UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029



DATE:

	April 14, 2008



SUBJECT:

	Technical Support Document for the Crawford County, Pennsylvania 8-hour
Ozone Maintenance Plan and Base Year 2002 Inventory	 	 

 FROM:

	Gregory Becoat, Environmental Scientist /s/

Air Quality Planning Branch (3AP21)

TO:

REVIEWED BY:	SIP Docket File

               /s/                        

Cristina Fernandez, Branch Chief

Air Quality Planning Branch (3AP21)



I.	Affected Regulation

This revision to the Commonwealth of Pennsylvania State Implementation
Plan (SIP) applies to the Maintenance Plan and 2002 Base-Year Inventory
for Crawford County, Pennsylvania.

II.	 Background

Ground-level ozone is not emitted directly by sources. Rather,
emissions of volatile organic compounds (VOCs) and nitrogen oxides (NOx)
react in the presence of sunlight to form ground-level ozone.  The air
pollutants, VOCs and NOx, are referred to as precursors of ozone. The
Clean Air Act (CAA) establishes a process for air quality management
through the attainment and maintenance of the NAAQS.

In 1979, EPA established the National Ambient Air Quality Standard
(NAAQS) for ozone at 0.12 parts per million (ppm) averaged over one
hour.  Crawford County was designated as nonattainment for this
standard. On November 15, 1990, the CAA was amended and Section
107(d)(1)(C) provided that designations occurred by operation of law for
areas that had been designated nonattainment before enactment of the
amendments.  At this point, Crawford County was classified as an
incomplete data 1-hour ozone nonattainment area.

  SEQ CHAPTER \h \r 1 In 1997, EPA revised the NAAQS and established a
new standard of 0.08 ppm averaged over eight hours.  In 2002, EPA began
the process to designate areas under the 8-hour ozone standard.  In
2004, Crawford County, in the Commonwealth of Pennsylvania, was
designated as an unclassifiable/attainment area for the 8-hour ozone
standard based on air quality data from 2001-2003.  See 40 CFR 81.339. 

The ozone monitor sited closest to Crawford County is located in Erie
County.  Air quality data from 2004-2006 shows a 2006 design value of
0.079 ppm; therefore, Crawford County remains in attainment with the
8-hour ozone NAAQS.

As of April 30, 2004 (69 FR 23951), EPA specified that even though the
1-hour ozone standard had been revoked, the 1-hour ozone NAAQS
designations and classification statuses were retained as of the
effective date of designation for the 8-hour NAAQS, for purposes of
anti-backsliding regulations (40 CFR 51.905).  Anti-backsliding
regulations apply even after revocation of the 1-hour ozone NAAQS.  

EPA’s Phase 1 Implementation Rule (69 FR 23951, 23998 (April 30, 2004)
for the 8-hour ozone standard requires at 40 CFR 51.905(a)(iii) that
states submit an 8-hour maintenance plan to EPA for those 1-hour
nonattainment areas that had not been previously redesignated to
attainment/maintenance for the 1-hour standard.  The maintenance plan
needs to demonstrate that the area will maintain the standard for 10
years after designation in accordance with section 110(a)(1) of the CAA.

On December 22, 2006, the U.S. Court of Appeals for the District of
Columbia Circuit vacated EPA’s Phase 1 Implementation Rule for the
8-hour Ozone Standard (69 FR 23951, April 30, 2004).  On June 8, 2007,
in South Coast Air Quality Management Dist. v. EPA, Docket No. 04-1201,
in response to several petitions for rehearing, the DC Circuit clarified
that the Phase 1 Rule was vacated only with regard to those parts of the
rule that had been successfully challenged.  Therefore, the Phase 1 Rule
provisions related to classifications for areas currently classified
under subpart 2 of Title I, Part D of the CAA.  The June 8 decision
reaffirmed the December 22, 2006 decision that EPA had improperly failed
to retain measures required for 1-hour nonattainment areas under the
anti-backsliding provisions of the regulations.

