### 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 failin g 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 larges t 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 health

protective 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	p assage	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 Non attainment	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	mo tor	vehicle	standard s	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	preempti on	of	state	mobile	source	regulations.		The	California	Clean	Car	Standard	is a	state

- of

the

- 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	Environment al	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	Nonatta inment	Area	are equipped	with	NO X controls.		A	variety	of	control	technologies	can	be	employed	to	control NO X emissions	from	coal

- fired	units .		These	include	( ranging from	least	effective	to	most	effective): uncontrolled,	boiler	tuning	and	maintenance, com bustion	modifications	( over - fired	air,	low NO X 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	Non attainment	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	a nd	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 strateg ies.