard. A public hearing was held on May 8, 

2014, in the Department’s Northeast Regional Office. Three commentators testified and 

provided written copies of their testimony. The fourth commentator provided written comments 

only. The comment period closed on May 9, 2014. The commentators are identified below. 

1. Breena Holland 

Associate Professor 

Dept. of Political Science and the Environmental Initiative 

Lehigh University, STEPS 586 

311 Maginnes Hall 

9 West Packer Avenue 

Bethlehem, PA 18015 

2. Sarabeth Brockley 

sbb213@lehigh.edu 

3. Al Wurth 

ahw1@lehigh.edu 

4. Claudia Steckel 

423 N. 27th St. 

Allentown, PA 18104-4828 

csteckel.botanicalinventory@verizon.net 

COMMENTS AND RESPONSES 

The identity of each commentator making the comment is indicated by the assigned numbers in 

parentheses after each comment. 

1. Comment: Page 2 [of the Redesignation Request] states that the analyses described in 

the Request for Redesignation demonstrate that the Allentown area meets the 2006 

24-hour PM2.5 standard and the reductions responsible for the air quality improvements 

are “permanent and enforceable.” According to EPA [U.S. Environmental Protection 

Agency] data, the reductions are not permanent, since the 35 μg/m3has already been 

exceeded during 2013. Specifically, 98% of the relevant data points indicate that the 

Allentown area is only meeting a level of 37 μg/m3, not 35 μg/m3, which the National 
- 2 - 

Ambient Air Quality Standards (NAAQS) require. Therefore, the first and third bullet 

points on page 2 (of the Introduction), which indicate that the Allentown area meets the 

conditions under which the CAA states an area may be redesignated, are incorrect. The 

NAAQS have not been attained and the improvements in air quality have not been 

demonstrated to be either permanent or enforceable. Page 9 of the Redesignation 

Request states that the Allentown Area continues to monitor in attainment with the 2006 

NAAQS for PM2.5. This is incorrect, since the level of PM2.5 for the 24 hour average in 

2013 is 37 μg/m3 and the 2006 standard is 35 μg/m3

. (1,2,3) 

Response: The Department disagrees with the commentators’ assertions. PM2.5 

monitors in the Allentown Area are well below the 2006 PM2.5 NAAQS of 35 μg/m3

.

Based on 2011-2013 PM2.5 concentrations, the design values for the Freemansburg and 

Lehigh Valley monitoring stations are 32 and 30 μg/m3, respectively. The Allentown 

Area has attained the 2006 PM2.5 standard and should be redesignated. 

The tables provided by the commentator appear to have been generated from the EPA’s 

AirData website (http://www.epa.gov/airdata/). The “Air Quality Statistics Report” 

available on the AirData website does not accurately select the maximum 98th percentile 

on a county level from the appropriate data set. The report appears to be generating the 

PM2.5 98th percentile using a monitor-based source data set instead of the site-based data 

set prescribed in 40 CFR Part 50, Appendix N, §3(d), which was promulgated as part of 

the 2006 PM2.5 NAAQS revision. The trends analyses highlighted in Section I(B) of the 

Department’s proposed Redesignation Request were performed using the site-based data 

set described in 40 CFR Part 50, Appendix N, §3(d). Furthermore, EPA will use the 

site-based data set in its action on this redesignation request. The site-based data is 

uploaded to EPA through the Air Quality System, which is not available on EPA’s 

website. 

The site-based data set is determined by combining values from monitors at a given site. 

Specifically, for each PM2.5 monitoring site, the monitoring agency (DEP) must 

designate a “primary” monitor. Other monitors located at the site are referred to as 

“collocated” monitors. All valid daily values from the primary monitor are considered 

part of the data set used for NAAQS design value calculations. Valid daily values from 

collocated monitors are included in the data set only on days for which data from a 

primary monitor is not available or is invalid. Where there is more than one collocated 

monitor, the collocated values are averaged. 

In the case of Northampton County, the Department maintains two monitoring sites: the 

Freemansburg (AIRS # 42-095-0025) monitor, and the Lehigh Valley monitoring site 

(AIRS # 42-095-0027). The Freemansburg site consistently measures a higher PM2.5 

concentration than the Lehigh Valley site. The Freemansburg site contains two PM2.5 

monitors – a monitor using the manual Federal Reference Method (FRM) and a monitor 

utilizing a continuous Federal Equivalent Method (FEM). The FRM monitor is 

designated as the primary monitor and samples on a daily basis. As such, the data set 

used for NAAQS design value calculations is primarily based on this monitor, with
- 3 - 

occasional supplementation from the FEM monitor on days for which the data from the 

FRM monitor is missing or invalid. 

Although technically designated as equivalent monitoring methods, continuous PM2.5 

FEM monitors in field settings may not correlate to an acceptable degree with collocated 

FRM monitors. Continuous in situ monitors may capture short-term VOCs not captured 

by 24-hour samples analyzed in a laboratory setting. In addition, continuous monitors are 

more significantly influenced by issues with moisture than their manual counterparts. 

For these reasons, continuous PM2.5 FEM monitors may often measure higher PM2.5 

concentration values than do the FRM monitors. 

With regard to the design value calculation, the design value is based on a 3-year period. 

Regardless of the method by which AirData extracts the monitoring data, the data 

outputted is not a design value but a one-year average of PM2.5 concentrations. 

Therefore, an individual year’s average cannot be used to determine if a particular 

monitor is attaining or not attaining the standard. 

Therefore, the Department concludes that the Allentown Area meets the CAA criteria for 

redesignation of the nonattainment area to attainment of the 2006 PM2.5 NAAQS. 

