Pennsylvania Department of Environmental Protection 

The Secretary 

Ms. Judy Katz, Director 

U.S. Environmental Protection Agency 

Region III 

1650 Arch Street 

Philadelphia, PA 19103-2029 

Dear Judy: 

Rachel Carson State Office Building 

P.O. Box 2063 

Harrisburg, PA 17105-2063 

July 19, 2001 

Phone: 717-787-2814 

E-Mail:DavidHess@state.pa.us 

Enclosed for your approval are two revisions to the Pennsylvania State Implementation 

Plan for the Philadelphia Ozone Nonattainment Area which were subject to a public comment 

period closing June 29, 2001. 

The first revision describes the analysis of additional reasonably available control measures 

that would advance the ozone attainment date for the Philadelphia area as requested by your 

letter of April 12, 200l. This SIP revision.includes the Secretary's letter of February 25, 2000. 

The second revision contains a new motor vehicle budget for 2005 which includes the 

reductions expected from the federal Tier 2/10w sulfur program for light-duty vehicles. 

Should you have questions regarding these submissions, contact James M. Salvaggio, 

Bureau of Air Quality, at 717-772-9702. 

Secretary 

An Equai Opportunitv fmployer www.dep.state.pa.us Printed on Recycled Paper 
Commonwealth of Pennsylvania 

Department of Environmental Protection 

State Implementation Plan (SIP) Revision 

For the Philadelphia Ozone Nonattainment Area 

Reasonably Available Control Measure (RACM) Analysis 

July 2001 

Division of Air Resource Management 

Bureau of Air Quality 

Pennsylvania Department of Environmental Protection 

PO Box 8468 

Harrisburg, P A 17105-8468 

717-787-9495 

1. Wick Havens, Chief 

www.dep.state.pa.us 
Purpose and Background 

On April 12,2001, the Pennsylvania Department of Environmental Protection (DEP) 

received a request from the u.s. Environmental Protection Agency (EPA) asking Pennsylvania 

to submit additional information to the EPA, as a revision of Pennsylvania's State 

Implementation Plan (SIP) for the Philadelphia Ozone Nonattainment Area, on the analysis of 

additional reasonably available control measures (RACMs) that would advance the ozone 

attainment date for the Philadelphia area. 

In accordance with the April 12, 2001 request, this document serves to demonstrate to 

the EPA that additional control measures were considered by DEP by clarifying relevant 

documentation previously submitted to EPA, and to reaffirm the DEP's commitment to the 

reductions contained in the state implementation plan (SIP) and revisions currently under review 

by the EPA. 

On August 1, 1998, DEP submitted to the EPA its proposed Phase I SIP for the 

attainment of the national ambient air quality standard for ozone for the Philadelphia 

metropolitan area as part of the Philadelphia-Wilmington-Trenton Nonattainment Area. The 

Phase I requirements include adoption of specific control strategies necessary to meet the Post 

1996 Rate-of-Progress plan through 1999; commitments to adopt, or adoption of, other Clean 

Air Act mandated and regional control programs; and modeling with interim assumptions. 

Phase II of the SIP, submitted on April 30, 1998 and revised in February 2000, includes 

participation in a two-year regional consultative process with other states in the eastern United 

States, and with EPA, to identify and commit to additional emission reductions necessary to 

attain the health-based ozone standard by the statutory dates. The Phase II SIP further describes 

the work undertaken by the Southeast Pennsylvania Ozone Stakeholders Group. It was in this 

forum where the additional measures described by the EPA in the April 12, 2001 letter were 

analyzed. 

On February 25,2000, DEP responded to EPA's Notice of Proposed Rulemaking (NPR) 

on the one-hour attainment demonstration for the Philadelphia-Wilmington-Trenton Area that 

was published in the Federal Register on December 16, 1999 (64 F.R. 70428) and the Notice of 

Adequacy Status that was published in the Federal Register on January 20,2000 (65 F.R. 3230). 

That response, included as Appendix A, referenced the work done by the Southeast Pennsylvania 

Ozone Stakeholders Group and included their final report that was issued on January 16, 1997. 

That report contained a list of recommended control strategies based upon the analysis conducted 

by the group. 

The Southeast Pennsylvania Ozone Stakeholders Group 

In January 1996, Governor Ridge convened the Southeast Pennsylvania Ozone 

Stakeholders Group to address the ozone nonattainment issues in Southeast Pennsylvania. The 

stakeholder group represented a wide range of interests from environmental and citizen groups, 

industry, public utilities, small business, transportation, government, and motorist and healthcare organizations. Twenty-eight stakeholders, including EPA, were invited to participate in the 

stakeholder process. CDR Associates, an independent mediator with an international reputation, 
was retained by DEP to facilitate the discussions in the stakeholder group. The group also 

formed data management committees and worked with nationally recognized technical 

consultants on preparation of inventory data, control measure potential, and air quality modeling. 

The stakeholder effort was a public process, held in open meetings, representing a broad 

base of constituencies. In addition, the stakeholders made an effort to ensure that other groups 

and the general public were aware of the process and had an opportunity to provide input. The 

stakeholders met for two full days each month, from April through December to discuss and, 

whenever possible, to find agreement on strategies that could materially improve air quality in 

southeastern Pennsylvania. The recommendations were contained in a final report, released on 

January 16, 1997. 

The deliberations of the stakeholders followed two guiding principles and objectives: 1) 

to identify control strategies that collectively produced regional air quality that meets the current 

health based standard, and 2) to reflect the unique conditions of southeastern Pennsylvania. In so 

doing, the recommendations contained in the report seek to balance federal requirements for air 

quality with cost effective strategies that protect the public health and the regional economic 

integrity of the nonattainment area. 

The Stakeholders Process and RACM 

As a result of the stakeholder process, the group discussed hundreds of measures and 

formally evaluated over 150 control measures for stationary, area and mobile sources. Of these, 

one-third were measures related to transportation under the following general categories: 

1. General programs for improved public transit within the city of Philadelphia and 

regional suburban communities; 

2. Restriction of certain roads or lanes to, or construction of such roads or lanes for use 

by, passenger buses or high occupancy vehicles; 

3. Employer-based transportation management plans, including incentives; 

4. Regional trip-reduction regulations or ordinances; 

5. Traffic flow improvement programs that achieve emission reductions; 

6. Fringe and transportation corridor parking facilities serving multiple occupancy 

vehicle programs or transit services; 

7. Programs to limit or restrict vehicle use in downtown areas or other areas of emission 

concentration particularly during periods of peak use; 

8. Programs for the provision of all forms of high-occupancy, shared-ride services; 

9. Programs to limit portions of road surfaces or certain sections of the metropolitan 

area to the use of non-motorized vehicles or pedestrian use, both as to time and place; 

10. Programs for secure bicycle storage facilities and other facilities, including bicycle 

lanes, for the convenience and protection of bicyclists, in both public and private 

areas; 

11. Programs to control extended idling of vehicles; 

12. Programs to reduce motor vehicle emissions, consistent with Title II, which are 

caused by extreme cold start conditions; 

13. Employer-sponsored programs to permit flexible work schedules; 

2 
14. Programs and ordinances to facilitate non-automobile travel, provision and utilization 

of mass transit, and to generally reduce the need for single-occupant vehicle travel, as 

part of transportation planning and development efforts of a locality, including 

programs and ordinances applicable to new shopping centers, special events, and 

other centers of vehicle activity; 

15. Programs for new construction and major reconstructions of paths, tracks or areas 

solely for the use by pedestrian or other non-motorized means of transportation when 

economically feasible and in the public interest; 

16. Programs to encourage the voluntary removal from use and the marketplace of 

pre-1980 model year light duty vehicles and pre-l 980 model light duty trucks. 

Pennsylvania included recommended reasonably available measures in the Philadelphia 

Ozone Severe Nonattainment SIP if they were cost-effective and would advance the attainment 

date, such as the Reasonably Available Control Technology (RACT) program for stationary 

sources. Measures were not included in the State Implementation Plan if they: 1) were 

considered to be economically or technologically infeasible, based on data presented to the group 

and taking into account local circumstances, 2) had emissions reductions that were insignificant 

or 3) would not advance the area's attainment date. 

A number of stakeholder recommendations not included in the SIP are nonetheless being 

implemented. Many of these measures serve additional purposes or are effective on a long-term 

basis. While not practical for SIP purposes, they still assist in reducing emissions growth and in 

transportation conformity. 

The stakeholders' final report, previously submitted to EPA on February 25,2000, 

contains a detailed explanation ofthe stakeholder process, the Operating Agreement and 

summaries of the specific strategies analyzed. For your convenience, Appendix B of this 

document contains a copy ofthe stakeholders' final report. Appendix C is detailed data on the 

measures considered. 

Summary 

DEP is committed to the development and implementation of control measures and 

requirements in accordance with the process provided in the Pennsylvania Air Pollution Control 

Act and other applicable laws in order to attain the one-hour ozone standard to the benefit of the 

citizens of Pennsylvania. It recognizes that the stakeholder process helps ensure that goal. In 

addition, DEP continues to work with the Ozone Transport Commission (OTC) in developing 

several regional control measures to ensure attainment. DEP is a signatory to a March 28, 2001 

OTC memorandum of understanding regarding the development of these measures. 

DEP is confident that the clarification submitted in this document will serve to 

substantiate information previously submitted by DEP regarding RACMs and DEP's analysis 

regarding those measures deemed appropriate to further the attainment date for the Philadelphia 

area as expeditiously as practical. As we stated in our letter of February 25,2001, we recognize 

that regular evaluation is an important part of any planning process. Therefore, Pennsylvania 

3 
will submit to EPA such mid-course review by December 31, 2003 as the Clean Air Act and the 

rules and regulations under the Clean Air Act require. 

Public Comment. This SIP revision was available for public comment for the period May 26 

through June 29,2001. One public hearing was held on June 28, 2001 in DEP's Southeast 

Regional Office, Conshohocken. Notice was provided in the major newspaper in the five-county 

area and as a notice in the Pennsylvania Bulletin. 

