### 1 

# VADEQ Comments on Combining the Baltimore and Washington
Ozone Nonattainment A reas

As stated during the previous call on this issue, the VADEQ is strongly opposed to the recommendation from the
District of Columbia and the State of Maryland, to reverse p ast precedent and combine the historically separate nonattainment areas of Baltimore and Washington, DC under the 2008 ozone standard

. Furthermore, we believe
that t here are serious flaws in the arguments presented to support such an action:

• We believe th at the Baltimore area is unduly influenced by the outlying and flawed Edgewood monitor. This monitor is not representative of air quality in the Washington area, and may not be representative of
most of Baltimore as well.

• We believe that combining these t wo nonattainment areas would do little or nothing to produce
additional meaningful emission reductions to i mprove ozone air quality in either area, and certainly would have no impact on the worst case monitor identified above.

• We believe that substantial e missions reductions have and will continue to occur regardless of the nonattainment designation process that will result in improved ozone air quality in Virginia and downwind

areas.



### • We believe that combining these areas would create a serious new burden o n both the air quality and transportation planning processes for both areas.



### Air Quality Data

Air quality in general for both the Baltimore and Washington areas is consistent with a marginal level of nonattainment. In addition, there is no noticeable gra dient of increase between the areas that would indicate substantial influence or contribution. The sole exception to regional ozone levels is the Edgewood, MD monitor
which h a s 2011 design value that is a full 10 parts per billion higher than any other mo nitor in these areas. We believe that the reason for this wide discrepancy in air quality is due to a unique combination of local influences
such as meteorolog y, pollution recirculation, and other s at this monitor. Because of this, we do not believe that this monitor is representative of the area(s) as a whole, or of the DC area contribution to Baltimore. As such this
monitor should not be used to drive the air quality planning and control requirements for the Washington area.

We also understand that thi s monitor is located the property of the Army’s Aberde e n Proving Ground which h as experienced significant recent growth as a result of the last Defense BRAC realignment which may also play a part
in the elevated ozone levels at this monitor. We would ins ist before any combination action, that this monitor undergo a detailed regional evaluation to better understand the ozone formation factors in play

, including Chesapeake Bay breeze and pollution stagnation and recirculation. We would also suggest that th is monitor be re

evaluated for site suitability due to the recent growth in the area.

### 2 Contribution Modeling

DEQ has performed a brief review of the MDE modeling provided to EPA Region III to support their position. We
find the summary presentation to be substantially lacking in terms of modeling and methodology. The immediate point is that all the results presented are for a limited number of days and are of 2002 and 2007 vintage. Much has changed since these base case years in terms of control programs and emissions reductions. Regarding the very selective episode that was chosen, we can only assume that it was the one that best supports their position . As you know, current SIP quality modeling normally requires multiple ep isodes with different characteristics or even an entire ozone season. There are also significant limitations to the screening inventories used in this analysis and no information is provided on model performance.

The part of this analysis that we take th e most issue with is the way in which the impact analysis of the DC area on
Baltimore was performed . Standard regional modeling practice is for this type of analysis is to ze ro out the emissions of an area and subtracting it from the base case to determin e its contribution to other areas. This is what was done for the contribution modeling for Maryland and Baltimore in Slides 1 and 2. However, the DC contribution analysis presented in Slide 5 is performed in reverse by zeroing out all other domain emiss ions. This analysis is not meaningful and is done incorrectly. Conducting a brute force zero out run that includes just the DC emissions completely changes the chemistry in the model and th e results cannot be reasonably relied upon. We 

## 92

8 76 77
80

79
76 75 73

69 82 7 76

80

77 79 79

### 3 believe that the more appropriate way to determine contribution is to use the much more comprehensive and rigorous regulatory modeling used to support the CSAPR rule which determined that all of Virginia contributes about 8 parts per billion (9%) of the 2012 ozone levels a t the Edgewood monitor.

Finally, performing this type of analysis on just one area is no more compelling than what similar analyses for any number of other “nearby” areas would produce. All the MDE analysis attempts to do is to incorrectly single out
and imply that the Washington, DC area as the main contributor to most of Baltimore’s ozone problem.



### Emission Reduction Data

Significant emissions reductions have occurred in the Washington area and in all of Virginia during the past ten years in the two major NO x precursor sector s , electric utilities and motor vehicles. We also predict that these
reductions will continue into the future.

In the Washington, DC area alone, it is estimated overall NOX emissions will be reduced from all source s by over 90,000 ton s per year between 2007 and 2025. Again much of this reduction comes from the power and mobile

sectors.

In the case of motor vehicle emissions that are the main source of NOx emissions in the area and the sector specifically named as the main contributo r to the Baltimore area, the news is even better. Emissions from this

sector are expected to be reduced by 80% or about 65,000 ton per year between 20 0 7 and 2040

. A similar percent reduction can also be expected in Virginia’s overall motor vehicle emiss ions during the same period. Any further significant motor vehicle control programs such as Tier 3 and low sulfur fuels will add more to these reductions.

### 4 D C Motor Vehicle Emissions Trend

With regard to total Virginia NOx emissions from the power sector, we have seen a steady and significant
reduction in emissions since 2002 of about 46,000 tons per year. Again, we expect these emissions to continue to decrease out to 2016, even with the addition of 3,100 megawatts of new coal and natura l gas capacity at a hypothetical 1 00% capacity.

### 5 However, all this current and future success comes with a price; w e have now reached a point of diminishing opportunities for and return from future controls. The power sector transition that is underway is going to take its course, helped along with by additional technology and/or transport based control programs. The same can be
said for the non

- utility stationary combustion sector that is going through a similar transition. M obile emi ssions are mainly driven by federal engine and fuel standards. What is left for us to do at a local level amounts to nibbling around the edges at great cost and little benefit. The example already identified is the recen t analysis by the transportation p lanning group in DC where the next most “feasible” transportation control measures would produce only 220 tons of NOx reductions at a cost of $85 million per year

.


### Commuting Patterns

T o further define the influence of Washington based traffic on the Balti more area, the following data was obtained
from the latest National Capital Region transportation model ing exercise

. These data show that d uring a typical morning commute in 2007
, only 1.4% of the total trips in the Washington area had a destination in th e Baltimore area. Likewise during the afternoon commute, 1.5% of total trips are to the Baltimore area. Furthermore, it is estimated that there will be no meaningful increase in these inter

- MSA trip s out to 2030 as shown below.



### Vehicle Trips Originatin g in the Washington DC Area

P lanning Implications

We continue to believe that the combination of these two well established areas and associated organizations would seriously disrupt, complicate, and slow the ability of both areas to perform air qual ity and transportation planning in the future. The increasing political and agenda driven goals of some of our partners in the DC planning process is already causing us to explore other possible arrangements for performing air quality and especially

trans portation planning in the future.