UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

                                                                        
                 October 6, 2011



SUBJECT:	

Technical Support Document - Adequacy Findings for the Motor Vehicle
Emissions Budgets in the Attainment Demonstration for the Pennsylvania
Portion of the Philadelphia-Wilmington-New Jersey City 1997 Fine
Particulate (PM2.5) National Ambient Air quality Standard (NAAQS)
Nonattainment Area 





FROM:	       /s/

Martin Kotsch,  

Office of Air Program Planning (3AP30)	





TO:	

Administrative Record for the Adequacy Findings for the Motor Vehicle
Emissions Budgets in the Attainment Demonstration for the Pennsylvania
Portion of the Philadelphia-Wilmington-New Jersey 1997 PM2.5 NAAQS
Nonattainment Area 

              /s/	



THRU:	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, 118(f)
“Adequacy review process for implementation plan submissions”.  

On April 12, 2010, the Pennsylvania Department of Environmental
Protection (PADEP) formally submitted an Attainment Demonstration Plan
for the 1997 PM2.5 NAAQS (hereafter the attainment demonstration) for
the Pennsylvania Portion of the Philadelphia-Wilmington-New Jersey PM2.5
Nonattainment Area as SIP revision. 

EPA will be issuing its own Notice of Proposed Rule making for a 30-day
public comment period soliciting public comment as to the approvability
of the Pennsylvania SIP submission.  Concurrently with EPA’s Notice of
Proposed Rulemaking, a notice will be posted on EPA’s website at
http://www.epa.gov/otaq/stateresources/transconf/currsips.htm  for the
purpose of opening EPA’s 30-day public comment period on the
adequacy/approvability of the budgets in the SIP revision.  That notice
will inform the public of the availability of the Pennsylvania SIP
revision on its own website.  EPA’s website notice will provide a link
to the address for the website where interested members of the public
could access the SIP revision. Following EPA’s public comment period,
responses to any comments received on the proposed mobile budgets in the
Pennsylvania SIP will be addressed in an amendment to this Technical
Support Document (TSD). 

Shown below in Table 1 are the 2 sets of budgets from the SIP submittal.


Table 1

The Budgets of the Pennsylvania Portion of
Philadelphia-Wilmington-Atlantic City 1997 PM2.5 NAAQS Attainment
Demonstration

Plan

Submittals	

Milestone 

Year	

Mobile Vehicle Emissions Budget for Direct PM-Tons Per Year	

Mobile Vehicle Emissions Budget for NOx-Tons Per Year

	Attainment Plan Demonstration	2009	      699	36,318

	

II. Evaluation of the Adequacy of the MVEBs Budgets in the Attainment
Demonstration for the Pennsylvania Portion of the
Philadelphia-Wilmington-New Jersey 1997 NAAQS PM2.5  Nonattainment Area
Submitted by PADEP on April 12 , 2010

In this TSD, we are evaluating the MVEBs associated with the 2009
attainment demonstration plan contained in the April 12, 2010 SIP
submittal, for conformity purposes.  We are using the evaluation
criteria detailed in the Transportation Conformity Rule, 40 CFR part
93.102(b)(2)(v), 93.102(b)(2)(v), 93.102(b)(3), and part 93, 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 Attainment Demonstration for the
Pennsylvania Portion of Philadelphia-Wilmington-New Jersey City 1997
NAAQSPM2.5 Non-attainment Area

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)	Have EPA and the State made a finding that NOx is an
insignificant contributor to the direct mobile PM emissions?	EPA and the
State have not made such a finding.

93.102(b)(2)(v)	Has EPA or State made a finding that VOCs, Sulfur Oxides
(SOx) or Ammonia (NH3) as precursors to be a significant contributor to
the mobile PM2.5 emissions?	Neither EPA or the State has made such a
finding.

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?
Neither EPA or the State has made such a finding.

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 and attainment demonstration was endorsed and
submitted as a SIP revision by the Governor’s   designee, the
Secretary of the PADEP, and a public hearing was held.

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 22 of the April 12, 2010 submittal containing
the attainment demonstration.  



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 2010.  



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



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 proposed mobile emissions budgets in the
SIP. 



III. Findings - Based upon our review and evaluation of the MVEBs
contained in PADEP’s April 12, 2010 submittal of the attainment plan
for the Pennsylvania Portion of Philadelphia-Wilmington-New Jersey 1997
PM2.5 NAAQS nonattainment area, we find the said MVEBs adequate for
conformity purposes.    



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