SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Pennsylvania Department of Environmental Protection

Date Submitted: January 29, 2013

Subject: Motor Vehicle Emissions Budgets for the Pennsylvania Counties in the Philadelphia-Wilmington, PA-NJ-DE 

 1997 Fine Particulate Matter Nonattainment Area

Completeness Review 

Completed by: Asrah Khadr 

Date Completed: February 6, 2013

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

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

designee, requesting EPA approval of the plan or revision 

thereof.

1. Letter dated January 29, 2013 from Michael L. Krancer, 

Secretary, Pennsylvania Department of Environmental 

Protection (DEP) to Shawn M. Garvin, Region III 

Administrator.

X

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

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

agreement in final form. That evidence shall include the date 

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

plan, if different from the adoption/issuance date.

2. Not applicable. NA

3. Evidence that the State has the necessary legal authority

under State law to adopt and implement the plan.

3. Revision was completed pursuant to 40 CFR Part 51, 

Appendix V, sections 2.1 and 2.2. 

X

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

approval and incorporation by reference into the plan, including 

indication of the changes made to the existing approved plan, 

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

State regulation/document signed, stamped, dated by the 

appropriate State official indicating that it is fully enforceable 

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

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

4. Pennsylvania submitted the revised motor vehicle 

emissions budgets (MVEBs) as well as technical appendices to 

support their revision.

X
EPA REQUIREMENT STATE SUBMITTAL (X)

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in conducting 

and completing the adoption/issuance of the plan.

5. Submittal satisfies all applicable requirements of 40 CFR 

Part 51 Appendix V, sections 2.1 and 2.2. 

X

6. Evidence that public notice was given of the proposed 

change consistent with procedures approved by EPA, including 

the date of publication of such notice.

6. Public notice of the State Implementation Plan (SIP) 

revision and the hearing was provided in Delaware County’s 

Newspaper, The Daily Times. Public notice was also provided 

in the Bucks County Courier Times as well as the Pennsylvania 

Bulletin. 

X

7. Certification that public hearings were held in accordance 

with the information provided in the public notice and the 

State's laws and constitution, if applicable.

7. Not applicable. NA

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

thereto.

8. The comments received as well as their responses are 

included in the document entitled “Commonwealth of 

Pennsylvania Comment Response Document for the Revisions 

to the Pennsylvania Portion of the Philadelphia-Wilmington, 

Pennsylvania-New Jersey-Delaware 1997 PM2.5 

Nonattainment Area January 2013.”

X
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. Fine particulate matter (PM2.5). X

2. Identification of the locations of affected sources including 

the EPA attainment/nonattainment designation of the locations 

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

2. Pennsylvania counties in the Philadelphia-Wilmington, PANJ-DE 1997 PM2.5 Nonattainment Area. X

 

3. Quantification of the changes in plan allowable emissions 

from the affected sources; estimates of changes in current 

actual emissions from affected sources or, where appropriate, 

quantification of changes in actual emissions from affected 

sources through calculations of the differences between certain 

baseline levels and allowable emissions anticipated as a result 

of the revision.

3. Updated MVEBs completed via the Motor Vehicle 

Emission Simulator model (MOVES), the difference between 

the updated MVEBs and the MVEBs completed via the 

Highway Mobile Source Emission Factor Model (MOBILE)

are quantified. 

X

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

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

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

and implemented. 

4. Pennsylvania provides technical support to show that the 

update of the MVEBs will not affect the Pennsylvania counties 

in the Philadelphia-Wilmington, PA-NJ-DE 1997 PM2.5

Nonattainment Area’s ability to attain the 1997 PM2.5 National 

Ambient Air Quality Standard (NAAQS). 

X

5. Modeling information required to support the proposed 

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

ambient monitoring data used, meteorological data used, 

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

models used, assumptions, and other information relevant to 

the determination of adequacy of the modeling analysis.

5. MOVES inputs and outputs are explained and sample input 

files are provided. 

X

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Not applicable. NA

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. Not applicable. NA

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Not applicable. NA
EPA REQUIREMENT STATE SUBMITTAL (X)

9. Special economic and technological justifications required 

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

explain why.)

9. Not applicable. NA

10. A Section 107 request must be accompanied by a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.

10. Not applicable. NA