pennsyLvania 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

SECRETARY 

July 22, 2013 

Mr. Shawn Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street (Mail Code: 3RAOO) 

Philadelphia, PA 19103-2029 

Dear Mr. Garvin: 

Enclosed for your approval is a revision to the Pennsylvania State Implementation Plan (SIP) to 

update the Motor Vehicle Emissions Budgets (MVEBs) in the "Maintenance Plan and Base Year 

Inventory for the Reading Eight-Hour Ozone Nonattainment Area" (Maintenance Plan). The 

Maintenance Plan was developed according to Section 175A(b) of the Clean Air Act 

(42 U.S.CA §7505a(b». This Maintenance Plan revision was also developed in accordance 

with the U.S. Environmental Protection Agency's (EPA) April 2012 guidance document titled, 

"Policy Guidance on the Use of MOVES20 1 0 and Subsequent Minor Revisions for State 

Implementation Plan Development,Transportation Conformity, and Other Purposes." The 

Pennsylvania Department of Environmental Protection (DEP) requests that the EPA use the 

direct final rulemaking process to expedite the approval of this non-controversial SIP revision. 

The Commonwealth has completed its public participation process for this SIP revision. DEP 

scheduled a public hearing to occur on the final day of the 30-day public comment period, which 

ended April 30, 2013, but no persons expressed interest in presenting testimony or attending. 

Therefore, DEP cancelled the hearing. DEP received no comments on the proposed SIP 

revision. After the public comment period closed, DEP made minor corrections to some tables 

in the proposed Maintenance Plan revision. These changes did not affect the final conclusion of 

the revision. 

The following documents are enclosed for your approval: 

1. The Maintenance Plan revision, which includes an MVEB for the purposes of 

transportation conformity; 

2. Certification of public participation activities; 

3. A technical support document for the Maintenance Plan revision; and 

4. Appendix C, "Technical Support Document, Mobile Source Highway Emissions 

Inventory," which replaces the Appendix C of the same title in the approved Maintenance 

Plan. 

A paper copy and a disk containing a searchable PDF copy of the revised Maintenance Plan are 

enclosed. I certify that the electronic file is an exact duplicate of the hard copy. 

- Rachel Carson State Office Building I P.O. Box-;Z063-IHarrisburg, PA 1710')C2063 -��

-

717.787.2814 (}J. Prirlted on Recycled Paper QS(9 www.depweb.state.pa.us 
Mr. Shawn Garvin - 2- July 22, 2013 

On August 24,2007, the EPA approved the Commonwealth's request for redesignation as 

attaimnent for the Reading Area and all of the components of the Maintenance Plan, which 

included MVEBs for 2009 and 2018 (72 FR 48559). 

As you know, the EPA updated the model that estimates highway vehicle emissions. The new 

model, the Motor Vehicle Emissions Simulator (MOVES), better estimates emissions from 

highway vehicles, but MOVES estimates much higher emissions of oxides of nitrogen, than the 

Mobile6.2 model used to derive the MVEBs in the approved Reading Maintenance Plan. The 

Berks County Planning Commission (BCPC), which is responsible for transportation plauning in 

Berks County, uses those approved MVEBs to satisfy transportation conformity requirements .. 

The BCPC is required to use the most up-to-date version of MOVES for all new transportation 

plauning that begins after March 2, 2013. Approval of the updated MVEBs in the 

Commonwealth's SIP will allow BCPC to compare similarly generated emissions used in its 

plans and the MVEBs, which will allow transportation projects to go forward in a timely mauner. 

If you have any questions or need additional information, please contact Joyce E. Epps, Director 

of the Bureau of Air Quality, by email at jeepps@pa.gov or by telephone at 717.787.9702. 

Sincerely, 

E. Christopher Abruzzo 

Acting Secretary 

Enclosures 
COMMONVVEALTH OF PENNSYLVANIA 

STD-521 REV. 06·2010 

PUBLICATIONS AUTHORIZATION AND INVOICE 

PUBLICATIONS AUTHORIZATION (To be completed by agency): 

INVOICE NO. 

TO; (NAME AND ADD~ESS OF NEWSPAPER) ! FEDERAL LD. NOJSOC. SEC. NO, FROM: (NAME AND ADDRESS OF AGENCY) AGENCY ! TELEPHONE NO. 

Reading Eagle ; 24-0676050 Alex Haas , 717-787-9495 

PO Box 582 DEP - Bureau of Air Quality 

Reading, PA 19603-0582 400 Market Street 

H;::"rrj,;;hi 1m PA 17101 

HEREWITH IS ENCLOSED COPY FOR PUBLICATION OF ADVERTISEMENT FOR PROPOSALS TO 

r,', EMPLOY j: PURCHASE I; CONTRACT r SELL I 

TYPE OF ADr. 

CLJ\SSIFIED rx LEGAL NOTICE 

PUBLISH ADVERTISEMENT (NO. OF TIMES) I MAXIMUM NO. OF LINES DATE 

1 x Only March 20, 2013 

I ORDER NO. 

DATES OF INSERTION SIGNKr. '.: U.,RE FOR AG.!=-NQ\ f 

No Later Than Saturday, March 30,2013 :£ 'J. (.'i::. ~/ {/6 

You, as vendor, are authorized to publish this advertisement in your newspaper, subject to the terms of this order, as follows: 

Advertisement to be published in regular advertising columns, no position specified; caption of two lines and signature to be in 

capitals and subject matter and title of officer to be set solid in type regularly used by your newspaper for public (legal) notice 

advertising; charge to be made at the rate charged to and paid by commercial advertisers for matter similarly set and occupying 

similar space; advertisement to be run in the editions specified above. Vendor agrees that, in the performance of any contract 

awarded to it hereunder, said vendor will not discriminate against any employee or other persons on account of race, color, sex, 

religious creed, ancestry, age or national origin and that the Commonwealth, upon receipt of satisfactory evidence of such discrimination, shall have the right to cancel said contract. Return this copy at once if you will not accept this advertisement under 

the terms set forth. 

Return original and two copies (signed by the editor or publisher) to the agency listed above. Proof of advertising 

in the form of a tear sheet must be stapled to original and copies, Original must be notarized. 

Commonwealth to be billed only for actual number of printed lines published. 

SAP FUND COST CENTER GENERAL LEDGER ACCOUNT CODE % 

)jif 7c)7'2,1) U - \'1 L 'I ( ! \ (,(/(.,(' CD ,j; 

" i "'_ 

C( ) !) )<X Ii (( {'e (:{ I,e . ',LI j.J.( ( 

INVOICE (To be completed by publisher)' 

DATE OF INSERTION ACTUAL NO. OF PRINTED LINES COST PER LINE TOTAL AMOUNT 

1stAd 3/30/13 107 1. 65 , 

341.i55 

2nd Ad I 

3rd Ad 1U L luaVl Lunar, e " .!UU 

Bold Charge 2.:00 I 

GRAND TOTAL-+ $348.!55 

Commonwealth of Pennsylvania 

County of Berks 

Before me, the subscriber, a Notary Public in and for said County, personally came Lynn Schittler 

who being duly sworn, doth depose and say that he is' .,..-c--:-_A.,-s_s_i_s_t_a_n"t,--:-,S."e.,-c.,-r-e-t-a-r"-y---------------

the Reading Eagle a general newspaper published at -::-:-R...,e-,-a_d.,-i_n"'g'------:-_-.,-_-,--, __ :-__ :--:-: ____ _ 

that the advertisement, of which tearsheet is attached hereto, was published in the regular advertising columns of said newspaper, 

in the editions of said newspaper, in all respects as ordered and invoiced above; and that the Commonwealth is not charged 

therefor at a rate higher than is charged any ordinary advertiser for a similar amount of matter occupying similar space and set in a 

similar matter, in said newspaper. U 

/ .' / 

yl;'. ,!. -', 

j }CP}C",,/!. ) SIGNATURE OF AFFIANT 

COMMONWEALTH Of PENNSYLVANIA 

My commission expires 

*This affidavit must be made by the Owner, Publisher, or the designated agent of the owner or publisher. 

NOTARIAL SEAL 

ANN L. LIPTAK, NOTARY PU8UC 

CITY OF READING, BERKS COUNTY 

MY COMMISSION EXPIRES OCT. 2. 2018 
R e "oI.~:> ["J) C! 

Maret.. ~o ZO)s I 

Proposed Revision I 

tt> the 5tateImplementation Plan 

to Update the Motor 

Vehicle Emissions 

BUdJlets in the Reading Elght~Hour Ozone 

Maintenance Area; 

Public Hearing 

The PA Department of 

Environmental Protection (Department) is re- vising the Motor Vehkle 

Emissions Budgets 

(MVERs) for the Reading 

Area Eight-Hour OZone 

Maintenance Area, The 

reVised budgets, once approved br the U.S. Environmenta Protection 

Agency (EPA), will expedite future transporta- tJ.~·n planning for the 

Re ding Area. The Depari' ment wj{[ submitthis, to the EPA as a frnal 

revi.j;ion to the State (mpterhentation Plan, The 

EPA developed a new 

computer model, the 

Motor Vehicle Emissions 

Simulator (MOVES) that 

eS:ttmat~s emissions: from 

highway vehicles more accurately. The approved maintenance 

pfan for the Reading 

Area used the former 

EPA-approved model, 

Mobile6, for estimating 

highway vehicle emissions:. Emissions of ox- ides of nitrogen are est/-> 

mated to be at higher 

levels by the new model 

than what was approved 

in the original mainte- nance plan. The Trans:-

portation Conformity 

I regulation requires that 

emissions from updated 

focal transportation improvement plans do not 

exceed the MVEBs in the 

area's approved, applicable SIP. By using similar 

modeling in transportation planning and the 

SIP, a more realistic comparison between the 

two will result with less 

chance of transportation 

projects being delayed. 

1 This proposal is available on the Department's 

website at , www.depweb.state.pa.us 

(choose "Air Plans") or through the contact persons listed. 

The Department is seeking public comment on this SIP revision and 

changes made to the 

motor vehicle emissions 

budget in the 1997 

Eight-Hour Ozone Maintenance Plan for the 

Reading Area. The Department will hold a public hearing to receive 

comments on the proposal on Tuesday, April 

3:0, 10:00 a.m. in Room 

Susquehanna A at the 

Department's South 

Central Regional Office, 

909 Elmerton Avenue, 

Harrisburg, PA 17110. 

Persons wishing to present testimony at the 

hearing should, contact 

Alex Haas, P.O. Box 

8468, Harrisburg, PA 

17105, (717) 787-9495 or 

aiehaas@pa.govto re- serve a time. If, by April 

25, no person has- ex- pressed an interest in 

testifying at the hearing, 

the he-aring will be cancelled. The Department 

will notify the publk if 

the hearing is cancelled 

on the Bureau of Air 

Quality webpage, http:// 

www.dep.state.pa.uslde 

p/deputate/airwaste/agl 

default.htm. Witnesses 

should keep testimony 

to ten minutes and 

should provide two written copies of their statement at the hearing. 

Persons with a disability 

who wish to attend the 

hearing and require an auxiliary aid, service or other accommodation to 

participate in the pro~ 

ceeding should contact 

Alex Haas at (717) 787-

9495 or alehaas@p-a.gov. 

TDD users- may contact 

the AT&T Relay servi"ce 

at (800) 654-5984 to dis- (USS how the Depart~ 

ment can best accommo~ 

date their needs. 

The Department must 

receive comments no later than April 30. Written 

comments should be 

sent to the attention of 

Chris Trostle, Mobile 

Sources Section Chief, 

Bureau of Air Quality, 

P.O. Box 8468, Harrisburg, PA 17105-8468, or dtrostle@pa.gov. Use 

"Reading MVEB Revision" as the subject line In written communication. 