2. Comment: Table I-I of the Redesignation Request provides data on the annual average 

concentrations of PM2.5 that conflicts with data available on the EPA website. 

Specifically, this table indicates that the annual concentration of PM2.5 for the year of 

2012 is 11.5 μg/m3, when EPA data indicates that it is 12.4 μg/m3, as shown in the 

screenshot below. This puts the annual average concentration of PM2.5 in 2012 higher 

than the years of both 2008 and 2009, demonstrating that the reductions in PM2.5 are not 

permanently declining. It should be noted that this means the 2012 annual average 

standard is also not being met, even if the 2006 annual average standard is. It should also 

be noted that the annual average in 2013 as illustrated in the screenshot attached to 

Comment 1, is 12.6, showing a rise in annual average concentrations between years 2012 

and 2013. (1,2,3)

Response: The Department recognizes that the data sets conflict but disagrees with the 

commentators’ conclusions. The Department disagrees with the commentators’ 

characterization of concentration trends. As Figures I-2 and I-3 indicate, there is a 

general trend of concentration decreases in the 24-hour design value. Furthermore, the 

2013 annual design value (2011-2013 data) is 12.2 μg/m3, a further decrease. EPA’s 

AirData website does not generate the appropriate site-based data set prescribed in 

40 CFR Part 50, Appendix N, §3(d). See response to comment 1 for more details. The 

Redesignation Request for the Allentown Area is for the 2006 24-hour PM2.5 NAAQS 

only. To address the commentators’ statements about concentrations, it should be noted 

on December 10, 2013, the Department recommended that Northampton County be 

designated as nonattainment for the 2012 annual PM2.5 NAAQS based on the 2012 

design value of 13.2 μg/m3 at the Freemansburg monitor (2010-2012 data). EPA is 

expected to issue final designation for the 2012 PM2.5 standard in December 2014, 

which will establish new nonattainment boundaries for the Allentown Area. 
- 4 - 

3. Comment: On page 5, the report states that since 2007, there has been a decrease in the 

design value of the 24-hour standard of 16%. The report wrongly characterizes the 

design value as 37 μg/m3 for the period of 2006-2008, as indicated in Table 1-4, which 

shows the annual average design value for that period is 36 μg/m3. Even if we assume 

that the design value for the 2010-2012 period is 32, which is incorrect based on the EPA 

data cited in Comment 2 above, the relevant drop in PM2.5 concentrations between 

2006-2008 and 2010-2012 is 4 μg/m3. This is a drop of 11%, not 16% as the report 

mistakenly indicates on page 5, which suggests the report’s reliance on exaggerated 

reductions. Assuming the 12.4 μg/m3 annual average for 2012 (which is based on EPA 

data referenced in Comment 2), the properly calculated annual average design value for 

the 2010-2012 time period is 13.5, not 13.2, which is the concentration referenced in 

Table 1-3. This means the annual average design value for the 2010-2012 time period is 

higher than in every 3 year average since the 2005-2007 time period. (It should be noted 

that while this does not mean the 2006 annual average is violated, it again brings 

attention to the report’s reliance on exaggerated reductions.) (1,2,3) 

Response: DEP appreciates the commentator bringing the calculation error in the 

percentage reduction to our attention. The commentator is also correct that the design 

value for 2006-2008 for the 2006 24-hour PM2.5 NAAQS was 36 μg/m3. Both of these 

errors have been corrected in the final Redesignation Request. See response to 

comment 1 for a detailed discussion of data set issues. The Department disagrees with 

the commentators’ characterization of concentration trends. As Figures 1-2 and 1-3 

indicate, the trend for PM2.5 concentrations across the Commonwealth, including the 

Allentown Area, continues downward. Furthermore, the 2013 annual design value 

(2011-2013 data) for the Freemansburg monitor in Northampton County is 12.2 μg/m3, a 

further decrease in PM2.5 design value for the area. The 2006 24-hour PM2.5 NAAQS 

of 35 μg/m3has not been violated in the Allentown Area since the 2006-2008 period, 

making the Allentown Area eligible for redesignation from nonattainment to attainment 

of the 2006 PM2.5 NAAQS. 

4. Comment: Assuming the 24 hour average for PM2.5 was 33 μg/m3 in 2012, as indicated 

in the EPA data cited in comment 2 above, then the design value for 24-hour average for 

the 2010-2012 time period is 33.8 μg/m3, not 32 μg/m3, as the report currently proposes 

in Table I-4. While this still puts the 2010-2012 period beneath the 35 μg/m3 standard, 

this compliance with the standard is not maintained for the 2011-2013 time period. 

Assuming the 24 hour average for 2011 is 35.2, for 2012 is 33 (see data cited in 

Comment 2), and for 2013 is 37 (see data cited in Comment 1), then the design value for 

the 2011-2013 time period for the 24 hour average is 35, which is only 1 μg/m3less than 

levels of PM2.5 for the 24-hour average reached back in the 2003-2005 time period. 

These errors in the design values for both the annual average and the 24 hour average 

mean that the slopes indicating the trend lines in Figure 1-2 and in Figure 1-3 are wrong, 

and incorrectly portray the extent of the decline in PM2.5 levels over time. Furthermore, 

since the relevant question is the extent to which air quality has improved since the 

nonattainment designation resulting from the 2006-2008 data, it would be more pertinent 

to reveal the trend since the 2006-2008 time period, not trends explaining data going back 
- 5 - 

to 2001. Showing data going back to 2001 conceals the significance of the recent rise in 

PM2.5 levels in the Lehigh Valley that are well captured in the Freemansburg monitoring 

data EPA has posted, which are concealed by errors in the present report. (1,2,3) 

Response: See response to comment 1. The Department disagrees with the 

commentators’ characterizations of air quality trends, and has made no changes in the 

Tables or Figures. Concentrations of PM2.5 have not been in violation of the 24-hour 

PM2.5 NAAQS. It is not uncommon to experience slight variations from year to year in 

concentration averages; EPA has established the form of the standard in such a way as to 

account for such differences. 

