pennsyLvania 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

SECRETARY 

April 28, 2014 

Mr. Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street, (Mail Code: 3RAOO) 

Philadelphia, PA 19103-2029 

~,,r::, 

Dear Mr,/Garvin: 

I am pleased to submit to you a request to redesignate the Lancaster 1997 annual and 

2006 24-hour fine particulate matter (PM2.5) nonattainment area to attainment, and a revision to 

the State Implementation Plan (SIP) including a Maintenance Plan demonstrating that the area 

can maintain the 1997 PM2.5 National Ambient Air Quality Standard (NAAQS) for at least ten 

years after redesignation, as required under Section 175A(b) of the Clean Air Act (CAA). The 

SIP submittal also includes the comprehensive emissions inventory required under 

Section 172( c )(3) ofthe CAA. 

The Department of Environmental Protection (DEP) opened a 30-day public comment period on 

March 8, 2014, on the proposed redesignation request, maintenance plan and comprehensive 

emissions inventory for the area and received written comments from one person. The public 

hearing scheduled for April 10, 2014, was cancelled because no one expressed interest in 

presenting testimony or attending the hearing. 

The following documents are enclosed for your approval: 

1. Request for Redesignation to attainment; 

2. Maintenance Plan State Implementation Plan revision, which includes the 

comprehensive emissions inventory and a Motor Vehicle Emissions Budget for 

the purposes of transportation conformity; 

3. Certification of public participation activities; and 

4. Comment and Response Document. 

A paper copy of the documents and a disc containing an electronic copy of the documents for the 

area are enclosed. I certifY that the electronic files are exact duplicates of the hard copies. 

The Commonwealth followed all ofthe applicable procedural requirements of the State's laws 

and constitution in conducting and completing the issuance of the SIP revision. 

Rachel Carson State Office Building I P.O. Box 2063 I Harrisburg, PA 17105-2063 

717.787.2814 01;, Printed on Recycled Paper \OQ www.depweb.state.pa.us 
Mr. Shawn M. Garvin - 2 - April 28, 2014 

Thank you in advance for the expeditious processing of the redesignation request and SIP 

revision. Should you have any questions or need additional infonnation, please contact 

Joyce E. Epps, Director, Bureau of Air Quality, bye-mail at jeepps@pa.gov or by telephone at 

717.787.9702. 

Sincerely, 

E. Christopher Abruzzo 

Secretary 

Enclosures 
Commonwealth of Pennsylvania

State Implementation Plan Revision: 

Maintenance Plan and 

Comprehensive Inventory 

Lancaster Nonattainment Area

1997 and 2006 Fine Particulate Matter

National Ambient Air Quality Standards

May 2014

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

www.dep.state.pa.us
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Table of Contents

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

A. Health and Environmental Effects of Fine Particulate Matter (PM2.5)....................1

B. Sources of PM2.5 and Precursor Pollutants of Concern............................................2

C. Purpose and Structure of this SIP Revision .............................................................5

D. Public Participation..................................................................................................9

II. Emission Inventories............................................................................................................9

A. Emissions Inventory Methodology for Baseline Year (2002) and 

Attainment Year (2007) Emissions........................................................................10

B. Baseline Year (2002) Emissions............................................................................15

C. Attainment Year (2007) Annual Emissions (Tons per Year) ................................15

D. Growth Projection Methodologies for 2017 and 2025 ..........................................16

E. Interim Year (2017) Emissions..............................................................................19

F. Maintenance Year (2025) Emissions.....................................................................20

G. Maintenance Plan Emissions Test .........................................................................20

III. Permanent and Enforceable Control Measures..................................................................22

A. Permanent and Enforceable Control Measures......................................................22

1. Stationary Point Sources............................................................................26

2. Highway Vehicle Sources..........................................................................31

3. Nonroad Sources........................................................................................34

4. Stationary Area Sources.............................................................................35

B. Motor Vehicle Emission Budgets for Transportation Conformity ........................36

IV. Ambient Air Quality Monitoring Network........................................................................39

V. Verification of Continued Attainment ...............................................................................39

VI. Contingency Measures.......................................................................................................39

Table of Tables

Table II-1: Lancaster Area 2002 Annual Emissions (Tons per Year) ......................................... 15

Table II-2: Lancaster Area 2007 Annual Emissions (Tons per Year) ......................................... 16

Table II-3: Lancaster Area VMT (Miles) and Vehicle Emissions (Tons per Year).................... 18

Table II-4: Lancaster Area Projected 2017 Emissions (Tons per Year)...................................... 19

Table II-5: Lancaster Area Projected 2025 Emissions (Tons per Year)...................................... 20

Table II-6: Lancaster Area NH3 Emissions and PM2.5 Design Values........................................ 21

Table II-7: Lancaster Area Maintenance Emissions Test............................................................ 22

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

Measures................................................................................................................... 25

Table III-2: Motor Vehicle Emission Budgets (Tons per Year).................................................. 37

Table III-3: Comparison of Safety Margin to Total Anticipated Emission Reductions in 

2017 and 2025 .......................................................................................................... 37

Table III-4: Comparison of 2025 On-Road Mobile VOC, NH3, and SO2 Emissions to the 

Total Projected 2025 Inventory ................................................................................ 38
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APPENDICES

APPENDIX A: STATIONARY POINT SOURCES

A-1 Methodology – Preparation of Pennsylvania Point Source Inventories and 

Instructions for Completing the Annual Emissions Reporting Forms

A-2 Facility Annual Emissions – 2002

A-3 Facility Annual Emissions – 2007, 2017, 2025

A-4 Banked Emissions Reduction Credits

APPENDIX B: STATIONARY AREA SOURCES 

B-1 Pennsylvania 2002 Area Source Criteria Air Pollutant Emission Estimation 

Methods (EH Pechan, Feb. 2004)

B-2 Pennsylvania 2007 Area Source Criteria Air Pollutant Emission Estimation 

Methods (Dec. 2009) 

B-3 Area Source Annual Emissions – 2002

B-4 Area Source Annual Emissions – 2007, 2017, 2025

APPENDIX C: REGIONAL EMISSIONS INVENTORY AND PROJECTION

METHODOLOGY

C-1 Technical Support Document for the Development of the 2007Emission 

Inventories for Regional Air Quality Modeling in the Northeast/Mid-Atlantic 

Region Version 3.3 (AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012)

C-2 Technical Support Document for the Development of the 2017/2020 Emission 

Inventories for Regional Air Quality Modeling in the Northeast/Mid-Atlantic 

Region Version 3.3 (AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012)

C-3 Technical Support Document for the Development of the 2025 Emission 

Inventory for PM Nonattainment Counties in the MANE-VU Region 

Version 3.3 Rev. 1 (AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012)

C-4 Technical Memo Emission Factors for Condensable PM

APPENDIX D: HIGHWAY VEHICLE SOURCES INVENTORY INFORMATION

D-1 Mobile Source Highway Emissions Inventory – An Explanation of 

Methodology

D-2 Highway Emissions Estimates – 2002, 2007, 2017, 2025

D-3 MOVES Input Parameter Summary

D-4 MOVES Input and Output Files

APPENDIX E: NONROAD SOURCES

E-1 Emissions Estimation Methodology – 2002

E-2 Nonroad Source Emissions – 2002

E-3 Nonroad Source Emissions – 2007, 2017, 2025
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I. INTRODUCTION AND OVERVIEW

A. Health and Environmental Effects of Fine Particulate Matter (PM2.5)

Particulate matter (PM) is a mixture of microscopic solids and liquid droplets 

suspended in air that include: acids (such as nitrates and sulfates), organic 

chemicals, metals, soil or dust particles and allergens (such as fragments of pollen 

or mold spores). Fine particle pollution or PM2.5 describes particulate matter that 

is less than or equal to 2.5 micrometers (μm) in diameter, approximately 1/30th 

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

penetrate deeply into the lungs.

Health studies have shown a significant association between exposure to fine 

particles and premature death from heart or lung disease. Fine particles can 

aggravate heart and lung diseases and have been linked to effects such as 

cardiovascular symptoms, cardiac arrhythmias, heart attacks, respiratory 

symptoms, asthma attacks, and bronchitis. These effects can result in increased 

hospital admissions, emergency room visits, absences from school or work, and 

restricted activity days. Individuals that may be particularly sensitive to fine 

particle exposure include people with heart or lung disease, older adults, and 

children. The article, “Fine-Particulate Air Pollution and Life Expectancy in the 

United States” by C. Arden Pope, III, et al. published January 22, 2009, in the

New England Journal of Medicine evaluated the role PM2.5 reductions occurring

in the 1980s and 1990s had on the increased life expectancy observed over that 

period. The study found that a reduction of 10 micrograms per cubic meter 

(μg/m3) of PM2.5 was associated with an average increase in life expectancy of 

7.3 months.

PM2.5 has significant environmental impacts, including acid rain and stream 

eutrophication. PM2.5 also affects visibility (regional haze) through the scattering 

and absorption of light. Fine particles, similar in size to the wavelength of light, 

are most efficient, per unit of mass, at reducing visibility. Soiling and materials 

damage can also be caused by PM2.5 in the air.

The United States Environmental Protection Agency (EPA) promulgated PM2.5

national ambient air quality standards (NAAQS) in 1997 after evaluating 

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

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

standard of 15.0 μg/m3, based on the 3-year average of annual mean PM2.5

concentrations. The EPA also established a primary and secondary 24-hour 

standard of 65 μg/m3determined by the 3-year average of the 98th percentile of 

24-hour concentrations. In 2006, the EPA promulgated a revised 24-hour PM2.5

standard of 35 μg/m3determined by the 3-year average of the 98th percentile of 

24-hour concentrations. The annual standard was not revised (71 FR 61144

(October 17, 2006)).
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On December 17, 2004, the EPA issued air quality designations for the 1997 

PM2.5 standard based on 2001-2003 air quality monitoring data. The final 

designations were published in the Federal Register on January 5, 2005 

(70 FR 944). The designations became effective on April 5, 2005. The EPA 

designated eight areas comprised of all or portions of 21 counties in Pennsylvania 

as PM2.5 nonattainment areas. On April 5, 2005, the EPA published a 

supplemental notice changing the designation of certain areas from nonattainment 

to attainment based on newly available PM2.5 quality-assured, and certified air 

quality data from 2002-2004. The EPA supplemental notice was published in the 

Federal Register on April 14, 2005 (70 FR 19844). Mercer County was the only 

county in the Commonwealth of Pennsylvania (Commonwealth or Pennsylvania) 

for which EPA changed the designation for the area from nonattainment to 

attainment based on the 2002-2004 air quality data.

The Lancaster Area, consisting of Lancaster County, was one of eight areas in

Pennsylvania designated by the EPA as nonattainment for the 1997 PM2.5

NAAQS. The Lancaster Area was designated nonattainment because the area

violated the 1997 annual PM2.5 standard of 15.0 μg/m3based on 2001-2003 

monitoring data. The Lancaster Area did not violate the 1997 24-hour PM2.5

NAAQS of 65 μg/m3.

On October 8, 2009, the EPA promulgated air quality designations for the 2006 

PM2.5 standard based on 2006-2008 air quality monitoring data. The final 

designations were published in the Federal Register on November 13, 2009

(74 FR 58688). The EPA designated seven areas comprised of all or portions of 

22 counties in Pennsylvania as PM2.5 nonattainment areas. The designations 

became effective on December 14, 2009. 

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

EPA as nonattainment for the 2006 PM2.5 NAAQS. The Lancaster Area was 

designated nonattainment because the area violated the 2006 24-hour PM2.5

standard of 35.0 μg/m3 based on 2006-2008 monitoring data. 

B. Sources of PM2.5 and Precursor Pollutants of Concern

Fine particle pollution can be emitted directly or formed secondarily in the 

atmosphere. PM2.5 emitted directly into the air in a stable solid or liquid chemical 

form (including PM2.5 that is formed near its source by condensation) is referred 

to as “primary” PM2.5. PM2.5 is formed by chemical reactions of gases in the 

atmosphere is considered to be “secondary” PM2.5. The chemical composition of

PM2.5 in an area depends on the mix of emissions, location, time of year, and 

weather. The chemical composition of PM2.5 can include sulfate, nitrate, 

ammonium, particle-bound water, black (elemental) carbon, a great variety of 

organic compounds, and miscellaneous inorganic material, such as dust and 

metals.
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Primary PM2.5 includes soot from diesel engines, condensed organic material 

from incomplete combustion and compounds from condensation during 

combustion or smelting.

The atmospheric chemistry of PM2.5 formation is complex. Formation of 

secondary PM2.5 depends on numerous factors, including the relative 

concentration of precursors, atmospheric conditions and the interactions of 

precursors with each other and with other particles, clouds or fog. The 

contribution of different precursors will vary by location.

The principal forms of secondary PM2.5 include:

 Sulfates, formed from emissions of sulfur dioxide (SO2) from power 

plants and industrial facilities;

 Nitrates, formed from emissions of nitrogen oxides (NOX) from power 

plants, vehicles, and other combustion sources;

 Ammonium, formed primarily from emissions of ammonia (NH3) from 

animal operations; and

 Secondary organic aerosol, formed from emissions of volatile organic 

compounds (VOCs) from incomplete combustion and evaporation from a 

wide diversity of sources.

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

formation, the EPA recognizes that effective control measures for PM2.5 will vary 

among nonattainment areas. This recognition was reflected in EPA’s 

“Implementation Guidance for the 2006 24-Hour Fine Particle National Ambient 

Air Quality Standard,” Office of Air Quality Planning and Standards, EPA, 

March 2, 2012 (“Implementation Guidance for the 2006 24-Hour PM2.5

NAAQS”). In the Implementation Guidance for the 2006 PM2.5 NAAQS, EPA 

adopted the framework and policy approach the agency espoused in its 

implementation rule for the 1997 PM2.5 NAAQS, known as the “Clean Air Fine 

Particle Implementation Rule” (72 FR 20586; April 25, 2007) (“Implementation 

Rule for the 1997 PM2.5 NAAQS”). 

In its Implementation Rule for the 1997 PM2.5 NAAQS, EPA had established 

general presumptive policies for assessing which PM2.5 precursors should be 

evaluated for possible controls.1 In that earlier rule, the EPA required states to 

evaluate control measures for SO2 and primary PM2.5 in all locations. The EPA 

required states to evaluate control measures for NOX unless a technical 

demonstration is made to show that NOX emissions from sources in the state do 

not significantly contribute to PM2.5 concentrations in the nonattainment area. 

The EPA required states to evaluate measures for VOC and NH3 only if a 

 

1 The EPA’s definition of “PM2.5 attainment plan precursor” can be found in 40 CFR Section 51.1000, which reads: 

“PM2.5 attainment plan precursor means S02 and those other PM2.5 precursors emitted by sources in the State which 

the State must evaluate for emission reduction measures to be included in its PM2.5 nonattainment area or 

maintenance area plan.”
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technical demonstration is made to show VOC or NH3 emissions significantly 

contribute to PM2.5 in the nonattainment area. 

The EPA reaffirmed the appropriateness of these presumptions in its 

Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS.2 Meanwhile, the 

U.S. Court of Appeals for the D.C. Circuit was considering a challenge to the 

Implementation Rule for the 1997 PM2.5 NAAQS, in Natural Resources Defense 

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

ruling in that case. The Court granted the petitions for review and remanded the 

case to EPA to re-promulgate the rule pursuant to Subpart 4 of Part D of the Clean 

Air Act, rather than implementing it under Subpart 1, as EPA had done 

(706 F.3d 428 at 437(DC Cir. 2013)).

Shortly thereafter, EPA withdrew its Implementation Guidance for the 2006 

24-hour PM2.5 NAAQS. According to EPA’s June, 2013 withdrawal 

memorandum (see second page of memorandum)3, EPA withdrew the guidance in 

response to the Court’s decision in Natural Resources Defense Council v. EPA, 

No. 08-1250.

This maintenance plan demonstrates maintenance of the standards consistent with 

the Court’s ruling. In general, the Court’s decision (for the 1997 NAAQS and to 

the extent it would be extrapolated to the 2006 24-Hour PM2.5 NAAQS) could 

affect an area’s nonattainment classification, certain deadlines, and the impacts of 

failing to attain timely, and could impose a deadline for implementation of 

reasonably available and best available control measures (706 F.3d at 436, n. 6).

Since the Lancaster Area is already attaining the 1997 annual and 2006 24-Hour 

PM2.5 NAAQS, however, those considerations are not relevant for this 

maintenance plan. The court noted that PM2.5 precursors, including ammonia and 

VOCs, are presumptively regulated in PM2.5 nonattainment areas under Subpart 4, 

pointing specifically to section 189(e), which applies to control of major 

stationary sources of PM10 [the court stated that PM10 includes PM2.5 throughout 

Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to CAA 

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

PM10 also apply to major stationary sources of PM10 precursors, except where the 

Administrator determines that major stationary sources do not contribute 

significantly to PM10 levels that exceed the standard in the area; Section 189(e) 

also requires EPA to issue guidelines regarding the application of Subsection (e). 

Pennsylvania assessed emissions of PM2.5, SO2, NOX, VOC and NH3 for the 

maintenance demonstration. 

 

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

2006 24-hour PM2.5 NAAQS as well.” See, Implementation Guidance for the 2006 24-hour PM2.5 NAAQS, page 3, 

footnote 8.

3 “Withdrawal of Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air 

Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013.
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This State Implementation Plan (SIP) revision provides emissions information for 

all pollutants (PM10, PM2.5, SO2, NOX, VOC and NH3), as required by EPA’s 

guidance entitled, “Emissions Inventory Guidance for Implementation of Ozone 

and Particulate Matter National Ambient Air Quality Standards (NAAQS) and 

Regional Haze. Regulations.”4

C. Purpose and Structure of this SIP Revision

In December 2004, after consultation with states and receipt of public input, the 

EPA designated eight areas in Pennsylvania, comprising all or parts of 

21 Pennsylvania counties, as PM2.5 nonattainment areas for 1997 PM2.5 NAAQS

based on 2001-2003 air quality monitoring data. Under Section 110 of the Clean 

Air Act (CAA), Pennsylvania is required to develop a revision to the SIP to 

demonstrate how the Lancaster Area will attain the 1997 standard by April 2010, 

meet emission reduction requirements in the CAA and ensure that in the event of 

a future violation or failure to meet emission reduction milestones, the area is 

brought back to attainment as quickly as possible.

However, on September 25, 2009, the EPA determined that the Lancaster Area 

had attained the 1997 PM2.5 NAAQS based on quality assured, quality controlled 

and certified ambient air monitoring data that show the area had monitored 

attainment based on 2006-2008 data (“Clean Data Determination”)

(74 FR 48863). This final action suspended the requirements for this area to 

submit an attainment demonstration and associated reasonably available control 

measures, reasonable further progress plans, contingency measures and other 

planning SIP revisions related to the attainment of the 1997 PM2.5 NAAQS for so 

long as the area continues to attain the 1997 PM2.5 NAAQS5.

On November 13, 2009 (74 FR 58688), after consultation with states and receipt 

of public input, the EPA designated seven areas in Pennsylvania, comprising all 

or parts of 22 Pennsylvania counties, as 2006 PM2.5 NAAQS nonattainment areas 

based on 2006-2008 air quality monitoring data. Under Section 110 of the Clean 

Air Act (CAA), Pennsylvania is required to develop a revision to the SIP to 

demonstrate how the Lancaster Area will attain the standard by December 2014, 

meet emission reduction requirements in the CAA and ensure that in the event of 

a future violation or failure to meet emission reduction milestones, the area is 

brought back to attainment as quickly as possible.

However, on March 29, 2012, the EPA determined that the Lancaster Area had 

attained the 2006 PM2.5 NAAQS based on quality assured, quality controlled and 

certified ambient air monitoring data that show the area had monitored attainment 

 

4 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations – EPA-454/R-05-001, August, 2005, updated November, 2005.

5 The EPA followed this action on July 29, 2011 (76 FR 45424) with a statutorily required determination under 

Section 179(c) of the CAA, that the Lancaster Area attained the 1997 PM2.5 NAAQS by the applicable attainment 

date of April 5, 2010. EPA based this determination on complete, quality assured, and certified ambient air 

monitoring data that show the area monitored attainment for the 2007-2009 monitoring period.
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based on 2008-2010 data (“Clean Data Determination”) (77 FR 18922). This 

final action suspended the requirements for this area to submit an attainment 

demonstration and associated reasonably available control measures, reasonable 

further progress plans, contingency measures and other planning SIP revisions 

related to the attainment of the 2006 PM2.5 NAAQS for so long as the area 

continues to attain the 2006 PM2.5 NAAQS.

EPA’s determinations of attainment and the Clean Data Determinations did not 

“redesignate” the area as “attainment.” The Lancaster Area remains a designated 

nonattainment area for the 1997 and 2006 PM2.5 NAAQS until the 

Commonwealth submits, and EPA approves, a Request for Redesignation and a 

Maintenance Plan showing the area can maintain the standards for at least 

10 years after redesignation. Nonattainment new source review continues to 

apply until EPA redesignates the area as attainment (72 FR 20603).

Transportation conformity and general conformity also apply; they will continue 

to apply to the area even after redesignation by EPA as attainment. The Clean 

Data Determinations do not suspend the CAA Section 172(c)(3) requirement to 

establish a comprehensive inventory for all pollutants considered potential 

precursors to PM2.5 and for direct emissions of PM2.5.

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

1997 and 2006 PM2.5 NAAQS and the 2007 comprehensive inventory required

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

of direct PM2.5, PM10 (particles less than 10 microns in diameter), SO2, NOX, 

VOC and NH3. The 2007 comprehensive inventory also serves as the attainment 

year inventory representing a level of emissions sufficient for the Lancaster Area 

to attain the 1997 and 2006 PM2.5 NAAQS.

To demonstrate maintenance of the PM2.5 NAAQS for this area, Pennsylvania is

showing that the future emissions of PM2.5 and its precursors will remain at levels 

that will provide for maintenance of the PM2.5 NAAQS for at least 10 years after 

redesignation, taking economic, population and travel growth into account (See, 

EPA, “Procedures for Processing Requests to Redesignate Areas to Attainment,” 

John Calcagni (September 4, 1992) (1992 Calcagni Memo)). This Maintenance 

Plan contains an attainment year inventory for 2007 and demonstrates that 

emissions will not be greater in 2017 and 2025 than the attainment year, with the 

exception of NH3. The projected increase in NH3 emissions does not present a 

concern for maintaining the NAAQS because PM2.5, SO2, NOX and VOC 

emissions are all projected to continue to decline in the Lancaster Area. The plan 

describes emission reduction measures that have been previously adopted; it 

neither changes existing measures nor adopts additional measures. The plan 

indicates how Maintenance Plan progress will be tracked and identifies measures

that would be available to promptly correct any NAAQS violation.

