Appendix B

VERSION 3.3 Technical Support Document for the Development of the 2025 

Emission Inventory for PM Nonattainment Counties in the MANE-VU 

Region; Prepared for MARAMA by AMEC Environment & Infrastructure 

and SRA International, Inc.; 

January 23, 2012
Technical Support Document 

for the

Development of the 2025

Emission Inventory

for PM Nonattainment Counties 

in the MANE-VU Region

Version 3.3

Prepared for:

Mid-Atlantic Regional Air Management Association (MARAMA)

8600 LaSalle Road, Suite 636

Towson, MD 21286

(443) 901-1882

January 23, 2012

MARAMA Contract Agreement FY2011-004

Submitted by

AMEC Environment & Infrastructure SRA International, Inc. 

4021 Stirrup Creek Drive 652 Peter Jefferson Parkway

Suite 100 Suite 300

Durham, NC 27703 Charlottesville, VA 22911

919 381-9900 571 499-0833
Acknowledgements

Funds for this CONTRACT are provided by MARAMA’s Memorandum of Agreement with the 

Ozone Transport Commission (OTC), which is funded by USEPA grant agreement XA973181 –

Regional Haze Planning in the Northeast and Mid-Atlantic States (CFDA 66.034). The purpose 

of that Memorandum of Agreement is to support the Mid-Atlantic / Northeast Visibility Union 

(MANE-VU) in developing programs to control regional haze or visibility impairment in the 

Northeast and Mid-Atlantic states.

About MARAMA

The Mid-Atlantic Regional Air Management Association, Inc. is a voluntary, non-profit 

association of ten state and local air pollution control agencies. MARAMA's mission is to 

strengthen the skills and capabilities of member agencies and to help them work together to 

prevent and reduce air pollution in the Mid-Atlantic Region. MARAMA provides cost-effective 

approaches to regional collaboration by pooling resources to develop and analyze data, share 

ideas, and train staff to implement common requirements.
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Table of Contents

1.0 INTRODUCTION.................................................................................................................. 1

1.1 INVENTORY PURPOSE ................................................................................................ 1

1.2 SOURCE CATEGORIES................................................................................................ 1

1.3 GEOGRAPHIC AND TEMPORAL RESOLUTION........................................................... 2

1.4 POLLUTANTS................................................................................................................ 3

1.5 DATA FORMATS ........................................................................................................... 3

1.6 INVENTORY VERSIONS ............................................................................................... 3

1.6.1 Version 2 Modeling Inventories with Existing Controls ............................................ 3

1.6.2 Version 3 Modeling Inventories with Existing Controls ............................................ 3

1.6.3 Version 3 Modeling Inventories with Potential New Controls................................... 4

1.6.4 Version 3 2025 Inventory for PM Nonattainment Counties...................................... 4

1.7 REPORT ORGANIZATION............................................................................................. 5

2.0 AREA SOURCES ................................................................................................................ 8

2.1 AREA SOURCE CATEGORIES...................................................................................... 8

2.2 2007 INVENTORY DEVELOPMENT .............................................................................. 8

2.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections .......................... 8

2.3 2025 INVENTORY DEVELOPMENT .............................................................................13

2.3.1 Area Source Growth Factors..................................................................................13

2.3.1.1 AEO Fuel Use Projection ...................................................................................13

2.3.1.2 Population Projections .......................................................................................14

2.3.1.3 Employment Projections ....................................................................................15

2.3.1.4 VMT Projections.................................................................................................15

2.3.1.5 No Growth Assignment for Certain Area Source Categories ..............................25

2.3.1.6 USEPA 2020 Projections for Residential Wood .................................................26

2.3.1.7 SCC, SIC, NAICS and Growth Parameter Crosswalk ........................................27

2.3.1.8 Final Version 2 Growth Factors for Area Sources ..............................................27

2.3.1.9 Version 3 Update to New Jersey Growth Factors for Area Sources ...................28

2.3.1.10 Version 3 Update to Growth Factors for the District of Columbia....................28

2.3.2 Area Source Control Factors..................................................................................30

2.3.2.1 Federal Rules Affecting Area Sources ...............................................................30

2.3.2.2 Federal MACT Rules .........................................................................................30

2.3.2.3 OTC Model Rules for VOC Sources...................................................................31

2.3.2.4 OTC Model Rule for ICI Boilers..........................................................................32

2.3.2.5 MANE-VU Fuel Oil Sulfur Strategy.....................................................................33

3.0 POINT SOURCES ..............................................................................................................45

3.1 POINT SOURCE CATEGORIES ...................................................................................45

3.2 2007 INVENTORY DEVELOPMENT .............................................................................45
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3.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections .........................46

3.3 2025 NONEGU INVENTORY DEVELOPMENT.............................................................47

3.3.1 NonEGU Growth Factors .......................................................................................47

3.3.2 Emission Reduction Credits...................................................................................49

3.3.3 NonEGU Control Factors .......................................................................................50

3.3.3.1 Federal Actions Affecting NonEGU Point Sources .............................................50

3.3.3.2 OTC 2001 Model Rules for NonEGUs................................................................52

3.3.3.3 OTC 2006 Model Rules for NonEGUs................................................................52

3.3.3.4 MANE-VU Fuel Oil Sulfur Strategy.....................................................................55

3.3.3.5 State-specific NonEGU Control Factors .............................................................55

3.4 2025 EGU INVENTORY DEVELOPMENT.....................................................................57

3.4.1 EGU Growth Factors .............................................................................................58

3.4.2 EGU Control Factors .............................................................................................62

3.4.3 Consideration of CSAPR Emission Allowances .....................................................63

4.0 NONROAD MOBILE SOURCES INCLUDED IN NMIM ......................................................64

4.1 NONROAD MODEL CATEGORIES...............................................................................64

4.2 2007 INVENTORY DEVELOPMENT .............................................................................64

4.3 2025 INVENTORY DEVELOPMENT .............................................................................65

4.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT ......................................65

4.5 NMIM/NONROAD GROWTH AND CONTROL INFORMATION.....................................65

5.0 MARINE VESSELS, AIRPORTS, AND RAILROADS.........................................................69

5.1 MAR INVENTORY CATEGORIES.................................................................................69

5.2 2007 INVENTORY DEVELOPMENT .............................................................................69

5.3 2025 INVENTORY DEVELOPMENT .............................................................................69

5.3.1 Commercial Marine Vessels ..................................................................................69

5.3.1.1 CMV Diesel Growth Factors...............................................................................70

5.3.1.2 CMV Diesel Control Factors...............................................................................70

5.3.1.3 CMV Residual Oil Growth Factors .....................................................................71

5.3.1.4 CMV Residual Oil Control Factors .....................................................................72

5.3.1.5 Military Vessels Growth and Control Factors......................................................73

5.3.1.6 State-specific CMV Updates for 2025 ................................................................73

5.3.2 Airports ..................................................................................................................73

5.3.2.1 Airport Growth Factors.......................................................................................74

5.3.2.2 Aircraft Control Factors ......................................................................................75

5.3.2.3 State-specific Airport Updates for 2025..............................................................76

5.3.3 Railroad Locomotives ............................................................................................76

5.3.3.1 Railroad Growth Factors ....................................................................................76

5.3.3.2 Railroad Control Factors ....................................................................................77

5.3.3.3 State-specific Railroad Updates for 2025 ...........................................................78
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6.0 ONROAD MOBILE SOURCES INCLUDED IN MOVES .....................................................79

6.1 MOVES MODEL CATEGORIES....................................................................................79

6.2 2007 MOVES MODEL INVENTORY..............................................................................79

6.3 2025 MOVES MODEL INVENTORY..............................................................................79

7.0 EMISSION SUMMARIES....................................................................................................80

8.0 DELIVERABLES ................................................................................................................93

9.0 REFERENCES ...................................................................................................................95

List of Appendices

Appendix A1 AEO2010 New England.xls

Appendix A2 AEO2010 Mid Atlantic.xls

Appendix A3 AEO2010 South Atlantic.xls

Appendix A4 AEO2011 New England.xls

Appendix A5 AEO2011 Mid Atlantic.xls

Appendix A6 AEO2011 South Atlantic.xls

Appendix A7 AEO2010 vs AEO2011 Comparison.docx

Appendix B Population_Factors.xls

Appendix C Employment_Factors.xls

Appendix D VMT GF Nonattainment Counties.xls

Appendix E EPA2020 Res Wood.xls

Appendix F AEO2011-Electricity Generation by EMM.xlsx

Appendix G UAF NEEDS Control FileMASTER92211.xls

Appendix H MAR Growth and Control.xls
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List of Exhibits

Exhibit 1-1 Comparison of Data Used for the 2025 PM Nonattainment Inventory and 

Version 3 of the Modeling Inventory

Exhibit 1-2 List of PM Nonattainment Areas and Counties

Exhibit 2-1 Area Source SCCs Affected by PM Transport Fraction

Exhibit 2-2 PM Transport Fractions for PM Nonattainment Counties

Exhibit 2-3 Comparison of 2007 Paved Road Dust PM10 Emission Estimates

Exhibit 2-4 Comparison of 2007 Paved Road Dust PM2.5 Emission Estimates

Exhibit 2-5 Growth Factors for Coal Fuel Use by AEO Region 2007 - 2025

Exhibit 2-6 Growth Factors for Residual Oil Fuel Use by AEO Region 2007 - 2025

Exhibit 2-7 Growth Factors for Distillate Oil Fuel Use by AEO Region 2007 - 2025

Exhibit 2-8 Growth Factors for Natural Gas Fuel Use by AEO Region 2007 - 2025

Exhibit 2-9 Growth Factors for Gasoline Fuel Use by AEO Region 2007 – 2025

Exhibit 2-10 Population Growth Factors by AEO Region 2007 – 2025

Exhibit 2-11 Employment Growth Factors by AEO Region 2007 – 2025

Exhibit 2-12 2007 and 2025 VMT and the 2007-2025 Growth Factor

Exhibit 2-13 Area Source Categories with No Growth Assignment

Exhibit 2-14 State Recommendations to Address Negative Growth 

and Other Growth Factors for the Area Source Sector

Exhibit 2-15 Exhibit 2-15 USEPA Estimated Percent Reductions for RICE MACT Standard

Exhibit 2-16 Area Source Emission Reductions from New Jersey ICI Boiler NOx Rules

Exhibit 2-17 MANE-VU Low Sulfur Fuel Oil Strategy

Exhibit 2-18 Sulfur Content and Control Factors for Residential Fuel Oil Combustion

Exhibit 2-19 Sulfur Content and Control Factors for Distillate Fuel Oil Combustion

Exhibit 2-20 Sulfur Content and Control Factors for Residual Fuel Oil Combustion

Exhibit 3-1 NonEGU Point Source SCCs Affected by PM Transport Fraction

Exhibit 3-2 State Recommendations to Address Negative Growth for the NonEGU 

Point Source Sector

Exhibit 3-3 USEPA Estimated Percent Reductions for RICE MACT Standard

Exhibit 3-4 NonEGU Point Source Emission Reductions from New Jersey 

ICI Boiler NOx Rules

Exhibit 3.5 Electricity Market Module Regions

Exhibit 3.6 Electricity Generation Growth Factors for Coal 

Exhibit 3.7 Electricity Generation Growth Factors for Petroleum

Exhibit 3.8 Electricity Generation Growth Factors for Natural Gas
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Exhibit 3.9 Electricity Generation Growth Factors for Renewables

Exhibit 4-1 Control Programs Included in the NMIM/NONROAD Model

Exhibit 5-1 CMV Diesel Control Factors by Year and Pollutant

Exhibit 5-2 CMV Residual Oil Control Factors by Year and Pollutant

Exhibit 5-3 Crosswalk between SCC and FAA Operations Type

Exhibit 5-4 Region-wide Growth Factors from 2007 by FAA Operations Type

Exhibit 5-5 Rail Control Factors by Year, Pollutant, and SCC

Exhibit 7.1 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Allentown, PA

Exhibit 7.2 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Baltimore, MD

Exhibit 7.3 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Hagerstown-Martinsburg, MD-WV

Exhibit 7.4 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Harrisburg-Lebanon-Carlisle-York, PA

Exhibit 7.5 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Johnstown, PA

Exhibit 7.6 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Lancaster, PA

Exhibit 7.7 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Metro New York/Northern New Jersey/Long Island 

NY/NJ/CT

Exhibit 7.8 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Philadelphia-Wilmington, PA/DE/NJ

Exhibit 7.9 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Pittsburgh-Beaver Valley, PA

Exhibit 7.10 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Reading, PA

Exhibit 7.11 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Washington DC/MD/VA

Exhibit 7.12 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: York, PA

Exhibit 8.1 Final Deliverables
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Acronyms and Abbreviations

Acronym Description

CAA Clean Air Act

CAMD Clean Air Markets Division (USEPA)

CEM Continuous emission monitoring 

CMV Commercial marine vessel

CO Carbon monoxide 

EGU Electric generating unit

ERTAC Eastern Regional Technical Advisory Committee

FIPS Federal Information Processing Standard

GSE Ground support equipment

MACT Maximum achievable control technology

MANE-VU Mid-Atlantic/Northeast Visibility Union

MANE-VU+VA MANE-VU states plus Virginia

MAR Marine, airport, rail 

MARAMA Mid-Atlantic Regional Air Management Association

MOBILE6 USEPA model

MOVES Motor Vehicle Emissions Simulator model

NAAQS National Ambient Air Quality Standards

NAICS North American Industry Classification System code

NCD National county database 

NEI National Emission Inventory

NESCAUM Northeast States for Coordinated Air Use Management

NIF3.0 NEI Input Format Version 3.0

NMIM National Mobile Input Model

NOF3.0 NEI Output Format Version 3.0

NONROAD USEPA model

NOx Oxides of nitrogen

ORL One-record-per-line (SMOKE format)

OTAQ Office of Transportation and Air Quality (USEPA)

PFC Portable fuel container

PM-CON Primary PM, condensable portion only ( < 1 micron)

PM-FIL Primary PM, Filterable portion only

PM-PRI Primary PM, includes filterable and condensable

PM-PRI= PM-FIL + PM-CON

PM10-FIL Primary PM10, filterable portion only

PM10-PRI Primary PM10, includes filterable and condensable, 

PM10- PRI = PM0-FIL + PM-CON

PM25-FIL Primary PM2.5, filterable portion only
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Acronym Description

PM25-PRI Primary PM2.5, includes filterable and condensable

PM25-PRI= PM25-FIL + PM-CON

RWC Residential wood combustion

SEMAP Southeast Modeling, Analysis and Planning

SIC Standard Industrial Classification code

SIP State Implementation Plan

SCC Source classification code

S/L State/local

SMOKE Sparse Matrix Operator Kernel Emissions

SO2 Sulfur dioxide

TSD Technical Support Document

USEPA U.S. Environmental Protection Agency

VISTAS Visibility Improvement State and Tribal Association of the Southeast 

VMT Vehicle miles traveled

VOC Volatile organic compounds
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1.0 INTRODUCTION

This technical support document (TSD) explains the data sources, methods, and results for 

preparing emission projections for 2025 for particulate matter (PM) nonattainment areas in 

the Mid-Atlantic / Northeast Visibility Union (MANE-VU) region. The MANE-VU 

region includes Connecticut, Delaware, the District of Columbia, Maine, Maryland, 

Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and 

Vermont. Virginia is not included in the MANE-VU region; however, several cities and 

counties in northern Virginia were included in this inventory as they are part of a 

nonattainment area that includes MANE-VU jurisdictions. 

1.1 INVENTORY PURPOSE

The Clean Air Act (CAA), as amended, requires each state with areas failing to meet the

National Ambient Air Quality Standards (NAAQS) to develop State Implementation Plans 

(SIPs) to expeditiously attain and maintain the standards. The CAA allows states to 

request nonattainment areas to be re-designated to attainment provided certain criteria are 

met. For particulate matter, the U.S. Environmental Protections Agency’s (USEPA’s) redesignation guidance requires the submittal of a comprehensive inventory of direct PM2.5 

emissions and emissions of PM precursors representative of the year when the area 

achieves attainment of the PM2.5 air quality standards. Another emission inventory 

related requirement includes a projection of the emission inventory to a year at least 10 

years following re-designation.

To support state’s efforts in developing PM2.5 maintenance plans and re-designation 

requests, MARAMA issued a contract to AMEC E&I to assemble a comprehensive 

emission inventory for 2025. A workgroup was formed to guide the 2025 inventory 

development process. Participants included a member from each state with a PM2.5 

nonattainment area, as follows: Paul Bodner (CT), Dave Fees and Jack Sipple (DE), Roger 

Thunell (MD), Judy Rand and Danny Wong (NJ), Ron Stannard (NY), Arleen Shulman 

(PA), and Doris McLeod (VA). The committee has met via teleconference on multiple 

occasions to discuss plans for the 2025 inventory. The 2025 inventory was developed 

using a combination of MARAMA’s in-house resources, support from state agencies and 

contractor support from AMEC E&I, Inc. and SRA International, Inc. 

1.2 SOURCE CATEGORIES

This report documents the development of annual emission projections for 2025 for each 

of these sectors, as follows: 
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EGU Point Sources are units that generate electric power and sell most of the 

power generated to the electrical grid. 

NonEGU Point Sources are individual industrial, commercial, and institutional 

facilities and are further subdivided by stack, emission unit, and emission process. 

Stationary Area Sources include sources that in and of themselves are quite small, 

but in aggregate may contribute significant emissions. Examples include small 

industrial/commercial facilities, residential heating furnaces, VOCs volatizing from 

house painting or consumer products, gasoline service stations, and agricultural 

fertilizer/pesticide application. 

Non-road Mobile Sources include internal combustion engines used to propel 

marine vessels, airplanes, and locomotives, or to operate equipment such as 

forklifts, lawn and garden equipment, portable generators, etc. For activities other 

than marine vessels, airplanes, and railroad locomotives (MAR), the inventory was 

developed using the most current version of USEPA’s NONROAD model as 

embedded in the National Mobile Inventory Model (NMIM). Because the 

NONROAD model does not include emissions from MAR sources, these emissions 

were estimated based on data and methodologies used in recent USEPA regulatory 

impact analyses. 

On-road Mobile Sources are sources of air pollution from internal combustion 

engines used to propel cars, trucks, buses, and other vehicles on public roadways. 

Emission projections for on-road mobile sources were developed by MARAMA or 

state staff using USEPA’s Motor Vehicle Emission Simulator (MOVES) model. 

Biogenic/geogenic emissions are not included in this inventory. 

1.3 GEOGRAPHIC AND TEMPORAL RESOLUTION

The geographic area for the 2025 inventory includes only those counties that are classified 

as nonattainment for the annual (1997) or daily (2006) particulate matter NAAQS. The 

inventory was developed at the county-level for non-point sources and at the process level 

for point sources. 

Annual inventories are required for re-designation of areas designated as nonattainment for 

the 1997 and 2006 NAAQS. Other inventory elements required by USEPA (such as 

interim inventory years) are being addressed by individual states in their SIP submittals.
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1.4 POLLUTANTS

The inventory includes emissions for directly emitted PM and PM-precursors (oxides of 

nitrogen {NOx}, and sulfur dioxide {SO2}). The PM species in the inventory are 

categorized as particles with an aerodynamic diameter less than or equal to a nominal 2.5 

micrometers (PM25-PRI), which includes both condensable particles (PM-CON) and 

filterable particles (PM25-FIL). 

1.5 DATA FORMATS

For each sector, we prepared easy-to-review spreadsheets that provide 2007 emissions and 

2025 growth factors, control factors, and emissions. We also prepared county level and 

nonattainment area summaries for all PM nonattainment counties and areas. The 

summaries show the 2007 and 2025 emissions, along with the percent change in emissions 

from 2007 to 2025 for each source sector. 

1.6 INVENTORY VERSIONS

The development of base and future year inventories is an iterative process that continually 

attempts to use the best data available to meet air quality planning needs, given time and 

resource constraints. The following subsections summarize the work completed to date.

1.6.1 Version 2 Modeling Inventories with Existing Controls

MARAMA developed comprehensive emission inventories to support air quality modeling

in the region. MARAMA developed a calendar year 2007 (MARAMA 2011a) inventory 

for all sectors except the onroad sector. These inventories, completed in February of 2011, 

are referred to as Version 2 of the MANE-VU+VA 2007 base year inventory. The 

inventories were provided in formats required for air quality modeling. Under a separate 

effort, the Northeast States for Coordinated Air Use Management (NESCAUM) developed 

a 2007 onroad inventory using the MOVES model to support air quality modeling.

MARAMA also prepared emission projections for 2013/2017/2020 (MARAMA 2011b) 

for all sectors except the electric generation and onroad sectors. These projections reflect a 

scenario representing the best estimates for the future year, accounting for all in-place 

controls that are fully adopted into federal or individual state regulations or SIPs. In the 

past, this inventory is also referred to as the "on-the-books" inventory. Modelers often 

refer to this scenario as the "future base case". 