MICHAEL L. KRANCER, 

Secretary 
Reading Eagle Company 

P. O. Box 582 

READING, PA 19603-0582 

ADVERTISING INVOICE 1 STATEMENT 

(610) 371-5167 

INVOICE NO 

100327901-03302013 

BILL DATE BILL FROM BILL TO TERMS OF PAYMENT PAGE 

• 

• 

ORDER NO 

03/30/13 0000327901 

03/30113 03124/13 03130/13 

DEPT OF ENVIRONMENTAL PROT.-BAO 

ALEX HAAS 

400 MARKET STREET 

HARRISBURG, PA 17105 

DESCRIPTION 

PROPOSEDREVISIONTOTHESTATEIMPLEMENTA TION 

Bold Text Charge 

AffidavitMaterial 

Proposed Revision to the State Implementation Plan 

to Update the Motor Vehicle Emissions Budgets in the 

Reading Eight-Hour Ozone Maintenance Area; Public 

Hearing The PA Department of Environmental 

Protection (Department) is revising the Motor Vehicle 

Emissions Budgets (MVEBs) for the Reading Area 

Eight-Hour Ozone Maintenance Area. The revised 

Net Due 30 Days Page 1 of 1 

SALES REPRESENTATIVE 

Carol Hitchens 

BILLED ACCOUNT NO VENDOR NO 

301848 301848 

ADVERTISER 

DEPT OF ENVIRONMENTAL PROT.-BAO 

em"M 

207 

AMOUNT 

Amount Due: 

$341.55 

$2.00 

$5.00 

$348.55 

TearHe~ ________________________________________ . ____________________________________________________ _ 

BILLED ACCOUNT NO 

301848 

INVOICE NO 

100327901-03302013 

*'" Legal ** 

BILLED ACCOUNT 

DEPT OF ENVIRONMENTAL PROT.-BAO 

BILL DATE 

0313012013 

MAKE CHECK PAYABLE TO: 

READING EAGLE COMPANY 

P.O. BOX 582 

READING, PA 19603-0582 

ADVERTISING INVOICE 1 STATEMENT 

$348.55 Amount Enclosed: _____ _ 

REMITTANCE - DETACH & RETURN THIS PORTION WITH YOUR PAYMENT 
Chris Abruzzo Tom Corbett

Acting Secretary Governor

Commonwealth of Pennsylvania 

Final

Volume I

State Implementation Plan Revision: NOx Motor 

Vehicle Emission Budget Revisions Based on the 

MOVES2010a Model

Reading Eight-Hour Ozone Maintenance Area

for the 1997 Ozone

National Ambient Air Quality Standard

July 2013

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495
This page is intentionally left blank.
i

Table of Contents

VOLUME I

1. INTRODUCTION AND OVERVIEW OF GROUND-LEVEL OZONE...........................................................1

1.1. 1997 8-HOUR OZONE NATIONAL AMBIENT AIR QUALITY STANDARDS 1

1.2. READING AREA AND OZONE SIP REVISIONS 2

1.3. EPA REQUIREMENTS FOR DEVELOPING AND REVISING MAINTENANCE PLANS 3

Table 1: Reading Area 2012 Design Values.........................................................................................................5

1.4. MAINTENANCE PLAN DEMONSTRATION AND MOTOR VEHICLE EMISSIONS BUDGETS 6

Table 2: Motor Vehicle Emissions Budgets..........................................................................................................6

1.5. NON-MOBILE INVENTORY REVIEW 7

Table 3: Revised Reading Area NOx Emissions from 2004 to 2018.....................................................................8

2. SOURCE CATEGORY EMISSIONS ...................................................................................................................9

2.1. POINT SOURCE CATEGORY EMISSIONS 9

2.1.1. Control Measures........................................................................................................................................9

2.1.2. Growth Estimates in the Reading Ozone Maintenance Plan ......................................................................9

2.1.3. Point Source Category Conclusion...........................................................................................................10

Table 4: 2009 Point Source Emissions – Maintenance Plan Estimates Versus Actual ......................................10

Table 5: 2018 Point Source Emissions – Maintenance Plan Estimates Versus Revised 2018 Emissions ..........11

2.2. AREA SOURCE CATEGORY EMISSIONS 11

2.2.1. Control Measures......................................................................................................................................11

2.2.2. Growth Estimates in the Reading Ozone Maintenance Plan ....................................................................11

Table 6: Comparison of Growth Factors Used in Maintenance Plan and Inventory Updates (2002 to 2009) ..12

Table 7: Comparison of Growth Factors Used in Maintenance Plan and Inventory Updates (2009 to 2018) 123

2.2.3. Growth Estimates in MARAMA 2011 Regional Modeling Effort..............................................................13

2.2.4. Marcellus Shale Emissions .......................................................................................................................13

2.2.5. Area Source Category Conclusion............................................................................................................14

2.3. NONROAD SOURCE CATEGORY EMISSIONS 14

2.3.1. Control Measures......................................................................................................................................14

2.3.2. Growth Estimates......................................................................................................................................14

2.3.3. Nonroad Source Category Conclusion .....................................................................................................15

2.4. HIGHWAY SOURCE CATEGORY EMISSIONS 15

2.4.1. Control Measures......................................................................................................................................15

2.4.2. Growth Estimates......................................................................................................................................16

Table 8: Revised Motor Vehicle Emissions Using MOVES2010a ......................................................................16

2.4.2. Mobile Source Category Conclusion ........................................................................................................16

3. SAFETY MARGINS .............................................................................................................................................17

4. MOTOR VEHICLE EMISSION BUDGET FOR TRANSPORTATION CONFORMITY...........................17

Table 9: Motor Vehicle Emissions Budgets........................................................................................................17

5. CONCLUSION ......................................................................................................................................................18
ii

VOLUME II

1. TECHNICAL SUPPORT DOCUMENT – SEE VOLUME II TABLE OF CONTENTS

TABLES

TABLE 1: READING AREA 2012 DESIGN VALUES 5

TABLE 2: MOTOR VEHICLE EMISSIONS BUDGETS 6

TABLE 3: REVISED READING AREA NOX EMISSIONS FROM 2004 TO 2018 8

TABLE 4: 2009 POINT SOURCE EMISSIONS – MAINTENANCE PLAN ESTIMATES VERSUS ACTUAL 10

TABLE 5: 2018 POINT SOURCE EMISSIONS – MAINTENANCE PLAN ESTIMATES VERSUS REVISED 2018 EMISSIONS

11

TABLE 6: COMPARISON OF GROWTH FACTORS USED IN MAINTENANCE PLAN AND INVENTORY UPDATES

(2002 TO 2009) 12

TABLE 7: COMPARISON OF GROWTH FACTORS USED IN MAINTENANCE PLAN AND INVENTORY UPDATES

(2009 TO 2018) 13

TABLE 8: REVISED MOTOR VEHICLE EMISSIONS USING MOVES2010A 16

TABLE 9: MOTOR VEHICLE EMISSIONS BUDGETS 17

APPENDICES

1. APPENDIX C: MAINTENANCE PLAN UPDATE FOR THE READING (BERKS COUNTY) EIGHT-HOUR MAINTENANCE

AREA: MOTOR VEHICLE EMISSION BUDGET REVISIONS USING MOVES2010A – SEE APPENDIX C TABLE OF

CONTENTS
1

1. Introduction and Overview of Ground-Level Ozone

Maintaining concentrations of ground-level ozone below the health-based 8-hour ozone national 

ambient air quality standards (NAAQS) is important because ozone is a serious human health 

threat and can cause damage to important food crops, forests, and wildlife.

Repeated exposure to ozone pollution may cause a variety of adverse health effects for both 

healthy people and those with existing conditions including: difficulty breathing, chest pains, 

coughing, nausea, throat irritation, and congestion. Ozone exposure can exacerbate bronchitis, 

heart disease, emphysema, and asthma, and reduce lung capacity. Asthma is a significant and 

growing threat to children and adults. Ozone can aggravate asthma, causing more asthma 

attacks, increased use of medication, more medical treatment and more frequent visits to hospital 

emergency clinics. Because ozone pollution usually forms in hot weather, anyone who spends 

time outdoors in the summer may be affected, particularly children, the elderly, outdoor workers 

and people exercising. Children are most at risk from exposure to ozone because they are active 

outside during the summertime when ozone levels are highest.

Ozone is one of the most pervasive and detrimental pollutants known to affect vegetation, 

causing more injury to trees and crops than any other air pollutant in the United States. Ozone 

interferes with photosynthesis, the process by which plants convert water and sunlight to food. 

Ozone makes plants more susceptible to disease, insects, other pollutants and harsh weather. It 

damages the foliage of trees and other plants, ruining the landscapes of cities, parks, forests, and 

recreation areas. Research has shown that current ozone concentrations result in reductions in 

wood growth of over 10 percent in forests of the Northeast United States. There is strong 

scientific evidence showing that current levels of ozone are reducing crop yields, particularly in 

sensitive species such as soybean, cotton, and peanuts. Annual crop loss alone from ozoneaffected soybeans in Illinois, Indiana and Ohio has been calculated to fall between $199 million 

and $346 million. The U.S. Environmental Protection Agency (EPA) has estimated national 

crop yield losses due to ozone in excess of $1 billion annually. One of the key components of 

ozone, oxides of nitrogen, contributes to fish kills and algae blooms in sensitive waterways, such 

as the Chesapeake Bay.

Ozone is not emitted directly to the atmosphere, but is formed by photochemical reactions 

between volatile organic compounds (VOCs) and oxides of nitrogen (NOX) in the presence of 

sunlight. The long, hot, humid days of summer are particularly conducive to ozone formation, so 

ozone levels are of concern primarily during the months of May through September. The 

primary sources of man-made VOCs and NOX, the ozone precursors, are the evaporation of fuels 

and solvents (gasoline and consumer products), combustion of fuels (motor vehicles, power 

plants and non-road engines), and industrial processes.

1.1. 1997 8-Hour Ozone National Ambient Air Quality Standards

In July 1997, the EPA established identical primary and secondary 8-hour ozone NAAQS at a 

concentration of 0.08 parts per million (ppm), based on the 3-year average of the annual fourthhighest daily maximum 8-hour average ozone concentrations measured in the ambient air at each 

monitored location. Implementation of the standards was delayed due to litigation. In April 
2

2004, EPA designated the Reading Area, which consists of all of Berks County, as 

nonattainment for the 1997 8-hour ozone standard, based on ambient air quality monitoring data

collected from 2001-2003. See 69 FR 23858 (April 30, 2004). The Reading Area was one of 

seventeen areas in Pennsylvania designated as an 8-hour ozone nonattainment area for the 1997 

ozone NAAQS.

On March 12, 2008, the EPA revised the NAAQS for ozone to 0.075 ppm averaged over 8 hours 

to provide even greater protection for children, other at-risk populations and the environment 

against the array of ozone-induced adverse health and welfare effects. See 73 FR 16436 

(March 27, 2008). The EPA had begun a voluntary reconsideration of the 2008 ozone NAAQS 

in January 2010 to set a more protective 8-hour ozone standard (75 FR 2938), but withdrew that 

reconsideration at the request of the President of the United States on September 2, 2011, leaving 

the 2008 ozone standard in place. On May 21, 2012, the EPA published a final rule for the 2008 

8-hour ozone NAAQS, implementing the nonattainment area classification approach and

attainment deadlines, and revoking the 1997 ozone NAAQS for the purpose of transportation 

conformity (77 FR 30160). The EPA has stated that it will promulgate an additional 

implementation rule for the 2008 ozone NAAQS to address State Implementation Plan (SIP)

requirements and other issues.

States will need to submit SIP revisions to demonstrate how they will bring the nonattainment 

areas into attainment of the 2008 ozone NAAQS. Nevertheless, the promulgation of the new 

ozone standard does not affect the need for this revision to the approved maintenance plan for the 

Reading Area (Reading Ozone Maintenance Plan) under the 1997 ozone NAAQS.

1.2. Reading Area and Ozone SIP Revisions

On January 25, 2007, the Department submitted a SIP revision to the EPA requesting 

redesignation of the Reading Area to attainment of the 1997 ozone NAAQS. The Department

concurrently submitted a SIP revision (2007 Reading SIP revision) to the EPA that included a 

maintenance plan based on the attainment and continued long-term attainment of the 1997 ozone 

NAAQS for the Reading Area (Reading Ozone Maintenance Plan), the 2002 baseline inventory, 

and motor vehicle emission budgets (MVEBs) to be used for purposes of transportation 

conformity. The EPA’s transportation conformity regulation, found at 40 CFR Part 93, 

Subpart A, requires that the transportation plan, transportation improvement program (TIP), and 

projects not from a conforming transportation plan and TIP must be consistent with the MVEBs

in the applicable air quality SIP. This criterion is satisfied if the state can demonstrate that 

emissions of the pollutants or pollutant precursors for which the area is in nonattainment or 

maintenance, and for which the applicable SIP contains MVEBs approved or deemed adequate 

by the EPA, are less than or equal to the MVEBs established in the applicable SIP or SIP 

submission. The metropolitan planning organization for the area, the Berks County Planning 

Commission, ensures that emissions resulting from its TIP are less than the MVEBs in the SIP

by completing periodic conformity determinations, which are subject to public comment. The 

EPA approved all of the components of the 2007 Reading SIP revision, including the MVEBs,

on August 24, 2007 (72 FR 48559), and redesignated the Reading Area to attainment.

The approved MVEBs included in the approved Reading Ozone Maintenance Plan were 

estimated using the EPA-approved highway emissions model in effect at that time, the Highway 
3

Mobile Source Emission Factor Model version 6.2 (Mobile6.2). The MVEB in the Reading

Ozone Maintenance Plan included emission budgets for both NOX and VOC. On March 2, 2010, 

the EPA released a new mobile source emissions model called the Motor Vehicle Emission 

Simulator 2010 (MOVES2010). The EPA provided a two-year grace period to transportation 

planning organizations, ending March 2, 2012, during which the older Mobile6.2 emissions 

model could be used to model emissions for transportation projects in order to meet the 

requirements of transportation conformity (75 FR 9411 (March 2, 2010)). In September 2010, 

EPA approved a revised version of the MOVES2010 model (MOVES2010a). On 

October 13, 2011, the EPA proposed a one-year extension to the two-year grace period because 

states and localities needed more time to transition to using MOVES2010a and to develop the 

technical capacity to use MOVES2010a (76 FR 63575). The EPA finalized the extension on 

February 27, 2012 (77 FR 11394). The extension allows states and localities to better evaluate 

whether SIPs and MVEBs, or transportation plans and TIPs, should be revised for future 

conformity determinations. The 1-year extension provides additional time that may be critical 

for nonattainment and maintenance areas to learn and apply MOVES2010a for regional 

conformity analyses. Any new transportation conformity analysis started after March 2, 2013,

must use the most up-to-date version of MOVES.

EPA issued the MOVES2010b version of the model and its associated guidance in April 2012. 

EPA considers both MOVES2010a and MOVES2010b to be minor revisions to MOVES2010 

that do not significantly affect the results of modeling criteria pollutant estimates for highway 

vehicles. References to “MOVES” in the remainder of this document relate to all of the 

approved versions of the model. The highway vehicle emissions modeling for this final SIP 

revision was already developed significantly using MOVES2010a. By the time that version 

2010b was issued, using MOVES2010b would have been impractical.