4 
APPENDIX A 

SE P A Ozone Stakeholder Working Group Final 

Report 
SOUTHEAST 

PENNSYLVANIA 

STAKEHOLDER 

WORKING GROUP 

FINAL REPORT 

January 16, 1997 
Southeastern 

Pennsylvania 

Ozone Stakeholder 

Working Group 

Final Report 

January 16, 1997 

Convener: Commonwealth of Pennsylvania 

James M. Seif 

Department of Environmental Protection 

Rachel Carson State Office Building 

400 Market Street 

Harrisburg, PA 17105 

Bradley L Mallory 

Department of Transportation 

555 Walnut Street 

Forum Place 

Harrisburg, PA 17101 

Facilitator: CDR Associates 

2710 -BK -DEP2071 

100 Arapahoe Avenue 

Boulder, CO 80302 

Recycled Paper ft 
March 12, 1996 

See Attached List 

Dea~ ____ _ 

We are pleased to invite you to participate in the Southeast Pennsylvania Clean Air 

Stakeholders Group. The Stakeholders Group will work during the next year to develop a 

course of action for the attainment and maintenance of the health-based ozone standard, a 

strategy tailored to meet the regional needs of the Philadelphia area. 

We believe that new clean air strategies in areas with continuing air pollution problems should 

be developed from the ground up, by those with significant stakes in the outcome. The 

Commonwealth needs a plan that is based on good air pollution science, is equitable among 

air pollution sources and meets the requirements of the federal Clean Air Act Amendments. 

The Clean Air Stakeholders Group has been charged with this important mission. We expect 

the outcome of this effort to be recommendations that the Commonwealth can use as the basis 

for continuing to meet its clean air obligations. The group will operate by a consensus 

decision-making process. Areas on which there is no consensus will also be identified. 

Since the sources contributing to ozone pollution and the people affected by it are diverse, the 

stakeholders group has to be large enough to represent these interests, yet small enough to 

form a group that can work together. You have been selected because of your ability to 

provide appropriate representation, as well as your personal qualifications and capacity to 

work toward consensus on a broad range of clean air issues. 

The first meeting has been scheduled for April 1 and 2, 1996. Most of the time at this 

convening meeting will be spent on developing principles of operation for the group, identifying 

agenda items, and participating in a brief training session on interest-based negotiation and 

consensus building. The group will also develop its own meeting schedules. You will be 

getting a packet of materials for the first meeting in the next few days. The Commonwealth will 

reimburse you for your travel expenses through a procedure which will be explained at the first 

meeting. As you already know, the Commonwealth has engaged an independent facilitator 

from CDR Associates to help us achieve a common understanding of the problem and arrive at 

potential solutions. 

Consensus is not an easy process. It takes communication, compromise, common sense and most of all, 

commitment. We appreciate your willingness to work with us, and we look forward to working with you in 

the coming months. Should you have questions in the meantime, please feel free to contact Robert 

Barkanic, Special Assistant; Air, Recycling and Radiation Protection, DEP, at 717-772-2725. 

Sincerely, 

James M. Seif 

Secretary 

Department of Environmental Protection 

Sincerely, 

Bradley L. Mallory 

Secretary 

Department of Transportation 
January 16, 1997 

The Honorable James M. Seif 

Secretary 

Department of Environmental Protection 

P.O. Box 2063 

Harrisburg, Po'\. 17105 

Gentlemen, 

The Honorable Bradley L. Mallory 

Secretary 

DepartmentofT~rtation 

555 Walnut Street 

Forum Place 

Harrisburg, P A 171 0 1 

The Southeastern Pennsylvania Ozone Stakeholders submit the enclosed report for your 

consideration. This report provides the results of our deliberations, including recommended 

control measures, supporting assumptions and context. In addition, we have indicated nonconsensus items which we feel will require additional attention from the Commonwealth. 

In accordance with th ... stakeholders' adopied mission statement and charge, the 

recommendations are based on the current health-based hourly ozone standard of .12 ppm to be 

achieved by the year 2005. 

We look forward to your comments and your full support for our recommendations. Our 

deliberations were thorough and diligent; the outcome merits serious consideration. Collectively, 

the stakeholders stand ready to meet with you to discuss these proposals. 

Sincerely yours, 

Southeastern Pennsylvania Ozone Stakeholders 

~cf}d-Jv 

C?~~ 

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2 
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3 
INTRODUCTION 

Stakeholders Mission 

The Governor of Pennsylvania, through the Pennsylvania Department of Environmental 

Protection and the Pennsylvania Department of Transportation, created the 

Southeastern Pennsylvania Ozone Stakeholders to recommend control strategies to 

the Commonwealth for attainment and maintenance of the current health-based 

standards and the requirements of the 1990 Federal Clean Air Act Amendments. 

Under the Clean Air Act Amendments, the five counties in southeastern PennsylvaniaBucks, Chester, Delaware, Montgomery and Philadelphia-are currently classified as 

"severe non-attainment" for ground-level ozone. The non-attainment area also includes 

parts of New Jersey, Maryland and Delaware. 

Ground-level ozone is a colorless, odorless gas produced when nitrogen oxides (NOx) 

and volatile organic compounds (VOC) react in the presence of heat and sunlight. 

In accordance with the stakeholders' adopted mission statement and charge, the 

recommendations in this report are based on the current health-based standard of .12 

ppm of ozone to be achieved by the year 2005. 

The stakeholders attempted to balance emission reductions equitably among different 

source types-area, mobile and stationary. It is important to preserve this balance as 

the recommendations are implemented. 

Stakeholders Process 

The stakeholder effort was a public process, held in open meetings, representing a 

broad base of constituencies. In addition, the stakeholders made an effort to ensure 

. that other groups and the general public were aware of the process and had an 

opportunity to provide us with input. The stakeholders held one public input meeting on 

November 7, 1996. The recommendations contained in this report are the result of long 

hours of deliberation and struggle. The stakeholders met for two full days each month, 

from April through December to discuss and, whenever possible, to find agreement on 

strategies that can materially improve air quality in southeastern Pennsylvania. 

At the same time that the stakeholders began to deliberate, the Inspection and 

Maintenance (11M) Working Group began to design the Commonwealth's decentralized 

inspection and maintenance program. The stakeholders worked to avoid issues 

associated with implementation of the inspection and maintenance program, leaving 

those issues to the 11M Working Group. 

4 
Stakeholders Members 

The Southeastern Pennsylvania Ozone Stakeholders represent a wide range of 

interests from environmental and citizen groups, industry, public utilities, small 

business, transportation, government, and motorist and health-care organizations. 

Twenty-eight stakeholders were invited to participate in the stakeholders process. 

During the process, some invitees withdrew, and others were added by the group to 

maintain the group's balance. 

CONSENSUS AGREEMENTS 

The recommended strategies outlined in this report are based on a consensus 

decision-making process as outlined in the Stakeholders' Operating Agreement (See 

Appendix D). Consensus is an agreement built by identifying and exploring all parties' 

interests and drafting a recommendation that satisfies these interests to the greatest 

extent possible. The recommended control measures throughout this report are 

labeled as consensus recommendations only if all the stakeholders agree that their 

major interests have been taken into consideration and addressed in a satisfactory 

manner. This report also contains items without consensus agreements. In those 

cases, the control measure is described along with differing points of view. 

STAKEHOLDERS EVALUATION PROCESS 

The deliberations of the Southeastern Pennsylvania Ozone Stakeholders have followed 

two guiding principles and objectives: 1) to identify control strategies that collectively 

produce regional air quality that meets the current health based standard, and 2) to 

reflect the unique conditions of southeastern Pennsylvania. In so doing, the 

recommendations contained in this report seek to balance federal requirements for air 

quality with cost effective strategies that protect the public health and the regional 

economic integrity of the five county non-attainment area. 

EMISSIONS ASSESSMENT 

Modeling 

The stakeholders reviewed Urban Airshed Modeling results as a way to test transport 

and boundary assumptions, examine the impact of control strategies already adopted 

or proposed for implementation and lay the groundwork for southeastern 

Pennsylvania's subsequent attainment demonstration. 

The transport (movement) of ozone and its precursors, VOC and NOx, into and out of 

the five-county area was discussed many times during stakeholder deliberations, 

5 
including during modeling work. The impact of transport on attainment appears to be 

significant, particularly for NOx. The stakeholders make their recommendations in 

anticipation that other regions, particularly up-wind areas, will implement similar levels 

of control to positively impact southeastern Pennsylvania's air quality. The 

stakeholders recognize that the five-county area will not demonstrate attainment until 

downwind areas are also able to demonstrate attainment. 

Stakeholders' Emissions Targets 

In southeastern Pennsylvania there are a variety of different sources of both NOx and 

VOC. Point sources include large industries and utilities. Area sources are small 

emission sources. Mobile sources, both highway and off-road vehicles, are the third 

category of ozone forming emissions. The 1990 estimates of pollutant by source 

(excluding biogenic or natural emissions) are depicted below. 

Pennsylvania Portion of Philadelphia Non-Attainment Area 

Anthropogenic VOC Emissions by Source 

Estimated Total Emissions: 612 tons per summer day 

Point 24.5% Area 30.4% Mobile 45.1% (Highway 30.7%, Off-Road 14.4%) 

Pennsylvania Portion of Philadelphia Non-Attainment Area 

Anthropogenic NOx Emissions by Source 

Estimated Total Emissions: 451 tons per summer day 

Point 37.7% Area 5.1% Mobile 57.2% (Highway 35.1%, Off-Road 22.1%) 

Source: Pennsylvania Department of Environmental Protection 

The stakeholders spent a great deal of their time reviewing emission inventories, 

emission projections and other baseline information. In one such presentation, Dr. S.T. 

Rao from the New York State Department of Environmental Conservation, suggested 

that a 25% reduction in VOC and a 50% reduction in NOx from the 1990 baseline 

across the entire eastern United States could lead to attainment. The group agreed to 

use the information from Dr. Rao as the best available overriding strategy to set 

emission reduction targets. Because NOx and VOC emissions are not evenly 

distributed throughout the region, the stakeholders understand that these reduction 

goals must be viewed as regional in nature. Thus, they will not be achieved in 

Southeastern Pennsylvania alone, but over a multi-state area. The development of 

Pennsylvania's attainment demonstration will be coordinated with Pennsylvania's 

neighboring states and the Ozone Transport Commission. 

Reductions from adopted and proposed control measures are projected to result in a 

35% reduction of VOC emissions by the year 2005. The stakeholders recommend 

VOC control strategies beyond the 35% reduction from 1990 baseline. Thus, the 25% 

6 
voe reduction target (approximately 150 tons per day) will be exceeded by as much as 

100 tons. 