1.6.2 Version 3 Modeling Inventories with Existing Controls 

Beginning in the fall of 2011, MARAMA sponsored development of Version 3_3 of the 

2007 base year modeling inventory to incorporate new paved road emission estimates, 
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revised modeling of nonroad and onroad sources, and other state-specific changes

(MARAMA2012a). MARAMA developed Version 3_3 of the future year inventory to 

account for changes to the 2007 base year inventory and selected changes in growth and 

control factors identified by states (MARAMA2012b). The future year modeling 

inventories for electric generating units (EGUs) are currently being developed under a 

separate effort lead by the Eastern Regional Technical Advisory Committee (ERTAC). 

The future year modeling inventories for onroad sources are currently being developed by 

NESCAUM, MARAMA or individual states.

1.6.3 Version 3 Modeling Inventories with Potential New Controls 

MARAMA also developed annual emission scenario intended to include all 2017/2020 

existing controls plus any new state measures that are under consideration. This is a "what 

if" scenario that assumes that all states adopt certain new control measures by 2017. 

Modelers sometimes call this the "future control case”. 

1.6.4 Version 3 2025 Inventory for PM Nonattainment Counties 

The 2025 inventory for PM nonattainment counties was developed using Version 3_3 of 

the modeling inventory, with the following exceptions:

Growth and control factors for 2025 were developed for the area, nonEGU point, 

and nonroad MAR sectors, using the same methodologies and data sources that 

were used to develop the 2017/2020 inventories with existing controls. 

For nonroad sources included in NMIM, Version 2 results were available for 2007, 

2017, and 2020. MARAMA and New York made additional NMIM runs for 2025 

based on Version 2 inputs. MARAMA made revisions to some of the inputs to 

NMIM for Version 3_3 of the modeling inventory; however, these revised NMIM 

runs were not used in the 2025 PM nonattainment county inventory due to time 

constraints. 

For onroad sources included in the MOVES model, MARAMA and states executed 

the model in the inventory mode for 2007 and 2025. Version 3_3 of the modeling 

inventory used results of the MOVES model executed in a manner to support air 

quality modeling.

For EGU point sources, the results of the ERTAC EGU projection methodology are 

not currently available. An alternative methodology for projecting EGU emissions 

based on growth and control factors was used, as described in Section 4. 
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Only counties classified as nonattainment for the PM2.5 annual or 24-hour 

NAAQS were included.

Exhibit 1-1 shows the data sources used for the 2025 PM nonattainment area inventory. 

Exhibit 1-2 lists the counties included in the 2025 PM nonattainment area inventory.

1.7 REPORT ORGANIZATION

Sections 2 to 6 describe the emission projection process for the following source sectors: 

area sources; point sources; nonroad mobile sources included in the NMIM model; other 

nonroad mobile sources (marine vessels, aircraft, and railroad locomotives); and onroad 

mobile sources included in the MOVES model. Section 7 provides nonattainment area 

emission pollutant summaries. Section 8 provides a description of the final deliverables, 

including the file names for all final deliverable products. References for the TSD are 

provided in Section 9. 

Exhibit 1.1 – Comparison of Data Used for Version 3 of the Modeling Inventory

and the 2025 PM Nonattainment Inventory

Sector

Modeling Inventory 2025 PM Nonattainment Inventory

2007 2017/2020 2007 2025

Area Version 3_3 Version 3_3 Version 3_3 Version 3_3

Nonroad-NMIM Version 3_3 Version 3_3 Version 2 2025 NMIM run 

based on 

Version 2 inputs

Nonroad-MAR Version 3_3 Version 3_3 Version 3_3 Version 3_3

Onroad MOVES runs by 

NESCAUM to 

support AQ 

modeling

MOVES runs by 

NESCAUM to 

support AQ 

modeling

MOVES runs by 

MARAMA or 

states in 

inventory mode

MOVES runs by 

MARAMA or 

states in 

inventory mode

Point-EGU Version 3_3 To be developed 

by ERTAC

Version 3_3 See section 4 for 

projection 

methodology

Point-nonEGU Version 3_3 Version 3_3 Version 3_3 Version 3_3
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Exhibit 1.2 – List of PM Nonattainment Areas and Counties

Nonattainment Area State

FIPS

Code County

PM Nonattainment?

2006 

Daily

NAAQS

1997 

Annual

NAAQS

Allentown, PA PA 42077 Lehigh Yes Yes

PA 42095 Northampton Yes Yes

Baltimore, MD MD 24003 Anne Arundel No Yes

MD 24005 Baltimore No Yes

MD 24013 Carroll No Yes

MD 24025 Harford No Yes

MD 24027 Howard No Yes

MD 24510 Baltimore City No Yes

Hagerstown-Martinsburg, MD-WV MD 24043 Washington No Yes

Harrisburg-Lebanon-Carlisle-York, PA PA 42041 Cumberland Yes Yes

PA 42043 Dauphin Yes Yes

PA 42075 Lebanon Yes Yes

PA 42133 York* Yes No

Johnstown, PA PA 42021 Cambria Yes Yes

PA 42063 Indiana(P) Yes Yes

Lancaster, PA PA 42071 Lancaster Yes Yes

New York-N. New Jersey-Long Island, CT 09001 Fairfield Yes Yes

NY-NJ-CT CT 09009 New Haven Yes Yes

NJ 34003 Bergen Yes Yes

NJ 34013 Essex Yes Yes

NJ 34017 Hudson Yes Yes

NJ 34021 Mercer Yes Yes

NJ 34023 Middlesex Yes Yes

NJ 34025 Monmouth Yes Yes

NJ 34027 Morris Yes Yes

NJ 34031 Passaic Yes Yes

NJ 34035 Somerset Yes Yes

NJ 34039 Union Yes Yes

NY 36005 Bronx Yes Yes

NY 36047 Kings Yes Yes

NY 36059 Nassau Yes Yes

NY 36061 New York Yes Yes

NY 36071 Orange Yes Yes

NY 36081 Queens Yes Yes

NY 36085 Richmond Yes Yes

NY 36087 Rockland Yes Yes

NY 36103 Suffolk Yes Yes

NY 36119 Westchester Yes Yes

Philadelphia-Wilmington, PA-NJ-DE DE 10003 New Castle Yes Yes

NJ 34005 Burlington Yes Yes

NJ 34007 Camden Yes Yes

NJ 34015 Gloucester Yes Yes

PA 42017 Bucks Yes Yes
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Nonattainment Area State

FIPS

Code County

PM Nonattainment?

2006 

Daily

NAAQS

1997 

Annual

NAAQS

PA 42029 Chester Yes Yes

PA 42045 Delaware Yes Yes

PA 42091 Montgomery Yes Yes

PA 42101 Philadelphia Yes Yes

Pittsburgh-Beaver Valley, PA PA 42003 Allegheny(P) Yes Yes

PA 42005 Armstrong(P) Yes Yes

PA 42007 Beaver Yes Yes

PA 42019 Butler Yes Yes

PA 42059 Greene(P) Yes Yes

PA 42073 Lawrence(P)* Yes Yes

PA 42125 Washington Yes Yes

PA 42129 Westmoreland Yes Yes

Reading, PA PA 42011 Berks No Yes

Washington, DC-MD-VA DC 11001 Washington No Yes

MD 24017 Charles No Yes

MD 24021 Frederick No Yes

MD 24031 Montgomery No Yes

MD 24033 Prince George No Yes

VA 51013 Arlington No Yes

VA 51059 Fairfax No Yes

VA 51107 Loudoun No Yes

VA 51153 Prince William No Yes

VA 51510 Alexandria No Yes

VA 51600 Fairfax City No Yes

VA 51610 Falls Church No Yes

VA 51683 Manassas City No Yes

VA 51685 Manassas 

Park No Yes

York, PA PA 42133 York* No Yes

* York County, PA, is in one nonattainment area for the 2006 24-hour standard (HarrisburgLebanon-Carlisle-York, PA) and another for the 1997 annual standard (York, PA). 

(P) indicates that only part of the county is in the nonattainment area; for this inventory, emissions 

for the entire county are included. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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2.0 AREA SOURCES

2.1 AREA SOURCE CATEGORIES

The area source sector contains emissions estimates for sources which individually are too 

small in magnitude or too numerous to inventory as individual point sources, and which 

can often be estimated more accurately as a single aggregate source for a county. 

Examples are emissions from home heating systems, house painting, consumer products

usage, and small industrial/commercial operations that are not permitted as point sources. 

There are 356 individual area source categories in the MANE-VU+VA inventory, 

categorized by a 10-digit SCC. 

2.2 2007 INVENTORY DEVELOPMENT

The emission projections for the 2025 area source inventory were based on Version 3_3 of 

the 2007 MANE-VU+VA inventory and are fully documented in the TSD for that effort 

(MARAMA 2012a). The only adjustment to the 2007 Version 3_3 area source inventory 

was to apply “transport factors” to fugitive dust sources, as described in the following 

subsection.

2.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections

Grid air quality models consistently overestimate fugitive dust impacts as compared to 

ambient samples. USEPA developed a methodology to reduce fugitive dust emissions for 

use in grid modeling analyses. It is considered a logical step to improve the ability to 

account for the removal of particles near their emission source by vegetation and surface 

features and can be useful in grid-based modeling analyses.

In February 2011, MARAMA developed 2007 emission modeling files for area sources 

which applied the USEPA “transport factor” to reduce fugitive dust emissions to account 

for the removal of particles near their emission source by vegetation and surface features. 

The standard transport fractions and SCC assignments from USEPA’s CHIEF website 

(USEPA 2007a) were used to reduce the PM25-PRI emissions in this inventory. Two files 

were used. Exhibit 2.1 shows the list of nonEGU SCCs for which the transport factor was 

applied. The major source categories included paved and unpaved roads, construction 

activity, agricultural crop land tilling, and agricultural livestock operations. Exhibit 2.2 

lists the transport fractions for PM nonattainment counties which vary by county. For 

example, the transport factors ranges from 0.1375 in Camden, New Jersey to 0.80 in 

Suffolk County, New York. For Virginia, no transport fraction was provided for the City 

of Fairfax; Fairfax County’s transport fraction was used for this jurisdiction.
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 2.1 Area Source SCCs Affected by PM Transport Fraction

SCC SCC Description

2294000000 Paved Roads: All Paved Roads: Total: Fugitives

2296000000 Unpaved Roads: All Unpaved Roads: Total: Fugitives

2311000000 Construction: All Processes: Total

2311010000 Construction: General Building Construction: Total

2311020000 Construction: Heavy Construction: Total

2311030000 Construction: Road Construction: Total

2801000000 Miscellaneous Area Sources;Agriculture Production - Crops;Agriculture - Crops;Total

2801000001 Ag crops: Agriculture - Crops: Land Breaking

2801000002 Ag crops: Agriculture - Crops: Planting

2801000003 Ag crops: Agriculture - Crops: Tilling

2801000004 Ag crops: Agriculture - Crops: Defoliation

2801000005 Ag crops: Agriculture - Crops: Harvesting

2801000006 Ag crops: Agriculture - Crops: Drying

2801000007 Ag crops: Agriculture - Crops: Loading

2801000008 Ag crops: Agriculture - Crops: Transport

2805000000 Ag livestock: Agriculture - Livestock: Total

2805001000 Ag livestock: Beef Cattle Feedlots: Total (also see 2805020000)

2805001001 Ag livestock: Beef Cattle Feedlots: Feed Preparation

2805005000 Ag livestock: Poultry Operations: Total

2805010000 Ag livestock: Dairy Operations: Total 

2805015000 Ag livestock: Hog Operations: Total 

2805020000 Ag livestock: Cattle and Calves Composite: Total

2805025000 Ag livestock: Hogs and Pigs Composite: Total

2805030000 Ag livestock: Poultry and Chickens Composite: Total

2805035000 Ag livestock: Horses and Ponies Composite: Total

2805040000 Ag livestock: Sheep and Lambs Composite: Total

2805045001 Ag livestock: Goats: Total
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 2.2 PM Transport Fractions for PM Nonattainment Counties

State FIPS County

PM Transport 

Fraction

CT 09001 FAIRFIELD 0.4347

CT 09009 NEW HAVEN 0.4442

DE 10003 NEW CASTLE 0.5087

DC 11001 WASHINGTON 0.3953

MD 24003 ANNE ARUNDEL 0.4874

MD 24005 BALTIMORE 0.4047

MD 24013 CARROLL 0.5641

MD 24017 CHARLES 0.4879

MD 24021 FREDERICK 0.4904

MD 24025 HARFORD 0.5147

MD 24027 HOWARD 0.2798

MD 24031 MONTGOMERY 0.3089

MD 24033 PRINCE GEORGES 0.2950

MD 24043 WASHINGTON 0.4003

MD 24510 BALTIMORE (CITY) 0.4874

NJ 34003 BERGEN 0.2657

NJ 34005 BURLINGTON 0.3008

NJ 34007 CAMDEN 0.1375

NJ 34013 ESSEX 0.3461

NJ 34015 GLOUCESTER 0.4361

NJ 34017 HUDSON 0.5286

NJ 34021 MERCER 0.3472

NJ 34023 MIDDLESEX 0.3273

NJ 34025 MONMOUTH 0.5468

NJ 34027 MORRIS 0.2297

NJ 34031 PASSAIC 0.1971

NJ 34035 SOMERSET 0.3635

NJ 34039 UNION 0.3117

NY 36005 BRONX 0.6145

NY 36059 NASSAU 0.6595

NY 36061 NEW YORK 0.6483

NY 36071 ORANGE 0.3803

NY 36081 QUEENS 0.6505

NY 36085 RICHMOND 0.7159

NY 36087 ROCKLAND 0.3556

NY 36103 SUFFOLK 0.7997

NY 36119 WESTCHESTER 0.3531

PA 42003 ALLEGHENY 0.2308

PA 42005 ARMSTRONG 0.3289

PA 42007 BEAVER 0.3141
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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State FIPS County

PM Transport 

Fraction

PA 42011 BERKS 0.4682

PA 42017 BUCKS 0.3980

PA 42019 BUTLER 0.3621

PA 42021 CAMBRIA 0.2253

PA 42029 CHESTER 0.4757

PA 42041 CUMBERLAND 0.4649

PA 42043 DAUPHIN 0.3438

PA 42045 DELAWARE 0.3515

PA 42059 GREENE 0.3224

PA 42063 INDIANA 0.2884

PA 42071 LANCASTER 0.6183

PA 42073 LAWRENCE 0.4422

PA 42075 LEBANON 0.4521

PA 42077 LEHIGH 0.4487

PA 42091 MONTGOMERY 0.3729

PA 42095 NORTHAMPTON 0.4306

PA 42101 PHILADELPHIA 0.3471

PA 42125 WASHINGTON 0.3436

PA 42129 WESTMORELAND 0.2875

PA 42133 YORK 0.5134

VA 51013 ARLINGTON 0.3534

VA 51059 FAIRFAX 0.2457

VA 51107 LOUDOUN 0.3345

VA 51153 PRINCE WILLIAM 0.1814

VA 51510 ALEXANDRIA 0.3745

VA 51610 FALLS CHURCH 0.3400

VA 51683 MANASSAS 0.3474

VA 51685 MANASSAS PARK 0.3551
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 2.3 – Comparison of 2007 Paved Road Dust PM10 Emission Estimates

Nonattainment Area

Without 

Transport Factor

With 

Transport Factor

Version2

Version 3 

New 

Method

Version2

Version 3 

New 

Method

Allentown 4,228 1,733 1,859 764

Baltimore 15,175 5,412 6,658 2,400

Hagerstown 1,490 263 596 105

Harrisburg-Lebanon-Carlisle-York 9,133 4,124 4,149 1,855

Johnstown 2,663 1,133 673 289

Lancaster 4,339 1,808 2,683 1,118

New York-Northern NJ-Long Island-CT 58,512 28,747 29,128 14,260

Philadelphia-Wilmington 29,379 12,644 11,070 4,801

Pittsburgh-Beaver Valley 14,470 6,173 4,491 1,920

Reading 3,346 1,423 1,567 666

Washington, DC-MD-VA 21,067 9,909 6,846 3,194

York 3,684 1,458 1,891 749

Exhibit 2.4 – Comparison of 2007 Paved Road Dust PM2.5 Emission Estimates

Nonattainment Area

Without 

Transport Factor

With 

Transport Factor

Version2

Version 3 

New

Method

Version2

Version 3 

New 

Method

Allentown 264 433 116 191

Baltimore 1,770 1,328 782 589

Hagerstown 196 64 78 26

Harrisburg-Lebanon-Carlisle-York 605 1,031 277 464

Johnstown 198 283 50 72

Lancaster 295 452 182 280

New York-Northern NJ-Long Island-CT 2,400 7,173 1,252 3,547

Philadelphia-Wilmington 1,396 3,165 547 1,202

Pittsburgh-Beaver Valley 942 1,543 299 480

Reading 209 356 98 167

Washington, DC-MD-VA 1,713 2,432 594 784

York 257 365 132 187
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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2.3 2025 INVENTORY DEVELOPMENT

The general procedures and data used for projecting emissions for the area source sector 

are summarized in this section. Growth factors were applied to the MANE-VU+VA 2007 

inventory to account for changes in fuel use, population, economic activity. Next, control 

factors were applied to account for future emission reductions from control regulations. 

The 2025 inventory accounts for post-2007 emission reductions from promulgated federal, 

State, local, and site-specific control programs and proposed control programs that are 

reasonably anticipated to result in post-2007 emission reductions. 

2.3.1 Area Source Growth Factors

The area and nonEGU point source growth factors were developed using six sets of data:

The Annual Energy Outlook (AEO) fuel consumption forecasts;

County-level population projections;

State-level employment projections by NAICS code; 

County-level vehicle miles travelled (VMT) projections; 

USEPA projections for livestock and residential wood combustion; and 

Other state-specific emission projection data.

The priority for applying these growth factors was to first use the state-supplied projection 

data (if available). If state-supplied data were not provided, then the AEO projection 

factors were used for fuel consumption sources, and the population/employment/VMT data 

were used for other source categories. 

2.3.1.1 AEO Fuel Use Projection 

The AEO is published annually by the U.S. Energy Information Administration (EIA). It 

presents long-term projections of energy supply, demand, and prices through 2035, based 

on results from EIA’s National Energy Modeling System (NEMS). NEMS projects the 

production, imports, conversion, consumption, and prices of energy, subject to 

assumptions on macroeconomic and financial factors, world energy markets, resource 

availability and costs, behavioral and technological choice criteria, energy technology cost 

and performance characteristics, and demographics.

AEO provides regional fuel-use forecasts for various fuel types (e.g., coal, residual oil, 

distillate oil, natural gas) by end use sector (e.g., residential, commercial, industrial, 

transportation, and electric power). Energy use projections are reported at the Census 

division level. The census divisions grouped states as follows:

South Atlantic - DE, DC, MD, VA 

Middle Atlantic – NJ, NY, PA 

New England – CT, ME, MA, NH, RI, VT
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Appendices A1, A2, and A3 contain the AEO2010 fuel use projections for each of these 

three regions. Appendices A4, A5, and A6 contain the AEO2011 fuel use projections

Version 2 of the MANE-VU+VA future year inventories was developed using AEO2010

(EIA2010). After the release of Version 2, AEO2011 was published (EIA2011a). 

MARAMA reviewed the updated fuel forecasts and compared the AEO2010 and 

AEO2011 projections. Appendix A7 documents MARAMA’s analysis. MARAMA 

calculated the difference in projected fuel usage between AEO2010 and AEO2011 for the 

residential, commercial, industrial, transportation, and electric power sector for the 

distillate fuel oil, residual fuel oil, coal, natural gas, and renewable fuel types. MARAMA 

identified thresholds for what constitutes a major change as follows:

An increase or decrease of 1% or less is considered to be no change and did not 

warrant a change in the growth factors between Versions 2 and 3 of the inventory;

An increase or decrease of between 1% and 5% is considered to be a minor change, 

and states agreed that these differences between AEO2010 and AEO2011 did not 

warrant a change in the growth factors between Versions 2 and 3 of the inventory;

An increase or decrease above 5% is considered a major change, and warrants a 

change in the growth factors used in Version 3. 

MARAMA recommended that the AEO2010 projections be retained for all residential, 

commercial, and industrial sector fuel use, except for industrial natural gas usage, where 

the AEO2011 projections will be used for Version 3 of the future year modeling inventory. 

New Jersey elected to use the more recent growth factors from AEO2011 instead of the 

AEO2010 growth factors for all area source fossil fuel use categories. 

Exhibits 2.5 to 2.9 summarize the projected fuel use rates by source sector (residential, 

commercial, industrial, transportation) and AEO geographic area for the years 2007 to 

2025. The unusual growth in commercial residual oil use in the South Atlantic region 

could not be explained; Maryland elected to use employment instead of the AEO2010 

growth factor for commercial residual oil combustion, while Virginia and the District 

chose to assume flat growth in this sector.

2.3.1.2 Population Projections

States provided county-level historic population data and projections for future years. The 

historical and projection years varied from state to state, so values were interpolated, when 

necessary, to create population estimates for each year from 2007 to 2025. The population 

data were then normalized to create growth factors from 2007 for each year future year. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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For example, Delaware had a population of 861,087 in 2007, and the projected population 

in 2017 is 953,204. Thus, the growth factor for 2017 is 953,204 / 861,087 = 1.107. 

