## MARYLAND DEPARTMENT OF THE ENVIRONMENT
1800 Washington Boulevard  Baltimore MD 21230

410-537-3000  1-800-633-6101  www.mde.state.md.us

Martin O’Malley Robert M. Summers, Ph.D. Governor Secretary

Anthony G. Brown

Lieutenant Governor



# Baltimore Serious Nonattainment Area 0.08 ppm 8-Hour Ozone State Implementation Plan

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

Serious Area Attainment Demonstration



# SIP Number:

13-07

June 17, 2013

Prepared for:



## U.S. Environmental Protection Agency

Prepared by:



## Maryland Department of the Environment

## This Page Left Intentionally Blank

## PLAN TO IMPROVE AIR QUALITY IN THE

BALTIMORE MD REGION

State Implementation Plan (SIP)

“Serious Area SIP”

For the 0.08 ppm National Ambient Air Quality Standard for Ozone

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

Serious Area Attainment Demonstration

for the

BALTIMORE MD

NONATTAINMENT AREA

Prepared by:

Maryland Department of the Environment

June 17, 2013THIS PAGE LEFT INTENTIONALLY BLANK

## Table of Contents

1.0 ...........................................................................................................1 Executive Summary

1.1 ......................................................................................................................... 1 Introduction

1.2 .............................................................................................................................. 2 Emissions

1.3 ................................................................................................................. 2 Control Programs

1.4

.............................................................................................................................. 3 Modeling

1.5 .............................................................................................................. 3 Weight of Evidence

2.0 ............................................................................................5 Introduction and Background

2.1 ................................................................................................ 5 State Implementation Plans

2.2 ......................................................................................................................... 6 Clean Air Act

2.3

................................................................................................. 7 Eight

‐ Hour Ozone Standard

2.4 ...................................................... 8 SIP Requirements for Moderate Nonattainment Areas

2.5 ............................... 8 SIP Requirements when Reclassifying from “Moderate” to “Serious”

2.6 ............................................................................................................. 9 Ground Level Ozone

2.7 ............................................................................... 10 Air Pollution and the Chesapeake Ba y

2.8 ..................................................................................................................... 11 Health Effects

2.9

.................................................................. 12 Maryland

‐ specific Air Pollution Health Effects

2.10 ............................................................................. 13 The Impact of Ozone Up on Agriculture

2.11 ................................................................................................ 13 The Air Quality Index (A QI)

2.12 ......................................................... 15 Sources of Ozone Pollution in the Baltimore Region

2.13 ......................................... 17 Frequency of Violation of Federal Health Standard for Ozone

2.14 ...................................................................................................... 18 Required SIP Principles

2.15 ............................................................................................................................ 19 Sanctions

2.16 ............................................................................................. 19 Reasonable Further Progress

2.17 ............................................ 19 Analysis of Reasonably Available Control Measures (RACM)

2.18 ...................................................................................................... 20 Contingency Measures

3.0 .....................21 The 2002 Base

‐ Year Inventory and Reasonable Further Progress Revisions

3.1 ......................................................................................... 21 Background and Requirements

3.2 .................................................................................................. 21 Total Emissions by Source

3.2.1 .............................................................................................................................. 2 1 Point Sources

3.2.2 ................................................................................................................... 22 Quasi

‐ Point Sources

3.2.3

............................................................................................................................... 22 Area Sources

3.2.4 ........................................................................................................................... 23 Mobile Sources

3.2.5 ........................................................................................................................ 24 Nonroad Sources

3.2.6 ..................................................................................................................... 26 Biogenic Emissions

4.0 .......................27 Reasonable Further Prog ress Projected 2008, 2011 and 2012 Inventories

4.1 ....................................................................................... 27 Growth Projection Meth odology

4.1.1 ........................................................ 28 Growth Projection Methodology for Point Sources: EGAS

4.1.2 ........................................................ 28 Growth Projection Methodology for Quasi

‐ Point Sources

4.1.3 ........................................................................ 28 Growth Projection Methodology: Area Sources

4.1.4 ................................................................. 31 Growth Projection Methodology: Nonroad Sources

4.1.5 ................................................................... 33 Growth Projection Methodology: Onroad Sources

Baltimore Serious Area 8-Hour Ozone SIP Page i4.1.6 .................................................................................................... 34 Biogenic Emission Projections

4.2 ........................ 34 Offset Provisions, Emissi on Reduction Credits and Point Source Growth

4.3

.................................................................................................................... 36 Actual vs. Allowable Emissions in Development of the 2008, 2011 and 2012 Projected

Emissions Inventories

4.4

.............................................................................................. 37 Projection Inventory Results

4.5 ........................................... 37 2008 Controlled Emissions for Reasonable Furthe r Progress

4.6 ........................................... 38 2011 Controlled Emissions for Reasonable Furthe r Progress

4.7 ........................................................................ 38 2012 Controlled Emissions for Attainment

5.0 ...........................................................40 2008 Reasonable Further Progress Requirements

5.1 ....................................................................................................................... 40 Introduction

5.1.1 ............ 40 Reasonable Further Progress Demonstrated in Previous State Implementation Plans

5.2 ..... 41 Guidance for Calculating Reasonable Further Progress (RFP) Emission Target Levels

5.2.1 ............................................................................................... 42 2008 VOC and NOx Target Levels

5.3 ................................ 46 Compliance with 2008 Reasonable Furt her Progress Requirements

6.0 ...........................................................48 2011 Reasonable Further Progress Requirements

6.1 ....................................................................................................................... 48 Introduction

6.2 ..... 48 Guidance for Calculating Reasonable Further Progress (RFP) Emission Target Levels

6.2.1 ............................................................................................... 48 2011 VOC and NOx Target Levels

6.3 ................................ 50 Compliance with 2011 Reasonable Furt her Progress Requirements

7.0 ...........................................................51 2012 Reasonable Further Progress Requirements

7.1 ....................................................................................................................... 51 Introduction

7.2 ..... 51 Guidance for Calculating Reasonable Further Progress (RFP) Emission Target Levels

7.2.1 ............................................................................................... 51 2012 VOC and NOx Target Levels

7.3 ................................ 53 Compliance with 2012 Reasonable Furt her Progress Requirements

8.0 ............................................................................................................54 Control Measures

8.1 ....................................................................................... 54 1

‐ Hour Ozone Control Measures

8.1.1 ........................................................................................................ 54 On

‐ Road Mobile Measures

8.1.2 ............................................................................................................... 56 Area Source Measures

8.1.3 ................................................................................................................... 59 Non

‐ Road Measures

8.1.4 .............................................................................................................. 61 Point Source Measures

8.2 ....................................................................................... 62 8

‐ Hour Ozone Control Measures

8.2.1 .......................................................................................... 63 The Maryland Healthy Air Act (HAA)

8.2.2 ..................................................................................... 65 Portable Fuel Containers Rule: Phase I

8.2.3 .......................................................... 66 Architectural and Industrial Maintenance Coatings Rule

8.2.4 ............................................................................................. 67 Consumer Products Rule: Phase 1

8.2.5 ...................................................................................... 68 Industrial Adhesives and Sealants Rule

8.2.6 .................................................................................... 69 Portable Fuel Containers Rule: Phase II

8.2.7 ............................................................................................. 70 Consumer Products Rule: Phase II

8.3 .................................................................................. 71 Voluntary and Innovative Measures

8.3.1 ........................ 71 Regional Forest Canopy Program: Conservation, Restoration, and Expansion

8.3.2 ................................................................................................. 74 Clean Air Teleworking Initiative

8.3.3 .......................................................................... 78 High Electricity Demand Day (HEDD) Initiative

8.3.4 ................................................................ 79 Emission Reductions from Transportation Measures

Baltimore Serious Area 8-Hour Ozone SIP Page ii9.0 ................................................86 Reasonably Available Control Measure (RACM) Analysis

9.1 .......................................................................................... 86 Analysis Overview and Criteria

9.1.1 ................................................................................................................. 87 Implementation Date

9.1.2 ............................................................................................................................. 87 Enforceability

9.1.3 ............................................................................................................ 88 Technological Feasibility

9.1.4 .............................................................................. 88 Economic Feasibility and Cost Effectiveness

9.1.5 ........................................................................... 88 Substantial and Widespread Adverse Impacts

9.1.6 ................................................................................................................ 88 De Minimis Threshold

9.1.7 .......................................................... 89 Advancing Achievement of 0.08 ppm (84 ppb) Standard

9.1.8 ......................................................................................................... 89 Intensive and Costly Effort

9.2 .................................................................................................... 89 RACM Measure Analysis

9.2.1 ................................................................................................................ 89 Analysis Methodology

9.2.2 .......................................................................................................................... 89 Analysis Results

9.3 ......................................................................................................... 90 RACM Determination

10.0

.............................................................................................. 91 Mobile Source Conformi ty

10.1 .. 92 Mobile Emissions Budget & the Baltimore Region Transportation Conformity Process

10.2 ......................................................... 92 Budget Level for On

‐ Road Mobile Source Emissions

10.3 ............................................................................................... 93 Trends in Mobile Emissions

11.0 .....................................................................................95 Serious Area Plan Commitments

11.1 .......................................................................... 95 Schedules of Adopted Control Measures

11.2 ............................................................................................ 98 Stationary Sourc e Thresholds

12.0 ....................................................................................................99 Contingency Measures

12.1 ............................................................................................................ 99 Purpose of Chapter

12.2 ................................................................................................ 99 Contingency Requirements

12.3 ................................................................................................................ 99 RFP Contingency

12.4 .................................................................................................. 100 Attainment Contingency

12.5 ...................................................................................................................... 101 Conclusions

13.0 ........................................................................... 104 Attainment Modeling Demonstration

13.1 ................................................................................................ 104 Modeling Study Overview

13.1.1 ................................................................................................. 104 Background and Objectives

13.1.2 ...................................................................... 106 Relationship to Regional Modeling Protocols

13.1.3 ........................................................................................................ 106 Conceptual Description

13.2 .......................................................................................... 106 Domain and Data Base Issues

13.2.1 ................................................................................................................. 106 Episode Selection

13.2.2 ............................................................................................... 107 Size of the Modeling Domain

13.2.3 ............................................................................................................. 107 Horizontal Grid Size

13.2.4 ............................................................................................................... 108 Vertical Resolution

13.2.5 .......................................................................................... 108 Initial and Boundary Conditions

13.2.6 ............................................................ 108 Meteorological Model Selection and Configuration

13.2.7 .................................................................... 109 Emissions Model Selection and Configuration

13.2.8 ................................................................... 109 Air Quality Model Selection and Configuration

13.2.9 ................................................................................................................ 110 Quality Assurance

13.3 ....................................................................................... 110 Model Performance Evaluation

Baltimore Serious Area 8-Hour Ozone SIP Page iii13.3.1 .............................................................................................................................. 1 10 Overview

13.3.2 ............................................................................... 111 Diagnostic and Operational Evaluation

13.3.3 ........................................................................................ 113 Summary of Model Performance

13.4 .............................................................................................. 114 Attainment Demonstration

13.4.1 .............................................................................................................................. 1 14 Overview

13.4.2 ................................................................................................... 114 Modeling Attainment Test

13.4.3 ................................................................................................. 117 Unmonitored Area Analysis

13.4.4 .......................................................................................................... 118 Emissions Inventories

13.4.5 .................................................. 119 Summary and Conclusions of Attainment Demonstration

13.5 ................................................................................................ 123 Procedural Requirements

13.5.1 ............................................................................................................................. 12 3 Reporting

13.5.2 ...................................................................... 123 Data Archival and Transfer of Modeling Files

14.0 ............................................................ 125 Weight of Evidence Attainment Demonstration

14.1 ...................................................... 125 Ambient Air Monitoring Measurements and Trends

14.1.1 ...................................................................................... 125 The Ambient Monitoring Network

14.1.2 ....................................................................................................................... 127 Ozone Trends

14.1.3 ................................................................................... 130 Temperature Adjusted Ozone Trend

14.1.4 ......................................................................................... 132 Ambient Ozone Precursor Trend

14.1.5 ....................................................................................................... 133 Supplemental Modeling

Baltimore Serious Area 8-Hour Ozone SIP Page iv

## Appendices

Appendix A – (Chapter 4) Projection Year Emission Inventories Appendix A-1: Projection Year Em ission Inventory Methodologies Appendix A-2: Point Source Base Year Inventory Appendix A-3: Quasi-Point Source Base Year Inventory Appendix A-4: Area Source Base Year Inventory Appendix A-5: Mobile Sour ce Base Year Inventory Appendix A-6: Nonroad Sour ce Base Year Inventory

Appendix B – (Chapters 5, 6, & 7) Reasonable Further Progress Calculations

Appendix C – (Chapter 8) Regulatory Support Information

Appendix D – (Chapter 9) RACM Measures List

Appendix E – (Chapter 10) Mobile Budget Documentation

Appendix F – (Chapter 13) Attainment Demonstration Appendix F-1: Baltimore Nonattainme nt Area Ozone Modeling Protocol Appendix F-2: Conceptual Description Appendix F-3: Episode Selection Documentation Appendix F-4: Modeling Domain Boundary Appendix F-5: Horizontal Grid Definition for MM5 and CMAQ Modeling Domain Appendix F-6: Vertical Layer Definiti ons for MM5 and CMAQ Modeling Domain Appendix F-7: Report on the Set-up and Appli cation of the 36 km CMAQ Model and the Extraction of the Boundary Conditions Appendix F-8: MM5 Model Performance Evaluation Appendix F-9: MM5 Model Configurations Appendix F-10: SMOKE Processing Description and Configuration Appendix F-11: CMAQ Configuration Appendix F-12: CMAQ Performance Appendix F-13: Additional Information on the RRF and the Modeled Attainment Test Appendix F-14: Future Year M odeling Emissions and Controls

Baltimore Serious Area 8-Hour Ozone SIP Page v

## List of Tables

Table 1

‐ 1: Control Measure Summary ................................................................................................ 3

Table 2

‐ 1: Top Ten Sources of Human Made Volatile Organic Compound (VOCs) in the Baltimore

Area in 2002, 2008, 2011 and 2012 ................................................................................................... 16

Table 2

‐ 2: Top Ten Sources of Nitrogen Oxides (NOx) in the Baltimore Area in 2002, 2008, 2011

and 2012

............................................................................................................................... ............. 17