Section 107(d)(3)(E) of the CAA requires that a Maintenance Plan be fully 

approved by the EPA before an area can be redesignated as attainment. The 
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Maintenance Plan is considered a SIP revision under Section 110 of the CAA. A 

state may submit the Request for Redesignation and the Maintenance Plan at the 

same time and federal rulemaking on both may proceed on a parallel track.

Pursuant to the requirements of Section 107(d)(3)(E) of the CAA, the Request for 

Redesignation submitted concurrently with this Maintenance Plan indicates that 

the Lancaster Area has attained the NAAQS and that attainment was due to 

permanent and enforceable control measures. The Request for Redesignation also 

demonstrates that the Commonwealth has met all of the regulatory and planning 

requirements under the CAA for the Lancaster Area that were due before the date 

of the Request for Redesignation.

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

ensure maintenance of the NAAQS:

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

network in order to verify the area’s attainment status (addressed in 

Section IV of this Plan);

 The state should develop an emissions inventory to identify the level of 

emissions sufficient to attain the NAAQS. This “attainment year 

inventory” was developed for 2007;

 The state may demonstrate maintenance by showing that the future 

emissions of a pollutant or its precursors will not exceed the level of the 

attainment inventory over at least 10 years following redesignation, taking 

economic growth into account. The Pennsylvania Department of 

Environmental Protection (DEP or Department) has developed emission 

inventories for 2025 and for 2017, an interim year between the attainment 

year and the maintenance year (addressed in Section II of this Plan);

 The Commonwealth should ensure that it has the legal authority to 

implement and enforce all measures necessary to attain and maintain the 

NAAQS, and indicate how maintenance plan progress will be tracked 

(addressed in Sections III and V of this Plan and the Request for 

Redesignation); and

 The Commonwealth should identify measures that would be available to 

promptly correct any NAAQS violation (addressed in Section VI of this 

Plan).

This document describes how the Commonwealth will meet those criteria.

This Maintenance Plan demonstrates that the 1997 and 2006 PM2.5 NAAQS will 

be maintained for at least 10 years after redesignation of the Lancaster Area to 

attainment of the standards. The Maintenance Plan shows that emission levels of 
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PM2.5 and its precursors over the 10 years following redesignation remain at levels 

that will provide for maintenance of the PM2.5 NAAQS, even considering growth 

in population and vehicle miles traveled.

This Maintenance Plan also shows that the following state and federal programs 

will ensure the continuing decline of PM2.5, SO2, NOX and VOC emissions:

 The Clean Air Interstate Rule (CAIR);

 Emission limits for large industrial boilers;

 State regulation of cement kilns, large stationary internal combustion 

engines, and smaller sources of NOX;

 State regulations incorporating by reference the federal Prevention of 

Significant Deterioration (PSD) regulations;

 State requirements for Best Available Technology (BAT);

 State regulation of the sulfur content of fuel oil;

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

solvents;

 The Pennsylvania and federal new motor vehicle emission control 

programs for passenger and light-duty trucks;

 The Pennsylvania and federal heavy-duty diesel emission control 

programs;

 Federal fuel programs for highway vehicles and nonroad mobile 

equipment; and

 Federal regulation of offroad diesel and gasoline-powered vehicles and 

equipment.

Emission reductions from Pennsylvania’s Diesel-Powered Motor Vehicle Idling 

Act, Act 124 of 2008 (Idling Act), were not included in the 2017 and 2025 

emission inventories, and, thus, were not relied upon for the demonstration of 

maintenance. The Idling Act was approved by EPA as a SIP revision on 

August 1, 2011 (76 FR 45705). Similarly, NOX and VOC emission reductions 

from Pennsylvania’s Outdoor Wood-Fired Boilers regulation were not included in 

the 2017 and 2025 emission inventories, and, thus, were not relied upon for the 

demonstration of maintenance. The Outdoor Wood-Fired Boiler regulation was 

published in the Pennsylvania Bulletin on October 2, 2010 (40 Pa.B. 5571), and 

approved by EPA as a SIP revision on September 20, 2011 (76 FR 58114). 

Emission reductions from these measures may nonetheless assist the Lancaster

Area in maintaining the PM2.5 NAAQS.

In this Maintenance Plan, the Department provides assurances that it will continue 

to operate the ambient air quality monitoring network in order to track 

maintenance of the standards and to evaluate emissions inventories periodically 

compared to the projections provided in the plan. The Department also provides a 

list of potential contingency measures that it would consider to correct any 

violation of the NAAQS that occurs after redesignation of the area.
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Eight years following redesignation, the Commonwealth will submit a revised 

plan that ensures attainment of the 1997 and 2006 PM2.5 NAAQS through 2035.

D. Public Participation

Requirements for a public comment process are set forth in Section 110(a)(2) of 

the CAA, 40 CFR Section 51.102(d) and Section 7.5 of the Pennsylvania Air 

Pollution Control Act. 35 P.S. Section 4007.5(b). On March 8, 2014, the 

Department provided notice of a public comment period and the opportunity for a 

hearing on the Lancaster Area Maintenance Plan for the 1997 and 2006 PM2.5 

NAAQS, 2007 comprehensive inventory required by Section 172(c)(3) of the 

CAA, and the Request to Redesignate the Lancaster Area to attainment for the 

1997 and 2006 PM2.5 standards. The public comment period closed 

April 11, 2014. The Department scheduled the public hearing to occur on April 

10, 2014, but no persons expressed interest in presenting testimony or attending. 

Therefore, the Department cancelled the hearing. The Department received 

comments from one commentator, which have been addressed in a Comment and 

Response document.

II. EMISSION INVENTORIES

To demonstrate maintenance of the 1997 and 2006 PM2.5 NAAQS for the Lancaster Area, 

Pennsylvania is showing that the future emissions of PM2.5 and its precursors will remain 

at levels that will provide for maintenance of the PM2.5 NAAQS for at least 10 years, 

taking economic, population and travel growth into account. This Maintenance Plan 

contains an attainment year inventory for 2007 and demonstrates that emissions will not 

be greater than the attainment year in 2017 and 2025, with the exception of NH3. The 

projected increase in NH3 emissions does not present a concern for maintaining the 

NAAQS because the emissions of all other pollutants are projected to continue to decline 

in the Lancaster Area. This Maintenance Plan also contains a 2002 baseline inventory 

that represents the emissions present when the Lancaster Area did not meet the 1997 and 

2006 PM2.5 NAAQS. In addition, this SIP revision fulfills the requirement for a 

comprehensive inventory for the Lancaster Area under 40 CFR Section 51.1008 to meet 

the requirements of Section 172(c)(3) of the CAA. As specified by the EPA, the 

pollutants inventoried by Pennsylvania include direct PM2.5, PM10, SO2, NOX, VOC, and 

NH3. Information on the manmade sources of these pollutants was compiled for:

 “Stationary point sources” (or “point” sources), which are sources for which the 

Department collects individual emissions-related information. Generally, they 

represent major stationary sources but may be smaller.

 “Stationary area sources,” which are industrial, commercial, and residential 

sources too small or too numerous to be handled individually. These include but 

are not limited to commercial and residential open burning, architectural and 

industrial maintenance coatings application and clean-up, consumer product use, 

and vehicle refueling at service stations. Where there is overlap between 
- 10 -

stationary point sources and stationary area sources, the area source values are 

adjusted to remove any double counting.

 “Highway vehicles,” which include passenger cars and light-duty trucks, other

trucks, buses and motorcycles.

 “Nonroad sources,” which encompass a diverse collection of engines, including

but not limited to outdoor power equipment, recreational vehicles, farm and

construction machinery, lawn and garden equipment, industrial equipment, 

recreational marine vessels, commercial marine vessels, locomotives, ships, and 

aircraft.

Pennsylvania and other Northeastern and Mid-Atlantic states participated in a regional 

effort to refine the emissions inventory and to compile a regional emissions inventory. 

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

regional effort, which allowed states to pool their resources to compile a regional

emissions inventory for the purpose of conducting the regional modeling analysis used in 

Pennsylvania’s air quality management planning efforts to attain the 8-hour ozone 

NAAQS and the PM2.5 NAAQS, and to prepare the regional haze plan.

A. Emissions Inventory Methodology for Baseline Year (2002) and Attainment 

Year (2007) Emissions

Stationary Point Sources. The 2002 and 2007 stationary point source

inventories were based on emissions reported to the Department by facilities. The 

Department requires owners and operators of larger facilities to submit annual 

production figures and emission calculations each year. Throughput data are 

multiplied by emission factors from Factor Information Retrieval (FIRE) Data 

System and the EPA’s publication series AP-42 and are based on Source 

Classification Code (SCC). Each process has at least one SCC assigned to it. If 

the owners and operators of facilities provide more accurate emission data based 

upon other factors, these emission estimates supersede those calculated using 

SCC codes. Appendix A-1 includes information on stationary point source 

emission methodology, and Appendix A-2 is the data set for facility 2002 annual 

emissions. Appendix A-3 includes the data set for facility 2007 annual emissions,

as well as projected facility emissions for 2017 and 2025. Appendix A-4 is a 

table documenting the banked emissions reduction credits for the Lancaster Area

in the 2017 and 2025 emission projections.

Condensable PM is a vapor or gas at stack temperature that condenses to a liquid 

or solid at stack exit. Condensable emissions from electric generating units 

(EGUs) were not reported uniformly by all facilities. Because of the need to 

consider the effect of condensable emissions from EGUs on regional haze and 

fine particles, the 2007 inventory data was augmented, utilizing the condensable 

emission factors for EGUs developed for MARAMA in 2008 to calculate 

condensable PM emissions where that data was missing. [The 2002 inventory did 
- 11 -

not include condensable PM for many facilities and was not augmented.] 

Appendix C-4 contains the technical memorandum describing how the emission 

factors were developed. The general process is to use the emission factors and 

heat input to calculate the condensable PM (PM-CON) emissions, and then to

perform the gap filling for compounds missing from the facility-reported 

emissions.

Stationary Area Sources. Stationary area source emissions are generally 

estimated by multiplying an emission factor by some known indicator or 

collective activity for each area source category at the county level. Pennsylvania 

estimates emissions from stationary area sources using emission factors and SCC 

codes in a method similar to that used for stationary point sources. Emission 

factors may also be derived from research and guidance documents if those 

documents are more accurate than FIRE and AP-42 factors. Throughput 

estimates are derived from county-level activity data, by apportioning national or 

statewide activity data to counties, from census numbers, and from county 

employee numbers. County employee numbers are based upon North American 

Industry Classification System (NAICS) codes to establish that those numbers are 

specific to the industry covered.

Pennsylvania’s 2002 stationary area source emissions inventory was developed in 

accordance with EPA guidance6and was submitted to the National Emissions 

Inventory (NEI) to satisfy the requirements of the Consolidated Emissions 

Reporting Rule.

EPA emissions inventories and emission estimation tools were used to create the 

2007 area source inventory. For many area source categories, the most recent 

EPA data was used. These categories included ammonia emissions from 

livestock and fertilizers which came from a recent application of the Carnegie 

Mellon University (CMU) ammonia model to produce 2007 emissions; output 

from a version of the Residential Wood Combustion (RWC) model developed by 

EPA and run with updated 2007 data to produce emission estimates for that 

source category; and EPA data on wildfire emissions developed as part of EPA’s 

SMARTFIRE system.

The EPA develops area source emission estimation methodologies and estimates 

for the NEI on a three-year cycle. Where 2008 NEI data were used to fill missing 

categories in the 2007 inventory, no growth adjustment was made to the 

emissions with the assumption that activity in 2008 and 2007 was similar.

For fugitive dust area sources, the 2007 inventory was adjusted to apply the EPA 

PM “transport factors” to fugitive dust sources.

 

6 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations – EPA-454/R-05-001, August, 2005, updated November, 2005.
- 12 -

More specific information on the procedure used for each industry type is 

contained in Pennsylvania 2002 Area Source Criteria Air Pollutant Emission 

Estimation Methods, (E.H. Pechan & Associates, Inc., February 2004), which is 

contained in Appendix B-1. Appendix B-2 contains the methodology for the 

2007 Pennsylvania area source inventory. Additional methodology information is 

available in the technical support document for the 2007 regional inventory which 

is contained in Appendix C-1. Appendix B-3 is a table containing stationary area 

source emissions data for 2002 for the Lancaster Area. Appendix B-4 contains 

the stationary area source emissions data for 2007, 2017 and 2025 for the 

Lancaster Area.

Highway Vehicle Sources. EPA’s MOVES2010 (Motor Vehicle Emission 

Simulator) is the official model for estimating air pollution emissions from onroad 

mobile sources including buses, cars, trucks and motorcycles. MOVES2010 

replaces MOBILE6.2, the previous mobile source model. Therefore, the 

Department employed MOVES2010 to estimate the onroad emissions inventory 

for 2002, 2007, 2017 and 2025.

Additional information on highway emission methodology is available in 

Appendix D. Appendix D-1 summarizes the methodology and data inputs used to 

produce the mobile emissions inventory. Appendix D-2 provides the 2002 base 

year, 2007 attainment year and 2017 and 2025 projections of mobile (highway) 

vehicle miles travelled (VMT) and annual PM2.5 direct and precursor emissions. 

Appendix D-3 describes the model inputs used to generate emission factors for a 

specific area. Some examples of the inputs described in Appendix D-3 are the 

type and frequency of vehicle emission testing, the fuel types required in the area, 

temperatures by month, and fleet age. The summary in Appendix D-3 indicates 

when default information contained in the model is used rather than specific area 

information. 

Nonroad Sources.

The 2002 Emissions Inventory.

The 2002 emissions for the majority of nonroad emission source categories and 

pollutants were estimated using the EPA NONROAD 2005 model. The 

NONROAD model estimates emissions for diesel, gasoline, liquefied petroleum 

gas, and compressed natural gas-fueled nonroad equipment types and includes 

growth factors. The National Mobile Inventory Model (NMIM) was used to 

estimate emissions of ammonia from sources contained in the NONROAD model. 

The NONROAD model does not estimate emissions from aircraft, locomotives or 

commercial marine vessels. Emissions from aircraft, locomotives, and 

commercial marine vessels were estimated using EPA guidance and best available 

information. If specific local operational data was available, that data was used to 

estimate emissions. State and national data was used if local data was 

unavailable. The Lancaster Area does not have emissions from commercial 

marine vessels.
- 13 -

Appendix E-1 is the technical document providing the methodology and 

description of the procedures used to generate 2002 county-level pollutant 

emission estimates for nonroad mobile engines included in the EPA’s 

NONROAD2005 model, locomotive engines, and aircraft operations. The table 

of 2002 nonroad emissions data sorted by source category is available as 

Appendix E-2.

Aircraft Emissions in 2002. Emissions from commercial aircraft operations for 

2002 were estimated using the EPA-approved Emissions and Dispersion 

Modeling System (EDMS) 4.20, the latest version available at the time the 

inventory was developed. The Department estimated emissions using operations 

data obtained from the United States Department of Transportation, Federal 

Aviation Administration’s (FAA) Terminal Area Forecast (TAF) for commercial 

aircraft operations and the TAF and the Airnav.com website for military 

operations. Using this operations data, emissions were modeled directly using the 

EDMS.

Emissions produced by aircraft at small airports were estimated by using airport 

operation statistics, which can be found at www.airnav.com and the Federal 

FAA’s TAF Detailed Report. An emissions factor for a typical general aviation 

single engine, multi-engine, and jet engine aircraft were derived by averaging the 

emissions factors from a basket of emission factors for common aircraft of each 

of the three types of aircraft. Emission factors and operational characteristics 

contained in EDMS were used. The proportion of operations among the three 

groups of aircraft was determined by examining the number of each aircraft type 

based at each airport. For military operations at small airports, the type of aircraft 

and its emission factors are sometimes identifiable. If not, emission factors 

calculated to represent an “average” military aircraft are used. Growth was 

estimated using estimates of future operations found in the FAA TAF Detailed 

Report.

Railroad Emissions. For 2002 locomotive emissions, the Department projected 

emissions from a 1999 survey when the Department obtained fuel use statistics 

from Class II and III railroads. For Class I railroads, which produce most of the 

emissions in the Commonwealth, the Department conducted a 2002 inventory of 

all railroads that operate in Pennsylvania because the 1999 fuel use data for 

Class I railroads was skewed by gridlock caused by the acquisition of Conrail by 

CSX and Norfolk Southern. Both Conrail and Norfolk Southern suffered major 

gridlock in Pennsylvania and beyond during 1999. Consequently, fuel 

consumption and air emissions for these two railroads were greatly reduced in 

1999. The Department requested and received 2002 fuel usage from these 

railroad companies and developed a 2002 emissions inventory for them. 

Emissions were generated using EPA emission factors.
- 14 -

The 2007 Emissions Inventory.

The 2007 inventory for the majority of nonroad categories was generated using 

NMIM2008 of which the NONROAD model is a part. The NONROAD model 

estimates emissions for diesel, gasoline, liquefied petroleum gas, and compressed 

natural gas-fueled nonroad equipment types and includes growth factors. For 

nonroad vehicle the NMIM does not estimate emissions from aircraft, 

locomotives or commercial marine vessels. Emissions from aircraft, locomotives, 

and commercial marine vessels were estimated using EPA guidance and best 

available information. If specific local operational data was available, that data 

was used to estimate emissions. State and national data was used if local data was 

unavailable. NMIM includes emissions from airport ground support equipment. 

However, emissions for airport ground support equipment calculated by NMIM 

were removed because EPA considers the emissions calculated by the EDMS to 

be better estimates of the emissions from airport ground support equipment. 

Growth estimates for source categories modeled by NMIM are included in the 

model. The EPA default values were used for most categories.

Aircraft. For airport emissions, Pennsylvania used the database developed by 

EPA to support the 2008 NEI, as described in the technical support document for 

the development of the 2007 inventory in Appendix C-1.

Railroad Emissions. The Department used the emissions inventory developed by 

the Eastern Regional Technical Advisory Committee (ERTAC). Emissions from 

2007 and 2008 were considered to be identical. ERTAC completed a nationwide 

inventory with the assistance of the railroad associations and submitted the 

inventory to the EPA. The ERTAC inventory was the accepted inventory for the 

2008 NEI and was loaded into the EPA’s Emission Inventory System (EIS). The 

Department made slight modifications in cooperation with ERTAC that resulted 

in changes in emissions of smaller Class III railroads operating in Pennsylvania 

which included locomotive yard operations. The Department had developed its 

own inventory using information received from a statewide survey of railroad 

operational data. The Department determined that ERTAC’s methodology and 

inventory were similar to the Department’s method except in the cases of some 

smaller railroads mentioned above.

ERTAC developed an emissions inventory for Class I, II, and III line haul activity 

based on fuel use, tonnage carried by the railroad using each individual rail link, 

current in-use locomotive emission standards, and rail link use. Track grade and 

locomotive power settings were not considered. ERTAC based their yard 

locomotive emissions on (1) name and location of rail yards, (2) number of 

switchers operating per yard, (3) the tier/year of switchers, (4) annual fuel use 

(gallons/year) for switchers per yard, (5) approximate duty cycle or just percent of 

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

switcher’s use.
- 15 -

B. Baseline Year (2002) Emissions

An emission inventory is an estimate of the emissions from sources in a particular 

area. The Department developed an emission inventory for 2002 in accordance 

with EPA guidance7. The 2002 emissions inventory represents the emissions 

present when the Lancaster Area did not meet the 1997 and 2006 PM2.5 NAAQS. 

The 2002 baseline year inventory includes the pollutants PM10, PM2.5, SO2, NOX, 

VOC, and NH3. The inventory consists of sources in four sectors: stationary point 

sources, stationary area sources, highway vehicle sources and nonroad sources. 

The 2002 inventory is not directly comparable to the 2007, 2017 and 2025 

inventories because of changes in inventory methodology and the adjustment 

made to account for condensable PM emissions from EGUs in the 2007, 2017 and 

2025 emission inventories. Table II-1 summarizes the emissions for 2002.

Table II-1: Lancaster Area 2002 Annual Emissions (Tons per Year)

Lancaster 2002 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 380 577 498 1,368 3,188 12

Area Sources 3,612 20,026 2,735 1,739 9,887 15,994

Highway Vehicle Sources 541 628 362 17,466 6,481 222

Non-Road Sources 322 337 295 4,001 5,009 3

Totals 4,856 21,569 3,890 24,575 24,566 16,231

C. Attainment Year (2007) Annual Emissions (Tons per Year)

An emissions inventory of 2007 emissions of PM10, PM2.5, SO2, NOX, VOC, and 

NH3 for the Lancaster Area identifies PM and PM precursor emissions during the 

period when the Lancaster Area was attaining the 1997 and 2006 PM2.5 NAAQS. 

Table II-2 summarizes the emissions for 2007. While, as noted above, the 2002 

emissions inventory is not directly comparable to the 2007, 2017 and 2025 

inventories due to changes in inventory methodology and the adjustment made to 

account for condensable PM emissions from EGUs in the 2007, 2017 and 2025 

emission inventories, PM2.5, SO2, NOX, VOC, and NH3 emissions decreased by 

23 percent, 13 percent, 18 percent, 21 percent and 3 percent, respectively, from 

2002 to 2007. The 2002 inventory was based on emissions reported to the 

Department by the owners and operators of the facilities. The 2002 reports did 

not include condensable PM for many facilities. The 2007 EGU inventory was 

augmented utilizing condensable PM emission factors for EGUs developed for 

MARAMA in 2008 to calculate condensable PM emissions where that data was 

missing. The projected 2017 and 2025 PM2.5 emissions for EGUs also include 

condensable PM emissions because they were projected from the 2007 inventory.

 

7 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations – EPA-454/R-05-001, August, 2005. Updated November, 

2005.
- 16 -

Table II-2: Lancaster Area 2007 Annual Emissions (Tons per Year)

Lancaster 2007 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 254 409 102 1,147 2,691 8

Area Sources 2,691 10,218 3,030 1,827 6,675 15,551

Highway Vehicle Sources 480 574 102 13,895 5,529 207

Non-Road Sources 290 309 148 3,173 4,627 3

Totals 3,715 11,511 3,382 20,041 19,522 15,769

D. Growth Projection Methodologies for 2017 and 2025

This section describes the data, methods, and assumptions utilized in developing 

estimates of emissions changes between 2007 and interim year 2017 and 

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

for the development of the 2017 emissions inventory. Appendix C-3 contains the 

technical support document for the development of the 2025 emissions inventory. 

The documents provide details on the specific factors, control assumptions, and 

implementation schedules used in the emission projection calculations for each 

source category. MARAMA coordinated development of the projection 

inventories for the regional inventory, consisting of the states in the 

Mid-Atlantic/Northeast Visibility Union and Virginia (MANE-VU+VA).

Significant infrastructure development to extract natural gas from the Marcellus 

Shale formation in some Pennsylvania counties has occurred. Point and area 

source emissions result from the placement of drilling equipment, gathering lines 

and compressor stations. The Lancaster Area has not experienced any Marcellus 

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

the future.

