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 (PM 2

. 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 PM 2

. 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.usMr. 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 17 105-8468

717-787-9495

www.dep.state.pa.usThis 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 Q uality Trends Analysis ....................................................................................4

C. C limate Trends Analysis ..........................................................................................7

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

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

D. Additi onal Trends ..................................................................................................11

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

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

E. Modelin g Analysis .................................................................................................13

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

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

B. P art 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. C ontrol 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 ........................................................................................................36TABLES

Table I-1: Allentown Area Annual PM 2.5 Concentrations ..............................................................5

Ta ble I-2: Allentown Area 24-Hour PM 2.5 Concentrations ............................................................5

Ta ble I-3: Allentown Area Annual PM 2.5 Design Values ...............................................................5

Ta ble I-4: Allentown Area 24-Hour PM 2.5 Design Values .............................................................6

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

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

Table I-7: EPA’s Transport Rule Modeling Results for the PM 2.5 Standard for the

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

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

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

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

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

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

FIGURES

Figure I-1: Pennsylvania’s 2006 24-Hour PM 2.5 Nonattainment Areas .........................................3

Figure I-2: PM 2.5 Annual Design Value Trend ...............................................................................6

Figure I-3: PM 2.5 24 -Hour Design Value Trend .............................................................................7

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

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

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

F igure I-7: Allentown Area Population Trend ..............................................................................11

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

F igure 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

a nd allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is less than or equal to 2.5 micrometers (μm) in diameter,

a pproximately 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

a nd 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 exposureinclude 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. publi shed January 22, 2009 in the New England Journal of Medicine evaluated the role PM 2 .5 reductions occurring in the 1980s and 1990s had on the increased life expectancy observed over that period. The study found that a reduction of 10 micrograms per cubic meter (μg/m 3 ) of PM 2.5 was associated with an average increase in life expectancy of 7.3 months.

PM 2 .5 has significant environmental impacts, including acid rain and stream eutrophication.

PM 2.5 also affects visibility (regional haze) through the scattering and absorption of 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 PM 2 .5 in the air.

The United States Environmental Protection Agency (EPA) issued PM 2.5 national ambient air quality standards (NAAQS) in 1997 after evaluating hundreds of health studies and conducting an extensive peer review process. The EPA established an annual primary (health-based) and

se condary (welfare-based) standard of 15.0 micrograms per cubic meter (μg/m 3 ), ba sed on the

3 -year average of annual mean PM 2.5 concentrations. The EPA also established a primary and secondary 24-hour standard of 65 μg/m 3 determined by the 3-year average of the 98th percentile

of 24 -hour concentrations. In 2006, the EPA promulgated a revised 24-hour PM 2 .5 standard of

35 μg/m 3 determined by the 3-year average of the 98th percentile of 24-hour concentrations. The

a nnual standard was not revised. (71 FR 61144 (October 17, 2006))

On O ctober 8, 2009, the EPA promulgated air quality designations for the 2006 24-hour PM 2 .5 standard based on 2006-2008 air quality monitoring data. The final designations were published

in t he Federal Register on November 13, 2009 (74 FR 58688). The EPA designated seven areas

c omprised of all or portions of 22 counties in Pennsylvania as 24-hour PM 2 .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 PM 2.5 NAAQS. The Allentown Area was designated nonattainment- 2
-

because the area violated the 2006 24-hour PM 2.5 standard of 35 μg/m 3 based on 2006-2008 monitoring data.

The subsequent analyses described in this Request for Redesignation clearly demonstrate that the ambient air quality in the Allentown Area now meets the 2006 24 -hour PM 2.5 NAAQS and that the emission reductions responsible for the improvements in PM 2 .5 air quality are both permanent

a nd 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 A ct (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

P art 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 Ma intenance 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 C AA ’ s Section 107(d)(3)(E) criteria for redesignation to attainment.

R equirements 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, DE P 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

co nduc ted 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

PM 2 .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

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

PM 2 .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 PM 2 .5 NAAQS. The Allentown Area was designated

nonattainment because the area violated the 2006 24-hour PM 2.5 standard of 35 μg/m 3

ba sed on 2006 -2008 monitoring data.

Figure I-1 : Pennsylvania ’ s 2006 24 -Hour PM 2. 5 Nonattainment Areas

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

The Allentown Area’s PM 2.5 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/m 3 and 36 μg/m, 3 respectively. The Allentown

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

w ere 13.2 μg/m 3 and 32 μg/m 3

, respectively. Following EPA criteria, annual PM 2.5 design values below 15.0 μg/m 3 and 24 -hour design values below 35 μg/m 3 are considered to be attainment. Concentrations are expected to remain lower than 15 μg/m 3

and 35 μg/m 3 over the next decade.- 4
-

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

24 -hour PM 2.5 NAAQS based on quality assured, quality controlled and certified ambient air monitoring data that show the area had monitored attainment based on 2008-2010 data (“Clean Data Determination”) (77 FR 18922 ). This final action suspended the requirements for this area to submit an attainment demonstration and associated reasonably available control measures, reasonable further progress plans, contingency measures and other planning SIP revisions related to the attainment of the 2006 PM 2.5 NAAQS for so long as the area continues to attain the 2006 PM 2.5 NAAQS.

The determination of attainment of the 24-hour PM 2 .5 NAAQS did not “redesignate” the

a rea as “attainment.” The Allentown Area remains nonattainment for the 2006 PM 2 .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 PM 2.5 monitoring sites in the AllentownBethlehem-Easton Metropolitan Statistical Area. The Schoenersville Road

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

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

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

PM 2 .5 concentrations). However, monitoring at that site was discontinued in

2005.

The ambient air quality data analysis for PM 2 .5 was completed using the appropriate regulations and guidance documents. Monitoring procedures were

determined in accordance with 40 CFR Part 58

. The PM 2.5 design values were

calculated in accordance with 40 CFR Part 50, 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 PM 2.5 monitoring concentrations in the

Allentown Area.

Trends in PM 2.5 concentrations were analyzed from 2001 through 2012. Table I-1 displays annual PM 2.5 concentrations monitored in the Allentown Area. Table I-2 (r elating to Allentown Area 24-hour PM 2.5 concentrations) contains the

98th percentile of 24-hour concentrations for each year.- 5
- Table I-1: Allentown Area Annual PM 2.5 Concentrations

Table I-2: Allentown Area 24 -Hour PM 2.5 Concentrations

Tables I-3 (relating to Allentown Area PM 2.5 design values) and I-4 (relating to

Allentown Area PM 2.5 design values) contain the Allentown Area’s annual and

24 -hour PM 2.5 design values using the 2001 through 2012 monitoring data. Design values for the annual and 24 -hour PM 2.5 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

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

11 percent.

Table I-3: Allentown Area Annual PM 2.5 Design Values- 6
- Table I-4 : Allentown Area 24 -Hour PM 2.5 Design Values

The 2001 through 2012 trend lines for annual and 24-hour PM 2.5 design values for the Freemansburg monitor are shown in Figures I-2 (relating to PM 2.5 annual design value trend) and I-3 (relating to PM 2.5 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 PM 2.5 concentrations are both negative, indicating decreasing concentrations. The Freemansburg monitor was chosen because it is currently the

onl y Allentown Area monitor with valid design values.

Figure I-2: PM 2.5 Annual Design Value Trend

y =

- 0.1517x + 14.536

11 11.5 12 12.5 13 13.5 14 14.5 15 15.5200120022003200420052006200720082009201020112012PM2.5 Design Value (ug/m3) 

## PM2.5 Annual Design Value Trend

Freemansburg Annual

DV

Level of Standard- 7
- Figure I-3: PM 2.5 24 -Hour Design Value Trend

C. Climate Trends Analysis

PM 2.5 formation in the eastern United States is a complex process involving local and regional meteorology, topography, chemistry and transport. Sulfates and nitrates are formed primarily through atmospheric reactions of precursor emissions of sulfur dioxide ( SO 2 ), oxides of nitrogen ( NO X ) and ammonia ( NH 3 ). Organic carbon is a combination of secondary organic particles formed from emissions of volatile organic compounds ( VOC ) and the organic portion of primary PM 2.5 that is directly emitted or condenses near its source. Currently, our understanding of sulfate and nitrate chemistry and its impacts on PM 2.5 concentrations far exceeds our understanding of contributions from anthropogenic VOCs. This is important because sulfates, nitrates, ammonium and organic

c arbon are major contributors to the total PM 2.5 , making up approximately

78 percent of the annual PM 2.5 concentration observed in the Allentown Area in

2007. y =

- 0.8077x + 41.667

25 27 29 31 33 35 37 39 41 43 45200120022003200420052006200720082009201020112012PM2.5 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 PM 2.5 NAAQS involves the range of meteorological conditions throughout the year. PM 2.5 chemistry favors sulfate formation during the warm summer months and nitrate formation during the colder winter months. In addition, local temperature inversions more common in the winter can concentrate emissions near the surface, leading to periods of elevated PM 2.5 concentrations.