Compared to Mobile6.2, the MOVES model estimates higher NOX emissions and, in some areas,

higher VOC emissions being produced by highway vehicles, depending on the model inputs for a 

specific area. Emissions of NOX estimated using MOVES will always be greater for 

transportation planning than the NOX emissions accounted for in the MVEBs estimated using

Mobile6.2. As a result, comparing emissions from the MOVES model to the MVEBs included 

in the currently approved maintenance plan would not allow local and regional transportation 

planning agencies to meet the requirements of transportation conformity; the emissions budget in 

the maintenance plan would be exceeded and transportation planning could be adversely 

affected. This is why the Department is updating the MVEBs for the Reading Area using the

EPA-approved emissions model, MOVES2010a.

It is important to mention that higher emission estimates calculated by MOVES2010a do not 

mean that emissions from vehicles dramatically increased. The MOVES model better estimates 

emissions that are already being produced by vehicles. Consequently, the ability of the area to 

maintain the standard will not be affected by using estimates produced by the new model.

1.3. EPA Requirements for Developing and Revising Maintenance Plans

The 2007 Reading SIP revision redesignation request is consistent with the September 4, 1992,

EPA memorandum written by John Calcagni, Director, Air Quality Management Division, 

entitled, Procedures for Processing Requests to Redesignate Areas to Attainment. For the 
4

Reading Ozone Maintenance Plan, the Department produced an emissions inventory for NOX, 

VOC, and carbon monoxide (CO) for 2004, the attainment year, which included ambient air 

quality monitoring data that showed emissions that met the 1997 ozone NAAQS in the Reading

Area. The inventory was based on a “typical summer day,” as required by the EPA. The 

Department developed an emissions inventory for 2018 that demonstrated that the area would 

meet the 1997 ozone NAAQS for a 10-year period following redesignation of the area to 

attainment. The emissions inventory for 2018, a maintenance year, showed that emissions of 

NOX, VOC, and CO in the Reading Area would not exceed emissions that occurred in 2004. The

maintenance year is a year at least 10 years in the future that a state chooses to demonstrate that

emissions over a 10-year period of analysis will not lead to an exceedance of the standard. A

state does this by showing that emissions in the maintenance year are less than emissions in the 

attainment year.

An emissions inventory in the 2007 Reading SIP revision showed that emissions in 2009, the 

interim year, did not exceed emissions in 2004, the attainment year. The 2009 and 2018 

inventories both considered future growth projected from a 2002 baseline year, and included 

emission reductions from permanent and enforceable control measures.

This final SIP revision updates highway emissions estimates using the MOVES2010a model. 

The Department need not update emissions estimates for nonroad sources for several reasons.

For one, the growth assumptions for emissions from nonroad sources in the 2007 Reading Ozone 

Maintenance Plan for the year 2009 were greater than the documented growth that actually 

occurred from 2002 to 2009. Additionally, newer, updated emission growth projections to 2018 

for nonroad sources are less than emission growth projections for these sources in the Reading

Ozone Maintenance Plan. A few indicators of growth used to project the area source emissions 

inventory in the Reading Ozone Maintenance Plan were less than actual area source growth 

factors used in this final SIP revision. Also in this final SIP revision, linearly interpolated 2018 

point source emission estimates derived from the Mid-Atlantic Regional Air Management 

Association (MARAMA) recent effort for modeling ambient particulate matter concentrations 

are used to revise 2018 projected point source emissions in the Reading Ozone Maintenance 

Plan.

Ambient air quality monitoring results for the Reading Area demonstrate continued attainment of

the 1997 ozone NAAQS (0.08 ppm, with rounding, 84 parts per billion (ppb)), as shown in Table 

1. Preliminary monitoring results for 2012 indicate a design value of 79 ppb.
5

Table 1: Reading Area 2012 Design Values

Monitor 2010

4

th

Highest

2011

4

th

Highest

2012

4

th

Highest

3-Year 

Average

or Design 

Value1

Kutztown

42-011-0006 78 ppb 73 ppb 75 ppb 75 ppb

Reading Airport 

42-011-0011 84 ppb 75 ppb 75 ppb 79 ppb

 

1

A “design value” is the annual fourth highest daily maximum 8-hour ozone concentration, averaged over three years.

The EPA Office of Transportation and Air Quality developed guidance titled, Policy Guidance 

on the Use of MOVES2010 and Subsequent Minor Revisions for State Implementation Plan 

Development, Transportation Conformity, and Other Purposes, (MOVES2010 guidance) EPA 

420-B-12-010, April 2012. This guidance describes requirements for SIP revisions. For 

maintenance demonstrations, areas can have a revised motor vehicle emissions inventory and 

budget using MOVES without revising emissions for other sectors included in the applicable SIP 

or completing additional modeling if:

 The SIP continues to meet applicable requirements when the previous motor vehicle 

emissions inventories are replaced with inventories generated by MOVES2010a; and,

 The state can document that growth and control strategy assumptions for non-motor 

vehicle sources continue to be valid and minor updates do not change the overall 

conclusions of the SIP.

The EPA further states that if both of the criteria are met, the state can simply re-submit the 

original maintenance plan with the revised motor vehicle emissions inventories, using the most 

current version of the MOVES model. However, if either criterion is not met, the emissions 

categories in the maintenance plan that have changed must be brought up to date.

Since the second criterion listed above is not met for point source or area source emissions, this 

final SIP revision includes information addressing the recommendations described in the 

MOVES2010 guidance, listed here:

 Demonstration that the 1997 ozone NAAQS approved maintenance plans continue to

meet applicable requirements with the revised motor vehicle emissions inventories, as 

calculated by the most recently approved MOVES model, and recalculation of the 

attainment year, interim year and maintenance year MVEBs with the latest planning 

assumptions, including documentation of the updated assumptions;

 Review of the point, area, and nonroad emissions inventories for the interim year and 

maintenance year to determine if growth and control strategy assumptions have changed 

and, if so, development of an analysis to determine if these changes affect the conclusion 
6

of the maintenance plan that air quality will remain compliant with the 1997 ozone 

NAAQS; and

 Assessment to confirm excess emissions in the SIP revision exist prior to allocating them 

to the MVEBs and the quantification of these excess emissions for use in the safety

margin applied to the MVEBs.

1.4. Maintenance Plan Demonstration and Motor Vehicle Emissions Budgets

Table 2 shows the revised 2004, 2009 and 2018 NOX MVEBs calculated using the latest 

planning assumptions for the Reading Area using MOVES2010a. Only revised NOX budgets 

have been included in Table 2 and revised in this final maintenance plan revision, as the existing 

MOBILE6.2-based VOC MVEBs are sufficient for future conformity determinations. 

Assumptions used in the MOVES2010a modeling, including model inputs, growth assumptions 

and modeling methodology, are provided in Appendix C. Highway vehicle emissions show a 

clear, downward trend.

Table 2: Motor Vehicle Emissions Budgets 

Year

NOX

Emissions 

(tons/day) 

(MOVES2010a)

VOC 

Emissions 

(tons/day) 

(MOBILE6.2)

2004 Attainment Year 34.40 17.0

2009 Modeled Emissions 26.98 12.1

Conformity Portion of 

Safety Margins1 2.00 1.00

2009 Interim Year Budget 28.98 13.1

2018 Modeled Emissions 12.90 6.5

Conformity Portion of 

Safety Margins 2.00 1.00

2018 Maintenance Year 

Budgets 14.90 7.5

 

1 A “safety margin” is the amount of emissions by which the total projected emissions from all sources of a given 

pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable further 

progress, attainment, or maintenance (40 CFR §93.101). The state may designate a portion of these emissions for 

use by the Metropolitan Planning Organization (MPO) or Department of Transportation (DOT) as a safety margin to 

be used for transportation projects. See 40 CFR §93.124(a) for application of a safety margin.
7

1.5. Non-Mobile Inventory Review

As explained above, the EPA states in its MOVES2010 guidance that revisions to existing SIPs 

and budgets must continue to meet applicable requirements under the Clean Air Act. A 

maintenance plan revised to take into account new emission estimates due to an update in the 

highway model must demonstrate that attainment of the standard continues, even with updated 

control measures and growth estimates. This final SIP revision includes increases in the 

maintenance plan’s NOX emission estimates for the attainment, interim and maintenance years

resulting from revising highway emissions using MOVES instead of the Mobile6.2 model. This 

final SIP revision also accounts for emissions of point, area, and nonroad sources using the latest 

planning assumptions and growth estimates. Total emissions in the years 2009 and 2018 cannot 

exceed the emissions in the 2004 attainment year inventory. The Department concludes that the 

Reading Area will continue to demonstrate attainment of the 1997 ozone NAAQS because total 

emissions of NOX in the interim year and maintenance year will be less than the 2004 attainment 

year inventory for NOX. Developing a revised highway inventory for CO is unnecessary for this 

final SIP revision because CO emissions decrease using MOVES in place of the Mobile6.2

model. VOC emissions are not being updated because VOC emission estimates for the Reading 

Area do not increase to the point at which the existing budget is exceeded when using the 

MOVES2010a model.

Growth and control strategy assumptions have changed for all of the emission categories since 

the Reading Ozone Maintenance Plan was approved. The changes in these assumptions have 

generally decreased forecasted emissions in future years. A severe economic recession occurred 

since the maintenance plan was approved and employment was greatly depressed, falling short of 

the employment projections in the maintenance plan for the year 2009. More controls of source 

categories have been implemented at both the federal and state level. The nonroad NOX

emission inventory is not being revised for the interim and maintenance years in this final SIP 

revision. The point source NOX emission inventory is being updated. The Department 

compared updated growth estimates with growth assumptions and growth estimates in the 

Reading Ozone Maintenance Plan. That analysis is included below. More detailed information 

can be found in Volume II: Technical Support Document.

Some SIP revisions for certain areas in the Commonwealth will require the Department to update 

growth and strategy assumptions of point and area sources. A number of areas in the 

Commonwealth are home to newly built point sources, such as electric generating units (EGUs). 

Some areas have experienced Marcellus Shale gas development, which has increased area source 

emissions.

The EPA developed the Clean Air Interstate Rule (CAIR) in 2005 to control emissions from 

EGUs. See, 70 FR 25162 (May 12, 2005) and later amendments. The U.S. Court of Appeals for 

the D.C. Circuit remanded CAIR in December 2008, without vacating it, in North Carolina v. 

EPA, 531 F.3d 896, modified, 550 F.3d 1176 (D.C. Cir. 2008. EPA developed the Cross-State 

Air Pollution Rule (CSAPR) in 2011 to limit the transport of NOX and sulfur dioxide, which 

could have changed projected emissions of point sources. See, 76 FR 48208 (Aug. 8, 2011), and 

later revisions. The court vacated CSAPR on August 21, 2012, however, and ordered EPA to 

continue administering CAIR pending the promulgation of a valid replacement. The court 

recently denied EPA’s requests that the court rehear the case. See, EME Homer City Generation 

L.P. v. EPA, 696 F.3d 7 (D.C. Cir. 2012), rehearing denied, 2013 U.S. App. LEXIS 1623 and 
8

1624 (D.C. Cir. Jan. 24, 2013). Following the court’s direction, CAIR remains in place. On 

November 19, 2012, EPA Assistant Administrator Gina McCarthy issued a memorandum stating 

that it is appropriate for EPA to rely on CAIR reductions as permanent and enforceable until 

court proceedings are resolved or, if the vacatur of CSAPR remains in place, until EPA 

promulgates a replacement and state plans for implementation are approved. Some owners and 

operators of EGUs have responded to new economic and regulatory developments by closing 

coal-fired electric generation units or by switching fuels (to natural gas) at their facilities. The 

Department has considered these developments and concluded that some changes apply to EGUs 

in the Reading Area.

Table 3 shows that NOX emissions in the interim and maintenance years will not exceed overall 

emissions from all sources in 2004, the attainment year, even though highway emissions for NOX

are greater in the Reading Area when modeled by MOVES than when the emissions were

estimated by Mobile6.2 in the Reading Ozone Maintenance Plan. Actual emissions for the 2009 

point sources, area sources grown with updated growth factors to 2009 and updated 2018 

projected point source and area source emissions are included in this SIP revision inventory. 

Projected nonroad category emissions from the Reading Ozone Maintenance Plan are used for 

2009 and 2018 in this final SIP revision. Projected nonroad sources do not need to be updated 

because emissions from these categories have not increased appreciably since the Reading Ozone 

Maintenance Plan was submitted to the EPA. Attainment of the 1997 ozone standard is 

maintained by showing revised actual and projected growth for 2009 and 2018 does not increase 

overall future emissions included in the Reading Ozone Maintenance Plan. This final SIP

revision demonstrates that growth assumptions in the Reading Ozone Maintenance Plan forecast 

greater growth than what actually occurred or will occur in the major source category segments.

Table 3: Revised Reading Area NOX Emissions from 2004 to 2018

NOX in tons/day

Year Point Area Nonroad Highway Total

2004 16.00 2.12 10.30 34.40 62.82

2009 11.51 2.31 8.40 28.98 51.20

Δ(2004-2009) -4.49 0.19 -1.90 -5.42 -11.62

2018 12.60 2.11 5.40 14.90 35.01.

Δ(2004-2018) -3.40 -0.01 -4.90 -19.50 -27.81
9

2. Source Category Emissions

2.1. Point Source Category Emissions

2.1.1. CONTROL MEASURES

At the time of the development of the Reading Ozone Maintenance Plan, many large sources 

were affected by the requirements of the federal CAIR. Pennsylvania implemented NOX control 

programs, including implementation of CAIR, which control NOX from large industrial boilers,

internal combustion engines, electric generating units, and cement kilns. Another control 

measure took effect for NOX emissions for point sources after the Reading Ozone Maintenance 

Plan was approved. New Source Performance Standards (NSPS) have been promulgated that 

affect newly manufactured stationary engines installed at facilities after January 1, 2012. The 

NSPS standards reduce NOx on 50 percent of new engines initially and are phased in to affect 

100 percent of engines beginning in 2014. The NOx emission standard is 95 percent cleaner for 

the affected engines.