EGUs. Annual 2007 EGU point emissions were “grown” to 2017 and 2025 using 

growth factors based on AEO2011 Table 96 - Electricity Generation by 

Electricity Market Module Region and Fuel Source. The appropriate AEO2011 

growth factor was applied to the 2007 emissions to calculate a “growth only” 

emission value for 2025. Post-2007 controls or shut downs were applied on a 

unit-by-unit basis. The control factors were applied to the grown emissions to 

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

description of the methodology used to project emissions from EGUs is located in 

the technical support document for the development of the 2025 emissions 

inventory in Appendix C-3.

Non-EGU Point Sources and Stationary Area Sources. For non-EGU point 

sources and stationary area sources, the emission projections for the 2017 and 

2025 were based on Version 3.3 of the 2007 MANE-VU+VA inventory, which 

was adjusted to apply the EPA PM “transport factors” to fugitive dust area

sources.
- 17 -

The methodology for projecting emissions to 2017 and 2025 is documented in the 

technical support documents for the development of the 2017 and 2025 emissions 

inventories contained in Appendix C-2 and Appendix C-3, respectively. These 

documents were prepared for MARAMA as part of an effort to assist states in 

developing maintenance plans for fine particles. The documents describe the data 

sources, methods, and results for emission forecasts.

NonEGU point source and stationary area source growth factors were developed 

using:

 Annual Energy Outlook (AEO) fuel consumption forecasts;

 State-level employment projections by NAICS code; and

 Other state-specific emission projection data. 

Generally, AEO projection factors were used for fuel consumption sources and 

employment data for other source categories. The U.S. Energy Information 

Administration (EIA) publishes the AEO annually. The AEO contains long-term 

projections of energy supply, demand and prices. AEO2010 fuel-use forecasts 

were available during inventory development. After AEO2011 was published, 

MARAMA compared the AEO2010 and AEO2011 projections. Minor 

differences were found for most categories. Based on this analysis, the AEO2010 

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

fuel use, except for industrial natural gas usage, where AEO2011 projections were 

used.

Predicted declines in fuel use and employment resulted in negative growth factors 

for some non-EGU point source and stationary area source categories. 

Consequently, for some categories, emissions are lower for the projected future 

years than for the base year, even before the application of control assumptions. 

Because of the possibility that facilities could apply for and sell Emission 

Reduction Credits (ERCs) at the level of the base year inventory, Pennsylvania 

opted for the conservative approach of assuming no growth (growth factor=1) for 

non-EGU point source categories with negative AEO or employment growth 

factors.

As discussed previously, because the 2002 stationary point source inventory was 

based on emissions reported to the Department by facilities and did not include 

condensable PM for many facilities, the emissions inventory shows an apparent 

increase of direct PM2.5 emissions from stationary point sources in 2007, 2017 

and 2025 compared with 2002.

Emission Reduction Credits (ERCs). ERCs can be created by a company if its 

emissions of certain pollutants are reduced more than what is necessary to fulfill 

regulatory requirements. ERCs can be either bought or sold to meet offset 

requirements for business expansion in areas with air quality problems. 

Emissions credits are emissions reductions that may return to the airshed in the 
- 18 -

future as companies elect to use them. To account for this potential increase, 

emissions credits banked in Pennsylvania’s Emissions Reductions Credit Registry 

System were added to the projected inventories. 

Highway Vehicle Sources. The EPA’s approved highway vehicle emission 

model, MOVES2010, projects highway vehicle average fleet emission factors. 

State specific information was used where available and appropriate. Traffic 

forecasts were compiled using information from the Pennsylvania Department 

of Transportation’s (PennDOT) Traffic Information System and 

socioeconomic data. The Pennsylvania methodology for estimating highway 

vehicle emissions is consistent with the April 2010 guidance published by the 

EPA’s Office of Transportation and Air Quality (OTAQ) entitled, Technical 

Guidance on the Use of MOVES2010 for Emissions Inventory Preparation in 

State Implementation Plans and Transportation Conformity. Appendices D-1 

through D-3 of this Maintenance Plan include specific information on the

highway emissions inventory methodology, data files of emissions estimates

and MOVES input parameters.

As shown in Table II-3, VMT for the future analysis year increases 36 percent

from 4.26 billion VMT in 2007 to 5.78 billion VMT in 2025 within the 

nonattainment area. Despite the growth in VMT, emissions of the most 

significant vehicle-related precursor, NOX, are significantly lower in the future 

analysis year. The emissions shown in Table II-3 do not include a transportation 

conformity safety margin, which will be discussed later in this document. See,

Section III-B relating to motor vehicle emission budgets for transportation 

conformity.

Table II-3: Lancaster Area VMT (Miles) and Vehicle Emissions (Tons per Year)

Year VMT PM2.5 PM1 0 SO2 NOx VOC N H3

2002 3,859,246,007 541 628 362 17,466 6,481 222

2007 4,255,370,795 480 574 102 13,895 5,529 207

2017 4,982,087,114 217 317 37 6,288 2,965 148

2025 5,784,450,553 161 284 39 4,043 1,868 144

Nonroad Sources.

Nonroad Sources in NMIM. Projected emissions for the majority of nonroad 

emission source categories and pollutants were estimated using the NMIM, which 

contains default assumptions for projected years. The NMIM estimates emissions 

for diesel, gasoline, liquefied petroleum gas, and compressed natural gas-fueled 

nonroad equipment types and includes growth factors. Control measures due to 

finalized emission standards for nonroad vehicles and engines are also accounted 

for in NMIM. Baseline emissions are multiplied by growth and control factors to 

obtain projected emissions.
- 19 -

Aircraft Emissions Growth. Aircraft operations were projected to future years by 

applying activity growth using data on itinerant (ITN) operations at airports as 

reported in the FAA’s Terminal Area Forecast (TAF) System for 2009-2030 

(FAA 2010). The ITN operations are defined as aircraft take-offs or landings. 

This information is available for approximately 3300 individual airports. Actual 

take-offs and landings are reported for 2007 and projected take-offs and landings

are provided for all years up to 2030. New aircraft emission controls that will be 

used in the future were also taken into account.

Railroad Emissions Growth. MANE VU+VA inventory development relied on 

AEO2010 growth projections published in May 2010. There are separate

projections for passenger rail and freight rail energy use. Passenger rail data from 

AEO2010 Table A-7 was used to calculate the growth factor for 2007-2017 and

2007-2025. These growth factors were applied to inter-city passenger train 

locomotives and independent commuter rail systems. For freight rail, the data 

from AEO2010 Table A-7 was used to calculate the growth factor for 2007-2017 

and 2007-2025. Freight rail annual growth factors for Class I line haul, 

Class II/III line haul, and yard switch locomotives were used.

Additional information about nonroad emission projection methodologies can also 

be found in Appendices C-2 and C-3, the technical support documents for the 

development of the 2017 and 2025 inventories, respectively. The table of 

nonroad emissions data sorted by source category is available as Appendix E-3.

E. Interim Year (2017) Emissions

Table II-4 summarizes the emissions expected in 2017. These emissions take 

activity and emissions growth and/or controls from 2007 into account. 

Appendix C, relating to the regional emissions inventory and projection 

methodology, contains the technical support documents that describe the 

methodologies used to project the 2007 emissions to 2017.

Table II-4: Lancaster Area Projected 2017 Emissions (Tons per Year)

Lancaster 2017 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 267 426 115 1,314 2,808 10

Area Sources 2,649 10,412 2,449 1,702 6,459 17,152

Highway Vehicle Sources* 249 317 37 6,916 2,965 148

Non-Road Sources 182 196 5 1,775 2,753 4

Emission Reduction Credits 0 0 0 2 172 0

Totals 3,348 11,351 2,605 11,710 15,157 17,314

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and NOX

has been set aside as a transportation conformity safety margin to accommodate unanticipated growth in 

highway vehicles. The highway vehicle emissions in Table II-4 reflect inclusion of that safety margin.
- 20 -

F. Maintenance Year (2025) Emissions

Table II-5 summarizes the emissions expected in 2025. These emissions take 

activity and emissions growth and/or controls from 2007 into account. 

Appendix C, relating to the regional emissions inventory and projection 

methodology, contains the technical support documents that describe the 

methodologies used to project the 2007 emissions to 2025.

Table II-5: Lancaster Area Projected 2025 Emissions (Tons per Year)

Lancaster 2025 PM2.5 PM10 SO2 NOx VOC NH3

Stationary Point Sources 272 432 120 1,383 2,874 11

Area Sources 2,610 10,617 1,766 1,704 6,426 18,372

Highway Vehicle Sources* 185 284 39 4,447 1,868 144

Non-Road Sources 132 143 5 1,310 2,240 4

Emission Reduction Credits 0 0 0 2 172 0

Totals 3,200 11,476 1,930 8,847 13,580 18,531

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and NOX has 

been set aside as a transportation conformity safety margin to accommodate unanticipated growth in 

highway vehicles. The highway vehicle emissions in Table II-5 reflect inclusion of that safety margin.

G. Maintenance Plan Emissions Test

To demonstrate maintenance of the 1997 and 2006 PM2.5 NAAQS for this area, 

Pennsylvania must show that the future emissions of PM2.5 and its precursors will

remain at levels that provide for maintenance of the PM2.5 NAAQS for at least 

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

account.

While EPA adopted in its Implementation Guidance for the 2006 24-Hour PM2.5

NAAQS the presumptions related to PM2.5 precursors in its Implementation Rule

for the 1997 PM2.5 NAAQS, Pennsylvania recognizes the Court decision in 

Natural Resources Defense Council v. EPA, No. 08-1250, 706 F.3d 428 (DC 

Cir. 2013) and EPA’s subsequent withdrawal of the Implementation Guidance for 

the 2006 24-Hour PM2.5 NAAQS. The court noted that PM2.5 precursors, 

including ammonia and VOCs, are presumptively regulated in PM2.5

nonattainment areas under Subpart 4, pointing specifically to section 189(e), 

which applies to control of major stationary sources of PM10 [the court stated that 

PM10 includes PM2.5 throughout Subpart 4] (706 F.3d at 436, n. 7, and at 437, 

n. 10). According to CAA Section 189(e), control requirements applicable for 

major stationary sources of PM10 also apply to major stationary sources of PM10

precursors, except where the Administrator determines that major stationary 

sources do not contribute significantly to PM10 levels that exceed the standard in 

the area; section 189(e) also requires EPA to issue guidelines regarding the 

application of subsection (e). Pennsylvania assessed emissions of PM2.5, SO2, 

NOX,VOC and NH3 for the maintenance demonstration. 
- 21 -

This Maintenance Plan contains an attainment year inventory for 2007 and 

demonstrates that emissions of PM2.5, SO2, NOX and VOC, including emissions in 

the transportation conformity safety margin for PM2.5 and NOX, will not be 

greater in 2017 and 2025 than in the attainment year, as shown in Table II-7.

Emissions of NOx are projected to decrease from 2007 to 2025 by approximately 

11,194 tons (56 percent). Emissions of PM2.5, SO2 and VOC also decrease from 

2007 to 2025 by approximately 516 tons (14 percent), 1,451 tons (43 percent), 

and 5,942 tons (30 percent), respectively. Over the same time period, emissions 

of NH3 are projected to increase 2,762 tons (18 percent). 

The projected increase in NH3 emissions does not present a concern for 

maintaining the PM2.5 NAAQS because emissions of all other pollutants are 

projected to decline in the Lancaster Area. The increase in NH3 emissions is due 

to anticipated growth reflected by activity factors (such as population and 

employment, for instance) in the absence of any anticipated requirements to 

reduce NH3 emissions. Changes in PM2.5 concentrations in the Lancaster Area 

have not been driven by changes in ammonia emissions in the past. As shown in 

Table II-6 and in Figure II-1, PM2.5 concentrations have decreased substantially 

from 2002 through 2011, while NH3 emissions have held relatively steady. Over 

the same time period, significant reductions in PM2.5, SO2, NOx and VOC have 

occurred, indicating that PM2.5 concentrations in the Harrisburg Area are sensitive 

to SO2 and NOx reductions and that PM2.5 formation in the Harrisburg Area is 

likely not limited by NH3 concentrations. Thus, the projected increase in NH3

emissions does not appear to be an important factor for maintaining the PM2.5 

NAAQS. In addition, the Lancaster Area currently has an annual design value 

based on 2010-2012 monitoring data of 12.1 μg/m3, which is significantly lower 

than the 1997 NAAQS of 15 μg/m3. The Lancaster Area also has a 24-hour 

design value based on 2010-2012 monitoring data of 31 μg/m3 which is 

significantly lower than the 2006 NAAQS of 35 μg/m3.

Table II-6: Lancaster Area NH3 Emissions and PM2.5 Design Values

Lancaster 2002 2005 2007 2008 2011

NH3 (Tons/Year) 7,819 8,195 7,302 7,266 7,461

PM2.5 - Annual Design Value 17.1 17.5 15.9 14.5 12.0

PM2.5 - 24-Hour Design Value 43 44 40 37 31
- 22 -

Figure II-1: Lancaster Area NH3 Emissions and PM2.5 Design Value Trends

Table II-7: Lancaster Area Maintenance Emissions Test

Lancaster PM2.5 SO2 NOx VOC NH3

2007 3,715 3,382 20,041 19,522 15,769

2017* 3,348 2,605 11,710 15,157 17,314

2025* 3,200 1,930 8,847 13,580 18,531

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and 

NOX has been set aside as a transportation conformity safety margin to accommodate unanticipated 

growth in highway vehicles. The emissions in Table II-6 reflect inclusion of that safety margin.

Air quality modeling that EPA conducted to analyze the impact of revising the 

PM2.5 NAAQS, summarized in the Regulatory Impact Analysis of December 

2012, indicates that Lancaster County would maintain the 1997 and 2006 

NAAQS, as well as attain the 2012 NAAQS with a concentration of 9.4 μg/m3in 

2020.8The modeling was performed with a 2007 base year. The projection to 

2020 took into account reductions expected to occur between 2007 and 2020 from 

existing federal and State control programs. The results of EPA’s modeling also

support redesignating the Lancaster Area to attainment for the 1997 and 2006

PM2.5 NAAQS.

III. PERMANENT AND ENFORCEABLE CONTROL MEASURES

A. Permanent and Enforceable Control Measures

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

formation, the EPA recognizes that effective control measures for PM2.5 will vary 

 

8 www.epa.gov/air/particlepollution/2012/2020table.pdf
- 23 -

among nonattainment areas. This was reflected in EPA’s “Implementation 

Guidance for the 2006 24-Hour Fine Particle National Ambient Air Quality 

Standard,” Office of Air Quality Planning and Standards, EPA, March 2, 2012

(“Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS”). In the 

Implementation Guidance for the 2006 PM2.5 NAAQS, EPA adopted the 

framework and policy approach the agency espoused in its implementation rule 

for the 1997 PM2.5 NAAQS, known as the “Clean Air Fine Particle 

Implementation Rule” (72 FR 20586; April 25, 2007) (“Implementation Rule for 

the 1997 PM2.5 NAAQS”).

In its Implementation Rule for the 1997 PM2.5 NAAQS, EPA had established 

general presumptive policies for assessing which PM2.5 precursors should be 

evaluated for possible controls. In that earlier rule, the EPA required states to 

evaluate control measures for SO2 and primary PM2.5 in all locations. The EPA 

required states to evaluate control measures for NOX unless a technical 

demonstration is made to show that NOX emissions from sources in the state do 

not significantly contribute to PM2.5 concentrations in the nonattainment area. 

The EPA required states to evaluate measures for VOC and NH3 only if a 

technical demonstration is made to show VOC or NH3 emissions significantly 

contribute to PM2.5 in the nonattainment area. 

The EPA reaffirmed the appropriateness of these presumptions in its 

Implementation Guidance for the 2006 24-Hour PM2.5 NAAQS.9 Meanwhile, the 

Court of Appeals for the D.C. Circuit was considering a challenge to the 

Implementation Rule for the 1997 PM2.5 NAAQS, in Natural Resources Defense 

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

ruling in that case. The Court granted the petitions for review and remanded the 

case to EPA to re-promulgate the rule pursuant to Subpart 4 of Part D of the Clean 

Air Act, rather than implementing it under Subpart 1, as EPA had done 

(706 F.3d 428 at 437(DC Cir. 2013)).

Shortly thereafter, EPA withdrew its Implementation Guidance for the 2006 

24-hour PM2.5 NAAQS. According to EPA’s June, 2013 withdrawal 

memorandum (see second page of memorandum)10, EPA withdrew the guidance 

in response to the Court’s decision in Natural Resources Defense Council v. EPA, 

No. 08-1250.

This maintenance plan demonstrates maintenance of the standards consistent with 

the Court’s ruling. In general, the Court’s decision (for the 1997 PM2.5 NAAQS 

and to the extent it would be extrapolated to the 2006 24-Hour PM2.5 NAAQS) 

could affect an area’s nonattainment classification, certain deadlines, and the 

impacts of failing to attain timely, and could impose a deadline for 

implementation of reasonably available and best available control measures 

(706 F.3d at 436, n. 6). Because the Lancaster Area is already attaining the 1997 

 

9 See footnote 2, above.

10 See footnote 3, above.
- 24 -

annual and 2006 24-Hour PM2.5 NAAQS, those considerations are not relevant for 

this maintenance plan. The court noted that PM2.5 precursors, including ammonia 

and VOCs, are presumptively regulated in PM2.5 nonattainment areas under 

Subpart 4, pointing specifically to section 189(e), which applies to control of 

major stationary sources of PM10 [the court stated that PM10 includes PM2.5

throughout Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to 

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

sources of PM10 also apply to major stationary sources of PM10 precursors, except 

where the Administrator determines that major stationary sources do not 

contribute significantly to PM10 levels that exceed the standard in the area; 

Section 189(e) also requires EPA to issue guidelines regarding the application of 

Subsection (e). Pennsylvania assessed emissions of PM2.5, SO2, NOX, VOC and 

NH3 for the maintenance demonstration.

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

PM2.5, SO2, NOX, and VOC emission reductions ensuring maintenance of the 

standard.

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

included in Table III-1 (Negative values indicate emission reductions.). The 

emission change estimates account for any anticipated growth in the activity of 

sources regulated by the strategy and include emissions in the transportation 

conformity safety margin. Direct PM2.5, SO2, NOX and VOC emissions in 2025 

in the Lancaster Area are anticipated to be lower than they were in 2007. This 

means that the projected growth in emissions is smaller than anticipated emission 

reductions from control measures for all pollutants in the nonattainment area. 

Each control measure is explained in greater detail in the following sections. 

Ammonia emissions, as discussed in Section II-G relating to the Maintenance 

Plan Emissions Test, are anticipated to increase from 2007 to 2025, but the 

increase does not present a concern for maintaining the NAAQS in the Lancaster

Area because emissions of all other pollutants are projected to decline in the area. 

Based on 2010-2012 monitoring data, the Lancaster Area currently has an annual 

design value of 12.1 μg/m3 and a 24-hour design value of 31 μg/m3, which is 

significantly lower than the 1997 annual PM2.5 NAAQS of 15 μg/m3and the 2006 

24-hour NAAQS of 35 μg/m3. In addition, in the past, reductions in PM2.5 

concentrations in the Lancaster area have not been linked to or dependant on NH3

emissions as shown in the analysis in Section II-G relating to the Maintenance 

Plan Emissions Test.
- 25 -

Table III-1: Summary of Emission Reductions (Tons) from 2007 to 2025

from Control Measures

2007 to 2025 Difference PM2.5 SO2 NOx VOC N H3

Stationary Point Sources 18 18 238 355 3

Area Sources -81 -1,264 -122 -249 2,821

Highway Vehicle Sources* -295 -63 -9,447 -3,661 -63

Nonroad Sources -158 -142 -1,862 -2,388 1

TOTAL -516 -1,451 -11,194 -5,942 2,762

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and 

NOX has been set aside as a transportation conformity safety margin to accommodate unanticipated 

growth in highway vehicles. The highway vehicle emissions in Table III-1 reflect inclusion of that 

safety margin.

Pursuant to 40 CFR Part 51, Subpart K (relating to source surveillance), the SIP 

revision is required to provide for monitoring of the status of compliance with any 

rules and regulations that set forth any portion of the control strategy. These 

include provisions, as applicable, for:

 emissions reports and recordkeeping for stationary sources;

 periodic testing and inspection of stationary sources;

 enforcement and complaint investigation of visible emission limitations;

 enforceable test methods for emission limits; and

 continuous emission monitoring for stationary sources.

Subpart K also requires monitoring of the implementation of transportation 

control measures (TCMs). There are no TCMs in this SIP revision.

The rules and regulations for stationary sources, which are part of the control 

strategy for attaining and maintaining the PM2.5 standard, as well as the 

Department’s comprehensive permitting program requirements in 25 Pa. Code

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

requirements of Subpart K. EPA has approved the Department’s permitting 

program as part of the State Implementation Plan.

There are many examples in the Pa. Code of provisions for monitoring the status 

of compliance with the Department’s rules and regulations. For example, 

§127.12(a) (relating to the content of applications) contain requirements for 

reporting and recordkeeping for plan approval applications. Similar requirements 

are found in §127.411(a) (relating to content of applications) for permit 

applications. Sections 145.145 and 145.146 contain the compliance 

demonstration, reporting and recordkeeping requirements for cement kilns that 

enable the Department to monitor the status of compliance with the regulations in 

Chapter 145 Subpart C. The Department also monitors the status of compliance 

by conducting complaint investigations. The Department does visible emission 

inspections at regulated facilities and reports the results to the EPA AFS system 
- 26 -

as required under the Department’s grant. The Department conducts inspections 

of air contamination sources in accordance with the Compliance Monitoring 

Schedule which is approved by EPA.

1. Stationary Point Sources

Background for Pennsylvania’s Stationary Source Permitting 

Programs. An owner or operator of a proposed new air contamination 

sources in the Commonwealth is required to receive a plan approval (preconstruction permit) from the Department prior to the construction, 

assembly, installation of new sources, modification of any existing 

stationary air contamination sources, or the installation of air pollution 

control equipment or devices. Following the construction of the new 

facility or air contamination source, the owner or operator must obtain an 

operating permit from the Department. The type of operating permit will 

depend on the quantity of regulated pollutants emitted from the air 

contamination sources. DEP will issue a “State-only Operating Permit” 

for minor air contamination stationary sources that are below the 

applicability thresholds for Title V facilities. A Title V operating permit is 

required for major facilities that have the potential to emit air 

contaminants exceeding the Title V thresholds. The Title V Permit, which 

is issued for a term of five years, incorporates all applicable requirements 

for the facility in a single federally enforceable operating permit.