To assess whether it is likely that unusual meteorological patterns have

contributed to the lower PM 2.5 concentrations observed in the 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

C enter at: www.ncdc.noaa.gov/cdo-web/search#t=secondTabLink

1. Temperature Trends Table I-5 (relating to Allentown Area monthly mean temperature (°F))

pr esents 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 PM 2 .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 PM 2 .5 concentrations as experienced. The Allentown Area’ s C lean Data Determination for the

2006 24-hour PM 2 .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 PM 2 .5 formation. 0 10 20 30 40 50 60 70 80 90degrees Fahrenheit 

## Monthly Mean Temperature- 10
- 2. Precipitation Trends

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

mont hly 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

da ta that unusual precipitation patterns contributed to the lower PM 2 .5 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 2012Precipitation (inches) 

## Annual Precipitation- 11
- concentrations in recent years in which the Allentown Area monitored

a ttainment of the PM 2.5 NAAQS

.

D. Additional Trends

1. Population Trends

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

ha s had significant population growth over the last decade as shown in

F igure 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 popul ation in Pennsylvania.

Population increases correspond with increased emissions from some

t ypes 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

PM 2 .5 concentrations. In fact, the area’ s PM 2.5 concentrations have declined in spite of the increase in population.

F igure I-7 : Allentown Area Population Trend

2. Economic Trends

Economic trends could have impacts on emissions and consequently affect

PM 2.5 concentrations in the Allentown Area. The two factors considered

he re 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

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

L abor, 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

incr eased 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

P hiladelphia Federal Reserve Bank has tracked economic activity in Pennsylvania over the last 25 years.

F igure 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

F igure 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 70000019901992199419961998200020022004200620082010 

## Allentown Area Population and Labor

Force Trends

Nonfarm Employment

Population- 13
- Figure I-9 : Pennsylvania and National Coincident Indexes from the

P hiladelphia 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

nonfa rm 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 PM 2.5 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 80.00 100.00 120.00 140.00 160.00 180.00Jan-79Feb-81Mar-83Apr-85May-87Jun-89Jul-91Aug-93Sep-95Oct-97Nov-99Dec-01Jan-04Feb-06Mar-08Apr-10Coincident Index 

## Pennsylvania and National Coincident

Indexes

PA

US- 14
- removal of ozone, secondary and directly emitted PM 2.5 , 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 e missions of SO 2 , NO X , VOC, NH 3 and direct PM 2.5 were modeled. The modeling was based on the annual PM 2.5 design values for the 2003 through 2007 base period.

EPA outlined the model results in the Air Quality Modeling Final Rule Technical Support Document for the Transport Rule. Air quality modeling was performed

to simulate ozone and PM 2.5 concentrations for the 2005 base year, a 2012 “no

CAIR” base case, a 2014 “no CAIR” base case, and the 2014 remedy scenario.

Ta ble I-7(relating to EPA’s Transport Rule modeling results for the PM 2.5 Standard for the Allentown Area) displays the results of EPA’s analysis for the

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

the 2006 PM 2.5 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 PM 2.5 NAAQS.

Table I-7: EPA ’ s Transport Rule Modeling Results for the PM 2.5 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 redesignat e 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

C AA 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- 15
-

EPA must implement the PM 2.5 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

state 2

, 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

e lements 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

a rea 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 PM 2.5 nonattainment status of the Allentown Area are not applicable requirements for purposes of review of the

C ommonwealth’s PM 2 .5 Redesignation Request. However, EPA requires that the

Commonweal th ’ s Prevention of Significant Deterioration (PSD) requirements be

a pproved 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

S ection 110 requirements, including provisions addressing PM 2.5

. Pennsylvania’ s SIP measures meeting Section 110(a)(2)(C) and 110(a)(2)(J) requirements are

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

a ssociated 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

re quirements 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 PM 2.5 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 PM 2.5 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 PM 2.5 NAAQS based on quality assured, quality controlled and certified ambient air monitoring data that show the area had monitored attainment based on 2008-2010 data (“Clean Data Determination”) (77 FR 18922). This final action suspended the requirements for this area to submit an attainment demonstration and associated reasonably available control measures, reasonable further progress plans, contingency measures and other planning SIP revisions

related to the attainment of the 2006 PM 2.5 NAAQS for so long as the area

continues to attain the 2006 PM 2.5 NAAQS.

Submittal of a comprehensive inventory is required by 40 CFR Section 51.1008 to meet the requirements of Section 172(c)(3) of the

C AA. 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

pa rt 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

PM 2.5 NAAQS.

2

. Section 173 of the CAA

Section 173 of the CAA outlines requirements related to permitting of air poll ution sources in nonattainment areas.

Stationary air pollution sources are subject to the regulations of the Commonwealth of Pennsylvania, Pennsylvania Code in Title 25

Environme ntal 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.

C ode 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).

The se 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

a pproved 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.

C ode 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

I n light of a recent Court decision, Natural Resources Defense Council v.

EPA , No. 08-1250, 706 F.3d 428 (D.C. Cir. 2013) (see discussion in

Section II I), 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 PM 2.5 , SO 2 , NO X , VOC and NH 3 for the

maintenance demonstration. Please see Section III

- C-1 relating to control measures for stationary sources for a discussion of the stationary source control measures in place in the 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 PM 2.5 NAAQS.

I II . DEMONSTRATION OF PERMANENT AND ENFORCEABLE IMPROVEMENT

This section provides an assessment of the PM 2.5 and PM 2.5 precursor emissions at a time the Allentown Area was monitoring nonattainment of the PM 2 .5 NAAQS and at the time

when this area attained the PM 2.5 NAAQS. 3 A 2005 (baseline) inventory of PM 2.5 and

PM 2.5 precursor emissions is used to represent emissions during the PM 2.5 nonattainment designation period. A 2007 inventory is used to identify PM 2.5 and PM 2.5 precursor emissions during a period when the Allentown Area demonstrated that it attained the

PM 2.5 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 PM 2.5 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 Q uality Planning and Standards, EPA, March 2, 2012 (“Implementation Guidance for
the 2006 24 -Hour PM 2.5 NAAQS ”). In the Implementation Guidance for the 2006 PM 2.5 NAAQS, EPA adopted the framework and policy approach the agency espoused in its implementation rule for the 1997 PM 2.5 NAAQS, known as the “Clean Air Fine Particle Implementation Rule (72 FR 20586; April 25, 2007) (the Implementation Rule for the

1997 PM 2.5 NAAQS ”)

In its Implementation Rule for the 1997 PM 2.5 NAAQS, EPA established general

pr esumptive policies for assessing which PM 2.5 precursors should be evaluated for possible controls. In that earlier rule, the EPA required states to evaluate control

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

control measures for NO X unless a technical demonstration is made to show NO X does not significantly contribute to PM 2.5 . The EPA 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 NH 3 only if a technical demonstration is made to show they significantly

contribute to PM 2.5 in that area.

The EPA reaffirmed the appropriateness of these presumptions in its Implementation

Guidance for the 2006 24-Hour PM 2.5 NAAQS. Meanwhile, the U.S. Court of Appeals for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997

PM 2.5 NAAQS, in Natural Resources Defense 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

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

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

PM 2.5 NAAQS. According to EPA’s June, 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 PM 2.5 NAAQS and to the extent it would be extrapolated to the 2006 24-Hour PM 2.5 NAAQS) could affect an area’s nonattainment 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 PM 2.5 NAAQS, those considerations are not relevant for this Request for Redesignation and the Maintenance Plan. The Court noted that PM 2.5 precursors, including ammonia and VOCs, are presumptively regulated in PM 2.5 nonattainment areas under Subpart 4, pointing specifically to Section 189(e) of the CAA, which applies to control of major stationary sources of PM 10 [the court stated that PM 10 includes PM 2.5 throughout Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to

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

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

PM 10 levels that exceed the standard in the area; Section 189(e) of the CAA also requires EPA to issue guidelines regarding the application of Subsection (e). Pennsylvania

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

demonstration.

This Request for Redesignation provides emissions information for all pollutants ( PM 10 , PM 2.5 , SO 2 , NO X , VOC and NH 3 ), as required by 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 ( PM 2.5 ) 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 PM 2.5 and PM 2.5 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 PM 2.5 and PM 2.5 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

e missions present when the Allentown Area did not meet the 2006 24 -hour PM 2 .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 200 5 baseline year inventory includes the pollutants PM 10 , PM 2.5 , SO 2 , NO X , VOC, and NH 3 . The inventory consists of sources in four sectors: electric generating units (EGUs), non-EGU point and stationary area sources, highway 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 NO X 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 e missions 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 PM 2. 5 PM 10 SO 2 NO X VOC NH 3 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 PM 10 , PM 2.5 , SO 2 , NO X , VOC and NH 3 emissions for the Allentown Area is used to identify emissions during the period when attainment

of the PM 2.5 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 PM 2 .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 sm all 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 PM 2.5 PM 10 SO 2 NO X VOC NH 3 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 NO X emissions than the current model, MOVES2010. The MOBILE6 model also predicts lower direct PM 2.5 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, PM 2.5 , SO 2 , NO X , VOC, and NH 3 emissions decreased by

10 %, 1 1 %, 0.2%, 15% and 47% respectively, from 2005 to 2007. The permanent

a nd enforceable reductions of direct PM 2.5 , SO 2, NO X 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

Te chnical 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 th is Request for Redesignation, this section describes the permanent and enforceable federal and state measures that provided PM 2 .5 , SO 2 , NO X and VOC emission reductions from 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 PM 2 .5 NAAQS adopted the same presumptions related to PM 2.5 precursors as EPA’s Implementation Rule

for the 1997 PM 2.5 NAAQS. However, DEP recognizes the Court decision in

N atural 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 PM 2 .5 NAAQS

.