Exhibit 2.10 summarizes the population growth factors by state and AEO2010 region. 

Population is projected to grow in every state between 2007 and 2025. The population 

growth in the New England states varies significantly by state. Population growth in the 

South Atlantic states is projected to be much higher than in the New England and MidAtlantic states. Appendix B contains the data use to develop the population projections. 

2.3.1.3 Employment Projections 

Every two years, the federal Bureau of Labor Statistics produces long-term industry and 

occupation forecasts for ten future years, and states are asked to do the same for their 

respective economies. The most recent projections are from state Departments of Labor 

for the period 2006 to 2016, most of which were published in 2008. These 10-year 

forecasts are updated every other year. The next set of state-specific projections will be for 

the period 2008 to 2018. Only the District of Columbia and Delaware were able to provide 

employment projections for 2008 to 2017; the 2008 to 2018 projections were not available 

for other states in time for use on this project. The employment projections are state-wide 

by 3-digit NAICS code. Exhibit 2.11 summarizes the manufacturing employment (NAICS 

sector 310) growth factors by state and AEO2010 region. States in the Northeast / MidAtlantic region show a marked decrease in manufacturing employment from 2007 forward. 

Appendix C contains the data that were used to develop the employment projections. 

2.3.1.4 VMT Projections

States developed projections of vehicle miles traveled (VMT) for 2007 and 2025 which 

were used as the growth factor for projecting emissions from re-entrained road dust from 

travel on paved roads (SCC 22-94-000-000). The 2007 and 2025 VMT are identical to 

those used in the MOVES modeling discussed in Section 8. Exhibit 2.12 shows the county 

level VMT for 2007 and 2025, and the growth factor for projecting 2007 emissions to 

2025. Growth factors for 2013, 2017, and 2020 were based on a linear interpolation of the 

2007 and 2025 VMT. Appendix D contains additional information on the data used to 

develop the VMT growth factors. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 2.5 AEO2010 Growth Factors for Coal by AEO Region 2007 – 2025
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Exhibit 2.6 Growth Factors for Residual Oil by AEO Region 2007 – 2025
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Exhibit 2.7 AEO2010 Growth Factors for Distillate Oil by AEO Region 2007 – 2025
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 2.8 Growth Factors for Natural Gas by AEO Region 2007 – 2025

AEO2010 for Residential/Commercial, AEO2011 for Industrial
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 2.9 AEO2010 Growth Factors for Gasoline by AEO Region 2007 – 2025
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Exhibit 2.10 Population Growth Factors by AEO Region 2007 – 2025
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Exhibit 2.11 Manufacturing Employment Growth Factors by Region 2007 - 2025
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Exhibit 2.12 2007 and 2025 VMT and the 2007-2025 Growth Factor

Million VMT Growth

Nonattainment Area County FIPS 2007 2025 2007-2005

Allentown Lehigh 42077 2,947 3,700 1.256

Allentown Northampton 42095 2,020 2,629 1.301

Baltimore Anne Arundel 24003 5,786 7,907 1.367

Baltimore Baltimore 24005 8,261 10,330 1.251

Baltimore Carroll 24013 1,296 1,766 1.363

Baltimore Harford 24025 2,362 3,060 1.296

Baltimore Howard 24027 3,815 6,059 1.588

Baltimore Baltimore City 24510 3,626 4,150 1.145

Hagerstown Washington 24043 2,090 2,940 1.407

Harrisburg-Lebanon-Carlisle-York Cumberland 42041 2,861 3,704 1.295

Harrisburg-Lebanon-Carlisle-York Dauphin 42043 3,072 3,689 1.201

Harrisburg-Lebanon-Carlisle-York Lebanon 42075 1,209 1,507 1.247

Harrisburg-Lebanon-Carlisle-York York 42133 3,304 4,209 1.274

Johnstown Cambria 42021 1,157 1,110 0.959

Johnstown Indiana 42063 844 928 1.100

Lancaster Lancaster 42071 4,255 5,395 1.268

New York Metro NY/NJ/CT Fairfield 9001 7,560 8,568 1.133

New York Metro NY/NJ/CT New Haven 9009 6,856 8,085 1.179

New York Metro NY/NJ/CT Bergen 34003 7,879 10,464 1.328

New York Metro NY/NJ/CT Essex 34013 4,895 6,131 1.253

New York Metro NY/NJ/CT Hudson 34017 2,313 2,801 1.211

New York Metro NY/NJ/CT Mercer 34021 3,566 3,996 1.121

New York Metro NY/NJ/CT Middlesex 34023 7,810 9,748 1.248

New York Metro NY/NJ/CT Monmouth 34025 6,319 8,595 1.360

New York Metro NY/NJ/CT Morris 34027 5,530 6,523 1.180

New York Metro NY/NJ/CT Passaic 34031 2,918 3,490 1.196

New York Metro NY/NJ/CT Somerset 34035 3,230 3,667 1.135

New York Metro NY/NJ/CT Union 34039 4,623 5,730 1.239

New York Metro NY/NJ/CT Bronx 36005 3,677 4,830 1.314

New York Metro NY/NJ/CT Kings 36047 5,461 6,272 1.148

New York Metro NY/NJ/CT Nassau 36059 11,780 14,705 1.248

New York Metro NY/NJ/CT New York 36061 3,938 5,203 1.321

New York Metro NY/NJ/CT Orange 36071 4,431 5,906 1.333

New York Metro NY/NJ/CT Queens 36081 8,859 10,949 1.236

New York Metro NY/NJ/CT Richmond 36085 2,152 3,354 1.558

New York Metro NY/NJ/CT Rockland 36087 2,675 4,060 1.517

New York Metro NY/NJ/CT Suffolk 36103 13,767 20,514 1.485

New York Metro NY/NJ/CT Westchester 36119 8,201 11,811 1.490

Philadelphia PA/DE/NJ New Castle 10003 5,544 6,959 1.255

Philadelphia PA/DE/NJ Burlington 34005 4,704 5,062 1.076
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Million VMT Growth

Nonattainment Area County FIPS 2007 2025 2007-2005

Philadelphia PA/DE/NJ Camden 34007 4,090 4,267 1.043

Philadelphia PA/DE/NJ Gloucester 34015 2,723 3,284 1.206

Philadelphia PA/DE/NJ Bucks 42017 5,047 6,516 1.291

Philadelphia PA/DE/NJ Chester 42029 4,423 6,201 1.402

Philadelphia PA/DE/NJ Delaware 42045 3,766 4,371 1.161

Philadelphia PA/DE/NJ Montgomery 42091 7,075 8,220 1.162

Philadelphia PA/DE/NJ Philadelphia 42101 5,973 6,337 1.061

Pittsburgh-Beaver Valley Allegheny 42003 9,345 10,134 1.084

Pittsburgh-Beaver Valley Armstrong 42005 628 672 1.071

Pittsburgh-Beaver Valley Beaver 42007 1,487 1,585 1.066

Pittsburgh-Beaver Valley Butler 42019 1,762 2,173 1.233

Pittsburgh-Beaver Valley Greene 42059 464 504 1.086

Pittsburgh-Beaver Valley Lawrence 42073 812 880 1.084

Pittsburgh-Beaver Valley Washington 42125 2,245 2,531 1.127

Pittsburgh-Beaver Valley Westmoreland 42129 3,512 3,898 1.110

Reading Berks 42011 3,341 4,079 1.221

Washington DC/MD/VA DC 11001 3,666 3,861 1.053

Washington DC/MD/VA Charles 24017 1,284 1,825 1.421

Washington DC/MD/VA Frederick 24021 3,009 4,442 1.476

Washington DC/MD/VA Montgomery 24031 7,471 9,711 1.300

Washington DC/MD/VA Prince George's 24033 8,754 11,616 1.327

Washington DC/MD/VA Arlington 51013 1,663 1,917 1.153

Washington DC/MD/VA Fairfax 51059 10,123 13,880 1.371

Washington DC/MD/VA Loudoun 51107 2,403 3,741 1.557

Washington DC/MD/VA Prince William 51153 3,202 4,643 1.450

Washington DC/MD/VA Alexandria 51510 736 866 1.177

Washington DC/MD/VA Fairfax 51600 193 220 1.143

Washington DC/MD/VA Falls Church 51610 64 76 1.186

Washington DC/MD/VA Manassas 51683 273 360 1.317

Washington DC/MD/VA Manassas Park 51685 26 30 1.166
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2.3.1.5 No Growth Assignment for Certain Area Source Categories

For several area source categories, it seems reasonable that emissions would not change 

from the 2007 values. No growth was applied to the 2007 emissions for the area source 

categories shown in Exhibit 2.13. 

Exhibit 2.13 Area Source Categories with No Growth Assignment 

SCC SCC Description

2296000000 Unpaved Roads /All Unpaved Roads /Total: Fugitives

2401008000 Surface Coating /Traffic Markings /Total: All Solvent Types

2461020000 Misc Non-industrial: Commercial /Asphalt Application: All Processes /Total: All

2461021000 Misc Non-industrial: Commercial /Cutback Asphalt /Total: All Solvent Types

2461022000 Misc Non-industrial: Commercial /Emulsified Asphalt /Total: All Solvent Types

2461023000 Misc Non-industrial: Commercial /Asphalt Roofing /Total: All Solvent Types

2601000000 On-site Incineration /All Categories /Total

2601010000 On-site Incineration /Industrial /Total

2601010000 On-site Incineration /Industrial /Total

2601020000 On-site Incineration /Commercial/Institutional /Total

2601020000 On-site Incineration /Commercial/Institutional /Total

2601030000 On-site Incineration /Residential /Total

2610000100 Open Burning /All Categories /Yard Waste - Leaf Species Unspecified

2610000400 Open Burning /All Categories /Yard Waste - Brush Species Unspecified

2610000500 Open Burning /All Categories /Land Clearing Debris (use 28-10-005-000 for Logging

2610030000 Open Burning /Residential /Household Waste (use 26-10-000-xxx for Yard Wastes)

2610040400 Open Burning /Municipal (from residences, parks, other for central burn) 

2660000000 Leaking Underground Storage Tanks /Leaking Underground Storage Tanks /Total: All

2680001000 Composting /100% Biosolids (e.g., sewage sludge, manure, mixtures of these matls

2680002000 Composting /Mixed Waste (e.g., a 50:50 mixture of biosolids and green wastes)

2806010000 Domestic Animals Waste Emissions /Cats /Total

2806015000 Domestic Animals Waste Emissions /Dogs /Total

2807020001 Wild Animals Waste Emissions /Bears /Black Bears

2807020002 Wild Animals Waste Emissions /Bears /Grizzly Bears

2807025000 Wild Animals Waste Emissions /Elk /Total

2807030000 Wild Animals Waste Emissions /Deer /Total

2807040000 Wild Animals Waste Emissions /Birds /Total

2810001000 Forest Wildfires - Wildfires – Unspecified

2810003000 Cigarette Smoke /Total

2810005000 Managed Burning, Slash (Logging Debris) /Unspecified Burn Method

2810010000 Human Perspiration and Respiration /Total

2810014000 Prescribed Burning /Generic - Unspecified land cover, ownership, class/purpose
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SCC SCC Description

2810015000 Prescribed Forest Burning /Unspecified

2810020000 Prescribed Rangeland Burning /Unspecified

2810030000 Structure Fires /Unspecified

2810035000 Firefighting Training /Total

2810050000 Motor Vehicle Fires /Unspecified

2810060200 Cremation /Animals

2810090000 Open Fire /Not categorized

2820010000 Cooling Towers /Process Cooling Towers /Total

2830000000 Catastrophic/Accidental Releases /All Catastrophic/Accidental Releases /Total

2830010000 Catastrophic/Accidental Releases /Transportation Accidents /Total

2.3.1.6 USEPA 2020 Projections for Residential Wood 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform. MARAMA decided to use USEPA emission projection parameters for 

residential wood combustion. USEPA’s methodology and data sources are summarized 

below (USEPA 2010a). 

USEPA projected residential wood combustion emissions are based on the expected 

increase in the number of low-emitting wood stoves and the corresponding decrease in 

other types of wood stoves. As newer, cleaner woodstoves replace older, more polluting 

stoves, there will be an overall reduction of emissions from this category. The approach 

used by USEPA was developed as part of a modeling exercise to estimate the expected 

benefits of the woodstove change-out program. This methodology uses a combination 

growth and control factors and is based on activity not pollutant. The growth and control 

are accounted for in a single factor for each residential wood SCC (certain SCCs represent 

controlled equipment, while other SCCs represent uncontrolled equipment). Control

factors are indirectly incorporated based on which stove is used. The specific assumptions 

USEPA made were:

Fireplaces, SCC=2104008001: increase 1%/year; 

Old woodstoves, SCC=2104008002, 2104008010, 2104008051: decrease 2%/year;

New woodstoves, SCC=2104008003, 2104008004, 2104008030, 2104008050,

2104008052 or 2104008053: increase 2%/year.

For the general woodstoves and fireplaces category (SCC 2104008000) USEPA computed 

a weighted average distribution based on 19.4% fireplaces, 71.6% old woodstoves, 9.1% 

new woodstoves using 2002 Platform emissions for PM2.5. These fractions are based on 

the fraction of emissions from these processes in the states that did not have the “general 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 27

woodstoves and fireplaces” SCC in the 2002 NEI. This approach results in an overall 

decrease of 1.056% per year for this source category. Appendix E contains the residential 

wood projection data from USEPA. 

2.3.1.7 SCC, SIC, NAICS and Growth Parameter Crosswalk

Since the employment projections were based on 3-digit NAICS code, it was necessary to 

map NAICS codes to SCCs and SIC codes that were used by states. Employment 

projections at the more specific 4-digit or 6-digit NAICS codes were not available. 

The first step for developing a comprehensive crosswalk between the different source 

classification codes (SCC, SIC, and NAICS codes) and emission activity growth indicators 

was to compile a complete list of the NAICS codes in the 2007 point source inventory. 

Some states use the SIC code while other use the NAICS code. Still other states use both 

the SIC and NAICS codes. When the NAICS code was not available SIC codes were 

converted to NAICS codes. The 6-digit NAICS code was truncated to a 3-digit code, 

which represents major industry subsectors of the economy. A U.S. Census Bureau 

document was used to perform this conversion (CENSUS 2000). 

The next step was to review parameters that could be used as the emission activity growth 

indicator for each SCC or NAICS. We initially relied on two USEPA crosswalks (USEPA 

2004a, USEPA 2004b) to match area and nonEGU point source SCCs to AEO2010 

categories, employment NAICS codes, and population. 

2.3.1.8 Final Version 2 Growth Factors for Area Sources

The previous sections described the initial growth factors recommended to develop 

projected future year emissions inventories for area and non-EGU sources. Draft growth 

and control factors, and a draft technical support document, were circulated for review by 

MARAMA and state agencies. During the review, it was noted that several emissions 

categories show negative growth into the future, particularly categories related to fossil 

fuel combustion and manufacturing employment. 

Many of the growth factors used to project emissions for area and non-EGU sources were 

based on the AEO2010 fuel consumption forecasts and state-level employment projections. 

The AEO2010 forecasts show declining trends for many fuel consumption sectors, 

especially industrial, residential, and commercial distillate fuel oil use. Similarly, the 

employment projections show declines in the predicted number of employees for many 

sectors of the economy. This is particularly true for the manufacturing sector, which is of 

interest because this sector is often associated with higher emissions than those for other 

sectors. By contrast, the employment projections show increasing trends in retail and 
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service-related sectors. However, these sectors are not typically associated with significant 

emissions.

Predicted declines in fuel use and employment resulted in growth factors less than unity 

(i.e., represent negative growth) for many area and non-EGU point source categories. 

Consequently, for some categories, emissions were initially projected to be lower for the 

projected future years than for the base year, even before the application of control 

assumptions (i.e., the future "growth only" emissions are lower than the base year 

emissions). A conference call was held to discuss the negative growth issue, and states

were polled as to whether or not they felt that the current set of proposed growth factors -

including the negative growth factors - were realistic for their state. In reply, some 

representatives mentioned that they have observed historic state-specific data that supports 

the trends displayed by the proposed growth factors. Other representatives mentioned that 

they feel comfortable with the growth factors and don't have a technical basis to change 

them or suggest others. Some states will supply their own factors or make their own 

assumptions. 

As a result of these discussions, each state provided guidance on how to handle projections 

when negative growth is indicated. Exhibit 2.14 shows the state recommendations for area 

sources. 

2.3.1.9 Version 3 Update to New Jersey Growth Factors for Area Sources 

New Jersey provided updated growth factors for area source for use in developing the 2025 

inventory for PM nonattainment counties. One of the key revisions was to use the more 

recent data from AEO2011 for energy consumption instead of the AEO2010 projections. 

New Jersey also provided updated employment, paved road, pesticide and agricultural 

livestock growth factors. 

2.3.1.10 Version 3 Update to Growth Factors for the District of Columbia

The District of Columbia provided updated employment growth factors based on DC 

Department of Labor forecasts for the period 2008 to 2018. 
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Exhibit 2-14 State Recommendations to Address Negative Growth 

and Other Growth Factors for the Area Source Sector

State AEO2010 

Growth Factors

Employment 

Growth Factors

Population 

Growth Factors

CT Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS 

Use county-level 

population projections

DE Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

For 2013, use state DOL 

employment projections by 3-digit 

NAICS; For 2017 and 2020, use 

no growth (growth factor=1) when 

employment growth is negative; 

otherwise use employment if 

positive growth

Use county-level 

population projections

DC Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

Use DOL employment growth for 

NAICS 722 for food and kindred 

product SCC; otherwise use 

2008-2018 data

For dry cleaning, use 

employment growth for 

NAICS 812 instead of 

population

MD Not using AEO2010; used 

employment for commercial & 

institutional fuel; used housing 

units for residential fuel

Provided updated employment 

projections; changed cross-walk 

between NAICS code and SCC 

for selected source categories

Provided updated 

population projections 

by county

NJ NJ submitted state specific 

growth factors. For fuel 

combustion categories only, 

used AEO2011 growth rates 

except for residual oil (use no 

growth)

NJ submitted state specific 

growth factors.

NJ submitted state 

specific growth factors 

and provided 

population projections 

by county

NY Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

PA Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

VA Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections
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2.3.2 Area Source Control Factors

Control factors were developed to estimate post-2007 emission reductions resulting from 

on-the-books regulations and other emission reduction measures. Control factors were 

developed for the following national, regional and state measures:

Federal Rules Affecting Area Sources

Federal MACT Rules 

OTC 2001 Model Rules 

OTC 2006 Model Rules 

MANE-VU Sulfur in Fuel Oil Limitations

These control programs, including their impact on PM2.5 and PM precursor emissions, are 

discussed in the following subsections. 

2.3.2.1 Federal Rules Affecting Area Sources 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform (USEPA 2010a). USEPA accounted for control strategies for four area 

source categories, only one of which reduced emissions of PM2.5 or PM2.5 precursors. 

USEPA developed projection factors to account for the replacement of retired woodstoves 

that were installed before promulgation of the new source performance standard (NSPS). 

We used USEPA’s latest methodology which uses a combination growth and control factor 

and is based on activity and not pollutant. The growth and control are accounted for in a 

single factor for specific SCCs that account for the turnover from pre-NSPS to post-NSPS 

woodstove.

2.3.2.2 Federal MACT Rules 

USEPA developed guidance for estimating VOC and NOx emission changes from MACT 

Rules (USEPA 2007b). We reviewed the guidance to identify area source controls 

associated with the federal maximum achievable control technology (MACT) standards for 

controlling hazardous air pollutants (HAPs). Although designed to reduce HAPs, many of 

the MACT standards also provide a reduction in criteria air pollutants. USEPA’s guidance

document provides an estimate of the percent reduction in VOC and NOx from each 

standard, and the compliance date for the standard. The information concerning MACT 

compliance periods provided was used to determine whether the MACT standard provided 

post-2007 emission reductions. For example, if a compliance period of a MACT standard 

was 2007 or earlier, then we assumed that the emission reductions from the MACT 

standard should be reflected in the baseline year and not as an additional post-2007 credit. 
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Only one area source category was listed in USEPA’s guidance document - municipal 

solid waste landfills. As the compliance date for this standard was January 2004, no post2007 reductions were applied because the emission reductions from the MACT standard 

should be reflected in the 2007 inventory and not as an additional post-2007 credit. 

USEPA has or will soon develop MACT standards for about 70 area source categories. 

We reviewed USEPA’s 2020 emissions projections described in the previous section and 

found that USEPA did not include emission reductions from recent area source MACT

standards. We conducted a review of USEPA’s air toxic website and found that USEPA 

determined that many area source MACT standards would result in nationwide reductions 

in criteria air pollutants in addition to the reductions in HAP emissions. However, many 

States in the MANE-VU+VA region already have emission standards for many categories 

that are as stringent as the Federal area source MACT standards. For example, many states

in the MANE-VU+VA region already have requirements as stringent as the Gasoline 

Distribution MACT and GACT (generally achievable control technology) standards, and 

little additional VOC reductions would be realized in the region. Given the resources 

allocated to this project, it was beyond the scope to conduct an analysis of the area source 

MACT requirements and state-by-state emission regulations to determine whether there 

would be emission reductions resulting from the area source MACT standards. 