The requirements contained in 25 Pa. Code Chapter 127 (relating to the 

construction, modification, reactivation and operation of sources), and 

associated definitions in 25 Pa. Code Chapter 121.1, are a suite of 

programs regulating air contamination sources to improve and maintain air 

quality. Chapter 127 establishes requirements for the submission, review 

and approval of pre-construction and operating permits for both major and 

non-major air contamination sources. The provisions of Chapter 127 have 

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

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

federally enforceable. Several aspects of Chapter 127 are highlighted 

below as being particularly important for the maintenance of the PM2.5

standard.

Title V Permitting Program. The Title V Permitting Program, 

adopted pursuant to the Clean Air Act Amendments of 1990, is 

applicable to major stationary sources as defined in 25 Pa. Code

Section 121.1. The purpose of the Title V program is to detail a 

facility’s air quality requirements in a single permit document so 

that industry, the regulatory agency, and the public know exactly 

what regulations and requirements apply and how the facility’s 

owner or operator will monitor and demonstrate compliance with 

all applicable requirements. The Title V permit includes all 
- 27 -

sources at a site including all air pollution control devices as well 

as activities that were determined to be insignificant sources of 

emissions. Each source is described in detail within a section of 

the Title V permit. The requirements include general conditions 

applicable to all Title V facilities, emission restrictions, detailed 

monitoring, recordkeeping, and reporting requirements to assure 

compliance with the facility’s applicable federal and state 

requirements.

Nonattainment New Source Review and Prevention of 

Significant Deterioration. Major facilities proposed in 

Pennsylvania will also be subject to New Source Review (NSR) 

requirements in nonattainment areas and Prevention of Significant 

Deterioration (PSD) requirements in areas of the Commonwealth 

designated attainment for National Ambient Air Quality Standards 

including carbon monoxide, particulate matter (PM), lead, nitrogen 

dioxide (NO2), ozone and sulfur dioxide (SO2). Generally, NSR 

permit requirements are applicable to a facility located in a 

nonattainment area for a particular pollutant with a potential to 

emit 50 tons or more per year (tpy) of volatile organic compounds 

or 100 tpy or more of NOx, SO2, PM or carbon monoxide. It 

should be noted that the entire Commonwealth, included in the 

Ozone Transport Region by operation of law, is treated as a 

“moderate” ozone nonattainment area, irrespective of the area’s 

attainment status. Because NOx and VOC are precursors of PM2.5, 

NOx and VOC emission reductions required statewide under the 

nonattainment NSR program for ozone also allow Pennsylvania to 

make substantial progress in attaining and maintaining the PM2.5

NAAQS. Any major stationary source or major modification 

subject to the NSR requirements must receive a plan approval. To 

receive approval from the Department, a person must show that the 

proposed source will, among other things, offset its potential to 

emit air contaminants including NOx, PM and VOCs by securing 

emission reductions credits at the specified offset ratio, will 

employ the “lowest achievable emission rate” (LAER) for each 

regulated pollutant and conduct an alternative analysis. The 

nonattainment NSR requirements are codified in 25 Pa. 

Chapter 127, Subchapter E and approved as a SIP revision on 

December 9, 1997 (62 FR 64722).

The PSD program is a pre-construction review and permitting 

program applicable to new or modified major stationary sources 

subject to Title I, Parts C and D of the federal CAA. The PSD 

requirements are applicable to major sources in areas attaining the 

NAAQS. The federal PSD regulations codified in 40 CFR Part 52 

are incorporated by reference in their entirety in 25 Pa. Code

§127.83 (relating to adoption by reference). The Department’s 
- 28 -

PSD regulations, codified in 25 Pa. Code Chapter 127, 

Subchapter D, were approved by the EPA on August 21, 1984 and 

codified at 40 CFR §52.2058 (49 FR 33128).). PSD permit 

requirements may apply to a facility located in an attainment area 

for a standard with the potential to emit 100 tpy or 250 tpy of the 

six criteria pollutants including carbon monoxide, lead, nitrogen 

dioxide, ozone, particulate matter and sulfur dioxide depending on 

the source category. Any major stationary source or major 

modification subject to the PSD requirements must conduct an 

analysis to establish the best available control technology (BACT). 

In addition, the owner or operator of a facility needs to conduct an 

ambient air quality analysis, analyze the impacts to soils, 

vegetation and visibility and make sure that the project will not 

adversely impact mandatory federal Class I areas including 

national parks greater than 6,000 acres and national wilderness 

areas and national memorial parks greater than 5,000 acres. 

Best Available Technology Program. The Department’s Best

Available Technology (BAT) Program ensures that new stationary 

sources will prevent, reduce or control emissions of air

contaminants to the maximum degree possible. The Department 

determines BAT requirements on a case-by-case basis for both 

major and minor stationary sources taking into account energy, 

environmental benefits and costs. Pursuant to 25 Pa. Code §127.1,

the emission of air pollutants from new sources in Pennsylvania 

must be controlled to the maximum extent, consistent with the best 

available technology as determined by the Department as of the 

date of issuance of the plan approval for the new source. Under 

25 Pa. Code §127.12(a)(5), an application for a plan approval must 

show that the emissions from a new source will be the minimum 

attainable through the use of the best available technology. 

Pennsylvania regulations define “best available technology” in 

25 Pa. Code §121.1 as, “Equipment, devices, methods or 

techniques as determined by the Department which will prevent, 

reduce or control emissions of air contaminants to the maximum 

degree possible and which are available or may be made 

available.” The Department’s BAT regulations, codified in 25 Pa. 

Code §§127.1 and 127.12(a)(5), were approved by EPA on 

July 30, 1996, and codified in the SIP at 40 CFR §52.2020(c)(1).

NOx and SO2 Control Programs. In 1998, EPA promulgated the NOX

SIP Call as the EPA’s principal effort to reduce interstate transport of air 

pollution (63 FR 57356; October 27, 1998). In response to the federal 

NOX SIP call rule, Pennsylvania adopted the NOX Budget Trading 

Program regulations for EGUs and large industrial boilers, with emission 

reductions to commence May 1, 2003. The regulations were approved by 
- 29 -

EPA as a revision to the Commonwealth’s SIP on August 21, 2001 

(66 FR 43795). Additionally, in response to the NOX SIP Call, 

Pennsylvania adopted additional NOX control regulations covering cement 

plants and internal combustion engines, with emission reductions to 

commence May 1, 2005. These regulations were approved by EPA as a 

SIP revision on September 29, 2006 (71 FR 57428).

Clean Air Interstate Rule (CAIR). In 2005, EPA adopted CAIR 

(70 FR 25162; May 12, 2005, as amended) to address interstate 

transport of NOX and SO2. CAIR is now being implemented in 

Pennsylvania through the Department’s CAIR regulation, codified 

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

amendments in Chapters 121, 129 and 145. EPA approved 

Pennsylvania’s CAIR SIP revision on December 10, 2009, codified 

at 40 CFR §52.2020(c)(1) (74 FR 65446). In the CAIR SIP 

revision, Pennsylvania terminated the NOX Budget Trading 

Program and transitioned to the federal CAIR for large electric 

generating units (EGU).

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

NOX and SO2 below 2002 levels throughout the eastern United 

States. Pennsylvania and the other CAIR states were required to 

adopt a regulation implementing the requirements of the CAIR or 

an equivalent program. The large EGUs in Pennsylvania were 

initially regulated under CAIR FIPs promulgated by EPA, but have 

been regulated under the SIP since EPA approved Pennsylvania’s 

CAIR SIP revision. Under the SIP revision, Pennsylvania 

participates in the EPA-administered cap-and-trade programs for 

NOX annual, NOX ozone season, and SO2 annual emissions.

EPA’s CAIR was remanded to EPA for revisions by the United 

States Court of Appeals for the District of Columbia on 

December 23, 2008 (See, North Carolina v. EPA, 531 F.3d 896, 

modified, 550 F.3d 1176 (D.C. Cir. 2008)). Following remand, 

EPA replaced CAIR with the Cross-State Air Pollution Rule 

(CSAPR), but in a separate legal challenge the court vacated 

CSAPR. In that ruling, the court ordered EPA to continue 

administering CAIR pending the promulgation of a valid 

replacement (See, EME Homer City Generation L.P. v. EPA, 

696 F.3d 7 (D.C. Cir. 2012, rehearing denied, 2013 U.S. App. 

LEXIS 1623 and 1624 (D.C. Cir. Jan. 24, 2013)). On June 24, 

2013, the Supreme Court of the United States accepted review of 

the case. Following the Circuit Court’s direction, CAIR remains in 

place pending the Supreme Court’s review.
- 30 -

NOX Budget Trading Program limits on non-EGUs. The CAIR 

SIP revision also established emission limits for the non-EGUs and 

other units that were subject to the Commonwealth’s NOX Budget 

Trading Program but are not subject to the CAIR NOX Ozone 

Season Trading Program. These units must continue monitoring 

NOX emissions and must meet an emissions cap. Each unit has an 

allowable emission rate, calculated by January 31 of each year, 

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

NOX ozone season emissions from all of these units exceed the 

statewide ozone season emission cap of 3,438 tons, each unit that 

exceeds its individual allowable emissions limit for that ozone 

season must surrender to the Department one CAIR NOX ozone 

season allowance and one CAIR NOX annual allowance for each 

ton of emissions over its allowable limit. In addition, the 

Commonwealth has set aside 181 tons of NOX, including tons that 

will be retired each year to compensate for sources that were 

exempted under the ‘‘twenty-five ton exemption’’ in 

section 145.4(b) 3. The balance of tons remaining in the set aside 

is available to the Department annually for accounting corrections. 

The Commonwealth retires any unused amount from this set aside 

each year.

It is unlikely that the 3,438-ton statewide NOX ozone season 

emission limitation will be exceeded. Pennsylvania’s non-EGU 

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

under the NOX Budget Trading Program never exceeded the 

statewide cap of 3,438 tons.

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

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

and codified at 40 CFR §52.2020(c)(1).

Cement kilns and large stationary internal combustion engines. 

The CAIR SIP revision also included regulations updating the the 

cement manufacturing and large stationary internal combustion 

engine regulations that were adopted pursuant to the NOX SIP Call. 

Until 2009, cement kilns and large stationary internal combustion 

engines that were subject to the NOX SIP Call were required to 

surrender NOX SIP Call allowances if they exceeded their NOX

emission limits set forth in Department regulations. Because the 

Department discontinued the NOX Budget Trading Program 

beginning 2009, at which point NOX SIP Call allowances were 

replaced by CAIR NOX ozone season allowances, the Department 

modified the regulations to require surrender of CAIR NOX ozone 

season and CAIR NOX annual allowances for emission limit 

exceedances.
- 31 -

The Department’s regulations for large stationary internal 

combustion engines and cement kilns, codified in 25 Pa. Code

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

EPA as a SIP revision on December 10, 2009, and codified at 

40 CFR §51.2020(c)(1). An amendment to the Department’s 

regulation for cement kilns to reduce NOX emissions effective 

April 15, 2011, codified in 25 Pa. Code Chapter 145, 

Subchapter C, was subsequently approved by EPA as as SIP 

revision on July 19, 2011, and codified at 40 CFR §51.2020(c)(1).

Federal Standards for Hazardous Air Pollutants. Federal standards to 

control hazardous air pollutants (HAPs) require Maximum Achievable 

Control Technology (MACT) at units located at major sources of HAPs. 

The EPA has promulgated a series of MACT regulations that are 

applicable to sources in Pennsylvania. These MACT standards are 

adopted and incorporated by reference in Section 6.6 of Pennsylvania’s 

Air Pollution Control Act and implementing regulations in 25 Pa. Code

§127.35 (relating to maximum achievable control technology standards for 

hazardous air pollutants). The standards are also included in federally 

enforceable plan approvals and operating permits issued by the 

Department for affected sources.

2. Highway Vehicle Sources

Even with increases in VMT that occur from 2007 through 2025, highway 

vehicle emissions will continue to decrease. As more vehicles subject to 

cleaner new car standards replace older vehicles subject to less stringent 

new vehicle standards, the fleet as a whole emits fewer emissions, 

compensating for the increase in vehicle miles traveled. These decreases

can be attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) and 

Pennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established 

by the CAA Amendments of 1990 include NOX and VOC limits for lightduty gasoline vehicles (LDGVs) and light-duty gasoline trucks (LDGTs). 

The phase in of these standards began in 1994. Evaporative VOC 

emissions were reduced in gasoline-powered cars starting with Model 

Year (MY) 1998.

In 1998, under the authority of section 177 of the CAA, the Department 

adopted the Pennsylvania Clean Vehicles Program (28 Pa.B. 5973, Dec. 5, 

1998). The Pennsylvania Clean Vehicles Program incorporates by 

reference certain California Low Emission Vehicle (CA LEV) emission 

standards for passenger cars and light-duty trucks. As required under 
- 32 -

Section 177 of the CAA, these provisions are identical to the low emission 

standards adopted by California. The regulation does not incorporate by 

reference the California zero emissions vehicle (ZEV) or emissions 

control warranty systems statement provisions.

In the same rulemaking, the Department adopted the National Low 

Emission Vehicle (NLEV) program as a compliance alternative to the 

Pennsylvania Clean Vehicles Program. The NLEV program became 

effective in the Ozone Transport Region (OTR) in 1999. Pennsylvania’s 

New Motor Vehicle Emissions Control Program regulations in 25 Pa. 

Code Sections 126.401-126.441, in addition to including the Clean 

Vehicles Program, allowed automobile manufacturers to comply with 

NLEV instead of the CA LEV program through MY 2005. These 

regulations affected vehicles 6,000 pounds and less and were the 

regulations in effect for new motor vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV 

(Tier 2), starting with MY 2004 (65 FR 6698; Feb. 10, 2000) The NLEV 

program was replaced for MY 2004 and later by the more stringent Tier 2 

regulations, and vehicle manufacturers operating under the NLEV 

program became subject to the Tier 2 requirements.

Pennsylvania amended the former New Motor Vehicle Emissions Control 

Program in 2006. The Clean Vehicles Program continues to incorporate 

the California Low Emission Vehicle Program by reference. As amended, 

the program affects MY 2008 and newer passenger cars and light-duty 

trucks vehicles (36 Pa.B. 7424; Dec. 9, 2006), corrected 37 Pa.B. 209 

(Jan. 12, 2007, eff. Dec. 9, 2006). EPA approved Pennsylvania’s Clean 

Vehicle Program as a revision to the Commonwealth’s SIP on January 24, 

2012 (77 FR 3386).

Heavy-Duty Diesel Control Programs. The EPA promulgated more 

stringent national regulations for heavy-duty engines and vehicles (over 

14,000 pounds) starting with MY 2004. In addition, federal consent 

decrees with seven of the largest heavy-duty engine manufacturers 

required, among other terms, that diesel engines made by these companies 

comply with these 2004 standards two model years early, in MY 2002. 

The emission reductions from these programs are reflected in the future 

year emission inventories, as provided in the MOVES model.

In 2002, the Department adopted the Heavy-Duty Diesel Emissions 

Control Program for model years starting after May 2004. The program 

incorporates California standards by reference and requires MY 2005 and 

subsequent new heavy-duty diesel highway engines to be those certified 

by California. California standards were more stringent than federal 

standards for the two model years between expiration of the consent 
- 33 -

decrees discussed above (MYs 2005 and 2006) and the implementation of 

more stringent federal standards affecting MY 2007 and beyond. 

However, EPA’s MOVES model already assumed that the engines would 

comply with consent decree standards, even without an enforcement 

mechanism. The Department has used MOVES defaults to calculate 

emissions from MY 2005 and 2006 highway engines.

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

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

were phased in from 2007 to 2010 for NOX and VOCs. For gasoline 

engines, the standards were phased in during MY 2008 and 2009. Federal 

and California standards were virtually identical for MY 2007. For MY

2008, California adopted requirements for idling restriction engine 

programming and an optional “clean NOX idle” standard. However, there

is no EPA-approved methodology to estimate emission reductions from 

this requirement. Therefore, the emission estimates use assumptions of 

the federal rule for MY 2007 through 2010.

Because the new engine standards are adversely affected by sulfur in fuel, 

the EPA also required most highway diesel fuel to contain no more than 

15 parts per million (ppm) of sulfur, beginning in the fall of 2006. There 

was a temporary compliance option allowing refiners to continue to 

produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

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

the phase-in provision.

Vehicle Emission Inspection/Maintenance Program. In early 2004, 

Pennsylvania expanded its Vehicle Emission Inspection/Maintenance 

(I/M) Program into the Lancaster Area. The program applies to gasolinepowered vehicles 9,000 pounds and under, model years 1975 and newer. 

For vehicles 1996 and newer, the program consists of an annual on-board 

diagnostics test and a gas cap pressure test. For subject vehicles 1995 and 

older, the program consists of an annual visual inspection of pollution 

control devices to ensure they are present, connected and the proper type 

for the vehicle and a gas cap pressure test. These regulations can be found 

in 67 Pa. Code Chapter 177. The Department submitted the expanded 

emissions program to EPA as a SIP revision on December 1, 2003. EPA 

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

Low Sulfur Gasoline. Sulfur is a natural component in crude oil that 

ends up in gasoline and diesel unless removed. Sulfur in gasoline impairs 

the effectiveness of emission control systems and contributes to air 

pollution. By removing most sulfur from gasoline, new advanced 

emission controls will work longer and more efficiently, and air pollution 

will be reduced.
- 34 -

The 1999 federal Tier 2 regulations (65 FR 6698; Feb. 10, 2000) reduced

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

emission control technologies in cars and trucks that reduce harmful air 

pollution. The emission inventory analysis in this Maintenance Plan uses 

the default assumptions provided in MOVES2010 to account for the 

implementation of the federal standards for low sulfur gasoline. 

Requirements for use of low-sulfur gasoline enabled use of advanced 

emission control systems in light-duty vehicles beginning in model year 

2004. Vehicles meeting Tier 2 emission standards are 77 to 95 percent 

cleaner than earlier models.

On March 3, 2014, EPA signed a regulation adopting more stringent 

vehicle standards and reducing sulfur limits in gasoline further with the

Tier 3 Motor Vehicle Emission and Fuel Standards program. The rule 

takes effect in 2017. The Tier 3 program requires the annual average 

content of sulfur in gasoline to be reduced to 10 parts per million, starting 

January 1, 2017. By 2018, EPA estimates that SO2 emissions from 

gasoline vehicles will be reduced by 56 percent. When fully implemented, 

this program, by 2030, will increase the effectiveness of vehicle emission 

controls even further and reduce onroad emissions of NOx by 25 percent, 

direct particulate matter by 10 percent and VOCs by 16 percent. The rule 

will also significantly reduce emissions of carbon monoxide and 

hazardous air pollutants including acrolein, benzene, formaldehyde and 

acetaldehyde.

3. Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel-powered 

(“compression ignition”) and gasoline-powered (“spark ignition”) nonroad 

engines of various sizes (horsepower) and applications. Information on 

these federal rules, including their implementation dates, can be found at 

www.epa.gov/nonroad. The Department used the assumptions built into 

the nonroad model (NONROAD2005) and NMIM to estimate emissions 

for all milestone years.

While the EPA has published a notice of proposed rulemaking for more 

stringent standards for locomotives and large commercial marine diesel 

engines, the agency has not finalized any new standards.

On June 29, 2004, EPA adopted a rule establishing a comprehensive 

national program to reduce emissions from nonroad diesel engines 

(69 FR 38958). The rule phased in requirements for reducing the sulfur 

content of diesel used in nonroad diesel engines. The reduction in fuel 

sulfur content prevents damage to the more advanced emission control 

systems needed to meet the engine standards; it will also reduce fine 

particulate emissions from diesel engines. In 2007, fuel sulfur levels were 
- 35 -

limited to 500 ppm for nonroad applications other than ocean-going 

marine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur 

concentration as in highway fuel, 15 ppm; this requirement began 

applying in 2012 to locomotive and marine diesel fuel. EPA adopted 

technical amendments to the program in rules published in the Federal 

Register on November 22, 2005 (70 FR 70498) and May 1, 2006 

(71 FR 25706). On April 30, 2010 (75 FR 22896), EPA adopted changes 

to the nonroad diesel fuel program to allow for the production and sale of 

diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marine 

vessels. This requirement does not impact the LancasterArea because the 

Lancaster Area does not have emissions from commercial marine vessels.

4. Stationary Area Sources

Low Sulfur Fuel Oil. The Environmental Quality Board has adopted a 

rule to reduce the sulfur content of fuel oil in Pennsylvania. This final 

rule, published in the Pennsylvania Bulletin February 9, 2013 

(43 Pa.B. 806), corrected April 20, 2013 (43 Pa.B. 2140), will limit the 

sulfur content of No. 2 fuel oil to 500 ppm, No. 4 fuel oil to 2,500 ppm 

and Nos. 5 and 6 fuel oils to 5,000 ppm. Compliance with the lower sulfur 

content limits will be required beginning July 1, 2016. The Department 

estimates statewide SO2 emission reductions of approximately 25,000 tons 

per year from this rule. The final-form regulation was submitted to EPA 

for approval as a SIP revision on February 26, 2013 and determined by 

EPA on March 28, 2013 to be administratively complete. Action on the 

SIP revision is expected in early 2014.

Consumer Products. This regulation applies statewide to any person 

who sells, supplies, offers for sale, or manufactures certain consumer 

products on or after January 1, 2005, for use in the Commonwealth. The 

program is contained in 25 Pa. Code Chapter 130, Subchapter B. It was 

submitted to the EPA as a SIP revision on March 26, 2003, and approved 

on December 8, 2004 (69 FR 70895). Amendments to the Consumer 

Products regulations were adopted on October 11, 2008, submitted to the 

EPA for approval as a SIP revision on March 11, 2009, and approved by 

EPA as a SIP revision on October 18, 2010 (75 FR 63717).

Adhesives, Sealants, Primers and Solvents. Pennsylvania adopted a 

regulation in 2010 to control VOC emissions from Adhesives, Sealants, 

Primers and Solvents. This regulation was published in the Pennsylvania 

Bulletin on December 25, 2010 (40 Pa.B. 7340) and approved by EPA as a 

SIP revision on September 26, 2012 (77 FR 59090).
- 36 -

B. Motor Vehicle Emission Budgets for Transportation Conformity

Section 176 of the CAA provides a mechanism by which federally funded or 

approved highway and transit plans, programs, and projects are determined not to 

produce new air quality violations, worsen existing violations, or delay timely 

attainment of the NAAQS. EPA regulations issued to implement transportation 

conformity provide that motor vehicle emission “budgets” establish caps of these 

emissions that cannot be exceeded by the predicted transportation system 

emissions in the future. Transportation agencies in Pennsylvania are responsible 

for making timely transportation conformity determinations. The responsible 

agency in the Lancaster Area is the Lancaster County Transportation 

Coordinating Committee, the designated Metropolitan Planning Organization 

(MPO) under federal transportation planning requirements.

In this Maintenance Plan, Pennsylvania establishes budgets for highway 

emissions for direct PM2.5 and NOX in order to ensure that transportation 

emissions do not impede clean air goals in the next decade and beyond. The 

highway emission budgets include a safety margin, which was created by setting 

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

emissions of PM2.5 and NOX to accommodate unanticipated growth in highway 

vehicles.

