EPA. REGION III December 1, 2011 ()FFICEOFREGION ADMINISTRATOR

Mr. Shawn M. GarvinRegional Administrator

U.S. Environmental Protection AgencyRegion III

1650 Arch Street (3RAOO)

Philadelphia PA 19103-2023

Dear Mr. Garvin:Thank you for the opportunity to revise our recommendation for Maryland’s nonattainment areas

under the 2008 8-hour ozone standard. In accordance with Section 107(d)(1) of the Clean Air Act,

Maryland’s boundary recommendations for attainment, nonattainment, and control region areas under

the revised 8-hour ozone standard are provided below.Lowering the ozone standard from 0.08 parts per million (ppm) to 0.075 ppm will require significant

reductions in both local and regional ozone pollution. Maryland will continue to adopt local control

programs to reduce locally formed ozone. Since most of Maryland is already heavily regulated dueto existing ozone and fine particle requirements, Maryland will also be relying heavily on reductions

in transported pollution in order to meet this more stringent standard. Maryland research shows that

measured, “incoming” ozone often already exceeds the 0.075 ppm standard.Maryland is pleased that EPA has initiated efforts to adopt federal rules to reduce ozone transport.We are also very concerned that these efforts do not go far enough and that EPA may not be

successful in finalizing the necessary regulations to allow Maryland to comply with the Clean Air Act

and to protect the health of our citizens.Because of these concerns, Maryland, like several other Mid-Atlantic and Northeast states, urges

EPA to consider establishing a very large nonattainment area for the new standard that would include

at least the following states: Delaware, District of Columbia, Kentucky, Indiana, Illinois, Maryland,Michigan, Missouri, New Jersey, New York, North Carolina, Ohio, Pennsylvania, Tennessee,

Virginia, West Virginia and Wisconsin. These states are the states that EPA has identified assignificantly contributing to Maryland’s ozone problem. This large nonattainment area wouldguarantee that appropriate emission reductions from upwind sources are achieved. Additionalsupporting technical information on the large nonattainment area is being forwarded to EPA

Region III by the Maryland Department of the Environment.
recommendations for these counties from 

nonattainment

to 

unclassifiable/attainment.

Table 1, which is enclosed with this letter, summarizes the specific areas that Maryland is

recommending as attainment, nonattainment, or secondary control region areas.Maryland recognizes that this boundary recommendation submittal is only the first step in the ozone

designation process, and looks forward to working with the Environmental Protection Agency (EPA)and Maryland stakeholders during the final steps of the designation process.

If you have any questions on this submission, please do not hesitate to contact Robert Summers, Ph.D.,

Secretary, Maryland Department of Environment at 410-537-3086 or George (Tad) Aburn, Director

of the Air and Radiation Management Administration at 410-537-3255.

erely

Governor

cc: Robert M. Summers, Ph.D., Secretary, Maryland Department of the Environment

Enclosure: Table 1
Baltimore Nonattainment Area

Anne Arundel County NonattainmentBaltimore City NonattainmentBaltimore County Nonattainment

Carroll County Nonattainment

Harford County NonattainmentHoward County Nonattainment

Washington DC-MD- VA Nonattainment Area

Calvert County NonattainmentCharles County Nonattainment

Frederick County NonattainmentMontgomery County NonattainmentPrince Georges County Nonattainment

Philadelphia-Wilmington-Atlantic City (PA-NJ-DE-MD) Nonattainment Area

Cecil County Nonattainment

UnclassUlable (Attainment,) counties

Allegany County Attainment

Garrett County AttainmentWashington County Attainment

St. Mary’s County Attainment

Kent County Attainment

Queen Anne’s County Attainment

Caroline County AttainmentTalbot County Attainment

Dorchester County Attainment

Wicomico County AttainmentSomerset County AttainmentWorcester County Attainment