Table 4

‐ 1: 2002

‐ 2008 Growth Factors .............................................................................................. 29

Table 4

‐ 2: 2002

‐ 2011 Growth Factors .............................................................................................. 29

Table 4

‐ 3: 2002

‐ 2012 Growth Factors .............................................................................................. 29

Table 4

‐ 4: Emission Reduction Credit s ............................................................................................. 34

Table 4

‐ 5: 2008 Projected Controlled VOC & NOx Emissions (tons/day) Baltimore No nattainment

Area

............................................................................................................................... ..................... 38

Table 4

‐ 6: 2011 Projected Controlled VOC & NOx Emissions (tons/day) Baltimore No nattainment

Area

............................................................................................................................... ..................... 38

Table 4

‐ 7: 2012 Projected Controlled VOC & NOx Emissions (tons/day) Baltimore No nattainment

Area

............................................................................................................................... ..................... 39

Table 5

‐ 1: 2002 Reasonable Further Progress Base

‐ Year Inventory (Ozone Season tons per day) 43

Table 5

‐ 2: 2002 Reasonable Further Progress Adjusted

‐ Year Inventory (Ozone Season tons per day)

............................................................................................................................... ..................... 44

Table 5

‐ 3: 2008 Reasonable Further Progress Adjusted

‐ Year Inventory (Ozone Season tons per day)

............................................................................................................................... ..................... 45

Table 5

‐ 4: Calculation of Non

‐ creditable Emissions Reductions (Ozone Season tons per day) ....... 45

Table 5

‐ 5: Calculation of VOC and NOx Target Levels for 2008 (Ozone Season tons per day) ...... 46

Table 5

‐ 6: Ba ltimore Nonattainment Area Comparison of 2008 Controlled and Target Inventories

Ozone Season Daily Emissions (tons per day) ................................................................................... 46

Table 6

‐ 1: Calculation of Non

‐ creditable Emissions Reductions (Ozone Season tons per day) ....... 49

Table 6

‐ 2: Calculation of VOC and NOx Target Levels for 2011 (Ozone Season tons per day)

........ 50

Baltimore Serious Area 8-Hour Ozone SIP Page viTable 6

‐ 3: Baltimore Nonattainment Area Comparison of 2011 Controlled and Target Inventories

Ozone Season Daily Emissions (tons per day) ................................................................................... 50

Table 7

‐ 1: Calculation of Non

‐ creditable Emissions Reductions (Ozone Season tons per day) ....... 52

Table 7

‐ 2: Calculation of VOC and NOx Target Levels for 2012 (Ozone Season tons per day)

........ 53

Table 7

‐ 3: Ba ltimore Nonattainment Area Comparison of 2012 Controlled and Target Inventories

Ozone Season Daily Emissions (tons per day) ................................................................................... 53

Table 8

‐ 1: Summary of Emissions Credits Available from Control Measures .................................. 63

Table 8

‐ 2: Annual Maryland Healthy Air Act NOx Emissions Reductions (TPY): .............................. 64

Table 8

‐ 3: Ozone Season Maryland Healthy Air Act NOx Emissions Reductions* ........................... 65

Table 8

‐ 4: Clean Air Teleworking Time Line ...................................................................................... 77

Table 10

‐ 1: 2012 Attainment Year Mobile Budgets for the Baltimore No nattainment Area .......... 93

Table 11

‐ 1: Maryland Schedule of Adopted Control Measures Baltimore, Washington DC, and Cecil
County Nonattainment Areas ............................................................................................................ 95

Table 11

‐ 2: Maryland Non

‐ CTG RACT Baltimore and Washington Nonattainment Areas .............. 97

Table 12

‐ 1: Baltimore No nattainment Area Comparison of 2012 Target Inventory plus 3%
Contingency and 2012 Controlled Inventories ................................................................................ 100

Table 12

‐ 2: Required Attainment Contingency .............................................................................. 100

Table 12

‐ 3: Minimum VOC Reduction s Required for Attainment Contingency ............................. 101

Table 12

‐ 4: Contingency Measure Calculations .............................................................................. 102

Table 13

‐ 1: Jurisdictions within the 8

‐ Hour Ozone Baltimore NAA

................................................ 105

Table 13

‐ 2: Baltimore NAA Statistics for 8

‐ ho ur Ozone ................................................................. 111

Table 13

‐ 3: Individual Site Statistics for 8

‐ hour Ozone Using 40 ppb Cutoff ................................. 111

Table 13

‐ 4: Individual Site Statistics for 8

‐ hr Ozone Using 60 ppb Cutoff ...................................... 112

Table 13

‐ 5: Modeling Attainment Test Using EPA Preferre d Methodology ................................... 115

Baltimore Serious Area 8-Hour Ozone SIP Page viiBaltimore Serious Area 8-H our Ozone SIP Page viii 

## List of Figures

Figure 2

‐ 1: Map of the Baltimore Metropolitan Eight

‐ hour Ozone Nonattainment Re gion .............. 7

Figure 2

‐ 2: Formation of Ground Level Ozone

................................................................................. 10

Figure 2

‐ 3: The Air Quality Index an d Action Guide ......................................................................... 14

Figure 2

‐ 4: Air

‐ Watch.ne t Real

‐ time Air Quality Data and Forecasts ............................................... 15

Figure 2

‐ 5: 8

‐ Hour Ozone Exc eedance Days for the Baltimore Nonattainment Area ...................... 18

Figure 8

‐ 1: Air Quality Ac tion Guide ................................................................................................. 75

Figure 13

‐ 1: 8

‐ Hour Ozone Baltimore NAA

..................................................................................... 105

Figure 13

‐ 2: Locations of Ozone Monitors in the Baltimore NAA

.................................................. 112

Figure 13

‐ 3: Baltimore NAA 8

‐ Hour Ozo ne Base Year (2002) and Future Year (2012) Design Values

............................................................................................................................... ........................... 116

Figure 13

‐ 4: Spatially Interpolated Extent of the 8

‐ Hour Ozone in the Baltimore NAA Using

Predicted 2012 Design Values ......................................................................................................... 118

Figure 13

‐ 5: Spatially Interpolated Extent of the 8

‐ Hour Ozone Within the Baltimore NAA Using

2002 Base Year Design Values ......................................................................................................... 120

Figure 14

‐ 1: Maps of the 2012 Ozone Monitoring Sites

................................................................. 126

Figure 14

‐ 2: Trend in 8

‐ hour Ozone Design Values per Year for all Maryland Sites ...................... 127

Figure 14

‐ 3: Trend in 8

‐ hour Ozone Exceedan ce Days per Year for all Maryland Sites ................. 128

Figure 14

‐ 4: Trends in Average Daily Peak 8

‐ hour Ozone for all Maryland Sites Binned by Four

‐ year
Periods

............................................................................................................................... .............. 129

Figure 14

‐ 5: Trend in Diurnal Ozone by 3

‐ year Rolling Averages for All Maryland Sites from the

Summers (A pril 1

– October 31) of 1993 through 2009 .................................................................. 130

Figure 14

‐ 6: Maryland Air Quality: Day s above 90  F and Ozone Exceedances, 1982

‐ 2008 .......... 131

Figure 14

‐ 7: Trend in Diurnal NOx by 3

‐ year Rolling Averages for All Sites in Maryland during the

Summers (April 1

– October 31) of 1993 through 2009 .................................................................. 132

## 1.0 EXECUTIVE SUMMARY

This document, the Baltimore Serious Nonattainment Area 0.08 ppm 8-Hour Ozone State Implementation Plan (“Serious Area Attainment Plan”)

, is a plan to improve air quality in the Baltimore region to meet the 1997, 0.08 ppm, nationa l ambient air quality standard (NAAQS) for ozone (8-hour ozone standard). The Plan consists of two Rate of Progress demonstrations, for the periods 2002-2008 and 2008-2011; and an attainment demonstration for 2012.

Additionally, the plan includes commitments by the state to meet requirements for serious nonattainment areas; it also includes commitme nts by the state to meet additional U.S. Environmental Protection Agency (EPA) requi rements for the Baltimore region, including a contingency plan for 2008 rate of progress, continge ncy plans for the 2012 rate s of progress, and an analysis of reasonably available control measures (RACM). The plan presents revised emissions inventories for 2002, 2008, 2011, and 2012 based on the MOVES2010a model for estimating onroad vehicle emissions. The anal ysis methodology is c onsistent with past statewide inventory

efforts.

The Serious Area Attainment Plan is intended to show the progr ess being made to improve air quality in the Baltimore Nonattainment Area and the efforts underway to assure that all necessary steps are taken to reach the federal health st andard for ground-level ozone by 2012. The plan has been prepared by the Maryland Department of the Environment Air and Radiation Management Administration to comply with the Clean Air Act Amendments of 1990 (CAAA) and with EPA requirements for the Baltimore region as stated in EPA’s reclassification of the Baltimore region (77 Fed. Reg. 4901, February 1, 2012).



### 1.1 INTRODUCTION

Ground level ozone is considered a significant health based pollutant and the EPA has set a specific national ambient air quality standard for ozone to best protect public health. This standard, known as the 8-hour ozone standard, is implemented by the federal Clean Ai r Act (“CAA” or “the Act”). Areas of the county that monitor air polluti on above the federal standard are designated

“nonattainment” and are therefore required to develop and implement air quality plans called State Implementation Plans, or SIPs, that show how a particular region will reduce pollution to the point where the region will meet the federal standards.

The Baltimore region, which comprises Baltimore C ity and the surrounding counties of Baltimore, Carroll, Anne Arundel, Howard and Harford, has been designated nonattainment under the 8-Hour Ozone standard. The following document explai ns the process by which the region will reduce pollution and meet the federal ozone standard by 2013 which is the de signated attainment date for the Baltimore region.

Baltimore Serious Area 8-Hour Ozone SIP Page 1

### 1.2 EMISSIONS

A significant portion of this document is related to emissions. Nitrogen oxide (NOx) and volatile organic compound (VOC) emissions create ozone unde r heat and sunlight. Reductions in these ozone precursor emissions are a necessity to re duce ozone pollution. The MDE is responsible for creating a NOx and VOC emissions i nventory that estimates the actual emissions created by all the

emission sources in our state. Emissions come fr om a variety of sources including mobile sources such as cars and trucks, point s ources such as power plants, area sources such as lawnmowers, and

non-road sources such as construction equipment and all terrain vehicles.

This document details the current emissions i nventory for NOx and VOC and predicted future emissions. It is important to project emissions in the future in order to tr ack progress achieved from emissions-reducing programs. Als o, projected emissions are incor porated into the attainment analysis work that actually predicts whether or not a region will meet the air quality standard.

The good news exhibited by this document is that NOx and VOC emissions are decreasing in the Baltimore region. Control programs aimed at re ducing emissions have been developed and implemented and the reductions required by these programs are significant. Population growth, economic growth, and public needs have a tendenc y, though, to reduce the impact of the emission reductions that come from control programs. Desp ite these obstacles, the overall trend in NOx and VOC emissions is downward, and MDE predicts that with additional reductions cleaner air will

come.



### 1.3 CONTROL PROGRAMS

Over the past several decades the MDE has adopt ed and implemented numerous control programs (laws, regulations, and voluntar y measures) that reduce NOx and VOC emissions in Maryland. In addition, several new control measures are being a dopted specifically to he lp Maryland attain the federal ozone standard. The new programs, in addition to the existing control programs that continue to be implemented and enforced, allow Maryland to develop an attainment demonstration that shows how Maryland will meet the federal ozone standard.

The most significant new control program is the Maryland Healthy Air Act (HAA), which substantially reduces NOx from Maryland’s older coal burning power plants. The HAA is more stringent than the parallel federal rule called the Clean Air Interstate Rule and is the most substantial emission control program ever a dopted in Maryland. Ov erall, the HAA reduced Maryland power plant NOx emissions by 70% (c ompared to 2002 levels) in 2009 and by 75% by 2012. The 2009 and 2012 reductions are a significant pa rt of the attainment scheme developed by

the MDE to meet the federal ozone standard.

Addition control programs being implemented to he lp Maryland meet the fe deral ozone standard include several VOC rules targeted at adhesives and sealants, lowe r VOC portable fuel containers, and lower VOC consumer products. Other non-traditi onal measures include an aggressive telework (also called “telecommuting”) pr ogram and a tree canopy program.

The following is a brief summary of new control measures being implemented to assist Maryland with attaining the 8-hour ozone standard.

Baltimore Serious Area 8-Hour Ozone SIP Page 2Table 1-1: Control Measure Summary

2008 2011 2012

Control Measure VOC NOx VOC NOx VOC NOx

On

‐ road Mobile Measures 52.86 158.43 61.94 181.42 66.59 192.33

Consumer Products Phase 1 3.70 0.00 3.77 0.00 3.79 0.00

Consumer Products Phase 2 0.00 0.00 0.46 0.00 0.46 0.00

Low VOC Paints (Architectural and

Maintenance Coatings ‐ AIM) 6.03 0.00 6.19 0.00 6.19 0.00

Portable Fuel Containers Phase 1 6.71 0.00 8.31 0.00 8.35 0.00

Portable Fuel Containers Phase 2 0.00 0.00 0.60 0.00 0.60 0.00

Industrial Adhesives Rule 0.00 0.00 2.63 0.00 2.64 0.00

Nonroad Measures 17.85 8.12 26.33 14.55 29.83 17.30

Railroads (Tier 2) 0.00 1.18 0.00 1.19 0.00 1.20
Healthy Air Act (HAA) 0.00 0.00 0.00 31.86 0.00 37.18

Total 87.14 167.73 110.51 229.35 118.45 248.48
* All control levels are in tons pe r day (tpd) and all totals are rounded.



### 1.4 MODELING

A significant part of the attainment demonstratio n for Maryland consists of air quality modeling analysis. Required by the Act, ai r quality models are run to exam ine future air quality conditions and whether or not a region will attain the standard by its designated attainment date. The models are not relied upon as the only attainment test but are an important pa rt of the attainment demonstration for Maryland.

The air quality modeling analysis completed for this SIP sh ows the Baltimore Nonattainment Area attaining the 8-hour ozone standar d. All of the air quality monito rs located in th e nonattainment area are predicted to be at levels consistent with attainment.