	On December 17, 2007, EPA received a request from the Pennsylvania
Department of Environmental Protection (PADEP) for approval under
section 110 of the CAA, a SIP revision pertaining to the Maintenance
Plan and 2002 Base-Year Inventory for Crawford County, Pennsylvania. 
This plan demonstrates how the Commonwealth of Pennsylvania intends to
maintain the 8-hour ozone NAAQS.  This maintenance plan contains a
base-year inventory for 2002 and demonstrates that emissions will not be
greater than the base year in 2009 and 2018.  The plan indicates how
maintenance plan progress will be tracked and identifies measures that
would be available to promptly correct any NAAQS violation.  The
Commonwealth of Pennsylvania’s SIP submittal meets the CAA
requirements for SIP submittals under section 110(a)(1).

What are the components of a section 110(a)(1) 8-hour ozone maintenance
plan?

	On May 20, 2005, EPA issued guidance that applies to areas that are
designated as unclassifiable/attainment for the 8-hour ozone standard. 
The purpose of this guidance is to address the maintenance requirements
in section 110(a)(1) of the CAA, and assist the states in the
development of a SIP.  The components from EPA’s guidance include:

1.  Attainment Inventory – The attainment inventory should be based on
actual “typical summer day” emissions of volatile organic compounds
(VOCs) and nitrogen oxides (NOx) for a 10-year maintenance period.   
For purposes of an attainment emissions inventory, the state must choose
any of the three years on which the 8-hour ozone attainment designation
was based.

2.  Maintenance Demonstration – The area must demonstrate how it will
remain in compliance with the 8-hour ozone standard for a period of 10
years following the effective date of designation as
unclassifiable/attainment.  If the effective date of the areas’
designation for the 8-hour NAAQS was June 15, 2004, the maintenance plan
must project attainment for 2014 or beyond.

3.  Ambient Air Quality Monitoring - The state should continue to
operate air quality monitors in accordance with 40 CFR Part 58 to verify
maintenance of the 8-hour ozone standard.

4.  Contingency Plan – The state must develop measures so that in the
event of a violation of the 8-hour ozone NAAQS, the measures can be
implemented as expeditiously as practicable after the violation.

5.  Verification of Continued Attainment – The state must indicate how
it intends on tracking the progress of the maintenance plan.  This is
necessary because emissions projections for the maintenance
demonstration depend on assumptions of point, area, and mobile source
growth.

B.  How has the state addressed the components of a section 110(a)(1)
8-hour ozone maintenance plan?

1.  Attainment Inventory – PADEP has provided a comprehensive and
current emissions inventory for VOCs and NOx.  PADEP included the 2002
Base-Year Inventory in order to project emissions.  Since the effective
year of the 8-hour ozone initial designation was 2004, PADEP is required
to project emissions for 10 years or beyond from the effective date of
initial designation.  Consequently, PADEP has developed an emissions
inventory for ozone precursors for the year 2002, 2009, and 2018.  In
the maintenance plan, PADEP included information on the manmade sources
of ozone precursors, VOCs and NOx (e.g., “Stationary sources,”
“Stationary area sources,” “Highway vehicles,” and “Nonroad
sources”).  The tables below show the VOCs and NOx emissions summary
for 2002, 2009, and 2018.  The Technical Appendices submitted with
Pennsylvania’s maintenance plan contain more detailed information for
each sector on the emissions inventories.

     

VOC Emissions Summary:  2002, 2009 and 2018

(tons per summer day) 

Major Source Category	2002	2009	2018

Stationary Point Sources	0.50	0.63	0.85

Stationary Area Sources	5.44	5.25	5.79

Highway Vehicles	4.51	2.42	1.39

Nonroad Sources	5.87	4.63	3.12

TOTAL	16.32	12.93	11.15



NOx Emissions Summary:  2002, 2009 and 2018

(tons per summer day)

Major Source Category	2002	2009	2018

Stationary Point Sources	7.87	9.59	11.96

Stationary Area Sources	0.74	0.79	0.83

Highway Vehicles	8.44	4.61	1.84

Nonroad Sources	3.05	2.51	1.80

TOTAL	20.10	17.50	16.43



To develop the VOC and NOx base-year emission inventories, PADEP used
the approaches and sources of data listed below.  PADEP included point,
area, mobile on-road, and mobile non-road sources for a base-year of
2002.  More information on the compilation of the 2002 base-year
emissions inventory can be found in the Appendices submitted by the
Commonwealth of Pennsylvania.

Point Source Emissions

Pennsylvania requires larger facilities to submit production figures and
emission calculations every year. The Factor Information Retrieval
(FIRE) Data System and EPA’s publication series AP-42 are used so that
throughput data can be multiplied by emission factors.  This process is
based on Source Classification Codes (SCC). Each process has at least
one assigned SCC code.  If the larger facilities provide more accurate
emission data based upon other factors, this data supersedes those
calculated using SCC codes.  