Amendments to the 40 CFR part 93 transportation conformity regulations to 

address the 1997 PM2.5 standard were published in the Federal Register on May 6, 

2005 (70 FR 24280), to account for PM2.5 and its precursors.11 The 

Implementation Rule did not amend these regulations. In the transportation 

conformity regulations, section 93.102 requires conformity determinations to be 

applicable to direct emissions of PM2.5 and NOX (unless a determination is made 

that transportation-related emissions are not significant contributors to PM2.5), but 

to emissions of SO2, VOC, and NH3 only if a finding is made that transportationrelated emissions of these pollutants are significant contributors to PM2.5. EPA 

approved Pennsylvania’s SIP revision establishing transportation conformity 

requirements in the Commonwealth on April 29, 2009 (74 FR 19451). 

This Maintenance Plan SIP revision establishes motor vehicle emission budgets

for PM2.5 and NOX. The information in Table III-2, once the EPA approves it for 

purposes of conformity, will establish transportation conformity budgets for the 

Lancaster Area. 

 

11 The Federal transportation conformity regulations were again amended on March 14, 2012 (77 FR 14979) to 

restructure several sections so that they apply to any new or revised NAAQS and make several clarifications to 

improve implementation. 
- 37 -

Table III-2: Motor Vehicle Emission Budgets (Tons per Year)

Lancaster PM2.5 NOx

2007 480 13,895

2017 Predicted 217 6,288

Safety Margin 32 628

2017 Budget 249 6,916

2025 Predicted 161 4,043

Safety Margin 24 404

2025 Budget 185 4,447

The highway emission budgets include a safety margin to accommodate 

unanticipated growth in highway vehicles. The safety margins were created by 

setting aside a portion of the difference between attainment year and maintenance 

year emissions of PM2.5 and NOX. Table III-3 shows that the amount of emission 

reductions anticipated between 2007 and 2017 and between 2007 and 2025 easily 

accommodates the safety margins granted. 

Table III-3: Comparison of Safety Margin to Total Anticipated

Emission Reductions in 2017 and 2025

Lancaster Area Total Emissions PM2.5 NOx

2007 3,715 20,041

2017 3,315 11,081

2025 3,175 8,443

2007 – 2017 Anticipated Emission 

Reductions 400 8,960

Margin Granted 32 628

2007 – 2025 Anticipated Emission 

Reductions 540 11,599

Margin Granted 24 404

For informational purposes, DEP analyzed the projected 2025 inventory and 

found that highway emissions of VOC, NH3, and SO2 account for 13.76 percent, 

0.78 percent, and 2.03 percent of the total projected 2025 inventory, respectively, 

as shown in Table III-4.
- 38 -

Table III-4: Comparison of 2025 On-Road Mobile VOC, NH3, and SO2 Emissions

to the Total Projected 2025 Inventory

Lancaster 2025 SO2 VOC NH3

On-Road Mobile Source Projected Inventory (Tons) 39 1,868 144

Total Projected 2025 Inventory (Tons) 1,930 13,580 18,531

Percent of Total Projected 2025 Inventory (%) 2.03 13.76 0.78

The motor vehicle emission budgets include PM from vehicle exhaust, brake 

wear, and tire wear, which are estimated by the MOVES model. The Department 

has included direct PM2.5 re-entrained road dust emissions from paved and 

unpaved roads in the area source inventory, not in the motor vehicle emission 

budgets. Appendices B-3 and B-4, relating to area source annual emissions, 

contain estimates of the PM2.5 emissions attributable to paved and unpaved roads.

The Lancaster monitoring site includes a monitor that measures PM2.5 mass and a 

speciation monitor that collects data on the chemical constituents of PM2.5 in the 

Lancaster Area. Transportation construction-related fugitive dust emissions are 

not a significant contributor to the PM2.5 concentrations observed at the Lancaster

monitor. At the Lancaster monitor, the crustal component was found to be small 

compared to other components of PM2.5 (See, Figure 1). Given that constructionrelated fugitive dust is one of many source categories contributing to the crustal 

material observed at the monitor, and transportation construction is a small subset 

of all construction, it is reasonable to conclude that transportation constructionrelated fugitive emissions are insignificant.

Figure 1. Pie Chart of 2007 Lancaster Speciation Data

Lancaster

Percentage of Total Mass

Year 2007

Nitrate

17%

Sulfate

25%

Ammonium

15%

Organic carbon

22%

Elemental carbon

4%

Crustal component

2%

Other

15%
- 39 -

IV. AMBIENT AIR QUALITY MONITORING NETWORK

The Commonwealth will continue to operate the air monitoring network in accordance 

with 40 CFR Part 58 to verify the attainment status of the Lancaster Area for the 1997 

and 2006 PM2.5 NAAQS, with no reductions in the number of sites from those in the 

existing network unless pre-approved by EPA. The Commonwealth has concurrently 

submitted a request for redesignation of the Lancaster Area that contains analysis of 

ambient air quality data and related factors.

V. VERIFICATION OF CONTINUED ATTAINMENT

The Commonwealth will track the attainment status of the 1997 and 2006 PM2.5 NAAQS 

in the Lancaster Area by reviewing air quality and emissions data during the maintenance 

period. The Commonwealth will perform an annual evaluation of two key factors, VMT 

data and emissions reported from stationary sources, and compare them to the 

assumptions about these factors used in this plan. The Commonwealth will also evaluate 

the periodic (every three years) emission inventories prepared under EPA’s Air Emission 

Reporting Requirements (40 CFR 51, Subpart A) to see if they exceed the attainment 

year inventory (2007) by more than 10 percent. Based on these evaluations, the 

Commonwealth will consider whether any further emission control measures should be 

implemented. 

VI. CONTINGENCY MEASURES

The Commonwealth will adopt and expeditiously implement corrective actions, as 

necessary and appropriate, in the following circumstances:

A first level response will be prompted if the annual mean PM2.5 concentration exceeds 

15.5 μg/m3in a single calendar year within the maintenance area, if the 98th percentile 

24-hour PM2.5 concentration exceeds 35.0 μg/m3in a single calendar year within the 

maintenance area or if the periodic emissions inventory for the Lancaster Area exceeds 

the attainment year inventory (2007) by more than 10 percent. The first level response 

will consist of a study to determine whether the PM2.5 value indicates a trend toward 

higher PM2.5 values and whether emissions appear to be increasing. If there appears to be 

an increasing trend, the study will evaluate whether the trend is likely to continue and, if 

so, the necessary and appropriate control measures to reverse the trend. Implementation 

of necessary and appropriate controls would take place as expeditiously as possible.

A second level response will be prompted if the 2-year average of the annual mean PM2.5

concentrations exceeds 15.0 μg/m3or if the 2-year average of 98th percentile 24-hour 

PM2.5 concentrations exceeds 35.0 μg/m3 within the maintenance area. If this trigger 

point occurs, the Commonwealth will evaluate whether additional emission control 

measures should be implemented in order to prevent a violation of the air quality 

standards. The Department will analyze the conditions leading to the PM2.5 levels and 

evaluate what measures might be most effective in correcting the PM2.5 levels. The 

Department will also analyze the potential emissions effect of federal, state and local 
- 40 -

measures that have been adopted but not yet implemented at the time the second level 

response is triggered. The Department will then begin the process of adopting any 

selected measures that are necessary and appropriate so that in the event of a violation, 

the measures can be implemented as expeditiously as practicable.

If a violation of the PM2.5 NAAQS occurs, the Commonwealth will propose and adopt 

additional emission reduction measures, as necessary and appropriate, as expeditiously as 

practicable in accordance with the implementation schedule in this section, the CAA, the 

Pennsylvania Air Pollution Control Act, other Pennsylvania statutory requirements, and 

the Department’s Policy for Development, Approval and Availability of Regulations in 

order to return the area to attainment with the standards.

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

NAAQS occurs in the Lancaster Area would be based on criteria including the following:

 air quality analysis indicating nature of violation [cause, location, source];

 emission reduction potential, including extent to which emission generating 

sources occur in the nonattainment area;

 timeliness of implementation in terms of the potential to return the area to 

attainment as expeditiously as practicable; and

 costs, equity and cost-effectiveness.

Additional emission reduction measures the Department would consider pursuing for 

promulgation if a violation of the NAAQS occurs in the Lancaster Area include the 

following:

Regulatory measures:

 A regulation based on the OTC Model Rule to update requirements for consumer 

products;

 A regulation based on the Control Techniques Guidelines (CTG) for industrial 

cleaning solvents; and

 Other regulatory measures identified based on the above-listed criteria.

Non-regulatory measures:

 Voluntary diesel projects:

o Diesel retrofit (including replacement, repowering or alternative fuel use) 

for public or private local onroad or offroad fleets;

o Idling reduction technology for Class 2 yard locomotives; and

o Idling reduction technologies or strategies for truck stops, warehouses and 

other freight-handling facilities.

 Promotion of accelerated turnover of lawn and garden equipment, especially 

commercial equipment.

 Additional promotion of alternative fuels for fleets, home heating and agricultural 

use.
- 41 -

Once the Department’s Bureau of Air Quality has obtained an approved request to initiate 

a rulemaking, the rulemaking may proceed as follows:

Within 2 months: Review by Air Quality Technical Advisory Committee 

(AQTAC), Citizens Advisory Council and other advisory committees,

12

as 

appropriate.

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

Within 7 months: Publication in the Pennsylvania Bulletin for comment as 

proposed rulemaking.

Within 9 months: Public hearing takes place and comment period on proposed 

rule closes.

Within 10 months: Independent Regulatory Review Commission (IRRC) 

comment on proposed rule.

Within 12 months: AQTAC, Citizens Advisory Council and other advisory 

committees, as appropriate, review responses to comments and draft final 

rulemaking.

Within 15 months: EQB meeting/action.

Within 16 months: IRRC action on final rulemaking.

Within 17 months: Attorney General review/action.

Within 18 months: Publication in the Pennsylvania Bulletin as final rulemaking 

and submission to the EPA as a SIP revision. The regulation would 

become effective upon publication in the Pennsylvania Bulletin.

 

12 Other committees could include the Small Business Compliance Advisory Committee and Agriculture Advisory 

Committee.
- 42 -

ACRONYMS AND ABBREVIATIONS

AEO Annual Energy Outlook

AQTAC Air Quality Technical Advisory Committee

BACT Best Available Control Technology

BAT Best Available Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CA LEV California Low Emission Vehicle (program)

CF Control Factor

CFR Code of Federal Regulations

CMU Carnegie Mellon University

CMV Commercial Marine Vessel

DEP Pennsylvania Department of Environmental Protection

EDMS Emissions and Dispersion Modeling System

EGAS Economic Growth Analysis System

EGU Electric Generating Unit

EIA Energy Information Administration

EIS Emission Inventory System

EPA The United States Environmental Protection Agency

EQB Environmental Quality Board

ERC Emission Reduction Credit

ERTAC Eastern Regional Technical Advisory Committee

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FIRE Factor Information Retrieval 

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

HAP Hazardous Air Pollutant

I/M Inspection and Maintenance

IRRC Independent Regulatory Review Commission

ITN Itinerant

LDGV Light Duty Gasoline Vehicles

LDGT Light Duty Gasoline Trucks

MACT Maximum Achievable Control Technology

MANE-VU Mid-Atlantic/Northeast Visibility Union

MARAMA Mid-Atlantic Regional Air Management Association

MOVES Motor Vehicle Emission Simulator

MPO Metropolitan Planning Organization

MY Model Year

NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NEI National Emissions Inventory

NH3 Ammonia

NLEV National Low Emission Vehicle (program)
- 43 -

NMIM National Mobile Inventory Model

NOX Oxides of Nitrogen

NSR New Source Review

OTAQ Office of Transportation and Air Quality

OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood-fired Boiler

PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates 

PM10 Particulate Matter less than 10 microns in diameter

PSD Prevention of Significant Deterioration

RWC Residential Wood Combustion

SCC Source Classification Code

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TSD Technical Support Document 

μg/m3 Microgram per cubic meter

μm Micrometer

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

WOE Weight of Evidence

ZEV Zero Emissions Vehicle
Commonwealth of Pennsylvania

Proposed

Redesignation Request

Lancaster Nonattainment Area

1997 and 2006 Fine Particulate Matter

National Ambient Air Quality Standards

May 2014

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

www.dep.state.pa.us
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TABLE OF CONTENTS

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

I. Demonstration of Attainment and Air Quality Trends Analysis .........................................4

A. Design Value Determination....................................................................................6

B. Air Quality Trends Analysis....................................................................................7

C. Climate Trends Analysis..........................................................................................9

1. Temperature Trends...................................................................................10

2. Precipitation Trends...................................................................................12

D. Additional Trends ..................................................................................................13

1. Population Trends......................................................................................13

2. Economic Trends.......................................................................................14

E. Modeling Analysis.................................................................................................15

II. SIP Approvals and Applicable Requirements....................................................................16

A. Section 110(a)(2) of the CAA................................................................................16

B. Part D - Plan Requirements for Nonattainment Areas...........................................17

1. Section 172(c) of the CAA ........................................................................17

2. Section 173 of the CAA.............................................................................18

3. Section 176 of the CAA.............................................................................18

4. Section 189(e) of the CAA ........................................................................19

C. Conclusion .............................................................................................................19

III. Demonstration of Permanent and Enforceable Improvement............................................19

A. Baseline (2002) Emissions Inventory ....................................................................21

B. Attainment Year (2007) Emissions Inventory .......................................................22

C. Control Measures...................................................................................................23

1. Stationary Point Sources............................................................................25

2. Highway Vehicle Sources..........................................................................30

3. Nonroad Sources........................................................................................33

4. Stationary Area Sources.............................................................................34

IV. Maintenance Plan...............................................................................................................34

Acronyms and Abbreviations ........................................................................................................37
TABLES

Table I-1: Lancaster Area Annual PM2.5 Concentrations...............................................................7

Table I-2: Lancaster Area 24-Hour PM2.5 Concentrations .............................................................7

Table I-3: Lancaster Area Annual PM2.5 Design Values................................................................7

Table I-4: Lancaster Area 24-Hour PM2.5 Design Values..............................................................8

Table I-5: Lancaster Area Monthly Mean Temperature (°F) .......................................................11

Table I-6: Lancaster Area Precipitation (inches)..........................................................................12

Table III-1: 2002 Lancaster Area Annual Emissions (Tons per Year).........................................22

Table III-2: 2007 Lancaster Area Annual Emissions (Tons per Year).........................................23

Table III-3: Change in Lancaster Area Annual Emissions (Tons per Year) from 2002 to 

2007............................................................................................................................24

Table III-4: Summary of Emission Totals (Tons) in 2007, 2017 and 2025..................................25

FIGURES

Figure I-1: Pennsylvania’s 1997 PM2.5 Nonattainment Areas......................................................5

Figure I-2: Pennsylvania’s 2006 PM2.5 Nonattainment Areas......................................................5

Figure I-3: PM2.5 Annual Concentration Trend.............................................................................8

Figure I-4: PM2.5 24-Hour Concentration Trend...........................................................................9

Figure I-5: Pie Chart of 2007 Lancaster Speciation Data .............................................................10

Figure I-6: Lancaster Area Monthly Mean Temperature (°F) ......................................................11

Figure I-7: Lancaster Area Annual Precipitation (inches)............................................................12

Figure I-8: Lancaster Area Population Trend ...............................................................................13

Figure I-9: Lancaster Area Population and Labor Force Trends..................................................14

Figure I-10: Pennsylvania and National Coincident Indexes from the Philadelphia 

Federal Reserve Bank.................................................................................................15
- 1 -

INTRODUCTION

Particulate matter (PM) is a mixture of microscopic solids and liquid droplets suspended in air 

that include: acids (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles 

and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM2.5

describes particulate matter that is less than or equal to 2.5 micrometers (μm) in diameter, 

approximately 1/30th the diameter of a human hair. Because of their small size, fine particles 

can penetrate deeply into the lungs.

Health studies have shown a significant association between exposure to fine particles and 

premature death from heart or lung disease. Fine particles can aggravate heart and lung diseases 

and have been linked to effects such as cardiovascular symptoms, cardiac arrhythmias, heart 

attacks, respiratory symptoms, asthma attacks, and bronchitis. These effects can result in 

increased hospital admissions, emergency room visits, absences from school or work, and 

restricted activity days. Individuals that may be particularly sensitive to fine particle exposure 

include people with heart or lung disease, older adults, and children. The article, “FineParticulate Air Pollution and Life Expectancy in the United States” by C. Arden Pope, III, et al. 

published January 22, 2009 in the New England Journal of Medicine evaluated the role PM2.5 

reductions occurring in the 1980s and 1990s had on the increased life expectancy observed over 

that period. The study found that a reduction of 10 micrograms per cubic meter (μg/m3) of PM2.5 

was associated with an average increase in life expectancy of 7.3 months.

PM2.5 has significant environmental impacts, including acid rain and stream eutrophication. 

PM2.5 also affects visibility (regional haze) through the scattering and absorption of light. Fine 

particles, similar in size to the wavelength of light, are most efficient, per unit of mass, at 

reducing visibility. Soiling and materials damage can also be caused by PM2.5 in the air.

The United States Environmental Protection Agency (EPA) issued PM2.5 national ambient air 

quality standards (NAAQS) in 1997 after evaluating hundreds of health studies and conducting 

an extensive peer review process. The EPA established an annual primary (health-based) and 

secondary (welfare-based) standard of 15.0 micrograms per cubic meter (μg/m3), based on the 

3-year average of annual mean PM2.5 concentrations. The EPA also established a primary and 

secondary 24-hour standard of 65 μg/m3determined by the 3-year average of the 98th percentile 

of 24-hour concentrations. In 2006, the EPA promulgated a revised 24-hour PM2.5 standard of 

35 μg/m3determined by the 3-year average of the 98th percentile of 24-hour concentrations. The 

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

On December 17, 2004, the EPA issued air quality designations for the PM2.5 standard based on 

air quality monitoring data from 2001-2003. The final designations were published in the 

Federal Register on January 5, 2005 (70 FR 944). The designations became effective on April 5, 

2005. On April 5, 2005, the EPA issued a supplemental notice changing the designation of 

certain areas from nonattainment to attainment based on newly available air quality data 

(70 FR 19844; April 14, 2005). The April 5, 2005, supplemental notice only affected Mercer 

County in the Commonwealth of Pennsylvania.
- 2 -

The Lancaster Area was one of eight areas in Pennsylvania, comprising all or parts of 

21 Pennsylvania counties, designated by the EPA as nonattainment for the 1997 PM2.5 NAAQS. 

The Lancaster Area, consisting of Lancaster County in Pennsylvania, was designated by EPA as 

nonattainment because it violated the 1997 annual standard of 15.0 μg/m3based on 2001-2003 

monitoring data. The Lancaster Area did not violate the 1997 24-hour standard of 65 μg/m3.

On October 8, 2009, the EPA promulgated air quality designations for the 2006 24-hour PM2.5

standard based on 2006-2008 air quality monitoring data. The final designations were published 

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

comprised of all or portions of 22 counties in Pennsylvania as PM2.5 nonattainment areas. The 

designations became effective on December 14, 2009.

The Lancaster Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 PM2.5 NAAQS. The Lancaster Area was designated nonattainment 

because the area violated the 2006 24-hour PM2.5 standard of 35 μg/m

3

based on 2006-2008

monitoring data.

The subsequent analyses described in this Request for Redesignation clearly demonstrate that the 

ambient air quality in the Lancaster Area now meets the 1997 and 2006 PM2.5 NAAQS. The 

emission reductions responsible for the improvements in PM2.5 air quality are both permanent 

and enforceable. These analyses and the maintenance plan submitted concurrently demonstrate 

that the Lancaster Area has completed all criteria set forth in Section 107(d)(3)(E) of the Clean 

Air Act (CAA) and should be officially redesignated as attainment for both the 1997 and 2006 

PM2.5 NAAQS.

Section 107(d)(3)(E) of the CAA states that an area may be redesignated to attainment if the 

following conditions are met:

● The NAAQS has been attained (discussed in Section I);

● The applicable implementation plan has been fully approved under Section 110(k) of the 

CAA and the state has met all applicable requirements for the area under Section 110 and 

Part D (discussed in Section II);

● The improvement in air quality is due to permanent and enforceable reductions in 

emissions (discussed in Section I and Section III); and

A Maintenance Plan with contingency measures has been fully approved under Section 175A 

(discussed in Section IV).

This Request for Redesignation describes how the Lancaster Area satisfies each of the CAA’s 

Section 107(d)(3)(E) criteria for redesignation to attainment.

Requirements for a public comment process are set forth in Section 110(a)(2) of the CAA, 

40 CFR Section 51.102(d) and Section 7.5 of the Pennsylvania Air Pollution Control Act. 

35 P.S. Section 4007.5(b). On March 8, 2014, the Department provided notice of a public 
- 3 -

comment period and the opportunity for a hearing on the Maintenance Plan, 2007 

comprehensive inventory required by Section 172(c)(3) of the CAA, and this Request for 

Redesignation. The public comment period closed April 11, 2014. The Department scheduled 

the public hearing to occur on April 10, 2014, but no persons expressed interest in presenting 

testimony or attending. Therefore, the Department cancelled the hearing. The Department 

received comments from one commentator, which have been addressed in a Comment and 

Response document.
- 4 -

I. DEMONSTRATION OF ATTAINMENT AND AIR QUALITY TRENDS 

ANALYSIS

On December 17, 2004, the EPA issued air quality designations for the 1997 PM2.5

annual standard based on 2001-2003 air quality monitoring data. The final designations 

were published in the Federal Register on January 5, 2005 (70 FR 944). The 

designations became effective on April 5, 2005. On April 5, 2005, the EPA issued a 

supplemental notice changing the designation of certain areas from nonattainment to 

attainment based on newly available air quality data (70 FR 19844; April 14, 2005). The 

April 5, 2005 supplemental notice only affected Mercer County in the Commonwealth of 

Pennsylvania (Commonwealth or Pennsylvania).

The Lancaster Area was one of eight areas in Pennsylvania, comprising all or parts of 

21 Pennsylvania counties, designated by the EPA as nonattainment for the 1997 PM2.5

NAAQS. The Lancaster Area, consisting of Lancaster County in Pennsylvania, was 

designated as nonattainment because it violated the 1997 annual standard of 15.0 μg/m3

based on 2001-2003 monitoring data. The Lancaster Area did not violate the 1997 24-

hour standard of 65 μg/m3.

On October 8, 2009, the EPA promulgated air quality designations for the 2006 PM2.5

standard based on 2006-2008 air quality monitoring data. The final designations were 

published in the Federal Register on November 13, 2009 (74 FR 58688). The EPA 

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

PM2.5 nonattainment areas. The designations became effective on December 14, 2009. 

