UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

Ms. Joyce Epps, Director 

Bureau of Air Quality 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

Pennsylvania Department of Enviromnental Protection 

Rachel Carson State Office Building 

P.O. Box 8468 

400 Market Street 

Harrisburg, Pennsylvania 17105-2063 

Dear Ms. Epps: 

MAR 1 3 2014 

On February 11, 2014, the Environmental Protection Agency received a revision to the 

Pennsylvania State Implementation Plan (SIP) from the Pennsylvania Department of 

Environmental Protection pertaining Air Quality Title V fees. EPA has determined that the 

submittal is administratively and technically complete, and is reviewing it to prepare a Notice of 

Proposed Rulemaking (NPR) action. 

If members of your staff have any questions, they may direct them to Ms. Gerallyn Duke, 

Office of Permits and Air Taxies, at (215) 814-2084. She is the principal contact for this 

rule making. 

Sincerely, 

~{2l;j}¥ Diana Esher, Director 

Air Protection Division 

Customer Service Hotline: 1-800-438-2474 
SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

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

 SIP Submitted by: Pennsylvania Department of Environmental Protection 

 Date Submitted: 2/11/14

 Subject: Pennsylvania Air Quality Title V Fee Amendment 

Completeness Review 

Completed by: Gerallyn Duke 

 Date Completed: 3/11/14 

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 February 11, 2014 on behalf of the 

Commonwealth of Pennsylvania from E. Christopher 

Abruzzo, Secretary, PADEP, to Shawn Garvin, 

Regional Administrator, EPA Region III

X

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

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

Check to see if the regulation, permit, order or consent decree 

has a sunset or expiration date. If so it is not acceptable as a 

SIP submission. 

2. Yes. PA submitted the PA Bulletin dated December 

14, 2013 which includes a copy of the regulations. 

Also, PA Bulletin states that final rulemaking was 

adopted September 17, 2013 and will be effective upon 

publication of Bulletin.

X

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Yes, PA has authority to revise and implement SIP 

with EPA oversight and approval. (see under Section C 

Statutory Authority)

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 

4. Yes. Final regulation was submitted as part of the 

September 17, 2013 PA Bulletin which includes a 

description of changes from proposed to final form 

rulemaking. The proposed regulation was submitted as 

part of the February 2, 2013 PA Bulletin which 

X
EPA REQUIREMENT STATE SUBMITTAL (X)

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.

indicates changes to be made to the existing approved 

plan, where applicable. Together these documents 

indicate all changes made to the existing approved plan.

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. December 14, 2013 PA Bulletin describes procedures 

followed and appears to be in accordance with 

applicable requirements. (see under Section K findings)

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. Notice of public hearing was given to the public in the 

PA Bulletin (43 PA. B577) on February 2, 2013 and in 

multiple newspapers of general circulation including 

but not limited to the Allentown Morning Call, Beaver 

County Times, Bucks County Courier Times, Delaware 

County Daily Times, Erie Times News, Greensburg 

Tribune Review, Pittsburgh Post Gazette, Reading 

Eagle, The Patriot News, The Tribune Review, and 

Wilkes-Barre Times Leader on January 31, 2013.

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. December 14, 2013 PA Bulletin describes procedures 

followed and appears to be in accordance with 

applicable requirements. (see under Section K findings)

X

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

thereto.

8. The state submittal includes a compilation of public 

comments and responses thereto.

X

 Technical Materials

1. Identification of all regulated pollutants affected by the plan. 1. All “regulated pollutants” under the Clean Air Act, 

excluding carbon monoxide and other greenhouse 

gases.

 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. Title V facilities locating in Nonattainment Areas, 

Attainment Areas, and Unclassified Areas throughout 

Pennsylvania, including Allegheny and Philadelphia 

Counties.

 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, 

3. N/A X
EPA REQUIREMENT STATE SUBMITTAL (X)

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.

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. N/A 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. N/A X

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. N/A X

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. N/A X

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. PADEP is developing an outreach initiative to educate 

and assist the public and regulated community in 

understanding the newly revised requirements and how 

to comply with them.

X

9. Special economic and technological justifications required 

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

explain why.)

9. The revised fee will result in total projected increased 

costs of $5.8 million for the regulated community in 

Pennsylvania and Allegheny and Philadelphia counties in 

FY2014 and 2015 and lower costs in future years due to 

decreasing amounts of emissions of regulated pollutants at 

major sources. Revenue to PADEP from the fee increase 

will be used solely to address the projected deficits in the 

TV Major Emission Facilities Account in the Clean Air 

X
EPA REQUIREMENT STATE SUBMITTAL (X)

Fund. Projected revenues for PADEP and the two local 

agencies will total $5.8 million in FY2014-2015 and ensure 

that the Commonwealth’s Title V air pollution control 

permit program is adequately funded for the next few years. 

(Additional funding figures, through 2019, are included 

Section G, Benefits, Costs and Compliance.)

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. N/A X