As a Maryland resident, I am deeply concerned about Maryland's continuing failure to address 

ozone air quality issues in Baltimore.

Sixteen years after EPA established its nationwide health-protective standard for ozone, the 

Baltimore area is still failing to meet this standard. What's even more concerning is that EPA 

recently tightened its health-based standard for ozone, meaning that the Baltimore area is now even 

further from achieving safe levels of air quality.

While the Maryland Healthy Air Act was an important step for cleaning up our air, as the Maryland 

Department of the Environment has recognized, the Act does not go far enough. In particular, 

additional emission reductions are needed from motor vehicles as well as from two of the state's 

largest sources of ozone-causing pollution: the Crane and Wagner coal plants. The coal plants still 

lack the most state-of-the-art emission controls for ozone-causing pollutants.

To protect my health, and the health of other members of the Baltimore community, I call on the 

Maryland Department of the Environment to address vehicular emissions and to establish healthprotective emission limits for the Baltimore-area coal plants.

Response:		

MDE	thanks	the	commenter(s)	for	expressing	their	concern	for	air	quality issues	within	the	

Baltimore	area.		MDE	agrees	with	the	commenter(s)	on	the	need	for	healthy	air	for	the	citizens	of	

Maryland.		

As	part	of	this	SIP	submission,	Maryland	has	presented	the	control	measures	used	to	improve	

ozone	levels	substantially	since	passage	of	the	Clean	Air	Act	Amendments	as	well	as	the	additional	

measures	implemented	to	continue	progress	and	achieve	the	0.08	ppm	8-hour	ozone	standard	in	

the	Baltimore	nonattainment	area.		This	SIP	addresses	the	requirements	imposed	on	the	Baltimore	

Nonattainment	Area	by	the	U.S.	EPA	in	76	FR	54412		when	the	area	was	reclassified	to	a	serious

ozone	nonattainment	area.		As	such,	it fully	conforms	to	all	current	EPA	guidance	and	regulatory	

requirements.

Maryland,	by	law,	is	prohibited	from	establishing	motor	vehicle	standards	and	fuel	standards	under	

42	U.S.C.A.	7543.		Maryland	is	one	of	fifteen states	to	proactively	adopt	the	California	Clean	Car	

Standard,	pursuant	to	CAA	section	177	(42	U.S.C.A	7507),	which	establishes	a	limited	exemption	to	

the	preemption	of	state	mobile	source	regulations.		The	California	Clean	Car	Standard	is	a	state-ofthe-art	program	that	increases	automobile	fuel	efficiency	and	cuts	pollution	from	our	cars	and	light	

trucks.		The	program	has	the	backing	and	support	of	the	Environmental	Defense	Fund	as	well	as	the	

Sierra	Club.		 The	State	has	also	adopted	California	Low	Emission	Vehicle	(Cal	LEV)	standards,	which	

are	more	stringent	than	federal	regulations.		

All	of	the	coal-fired	electric	generating	units	within	the	Baltimore	Nonattainment	Area	are	

equipped	with	NOX controls.		A	variety	of	control	technologies	can	be	employed	to	control	NOX

emissions	from	coal-fired	units.		These	include	(ranging	from	least	effective	to	most	effective):	

uncontrolled,	boiler	tuning	and	maintenance,	combustion	modifications	(over-fired	air,	low	NOX

burners),	selective	auto-catalytic	reduction	(SACR),	selective	non-catalytic	reduction	(SNCR),	and	

selective	catalytic	reduction	(SCR).		All	of	the	coal-fired	electric	generating	units	within	the	

Baltimore	Nonattainment	Area	utilize	a	combination	of	controls	and	are	equipped	with	a	minimum	

of	a	SNCR	level	of	control.		

MDE	has	been	designated	as	a	moderate	nonattainment	area	under	the	75	ppb	8-hour	ozone	and	

continues	to	implement	additional	control	programs	and	regulations that	will	be	needed	for	the	

area	to	attain	this	new,	more	stringent	standard.		MDE	will	consider	all	sources,	including	electric	

generating	units	and	vehicular	emissions,	when	developing	these	strategies.