Reductions from adopted and proposed control measures are projected to result in a 

27% reduction in NOx emissions by the year 2005. The group looked for additional 

NOx reductions beyond the 27%. To reach 50% reduction from 1990 baseline, the 

stakeholders would have to identify measures that reduce approximately 105 tons of 

NOx per typical summer day. However, the NOx reductions were more difficult to 

achieve, and the stakeholders identified measures that reduced approximately 50 of the 

105 tons. 

Voluntary measures recommended by the stakeholders in this report could yield 

approximately 8 additional tons of voe and approximately 10 additional tons of NOx. 

The stakeholders recognize that the interplay between the two pollutants is uncertain. 

The additional reduction in VOC emissions will result in benefits to local air quality as 

well as benefits to the more regional ozone problem. 

The following table lists the recommended strategies and an estimated NOx or VOC 

reduction. In some cases no estimated emission reduction is listed. Those cases 

include: 

• recommended strategies that require research to quantify (e.g. heavy-duty diesel 

inspection) 

• recommended strategies with unresolved implementation issues (e.g. change in 

fuels beyond the five-county area), or 

• strategies with uncertain agency commitment (e.g. 200 additional eNG buses). 

7 
Southeast Pennsylvania Ozone Stakeholders 

Control Measures and Emission Reduction Estimates 

Description 

2005 CAA Baseline Emission Estimate 

Auto and Truck Body VOC Content Limits 

Auto and Truck Body Refinishing 

Degreasing 

Gasoline Service Stations: Stage II Vapor Recovery Systems 

Lawn Care 

Additional Remote Sensing 

Heavy-Duty Diesel NOx Research 

National Low Emission Vehicle 

Alternative Fuels Programs 

Airport Emission Controls 

Fuel Changes Beyond 5-County Area 

Southeast Pennsylvania Transportation Authority 

Clean Diesel Program 

Park and Ride Lot Expansion 

Rail Headway Improvements 

Improvements to Suburban Bus Service 

CNG Buses 

Utility Boilers: Phase III of NOx MOU 

Industrial Boilers 

Process Heaters 

Reciprocating IC Engines 

Subtotal 

VOC (tpd) 

Reduction Total 

3.8 

1.0 

5.9 

1.9 

11.2 

1.2 

11.5 

2.4 

0.2 

0.5 

0.03 

0.04 

0 

0 

0 

0 

39.7 

397 

NOx (tpd) 

Reduction Total 

o 

o 

o 

o 

0.7 

0.6 

13.5 

1.4 

0.07 

2.2 

0.04 

0.06 

6.4 

331 

3.5 to 4.5 

6.8 to 8.6 

11.0 

46.3 to 49.1 

8 
Southeast Pennsylvania Ozone Stakeholders Voluntary Measures 

Description 

Mobility Alternatives 

Comprehensive Regional Ride Sharing 

Transit Chek 

Telecommuting 

Alternative Work Schedules 

Educational Programs and Ozone Action Program 

School-Based Public Awareness 

We Care Programs Promotion 

Outreach and Education 

Transit Strategies 

Voluntary No Drive Days 

Voluntary No Burn Days 

Legislative Initiative 

Bicycle Promotion and Improvement 

WorklRail/Non-work Trips 

Land Use Planning 

Promote Community Centers and Transportation Centers 

Subtotal 

Total 

voe (tpd) 

Reduction 

0.08-1.76 

4.6-5.1 

1.1 

5.8 - 8.0 

45.5 - 47.7 

NO. (tpd) 

Reduction 

0.1-1.94 

7.4-7.8 

1.0 

8.5 - 10.7 

53.9 - 58.9 

9 
EXISTING AND ANTICIPATED CONTROL MEASURES 

Existing Measures (by summer 1996) 

The stakeholders assume the following strategies are required by the Clean Air Act 

Amendments and the Pennsylvania Air Pollution Control Act: 

NOx Reasonably Available Control Technology (RACT) 

VOC RACT fix-up 

New Federal Motor Vehicle Emission Standards 

Phase 1\ Gasoline Volatility Reductions 

Phase I Federal Reformulated Gasoline 

Stage I Terminal Controls (Required at Service Stations before 1990) 

Stage 1\ Vapor Recovery-Service Stations 

Improved Rule Effectiveness 

VOC Controls at Hazardous Waste Treatment, Storage and Disposal Facilities 

Anticipated Measures 

The stakeholders assume the following strategies will be fully implemented as required 

by the Clean Air Act Amendments: 

Highway Vehicles 

Federal Reformulated Gasoline-Phase 1\ (5-county area) 

High-Enhanced Inspection and Maintenance (5-county area) 

The Stakeholders assume the recommended control strategies contained in 

this report will include a Decentralized, High-Enhanced Vehicle Inspection 

and Maintenance program. A separate Inspection and Maintenance 

Working Group is developing recommendations for program implementation. 

A pilot program will be underway in early 1997. 

MACT Standards-Clean Air Act Title III (National) 

Petroleum Refinery 

Printing and Publishing 

Marine Vessel Loading 

National Rules/Control Technique Guidelines (National) 

Architectural and Industrial Maintenance Coatings 

Consumer Products Rule 

Autobody Refinishing 

Fuel Combustors (Ozone Transport Region) 

OTC Stationary Source NOx Memorandum of Understanding (MOU)-Phase II 

Controls (see attached NOx MOU) 

Non-Road EnginesNehicles (National) 

Federal Emissions Standards by Engine Type 

lO 
RECOMMENDED EMISSION CONTROL STRATEGIES 

Introduction 

The stakeholders attempted to reach consensus on a package of emission control 

strategies. The results of their discussion follows. Estimated emission reductions for 

the following control measures are listed in the table on page 8. For a list of control 

strategies considered by the stakeholders, refer to Appendix C. 

Funding Consistency 

The stakeholders agree that federal, state, regional and metropolitan planning 

organization (MPO) funding should be consistent with the recommendations in this 

document. 

Area Source Emissions 

Auto and Truck Body VOC Content Limits 

The stakeholders recommend limiting the VOC content of auto body refinishing 

products to the South Coast Air Quality Management District (SCAQMD) Standard. 

Auto and Truck Body Refinishing 

The Pennsylvania Department of Environmental Protection should pursue 

improvements in the auto and truck body repair industry to address improper handling, 

application and disposal of products containing VOC. Most of the stakeholders support 

state-wide limits on the sale of paint containing vac to auto and truck body repair 

shops to only those that have hazardous waste generation 10 numbers, equipment to 

control vac emissions and industry-funded training for employees handling and using 

the products. 

Degreasing 

The stakeholders recommend requiring the use of citric-based, water-based and other 

low VOC degreasers for commercial and industrial sources using VaC-containing 

degreasing solvents during the production, repair, maintenance or servicing of parts, 

products, tools, machinery, equipment or general work areas, using SCAQMD as a 

model. The stakeholders recommend that the control apply to all persons who store 

and dispose of VaC-containing materials used in degreasing. The stakeholders 

recommend exempting degreasing solvents with less than a 0.1 psi vapor pressure. 

11 
Gasoline Service Stations: Stage II Vapor Recovery Systems 

The stakeholders recommend that service stations with vacuum assist systems be 

required to install pressure vacuum valves on vent lines on underground storage tanks 

to further reduce VOC emissions. Stations switching from a balance system to a 

vacuum assist system should be required to install pressure vacuum valves. 

Lawn Care 

The stakeholders recommend that the state ban the use of non-commercial gasolinepowered lawn mowers and other gasoline-powered lawn equipment on Ozone Action 

Days. Most of the stakeholders recommend extending this ban to commercial lawn 

services. 

Mobile Source Emissions 

Additional Remote Sensing (on-road emission screening) 

Recognizing the role new technologies can play in reducing mobile source emissions, 

the stakeholders recommend expanding the enhanced inspection and maintenance 

(11M) remote sensing program beyond the proposed Pennsylvania State Implementation 

Plan (SIP) for Inspection and Maintenance. If remote sensing identifies an automobile 

registered outside the 11M testing area, the Commonwealth should request voluntary 

correction of the emission problem. 

Heavy-Duty Diesel NOx Research 

The stakeholders recommend that the Commonwealth initiate a research project to 

determine the NOx levels from heavy-duty diesel vehicles. If the research indicates 

significant NOx increases (in excess of manufacturer specifications), the stakeholders 

recommend the Commonwealth adopt appropriate NOx standards and initiate an 

inspection and repair program. (There is no estimated emission reduction associated 

with this strategy in the table on page 8 of this report.) 

Air Quality Benefits From Existing Transportation Programs 

The stakeholders recommend that the appropriate Commonwealth agencies determine 

the air quality value of programs such as transportation management and intelligent 

transportation systems (ramp metering, EZ Pass, smart route, etc.) and gas cap 

replacement programs. (There is no estimated emission reduction associated with this 

strategy in the table on page 8 of this report.) 

12 
National Low Emission Vehicle 

The stakeholders recommend the Commonwealth implement the National Low 

Emission Vehicle (NLEV) because of its national focus and cost-effectiveness. In the 

absence of NLEV, the stakeholders recommend the Commonwealth implement the 

Ozone Transport Commission Low Emission Vehicle (OTC LEV). 

Alternative Fuels Programs 

The stakeholders support continuation and expansion of voluntary liquefied petroleum 

gas (LPG), compressed natural gas (CNG) and other alternative fuels programs at 

refueling sites, including toll roads, to encourage the use of alternative fuels. The 

stakeholders also recommend expanded funding of the alternative fuel incentives 

program at the current match level to encourage the purchase and conversion of public 

and commercial fleets. 

Airport Emission Controls 

Stakeholders recommend efforts to control emissions from shuttle buses, ground 

support equipment and auxiliary power units at Pennsylvania's commercial airports and 

major transportation pOints to reduce NOx and VOC emissions. While the stakeholders 

believe that specific measures should be left to the discretion of the individual facilities, 

the stakeholders strongly recommend these facilities use alternative fuels wherever 

possible. The stakeholders also recommend that measures be taken to restrict 

curbside idling at airports and other transportation hubs statewide. The Department of 

Environmental Protection and commercial airports should negotiate emission targets for 

overall emissions. 

Fuel Changes Beyond 5-County Area 

The stakeholders agree that a fuel change in contiguous counties (Lancaster, Berks, 

Lehigh and Northampton counties) would be helpful in reaching attainment. The 

stakeholders did not reach consensus on expanding the use of reformulated gasoline 

(RFG) to selected areas beyond the five county Consolidated Metropolitan Statistical 

Area (CMSA). During the discussion, the stakeholders considered three options: 

• Federal RFG 

• low reid vapor pressure (RVP) gasoline with VOC and toxics reductions equal to 

RFG 

• a supplier option to provide low RVP gasoline or RFG, with a contingency to provide 

RFG if the attainment goal is not reached. 