### 1.5 WEIGHT OF EVIDENCE

As mentioned above, air quality mode ls are not the only tool availabl e to predict atta inment of the federal ozone standard. A weight of evidence approach can be used to further analyze air quality data, trends, and meteorology and complete supplemental modeling. The MDE has completed supplemental data analyzes to show that the Baltimore NAA will indeed meet the federal ozone standard by 2013.

Some of the weight of evidence analysis utilized for the Baltimore NAA includes:

 an analysis of ozone trends;

 an analysis of ozone precursor trends; and

 supplemental modeling.

Baltimore Serious Area 8-Hour Ozone SIP Page 3Based on the above analyses and air quality modeling pe rformed for the Baltimore NAA, the weight of evidence shows that the region will meet the 8-hour ozone standard by the end of the 2012 ozone

season.

Baltimore Serious Area 8-Hour Ozone SIP Page 4

## 2.0 INTRODUCTION AND BACKGROUND

This document, entitled Baltimore Serious Nonattainment Area 0.08 ppm 8-Hour Ozone State Implementation Plan, presents the Maryland Department of the Environment's (MDE) progress in adopting and implementing air pollution control programs needed to attain the 8-hour ozone standard by 2014 in the Baltimore metropolitan ar ea. Based on the control measures being implemented, the related air quali ty modeling results, and the wei ght of evidence demonstration prepared, there is significant evidence that the Baltimore Nonattainment Area will attain the 8-hour ozone standard by June 15, 2013.



### 2.1 STATE IMPLEMENTATION PLANS
The State Implementation Plan (SIP) is a detailed document required for states or regions that do not meet air quality levels set by the federal gover nment. The SIP identifies how that State will attain and/or maintain the primary and sec ondary National Ambient Air Quality Standards (NAAQS) set forth in section 109 of the Clean Air Act (“CAA” or “the Act") and 40 Code of Federal Regulations 50.4 through 50.12 and which includes federally-enforceable requirements. Each State is required to have a SIP that contains control measures and strategies that demonstrate how each area will attain and maintain the NAAQS . These plans are de veloped through a public process, formally adopted by the State, and su bmitted by the Governor's designee to EPA. The Clean Air Act requires EPA to review each plan a nd any plan revisions and to approve the plan or plan revisions if consistent with the Act.

SIP requirements applicable to all areas are provided in section 110 of the Act. Part D of Title I of the Act specifies additional requirements applicable to nonattai nment areas. Section 110 and part D describe the elements of a SIP and include, among other components, emission inventories, a monitoring network, an air quality analysis, modeling, attainment demonstrations, enforcement mechanisms, and regulations which have been adopt ed by the State to attain or maintain NAAQS. EPA has adopted regulatory requirements which de tail the procedures for preparing, adopting and submitting SIPs and SIP revisions. These regulatory requirements are codified in 40 CFR part 51. EPA's action on each State's SIP is promulgated in 40 CFR part 52.

The contents of a typical SIP fall into several cat egories: (1) State-adopted control measures which consist of either rules/regulations or source-specific requirements (e.g., orders and consent decrees); (2) State-submitted comprehensive air quality plans, such as attainment plans, maintenance plans rate of progress plans, and tran sportation control plans demonstrat ing how these state regulatory and source-specific controls, in conjunction with federal programs, will bring and/or keep air quality in compliance with federal air quality standards; (3) State-submitted "non-regulatory" requirements, such as emission inventories, small business compliance assistance programs, statutes demonstrating legal authority, and monitoring networks; and (4) additional requirements promulgated by EPA, in the absence of a commen surate State provision, to satisfy a mandatory section 110 or part D (CAA) requirement.

Once the Administrator of the EPA approves a state pl an, the plan is enforceable as a state law and

as federal law under Section 113 of the CAA. If the SIP is found to be inadequate in EPA's judgment to attain the NAAQS in all or any region of the state, and if the state fails to make the requisite amendments, under Sectio n110(c)(1), the EPA Administra tor may issue amendments to

Baltimore Serious Area 8-Hour Ozone SIP Page 5the SIP that are binding. EPA is required to impose severe sa nctions on the state under three

circumstances: the state's failure to submit a SIP revision; the finding of the inadequacy of the SIP to meet prescribed air quality requirements; and th e state's failure to enforce the control strategies

that are contained in the SIP. Sanctions incl ude withholding federal funds for highway projects other than those for safety, mass tr ansit, or transportati on improvement projects related to air quality improvement or maintenance; and the imposition of 2:1 offset sanctions; these sanctions begin 24 months after the EPA announcement. No federal agency or department will be able to award a grant or fund, license, or permit any tran sportation activity th at does not conform to the most recently approved SIP.



### 2.2 CLEAN AIR ACT

The Clean Air Act was passed in 1970 to protect public health and welfare. Congress amended the Act in 1990 to establish requirements for areas not meeting the National Ambient Air Quality

Standards. The Clean Air Act Amendments of 1990 (CAAA) established a process for evaluating air quality in each region and identifying and classifying nonattainment areas according to the severity of their air polluti on problem. The CAAA defines gr ound-level ozone as a criteria pollutant. In 1979 EPA promulgated the 0.12 parts per million (ppm) 1-hour ozone standard. In 1997, EPA issued a revised and stricter ozone standard of 0.08 ppm 1 measured over an eight-hour period. The one-hour ozone standard was consequently revoked in June 2005. The Clean Air Act also sets National Ambient Air Quality Standard s for five other criter ia pollutants; carbon monoxide, particulate matter, lead, sulf ur dioxide and ni trogen dioxide.

In April 2004, EPA designated the Baltimore metropol itan area as a “moderate” nonattainment area for the 0.08 ppm eight-hour ozone standard under Subpart 2 of part D, Title I. The boundaries of the

Baltimore Nonattainment Area are defined in the Federal Register, (Vol:69, no.84, 4/30/04). The

Baltimore Nonattainment Area includes Baltimore City and Anne Arundel, Baltimore, Carroll, Harford, and Howard counties. A map of the nona ttainment area is shown in Figure 2-1.

1 Note that the 0.08 ppm ozone standard is often referred to as “80 ppb,” “84 ppb,” or “85 ppb” due to issues of how 0.08 ppm is rounded when converted to units of parts per billion (ppb).

Baltimore Serious Area 8-Hour Ozone SIP Page 6Figure 2-1: Map of the Baltimore Metropoli tan Eight-hour Ozone Nonattainment Region

To meet the federal 0.08 ppm 8-hour standard for ozone, nonattainment areas are required to develop their SIP documents to reduce ozone-forming emissions by at least 15 percent between 2002-2008, and to reduce all ozone precursor emissions to a level sufficient to attain the federal eight-hour standard by June 15, 2010. However, the re gion is required to demonstrate attainment of the standard by the end of the last ozone seas on before that date, which is September 2009.

The region did not meet the Clean Air Act Amendm ents deadline of June 2010. Analysis suggests this was due to transported po llution from outside the region. Th is analysis was based on ozone concentrations measured at high elevation monitors located to the west of the Baltimore NAA. The results demonstrated the effect of transported po llution, which contributed potentially up to 50% of the pollution on the worst days of summer.



### 2.3 EIGHT-HOUR OZONE STANDARD

In 1997, EPA issued a revised ozone health standa rd based on an 8-hour measurement to protect human health against longer exposure periods. Since the late 1980’s, more than 3,000 published

health studies have indicated that health effect s occur at levels lower than the previous 1-hour standard and that exposure times longer than on e hour are of concern. EPA established an 8-hour standard at 0.08 ppm and defined the new standard as a “concentra tion-based” form, specifically the 3-year average of the annual 4th highest daily maximum 8-hour ozone concentration.

EPA changed the form of the standard to a concen tration-based form because it more accurately reflects actual human exposure and related health eff ects. Even at relatively low levels, ozone may cause inflammation and irritation of the respirator y tract, particularly dur ing physical activity. The resulting symptoms can include breathing diffi culty, coughing, and throat irritation. Breathing ozone can affect lung function and worsen asthma attacks. Ozone can increas e the susceptibility of

Baltimore Serious Area 8-Hour Ozone SIP Page 7the lungs to infections, allergens, and other air pollutants. Medical studies have shown that ozone damages lung tissue and complete recovery may take several days af ter exposure has ended.



### 2.4 SIP REQUIREMENTS FOR MODE RATE NONATTAINMENT AREAS

The Clean Air Act Section 182 (b) requires mode rate nonattainment areas to submit state implementation plan revisions that meet the following planning requirements:

 Reasonable Further Progress: 15% emission re duction from baseline within 6 years of

enactment

 Attainment demonstration: Due 3 years af ter CAA Amendments enactment (7/15/07)

 New Source Review (NSR) and Reasonably Av ailable Control Tec hnology (RACT) major source applicability: 100 tons per year (TPY)

 NSR offsets: 1.15 to 1

 NSR permits: required for new or m odified major stationary sources

 NOx control for RACT: requirement for major st ationary VOC sources al so applies to major

NOx sources

 RACM/RACT: RACT required for all Control Technique Guideline (CTG) sources and all other major sources

 Inspection and Maintenan ce (I&M): Basic I&M

 Stage II vapor recovery: required for all gas stations

 Contingency measures: required for failure to meet Reasonable Further Progress (RFP)

milestones or attain

Before designation as a moderate nonattainment area for the eight-hour standard, the Baltimore region was classified as a “severe” nonattainment area for the one-hour oz one standard. The Clean Air Act Section 182 (d) requirements for severe n onattainment areas include a number of planning requirements that are more stringent than those required for a moderate nonattainment area. Some of the more stringent requirements, such as lo wer permit thresholds, remain in force in the Baltimore region and throughout Maryland in order to prevent backsliding.

The more stringent regulations remaining in force in Maryland are the following:

 Lower permit threshold for point sources from 100 tons per year, to 25 tons per year;

 Lower threshold for definition of “Major” so urce to 25 tons per year for RACT control requirements;

 Require new or expanding sources to offset increased emissions by 1.3:1;

 Enhanced I&M



### 2.5 SIP REQUIREMENTS WHEN RECLASSIFYING FROM

“MODERATE” TO “SERIO US”

On February 1, 2012 (effective March 2, 2012) EPA r eclassified the Baltimore, MD Nonattainment

Area as a “serious” nonattainment area. 2 As a serious nonattainment area for 8-hour ozone National

2 EPA 40 CFR Part 81 , Federal Register , Vol. 77, No. 21, February 1, 2012, pp. 4901-4903.

Baltimore Serious Area 8-Hour Ozone SIP Page 8Ambient Air Quality Standard (NAAQS), the Baltimor e region is required to meet the requirements defined in the Clean Air Act, Section 182 (d) and to submit a revised serious area SIP by September 30, 2012. The “serious” nonattainment area requirements include:

 Meet all requirements for moderate nonattainment areas

 Adopt state regulations to meet CAA Section 182 (d)

 Adopt a contingency plan for 2008 Reasonable Further Progress (RFP)

 Require new or expanding sources to offset increased emissions by 1.3:1

 Revise and submit an updated attainment de monstration that reflects MOVES-based motor vehicle emissions budgets

 Demonstrate 3% per year reasonable furt her progress from 2008-2011 and from 2011-2012

 Adopt contingency measures for failur e to make RFP in those periods and

 Submit an analysis of Reasonably Available Control Measures for the region.

 Submit a new attainment demonstration



### 2.6 GROUND LEVEL OZONE

Ground-level ozone is an extremely reactive gas comprised of three atoms of oxygen. Ozone, the primary constituent of smog, continues to be a pollution problem throughout many areas of the United States. Unlike many other pollutants, ground-level ozone is not directly emitted into the atmosphere from a specific source. Instead, grou nd-level ozone is formed when nitrogen oxides (NOx) chemically react with vol atile organic compounds (VOCs) th rough a series of complicated chemical reactions in the presence of strong sunshine (u ltraviolet light).

Because ozone formation is greatest when the sun light is most intense, the peak ozone levels typically occur in Maryland during hot, dry, stagnant summertime c onditions generally referred to as the ozone season (April 1 to October 31). Peak ozone concentrations exhibit a clear seasonal cycle, with concentrations rising with the onset of warmer weather in the spring and declining again as the autumn approaches. Changing weather patt erns can significantly contribute to yearly

differences in ozone concentrations. Years with summertime weather conditions that are hot and dry will generally result in many more days of poor air quality than cool and wet summers.

Baltimore Serious Area 8-Hour Ozone SIP Page 9Figure 2-2: Formation of Ground Level Ozone

The formation of ozone is not an instantaneous pr ocess, nor is it limited in geographical scope. While many urban areas tend to have high levels of ozone, even rura l areas are subject to increased ozone levels because wind carries ozone, and the pollutants that form it, hundreds of miles from their original sources. Numerous studies and modeling data show compelling evidence that weather patterns often result in the transport of ozone and the polluta nts responsible for ozone formation, well beyond the locality that produced the emissions . In many cases, unhealt hy days of air pollution experienced in Maryland are ex acerbated by pollutants transporte d into Maryland from neighboring

states.

Ground-level ozone can have significant impacts on human health, particularly people with existing respiratory disease, the elderly, and children. Ozone also impacts the environment and ecosystem

health. Scientific evid ence suggests that air pollution weaken s the immune systems of many types of vegetation and can cause significant crop damage . In addition, rain and snow wash air pollution deposited on vegetation and architectural surfaces into the streams and rivers of the region and finally into the Chesapeake Bay.



### 2.7 AIR POLLUTION AND THE CHESAPEAKE BAY

Typically, air polluti on is thought of as smog that affects pe ople’s health and reduces visibility. However, air pollution also contributes to land an d water pollution that affects the health of the Chesapeake Bay’s resources - its fish, shellfish, an d other animals. Over the last thirty years, research has provided us with increased knowledge of how air pollution can di rectly affect the Bay.

Baltimore Serious Area 8-Hour Ozone SIP Page 10Pollutants released into the air will eventually ma ke their way back down to the earth’s surface. Some of the factors that determine how far pollutants can trav el through the air include the following: the chemical makeup of the pollutant, weather conditions (wind, temperature, humidity), type and height of the emission source (smokestack, automobile tail pipe), and the presence of other chemicals in the air. Airborne pollutants fall to the earth’s surface by wet deposition (precipitation), or dry deposition (settling or adsorption). Airborne pollutants th at deposit on the landscape can be transported into streams, rivers, and th e Bay by runoff or through groundwater flow.

