SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

(in accordance with 40 CFR Part 51 - App. V)

SIP Submitted by: Pennsylvania Department of Environmental Protection

Date Submitted: March 19, 2014

Subject: Update of the Motor Vehicle Emissions Budgets for the Allentown-Bethlehem-Easton Eight-Hour Ozone 

Maintenance Area

Completeness Review 

Completed by: Asrah Khadr 

Date Completed: 3/24/14

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal letter of submittal from the Governor or his 

designee, requesting EPA approval of the plan or revision 

thereof.

1. Letter dated March 7, 2014 from E. Christopher Abruzzo,

Secretary, Pennsylvania Department of Environmental 

Protection to Shawn M. Garvin, Regional Administrator.

X

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, consent

agreement in final form. That evidence shall include the date 

of adoption or final issuance as well as the effective date of the 

plan, if different from the adoption/issuance date.

2. Letter dated March 7, 2014 from E. Christopher Abruzzo, 

Secretary, Pennsylvania Department of Environmental 

Protection to Shawn M. Garvin, Regional Administrator stating 

that the Pennsylvania State Implementation Plan (SIP) was 

revised.

X

3. Evidence that the State has the necessary legal authority

under State law to adopt and implement the plan.

3. E. Christopher Abruzzo, Secretary, Pennsylvania 

Department of Environmental Protection has delegated 

authority to adopt and implement the Pennsylvania SIP 

revision. 

X
EPA REQUIREMENT STATE SUBMITTAL (X)

4. A copy of actual regulation, or document submitted for 

approval and incorporation by reference into the plan, including 

indication of the changes made to the existing approved plan, 

where applicable. The submittal shall be a copy of the official 

State regulation/document signed, stamped, dated by the 

appropriate State official indicating that it is fully enforceable 

by the State. The effective date of the regulation/document 

shall, whenever possible, be indicated in the document itself.

4. Documents entitled, “State Implementation Plan Revision: 

NOx Motor Vehicle Budget Revisions Based on the 

MOVES2010a Model,” as well as a letter dated March 7, 2014 

from E. Christopher Abruzzo, Secretary, Pennsylvania 

Department of Environmental Protection to Shawn M. Garvin, 

Regional Administrator indicating revision to Pennsylvania 

SIP. 

X

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in conducting 

and completing the adoption/issuance of the plan.

5. The submittal was developed in accordance with Section 

175A(b) of the Clean Air Act. 

X

6. Evidence that public notice was given of the proposed 

change consistent with procedures approved by EPA, including 

the date of publication of such notice.

6. Publication invoice for publication of public notice in the 

Allentown Morning Call on December 13, 2013. A copy of the 

public notice as it appeared in the Allentown Morning Call. 

X

7. Certification that public hearings were held in accordance 

with the information provided in the public notice and the 

State's laws and constitution, if applicable.

7. No public hearing was requested. X

8. Compilation of public comments and the State's response 

thereto.

8. N/A N/A
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. Ozone. X

2. Identification of the locations of affected sources including 

the EPA attainment/nonattainment designation of the locations 

and the status of the attainment plan for the affected area(s).

2. The Allentown-Bethlehem-Easton Eight-Hour Ozone 

Maintenance Area. The area currently has a maintenance plan. 

X

 

3. Quantification of the changes in plan allowable emissions

from the affected sources; estimates of changes in current 

actual emissions from affected sources or, where appropriate, 

quantification of changes in actual emissions from affected 

sources through calculations of the differences between certain 

baseline levels and allowable emissions anticipated as a result 

of the revision.

3. The SIP revision provides motor vehicle emissions budgets 

developed by MOVES2010a. The results provided are 

different than the MVEBs developed without the use of 

MOVES2010a. The MVEBs are clearly quantified. 

X

4. The State's demonstration that the national ambient air 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved 

and implemented. 

4. The SIP revision provides motor vehicle emissions budgets 

developed by MOVES2010a. The results provided are 

different than the MVEBs developed without the use of 

MOVES2010a, but the difference is not due to any changes in 

control strategies or other applicable requirements. It is due to 

the more advanced calculation mechanisms of the 

MOVES2010a model. 

X

5. Modeling information required to support the proposed 

revision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, 

justification for use of offsite data (where used), modes of 

models used, assumptions, and other information relevant to 

the determination of adequacy of the modeling analysis.

5. MOVES2010a input and output files have been provided as 

well as the run specifications and the methodology and sources 

of data utilized to conduct the modeling. 

X

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Not applicable. 

N/A

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. Not applicable. 

N/A
EPA REQUIREMENT STATE SUBMITTAL (X)

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Not applicable. N/A

9. Special economic and technological justifications required 

by any applicable EPA policies. (If a policy is not appropriate, 

explain why.)

9. Not applicable. N/A

10. A Section 107 request must be accompanied by a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.

10. Not applicable because this is not a section 107 request. N/A