In general, the Court’s decision (for the 1997 PM 2 .5 NAAQS and to the extent it would be extrapolated to the 2006 24-Hour PM 2.5 NAAQS) could affect an area’ s nonattainment classification, certain deadlines, and the impacts of failing to attain timely, and could impose a deadline for implementation of reasonably available

a nd best available control measures (706 F.3d at 436, n. 6). Since the Allentown Area is already attaining the 2006 24-Hour PM 2.5 NAAQS, however, those considerations are not relevant for this Redesignation Request or the accompanying Maintenance Plan.

The Court noted that PM 2.5 precursors are presumptively regulated in PM 2.5 nonattainment areas under Subpart 4 , pointing specifically to Section 189(e) of

the CAA , which applies to control of major stationary sources of PM 10 [the court

stated that PM 10 includes PM 2.5 throughout Subpart 4]

. (706 F.3d at 436, n. 7, and at 437, n. 10 ). According to Section 189(e) of the CAA, control requirements

a pplicable for major stationary sources of PM 10 also apply to major stationary

sources of PM 10 precursors, except where the Administrator determines that major stationary sources do not contribute significantly to PM 10 levels that exceed the standard in the area; Section 189(e) of the CAA also requires EPA to issue

g uidelines regarding the application of Subsection (e). Pennsylvania assessed

e missions of PM 2.5 , SO 2 , NO X , VOC and NH 3 for the maintenance demonstration.

Emissions of PM 2.5 , SO 2 , NO X , VOC and NH 3 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 PM 2.5 , SO 2 , NO X 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

de crease in PM 2.5 emissions is a conservative estimate because the 2007 inventory was augmented to account for condensable PM. A summary of the quantity of

e mission 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 n egative values in Table III-3 indicate emission reductions.

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

from 2005 to 2007

Change from 2005 to 2007 PM 2.5 SO2 NO X 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

PM 2.5 , SO 2 , NO X 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

mar gin for PM 2.5 and NO X . 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 pr ojected growth in emissions is smaller than anticipated emission reductions from control measures for all pollutants in the nonattainment area.

B ased 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 PM 2.5 NAAQS of

35 μg/m. 3 Each measure is explained in greater detail in the following sections.

T able III-4 : Summary of Emission Totals (Tons) in 2007, 2017 and 2025

Allentown PM2.5 SO2 NO X 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 PM 2.5 and

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

sourc e 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

de pend on the quantity of regulated pollutants emitted from the air

contamination sources. DEP will issue a “ St ate-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

c ontaminants 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

be en codified in the SIP at 40 CFR § 52.2020(c)(1) at various times since

Ma y 1, 1972 and most recently on October 5, 2012, and are therefore all

fe derally 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

fa cility’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 T itle 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

d esignated attainment for National Ambient Air Quality Standards including carbon monoxide, particulate matter (PM), lead, nitrogen dioxide (NO 2 ), ozone and sulfur dioxide (SO 2 ). 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 NO X , SO 2 , PM or carbon monoxide. It

shoul d 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 NO X and VOC are precursors of PM 2.5 , NO X and VOC emission reductions required statewide under the nonattainment NSR program for ozone also allow Pennsylvania to make substantial progress in attaining and maintaining the PM 2.5 NAAQS. Any major stationary source or major modification subject to the NSR requirements must receive a plan approval. To

re ceive approval from the Department, a person must show that the proposed source will, among other things, offset its potential to emit air contaminants including NO X , PM and VOCs by securing emission reductions credits at the specified offset ratio, will employ th e “lowest achievable emission rate” (LAER) for each regulated pollutant and conduct an alternative analysis. The

nona ttainment NSR requirements are codified in 25 Pa.

C hapter 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

re quirements are applicable to major sources in areas attaining the NAAQS. The federal PSD regulations codified in 40 CFR Part 52

a re incorporated by reference in their entirety in 25 Pa. Code § 127.83 (relating to adoption by reference). The Department’ s P SD regulations, codified in 25 Pa. Code Chapter 127, Subchapter D, were approved by the EPA on August 21, 1984 and

c odified 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, NO 2 , ozone, PM and SO 2 depending on the source category. Any major stationary source or major modification subject to the PSD requirements must conduct an analysis to establish the best 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

c ontaminants 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

mi nimum 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.

C ode §§ 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).

NO X and SO 2 Control Programs. In 1998, EPA promulgated the NO X SIP Call as the EPA’s principal effort to reduce interstate transport of air pollution (63 FR 57356; October 27, 1998). In response to the federal

NO X SIP call rule, Pennsylvania adopted the NO X Budget Trading Program regulations for EGUs and large industrial boilers, with emission

re ductions to commence May 1, 2003. The regulations were approved by

EPA a s a revision to the Commonwealth’s SIP on August 21, 2001 (66 FR 43795). Additionally, in response to the NO X SIP Call, Pennsylvania adopted additional NO X control regulations covering cement plants and internal combustion engines, with emission reductions to commence May 1, 2005. These regulations were approved by EPA as a

S IP 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 NO X and SO 2 . CAIR is now being implemented in

P ennsylvania through the Department’s CAIR regulation, codified

in 25 Pa. Code Chapter 145, Subchapter D, with related

a mendments in Chapters 121, 129 and 145. EPA approved

P ennsylvania’s CAIR SIP revision on December 10, 2009, codified

at 40 CFR § 52.2020(c)(1) (74 FR 65446). In the CAIR SIP revision, Pennsylvania terminated the NO X Budget Trading Program and transitioned to the federal CAIR for large electric generating units (EGU).

The market-based CAIR is designed to reduce EGU emissions of

NO X and SO 2 below 2002 levels throughout the eastern United- 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

NO X annu al, NO X ozone season, and SO 2 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, modifi ed, 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

C ourt of the United States reversed the Court of Appeals’ decision

that ha d vacated the Transport Rule. Th e 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

unde r a stay previously imposed by the Court of Appeals and

CAIR continues to be implemented.

NO X Budget Trading Program limits on non-EGUs. The CAIR

SIP revision also established emission limits for the non-EGUs and other units that were subject to the Commonwealth’s NO X Budget Trading Program but are not subject to the CAIR NO X Ozone Season Trading Program. These units must continue monitoring

NO X emissions and must meet an emissions cap. Each unit has an allowable emission rate, calculated by January 31 of each year,

ba sed on the previous ozone season’s heat input. If the combined

NO X ozone season emissions from all of these units exceed the statewide ozone season emission cap of 3,438 tons, each unit that

e xceeds its individual allowable emissions limit for that ozone season must surrender to the Department one CAIR NO X ozone season allowance and one CAIR NO X annual allowance for each ton of emissions over its allowable limit. In addition, the Department has set aside 181 tons of NO X , including tons that will be retired each year to compensate for sources that were exempted

unde r the “twenty-five ton exemption” in section 145.4(b) 3. The

ba lance 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 NO X ozone season emission limitation will be exceeded. Pennsylvania’s non-EGU

sources’ total emissions during each of the years they were trading

under the NO X Budget Trading Program never exceeded the statewide cap of 3,438 tons.

The Department’s regulation, codified in 25 Pa. Code § 145.8(d),

wa s approved by EPA as a SIP revision on December 10, 2009,

a nd 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 NO X SIP Call. Until 2009, cement kilns and large stationary internal combustion engines that were subject to the NO X SIP Call were required to

surrender NO X SIP Call allowances if they exceeded their NO X emission limits set forth in Department regulations. Because the Department discontinued the NO X Budget Trading Program beginning 2009, at which point NO X SIP Call allowances were replaced by CAIR NO X ozone season allowances, the Department modified the regulations to require surrender of CAIR NO X ozone season and CAIR NO X annual allowances for emission limit

exceedances.

The Department’s regulations for large stationary internal combustion engines and cement kilns, codified in 25 Pa. Code

C hapter 145, Subchapters B and C, respectively, were approved by

EPA a s 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 NO X 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

a pplicable 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

sourc es.

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, hig hway 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) andPennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established by the CAA Amendments of 1990 include NO X 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.

I n 1998, under the authority of Section 177 of the CAA, the Pennsylvania Environmental Quality Board (EQB) adopted the Pennsylvania Clean

Ve hicles 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

pr ovisions 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

inventor ies, as provided in the Motor Vehicle Emission Simulator ( MOVES) model.

I n 2002, the EQB adopted the Heavy-Duty Diesel Emissions Control

P rogram 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

c omply with consent decree standards, even without an enforcement mechanism. The Department has used MOVES defaults to calculate

emissions from MY 2005 and 2006 highway engine s.

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 NO X and VOCs. For gasoline engines, the standards were phased in during MY 2 008 and 2009. Federal and California standards are virtually identical for MY 2007. For

MY 2008, California adopted requirements for idling restriction engine programming and an optional “clean NO X idle” standard. However, there is no EPA-approved methodology to estimate emission reductions from this requirement. Therefore, the emission estimates use assumptions of

the f ederal 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

wa s a temporary compliance option allowing refiners to continue to produce up to 20 percent of their highway diesel fuel at 500 pp m 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

a pproved the SIP revision on October 6, 2005 (70 FR 58313).