2.1.2. GROWTH ESTIMATES IN THE READING OZONE MAINTENANCE PLAN

Annual point source inventories using historical emissions data reported to the Department by 

point source facilities were included in the Reading Ozone Maintenance Plan. The Department 

developed an emissions inventory of point sources for calendar years 2002 and 2004. The 2002 

point source emissions inventory represents a time when the Reading Area did not meet the 1997 

ozone NAAQs. The 2004 point source inventory showed emissions that occurred during 2004, 

the attainment year for the 1997 ozone NAAQS.

Emission projections for the point source sector for 11 states, including Pennsylvania, and the 

District of Columbia, were prepared for MARAMA by MACTEC Federal Programs, Inc.

(MACTEC). Future year projections were developed by MACTEC so that states could use the 

point source inventories in their SIPs. Emission projections were prepared for years 2009 and 

2018.

For the purpose of projecting emissions into the future, the point source inventory in the Reading 

Ozone Maintenance Plan was divided into two subsectors – the EGU sector and the non-EGU 

sector. Different projection methods were used for those two sectors. For the EGU sector, the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) effort used the Integrating Planning 

Model (IPM) to project future electric generation, as well as to calculate the impact of control 

programs on future emission levels. The Reading Area has two EGU emission facilities. For the 

non-EGU sector, growth factors were developed by using the EPA’s Economic Growth Analysis 

System Version 5.0 (EGAS 5.0). The U.S. Department of Energy fuel consumption forecasts 

were used to replace default values in EGAS 5.0. Also, state-supplied population, employment, 

and other emission projection data were used to update and enhance the EGAS 5.0 default 

values.

GenOn’s Titus Generating Station, which is one of the top two point source producers of NOX in 

the Reading Area, is scheduled for shutdown before the 2018 maintenance year. The SIP 

revision treats Titus Generating Station as if it will be active in 2018. With this in mind, this 

revision is conservative in its emission estimate of NOX for point sources.
10

2.1.3. POINT SOURCE CATEGORY CONCLUSION

Projected NOX emissions for 2009 in the Reading Ozone Maintenance Plan are being revised

with actual emissions for point sources in 2009, because the actual emissions are readily 

available and allow easy comparison between the projected emissions in the maintenance plan 

and the actual emissions. The Department assessed point source emissions by comparing the 

actual emissions inventory data submitted to the Department by owners and operators of point 

sources for 2009 to the estimated 2009 NOX emissions from point sources in the Reading Ozone 

Maintenance Plan. The Reading Ozone Maintenance Plan overestimated point source emissions

for 2009. Table 4 shows that the projected point source emissions of NOX in the maintenance 

plan were 5.3 tons per day more than actual 2009 point source emissions. Actual emissions of 

NOX declined significantly from 2004 to 2009, even when compared to the slow growth in 

emissions forecasted in the Reading Ozone Maintenance Plan.

Table 4: 2009 Point Source Emissions - Maintenance Plan Estimates Versus Actual

2009 Emissions NOX 

(tons/day)

Maintenance Plan 

Estimate

16.8

Actual Emissions 11.5

In this final SIP revision, the Department revises the 2018 inventory in the Reading Ozone 

Maintenance Plan by using emissions from the inventory developed by MARAMA. Because the 

updated inventory produced by MARAMA uses different years for the baseline and projected 

inventories, and different surrogates to estimate growth than those used in the Reading Ozone 

Maintenance Plan, comparison between growth factors used to produce the two inventories is 

difficult. The MARAMA projected inventory estimated emissions for the years 2017 and 2020

from a baseline 2007 emissions inventory. In order to obtain emission estimates for the 2018 

maintenance year, a straight line interpolation between 2007 and 2020 was used. Projected NOX

emissions in 2018 using the MARAMA estimates are still well below the 2018 projected 

emissions in the Reading Ozone Maintenance Plan, as shown in Table 5, and thus show that 

projected emissions in 2018 will fall below the 2004 (attainment year) emission levels.
11

Table 5: 2018 Point Source Emissions – Maintenance Plan

Estimate Versus Revised 2018 Emissions

2018 Emissions NOX 

(tons/day)

2018 Maintenance Plan 

Estimate 19.2

2018 Revised Estimate 

(MARAMA Inventory) 12.6

2.2. AREA SOURCE CATEGORY EMISSIONS

2.2.1. CONTROL MEASURES

The area sector includes, but is not limited to, such diverse emissions source categories as:

surface coating; commercial and consumer solvent use; residential heating; open burning; traffic 

line painting; and landfill gases. Emissions are produced from a wide number of sources for 

which actual emissions or direct indicators of emissions are not available. One control measure

took effect for NOX emissions for area sources after the Reading Ozone Maintenance Plan was 

approved. New Source Performance Standards (NSPS) have been promulgated that affect newly 

manufactured stationary engines installed at facilities after January 1, 2011. These standards

require internal combustion engines to meet a 50 percent reduction in NOx, and will reduce NOx 

emissions of the affected sources in 2018. The reductions that will result are not included in the 

inventory. These reductions are mentioned to demonstrate that emissions will continue to 

decrease.

2.2.2. GROWTH ESTIMATES IN THE READING OZONE MAINTENANCE PLAN

Area source emission growth factors were developed by using the default configuration in EGAS 

5.0. EGAS 5.0 used the Department of Energy Annual Energy Outlook 2004 (AEO2004) fuel 

use projections. In this final SIP revision, the AEO2005 fuel consumption forecasts were used to 

replace AEO2004 forecasts. State-supplied population and employment data were used to 

replace default data, when the state-specific data was available. Growth estimates were 

represented by growth factors for each area source classification code (SCC) for each county.

County-level population data for 2000, and projections for 2010 and 2020 from the Pennsylvania 

State Data Center, http://pasdc.hbg.psu.edu/, were provided to derive growth factors. These data 

were interpolated to obtain growth factors for projecting emissions from 2002 to 2009 for SCCs 

that are population based. General employment data for 21 counties or areas for 2000, and 

projections to 2010 and 2020, were used. These data were also interpolated to estimate growth 

factors for projecting from 2002 to 2009 and 2018 for nine area source categories. For all other 

area source categories, AEO2005 forecasts were used for projecting emissions from area source 

fuel combustion, when available. If AEO2005 forecasts are not available, EGAS 5.0 default 

factors were used.
12

The Reading Ozone Maintenance Plan relied upon many different types of socioeconomic 

indicators that served as surrogates to actual sales data to estimate emissions from the area 

source sector when actual sales data was not available. Population, employment, fuel use and 

housing data are some of the surrogates used to estimate emissions. Methodologies for 

estimating some emissions from some area sources were updated by the EPA in the time since 

EPA approved the Reading Ozone Maintenance Plan, but because the emissions change similarly 

for the attainment, interim and maintenance years, the changes will not result in a significant 

difference between the attainment year’s emissions and the maintenance year’s emissions. As 

can be seen from Table 6, with the exception of the growth surrogates of commercial boilers 

using natural gas and population, emissions would decrease from area sources, since actual 

growth rates from 2002 to 2009 are lower or nearly the same when compared to the growth rates 

used in the Reading Ozone Maintenance Plan. Population is higher than what was in the 

maintenance plan, but population serves predominately as a growth surrogate for VOC emission 

growth, which is not considered in this SIP revision. The growth surrogates presented in Table 6 

are used to estimate emission growth for most SCCs in the area source category in the 

maintenance plan and account for a large majority of the emissions in the area source inventory. 

Growth from 2009 to 2018 presented in Table 7 shows that the growth in the Reading Ozone 

Maintenance Plan was estimated to be less than projected growth in the MARAMA inventory for

commercial anthracite coal, and commercial natural gas use. Revised projected growth for other 

sources were very similar to growth projections in the maintenance plan.

Table 6: Comparison of Growth Factors Used in Maintenance Plan and

Inventory Updates (2002 to 2009)

Growth Surrogates Actual 

Growth 

(Census 

Data)

Maintenance 

Plan 

Surrogate 

Estimates 

(2006)

2009 Population * 1.0696 1.0381

2009 Total Employment 0.9928 1.0645

2009 Commercial Boilers Natural Gas 1.0702 1.0105

2009 Commercial Boilers, Distillate 0.9797 1.0731

2009 Commercial Boilers, Coal 0.6522 1.0481

*Growth for the year 2009 is computed from 2002 to 2009.
13

Table 7: Comparison of Growth Factors Used in Maintenance Plan 

and Inventory Updates (2009 to 2018)

Growth Surrogates Revised 

Growth 

from 

MARAMA 

Inventory 

(2009-2018)*

Maintenance 

Plan Growth 

(2009-2018)*

Population 1.0851 1.0472

Employees 0.9998 1.0779

Anthracite Coal, Industrial 0.9136 0.9983

Anthracite, Commercial 1.0230 0.9865

All Combustor Types, Distillate Oil, 

Residential

0.8226 0.9598

Boilers and Internal Combustion 

Engines, Natural Gas, Commercial

1.0687 1.0521

Combustor Types, Natural Gas, 

Residential

1.0188 1.0181

*Growth for the year 2018 is given as a factor estimating growth from 2009 to 2018. Due to 

different time ranges used for growth estimates in the maintenance plan and more recent 

inventory data, growth based on 2002 was impossible to estimate. This method allows for a 

direct comparison.

2.2.3. GROWTH ESTIMATES IN MARAMA 2011 REGIONAL MODELING EFFORT

The development of growth factors for the MARAMA 2011 regional modeling effort for area 

sources used one or a combination of the following as surrogates for growth: AEO2010, 

population data, or employment data. A direct comparison cannot be made between the growth 

factors based on AEO2005 or population in the original maintenance plan and this final SIP

revision which uses growth factors from MARAMA’s 2011 regional modeling effort. As years 

pass, different inventory methodologies are developed. This final SIP revision uses the best 

method to compare emissions inventories that use differing methodologies. (See Volume II: 

Technical Support Document). The MARAMA 2011 regional modeling effort developed growth 

factors for most SCCs using AEO2010 or county level population. Employment data was 

derived from North American Industry Classification System to the state level. Since 

employment data to the county level was not available from the MARAMA 2011 modeling, state 

employment data was applied to all SCCs that use employment data and counties in this final SIP 

revision. The recession reduced employment, which fell short of the projections in the 

maintenance plan for the year 2009. Starting from depressed employment levels in 2009, it is 

unlikely that employment projections in the maintenance plan will be exceeded in 2018, even if 

employment growth recovers to normal levels in the near future.

2.2.4. MARCELLUS SHALE EMISSIONS

Significant infrastructure development to extract Marcellus Shale natural gas in some 

Pennsylvania counties has occurred since the 2007 Reading Area SIP revision was submitted to 

the EPA by the Department. Area source emissions result from the placement of drilling 
14

equipment, gathering lines and compressor stations. The Reading Area has not experienced any 

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

future.

2.2.5. AREA SOURCE CATEGORY CONCLUSION

Projected area source NOX emissions in the Reading Ozone Maintenance Plan are being revised 

in this final SIP revision. Area source emissions are being revised because updated growth 

factors do not clearly demonstrate that emissions growth in the Reading Ozone Maintenance SIP 

over-predicted emissions. Revised emission growth estimates for fuel use, which produces NOX

emissions, is sufficiently non-predictive to demonstrate that area source emissions decreased 

when compared to the Reading Ozone Maintenance Plan. Therefore, area source emissions in 

the Reading Ozone Maintenance Plan were revised for both 2009 and 2018. Projected emissions 

of NOX from area sources were slightly higher in 2009 (see Table 3) and nearly the same in 

2018.

2.3. Nonroad Source Category Emissions

2.3.1. CONTROL MEASURES

The nonroad category contains many different types of equipment. The Department used 

NONROAD2005 for the Reading Ozone Maintenance Plan. All versions of the EPA’s 

NONROAD Model estimate emissions for over 200 types of engines and vehicles. Nonroad

engines and vehicles can be used for such applications as construction, lawn and garden care, 

farming, and industrial applications. In addition, emissions from three types of activities,

including aircraft, locomotive, and commercial marine vessel activities, are not estimated in the 

NONROAD Model but are in the nonroad category. The model went through one major 

revision since it was used for the Reading Ozone Maintenance Plan. NONROAD2008a is the 

latest version of this model. This new version of the model incorporates two nonroad sector 

reduction strategies that were not included in the Reading Ozone Maintenance Plan:

 Diesel recreational marine standards in the 2008 final rule on locomotive and marine 

engines (See Control of Emissions of Air Pollution From Locomotive Engines and 

Marine Compression-Ignition Engines Less Than 30 Liters per Cylinder, 73 FR 25098, 

May 6, 2008); and

 The October 2008 small spark ignition and spark ignition and recreational marine rule 

(See Control of Emissions From Nonroad Spark-Ignition Engines and Equipment, 73 FR 

59034, October 8, 2008).

For the Reading Ozone Maintenance Plan, the Department modified files in the 

NONROAD2005 model, when state specific data was available, that affect emission categories 

such as residential lawn and garden and recreational marine vessels. 