The Lancaster Area was one of seven areas in Pennsylvania designated by the EPA as 

nonattainment for the 2006 PM2.5 NAAQS. The Lancaster Area was designated 

nonattainment because the area violated the 2006 24-hour PM2.5 standard of 35 μg/m3

based on 2006-2008 monitoring data.
- 5 -

Figure I-1: Pennsylvania’s 1997 PM2.5 Nonattainment Areas

Figure I-2: Pennsylvania’s 2006 PM2.5 Nonattainment Areas
- 6 -

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

The Lancaster Area’s annual PM2.5 design value has decreased over the 2001 to 2012

time frame. Based on 2001-2003 air quality monitoring data, the Lancaster Area’s 

annual and 24-hour design values for 2003 were 17.0 μg/m3and 45 μg/m3, respectively. 

Based on 2001-2003 air quality monitoring data, the Lancaster Area’s 2012 annual and 

24-hour design values were 12.1 μg/m3and 31 μg/m3. Following EPA criteria, annual 

PM2.5 design values below 15.0 μg/m3and 24-hour design values below 35 μg/m3are 

considered to be attainment. Annual and 24-hour concentrations are expected to remain 

lower than 15 μg/m3and 35 μg/m3over the next decade.

On September 25, 2009, the EPA determined that the Lancaster Area had attained the 

1997 PM2.5 NAAQS based on quality assured, quality controlled and certified ambient air 

monitoring data that show the area had monitored attainment based on 2006-2008 data 

(“Clean Data Determination”) (74 FR 48863). This final action suspended the 

requirements for this area to submit an attainment demonstration and associated 

reasonably available control measures, reasonable further progress plans, contingency 

measures and other planning SIP revisions related to the attainment of the 1997 PM2.5

NAAQS for so long as the area continues to attain the 1997 PM2.5 NAAQS1.

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

PM2.5 NAAQS based on quality assured, quality controlled and certified ambient air 

monitoring data that show the area had monitored attainment based on 2008-2010 data 

(“Clean Data Determination”) (77 FR 18922). This final action suspended the 

requirements for this area to submit an attainment demonstration and associated 

reasonably available control measures, reasonable further progress plans, contingency 

measures and other planning SIP revisions related to the attainment of the 2006 PM2.5

NAAQS for so long as the area continues to attain the 2006 PM2.5 NAAQS.

The determination of attainment did not “redesignate” the area as “attainment.” The 

Lancaster Area remains nonattainment for the 1997 and 2006 PM2.5 NAAQS until the 

Commonwealth submits, and EPA approves, a Request for Redesignation and a 

Maintenance Plan showing the area can maintain these standards for at least 10 years.

A. Design Value Determination

The ambient air quality analysis is based on PM2.5 data measured at the Lancaster 

Area monitoring site. The ambient air quality data analysis for PM2.5 was 

completed using the appropriate regulations and guidance documents. Monitoring 

procedures were determined in accordance with 40 CFR Part 58. The PM2.5

design values were calculated in accordance with 40 CFR Part 50, Appendix N, 

“Interpretation of the National Ambient Air Quality Standards for Particulate 

Matter.”

 

1 The EPA followed this action on July 29, 2011 (76 FR 45424) with a statutorily required determination under 

Section 179(c) of the CAA, that the Lancaster Area attained the 1997 PM2.5 NAAQS by the applicable attainment 

date of April 5, 2010. EPA based this determination on complete, quality assured, and certified ambient air 

monitoring data that show the area monitored attainment for the 2007-2009 monitoring period.
- 7 -

B. Air Quality Trends Analysis

This section provides a brief summary of PM2.5 monitoring concentrations in the

Lancaster Area. 

Trends in PM2.5 design values were analyzed from 2001 through 2012. Table I-1 

displays annual PM2.5 concentrations monitored in the Lancaster Area. Table I-2 

contains the 98th percentile of 24-hour concentrations for each year. 

Table I-1: Lancaster Area Annual PM2.5 Concentrations

Annual Mean

Site and AQS 

ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Grofftown Rd

42-071-0007 17.2 16.2 17.6 16.6 18.2 14.1 15.4 13.9 12.2 11.7 12.0 12.6

Table I-2: Lancaster Area 24-Hour PM2.5 Concentrations

Annual 98% Concentration

Site and AQS 

ID 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Grofftown Rd 

42-071-0007 42.1 40.2 51.5 35.5 45.2 34.9 39.6 35.0 29.4 34.1 29.9 28.9

Tables I-3 and I-4 contain the Lancaster Area’s annual and 24-hour PM2.5 design 

values calculated using the 2001 through 2012 monitoring data. Design values

for the annual and 24-hour PM2.5 NAAQS show a declining trend. The Lancaster 

Area was designated as nonattainment for the 1997 annual standard based on the 

2001 through 2003 annual design value of 17.0 μg/m3. The 24-hour design value 

for that time period was 45 μg/m3. Compared with the 2001 through 2003 design 

values, the annual design value for 2010 through 2012 has decreased by

29 percent and the 24-hour design value by 31 percent. The annual and 24-hour 

PM2.5 design values for the Lancaster Area are shown below in Tables I-3 and I-4, 

respectively.

Table I-3: Lancaster Area Annual PM2.5 Design Values

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

Grofftown Rd 

42-071-0007 16.9 17.1 17.0 16.8 17.5 16.3 15.9 14.5 13.8 12.6 12.0 12.1

1997 Annual PM2.5 NAAQS = 15 ug/m3

Design Value
- 8 -

Table I-4: Lancaster Area 24-Hour PM2.5 Design Values

The 2001 through 2012 trend lines for annual and 24-hour PM2.5 concentrations

are shown in Figures I-2 and I-3. As shown in Figures I-2 and I-3, the slope of 

the trend lines for the annual and 24-hour PM2.5 concentrations are both negative, 

indicating decreasing concentrations. 

Figure I-3: PM2.5 Annual Concentration Trend

Site and AQS ID

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

2010-

2012

Grofftown Rd 

42-071-0007 42 43 45 42 44 39 40 37 35 33 31 31

2006 24-Hour PM2.5 NAAQS 3 year 98% = 35 ug/m3

Design Value

y = -0.5704x + 18.519

0

2

4

6

8

10

12

14

16

18

20

200120022003200420052006200720082009201020112012

PM2.5 Concentration (ug/m3)

PM2.5 Annual Trend

Yearly PM2.5

Mean

Level of 1997

Annual

Standard
- 9 -

Figure I-4: PM2.5 24-Hour Concentration Trend

C. Climate Trends Analysis

PM2.5 formation in the eastern United States is a complex process involving local 

and regional meteorology, topography, chemistry and transport. Sulfates and 

nitrates are formed primarily through atmospheric reactions of precursor 

emissions of sulfur dioxide (SO2), oxides of nitrogen (NOX) and ammonia (NH3). 

Organic carbon is a combination of secondary organic particles formed from 

emissions of volatile organic compounds (VOC) and the organic portion of 

primary PM2.5 that is directly emitted or condenses near its source. Currently, our 

understanding of sulfate and nitrate chemistry and its impacts on PM2.5

concentrations far exceeds our understanding of contributions from anthropogenic 

VOCs. This is important because sulfates, nitrates, ammonium and organic 

carbon are major contributors to the total PM2.5, making up approximately 

80 percent of the annual PM2.5 concentration observed in the Lancaster Area in 

2007.

y = -1.4549x + 46.648

0

10

20

30

40

50

60

200120022003200420052006200720082009201020112012

PM2.5 Concentration (ug/m3)

PM2.5 24-Hour Trend

24-Hour

PM2.5 98th%

Level of 1997

24-Hour

Standard
- 10 -

Figure I-5: Pie Chart of 2007 Lancaster Speciation Data

Attainment of the PM2.5 NAAQS involves the range of meteorological conditions 

throughout the year. PM2.5 chemistry favors sulfate formation during the warm 

summer months and nitrate formation during the colder winter months. In 

addition, local temperature inversions more common in the winter can concentrate 

emissions near the surface, leading to periods of elevated PM2.5 concentrations.

To assess whether it is likely that unusual meteorological patterns have 

contributed to the lower PM2.5 concentrations observed in the Lancaster Area, 

temperature and precipitation trends over the last 10 years were examined.

The data used in the trends analysis is from the Global Historical Climatology 

Network (GHCN) database for the Lancaster Airport. The monthly summary data 

was obtained from the NOAA National Climatic Data Center at: 

www.ncdc.noaa.gov/cdo-web/search#t=secondTabLink

1. Temperature Trends

Table I-5 presents monthly mean temperature data for the Lancaster Area 

for 2001 through 2012. Figure I-5 graphically displays the data.

Lancaster

Percentage of Total Mass

Year 2007

Nitrate

17%

Sulfate

25%

Ammonium

15%

Organic carbon

22%

Elemental carbon

4%

Crustal component

2%

Other

15%
- 11 -

Table I-5: Lancaster Area Monthly Mean Temperature (°F)

Lancaster Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2001 27.9 33.6 37.6 50.9 61.0 71.1 71.1 75.2 64.0 54.9 48.0 39.4

2002 35.2 37.0 41.9 54.0 59.9 71.6 76.6 75.6 67.5 52.3 41.7 30.0

2003 24.6 25.9 40.3 49.5 57.6 67.6 73.9 74.7 65.8 51.6 47.5 33.8

2004 23.5 31.5 43.3 52.3 66.9 68.5 73.0 71.6 67.5 53.4 45.7 34.5

2005 29.1 32.9 36.7 53.1 56.8 72.9 75.6 75.7 70.0 55.9 45.9 30.7

2006 38.8 32.5 42.1 53.4 61.0 70.5 76.3 74.5 63.5 52.7 47.5 39.9

2007 35.1 25.0 40.3 48.0 63.3 71.8 72.9 73.0 67.5 60.8 42.3 34.2

2008 32.5 32.2 41.4 52.5 57.2 72.7 74.1 70.3 66.2 52.3 42.3 34.3

2009 25.0 33.1 40.5 51.4 61.7 69.3 71.1 74.1 64.2 52.7 48.0 32.7

2010 30.4 28.9 46.6 54.1 64.2 73.8 77.4 74.7 68.5 54.5 43.7 30.0

2011 25.9 32.7 40.5 54.0 64.8 72.3 78.6 73.2 67.5 53.6 47.3 39.0

2012 34.7 37.4 49.8 51.1 66.4 70.7 78.1 74.3 65.5 55.0 40.1 38.8

Figure I-6: Lancaster Area Monthly Mean Temperature (°F)

The Lancaster Area was designated nonattainment for the 1997 PM2.5

NAAQS based on 2001 through 2003 monitoring data and nonattainment 

for the 2006 PM2.5 NAAQS based on 2006 through 2008 monitoring data. 

These timeframes show typical year-to-year variation in temperature with 

no unusual conditions that would be expected to cause higher PM2.5

concentrations as experienced. The Lancaster Area’s Clean Data 

Determinations for the 1997 and 2006 PM2.5 NAAQS were based on 2006

through 2008, and 2008 through 2010 monitoring data, respectively. The 

Lancaster Area continues to monitor attainment. Examination of the 

temperature data from 2006 through 2012 shows normal variation in 

0

10

20

30

40

50

60

70

80

90

1/1/20011/1/20021/1/20031/1/20041/1/20051/1/20061/1/20071/1/20081/1/20091/1/20101/1/20111/1/2012

Monthly Mean Temperature (F)
- 12 -

seasonal temperatures but no evidence of unusual patterns that would be

expected to repress PM2.5 formation.

2. Precipitation Trends

Table I-6 presents monthly and annual precipitation data for the Lancaster 

Area for 2001 through 2012. Figure I-6 graphically displays the annual 

precipitation data.

Table I-6: Lancaster Area Precipitation (inches)

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Annual 

Total

2001 2.1 1.7 4.0 2.2 3.2 1.8 1.1 4.5 4.3 0.7 0.9 1.5 27.9

2002 2.5 0.3 3.6 3.4 5.6 3.5 1.1 3.5 3.1 7.8 3.8 4.3 42.4

2003 1.5 3.0 3.3 2.6 4.4 6.0 2.6 3.6 8.7 4.6 3.8 2.4 46.3

2004 1.7 2.8 1.7 5.9 3.2 5.7 7.2 5.6 5.8 2.0 3.6 3.1 48.1

2005 3.3 1.5 3.6 4.2 1.1 5.7 7.0 1.5 0.8 8.1 3.0 3.0 42.7

2006 3.9 1.6 0.9 4.1 2.5 13.1 3.6 1.2 6.0 3.4 6.0 2.2 48.3

2007 2.1 1.8 3.0 4.4 1.3 4.2 5.1 4.3 1.0 5.3 2.7 3.8 39.0

2008 0.9 4.7 3.1 1.0 3.7 2.7 6.6 1.3 4.9 2.2 1.5 3.4 36.0

2009 1.8 0.8 1.5 4.1 4.4 4.6 2.2 6.0 4.2 5.8 1.5 4.3 41.2

2010 1.4 1.8 3.1 1.9 3.9 1.4 6.1 1.5 7.9 3.6 2.1 2.0 36.5

2011 1.5 2.9 4.2 6.4 5.2 4.6 1.7 6.7 13.1 3.5 4.3 3.1 57.1

2012 2.1 2.1 1.1 1.8 3.8 4.1 3.7 1.4 6.1 7.2 1.1 3.2 37.8

Figure I-7: Lancaster Area Annual Precipitation (inches)

0

10

20

30

40

50

60

70

200120032005200720092011

Precipitation (inches)

Annual Precipitation
- 13 -

Examination of the 2001 through 2003 precipitation data indicates both 

drier and wetter than usual years within the timeframe. Examination of 

the precipitation data from 2006 through 2011 also shows variation in 

precipitation amounts. There is no indication from the data that unusual 

precipitation patterns contributed to the lower PM2.5 concentrations in 

recent years in which the Lancaster Area monitored attainment of the 

PM2.5 NAAQS.

D. Additional Trends

1. Population Trends

The Lancaster Area, which consists of Lancaster County, has had 

significant population growth over the last decade. The population of 

Lancaster County increased approximately 10 percent between the 2000 

and 2010 Censuses. According to the Bureau of the Census, the

population of Lancaster County was 471,818 in 2000 and 519,445 in 2010. 

Lancaster County ranked the 6th largest in population in Pennsylvania.

Population increases correspond with increased emissions from some 

types of emission sources and, therefore, can result in increased pollution 

levels. While the Lancaster Area’s population has grown approximately 

10 percent over the last decade, this growth has not resulted in increased 

PM2.5 concentrations. In fact, the area’s PM2.5 concentrations have 

declined in spite of the increase in population.

Figure I-8: Lancaster Area Population Trend

440,000

450,000

460,000

470,000

480,000

490,000

500,000

510,000

520,000

530,000

Lancaster County Population Trend

Population
- 14 -

2. Economic Trends

Economic trends could have impacts on emissions and consequently affect 

PM2.5 concentrations in the Lancaster Area. The two factors considered 

here include estimated labor force changes in the Lancaster Area and 

overall economic activity in Pennsylvania as measured by the Coincident 

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

Labor, Bureau of Labor Statistics, Mid-Atlantic Information Office. The 

Coincident Index data was obtained from the Philadelphia Reserve Bank.

Figure I-8 shows the Lancaster Area’s population change and estimated 

labor force change since 1980. A larger labor force could lead to more 

driving and increased infrastructure demands. This in turn could lead to 

higher emissions. Increases in the county’s labor force also contribute to 

overall increases in economic activity (greater family income/spending). 

The Philadelphia Federal Reserve Bank has tracked economic activity in 

Pennsylvania over the last 25 years. Pennsylvania’s Economic Activity 

Index is graphically depicted in Figure I-9. In spite of these upward 

trends, air quality continues to improve in the Lancaster Area.

Figure I-9: Lancaster Area Population and Labor Force Trends

Data Source:

U.S. Department of Labor, Bureau of Labor Statistics, Mid-Atlantic Information Office

The database containing “State and local industry employment and earnings – monthly” data was accessed 

from the following site: www.bls.gov/ro3/data.htm

0

100000

200000

300000

400000

500000

600000

1980 1990 2000 2010

Lancaster County Population and Labor 

Force Trends

Nonfarm Employment

Population
- 15 -

Figure I-10: Pennsylvania and National Coincident Indexes from the Philadelphia Federal 

Reserve Bank

Data downloaded on 5/24/2012 from: The Federal Reserve Bank of Philadelphia at: 

www.philadelphiafed.org/research-and-data/regional-economy/indexes/coincident/

The Federal Reserve Bank of Philadelphia produces a monthly coincident 

index for each of the 50 states. The coincident indexes combine 

four state-level indicators to summarize current economic conditions in a 

single statistic. The four state-level variables in each coincident index are 

nonfarm payroll employment, average hours worked in manufacturing, the 

unemployment rate, and wage and salary disbursements deflated by the 

consumer price index (U.S. city average). The trend for each state’s index 

is set to the trend of its gross domestic product (GDP), so long-term 

growth in the state’s index matches long-term growth in its GDP.

E. Modeling Analysis

Modeling that EPA conducted to analyze the impact of revising the PM2.5 

NAAQS, summarized in the Regulatory Impact Analysis of December 2012, 

indicates that Lancaster County would maintain the 1997 and 2006 NAAQS, as 

well as attain the 2012 NAAQS with a concentration of 9.4 μg/m3in 2020.2The 

modeling was performed with a 2007 base year. The projection to 2020 took into 

account reductions expected to occur between 2007 and 2020 from existing 

federal and State control programs. The results of EPA’s modeling support 

redesignating the Lancaster Area to attainment for the 1997 and 2006 PM2.5 

NAAQS.

 

2 www.epa.gov/air/particlepollution/2012/2020table.pdf

0.00

20.00

40.00

60.00

80.00

100.00

120.00

140.00

160.00

180.00

Jan-79

Feb-81

Mar-83

Apr-85

May-87

Jun-89

Jul-91

Aug-93

Sep-95

Oct-97

Nov-99

Dec-01

Jan-04

Feb-06

Mar-08

Apr-10

Coincident Index

Pennsylvania and National Coincident 

Indexes

PA

US
- 16 -

II. SIP APPROVALS AND APPLICABLE REQUIREMENTS

In order for EPA to redesignate a nonattainment area to attainment, the applicable SIP 

revision must be fully approved by the EPA under Section 110(k) of the CAA. In 

addition, the state must have met all requirements applicable to the area under 

Section 110 and Part D-Plan Requirements for Nonattainment Areas. The specific 

requirements applicable to the Lancaster Area can be found in Sections 110(a)(2), and 

Part D Sections 172(c) (relating to nonattainment plan provisions), 173 (relating to permit 

requirements) and 176 (relating to limitations on certain federal assistance) of the CAA. 

The U.S. Court of Appeals for the District of Columbia circuit has also recently held that 

EPA must implement the PM2.5 NAAQS pursuant to Subpart 4 of Part D – see Section III 

below for more information.

These requirements have been fulfilled for the Lancaster Area.

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

Section 110(a) of the CAA contains the general requirements for a SIP. 

Pennsylvania concludes that, as EPA has stated in previous rulemaking in another 

state,

3

only the Section 110 and Part D requirements that are linked with a 

particular area’s designation are the relevant measures to consider in evaluating a 

redesignation request. Further, Pennsylvania believes that the other Section 110 

elements that are not connected with nonattainment plan submissions and not 

linked with an area’s attainment status are also not applicable requirements for 

purposes of redesignation. A state remains subject to these requirements after an 

area is redesignated to attainment.

The requirements of Section 110(a)(2) of the CAA that are statewide 

requirements and that are not linked to the PM2.5 nonattainment status of the 

Lancaster Area are not applicable requirements for purposes of review of the 

Commonwealth’s PM2.5 redesignation request. However, EPA requires that the 

Commonwealth’s Prevention of Significant Deterioration (PSD) requirements be 

approved prior to redesignation, because PSD requirements will apply after 

redesignation. Sections 110(a)(2)(C) and 110(a)(2)(J) of the CAA require state 

plans to meet the requirements of CAA, Subchapter I, Part C, which contains PSD 

requirements. In addition, Section 110(a)(2)(I) requires that a plan revision for an 

area designated as a nonattainment area meet the applicable requirements of 

CAA, Subchapter I, Part D (relating to nonattainment areas). Therefore, 

Pennsylvania has concluded that only the parts of Sections 110(a)(2)(C), 

110(a)(2)(I) and 110(a)(2)(J) that relate to Part D applicable requirements or PSD 

are applicable for purposes of redesignation.

 

3 See EPA’s proposed approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland 

nonattainment area for the 1997 PM2.5 NAAQS (76 FR 79593). On December 31, 2012, EPA published final 

approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland nonattainment area for the 

1997 PM2.5 NAAQS (77 FR 76883).
- 17 -

EPA has previously approved provisions of Pennsylvania’s SIP addressing 

Section 110 requirements, including provisions addressing PM2.5. Pennsylvania’s 

SIP measures meeting Section 110(a)(2)(C) and 110(a)(2)(J) requirements are 

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

associated with this Request for Redesignation for the Lancaster Area is a SIP 

revision for an area designated as a nonattainment area and meets the applicable 

requirements of Part D of Subchapter I of the CAA. Therefore, the Maintenance 

Plan associated with this Request for Redesignation meets the requirements of 

Section 110(a)(2)(I). Please see the discussion below concerning Part D (plan 

requirements for nonattainment areas).

B. Part D - Plan Requirements for Nonattainment Areas

1. Section 172(c) of the CAA

Section 172 of the CAA contains the general provisions required to be 

included in SIP revisions for nonattainment areas. These include 

attainment demonstrations, reasonably available control measures, 

reasonable further progress, inventory data, and permitting requirements.

As stated above, on September 25, 2009, the EPA determined that the 

Lancaster Area had attained the 1997 PM2.5 NAAQS (“Clean Data 

Determination”) (73 FR 49949). EPA’s Clean Data Determination was 

based on quality-assured, quality-controlled and certified ambient air 

monitoring data that show the area had monitored attainment since the 

2006 through 2008 monitoring period. The Clean Data Determination 

suspended the requirements for this area to submit an attainment 

demonstration, associated reasonably available control measures, a 

reasonable further progress plan, contingency measures, and other 

planning SIP revisions related to attainment of the 1997 PM2.5 NAAQS for 

so long as the area continues to meet the 1997 PM2.5 NAAQS.

On March 29, 2012, the EPA determined that the Lancaster Area had 

attained the 2006 PM2.5 NAAQS based on quality assured, quality 

controlled and certified ambient air monitoring data that show the area had 

monitored attainment based on 2008-2010 data (“Clean Data 

Determination”) (77 FR 18922). This final action suspended the 

requirements for this area to submit an attainment demonstration and 

associated reasonably available control measures, reasonable further 

progress plans, contingency measures and other planning SIP revisions 

related to the attainment of the 2006 PM2.5 NAAQS for so long as the area 

continues to attain the 2006 PM2.5 NAAQS.