No option received consensus support, although significant support exists for each 

option. Those who support expanding the area for RFG cite the greater ozone 

reduction, the NOx reduction beginning in the year 2000, the lower than expected cost 

13 
and the secondary toxies benefit as reasons why RFG is preferable. Those who 

support the low RVP proposals cite the cost-effectiveness of RVP as a control measure 

and are concerned over the increased cost of RFG. (Given this disagreement, the 

emission reduction table on page 8 does not reflect an emission reduction.) 

Southeast Pennsylvania Transportation Authority (SEPTA) 

SEPTA is changing its operations and upgrading its equipment in ways that should 

improve air quality. Although these improvements are not motivated primarily by the air 

quality benefit, the secondary regional air quality benefit should be accounted for in the 

Commonwealth's SIP. 

Clean Diesel 

The stakeholders support SEPTA's Clean Diesel program including SEPTA's 

plan to purchase 400 Cleaner Diesel Icarus buses, and the potential purchase of 

200 additional cleaner diesel buses. SEPTA will determine an additional bus 

purchase strategy in the near future; a decision is likely within the time frame of 

the development of Pennsylvania's Attainment SIP. (Because of uncertainty 

associated with the 200 buses, there is no estimated emission reduction in the 

table on page 8 of this report.) 

Park and Ride 

The stakeholders support SEPTA's short-term park and ride lot expansion on the 

regional rail system-approximately 4500 spaces. 

Headway Improvements 

The stakeholders support SEPTA's rail service headway improvements on the 

R7 regional rail line (up to 5 trains/hour) in conjunction with the 1-95 highway 

reconstruction project . 

Improvements to Suburban Bus Service 

Stakeholders recommend that the state find ways to assist SEPTA to expand 

public transit to suburban Philadelphia. The stakeholders also recommend that 

public and private partnerships be pursued to fund these efforts. (There is no 

estimated emission reduction associated with this strategy in the table on page 8 

of this report.) 

CNG Buses 

Possible purchase of 70 to 100 CNG-fueled buses for SEPTA's Frontier Division. 

SEPTA will continue to review the viability of this project and will determine 

whether a commitment can be made within the time frame of the development of 

Pennsylvania's Attainment SIP. (There is no estimated emission reduction 

associated with this strategy in the table on page 8 of this report.) 

14 
Stationary Sources 

Utility Boilers 

The stakeholders support Phase III NOx reductions for utility boilers as described in the 

NOx MOU, if they occur state-wide (see attached NOx MOU, Appendix B). The 

Department of Environmental Protection should pursue implementation of fair-share 

reduction requirements for utility boilers throughout the Ozone Transport Assessment 

Group (OTAG) region. 

Heaters/Boilers 

The stakeholders recommend expanding emission controls to some boilers, process 

heaters and other combustion units not currently included in the NOx MOU. Emission 

reduction requirements should apply to combustion units with rated heat inputs greater 

than 100 mmbtu/hour heat input and less than 250 mmbtu/hour heat input. Reductions 

should be based on a cost-effectiveness analysis for each boiler/heater similar to RACT 

with a $3000/ton threshold for installation of controls. The baseline to be used in the 

analysis is the average of the actual post-RACT ozone season operations of the 

boiler/heater for the previous three years. Boilers and heaters that are already below 

an average of 0.2 Ibs/mmbtu emissions rate during the ozone season will be exempt 

from further reductions. 

Reciprocating Internal Combustion Engines 

The stakeholders recommend NOx control technologies such as selective catalytic 

reduction (SCR), selective non-catalytic reduction (SNCR) or low emission combustion 

technology to reduce emissions from stationary internal combustion engines to at or 

below 2 grams/brake horse power hour, except emergency generators, unless they are 

used primarily during high ozone days. Stakeholders recommend that the Department 

of Environmental Protection base these measures on rated engine capacity of 1000 

horse power or larger. We further recommend that permit restrictions be made 

available to those facilities that either underutilize their engines or have special 

circumstances. In such cases, the permit restriction should be designed so that 

facilities operating under the restrictions cannot produce emissions beyond a specified 

level and that this level is verifiable and enforceable. 

Shutdowns 

The stakeholders support flexibility in how emission reductions from shutdowns are 

used. (There is no estimated emission reduction in the table on page 8 of this report.) 

15 
Trading Programs 

By consensus, the stakeholders recommend that the state implement an emiSSion 

reduction credit trading program to harness market mechanisms and to encourage 

innovation and competition in the private sector to achieve emission reductions. 

The stakeholders support the maximum feasible innovation and flexibility in the design 

of any trading program, provided that the reductions are: 

1) quantifiable, 

2) . verifiable, 

3) surplus, 

4) enforceable, and 

5) the transaction includes a benefit for the environment. 

The Commonwealth should require that protocols for generating and using emission 

credits support the five principles listed above and provide for the following: 

• A one-time emission reduction can generate a credit only if traded for a one-time 

emission. 

• Trading mechanisms, including inter-sector trading, should produce transactions 

with comparable air quality benefits. 

• Any trading program should consider the seasonal effects of credit generation 

and use on air quality. An unresolved point in stakeholder deliberations was that 

trading non-ozone-season emissions for ozone-season emissions may reduce 

the likelihood of attainment. 

The stakeholders differ over other details of a trading program: 

Inter-Pollutant Trading-Some stakeholders are opposed to trading one kind of 

pollutant for another because they believe that differences in toxicity between different 

VOC should render them untradable for one another. In addition, some oppose trading 

NOx for VOC and recommend limiting the trading to NOx for NOx and similar VOC for 

similar VOC. Most believe that a vibrant market requires having flexibility to trade 

between different pollutants and that appropriate trading ratios can be established 

among different VOC and between VOC and NOx. 

Geography-The location of the emission reduction and the location of the traded 

emissions is of concern to some stakeholders. They are concerned that businesses 

and residents near the facility that purchases the emission credit will be unwilling to 

accept a higher level of emission than would have occurred without a trading program. 

Open Market Trading-The stakeholders remain in disagreement about perhaps the 

most fundamental question-whether the trading should occur through a hybrid system 

of open-market trading and a cap-and-trade program, or exclusively through a cap-and16 
trade program. Most of the stakeholders support a hybrid approach. Some 

stakeholders support only a cap-and-trade approach. 

Voluntary Measures 

The stakeholders recommend voluntary emission reduction programs to augment the 

emission reductions from regulatory controls. The stakeholders recommend that EPA 

provide recognition and incentives for voluntary measures. 

Energy Conservation 

The stakeholders recommend that the Commonwealth promote and support energy 

conservation programs and work with local governments and federal agencies to 

encourage participation in these programs. 

Mobility Alternatives 

The stakeholders recommend that the Department of Environmental Protection support 

and encourage a comprehensive Mobility Altematives Program, including the following 

elements: 

• a voluntary regional ride-sharing program to encourage public transit and ride 

sharing including employer participation incentives, 

• promotion and expansion of the Transitchek program to further encourage the use 

of regional mass transit and ride sharing, 

• a telecommuting program to provide incentives to area businesses to reduce 

commuting traffic and 

• encouragement of alternative work schedules to stagger commuter traffic on area 

highways. 

Educational Programs 

The stakeholders recommend that the Department of Environmental Protection pursue 

other educational programs including the following voluntary and community education 

efforts: 

• a school-based program to promote knowledge of the ozone problem and the 

actions that lead to emission reductions, 

• a business-based program to promote voluntary pollution prevention and bestmanagement-practices programs and 

• a media-based program to alert the general public to days when ozone is forecast to 

be unhealthful and to request ozone-reducing actions. 

17 
Ozone Action Program 

The stakeholders recommend continuation of existing efforts to predict and announce 

high ozone days as part of an ozone action program and as part of other recommended 

control strategies that take effect on high ozone days. The stakeholders further 

recommend an ozone action program that will include the following elements: 

• transit strategies that will encourage transit use through incentives available on 

ozone action days, 

• promote a variety of voluntary ways to eliminate single-occupant vehicle travel on 

ozone action days, primarily by eliminating unnecessary automobile trips and 

• encourage citizens in southeastern Pennsylvania to eliminate open burning 

voluntarily on ozone action days. 

Bicycle Promotion and Improvements 

• The stakeholders further recommend that the Commonwealth encourage the use of 

bicycles (or other non-motorized means of travel) as substitute for short automobile 

trips. In order to promote bicycle use, the Commonwealth is urged to carry out 

bicycle and pedestrian improvements designed to offer safe and comfortable rightof-way. The stakeholders urge the Commonwealth to develop comprehensive 

bicycle improvements at regional facilities, including improvements at 14 selected 

rail stations, and expand non-motorized programs. 

Legislative Initiatives 

Land Use Planning-Promote Community Centers and Transportation Centers 

The stakeholders support and recommend that legislative initiatives be pursued to give 

county and municipal planning agencies greater powers and incentives to promote 

cooperative and comprehensive regional, county and local plans and coordinated 

implementation strategies, based on the concepts of compact community centers and 

transportation centers. Such centers would help to foster more concentrated 

development patterns, reduce unnecessary trips and facilitate choice in travel such as 

pedestrian, bicycle and public transit modes. 

Fuel Quality 

The stakeholders recommend that the Commonwealth implement a fuel quality testing 

program. 

18 
Funding 

Funding 

The stakeholders disagreed about whether to include recommendations about funding 

specific projects or organizations. The stakeholders discussed increasing dedicated 

public transit funding but did not agree to make a recommendation. 