Excess nitrogen and chemical contaminants from atmospheric deposition impact the Chesapeake Bay and its watershed. Too much nitrogen enteri ng the Chesapeake Bay l eads to eutrophication, a process that causes an accelerated growth of algae. Too much al gae in the Bay blocks sunlight needed for submerged aquatic vegetation to grow. Als o, when the algae die, th ey sink to the bottom of the Bay and decompose in a process th at depletes the oxygen in the water.

The effects of nitrogen can also be seen in acid rain. Nitrogen oxides (NOx ) are one of the key air pollutants causing acid deposition, which results in adverse effects in aquatic and terrestrial ecosystems. Acid deposition increases the acidity of water and soils. Increases in water acidity can impair the ability of certain fish and aquatic life to grow, reproduce, and survive. Increases in soil acidity can impair the ability of some type s of trees to grow and resist disease.



### 2.8 HEALTH EFFECTS

Ozone is a highly reactive gas that reacts strongly with living tissues, as well as many synthetic

substances. Since 90% of the oz one breathed into the lungs is ne ver exhaled, ozone molecules react with lung tissue to cause se veral health consequences. 3 Too much ozone in the air can be harmful to people who work or exercise outdoors regularly, a nyone with respiratory difficulties, and especially to children. The most common sy mptom that people have when exposed to ozone is pain when taking a deep breath. Exposure to ozone can result in both long-term and short-term effects in healthy individuals as well as t hose who are already se nsitive to air polluti on, such as children, asthmatics and the elderly.

Ozone’s long-term effects may include reduced l ung function, scarring of lung tissue, and even premature death. 4 Research suggests that repeated expos ure to ozone may cause damage to lung tissue, thereby reducing lung f unction. According to EPA, “Long- term exposures to ozone can cause repeated inflammation of the lung, impairment of lung defense mechanisms, and irreversible changes in lung structure, which could lead to premature aging of the lungs and/or chronic respiratory illnesses such as emphysema and chronic bronchitis.” 5

3 Sources and Health effects of Gr ound-Level Ozone, downloaded from http://www.dnr.state.wi.us/eq/aie/ozone/b_effect.htm

.

4 Bell ML, Dominici F, and Samet JM. A Meta-Anaysis of Time-Series Studies of Ozone and Mortality with Comparison to the National Morbidity, Mortality, and Air Pollution Study . Epdidemiology 2005; 16:436 445.

5 United States Environmental Protection Agecny. (17 July, 1997), Factsheet: EPA’s Revised Ozone Standard. United State Environmental Protection Agency , Technology Transfer Network, OAR Policy and Guidance. Retrived on December 28, 2005 from the World Wide Web: http://www.epa.gov/ttn/oarpg/naaqsfin/03fact.html/

Baltimore Serious Area 8-Hour Ozone SIP Page 11Children are at greater risk for ozone-related resp iratory problems because their lungs are still developing, they breathe more rapi dly, and they play outsi de during the afternoons when ozone is at its highest levels. Childre n also inhale more air; hence, th ey receive more pollution per pound of body weight than adults do. 6 Additionally, anyone suffering from lung disease has even more trouble breathing when air is polluted with high levels of ozone. Prolonged exposure, even to relatively low levels of ozone, can significa ntly reduce a healthy adult’s lung function. 7

Short-term effects of ozone exposure among hea lthy populations include impaired lung function and reduced ability to perform physical exercise . For example, healthy young people developed a significant reduction of lung function, additiona l coughing and breathing pains, and enhanced airway reactivity to irri tants when exposed to ozone at conc entrations of 80-120 parts per billion (ppb) for 6.6 to 7.0 hours while exercising moderately. 8 Among people who are especially sensitive to ozone pollution, short-term effects include in creased hospital admissions and emergency room visits for respiratory diseases such as asthma.

In summary, health effect s from exposure to ozone can include the following:

 Increased susceptibility to respiratory infection
 Impaired lung function and reduced ab ility to perform physical exercise
 Severe lung swelling and death, due to s hort-term exposures greater than 300 ppb
 Increased hospital admissions and emergency room visits for respiratory diseases



### 2.9 MARYLAND-SPECIFIC AIR PO LLUTION HEALTH EFFECTS

According to the U.S. Census Bureau, Cens us 2000 data, there are 5,296,486 people living in Maryland, of whom 1,136,846 were under 15 years of age, and of whom 599,307 were 65 or over 9

. This means that the total number of children and elderly in Maryland was 1,736,153. Approximately one third of Maryland’s population is more likely to suffer the adverse effects of air pollution simply as a result of their age.

6 Ambient Air Pollution: Respiratory Hazards to Children Committee on Environmental Health Pediatrics 1993 91:

1210-1213.

7 Galizia, A. and Kinney, P.L. Long-Term Residence in Areas of High Ozone: Associations with Respiratory Health in Nationalwide Sample of Nonsmoking Young Adults. August 1999. Environ Health Perspect, Vol. 107, No. 8, pp. 675-

679

8 Foinsbee et al., 1990; Horstman et al., 1990; McDonnell et al., 1991. Out of Breath: A Report on the Health Consequences of Ozone and Acidic Air Pollution in Metropolitan Chica go. American Lung Association of Metropolitan Chicago, October 19, 1994

9 United States Census Bureau. Census 2000 Demographic Profile highlights: Maryland. (Online, follow link to Maryland). United Stated Census Bureau, American FactFinder, 2000. Retrieved on March 28, 2005 from the World

Wide Web: http://factfinder.census.gov/

Baltimore Serious Area 8-Hour Ozone SIP Page 12According to an April 2006 10 report from the American Lung Asso ciation, the group of people with respiratory disease in the state of Maryland includes:

 274,967 adult asthmatics and 100,370 child asthmatics;
 147,226 residents with chronic bronchitis; and
 57,310 residents with emphysema.



### 2.10 THE IMPACT OF OZON E UPON AGRICULTURE

Because ozone formation requires sunlight, periods of high ozone concentration coincide with the agriculture growing season in Maryland. Ozone damage to plants can occur with or without any visible signs. Consequently, many farmers are unaw are that ozone is reducing their yields. Ozone enters the plant’s leaves through it s gas exchange pores (stomata), just as other atmospheric gases do in normal gas exchange. The ozone then dissolves in the water within the plant and reacts with other chemicals, causing a variety of problems.

Ozone damage in the plant causes photosynthesis to slow, resulting in slower plant growth. Such ozone induced problems also decrease the numbers of flowers and fruits a plant will produce, and impair water use efficiency and other functions. Plants weakened by ozone ma y be more susceptible to pests, disease, and drought.

Most studies of the economic impact of air po llution on agriculture have found that a 25 percent reduction in ambient ozone would provide benefits of at least $1-2 billi on annually in the United

States. Studies of soybean yields at the University of Maryland found a 10 percent loss of the soybean crop due to current levels of ozone in the state. The same study showed that ozone exposure causes the loss of 6-8 percent of winter wheat and 5 percent of th e corn crop yields to Maryland farmers.



### 2.11 THE AIR QUALITY INDEX (AQI)

The AQI is an index used for reporting forecasted and daily air quality. The AQI uses both a colorcoded and numerical scale to report how clean or po lluted the air is and what associated health effects might be of concern. The AQI focuses on h ealth effects people may e xperience within a few hours or days after breathing polluted air. The AQI is calculated for five ma jor pollutants regulated by the Clean Air Act: particulate matter, ozone, carbon monoxide, sulfur dioxide, and nitrogen

dioxide.

10 America Lung Association State of the Air, April 2006, pp. 1-207

Baltimore Serious Area 8-Hour Ozone SIP Page 13Figure 2-3: The Air Quality Index and Action Guide

Using the Air Quality Index, the Maryland Depart ment of the Environment and the Metropolitan Washington Council of Governments (COG) issue daily air quality forecasts for the Baltimore metropolitan area, Washington metropolitan area , Western Maryland, and the Eastern Shore. Extended range forecasts provide a three-day forecast so people can better plan their week and take the opportunity to arrange car pools, take mass transit, or take other actions to limit pollution when air quality is predicte d to be unhealthful.

MDE and COG issue the air quality forecasts to local media and hundreds of businesses and individuals throughout the region. Anyone can sign up to receive the free, daily email by visiting the Clean Air Partners web site at http://www.cleana irpartners.net/. The Clean Air Partners web site provides the public with easy-acce ss local and national air quality in formation. Clean Air Partners offers daily AQI forecasts and real-time AQI cond itions throughout most of Maryland, the District of Columbia, and Northern Virgin ia. Users of Clean Air Partners may also sign-up for AirAlerts to

receive real-time email notifica tions when air quality reaches unhealthy levels in the region.

Baltimore Serious Area 8-Hour Ozone SIP Page 14Figure 2-4: Air-Watch.net Real-tim e Air Quality Data and Forecasts



### 2.12 SOURCES OF OZONE POLLUTION IN TH E BALTI MORE REGION

There are a number of diverse sources that di scharge VOCs and NOx, the two primary pollutants responsible for ozone formation. Human made s ources, called anthropogenic sources, are divided into four categories: point, area, on-road mobile and non-road mobile sources. A fifth category, "biogenic" emissions, includes all naturally occurring s ources of VOC emissions from trees, crops and other forms of vegetation.

Point sources are primarily manufacturing businesse s that produce emissions equal to or greater than 25 tons per year (tpy) of VOCs or NOx. La rge industrial plants such as power plants and chemical manufacturers are examples of point sources.

Area sources are smaller sources of air pollution whose emissions are too small to be measured individually. Examples of area sources include commercial and consumer products (such as paints and hairspray), bakeries, dry clea ners, gasoline refueling stations, printing facilities, and autobody refinishing shops.

Baltimore Serious Area 8-Hour Ozone SIP Page 15Sources of air pollution that are not stationary are referred to as mobile s ources and are split into two categories: on-road mobile sources and non-ro ad mobile sources. The former include cars, vans, trucks and buses (i.e. vehi cles that operate on highways). Non-road mobile sources include boats, lawn and garden equipment, construction equipment and locomotives.

Table 2-1: Top Ten Sources of Human Made Volatile Organic Compound (VOCs) in the Baltimore Area in 2002, 2008, 2011 and 2012

VOC (Tons/Day)

Rank Source Category Source 2002 2008 2011 2012

1 On-Road Mobile Cars, Buses, Trucks 72.48 50.12 44.54 40.23

2 Nonroad Lawn and Garden Total 34.52 22.36 19.37 18.01

3 Area Commercial & Consumer Solvents 24.75 22.33 22.33 22.43

4 Area Portable Fuel Containers 18.68 13.00 11.23 11.29

5 Area Architectural Surface Coatings 18.28 13.43 13.78 13.85

6 Area Industrial Surface Coating 16.97 18.44 19.09 19.23

7 Point Utilities and Other Stationary Sources 12.74 14.31 15.13 15.48

8 Nonroad Pleasure Craft Total 8.68 6.68 5.40 4.94

9 Area Surface Cleaning/Degreasing 8.09 8.81 9.12 9.19

10 Area Gasoline Marketing 6.67 7.50 7.93 8.07

221.85 176.97 167.92 162.73

* The emissions estimates above are rounded to the nearest whole number. The figures are MDE’s best estimates.

Total VOC emissions in the Baltimore area were 382 tons per day in 2002 and 285.7 tons per day in 2008. Biogenic

emissions account for 314.7 tons/day of VOC emissions in the Baltimore region.

Baltimore Serious Area 8-Hour Ozone SIP Page 16Table 2-2: Top Ten Sources of Nitrogen Oxides (NOx) in the Baltimore Area in 2002, 2008, 2011 and

2012

NOx (Tons/Day)

Rank Source Category Source 2002 2008 2011 2012

1 On-Road Mobile Cars, Buses, Trucks 202.22 125.69 104.62 93.47

2 Point Utilities and Other Stationary Sources 102.19 111.64 82.26 81.44

3 Nonroad Construction and Mining Total 21.52 18.66 16.52 15.55

4 Nonroad Industrial Total 7.40 5.32 3.75 3.25

5 Nonroad Railroad Total 6.26 5.61 5.43 5.38

6 Nonroad Lawn and Garden Total 5.86 5.17 4.70 4.35

7 Area Incineration 3.84 3.84 3.84 3.84

8 Nonroad Commercial Total 3.27 3.07 2.88 2.76

9 Area Residential Fuel Combustion 2.66 2.78 2.83 2.84

10 Nonroad Pleasure Craft Total 0.76 0.96 1.01 1.01

355.99 282.75 227.85 213.90

* The emissions estimates above are rounded to the nearest whole number. The figures are MDE's best estimates.

The total emission of NOx in the Baltimore area was 541 tons per day in 2002 and 320 tons per day in 2008.



### 2.13 FREQUENCY OF VIOLATION OF FEDERAL HEALTH STANDARD

FOR OZONE

Since the Clean Air Act Amendments of 1990, Mary land has made significant improvements in the quality of air. National, state, and local programs have all contri buted to dramatically limiting the amount of pollution that is generated, which has re duced the number of days that unhealthful air is experienced throughout the region. Mandated reduc tions in emissions from businesses and industries and technologi cal improvements in automobiles have brought about a steady progress in air quality.

Baltimore Serious Area 8-Hour Ozone SIP Page 17Baltimore, MD NAA 8-Hour Ozone Exceedance Days per Year

43 44

37 43 42 51 58

28 30 50

23 48

40

36

30 51

40

16 26 37

11 10 23 26

15

3 28

16 65 65

0 10 20 30 40 50 60 70

1 98

0 19 82

1 984 19 86

1 988

1 990 19 92 1994 1996 1998 20 0 0 2 002 20 04 2 006 20 08Number of Days

Figure 2-5: 8-Hour Ozone Exceedance Days for the Baltimore Nonattainment A rea

The federal 8-hour ozone standard is set at 0.08 pa rts per million of ozone averaged over an eighthour period. Figure 2-5 applies the eight-hour standard to historic data and shows the number of days that would have exceeded levels under the new standard. The figure also clearly shows an improving trend in the Baltimore regions air qual ity since 1980. While annua l fluctuations can be attributed to weather (hot, sta gnant summers are favorable for ozone formation), the downward

trend is indicative of controls on sources of air pollution and the resulting levels of ozone precursors present in the ambient air.