Low sulfur gasoline. Sulfur is a natural ly occurring component of crude oil that ends up in gasoline and diesel unless removed. Sulfur in gasoline impairs the effectiveness of emission control systems and contributes to air pollution. By removing most sulfur from gasoline, new advanced emission controls will work longer and more efficiently, and air pollution

will be reduc ed.

The 1999 federal Tier 2 regulations (65 FR 6698 ; Feb. 1 0, 2000) reduce d the sulfur content of gasoline by up to 90 percent , enabling the use of new emission control technologies in cars and trucks that reduce harmful air pollution. The emission inventory ana lysis 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

- sul fur 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

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

effectiveness of vehicle emission controls even further and reduce onroad

e missions of NO X by 25 percent, direct particulate matter by 10 percent and VOCs by 16 percent. The rule will also significantly reduce emissions of carbon monoxide and hazardous air pollutants including acrolein, benzene, formaldehyde and acetaldehyde. Emission reductions from the federal Tier 3 program have not been included in future year

inventor ies 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 PM 2.5 NAAQS.

3. Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel-powered (“compression ignition”) and gasoline-powered (“spark ignition”) nonroad engines of various sizes (horsepower) and applications. Information on these federal rules, including their implementation dates, can be found at www.epa.gov/nonroad

. The Department used the assumptions built into the nonroad model (NONROAD2005) and NMIM to estimate emissions for all milestone years.

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

na tional 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 pr events 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- go ing marine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur concentration as in highway fuel, 15 ppm; this requirement began

a pplying 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

ve ssels. 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

C onsumer Products program is codified in 25 Pa. Code Chapter 130,

S ubchapter 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,

subm itted to the EPA as a SIP revision on March 11, 2009, an d 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 PM 2.5 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 PM 2.5 , SO 2 , NO X , VOC and NH 3 over the 10 years following redesignation will remain below the emissions level in 2007, while allowing for growth in population and vehicle miles traveled. Based on 2010-2012 monitoring data, the Allentown Area has a 24-hour design value of 32 μg/m, 3 whic h 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 SO 2 , NO X , direct PM 2.5 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 NO X ;

● 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

p assenger and light-duty trucks;

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

● Fe deral 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, NO X 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 PM 2.5 NAAQS assurances that it will continue to operate the ambient air quality monitoring network in order to track maintenance of the standard and to evaluate emissions inventories periodically compared to the projections provided in the plan. DEP has also provided in the Maintenance Plan a li st of contingency measures that it would consider to correct any violation of the 2006

PM 2 .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

NH 3 Ammonia NLEV National Low Emission Vehicle (program) NMIM National Mobile Inventory Model- 37
-

NOAA National Oceanic and Atmospheric Administration

NONROAD Nonroad Model

NO X Oxides of Nitrogen

NSR New Source Review

OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood-fired Boiler PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM 2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates

PM 10 Particulate Matter less than 10 microns in diameter ppm parts per million

PSD Prevention of Significant Deterioration

RWC Residential Wood Combustion

SCC Source Classification Code SIP State Implementation Plan

SO 2 Sulfur Dioxide

TAF Terminal Area Forecast TCM Transportation Control Measures TIP Transportation Improvement Program TSD Technical Support Document μg/m 3 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 201 4

Bureau of Air Quality Pennsylvania Department of Environmental Protection

P.O. Box 8468 Harrisburg, PA 17105-8468

717 -787 -9495

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

- Table of Contents

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

A. Health and Environmental Effects of Fine Particulate Matter (PM 2.5 ) ....................1

B. S ources of PM 2.5 and Precursor Pollutants of Concern ............................................2

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

D. P ublic Participation ..................................................................................................8

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

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

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

C. Gr owth 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

I V. 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

Ta ble 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

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

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

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

Ta ble 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, NH 3 , and SO 2 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 (PM 2.5 )

Particulate matter (PM) is a mixture of microscopic solids and liquid droplets suspended in air that include: acids (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is less than or equal to 2.5 micrometers (μm) in diameter, approximately 1/30th

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

pe netrate 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

a ggravate 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 PM 2.5 reductions occurring in the 1980s and 1990s had on the increased life expectancy observed over that period. The study found that a reduction of 10 micrograms per cubic meter (μg /m 3 ) of PM 2.5 was associated with an average increase in life expectancy of

7.3 months.

PM 2.5 has significant environmental impacts, including acid rain and stream eutrophication. PM 2.5 also affects visibility (regional haze) through the scattering and absorption of light. Fine particles, similar in size to the wavelength of light, are most efficient, per unit of mass, at reducing visibility. Soiling and materials

da mage can also be caused by PM 2.5 in the air.

The United States Environmental Protection Agency (EPA) promulgated PM 2 .5 national ambient air quality standards (NAAQS) in 1997 after evaluating

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

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

standard of 1 5.0 μg/m, 3 based on the 3-year average of annual mean PM 2.5 concentrations. The EPA also established a primary and secondary 24-hour standard of 65 μg/m 3 determined by the 3 -year average of the 98th percent il e of

24 -hour concentrations. In 2006, the EPA promulgated a revised 24-hour PM 2 .5 NAAQS of 35 μg/m 3 determined 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

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

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

EPA a s nonattainment for the 2006 PM 2.5 NAAQS. The Allentown Area was

de signated nonattainment because the area violated the 2006 24-hour PM 2.5 NAAQS of 35 μg/m 3 based on 2006-2008 monitoring data.

B. Sources of PM 2.5 and Precursor Pollutants of Concern

Fine particle pollution can be emitted directly or formed secondarily in the atmosphere. PM 2.5 emitted directly into the air in a stable solid or liquid chemical form (including PM 2.5 that is formed near its source by condensation) is referred

to as “primary” PM 2 .5

. PM 2.5 is formed by chemical reactions of gases in the atmosphere is considered to be “secondary” PM 2 .5 . The chemical composition of

PM 2.5 in an area depends on the mix of emissions, location, time of year, and weather. The chemical composition of PM 2.5 ca n 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 PM 2.5 includes soot from diesel engines, condensed organic material from incomplete combustion and compounds from condensation during combustion or smelting.

The atmospheric chemistry of PM 2.5 formation is complex. Formation of secondary PM 2.5 depends on numerous 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 PM 2.5 include:

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

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

 Ammonium, formed primarily from emissions of ammonia ( NH 3 ) from animal operations; and- 3
-  Secondary organic aerosol, formed from emissions of volatile organic

c ompounds (VOCs) from incomplete combustion and evaporation from a

wide diversity of sources.

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

for mation, the EPA recognizes that effective control measures for PM 2.5 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 PM 2.5 NAAQS ”). In the Implementation Guidance for the 2006 PM 2.5 NAAQS, EPA adopted the framework and policy approach the agency espoused in its implementation rule

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

the 1997 PM 2 .5 NAAQS ”).

In its Implementation Rule for the 1997 PM 2.5 NAAQS, EPA established general presumptive policies for assessing which PM 2.5 precursors should be evaluated for possible controls. 1 In that earlier rule, the EPA required states to evaluate control

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

evaluate control measures for NO X unless a technical demonstration is made to

show that NO X emissions from sources in the state do not significantly contribute

to PM 2.5 concentrations in the nonattainment area. The EPA required states to

evaluate measures for VOC and NH 3 only if a technical demonstration is made to

show VOC or NH 3 emissions significantly contribute to PM 2.5 in the

nonattainment area.

The EPA reaffirmed the appropriateness of these presumptions in its Implementation Guidance for the 2006 24-Hour PM 2 .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 PM 2.5 NAAQS, in Natural Resources Defense

Council v. EPA , No. 08 -1250 . On January 4, 2013, the Court handed down its ruling in that case. The Court granted the petitions for review and remanded the

c ase 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 (7 06 F.3d 428 at 437(DC Cir. 2013)).

Shortly thereafter, EPA withdrew its Implementation Guidance for the 2006

24 -hour PM 2.5 NAAQS. According to EPA’s June, 2013 withdrawal

1 The EPA’s definition of “ PM 2.5 at tainment plan precursor” can be found in 40 CFR Section 51.1000, which reads:

“ PM 2.5 attainment plan precursor means S0 2 and those other PM 2.5 precursors emitted by sources in the State which

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

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

2006 24-hour PM 2.5 NAAQS as well.” See, Implementation Guidance for the 2006 24 -hour PM 2.5 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 PM 2 .5 NAAQS) could affect an area’s nonattainment classification, certain deadlines, and the impacts of failing to attain timely, and could impose a deadline for implementation of reasonably available and best available control measures (706 F.3d at 436, n. 6).