Stationary Area Source Emissions

Stationary area sources includes industrial/commercial/residential
sources too small and/or numerous to be inventoried individually. 
Examples include solvent use, waste disposal, or home heating.  The area
source values are adjusted to remove any double counting whenever there
is overlap between stationary point sources and stationary area sources.
 Pennsylvania developed emissions from area sources using emission
factors and SCC codes in a method similar to that used for stationary
point source emissions.  Emission factors may also be derived from
research and guidance documents if those documents are more accurate
than FIRE and AP-42 factors.  Throughput estimates are derived from
numerous data sources (e.g., county-level activity data, by apportioning
national or statewide activity data to counties, from census numbers,
and from county employee numbers).  More specific information on the
procedure used for each industry type is contained in Pennsylvania 2002
Area Source Criteria Air Pollutant Emission Estimation Methods, (E.H.
Pechan & Associates, Inc., February 2004) which is contained in the
Technical Appendix submitted by the Commonwealth of Pennsylvania.  The
factors used for the temporal allocation of projections from the 2002
baseline inventory were provided by the Mid-Atlantic Regional Air
Management Association (MARAMA), which is performing air quality
modeling for the Northeast and Mid-Atlantic states.

Highway Vehicle Sources

Highway vehicle sources include passenger cars, light-duty trucks, other
trucks, buses, and motorcycles.  Pennsylvania uses MOBILE6.2, the
current EPA-approved highway vehicle emission model, to estimate highway
vehicle emissions.  Crawford County projected highway vehicle emissions
were estimated using MOBILE6.2 and PENNDOT estimates of vehicle miles
traveled (VMT) by vehicle type and roadway type.  More information on
highway methods is available in Pennsylvania’s submitted Technical
Appendices (Appendix C). The estimate used information specific to
Crawford County where appropriate. 

Nonroad Sources

Nonroad sources covers a diverse collection of engines, including
outdoor power equipment, recreational vehicles, farm and construction
machinery, lawn and garden equipment, industrial equipment, recreational
marine, commercial marine vessels, locomotives, ships, aircraft, and
many other applications.  The 2002 emissions for the majority of nonroad
emission source categories were estimated using the EPA NONROAD2005
model, which estimates emissions for diesel, gasoline, liquefied
petroleum gasoline, and compressed natural gas-fueled nonroad equipment
types.  NONROAD does not estimate emissions from aircraft or
locomotives.  For 2002 locomotive emissions, PADEP projected emissions
from a 1999 survey using national fuel consumption information and EPA
emission and conversion factors.  There are no commercial aircraft
operations in Crawford County.  For aircraft emissions, PADEP used small
airport operation statistics from   HYPERLINK "http://www.airnav.com" 
www.airnav.com , and Emissions and Dispersion Modeling System.

2.  Maintenance Demonstration – As the tables above indicate, the
total future emissions are projected to decrease during the 10-year
maintenance period. However, it is important to note that the formation
of ozone is dependent on a number of variables, which cannot be
estimated by emissions growth and reduction calculations alone.  Other
variables include, weather and the transport of ozone precursors from
areas outside of the Commonwealth of Pennsylvania.  The following
Federal and state measures will be in place to ensure emissions during
the maintenance period are equal or less than the emissions in the
attainment year:

A.  Stationary Point Sources

Clean Air Interstate Rule (CAIR)

The Federal CAIR regulations (70 FR 25162, May 12, 2005) will transition
from the NOx SIP Call electric generating unit regulations in 2009 and
continue to ensure that large electric generation facilities upwind of
the area will maintain background emissions at or below 2002 levels
while any new facilities locating within the area will be required to
obtain both offsets and allowances that will ensure ambient equivalence
with regard to ozone production potential.  Pennsylvania and other
nearby states are required to adopt a regulation implementing the
requirements of the CAIR or its equivalent.  On April 28, 2006, EPA
promulgated Federal Implementation Plans (FIPs) to reduce the interstate
transport of NOx and sulfur dioxides that contribute significantly to
nonattainment and interferes with maintenance of the 8-hour ozone and
PM2.5 NAAQS.  The electric generating units (EGUs) in the CAIR-covered
States will be regulated under the FIPs until revisions to SIPs for the
implementation of the CAIR requirements are approved by EPA.  