19 
APPENDIX A 

Organizations/Stakeholders Invited 

To Participate In The 

Stakeholders Process 

20 
Philadelphia Stakeholders Representative 

Area Sources/Small Mark Hammond Graphic Arts/Printing 

Business 

Area Sources Jim Bauer Coatings 

Large Business/Employee Martha Anderson Thomas Jefferson 

Trips Hospital 

Stationary Tony Ippolito Sun Oil 

Source/Economic 

Development 

Stationary Source Susan Verzilli Rohm and Haas 

Large Business/Mobile Ned Griffith ARCO Chemical 

Sources 

Transportation Jill Welch Delaware County TMA 

Sector/Suburban County 

Transportation Sector Rich Bickel Septa 

Transportation /Small David Lee I and M Working Group 

Business 

Transportation /Mobile Jack Weber AAA 

Sources 

Transportation Sector Jim Perudo New Car Dealers 

Mobile Sources/Small Larry Potts Service Stations 

Business 

Health Norm Childs American Lung 

Health/Citizen Dr. Robin Foster-Drain To Our Children's Future 

With Health 

Environmental Shirley Loveless Pennsylvania 

Environmental Council 

Environmental Joe Minott Clean Air Council 

Environmental Nancy Parks Sierra Club 

Local Government Pat O'Neill City of Philadelphia 

Public- Peter Quinn GVFTMA 

PrivatelT ransportation 

21 
Regional Government Rob Roggenburk DVRPC 

State Jim Rue DEP 

State Fran Carlini DEP 

State Andy Warren DOT 

State Audrey Minor DOT 

Federal Tom Maslany EPA 

22 
APPENDIXB 

NOx Memorandum of Understanding 

23 
MEMORANDUM OF UNDERSTANDING 

AMONG THE STATES OF THE OZONE TRANSPORT COMMISSION 

ON DEVELOPMENT OF A REGIONAL STRATEGY CONCERNING THE CONTROL 

OF STATIONARY SOURCE NITROGEN OXIDE EMISSIONS 

WHEREAS, the States of the Ozone Transport Commission (OTC) face a pervasive 

problem in their efforts to attain the National Ambient Air Quality Standard (NAAQS) for 

ozone; and 

WHEREAS, a 1991 National Academy of Sciences study on ground-level ozone 

indicates that a combination of reductions in emissions of volatile organic compounds 

(VOCs) and nitrogen oxides (NOx) will be necessary to bring the entire Ozone 

Transport Region (OTR) into attainment by the statutory attainment dates; and 

WHEREAS, modeling and other studies confirm that NOx emission reductions are 

effective in reducing ozone formation and help to reduce ozone transport; and 

WHEREAS, the States of the OTC are requiring major stationary sources of NOx to 

implement reasonably available control technology (RACT); and 

WHEREAS, by November 15, 1994, the States must submit attainment demonstrations 

to EPA as State Implementation Plan (SIP) revisions; and 

WHEREAS, the implementation of RACT for the control of NOx emissions will not be 

sufficient to enable all States in the OTR to reach attainment; and 

WHEREAS, the undersigned States seek to develop an effective regional program to 

reduce NOx emissions, which would be implemented in conjunction with other 

measures to control ozone precursors (including state-specific measures, regional 

measures and Federal measures required under the Clean Air Act); and 

WHEREAS, these measures together may enable EPA to approve the States' SIPs and 

refrain from imposing sanctions that could restrict economic growth throughout the 

OTR; and 

WHEREAS, information that the States have collected in their emissions inventories 

shows that large boilers and other large indirect heat exchangers are the source of a 

substantial portion of the NOx emissions in the States, and will continue to be so after 

they implement RACT; 

WHEREAS, the States intend to complete a reevaluation of stationary source controls 

for 2003 and beyond in 1997, based on results of EPA-approved models and other 

relevant technical data; 

24 
THEREFORE, the undersigned member States hereby agree to propose regulations 

and/or legislation for the control of NOx emission from boilers and other indirect heat 

exchangers with a maximum gross heat input rate of at least 250 million BTU per hour; 

and 

FURTHERMORE, that the States agree to propose regulations that reflect the 

difference in conditions in (i) the OTR's "Northern Zone" consisting of the northern 

portion of the OTR: (ii) the OTR's "Inner Zone" consisting of the central eastern portion 

of the OTR: and (iii) the OTR's "Outer Zone" consisting of the remainder of the OTR; 

and 

FURTHERMORE, that to establish a credible emissions budget, the States agree to 

propose regulations that require enforceable specific reductions in NOx emissions from 

the actual 1990 emissions set forth in each State's 1990 inventory submitted to EPA in 

compliance with_'182(a) (1) of the Clean Air Act or in a similar emissions inventory 

prepared for each attainment area (provided that for exceptional circumstances that a 

more representative base year may be applied to individual sources in a manner 

acceptable to EPA) subject to public notice; and 

FURTHERMORE. that the States agree to develop a budget in a manner acceptable to 

EPA based on the principles above no later than March 1, 1995; and 

FURTHERMORE, if such a budget is not developed by March 1, 1995, that the 1990 

interim inventory used by EPA in its Regional Oxidant Model simulations for the 1994 

OTC Fall Meeting will be used for the budget; and 

FURTHERMORE, that the States agree to propose regulations that require subject 

sources in the Inner Zone to reduce their rate of NOx emissions by 65 percent from 

base year levels by May 1, 1999, or to emit NOx at a rate no greater than 0.2 pounds 

per million BTU; and 

FURTHERMORE, that the States agree to propose regulations that require subject 

sources in the Outer Zone to reduce their rate of NOx emissions by 55 percent from 

base year levels by May 1, 1999, or to emit NOx at a rate no greater than 0.2 pounds 

per million BTU; and 

FURTHERMORE, that the States agree to propose regulations that require sources in 

the Inner Zone and the Outer Zone to reduce their rate of NOx emissions by 75 percent 

from base year levels by May 1, 2003, or to emit NOx at a rate no greater than 0.15 

pounds per million BTU; and 

FURTHERMORE, that the States agree to propose regulations that require subject 

sources in the Northern Zone to reduce their rate of NOx emissions by 55 percent from 

base year levels by May 1, 2003, or to emit NOx at a rate no greater than 0.2 pounds 

per million BTU; and 

25 
FURTHERMORE, that the States agree to develop a regionwide trading mechanism in 

consultation with EPA; and 

FURTHERMORE, that in lieu of proposing the regulations described above, a State 

may propose regulations that achieve an equivalent reduction in stationary source NOx 

emissions in an equitable manner; and 

FURTHERMORE, that the regulations for May 1, 2003 described above may be 

modified if (i) additional modeling and other scientific analysis shows that the 

regulations as modified together with regulations governing VOC emissions, will 

achieve attainment of the ozone NMQS across the OTR, and (ii) this Memorandum of 

Understanding is modified to reflect those modeling results and other analysis no later 

than December 31,1998; and 

FURTHERMORE, that the States agree to propose regulations that are otherwise 

consistent with the attached recommendations of the OTC's Stationary/Area Source 

Committee; and 

FURTHERMORE, that the undersigned States agree to request that the EPA 

Administrator determine whether the SIPs of States outside the OTR contain adequate 

provisions to prohibit the emission of air pollutants in amounts that will contribute 

significantly to nonattainment of a National Ambient Air Quality Standard (NMQS) 

within the OTR, as required under 42 U.S.C. Section 110(a)(2)(O). 

26 
APPEND/XC 

Control Measures Summary 

27 
Measure 

No. Source Category 

Primary Control Measures Under Consideration 

1 Industrial Surface Coating 

Wood Furniture - Point 

Wood Furniture - Area 

Auto Body 

Can Coating 

Misc. Metal Parts 

Plastic/Rubber/Glass Parts 

Fabric/Paper Coating 

Vinyl Coating 

Magnet Wire 

Coil Coating 

Metal Furniture/Appl. 

Industrial Adhesives 

2 Surface Coating - Aerospace 

Aerospace Ctg. - Point 

Aerospace Ctg. - Area 

3 Autobody Refinishing 

Auto Ref. - Area 

4 Surface Cleaning/Degreasing 

Surface Cleaning/Degreasing 

5 Gasoline Service Stations: Underground 

Storage Tanks 

SE Pennsylvania Ozone Stakeholders Group 

Control Measures Summary 

VOC 

2005 2005 Emission Cost 

Control Measure Emissions tpd Reduction tpd Per Ton 

Add-on Controls or vec Content Limits 

1997 SCAOMD Limits 0.3 0.1 25 

CTG Limits 2.9 1.0 1,800-5,900 

none (more stringent levels were not 0.4 0 0 

identified) 

CARB RACT/BARCT 9.0 2.2 4,000-5,000 

CARB RACT/BARCT 2.2 0.7 4,260 

SCAOMD Limits 0.3 0.2 1,110 

SCAOMD Limits 23.1 5.5 4,000-5,000 

SCAOMD Limits N/A 41% 4,000-5,000 

none (more stringent levels were not N/A 0 

identified) 

CARB RAeT/BARCT 0.9 0.3 4,000-5,000 

CARB RACT/BARCT 7.5 1.5 4,000-5,000 

SCAOMD Limits 0.9 0.8 800-6,800 

Extend RACT, vec Content Limit 

none (assumed to be covered by MACT) 0 0 

MACT/SCAOMD limits 0.5 0.3 4,000-5,000 

vec Content Limits; CA Best Available 

Retrofit Control Technology 

SCAOMD Limits 10.8 3.8 3,700 

CARB's Best Available Control Technology; 

Low-VeC Solvents 

SCAOMD Limits 14.8 5.9 Cost Saving 

$100 

Install Pressure Vacuum (PV) Valves on 0.2 0 20·615 

Vent Line 

NO. 