5. Comment: Starting on page 7, the report discusses trends in climate, population, and the 

labor force, in order to argue that the claimed reductions in PM2.5 levels will be 

sustained. In reference to each of these topics, the report claims that there is no evidence 

of these variables suppressing the claimed decrease in PM2.5 levels. In general, this 

discussion lacks the level of detail and specificity that would make it compelling. For 

instance, on page 12, the report discusses that a larger labor force could lead to more 

driving and increased infrastructure demands, increasing PM2.5 levels. The report then 

claims that while there have been upward trends in the labor force dating back to the 

completely irrelevant date of 1990, air quality has nonetheless improved. But the report 

fails to recognize that the lowest annual average PM2.5 levels and the lowest 24 hour 

PM2.5 levels occurred in 2009, which is when there was also a dramatic drop in the labor 

force (likely due to the 2008 recession). The relative rise in labor and population since 

that time may explain some of the increasing concentrations of PM2.5 since 2009, but 

any effort to characterize such nuances is glossed over in the presentation of larger trends 

that does not evaluate the relationship between particular years (with respect to labor and 

population trends) and particular months (with respect to temperature and precipitation 

trends). A more illustrative and persuasive analysis of the impact of these trends would 

model high, low and mean projections of these variables, with accompanying calculations 

of their impact on the projected PM2.5 levels. The current approach simply discounts 

any effect of these variables, which amounts to assuming away rather than analyzing their 

effects. 

The analysis of economic trends (Page 11-13) seems to suggest that labor force changes 

and levels of economic activity are potential sources of changes in future air quality 

impacts from emissions. Presumably the purpose of the discussion is to suggest that 

these economic indicators have been increasing while emissions have remained relatively 

stable. The request for redesignation indicates that this comparison supports the claim 

that attainment status will be maintained in the future. First, the choice of those 

indicators should be validated by comparing their relationship to air emissions in past 

years, to determine their historical association with emission levels. Second, and more 

important for supporting the claim that “in spite of these upward trends, air quality 

continues to improve in the Allentown Area,” the trends should be compared across the 

time period in question. The depiction of increasing longer-term trends from 1990 and 

1979 respectively, as indicators that outpace short-term trends in air pollution from 

2006-2012 (across the period of the greatest economic downturn since the great 
- 6 - 

depression), cannot be interpreted as demonstrating a future trend of stable or declining 

emissions. Indeed, over the emissions-measurement time period, the Pennsylvania 

economic “coincident” index and Allentown labor force barely increased. This 

comparison of growth rates over different time periods cannot be understood as a clear 

predictor of the future impact of potentially increased employment and economic growth 

on air emission levels. (1,2,3) 

Response: The Department appreciates the commentators’ suggestions for how to 

conduct a comprehensive study of how socioeconomic variables relate to PM2.5 levels. 

The Department is required to demonstrate that the improvement in air quality between a 

year when the area was not attaining the standard (2005) and a year when the area was 

attaining the standard (2007) is due to permanent and enforceable control measures. The 

Department is not required to perform the type of detailed analysis described by the 

commentator, and offered the general trends discussion as an additional factor to consider 

in the efficacy of the permanent and enforceable measures described in Section III(C) of 

the Redesignation Request (relating to Control Measures). It is clear from the analysis of 

trends between 2005 and 2007 that the emissions contributing to PM2.5 levels have 

decreased. (The Department did not use 2009 as an analysis year for emissions.) When 

2007 emissions are projected to 2017 and 2025, both milestone years chosen based on 

EPA guidance, emissions again decrease significantly. Growth factors assumed for 

specific source categories, as well as control factors, are discussed extensively in the 

Appendices of the Maintenance Plan. Should the Allentown Area experience an increase 

in emissions such that the 2006 PM2.5 standard is violated, the contingency measures in 

the Maintenance Plan would be triggered in order to bring the area back into attainment. 

Section V (relating to verification of continued attainment) of the Maintenance Plan also 

commits the Department to examining emission inventories periodically and to taking 

further action should emissions exceed the attainment year inventory (2007) by more than 

10 percent. 

6. Comment: On page 16, the report says that the inventory data for the year of 2007 is 

sufficient for meeting the inventory requirements established in 40 CFR Section 51.1008 

of the CAA because the data for the 2007-2009 period show attainment. The 2007-2009 

period is not an appropriate period to reference in justifying air quality since that time 

period had an annual average that was lower than any period before or after and a 

24-hour average that has now been exceeded. (1,2,3) 

Response: The Department disagrees. The year 2007 for the attainment year emissions 

inventory was chosen for a number of reasons as articulated in the Maintenance Plan and 

its appendices. The 2007 attainment year inventory represents the level of emissions 

present in the Allentown Area during a period when the Allentown Area attained the 

2006 24-hour PM2.5 NAAQS. The Maintenance Plan demonstrates that PM2.5 

emissions will not be greater than the 2007 attainment year in 2017 and 2025. Therefore, 

the Allentown Area should continue to meet the PM2.5 NAAQS. A lower annual design 

value in the 2007-2009 time period actually provides a greater margin of safety for 

continuing to attain the PM2.5 NAAQS. DEP disagrees with the commentators’ 

statement that higher 24-hour PM2.5 concentrations have been experienced after 2007. 
- 7 - 

The data in Table I-2 (relating to Allentown Area 24-hour PM2.5 concentrations and 

Table I-4 (relating to Allentown Area 24-hour PM2.5 design values) show that this is not 

the case. 

