UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	December 16, 2009

SUBJECT:	    Technical Support Document - Delaware; Reasonable Further
Progress Plan, 

	                   2002 Base Year Emissions Inventory, Reasonably
Available Control Measures, Contingency Measures, and Transportation
Conformity Budgets for the Delaware Portion of the Philadelphia 1997
8-Hour Ozone Moderate Nonattainment Area

			/s/

FROM:	Rose Quinto, Environmental Engineer

Office of Air Program Planning 

TO:		File

			/s/

THRU: 	Cristina Fernandez, Associate Director

		Office of Air Program Planning

This document provides a technical review of a revision to the Delaware
State Implementation Plan (SIP) submitted by the Delaware Department of
Natural Resources and Environmental Control (DNREC) on June 13, 2007. 
This SIP revision addresses emissions inventory, reasonably available
control measures (RACM), contingency measures, and reasonable further
progress (RFP) requirements for the 1997 8-hour ozone national ambient
air quality standard (NAAQS) for the Delaware portion of the
Philadelphia moderate nonattainment area.  The SIP revision also
establishes a motor vehicle emissions budget (MVEB) for 2008.

A.  BACKGROUND

General Requirements

Section 182 of the Clean Air Act (CAA) and the Environmental Protection
Agency’s (EPA’s) 1997 8-hour ozone regulations (40 CFR 51.910)
require each moderate and above 

8-hour ozone nonattainment area to submit an emissions inventory and RFP
SIP revision that describes how the area will achieve actual emissions
reductions of volatile organic compounds (VOC) and nitrogen oxides (NOx)
from a baseline emissions inventory.  An emissions inventory is an
estimation of actual emissions of air pollutants in an area.  The
emissions inventory for an ozone nonattainment area contains VOC and NOx
emissions, which are precursors to ozone formation.  In this case, the
baseline emissions inventory is 2002.

Pursuant to section 172(c)(1) of the CAA, States are required to submit
plans for nonattainment areas that provide for the implement of all
reasonably available control measures (RACM) as expeditiously as
practicable.  Specifically, section 172(c)(1) states the following:
‘‘Such plan provisions shall provide for the implementation of all
reasonably available control measures as expeditiously as practicable
(including such reductions in emissions from existing sources in the
area as may be obtained through the adoption, at a minimum, of
reasonably available control technology) and shall provide for
attainment of the national primary ambient air quality standards.’’ 
Control measures that would advance the attainment date are considered
RACM and must be included in the SIP.  RACM are necessary to ensure that
the attainment date is achieved ‘‘as expeditious as
practicable.’’ 

Phase 1 of the 8-hour ozone implementation rule, published on April 30,
2004 (69 FR 23951), set out criteria for classifying nonattainment areas
under the 1997 8-hour ozone standard. The Phase 1 rule also addressed
revocation of the 1-hour NAAQS; how anti-backsliding principles will
ensure continued progress toward attainment of the 8-hour ozone NAAQS;
attainment dates; and the timing of emissions reductions needed for
attainment.  On November 29, 2005, EPA published the Phase 2 final rule
for implementation of the 8-hour standard.  The Phase 2 rule addressed
the RFP control and planning obligations as they apply to areas
designated nonattainment for the 1997 8-hour ozone NAAQS (70 FR 71612). 
The Phase 2 final rule was revised on June 8, 2007 (72 FR 31727).  Among
other things, the Phase 1 and 2 rules outline the SIP requirements and
deadlines for various requirements in areas designated as moderate
nonattainment.  The rules set a due date of June 15, 2007 for the
required base year emission inventory, RFP plan, modeling and attainment
demonstration, RACM, MVEB, and contingency measures (40 CFR 51.908(a),
(c)).

Section 182(b)(1) of the CAA and EPA’s 1997 8-hour ozone
implementation rule (40 CFR 51.910) require each 8-hour ozone
nonattainment area designated moderate and above to submit for review
and approval into its SIP an emissions inventory and RFP plan that
describes how the area will achieve actual emissions reductions of VOC
and NOx from a baseline emissions inventory.  For a moderate 8-hour
ozone nonattainment area with an attainment date more than 5 years after
designation, a 15 percent RFP reduction in ozone precursor emissions is
required within 6 years (2002-2008).  For a moderate area with an
approved 15 percent rate-of-progress (ROP) plan under the 1-hour
standard, States can use reductions from VOC or NOx or a combination of
either.  For a moderate area without an approved ROP plan, a 15%
reduction in VOC is required.  These VOC reductions can be obtained from
the part of the area with an approved 1-hour ROP.  Table 1 outlines
these requirements.