2005 2005 Emission Cost 

Emissions tpd Reduction tpd Per Ton 

0 N/A 

0 N/A 

0 N/A 

0 N/A 

0 N/A 

28 
7 Petroleum Refinery Fugitive Emission Inspection and Maintenance Program 0 

Leaks 

Refinery Fugitives More Stringent LDAR 5.3 1.0 680-1,150 0 

8 Rule Effectiveness Improvements Increase Compliance with Regulations 

Rule Effectiveness Improvements Increased Compliance Activities 21.7 Unknown 0 

9 Web Offset Lithography Carbon Adsorber 0 

Web Offset Lithography Beyond CTG Req. (e.g., carbon adsorp.) 0.7 ~O Unknown 

10 Graphic Arts Low-VOC Inks and Cleaning Solvents 0 

Graphic Arts Extend RACT to Small Sources 2.4 1.5 3,500-4,800 N/A 

12 Pesticides Reformulation to Lower VOC Content 0 

Pesticides CA FIP Rule 1.4 0.3 1,000 

13 Utility Boilers 

Coal-Fired Boiler LNB + Overfire Air Plus (Phase 2 NO. MOU) 0.3 10.8 

Coal-Fired Boiler Selective CatalytiC Reduction (SCR) 0.3 10.8 4.0 4,000 

Oil/Gas-Fired Boiler LNB 0.8 23.2 

SCR 9.0 4,400 

14 Industrial Boilers 1.0 29.0 

Coal-Fired LNB 0.1 3.3 1.8 2,400 

Gas/Oil-Fired LNB + Flue Gas Recirculation (FGR) 25.3 16.5 2,000-

4,000 

18 Glass Manufacturing LNB 0 1.6 

SCR 1.2 800-2,950 

Oxy-Firing 1.2 2,150-

5,300 

19 Gas Turbines: Natural Gas LNB 

SCR + Steam Injection 0 0 0 0 3,580-

10,800 

20 Gas Turbines: Oil Water Injection 0.6 0 6.6 

NSCR + Water Injection 4.0 2,690-

8,100 

21 Reciprocating IC Engines: Diesel/Oil Ignition Timing Retard 0 0 0.1 

SCR 0.1 580-4,810 

22 Reciprocating IC Engines: Natural Gas Air/Fuel (AF) Ratio Adjustment + ITR 0.5 0 11.3 

SCR 10.1 580-4,810 

NSCR 10.1 180-310 

23 Process Heaters: Natural Gas or Oil LNB + FGR 0.1 0 10.4 6.8 1,500-

2,300 

29 
24 Iron and Steel Mills LNB + FGR or LNB + SCR 0.4 0 1.0 0.8 800-2,960 

LNB + SCR 0.8 2,150-

5,300 

25 Industrial, Commercial, and Institutional RACT to Small Sources 1.0 0 25.2 12.6 

Combustion 

RACT (LNB) to Smaller Sources: 

Coal 0.6 0.3 1,600 

Oil/Gas 24.6 12.3 760-1,400 

26 Residential Water Heaters LNB 0 0 0.9 0.1 Unknown 

27 Residential Space Heaters LNB 0 0 0 0 

28 Medical Waste Incinerators SNCR 0 0 0 0 12,000 

29 Municipal Waste Incinerators SNCR 0 0 0.1 <0.1 1,000-

4,000 

31 Highway Vehicles and Stationary Sources Ozone destroying paint 

- air handling 0 0 

systems, car radiators 

32 Asphalt Paving Driveways 

- Non-HC Asphalt 1.6 0 0 0 N/A 

33 Consumer Solvents Driveways 

- Sealer Low VOC 0.16 0.01 237 0 0 N/A 

34 Tra nsportation Land Use Planning 

- Promote Community 66.6 1.06 17,500- 105.8 0.96 -- Centers 19,100 

35 Light-, Medium-, and Heavy-Duty Diesel California Reformulated Diesel Program 2.8 0 N/A 11.3 0.8 $3,700-

Vehicles and Trucks 7,700 

36 Light-Duty Gasoline Vehicles and Trucks More Remote Sensing 63.8 1.2 3,340 94.5 0.6 -- 37 Light-Duty Gasoline Vehicles and Trucks Scrappage Programs 63.8 0.1 4,800 94.5 0.1 -- 38 Heavy-Duty Diesel Trucks Vehicle Emission Inspections 2.8 <0.1 11.3 0 

39 Llght-, Medium-, and Heavy-Duty Diesel Emission-Based Registration Fees 66.6 2.8 18,750 105.8 8.7 -- Vehicles and Trucks 

41 All Vehicles Eliminate Excessive Curb Idling 0 0 0 0 

42 Urban Buses Emissions Reduction Credit for Heavy-Duty 

Buses 

42a Highway Vehicles Emissions Reduction Credit for Heavy-Duty 2.8 .47 0 11.3 2.19 0 

Buses: Clean Diesel for SEPTA-baseline 

42b Highway Vehicles Alternative Fuel Vehicles SEPTA: CNG for 2.8 .01 457,800 11.3 0.23 26,700 

Frontier Division Business 

43 All Vehicles Smoking Vehicle Program 66.6 0.2 6,300 105.8 0 -- 44 Highway Vehicles Traffic Flow Improvements - Advanced 66.6 0.15 21,620 105.8 0.16 

Signal on 50 miles of Congested Arteries 

45 Highway Vehicles Traffic Flow Improvements 

- CSD 0.35 125,048 0.27 

Signalization 

46 Highway Vehicles Traffic Flow Improvements 

- Congestionl 0.16 200,452 0.07 

30 
Incident Management on Freeways 

47 Highway Vehicles Traffic Flow Improvements 

- Ramp Metering 0,41 2,700 0,034 

48 Highway Vehicles Traffic Flow Improvements 

- Enforce 55 mph 0,18 11,166 0,63 

on PA Turnpike 

51 Highway Vehicles Transit Operations 

- Rail Headway 66,6 0,04 369,600 105.8 0,06 246,400 

Improvements· Planned R 7 Changes 

55 Highway Vehicles Transit Operations· Improve Suburban Bus 0.Q7 45,356 0,10 

Service 

56 Highway Vehicles Transit Operations 

- Transit First Principles 0,02 123,079 0,02 

57 Highway Vehicles Transit Operations 

- Reuse of Surplus Light 0,01 92,277 0,01 

Rail and Trackless Trolleys 

58 Highway Vehicles Transit Operations 

- Improve City Transit 0,09 42,637 0,09 

Division Service 

59 Highway Vehicles Transit Operations 

- Philadelphia to 0,01 619,774 0,03 

Harrisburg Rail Service Improvements 

61 Highway Vehicles Transportation Management Plans 

- 0,30 10,262 0,33 

Comprehensive Regional Ridesharing 

Program 

62 Highway Vehicles Transportation Management Plans 

- 0,12 128,691 0,14 

Availability and Promotion of Average $25 

Transitchek 

63 Highway Vehicles Transportation Management Plans 

- 0,59 14,272 0,68 

Telecommuting 

64 Highway Vehicles Transportation Management Plans 

- 0,21 11,226 0,27 

Compressed Work Weeks 

69 Highway Vehicles Parking Management 

- Construct New Park 0,05 139,991 0,08 

and Ride Lots Along Highways 

70 Highway Vehicles Parking Management 

- Expand Parking at 66,6 0,03 274,150 105.8 0.04 169,950 

Rail Stations (combine with #69) Planned 

Expansion 

71 Highway Vehicles Non-Motorized Programs and Facilities 

- 0,21 48,740 0,18 

Comprehensive Bicycle Improvements - Auto 

Work Trips 

72 Highway Vehicles Non-Motorized Programs and Facilities 

- 0.00 65,513 0.00 

Comprehensive Bicycle Improvements - 14 

Rail Station Trips 

73 Highway Vehicles Non-Motorized Programs and Facilities 

- 0.33 21,709 0.34 

Comprehensive Bicycle Improvements -

Non-work Trips 

74 Highway Vehicles Emissions Reduction Programs 

- Removal of 66,6 0.4 57,354 105.8 0.3 

50% of Pre-1980 Vehicles 

31 
75 Highway Vehicles Emissions Reduction Programs - Reduction 1.00 1,864 0.63 

in Cold Starts/lnsulate Catalytic Converters 

76 Highway Vehicles Emissions Reduction Programs - National 66.6 11.5 1,860 105.8 13.5 

LEV Program 

77 Highway Vehicles Pricing Mechanisms - Feebate on New Car 0.28 4,393 0.17 

Purchase 

78 Highway Vehicles Pricing Mechanisms - Gas Tax (84¢ per 5.20 (205,484) 8.70 

gallon) 

79 Highway Vehicles Pricing Mechanisms - VMT Tax (4¢ per 66.6 5.20 (205,412) 105.8 8.70 

gallon) 

84 Highway Vehicles Transit Operations - Grants to Non-profits to 0.016 52,700 0.023 35,800 

Promote Transit 

91 Highway Vehicles High Occupancy Vehicle Lanes 66.6 0.6 Very High 105.8 1.3 Very High 

96 Highway Vehicles LPG - Pilot Programs at Service Stations 2.41 11,200 1.42 

Highway Vehicles CNG - Pilot Programs at Service Stations 66.6 2.41 174,100 105.8 1.42 294,300 

100 Highway Vehicles Area Source Business - Credits for 3,700-9,200 -- Alternative Fuel Vehicles 

103 Marine Vessels Control of Emissions (NO.) from Ships and 0 0 N/A 0 0 $10,000 

Ports 

104 Commercial Marine Vessels Emission fees ($10,000 per ton NO.) 0 0% N/A 0 0 $10,000 

105 Lawn and Garden Emission Reduction Credits for Leaf Blowers; 30.1 3.0 1,200 1.3 0.1 62,000 

Electric Lawnmowers 

106 Lawn and Garden Incentives for Electric Lawnmowers 30.1 3.0 1,200 1.3 0.1 62,000 

107 Nonroad Nonroad Engine Emission Reduction Credit 16.0 1.6 3,700-9,200 63.0 6.3 -- Programs 

109 Aircraft Control of Emissions from Aircraft and 9.4 1.6 -0 10.7 0.23 $970 

Ground Support Equipment 

Aircraft CNG-fueled Shuttle Buses 0.01 730,200 0.05 -- Aircraft LPG-fueled Shuttle Buses 0.005 (207,500) 0.003 -- III ~175 horsepower Compression Ignition California Phase II Exhaust Standards and 

(Diesel) Engines: EPA Statement of Principles with Engine 

Manufacturers 

Construction Equipment: Scrapers, 7.1 0 Unknown 43.3 0.8 Unknown 

Bore/Drill Rigs, Excavators, Cranes, 

Off-Highway Trucks, Rubber Tired 

Dozers, and Off-Highway Tractors 

Logging Equipment: Fellers/Bunchers . 112 Recreational Vehicles 0.6 9.3 

2-stroke engine category Potential CARB Standards 0.3 60-700 0 N/A 

4-stroke engine category Potential CARB Standards 0 60-700 0 N/A 

32 
113 Open Burning Ban on High Ozone Days 0.23 0.18 ~O 0.1 0.08 

114 Open Burning Year Round Ban 0.23 0.18 ~O 0.1 0.08 

116 All Lawn Care Ban on High Ozone Days 30.1 11.2 0 1.3 6.7 

118 Motor Vehicles Voluntary "No-Drive" Measure 63.1 5.1 92.6 7.4 

119 All Sources (or a Subset) Cap and Trade 1,000-1,800 

120 All Sources (or a Subset) Open Market Trade 1,000-1,800 

122 Various School-Based Public Awareness 4.6 101,700 7.8 -- Ozone Action 

123 Various Promote We Care Programs to Businesses Included in 122 

124 Various Outreach and Education - Environmentally Included in 122 

Responsible Behavior - Green Light 

126 Various Buying Emission Reduction Credits So They Market Price Market 

Cannot be Used (NO. and VOC) Price 

127 Various Reduce ERCs by X% per Year While They Market Price Market 

Are in the Bank (NO. and VOC) Price 

129 Highway Vehicles Ozone Action Days Transit Strategy 66.6 1.4 25,600 105.8 2.5 

130 Non-road Spark Ignition Engines <25 hp No Non-road SI Engines Standard Because (21.0) 13.0 

of NO. Disbenefit 

131 Lawn & Garden Refueling Leakless Gas Can Nozzles 2.5 2.2 1,400-5,800 0 0 NfA 

Outside Five County Area Measures 

85 Highway Vehicles Stage II - Entire Region (Beyond 5 County) 5.0 3.3 900 0 0 

128 Highway Vehicles and Non-road Expand Reform Gas Area to Counties North 56.0 14.8 5,800-10,300 67.0 4.0 -- and West of Five County Area 