Submittal of a comprehensive inventory is required by 40 CFR

Section 51.1008 to meet the requirements of Section 172(c)(3) of the 

CAA. This requirement was not suspended by the Clean Data 
- 18 -

Determination. In fulfillment of this requirement, the 2007 inventory, 

which also serves as the attainment year inventory, is being submitted as 

part of the Maintenance Plan, submitted concurrently with this Request for 

Redesignation.

2. Section 173 of the CAA

Section 173 of the CAA outlines requirements related to permitting of air 

pollution sources in nonattainment areas.

Stationary air pollution sources are subject to the regulations of the 

Commonwealth of Pennsylvania, Pennsylvania Code in Title 25 

Environmental Resources (25 Pa. Code Chapters 121-145). These 

regulations include:

● Standards of Performance for New Stationary Sources 

promulgated by EPA under the Clean Air Act (25 Pa. Code

Chapter 122);

● Standards for Contaminants (25 Pa. Code Chapter 123);

● National Emission Standards for Hazardous Air Pollutants (25 Pa. 

Code Chapter 124);

● Construction, Modification, Reactivation and Operation of 

Sources, including plan approval, prevention of significant 

deterioration, new source review, operating permit program 

(25 Pa. Code Chapter 127);

● Standards for Sources (25 Pa. Code Chapter 129); and

● Annual Emission Statements and required reporting to the 

Department (25 Pa. Code Chapter 135).

These permitting, stationary source monitoring and reporting, 

preconstruction review, offset ratios and enforceable emission limitations 

requirements were adopted to implement the federally mandated 

requirements in Sections 110, 172, 173 and 182(a) of the CAA. EPA has 

approved all of these regulations as SIP revisions, as indicated in 

Section III of this document.

3. Section 176 of the CAA

Section 176(c) of the CAA contains the provision prohibiting federal 

financing of projects or activities that do not conform to an approved 

implementation plan.
- 19 -

The Commonwealth adopted and incorporated EPA’s General Conformity 

rule (40 CFR Part 93, Subpart B) by reference in its entirety in 25 Pa. 

Code Section 127.802. The General Conformity regulation describes 

procedures to determine if federally-financed, non-transportation projects 

are in conformity with air quality plans.

EPA and the U.S. Department of Transportation (DOT) have issued 

regulations regarding criteria and procedures for demonstrating and 

assuring conformity of transportation improvement programs (TIP or 

program), long range plans (LRP or plan), and individual transportation 

projects with the requirements of the CAA and the SIP for the specific 

nonattainment area. Affected transportation planning organizations are 

complying with all federal laws, regulations and guidance for 

transportation conformity.

4. Section 189(e) of the CAA

In light of a recent court decision, Natural Resources Defense Council v. 

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

Section III), the Department considered Section 189(e) of the CAA. 

According to Section 189(e) and the court decision, control requirements 

in nonattainment areas applicable for major stationary sources of PM also 

apply to major stationary sources of PM precursors. Pennsylvania 

assessed emissions of PM2.5, SO2, NOX, VOC and NH3 for the 

maintenance demonstration. Please see Section III-C-1 relating to control 

measures for stationary sources for a discussion of the stationary source 

control measures in place in the Lancaster Area.

C. Conclusion

The requirements of Section 110(a) and Subpart D of the CAA have been fulfilled

in the Lancaster Area for the 1997 and 2006 PM2.5 NAAQS. 

III. DEMONSTRATION OF PERMANENT AND ENFORCEABLE IMPROVEMENT

This section provides an assessment of the PM2.5 and PM2.5 precursor emissions at a time 

the Lancaster Area was monitoring nonattainment of the PM2.5 NAAQS and at the time 

when this area attained the PM2.5 NAAQS. A 2002 (baseline) inventory of PM2.5 and 

PM2.5 precursor emissions is used to represent emissions during the PM2.5 nonattainment 

designation period. A 2007 inventory is used to identify PM2.5 and PM2.5 precursor 

emissions during a period when the Lancaster Area demonstrated that it attained the 

PM2.5 NAAQS. Detailed information is presented in the Maintenance Plan by sector.

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

the EPA recognizes that effective control measures for PM2.5 will vary among 
- 20 -

nonattainment areas. This recognition was reflected in EPA’s “Implementation Guidance 

for the 2006 24-Hour Fine Particle National Ambient Air Quality Standard,” Office of 

Air Quality Planning and Standards, EPA, March 2, 2012 (“Implementation Guidance for 

the 2006 24-Hour PM2.5 NAAQS”). In the Implementation Guidance for the 2006 PM2.5

NAAQS, EPA adopted the framework and policy approach the agency espoused in its 

implementation rule for the 1997 PM2.5 NAAQS, known as the “Clean Air Fine Particle 

Implementation Rule (72 FR 20586; April 25, 2007) (the Implementation Rule for the 

1997 PM2.5 NAAQS”)

In its Implementation Rule for the 1997 PM2.5 NAAQS, EPA had established general 

presumptive policies for assessing which PM2.5 precursors should be evaluated for 

possible controls. In that earlier rule, the EPA required states to evaluate control 

measures for SO2 and primary PM2.5 in all locations. The EPA required states to evaluate 

control measures for NOX unless a technical demonstration is made to show NOX does 

not significantly contribute to PM2.5. The EPA required states to evaluate measures for 

VOC and NH3 only if a technical demonstration is made to show they significantly 

contribute to PM2.5 in that area.

The EPA reaffirmed the appropriateness of these presumptions in its Implementation 

Guidance for the 2006 24-Hour PM2.5 NAAQS. Meanwhile, the U.S. Court of Appeals 

for the D.C. Circuit was considering a challenge to the Implementation Rule for the 1997 

PM2.5 NAAQS, in Natural Resources Defense Council v. EPA, No. 08-1250. On 

January 4, 2013, the Court handed down its ruling in that case. 

The Court granted the petitions for review and remanded the case to EPA to repromulgate the rule pursuant to Subpart 4 of Part D of the Clean Air Act, rather than 

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

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

PM2.5 NAAQS. According to EPA’s June, 2013 withdrawal memorandum (see 

second page of memorandum)4, EPA withdrew the guidance in response to the Court’s 

decision in Natural Resources Defense Council v. EPA, No. 08-1250.

The Maintenance Plan accompanying this Request for Redesignation demonstrates 

maintenance of the standards consistent with the Court’s ruling.

In general, the Court’s decision (for the 1997 PM2.5 NAAQS and to the extent it would be 

extrapolated to the 2006 24-Hour PM2.5 NAAQS) could affect an area’s nonattainment 

classification, certain deadlines, and the impacts of failing to attain timely, and could 

impose a deadline for implementation of reasonably available and best available control 

measures (706 F.3d at 436, n. 6). Because the Lancaster Area is already attaining the 

1997 and 2006 PM2.5 NAAQS, those considerations are not relevant for this Request for 

Redesignation and the Maintenance Plan. The court noted that PM2.5 precursors, 

including ammonia and VOCs, are presumptively regulated in PM2.5 nonattainment areas 

 

4 “Withdrawal of Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air 

Quality Standards (NAAQS),” Stephen D. Page, EPA, June 6, 2013.
- 21 -

under Subpart 4, pointing specifically to Section 189(e), which applies to control of 

major stationary sources of PM10 [the court stated that PM10 includes PM2.5 throughout 

Subpart 4] (706 F.3d at 436, n. 7, and at 437, n. 10). According to Section 189(e) of the 

CAA, control requirements applicable for major stationary sources of PM10 also apply to 

major stationary sources of PM10 precursors, except where the Administrator determines 

that major stationary sources do not contribute significantly to PM10 levels that exceed 

the standard in the area; Section 189(e) also requires EPA to issue guidelines regarding 

the application of Subsection (e). Pennsylvania assessed emissions of PM2.5, SO2, NOX, 

VOC and NH3 for the maintenance demonstration. 

This Request for Redesignation provides emissions information for all pollutants (PM10, 

PM2.5, SO2, NOX, VOC and NH3), as required by EPA’s guidance entitled, “Emissions 

Inventory Guidance for Implementation of Ozone and Particulate Matter National 

Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.”

5

Section III

first describes the PM2.5 and PM2.5 precursor emission estimates for the Lancaster Area. 

These inventories have been developed in accordance with EPA emission inventory 

preparation guidance. The section then presents information about the permanent and 

enforceable control measures that have been implemented in the Lancaster Area to 

produce the PM2.5 and PM2.5 precursor emission reductions that have occurred between 

these years and that will provide emission reductions ensuring maintenance of the PM2.5

standards.

A. Baseline (2002) Emissions Inventory

An emissions inventory for the baseline year, 2002, was developed for PM10, 

PM2.5, SO2, NOX, VOC and NH3 in accordance with EPA guidance. The baseline 

year inventory represents the emissions present when the Lancaster Area did not 

meet the PM2.5 standards. The inventory contains information for these sectors:

● “Stationary sources” (or “point” sources), which are sources for which the 

Department collects individual emissions-related information. Generally, 

they represent major stationary sources but may be smaller.

● “Area sources,” which are industrial, commercial, and residential sources 

too small or too numerous to be handled individually. These include but 

are not limited to commercial and residential open burning, architectural 

and industrial maintenance coatings application and clean-up, consumer 

product use, and vehicle refueling at service stations. Where there is 

overlap between stationary point sources and stationary area sources, the 

area source values are adjusted to remove any double counting.

● “Highway vehicles,” which include passenger cars and light-duty trucks, 

other trucks, buses and motorcycles. 

 

5 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations – EPA-454/R-05-001, August, 2005, updated November, 2005.
- 22 -

● “Nonroad sources,” which encompass a diverse collection of engines, 

including but not limited to outdoor power equipment, recreational 

vehicles, farm and construction machinery, lawn and garden equipment, 

industrial equipment, recreational marine vessels, commercial marine 

vessels, locomotives, ships, and aircraft.

Pennsylvania and other Northeastern and Mid-Atlantic states participated in a 

regional effort to refine the emissions inventory and to compile a regional

emissions inventory. The Mid-Atlantic Regional Air Management Association

(MARAMA) coordinated that regional effort, which allowed states to pool their 

resources to compile a regional emissions inventory for the purpose of conducting

the regional modeling analysis used in Pennsylvania’s air quality management 

planning efforts to attain the 8-hour ozone NAAQS and the PM2.5 NAAQS, and to

prepare the Regional Haze SIP revision.

Table III-1: 2002 Lancaster Area Annual Emissions (Tons per Year)

A summary of the 2002 inventory is shown in Table III-1. The 2002 inventory is 

not directly comparable to the 2007, 2017 and 2025 inventories because of 

changes in inventory methodology and the adjustment made to account for 

condensable PM emissions from EGUs in the 2007, 2017 and 2025 emission 

inventories. The Technical Appendices to the Maintenance Plan contain more 

detailed information about the 2002 emissions for each sector.

B. Attainment Year (2007) Emissions Inventory

A 2007 inventory of PM10, PM2.5, SO2, NOX, VOC and NH3 emissions for the 

Lancaster Area is used to identify emissions during the period when attainment of 

the PM2.5 NAAQS was demonstrated for the Lancaster Area. A summary of the 

2007 inventory is provided in Table III-2.

Lancaster 2002 PM2.5 PM1 0 SO2 NOx VOC N H3

Stationary Point Sources 380 577 498 1,368 3,188 12

Area Sources 3,612 20,026 2,735 1,739 9,887 15,994

Highway Vehicle Sources 541 628 362 17,466 6,481 222

Non-Road Sources 322 337 295 4,001 5,009 3

Totals 4,856 21,569 3,890 24,575 24,566 16,231
- 23 -

Table III-2: 2007 Lancaster Area Annual Emissions (Tons per Year)

PM2.5,SO2, NOX, VOC, and NH3 emissions decreased by 23 percent, 13 percent, 

18 percent, 21 percent and 3 percent, respectively, from 2002 to 2007. The

permanent and enforceable reductions of direct PM2.5, SO2, NOX and VOC 

emissions between 2002 and 2007, as described in more detail in Section III, led 

to the improvement in air quality observed in that time period. 

The 2002 inventory was based on emissions reported to the Department by 

facilities and did not include condensable PM for many facilities. The 2007 EGU 

inventory was augmented utilizing the updated condensable emission factors for 

EGUs developed for MARAMA in 2008 to calculate condensable PM emissions 

where that data was missing.

The Maintenance Plan describes how the 2007 inventory was compiled. The 

Technical Appendices to the Maintenance Plan contain more detailed information 

for each sector.

C. Control Measures

Along with the analysis of ambient air quality and contributing factors in 

Section I of this Request for Redesignation, this section describes the permanent 

and enforceable federal and state measures that provided PM2.5, SO2, NOX and 

VOC emission reductions from 2002 to 2007 to bring the Lancaster Area into 

attainment and measures that will assure maintenance of the standards.

While EPA adopted in its Implementation Guidance for the 2006 24-Hour PM2.5

NAAQS the presumptions related to PM2.5 precursors in its Implementation Rule

for the 1997 PM2.5 NAAQS, the Department recognizes the Court decision in 

Natural Resources Defense Council v. EPA, No. 08-1250, 706 F.3d 428 (D.C.

Cir. 2013) and EPA’s subsequent withdrawal of the Implementation Guidance for 

the 2006 24-Hour PM2.5 NAAQS. 

In general, the Court’s decision (for the 1997 PM2.5 NAAQS and to the extent it 

would be extrapolated to the 2006 24-Hour PM2.5 NAAQS) could affect an area’s 

nonattainment classification, certain deadlines, and the impacts of failing to attain 

timely, and could impose a deadline for implementation of reasonably available 

and best available control measures (706 F.3d at 436, n. 6). Since the Lancaster

Area is already attaining the 1997 and 2006 24-Hour PM2.5 NAAQS, however, 

Lancaster 2007 PM2.5 PM1 0 SO2 NOx VOC N H3

Stationary Point Sources 254 409 102 1,147 2,691 8

Area Sources 2,691 10,218 3,030 1,827 6,675 15,551

Highway Vehicle Sources 480 574 102 13,895 5,529 207

Non-Road Sources 290 309 148 3,173 4,627 3

Totals 3,715 11,511 3,382 20,041 19,522 15,769
- 24 -

those considerations are not relevant for this Redesignation Request or the 

accompanying Maintenance Plan.

The Court noted that PM2.5 precursors are presumptively regulated in PM2.5

nonattainment areas under Subpart 4, pointing specifically to Section 189(e), 

which applies to control of major stationary sources of PM10 [the court stated that 

PM10 includes PM2.5 throughout Subpart 4]. (706 F.3d at 436, n. 7, and at 

437, n. 10). According to CAA Section 189(e), control requirements applicable 

for major stationary sources of PM10 also apply to major stationary sources of 

PM10 precursors, except where the Administrator determines that major stationary 

sources do not contribute significantly to PM10 levels that exceed the standard in 

the area; Section 189(e) also requires EPA to issue guidelines regarding the 

application of Subsection (e). Pennsylvania assessed emissions of PM2.5, SO2, 

NOX, VOC and NH3 for the maintenance demonstration.

Emissions of PM2.5, SO2, NOX, VOC and NH3 in the Lancaster Area decreased by

23 percent, 13 percent, 18 percent, 21 percent and 3 percent, respectively, from 

2002 to 2007. The permanent and enforceable reductions of direct PM2.5, SO2, 

NOX and VOC emissions, as described in more detail in Section III, led to the 

improvement in air quality observed in that time period. As noted above, the 

decrease in PM2.5 emissions is a conservative estimate because the 2007 inventory 

was augmented to account for condensable PM. A summary of the quantity of 

emission reductions from 2002 to 2007 is included in Table III-3. (Negative 

values indicate emission reductions.)

Table III-3: Change in Lancaster Area Annual Emissions (Tons per Year)

from 2002 to 2007

Change from 2002 to 2007 PM2.5 SO2 NOx VOC NH3

Stationary Point Sources -127 -395 -221 -497 -4

Area Sources -922 295 87 -3,212 -444

Highway Vehicle Sources -60 -260 -3,572 -953 -15

Nonroad Sources -32 -147 -828 -382 0

TOTAL -1,140 -508 -4,534 -5,044 -462

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

PM2.5, SO2, NOX and VOC emission reductions, ensuring maintenance of the 

standards.

A summary of the total emissions in 2007 and projected estimates for 2017 and 

2025 is included in Table III-4. The emission estimates account for any 

anticipated growth in the activity of sources and include a transportation 

conformity safety margin for PM2.5 and NOX. For all pollutants, except NH3, 

emissions in 2017 and 2025 in the Lancaster Area are anticipated to be lower than 

they were in 2007. This means that the projected growth in emissions is smaller

than anticipated emission reductions from control measures for all pollutants, 
- 25 -

except NH3, in the nonattainment area. The projected increase in NH3 emissions 

does not present a concern for maintaining the NAAQS because emissions of all 

other pollutants are projected to decline. In addition, the Lancaster Area currently 

has an annual design value based on 2010-2012 monitoring data of 12.1 μg/m3, 

which is significantly lower than the 1997 NAAQS of 15 μg/m3. Based on 

2010-2012 monitoring data, the Lancaster Area also has a 24-hour design value of 

31 μg/m3 which is significantly lower than the 2006 PM NAAQS of 35 μg/m3. 

Each measure is explained in greater detail in the following sections.

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

Lancaster PM2.5 SO2 NOx VOC NH3

2007 3,715 3,382 20,041 19,522 15,769

2017* 3,348 2,605 11,710 15,157 17,314

2025* 3,200 1,930 8,847 13,580 18,531

*A portion of the difference between attainment year and maintenance year emissions of PM2.5 and NOX has 

been set aside as a transportation conformity safety margin to accommodate unanticipated growth in 

highway vehicles. The emissions in Table III-4 reflect inclusion of that safety margin.

1. Stationary Point Sources

Background for Pennsylvania’s Stationary Source Permitting 

Programs. An owner or operator of a proposed new air contamination 

sources in the Commonwealth is required to receive a plan approval (preconstruction permit) from the Department prior to the construction, 

assembly, installation of new sources, modification of any existing 

stationary air contamination sources, or the installation of air pollution 

control equipment or devices. Following the construction of the new 

facility or air contamination source, the owner or operator must obtain an 

operating permit from the Department. The type of operating permit will 

depend on the quantity of regulated pollutants emitted from the air 

contamination sources. DEP will issue a “State-only Operating Permit” 

for minor air contamination stationary sources that are below the 

applicability thresholds for Title V facilities. A Title V operating permit is 

required for major facilities that have the potential to emit air 

contaminants exceeding the Title V thresholds. The Title V Permit, which 

is issued for a term of five years, incorporates all applicable requirements 

for the facility in a single federally enforceable operating permit. 

The requirements contained in 25 Pa. Code Chapter 127 (relating to the 

construction, modification, reactivation and operation of sources), and 

associated definitions in 25 Pa. Code Chapter 121.1, are a suite of 

programs regulating air contamination sources to improve and maintain air 

quality. Chapter 127 establishes requirements for the submission, review 

and approval of pre-construction and operating permits for both major and 

non-major air contamination sources. The provisions of Chapter 127 have 

been codified in the SIP at 40 CFR §52.2020(c)(1) at various times since 
- 26 -

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

federally enforceable. Several aspects of Chapter 127 are highlighted 

below.

Title V Permitting Program. The Title V Permitting Program, adopted 

pursuant to the Clean Air Act Amendments of 1990, is applicable to major 

stationary sources as defined in 25 Pa Code Section 121.1. The purpose 

of the Title V program is to detail a facility’s air quality requirements in a 

single permit document so that industry, the regulatory agency, and the 

public know exactly what regulations and requirements apply and how the 

facility’s owner or operator will monitor and demonstrate compliance with 

all applicable requirements. The Title V permit includes all sources at a 

site including all air pollution control devices as well as activities that 

were determined to be insignificant sources of emissions. Each source is 

described in detail within a section of the Title V permit. The 

requirements include general conditions applicable to all Title V facilities, 

emission restrictions, detailed monitoring, recordkeeping, and reporting 

requirements to assure compliance with the facility’s applicable federal 

and state requirements.

Nonattainment New Source Review and Prevention of Significant 

Deterioration. Major facilities proposed in Pennsylvania will also be 

subject to New Source Review (NSR) requirements in nonattainment areas 

and Prevention of Significant Deterioration (PSD) requirements in areas of 

the Commonwealth designated attainment for National Ambient Air 

Quality Standards including carbon monoxide, particulate matter (PM), 

lead, nitrogen dioxide (NO2), ozone and sulfur dioxide (SO2). Generally, 

NSR permit requirements are applicable to a facility located in a 

nonattainment area for a particular pollutant with a potential to emit 

50 tons or more per year (tpy) of volatile organic compounds or 100 tpy or 

more of NOx, SO2, PM or carbon monoxide. It should be noted that the 

entire Commonwealth, included in the Ozone Transport Region by 

operation of law, is treated as a “moderate” ozone nonattainment area, 

irrespective of the area’s attainment status. Because NOx and VOC are 

precursors of PM2.5, NOx and VOC emission reductions required 

statewide under the nonattainment NSR program for ozone also allow 

Pennsylvania to make substantial progress in attaining and maintaining the 

PM2.5 NAAQS. Any major stationary source or major modification 

subject to the NSR requirements must receive a plan approval. To receive 

approval from the Department, a person must show that the proposed 

source will, among other things, offset its potential to emit air 

contaminants including NOx, PM and VOCs by securing emission 

reductions credits at the specified offset ratio, will employ the “lowest 

achievable emission rate” (LAER) for each regulated pollutant and 

conduct an alternative analysis. The nonattainment NSR requirements are 
- 27 -

codified in 25 Pa. Code Chapter 127, Subchapter E and approved as a SIP 

revision on December 9, 1997 (62 FR 64722).

The PSD program is a pre-construction review and permitting program 

applicable to new or modified major stationary sources subject to Title I, 

Parts C and D of the federal CAA. The PSD requirements are applicable 

to major sources in areas attaining the NAAQS. The federal PSD 

regulations codified in 40 CFR Part 52 are incorporated by reference in 

their entirety in 25 Pa. Code §127.83 (relating to adoption by reference). 

The Department’s PSD regulations, codified in 25 Pa. Code Chapter 127, 

Subchapter D, were approved by the EPA on August 21, 1984 and 

codified at 40 CFR §52.2058 (49 FR 33128).). PSD permit requirements 

may apply to a facility located in an attainment area for a standard with the 

potential to emit 100 tpy or 250 tpy of the six criteria pollutants including

carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter and 

sulfur dioxide depending on the source category. Any major stationary 

source or major modification subject to the PSD requirements must 

conduct an analysis to establish the best available control technology 

(BACT). In addition, the owner or operator of a facility needs to conduct 

an ambient air quality analysis, analyze the impacts to soils, vegetation 

and visibility and make sure that the project will not adversely impact 

mandatory federal Class I areas including national parks greater than 

6,000 acres and national wilderness areas and national memorial parks 

greater than 5,000 acres. 