2.3.2. GROWTH ESTIMATES

Emissions from nonroad sources have decreased since the submittal of the Reading Ozone 

Maintenance Plan as a result of additional controls mentioned above, and other tier level controls 

that have been phased in since 2004 for engines used in the nonroad sector. The fleet turnover 
15

that occurs as older, more polluting nonroad equipment and vehicles are replaced by newer 

equipment and vehicles that meet more stringent emission standards has continued to lower 

emissions in the nonroad sector since the late 1990s, and will continue to do so for the next 10 

years. Emission reductions occurred across all segments of the nonroad category, including 

construction equipment, farming equipment, locomotives, and lawn and garden equipment. 

Furthermore, the recession significantly lowered construction, railroad, aircraft, and industrial 

activity, and, consequently, lowered emissions. Even if growth returns to pre-recession levels, 

overall growth will likely remain lower than what was predicted in the maintenance plan up to 

the 2018 maintenance year.

2.3.3. NONROAD SOURCE CATEGORY CONCLUSION

The Department demonstrated through the analysis above that it is reasonable to assume that 

emissions growth for nonroad sources that has occurred, and is occurring, is less than the growth 

forecasted in the Reading Ozone Maintenance Plan for NOX for both maintenance years, 2009 

and 2018. The Department compared growth estimates between those used in NONROAD2005 

and NONROAD2008a, and took into account fleet turnover, effects of the recession and the two 

new standards introduced in 2008. Emissions of NOX from the nonroad source sector have not 

increased as a result of any new activity or update in methodology. Therefore, no revisions to 

the nonroad source sector for NOX emissions are necessary.

2.4. Highway Source Category Emissions

2.4.1. CONTROL MEASURES

Assumptions for vehicle emissions standards have not been changed significantly in the modeled 

analysis from when the Reading Ozone Maintenance Plan was submitted to EPA. Pennsylvania 

began implementation of California emission standards, which are incorporated by reference in 

Pennsylvania regulations, for model year 2005 for diesel-powered heavy-duty trucks, and model 

year 2008 for passenger cars and light-duty trucks.

In January 2012, the California Air Resources Board (CARB) approved significant revisions to 

its regulations for criteria pollutant and greenhouse gas emissions from passenger cars, light-duty 

trucks and medium-duty vehicles. The amendments, referred to as LEV III, were approved by 

California’s Office of Administrative Law (OAL) on August 7, 2012, and will become effective 

in model year (MY) 2015 for criteria pollutants and in MY 2017 for greenhouse gases. The 

requirements were automatically incorporated by reference as part of the Pennsylvania Clean 

Vehicles Program, to the extent the amendments apply to Pennsylvania’s program. See, 

25 Pa. Code §126.411(b). On August 28, 2012, the EPA and the U.S. Department of 

Transportation’s National Highway Traffic Safety Administration (NHTSA) issued a joint Final 

Rulemaking to extend the National Program of harmonized greenhouse gas and fuel economy 

standards to MYs 2017-2025 passenger vehicles. Neither the California nor the EPA-NHTSA 

Final Rulemaking has been analyzed as to its effect on future year emission estimates of NOX, at 

the time of the development of this final SIP revision. However, it is reasonable to assume that 

NOX emissions will decrease as these vehicles replace older vehicles during fleet turnover.
16

2.4.2. GROWTH ESTIMATES

Overall emissions from highway vehicles will continue to decrease as new vehicles take the 

place of older vehicles during normal fleet turnover. Fleet turnover is the greatest driver in 

lowering emissions from highway vehicles. Fleet turnover has been slower than forecast in the 

Reading Ozone Maintenance Plan. This is, in part, a result of the recent recession. Other factors 

have some impact on emissions from the highway source category, such as changes in fleet age, 

vehicle miles traveled, and the fleet mix of vehicles. The fleet age is also increasing as people 

operate their vehicles for a longer period of time. This will reduce the rate of fleet turnover and 

the reductions expected in emissions. It is difficult to compare vehicle miles traveled (VMT) in 

Pennsylvania between the Reading Ozone Maintenance Plan and this final SIP revision because 

the method for estimating VMT has changed. Nationally, there was a slight decline in VMT 

during the recession. The percentage of vehicles in Pennsylvania that are light-duty trucks is 

also shrinking. Consumers are purchasing more passenger cars than light-duty trucks. Passenger 

cars tend to have lower emissions.

Emission estimates of NOX were developed using MOVES2010a and the latest planning 

assumptions. Emissions have been estimated for 2004 (attainment year), 2009 and 2018

(maintenance years). The MOBILE6.2 emission estimates from the original maintenance plan 

have been included in Table 8 to illustrate relative changes in emissions.

Table 8: Revised Motor Vehicle Emissions Using MOVES2010a (tons/summer day)

Pollutant Original MOBILE6.2 Emissions Revised MOVES2010a Emissions

2004 2009 2018 2004 2009 2018

NOX 29.8 20.7 8.4 34.4 27.0 12.9

VOC 17.0 12.1 6.5 N/A* N/A N/A

*VOC budgets were not recalculated using MOVES2010a. The VOC MVEBs developed with Mobile6.2 are 

approved for transportation conformity.

Table 8 shows the MOVES model estimates NOX emissions in 2009 and 2018 that exceed the

MOBILE6.2-derived emissions in the Reading Ozone Maintenance Plan. This would cause 

transportation planning emissions estimates using MOVES to exceed the MVEBs. The updated 

NOX MVEBs provided in Table 9 will help ensure that the Reading Area can demonstrate 

transportation conformity using MOVES2010a, once the conformity grace period expires, while 

the emissions estimates still demonstrate that the Reading Area demonstrates attainment with the 

1997 ozone NAAQS.

2.4.2. MOBILE SOURCE CATEGORY CONCLUSION

This final SIP revision includes revised MVEBs for Berks County using updated highway 

vehicle emissions estimates derived from MOVES. Appendix C of this final SIP revision 

replaces the corresponding sections of the original Appendix C in the Reading Ozone 

Maintenance Plan. Appendix C of this final SIP revision describes the highway modeling 

methodology necessary to produce accurate emission estimates from the MOVES model.
17

3. Safety Margins

Table 3 shows that the emissions in the interim and maintenance years, even when using 

conservative estimates in the Reading Ozone Maintenance Plan, for point, area and nonroad 

sectors, provide a significant safety margin for continued maintenance.

Therefore, a portion of those safety margins is being allocated to transportation projects to help 

ensure that any future planning assumption updates will not negatively impact the area’s ability 

to demonstrate transportation conformity. Adequate safety margins will also defer the need for 

future SIP revisions, where the purpose of the SIP revision is only to update numbers and not to 

document any actual emissions reductions to the atmosphere.

To help ensure that the transportation conformity process is not needlessly delayed, a 2.0 ton/day

safety margin for NOX has been applied to the MVEBs in 2009 and 2018 in this final SIP 

revision. All indications are that the 2009 and 2018 emission estimates made for point, area and 

nonroad sources in the Reading Ozone Maintenance Plan are higher than any actual emissions 

for 2009 and revised estimates for 2018 in this SIP revision. Table 3 quantitatively shows that 

these safety margins will continue to allow the area to remain well below the 2004 attainment 

year emissions inventory cap, thereby ensuring that future air quality will continue to meet the 

1997 ozone NAAQS.

4. Motor Vehicle Emission Budgets for Transportation Conformity

The Department proposes to establish budgets for highway emissions in order to ensure that 

transportation emissions do not impede clean air goals for almost the next decade. The 

information in Table 9, once EPA approves this final SIP revision for the purposes of 

transportation conformity, will establish MVEBs for Berks County.

Table 9: Motor Vehicle Emissions Budgets

Calendar Year Pollutant

NOX

2009 Predicted

Safety Margin

24,501 kilograms/summer day

(27.0 tons/summer day)

1815 kilograms/summer day

(2.0 tons/summer day)

2009 Budget 26,316 kilograms day

(29.0 tons/summer day)

2018 Predicted

Safety Margin

11,706 kilograms day

(12.9 tons/summer day)

1815 kilogram/summer day

(2.0 tons/summer day)

2018 Budget 13,521 kilograms/summer day

(14.9 tons summer day)
18

5. Conclusion

By examining actual and projected emissions, increased controls for all emissions categories, and 

evidence that actual emissions growth for point source, area source, and nonroad source 

categories has been less than the projected emissions growth in the approved Reading Ozone 

Maintenance Plan, the Department has shown that the conclusion in the Reading Ozone 

Maintenance Plan that the Reading Area will continue to maintain attainment of the 1997 ozone 

NAAQS remains valid, even after updating the highway emissions using the new EPA-approved 

MOVES model. Updating NOX emissions in the MVEBs will not negatively affect the Reading

Area’s ability to maintain the 1997 ozone NAAQS. In this final SIP revision, the Department 

has updated emissions of NOX that were included in the Reading Ozone Maintenance Plan for 

point, area and highway sources. Emissions of nonroad sources were not updated from the 

Reading Ozone Maintenance Plan because it was shown that growth in emissions for those 

sources decreased or was unaffected.
Chris Abruzzo Tom Corbett

Acting Secretary Governor

Commonwealth of Pennsylvania 

Final

VOLUME II: Technical Support Document 

State Implementation Plan Revision: NOx Motor 

Vehicle Emission Budget Revisions Based on the 

MOVES2010a Model

Reading Eight-Hour Ozone Maintenance Area

March 2013

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495
[This page intentionally left blank.]
i

Contents

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

Point Source Category Emissions.................................................................................................................1

2009 Point Source Category Emissions....................................................................................................1

2018 Point Source Category Emissions....................................................................................................6

Area Source Category Emissions................................................................................................................12

2009 Area Source Category Emissions...................................................................................................12

2018 Area Source Category Emissions...................................................................................................17

Nonroad Source Category Emissions .........................................................................................................24

Highway Source Category Emissions.........................................................................................................25

Tables

Table 1: Point Source Emissions for 2009 – SIP Estimated Versus Actual .................................................2

Table 2: Actual 2009 Annual NOX Point Source Inventory for the Reading Ozone Maintenance Area by 

Facility Source........................................................................................................................................2

Table 3: Reading Ozone Maintenance Plan Emission Estimates for 2018...................................................7

Table 4: Revised Reading Ozone Maintenance Plan Emissions Estimates of Non-EGU and EGU Point 

Sources for 2018 (MARAMA 2007 Baseline and 2020 Projected Inventories) ....................................7

Table 5: MARAMA 2018 Annual Baseline and Projected NOX Point Source Inventories for the Reading

Ozone Maintenance Area by Facility Source .........................................................................................8

Table 6: Revised Socioeconomic Data for the Reading Ozone Maintenance Area Relative to Projected 

Growth in the Reading Area Maintenance Plan (2002-2009)..............................................................13

Table 7: NOX Affected Area Source Emission Categories in the Reading Ozone Maintenance Areas for 

Calendar Year 2009..............................................................................................................................14

Table 8: Revised Socioeconomic Data for the Reading Ozone Maintenance Area Relative to the Projected 

Growth in the Reading Area Maintenance Plan (2009-2018)..............................................................18

Table 9: Affected NOX Area Source Emission Categories in the Reading Ozone Maintenance Areas for 

the Calendar Year 2018........................................................................................................................19

Table 10: Revised Motor Vehicle Emissions Using MOVES2010a...........................................................25
ii

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1

Introduction

This Technical Support Document provides detailed information on the categories of point, area, 

nonroad, and highway sources of oxides of nitrogen (NOX) emission estimates and assumptions. 

Data shown in this document were used in the State Implementation Plan Revision: Maintenance 

Plan and Base Year Inventory – Reading Eight-Hour Ozone Nonattainment Area, which is 

hereafter referred to as the Reading Ozone Maintenance Plan. Other data and assumptions

outlined in the Technical Support Document are also used in this final State Implementation Plan 

(SIP) revision to the Reading Ozone Maintenance Plan that is entitled, “State Implementation 

Plan Revision: NOX and VOC Motor Vehicle Emission Budget Revisions Based on the 

MOVES2010a Model – Reading Eight-Hour Ozone Maintenance Area” The Reading Ozone 

Maintenance Plan revision demonstrates that replacing highway emissions estimates using the 

MOVES model instead of the Mobile6 model to generate emissions estimates will not cause 

emissions from all sources in the maintenance year to exceed all emissions in the attainment 

year. This Technical Support Document will describe how emission estimates and emission 

growth rates that were used in both the Reading Ozone Maintenance Plan and the Reading

Ozone Maintenance Plan revision were developed for all source categories (point, area, nonroad, 

and highway).

Point Source Category Emissions

Point sources include emissions from large commercial, institutional, and industrial facilities, 

such as chemical manufacturing facilities, large waste disposal sites, and large heating and 

electric generating units (EGUs). Emission projections used in the Reading Ozone Maintenance 

Plan were prepared for the point source sector for 11 states, including Pennsylvania, and the 

District of Columbia, for the Mid-Atlantic Regional Air Management Association (MARAMA)

by MACTEC Federal Programs, Inc. Future year projections were developed by MACTEC so 

that states could use the projections as inventories in their SIPs. Estimates were prepared for 

years 2009 and 2018, and took into consideration both growth in economic activity and 

additional controls required by regulation.

For the purpose of projecting emissions into the future for all of the states’ ozone maintenance 

plans, the point source inventory of emissions is divided into two subsectors – the EGU sector 

and the non-EGU sector. Different projection methods are used for those two sectors. The 

Reading Area has two EGU emission sources. The Reading Area contains many non-EGU point 

sources. For the non-EGU sector, growth factors were developed by using The United States 

Environmental Protection Agency’s (EPA) Economic Growth Analysis System (EGAS) Version 

5.0. U.S. Department of Energy fuel consumption forecasts were used to replace default values 

for combustion sources in EGAS 5.0. Also, state-supplied population, employment, and other 

emission projection data were used if either EGAS 5.0 values did not exist or if the statesupplied data was deemed better than values given by EGAS 5.0.