S ince the Allentown Area is already attaining the 2006 24-Hour PM 2 .5 NAAQS, however, those considerations are not relevant for this Maintenance Plan. The

Court noted that PM 2.5 precursors, including ammonia and VOCs, are presumptively regulated in PM 2.5 nonattainment areas under Subpart 4, pointing

spec ifically to section 189(e), which applies to control of major stationary sources

of PM 10 [the court stated that PM 10 includes PM 2.5 throughout Subpart 4] (7 06 F.3d at 436, n. 7, and at 437, n. 10). According to Section 189(e) of the

C lean Air Act (CAA), control requirements applicable for major stationary

sources of PM 10 also apply to major stationary sources of PM 10 precursors, except where the Administrator determines that major stationary sources do not contribute significantly to PM 10 levels that exceed 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 PM 2 .5 , SO 2 , NO X , VOC and NH 3 for the maintenance demonstration.

This State Implementation Plan (SIP) revision provides emissions information for all pollutants ( PM 10 , PM 2.5 , SO 2 , NO X , VOC and NH 3 ), as required by EPA’ s guidance entitled, “Emissions Inventory Guidance for Implementation of Ozone

a nd Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.” 4

C. Purpose a nd Structure o f t his 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 PM 2 .5 NAAQS nonattainment areas

based on 2006-2008 air quality monitoring data. Under Section 1 10 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 ( PM 2.5 ) 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

a ttained the 2006 PM 2.5 NAAQS based on 2008-2010 quality assured, quality

c ontrolled 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 PM 2.5 NAAQS for so long as the area

continues to attain the 2006 PM 2.5 NAAQS.

EPA’s determination of attainment and the Clean Data Determination d id not “redesignate ” the area as “attainment.” The Allentown Area remain s a designated

nonattainment area for the 2006 PM 2 .5 NAAQS until the Commonwealth submits, and EPA approves, a Request for Redesignation and a Maintena nce Plan showing the area can maintain the standard for at least 10 years after redesignation.

N onattainment new source review continues to apply until EPA redesignates the area as attainment (72 FR 20603 ). Transportation conformity and genera l 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

inventor y for all pollutants considered potential precursors to PM 2 .5 and for direct

emissions of PM 2.5.

This SIP revision includes the Maintenance Plan for the Allentown Area for the

2006 P M 2.5 NAAQS and the 2007 comprehensive inventory required under

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

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

. The 2007 comprehensive inventory also serves as the attainment year inventory representing a level of emissions sufficient for the Allentown Area to

a ttain the 2006 PM 2.5 NAAQS.

To demonstrate maintenance of the PM 2.5 NAAQS for this area, Pennsylvania is showing that the future emissions of PM 2.5 and its precursors will remain at levels that will provide for maintenance of the PM 2.5 NAAQS for at least 10 years after

re designation, 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

P lan 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

R edesignation 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

de monstrates that the Commonwealth has met all of the regulatory and planning

re quirements under the CAA for the Allentown Area that were due before the date

of the Request for Redesignation.

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

e nsure maintenance of the NAAQS:

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

ne twork 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

e missions sufficient to attain the NAAQS. This “attainment yea r 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

inventor ies 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

im plement 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 o f this Plan and the Request for

R edesignation); and

 The Commonwealth should identify measures that would be available to promptly correct any NAAQS violation (addressed in Section VI of this

P lan).

This document describes how the Commonwealth will meet those criteria.- 7
- Th is Maintenance Plan demonstrates that the 2006 PM 2.5 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

PM 2 .5 and its precursors over the 10 years following redesignation remain at levels

that will provide for maintenance of the PM 2.5 NAAQS, even considering growth in popul ation and vehicle miles traveled.

Th is Maintenance Plan also shows that the following state and federal programs will ensure the continuing decline of PM 2.5 , SO 2 , NO X and VOC emissions:

 The Clean Air Interstate Rule (CAIR);

 Emission limits for large industrial boilers;

 State regulation of cement kilns, large stationary internal combustion engines, and smaller sources of NO X ;

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

 State requirements for Best Available Technology (BAT);

 State regulation of the sulfur content of fuel oil;

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

s olvents;

 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

program s;

 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

Ac t, 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, NO X 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 wa s publi shed in the Pennsylvania Bulletin on Oc tober 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 23 414) 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 PM 2.5 NAAQS.- 8
- In th is Maintenance Plan, the Department provides assurances that it will continue
to oper ate 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 li st 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 PM 2.5 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 not ice of a public comment period and the opportunity for a hearing on

the Allentown Area Maintenance Plan for the 2006 PM 2.5 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 PM 2 .5 standard. The Department conducted a public hearing on May 8, 2014. The publi c comment period closed May 9, 2014. The Department received comment s fr om four commentators, which have been addressed in a Comment and Response

Document.

II . EMISSION INVENTORIES

To demonstrate maintenance of the 2006 PM 2 .5 NAAQS for th e Allentown Area, Pennsylvania is showing that the future emissions of PM 2.5 and its precursors will remain at levels that will provide for maintenance of the PM 2.5 NAAQS for at least 10 years, taking economic, population and travel growth into account. This Maintenance 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 PM 2 .5 NAAQS. In addition, th is 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

spec ified by the EPA, the pollutants inventoried by Pennsylvania includ e direct PM 2.5 , PM 10 , SO 2 , NO X , VOC, and NH 3 . Information on the manmade sources of these pollutants was compiled for:

 “Stationary point sour ces ” (or “point” sources), which are sources for which the Department collects individual emissions-related information. Generally, they represent major stationary sources but may be smaller.

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

a re not limited to commercial and residential open burning, architectural and

indus trial 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 engin es , including but not limited to outdoor power equipment, recreational vehicles, farm and

c onstruction machinery, lawn and garden equipment, industrial equipment, recreational marine vessels, commercial marine vessels, locomotives, ships, and

a ircraft.

Pe nnsylvania and other Northeastern and Mid-Atlantic states participated in a regional

e ffort to refine the emissions inventory and to compile a regional emissions inventory.

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

re gional 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 NAAQ S and the PM 2.5 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

PM 2.5 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 PM 10 , PM 2.5 , SO 2 , NO X , VOC, and NH 3 . The inventory consists of sources in four sectors: electric generating units (EGUs), non-EGU point and stationary area sources, highway 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 2.5 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 EGU 2,991 3,582 48,760 10,485 101 71

Non

- EGU + Stationary Area 3,747 19,342 14,712 10,360 11,9 76 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)

S tationary Point Sources. The 2007 stationary point source inventories were based on emissions reported to DEP by facilities. DEP requires owners and

ope rators 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

e stimates supersede those calculated using SCC codes. Appendix A-1 includes

infor mation on stationary point source emission methodology, and Appendix A-2

is t he data set for facility 2005 annual emissions (NEI Tier 1). Appendix A-3

include s 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

ba nked emissions reduction credits for the Allentown Area in the 2017 and 2025

e mission 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 i nclude condensable PM for many facilities.] Appendix C-4 contains the

tec hnical 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

sourc e 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.

Appe ndix 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

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

statio nary 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

MOV ES2010 to estimate the onroad emissions inventory for 2007, 2017 and

2025.

More information on highway emission methodology is available in Appendix D. Appe ndix D-1 summarizes the methodology and data inputs used to produce the mobile emissions inventory. Appendix D-2 provides the 2007 attainment year

a nd 2017 and 2025 projections of mobile (highway) vehicle miles travelled (VMT) and annual PM 2.5 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

ve hicle emission testing, the fuel types required in the area, temperatures by month, and fleet age. The summary in Appendix D-3 indicates when default

infor mation 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

NO NROAD 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

a ircraft, 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.

Railr oad 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

switche rs operating per yard, (3) the tier/year of switchers, (4) annual fuel use (ga llons/year) for switchers per yard, (5) approximate duty cycle or just percent of

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

switche r’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 PM 10 , PM 2.5 , SO 2 , NO X , VOC, and NH 3 for the Allentown Area

identifie s PM and PM precursor emissions during the period when the Allentown Area was attaining the 2006 PM 2.5 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 PM 2.5 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

e missions inventory is not directly comparable to the 2007, 2017 and 2025 inventories, PM 2.5 , SO 2, NO X , VOC, and NH 3 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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

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

for the d evelopment of the 2017 e mis sions inventory. Appendix C-3 contains the technical support document for the development of the 2025 emissions inventory. The documents prov ide 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

g rowth factors based on AEO2011 Table 96 - Electricity Generation by

Elec tricity 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

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

de scription 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 we re based on Version 3 .3 o f 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

doc uments 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

pr ojections 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

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

fue l 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.

B ecause 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 incr ease, 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.

S tate 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

socioe conomic 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

Stat e Implementation Plans and Transportation Conformity

. Appendi ces D-1 through D-3 of this Maintenance Plan include specific information on the hig hway emissions inventory methodology, data files of emissions estimates

a nd 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 sig nificant vehicle-related precursor, NO X , 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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

fi nalized 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 (F AA 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.

Ra ilroad 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

a nd 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

Tab le 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 PM 2.5 and NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. The highway vehicle emissions in Table II -4 reflect inclusion of that safety margin.

E. Maintenance Year (2025) Emissions

Ta ble 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 PM 2.5 PM 10 SO 2 NOx VOC NH 3 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 PM 2.5 and NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. The highway vehicle emissions in Table II -5 reflect inclusion of that safety margin.

F. Maintenance Plan Emissions Test

To demonstrate maintenance of the 2006 PM 2 .5 NAAQS for this area, Pennsylvania must show that the future emissions of PM 2.5 and its precursors will remain at levels that provide for maintenance of the PM 2.5 NAAQS for at least

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

account.