7. Comment: The commentators identify this comment as “Testimony regarding 

‘Commonwealth of Pennsylvania DEP Proposed Ambient Air Monitoring Network 

Plan - 2011’ (DEP, June 25, 2010)”. The comment is as follows:

On page 16, the discussion of PM2.5 states that Monitor 42-095-0027, which is located at 

the Lehigh Valley Hospital (Muhlenburg) in Lehigh County, should be influenced by 

mobile sources of air pollution coming from Rt. 22 and Rt. 378 and airport emissions 

from the LV International Airport. This monitor is located south of Rt. 22, east of 

Rt. 378, and southeast of the LV International Airport. The report provides no evidence 

of prevailing wind direction to support the claim that the monitor should be influenced by 

mobile sources of pollution on the freeways and from the airport. For example, if the 

prevailing winds run from the southwest to the northeast, then the only mobile sources of 

pollution that are upwind of this monitor are the vehicles on Rt. 378. It should be noted 

that while Rt. 22 has a traffic count of 83000 vehicles near the monitoring site, the 

monitor is located south of Rt. 22. If the monitor intends to assess an area of poor air 

quality, it is only doing this if the prevailing winds in the area are running from the 

northwest to southeast, which is not confirmed by relevant windrose data. (1,2,3)

Response: The Department is no longer accepting comments on “Commonwealth of 

Pennsylvania DEP Proposed Annual Monitoring Network Plan - 2011” (DEP, June 25, 

2010) (the “2011 plan”). The details of the siting of specific monitors are not appropriate 

or necessary for response in the context of the Redesignation Request since the 2011 plan 

is already final. As a courtesy, the Department provided the commentators with the 2011 

plan during the comment period for the Allentown Area Maintenance Plan and 

Redesignation Request in response to their request for information on monitor siting in 

the Allentown Area. 

EPA requires state and local agencies to enhance air monitoring to “improve public 

health protection and better inform the public about air quality in their communities.” 

Under 40 CFR 58.10 (relating to annual monitoring network plan and periodic network 

assessment), air quality state and local monitoring agencies must adopt an annual 

air-monitoring network plan and make the plan available for public inspection for at least 

30 days prior to final submission to the EPA Regional Administrator. For example, a 

comment period on the 2014-2015 plan opened on May 10, 2014 and closed on June 9, 

2014; comment periods are opened on the annual plan at approximately the same time 

each year. The plan, which is due to EPA each July 1, must include a statement of 

purpose for each monitor and evidence that siting and operation of each monitor meets 

Federal requirements. 

PM2.5 monitor locations are based on EPA requirements that consider population 

distribution. The monitors are sited to be representative of the area. 
- 8 - 

8. Comment: The commentators identify this comment as “Testimony regarding 

‘Commonwealth of Pennsylvania DEP Proposed Ambient Air Monitoring Network 

Plan - 2011’ (DEP, June 25, 2010).” The comment is as follows:

On page 16, the discussion of PM2.5 states that Monitor 42-095-0027 (a second monitor 

in the ABE area) is supposed to be located in an area of poor air quality. If this monitor 

is in an area of poor air quality, then it should show readings of PM2.5 concentrations 

that are higher than the readings from the Freemansburg monitor, which is where the first 

and older monitor for PM2.5 is located. Monitor 42-095-0027 shows readings that are 

lower than the Freemansburg monitor for PM2.5, so Monitor 42-095-0027 cannot be 

located in an area of comparably poor air quality. Rather than locate a second monitor in 

an area of poor air quality, DEP has located a monitor in an area of better air quality, 

which makes the Freemansburg monitor data look as though it is collecting 

unrepresentatively high levels of PM2.5. DEP has not shown that the Freemanburg 

monitor is collecting unrepresentatively high air quality because it is only measuring 

PM2.5 data in a location that has comparably lower levels. According to the information 

provided on page B-52, Monitor 42-095-0027 is meeting the (40 CFR section 58) 

Appendix D Objective of assessing “population exposure,” not the “highest 

concentration” Appendix D Objective. If DEP is supposed to locate a second monitor in 

areas of high PM2.5 concentrations (i.e. poor air quality as stated on page 16), then it 

should select a location for the monitor where hot spots actually exist, which would be 

closer to slow moving traffic, rather than to traffic in “high mixing” environments, where 

air turbulence created by fast moving vehicles functions to disperse pollutants quickly. 

(1,2,3)

Response: Based on current monitoring network requirements, a minimum of two 

monitors are required in the Allentown-Bethlehem-Easton PA-NJ Metropolitan Statistical 

Area (MSA), consisting of Carbon, Lehigh and Northampton Counties in PA, and 

Warren County, NJ. The Department operates two State and Local Air Monitoring 

Stations (SLAMS) (as defined by EPA) monitors in Northampton County – 

Freemansburg and Lehigh Valley. The Freemansburg site was added to the 

Commonwealth of Pennsylvania Air Monitoring System (COPAMS) in 1997 as a full 

site – carbon monoxide, sulfur dioxide, nitrogen dioxide, ozone and particulate matter 

(PM10). A PM2.5 monitor was added in the first phase of PM2.5 deployment beginning 

in 1999, following the EPA’s revision of the PM NAAQS in 1997, which established 

annual and 24-hour PM2.5 standards. 

In 2010, the Department installed an additional PM2.5 monitor in the AllentownBethlehem-Easton MSA, the Lehigh Valley monitor. The Lehigh Valley monitor was 

sited in an area of expected poor air quality, influenced by mobile sources from I-78 and 

U.S. 22, as well as airport emissions from the Lehigh Valley International Airport, and 

upwind from a populated area. 

