Pennsylvania Department of Environmental Protection 

-- Rachel Carson State Office Building 

P.O. Box 2063 

Harrisburg, PA 17105-2063 

December 7, 2007 

Secretary 717-787-2814 

Mr. Donald S . Welsh 

Regional Administrator 

U.S. EPA, Region III (3RAOO) 

1650 Arch Street 

Philadelphia, PA 19103-2029 

Re: State Implementation Plan Submission to Meet Obligations Under Section 110(a)(2)(D)(i) 

for the Eight-Hour Ozone and PM2.5 National Ambient Air Quality Standards (NAAQS) 

Dear Mr . Welsh: 

This letter is being submitted for approval on behalf of the Commonwealth of Pennsylvania 

as a revision to the State Implementation Plan (SIP) to meet the requirements of the federal Clean 

Air Act (CAA) related to interstate pollution transport requirements in accordance with 

Section 110(a)(2)(D)(i) .. 

In accordance ""'lith Section 110(a)(2) of the CAA and 40 CPR Section 51.102(d), the PA 

Department of Environmental Protection (DEP) held a public hearing to receive comments on the 

proposed SIP revision on October 16, 2007. The comment period closed on October 16, 2007. One 

commentator, the State of Connecticut, submitted comments on the proposed SIP revision. A 

comment/response document and proof of public notice are enclosed. 

As discussed below, this SIP revision is consistent with the August 15,2006, William T. Harnett 

Guidance Memorandum, "Guidance for SIP Submissions to Meet Current Outstanding Obligations 

Under Section 110(a)(2)(D)(i) for the Eight-Hour Ozone and PM2.

5 NAAQS" (Harnett Memorandum). 

Section 110(a)(l) of the CAA provides that states must adopt and submit SIP revisions to the 

EPA within three years after the promulgation of a new or revised NAAQS, meeting the provisions 

of Section 110(a)(2) as applicable. Therefore, SIP revisions addressing the requirements related to 

Section 110(a)(2) for the eight-hour ozone and the PM2.5 NAAQS were due by statute no later than. 

July 2000. Due to the litigation of both the eight-hour ozone and the PM2.

5 NAAQS, the 

Commonwealth did not submit a SIP revision to satisfy the Section 110(a)(2) requirements by July 

2000. EPA published a finding of failure to submit in the Federal Register on April 25, 2005, with 

an effective date of May 25, 2005. The Clean Air Interstate Rule (CAIR) Federal Implementation 

Plan (FIP) promulgated by EPA on April 28, 2006 (71 FR 25328), has partially satisfied this 

requirement, and the additional measures outlined herein will fully satisfy the pollutant transport 

provisions in Section 110 of the CAA. The August 15, 2006, Harnett Memorandum provides 

guidance to the states for meeting the 110(a)(2)(D)(i) requirements. 

An Equal Opportunity Employer www.dep.state.pa.us 

W 

Printed on Recycled Paper \6<9 
Mr. Donald S. Welsh - 2- December 7, 2007 

The "good neighbor" provisions of Section 110(a)(2)(D)(i) of the Act requires the 

Commonwealth to submit a SIP revision that contains adequate provisions prohibiting any source or 

other type of emissions activity within the state from emitting any air pollutant in amounts which 

will: 

(I) contribute significantly to nonattainment in, or interfere with maintenance by, any 

other state with respect to any national primary or secondary air quality standard, or 

(II) interfere with measures required to be included in the applicable implementation 

plan for any other state to prevent significant deterioration of air quality or to protect 

visibility. 

Interstate Transport Requirement: 

• On May 12,2005, EPA promulgated the CAIR, which determined that 28 states (including 

Pennsylvania) and the District of Columbia contribute significantly to non attainment of the 

eight-hour ozone and PM2.

5 NAAQS (70 FR 25162). The CAIR requires upwind states to 

revise their SIPs to include control measures to reduce nitrogen oxide and sulfur dioxide 

emissions to address interstate transport of ozone and PM2.5 precursor emissions. 

Subsequently, EPA promulgated FIPs on April 28, 2006, for CAIR-covered states to ensure 

that the reductions are achieved according to the prescribed deadlines (71 FR 25328). 

• Electric Generating Units (EGUs) in the Commonwealth are covered by the CAIR FIP for 

annual and seasonal ozone and for sulfur dioxide precursor emissions. The Harnett 

Memorandum advises that states covered by CA1R can comply with the 

Section 110(a)(2)(D)(i) obligations relating to "significant contribution" and "interference 

with maintenance" requirements by complying with the CAIR requirements. The Harnett 

Memorandum further advises that states within the CAIR-covered region need not submit a 

separate SIP revision to satisfy the Section 110(a)(2)(D)(i) requirements provided that they 

submit a SIP revision to satisfy CAIR. EGUs in Pennsylvania will continue to be regulated 

under the FIP until EPA approves Pennsylvania's CAIR final-form regulation as a separate 

element of the SIP. 

Nonattainment New Source Review (NNSR) and Prevention of Significant Deterioration (PSD) 

Requirements: 

With respect to NNSR and PSD, the Harnett Memorandum advises that a state may fulfill its 

Section 110(a)(2)(D)(i) requirements by confirming that: 

1. Major stationary sources for eight-hour ozone and PM2.5 are currently subject to PSD and 

NNSR permitting programs and that states are on track to meet the June 15,2007, deadline 

for sUbmitting SIPs to address the Phase II ozone implementation rule requirements. 

o The Commonwealth confirms that on August 9, 2007, it submitted a SIP revision to 

EP A for approval that meets the requirements of the Phase II Ozone Implementation 
Mr. Donald S. Welsh - 3 - December 7, 2007 

Rule for NNSR. The federal PSD provisions are incorporated by reference in their 

entirety in the Pennsylvania Code and codified as a SIP revision in 40 CFR 52.2020. 

Therefore, a PSD SIP revision to implement the Phase II rule was not required. 

2. Major sources are subject to PSD and NNSR permitting programs implemented in 

accordance with EPA's interim guidance calling for use of PMlO as a surrogate for PM2.5 

related to the PSD and NNSR program requirements. DEP implements and enforces the PSD 

and NNSR in all areas of the Commonwealth, except Philadelphia and Allegheny counties; 

those counties administer and enforce· approved local air pollution control programs under 

Section 12 of the Pennsylvania Air Pollution Control Act. 

o The Commonwealth confirms that it is meeting the requirement for the use of PMlO as 

a surrogate for PM2.5 in the psI> and NNSR programs. 

Visibility Requirement: 

The EPA's guidance memorandum advises that the Section 110(a)(2)(D)(i)requirement 

related to protection of visibility is deferred until such time as the Commonwealth submits its 

Regional Haze SIP. The Commonwealth's Regional Haze SIP revision will assess whether there is 

interference with measures required to be included in the applicable implementation plan for any 

other state to protect visibility. 

Conclusion: 

The Commonwealth confirms that it meets requirements of Section 110(a)(2)(D)(i) of the 

Act for the eight-hour ozone and the PM2.5 NAAQS and does not significantly contribute to 

. nonattainment or interference with maintenance of the NAAQS in another state. 

If you have any questions regarding this submittal or require additional information, please 

contact Joyce E. Epps, Director, Bureau of Air Quality, bye-mail atjeepps@state.pa.us or by telephone 

at 717-787-9702. 

Sincerely, 

Enclosure 
Mr. Donald S . Welsh 

- 4- December 7, 2007 

bee: WARM 

J. Epps 

A. Shulman 

ARM Reading File