	SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: 	Pennsylvania Department of Environmental Protection
(PADEP)	

Date Submitted: 	April 24, 2007

Subject: 		Redesignation of the Erie ozone nonattainment area to
attainment and approval of the area(s maintenance plan and 2002
base-year inventory.  

Completeness Review 

Completed by: 	Amy Caprio				

Date Completed: 	June 5, 2007

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.Letters submitted April 24, 2007 on behalf of the Commonwealth of
Pennsylvania from Kathleen A. McGinty, Secretary, PADEP to Donald S.
Welsh, Regional Administrator, EPA Region III.  	

X





2. Evidence that the State has adopted the plan in the State code or
body of regulations; or issued the permit, order, 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 regulatory change the submittal is request for
redesignation, a maintenance plan, and 2002 base-year inventory approval
that is effective March 2007).  	

X



3. Evidence that the State has the necessary legal authority under State
law to adopt and implement the plan.	

3.  PA has SIP authority under Section 5 of the Air Pollution Control
Act.  	

 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.  N/A See number 2 above.  	

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.  N/A	

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.  PADEP provided proof that the notice of public hearing was published
in the Pennsylvania Bulletin on Saturday February 17, 2007. 	

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. Notice of the hearing was given to the public in the Pennsylvania
Bulletin on February 17, 2007 and in a newspaper of general circulation
(Erie Times News) on February 17, 2007.  	

X



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

8.  The state submittal includes a compilation of public comments and
responses thereto.  In this instance there were no public comments
received at PADEP’s public hearing.   	

X



1. Identification of all regulated pollutants affected by the plan.	

1.  The introduction of the Redesignation Request and Maintenance Plan
discuss what pollutant this action is addressing.  	

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.  Erie County (Erie 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.  Detailed information on the point, area and mobile source emissions
estimates used in the request of redesignation to attainment, the ozone
maintenance plan, and the 2002 base-year inventory for the Erie Area. 
Information is provided on growth factors used to project emission
inventories as well as methods used to determine the growth factors.  	

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.  The state has developed a current and projected (2002, 2004, 2009,
and 2018) emissions inventory showing attainment of the national ambient
air quality standard (NAAQS).  This inventory took into account multiple
factors such as; growth rates, implementation of programs throughout the
area, and the level of emissions sufficient to achieve the 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.  All data and evidence is present for this action.  	

X



6. Evidence, where necessary, that emission limitations are based on
continuous emission reduction technology.	

6.  N/A   	

X



7. Evidence that the plan contains emission limitations, work practice
standards and recordkeeping/reporting requirements, where necessary, to
ensure emission levels.	

7.  Evidence is shown that PADEP will do periodic emissions inventory
updates and analysis.  Pennsylvania will evaluate Vehicle Miles Traveled
data and emissions reported from stationary sources to track attainment
and maintenance.  	

X



8. Compliance/enforcement strategies, including how compliance will be
determined in practice.	

8.  Contingency measures will be implemented if the Erie Area violates
or exceeds the NOx and VOC regional emissions budget.  These measures
are meant to bring the area back to attainment of the 8-hour ozone
standard. 	

X



9. Special economic and technological justifications required by any
applicable EPA policies.	

9.  N/A	

X



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.  Maintenance Plan was submitted to EPA Region III on April 24, 2007.
 This plan demonstrates maintenance for 2004-2018.  	

X