Point Source Emissions for 2009

Table 1 gives totals of NOX emissions for both 2009 projected emissions in the Reading Ozone 

Maintenance Plan and the actual 2009 Reading Area emissions reported to the Department after 
2

the Reading Ozone Maintenance Plan was developed.

1

 Table 1 demonstrates that the 

assumptions that point source emissions in the Reading Ozone Maintenance Plan for 2009 were 

overestimated for NOX. Table 2 lists the actual 2009 NOX emissions from the individual 

facilities in the Reading Area. Two large facilities in the Reading Area, Titus Generating Station 

and Lehigh Cement, produce 75 percent of all point source NOX emissions. Fuel throughputs of 

these two facilities are such that average summer throughputs are approximately the same as 

average annual throughputs. Therefore, when the annual emissions were divided by 365 days in 

a year, the result approximates average summer day emissions.

Actual Emissions for 2009

Table 1: Point Source Emissions for 2009 - SIP Estimated Versus Actual

Emissions for 2009 NOX 

(tons/day)

Emissions in Maintenance Plan 16.8

Actual Emissions (actual 

reported annual emissions in 

Table 2 divided by 365 days)

11.5

Table 2: Actual 2009 Annual NOX Point Source Inventory for the Reading Ozone 

Maintenance Area by Facility Source

EPA AFS Number Facility Name NOX 

(tons per 

year)

420110096 ADELPHI KITCHENS 

INC/ROBESONIA

0.3

420110054 ATLAS MINERALS & 

CHEM/MERTZTOWN

4.1

420110095 BALDWIN HDWR 

CORP/READING PLT

4.7

420110354 BERKS CAN CO INC/BERKS 

CAN PLANT

0.1

 

1

Air Information Management System Submittal, Pennsylvania Department of Environmental Protection, 2009
3

EPA AFS Number Facility Name NOX 

(tons per 

year)

420110002 BERKS CNTY/BERKS CNTY 

COMPLEX

22.4

420110028 BOYERTOWN FOUNDRY 

CO/FKA EAFCO

2.9

420110075 CAMBRIDGE LEE IND 

/READING TUBE DIV

15.4

420110101 CAN CORP OF 

AMER/BLANDON PLT

9.5

420110031 CARPENTER TECH 

CORP/READING PLT

169.2

420110099 CHIYODA AMER 

INC/CAERNARVON

3.3

420110438 CRAFT MAID KITCHEN 

INC/READING

0.3

420111012 DAIRY FARMERS OF AMER 

INC/READING

9.6

420110365 DELAWARE CNTY 

SWA/ROLLING HILLS MUNI 

WASTE LDFL

5.5

420110636 DYER QUARRY INC/DYER 

QUARRY

6.6

420110274 EAST PENN MFG CO 

INC/BATTERY ASSEMBLY

41.3

420110478 EAST PENN MFG CO 

INC/KUTZTOWN

0.9

420110014 EAST PENN MFG CO 

INC/SMELTER PLT

57.3
4

EPA AFS Number Facility Name NOX 

(tons per 

year)

420110355 EJB PAVING & 

MATERIALS/ONTELAUNEE

9.5

420110638 EXIDE TECH/READING 

FORMATION & DIST CTR

3.7

420110034 EXIDE TECH/READING 

SMELTER

59.4

420110446 FLEETWOOD IND/LEESPORT 0.1

420111066 FR&S INC/PIONEER CROSSING 

LDFL

16.2

420110045 GENON REMA LLC/TITUS GEN 

STA

1529.2

420110554 GLEN GERY CORP/MID 

ATLANTIC PLT

18.6

420110458 GREEN GAS PIONEER 

CROSSING ENERGY 

LLC/EXETER

28.1

420110867 ICON REAL ESTATE 

INC/READING

0.6

420110016 INTERSTATE 

CONTAINER/READING PLT

0.8

420110039 LEHIGH CEMENT CO 

LLC/EVANSVILLE CEMENT 

PLT & QUARRY

1610.2

420110476 MCCONWAY & TORLEY 

LLC/KUTZTOWN FOUNDRY

27.8

420110091 MORGAN 

CORP/CAERNARVON TWP

1.5
5

EPA AFS Number Facility Name NOX 

(tons per 

year)

420110820 NEW MORGAN LDFL CO 

INC/CONESTOGA LDFL NEW 

MORGAN B

15.8

420110427 ONTELAUNEE POWER OPR CO 

LLC/ONTELAUNEE PLT

61.4

420110097 OROGRAIN BAKERIES MFG 

INC/READING PLANT

2.3

420110431 PA DPW/HAMBURG CTR 11.8

420110471 PA DPW/WERNERSVILLE 

STATE HOSP

15.2

420110008 PA STATE SYS OF HIGHER 

ED/KUTZTOWN UNIV OF PA

7.9

420110105 READING TERM 

CORP/SINKING SPRING TERM

0.1

420110089 READING TRUCK BODY 

/READING

3.1

420111018 ROEBERG 

ENTERPRISES/YORGEYS 

CLNRS

0.5

420110637 SEALED AIR CORP/READING 

PLT

11.0

420110237 SUNOCO PARTNERS MKT & 

TERM LP/MONTELLO

2.7

420110088 TEXAS EASTERN 

TRANS/BECHTELSVILLE

211.6

420110087 TEXAS EASTERN 

TRANS/BERNVILLE STA

163.2
6

EPA AFS Number Facility Name NOX 

(tons per 

year)

420110473 UNITED CORRSTACK 

LLC/READING

29.8

420112001 WILLIAMS 

METALFINISHING/SINKING 

SPRING

0.1

420110090 YUASA BATTERY 

INC/LAURELDALE

4.8

Total Actual Annual Emissions 4200.5

Point Source Category 2018 Emissions

Ideally, emissions growth could be compared between what was assumed in the Reading Ozone 

Maintenance Plan and recently revised assumptions for emissions growth. Both sets of 

assumptions are valid because the EPA requires that assumptions in growth be updated with each 

revision to the maintenance plan. If the revised assumptions for growth are less than what was 

assumed in the original maintenance plan, then it can be easily shown that emissions in the 

maintenance years are still below the emissions in the attainment year. However, when revised 

growth in some types of point sources is higher, and in some types, the growth is lower, 

emissions growth cannot easily be compared to show the new assumptions still maintain the 

ozone standard. Then, a projected emissions inventory needs to be developed and compared. 

For the Reading Area, a projected point source inventory for the maintenance year 2018 needed 

to be developed to show maintenance with the ozone standard.

The 2018 point source inventory for the Reading Ozone Maintenance Plan was developed for

MARAMA by MACTEC. More recently, an emissions inventory of all emission source 

categories (point, area, nonroad, and highway) was developed by MARAMA and MACTEC for 

a regional modeling effort. Table 3 and Table 4 compare total emissions of NOX produced by 

non-EGU and EGU sources in the Reading Ozone Maintenance Plan with the recently developed 

inventories. During the last year, MARAMA developed inventories for the baseline year of 2007 

and projected years of 2013, 2017, 2020, and 2025.2 The difference in the inventory years for 

the inventory used in the Reading Ozone Maintenance Plan and new MARAMA/MACTEC 

inventory development efforts did not allow for easy comparison of growth factors used for 

 

2 MARAMA 2007, 2017, and 2020 Baseline and Projected Inventories, Version 3, Julie McDill, Mid-Atlantic Regional 

Management Association, Towson, MD, January 2012.
7

projecting emissions. Projected emissions in 2018 were estimated for the maintenance plan 

revisions using straight-line interpolation between the 2007 MARAMA baseline inventory and 

the 2020 MARAMA projected year inventory using the following equation: 

2018 emissions = 2007 Emissions - ((2007 Emissions – 2020 emissions) *(2018-2007) ÷ 

 (2020 - 2007)) 

Emission projections of non-EGU and EGU point sources in the Reading Ozone Maintenance 

Plan were overestimated for the year 2018 when compared to newer emissions data derived by 

MARAMA. See Tables 3 and 4.

Table 3: Reading Ozone Maintenance Plan Emission Estimates for 2018

Year NOX

Emissions 

(tons/year)

NOX

Emissions 

(tons/day)

2018 7053* 19.2

*Annual 2018 emissions from Titus Generating Station were not included in the 

Reading Ozone Maintenance Plan. Annual emissions are an estimate after

including Titus’s annual emissions, which were based on the daily emissions in 

the maintenance plan.

Table 4: Revised Reading Ozone Maintenance Plan Emissions Estimates 

of Non-EGU and EGU Point Sources for 2018 (MARAMA 2007 Baseline 

and 2020 Projected Inventories)

Year NOX

Emissions 

(tons/year)

NOX

Emissions 

(tons/day)

2007 (Baseline) 5927.9 16.4

2020 (Projected) 4353.8 11.9

2018 (Interpolated) 4595.2 12.6

Table 5 shows actual 2007 and projected 2020 facility emissions of NOX for non-EGU and EGU 

point source in the Reading area. 
8

Table 5: MARAMA 2018 Annual Baseline and Projected NOX Point Source Inventories for 

the Reading Ozone Maintenance Area by Facility Source

EPA AFS 

Number

Facility Name 2007 Baseline 

NOX

Emissions

2020 

Projected 

NOX

Emissions

420110096 ADELPHI KITCHENS 

INC/ROBESONIA

0.0 0.0

420110054 ATLAS MINERALS & 

CHEM/MERTZTOWN

12.3 12.3

420110095 BALDWIN HDWR 

CORP/READING PLT

8.5 11.7

420110354 BERKS CAN INC/BERKS CAN 

PLANT

0.1 0.2

420110002 BERKS CNTY/BERKS CNTY 

COMPLEX

21.4 21.4

420110028 BOYERTOWN FOUNDRY 

CO/FKA EAFCO

3.1 3.2

420110075 CAMBRIDGE LEE 

IND/READING TUBE DIV

14.3 14.9

420110101 CAN CORP OF AMER/BLANDON 

PLT

4.0 5.6

420110031 CARPENTER TECH 

CORP/READING PLT

236.3 281.5

420110099 CHIYODA AMER 

INC/CAERNARVON

4.4 6.2

420110438 CRAFT MAID KITCHEN 

INC/READING

0.0 0.0

420111012 DAIRY FARMERS OF AMER. 

INC/READING

8.3 9.5
9

EPA AFS 

Number

Facility Name 2007 Baseline 

NOX

Emissions

2020 

Projected 

NOX

Emissions

Emissions 

Reduction 

Credits

DECORATIVE SPECIALTIES/DSI 

INC.

9.4

420110365 DELAWARE CNTY 

SWA/ROLLING HILLS MUNI 

WASTE LDFL

9.2 9.7

420110636 DYER QUARRY INC/DYER 

QUARRY

8.1 8.5

420110274 EAST PENN MFG CO 

INC/BATTERY ASSEMBLY

37.5 53.2

420110478 EAST PENN MFG CO 

INC/KUTZTOWN

1.1 1.1

420110014 EAST PENN MFG CO 

INC/SMELTER PLT

62.1 62.9

420110355 EJB PAVING & 

MATERIALS/ONTELAUNEE

12.0 12.2

420110638 EXIDE TECH/READING 

FORMATION & DIST CTR

3.5 3.5

420110034 EXIDE TECH/READING 

SMELTER

60.8 60.8

420110446 FLEETWOOD IND/LEESPORT 0.3 0.4

420111066 FR&S INC/PIONEER CROSSING 

LDFL

16.2 17.1

420110045 GENON REMA LLC/TITUS GEN 

STA/NON-POINT

3.5 4.4

420110045 GENON REMA LLC/TITUS GEN 

STA/POINT

2474.4 2278.9
10

EPA AFS 

Number

Facility Name 2007 Baseline 

NOX

Emissions

2020 

Projected 

NOX

Emissions

420110554 GLEN GERY CORP/MID 

ATLANTIC PLT

31.1 31.1

420110040 GLIDDEN DEA/ICI 

PAINTS/READING

5.0 5.4

420110114 GRAFICA COMMERCIAL 

PRINTING

0.2 0.2

420110867 ICON REAL ESTATE 

INC/READING

1.4 1.9

420110016 INTERSTATE 

CONTAINER/READING PLT

1.1 1.2

420110039 LEHIGH CEMENT CO 

LLC/EVANSVILLE CEMENT PLT 

& QUARRY

2296.6 651.0

420110476 MCCONWAY & TORLEY 

LLC/KUTZTOWN FOUNDRY

22.9 23.5

420110091 MORGAN CORP/CAERNARVON 

TWP

0.5 0.6

420110820 NEW MORGAN LDFL CO 

INC/CONESTOGA LDFL NEW 

MORGAN B

37.9 40.0

420110427 ONTELAUNEE POWER OPR CO 

LLC/ONTELAUNEE PLT

4.0 4.0

420110427 ONTELAUNEE POWER OPR CO 

LLC/ONTELAUNEE PLT

31.2 40.6

420110097 OROGRAIN BAKERIES MFG 

INC/READING PLANT

2.6 3.1

420110431 PA DPW/HAMBURG CTR 11.0 11.3
11

EPA AFS 

Number

Facility Name 2007 Baseline 

NOX

Emissions

2020 

Projected 

NOX

Emissions

420110471 PA DPW/WERNVILLE STATE 

HOSPITAL

16.4 17.0

420110008 PA STATE SYS OF HIGHER 

ED/KUTZTOWN UNIV OF PA

25.1 26.8

420110105 READING TERM CORP/SINKING 

SPRING TERM

0.0 0.0

420110089 READING TRUCK BODY 

/READING

4.4 5.8

420111018 ROEBERG 

ENTERPRISES/YORGEYS 

CLNRS

0.6 0.7

420110637 SEALED AIR CORP/READING 

PLT

17.5 19.4

420110111 SFS INTEC/WYOMISING 0.1 0.1

420110237 SUNOCO PARTNERS MKT & 

TERM LP/MONTELLO

2.2 2.3

420110088 TEXAS EASTERN 

TRANS/BECHTELSVILLE

222.5 316.0

420110087 TEXAS EASTERN 

TRANS/BERNVILLE STA

167.6 238.0

420110473 UNITED CORRSTACK 

LLC/READING

19.3 27.4

420112001 WILLIMAS METAL 

FINISHING/SINKING SPRING

0.2 0.2

420110090 YUASA BATTERY INC/ 

LAURELDALE

4.9 6.8
12

EPA AFS 

Number

Facility Name 2007 Baseline 

NOX

Emissions

2020 

Projected 

NOX

Emissions

Total Annual Point Source NOx 

Emissions

5937.3 4353.8

Area Source Category Emissions

The area source category includes emissions from sources such as surface coating, solvent use, 

residential and commercial heating, and other sources that emit small amounts of emissions on a 

per use basis but have a large number of users. The Reading Ozone Maintenance Plan relied on 

a number of socioeconomic indicators to estimate emissions, and projections of emissions, such 

as: population, industrial employment, employment, and industry specific growth factors. In the 

maintenance plan, a baseline area source inventory of 2002 was grown using socioeconomic 

factors of expected population and employment growth. For some sources, such as coal-, 

distillate-, or natural gas-fired boilers, data from the 2005 Annual Energy Outlook or the EGAS 

model was used to predict future growth and emissions. For other area source categories, statespecific industry growth estimates supplied by the Department were used.