### 2.14 REQUIRED SIP PRINCIPLES

Section 110 of the 1990 CAAA specifies the conditions under which EPA approves SIP submissions. These requirements are being followed by the Maryland Department of the Environment in developing this air quality plan (SIP). In order to develop effective control strategies, EPA has identified four fundamental princi ples that SIP control stra tegies must adhere to

in order to achieve the desired emissions reductions . These four fundamental principles are outlined

in the General Preamble to Title I of the Clean Air Act Amendments of 1990 at Federal Register 13567 (EPA, 1992a). The four fundament al principles are as follows:

1. Emissions reductions ascribed to the control measure must be quantifiable and measurable;

Baltimore Serious Area 8-Hour Ozone SIP Page 182. The control measures must be enforceable, in that the state must show that they have adopted legal means for ensuring that sources ar e in compliance with the control measure;

3. Measures are replicable; and

4. The control strategy must be acc ountable in that the SIP must contain provisions to track emissions changes at sources and to provide for corrective actions if the emissions reductions are not achieved according to the plan.



### 2.15 SANCTIONS

EPA must impose various sanctions if the State does not submit a plan, submits a plan that the EPA does not approve, or fails to implement the pl an. These sanctions incl ude withholding federal highway funding, withholding air quality planning grants, and imposing a federal plan (“federal implementation plan.”). Failure to submit or impl ement a plan will have significant consequences for compliance with conformity requirements and the imposition of 2:1 offset requirements.



### 2.16 REASONABLE FU RTHER PROGRESS

As a serious area, EPA requires the two Reasona ble Further Progress demonstrations for the Baltimore Nonattainment Area; one for the period 2002 – 2008 and the second for 2008 – 2011. 11
EPA’s implementation guidance requires that a se rious ozone nonattainment area, such as the Metropolitan Baltimore region, with an approve d 15% VOC reduction plan for the period 1990- 1996 (required for former 1-hour ozone non-attain ment areas) demonstrate a 15% Reasonable Further Progress by 2008 and 3% per year Reason able Further Progress by 2011. Chapter 5 contains the Baltimore region’s reasonable further prog ress demonstration for the years 2002-2008, and Chapter 6 provides the RFP demonstration for 2008-2011. The region needs to fulfill the 2008-2011 reasonable further progress requirements by January 1, 2012.

In order to demonstrate reasonable further progress, a region must show that its expected emissions, termed “controlled inventories,” of NOx and VOC will be less than or equal to the target levels set for the end of the reasonable further progress pe riod, or “milestone year”. For the RFP period 2002- 2008, the “target inventories” of emissions are the maximum quantity of anthropogenic emissions permissible during the 2008 milestone year. For the RFP period 2008-2011, the “target inventories” of emissions are the maximum quantity of anthropogenic emissions permissible during the 2011 milestone year.



### 2.17 ANALYSIS OF REASONABLY AV AILABLE CONTROL MEASURES (RACM)

An extensive list of potential control measures was analyzed and evaluated ag ainst criteria used for potential RACM measures. Individual measures must meet the following criteria: reduce emissions by the beginning of the Baltimore region’s 2008 ozone season (April 1, 2008); are enforceable; are technically feasible; are economical ly feasible, defined as a cost of $3,500 to $5,000 per ton or less;

11 Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard, Federal Register, Vol 70, No. 228, Nov.29, 2005, pp. 71612-71705.

Baltimore Serious Area 8-Hour Ozone SIP Page 19would not create substantial or wi despread adverse impacts within the region; and the emissions from the source being controlled must exceed a de minimis threshold, defined as 0.1 tons per day. Based on the analysis completed for the Baltimor e Nonattainment Area whic h relied heavily upon a very formal RACM analysis completed for the Washington DC Nonattainment Area (where MDE actively participated in a significant RACM workgroup) there were no identified RACM measures that if implemented would advance attainme nt in the Baltimore Nonattainment Area.



### 2.18 CONTINGENCY MEASURES

In the event that the reductions anticipated in the 2011 Reasonable Further Progress demonstrations

or the 2012 attainment demonstration are not realized within the time frames specified, there must be contingency measures ready for implementation. EP A issued guidance that says that contingency measures must provide for a 3% reduction in adju sted 2002 base year inventory for both Reasonable Further Progress and attainment. A minimum of 0.3 percent VOC must be included. The total required reductions for RFP contingency equa te to approximately 7.76 TPD of VOC, which Maryland meets. The measures proposed as contingency measures are listed in Chapter 12, which contains detail on these measures, how they would be implemented and enforced, and the level of emission reduction benefits expected.

Baltimore Serious Area 8-Hour Ozone SIP Page 20

## 3.0 THE 2002 BASE-YEAR INVENTORY AND REASONABLE

FURTHER PROGRESS REVISIONS

3.1 BACKGROUND AND REQUIREMENTS

The 2002 Base-Year Inventory is p ublished in a separate document, "2002 Base Year Emissions Inventory & QA/QC Plan Maryland," June 15, 2 006. This document was submitted to the U.S. Environmental Protection Agency (EPA) Region III. MDE prepared the document, and the document remains intact to fulfill the State Implem entation Plan (SIP) inventory requirement of the CAA. It is available for inspection at the Ma ryland Department of the Environment, Air and Radiation Management Admi nistration, 1800 Washington Boul evard, Suite 730, Baltimore, Maryland 21230.

The emissions inventory covers the Baltimore nona ttainment area, shown in Figure 2-1, which is classified as a moderate nonattainment area for ozone by the EPA. The 2002 emissions inventory is the starting point for calculati ng the emissions reductions requir ed to meet the goal of a 15% reduction in VOC/NOx emissions, from anthropo genic sources, by 2008. Meeting this 2008 goal means meeting reasonable further progress require ments prescribed for moderate nonattainment areas by the Clean Air Act Amendments (CAAA) and EPA.

This separately published document, which was pr eviously submitted to EPA, addresses emissions of volatile organic compounds ( VOCs), nitrogen oxides (NOx), and carbon monoxide (CO) on a typical summer ozone season day and annual basis. Included in the inventory are anthropogenic (human-made) stationary, non-road and on-road mobile sources; and bi ogenic (naturally occurring) sources of ozone precursors.

When updating or revising a SIP, EPA requires that the latest models a nd inventory methodologies be used when calculating Reasonable Further Progr ess (RFP) goals and target levels. As such, updates to the RFP inventories are documented in Appendix A-1.



### 3.2 TOTAL EMISSIONS BY SOURCE

3.2.1 Point Sources

For emissions inventory purposes, po int sources are defined as stati onary, commercial, or industrial operations that emit more than 10 tons per year (tons/year) of VOCs or 25 tons/year or more of NOx or CO. The point source inventory consists of actual emissions for the base-year 2002 and includes sources within the geographical area of the Baltimore Nonattainment Area.

3.2.1.1 Reasonable Further Progress Revisions

No revisions to the point source emissions i nventory were necessary for Reasonable Further Progress purposes.

Baltimore Serious Area 8-Hour Ozone SIP Page 21

### 3.2.2 Quasi-Point Sources

The Maryland Department of the Environment Air and Radiation Management has identified

several facilities that due to size and/or function are not considered point sources. These establishments contain a wide variety of air emi ssion sources, including tr aditional point sources, on-road mobile sources, off-road mobile so urces and area sources. For each particular establishment, the emissions from these source s are totaled under a si ngle point source and summary documents include these “qua si-point” sources as point sources.

Quasi-point sources will include a ll emissions at the facility re gardless of whether they are classified as point, area, nonroad, or mobile source emissions. These emissions are actual emissions reported for the facilities. The Baltimore N onattainment Area has the following quasi-point

sources:

 Baltimore Washington International Airport (BWI)

 Aberdeen Proving Grounds

These emissions have been included as “point source” in summary documents.

3.2.2.1 Reasonable Further Progress Revisions

No revisions to the quasi-point source emi ssions inventory were necessary for Reasonable Further Progress purposes.



### 3.2.3 Area Sources

Area sources are sources of emissions too sma ll to be inventoried individually and which collectively contribute significant em issions. Area sources include sm aller stationary point sources not included in the states' point source inventories; for exampl e, printing establishments, dry cleaners, and auto refinishing companies, as well as non-stationary sources.

Area source emissions typically are estimated by multiplying an emission factor by some known

indicator of collec tive activity for each source category at th e county or county-equivalent level. An activity level is any parameter associated with th e activity of a source, such as production rate or fuel consumption that may be correlated with th e air pollutant emissions from that source. For example, the total amount of VOC emissions emitted by commercial aircraft can be calculated by multiplying the number of landing and takeoff cycl es (LTOs) by an EPA-approved emission factor per LTO cycle for each specific aircraft type.

Several approaches are available for estimating area source activity levels and emissions. These include apportioning statewide activity totals to the local inventory area and using emissions per employee or other unit factors. For example, solvent evaporation from consumer and commercial products such as waxes, aerosol products, and window cleaners cannot be routinely determined for many local sources. The per capita emission factor assumes that emissions in a given area can be reasonably associated with population. This a ssumption is valid over broad areas for certain

Baltimore Serious Area 8-Hour Ozone SIP Page 22Baltimore Serious Area 8-Hour Ozone SIP Page 23 activities such as dry cleaning and small degreasing operations. For some other sources an employment based factor is more appr opriate as an activity surrogate.

3.2.3.1 Reasonable Further Progress Revisions

No revisions to the area source emissions inve ntory were necessary for Reasonable Further Progress purposes.



### 3.2.4 Mobile Sources

On-road mobile sources include all vehicles registered to use the public roadways. The predominant emissions source in this category is the automobiles, although trucks and buses are also significant s ources of emissions.

The computation of highway vehicle emissions re quired two primary entitie s: a) vehicle emission factors and b) vehicle activity.

The emission factors are generated by using MOBILE 6.2, which is the latest version of U.S. EPA’s emission factor model as far as the base year inve ntory. Vehicle activity (vehicle miles traveled, or “VMT”) is usually obtained from two sources: a) the Maryland State Highway Administration (SHA), and b) Baltimore Metropolitan Council (B MC) staff. VMT data from SHA, based on vehicle traffic counts on the roadway system, is ma inly used for the rural counties. The Baltimore Region Transportation Board-provided transporta tion modeled link-based data is used in the emission modeling of the Baltimore Ozone Nonattainment Area.

In a simple modeling scenario, the product of the em ission factor and vehicle miles traveled should yield emission levels. Proper units and conversions are used to arrive at reasonable emission

estimates.

In a complex modeling scenario, many emissions type s, such as exhaust, evaporative, diurnal, crankcase, and refueling emissions, are computed separately and treated with the appropriate activity levels.

MOBILE6 expects enormous amount of local data input, such as the fleet characteristics, fleet mileage accrual rates, speed, fuel parameters, in spection and maintenance (I/M) program in place,

and weather data.

In MOBILE6 emission factor model, the total hi ghway vehicle population is characterized by the following 16 composite vehicle type categories:

LDV - Light-Duty Vehicles (Passenger Cars) LDT1 - Light-Duty Trucks 1 LDT2 - Light-Duty Trucks 2 LDT3 - Light-Duty Trucks 3 LDT4 - Light-Duty Trucks 4 HDV2B- Class 2b Heavy Duty Vehicles HDV3 - Class 3 Heavy Duty Vehicles HDV4 - Class 4 Heavy Duty Vehicles HDV5 - Class 5 Heavy Duty Vehicles HDV6 - Class 6 Heavy Duty Vehicles HDV7 - Class 7 Heavy Duty Vehicles HDV8A- Class 8a Heavy Duty VehiclesHDV8B- Class 8b Heavy Duty Vehicles

HDBS - School Buses HDBT - Transit and Urban Buses MC - Motorcycles

These composite vehicle types are further classi fied into 28 vehicle types, depending on whether they use gasoline or diesel fuel. For example, all motorcycles are gasoline based and transit and

urban buses are diesels. School buses can be eith er gasoline-driven or diesel-driven vehicles.

MOBILE6 also allows for the modeling of other fu el type vehicles such as hybrids and alternate fuel vehicles (AFV) as a special cas e in a complex modeling initiative.

The MOBILE6 model produces emission factors for each of the 28 vehicle types and one composite factor for all vehicle types.

A post-processing system takes care of all emi ssion computations of the modeling domain by aggregating the emissions from roads/links appropri ate to the area. It al so produces meaningful reports by area, by vehicle type and by roadway type.

3.2.4.1 Reasonable Further Progress Revisions

EPA replaced the previous model for estim ating on-road mobile source emissions, MOBILE6.2, with a new model, MOVES ( MO tor V ehicle E mission S imulator).

MOVES2010 is the state-of-t he-art upgrade to EPA’s modeling tools for estimating emissions from highway vehicles, based on analysis of millions of emission test results and

considerable advances in the Agency’s understandi ng of vehicle emissions.

This SIP presents revised emissions i nventories for 2002, 2008, 2011, and 2012 based on the MOVES2010a model for estimating on-road ve hicle emissions. The analysis methodology is consistent with past statewide inventor y efforts including the 2008 National Emissions Inventory (NEI) submission. Also, the methodol ogy includes the use of statewide traffic roadway data obtained from the State Highway Administration and custom post-processing software (PPSuite) to calculate hourly speeds and prepare key traffic input files to the

MOVES2010a emission model. MOVES2010a is built in to the PPSuite software package.

MDE used MOVES2010a to estimate volatile organic compounds ( VOCs), nitrogen oxides (NOx), and carbon monoxide (CO) emi ssions for this SIP revision.



### 3.2.5 Nonroad Sources

Emissions for all nonroad vehicles and engines ex cept for those at BWI airport (aircraft, ground support equipment (GSE) and, auxiliary power un its (APU)), locomotives, and diesel marine vessels were calculated using EPA’s NONROAD 2005.0.0 (dt. 12/02/2005) model. Since the time it was first issued on 12/02/2005, this model version has undergone several corrections. The base year nonroad inventory was created using what wa s the version currentas of 3/21/2006.

Emissions from the “nonroad vehicles and engines” category result from the use of fuel in a diverse collection of vehicles and equipment, incl uding those in the following categories:

Baltimore Serious Area 8-Hour Ozone SIP Page 24 Recreational vehicles, such as all-terrain vehicles and off-road motorcycles;

 Logging equipment, such as chain saws;

 Agricultural equipment, such as tractors;

 Construction equipment, such as graders and back hoes;

 Industrial equipment, such as fork lifts and sweepers;

 Residential and commercial lawn and garden equi pment, such as leaf and snow blowers; and

 Aircraft ground support equipment.