Table 1.  RFP Requirements for a Moderate 8-Hour Ozone Nonattainment
with an Attainment Date More than 5 Years after Designation

Area Portion	Requirement	40 CFR Reference

Portion with approved 15% VOC ROP plan	15% VOC and/or NOx reductions 

(2002 – 2008)	51.910(a)(1)(iii)(B)(2) & 51.910(b)(2)(b)(ii)

Portion without approved 15% VOC ROP plan                               
    	15% VOC reductions (2002 -2008).  The reductions may come from
anywhere within the 8-hour nonattainment area.	51.910(a)(1)(iii)(B)(1)



In addition, RFP plans must include contingency measures, which are
additional controls that would be implemented if the area fails to make
reasonable further progress.  (See CAA section 172(c)(9)). 
Implementation of these measures would provide additional emissions
reductions of up to 3 percent of the adjusted base year inventory (or
lesser percentage that will make up the identified shortfall).  RFP
plans must also include a MVEB, which is the allowable on-road mobile
emission an area can produce and continue to demonstrate RFP.  (See 40
CFR 93).

The State of Delaware

	In 1997, EPA revised the health-based NAAQS for ozone, setting it at
0.08 parts per million (ppm) averaged over an 8-hour time frame.  EPA
set the 8-hour ozone standard based on scientific evidence demonstrating
that ozone causes adverse health effects at lower ozone concentrations
and over longer periods of time, than was understood when the
pre-existing 

1-hour ozone standard was set.  EPA determined that the 8-hour standard
would be more protective of human health, especially children and adults
who are active outdoors, and individuals with a pre-existing respiratory
disease, such as asthma.

On April 30, 2004 (69 FR 23951), EPA finalized its
attainment/nonattainment designations for areas across the country with
respect to the 8-hour ozone standard.  These actions became effective on
June 15, 2004.  Among those nonattainment areas is the
Philadelphia-Wilmington-Atlantic City (PA-NJ-MD-DE) moderate
nonattainment area (NAA).  This NAA includes the three counties in
Delaware, five counties in eastern Pennsylvania, one county in Maryland,
and eight counties in southern New Jersey. 	

	Pursuant to Phase 1 of the 8-hour ozone implementation rule, published
on 

April 30, 2004 (69 FR 23951), an area was classified under Subpart 2 of
the CAA based on its 

8-hour design value if that area had a 1-hour design value at or above
0.121 ppm (the lowest 

1-hour design value in Table 1 of Subpart 2).  Based on this criterion,
Delaware, as part of the Philadelphia area was classified under Subpart
2 as a moderate nonattainment area.  On November 29, 2005 (70 FR 71612),
as revised on June 7, 2007 (72 FR 31727), EPA published the Phase 2
final rule for implementation of the 8-hour standard that addressed the
RFP control and planning obligations as they apply to areas designated
nonattainment for the 1997 8-hour ozone NAAQS.  The Phase 1 and 2 rules
outline the SIP requirements and deadlines for various requirements in
areas designated as moderate nonattainment.  For such areas, reasonably
available control technology (RACT) plans were due by September 2006 (40
CFR 51.912(a)(2)). The rules further require that modeling and
attainment demonstrations, reasonable further progress plans, reasonably
available control measures, projection year emission inventories, motor
vehicle emissions budgets and contingency measures were all due by June
15, 2007 

(40 CFR 51.908(a), (c)). 

Section 182(b)(1) of the CAA and EPA’s 1997 8-hour ozone
implementation rule 

(40 CFR 51.910) require each 8-hour ozone nonattainment area designated
moderate and above to submit an emissions inventory and RFP plan, for
review and approval into its SIP, that describes how the area will
achieve actual emissions reductions of VOC and NOx from a baseline
emissions inventory.

B.  STATE SUBMITTAL

I.  Base Year Emissions Inventory 

An emissions inventory is a comprehensive, accurate, current inventory
of actual emissions from all sources and is required by section
172(c)(3) of the CAA.  For ozone nonattainment areas, the emissions
inventory needs to contain VOC and NOx emissions because these
pollutants are precursors to ozone formation.  EPA recommended 2002 as
the base year emissions inventory, and is therefore the starting point
for calculating RFP.  Delaware submitted its 2002 base year emissions
inventory on June 13, 2007.  A summary of the 2002 base year VOC and NOx
emissions inventory are included in Tables 2 and 3 in this document.

