Technical Support Document (TSD) for the 

Baltimore Nonattaiment Area 8-Hour Ozone State Implementation Plan: 

Demonstrating Rate of Progress for 2008,2011, and 2012 

Revision to 2002 Base Year Emissions; and Serious Area Attainment Demonstration 

Submitted by the 

Maryland Department of the Environment 

TSD Prepared November 2015 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Reviewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 
I. Introduction 

The purpose of this document is to provide a technical summary of the Office of 

Air Monitoring and Analysis (OAMA) review of the emissions inventories submitted 

with the Baltimore Nonattaiment Area 8-Hour Ozone State Implementation Plan: 

Demonstrating Rate of Progress for 2008, 2011, and 2012, Revision to 2002 Base Year 

Emissions; and Serious Area Attainment Demonstration submitted by Maryland 

Department of the Environment (MDE). The Baltimore Nonattainment Area (BNAA) is 

comprised of Baltimore City and the counties of Baltimore, Carroll, Anne Arundel, 

Howard, and Harford. Effective March 2, 2012 EPA reclassified the BNAA from a 

moderate nonattainment area to a serious nonattainment area (NAA) for the 8-hour ozone 

National Ambient Air Quality Standard (NAAQS). Under the Clean Air Act (CAA) 

section 182(b )(1 )(A) moderate and above NAAs are required to submit a "rate of 

progress" (ROP) plan which ensures a 15 percent VOC reduction by 6 years after the 

NAA designation. In addition, areas classified as serious and above are required under 

CAA section 182( c )(2)(B) to submit a plan to achieve at least a further annual 3 percent 

VOC reduction, also called, "annual reasonable further progress(RFP)." This review 

does not determine the approvability ofthe rate of progress plan or attainment 

demonstration. Any questions pertaining to this technical summary should be directed to 

Alice Chow, Associate Director, Office of Air Monitoring and Analysis, at 215-814-2144 

or via email at chow.alice@epa. gov. 

II. 2002 Base Year Inventory RFP Revisions 

In a ROP/RFP plan the base year inventory is used to provide a reference point to 

determine the emission reductions that must be achieved for the 15 percent V OC (or 

NOx) reduction, and the subsequent 3 percent reductions for serious areas out to the 

attainment year. For ozone, the base year inventory for ROP/RFP is typically the same 

base year submitted in the nonattainment plan. If significant changes have occurred since 

the approval of the base year inventory, updates to the inventory should be made to in 

order to make the emissions comparable to projected inventories. In June of2014, EPA 

approved the 2002 emissions inventories submitted by Maryland for the BNAA for the 

ozone NAAQS. See (75 FR 31709, June 4, 201 0). This section will discuss the revisions 

(if any) made to the 2002 Base Inventory. 

No revisions to the point and nonpoint (area) source inventories were made for 

RFP purposes. 

The approved 2002 base year inventory for nonroad sources used the 

NONROAD2005 model. Since the time of approval, a new version of the model, 

NONROAD2008 has been released. MDE updated emissions using the new version. 

Aircraft, locomotives, and commercial marine vessels were calculated outside of the 

NONROAD2008 model, but were included in the nonroad inventory. 
The onroad mobile source inventory was also updated to take into account 

emission differences due to a newer model. MDE revised emissions for 2002 using 

MOVES2010, which replaced MOBILE6.2. 

OAMA staff reviewed the emissions and believes them to be reasonable. 

III. RFP Projected Inventories- 2008, 2011, and 2012 

MDE submitted a 2008 projected inventory to fulfill the CAA section 

182(b )(1 )(A) requirement for moderate and above areas. The 2011 projected inventory is 

used to fulfill the 182( c )(2)(B) requirement for serious and above areas of NAA, and the 

2012 projected inventory is required for the attainment year. Inventories were developed 

for all emission sources for all three years. 

The point source emissions for 2008, 2011, and 2012 were projected, using 

surrogates for EPA's Economic Growth and Analysis System, Version 5.0 (EGAS 5.0). 

The nonpoint or area source emissions for 2008,2011, and 2012 were projected 

using growth factors to account for population, household and employment data from the 

Baltimore Metropolitan Council. 

For the nonroad projected inventories for 2008, 2011, and 2012, MDE used 

EPA's NONROAD2008 model. The NONROAD model allows for the calculation of 

past year, present year, and future year inventories to be generated. Emissions for 

aircraft, locomotive, and commercial marine vehicles are calculated outside of the 

NONROAD model. Growth for locomotives and commercial marine vessels came from 

employment data as surrogates. Aircraft emissions were estimated from Maryland 

Aviation Administration activity data and the Federal Aviation Administration's 

Terminal Area Forecasts. 

The onroad emissions for 2008, 2011, and 2012 were estimated using the 

MOVES2010a model. The analysis was done by Michael Baker, Jr., Inc., in consultation 

with MDE. Local activity data was used to replace default inputs in the model where 

appropriate. 

OAMA staff reviewed the emissions and believes them to be reasonable.