The nonroad model estimates emissions for each sp ecific type of nonroad equipment by multiplying the following input data estimates:

 Equipment population for base year (or base year population grown to a future year), distributed by age, power, fu el type, and application;

 Average load factor, expressed as average fraction of available power;

 Available power, in horsepower;

 Activity, in hours of use per year; and

 Emission factor with deteriorat ion and/or new standards.

The emissions are then temporally and geographically allocated using appropria te allocation factors.

3.2.5.1 Reasonable Further Progress Revisions

EPA replaced the previous model for estimating off-road mobile source emissions, NONROAD2005, with a new version, NON ROAD2008. The main change for

NONROAD2008 is the inclusion of emission reductions associated with two rules finalized

in 2008:

o Diesel (CI) recreational marine standard s in the Locomotive/Marine final rule (Federal Register Vol 73, No. 88, page 25098, May 6, 2008).

o Small Spark Ignition (SI) and SI Recreationa l Marine final rule (Federal Register Vol 73, No. 196, page 59034, October 8, 2008).

NONROAD2008 predicts substantially lower hydrocarbons (HC) and CO and somewhat

lower NOx and PM emissions than NONRO AD2005 while using comparable scenario inputs.

Aircraft (military, commercial, general aviation, and air taxi) and auxili ary power units (APU) operated at airports, along with locomotives and diesel marine ve ssels, are also considered nonroad

sources and are included in the nonroad category.

Baltimore Washington International Airport (B WI) and the Maryland Aviation Administration (MAA) provided all types of air port emissions for BWI airport. Aircraft and APU emissions for

other counties were calculated by MDE through landing and take-off data surveys. Emissions from

locomotives and commercial diesel marine vessels were also produced by the MDE.

Baltimore Serious Area 8-Hour Ozone SIP Page 25

### 3.2.6 Biogenic Emissions

An important component of the inventory is bi ogenic emissions. Biogenic emissions are those resulting from natural sources. Biogenic emission s are primarily VOCs that are released from vegetation; they are emitted th roughout the day. Biogenic emissi ons of NOx include lightning and forest fires. EPA used a biogeni c computer model (BEI S3.12) to estimate biogenic emissions for each county in the country for all twelve months of the year 2002.

Emissions data for the Baltimore Nonattainme nt Area was acquired from the EPA website (ftp://ftp.epa.gov/EmisInventory/200 2finalnei/biogenic_sector_data /). EPA has recommended that states use these emissions in case they do not have their own estimated biogenic emissions. The Baltimore, Maryland ozone non-attainment area d ecided to use the inventories provided by the

EPA.

Baltimore Serious Area 8-Hour Ozone SIP Page 26

## 4.0 REASONABLE FURTHER PROGRE SS PROJECTED 2008, 2011

AND 2012 INVENTORIES

Part II of EPA’s rule to implement the 8-hour NAAQS required the Baltimore, MD as a moderate ozone nonattainment area to achieve, by 2008, a 15 percent emissions reduction, including either VOC or NOx emissions or any combination of the two. 12 By re-classifying as a “serious” ozone nonattainment area, the Baltimore, MD region is further required to reduce VOC and NOx emissions by 3 percent per year by 2011. An inventory for the attainme nt year 2012 is also required for the region.

The reductions must be calculated from the an thropogenic emissions levels reported in the 2002 Base-Year Inventory after those le vels have been adjusted to re flect the expected growth in

emissions between 2002 and 2008/2011/2012. The 2002 Base-Year Inventor y was described in Chapter 3. This chapter presents the 2008, 2011 and 2012 Projection Inventories, that is, the estimation of the levels of emissions to be expe cted in those years before the consideration of

emission controls.

The 2008, 2011 and 2012 projected inventories are de rived by applying the appropriate growth

factors to the 2002 Base-Year Emi ssions Inventory. EPA guidance desc ribes four typical indicators of growth. In order of priorit y, these are as follows: (1) produc t output, or the amount of product being produced; (2) value added, or “the value of a product sold by a firm less the value of the goods purchased and used by the firm to produce the product”; 13 (3) earnings, and (4) employment. Surrogate indicators of activity, for example populat ion growth, are also acceptable methods.

Round 6B Cooperative Forecasting results (popu lation, household and employment projections), prepared and officially adopted by the Baltimore Metropolitan Council (BMC) were used to project emissions from area sources. Projections for onroad emissions were developed using MOVES model (please see Appendix E for info rmation on mobile source emissions).

EPA’s nonroad model, NONROAD2008, was us ed for developing the 2008, 2011 and 2012 nonroad model inventories. BMC’s Round 6B Coope rative Forecasting results and the Economic Growth Analysis System (EGAS) model were used to project growth in the additional nonroad source categories such as railroad locomotives, marine vessels and airports. The EGAS model was also used to project growth in point source emissions.



### 4.1 GROWTH PROJECTION METHODOLOGY

The following sections describe the method follow ed to determine the projected inventories for 2008, 2011 and 2012.

12 EPA 40 CFR Parts 51, 52 & 90, Federal Register. Vol.70, No. 228, Nov. 29, 2005, pp.71612-71705.

13 STAPPA-ALAPCO-EPA Emission Inventory Improvement Program, Emission Projections, prepared by The PechanAvanti Group, Springfiel d, VA, December 1999.

Baltimore Serious Area 8-Hour Ozone SIP Page 27

### 4.1.1 Growth Projection Methodology for Point Sources: EGAS

The growth in point source emissi ons is projected using EGAS vers ion 5.0. Point source emissions for 2002 are provided from the state data sources. The model is run with the 2002 emissions data grouped by Source Classification Code (SCC) . Growth factors generated from the Bureau of Labor

Statistics national econom ic forecast and the baseline regional economic forecast are applied to each

SCC grouping.

For source category listings and descriptions, proj ection me thods and data sources, and surrogate growth indicators, please refer to Appendix A-1.

Point source emission projection data is contained in Appendix A-2.



### 4.1.2 Growth Projection Methodology for Quasi-Point Sources

Quasi-point sources will include a ll emissions at the facility re gardless of whether they are classified as point, area, nonroad, or mobile source emissions. These emissions are actual emissions reported for the facilities. Actual emissions will be forecast to the projection years using surrogates specific to each quasi-point source. The growth factor indicators and their sources are listed below by facility (names are in italics):

Quasi-Point Source Surrogate Growth Indicator

Baltimore Washington International Airport (BWI):

Aircraft LTOs FAA Aircra ft Operations Forecasts

Mobile Source Emissions FAA Enplanement Forecasts

Aberdeen Proving Grounds BRAC Population Estimates

For source category listings and descriptions, proj ection methods and data sources, and surrogate growth indicators please refer to Appendix A-1.

Quasi-point source emission projection da ta is contained in Appendix A-3.



### 4.1.3 Growth Projection Methodo logy: Area Sources

Base-year area source surrogate growth fact ors for 2002 were calcula ted using 2002 population, household, and employment data. Linearly interpolating betw een 2000 and 2005 data produced the 2002 data. Dividing Round 6B population, household, a nd employment forecasts for the analysis year by the derived 2002 values for the region pr oduced the growth factors for the periods of 2002 to 2008, 2002 to 2011 and 2002 to 2012. Categories related to the transportation and storage of gasoline were grown using projected vehicle m iles traveled (VMT) for analysis years. Area projection inventories are contai ned in Appendix B. The growth factors used for the 2002-2008, 2002-2011, and 2002-2012 projection years are presented in Tables 4-1, 4-2 and 4-3. The growth factors were applied to emissions cat egories by specific jurisdictions.

Baltimore Serious Area 8-Hour Ozone SIP Page 28Table 4-1: 2002-2008 Growth Factors 14

Jurisdiction Employment Population Household VMT

Anne Arundel County 1.0742 1.0447 1.0734 1.1346

Baltimore City 1.0533 1.0070 1.0196 1.1101

Baltimore County 1.1343 1.0510 1.0591 1.1223

Carroll County 1.0909 1.1091 1.1204 1.1358

Harford County 1.1429 1.0963 1.1191 1.1408

Howard County 1.0238 1.1002 1.1126 1.1105

Table 4-2: 2002-2011 Growth Factors 15

Jurisdiction Employment Population Household VMT

Anne Arundel County 1.1119 1.0622 1.1065 1.1776

Baltimore City 1.0783 1.0146 1.0390 1.1557

Baltimore County 1.1860 1.0696 1.0808 1.2099

Carroll County 1.1238 1.1441 1.1620 1.2096

Harford County 1.2083 1.1438 1.1778 1.1991

Howard County 1.0382 1.1434 1.1680 1.1776

Table 4-3: 2002-2012 Growth Factors 16

Jurisdiction Employment Population Household VMT

Anne Arundel County 1.1266 1.0676 1.1168 1.1960

Baltimore City 1.0822 1.0144 1.0432 1.1709

Baltimore County 1.1930 1.0730 1.0853 1.2346

Carroll County 1.1327 1.1534 1.1739 1.2325

Harford County 1.2262 1.1558 1.1949 1.2287

Howard County 1.0426 1.1547 1.1866 1.1960

14 Employment, population, and household growth factors are based on BMC Final Round 6B Cooperative Forecasts. VMT growth factors are based on VMT estimates provided by the MDE Mobile Sources Control Program.

15 Ibid

. 16 Ibid

.

Baltimore Serious Area 8-Hour Ozone SIP Page 29The 2008, 2011 and 2012 emissions for area sources are calculated by multiplying the 2002 baseyear area emissions by the above growth factors for the appropriate year for each jurisdiction. Each area source category was matched to an appropriate growth surrogate based on the activity used to generate the base-year emission estimates. Surrogates were chosen as follows:

Surface Coating – depending on whether emission factor s were based on employment or population, surrogate chosen varied with individual subcategorie s. For example, automobile refinishing category was grown us ing employment, as the emission factor was based on it, but population was chosen for growing tr affic markings as its emission factor was based on population.

Commercial/Consumer Solvent Use - population was chosen as th e growth surrogate since 2002 emissions are based on per capita emission factors.

Residential Fuel Combustion – households was chosen as the growth surrogate.

Industrial/Commercial/Instituti onal Fuel Combustion - employment was chosen as the growth surrogate except for the commercial/institutional coal combustion category, where no growth was

assumed.

Vehicle Fueling (Stage II) a nd Underground Tank Breathing - all gasoline marketing categories were based on vehicle miles traveled (VMT) data since VMT is an appropriate surrogate for gasoline sales. Emission factors for these categories are based on gasoline sales.

Open Burning - population was chosen as the growth surroga te as yard wastes, land debris, and the like increase with population.

Structural Fires, Motor Vehicle Fires – population was chosen as the growth surrogate.

Publicly Owned Treatment Works (POTW) – households was chosen as the growth surrogate.

Dry Cleaning - population was chosen as the surrogate.

Graphic Arts - population was used to estimate growth since emissions are based on per capita

emission factors.

Surface Cleaning - employment growth was used as the surrogate.

Tank Truck Unloading –growth in VMT was applied to this category since base-year emissions are calculated using gasoline sales.

Municipal Landfills - Base-year emissions are estimated us ing data on total refuse deposited. Population was chosen as a surroga te since deposited waste is from the general population rather

than industrial facilities.

Asphalt Paving - population was chosen as the surrogate since base-year emissi ons are calculated using per capita emission factors.

Baltimore Serious Area 8-Hour Ozone SIP Page 30Bakeries, Breweries - population was chosen as the surrogate.

Soil/Groundwater Remediation - zero growth was applied to this category. The number of remediations during the ozone season, used to ge nerate base-year emissions, does not directly correlate to population, households, or employment growth.

General Aviation and Air Taxi Emissions - Emissions from small airp orts were projected using the EGAS 5.0 model. The Maryland Aviation Admi nistration (MAA) provided commercial aircraft operations information at Baltimore Washington International (BWI) Airport. Emissions were calculated using FAA-approved activity data and the Emissions Dispersion Modeling system (EDMS) model. Emissions were grown by F AA Terminal Area Forecasts (TAFs).

Aircraft Refueling Emissions - emissions from refueling of aircrafts was projected based on employment.

Portable Fuel Container Emissions - emissions from portable fuel containers were grown based on population.

Railroad Locomotives - employment growth was us ed as the surrogate.

Forest Fires, Slash Burning, Prescribed Burning – zero growth was applied to this category.

Accidental Oil Spills - zero growth was applie d to this category.

Incineration – zero growth was applied to this category.

Pesticide Application - zero growth was applied to this category.

For source category listings and descriptions, proj ection methods and data sources, and surrogate growth indicators, please refer to Appendix A-1.

Area source emission projection data is contained in Appendix A-4.



### 4.1.4 Growth Projection Methodology: Nonroad Sources

The 2008, 2011 and 2012 nonroad source inventories we re created through the use of EPA’s NONROAD2008 model. Locomotives, marine diesel vessels, and ai rcraft are not included. The base year 2002 nonroad source inventory was re vised for Reasonable Further Progress using

NONROAD2008 model.

Nonroad model runs were made for the metr opolitan Baltimore region for a typical summer weekday.

Methodology to prepare inputs for the oz one season day is provided below.

Baltimore Serious Area 8-Hour Ozone SIP Page 31Temperature:

Temperature data were acquired fr om the National Climatic Data Center (NCDC). Hourly average temperature data were collected for Baltimore Wa shington International (BWI) station for the top ten 8-hour maximum ozone days between 2002 and 2004. Then minimum, maximum, and average temperatures were computed from th is hourly temperature dataset.

Fuel inputs:

Month-specific data for fuel Reid Vapor Pressu re (RVP) and oxygen weight percent were collected from the Baltimore Regional Transportation Boar d (BRTB), the Baltimore Metropolitan Council (BMC), and the MDE Mobile Sour ces Control Program. The data was averaged for the period May through September to obtain ozone season average input s. Model defaults were used for gas, diesel, marine diesel, and CNG/LPG sulfur percent. Stage II controls we re not assumed and were set at

zero for the model runs.