33 
Demoted Measures 

6 Bulk Terminals Vapor Recovery System 

11 Adhesives: Industrial Reformulation and Product Substitution 0 

15 Adipic Acid Manufacturing Plants Thermal Reduction 0 0 

16 Nitric Acid Manufacturing Plants Extended Absorption 0 0 

SCR 

Nonselective Catalytic Reduction (NSCR) 

17 Cement Manufacturing LNB 0 0 

SCR 

SNCR (Urea-based) 

30 Various Small Business Tax Incentives 

40 Light-Duty Vehicles and Light-Duty Trucks Eliminate Excessive Car Dealership Vehicle 

Starts 

49 Highway Vehicles Transit Operations - Restore Regional Rail 0.01 857,915 0.02 

Service 

50 Highway Vehicles Transit Operations - Extension of Route 66 0.00 952,400 0.00 

Trackless Trolley 

52 Highway Vehicles Transit Operations - Systemwide Fare 66.6 0.09 109,255 105.8 0.13 

Reductions of 10% 

53 Highway Vehicles Transit Operations - Systemwide Fare 0.20 99,102 0.26 

Reductions of 20% 

54 Highway Vehicles Transit Operations - Systemwide Fare 0.47 112,247 0.69 

Reductions of 50% 

60 Highway Vehicles Transportation Management Plans - ETRP 1.80 (36,649) 2.20 

65 Highway Vehicles Parking Management - Prohibit New Parking Negligible Negligible Negligible 

Facilities in CBD Impact Impact Impact 

66 Highway Vehicles Parking Management - Limit Parking 0.08 (33,728) 0.08 

Facilities at New Suburban Employment 

Sites 

67 Highway Vehicles Parking Management - $3 Parking Surcharge 1.90 (435,912) 2.50 

68 Highway Vehicles Parking Management - $3 Parking Tax in the 0.47 (43,909) 0.73 

CBD 

80 Highway Vehicles Pricing Mechanisms - Double Tolls on PA 0.01 0 0.00 

Turnpike During Peak Periods 

81 Highway Vehicles Emission Reduction Programs - Alternative 2.8 0.14 229,500 11.3 2.4 13,550 

Fuels - SEPTA (0.61 with 42a) (53,300 with (4.6 with 42c) (7,100 with 

42a) 42a) 

82 Highway Vehicles Transit Operations - Reduce SEPTA Fares 

July-August 

34 
83 Highway Vehicles Pricing Mechanisms - HOV Parking Rate 

Incentive 

86 Highway Vehicles Stage II - Statewide 60-70% : 0 

87 Highway Vehicles Ride Sharing 

88 Highway Vehicles Increase Mass Transit Ridership - Parking 

Taxes, Market Incentives 

89 Highway Vehicles Flat Tax on Vehicles - $2007 

90 Highway Vehicles Build Two-Tier Highways 

92 Highway Vehicles Traffic Flow @ 45 mph 

93 Highway Vehicles Insulate Catalytic Converters 

94 Highway Vehicles Promote Telecommuting 

95 Highway Vehicles Credits for Compressed Work Week 

97 Highway Vehicles Non-Employee Trip Reduction - Health Clubs 

98 Highway Vehicles Buy New Engines for SEPTA - CNG, LPG 

Highway Vehicles Buy New Engines for SEPTA - LNG - Fleet 2.8 .14 337,000 11.3 2.4 19,900 

Replacement Program (.61 with 42a) (78,300 with (4.60 with 42a) (10,400 

42a) with 42a) 

99 Highway Vehicles Clean Fleet Replacement for Institutions, 

Large Businesses 

Highway Vehicles Clean Fleet Replacement for Institutions, 66.6 2.89 12,400 105.8 1.71 20,900 

Large Business· Light-Duty Vehicles 

101 Highway Vehicles Voluntary ETR 

102 Highway Vehicles Alternative Fuel Vehicle - Build Fuel Stations 

108 Locomotives Regional Railroad NO. Emissions Reduction 0.8 0% 8.2 2.9-3.5% 

Measure 

110 Locomotive Engines Potential Federal NO. Emission Standards 0,8 8.2 3.3% 

Potential CA NO. Emission Standards 6.6% 

115 Commercial Lawn Care Ban on High Ozone Days 

117 Recreational Boating Ban on High Ozone Days 10.9 1.1 

121 All Sources (or a Subset) Across the Board Emission Reductions 

125 Various Environmental Think Tank 

35 
APPENDIXD 

Operating Agreements 

36 
OPERATING AGREEMENTS FOR STAKEHOLDER DELIBERATIONS 

Finalized - May 6, 1996 

PURPOSE 

To recommend strategies for ozone attainment and maintenance based 

on the current health-based standards and the requirements of the Clean 

Air Acts. 

ROLES 

Stakeholder Representative Roles 

Each member of the Ozone Stakeholder Working Group is expected to: (a) regularly 

attend and prepare for work sessions of the Ozone Stakeholder Working Group; (b) 

clearly articulate and represent the interests of his/her group, when appropriate; (c) 

listen to other points of view and try to understand the interests of others; (d) openly 

discuss issues with people who hold diverse views and participate in a cooperative 

problem solving procedure to resolve differences; (e) generate and evaluate options to 

address the needs expressed by the Ozone Stakeholder Working Group; (f) keep 

his/her constituent group(s) informed and solicit their input, when appropriate. 

Facilitators 

CDR Associates will provide facilitation services to the Ozone Stakeholder Working 

Group. The facilitators will design and implement discussion and decision making 

procedures to help the Working Group accomplish its goals. In consultation with the 

Process Advisory Committee, the facilitators will design work session agendas. They 

will conduct the meetings, provide a procedural structure, and make strategic 

suggestions as to how cooperative problem solving can be implemented. They will 

remain impartial toward the substance of the issues under discussion. Any decision 

that results from the facilitators' activities will be a group decision, not a decision of the 

facilitators. The facilitators will remain responsible to the whole group and not to one 

member or interest. The facilitators will enforce ground rules that are accepted by the 

group and that support the effective working relationship of the group. 

Process Advisory Committee 

The Process Advisory Committee (a subset of the stakeholders) will work with the 

facilitators to help with the process (develop agendas, frame issues, develop the 

problem solving process, etc.). Stakeholders may raise any procedural concerns with a 

member of the Process Advisory Committee or directly with the facilitators to improve 

the problem solving process. 

37 
Technical Consultants 

The Ozone Stakeholder Working Group will solicit technical assistance as needed to 

inform the deliberations. Services might include data collection, modeling and analysis. 

The Commonwealth will provide the technical consultant to support the Ozone 

Stakeholder Working Group. In order to support the Ozone Stakeholder Working 

Group in a expeditious manner, the technical consultant will be selected from an 

existing PA Department of Transportation contract. Penn DOT will manage the 

administrative aspects of the contract; the substantive focus will be managed by the 

stakeholder group and its Data Advisory Committee. Individual stakeholders may bring 

additional information, collected through their own sources, into the stakeholder 

deliberations. The stakeholders may accept the information directly or refer it to the 

Data Advisory Committee. 

Data Advisory Committee 

The Data Advisory Committee (a subset of the stakeholders) will work with the 

facilitators and the stakeholders to help with technical questions, data collection, 

technical presentations, consultant selection and budget allocation. 

DECISION MAKING 

Consensus' 

The negotiators will use a consensus decision making process. 

Consensus is an agreement built by identifying and exploring all parties' interests and 

by assembling a package agreement which satisfies these interests to the greatest 

extent possible. A consensus is reached when all parties agree that their major 

interests have been taken into consideration and addressed in a satisfactory manner so 

that they can support the decision of the group. The process of building consensus 

involves the development of alternatives and the assessment of the impacts of those 

alternatives. A consensus agreement is one that all parties can live with. 

Consensus does not necessarily mean unanimity. Some parties may strongly endorse 

a particular solution while others may accept it as a workable agreement. Group 

members can participate in the consensus without embraCing each element of the 

agreement with the same fervor as other members, or necessarily having each of his or 

her interests satisfied to the fullest extent. In a consensus agreement, the parties 

recognize that, given the combination of gains and trade-offs in the decision package 

and given the current circumstances and alternative options, the resulting agreement is 

the best one the involved parties can make at this time. 

38 
Key Principles of Consensus 

To achieve consensus, everyone in the group must actively participate. 

To participate fully and freely, all group members must have a common base of 

information and keep up-to-date on the progress of the group. 

A norm must be created in which everyone will feel comfortable to state his or 

her views and to disagree. 

A disagreement can illuminate unrecognized problems and serve as a catalyst 

for improving the decision. 

The goal of the group is to discover the unmet need that has produced an 

objection and to find a way to meet that need in a revised agreement, rather than 

to suppress the objection. 

Agreement on definition, principles and criteria should precede and become the 

underpinnings of substantive agreements. 

If there are issues the stakeholders cannot resolve through consensus decision making, 

the stakeholders will summarize the issue and fully document the remaining 

differences, including the specific concerns of individual stakeholders. Implementing 

agencies will use this summary as they advance ozone attainment in line with their 

mandates and air quality responsibilities. 

CONSTITUENTS 

Informed constituencies will enhance the prospects for approval of the 

recommendations of the Working Group. The members of the Ozone Stakeholder 

Working Group who represent agencies or constituencies will inform their constituents 

on an ongoing basis as to the issues under discussion and the progress being made in 

the cooperative problem solving sessions. They will represent the interests of their 

constituent group and bring their constituents' concerns and ideas to the negotiation. 