Area Source Category 2009 Emissions

Table 6 shows a recent estimate of actual socioeconomic indicators. Actual growth that occurred 

from 2002 to 2009 was derived from data published by the U.S. Department of Commerce, 

Bureau of Census3,4, 5and the Energy Information Administration, U.S. Department of Energy6. 

The actual growth is compared side-by-side with the predicted growth from the Reading Ozone 

 

3 U.S. Department of Commerce, Bureau of the Census, "Population Estimates Program," T1. Population Estimates 

[10] data Set: 2008 Population Estimates, available from http://www.census.gov/popest/counties/CO-EST2009-

01.html, accessed October 2011.

4 U.S. Department of Commerce, Bureau of the Census, Housing Unit Estimates, Data Set 2002 and 2009 

Population Estimates, Note: For information on errors stemming from model error, sampling error, and nonsampling error, see: http://www.census.gov/popest/topics/methodology, accessed October 2011.

5 Employee and establishment numbers: U.S. Census Bureau, County Business Patterns, 

http://factfinder.census.gov/econ/cbp/index.html

6 Energy Information Administration, U.S. Department of Energy, State Energy Data System - Consumption, 

Physical Units, 1960-2006, available from: http://www.eia.gov/state/seds/sedsstates.cfm?q_state_a=PA&q_state=Pennsylvania
13

Maintenance Plan. The Reading Ozone Maintenance Plan over-predicted growth for most area 

sources for the 2002 to 2009 timeframe. The Reading Ozone Maintenance Plan under-predicted 

growth for two growth surrogates, population growth and natural gas combustion, and therefore, 

under-predicted emissions in the Reading Area for sources that depend on those surrogates for 

determining emissions growth. However, this will not make a large difference in emission 

estimates because most large emission sources predicted by population growth are sources of 

volatile organic compounds which this revision does not address. Gains in emissions from

natural gas use were offset by lower emissions from other fossil fuels. Table 7 compares the 

NOX area sources emissions in the Reading Ozone Maintenance Plan with emissions predicted 

by the MARAMA inventory to determine within a reasonable amount what the exact effect on 

emissions will be due to this under-prediction. The emissions are derived from a 2007 baseline 

emissions inventory that was grown to 2017 and linearly interpolated to determine 2009

emissions. Emissions estimated based on updated assumptions by MARAMA indicate that area 

source emissions of NOX in the Reading Ozone Maintenance Area are approximately 76 tons per 

year more than what was included in the Maintenance Plan. Given that these NOX-producing 

area sources are mostly fuel combustion sources, the increase in area source NOX emissions 

would mostly occur outside of the ozone season during colder temperatures. Increased NOX

emissions for area sources as a result of updated growth estimates would be minimal. After 

adjusting annual emissions to obtain summer weekday emissions, increased emissions in 2009 

were less than 0.1 tons of NOX per summer week day more than what was given in the Berks 

Ozone Maintenance Plan which would be more than offset by emission reductions from other 

sectors in the Reading Ozone Maintenance Plan, for instance, point sources. 

Table 6: Revised Socioeconomic Data for the Reading Ozone Maintenance Area Relative to 

Projected Growth in the Reading Area Maintenance Plan (2002-2009)

Surrogate Indicator for 

Growth

Actual Use 

2002

Actual Use 

2009

Actual 

Growth 

2002-2009

Maintenance 

Plan Growth 

(2002-2009)

Population 380,629 407,125 1.0696 1.0381

Total Employees 145,505 144,462 0.9928 1.0645

Total Coal Consumption (short 

tons)

274,048 178,741 0.6522 1.0481

Total Natural Gas 

Consumption (million cubic ft.)

15,972 17,094 1.0702

---

Natural Gas Boilers --- --- --- 1.0105

Natural Gas, Residential --- --- --- 1.0841

Distillate Oil Consumption

(barrels)

1,738,815 1,703,461 0.9797 1.0731
14

Table 7: NOX Affected Area Source Emission Categories in the Reading Ozone 

Maintenance Areas for Calendar Year 2009

Source 

Classification 

Code

Source Classification Description 2009 

Projected 

Emissions

2009 NOX

Emissions in 

the 

Maintenance 

Plan

2102001000 Total: All Boiler Types, Anthracite Coal, 

Industrial, Stationary Source Fuel 

Combustion

536.869 238.816

2102004000 Stationary Fuel Comb /Industrial /Distillate 

Oil /Total: Boilers and IC Engine 39.636 0.000

2102005000 Stationary Fuel Comb /Industrial /Residual 

Oil /Total: All Boiler Types 55.836 0.000

2102006000 Stationary Fuel Comb /Industrial /Natural 

Gas /Total: Boilers and IC Engine 0.000 0.000

2102007000 Stationary Fuel Comb /Industrial /Liquefied 

Petroleum Gas /Total: All Boilers

29.948 0.000

2102011000 Stationary Fuel Comb /Industrial /Kerosene 

/Total: All Boiler Types 0.628 0.000

2103001000 Total: All Boiler Types, Anthracite Coal, 

Commercial/Institutional, Stationary Source 

Fuel Combustion

69.185 129.404

2103004000 Total: Boilers and IC Engines, Distillate 

Oil, Commercial/Institutional, Stationary 

Source Fuel Combustion

44.435 85.210

2103005000 Total: All Boiler Types, Residual Oil, 

Commercial/Institutional, Stationary Source 

Fuel Combustion

5.778 11.215

2103006000 Total: Boilers and IC Engines, Natural Gas, 

Commercial/Institutional, Stationary Source 

Fuel Combustion

103.115 137.548
15

Source 

Classification 

Code

Source Classification Description 2009 

Projected 

Emissions

2009 NOX

Emissions in 

the 

Maintenance 

Plan

2103007000 Total: All Combustor Types, Liquefied 

Petroleum Gas (LPG), 

Commercial/Institutional, Stationary Source 

Fuel Combustion

3.643 0.253

2103011000 Total: All Combustor Types, Kerosene, 

Commercial/Institutional, Stationary Source 

Fuel Combustion

4.913 6.076

2104001000 Total: All Combustor Types, Anthracite 

Coal, Residential, Stationary Source Fuel 

Combustion

2.203 19.907

2104004000 Total: All Combustor Types, Distillate Oil, 

Residential, Stationary Source Fuel 

Combustion

324.421 389.084

2104006000 Total: All Combustor Types, Natural Gas, 

Residential, Stationary Source Fuel 

Combustion

223.435 226.049

2104007000 Total: All Combustor Types, Liquefied 

Petroleum Gas (LPG), Residential, 

Stationary Source Fuel Combustion

50.398 37.041

2104011000 Total: All Heater Types, Kerosene, 

Residential, Stationary Source Fuel 

Combustion

18.033 65.687

2601010000 Total, Industrial, On-site Incineration, 

Waste Disposal, Treatment, and Recovery --- 40.090

2601020000 Total, Commercial/Institutional, On-site 

Incineration, Waste Disposal, Treatment, 

and Recovery

--- 40.633

2610000100 Yard Waste - Leaf Species Unspecified, All --- 3.473
16

Source 

Classification 

Code

Source Classification Description 2009 

Projected 

Emissions

2009 NOX

Emissions in 

the 

Maintenance 

Plan

Categories, Open Burning, Waste Disposal, 

Treatment, and Recovery

2610000400 Yard Waste - Brush Species Unspecified, 

All Categories, Open Burning, Waste 

Disposal, Treatment, and Recovery

--- 2.770

2610000500 Land Clearing Debris (use 28-10-005-000 

for Loggin, All Categories, Open Burning, 

Waste Disposal, Treatment, and Recovery

79.669 101.918

2610010000 Total, Industrial, Open Burning, Waste 

Disposal, Treatment, and Recovery --- 3.715

2610020000 Total, Commercial/Institutional, Open 

Burning, Waste Disposal, Treatment, and 

Recovery

--- 5.857

2610030000 Household Waste (use 26-10-000-xxx for 

Yard Wastes, Residential, Open Burning, 

Waste Disposal, Treatment, and Recovery

--- 28.787

2810001000 Total, Forest Wildfires, Other Combustion, 

Miscellaneous Area Sources --- 0.251

2810015000 Total, Prescribed Burning for Forest 

Management, Other Combustion, 

Miscellaneous Area Sources

--- 0.483

2810030000 Total, Structure Fires, Other Combustion, 

Miscellaneous Area Sources --- 0.575

Total 2009 Annual Areas Source NOx 

Emissions 1592.145 1586.511

Total 2009 Summer Week Day Area 

Source NOx Emissions 2.305 2.239
17

Area Source Category 2018 Emissions

The Reading Ozone Maintenance Plan estimated area source sector growth using a baseline 

inventory from 2002 and growing emissions to the maintenance years of 2009 and 2018, based 

on the growth of socioeconomic activity.

7

 Data used to revise growth estimates was obtained 

from the same MARAMA inventory effort described in the point source section above. The 

effort used a baseline inventory of 20078and maintenance year inventories of 2017 and 2020.

9

 

Just as in the point source emissions, these inventory years made a direct comparison of 

emissions and growth rates difficult because the MARAMA baseline years and projected 

inventory years were too dissimilar from what was included in the Reading Ozone Maintenance 

Plan. Therefore, the emissions growth predicted to occur from 2009 to 2018 was determined 

through linear interpolation by using emission estimates for 2007 and 2020 from the new 

MARAMA inventory. Projected growth between 2009 and 2018 in the Reading Ozone 

Maintenance Plan was estimated using the 2009 and 2018 emission estimates. In Table 8, the 

revised growth projections are given. 

The growth rate predicted in the maintenance plan from 2009 to 2018 is derived by the following 

formula:

Growth Factor (2009-2018) = ((Growth Factor (2002-2018) – Growth Factor (2002-2009)) 

÷ Growth Factor (2002-2009)) + 1

A linear interpolation between the 2007 MARAMA baseline emissions and the 2020 MARAMA 

projected emissions was used to calculate emissions for the years 2009 and 2018. From these 

interpolated emissions (see equations 1 and 2 below), the projected growth between 2009 and 

2018 was calculated (see equation 3 below). Fossil fuel combustion surrogates in Table 8

represent most emissions of NOX. The surrogates for growth shown in Table 8 are used to 

predict revised growth for a large majority of emissions from area source categories in the 

Reading Ozone Maintenance Plan revision.

(1) 2009 Emissions = 2007 Emissions - (2020 Emissions – 2007 Emissions) * ((2009 –

 2007) ÷ (2020-2007))

(2) 2018 Emissions = 2007 Emissions - (2020 Emissions – 2007 Emissions) * ((2018 –

 2007) ÷ (2020-2007))

 

7

State Implementation Plan Revision: Maintenance Plan and Base Year Inventory Lancaster Eight-Hour Ozone 

Nonattainment Area, September 2006, Appendix B-1, Area Source Methodology, p.2.

8 Mid-Atlantic Regional Air Management Association, Technical Support Document for the Development of the 

2007 Emissions Inventories for Regional Air Quality Modeling in the Northeast/Mid-Atlantic Region Version 3.3, 

January 23, 2012

9 Mid-Atlantic Regional Air Management Association, Technical Support Document for the Development of the 

2017/2020 Emissions Inventories for Regional Air Quality Modeling in the Northeast/Mid-Atlantic Region Version 

3.3, January 23, 2012
18

(3) Emissions Growth (2009-2018) = ((2018 Emission – 2009 Emissions) ÷ 2009 Emissions) + 1

 

Table 8 shows that, for the most part, growth in the Reading Ozone Maintenance Plan is 

comparable to newer assumptions developed by the MARAMA inventory effort. It deserves 

mentioning that the two sets of employee growth that are compared in Table 8 were estimated 

using two different methods. It is safe to assume that, due to the severe economic downturn 

experienced from 2007 to 2009, employee growth does not approach what was predicted in the 

Reading Ozone Maintenance Plan. Emissions of NOX from area sources are dominated by fossil 

fuel combustion. Table 8 shows that the Reading Ozone Maintenance Plan under-predicted 

indicators for growth from 2009 to 2018 for population, commercial anthracite coal use, distillate 

oil, and commercial natural gas use. It is difficult to discern from comparing growth factors in 

the Maintenance Plan to updated growth estimates whether emissions were under-predicted. 