Best Available Technology Program. The Department’s Best Available 

Technology (BAT) Program ensures that new stationary sources will 

prevent, reduce or control emissions of air contaminants to the maximum 

degree possible. The Department determines BAT requirements on a 

case-by-case basis for both major and minor stationary sources taking into 

account energy, environmental benefits and costs. Pursuant to 25 Pa. 

Code §127.1, the emission of air pollutants from new sources in 

Pennsylvania must be controlled to the maximum extent, consistent with 

the best available technology as determined by the Department as of the 

date of issuance of the plan approval for the new source. Under 25 Pa.

Code §127.12(a)(5), an application for a plan approval must show that the 

emissions from a new source will be the minimum attainable through the 

use of the best available technology. Pennsylvania regulations define 

“best available technology” in 25 Pa. Code §121.1 as, “Equipment, 

devices, methods or techniques as determined by the Department which 

will prevent, reduce or control emissions of air contaminants to the 

maximum degree possible and which are available or may be made 

available.” The Department’s BAT regulations, codified in 25 Pa. Code

§§127.1 and 127.12(a)(5), were approved by EPA on July 30, 1996, and 

codified in the SIP at 40 CFR §52.2020(c)(1).
- 28 -

NOx and SO2 Control Programs. In 1998, EPA promulgated the NOX

SIP Call as the EPA’s principal effort to reduce interstate transport of air 

pollution (63 FR 57356; October 27, 1998). In response to the federal 

NOX SIP call rule, Pennsylvania adopted the NOX Budget Trading 

Program regulations for EGUs and large industrial boilers, with emission 

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

EPA as a revision to the Commonwealth’s SIP on August 21, 2001 

(66 FR 43795). Additionally, in response to the NOX SIP Call, 

Pennsylvania adopted additional NOX control regulations covering cement 

plants and internal combustion engines, with emission reductions to 

commence May 1, 2005. These regulations were approved by EPA as a 

SIP revision on September 29, 2006 (71 FR 57428).

Clean Air Interstate Rule (CAIR). In 2005, EPA adopted CAIR 

(70 FR 25162; May 12, 2005, as amended) to address interstate transport 

of NOX and SO2. CAIR is now being implemented in Pennsylvania 

through the Department’s CAIR regulation, codified in 25 Pa. Code

Chapter 145, Subchapter D, with related amendments in Chapters 121, 

129 and 145. EPA approved Pennsylvania’s CAIR SIP revision on 

December 10, 2009, codified at 40 CFR §52.2020(c)(1) (74 FR 65446). In 

the CAIR SIP revision, Pennsylvania terminated the NOX Budget Trading 

Program and transitioned to the federal CAIR for large electric generating 

units (EGU).

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

SO2 below 2002 levels throughout the eastern United States. 

Pennsylvania and the other CAIR states were required to adopt a 

regulation implementing the requirements of the CAIR or an equivalent 

program. The large EGUs in Pennsylvania were initially regulated under 

CAIR FIPs promulgated by EPA, but have been regulated under the SIP 

since EPA approved Pennsylvania’s CAIR SIP revision. Under the SIP 

revision, Pennsylvania participates in the EPA-administered cap-and-trade 

programs for NOX annual, NOX ozone season, and SO2 annual emissions.

EPA’s CAIR was remanded to EPA for revisions by the United States 

Court of Appeals for the District of Columbia on December 23, 2008 (See, 

North Carolina v. EPA, 531 F.3d 896, modified, 550 F.3d 1176 (D.C. Cir. 

2008)). Following remand, EPA replaced CAIR with the Cross-State Air 

Pollution Rule (CSAPR), but in a separate legal challenge the court 

vacated CSAPR. In that ruling, the court ordered EPA to continue 

administering CAIR pending the promulgation of a valid replacement (see, 

EME Homer City Generation L.P. v. EPA, 696 F.3d 7 (D.C. Cir. 2012, 

rehearing denied, 2013 U.S. App. LEXIS 1623 and 1624 (D.C. Cir. 

Jan. 24, 2013)). On June 24, 2013, the Supreme Court of the United 

States accepted review of the case. Following the Circuit Court’s 

direction, CAIR remains in place pending the Supreme Court’s review.
- 29 -

NOX Budget Trading Program limits on non-EGUs. The CAIR SIP 

revision also established emission limits for the non-EGUs and other units 

that were subject to the Commonwealth’s NOX Budget Trading Program 

but are not subject to the CAIR NOX Ozone Season Trading Program. 

These units must continue monitoring NOX emissions and must meet an 

emissions cap. Each unit has an allowable emission rate, calculated by 

January 31 of each year, based on the previous ozone season’s heat input. 

If the combined NOX ozone season emissions from all of these units 

exceed the statewide ozone season emission cap of 3,438 tons, each unit 

that exceeds its individual allowable emissions limit for that ozone season 

must surrender to the Department one CAIR NOX ozone season allowance 

and one CAIR NOX annual allowance for each ton of emissions over its 

allowable emission limit. In addition, the Commonwealth has set aside 

181 tons of NOX, including tons that will be retired each year to 

compensate for sources that were exempted under the “twenty-five ton 

exemption” in 25 Pa. Code §145.4(b) 3. The balance of tons remaining in 

the set aside is available to the Department annually for accounting 

corrections. The Commonwealth retires any unused amount from this set 

aside each year.

It is unlikely that the 3,438-ton statewide NOX ozone season emission 

limitation will be exceeded. Pennsylvania’s non-EGU sources’ total 

emissions during each of the years they were trading under the NOX

Budget Trading Program never exceeded the statewide cap of 3,438 tons.

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

approved by EPA on December 10, 2009, and codified in the SIP at 

40 CFR §52.2020(c)(1).

Cement kilns and large stationary internal combustion engines. The 

CAIR SIP revision also included regulations updating the cement 

manufacturing and large stationary internal combustion engine regulations 

that were adopted pursuant to the NOX SIP Call. Until 2009, cement kilns 

and large stationary internal combustion engines that were subject to the 

NOX SIP Call were required to surrender NOX SIP Call allowances if they 

exceeded their NOX emission limits set forth in Department regulations. 

Because the Department discontinued the NOX Budget Trading Program 

beginning 2009, at which point NOX SIP Call allowances were replaced 

by CAIR NOX ozone season allowances, the Department modified the 

regulations to require surrender of CAIR NOX ozone season and CAIR 

NOX annual allowances for emission limit exceedances.

The Department’s regulations for large stationary internal combustion 

engines and cement kilns, codified in 25 Pa. Code Chapter 145, 

Subchapters B and C, respectively, were approved by EPA on 
- 30 -

December 10, 2009, and codified at 40 CFR §51.2020(c)(1). An 

amendment to the Department’s regulation for cement kilns to reduce 

NOX emissions effective April 15, 2011, codified in 25 Pa. Code

Chapter 145, Subchapter C, was approved by EPA on July 19, 2011 and 

codified at 40 CFR §51.2020(c)(1).

Federal Standards for Hazardous Air Pollutants. Federal standards to 

control hazardous air pollutants (HAPs) require Maximum Achievable 

Control Technology (MACT) at units located at major sources of HAPs. 

The EPA has promulgated a series of MACT regulations that are 

applicable to sources in Pennsylvania. These MACT standards are 

adopted and incorporated by reference in Section 6.6 of Pennsylvania’s 

Air Pollution Control Act and implementing regulations in 25 Pa. Code

§127.35 (relating to maximum achievable control technology standards for 

hazardous air pollutants). The standards also included in federally 

enforceable plan approvals and operating permits issued by the 

Department for affected sources.

2. Highway Vehicle Sources

Even with increases in vehicle miles travelled (VMT) that occurred 

between 2002 and 2007, and are anticipated to occur from 2007 through 

2025, highway vehicle emissions will continue to decrease. As more 

vehicles subject to cleaner new car standards replace older vehicles subject 

to less stringent new vehicle standards, the fleet as a whole emits fewer 

emissions, compensating for the increase in VMT. These decreases can be 

attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) and 

Pennsylvania Clean Vehicle Program for passenger vehicles and lightduty trucks and cleaner gasoline. Tier 1 tailpipe standards established 

by the CAA Amendments of 1990 include NOX and VOC limits for lightduty gasoline vehicles (LDGVs) and light-duty gasoline trucks (LDGTs). 

These standards began to be phased in 1994. Evaporative VOC emissions 

were reduced in gasoline-powered cars starting with Model Year (MY) 

1998.

In 1998, under the authority of Section 177 of the CAA, the Pennsylvania 

Environmental Quality Board (EQB) adopted the Pennsylvania Clean 

Vehicles Program (28 Pa.B. 5873; Dec. 5, 1998). The Pennsylvania Clean 

Vehicles Program incorporates by reference certain California Low 

Emission Vehicle (CA LEV) emission standards for passenger cars and 

light-duty trucks. As required under Section 177 of the CAA, these

provisions are identical to the low emission standards adopted by 

California. The regulation does not incorporate by reference the 
- 31 -

California zero emissions vehicle (ZEV) or emissions control warranty 

systems statement provisions.

In the same rulemaking, the EQB adopted the National Low Emission 

Vehicle (NLEV) program as a compliance alternative to the Pennsylvania 

Clean Vehicles Program. The NLEV program became effective in the 

Ozone Transport Region (OTR) in 1999. Pennsylvania’s New Motor 

Vehicle Emissions Control Program regulations in 25 Pa. Code

§§ 126.401-126.441 allowed automobile manufacturers to comply with 

NLEV instead of the CA LEV program through MY 2005. These 

regulations affected vehicles 6,000 pounds and less and were the 

regulations in effect for new motor vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV 

(Tier 2), starting with MY 2004. The NLEV program was replaced for 

MY 2004 and later by the more stringent Federal “Tier 2” vehicle 

emissions regulations (65 FR 6698; Feb. 10, 2000), and vehicle 

manufacturers operating under the NLEV program became subject to the 

Tier 2 requirements.

Pennsylvania amended the former New Motor Vehicle Control Program in 

2006. The Clean Vehicles Program continues to incorporate the 

California Low Emission Vehicle Program (CA LEV II) by reference. As 

amended, the program affects MY 2008 and newer passenger cars and 

light-duty trucks vehicles (36 Pa.B. 7424; Dec. 9, 2006, corrected 

37 Pa.B. 209; Jan. 12, 2007, eff. Dec. 9, 2006). EPA approved 

Pennsylvania’s Clean Vehicle Program as a revision to the 

Commonwealth’s SIP on January 24, 2012 (77 FR 3386).

Heavy-Duty Diesel Control Programs. The EPA promulgated more 

stringent national regulations for heavy-duty engines and vehicles (over 

14,000 pounds) starting with MY 2004. In addition, consent decrees with 

seven of the largest heavy-duty engine manufacturers required, among 

other terms, that diesel engines made by these companies comply with 

these 2004 standards two model years early, in MY 2002. The emission 

reductions from these programs are reflected in the future year emission 

inventories, as provided in the Motor Vehicle Emission Simulator

(MOVES) model.

In 2002, the EQB adopted the Heavy-Duty Diesel Emissions Control 

Program for model years starting after May 2004. The program 

incorporates California standards by reference and requires MY 2005 and 

subsequent new heavy-duty diesel highway engines to be those certified 

by California. California standards were more stringent than federal 

standards for the two model years between expiration of the consent 

decrees discussed above (MYs 2005 and 2006) and the implementation of 
- 32 -

more stringent federal standards affecting MY 2007 and beyond. 

However, EPA’s MOVES model already assumed that the engines would 

comply with consent decree standards, even without an enforcement 

mechanism. The Department has used MOVES defaults to calculate 

emissions from MY 2005 and 2006 highway engines.

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

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

were phased in from 2007 to 2010 for NOX and VOCs. For gasoline 

engines, the standards were phased in during MY 2008 and 2009. Federal 

and California standards are virtually identical for MY 2007. For 

MY 2008, California adopted requirements for idling restriction engine 

programming and an optional “clean NOX idle” standard. However, there 

is no EPA-approved methodology to estimate emission reductions from 

this requirement. Therefore, the emission estimates use assumptions of 

the federal rule for MY 2007 through 2010.

Because the new engine standards are adversely affected by sulfur in fuel, 

the EPA also required most highway diesel fuel to contain no more than 

15 parts per million (ppm) of sulfur, beginning in the fall of 2006. There 

was a temporary compliance option allowing refiners to continue to 

produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

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

the phase-in provision.

Vehicle Emission Inspection/Maintenance Program. In early 2004, 

Pennsylvania expanded its Vehicle Emission Inspection/Maintenance 

(I/M) Program into the Lancaster Area. The program applies to gasolinepowered vehicles 9,000 pounds and under, model years 1975 and newer. 

For vehicles 1996 and newer, the program consists of an annual on-board 

diagnostics test and a gas cap pressure test. For subject vehicles 1995 and 

older, the program consists of an annual visual inspection of pollution 

control devices to ensure they are present, connected and the proper type 

for the vehicle and a gas cap pressure test. These regulations can be found 

in 67 Pa. Code Chapter 177. The Department submitted the expanded 

emissions program to EPA as a SIP revision on December 1, 2003. EPA 

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

Low sulfur gasoline. Sulfur is a naturally occurring component of crude 

oil that ends up in gasoline and diesel unless removed. Sulfur in gasoline 

impairs the effectiveness of emission control systems and contributes to 

air pollution. By removing most sulfur from gasoline, new advanced 

emission controls will work longer and more efficiently, and air pollution 

will be reduced.
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The 1999 federal Tier 2 regulations (65 FR 6698; Feb. 10, 2000) reduced

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

emission control technologies in cars and trucks that reduce harmful air 

pollution. The emission inventory analysis in the Maintenance Plan 

submitted concurrently with this Request for Redesignation uses the 

default assumptions provided in MOVES2010 to account for the 

implementation of the federal standards for low sulfur gasoline. 

Requirements for use of low-sulfur gasoline enabled use of advanced 

emission control systems in light-duty vehicles beginning in MY 2004. 

Vehicles meeting Tier 2 emission standards are 77 to 95 percent cleaner 

than earlier models.

EPA signed a regulation adopting more stringent vehicle standards and 

reducing sulfur limits in gasoline further with the Tier 3 Motor Vehicle 

Emission and Fuel Standards program on March 3, 2014. The rule takes 

effect in 2017. The Tier 3 program requires the annual average content of 

sulfur in gasoline to be reduced to 10 parts per million, starting January 1, 

2017. By 2018, EPA estimates that SO2 emissions from gasoline vehicles 

will be reduced by 56 percent. When fully implemented, this program, by 

2030, will increase the effectiveness of vehicle emission controls even 

further and reduce onroad emissions of NOx by 25 percent, direct 

particulate matter by 10 percent and VOCs by 16 percent. The rule will 

also significantly reduce emissions of carbon monoxide and hazardous air 

pollutants including acrolein, benzene, formaldehyde and acetaldehyde.

3. Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel-powered 

(“compression ignition”) and gasoline-powered (“spark ignition”) nonroad 

engines of various sizes (horsepower) and applications. Information on 

these federal rules, including their implementation dates, can be found at 

www.epa.gov/nonroad. The Department used the assumptions built into 

the nonroad model (NONROAD2005) and NMIM to estimate emissions 

for all milestone years.

While the EPA has published a notice of proposed rulemaking for more 

stringent standards for locomotives and large commercial marine diesel 

engines, the agency has not finalized any new standards.

On June 29, 2004, EPA adopted a rule establishing a comprehensive 

national program to reduce emissions from nonroad diesel engines 

(69 FR 38958). The rule phased in requirements for reducing the sulfur 

content of diesel used in nonroad diesel engines. The reduction in fuel 

sulfur content prevents damage to the more advanced emission control 

systems needed to meet the engine standards; it will also reduce fine 

particulate emissions from diesel engines. In 2007, fuel sulfur levels were 
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limited to 500 ppm for nonroad applications other than ocean-going 

marine vessels. In 2010, fuel sulfur levels were reduced to the same sulfur 

concentration as in highway fuel, 15 ppm; this requirement began 

applying in 2012 to locomotive and marine diesel fuel. EPA adopted 

technical amendments to the program in rules published in the Federal 

Register on November 22, 2005 (70 FR 70498), and May 1, 2006 

(71 FR 25706). On April 30, 2010 (75 FR 22896), EPA adopted changes 

to the nonroad diesel fuel program to allow for the production and sale of 

diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marine 

vessels. This requirement does not impact the Lancaster Area because the 

Lancaster Area does not have emissions from commercial marine vessels.

4. Stationary Area Sources

Consumer Products. This regulation applies statewide to any person 

who sells, supplies, offers for sale, or manufactures certain consumer 

products on or after January 1, 2005, for use in the Commonwealth. The 

program is contained in 25 Pa. Code Chapter 130, Subchapter B. It was 

submitted to the EPA as a SIP revision on March 26, 2003, and approved 

on December 8, 2004 (69 FR 70895). Amendments to the Consumer 

Products regulations were adopted on October 11, 2008, submitted to the 

EPA as a SIP revision on March 11, 2009, and approved on October 18, 

2010 (75 FR 63717).

Adhesives, Sealants, Primers and Solvents. The EQB adopted a 

regulation in 2010 to control VOC emissions from adhesives, sealants, 

primers and solvents. This regulation was published in the Pennsylvania 

Bulletin on December 25, 2010 (40 Pa.B. 7340) and approved by EPA as a 

SIP revision on September 26, 2012 (77 FR 59090).

IV. MAINTENANCE PLAN

The Maintenance Plan for the Lancaster Area is being submitted to EPA for approval as a 

SIP revision concurrently with this Request for Redesignation. The Maintenance Plan 

shows that the 1997 PM2.5 NAAQS will be maintained for at least 10 years after 

redesignation. Eight years following redesignation, the Commonwealth will submit a 

revised plan that ensures attainment through 2035.

The Maintenance Plan shows that emission levels of PM2.5, SO2, NOX and VOC over the 

10 years following redesignation will remain below the emissions level in 2007, while 

allowing for growth in population and vehicle miles traveled. The projected increase in 

NH3 emissions does not present a concern for maintaining the NAAQS because PM2.5, 

SO2, NOX and VOC emissions are all projected to continue to decline in the Lancaster 

Area. Based on 2010-2012 monitoring data, the Lancaster Area currently has an annual 

design value of 12.1 μg/m3, which is significantly lower than the 1997 NAAQS of 

15 μg/m3. In addition, based on 2010-2012 monitoring data, the Lancaster Area has a 
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24-hour design value of 31 μg/m3 which is significantly lower than the 2006 NAAQS of 

35 μg/m3. The following state and federal programs will ensure the continuing decline of 

SO2, NOX, direct PM2.5 and VOC emissions:

● Clean Air Interstate Rule;

● Emission limits for large industrial boilers;

● State regulation of cement kilns, large stationary internal combustion engines, and

smaller sources of NOX;

● State regulations incorporating by reference the federal Prevention of Significant 

Deterioration (PSD) regulations; 

● State requirements for Best Available Technology (BAT);

● State regulation of the sulfur content of fuel oil;

● State regulation of VOC emissions from adhesives, sealants, primers and solvents;

● The Pennsylvania and federal new motor vehicle emission control programs for 

passenger and light-duty trucks;

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

● Federal fuel programs for highway vehicles and nonroad mobile equipment; and

● Federal regulation of off-road diesel and gasoline-powered vehicles and 

equipment.

Emission reductions from Pennsylvania’s Diesel-Powered Motor Vehicle Idling Act, 

Act 124 of 2008 (Idling Act) were not included in the 2017 and 2025 emission 

inventories, and, thus, were not relied upon for the demonstration of maintenance. The 

Idling Act was approved by EPA as a SIP revision on August 1, 2011 (76 FR 45705). 

Similarly, NOX and VOC emission reductions from Pennsylvania’s Outdoor Wood-Fired 

Boilers regulation were not included in the 2017 and 2025 emission inventories, and were 

not relied upon for the demonstration of maintenance. The Outdoor Wood-Fired Boiler 

regulation was published in the Pennsylvania Bulletin on October 2, 2010 

(40 Pa.B. 5571) and approved by EPA as a SIP revision on September 20, 2011 

(76 FR 58114). However, emission reductions from these measures may nonetheless 

assist the Lancaster Area in maintaining air quality.

DEP has provided in the Maintenance Plan for the PM2.5 NAAQS assurances that it will 

continue to operate the ambient air quality monitoring network in order to track 

maintenance of the standard and to evaluate emissions inventories periodically compared 

to the projections provided in the plan. DEP has also provided in the Maintenance Plan a 
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list of contingency measures that it would consider to correct any violation of the 1997 

PM2.5 NAAQS that might occur after redesignation of the area.
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ACRONYMS AND ABBREVIATIONS

AEO Annual Energy Outlook

AQS EPA’s Air Quality System

AQTAC DEP’s Air Quality Technical Advisory Committee

BACT Best Available Control Technology

BAT Best Available Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CA LEV California Low Emission Vehicle (program)

CAMx Comprehensive Air Quality Model with Extension

CFR Code of Federal Regulations

CMV Commercial Marine Vessel

DEP Pennsylvania Department of Environmental Protection

DOT U.S. Department of Transportation

EGU Electric Generating Unit

EIA Energy Information Administration

EIS Emission Inventory System

EPA U.S. Environmental Protection Agency

EQB Environmental Quality Board

ERC Emission Reduction Credit

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

GDP Gross Domestic Product

GHCN Global Historical Climatology Network

HAP Hazardous Air Pollutant

I/M Inspection and Maintenance

IRRC Independent Regulatory Review Commission

LDGV Light Duty Gasoline Vehicles

LDGT Light Duty Gasoline Trucks

LRP Long Range Plan

MACT Maximum Achievable Control Technology

MARAMA Mid-Atlantic Regional Air Management Association

MM5 Mesoscale Model

MOVES Motor Vehicle Emission Simulator

MPO Metropolitan Planning Organization

MY Model Year

NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NEI National Emissions Inventory

NH3 Ammonia

NLEV National Low Emission Vehicle (program)

NMIM National Mobile Inventory Model
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NOAA National Oceanic and Atmospheric Administration

NONROAD Nonroad Model

NOX Oxides of Nitrogen

NSR New Source Review

OTC Ozone Transport Commission

OTR Ozone Transport Region

OWB Outdoor Wood-fired Boiler

PennDOT Pennsylvania Department of Transportation

PM Particulate Matter

PM2.5 Particulate Matter less than 2.5 microns in diameter or Fine Particulates 

PM10 Particulate Matter less than 10 microns in diameter

ppm parts per million

PSD Prevention of Significant Deterioration

RWC Residential Wood Combustion

SCC Source Classification Code

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAF Terminal Area Forecast

TCM Transportation Control Measures

TIP Transportation Improvement Program

TSD Technical Support Document 

μg/m3 Microgram per cubic meter

μm Micrometer

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

ZEV Zero Emissions Vehicle