Members of the Working Group may elect to hold regular meetings with their 

constituent group (a formal caucus), to provide copies of work session summaries to 

their constituents and request comments, and/or to communicate informally with their 

constituents as appropriate. 

REPRESENTATION 

To enhance creativity during meetings, individuals who represent agencies or 

constituencies are not expected to restrict themselves to the prior positions held by their 

agencies or constituencies. The goal of the stakeholder group is to have frank and 

open discussion of the issues in questions and the options to address the issues. 

39 
Therefore, ideas raised in the process of the dialogue, prior to agreement by the whole 

group, are for discussion purposes only and should not be construed to reflect the 

position of a stakeholder or to prematurely commit the group or anyone stakeholder. 

Stakeholders are expected to serve as a continuous liaison so that the interests of any 

agency or constituency they represent are represented while the stakeholders give 

thorough consideration to new options. 

AITENDANCE 

Participating in consensus decision making requires consistent attendance. Should a 

stakeholder be unable to attend, and should the stakeholder choose to nominate an 

alternate, an alternate may attend the meeting. Alternates must attend as many 

meetings as possible. Alternates may enter into the deliberations and into decision 

making when the stakeholder is not present Alternates will not be allowed to keep the 

group from moving forward or delay a decision because they do not have knowledge or 

authority to decide. Stakeholder representatives and alternates are responsible for 

staying current with any sessions they are unable to attend. Stakeholders are not 

obligated to use the time dedicated to problem solving sessions to backtrack and 

accommodate those who have not attended a prior meeting. 

SUPPORT 

Stakeholders are encouraged to bring staff from their agency/organization and 

members of their constituency to support the problem solving process. Stakeholders 

can defer to those individuals when their expertise is required or when requested by the 

Working Group. The use of support staff must not disrupt stakeholder deliberations. 

Only stakeholder representatives and alternates (when the representative is absent) will 

enter into consensus decisions. 

OBSERVERS 

Ozone Stakeholder Working Group Meetings will be open to the public. Input by nonmembers may be useful to the Ozone Stakeholder Working Group. However, in order 

for the Working Group to achieve its mission, discussion and deliberation at Committee 

work sessions must be focused and manageable. Participation of non-members of the 

Working Group will be at the discretion of the Working Group. Opportunities for 

participation by non-members include: 

1. Opportunity for non-members to discuss their views with members of the 

Working Group during breaks. 

2.· Scheduled time at the end of the work sessions for questions and comments from 

non-members (10 or 15 minutes). 

40 
COMMUNICATING WITH THE PUBLIC 

The Ozone Stakeholder Working Group may elect to hold public meetings to provide 

information to the public on the Working Group's progress and/or to solicit input from 

the public. 

Work session summaries will be available to the public upon request. The DEP 

Newsletter, UPDATE, will list meeting notices and agendas. Information, including 

meeting summaries, will also be posted on DEP's World Wide Web Public Participation 

Center. 

DISCUSSION GUIDELINES 

The following guidelines encourage productive negotiations. Members of the Ozone 

Stakeholder Working Group will commit to "best efforts" at following them and will give 

the facilitators the authority to enforce them: 

It is absolutely crucial that everyone have a chance to be heard and to hear 

others. Therefore, side conversations or interruptions while someone is 

speaking should be avoided. 

In order to give everyone a chance to talk, participants should be sensitive about 

the length and pertinence of their comments and the importance of encouraging 

participation from all members of the group. 

In order to maximize the productive time available, people should avoid 

repeating points that have already been adequately made by others, except to 

briefly indicate concurrence. 

It is important to remain open-minded about proposals, ideas, concerns, etc., 

while different points of view are being presented and discussed. Rather than 

label particular proposals as "good" or "bad," it will be useful to be open to the 

underlying concems that are expressed in a proposal. 

Disagreement is inevitable, but must be focused on the issues involved rather 

than based on perceptions of motives or relationships and personalities. 

The consensus process is a cooperative, joint problem-solving effort. Therefore, 

members must avoid competitive behavior that denigrates other participants or 

that is disruptive to the work of the group. 

The work sessions will begin and end promptly at the scheduled times. 

41 
COMMUNICATING WITH THE MEDIA 

Work sessions of the Ozone Stakeholder Working Group will be open to the public, 

including the media. The consensus process is a solution-oriented, problem solving 

approach, not a platform for lobbying the public through the media. The deliberations of 

the Ozone Stakeholder Working Group should not be used as opportunities for 

individual members to posture in order to gain the attention of the media. 

If the Working Group as a whole decides that there is a need for the Group to 

communicate with the press, the Working Group members will designate a 

spokesperson(s) and/or draft a statement. Stakeholders can refer members of the 

press to CDR for questions about the process and to DEP for information about the 

stakeholder group's progress on substantive issues. 

In communicating with the media and the general public, a clear distinction should be 

made between preliminary information, concept papers, or proposals under 

consideration and final decisions. It is important to differentiate between discussions 

and decisions. Preliminary documents will be marked with "DRAFr' or "FOR 

DISCUSSION PURPOSES ONLY." 

Each stakeholder is free to speak with the press on behalf of the agency or 

constituency he or she represents and must make it clear to the press that the 

comments should not be attributed to the whole stakeholder group. No stakeholder will 

speak for the whole stakeholder group without express authorization by consensus of 

the stakeholder group. No stakeholder will characterize the point of view of other 

representatives. 

EXTERNAL INITIATIVES 

Stakeholders will disclose to the stakeholder group as a whole any potential initiatives 

or activities (e.g. law suits, legislative actions) that could impact the functioning of the 

stakeholder group or be of interest to the stakeholders. Stakeholders will provide the 

information in an open and timely manner. DEP, EPA, the City of Philadelphia and any 

other stakeholder will keep the group informed of any policy, regulation or legislation 

related to the ozone problem. 

TASKS GROUPS 

The Ozone Stakeholder Working Group may form task groups to perform specific 

functions or develop proposals on specific issues. Information and recommendations 

the task groups develop will be presented to the stakeholders for the Committee's 

consideration. The composition and scope of work for each task group will be 

designated by the stakeholders. The task groups may include technical support from 

non-members of the working group. 

42 
INSPECTION AND MAINTENANCE WORKING GROUP 

While the ozone stakeholder group deliberates, a separate but related group will be 

working to outline the details of a successful, decentralized emissions program. The 

ozone stakeholder group is responsible for policy level recommendations about the 

emissions program's contribution to ozone attainment. The I and M Working Group will 

take policy direction from the ozone stakeholders and then is responsible for 

recommendations about the emission program's implementation. 
APPENDIXE 

Glossary 

44 
AQMD 

BTU 

CAAA 

CFFV 

CMSA 

CNG 

DEP 

DERs 

DVRPC 

EPA 

ERC 

FIP 

g/bhp-hr 

11M 

IC 

LEV 

LNB 

LPG 

MACT 

mmbtu 

MOU 

MPO 

MTBE 

NAAQS 

NGV 

NLEV 

NOx 

OBO I 

OBO II 

OBD 

OTAG 

OTC 

PennOOT 

ppb 

ppm 

psi 

PV 

RACT 

RFG 

RVP 

SCR 

SEPTA 

SIP 

SCAQMD 

SNCR 

air quality management district 

British thermal unit 

Clean Airs Act Amendments of 1990 

clean fuel fleet vehicle 

consolidated metropolitan statistical area 

compressed natural gas 

Pennsylvania Department of Environmental Protection 

discrete emissions reductions 

Delaware Valley Regional Planning Commission 

U.S. Environmental Protection Agency 

emission reduction credit 

Federal Implementation Plan 

grams per brake horsepower hour 

inspection and maintenance 

internal combustion 

low-emission vehicle 

low NOx burner 

liquefied petroleum gas 

maximum achievable control technology 

million BTU 

memorandum of understanding 

metropolitan planning organization 

methyl tertiary butyl ether 

National Ambient Air Quality Standard(s) 

natural gas vehicle 

national emission vehicle 

nitrogen oxide 

phase I onboard diagnostics 

phase II onboard diagnostics 

onboard diagnostic 

Ozone Transportation Assessment Group 

Ozone Transport Commission 

Pennsylvania Department of Transportation 

parts per billion 

parts per million 

pounds per square inch 

pressure vacuum 

reasonable available control technology 

reformulated gasoline 

reid vapor pressure 

selective catalytic reduction 

Southeastern Pennsylvania Transportation Authority 

state implementation plan 

South Coast Air Quality Management District 

selective non-catalytic reduction 

4S 
OZONE STAKEHOLDERS 

Richard Bickel, Southeastern Pennsylvania Transportation Authority - SEPTA 

Dennis Capella, PECO Energy Company 

Francine Carlini, Pennsylvania Department of Environmental Protection - Philadelphia 

Region 

Tom D'Alessandro, Thomas Jefferson University Hospital 

Ned Griffith, ARCO Chemical Company 

Mark Hammond, Graphics Arts Association 

Paul Hess, DEP Citizens Advisory Council 

Anthony Ippolito, Sun Company/Associated Petroleum Industries of Pennsylvania 

David Jackson, Chester County Health Department 

Rosalind Johnson, Sea Change 

David Lee, ASE SAE 

Shirley Loveless, Pennsylvania Environmental Council 

Tom Maslany, U. S. Environmental Protection Agency 

Audrey Miner, Pennsylvania Department of Transportation 

Joseph Otis Minott, Clean Air Council 

Patrick O'Neill, City of Philadelphia 

Nancy Parks, Sierra Club 

Jim Peruto, Keenan Motors 

Peter Quinn, Greater Valley Forge Transportation Management Association 

Ron Roggenburk, Delaware Valley Regional Planning Commission 

Jim Rue, Pennsylvania Department of Environmental Protection 

Jerry Schantz, Automotive Service Association of Pennsylvania 

Michael Stokes, Montgomery County Planning Commission 

Suzanne Verzilli, Rohm and Haas 

Andy Warren, Pennsylvania Department of Transportation 

Jack Weber, AAA Mid-Atlantic 

Jill Sebest Welch, Delaware County Transportation Management Association 

FACILITATOR 

Mike Hughes -- CDR Associates 
APPENDIXB 

Control Measure Evaluations Prepared for SE 

P A Ozone Stakeholders Group 

Draft 

Full report submitted to EPA with SIP revision. See File for 

Report.