The PM2.5 monitor in Allentown was discontinued in 2005 because it was determined by 

DEP to be duplicative of the Freemansburg site in the MSA and not required. 
- 9 - 

All of these actions were approved by EPA as meeting the requirements for 40 CFR 

Parts 53 and 58. 

For purposes of granting a Redesignation Request, the EPA looks at the monitor in the 

area with the highest concentration (“design monitor”) to determine whether an area is 

eligible for redesignation. The Department agrees with the commentators that the 

Freemansburg monitor consistently has measured concentrations that are higher than the 

newer Schoenersville Road monitor. The Department disagrees with the commentators’ 

statement that including data for both monitors makes the Freemansburg monitor data 

look unrepresentative. The Department also disagrees that the differences between the 

two monitors is relevant for the Redesignation Request. EPA looked at the monitor with 

the highest concentration (Freemansburg) in making its determination of clean data and 

attainment. The concentrations at both monitors will determine whether this area is 

considered to be in attainment for the 2006 standard (see maintenance plan) throughout 

the ten-year maintenance period.

9. Comment: The commentators identify this comment as “Testimony regarding 

‘Commonwealth of Pennsylvania DEP Proposed Ambient Air Monitoring Network 

Plan - 2011’ (DEP, June 25, 2010).” The comment is as follows:

According to the discussion on page 16, Monitor 42-095-0027 is intended to be in an area 

of poor air quality, which DEP attributes to traffic from Rt. 22 and Rt. 378, as well as 

form the LV International Airport. The closest of these three sources is Rt. 22, which is 

approximately .3 miles, or more than 450 meters from the monitor. If a roadway with an 

average daily traffic volume of 83000 (i.e. Rt. 22) is more than 450 meters from the 

monitor, then according to section 6.3 (b) of Appendix E to Section 58 of 40 CFR, the 

monitor is “urban scale,” not “neighborhood scale,” as characterized on page B-52. If 

DEP is classifying Monitor 42-095-0027 as “neighborhood scale” because the monitor 

45 meters from Schoenersville Road, then it is not meeting the criteria of being near 

roadways with the highest traffic volume (see section 6.3 (b) of Appendix E to Section 58 

of 40 CFR), which is Rt. 22, not Schoenersville Road. DEP should either do 

“micro-scale” monitoring at a location where the general public would be exposed to 

maximum concentrations of PM2.5 from mobile sources, or admit it is doing 

“neighborhood scale” monitoring and not claim it is monitoring a poor air quality area, 

since the first monitor in Freemansburg is already doing neighborhood scale monitoring. 

In other words, DEP needs to assess whether the Freemansburg area has poor air quality 

by doing micro-scale hot spot monitoring, not by selecting an area with predictably better 

air quality than Freemansburg has and then treating Freemansburg data as though it is 

revealing a hot spot. A real hot spot would be at the 5-Points intersection in downtown 

Bethlehem, PA, or in a similarly situated area of Allentown. Monitoring in these areas 

would likely demonstrate one important reason why the citizens of the immediate 

residential communities have high levels of asthma and other respiratory disorders 

associated with exposure to PM2.5 pollution. These levels would have higher PM2.5 

measurements than revealed by either the Freemansburg monitor or 

Monitor 42-095-0027. DEP should be trying to protect people from the worst 
- 10 - 

concentrations of PM2.5, not pretending like the most exposed people are irrelevant to 

policy decision that air quality data is supposed to inform. (1,2,3)

Response: The Department tailors its monitoring program to meet applicable federal 

requirements and annually evaluates the adequacy of the network prior to finalizing the 

Annual Monitoring Network Plan due to EPA by July 1st each year. PM2.5 monitor 

locations are based on EPA requirements that consider population distribution. The 

monitors are sited to be representative of the area. See the responses to comments 7 and 

8.

10. Comment: The commentator referred to EPA’s clean data determination (published 

March 29, 2012) to comment as follows:

EPA states the data supporting attainment was based on monitoring from years 2008 

through 2010 (page 4, 3rd line), but only one monitoring site’s data - the Schoenersville 

Road site - was potentially acceptable during that timeline (since the F-burg empirical 

data was not being included & the Hanover site had been long off-line); but the 

Schoenersville Road site had only come on-line in the last year of data monitoring 

timeline being used to determine attainment status. So without enough empirical data to 

make a determination on attainment status, modeling through design value contribution 

was applied and allowed to be based on data through 2012 which isn’t in agreement with 

what the report states up front – that attainment was based on 2008-2010 data. How then, 

can EPA state that the data used to support attainment is quality assured, quality 

controlled, and certified ambient air monitoring data when there are inconsistencies in 

reporting the data timeframe. What else might be misrepresented or misleading in the 

data gathering process? (4)

Response: The Department disagrees. On March 29, 2012, EPA published the Clean 

Data Determination for the Allentown Area for the 2006 PM2.5 NAAQS in the Federal 

Register. (77 FR 18922.) The Clean Data Determination for the Allentown Area was 

based on 2008-2010 PM2.5 monitoring data from the Freemansburg monitoring site 

(AQS ID 42-095-0025). The monitoring data used by EPA can be found under 

“supporting documents” in the docket for the Clean Data Determinations: 

http://www.regulations.gov/#!docketDetail;D=EPA-R03-OAR-2011-0818

11. Comment: The elevated PM2.5 levels detected from the Freemansburg monitor, due to 

a very local, proximal disturbance from the relatively recent development of the 

Bethlehem Steel site prove that a single regional monitor (in this case, at Schoenersville 