 

Interstate Pollution Transport Reduction 

Pennsylvania and other covered states adopted NOx control regulations
for large industrial boilers and internal combustion engines, EGUs, and
cement plants. The regulation covering industrial boilers and EGUs
required emission reductions to commence May 1, 2003, while the
regulation covering large internal combustion engines and cement plants
required emission reductions to commence May 1, 2005.  

 

B.  Stationary Area Sources

Portable Fuel Containers

Pennsylvania adopted a portable fuel container regulation, 25 Pa Code
Chapter 130, Subchapter A, to address VOC loss resulting from permeation
through portable gasoline containers, evaporative loss through container
openings, and from spillage during the filling of small tanks on
machines such as lawn mowers, chain saws, jet skis.  The regulation
requires that portable fuel containers manufactured after January 1,
2003 for sale in Pennsylvania meet certain requirements.  PADEP
predicted that the portable fuel container regulation would be
completely phased in over a 10-year period.  Emission reduction
estimates for the program reflect this phased-in replacement of the
containers. EPA received Pennsylvania’s regulation as a SIP revision
on March 26, 2003 and approved on December 8, 2004 (69 FR 70893).  

Consumer Products

The Consumer Products Rule, 25 Pa Code Chapter 130, Subchapter B,
applies statewide to any person who sells, supplies, offers for sale, or
manufactures certain consumer products on or after January 1, 2005, for
use in the Commonwealth of Pennsylvania.  Pennsylvania’s regulation
includes general provisions, VOC standards, innovative products,
administrative and reporting requirements, test methods, and provisions
for exemptions, variances, and alternative control plans for consumer
products.  Pennsylvania’s regulation was submitted to EPA as a SIP
revision on March 26, 2003 and approved on December 8, 2004 (69 FR
70895).  

Architectural and Industrial Maintenance (AIM) Coatings

The Pennsylvania AIM Coatings regulation, 25 Pa Code Chapter 130,
Subpart C, applies statewide to any person who supplies, sells, offers
for sale, or manufactures, blends or repackages an AIM coating for use
within the Commonwealth of Pennsylvania. The regulation does not apply
to the following: (1) Any AIM coating that is sold or manufactured for
use outside the Commonwealth or for shipment to other manufacturers for
reformulation or repackaging; (2) any aerosol coating product; or (3)
any AIM coating that is sold in a container with a volume of one liter
(1.057 quarts) or less. The AIM coatings regulation sets specific VOC
content limits, in grams per liter, for AIM coatings categories with a
compliance date of January 1, 2005. Manufacturers ensure compliance with
the limits by reformulating coatings and substituting coatings with
compliant coatings that are already in the market.  The regulation
contains VOC content requirements for a wide variety of field-applied
coatings, including graphic arts coatings, lacquers, primers and stains.
 The regulation also contains provisions for a variance from the VOC
content limits, which can be issued only after public hearing and with
conditions for achieving timely compliance.  In addition, the regulation
contains administrative requirements for labeling and reporting. There
are a number of test methods that would be used to demonstrate
compliance with the AIM Coatings regulation. Some of these test methods
include those promulgated by EPA and South Coast Air Quality Management
District of California. The methods used to test coatings must be the
most current approved method at the time testing is performed.

Pennsylvania’s regulation was submitted to EPA as a SIP revision on
December 3, 2003, with a supplement submitted on October 19, 2004 and
approved on November 23, 2004 (69 FR 69080).

   

C.  Highway Vehicle Sources

Even with increases in VMT that occur from 2002 through 2018, highway
vehicle emissions of both VOC and NOx will continue to decrease.  As
more vehicles subject to cleaner new car standards replace older
vehicles subject to less stringent new vehicle standards, the fleet as a
whole emits fewer emissions, compensating for the increase in VMT.  
These decreases can be attributed to the programs described below. 

Federal Motor Vehicle Control Programs  (FMVCP) 

FMVCP are for passenger vehicles, light-duty trucks and cleaner
gasoline.  In 2009 and 2018, vehicles manufactured to meet Federal
standards through Tier 0, 1, and 2 will still be in Pennsylvania’s
fleet.  Tier 1 tailpipe standards established by the CAA Amendments of
1990 include NOx and VOC limits for light-duty gasoline vehicles (LDGVs)
and light-duty gasoline trucks (LDGTs). These standards began to be
phased in starting with model year 1994.  Evaporative VOC emissions were
also reduced in gasoline-powered cars starting with model year 1998.