Table 9 compares estimated NOX emissions in the Reading Ozone Maintenance Plan with 

emissions predicted by the updated MARAMA inventory. The 2009 and 2018 NOX emission 

from the MARAMA inventory were linearly interpolated between a 2007 baseline inventory and 

an estimated 2020 inventory. Table 9 shows that the Reading Ozone Maintenance Plan NOX

emissions are slightly larger than the newer MARAMA inventory by about 75 tons per year. 

Therefore, updated area source NOX emissions are higher than what is inventoried in the Reading 

Ozone Maintenance Plan for 2018.

Table 8: Revised Socioeconomic Data for the Reading Ozone Maintenance Area Relative to 

the Projected Growth in the Reading Area Maintenance Plan (2009-2018)

Indicator for Growth Revised Growth in 

MARAMA Inventory 

(2009-2018)

Maintenance Plan 

Growth 

(2009-2018)

Population 1.0851 1.0472

Employees 0.9998* 1.0779

Anthracite Coal, Industrial 0.9136 0.9983

Anthracite Coal, Commercial 1.0230 0.9865

All Combuster Types, Distillate Oil, 

Residential

0.8226 0.9598

Boilers and Internal Combustion 

Engines, Natural Gas, Commercial

1.0687 1.0521

Combuster Types, Natural Gas, 

Residential

1.0188 1.0181

*The MARAMA inventory estimated growth in employment based on statewide North American Industry 

Classification System codes. NAICS codes proved too cumbersome to establish employment growth on the county 
19

level. Employment growth in Table 8 was derived from U.S Census Bureau industrial employment data and was not 

developed by MARAMA.

Table 9: Affected NOX Area Source Emission Categories in the Reading Ozone 

Maintenance Areas for Calendar Year 2018

Source 

Classification 

Code

Source Classification Description 2018 Projected 

Emissions

2018 NOX

Emissions in 

the 

Maintenance 

Plan

2102001000 Total: All Boiler Types, Anthracite 

Coal, Industrial, Stationary Source Fuel 

Combustion

490.489 238.402

2102004000 Stationary Fuel Comb /Industrial 

/Distillate Oil /Total: Boilers and IC 

Engines

37.372 0.000

2102005000 Stationary Fuel Comb /Industrial 

/Residual Oil /Total: All Boiler Types 39.392 0.000

2102006000 Stationary Fuel Comb /Industrial 

/Natural Gas /Total: Boilers and IC 

Engine

0.000 0.000

2102007000 Stationary Fuel Comb /Industrial 

/Liquefied Petroleum Gas /Total: All 

Boilers

28.045 0.000

2102011000 Stationary Fuel Comb /Industrial 

/Kerosene /Total: All Boiler Types 0.592 0.000

2103001000 Total: All Boiler Types, Anthracite 

Coal, Commercial/Institutional, 

Stationary Source Fuel Combustion

70.774 127.655

2103004000 Total: Boilers and IC Engines, Distillate 

Oil, Commercial/Institutional, 

Stationary Source Fuel Combustion

36.232 89.222

2103005000 Total: All Boiler Types, Residual Oil, 

Commercial/Institutional, Stationary 

6.119 11.553
20

Source 

Classification 

Code

Source Classification Description 2018 Projected 

Emissions

2018 NOX

Emissions in 

the 

Maintenance 

Plan

Source Fuel Combustion

2103006000 Total: Boilers and IC Engines, Natural 

Gas, Commercial/Institutional, 

Stationary Source Fuel Combustion

110.202 144.709

2103007000 Total: All Combustor Types, Liquefied 

Petroleum Gas (LPG), 

Commercial/Institutional, Stationary 

Source Fuel Combustion

3.646 0.258

2103011000 Total: All Combustor Types, Kerosene, 

Commercial/Institutional, Stationary 

Source Fuel Combustion

6.268 5.980

2104001000 Total: All Combustor Types, Anthracite 

Coal, Residential, Stationary Source 

Fuel Combustion

1.600 18.291

2104004000 Total: All Combustor Types, Distillate 

Oil, Residential, Stationary Source Fuel 

Combustion

266.855 373.431

2104006000 Total: All Combustor Types, Natural 

Gas, Residential, Stationary Source Fuel 

Combustion

227.640 230.129

2104007000 Total: All Combustor Types, Liquefied 

Petroleum Gas (LPG), Residential, 

Stationary Source Fuel Combustion

39.784 44.211

2104008001 Fireplaces: General, Wood, Residential, 

Stationary Source Fuel Combustion ---- 1.970

2104008002 Fireplaces: Insert; non-EPA certified, 

Wood, Residential, Stationary Source 

Fuel Combustion

---- 4.902
21

Source 

Classification 

Code

Source Classification Description 2018 Projected 

Emissions

2018 NOX

Emissions in 

the 

Maintenance 

Plan

2104008004 Fireplaces: Insert; EPA certified; 

catalytic, Wood, Residential, Stationary 

Source Fuel Combustion

---- 0.088

2104008010 Woodstoves: General, Wood, 

Residential, Stationary Source Fuel 

Combustion

---- 3.505

2104008030 Catalytic Woodstoves: General, Wood, 

Residential, Stationary Source Fuel 

Combustion

---- 0.063

2104008100 Stationary Fuel Comb /Residential 

/Wood /Fireplace: general 11.295 ----

2104008210 Stationary Fuel Comb /Residential 

/Wood /Woodstove: fireplace inserts; 

non6.813 ----

2104008220 Stationary Fuel Comb /Residential 

/Wood /Woodstove: fireplace inserts; 

EPA

1.697 ----

2104008230 Stationary Fuel Comb /Residential 

/Wood /Woodstove: fireplace inserts; 

EPA

0.621 ----

2104008310 Stationary Fuel Comb /Residential 

/Wood /Woodstove: freestanding, nonEPA 19.634 ----

2104008320 Stationary Fuel Comb /Residential 

/Wood /Woodstove: freestanding, EPA 

certified

4.889 ----

2104008330 Stationary Fuel Comb /Residential 

/Wood /Woodstove: freestanding, EPA 

1.791 ----
22

Source 

Classification 

Code

Source Classification Description 2018 Projected 

Emissions

2018 NOX

Emissions in 

the 

Maintenance 

Plan

certified

2104008400 Stationary Fuel Comb /Residential 

/Wood /Woodstove: pellet-fired, general 11.863 ----

2104008510 Stationary Fuel Comb /Residential 

/Wood /Furnace: Indoor, cordwoodfired1.473 ----

2104008610 Stationary Fuel Comb /Residential 

/Wood /Hydronic heater: outdoor 3.324 ----

2104009000 Stationary Fuel Comb /Residential 

/Firelog /Total: All Combustor Types 4.720 ----

2104011000 Total: All Heater Types, Kerosene, 

Residential, Stationary Source Fuel 

Combustion

17.880 69.041

2601010000 Total, Industrial, On-site Incineration, 

Waste Disposal, Treatment, and 

Recovery

---- 43.212

2601020000 Total, Commercial/Institutional, On-site 

Incineration, Waste Disposal, 

Treatment, and Recovery

---- 43.797

2610000100 Yard Waste - Leaf Species Unspecified, 

All Categories, Open Burning, Waste 

Disposal, Treatment, and Recovery

---- 3.637

2610000400 Yard Waste - Brush Species 

Unspecified, All Categories, Open 

Burning, Waste Disposal, Treatment, 

and Recovery

---- 2.900

2610000500 Land Clearing Debris (use 28-10-005-

000 for Logging, All Categories, Open 

79.669 106.724
23

Source 

Classification 

Code

Source Classification Description 2018 Projected 

Emissions

2018 NOX

Emissions in 

the 

Maintenance 

Plan

Burning, Waste Disposal, Treatment, 

and Recovery

2610010000 Total, Industrial, Open Burning, Waste 

Disposal, Treatment, and Recovery ---- 4.004

2610020000 Total, Commercial/Institutional, Open 

Burning, Waste Disposal, Treatment, 

and Recovery

---- 6.313

2610030000 Household Waste (use 26-10-000-xxx 

for Yard Wastes, Residential, Open 

Burning, Waste Disposal, Treatment, 

and Recovery

---- 30.145

2680001000 All Processes, 100% Bio-solids (e.g., 

sewage sludge, manure, mixture, 

Composting, Waste Disposal, 

Treatment, and Recovery

---- 0.000

2680002000 All Processes, Mixed Waste (e.g., a 

50:50 mixture of bio-solids an, 

Composting, Waste Disposal, 

Treatment, and Recovery

---- 0.000

2810001000 Total, Forest Wildfires, Other 

Combustion, Miscellaneous Area 

Sources

---- 0.251

2810015000 Total, Prescribed Burning for Forest 

Management, Other Combustion, 

Miscellaneous Area Sources

---- 0.483

2810030000 Total, Structure Fires, Other 

Combustion, Miscellaneous Area 

Sources

---- 0.602
24

Source 

Classification 

Code

Source Classification Description 2018 Projected 

Emissions

2018 NOX

Emissions in 

the 

Maintenance 

Plan

Total Annual Area Source NOx 

Emissions 1530.679 1605.476

Total 2018 Summer Week Day Area 

Source NOx Emissions 2.106 2.313

Nonroad Source Category Emissions

Emissions from the nonroad category are produced by many different types of vehicles and 

equipment. The EPA’s NONROAD model estimates emissions for over 200 types of equipment, 

engines and vehicles. Nonroad engines and vehicles can be used for such applications as 

construction, lawn and garden care, farming, and commercial and industrial applications. In 

addition, emissions from three types of activities including aircraft, locomotives, and commercial 

marine vessels are not estimated in the NONROAD model but are still included in the nonroad 

category. The aircraft, rail, and commercial marine emissions are estimated outside of the 

NONROAD model. In the approved Reading Ozone Maintenance Plan, the NONROAD2005 

model was used to estimate nonroad emissions. The model went through one major revision

since it was used for the maintenance plan. NONRAOD2008a is the latest version of this model. 

This new version of the model incorporated two reduction strategies that affect engines and 

vehicles in the nonroad sector:

 Diesel recreational marine standards in the 2008 final rule on locomotive and marine engines 

(73 FR 25098); and

 The October 2008 small spark ignition and spark ignition and recreational marine rule 

(73 FR 59034).

For the Reading Ozone Maintenance Plan, the Department modified files in the NONROAD 

model, when state specific data was available for emission categories such as residential lawn and 

garden.

Emissions from nonroad sources have decreased since the submittal of the Reading Ozone 

Maintenance Plan, as a result of the additional controls mentioned and other tier level controls 

that have been phased in with fleet turnover since 2004. The fleet turnover that occurs as older, 

more polluting nonroad equipment and vehicles are replaced by newer equipment and vehicles 

that meet more stringent emission standards has continued to lower emissions in the nonroad 

sector since the late 1990s and will continue to do so for the next 10 years. Emission reductions

occurred across all segments of the nonroad category, including construction equipment, farming 

equipment, locomotives, and lawn and garden equipment. Modeling runs were not completed for 
25

the nonroad emission source categories. The Department will treat nonroad emissions in the 

Reading Area as non-changing from their 2004 levels for the purpose of this SIP revision, even 

though full scale modeling runs using the NONROAD2008a would show nonroad emissions in a 

decline. 

Highway Source Category Emissions

Highway emissions were estimated by Michael Baker, Jr., Inc., who is a consultant to the 

Pennsylvania Department of Transportation. The methodology for estimating emissions of 

highway vehicles is greatly different than what was used in the Reading Ozone Maintenance Plan

because an entirely new highway emissions model is being used. Highway emissions are being 

estimated using the MOVES model instead of the Mobile6 model. With this change, a new set of 

inputs was used in the MOVES model. The method for forecasting traffic growth and vehicle 

miles travelled remains the same as that used in the Reading Ozone Maintenance Plan. Both the 

revised maintenance plan and the original maintenance plan used the Statistical Evaluation of 

Projected Traffic Growth. A revised Appendix C, Maintenance Plan Update for the Reading

(Berks County) Eight-Hour Ozone Maintenance Area: Motor Vehicle Emission Budget Revisions

Using MOVES2010a, is attached. Also attached, please find Appendix C-1, Mobile Source 

Highway Emissions Inventory – An Explanation of Methodology.

The MOVES model estimates that highway vehicle emissions increase greatly for NOX for the 

2009 and 2018 attainment years when compared to the highway vehicle emission estimates 

included in the Reading Ozone Maintenance Plan for those same years. (See Table 10). MOVES 

also increases the emission estimates of the 2004 attainment year. Since the emissions increase in 

both the attainment and maintenance years, MOVES modeled emissions, like Mobile modeled 

emissions, of highway vehicles still show a large decrease in emissions between 2004 and 2009 

and between 2004 and 2018.

Table 10: Revised Motor Vehicle Emissions Using MOVES2010a (tons/summer day)

Pollutant Original MOBILE6.2 Emissions Revised MOVES2010a Emissions

2004 2009 2018 2004 2009 2018

NOX 29.8 20.7 8.4 34.4 27.0 12.9

VOC 17.0 12.1 6.5 N/A N/A N/A