Road) is not sufficient to capture conditions that may carry a major health risk to 

residents of a given municipality, especially those living within the densely populated 

area surrounding a disturbed site. The Freemansburg monitor, alone, informed us of that 

critical risk, but in seeking attainment status, EPA chose to negate the data “anomaly” 

caused by what they dubbed, the “Freemansburg Problem” and move to design value 

contribution which, in effect, skews/ dilutes the Freemansburg data, therefore having 

PM2.5 levels appear less than they actually were. Allentown, too, would benefit from its 

own version of a “Freemansburg” monitor. I urge DEP not to support attainment status 
- 11 - 

for Allentown based on the location of existing monitors which cannot accurately capture 

true PM2.5 levels occurring in Allentown. Allentown would need to have its own 

monitor to reflect what’s happening within City limits. (4) 

Response: See response to comment 8. The Department tailors its monitoring program 

to meet applicable federal requirements and annually evaluates the adequacy of the 

network prior to finalizing the Annual Monitoring Network Plan due to EPA by July 1st 

each year. PM2.5 monitor locations are based on EPA requirements that consider 

population distribution. The PM2.5 monitors are sited to be representative of the area 

and are neither required nor intended to monitor at specific hotspots. Note that the 

Department found in 2005 that a monitor within the Allentown city limits was duplicative 

of other monitors in the area. EPA approved the removal of this monitor prior to the 

dismantling of the sampler. 

12. Comment: Without PM2.5 monitors within City limits, a true representation of PM2.5 

levels, within the City itself (the “City proper”), during the timeline used to support 

attainment for Allentown is not knowable as evidenced by what has been dubbed, the 

“Freemansburg Problem.” Allentown is bounded by major traffic corridors (222 bypass; 

routes 309, 78 & 22) which will see a continuing increase in truck traffic beginning this 

year and continuing for the foreseeable future, mainly due to regional warehouse 

development both east, northeast of and in townships west of the City. By the time air 

from such development reaches the existing monitors on the west side of Northampton 

County, PM2.5 and other air quality levels will likely be compromised (i.e., will appear 

less than what they are within City limits). PM2.5 levels (known to result in great part 

from auto exhaust) may be significantly higher, locally (i.e., within City limits) than 

monitors beyond City limits to the east can detect. (4)

Response: PM2.5 monitor locations are based on EPA requirements that consider 

population distribution. The monitors are sited to be representative of the area. See 

response to comment 8.

13. Comment: The commentator opposes the redesignation of the Allentown area for the 

2006 24-hour PM2.5 standard. The commentator writes that, as shown by the 

Freemansburg monitor, PM2.5 levels can vary markedly within a region depending on 

activities proximal to the monitor which may put citizens of that region at risk, 

health-wise, and that such activities (1) have been occurring (Arena/NIZ development, 

15th street bridge restoration) and (2) will be occurring (Lehigh Riverfront & American 

Parkway development projects, and restoration of several large City bridges including the 

8th Street; and possibly Tilghman St. & Hamilton St. ) within Allentown and, as well, to 

the west of Allentown (warehouse and manufacturing development) causing disturbances 

and increased traffic on all major roadways surrounding the City. 

Major development in townships west of Allentown – including residential, numerous 

warehouses, Ocean Spray, and the increased traffic, especially truck traffic on all major 

routes (222 bypass, 309, 78 & 22) surrounding Allentown will have significant negative 

impact on the air quality, with, surely increased PM2.5 levels since exhaust is a known 
- 12 - 

major source of PM2.5. Without PM2.5 monitors within City bounds, we cannot know 

the impact on PM2.5 levels that will result from the increased traffic load on all area 

throughways and roads surrounding Allentown. Even with future federal EPA-mandated 

upgrades promised to reduce vehicular pollution (as is mentioned as part of the 

Attainment Maintenance Plan), without PM2.5 monitors within Allentown, itself, the 

citizens of Allentown are left guessing as to their health risk relative to PM2.5 levels. 

Contaminants of Riverfront brownfield sites’ structures and/or in their underlying soils 

include asbestos, coal and coal ash, seven (7) soils ranked as APECs (Areas of Potential 

Concern), lead, pigeon excreta, and unknown hazardous waste. Some of these 

contaminants are known sources of PM2.5. How can the City, without its own monitor to 

detect PM2.5 levels resulting from development of these sites know if and when its 

citizens are at risk? Note: the neighborhoods surrounding the riverfront are typically 

low-income. (4) 

Response: PM2.5 monitor locations are based on EPA requirements that consider 

population distribution. The monitors are sited to be representative of the area. See 

response to comment 8 for a more detailed discussion. 

The federal Clean Air Act in Section 176 has programs that address air quality effects of 

many major projects. The transportation conformity program requires the local 

transportation agency to ensure, on a regional basis, that transportation improvement 

projects do not interfere with the ability of an area to attain or maintain a NAAQS. 

Similar requirements are placed on non-transportation federally funded, assisted or 

regulated projects. Pennsylvania has federally-approved programs implementing 

Section 176. In addition, control measures described in the Maintenance Plan for motor 

vehicles will reduce emissions from cars, trucks, buses, construction vehicles and other 

engines in the future. 

14. Comment: Potential environmental disturbances may result from Allentown’s future 

development/restoration plans for: two brownfield sites, including the Lehigh Riverfront 

project, which has a master plan in place (following two slides), and possibly Allentown 

State Hospital (3rd of next three slides), and at least one large bridge restoration 

(Albertus C. Meyers, a.k.a., the 8th Street bridge); and perhaps also the Hamilton St. and 

Tilghman St. bridges, which I could not confirm. Because such projects may put the 

City’s residents at risk for elevated PM2.5 levels, should we not be prudent and add 

monitoring sites within the City limits? How else will we know whether we have our own 

“Freemansburg Problem.” 