Table 2.  Delaware 2002 Base Year VOC Emissions in tons per day (tpd)

Source Sector	Kent	New Castle	Sussex	State Total

Point	0.49	          9.42	         13.35	23.26

Stationary Area 	5.75	        20.02	 7.31	33.08

Non-Road Mobile	5.17	        12.24	 9.36	26.77

On-Road Mobile	5.45	        16.98	 9.95	32.38

Total Emissions	      16.86	        58.66	         39.97	       115.49



Table 3.  Delaware 2002 Base Year NOx Emissions in tpd

Source Sector	Kent	New Castle	Sussex	State Total

Point	 5.06	44.09	24.95	74.10

Stationary Area 	 0.45	  1.95	  0.77	  3.17

Non-Road Mobile	      15.02	24.62	13.15	52.79

On-Road Mobile	      13.97	36.56	18.50	69.03

Total Emissions	      34.50	        107.22	          57.37	       199.09



II.  Adjusted Base Year Inventory and 2008 RFP Target Levels

The process for determining the emissions baseline from which the RFP
reductions are calculated, is described in section 182(b)(1) of the CAA
and 40 CFR 51.910.  This baseline value has been determined to be the
2002 adjusted base year inventory.  Sections 182(b)(1)(B) and (D)
require the exclusion from the base year inventory of emissions benefits
resulting from the Federal Motor Vehicle Control Program (FMVCP)
regulations promulgated by January 1, 1990, and the Reid Vapor Pressure
(RVP) regulations promulgated June 11, 1990 (55 FR 23666).  The FMVCP
and RVP emissions reductions are determined by the State using EPA’s
on-road mobile source emissions modeling software, MOBILE6.  The FMVCP
and RVP emission reductions are then removed from the base year
inventory by the State, resulting in an adjusted base year inventory. 
The emission reductions needed to satisfy the RFP requirement are then
calculated from the adjusted base year inventory.  These reductions are
then subtracted from the adjusted base year inventory to establish the
emissions target for the RFP milestone year (2008).

For moderate areas like Delaware, the CAA specifies a 15 percent
reduction in ozone precursor emissions over an initial 6-year period. 
In the Phase 2 rule, EPA interpreted this requirement for areas that
were also designated nonattainment and classified as moderate or higher
for the 1-hour ozone standard.  In the Phase 2 rule, EPA provided that
an area classified as moderate or higher that has the same boundaries as
an area, or is entirely composed of several areas or portions of areas,
for which EPA fully approved a 15 percent plan for the 1-hour NAAQS, is
considered to have met the requirements of section 182(b)(1) of the CAA
for the 

8-hour NAAQS.  In this situation, a moderate nonattainment area is
subject to RFP under section 172(c)(2) of the CAA and shall submit, no
later than 3 years after designation for the 8-hour NAAQS, a SIP
revision that meets the requirements of 40 CFR 51.910(b)(2).  The RFP
SIP revision must provide for a 15 percent emission reduction (either
NOx and/or VOC) accounting for any growth that occurs during the 6-year
period following the baseline emissions inventory year, that is,
2002-2008.  The sections 182 and 172 requirements differ in that section
182(b)(1) specifies that it must be a 15 percent VOC reduction, where
section 172(c)(2) provides that the 15 percent reduction can be either a
VOC and/or NOx reduction.

	According to EPA’s Phase 2 Implementation Rule (70 FR 71612),
Delaware must achieve 15 percent VOC emission reduction in Sussex County
from its 2002 baseline level, and 15 percent VOC and/or NOx emission
reduction in Kent and New Castle Counties from their combined 2002
baseline level before the end of 2008. 

According to section 182(b)(1)(D) of the CAA, emission reductions that
resulted from the FMVCP and RVP rules promulgated prior to 1990 are not
creditable for achieving RFP emission reductions.  Therefore, the 2002
base year inventory is adjusted by subtracting the VOC and NOX emission
reductions that are expected to occur between 2002 and the future
milestone years due to the FMVCP and RVP rules.  The FMVCP/RVP VOC and
NOx emission reductions that are expected between 2002 and 2008 were
determined using EPA’s MOBILE6.2 model.  The input and output files of
the MOBILE6.2 runs for the adjustments, the emission factors generated,
and relevant calculations for emission projections are found in Appendix
4-1 of the Delaware SIP submittal.  The adjustments are presented in
Table 4 for Sussex County and Table 5 for Kent and New Castle Counties.