In 1998, under the authority of section 177 of the CAA, PADEP adopted
the Pennsylvania Clean Vehicles Program.  (28 Pa B 5873, December 5,
1998.)  This program incorporates certain California Low Emission
Vehicle (CA LEV) emission standards for passenger cars and light-duty
trucks by reference.  As required under section 177 of the CAA, these
provisions are identical to the low emission standards adopted by
California, except that the regulation does not incorporate by reference
the California zero emissions vehicle (ZEV) or emissions control
warranty systems statement provisions.

In the same rulemaking, the Commonwealth adopted the National Low
Emission Vehicle (NLEV) program as a compliance alternative to the
Pennsylvania Clean Vehicles Program.  The NLEV program became effective
in the Ozone Transport Region in 1999.  Pennsylvania’s New Motor
Vehicle Emissions Control Program regulations (25 Pa Code Subchapter
126.401-126.441) allow automobile manufacturers to comply with NLEV
instead of CA LEV program through model year 2005.  These regulations
were in effect for new motor vehicles in the baseline year, 2002, and
affect vehicles 6,000 pounds or less.

In 1999, EPA promulgated regulations more stringent than NLEV (Tier 2),
starting with the 2004 model year.  However, in order to participate in
the NLEV program, Pennsylvania was required to adopt language that
extended its “commitment” to NLEV until the 2006 model year.  
Ultimately, the NLEV program was replaced for model year 2004 and later
by the more stringent Federal “Tier 2” vehicle emissions regulations
(65 FR 6698, February 10, 2000), and vehicle manufacturers operating
under the NLEV program became subject to the Tier 2 requirements. 
Therefore, the Federal Tier 2 program governs new vehicles sold in
Pennsylvania in the attainment year, 2004.  The incorporated CA LEV
requirements are applicable in Pennsylvania for model year 2006 and each
model year thereafter.

Pennsylvania Clean Vehicle Program for passenger vehicles and light-duty
trucks and cleaner gasoline

The New Motor Vehicle Control Program which includes the Pennsylvania
Clean Vehicles Program incorporated the California Low Emission Vehicle
Program (CA LEV II) by reference.  This allows automakers to comply with
the NLEV program as an alternative to this Pennsylvania program until
model year 2006.  As amended, the program affects model year 2008 and
newer passenger cars and light-duty trucks vehicles less than 8,500 lbs
gross vehicle weight rating (36 Pa B 7424, December 9, 2006). 

Emissions for milestone years were estimated based on compliance with
the Pennsylvania Clean Vehicles Program according to the methodology
described in section 7.4.1 of the Technical Guidance on the Use of
MOBILE6.2 for Emissions Inventory Preparation published by EPA’s
Office of Transportation and Air Quality (OTAQ) in January 2002.  In
order to provide conservative estimates of emissions, Pennsylvania is
assuming in its MOBILE modeling that the Federal Tier 2 program applies
to subject vehicles sold in Pennsylvania from model year 2004 through
model year 2007 and the Pennsylvania Clean Vehicles Program applies to
subject vehicles sold in model year 2008 and beyond.

Heavy-Duty Diesel Control Programs

EPA promulgated more stringent national regulations for heavy-duty
engines and vehicles starting with model year 2004.  In addition, a
consent decree was agreed upon which required that diesel engines, made
by seven of the largest heavy-duty engine manufacturers companies,
comply with the 2004 standards in model year 2002.  Pennsylvania
includes these programs as provided in the MOBILE model. 

In 2002, Pennsylvania adopted the Heavy-Duty Diesel Emissions Control
Program for model years starting after May 2004.  The program
incorporates California standards by reference and requires model year
2005 and subsequent new heavy-duty diesel highway engines to be those
certified by California.  

EPA adopted new emission standards for heavy-duty engines and vehicles
for model year 2007 and subsequent.  For diesel engines, the standards
will be phased in from 2007 to 2010 for NOx and VOCs. For gasoline
engines, the standards will be phased in during model years 2008 and
2009.  Federal and California standards are identical for model year
2007 and beyond; the emission estimates use assumptions of the Federal
rule for these years.

