UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

                                                                        
                                              January 7, 2010



SUBJECT:	

Technical Support Document (TSD) - Adequacy Findings for the Motor
Vehicle Emissions Budgets in the 2009 Attainment Plan for the Delaware
Portion of the Philadelphia 1997 Fine Particulate Matter (PM2.5)
National Ambient Air Quality Standard (NAAQS) Nonattainment Area 





FROM:	          /s/

Martin T. Kotsch                    

Environmental Engineer (3AP30)	





TO:	

Administrative Record for the Adequacy Findings for the Motor Vehicle
Emissions Budgets in the 2009 Attainment Plan for the Delaware portion
of the Philadelphia 1997 PM2.5  NAAQS Nonattainment Area

	





THRU:	                   /s/

Cristina  Fernandez, Associate Director 

Office of Air Program Planning (3AP30)	





I.   Administrative Requirements for Making Adequacy Findings  

We have followed the process for determining the adequacy of the
submitted State Implementation Plan (SIP) Motor Vehicle Emissions
Budgets (MVEBs) in accordance with the procedures listed in the January
2008 Conformity Regulations contained in 40 CFR Part 93.102
(“Geographical applicability”) and 40 CFR Part 93.118(f)
(“Adequacy review process for implementation plan submissions”).  

By transmittal letter dated April 3, 2008, the State of Delaware
formally submitted a  2009 PM2.5 Attainment Demonstration Plan for the
1997 PM2.5  NAAQS (hereafter the 2009 attainment plan) with mobile
emissions budget for Nitrogen Oxides (NOx) and direct Particulate Matter
(PM) for the Delaware portion of the Philadelphia 1997 PM2.5 NAAQS
nonattainment area (hereafter, “the Delaware area”).  

Shown below in Table 1 are the budgets from the 2009 attainment plan
submittal. 

Table 1.

The Budgets of the Delaware 2009 Attainment Plan  

Plan

Submittal	

Milestone 

Year	

Mobile Vehicle Emissions Budget for NOx-Tons Per Year	

Mobile Vehicle Emissions Budget for Direct PM-Tons Per  Year

	Attainment Plan	2009	4,904.0	87.0

	

II.  Evaluation of the Adequacy of the MVEBs in the 2009 Attainment Plan
for the Delaware Portion of the Philadelphia 1997 PM2.5 NAAQS
Non-attainment Area Submitted By the Delaware Department of Natural
Resources and Environmental Control 

In this TSD, we are evaluating the MVEBs associated with the 2009
attainment plan and 2010 Contingency Plan contained in the submittals
for conformity purposes.  We are using the evaluation criteria detailed
in the Transportation Conformity Rule, 40 CFR Part 93.102(b)(2)(iv),
93.102(b)(2)(v), 93.102(b)(3) and Part 93.118(e)4 through 93.118(e)5.
The evaluation is presented in Table 2, below.

Table 2.

Adequacy of the MVEBs Contained in the 2009 Attainment Plan for the
Delaware Portion of the Philadelphia 1997 PM2.5 NAAQS

Transportation Conformity Rule

40 CFR Part 93,  93.118	

Review Criteria	

Was the Criterion Satisfied?  If Yes, How was this Criteria Satisfied?

93.102(b)(2)(iv)	Has the EPA and the State made a finding that NOx is an
insignificant contributor to the direct mobile PM emissions or does the
implementation plan fail to establish a NOx budget as part of the PM 2.5
attainment?	Neither EPA nor the State have made any findings that NOx is
an insignificant contributor to the PM2.5 mobile emissions and therefore
it has been included in the SIP as a proposed mobile emissions budget
for 2009.

93.102(b)(2)(v)	Has the EPA or State made a finding that Volatile
Organic Compounds (VOCs), Sulfur Oxides (SOx) or Ammonia (NH3) as
precursors to be a significant contributor to the mobile PM emissions or
does the implementation plan  submission establish a  budget for VOCs,
SOx or NH3 as part of a PM 2.5  attainment strategy?

	Neither EPA nor the State have made any findings that VOC’s, SOx or
NH3 are a significant contributor to the PM2.5 mobile emissions and
therefore it has not been included in the SIP as a proposed mobile

93.102(b)(3)

	Has the EPA or the State made a finding that re-entrained road dust is
a significant contributor to the PM mobile emissions or does the
implementation plan  establish a budget that includes re-entrained road
dust as part of a PM 2.5 attainment strategy?

	Neither EPA nor the State have made any findings that re-entrained road
dust is a significant contributor to the PM2.5 mobile emissions, and
therefore, it has not been included in the SIP as a proposed mobile
emissions budget.

Sec. 93.118(e)(4)(i)	Was the submitted revised plan endorsed by the
Governor (or his or her designee) and subject to a State public hearing?

	Yes.  The submitted 2009 Attainment Plan was endorsed and submitted as
a SIP revision by the Governor’s designee, the Secretary of Delaware
Department of Natural resources and Environmental Control.  A public
hearing on the SIP proposal was held by the State.



Sec. 93.118(e)(4)(ii)	Before the attainment demonstration was submitted
to EPA, did consultation between federal, State and local agencies
occur; was full implementation plan documentation provided to EPA, and
was EPA’s stated concerns, if any, addressed?

	Yes. Consultation has occurred among all required Federal, State and
local agencies.

Sec. 93.118(e)(4)(iii)	Was the motor vehicle emissions budget(s) clearly
identified and precisely quantified?	Yes, the budgets are clearly
identified on page 101 of the SIP submittal containing the 2009
Attainment Plan.



Sec. 93.118(e)(4)(iv)	Is the motor vehicle emissions budget(s), when
considered together with all other emission reductions, consistent with
applicable requirements for attainment demonstrations?

	EPA believes the budgets can be declared adequate because in
conjunction with the other emission reductions, they   demonstrate
attainment for 2009.

Sec. 93.118(e)(4)(v)	Is the motor vehicle emissions budget(s) consistent
with and clearly related to the emissions inventory and the control
measures in the Plan?

	EPA believes that the budgets are clearly related to the emissions
inventory and the control measures in the SIP submittal.

Sec. 93.118(e)(4)(vi)	Revisions to previously submitted attainment
demonstrations:  explain and document any changes to previously
submitted budgets and control measures; impacts on point and area source
emissions; any changes to established safety margins (see Sec. 93.101
for definition); and reasons for the changes (including the basis for
any changes related to emission factors or estimates of vehicle miles
traveled).

	N/A The area was designated nonattainment for this NAAQS for the first
time in 2005 and this was the initial control strategy SIP submitted by
the state to address the NAAQS.



Sec. 93.118(e)(5)	Did they provide and we review public comments and the
State’s responses to those comments with the submitted control
strategy SIP?

	There were no comments on the SIP related to the proposed mobile
vehicle emissions budgets.



III.  Findings - Based upon our review and evaluation of the MVEBs
contained in the submittal of the 2009 attainment plan for the Delaware
Portion of the Philadelphia 1997 PM2.5 NAAQS nonattainment area, we find
the said MVEBs adequate for conformity purposes.  

IV.  The Applicable Motor Vehicle Emissions Budgets for Purposes of
Demonstrating Conformity for 2009 in the Delaware Area  - The applicable
motor vehicle emissions budgets for purposes of demonstrating conformity
are 4904.0 tons/year of NOx and 87.0 tons/year Direct PM for 2009. 

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