Table 4.  Mobile Source FMVCP/RVP Adjustments for Sussex County in tpd

Adjusted On-Road Mobile Source Emissions	VOC	NOx	Note

Adjusted for 2002	16.66	20.24	A

Adjusted for 2008	15.51	18.81	B2008

Mobile Source Adjustments for 2002 Baseline



	 2002-2008	  1.15	  1.42	C2008 = A – B2008



Table 5.  Mobile Source FMVCP/RVP Adjustments for Kent & New Castle
Counties in tpd

Adjusted On-Road Mobile Source Emissions	VOC	NOx	Note

Adjusted for 2002	42.16	56.02	a

Adjusted for 2008	39.18	51.64	b2008

Mobile Source Adjustments for 2002 Baseline



	2002-2008	  2.98	  4.38	c2008 = a – b2008



	The mobile source adjustments in Tables 4 and 5 are the non-creditable
emission reductions due to the pre-1990 FMVCP and RVP rules. 
Subtracting these adjustments from the 2002 base year emissions
inventory (i.e., the State total emissions in Tables 2 and 3) will give
the 2002 adjusted base year emissions inventory relative to the subject
milestone year, as presented in Table 6 for Sussex County and Table 7
for Kent and New Castle Counties.

Table 6.  The 2002 Adjusted Base Year Emissions Inventory for Sussex
County in tpd

	VOC	NOx	Note

2002 Base Year Emissions Inventory	39.97	57.37	E





	Mobile Source Adjustments for 2002-2008	  1.15	  1.42	C2008





	2002 Adjusted Baseline Relative to 2008	38.82	55.95	F2008 = E – C2008



Table 7.  The 2002 Adjusted Base Year Emissions Inventory for Kent & New
Castle Counties in tpd

	VOC	NOx	Note

2002 Base Year Emissions Inventory	75.52	141.72	e





	Mobile Source Adjustments for 2002-2008	  2.98	    4.38	c2008





	2002 Adjusted Baseline Relative to 2008	72.54 	137.34	f2008 = e –
c2008



	By the end of 2008, Delaware is required to reduce 15 percent in its
2002 adjusted base year emissions inventory.  According to the Phase 2
rule (70 FR 71612), Sussex County must achieve this 15 percent reduction
in its VOC emission, since it did not have a 15 percent VOC ROP plan
approved by EPA under the 1-hour ozone standard.  For Kent and New
Castle Counties, their 15 percent emission reductions can be achieved
from VOC emissions and/or from NOx emissions.  

	The 15 percent VOC emission reduction and emission target in 2008 in
Sussex County are calculated as follows:

		Sussex 2002 adjusted VOC baseline relative to 2008 is 38.82 tpd.

		Required 15 percent emission reduction:  38.82 x 15% = 5.82 tpd.

		2008 VOC emission target:  38.83 – 5.82 = 33.00 tpd.

	The 15 percent VOC emission reduction and emission target in 2008 in
Kent and New Castle Counties are calculated as follows:

		Kent/New Castle 2002 adjusted VOC baseline relative to 2008 is 72.54
tpd.

		Required 15 percent emission reduction:  72.54 x 15% = 10.88 tpd.

		2008 VOC emission target:  72.54 – 10.88 = 61.66 tpd.

III.  Control Measures and Emission Reductions for RFP

	The only post-2002 point source VOC control in Sussex County is
Regulation No. 24, Section 46, Control of Crude Oil Lightering
Operations.  Since there were no new VOC controls for point sources,
non-point source sector, and non-road mobile source sector for VOC
emissions between 2008 and 2009, Delaware’s 2008 emission reductions
and projections are estimated by interpolating the 2002 base year
emissions and the 2009 projections.  Kent and New Castle Counties
applied for and obtained total VOC and NOx emission reductions from
facility/unit shutdown or modification.  The 2008 on-road mobile source
VOC emissions were projected using EPA’s MOBILE6.2 for obtaining
factors and the Peninsula Travel Demand Model (PTDM) for predicting
future vehicle miles traveled (VMT).  Tables 8 and 9 summarize the total
2008 VOC emission projection for the RFP requirements for Sussex County,
and Kent and New Castle Counties, respectively.