EPA’s Implementation Guidance for the 2006 24-Hour PM 2 .5 NAAQS adopted the same presumptions related to PM 2.5 precursors as EPA’s Implementation Rule

for the 1997 PM 2.5 NAAQS. 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 PM 2 .5 NAAQS

. The Court noted

that PM 2.5 precursors, including ammonia and VOCs, are presumptively regulated

in PM 2.5 nonattainment areas under Subpart 4 , pointing specifically to

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

PM 10 [the court stated that PM 10 includes PM 2.5 throughout Subpart 4] (706 F.3d

at 436, n. 7, and at 437, n. 10 ). According to Section 189( e) of the CAA, control requirements applicable for major stationary sources of PM 10 also apply to major stationary sources of PM 10 precursors, except where the Administrator determines that major stationary sources do not contribute significantly to PM 10 levels that exceed 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 PM 2.5 , SO 2 , NO X , VOC and NH 3 for the maintenance

demonstration.

This Maintenance Plan contains an attainment year inventory for 2007 and

demonstrates that emissions of PM 2.5 , SO 2 , NO X , VOC and NH 3 , including emissions in the transportation conformity safety margin for PM 2.5 and NO X , will not be greater in 2017 and 2025 than in the attainment year, as shown in

Ta ble II -6

. Emissions of SO 2 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 PM 2.5 , VOC and NH 3 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 PM 2.5 SO 2 NOx VOC NH 3 2007 6,507 56,900 34,685 19,038 861

2 017* 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 PM 2.5 and

NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. The emissions in Table II -6 reflect inclusion of that safety margin.

I II . PERMANENT AND ENFORCEABLE CONTROL MEASURES

A. Permanent and Enforceable Control Measures

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

for mation, the EPA recognizes that effective control measures for PM 2.5 will vary among nonattainment areas. This was reflected in EPA’ s “Implementation Guidance for the 2006 24-Hour Fine Particle National Ambient Air Qualit y Standard,” Office of Air Quality Planning and Standards, EPA, March 2, 2012 (“Implementation Guidance for the 2006 24-Hour PM 2.5 NAAQS ”). In the Implementation Guidance for the 2006 PM 2.5 NAAQS, EPA adopted the framework and policy approach the agency espoused in its implementation rule

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

the 1997 PM 2 .5 NAAQS ”).

In its Implementation Rule for the 1997 PM 2.5 NAAQS, EPA established general presumptive policies for assessing which PM 2.5 precursors should be evaluated for possible controls. In that earlier rule, the EPA required states to evaluate control

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

evaluate control measures for NO X unless a technical demonstration is made to

show that NO X emissions from sources in the state do not significantly contribute

to PM 2.5 concentrations in the nonattainment area. The EPA required states to

evaluate measures for VOC and NH 3 only if a technical demonstration is made to

show VOC or NH 3 emissions significantly contribute to PM 2.5 in the

nonattainment area.

The EPA reaffirmed the appropriateness of these presumptions in its Implementation Guidance for the 2006 24-Hour PM 2 .5 NAAQS. 6 Meanwhile, the Court of Appeals for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997 PM 2.5 NAAQS, in Natural Resources Defense

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

6 See footnote 2, above.- 20
- ruling in that case. The Court granted the petitions for review and remanded the

c ase 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 PM 2.5 NAAQS. According to EPA’s June, 2013 withdrawal memorandum (see second page of memorandum), 7 EPA withdrew the guidance in response to the Court’s decision in Natural Resources Defense Council v. EPA

, No. 08 -1250.

This Maintenance Plan demonstrates maintenance of the standard consistent with

the Court ’s ruling. In general, the Court’s decision (for the 1997 PM 2.5 NAAQS and to the extent it would be extrapolated to the 2006 24-Hour PM 2.5 NAAQS) could affect an area’s nonattainment 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 PM 2.5 NAAQS, however, those considerations are not relevant for this

Maintenance Plan. The Court noted that PM 2.5 precursors, including ammonia and VOCs, are presumptively regulated in PM 2.5 nonattainment areas under Subpart 4, pointing specifically to section 189(e) of the CAA, which applies to control of major stationary sources of PM 10 [the court stated that PM 10 includes

PM 2.5 th roughout 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

statio nary sources of PM 10 also apply to major stationary sources of PM 10 precursors, except where the Administrator determines that major stationary sources do not contribute significantly to PM 10 levels that exceed the standard in the area; Section 189(e) of the CAA also requires EPA to issue guidelines regarding the application of Subsection (e). Pennsylvania assessed emissions of

PM 2 .5 , SO 2 , NO X , VOC and NH 3 for the maintenance demonstration.

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

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

standa rd.

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

include d in Table III -1

. (Negative values indicate emission reductions.) The

e mission change estimates account for any anticipated growth in the activity of sources regulated by the strategy and include emissions in the transportation conformity safety margin. Direct PM 2 .5 , SO 2 , NO X and VOC and NH 3 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

e mission reductions from control measures for all pollutants in the nonattainment

a rea. 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/m 3

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

whic h 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 Measu res

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

- 30,0 50

- 17,467

- 5,905

- 54
*A portion of the difference between attainment year and maintenance year emissions of PM 2.5 and

NO X has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in highway vehicles. The highway vehicle emissions in Table II I-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 PM 2.5 standard, as well as the Department’s comprehensive permitting program requirements in 25 Pa. Code

C hapter 127 and the Commonwealth’s SIP in 40 CFR 52.2020, meet the

re quirements of Subpart K. EPA has approved the Department’s plan approval

a nd 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

a pplications) 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

e mission 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

sourc e 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

fa cility or air contamination source, the owner or operator must obtain an operating permit from the Department. The type of operating permit will

de pend 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

c ontaminants 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. Th e provisions of Chapter 127 have

be en codified in the SIP at 40 CFR § 52.2020(c)(1) at various times since

Ma y 31, 1972 and most recently on October 5, 2012, and are therefore all

fe derally enforceable. Several aspects of Chapter 127 are highlighted

b elow as being particularly important for the maintenance of the PM 2.5 standard.

Title V Permitting Program. The Title V Permitting Program, adopted pursuant to the Clean Air Act Amendments of 1990, is applicable to major 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

e missions. 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 o f 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 (NO 2 ), ozone and sulfur dioxide (SO 2 ). 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, SO 2 , PM or carbon monoxide. It should be noted that the entire Commonwealth, included in the Ozone Transport Region by operation of law, is treated as a

“moderate” ozone nonattainment area, irrespective of the area’ s attainment status. Because NOx and VOC are precursors of PM 2 .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 PM 2.5 NAAQS. Any major stationary source or major modification subject to the NSR requirements must receive a plan approval. To

re ceive 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

e mploy the “lowest achievable emission rate” (LAER) for each regulated pollutant and conduct an alternative analysis. The

nona ttainment NSR requirements are codified in 25 Pa.- 24
- Chapter 12 7, 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

re quirements are applicable to major sources in areas attaining the NAAQS. The federal PSD regulations codified in 40 CFR Part 52

a re incorporated by reference in their entirety in 25 Pa. Code § 127.83 (relating to adoption by reference). Th e Department’ s PSD regulations, codified in 25 Pa. Code Chapter 127, Subchapter D, were approved by the EPA on August 21, 1984 and

c odified 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

c ontaminants to the maximum degree possible. The Department

de termines 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.

C ode §§ 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 SO 2 Control Programs. In 1998, EPA promulgated the NO X S IP Call as the EPA’s principal effort to reduce interstate transport of air pollution (63 FR 57356 ; October 27, 1998). In response to the federal

NO X SIP call rule, Pennsylvania adopted the NO X Budget Trading Program regulations for EGUs and large industrial boilers, with emission

re ductions to commence May 1, 2003. The regulations were approved by

EPA as a revision to the Commonwealth’s SIP on August 21, 2001 (66 FR 43795). Additionally, in response to the NO X SIP Call, Pennsylvania adopted additional NO X control regulations covering cement plants and internal combustion engines, with emission reductions to commence May 1, 2005. These regulations were approved by EPA as a

S IP 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

tra nsport of NO X and SO 2 . CAIR is now being implemented in

P ennsylvania through the Department’s CAIR regulation, codified

in 25 Pa. Code Chapter 145, Subchapter D, with related

a mendments in Chapters 121, 129 and 145. EPA approved

P ennsylvania’s CAIR SIP revision on December 10, 2009, codified

at 40 CFR § 52.2020(c)(1) (74 FR 65446). In the CAIR SIP revision, Pennsylvania terminated the NO X Budget Trading Program and transitioned to the federal CAIR for large electric generating units (EGU).

The market-based CAIR is designed to reduce EGU emissions of

NO X and SO 2 below 2002 levels throughout the eastern United States. Pennsylvania and the other CAIR states were required to

a dopt 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

NO X annual, NO X ozone season, and SO 2 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, modifi ed, 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.