The only exception to the above discussion of area source MACT standards pertains to the 

recently promulgated rules for reciprocating internal combustion engines (RICE). USEPA 

made available an estimate of the percent reduction in emissions attributable to the RICE 

MACT rule in 2012 and 2014 (USEPA 2010b). These reductions by SCC are shown in 

Exhibit 2-15. The USEPA 2014 estimates were used for the MANE-VU+VA 2017, 2020

and 2025 inventories. 

2.3.2.3 OTC Model Rules for VOC Sources 

The Ozone Transport Commission (OTC) developed model rules for its member states in 

2002 for several area source VOC categories: consumer products, architectural and 

industrial maintenance (AIM) coatings, portable fuel containers (PFCs), mobile equipment 

repair and refinishing, and solvent cleaning (OTC 2001). In 2006 the OTC introduced

model rules for two additional area source categories (adhesives/sealants and asphalt 

paving) and more stringent requirements for consumer products and portable fuel 

containers (OTC 2007). These rules resulted in reductions of VOC emissions. Because 

VOC emissions are generally not considered to be significant PM precursors, and these 

rules did not result in reductions in PM2.5 or precursor emissions, no further discussion of 

the OTC model rules for VOC sources is warranted. 
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Exhibit 2-15 USEPA Estimated Percent Reductions for RICE MACT Standard

SCC NOx PM2.5 SCC Description

2101004000 7.57 Electric Utility;Distillate Oil;Total: Boilers and IC Engines

2101004002 11.81 Electric Utility;Distillate Oil;All IC Engine Types

2101006000 7.97 Electric Utility;Natural Gas;Total: Boilers and IC Engines

2101006002 9.87 Electric Utility;Natural Gas;All IC Engine Types

2102004000 7.57 Industrial;Distillate Oil;Total: Boilers and IC Engines

2102006000 7.97 Industrial;Natural Gas;Total: Boilers and IC Engines

2102006002 9.87 Industrial;Natural Gas;All IC Engine Types

2103004000 7.57 Commercial/Institutional;Distillate Oil;Total: Boilers and IC 

Engines

2103006000 7.97 Commercial/Institutional;Natural Gas;Total: Boilers and IC 

Engines

2199004000 7.57 Area Source Fuel Combustion;Distillate Oil;Total: Boilers and IC 

Engines

2199004002 11.81 Area Source Fuel Combustion;Distillate Oil;All IC Engine Types

2199006000 7.97 Area Source Fuel Combustion;Natural Gas;Total: Boilers and IC 

Engines

2310000000 12.53 Oil and Gas Production: All Processes;Total: All Processes

2310000220 12.53 Oil and Gas Exploration/Production; Drill Rigs

2310000440 12.53 Oil and Gas Exploration/Production; Saltwater Disposal Engines

2310001000 12.53 Oil and Gas Production: SIC 13; On-shore;Total: All Processes

2310002000 12.53 Oil and Gas Production: SIC 13; Off-shore;Total: All Processes

2310020000 12.53 Oil and Gas Production: SIC 13;Natural Gas;Total: All Processes

2310020600 12.53 Oil and Gas Exploration and Production;Natural Gas;Compressor 

Engines

2310023000 12.53 Oil and Gas Exploration and Production;Natural Gas;Cbm Gas 

Well - Dewatering Pump Engines

2.3.2.4 OTC Model Rule for ICI Boilers

The OTC recommended that member states pursue state-specific rulemakings or other 

implementation methods to achieve NOx emission reduction for industrial, commercial, 

and institutional (ICI) boilers based on guidelines that varied by boiler size and fuel type. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in NOx emissions should be applied in 2013, 2017, and 2020. 

All but one state, New Jersey, indicated that they have not adopted rules for area sources 

equivalent to the 2006 OTC recommendations. New Jersey specified that the state has 

post-2007 ICI boiler rules that reduce NOx emissions and provided the estimates of the 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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reductions in NOx emissions by SCC resulting from boiler tune-up requirements, as shown 

in Exhibit 2.16: 

Exhibit 2.16 Area Source Emission Reductions from 

New Jersey ICI Boiler NOx Rules

SCC SOURCE 

CATEGORY

Percent

Reduction 

from Tuneups 2007-

2013

Rule 

Effectivenes

s

Rule 

Penetratio

n

Overall 

Percent 

Reduction 

2007-2013

2102004000 Industrial: Distillate 25% 80% 30% 6%

2102005000 Industrial: Residual 25% 80% 30% 6%

2102006000 Industrial: Nat Gas 25% 80% 30% 6%

2102007000 Industrial: LPG 25% 80% 30% 6%

2103004000 Comm/Inst: Distillate 25% 80% 30% 6%

2103005000 Comm/Inst: Residual 25% 80% 30% 6%

2103006000 Comm/Inst: Nat Gas 25% 80% 30% 6%

2103007000 Comm/Inst - LPG 25% 80% 30% 6%

2.3.2.5 MANE-VU Fuel Oil Sulfur Strategy

MANE-VU developed a low sulfur fuel oil strategy to help states develop Regional Haze 

SIPs (MANE_VU 2007). The sulfur in fuel oil recommendations are shown in Exhibit 

2.17 and vary by state, type of fuel oil, and year of implementation. 

Exhibit 2.17 MANE-VU Low Sulfur Fuel Oil Strategy 

Inner Zone States (DE, NJ, NY, PA)

Fuel Oil Type Sulfur Content

2012

Sulfur Content

2016

Distillate 500 ppm 15 ppm

#4 Residual 0.25 % 0.25 %

#6 Residual 0.3 to 0.5 % 0.3 to 0.5 %

Outer Zone States (CT, DC, MD)

Fuel Oil Type Sulfur Content

2014

Sulfur Content

2018

Distillate 500 ppm 15 ppm

#4 Residual n/a 0.25 to 0.5 %

#6 Residual n/a 0.5 %
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Each state was polled and asked to provide guidance as to when, if at all, the MANE-VU 

strategy would be incorporated into their state rules. States were also asked to provide the 

2007 sulfur contents for each fuel type by county in order to calculate the percent reduction 

in emissions for the future years. Three states (MD, NJ, NY) have adopted or are 

committed to adopting the strategy into their rules. Four jurisdictions (CT, DC, DE, PA) 

indicated that not enough regulatory development progress has been made to include the 

reductions in future years with absolute certainty. One state (VA) has no plans to adopt the 

low sulfur fuel oil strategy. The response from each jurisdiction is summarized below: 

Connecticut will not include the reductions from MANE-VU low sulfur fuel oil 

strategy at this time for official SIP inventories used for the PM2.5 redesignation 

effort. Section 16a-21a of the Connecticut General Statutes (as amended by PA 10-

74) conditions implementation of number two heating oil sulfur limitation (50 ppm 

beginning 7/1/2011 and 15 ppm beginning 7/1/2014) on similar implementation in 

NY, MA and RI. NY has taken action, but the other states have not done so yet. 

CTDEP expects that 15ppm residential heating oil will be in place in CT by the 

"MANE-VU Ask" 2018 target date. However, until the other states act, SIP 

emission inventories will not be approvable with the 15 ppm value. Therefore, at 

this time CT elects to retain the 2007 sulfur value through 2025. For residual oil, 

Section 22a-174-19a of the Regulations of CT State Agencies (RCSA) limits 

sources >=15MW and boilers >=250 mmBtu/hr to 0.5% and further limits any of 

those sources that are also Title IV acid rain sources to 0.3%. For affected sources, 

these limits are consistent with the "MANE-VU Ask", and should be reflected in 

the actual emissions incorporated into the 2007 point source inventory. Other 

sources (including most area sources) not otherwise restricted by permit/order are 

limited to 1.0% by RCSA 22a-174-19. As both of these regulations have not 

changed after 2007, there are no new controls (i.e., post 2007 control factors are 

1.0) for residual oil.

The District of Columbia does not have a low sulfur rule in place yet. They do 

have a draft, and anticipate adopting a rule by 2014, but are inclined not to take 

credit for reductions at this point in time. 

Delaware’s low-sulfur fuel regulation development is running behind schedule and 

will not be promulgated done in time to include in the re-designation 

requests/maintenance plans. Emission reductions from MANE-VU low sulfur fuel 

oil strategy are not included in the 2025 inventory at this time.

Maryland expects to revise COMAR 26.11.09.07 (Sulfur Content Limitations for 

Fuel) by 2014 to adopt the limits in the MANE-VU low sulfur fuel oil strategy. 
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New Jersey has revised N.J.A.C. 7:27-9.2 (Sulfur content standards) to adopt the 

2016 sulfur content limits and schedule shown in Exhibit 2.19. All of the PM 

nonattainment counties in New Jersey already meet the MANE-VU limits for 

residual oil. 

New York adopted a law that limits the sulfur content of No. 2 heating oil to no 

more than 15 parts per million starting in July 2012, down from the current range 

of 2,000 to 15,000 parts per million. New York expects to revise 6 NYCRR 

Subpart 225-1 (Fuel Composition and Use - Sulfur Limitations) to lower the sulfur 

content of distillate fuel oil for all stationary sources (including home heating) and 

stationary internal combustion engines. Nearly all of the PM nonattainment 

counties in New York already meet the MANE-VU limits for residual oil. For the 

two counties (Orange and Suffolk), compliance with the MANE-VU limits is 

expected by 2017.

Pennsylvania low-sulfur fuel regulation development is running behind schedule 

and will not be promulgated done in time to include in the re-designation 

requests/maintenance plans. Emission reductions from MANE-VU low sulfur fuel 

oil strategy are not included in the 2025 inventory at this time.

Virginia will not include the emission reductions from low sulfur fuel oil, as it is

not part of MANE-VU and has no plans to adopt the low sulfur fuel oil strategy. 

The state responses regarding the currently adopted sulfur contents for home heating oil, 

distillate oil, and residual oil are summarized in Exhibits 2.18, 2.19 and 2.20, respectively. 

For the purposes of developing the 2025 inventory that will be used for re-designations and 

maintenance plans, the sulfur contents and control factors shown in the Exhibits were used 

on a county-by-county basis to account for the emission reductions from the MANE-VU 

low sulfur fuel oil strategy. There are separate columns in the detailed area source 

inventory spreadsheet that specify SO2 control factors and emissions for each projection 

year for a “currently adopted” scenario that includes reductions for states (MD, NJ, NY) 

that have or are committed to having rules in place. No emission reductions are applied for 

the other states (CT, DC, DE, PA, VA) in the “currently adopted” scenario. 

For other air quality planning purposes, we accounted separately for emission reductions 

that would occur assuming all states fully adopt the MANE-VU low sulfur fuel limits by 

2025. There are separate columns for SO2 control factors and emissions for a “fully 

adopted” scenario where all states (except Virginia) have the MANE-VU low sulfur fuel 

oil limits in place. 
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Exhibit 2.18 Currently Adopted Sulfur Content and Control Factors for Residential Fuel Oil Combustion

Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

CT 09009 New Haven 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DE 10003 New Castle 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DC 11001 Washington 1000 1000 1000 1000 1000 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24005 Baltimore 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24013 Carroll 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24017 Charles 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24021 Frederick 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24025 Harford 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24027 Howard 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24031 Montgomery 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24033 Prince Georges 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24043 Washington 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24510 Baltimore City 3000 3000 15 15 15 1.000 0.005 0.005 0.005

NJ 34003 Bergen 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34005 Burlington 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34007 Camden 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34013 Essex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34015 Gloucester 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34017 Hudson 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34021 Mercer 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34023 Middlesex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34025 Monmouth 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34027 Morris 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34031 Passaic 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075
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Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34039 Union 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NY 36005 Bronx 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36047 Kings 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36059 Nassau 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36061 New York 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36071 Orange 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36081 Queens 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36085 Richmond 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36087 Rockland 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36103 Suffolk 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36119 Westchester 3700 15 15 15 15 0.004 0.004 0.004 0.004

PA 42003 Allegheny 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42005 Armstrong 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42007 Beaver 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42011 Berks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42017 Bucks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42019 Butler 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42021 Cambria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42029 Chester 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42041 Cumberland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42043 Dauphin 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42045 Delaware 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42059 Greene 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42063 Indiana 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42071 Lancaster 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42073 Lawrence 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42075 Lebanon 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
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Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42091 Montgomery 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42095 Northampton 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42125 Washington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42133 York 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51013 Arlington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51059 Fairfax 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51107 Loudoun 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51153 Prince William 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51510 Alexandria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51610 Falls Church 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51683 Manassas City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51685 Manassas Park City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
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Exhibit 2.19 Currently Adopted Sulfur Content and Control Factors for Distillate Fuel Oil Combustion

Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

CT 09009 New Haven 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DE 10003 New Castle 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DC 11001 Washington 1000 1000 1000 1000 1000 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24005 Baltimore 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24013 Carroll 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24017 Charles 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24021 Frederick 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24025 Harford 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24027 Howard 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24031 Montgomery 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24033 Prince Georges 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24043 Washington 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24510 Baltimore City 3000 3000 15 15 15 1.000 0.005 0.005 0.005

NJ 34003 Bergen 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34005 Burlington 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34007 Camden 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34013 Essex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34015 Gloucester 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34017 Hudson 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34021 Mercer 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34023 Middlesex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34025 Monmouth 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34027 Morris 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34031 Passaic 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075
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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34039 Union 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NY 36005 Bronx 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36047 Kings 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36059 Nassau 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36061 New York 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36071 Orange 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36081 Queens 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36085 Richmond 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36087 Rockland 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36103 Suffolk 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36119 Westchester 3700 3700 15 15 15 1.000 0.004 0.004 0.004

PA 42003 Allegheny 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42005 Armstrong 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42007 Beaver 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42011 Berks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42017 Bucks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42019 Butler 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42021 Cambria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42029 Chester 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42041 Cumberland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42043 Dauphin 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42045 Delaware 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42059 Greene 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42063 Indiana 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42071 Lancaster 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42073 Lawrence 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42075 Lebanon 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42091 Montgomery 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42095 Northampton 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42125 Washington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42133 York 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51013 Arlington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51059 Fairfax 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51107 Loudoun 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51153 Prince William 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51510 Alexandria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51610 Falls Church 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51683 Manassas City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51685 Manassas Park City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
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Exhibit 2.20 Currently Adopted Sulfur Content and Control Factors for Residual Fuel Oil Combustion

Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

CT 09009 New Haven 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

DE 10003 New Castle 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

DC 11001 Washington 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24005 Baltimore 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24013 Carroll 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24017 Charles 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24021 Frederick 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24025 Harford 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24027 Howard 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24031 Montgomery 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24033 Prince Georges 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24043 Washington 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24510 Baltimore City 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

NJ 34003 Bergen 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34005 Burlington 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34007 Camden 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34013 Essex 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34015 Gloucester 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34017 Hudson 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34021 Mercer 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34023 Middlesex 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34025 Monmouth 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34027 Morris 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34031 Passaic 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000
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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34039 Union 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36005 Bronx 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36047 Kings 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36059 Nassau 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

NY 36061 New York 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36071 Orange 1.5 1.5 0.5 0.5 0.5 1.000 0.333 0.333 0.333

NY 36081 Queens 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36085 Richmond 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36087 Rockland 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

NY 36103 Suffolk 1 1 0.5 0.5 0.5 1.000 0.500 0.500 0.500

NY 36119 Westchester 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

PA 42003 Allegheny 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42005 Armstrong 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42007 Beaver 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42011 Berks 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42017 Bucks 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42019 Butler 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42021 Cambria 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42029 Chester 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42041 Cumberland 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42043 Dauphin 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42045 Delaware 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42059 Greene 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42063 Indiana 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42071 Lancaster 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42073 Lawrence 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42075 Lebanon 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000
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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42091 Montgomery 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42095 Northampton 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42125 Washington 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42133 York 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

VA 51013 Arlington 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51059 Fairfax 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51107 Loudoun 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51153 Prince William 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51510 Alexandria 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51610 Falls Church 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51683 Manassas City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51685 Manassas Park City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000
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3.0 POINT SOURCES

3.1 POINT SOURCE CATEGORIES

States were asked to classify units in the 2007 MANE-VU+VA point source emissions 

inventory as either EGU or nonEGU. Most, but not all, units that report hourly emissions 

to USEPA’s Clean Air Markets Division (CAMD) are classified as EGUs. 

CAMD implements USEPA’s rule found in Volume 40 Part 75 of the Code of Federal 

Regulations (CFR), which requires an hourly accounting of emissions from each affected 

unit - i.e., sources participating in an emissions cap and trade program under the Acid 

Rain Control Program, the NOx Budget Trading Program, or the Clean Air Interstate Rule. 

Most of the CAMD sources are traditional power plants that sell electricity to the electrical 

grid. However, there are other types of sources that report to CAMD that are not 

considered to be EGUs, such as petroleum refineries and cement kilns. 

The following criteria was provided to states to classify a unit as an EGU:

An EGU sells most of the power generated to the electrical grid; 

An EGU burns mostly commercial fuel. Commercial fuel in this case means 

natural gas, oil, and coal. Wood is not considered a commercial fuel because some 

states identify wood as renewable. Therefore, to avoid double counting, units that 

burn wood and other renewable sources (depending on each state's own definition) 

should not be considered as an EGU (unless it is already in the CAMD database).

The following units were not considered EGUs for emission projections: (1) a unit that 

generates power for a facility but occasionally sells to the grid; (2) emergency generators; 

or (3) distributed generation units.

The emission projection methodology for units classified as nonEGUs is discussed in 

Section 3.3. The emission projection methodology for EGUs is discussed in Section 3.4. 

3.2 2007 INVENTORY DEVELOPMENT

The emission projections for the 2025 point source were based on Version 3_3 of the 2007 

MANE-VU+VA inventory and are fully documented in the TSD for that effort 

(MARAMA 2012a). The only adjustment to the 2007 Version 3_3 point source source 

inventory was to apply “transport factors” to fugitive dust sources, as described in the 

following subsection.
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3.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections

As described previously in Section 2.2.1.1, PM2.5 emissions for point sources were 

adjusted using the USEPA PM transport fractions for fugitive dust sources. Exhibit 3.1 

shows the list of nonEGU SCCs for which the transport factor was applied. The major 

source categories included various operations in the mineral products and construction 

industries. Exhibit 2.2 in the previous Section 2 shows the transport fractions for each PM 

nonattainment county. 

Exhibit 3.1 NonEGU Point Source SCCs Affected by PM Transport Fraction

SCC SCC Description

30300519 Prim Metal Prod: Primary Copper Smelting: Unpaved Road Traffic: Fug Emiss

30300831 Prim Metal Prod: Iron Production: Unpaved Roads: Light Duty Vehicles

30300832 Prim Metal Prod: Iron Production: Unpaved Roads: Med Duty Vehicles

30300833 Prim Metal Prod: Iron Production: Unpaved Roads: Heavy Duty Vehicles

30300834 Prim Metal Prod: Iron Production: Paved Roads: All Vehicle Types

30302321 Prim Metal Prod: Taconite Iron Ore Processing: Haul Road: Rock

30302322 Prim Metal Prod: Taconite Iron Ore Processing: Haul Road: Taconite

30500290 Industrial Processes;Mineral Products;Asphalt Concrete;Haul Roads: General

30501024 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Hauling

30501030 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material 

Handling (See 305310);Tops

30501031 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Scrapers: Travel Mode

30501039 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Hauling: Haul Trucks

30501045 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Bulldozing: Overburden

30501046 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Bulldozing: Coal

30501047 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Grading

30501048 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material 

Handling (See 305310);Over

30501049 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material 

Handling (See 305310);Wind

30501050 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Vehicle Traffic: 

Light/Medium Vehicles

30501090 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Haul Roads: General

30501640 Mineral Products: Lime Manufacture: Vehicle Traffic

30502011 Mineral Products: Stone Quarrying - Processing: Hauling

30502504 Mineral Products: Construction Sand and Gravel: Hauling

30531090 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Haul Roads: General

31100101 Building Const: Construction: Building Contractors: Site Preparation: Topsoil 

Removal

31100102 Building Const: Construction: Building Contractors: Site Prep: Earth Moving (Cut 

and Fill)
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SCC SCC Description

31100103 Building Const: Construction: Building Contractors: Site Prep: Aggregate Hauling 

(On Dirt)

31100205 Building Const: Demolitions/Special Trade Contracts: On-site Truck Traffic

31100206 Building Const: Demolitions/Special Trade Contracts: On-site Truck Traffic

50100401 Waste Disposal;Solid Waste Disposal - Government;Landfill Dump;Unpaved Road 

Traffic

3.3 2025 NONEGU INVENTORY DEVELOPMENT

3.3.1 NonEGU Growth Factors

NonEGU point source growth factors were developed using three sets of data:

Annual Energy Outlook fuel consumption forecasts;

State-level employment projections by NAICS code; and

Other state-specific emission projection data.

The priority for applying these growth factors was to first use the state-supplied projection 

data (if available). If no state-supplied data are available, then we used AEO projection 

factors for fuel consumption sources and employment data for other source categories. 