Without PM2.5 monitor(s) being located within the City limits over the course of the data 

window used to support current attainment, a representative measure of PM2.5 levels 

within the City, itself, over that time (and over the next 10 years) cannot be known. The 

location of existing PM2.5 monitors, being beyond City limits are incapable of accurately 

capturing City-wide PM2.5 levels both: (1) during the data window used in support of 

attainment, currently, and (2) during the next 10-year data window. (4) 
- 13 - 

Response: The Department tailors its monitoring program to meet applicable federal 

requirements and annually evaluates the adequacy of the network prior to finalizing the 

Annual Monitoring Network Plan due to EPA by July 1st each year. PM2.5 monitor 

locations are based on EPA requirements that consider population distribution. The 

monitors are sited to be representative of the area. See response to comment 8. 

15. Comment: The commentator describes breathing difficulties upon moving to Allentown 

and during peak traffic flows. When returning from travel north of the Blue Mountain, 

the commentator’s breathing difficulties return immediately after emerging from the 

south side of the Lehigh Tunnel. The commentator states that she cannot prove that her 

breathing difficulties result from PM2.5, but she asks how, without dedicated PM2.5 

monitoring within Allentown city limits, she and possibly other Allentown residents can

rule it out? (4) 

Response: The Department appreciates the commentator’s comment. See response to 

comments 8 and 11 regarding PM2.5 monitoring within Allentown city limits. 

While traffic (accounted for in the Allentown inventories as “highway vehicle 

emissions”) continues to be a major source of PM2.5-related emissions, particularly NOX, 

the Maintenance Plan shows that the highway vehicle emissions of direct PM2.5, NOX

and VOC are predicted to decrease significantly between 2007 and 2025, despite an 

anticipated increase of about 38 percent in vehicle miles travelled. The decrease is due 

primarily to federal regulation of gasoline, diesel and the manufacture of cleaner new 

vehicles, as well as to state programs for vehicle emission inspection and maintenance 

and the conformity of highway project plans to air quality plans. The mathematical 

model used (see a description of the MOVES model on page 15 and in Appendix D of the 

Maintenance Plan) for these estimates takes into account growth in traffic in each road 

segment in the Allentown area, as well as control measures for new and existing vehicles. 

The following information from the Maintenance Plan illustrates this point. 

Highway Vehicle Emissions in the Allentown Area 

(from Tables II-2, II-4 and II-5 in the Maintenance Plan) 

Direct PM2.5 NOX VOC

2007 536 15,857 6,936

2017 297 8,081 3,791

2025 234 5,303 2,410
COMMONWEALTH OF PENNSYLVANIA 

STD-521 REV 06-2010 CJ .. AOO\G ~::2')?~\ INVOICE NO. 

PUBLICATIONS AUTHORIZATION AND INVOICE 

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TO: (NAME AND ADDRESS OF NEWSPAPER) 

Allentown Morning Call 

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23-0337560 Alex Haas 717-787-9495 

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Proposed State lmpleinentafion Plan Revision 

Redesignatioll Request and Maintenance Plan for the Allentown 

NOnattainment Area for the 2006 24-Mur Fine Particulate Matter National 

Ambient .Air QUality Standard;-J'Ublic Hearing , C •m me , •c•• " ,~--------f'"cC..'...'c'=~--"-~"---

Commonwealth of PetUJ+!E'M aJ\;i' saouepadX;J 

County of Le)l cO h · , 

GRAND TOTAL-+ 

the regUlar advertising columns of said newspap' 

Jove; and that the Commonwealth is not charg· 

ount of matter occupying similar space and set ir 
AIJ •• J • .,., 1'1.,":::.> C. !I 

P ... bl:s),.d Apr;l Z, ZoJL1. 

PrOposed state lifu)-rementatioii-Pian ReViSion 

:: RedeSignati~~ ·Req~~st an·d .Maintena~ce Plan tOr the ~ii~nfowil, . .- Nonaffainment Area for the 2006 24:-hour· Fine,Particulate Maffer National Am~ienf -Air Quality Standardf:Pu~lic· Hearing 

P:arficul~·te matte'~- _{P.MJ "inc~_Ud~S bofll -.~oli~- a~d-1[-~uid Particles 

·suspended ln'the.air. Fine particle pollution _.de~cribes. particulate matter 

that is less than or equal_ to 2.5. micrometers in·diel.rJleter·(PM2.5). PM2.5 

concentrations above:.fhe federal healfh:-based standard pose_a seri.ous 

human health 'threat. With Significant. impr.ovements .• i_t:l Etir' quality in-the 

Allentown Area, this< non-i:lftainmenf _ar.ea -no_w. rrieets .the · 2006' 24-hour PM2~5 National Ambier)t :Air Quqlity Standard· (NAAQS); ·Therefore, the · Depa~trneht-: qf · Environmental_' Prot~dion . {DE;P_) . intends- to .. submit a request to the· .LJ.~; Etivironmentai-Protectlon Agericy (EPA)-.fo redeslg- natethe'8.reato·:attainmenf. · ,_- ·-· ··· · ·-- ·· '· 