Model inputs (temperature, fuel, and ot her parameters) are listed below:

NONROAD Model Inputs (all NR Runs)

Options File
Fuel RVP for gas 6.6 Minimum Temp (  F) 65.55 Oxygen Weight % 2.44 Maximum Temp (  F) 87.60

Gas S % 0.0339 Average Temp (  F) 76.80

Diesel S % 0.2284 State II Control % 0

Marine Diesel S % 0.2318 EtOH Blend Market % 75.1

CNG/LPG Sulfur % 0.003 EtOH Volume % 9.3

Period Episode Inventory Year Requested (2002, 2008, 2011, 2012)

Period Seasonal

Season Summer Type Typical Day Day Weekday

Region Region County

Selected Anne Arundel County MD Harford County MD Baltimore County MD Howard County MD Carroll County MD Baltimore City MD

Sources

Active All Sources

Since the nonroad model does not generate emissi ons for aircraft, auxiliary power units (APU), locomotives, and commercial diesel marine vessels, these were either projected from the base year

Baltimore Serious Area 8-Hour Ozone SIP Page 32emissions using the BMC Round 6B Cooperative Forecast or the EGAS model. Below are the details for projecting emissions for the above mentioned individual nonroad categories.

Aircraft emissions (military, comm ercial, general aviation, air taxi)

As previously noted, Maryland Aviation Administration (MAA) provided all types of airport activity data and emissions for Baltimore Wash ington International (BW I) airport. Aviation emissions from BWI were grown by FAA Termin al Area Forecasts (TAFs). Emissions were calculated using FAA-approved activity data and the Emissions Dispersion Modeling system (EDMS) model.

General aviation and air taxi emissions from sm all airports were projected using the EGAS 5.0

model.

Auxiliary power units emissions These emissions were only available for BWI ai rport. Emissions were calculated using FAAapproved activity data and the EDMS model.

Ground support equipment emissions The NONROAD2005.1.0 model generated these emissi ons for small airports. BWI ground support equipment (GSE) emissions were generated usin g the EDMS model, which calculated emissions based on actual aircraft operations. The NONRO AD model calculates emissions based on GSE population only and therefore emissions generated th is way are considered less accurate than the ones generated by the EDMS model.

Commercial Diesel Marine Vessels

Base year emissions from commer cial diesel marine vessels were grown to future years using employment as the surrogate.

Railroad

Railroad or locomotive emissions were grow n using employment as the surrogate.

For source category listings and descriptions, proj ection methods and data sources, and surrogate growth indicators please refer to Appendix A-1.

Nonroad mobile source emission projecti on data is containe d in Appendix A-6.



### 4.1.5 Growth Projection Methodology: Onroad Sources

The 2008, 2011 and 2012 mobile source inventories we re created through the MOVES model. A full description of this mobile emission estima ting process can be found in Appendix E of this

report.

Baltimore Serious Area 8-Hour Ozone SIP Page 33

### 4.1.6 Biogenic Emission Projections

Biogenic emission inventories are th e same as those used for the 2002 base year for Baltimore, MD ozone nonattainment region. Year-specific biogenic inventories were not estimated. Base year emissions for 2002 were estimated by EPA usi ng BEIS3.12 model. No 2008 biogenic inventories were prepared as these inventories are not used to determine rate of progress.



### 4.2 OFFSET PROVISIONS, EMISSI ON REDUCTION CREDITS AND

POINT SOURCE GROWTH

The Clean Air Act (CAA or “the Act”) requires that emissions growth from major stationary sources in nonattainment areas be offset by emi ssions reductions that would not otherwise be achieved by other mandated controls. The offset re quirement applies to all new major stationary sources, and to existing major stationary sources th at have undergone major modifications. At the same time, existing sources’ emissions increases re sulting specifically from increases in capacity utilization are not subject to the offset requirement.

For the purposes of the offset requirement, major st ationary sources include all stationary sources exceeding an applicable size cutoff. The NSR thre sholds for the Baltimore Nonattainment Area are 25 tpy VOC and 25 tpy NOx.

EPA has issued guidance on the inclusion of emissi on reduction credits in the projected emissions inventory. The guidance states:

The base year inventory includes actual emissions from existing sources and would not normally reflect emissions from units that were shutdown or curtailed before the base year,

as these emissions are not ‘in the air.’ To the extent that these emission reduction credits are

to be considered available for use as offset s and are thus ‘in the air’ for purposes of demonstrating attainment, they must be speci fically included in the projected emissions inventory used in the attainment demonstra tion along with other growth in emissions over the base year inventory. This step assures th at emissions from shutdown and curtailed units are accounted for in attainment planning. 17

MDE has included emission reduction credits in the attainment demonstration projected inventory.

A list of these emission reduction credits and as sociated facilities is shown in Table 4-4.

Table 4-4: Emission Reduction Credits

Facility Name State Facility Identifier Pollutant

Code Emission

Reduction

Credits (TPY)

Alltrista Metal Services 510-0508 NOX 2

Andrews Air Force Base 033-0655 NOX 15

Armco Stainless/ 510-0340 NOX 16

Bausch & Lomb 023-0019 NOX 1

17 Federal Register, Vol. 71, No. 243 , page 75910, December 19, 2006.

Baltimore Serious Area 8-Hour Ozone SIP Page 34Facility Name State Facility Identifier Pollutant Emission

Reduction

Credits

Code (TPY)

Bethlehem Steel 005-0147 NOX 701 Chevron Asphalt 510-0072 NOX 49

Coca Cola 510-0242 NOX 5

Crown Cork & Seal - Duncanwood 510-0320 NOX 10 G. Heileman Brewing (Strohs) 005-0129 NOX 24

General Electric 027-0020 NOX 82

General Motors - Truck & Bus 510-0354 NOX 119 Giant - Bakery (930 King St) 031-0224 NOX 2

Gordon D. Garratt 510-0360 NOX 1 Grief Brothers Corp. 005-0134 NOX 1 Millenium Inorganic Chemicals 510-0109 NOX 30

Proctor & Gamble 510-0185 NOX 12

Pulaski Incinerator 510-0498 NOX 302 Quebecor Printing 003-0274 NOX 2

Rohr Industries 043-0104 NOX 6 Schluderberg-Kurdle 510-0283 NOX 19

Showell Farms 047-0036 NOX 8 Simpkins Industries - River Rd 027-0005 NOX 87 TPS Technologies, Inc. -Todd's La. 005-2131 NOX 16 Trigen (Leadenhall St) 510-2796 NOX 33 U.S.Can - Sparrows Pt. (Amer Nat) 005-0183 NOX 7 Westport 510-0006 & Riverside 005-0078 510-0006 NOX 1480

WR Grace 510-0076 NOX 17 3M Commercial Graphics 013-0052 VOC 30

Alltrista Metal Services 510-00508 VOC 11 American Mouldings 043-0191 VOC 69 Armco/Balto. Specialty Steel 510-0340 VOC 11

BARCO – Fairlawn 510-2854 VOC 5

Bata Shoe 025-0003 VOC 18

Bausch & Lomb 023-0019 VOC 16 Baycraft Fiberglass Engineering 025-0231 VOC 10

Bethlehem Steel 005-0147 VOC 0

BGE - SNG Plant 005-1054 VOC 7 Blue Chip Products 015-0058 VOC 35 Carpenter Insulation 043-0189 VOC 146 CE Stevens Packaging (printer) 510-2900 VOC 10

Cello Professional Products 025-0145 VOC 0

Cherokee Sanford 033-0565 VOC 0 Chevron Asphalt 510-0072 VOC 2

Conoco Sun Gasoline Terminal 510-0676 VOC 27

Baltimore Serious Area 8-Hour Ozone SIP Page 35Facility Name State Facility Identifier Pollutant Emission

Reduction

Credits

Code (TPY) Constellation - Westpor t 510-0006 & Riverside 005-

0078 510-0006 VOC 23

Crown Central Petroleum 003-0234 VOC 21

Crown Cork & Seal - Duncanwood 510-0320 VOC 13

Crown Cork & Seal - Hurlock 019-0073 VOC 96

CSX Minerals 043-0110 VOC 10

Ecko-Glaco Ltd. 005-0310 VOC 27 G. Heileman Brewing Co. (Strohs) 005-0129 VOC 48

General Motors - Electromotive 005-0692 VOC 15

General Motors - Truck & Bus 510-0354 VOC 0 Giant - Bakery - 930 King St 031-0224 VOC 0 Grief Brothers Corporation 005-0134 VOC 0

LeSaffre Yeast 510-0191 VOC 179 Mail-Weil Graphics 019-0097 VOC 8 Maryland Paper Box 005-2220 VOC 15

Metalfab - Grove Road 021-0317 VOC 11

PPG Industries 001-0005 VOC 28

Pulaski Incinerator 510-0498 VOC 11 Quebecor Printing 003-0274 VOC 322

Rohr Industries 043-0104 VOC 4 Schlumberger Malco, Inc. 005-1614 VOC 12 Simpkins Industries (River Rd) 027-0005 VOC 7 Thomas Mfg. 005-0240 VOC 22 Tidewater Industrial Corp. 011-0039 VOC 11 TPS Technologies (Todd's La.) 005-2131 VOC 4 U.S.Can-Sparrows Pt. (Amer Nat) 005-0183 VOC 90



### 4.3 ACTUAL VS. ALLOWABLE EMI SSIONS IN DEVELOPMENT OF THE 2008, 2011 AND 2012 PROJECTED EMISSIONS INVENTORIES

For the purposes of calculating the projection em issions inventories, EP A guidance specifically outlines the circumstances under which emissions proj ections are to be based on actual or allowable

emissions. For sources or source categories that are subject to a pre-1990 regulation and that the state does not anticipate subjecting to additional regulation, emissions project ions should be based

on actual emissions levels. Actual emissions levels should also be used for emissions projections for sources or source categories that were unregulated as of 1990. Fo r sources that are expected to be subject to post-1990 regulations, projections should be based on new allowable emissions.

To simplify comparisons between the base-year a nd the projected year, EPA guidance states that comparisons should be made only between like em issions: actual to actual, or allowable to

Baltimore Serious Area 8-Hour Ozone SIP Page 36allowable, not actual to allowable. As a result , all base-year and all pr ojection-year emissions

estimates are based on actual emissions.

Maryland regulation defines "actual emissi ons" and “allowable emissions” as follows: 18

“Actual emissions” means the average rate, in tons per year, at which a source discharged a pollutant during a 2-year period which precedes the date of a completed application for an NSR source or other specified date, and which is representative of normal source operation... Actual emissions shall be calculated using th e source's operating hours, production rates, and types of materials processed, stored, or combusted during the selected time period.

“Allowable emissions” means the maximum emissi ons a source or installation is capable of discharging after consideration of any physi cal, operational, or emissions limitations required by [state regulations] or by fede rally enforceable conditions which restrict operations and which are included in an applicab le air quality permit to construct, permit to operate, secretarial order, plan for compliance, c onsent agreement, court order, or applicable federal requirement.



### 4.4 PROJECTION INVENT ORY RESULTS

Chapter 8 of this SIP describes the control measures that have been implemented or will be implemented from 2008 through 2012 that will reduce emissions. Most control measures are required by federal or state re gulations. Projected contro lled inventories for 2008, 2011 and 2012 assume a number of control measures, as identifie d in Chapter 8, to be in place by these years.

Tables 4-5, 4-6, and 4-7 present th e projected controlled emissions for the 2008 reasonable further progress, 2011 reasonable further progress, and 2012 attainment years resulting from implementation of the control measures.



### 4.5 2008 CONTROLLED EMISSIONS FOR REASONABLE FURTHER

PROGRESS

The projection of 2008 controlled emissions is s imply the 2008 uncontrolled emissions minus the

emission reductions achieved from the federal control measures and the reasonable further progress control measures implemented by states for the 8-hour ozone SIP. This information is presented in

Table 4-5. Controlled inventories are contained in Appendix A. Details on mobile source controlled inventories can be found in Appendix E.

18 See Code of Maryland Regulations (COMAR) 26.11.01.01.

Baltimore Serious Area 8-Hour Ozone SIP Page 37Table 4-5: 2008 Projected Controlled VOC & NOx Emissions (tons/day)

Baltimore Nonattainment Area

Emission

Source Category 

### Baltimore NAA

VOC Emissions * 

### Baltimore NAA

NOx Emissions *

Point 15.63 122.65

Area 108.17 8.43

Non-road 44.04 42.85

Mobile 50.12 125.69

Total 217.96 299.62

* Small discrepancies may result due to rounding.



### 4.6 2011 CONTROLLED EMISSIONS FOR REASONABLE FURTHER

PROGRESS

The projection of 2011 controlled emissions is s imply the 2011 uncontrolled emissions minus the

emission reductions achieved from the federal control measures and the reasonable further progress control measures implemented by states for the 8-hour ozone SIP. This information is presented in

Table 4-6. Controlled inventories are contained in Appendix A. Details on mobile source controlled inventories can be found in Appendix E.

Table 4-6: 2011 Projected Controlled VOC & NOx Emissions (tons/day)

Baltimore Nonattainment Area

Emission

Source Category 

### Baltimore NAA

VOC Emissions * 

### Baltimore NAA

NOx Emissions *

Point 16.79 95.21

Area 106.07 8.54

Non-road 38.26 38.12

Mobile 44.54 104.62

Total 205.65 246.48

* Small discrepancies may result due to rounding.



### 4.7 2012 CONTROLLED EMISSION S FOR ATTAINMENT

The projection of 2012 controlled emissions is s imply the 2012 uncontrolled emissions minus the

emission reductions achieved from the federal control measures and the reasonable further progress

Baltimore Serious Area 8-Hour Ozone SIP Page 38control measures implemented by states for the 8-hour ozone SIP. This information is presented in

Table 4-7.

Table 4-7: 2012 Projected Controlled VOC & NOx Emissions (tons/day)

Baltimore Nonattainment Area

Emission

Source Category 

### Baltimore NAA

VOC Emissions * 

### Baltimore NAA

NOx Emissions *

Point 17.19 94.79

Area 106.79 8.56

Non-road 35.69 36.05

Mobile 40.23 93.47

Total 199.90 232.88

* Small discrepancies may result due to rounding.

