SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: John Quigley, Secretary, Pennsylvania Department of Environmental Protection (PADEP)

 Date Submitted: Letter dated September 30, 2015, received October 1, 2015

 Subject: 2011 Base Year Inventory for the following marginal areas for the 2008 National Ambient Air Quality 

Standards: Allentown-Bethlehem-Easton, Lancaster, Pennsylvania portion of the PhiladelphiaWilmington-Atlantic City, Pittsburgh-Beaver Valley, and Reading

Completeness Review 

 Completed by: Maria A. Pino

 Date Completed: 9 October 2015

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal signed, stamped, and dated letter of submittal 

from the Governor or his designee, requesting EPA 

approval of the plan or revision thereof. If electing to 

submit a paper submission with a copy in electronic 

version, the submittal letter must verify that the electronic 

copy provided is an exact duplicate of the paper 

submission.

1. Letter to Shawn M. Garvin, Regional Administrator, EPA 

Region III., dated September 30, 2015, from PADEP Secretary 

Quigley, received October 1, 2015.

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. N/A – Not a plan or regulation, sp not “adopted.” Final 

emissions inventory report, dated September 2015, “State 

Implementation Plan Revision: 2011 Base Year Inventory for 

Pennsylvania Portion of Five 2008 Ozone Nonattainment Areas: 

Allentown-Bethlehem-Easton, Lancaster, PhiladelphiaWilmington-Atlantic City, Pittsburgh-Beaver Valley, Reading” 

(September 2015 SIP Revision Submittal).

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. The emission inventories are not “plans or regulations.” 

However, section 5 of the Air Pollution Control Act (35 P. S. § 

4005) subsection (a)(1) grants Pennsylvania’s Environmental 

Quality Board the authority to adopt rules and regulations for the 

prevention, control, reduction and abatement of air pollution in 

this Commonwealth, and subsection (a)(8) grants the Board the 

authority to adopt rules and regulations designed to implement 

the Clean Air Act (CAA) (42 U.S.C.A. §§ 7401—7671q).
EPA REQUIREMENT STATE SUBMITTAL (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 (such as 

redline/strikethrough) to the existing approved plan, where 

applicable. The submission shall include 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 any

regulation/document contained in the submission shall, 

whenever possible, be indicated in the regulation/document 

itself; otherwise the State should include a letter signed, 

stamped, and dated by the appropriate State official 

indicating the effective date. If the regulation/document 

provided by the State for approval and incorporation by 

reference into the plan is a copy of an existing publication, 

the State submission should, whenever possible, include a 

copy of the publication cover page and table of contents.

4. State Implementation Plan Revision: 2011 Base Year 

Inventory for Pennsylvania Portion of Five 2008 Ozone 

Nonattainment Areas: Allentown-Bethlehem-Easton, Lancaster, 

Philadelphia-Wilmington-Atlantic City, Pittsburgh-Beaver 

Valley, and Reading, dated September 2015

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. Statement in September 30, 2015 submittal letter from 

PADEP Secretary Quigley. Copies of public notice in the 

Pennsylvania Bulletin and newspapers.

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. Notices in the Pennsylvania Bulletin (45 Pa.B. 4985, 

8/22/2015), Allentown Morning Call (8/19/2015), Bucks County 

Courier Times (8/19/2015), Delaware County Daily Times

(8/19/2015), Harrisburg Patriot News (8/18/2015), Lancaster 

New Era (8/20/2015), Pittsburgh Post-Gazette (8/18/2015), and 

Reading Eagle (8/19/2015).

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. N/A – No public hearing was requested, as stated in the 

September 30, 2015 submittal letter. Public notice cited in #6, 

above, included opportunity to request a public hearing.

8. Compilation of public comments and the State’s 

response thereto.

8. N/A – No public comments were received, as stated in the 

September 30, 2015 submittal letter.
Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. VOCs, NOx, and CO emissions under the 2008 ozone 

NAAQS, as stated in the Introduction and Overview section of 

the September 2015 SIP Revision Submittal.

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. Marginal nonattainment areas under the 2008 ozone 

NAAQS, the Allentown-Bethlehem-Easton, Lancaster, 

Philadelphia-Wilmington-Atlantic City, Pittsburgh-Beaver 

Valley, and Reading Areas, and described in the Introduction 

and Overview section of the September 2015 SIP Revision 

Submittal

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. N/A. This is the 2011 Base Year Inventory, representing 

VOCs, NOx, and CO emissions in the Allentown-BethlehemEaston, Lancaster, Philadelphia-Wilmington-Atlantic City, 

Pittsburgh-Beaver Valley, and Reading Areas in calendar year 

2011, as described in the Summary of the Base Year Emissions

Inventory section of the September 2015 SIP Revision 

Submittal.

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

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

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

and implemented. 

4. N/A. This is the 2011 Base Year Inventory, representing 

VOCs, NOx, and CO emissions in the Allentown-BethlehemEaston, Lancaster, Philadelphia-Wilmington-Atlantic City, 

Pittsburgh-Beaver Valley, and Reading Areas in calendar year 

2011, as described in the Summary of the Base Year Emissions 

Inventory section of the September 2015 SIP Revision 

Submittal.

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. Files with technical information & data supporting the 

emissions inventory are contained in CDs accompanying the 

submittal.

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

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

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. N/A

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. N/A

9. Special economic and technological justifications required 

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

explain why.)

9. N/A

10. A Section 107 request must be accompanied by a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.

10. N/A