ThE!- DE~,._~~:·s-~ekihg -P~bl_i·c· .corilmerif. on the r~d~~~~-n-~tiOM ~1'ciU~st ~rid a· propOsed revision _to· the _Slate- Implementation_ Plan:\SIP) COQiaining--th'e . 2007 .comprehensive inventorY as required-under ~_ec_tion 172(c)(3), of-the feder~l Clean' Air Act'(CAA)-.and a maintEmance pla:n·demonstrating·fhat the area. Can maintarn·the- 2006 24,-=hour PM2:5 health-baSed.iNAAO_S for 

the next' 10 yearS·.a!;)_ :required· under. Sect~~n. · 175A(a) .ci.f·_tile · CM .{42 . U.S.C:A. § :7505a).-.Upon EPA approval,jhe_:mainte!nance plan wilhillso 

establish. neW·. motor. vehide emissjqn_-btJ"dgets ·tor trans'porfafion· Conformity· purposes .. · ·. - · : ---.-·.: ·. · '· --"-, '.' ,,_, 

·.The_ req~~sf. to.-.redesr~~ate the:a:rea to att~~~nient ar1d·fhe ~reposed SIP 

revision: are: avaHable on~. the DEP's -websife _at_.:w'Nw.dep'·.state.pci,.us {choose·- 'Air,'· choose· 'BureaU .of Air QuaJily;--'·:·_choo'se \~Regs/Piaris,' 

'choose· 'Cfean Air-Plans') or through ·the contacfp'er~ons'. ll~fed below.\· 

bEP 'will hold aPubllc··hearing tO: recEi~ve Coinrlierits'·on.;fhEfproPosaf on Thursday, May 8, 2014~ at-_.1:00 p.m;, ·at. ftleiDEP' Noiitwa.St"Regional Offic:e,. 2 Publh:: Square, Susqu~hanria·.- Room__-A,. Wilkes-Barre, .PA; Per- sons. Wishing to present f!=lsfimony. at the- hearitig should · ..contact .Alex 

Hqas;. P.O. Box 84_68, Harrisbi.Jrg;:-.PA:1Tl05,- (717) ·787-_94_9q-·,or,- al.e,- haas@pa,go.v. to_ reserve .a time. Witnessestshould. ke13p: testimony to. ten 

minutes· and should' provide- twO ·written .copie's of their: statement- at the 

hearing. -f. · 

ltc·b·~~-T~~sdav, -Mav-_6; 20l4; :·ria :pers~n-:has·:-~~~r~~~ed': an· interest 111 

testifying· at. the hearing; the hl'!aring wur be-cancelled,,.DEP willl?rovide· 

public notlce on f_he·sureau of-Air Qual_lty:webp_age at fhe·WIIoWing link. it· 

the_· hearing --is. cance_lled: hlfP:!/WWw.dep.state.pa·.'us/dep/'depu_tate/· airwaste/aq/defatJit.hfm . .Persons-ma'y also contac;:f the DEP to' find out if 

the-hearing is cancelled'· bY contacfill9.-Aiex Haas. at (7.17}:'787-_9495 or alehaas@pa.gov. · -

Per'son~_wifh a diSability Who· wish to. ~tfend:·the h~aiirlg. and reqUire an, 

·auxiliary- aidi service o_r ·-other'. _act;-omrnodation· to· participate_ in the· 

proceeding_ shouldJ contact Alex ·Haas·. at (717) 787;..9495. or _alehc:~c;~s@pa.- _gov. · -

TDD users· m·EIY. corifa~dhe .AT&{Relayrservi'~e--at' {800) 6·5~1'-:5984--fo­ discuss. _how DEP' can l;lesf_ a_ccommodate. fhei_r .heeds.DEP-must receive 

comments ho later than May-9,_ 2014.:Written·comments.-should btl sent· to 

the at1entlon of· Nancy Herb/ BUr!;!au _ot-·Air-.. QualifY; .f':O._ 6ox 8468,. 

Harrisburg, .PA ·17105-8468, o( nherb@pa_.~;~dv~ Use. -'Ailentown..PM2.5·'RE!-- d~signati,on'- ·as _the -~~l;liecf_ line in __ writt~n ·corf!r'tlUnicatlcin. · · 

E. CHRISTOPHER ABRUZZO; 

#l90ll ~ 4/2/2014 Secret_ary 
THE MORNING CALL 

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~~HomeFinder -~r .corn ~TIUBliNE <,;;rc;~, 
NOTICES

Proposed State Implementation Plan Revision; Redesignation Request and 

Maintenance Plan for the Allentown Nonattainment Area for the 2006 24-

hour Fine Particulate Matter National Ambient Air Quality Standard; 

Public Hearing

[44 Pa.B. 2136]

[Saturday, April 5, 2014]

Particulate matter (PM) includes both solid and liquid particles suspended in the air. Fine 

particle pollution describes particulate matter that is less than or equal to 2.5 micrometers in 

diameter (PM2.5). PM2.5 concentrations above the Federal health-based standard pose a 

serious human health threat. With significant improvements in air quality in the Allentown 

Area, this nonattainment area now meets the 2006 24-hour PM2.5 National Ambient Air 

Quality Standard (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 comment 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 (choose ''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, May 8, 2014, at 1 p.m. at the DEP Northeast Regional Office, 2 Public Square, 

Susquehanna Room A, Wilkes-Barre, PA 18701-1915. Persons wishing to present 

testimony at the hearing should contact Alex Haas, 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, May 6, 2014, no person has expressed an interest in testifying at the 

hearing, the hearing will be cancelled. The Department will provide public notice on the 

Bureau of Air Quality web page at 

www.dep.state.pa.us/dep/deputate/airwaste/aq/default.htm if the hearing is cancelled. 

PA Bulletin, Doc. No. 14-719 Page 1 of 2

http://www.pabulletin.com/secure/data/vol44/44-14/719.html 8/22/2014
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 May 9, 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 ''Allentown PM2.5 Redesignation'' as the 

subject line in written communication.

E. CHRISTOPHER ABRUZZO,

Secretary

[Pa.B. Doc. No. 14-719. Filed for public inspection April 4, 2014, 9:00 a.m.]

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