 

EPA also required most highway diesel fuel to contain no more than 15
ppm of sulfur, since the fall of 2006.  Due to a temporary compliance
option, refiners may continue to produce up to 20 percent of their
highway diesel fuel at 500-ppm fuel.  Pennsylvania uses MOBILE defaults
to estimate the effects of the phase-in provision.     

Changes to Vehicle Safety Inspection Program

PennDOT amended its vehicle safety inspection program to include a
visual inspection of certain pollution control components in counties
for which a separate vehicle emissions inspection program is not
required. These regulations can be found in 67 Pa Code Chapter 175. 
Pennsylvania submitted the amended safety inspection program as a
revision to its SIP on December 1, 2003 and EPA approved the revision on
October 6, 2005 (70 FR 58313).

D.  Nonroad Sources  

EPA has adopted a series of regulations affecting new diesel-powered and
gasoline-powered nonroad engines of various sizes and applications. 
PADEP used the assumptions built into the nonroad model (NONROAD2005) to
estimate emissions for all milestone years.

EPA will also require diesel fuel used in most nonroad applications to
contain less sulfur.  The sulfur will prevent damage to the more
advanced emission control systems needed to meet the engine standard and
also reduce fine particulate emissions from diesel engines.  In 2007,
fuel sulfur levels will be limited to 500 ppm for nonroad applications
other than ocean-going marine vessels.  In 2010, fuel sulfur levels will
be reduced to the same sulfur concentration as in highway fuel, 15 ppm. 
This requirement applies in 2012 to locomotive and marine diesel fuel. 

Based on the comparison of the projected emissions and the attainment
year emissions along with the additional measures, EPA concludes that
PADEP has successfully demonstrated that the 8-hour ozone standard
should be maintained in Crawford County.

3.  Ambient Air Quality Monitoring –  PADEP commits to continue to
operate its current air quality monitor in accordance with 40 CFR Part
58, to verify the attainment status of the area, with no reductions in
the number of sites from those in the existing network unless
pre-approved by EPA.

4.  Contingency Plan – Section 110(a)(1) of the CAA requires that the
state develop a contingency plan which will ensure that any violation of
a NAAQS is promptly corrected.  The purpose of the contingency plan is
to adopt measures, outlined in the maintenance plan, in order to assure
continued attainment in the event of a violation of the 8-hour ozone
NAAQS.  The maintenance plan should identify the events that would
“trigger” the adoption and implementation of a contingency
measure(s), the contingency measure(s) that would be adopted and
implemented, and the schedule indicating the time frame by which the
state would adopt and implement the measure(s).  

The ability of Crawford County to stay in compliance with the 8-hour
ozone standard depends upon VOCs and NOx emissions in the area remaining
at or below 2002 base year inventory.  The Commonwealth’s maintenance
plan projects VOCs and NOx emissions to decrease and stay below 2002
levels through the year 2018.  The maintenance plan outlines the
procedures for adoption and implementation of contingency measures to
further reduce emissions should a violation occur.

In the Commonwealth of Pennsylvania, contingency measures would be
considered if for two consecutive years the fourth highest 8-hour ozone
concentrations at the design monitor for the Erie Area are above 84 ppb.
 If this trigger point occurs, PADEP will evaluate whether additional
local emission control measures should be implemented in Crawford County
in order to prevent a violation of the air quality standard.  PADEP will
analyze the conditions leading to the excessive ozone levels and
evaluate what measures might be most effective in correcting the
excessive ozone levels.  PADEP will also analyze the potential emissions
effect of federal, state and local measures that have been adopted but
not yet implemented at the time the excessive ozone levels occurred. 
PADEP will then begin the process of implementing any selected measures
so that in the event of a violation, the measures can be implemented as
expeditiously as practicable after the violation. Contingency measures
to be considered for Crawford County will include, but not limited to:

Non-regulatory measures:

Diesel retrofit (including replacement, repowering or alternative fuel
use) for public or private local onroad or offroad fleets. 

Idling reduction technology for Class 2 yard locomotives. 

Accelerated turnover of lawn and garden equipment, especially commercial
equipment, including promotion of electric equipment. 

Additional promotion of alternative fuel (e.g. biodiesel) for home
heating and agricultural use.