The AEO fuel consumption forecasts and employment projections by NAICS code used 

for area sources were also used for nonEGU point sources. See Section 2.3.1 of this report 

for a description of these data sets. 

Section 2 described the growth factors used to develop projected future year emissions 

inventories for both area and non-EGU sources. Draft growth and control factors, and a 

draft technical support document, were circulated for review by MARAMA and state 

agencies. During the review, it was noted that several emissions categories show negative 

growth into the future, particularly categories related to fossil fuel combustion and 

manufacturing employment. The AEO forecasts show declining trends for many fuel 

consumption sectors, especially industrial, residential, and commercial distillate fuel oil 

use. Similarly, the employment projections show declines in the predicted number of 

employees for many sectors of the economy. This is particularly true for the 

manufacturing sector, which is of interest because this sector is often associated with 

higher emissions than those for other sectors. By contrast, the employment projections 

show increasing trends in retail and service-related sectors. 

Predicted declines in fuel use and employment resulted in growth factors less than unity 

(i.e., represent negative growth) for many area and non-EGU point source categories. 

Consequently, for some categories, emissions are lower for the projected future years than 
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for the base year, even before the application of control assumptions (i.e., the future 

"growth only" emissions are lower than the base year emissions). The MARAMA 

emissions inventory workgroup met on several occasions via conference calls and email 

exchanges to discuss whether the negative growth projections were realistic, and what 

additional assumptions should be made. A topic of particular concern is negative growth 

for non-EGU point sources versus the treatment of Emissions Reduction Credits (ERCs) in 

the future year inventories.

A few states cited the importance of the negative growth issue for non-EGUs and how it 

relates to their ERC programs which are critical to new businesses being able to locate in 

those states. Because businesses could apply for and sell ERCs at the level of the base 

year inventory, it would not be realistic to show negative growth for non-EGU point 

sources. During an economic downturn, a facility could shut down and sell its ERCs, 

making the effective level of future year emissions equal to (i.e., no lower than) the base 

year. Therefore, a recommended conservative approach for addressing negative growth for 

non-EGU point sources is to set a minimum growth rate of 1 (no growth).

During the conference call held on July 23, 2010 to discuss the negative growth issue, state 

agency representatives were polled as to whether or not they felt that the current set of 

proposed growth factors - including the negative growth factors - were realistic for their 

state or district. In reply, some representatives mentioned that they have observed historic 

state-specific data that supports the trends displayed by the proposed growth factors. Other 

representatives mentioned that they feel comfortable with the growth factors and don't 

have a technical basis to change them or suggest others. Some states will supply their own 

factors or make their own assumptions. 

As a result of these discussions, each state provided guidance on how to handle projections 

when negative growth is indicated. Exhibit 3.2 shows the state recommendations for 

nonEGU point sources.

Exhibit 3.2 State Recommendations to Address Negative Growth 

for the NonEGU Point Source Sector

State AEO2010 Growth Factors Employment Growth Factors

CT Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use state DOL employment projections by 3-

digit NAICS 

DE Use AEO2010 growth rates For 2013, use state DOL employment 

projections by 3-digit NAICS; 

For 2017 and 2020, use no growth (growth 

factor=1) when employment growth is 
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State AEO2010 Growth Factors Employment Growth Factors

negative; otherwise use employment if 

positive growth

DC Use AEO2010 growth rates Use state 2008-2018 DOL employment 

projections by 3-digit NAICS; no growth when 

employment is projected to decrease

MD Not using AEO2010 growth factors (except for 

the electric power generation SCCs); 

Use MD DOL employment projections for 

industrial and commercial fuel use SCCs, 

unless employment growth rate is negative, in 

which case use no growth (growth factor=1)

Use updated state DOL employment 

projections by 3-digit NAICS; 

For DoD facilities, account for impacts of Base 

Realignment and Closure;

For source that have closed, account for 

emission reduction credits

NJ New Jersey submitted state specific growth 

factors. Used either state specific growth 

factors, no growth (growth factor=1) when 

state AEO growth is negative or AEO if 

positive growth

NJ submitted state specific growth factors. 

Used either state specific factors, no growth 

(growth factor=1) when state DOL 

employment growth is negative or

employment if positive growth

NY Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

PA Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

VA Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

3.3.2 Emission Reduction Credits

Mulitple states (Connecticut, Maryland, and New Jersey) added county level records 

account for account emission reduction credits (ERCs) issued to stationary sources 

pursuant to state regulations. States provided ERCs on a county-by-county basis. 

Fictitious facilities with an identifier of “OFFSET99999” were created for each county 

using SCC 23-99-000-000 (miscellaneous industrial processes: not elsewhere classified). 

Stack data were developed that assumed that emissions were released at the county 

centroid with an assumed release height of 10 feet. For the 2017 and 2020 inventories, 

ERC emissions were set to the amount of banked emissions available in 2007. 

Delaware included the banked credits at the specific locations that they were generated. 

New York and Pennsylvania did not explicitly provide any information on ERCs.

The District of Columbia and Virginia do not have a formal banking and trading program. 

They used growth rates of 1 for those SCCs in the point source emissions inventory that 

showed a negative growth. In addition, for units that have or are projected to have shut 
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down, they preserved the 2007 emissions in the inventory to account for potential use as 

offsets or credits.

3.3.3 NonEGU Control Factors

Control factors were developed for both on-the-books regulations and proposed regulations 

and other actions to estimate emission reductions in future years. Control factors were 

considered for the following national or regional control measures:

Federal Rules Affecting NonEGU Point Sources

OTC 2001 Model Rules 

OTC 2006 Model Rules 

MANE-VU Sulfur in Fuel Oil Strategy

These control programs are discussed in the following subsections. 

3.3.3.1 Federal Actions Affecting NonEGU Point Sources 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform (USEPA 2010a). These categories, and how they were accounted for in

the MANE-VU+VA emission projection inventories, are described below: 

MACT Standards - USEPA developed guidance for estimating VOC and NOx

emission changes from MACT Rules (USEPA 2007b). We reviewed the guidance 

to identify nonEGU source controls associated with MACT standards for 

controlling HAPs. The information concerning MACT compliance periods was 

used to determine whether the MACT standard resulted in post-2007 emission 

reductions. Because major source categories had a compliance period of 2007 or 

earlier, we assumed that the emission reductions from the MACT standard should 

be reflected in the baseline year and not as an additional post- 2007 credit. The 

only exception to the above discussion of area source MACT standards pertains to 

the recently promulgated rules for reciprocating internal combustion engines. 

USEPA made available an estimate of the percent reduction in emissions 

attributable to the RICE MACT rule in 2012 and 2014 (USEPA 2010b). These 

reductions by SCC are shown in Exhibit 3.3. The USEPA 2014 estimates were 

used for the MANE-VU+VA 2017, 2020 and 2025 inventories. 

Industrial, Commercial, and Institutional Boilers and Process Heaters MACT 

Standard - USEPA’ s 2020 control factor file identified a number of solid fuelburning SCCs for which they estimated an 87% reduction in both PM10 and 

PM2.5. These were used for 2025 also for the affected SCCs.
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Petroleum refinery enforcement settlements - For the facilities identified by 

USEPA located in New Jersey and Pennsylvania we applied post-2007 estimated 

reductions for NOx, PM10, PM2.5, and SO2 to affected units. 

Exhibit 3.3 USEPA Estimated Percent Reductions for RICE MACT Standard

SCC NOx PM2.5 SCC Description

20100102 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating

20100105 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating: 

Crankcase Blowby

20100107 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating: 

Exhaust

20100202 12.53 Electric Generation;Natural Gas;Reciprocating

20100207 12.53 Electric Generation;Natural Gas;Reciprocating: Exhaust

20200102 15.14 Industrial;Distillate Oil (Diesel);Reciprocating

20200104 15.14 Industrial;Distillate Oil (Diesel);Reciprocating: Cogeneration

20200107 15.14 Industrial;Distillate Oil (Diesel);Reciprocating: Exhaust

20200202 12.53 Industrial;Natural Gas;Reciprocating

20200204 12.53 Industrial;Natural Gas;Reciprocating: Cogeneration

20200207 12.53 Industrial;Natural Gas;Reciprocating: Exhaust

20200253 37.96 Industrial;Natural Gas;4-cycle Rich Burn

20200301 37.96 Industrial;Gasoline;Reciprocating

20200307 37.96 Industrial;Gasoline;Reciprocating: Exhaust

20201001 12.53 Industrial;Liquified Petroleum Gas (LPG);Propane

20201002 12.53 Industrial;Liquified Petroleum Gas (LPG);Butane

20201702 37.96 Industrial;Gasoline;Reciprocating Engine

20201707 37.96 Industrial;Gasoline;Reciprocating: Exhaust

20300101 15.14 Commercial/Institutional;Distillate Oil (Diesel);Reciprocating

20300105 15.14 Commercial/Institutional;Distillate Oil 

(Diesel);Reciprocating: Crankcase Blowby

20300106 15.14 Commercial/Institutional;Distillate Oil 

(Diesel);Reciprocating: Evaporative Losses 

20300107 15.14 Commercial/Institutional;Distillate Oil 

(Diesel);Reciprocating: Exhaust

20300201 12.53 Commercial/Institutional;Natural Gas;Reciprocating

20300204 12.53 Commercial/Institutional;Natural Gas;Cogeneration

20300207 12.53 Commercial/Institutional;Natural Gas;Reciprocating: 

Exhaust

20300301 37.96 Commercial/Institutional;Gasoline;Reciprocating

20300307 37.96 Commercial/Institutional;Gasoline;Reciprocating: Exhaust

20301001 12.53 Commercial/Institutional;Liquified Petroleum Gas 

(LPG);Propane

20301002 12.53 Commercial/Institutional;Liquified Petroleum Gas 

(LPG);Butane

20400401 37.96 Engine Testing;Reciprocating Engine;Gasoline
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SCC NOx PM2.5 SCC Description

20400402 15.14 Engine Testing;Reciprocating Engine;Diesel/Kerosene

20400403 15.14 Engine Testing;Reciprocating Engine;Distillate Oil: CI: CI: 

VOC 2005cr = 0

31000203 12.53 Oil and Gas Production;Natural Gas 

Production;Compressors

50100421 12.53 Solid Waste Disposal;Landfill Dump;Waste Gas Recovery: 

Internal Combustion Device

3.3.3.2 OTC 2001 Model Rules for NonEGUs

The OTC developed NOx control measures for industrial, commercial, and institutional 

(ICI) boilers and distributed generation units in 2001 (OTC 2001). We reviewed the 

OTC’s status reports to identify states status in adopting the OTC 2001 model rules (OTC 

2009a). Most states have adopted the OTC model rules with compliance dates in 2007 or 

earlier. As a result, we assumed that the emission reductions from the 2001 OTC model 

rules for nonEGUs are already reflected in the 2007 inventory and no post- 2007 

reductions were applied. 

3.3.3.3 OTC 2006 Model Rules for NonEGUs 

In 2006, the OTC introduced model rules (OTC 2007) for one nonEGU VOC source 

category (adhesives/sealants) and new/more stringent requirements for several NOx source 

categories (asphalt production plants, cement kilns, glass/fiberglass furnaces, and 

industrial, commercial, and institutional {ICI} boilers). We reviewed the OTC’s status 

reports to identify where state status in adopting the OTC 2006 model rules (OTC 2009b). 

To obtain further clarification of each state’s status, states were polled to determine 

whether they have adopted a rule that would achieve reductions equivalent to the OTC 

model rule, whether credit for each rule was already accounted for in the 2007 inventory, 

and whether the estimated reduction in emissions should be applied in 2013, 2017, 2020

and 2025. The following paragraphs describe the control factors applied for each rule by 

state and future year. 

3.3.3.3.1 OTC 2006 Model Rule for Asphalt Production Plants

The OTC recommended that member states pursue state-specific rulemakings or other 

implementation methods that would achieve a 35 percent reduction in NOx emissions. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC model rule and whether the estimated reduction in 

NOx emissions should be applied in 2013, 2017, 2020 and 2025. Only New Jersey 

indicated that the reductions should be applied. New York did not provide guidance, and it 
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was assumed that the NOx reductions should be applied in New York for three future 

years. All other states indicated that the NOx reductions should not be applied in the future 

years. For those states that indicated they wanted to include the reductions, a 35 percent 

reduction in NOx emissions was applied for SCC 3-05-002-xx. 

3.3.3.3.2 OTC 2006 Model Rule for Cement Manufacturing Plants

Cement kilns are located in Maryland, New York, and Pennsylvania. Virginia has one 

cement kiln, which is not located in a PM nonattainment county. The OTC recommended 

state-specific rulemakings or other implementation methods that would result in about a 60 

percent reduction in uncontrolled levels NOx emissions. This emission reduction for 

cement kilns was calculated using the methodology previously developed and documented 

in the OTC report (OTC 2007). Cement kilns are already subject to NOx controls as part 

of Phase I of the NOx SIP call. Emission reductions resulting from the NOx SIP call are 

already accounted for in the 2007 inventory. 

The following methods were used to calculate the additional reductions from the OTC 

2006 Control Measure in each state:

Maryland indicated controls will become effective in 2011 for the two facilities in 

the state. Maryland specified a 25 percent reduction for the Holcim facility and a 

40 percent reduction for the Lehigh facility. No reductions were specified for the 

two kilns at the Essroc facility. 

New York did not provide guidance regarding cement kilns. We used the percent 

reductions previously developed and documented in the previous round of emission 

projections developed for MARAMA (MARAMA 2007). An incremental control 

efficiency of 40 percent was used for New York cement kilns in that inventory.

Pennsylvania provided kiln-specific projected future year NOx emissions for 2013, 

2017, and 2020. The 2020 controlled emissions were also used for 2025. A kilnspecific control factor was calculated based on the ratio of the future year emissions 

to the 2007 emissions. 

3.3.3.3.3 OTC 2006 Model Rule for Glass and Fiberglass Furnaces

The OTC recommended state-specific rulemakings or other implementation methods to 

achieve an approximately 85 percent reduction in NOx emissions from uncontrolled levels. 

Emission reductions for glass and fiberglass furnaces were calculated using the 

methodology previously developed and documented in the OTC report (OTC 2007). Glass 

and fiberglass furnaces are located in Maryland, New Jersey, New York, and Pennsylvania. 

There are no other States with facilities in a PM nonattainment county.
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The following methods were used to calculate the additional reductions from the OTC 

2006 Control Measure in each state:

Maryland indicated that a 48 percent reduction should be applied to the single glass 

manufacturing facility in Maryland. 

New Jersey indicated that a 50 percent reduction in NOx emissions should be 

applied to glass and fiberglass furnaces in 2013, 2017, 2020 and 2025.

New York did not provide guidance regarding glass or fiberglass furnaces. We 

used the percent reductions developed and documented in the previous round of 

emission projections developed for MARAMA (MARAMA 2007). An 

incremental control efficiency of 70 percent was used for New York glass and 

fiberglass furnaces in that inventory.

Pennsylvania provided furnace-specific projected future year NOx emissions for 

2017 and 2020 for all facilities, including those in Allegheny County. The 2020 

controlled emissions were also used for 2025. A furnace-specific control factor 

was calculated based on the ratio of the future year emissions to the 2007 

emissions. 

For the three glass manufacturing facilities in Allegheny County, we used the 

percent reductions previously developed and documented in the previous round of 

emission projections developed for MARAMA (MARAMA 2007). An 

incremental control efficiency of 86 percent was used for Allegheny County glass 

and fiberglass furnaces in that inventory.

3.3.3.3.4 OTC 2006 Model Rule for ICI Boilers

The OTC recommended that member states pursue state-specific rulemakings or other 

implementation methods to achieve NOx emission reduction for industrial, commercial, 

and institutional (ICI) boilers based on guidelines that varied by boiler size and fuel type. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in NOx emissions should be applied in 2013, 2017, 2020, and 2025. 

Most states have not adopted rules equivalent to the 2006 OTC recommendations. These 

states indicated that they will likely depend on a USEPA national rule for possible 

inclusion in the BOTW inventory. Specifically, the OTC Resolution 10-01 (June, 2010) 

called on USEPA for national regulations for ICI boilers.

New Jersey provided NOx percent reductions that varied by heat input rate and fuel/boiler 

type and included an 80 percent rule effectiveness adjustment, as shown in Exhibit 3.4.
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Exhibit 3.4 NonEGU Point Source Emission Reductions from 

New Jersey ICI Boiler NOx Rules

Heat Input Rate

(mmBtu/hr) Fuel/Boiler Type

Overall % 

Reduction 

2007-2025

at least 5 but < 10 All 20%

at least 10 but < 20 All 20%

at least 25 but < 50 Natural gas only 40%

No. 2 Fuel oil only 40%

Refinery fuel gas and 

other gaseous fuels 40%

Other liquid fuels 40%

Duel Fuel using fuel oil 

and/or natural gas 40%

at least 50 but < 100 Natural gas only 40%

No. 2 Fuel oil only 27%

Other liquid fuels 27%

Duel Fuel using fuel oil 

and/or natural gas 40%

at least 100 or greater No. 2 Fuel oil only 40%

The NIF file submitted by New Jersey for this project did not include the boiler design 

capacity. This data gap was filled using the boiler design capacities previously developed 

for the OTC study in 2006, if available; otherwise the SCC description was used to assign 

a default boiler design capacity.

New York specified that a 50 percent reduction should be applied in the existing controls 

inventory for all boilers with greater than 25 mmBtu/hour design capacity. The NIF file 

submitted by New York for this project did not include the boiler design capacity. This 

data gap was filled using the boiler design capacities previously developed for the OTC 

study in 2006, if available; otherwise the SCC description was used to assign a default 

boiler design capacity.

3.3.3.4 MANE-VU Fuel Oil Sulfur Strategy

MANE-VU developed a low sulfur fuel oil strategy to help states develop Regional Haze 

SIPs (MANE-VU 2007). The sulfur in fuel oil recommendations were previously shown 

in Section 2.3.2.5 and vary by state, fuel oil type, and implementation year.

3.3.3.5 State-specific NonEGU Control Factors

The following state-specific nonEGU control factors were provided:
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Bellefield Boiler Plant, Allegheny County. Allegheny County indicated that this 

facility changed their fuel source from coal to natural gas in July 2009 and future 

year emissions were changed to reflect the fuel switch. 

USS Clairton Works, Allegheny County. The facility will remove Batteries 7-9 

and have Battery C operational by 2013, resulting in a change in PM emissions in 

2013. Also, USS Clairton Works will remove Batteries 1-3 and have Battery D 

operational in 2015, resulting in a change in PM emissions in 2017, 2020 and 2025. 

Chrysler, Delaware. The Chrysler facility (ID 1000300128) shut down in 2009. 

Delaware specified that only a 25 percent reduction should be taken for all 

pollutants as some emissions will be banked for future use by other sources. 

OSG Ship Management (ID 1000500093), Delaware. Delaware provided sourcespecific growth factors and percent reductions in VOC emissions for 2013, 2017, 

and 2020 from the lightering operations at OSG Ship Management (ID 

1000500093). The 2025 emissions were expected to be the same as the 2020 

emissions. 

Control Technology Guidance (CTG) Documents, Delaware. Delaware 

determined that VOC emission reductions from new CTG recommendations would 

be very small. Although the new CTGs set up new recommendations for higher 

control efficiencies, the actual VOC reductions would be minimum, if not none, 

because most DE’s existing facilities are not affected by the new requirements and 

emissions from those facilities are relatively small (based on 2002 inventory). 

Unit Shutdowns, Delaware. Delaware identified several emission units that have 

shut down at the following facilities: Dow Reichhold Specialty latex (ID 

1000100016), SPI Poly-Ols (ID 1000300426), and Invistas (ID 1000500002). 

Emissions for all pollutants were set to zero for these units. 

Premcor Refinery NOx Plantwide Cap, Delaware. The refinery was sold to the 

Delaware City Refining Company and an agreement was reached with DNREC's 

Secretary that allows plant-wide applicability limit (cap) for NOx. Delaware 

decided to devide the NOx -cap to each stack equally. Delaware estimated a 

plantwide reduction of 10.05 percent in 2013 and 41.22 percent in 2017, 2020 and 

2025. 

PEPCO Benning Road, District of Columbia. This facility is scheduled for 

deactivation in 2012. All emissions were set to zero in the projection inventories.
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2009 New Jersey Rule for NOx for Municipal Solid Waste Incinerators. This 

rule will achieve a 27 percent reduction from one facility - Camden County Energy 

Recovery Associates, L.P. (ID 3400751614).

New Jersey Rule for VOC Storage Tanks. New Jersey provided expected VOC 

emission reductions resulting from post-2007 rules for VOC storage tanks. For 

refinery floating roof storage tanks (SCC 4-03-011-xx), the reductions are 75 

percent for 2013, 82 percent for 2017, and 85 percent for 2020. For bulk terminal 

tanks (SCC 4-04-001-xx), the reductions are 20 percent for 2013, 40 percent for 

2017, and 50 percent for 2020. For pipeline breakout stations (SCCs 4-04-002-xx 

and 4-06-005-xx), the reductions are 26 percent for 2013, 52 percent for 2017, and 

65 percent for 2020 and 2025. 