NO X Budget Trading Program limits on non-EGUs. The CAIR

SIP revision also established emission limits for the non-EGUs and other units that were subject to the Commonwealth’s NO X Budget Trading Program but are not subject to the CAIR NO X Ozone Season Trading Program. These units must continue monitoring

NO X emissions and must meet an emissions cap. Each unit has an allowable emission rate, calculated by January 31 of each year,

ba sed on the previous ozone season’s heat input. If the combined

NO X 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 NO X ozone season allowance and one CAIR NO X annual allowance for each ton of emissions over its allowable limit. In addition, the Department has set aside 181 tons of NO X , including tons that will be retired each year to compensate for sources that were exempted

unde r 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 NO X ozone season emission limitation will be exceeded. Pennsylvania’s non-EGU

sources’ total emissions during each of the years they were trading

under the NO X Budget Trading Program never exceeded the statewide cap of 3,438 tons.

The Department’s regulation, codified in 25 Pa. Code § 145.8(d),

wa s approved by EPA as a SIP revision on December 10, 2009,

a nd 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 NO X SIP Call.- 27
- Until 2009, cement kilns and large stationary internal combustion engines that were subject to the NO X SIP Call were required to

surrender NO X SIP Call allowances if they exceeded their NO X emission limits set forth in Department regulations. Because the

De partment discontinued the NO X Budget Trading Program beginning 2009, at which point NO X SIP Call allowances were replaced by CAIR NO X ozone season allowances, the Department modified the regulations to require surrender of CAIR NO X ozone season and CAIR NO X 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 NO X 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

ad opted 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

De partment 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

c leaner 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 decreas es

c an be attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) andPennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established by the CAA Amendments of 1990 include NO X 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

Y ear (MY) 1998.

I n 1998, under the authority of section 177 of the CAA, the Department

a dopted 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

standa rds 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

N LEV 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

re gulations, and vehicle manufacturers operating under the NLEV program became subject to the Tier 2 requirements.

P ennsylvania 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

truc ks 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

Ve hicle Program as a revision to the Commonwealth’s SIP on January 24, 2012 (77 FR 3386).

Heavy- Du ty 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

y ear 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 we re more stringent than federal standards for the two model years between expiration of the consent decrees discussed above (MYs 2005 and 2006 ) and the implementation of more stringent federal standards 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

e missions from MY 2005 and 2006 highway engines.

The EPA adopted new emission standards for heavy-duty engines and

ve hicles for MY 2007 and subsequent. For diesel engines, the standards

were phased in from 2007 to 2010 for NO X and VOCs. For gasoline engines, the standards were phased in during MY 2008 and 2009. Federal and California standards were virtually identical for MY 2007. For

MY 2008, California adopted requirements for idling restriction engine programming and an option al “clean NO X idle” standard. However, there is no EPA-approved methodology to estimate emission reductions from this requirement. Therefore, the emission estimates use assumptions of

the f ederal 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

wa s a temporary compliance option allowing refiners to continue to produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until

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

F or 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

a pproved 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

emissi on 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) reduce d

the sulfur content of gasoline by up to 90 percent, enabling the use of new

emission control tech nologies 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, 20 14, 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

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

effectiveness of vehicle emission controls even further and reduce onroad emissions of 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

a crolein, benzene, formaldehyde and acetaldehyde. Emission reductions from the federal Tier 3 program have not been included in future year

inventor ies 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 PM 2 .5 NAAQS.

3

. Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel-powered ( “compression ignition”) and gasoline-powered (“spark ignition”) nonroad

e ngines 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

na tional 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

mar ine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur concentration as in highway fuel, 15 ppm; this requirement began

a pplying in 2012 to locomotive and marine diesel fuel. EPA adopted

tec hnical 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

ve ssels. This requirement does not impact the Allentown Area because

the Allento wn 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

a nd 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

e stimates statewide SO 2 emission reductions of approximately 25,000 tons

pe r 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 a dministratively 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

C onsumer Products program is codified in 25 Pa. Code Chapter 130,

Subc hapter 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 Pe nnsylvania

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

de signated Metropolitan Planning Organization (MPO) under federal transportation planning requirements.

In this Maintenance Plan, Pennsylvania establish es budgets for highway

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

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

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

vehicles.

Amendments to the 40 CFR part 93 transportation conformity regulations to

address the 2006 PM 2.5 standard were published in the Federal Register on March 24, 2010 (75 FR 14260), to account for PM 2.5 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

de terminations to be applicable to direct emissions of PM 2.5 and NO X (unless a determination is made that transportation-related emissions are not significant

contributors to PM 2.5 ), but to emissions of SO 2 , VOC, and NH 3 only if a finding is made that transportation-related emissions of these pollutants are significant

contributors to PM 2.5

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

Th is Maintenance Plan SIP revision establishes motor vehicle emission budgets

for PM 2.5 and NO X

. 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 PM 2.5 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

una nticipated growth in highway vehicles. The safety margins were created by setting aside a portion of the difference between attainment year and maintenance year emissions of PM 2.5 an d NO X

. Table III -3 shows that the amount of emission reductions anticipated between 2007 and 2017 and between 2007 and 2025 easily accommodates the safety margins granted.- 34
- Table III-3 : Comparison of Safety Margin to Total Anticipated

Emission Reductions in 2017 and 2025

Allentown Area Total Emissions PM 2.5 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, NH 3 , and SO 2 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, NH 3 , and SO 2 Emissions

to the Total Projected 2025 Inventory

2025 SO 2 VOC NH 3 On

- Road Mobile Source Projected Inventory (Tons) 47 2,410 174 Total Proj ected 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 PM 2.5 re -entrained road dust emissions from paved and unpaved roads in the area source inventory, not in the motor vehicle emission budgets. Appendix B-2 , relating to area source annual emissions, contains

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

The Freemansburg monitoring site located in Northampton County includes a moni tor that measures PM 2.5 mass and a speciation monitor that collects data on

the chemical constituents of PM 2.5 in the Allentown Area. Transportation construction-related fugitive dust emissions are not a significant contributor to the

PM 2.5 concentrations observed at the Allentown monitor . At the Allentown monitor, the crustal component was found to be small compared to other components of PM 2.5 (See, Figure 1 ). Given that construction-related fugitive dust is one of many source categories contributing to the crustal material observed at the monitor, and transportation construction is a small subset of all construction, it is reasonable to conclude that 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

P art 58 to verify the attainment status of the Allentown Area for the 2006 PM 2 .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 PM 2.5 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 (e very 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

c onsider 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

a nd appropriate, in the following circumstances:

A first level response will be prompted if the 98 th percentile 24-hour PM 2.5 concentration

exceeds 35.0 μg/m 3 in a single calendar year within the maintenance area or if the

pe riodic 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 dete rmine whether the PM 2.5 value indicates a trend toward higher PM 2 .5 values and whether emissions appear to be increasing. If there appears to be an increasing trend, the study will evaluate whether the trend is likely to continue and, if so, the necessary and

a ppropriate 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 98 th percentile 24-hour

PM 2.5 concentrations exceeds 35.0 μg/m 3 within the maintenance area. If this trigger point occurs, the Department will evaluate whether additional emission control measures

shoul d be implemented in order to prevent a violation of the air quality standard. The Department will analyze the conditions leading to the PM 2.5 levels and evaluate what measures might be most effective in correcting the PM 2.5 levels. The Department will

a lso 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

im plemented as expeditiously as practicable.

If a violation of the PM 2.5 NAAQS occurs, the Department will propose and adopt additional emission reduction measures, as necessary and appropriate, as expeditiously as practicable in accordance with the implementation schedule in this section, the CAA, the

P ennsylva nia Air Pollution Control Act, other Pennsylvania statutory requirements, and the Department’s Policy for Development, Approval and Availability of Regulations in

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

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

NA AQS 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

pr omulgation 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, 9 as

app ropriate.

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

W ithin 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.

W ithin 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 EQ B 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 Progr am 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-Atlanti c/ Northeast Visibility Union MARAMA Mid-Atlantic Regional Air Management Association

MOVES Motor Vehicle Emission Simulator MPO Metropolitan Planning Organization

MY Model Year NAAQS National Ambient Air Quality Standard NAICS North American Industry Classification System NEI National Emissions Inventory

NH 3 Ammonia NLEV National Low Emission Vehicle (program)- 40
-

NMIM National Mobile Inventory Model

NO X 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

PM 2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates

PM 10 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

SO 2 Sulfur Dioxide

TAF Terminal Area Forecast TCM Transportation Control Measures TSD Technical Support Document μg/m 3 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

wr itten 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

P articulate 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

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

onl y. 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 Wu rth ahw1@lehigh.edu

4. Claudia Steckel

423 N. 27th St. Allentown, PA 18104-4828

c steckel.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

a re “permanent and enforceable.” According to EPA [U.S. Environmental Protection Agency] data, the reductions are not permanent, since the 35 μg/m 3 has already been

e xceeded during 2013. Specifically, 98% of the relevant data points indicate that the Allentown area is only meeting a level of 37 μg/m 3

, n ot 35 μg/m 3 , which the National- 2
-

Am bient 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

NA AQS have not been attained and the improvements in air quality have not been

de monstrated 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/m 3 and the 2006 standard is 35 μg/m 3

. (1,2,3)

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

moni tors in the Allentown Area are well below the 2006 PM2.5 NAAQS of 35 μg/m 3

. Based on 2011-2013 PM2.5 concentrations, the design values for the Freemansburg and Lehigh Valley monitoring stations are 32 and 30 μg/m 3

, 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

sit e-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

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

moni tor, the collocated values are averaged.