Table 8.  Sussex County Total VOC Emission Projection in tpd

Point Source Sector	10.71

Area Source Sector	  6.32

Non-Road Mobile Sector	  8.01

On-Road Mobile Sector	  7.09

Total 2008 Emission Projection	32.13



	The total VOC emission projection meets the 2008 emission target under
the 15 percent RFP requirements (33.00 tpd).  Therefore, the 2008 RFP in
Sussex County is demonstrated.

Table 9.  Kent & New Castle Counties Total VOC Emission Projection in
tpd

Point Source Sector	10.51

Area Source Sector	21.64

Non-Road Mobile Sector	13.81

On-Road Mobile Sector	14.75

Total 2008 Emission Projection	60.71



	The total VOC emission projection meets the 2008 emission target under
the 15 percent RFP requirements (61.66 tpd).  Therefore, the 2008 RFP in
Kent and New Castle Counties is demonstrated.

IV.  Contingency Measures

	The CAA requires States with nonattainment areas to implement specific
control measures if the area fails to make RFP (CAA section 172(c)(9)). 
This CAA provision is a requirement for States with moderate and above
ozone nonattainment areas to include sufficient contingency measures in
their RFP so that, upon implementation of such measures, additional
emission reductions of at least 3 percent of the adjusted 2002 baseline
emissions (or a lesser percentage that will make up the identified
shortfall) would be achieved in the year after the failure has been
identified.  Under the same provision of the CAA, EPA also requires that
the contingency measures must be fully adopted control measures or
rules, so that upon failure to meet milestone requirements, the
contingency measures can be implemented without any further rulemaking
activities by the States and/or EPA.  For more information on
contingency measures, see the April 16, 1992 General Preamble (57 FR
13512) and the November 29, 2005 Phase 2 

8-hour ozone implementation rule (70 FR 71612).

	To meet the requirements for contingency emission reductions, EPA
allows States to use NOx emission reductions to substitute for VOC
emission reductions in their contingency plans.  The condition set forth
by EPA for NOx substitution is that States must achieve a minimum of 0.3
VOC reductions of the total 3 percent contingency reduction, and the
remaining 2.7 percent reduction can be achieved through NOx emission
controls.  Delaware included both VOC and NOx emission controls as
contingency measures in this 8-hour ozone RFP.  

	

	Based on the CAA and EPA requirements on contingency measures, the
contingency VOC reduction for Delaware for the 2008 milestone year is as
follows:

	The 2002 VOC baseline (statewide) adjusted to 2008 (see Tables 6 and 7
in this document) is 111.36 tpd, therefore, contingency VOC emission
reduction in 2008 is 111.36 x 3 

percent = 3.34 tpd.

	Analysis in Chapter 5.5, page 29 of the Delaware SIP, indicates that
the three counties in Delaware will have a VOC emission reduction
surplus of 1.82 tpd in 2008 [i.e., (33.00 + 61.66) – (32.13 + 60.71) =
(94.66 – 92.84) = 1.82].  Therefore there is 3.34 – 1.82 = 1.52 tpd
contingency VOC reduction shortfall in 2008. 

	Delaware’s 2002 VOC-to-NOx baseline (with respect to 2008) ratio is
(38.82 + 72.54): (55.95 + 137.34) = 111.36:193.29 = 1:1.74 (Section 4,
Tables 4-3 and 4-4 in the Delaware SIP).  Therefore, the contingency VOC
reduction shortfall is equivalent to 1.52 x 1.74 = 2.64 tpd NOx
reduction shortfall.                                                    
                                                                        
    

	Delaware has implemented numerous controls leading to NOx reductions in
2008 that are greater than the identified 2.64 contingency shortfall
(see subsections 5.4 and 6.4 of the Delaware SIP).  Therefore, there is
no need to specify additional contingency measures for the 2008
milestone year.

V.  RACM Analysis and Determination

	

	Section 172(c)(1) of the CAA and 40 CFR 51.912(d) impose a RACM
requirement for areas designated nonattainment for the 8-hour NAAQS. 
Delaware must demonstrate that it has adopted all RACM controls
necessary to move toward attainment as expeditiously as practicable and
to meet all RFP requirements.