3.4 2025 EGU INVENTORY DEVELOPMENT

An emission projection methodology for EGUs is being developed as part of an inter-RPO 

coordination effort under the direction of ERTAC. The computer code to implement the 

ERTAC methodology will not be available in time for use in state’s re-designation requests 

or maintenance plans. An interim approach for projecting EGU emissions is discussed in 

the following paragraph. 

Annual 2007 EGU point emissions were grown to 2025 based on electricity generation 

projections that are delineated by region and fuel. Growth factors are based on AEO2011 

Table 96 - Electricity Generation by Electricity Market Module Region and Fuel Source

(see Appendix F). The 2007 emissions were extracted for those units flagged as EGUs in 

the MANE-VU+VA 2007 inventory. The appropriate AEO2011 growth factor was 

applied to the 2007 emissions to calculate a “growth only” emission value for 2025. The 

following key assumptions were made:

Growth beyond unit capacity or permit limits was not considered (e.g., fuel 

consumption was allowed to grow beyond a unit’s physical capacity or permit 

limit); 

Generation from specific new units that are anticipated to operate in 2025 but did 

not in 2007 is not explicitly accounted for, but instead is assumed to be accounted 

for in the AEO2011 growth forecasts; 

Similarly, generation from specific units that have or are anticipated to shut down 

after 2007 is not explicitly accounted for, but instead are assumed to be accounted 

for in the AEO2011 growth forecasts. 
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States indicated where post-2007 controls or shut downs were to be applied on a 

unit by unit basis. The control factors were applied to the grown emissions to 

calculate a “growth and control” emission value for 2025. 

Details on the growth and control factors are provided in the following sections. 

3.4.1 EGU Growth Factors

Table 96 of the AEO2011 provides electricity generation projections by electricity market 

module region and fuel source for the years 2007 to 2035 (EIA 2011b). AEO2011 

disaggregates generation to 22 sub-regions for electricity planning and dispatch This is a 

new approach started in AEO2011. Disaggregation of the Electricity Market Module 

(EMM) is intended to reduce errors that result from aggregation and averaging, to better 

represent environmental and regional issues, and thus to improve the projections of 

capacity additions and fuels consumed for generation. Exhibit 4.1 identifies the 22 subregions. 

Exhibit 3.5 Electricity Market Module Regions
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The EIA provided a file that assigns each EGU to an EMM region. Units in the PM 

nonattainment counties included in this analysis reside in one of the following seven EMM 

regions: 

Northeast Power Coordinating Council / Northeast (NEWE)

Northeast Power Coordinating Council / NYC Westchester (NYCW)

Northeast Power Coordinating Council / Long Island (NYLI)

Northeast Power Coordinating Council / Upstate New York (NYUP)

Reliability First Corporation / East (RFCE)

Reliability First Corporation / West (RFCW)

SERC Reliability Corporation / Virginia Carolina (SRVC)

Exhibit 3.6 shows the growth factors for electricity generation for coal. The AEO2011 

shows zero generation from coal in the NYC Westchester and Long Island regions. 

Generation from coal is projected to decline significantly in the Northeast and Upstate 

New York regions. Generation from coal is expected to decline slightly in the RFC East, 

RFC West, and SERC Virginia-Carolina regions. 

Exhibit 3.7 shows the growth factors for electricity generation for petroleum. The 

AEO2011 shows that the growth factors vary widely by EMM region. A positive growth 

rate (e.g., growth factor > 1) from 2007 to 2025 is projected for the RFC East and SERC 

Virginia-Carolina regions. In all other EMM regions in the study area, generation from 

petroleum is projected to decline (e.g., growth factor < 1). 

Exhibit 3.8 shows the growth factors for electricity generation for natural gas. The 

AEO2011 shows that the growth factors vary widely by EMM region. A negative growth 

rate (e.g., growth factor < 1) from 2007 to 2025 is projected for the NYC Westchester and 

SERC Virginia-Carolina regions. In all other EMM regions in the study area, generation 

from natural gas is projected to increase (e.g., growth factor > 1).

Exhibit 3.9 shows the growth factors for electricity generation for renewables. The 

AEO2011 shows that the growth factors vary widely by EMM region. A large increase in 

generation from renewables from 2007 to 2025 is projected for the RFC East, RFC West 

and SERC Virginia-Carolina regions. A more modest increase in renewable is projected 

for the Northeast and Upstate New York regions. A slight decline is projected for the 

NYC Westchester and Long Island regions. 
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Exhibit 3.6 Electricity Generation Growth Factors for Coal

Exhibit 3.7 Electricity Generation Growth Factors for Petroleum
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Exhibit 3.8 Electricity Generation Growth Factors for Natural Gas

Exhibit 3.9 Electricity Generation Growth Factors for Renewables
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After reviewing the AEO growth factors, New York had doubts about the AEO 

projections. To be conservative, New York specified that a growth factor of 1.0 should be 

used for any unit where AEO growth was projected to be negative. 

3.4.2 EGU Control Factors

States provided information on post-2007 controls or shut downs to be applied on a unit by 

unit basis for the 2025 inventory. This control information was provided in a format that is 

being used by the ERTAC EGU Projection Methodology (Appendix G UAF NEEDS 

Control FileMASTER92211.xls). 

In addition to the ERTAC control file, the following comments were received:

Delaware – The Edge Moor facility (ORIS=593) plans to switch from coal to 

natural gas/# 6 oil. However, the Title V permit is not yet approved. Delaware 

made the decision to assume the facility still is burning coal in 2025 for the 

purposes of this PM re-designation inventory. Delaware may change the EGU 

estimates at a future date when the SIP submittal is written.

District of Columbia – The PEPCO Benning Road facility (ORIS=603) is 

scheduled to shut down permanently in 2012 and all future year emissions have 

been set to zero.

Maryland – The Healthy Air Act sets unit-specific emission caps (tons/year) for 

SO2 and NOx. Maryland provided unit specific control factors to ensure that the 

future year emissions were equal to the Healthy Air Act emission caps. Affected 

facilities include CP Crane, Herbert A Wagner, R. Paul Smith, Chalk Point, 

Dickerson, Morgantown, and Brandon Shores. 

New Jersey – Control factors for SO2 and NOx for each unit were calculated based 

on the ratio of the future controlled emission rate (lbs/mmBtu) to the 2007 actual 

emission rate (lbs/mmBtu). Large reductions in SO2 emissions are expected from 

the installation of control equipment at the Hudson and Mercer generating stations. 

NOx controls were also installed at the Hudson generating station in 2010. 

Pennsylvania – RRI’s Portland Generating Station is under a USEPA Order to 

reduce SO2 emissions. SO2emissions beyond 013 were reduced by 95 percent to 

address the ordered emission reductions. SO2 controls were installed at RRI 

Keystone, PPL Brunner Island, and Allegheny Energy Hatfields Ferry in 2010. 

SO2 controls at the Cheswick Station were installed in 2011. Units 1 and 2 at PPL 

Martins Creek, Units 1 and 2 at Exelon Cromby, and Units 1 and 2 at Exelon 
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Eddystone are or will be permanently shut down by 2013 and the emissions for all 

pollutants were set to zero for 2017/2020/2025. The future operation of Unit 1 at 

Exelon Schuylkill are projected to be about 250 hours, compared to 1,037 hours in 

2007. Future emissions for this unit were reduced by 75 percent to reflect this 

lowered operating capacity.

Virginia – Dry scrubbers at the Potomac River Generating Station were installed in 

2008. In 2008, the facility received a federally enforceable facility-wide permit 

that placed limits on the facility’s annual potential to emit of both NOX and SO2.

3.4.3 Consideration of CSAPR Emission Allowances

On July 6, 2011, the USEPS finalized the Cross-State Air Pollution Rule (CSAPR) that 

requires 27 states to reduce power plant emissions that contribute to ozone and/or fine 

particle pollution in other states. This final rule replaces the 2005 Clean Air Interstate 

Rule (CAIR). Under the final rule, USEPA distributes a annual SO2 and NOx emission 

allowances to covered units in each state, the sum of which equals the annual SO2 and 

NOx budgets for those states (allowing for a two percent set-aside for new units). 

USEPA provided allocations for each affected unit. States initially considered whether 

these unit-level allocations for SO2 and NOx provided a more realistic estimate of future 

year emissions than the growth and control methodology described in Sections 4.3.1 and 

4.3.2 of this report. However, the United States Court of Appeals for the District of 

Columbia issued an order staying CSAPR on December 31, 2011, pending the resolution 

of an appeal of the rule. Because of the uncertainty regarding implementation of CSAPR, 

states decided to use the growth and control methodology described in Sections 4.3.1 and 

4.3.2 rather than the proposed CSAPR caps for SO2 and NOx. 
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4.0 NONROAD MOBILE SOURCES INCLUDED IN NMIM

4.1 NONROAD MODEL CATEGORIES

USEPA’s NONROAD model estimates emissions from equipment such as recreational 

marine vessels, recreational land-based vehicles, farm and construction machinery, lawn 

and garden equipment, aircraft ground support equipment (GSE) and rail maintenance 

equipment. This equipment is powered by diesel, gasoline, compressed natural gas (CNG) 

or liquefied petroleum gas (LPG) engines. 

NMIM was developed by USEPA to develop county-level emission estimates for certain 

types of nonroad equipment. NMIM uses the current version the NONROAD model to 

develop emission estimates and was used to develop the projection inventories discussed 

here. The NMIM national county database contains monthly input data to reflect county 

specific fuel parameters and temperatures. Most of the work associated with executing 

NMIM involved updating the NMIM county database with state-specific information. 

4.2 2007 INVENTORY DEVELOPMENT

MARAMA used the NMIM model to develop county level emission estimates by SCC for 

2007 (see {MARAMA 2011a} for complete documentation). For this analysis, the 

NMIM2008 software (version NMIM20090504), the NMIM County Database (version 

NCD20090531), and NONROAD2008a (July 2009 version) were used as starting points

(USEPA 2009a). Changes were made to the NCD20090531 based on state review and 

comment. 

A summary of the major adjustments to the default NMIM County Database for the 2007 

NMIM model runs includes:

State review and adjustments to fuel characteristics (Reid Vapor Pressure, sulfur 

and oxygenate fractions) to better represent county-specific fuel characteristics in 

2007; and 

States identified discrepancies in the housing and population data contained in the 

NONROAD model and these data were updated using 2007 housing information 

and updated 2007 population estimates. 

Two states – New York and Virginia – provided their independent NONROAD modeling 

results which were used instead of the MARAMA modeling results. 
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4.3 2025 INVENTORY DEVELOPMENT

MARAMA ran the NMIM model for 2025 for six jurisdictions (CT, DE, DC, MD, PA). 

Two states, New York and Virginia, did their own NONROAD modeling and provided 

2025 NMIM results for the affected counties.

4.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT

The NMIM/NONROAD model includes emissions from airport ground support 

equipment. Emissions from airport ground support equipment is also included in 

USEPA’s aircraft inventory that was prepared using the Federal Aviation Administration’s 

Emissions and Dispersion Modeling System (EDMS). Correspondence with USEPA 

indicated that USEPA considers the emissions calculated by EDMS to be better than those 

calculated by NONROAD. For this reason, all emissions calculated by NMIM/ 

NONROAD for airport ground support equipment were removed from both the 2007 and 

2025 inventories to avoid double counting emissions. 

4.5 NMIM/NONROAD GROWTH AND CONTROL INFORMATION

In estimating future year emissions, the NMIM/NONROAD model includes growth and 

scrappage rates for equipment in addition to a variety of control programs. It is not 

possible to separate out the future year emissions due to “growth only” or “control only” in 

a single run. That is, the model run provides a single future year estimate that is a “growth 

and control” scenario.

The growth data used in the NMIM/NONROAD model is documented in a USEPA report 

(USEPA 2004c). The GROWTH packet of the NONROAD model cross-references each 

SCC to a growth indicator code. The indicator code is an arbitrary code that identifies an 

actual predicted value such as human population or employment that is used to estimate 

the future year equipment population. The GROWTH packet also defines the scrappage 

curves used to estimate the future year model year distribution.

The NMIM/NONROAD model also accounts for all USEPA emission standards for 

nonroad equipment. There are multiple standards that vary by equipment type, rated 

power, model year, and pollutant. Exhibit 4.1 is a summary of the emission control 

programs accounted for in the NMIM/NONROAD model. A complete summary of the 

nonroad equipment emission standards can be found on USEPA’s nonroad emission 

standards reference guide website (USEPA 2011). 
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Exhibit 4.1 Control Programs Included in the NMIM/NONROAD Model

Regulation Description

Control of Air Pollution; 

Determination of Significance for 

Nonroad Sources and Emission 

Standards for New Nonroad 

Compression Ignition Engines At or 

Above 37 Kilowatts

59 FR 31036

June 17, 1994

This rule establishes Tier 1 exhaust emission standards for 

HC, NOx, CO, and PM for nonroad compression-ignition 

(CI) engines ≥37kW (≥50hp). Marine engines are not 

included in this rule. The start dates and pollutants 

affected vary by hp category as follows:

50-100 hp: Tier 1,1998; NOx only

100-175 hp: Tier 1, 1997; NOx only

175-750 hp: Tier 1, 1996; HC, CO, NOx, PM

>750 hp: Tier 1, 2000; HC, CO, NOx, PM

Emissions for New Nonroad SparkIgnition Engines At or Below 19 

Kilowatts; Final Rule

60 FR 34581

July 3, 1995

This rule establishes Phase 1 exhaust emission standards 

for HC, N NOx Ox, and CO for nonroad spark-ignition 

engines ≤19kW (≤25hp). This rule includes both handheld 

(HH) and non-hand-held (NHH) engines. The Phase 1 

standards become effective in 1997 for :

 Class I NHH engines (<225cc), 

 Class II NHH engines (≥225cc), 

 Class III HH engines (<20cc), and 

 Class IV HH engines (≥20cc and <50cc). 

The Phase 1 standards become effective in 1998 for:

 Class V HH engines (≥50cc) 

Final Rule for New Gasoline SparkIgnition Marine Engines; Exemptions 

for New Nonroad CompressionIgnition Engines at or Above 37 

Kilowatts and New Nonroad SparkIgnition Engines at or Below 19 

Kilowatts

61 FR 52088

October 4, 1996

This rule establishes exhaust emission standards for HC+

NOx for personal watercraft and outboard (PWC/OB) 

marine SI engines. The standards are phased in from 

1998-2006.

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines

63 FR 56967

October 23, 1998

This final rule sets Tier 1 standards for engines under 50 

hp, phasing in from 1999 to 2000. It also phases in more 

stringent Tier 2 standards for all engine sizes from 2001 to 

2006, and yet more stringent Tier 3 standards for engines 

rated over 50 hp from 2006 to 2008. The Tier 2 standards 

apply to NMHC+ NOx, CO, and PM, whereas the Tier 3 

standards apply to NMHC+ NOx and CO. The start dates 

by hp category and tier are as follows:

 hp<25: Tier 1,2000; Tier 2, 2005; no Tier 3

 25-50 hp: Tier 1, 1999; Tier 2, 2004; no Tier 3

 50-100 hp: Tier 2, 2004; Tier 3, 2008

 100-175 hp: Tier 2, 2003; Tier 3, 2007

 175-300 hp: Tier 2, 2003; Tier 3, 2006

 300-600 hp: Tier 2, 2001, Tier 3, 2006

 600-750 hp: Tier 2, 2002; Tier 3, 2006

 >750 hp: Tier 2, 2006, no Tier 3

This rule does not apply to marine diesel engines above 50 

hp.
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Regulation Description

Phase 2: Emission Standards for 

New Nonroad Nonhandheld Spark 

Ignition Engines At or Below 19 

Kilowatts

64 FR 15207

March 30, 1999

This rule establishes Phase 2 exhaust emission standards 

for HC+ NOx for nonroad nonhandheld (NHH) sparkignition engines ≤19kW (≤25hp). The Phase 2 standards 

for Class I NHH engines (<225cc) become effective on 

August 1, 2007 (or August 1, 2003 for any engine initially 

produced on or after that date). The Phase 2 standards for 

Class II NHH engines (≥225cc) are phased in from 2001-

2005.

Phase 2: Emission Standards for 

New Nonroad Spark-Ignition 

Handheld Engines At or Below 19 

Kilowatts and Minor Amendments to 

Emission Requirements Applicable 

to Small Spark-Ignition Engines and 

Marine Spark-Ignition Engines; Final 

Rule

65 FR 24268

April 25, 2000

This rule establishes Phase 2 exhaust emission standards

for HC+ NOx for nonroad handheld (HH) spark-ignition 

engines ≤19kW (≤25hp). The Phase 2 standards are 

phased in from 2002-2005 for Class III and Class IV 

engines and are phased in from 2004-2007 for Class V 

engines.

Control of Emissions From Nonroad 

Large Spark-Ignition Engines and 

Recreational Engines (Marine and 

Land-Based); Final Rule

67 FR 68241

November 8, 2002

This rule establishes exhaust and evaporative standards 

for several nonroad categories: 

1) Two tiers of emission standards are established for large 

spark-ignition engines over 19 kW. Tier 1 includes exhaust 

standards for HC+ NOx and CO and is phased in from 

2004-2006. Tier 2 becomes effective in 2007 and includes 

exhaust standards for HC+ NOx and CO, as along with

evaporative controls affecting fuel line permeation, diurnal 

emissions and running loss emissions.

2) Exhaust and evaporative emission standards are 

established for recreational vehicles, which include 

snowmobiles, off-highway motorcycles, and all-terrain 

vehicles (ATVs). For snowmobiles, HC and CO exhaust 

standards are phased-in from 2006-2012. For off-highway 

motorcycles, HC+ NOx and CO exhaust emission 

standards are phased in from 2006-2007. For ATVs, 

HC+NOx and CO exhaust emission standards are phased 

in from 2006-2007. Evaporative emission standards for 

fuel tank and hose permeation apply to all recreational 

vehicles beginning in 2008.

3) Exhaust emission standards for HC+ NOx, CO, and PM 

for recreational marine diesel engines over 50 hp begin in 

2006-2009, depending on the engine displacement. These 

are “Tier 2” equivalent standards.

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines and 

Fuel; Final Rule (Clean Air Nonroad 

Diesel Rule – Tier 4)

69 FR 38958

June 29, 2004

This final rule sets Tier 4 exhaust standards for CI engines 

covering all hp categories (except marine and 

locomotives), and also regulates nonroad diesel fuel sulfur 

content.

1) The Tier 4 start dates and pollutants affected vary by hp 

and tier as follows:

 hp<25: 2008, PM only

 25-50 hp: Tier 4 transitional, 2008, PM only; 

 Tier 4 final, 2013, NMHC+ NOx and PM
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Regulation Description

 50-75 hp: Tier 4 transitional, 2008; PM only; 

 Tier 4 final, 2013, NMHC+ NOx and PM 

 75-175 hp: Tier 4 transitional, 2012, HC, NOx, and PM; 

 Tier 4 final, 2014, HC, NOx,PM

 175-750 hp:Tier 4 transitional, 2011, HC, NOx, and PM;

 Tier 4 final, 2014, HC, NOx,PM

 >750 hp: Tier 4 transitional, 2011, HC, NOx, and PM; 

 Tier 4 final, 2015, HC, NOx,PM

2) This rule will reduce nonroad diesel fuel sulfur levels in 

two steps. First, starting in 2007, fuel sulfur levels in 

nonroad diesel fuel will be limited to a maximum of 500 

ppm, the same as for current highway diesel fuel. Second, 

starting in 2010, fuel sulfur levels in most nonroad diesel 

fuel will be reduced to 15 ppm.

Control of Emissions From Nonroad 

Spark-Ignition Engines and 

Equipment; Final Rule (Bond Rule)

73 FR 59034

October 8, 2008

This rule establishes exhaust and evaporative standards 

for small SI engines and marine SI engines:

1) Phase 3 HC+ NOx exhaust emission standards are 

established for Class I NHH engines starting in 2012 and 

for Class II NHH engines starting in 2011. There are no 

new exhaust emission standards for handheld engines. 

New evaporative standards are adopted for both handheld 

and nonhandheld equipment. The new evaporative 

standards control fuel tank permeation, fuel hose 

permeation, and diffusion losses. The evaporative 

standards begin in 2012 for Class I NHH engines and 2011 

for Class II NHH engines. For handheld engines, the 

evaporative standards are phased-in from 2012-2016.

2) More stringent HC+ NOx and CO standards are 

established for marine SI PWC/OB engines beginning in 

2010. In addition, new exhaust HC+ NOx and CO 

standards are established for sterndrive and inboard (SD/I) 

marine SI engines also beginning in 2010. High 

performance SD/I engines are subject to separate HC+

NOx and CO exhaust standards that are phased-in from 

2010-2011. New evaporative standards were also adopted 

for all marine SI engines that control fuel hose permeation, 

diurnal emissions, and fuel tank permeation emissions. 

The hose permeation, diurnal, and tank permeation 

standards take effect in 2009, 2010, and 2011, 

respectively.