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

F reemansburg (AIRS # 42 -095 -0025 ) monitor, and the Lehigh Valley monitoring site (A IRS # 42 -095 -0027). The Freemansburg site consistently measur es 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

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

de signated 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, w ith- 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 sho rt -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

c oncentration 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.

The refore, 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/m 3

, when EPA data indicates that it is 12.4 μg/m 3 , 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 commentato rs ’ characterization of concentration trends. As Figures I-2 and I-3 indicate, there is a

g eneral trend of concentration decreases in the 24-hour design value. Furthermore, the 2013 annual design value (2011-2013 data) is 12.2 μg/m 3 , 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 Reque st 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

o n 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/m 3 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

de sign value of the 24-hour standard of 16%. The report wrongly characterizes the

de sign value as 37 μg/m 3 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/m 3

. Even if we assume that the design value for the 2010-2012 period is 32, which is incorrect based on the EPA

da ta cited in Comment 2 above, the relevant drop in PM2.5 concentrations between

2006 -2008 and 2010-2012 is 4 μg/m 3

. 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/m 3 a nnual average for 2012 (which is based on EPA

da ta 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)

Re sponse: 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/m 3 . B oth 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 c ommentators’ 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/m 3

, a further decrease in PM2.5 design value for the area. The 2006 24-hour PM2.5 NAAQS

of 35 μg/m 3 has 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/m 3 in 20 12, 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/m 3

, not 32 μg/m 3

, as the report currently proposes

in Table I-4. While this still puts the 2010-2012 period beneath the 35 μg/m 3 s tandard,

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

C omment 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/m 3 less 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

mea n 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

nona ttainment designation resulting from the 2006-2008 data, it would be more pertinent

to re veal 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

P M2.5 levels in the Lehigh Valley that are well captured in the Freemansburg monitoring

da ta EPA has posted, which are concealed by errors in the present report. (1,2,3)

Re sponse: 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

inst ance, 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

c laims 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

P M2.5 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 ti me 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 an alysis 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

indi cators 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

ti me period in question. The depiction of increasing longer-term trends from 1990 and

1979 r espectively, 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

e conomic “coincident” index and Allentown labor force barely increased. This

c omparison 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

c onduct 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

De partment 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 t he efficacy of the permanent and enforceable measures described in Section III(C) of

the Rede signation Request (relating to Control Measures). It is clear from the analysis of

tre nds between 2005 and 2007 that the emissions contributing to PM2.5 levels have

decreased. (The Department did not use 2009 as an analysis year fo r 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 emis sions 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.

S ection 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)

Re sponse: 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

pr esent 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 A llentown 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 pa ge 16, the discussion of PM2.5 states that Monitor 42 -095 -0027, which is located at the Lehigh Valley Hospital (Muhlenburg) i n Lehigh County, should be influenced by mobile sources of air pollution coming from Rt. 22 and Rt. 378 and airport emissions

fr om the LV International Airport. This monitor is located south of Rt. 22, east of

R t. 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

pr evailing winds run from the southwest to the northeast, then the only mobile sources of poll ution 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

moni tor 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)

Re sponse: 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

he alth protection and better inform the public about air quality in their communities.”

Unde r 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 pe riods 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 pa ge 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 i n 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

moni tor 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

pr ovided 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

c oncentration” Appendix D Objective. If DEP is supposed to locate a second monitor in

a reas of high PM2.5 concentrations (i.e. poor air quality as stated on page 16), then it

shoul d 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

a ir 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

sit e

– 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

sit ed 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 wa s 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

P arts 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 hig hest concentration (Freemansburg) in making its determination of clean data and

a ttainment. 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:

Ac co rding 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

a pproximately .3 miles, or more than 450 meters from the monitor. If a roadway with an

a verage daily traffic volume of 83000 (i.e. Rt. 22) is more than 450 meters from the

moni tor, 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

b y doing mic ro -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

Be thl ehem, PA, or in a similarly situated area of Allentown. Monitoring in these areas

would li kely demonstrate one important reason why the citizens of the immediate

re sidential communities have high levels of asthma and other respiratory disorders associated with exposure to PM2.5 pollution. These levels would have higher PM2.5

mea surements 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 poli cy 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 st ates 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

R oad 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,

c an 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

da ta 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

c ontribution 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

moni tor to reflect what’s happening within City limits. (4)

Response: See response to comment 8

. The Department tailors its monitoring program

to m eet applicable federal requirements and annually evaluates the adequacy of the

ne twork 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

leve ls, within the City itself (the “City proper”), during the timeline used to support

a ttainment for Allentown is not knowable as evidenced by what has been dubbed, the “Freemansburg Problem.” Allentown is bounded by major traffic corridors (222 bypass;

route s 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

fr om auto exhaust) may be significantly higher, locally (i.e., within City limits) than

moni tors 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

a ctivities proximal to the monitor which may put citizens of that region at risk, health-wise, and that such activities (1) have been occurring (A rena/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

im pact 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 impac t 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

C oncern), lead, pigeon excreta, and unknown hazardous waste. Some of these

c ontaminants are known sources of PM2.5. How can the City, without its own monitor to

de tect 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.

T he 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.

S imilar requirements are placed on non-transportation federal ly 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 L ehigh 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.”

W ithout 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

loca tion 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

a ttainment, 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

loca tions 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 c ommentator’s breathing difficulties return immediately after emerging from the south side of the Lehigh Tunnel. The commentator states that she cannot prove that her

br eathing 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

c omments 8 and 1 1 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 NO X , the Maintenance Plan shows that the highway vehicle emissions of direct PM2.5, NO X 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

pr imarily 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 NO X VOC

2007 536 15,857 6,936

2017 297 8,081 3,791

2025 234 5,303 2,410COMMONWEALTH OF PENNSYLVANIA
STD-521 REV 06-2010 

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### 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

MEDIA GROUP

PO Box 415459 Boston, MA 02241-5459 adbilling®tribune.com 866-536-2721

DEPT OF ENVIRO PRO HARRISBURG

Alex Haas

400 MARKET ST
BUREAU OF AIR QUALITY FL 12 PO BOX 8468 HARRISBURG, PA 17101 Legal Invoice and Summary

Billed Account# Client Account#
Invoice#

Client Name

Billing Period

Due Date CU00162831

001260509

03/31/14

- 04/06/14

05/06/14

TOTAL AMOUNT DUE 1,357.90



### 00016283100016283108001260509 00135790 00135790 8

To ensure proper credit, please detach and return with remittance.

04/02/14 ALTM011118

Classified Listings, Online Proposed State Implementation Plan Revis
ALTSII0-201404-79011

04/04/14 ALTM011267 2278971

PO#AD#: 81466

Classified Listings, Online LEGAL NOTICE@

ALTSII0-201404-81466

2286263

Total Current Advertising

Department 

### of

Environmental Protection



### APR 1 5 2014

Air Resource Management
Division

Billed Period

03/31/14-04/06/14 Billed Account#

CU00162831

. Billed Account Name

DEPT OF ENVIRO PRO HARRISBURG Client Account#

THE
MORNING 

### themorningcall.com
CALL 

## careerbuildercom

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,, 740.04

617.86 617.86

1,357.90

Client Account Name

Page 1/1

### ~~HomeFinder**~TIUBliNE -~r**  .corn**<,;;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 Nation al Ambient Air Quality Standard; Public Hearing

[44 Pa.B. 2136] [Saturday, April 5, 2014]

Particulate matter (PM) include s both solid and liquid particles suspended in the air. Fine particle pollution describes partic ulate matter that is less than or equal to 2.5 micrometers in diameter (PM 2.5 ). PM 2.5 concentrations above the Federa l 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 PM 2.5 National Ambient Air

Quality Standard (NAAQS). Therefore, th e 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 se ction 172(c)(3) of the Federal Clean Air Act (CAA) (42 U.S.C.A. § 7502(c)(3)) and a maintenance plan demonstrating that th e area can maintain

the 2006 24-hour PM 2.5 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 mo tor vehicle emission budge ts for transportation conformity purposes.

The request to redesignate the area to at tainment and the proposed SIP revision are available on the Department's web site at w ww.dep.state.pa.us (choose ''Air,'' then ''Bureau of Air Quality,'' then ''Regs/Plan,'' then ''Clean Air Plans'') or thr ough 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 Re gional Office, 2 Public Square, Susquehanna Room A, Wilkes-Barre, PA 18701-1915. Persons wishing to present testimony at the hearing should contact Al ex 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 pe rson 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/deputat e/airwaste/aq/default.htm if the hearing is cancelled. Page 1 of 2 PA Bulletin, Doc. No. 1 4 -71 9

8 / 22 / 201 4 htt p ://www. p abulletin.com/secure/data/vol44/4 4 -14/719.htm lPersons may also contact the Department to find out if th e hearing is cancelled by contacting Alex Haas.

Persons with a disabili ty who wish to attend the heari ng and require an auxiliary aid, service or other accommodation to participate in the proceed ing should contact Alex Haas. TDD users may contact the Pe nnsylvania AT&T Relay Servi ce 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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