Regulatory measures:

Additional controls on consumer products

Additional controls on portable fuel containers

       In the event that additional emission reductions are necessary,
PADEP will propose and adopt additional emission reduction measures to
attain and maintain the ozone NAAQS in accordance with the requirements
of the Clean Air Act, the Air Pollution Control Act, other Pennsylvania
statutory requirements, and PADEP’s Policy for Approval and
Distribution of Regulations. 

	All measures taken were considered potential cost-effective and timely
control strategies by the regional planning organizations during their
2005-2006 ozone attainment deliberations.    The following schedule
displays the timeframe by which PADEP plans on implementing contingency
measures.

Non-regulatory measures:

Within 2 months:  Identify stakeholders for potential non-regulatory
measures.  

Within 3 months:  If funding is necessary, identify potential sources of
funding and the timeframe under which funds would be available.  In
addition to non-Title V Clean Air funds, the following programs may be
able to provide funding:

Transportation projects, Federal Congestion Mitigation and Air Quality
funds from the Federal Highway Administration, as allocated to the
Northern Tier RPO.

For projects which also have an energy efficiency co-benefit, the
Pennsylvania Energy Harvest program.

For projects which would be undertaken by small business and are
pollution prevention projects, the Small Business Advantage Grant and
Small Business Pollution Prevention Loan programs.

For projects which involve alternative fuels for vehicles/refueling
operations, the    Alternative Fuel Incentive Grant program.

For projects involving diesel emissions, federal Energy Policy Act
diesel reduction funds allocated to Pennsylvania or for which
Pennsylvania or project sponsors may apply under a competitive process.

Within 9 months:  If state loans or grants are involved, enter into
agreements with implementing organization (business, local government,
transit companies, non-profit entities, etc.).  Quantify projected
emission benefits. 

Within 12 months:  Submit revised SIP to EPA.

Within 12-24 months:  Implement strategies and projects.

Regulatory measures:

Within 1 month of triggering event:  Submit request to begin regulatory
development process.

		

Within 3 months of triggering event:  Review by Air Quality Technical
Advisory Committee (AQTAC), Citizens Advisory Council and other advisory
committees as appropriate.

Within 6 months of triggering event:  Environmental Quality Board (EQB)
meeting/action. 

Within 8 months of triggering event:  Publish in the Pennsylvania
Bulletin for comment as proposed rulemaking.  

		

Within 10 months of triggering event:  Public hearing takes place and
comment period on proposed rule closes. 

		

Within 11 months of triggering event:  House and Senate Standing
Committees and Independent Regulatory Review Commission (IRRC) comment
on proposed rule.   

Within 13 months of triggering event:  AQTAC, Citizens Advisory Council
and other committee review responses to comments and draft final
rulemaking. 

Within 16 months of triggering event:  EQB meeting/action.

		

Within 17 months of triggering event:  IRCC action on final rulemaking.

Within 18 months of triggering event:  Attorney General’s
review/action.   

Within 19 months of triggering event:  Publish in the Pennsylvania
Bulletin as final rulemaking and submit to EPA as a SIP revision.   The
regulation would become effective upon publication in the Pennsylvania
Bulletin.  

	

5.  Verification of Continued Attainment – PADEP has indicated that
the attainment status of the 8-hour ozone NAAQS for Crawford County will
be tracked by reviewing air quality at the design monitor for the Erie
Area and emissions data during the maintenance period.  PADEP also
indicated that an annual evaluation of VMT and emissions reported from
stationary sources will be performed and compared to the assumptions
about the factors used in the maintenance plan. PADEP will also evaluate
the periodic (every three years) emission inventories prepared under
EPA’s Consolidated Emission Reporting Regulation (40 CRF 51 Subpart A)
for any unanticipated increases.  Based on these evaluations, PADEP will
consider whether any further emission control measures should be
implemented. 

	

III.       Evaluation

EPA views that the five components required of Section 110(a)(1) 8-hour
ozone maintenance plan have been met.  The Commonwealth of Pennsylvania
has met the requirements to submit a Section 110(a)(1) maintenance plan
and has adequately addressed the components of a Section 110(a)(1) plan.
 Therefore, approval of the Commonwealth of Pennsylvania’s 8-hour
Ozone Maintenance Plan and 2002 Base-Year Inventory is recommended.

IV.       Conclusion

This SIP revision request satisfies all requirements for an acceptable
SIP revision.

V.    Recommended Agency Action

The SIP revision request should be approved. 

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