Source: USEPA 2010c
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5.0 MARINE VESSELS, AIRPORTS, AND RAILROADS

5.1 MAR INVENTORY CATEGORIES

This category of sources is collectively referred to as the MAR (marine, airports, railroads) 

sector. It includes nonroad engines associated with the following activities:

Marine Vessels - The Commercial Marine Vehicle (CMV) sector includes all boats 

and ships used either directly or indirectly in the conduct of commerce or military 

activity. The majority of these vessels are powered by diesel engines that are either 

fueled with distillate or residual fuel oil blends. For the purpose of this inventory it 

is assumed that Category 3 vessels primarily use residual blends, while Category 1

and 2 vessels typically used distillate fuels.

Airports - The aircraft sector includes all aircraft types used for public, private, 

and military purposes. This includes four types of aircraft 1) Commercial; 2) Air 

Taxis; 3) General Aviation; and 4) Military. Ground support equipment (GSE) and 

auxiliary power units (APU) are also included. 

Railroads - The railroad sector includes railroad locomotives powered by dieselelectric engines. Locomotives are divided into Class I line haul, Class II/III line 

haul, commuter/passenger and Class I yard.

5.2 2007 INVENTORY DEVELOPMENT

The emission projections for the 2025 point source were based on Version 3_3 of the 2007 

MANE-VU+VA inventory and are fully documented in the TSD for that effort 

(MARAMA 2012a). There were no adjustment to the 2007 Version 3_3 MAR inventory 

for this analysis. 

5.3 2025 INVENTORY DEVELOPMENT 

Appendix H contains the data that were used to develop growth and control factors for the 

commercial marine vessel, airport, and railroad sectors.

5.3.1 Commercial Marine Vessels 

For the purpose of emission calculations, marine vessel engines are divided into three 

categories based on displacement (swept volume) per cylinder. Category 1 and Category 2 

marine diesel engines typically range in size from about 500 to 8,000 kW (700 to 11,000 

hp). These engines are used to provide propulsion power on many kinds of vessels 

including tugboats, pushboats, supply vessels, fishing vessels, and other commercial 
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vessels in and around ports. They are also used as stand-alone generators for auxiliary 

electrical power on vessels. Category 3 marine diesel engines typically range in size from 

2,500 to 70,000 kW (3,000 to 100,000 hp). These are very large marine diesel engines used 

for propulsion power on ocean-going vessels such as container ships, oil tankers, bulk 

carriers, and cruise ships.

The majority of marine vessels are powered by diesel engines that are either fueled with 

distillate or residual fuel oil blends. For the purpose of emission inventories, USEPA has 

assumed that Category 3 vessels primarily use residual blends, while Category 1 and 2 

vessels typically use distillate fuels. 

USEPA developed national emission inventories for Category 1 and 2 vessels and 

Category 3 vessels for calendar years 2002 through 2040 as part of its effort to develop 

emission standards for these vessels. The methodologies used to develop the emission 

projections (for both a baseline and controlled scenario) are documented in three regulatory 

impact assessments (USEPA 2008b, USEPA 2009c, USEPA 2009d). The USEPA data 

and methodologies from these RIAs were used to develop separate growth and control 

factors for Category 1 and 2 vessels (diesel) and Category 3 vessels (residual). 

5.3.1.1 CMV Diesel Growth Factors

For Category 1 and 2 diesel vessels, USEPA used projection data for domestic shipping 

from the AEO2006 (EIA 2006). The annual growth rate reported in the RIA is 0.9%. 

More recent growth data for domestic shipping is available in the AEO2010 (EIA 2010). 

Because Category 1 and 2 vessels primarily account for activity data for ships that carry 

domestic cargo, we decided to use the recent growth data for domestic shipping available 

in the AEO2010. We used Table A-7 of the AEO2010 for domestic shipping to calculate 

the growth factor for 2007-2025 to be 1.064. This growth factor was used for CMV diesel 

port emissions (SCC 22-80-002-100) and CMV diesel underway emissions (SCC 22-80-

002-200). 

5.3.1.2 CMV Diesel Control Factors

In developing their emission projections, USEPA developed two scenarios that accounted 

for both the 2004 nonroad diesel rule and the 2008 diesel marine vessel rule: 

USEPA’s baseline (pre-control) inventory accounted for: 

1. the 0.9 percent annual growth in fuel use based on AEO2006, 

2. the impact of existing engine regulations that took effect in 2008, 

3. the 2004 Clean Air Nonroad Diesel Rule that will decrease the allowable 

levels of sulfur in fuel beginning in 2012, and 

4. fleet turnover. 
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USEPA’s controlled inventory accounted for:

1. the 0.9 percent annual growth in fuel use based on AEO2006;

2. the reductions included in the baseline inventory, and the reductions from 

USEPA’s 2008 rule Final Locomotive-Marine rule for Tier 3 and 4 engines; 

3. The 2008 final rule that includes the first-ever national emission standards 

for existing marine diesel engines, applying to engines larger than 600kW 

when they are remanufactured. The rule also sets Tier 3 emissions 

standards for newly-built engines that are phasing in from 2009. Finally, 

the rule establishes Tier 4 standards for newly-built commercial marine 

diesel engines above 600kW, phasing in beginning in 2014.

To calculate a control factor that accounts for reductions included in the USEPA controlled 

inventory, it was necessary to first calculate a “growth only” scenario applying USEPA’s 

0.9 percent annual growth rate to the 2007 base emissions. Once the growth rate was 

applied, then a control factor for each pollutant was calculated by dividing the future year 

controlled emissions by the future year “growth only” emissions. Exhibit 5.1 shows the 

control factors for 2013, 2017, 2020, and 2025 for diesel commercial marine vessels. 

Exhibit 5.1 CMV Diesel Control Factors by Year and Pollutant

Year NOx PM2.5 SO2

2013 0.787 0.747 0.464

2017 0.642 0.550 0.076

2020 0.537 0.460 0.032

2025 0.401 0.353 0.031

5.3.1.3 CMV Residual Oil Growth Factors

For Category 3 residual oil vessels, data from a USEPA-sponsored study was used to 

develop an annualized growth factor of 4.5 percent for the region. A few states considered 

the growth rate to be extremely high and not reflective of recent economic conditions. 

Because USEPA’s Category 3 vessel inventory is primarily based on activity data for ships 

that carry foreign cargo, we decided to use the recent growth data for international 

shipping available in the AEO2010. We used data from Table A-7 of the AEO2010 for 

international shipping to calculate the growth factor for 2007-2025 to be 0.956. These 

growth factors were used for CMV residual oil port emissions (SCC 22-80-003-100) and 

CMV residual oil underway emissions (SCC 22-80-003-200).
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5.3.1.4 CMV Residual Oil Control Factors

On December 22, 2009, USEPA announced final emission standards under the Clean Air 

Act for new marine diesel engines with per-cylinder displacement at or above 30 liters 

(called Category 3 marine diesel engines) installed on U.S.-flagged vessels. The final 

engine standards are equivalent to those adopted in the amendments to Annex VI to the 

International Convention for the Prevention of Pollution from Ships (a treaty called 

"MARPOL"). The emission standards apply in two stages: near-term standards for newlybuilt engines will apply beginning in 2011, and long-term standards requiring an 80 

percent reduction in NOx will begin in 2016. USEPA also adopted changes to the diesel 

fuel program to allow for the production and sale of diesel fuel with no more than 1,000 

ppm sulfur for use in Category 3 marine vessels. The regulations generally forbid 

production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters, 

unless operators achieve equivalent emission reductions in other ways. 

On March 26, 2010, the International Maritime Organization (IMO) officially designated 

waters off North American coasts as an emissions control area (ECA) in which stringent 

international emission standards will apply to ships. In practice, implementation of the 

ECA means that ships entering the designated area would need to use compliant fuel for 

the duration of their voyage that is within that area, including time in port and voyages 

whose routes pass through the area without calling on a port. The North American ECA 

includes waters adjacent the Atlantic extending up to 200 nautical miles from east coast of 

the US. The quality of fuel that complies with the ECA standard will change over time. 

From the effective date in 2012 until 2015, fuel used by vessels operating in designated 

areas cannot exceed 1.0 percent sulfur (10,000 ppm). Beginning in 2015, fuel used by 

vessels operating in these areas cannot exceed 0.1 percent sulfur (1000 ppm). Beginning 

in 2016, NOx after treatment requirements become applicable.

To calculate a control factor that accounted for reductions included in the USEPA 

controlled inventory, it was necessary to first calculate a “growth only” scenario applying 

USEPA’s 4.5 percent annual growth rate to the 2007 base emissions. Once the growth rate 

was applied, then a control factor for each pollutant was calculated by dividing the future 

year controlled emissions by the future year “growth only” emissions. 

Exhibit 5.2 shows the control factors for 2013, 2017, and 2020 for residual oil commercial 

marine vessels. 
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Exhibit 5.2 CMV Residual Oil Control Factors by Year and Pollutant

Year NOx PM2.5 SO2

2013 0.736 0.353 0.270

2017 0.654 0.216 0.120

2020 0.597 0.137 0.036

2025 0.480 0.137 0.036

5.3.1.5 Military Vessels Growth and Control Factors

Virginia reported emissions for military vessels, but did not distinguish between diesel or 

residual fuels. An assumption of “no growth” for military vessel activity and emissions in 

Virginia was made so that emissions remain at 2007 levels in 2025. Virginia was the only 

state to report emission from military vessels.

5.3.1.6 State-specific CMV Updates for 2025

New Jersey provided updated CMV emission estimates for 2007, 2013, 2017, 2020, and 

2025, and growth and control factors for 2013, 2017, 2020, and 2025. These data were 

used to replace the emission estimates previously used for the 2007 MANE-VU+VA base 

year inventory and the MANE-VU+VA future year inventories.

5.3.2 Airports

Aircraft emissions in the 2007 MANE-VU+VA inventory are available on either a countyby-county or airport-by-airport basis for six types of aircraft operations:

Air carrier operations represent landings and take-offs (LTOs) of commercial 

aircraft with seating capacity of more than 60 seats;

Commuter/air taxi operations are one category. Commuter operations include 

LTOs by aircraft with 60 or fewer seats that transport regional passengers on 

scheduled commercial flights. Air taxi operations include LTOs by aircraft with 60 

or fewer seats conducted on non-scheduled or for-hire flights;

General aviation represents all civil aviation LTOs not classified as commercial;

Military operations represent LTOs by military aircraft; 

Ground Support Equipment (GSE) typically includes aircraft refueling and baggage 

handling vehicles and equipment, aircraft towing vehicles, and passenger buses; 

Auxiliary power units (APUs) provide power to start the main engines and run the 

heating, cooling, and ventilation systems prior to starting the main engines.
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5.3.2.1 Airport Growth Factors

Aircraft operations were projected to future years by applying activity growth using data 

on itinerant (ITN) operations at airports as reported in the Federal Aviation 

Administration’s (FAA) Terminal Area Forecast (TAF) System for 2009-2030 (FAA 

2010). The ITN operations are defined as aircraft take-offs or landings. This information is 

available for approximately 3300 individual airports. Actual LTOs are reported for 2007 

and projected LTOs are provided for all years up to 2030.

The data was aggregated and applied at the county level for the four operation types: 

commercial, general, air taxi, military. A growth factor was computed for each operation 

type by dividing future-year ITN by 2007-year ITN. Inventory SCCs were assigned 

factors based on the operation type, as shown in Exhibit 5.3.

Exhibit 5.3 Crosswalk between SCC and FAA Operations Type

SCC SCC Description FAA Operation Type Used for 

Growth Factor

2265008005 Airport Ground Support Equipment, 4-Stroke Gas Total Itinerant Operations

2267008005 Airport Ground Support Equipment, LPG Total Itinerant Operations

2268008005 Airport Ground Support Equipment, CNG Total Itinerant Operations

2270008000 Airport Ground Support Equipment, Diesel Total Itinerant Operations

2270008005 Airport Ground Support Equipment, Diesel Total Itinerant Operations

2275001000 Aircraft /Military Aircraft /Total Itinerant Military Operations

2275020000 Aircraft /Commercial Aircraft /Total: All Types Itinerant Air Carrier Operations

2275050000 Aircraft /General Aviation /Total Itinerant General Aviation Operations

2275050011 Aircraft /General Aviation /Piston Itinerant General Aviation Operations

2275050012 Aircraft /General Aviation /Turbine Itinerant General Aviation Operations

2275060000 Aircraft /Air Taxi /Total Itinerant Air Taxi Operations

2275060011 Aircraft /Air Taxi /Piston Itinerant Air Taxi Operations

2275060012 Aircraft /Air Taxi /Turbine Itinerant Air Taxi Operations

2275070000 Aircraft /Aircraft Auxiliary Power Units /Total Total Itinerant Operations

Exhibit 5.4 summarizes the region-wide growth factors by FAA operation type. The 

growth factor for individual airports/counties may deviate substantially from these regionwide growth factors.
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Exhibit 5.4 Region-wide Growth Factors from 2007 by FAA Operations Type

5.3.2.2 Aircraft Control Factors

The NOx aircraft engine emissions standards adopted by USEPA in November 2005 

(USEPA 2005) were reviewed. The standards are equivalent to the NOx emission 

standards (adopted in 1999 for implementation beginning in 2004) of the United Nations 

International Civil Aviation Organization (ICAO), and will bring the US aircraft standards 

into alignment with the international standards. The standards apply to new aircraft 

engines used on commercial aircraft including small regional jets, single-aisle and twinaisle aircraft, and 747s and larger aircraft. The standards also apply to general aviation and 

military aircraft, which sometimes use commercial engines. For example, small regional jet 

engines are used in executive general aviation aircraft, and larger commercial aircraft 

engines may be used in military transport aircraft. 

Nearly all previously certified or in-production engine models currently meet or perform 

better than the standards USEPA adopted in the November 2005 rule. In addition, 

manufacturers have already been developing improved technology in response to the 

ICAO standards. According to USEPA’s recent analysis for the proposed transport rule 

(USEPA 2010b), this rule is expected to reduce NOx emissions by approximately 2 percent 

in 2015 and 3 percent in 2020. Because of the relatively small amount of NOx reductions, 

our aircraft emission projections do not account for this control program.

USEPA has also issued an Advance Notice of Proposed Rulemaking (ANPR) on lead 

emissions from piston-engine aircraft using leaded aviation gasoline (USEPA 2010c). 

However, this rule has not yet been adopted and co-benefits for criteria air pollutants are

likely to be small. Therefore, the effects of this rule were not included in the future-year 

emissions projections.
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5.3.2.3 State-specific Airport Updates for 2025

After reviewing the growth factors described in the previous section, Connecticut provided 

state-specific growth factors for 2025 by SCC and county. These state-specific factors 

were used instead of the factors described in the previous section.

New Jersey provided updated aircraft growth factors and emission estimates for 2007, 

2013, 2017, 2020, and 2025. These data were used to replace the emission estimates 

previously used for the 2007 MANE-VU+VA base year inventory and the MANEVU+VA future year inventories.

5.3.3 Railroad Locomotives

Railroad locomotive engine emissions in the 2007 MARAMA inventory are classified into 

the following categories:

Class I line haul locomotives are operated by large freight railroad companies and 

are used to power freight train operations over long distances (SCC 22-85-002-

006);

Class II/III line haul locomotives are operated by smaller freight railroad 

companies and are used to power freight train operations over long distances (SCC 

22-85-002-007);

Inter-city passenger train locomotives are operated primarily by Amtrak to provide 

inter-city passenger transport (SCC 22-85-002-008);

Independent commuter rail systems operate locomotives that provide passenger 

transport within a metropolitan area (SCC 22-85-002-009); and 

Yard/switch locomotives are used in freight yards to assemble and disassemble 

trains, or for short hauls of trains that are made up of only a few cars (SCC 22-85-

002-010).

5.3.3.1 Railroad Growth Factors

In March 2008, USEPA finalized a three part program that will dramatically reduce 

emissions from diesel locomotives of all types -- line-haul, switch, and passenger rail. As 

part of this work USEPA developed a national emission inventory for calendar years 2002 

through 2040. Emission projections methodologies for a baseline and controlled scenario 

were developed and documented (USEPA 2008b). USEPA used projection data from the 

AEO2006 (EIA 2006). Table A-7 of AEO2006 showed that freight rail energy use will 

grow 1.6 percent annually. 
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More recent growth data is available in the AEO2010 which was published in May 2010. 

There are separate projections for passenger rail and freight rail energy use. For the 

MANE VU+VA inventory the more recent AEO2010 growth projections were used.

Passenger rail data from AEO2010 Table A-7 was used to calculate the growth factor for 

2007-2025 to be 1.241. These growth factors were applied to inter-city passenger train 

locomotives (SCC 22-85-002-008) and independent commuter rail systems (SCC 22-85-

002-009). 

For freight rail, the data from AEO2010 Table A-7 was used to calculate the growth factor 

for 2007-2025 to be 1.098. The freight rail annual growth factors for Class I line haul 

(SCC 22-85-002-006), Class II/III line haul (SCC 22-85-002-007), and yard switch (SCC 

22-85-002-010) locomotives were used.

5.3.3.2 Railroad Control Factors

USEPA developed two scenarios that accounted for both the 2004 nonroad diesel rule and 

the 2008 diesel locomotive rule: 

USEPA’s baseline (pre-control) inventory accounted for 

1. AEO2006 annual growth in fuel use, 

2. The impact of existing regulations for Tier 0, 1, and 2 locomotive engines 

that take effect in 2008, 

3. The 2004 Clean Air Nonroad Diesel Rule that will decrease allowable 

levels of sulfur in locomotives fuel beginning in 2012, and 

4. Fleet turnover.

USEPA’s controlled inventory accounted for 

1. AEO2006 annual growth in fuel use, 

2. Reductions included in the baseline inventory, and 

3. Reductions from USEPA’s 2008 rule Final Locomotive-Marine rule for 

Tier 3 and 4 engines. This rule lowered diesel sulfur content and tightened 

emission standards for existing and new locomotives. 

4. Voluntary retrofits under the National Clean Diesel Campaign are not 

included in our projections.

To calculate a factor that accounted for reductions included in the USEPA controlled 

inventory, it was necessary to first calculate a “growth only” scenario applying USEPA’s 

1.6% annual growth rate to the 2006 base emissions. Once the growth rate was applied, 

then a control factor for each pollutant was calculated by dividing the future year 

controlled emissions by the future year “growth only” emissions. 
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Exhibit 5.5 shows the control factors for 2013, 2017, 2020, and 2025 for the five 

locomotive classifications and pollutants. 

5.3.3.3 State-specific Railroad Updates for 2025

New Jersey provided updated railroad growth factors, control factors, and emission 

estimates for 2007, 2013, 2017, 2020, and 2025. These data were used to replace the 

emission estimates previously used for the 2007 MANE-VU+VA base year inventory and 

the MANE-VU+VA future year inventories.

Exhibit 5.5 Rail Control Factors by Year, Pollutant, and SCC

Year NOx PM2.5 SO2

SCC 22-85-002-006 Line Haul Class I Operations

2013 0.771 0.595 0.003

2017 0.633 0.449 0.003

2020 0.547 0.364 0.003

2025 0.412 0.252 0.003

SCC 22-85-002-007 Line Haul Class II / III Operations

2013 1.000 0.829 0.003

2017 0.960 0.791 0.003

2020 0.920 0.752 0.003

2025 0.852 0.688 0.003

SCC 22-85-002-008 Inter-City Passenger

2013 0.571 0.566 0.003

2017 0.421 0.402 0.003

2020 0.340 0.294 0.003

2025 0.241 0.180 0.003

SCC 22-85-002-009 Commuter Rail

2013 0.571 0.566 0.003

2017 0.421 0.402 0.003

2020 0.340 0.294 0.003

2025 0.241 0.180 0.003

SCC 22-85-002-010 Yard / Switch

2013 0.912 0.777 0.003

2017 0.843 0.712 0.003

2020 0.771 0.650 0.003

2025 0.634 0.534 0.003
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6.0 ONROAD MOBILE SOURCES INCLUDED IN MOVES

6.1 MOVES MODEL CATEGORIES

USEPA’s MOVES model estimates emissions from vehicles travel such as cars, trucks, 

buses and motorcycles. These vehicles are powered by diesel, gasoline, and alternative 

fuel formulations. MOVES2010 includes the capability to estimate both vehicle exhaust 

and evaporative emissions (including vehicle refueling emissions) and brake wear and tire 

wear emissions for criteria pollutants and precursors. However, MOVES2010 does not 

include the capability to estimate emissions of re-entrained road dust. Estimates of

emissions from re-entrained road dust are included in the area source inventory. 

6.2 2007 MOVES MODEL INVENTORY

MARAMA provided county-level MOVES results for 2007 for CT, DE, DC, and MD. 

Other states (NJ, NY, PA, VA) provided results for affected counties in their states.

6.3 2025 MOVES MODEL INVENTORY

MARAMA provided county-level MOVES results for 2025 for CT, DE, DC, and MD. 

Other states (NJ, NY, PA, VA) provided results for affected counties in their states.
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7.0 EMISSION SUMMARIES

Exhibits 7.1 to 7.12 summarize PM2.5 and PM precursor emissions by PM nonattainment 

area and source sector for 2007 and 2025. Some general observations by pollutant include:

PM2.5 emissions are projection to decrease between 2007and 2025 in all PM 

nonattainment areas. The reductions are due to the turnover to cleaner onroad 

vehicles, nonroad engines, and residential wood combustion equipment. The 

PM2.5 emissions shown account for the application of the PM transport factor (see 

discussion in Section 2.2.1.1 of this TSD).