	

	Section III of this document, demonstrates that the RFP requirements
for Delaware have been met.  Control measures under RACT, constitute a
major group of RACM control measures for stationary sources.  To meet
the CAA’s RACT requirements under the 8-hour ozone standard, Delaware
submitted a RACT SIP revision on October 2, 2006, which certifies that
all relevant RACT controls have been implemented in Delaware for
attaining the 8-hour ozone standard.  EPA approved Delaware’s 8-hour
RACT SIP revision on July 23, 2008 (73 FR 42681).  On May 2, 2007,
Delaware submitted a new VOC control from crude oil lightering
operations.  EPA approved this rule on September 13, 2007 (72 FR 52285).

	In addition to those RACT control measures, Delaware adopted a number
of other VOC and NOx RACM measures.  A summary of the other control
measures that Delaware adopted are listed in Table 10.

Table 10. Summary of Other Control Measures

Control Measures	Date submitted to EPA	Approval Date

Regulation 1113 – Tightening of Delaware’s Open Burning Regulation
05/02/07	09/20/07 (72 FR 53686)

Regulation 1144 – Control of Stationary Generator Emissions	11/01/07
04/29/08 (73 FR 23101)

Regulation 1148 – Control of Stationary Combustion Turbine Emissions
09/11/07	11/10/08 (73 FR 66554)

Regulation 1145 – Restrictions on Excessive Idling of Heavy Duty
Vehicles



Brandywine School Districts Clean School Bus USA grant



Voluntary and mandatory Ozone Action Day initiatives





	There are no additional RACM measures or group of RACM measures that
Delaware could adopt to advance the attainment date from 2009 to 2008,
therefore Delaware has met the RACM requirements of the CAA.

	

VI.  Transportation Conformity Budgets

 	Section 176 of the CAA requires that highway transportation activities
in ozone nonattainment areas must: (1) establish in their SIP, mobile
source VOC and NOx emission budgets for each of the milestone years up
to the attainment year and submit the mobile budgets to EPA for
approval; (2) upon adequacy determination or approval of EPA, States
must conduct transportation conformity analysis for their Transportation
Improvement Programs (TIPs) and long range transportation plans to
ensure highway vehicle emissions will not exceed relevant mobile
budgets; and (3) failure of demonstrating such transportation conformity
lapses resulting in freezing of Federal highway funds and all Federal
highway projects in the lapsed area. 

	The mobile emission budgets for 2008 RFP milestone are based on the
projected 2008 mobile source emissions, accounting for all relevant
mobile source controls including all Federal controls and Delaware
specific controls.  The 2008 mobile emissions are projected using
EPA’s MOBILE6.2 for obtaining emission factors and the “Peninsula
Travel Demand Model” for predicting future vehicle miles traveled
(VMT).  Table 11 is a summary of the 2008 VOC and NOx motor vehicle
emissions budgets for the three counties in Delaware. 

Table 11.  Motor Vehicle Emission Budgets for 2008

County	FIPS	2008 Emissions (tpd)



VOC	NOx

Kent	10001	  4.14	  9.68

New Castle	10003	10.61	21.35

Sussex	10005	  7.09	12.86

State Total

21.84	43.89



                On March 21, 2008, EPA posted the availability of these
budgets for Delaware on EPA’s conformity website for the purpose of
soliciting public comments.  The public comment period closed on April
21, 2008 and no comments were received.  On December 19, 2008 (73 FR
77682), EPA published a notice of adequacy for the Delaware 2008 RFP
MVEBs.  In this notice, EPA found that Delaware’s RFP MVEBs are
adequate for transportation conformity purposes.  As a result of EPA’s
finding, Delaware shall use the MVEBs from the June 13, 2007 RFP plan
for future conformity determinations for the 8-hour standard.

                   

D.  SUMMARY AND RECOMMENDATIONS:

	DNREC has used acceptable techniques and methodologies to develop the
base year and milestone year inventories, the emission reductions for
the milestone year, and the effects of non-creditable reductions and
pre-1990 CAA rule corrections.  VOC and NOx emissions for the period
between 2002 and 2008 were well below the target level for 2008, and
emissions in 2008 will be below the rate-of-progress target level. 
Therefore, we recommend approval of the Delaware RFP plan, contingency
measures, RACM analysis, and the 2002 base year inventory.  In addition,
we recommend the approval of the MVEBs which are based on the RFP plan. 


 PAGE   

 PAGE  3 