NOx emissions decline in all PM nonattainment areas between 2007 and 2025 and 

by more than 50 percent in a few areas. Most of the decline results from the 

turnover of the onroad vehicle fleet to vehicles with improved emission controls 

and fuel efficiency. Reductions in nonroad sources are also substantial. Three 

areas (Baltimore, NY/NJ/CT, and Washington DC/MD/VA) also show substantial 

reductions due to controls on EGUs. 

SO2 emissions decrease in all PM nonattainment areas. All areas are showing 

reductions due to the lower sulfur contents of fuels used by onroad vehicles and 

nonroad equipment. Additional reductions in areas located in Maryland, New 

Jersey, and New York are due to the lower sulfur content regulations in those state 

for home heating, distillate oil, and residual oil. Connecticut, Delaware, the 

District of Columbia, Pennsylvania, and Virginia did not take credit for any 

reductions for low sulfur fuel oils since they have not adopted the MANE-VU 

recommendations into their regulations (see discussion in Section 2.3.2.5 of the 

TSD). Especially large reductions are found in areas where controls are projected 

to be in place on EGUs (Allentown, Baltimore, Harrisburg, Metro New York, 

Philadelphia, Pittsburgh, Washington DC/MD/VA, and York, PA). 

County-by-county emissions for 2007 and 2025 are available on the MARAMA ftp site. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 81

Exhibit 7.1 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Allentown, PA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,987 1,936 -51 -2.6%

Nonroad MAR 516 277 -239 -46.3%

Nonroad NMIM 2,661 1,007 -1,654 -62.1%

Onroad MOVES 15,652 4,190 -11,462 -73.2%

Point EGU 7,763 5,837 -1,927 -24.8%

Point nonEGU 5,900 2,114 -3,786 -64.2%

34,480 15,362 -19,117 -55.4%

Direct PM2.5

Area 2,150 1,958 -192 -8.9%

Nonroad MAR 26 15 -11 -42.3%

Nonroad NMIM 229 113 -117 -51.0%

Onroad MOVES 528 190 -338 -64.0%

Point EGU 2,264 2,138 -125 -5.5%

Point nonEGU 1,301 1,227 -75 -5.7%

6,498 5,640 -858 -13.2%

Sulfur Dioxide (SO2)

Area 2,552 1,118 -1,434 -56.2%

Nonroad MAR 12 4 -8 -70.4%

Nonroad NMIM 147 4 -143 -97.3%

Onroad MOVES 118 43 -75 -63.2%

Point EGU 48,203 3,962 -44,241 -91.8%

Point nonEGU 5,868 5,875 7 0.1%

56,900 11,005 -45,895 -80.7%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 82

Exhibit 7.2 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Baltimore, MD

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 4,732 5,167 435 9.2%

Nonroad MAR 16,703 8,521 -8,182 -49.0%

Nonroad NMIM 10,466 4,265 -6,201 -59.2%

Onroad MOVES 43,939 15,900 -28,038 -63.8%

Point EGU 23,572 8,939 -14,634 -62.1%

Point nonEGU 11,981 13,362 1,380 11.5%

111,394 56,154 -55,240 -49.6%

Direct PM2.5

Area 5,004 5,197 193 3.9%

Nonroad MAR 572 201 -371 -64.8%

Nonroad NMIM 969 519 -450 -46.4%

Onroad MOVES 1,503 749 -755 -50.2%

Point EGU 6,677 7,134 456 6.8%

Point nonEGU 2,296 2,366 71 3.1%

17,022 16,166 -855 -5.0%

Sulfur Dioxide (SO2)

Area 2,316 315 -2,001 -86.4%

Nonroad MAR 1,803 268 -1,535 -85.1%

Nonroad NMIM 581 15 -566 -97.4%

Onroad MOVES 375 380 5 1.3%

Point EGU 93,665 18,922 -74,744 -79.8%

Point nonEGU 4,759 4,867 108 2.3%

103,499 24,766 -78,733 -76.1%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 83

Exhibit 7.3 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Hagerstown Martinsburg, MD-WV

Annual Annual Change (tpy) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 296 339 43 14.5%

Nonroad MAR 289 144 -145 -50.2%

Nonroad NMIM 793 301 -492 -62.0%

Onroad MOVES 5,124 1,966 -3,158 -61.6%

Point EGU 1,398 1,390 -8 -0.6%

Point nonEGU 1,982 1,518 -465 -23.4%

9,883 5,657 -4,225 -42.8%

Direct PM2.5

Area 501 538 37 7.3%

Nonroad MAR 10 3 -7 -68.6%

Nonroad NMIM 74 33 -41 -55.6%

Onroad MOVES 185 69 -117 -62.8%

Point EGU 310 299 -11 -3.5%

Point nonEGU 188 188 0 0.1%

1,269 1,131 -138 -10.9%

Sulfur Dioxide (SO2)

Area 274 83 -191 -69.7%

Nonroad MAR 5 2 -4 -69.4%

Nonroad NMIM 45 1 -44 -97.6%

Onroad MOVES 44 47 3 6.4%

Point EGU 5,536 4,590 -946 -17.1%

Point nonEGU 1,277 1,271 -6 -0.5%

7,182 5,993 -1,189 -16.5%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model

Note: only includes emissions for Washington County, MD; emissions for West Virginia portion of 

the nonattainment area will be provided by Maryland in their SIP submittal.
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 84

Exhibit 7.4 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Harrisburg-Lebanon-Carlisle-York, PA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 3,874 3,705 -169 -4.4%

Nonroad MAR 1,775 981 -793 -44.7%

Nonroad NMIM 5,329 2,055 -3,274 -61.4%

Onroad MOVES 36,440 9,338 -27,102 -74.4%

Point EGU 15,985 15,531 -454 -2.8%

Point nonEGU 10,965 9,646 -1,319 -12.0%

74,368 41,255 -33,113 -44.5%

Direct PM2.5

Area 5,452 5,201 -251 -4.6%

Nonroad MAR 74 35 -39 -52.3%

Nonroad NMIM 474 211 -263 -55.4%

Onroad MOVES 1,225 346 -879 -71.8%

Point EGU 2,123 2,060 -63 -3.0%

Point nonEGU 923 915 -8 -0.9%

10,272 8,769 -1,503 -14.6%

Sulfur Dioxide (SO2)

Area 4,900 2,763 -2,136 -43.6%

Nonroad MAR 30 15 -15 -50.2%

Nonroad NMIM 293 8 -285 -97.3%

Onroad MOVES 255 89 -165 -64.9%

Point EGU 106,189 5,179 -101,010 -95.1%

Point nonEGU 11,520 11,539 19 0.2%

123,186 19,593 -103,593 -84.1%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 85

Exhibit 7.5 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Johnstown, PA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 861 822 -39 -4.5%

Nonroad MAR 1,132 568 -564 -49.8%

Nonroad NMIM 909 366 -543 -59.7%

Onroad MOVES 6,017 1,217 -4,800 -79.8%

Point EGU 41,440 40,004 -1,435 -3.5%

Point nonEGU 932 1,097 165 17.7%

51,291 44,074 -7,216 -14.1%

Direct PM2.5

Area 1,198 1,114 -84 -7.0%

Nonroad MAR 45 18 -27 -60.6%

Nonroad NMIM 84 36 -48 -56.9%

Onroad MOVES 195 43 -152 -78.2%

Point EGU 2,867 2,768 -99 -3.4%

Point nonEGU 231 234 3 1.4%

4,619 4,212 -407 -8.8%

Sulfur Dioxide (SO2)

Area 1,179 593 -586 -49.7%

Nonroad MAR 13 1 -12 -95.9%

Nonroad NMIM 51 1 -50 -97.4%

Onroad MOVES 45 12 -32 -72.3%

Point EGU 143,303 141,481 -1,821 -1.3%

Point nonEGU 30 35 4 14.7%

144,621 142,123 -2,498 -1.7%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model

Note: summary includes emissions for all of Indiana County; however, only part of the county is in 

the nonattainment area. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 86

Exhibit 7.6 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Lancaster, PA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,827 1,704 -122 -6.7%

Nonroad MAR 293 140 -153 -52.1%

Nonroad NMIM 2,880 1,170 -1,710 -59.4%

Onroad MOVES 14,163 3,779 -10,384 -73.3%

Point EGU 0 0 0 0.0%

Point nonEGU 1,147 1,383 236 20.5%

20,310 8,177 -12,133 -59.7%

Direct PM2.5

Area 1,827 1,704 -122 -6.7%

Nonroad MAR 293 140 -153 -52.1%

Nonroad NMIM 2,880 1,170 -1,710 -59.4%

Onroad MOVES 14,163 3,779 -10,384 -73.3%

Point EGU 0 0 0 0.0%

Point nonEGU 1,147 1,383 236 20.5%

20,310 8,177 -12,133 -59.7%

Sulfur Dioxide (SO2)

Area 3,030 1,766 -1,264 -41.7%

Nonroad MAR 4 0 -3 -87.6%

Nonroad NMIM 144 5 -139 -96.8%

Onroad MOVES 104 38 -66 -63.4%

Point EGU 0 0 0 0.0%

Point nonEGU 102 120 18 17.5%

3,384 1,929 -1,454 -43.0%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 87

Exhibit 7.7 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Metro New York/Northern New Jersey/Long Island NY/NJ/CT

Annual Annual Change (tpy) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 64,044 56,873 -7,170 -11.2%

Nonroad MAR 46,842 31,820 -15,023 -32.1%

Nonroad NMIM 71,021 13,771 -57,250 -80.6%

Onroad MOVES 252,723 74,474 -178,249 -70.5%

Point EGU 36,928 34,378 -2,550 -6.9%

Point nonEGU 20,117 20,881 765 3.8%

491,675 232,198 -259,477 -52.8%

Direct PM2.5

Area 18,512 19,318 805 4.4%

Nonroad MAR 1,705 755 -950 -55.7%

Nonroad NMIM 5,926 1,528 -4,398 -74.2%

Onroad MOVES 10,189 4,878 -5,311 -52.1%

Point EGU 6,267 4,660 -1,607 -25.6%

Point nonEGU 1,530 1,704 174 11.4%

44,131 32,844 -11,287 -25.6%

Sulfur Dioxide (SO2)

Area 42,122 10,353 -31,768 -75.4%

Nonroad MAR 11,823 1,957 -9,865 -83.4%

Nonroad NMIM 2,204 56 -2,148 -97.5%

Onroad MOVES 1,750 1,564 -186 -10.6%

Point EGU 63,236 44,867 -18,370 -29.0%

Point nonEGU 5,293 5,351 59 1.1%

126,427 64,149 -62,279 -49.3%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model

Note: 2025 NMIM emissions for New York counties are missing from the above summaries.
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 88

Exhibit 7.8 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Philadelphia-Wilmington, PA/DE/NJ

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 18,043 17,741 -302 -1.7%

Nonroad MAR 12,271 9,357 -2,913 -23.7%

Nonroad NMIM 19,579 8,305 -11,274 -57.6%

Onroad MOVES 106,315 26,648 -79,668 -74.9%

Point EGU 12,616 4,873 -7,743 -61.4%

Point nonEGU 19,143 14,944 -4,199 -21.9%

187,967 81,869 -106,099 -56.4%

Direct PM2.5

Area 13,811 12,983 -829 -6.0%

Nonroad MAR 658 299 -360 -54.7%

Nonroad NMIM 1,808 1,059 -749 -41.4%

Onroad MOVES 3,795 1,443 -2,352 -62.0%

Point EGU 1,048 813 -236 -22.5%

Point nonEGU 3,524 3,062 -462 -13.1%

24,644 19,657 -4,987 -20.2%

Sulfur Dioxide (SO2)

Area 16,763 9,756 -7,007 -41.8%

Nonroad MAR 5,136 677 -4,459 -86.8%

Nonroad NMIM 998 32 -966 -96.7%

Onroad MOVES 773 422 -351 -45.4%

Point EGU 20,665 4,563 -16,102 -77.9%

Point nonEGU 14,370 8,990 -5,380 -37.4%

58,705 24,440 -34,265 -58.4%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 7.9 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Pittsburgh-Beaver Valley, PA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 8,608 8,613 5 0.1%

Nonroad MAR 14,258 7,116 -7,142 -50.1%

Nonroad NMIM 9,827 4,223 -5,605 -57.0%

Onroad MOVES 56,652 12,725 -43,927 -77.5%

Point EGU 82,657 84,453 1,795 2.2%

Point nonEGU 20,217 18,760 -1,456 -7.2%

192,219 135,890 -56,330 -29.3%

Direct PM2.5

Area 7,562 6,835 -728 -9.6%

Nonroad MAR 467 196 -271 -58.1%

Nonroad NMIM 880 432 -448 -50.9%

Onroad MOVES 1,905 531 -1,374 -72.1%

Point EGU 6,293 6,348 55 0.9%

Point nonEGU 5,108 5,109 1 0.0%

22,216 19,450 -2,766 -12.4%

Sulfur Dioxide (SO2)

Area 13,589 10,791 -2,798 -20.6%

Nonroad MAR 260 95 -165 -63.4%

Nonroad NMIM 529 15 -514 -97.2%

Onroad MOVES 419 141 -278 -66.4%

Point EGU 429,186 93,130 -336,056 -78.3%

Point nonEGU 13,247 13,699 451 3.4%

457,230 117,871 -339,359 -74.2%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model

Note: summary includes emissions for all of Allegheny, Armstrong, Greene and Lawrence counties; 

however, only parts of those counties are in the nonattainment area. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 90

Exhibit 7.10 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Reading, PA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,289 1,114 -175 -13.6%

Nonroad MAR 621 307 -314 -50.5%

Nonroad NMIM 1,911 696 -1,215 -63.6%

Onroad MOVES 11,370 2,831 -8,538 -75.1%

Point EGU 2,506 2,432 -74 -2.9%

Point nonEGU 3,288 1,919 -1,369 -41.6%

20,983 9,298 -11,685 -55.7%

Direct PM2.5

Area 1,859 1,727 -132 -7.1%

Nonroad MAR 30 15 -15 -51.5%

Nonroad NMIM 161 72 -88 -54.9%

Onroad MOVES 379 96 -284 -74.7%

Point EGU 947 921 -26 -2.7%

Point nonEGU 325 331 6 1.8%

3,701 3,161 -540 -14.6%

Sulfur Dioxide (SO2)

Area 2,389 1,223 -1,166 -48.8%

Nonroad MAR 7 1 -7 -92.6%

Nonroad NMIM 99 3 -96 -97.1%

Onroad MOVES 81 27 -53 -66.3%

Point EGU 14,491 13,990 -501 -3.5%

Point nonEGU 649 660 11 1.7%

17,716 15,903 -1,812 -10.2%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

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Exhibit 7.11 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Washington DC/MD/VA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 8,936 9,342 406 4.5%

Nonroad MAR 6,700 6,711 11 0.2%

Nonroad NMIM 20,181 8,003 -12,179 -60.3%

Onroad MOVES 42,971 14,067 -28,904 -67.3%

Point EGU 29,029 13,919 -15,109 -52.0%

Point nonEGU 8,826 11,253 2,427 27.5%

116,643 63,295 -53,348 -45.7%

Direct PM2.5

Area 9,528 9,725 198 2.1%

Nonroad MAR 201 160 -40 -20.2%

Nonroad NMIM 2,003 1,112 -891 -44.5%

Onroad MOVES 1,467 728 -739 -50.4%

Point EGU 4,984 4,996 12 0.2%

Point nonEGU 563 594 32 5.6%

18,746 17,316 -1,430 -7.6%

Sulfur Dioxide (SO2)

Area 5,733 3,862 -1,871 -32.6%

Nonroad MAR 416 488 72 17.3%

Nonroad NMIM 1,230 30 -1,201 -97.6%

Onroad MOVES 387 347 -40 -10.4%

Point EGU 179,243 24,694 -154,549 -86.2%

Point nonEGU 4,206 3,570 -636 -15.1%

191,215 32,990 -158,225 -82.7%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model

Note: 2007 and 2025 MOVES onroad emissions for Virginia counties are missing from the above 

summaries.
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 92

Exhibit 7.12 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: York, PA

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,680 1,678 -2 -0.1%

Nonroad MAR 198 104 -93 -47.2%

Nonroad NMIM 2,463 836 -1,627 -66.1%

Onroad MOVES 10,519 2,740 -7,779 -74.0%

Point EGU 15,760 15,226 -534 -3.4%

Point nonEGU 6,404 6,431 28 0.4%

37,024 27,015 -10,008 -27.0%

Direct PM2.5

Area 2,394 2,325 -69 -2.9%

Nonroad MAR 13 7 -6 -48.7%

Nonroad NMIM 189 77 -112 -59.4%

Onroad MOVES 348 121 -227 -65.2%

Point EGU 2,098 2,026 -72 -3.4%

Point nonEGU 364 365 1 0.3%

5,407 4,921 -486 -9.0%

Sulfur Dioxide (SO2)

Area 1,684 1,059 -625 -37.1%

Nonroad MAR 2 0 -2 -88.4%

Nonroad NMIM 132 3 -129 -97.5%

Onroad MOVES 79 28 -50 -63.8%

Point EGU 106,158 5,136 -101,021 -95.2%

Point nonEGU 9,743 9,749 6 0.1%

117,798 15,977 -101,821 -86.4%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 93

8.0 DELIVERABLES

Files are stored on MARAMA ftp site:

Address: ftp.marama.org

Login ID: regionalei

Password: marama2007 

Folder: /2025/Final 2025 (Version 3_3)

Exhibit 8.1 lists the file names for all final deliverables. 

Exhibit 8.1 Final Deliverables

File Name Description

TSD V3_3 MANE-VU 2025 Inventory PM 

Nonattainment Counties.docx

Technical Support Document for 2025 emission 

inventory for PM nonattainment counties

Appendix A1 AEO2010 New England.xls AEO2010 Energy Consumption by Sector and 

Source for New England Region (CT, MA, ME, 

NH, RI, VT) and calculated growth factors

Appendix A2 AEO2010 Mid Atlantic.xls AEO2010 Energy Consumption by Sector and 

Source for Mid-Atlantic Region (NJ, NY, PA) 

and calculated growth factors

Appendix A3 AEO2010 South Atlantic.xls AEO2010 Energy Consumption by Sector and 

Source for South Atlantic Region (DC, DE, MD, 

VA) and calculated growth factors

Appendix A4 AEO2011 New England.xls AEO2011 Energy Consumption by Sector and 

Source for New England Region (CT, MA, ME, 

NH, RI, VT) and calculated growth factors

Appendix A5 AEO2011 Mid Atlantic.xls AEO2011 Energy Consumption by Sector and 

Source for Mid-Atlantic Region (NJ, NY, PA) 

and calculated growth factors

Appendix A6 AEO2011 South Atlantic.xls AEO2011 Energy Consumption by Sector and 

Source for South Atlantic Region (DC, DE, MD, 

VA) and calculated growth factors

Appendix A7 AEO2010 vs AEO2011 

Comparison.docx

Technical Memorandum comparing AEO2010 

and AEO2011 energy consumption projections

Appendix B Population_Factors.xls County-level population growth factors as 

provided by states
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 94

File Name Description

Appendix C Employment_Factors.xls State-level employment growth factors provided 

by states

Appendix D VMT GF Nonattainment 

Counties.xls

County-level VMT for 2007 and 2025

Appendix E EPA2020 Res Wood.xls USEPA growth factor formulas by SCC for 

residential wood combustion

Appendix F AEO2011-Electricity Generation by

EMM.xlsx

AEO 2011 Electricity Generation by Electricity 

Market Module Region and Source, Reference 

case, and associated growth factors

Appendix G UAF NEEDS Control 

FileMASTER92211.xls

State information on future EGU controls and 

emission rates

Appendix H MAR Growth and Control.xls USEPA and FAA data used to develop growth 

and control factors for commercial marine 

vessels, airports, and railroads

V3_3 Area_07_25 PM Nonattainment.xlsx County and SCC-level emissions and 

growth/control factors for area sources

V3_3 EGU_07_25 PM Nonattainment.xlsx Unit level emissions and growth/control factors 

for EGUs

V3_3 MAR_07_25 PM Nonattainment.xlsx County and SCC-level emissions and 

growth/control factors for commercial marine 

vessels, airports, and railroad locomotives

V3_3 MOVES_07_25 PM Nonattainment.xlsx County level emissions for onroad vehicles 

included in USEPA’s MOVES model

V3_3 NMIM_07_25 PM Nonattainment.xlsx County and SCC-level emissions for nonroad 

equipment included in USEPA’s 

NMIM/NONROAD model

V3_3 NonEGU_07_25 PM Nonattainment.xlsx Unit level emissions and growth/control factors 

for nonEGUs

V3_3 Summaries_ 07_25 PM

Nonattainment.xlsx

Emission summaries by county and 

nonattainment area
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012

Page 95

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