Baltimore Serious Area 8-Hour Ozone SIP Page 39

## 5.0 2008 REASONABLE FURTHER PROGRESS REQUIREMENTS

5.1 INTRODUCTION

In June 2005 EPA revoked the one-hour ozone sta ndard and published implementation guidance for

the 8-hour ozone standard. EPA classified the me tropolitan Baltimore region as being in moderate nonattainment of the 8-hour ozone standard; EPA made this classification under the Clean Air Act (CAA or “the Act”) Subpart 2, Section 182(b).

As a moderate nonattainment area, the metropolitan Baltimore region is required to demonstrate reasonable further progress towards attainment by 2008. 19 EPA’s implementation guidance requires that a moderate area, such as Baltimore, with an approved 15% VOC reduction plan for the period 1990-1996 (required for former 1-hour ozone non-attainment areas) demonstrate a 15% R by 2008. This chapter contains the Baltimore region’s reasonable fu rther progress demonstration f the years 2002-2008. The region needs to fulf ill the 2002-2008 reasonable further progress requirements by January 1, 2009. FP

or

In order to demonstrate reasonable further progress, a region must show that its expected emissions, termed “controlled inventories,” of NOx and VOC will be less than or equal to the target levels, or “target inventories” set for the end of the reasonable further progress period, or “milestone year”. For the RFP period 2002-2008, the targ et inventories of emissions are the maximum quantity of anthropogenic emissions permissible during the 2008 milestone year.

This section describes the methodology used to establish the regional ta rget inventories and controlled inventories for 2008. Because the expected NOx and VOC emissions are less than or equal to the target levels in the analysis, the Ba ltimore region meets the RFP requirements for 2008.

The reasonable further progress em ission inventories utilize the latest EPA models (MOVES and NONROAD2008) providing re vised up-to-date emission estimates.



### 5.1.1 Reasonable Further Progress Demo nstrated i n Previous State Implementation Plans

Since 1990, the Clean Air Act has required ozone nonattainment areas to demonstrate progress towards attaining the ozone standa rd. This requirement is referred to as the reasonable further progress requirement, or RFP. During the peri od 1990-1996, areas in nonattain ment of the one-hour ozone standard were required to reduce VOC em issions by 15%. Since 1996, regions have been required to demonstrate a 9% rate of progress ever y three years until the region’s attainment date.

19 Final Rule To Implement the 8-Hour Ozone National Ambient Air Quality Standard—Phase 2; Final Rule To Implement Certain Aspects of the 1990 Amendments Relating to New Source Review and Prevention of Significant Deterioration as They Apply in Carbon Monoxide, Particulate Matter and Ozone NAAQS; Final Rule for Reformulated Gasoline, Federal Register, Vol 70, No. 228, Nov.29, 2005, pp. 71612-71705.

Baltimore Serious Area 8-Hour Ozone SIP Page 40Baltimore Serious Area 8-Hour Ozone SIP Page 41 The CAA included restrictions on the use of cont rol measures to m eet the 15% requirements. Reductions in ozone precursors re sulting from four types of federa l and state regulations could not be used to meet rate of progress. These four types of programs are as follows:

(1) Federal Motor Vehicle Control Program (FMVCP) tailpipe and evaporat ive standards issued in January 1, 1990; (2) Federal regulations (55 Fed Reg. 23666, June 11, 1990) limit the Reid Vapor Pressure (RVP) of gasoline in ozone nonattainment areas; (3) State regulations correcting defi ciencies in reasonably ava ilable control technology rules (4) State regulations establishing or correcting inspection and ma intenance (I/M) programs for

on-road vehicles.

The basic procedures of developing target levels for the 15% Plan are describe in EPA’s guidance, Adjusted Base Year Emissions Inventory and th e 1996 Target for the 15% Rate of Progress Plans

.



### 5.2 GUIDANCE FOR CALCULATIN G REASONABLE FURTHER PROGRESS (RFP) EMISSION TARGET LEVELS

The Clean Air Act Amendments (CAAA) of 1990 pr ovide the primary guidan ce for calculating the VOC and NOx target levels used in a region’s RFP plans. In N ovember 2005 as part of its final implementation rule for the 8-hour ozone standard, EP A issued guidance to assist the states in RFP development.

The guidance that applies to the metropolitan Bal timore area is guidance for previously severe 1- hour ozone nonattainment areas with an approve d 15% RFP plan for the period 1990-1996. Since the Baltimore region is a former severe 1-hour ozone nonattainment area and has an approved 15% RFP plan for the above period, “Method 2” of the guidance applies to the region. 20 The region is required to reduce emissions by 15% from 2002-2008 to demonstrate RFP, according to Method 2.

EPA’s guidance (Method 2) states that the target level of VOC and NOx emissions in 2008 needed to meet the 2008 RFP requirement is any comb ination of VOC and NOx reductions from the adjusted base year 2002 inventories (base year 2002 emissions minus non-creditable emissions reduction occurring between 2002 and 2008) that total 15 percent. For example, the target level of VOC emissions in 2008 could be a 10 percent re duction from the adjusted base year 2002 VOC inventory and a 5 percent reduction from the ad justed NOx inventory. The actual projected 2008

VOC and NOx inventories for all so urces with all control measures in place and including projected 2008 growth in activity must be at or lower than the target levels of VOC and NOx emissions.

This section briefly summarizes the requirements a nd procedures for calculat ing the target emission levels required for a RFP demonstration. RFP dem onstrations build upon each other, starting from the base year of 2002.

20 “Appendix A to Preamble—Methods to Account for Non-Creditable Reductions When Calculating ROP Targets for the 2008 and Later ROP Milestone Years,” in Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard, Federal Register, Vol 70, No. 228, Nov.29, 2005.

### 5.2.1 2008 VOC and NOx Target Levels

EPA’s Final Rule To Implement the 8-Hour Oz one National Ambient Air Quality Standard – Phase II mandates that to meet the reasonable further progress requirement, the Baltimore, MD ozone

nonattainment area needs to reduce its emi ssions by 15% between 2002 and 2008 using either reductions in VOC or NOx or any combination of the two. The Baltimore region is able to demonstrate reasonable further progress for the period 2002-2008.

The target levels for 2008 reasonable further pr ogress plans are calculated according to the EPA’s

final rule mentioned above. The general formula for calculation of 2008 target levels is as follows:

Equation 5-1

Target

Level 2008 = RFP base year

emissions ‐ reductions required to meet

the reasonable further

progress requirement ‐ non

‐ creditable

emissions reduction

between 2002 and 2008

Calculation of 2008 Target Levels

Equation 5-2 gives the general fo rmula for calculating post-1996 targ et levels. Since the region has

chosen to demonstrate the 2008 reasonable fu rther progress using 8% VOC reduction, the 2008 VOC target level becomes:

Equation 5-2

2008 VOC Target

Level = 2002 RFP Base

‐ Year emissions ‐ 8.0% VOC

Reduction ‐ non

‐ creditable

emissions reduction

between 2002 and 2008

Equation 5-3

2008 NOx Target

Level = 2002 RFP Base

‐ Year emissions ‐ 7.0% NOx

Reduction ‐ non

‐ creditable

emissions reduction

between 2002 and 2008



### Step 1: Develop 2002 Base Year Inventories an d 2002 Reason able Further Progress Base

Year Inventories

The 2002 Base-Year Inventory is p ublished in a separate document, "2002 Base Year Emissions Inventory & QA/QC Plan Maryland," (June 15, 2 006). This document was submitted to EPA Region III. The document was prepared by the Maryland Department of the Environment and remains intact to fulfill the SIP inventory requirement of the CAA. It is available for inspection at the Maryland Department of the Environment, Air and Radiation Management Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland 21230.

Baltimore Serious Area 8-Hour Ozone SIP Page 42The RFP base-year inventory in cludes only anthropogenic emi ssions generated within the Metropolitan Baltimore Nonattainment Area and is re quired to utilize the most recent EPA models and methods when estimating emissions. As suc h, the 2002 RFP inventory uses the MOVES model

to estimate on-road mobile emissions and th e NONROAD model (version 2008) to estimate the

non-road mobile emissions. The reasonable further progress base year VOC and NOx emissions are presented in Table 5-1.

Table 5-1: 2002 Reasonable Further Progress Base-Year Inventory (Ozone Season tons per day)

Source VOC NOx

Point 13.88 111.89

Area 116.81 8.18

Non-Road 59.61 49.18

On-Road 72.48 202.22

TOTAL 262.77 371.47

Note: Small discrepancies may result due to rounding



### Step 2: Develop 2002 and 2008 Reasonable Further Progress Adjusted Year Inventories

According to the 1990 CAAA, reductions necessary to meet the reasonable further progress requirement must be calculated from an emissions baseline that excludes the effects of the noncreditable Federal Motor Vehicle Control Prog ram (FMVCP) and Reid Vapor Pressure (RVP) programs described in Section 5.1.1. Therefore the 2002 baseline must be adjusted by subtracting

the VOC and NOx reductions that result from these two programs between 2002 and 2008. The resulting inventory is referred to as the 2002 Adjusted Base Year Inventory.

In order to calculate the non-creditable emissi ons reductions, which occur between 2002 and 2008, the following two mobile inventories are needed:

1) 2002 Reasonable Further Progress Adjusted-Year Inventory 2) 2008 Reasonable Further Progress Adjusted-Year Inventory

Both of these mobile inventories were create d using the inputs, liste d below, with the only

difference between the two inventor ies being the model year. Invent ory #1 and #2 were created for 2002 and 2008, respectively.

a) 1990 I/M Program b) RVP = 7.8 psi (RVP required according to June 1990 fuel RVP regulations) 21

21 The 1990 Phase II regulations specify 7.8 psi as the maxi mum RVP of gasoline being sold in the Baltimore, DC-MDVA ozone nonattainment area in 1992.

Baltimore Serious Area 8-Hour Ozone SIP Page 43c) No Post-1990 Clean Air Act Measures d) 2002 Vehicle Activity Inputs e) 2002 Vehicle Miles Traveled (VMT)

The on-road mobile input files ar e included in Appendix E. Tables 5-2 & 5-3 show RFP adjustedyear inventories for 2002 and 2008, respectively.

Table 5-2: 2002 Reasonable Further Progress Adjusted-Year Inventory (Ozone Season tons per day)

Source VOC NOx

Point 13.88 111.88

Area 116.81 8.18

Non-Road 70.22 40.96

On-Road 111.14 287.69

TOTAL 312.05 448.71

Note: Small discrepancies may result due to rounding

Baltimore Serious Area 8-Hour Ozone SIP Page 44Table 5-3: 2008 Reasonable Further Progress Adjusted-Year Inventory (Ozone Season tons per day)

Source VOC NOx

Point 13.88 111.88

Area 116.81 8.18

Non-Road 70.22 40.96

On-Road 107.05 285.91

TOTAL 307.96 446.93

Note: Small discrepancies may result due to rounding



### Step 3: Non-creditable Emissions Reductions

The non-creditable emissions reductions that occu r in the absence of an y post-1990 CAA measures during a reasonable further progress period can be determined by ta king the difference between the RFP adjusted-year inventories for the relevant milestone years. For VOC and NOx, the relevant milestone years are 2002 and 2008.

Equation 5-4

Non

‐ creditable

Emissions Reductions = 2002 RFP Adjusted

Year Inventory ‐ 2008 RFP Adjusted

Year Inventory

Table 5-4:

Calculation of Non-credita ble Emissions Reductions (Ozo ne Season tons per day)

Description VOC NOx

2002 Adjusted Year Inventory (a) 111.14 287.69

2008 Adjusted Year Inventory (b) 107.05 285.91

Non-creditable Emissions Reduction (a-b) 4.09 1.78



### Step 4: Calculation of 2008 Target Levels

The VOC and NOx target levels for 2008 are calculated in Table 5-5 below:

Baltimore Serious Area 8-Hour Ozone SIP Page 45Table 5-5:

Calculation of VOC and NO x Target Levels for 2008 (Ozone Season tons per day)

Description Formula VOC NOx

A 2002 Base Year Inventory 485.97 371.47

B Biogenic Emissions 223.20 0.00

C 2002 Rate-of Progress Base Year Inventory A - B 262.77 371.47

D FMVCP/RVP Reductions Between 2002 and 2008 4.08 1.78

E 2002 Adjusted Base Year Inventory Calculated Relative to 2008 C - D 258.69 369.69

F Reduction Ratio 0.0800 0.0700

G Emissions Reductions Required Between 2002 and 2008 E * F 20.70 25.88

H Target Level for 2008 [TL (2008) ] C - D - G 238.00 343.81



### 5.3 COMPLIANCE WITH 2008 REASON ABLE FURTHER PROGRESS REQUIREMENTS

In order to demonstrate reasonable further progr ess for the period 2002-2008, the Baltimore region must show that expected emissions in 2008 are equal to or less than the 2008 target levels presented

in Table 5-5.

The 2008 controlled inventories are inventories of all anthropogenic VOC and NOx emissions expected to occur in the Ba ltimore Nonattainment Area during 2008. The 2008 inventories were developed as described in Chapter 4 and are disp layed in Table 4-5. As summarized in Table 5-6,

the 2008 controlled VOC and NOx inventories are le ss than the 2008 target inventories. Table 5-6 demonstrates that the Baltimore region fulf ills the 2002-2008 reasonable further progress requirements.

Table 5-6:

Baltimore Nonattainment Area Comparison of 2008 Controlled and Target Inventories Ozone Season Daily Emissions (tons per day)

Description VOC NOx

2008 Target Levels 238.00 343.81

2008 Controlled Emissions 217.96 299.62

Baltimore Serious Area 8-Hour Ozone SIP Page 46References

U.S. EPA, “Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15% Rate of Progress Plans”

U.S. EPA, “Guidance on the Post-1996 Reasona ble Further Progress Plan and the Attainment Demonstration,” February 18, 1994.

U.S. EPA, “NOx Substitution Guidance,” December 1993.

Baltimore Serious Area 8-Hour Ozone SIP Page 47

## 6.0 2011 REASONABLE FURTHER PROGRESS REQUIREMENTS

6.1 INTRODUCTION

In addition to the 2002-2008 reasonable further progr ess (RFP) demonstration contained in Chapter 5, the Baltimore region must also demonstr ate RFP for the period 2008-2011. In order to demonstrate RFP, a region must show that its ex pected emissions, termed “controlled inventories,”

of NOx and VOC will be less than or equal to the target levels set for the end of the RFP period, or “milestone year”. By re-classifyi ng as a “serious” ozone nonattainmen t area, the Baltimore region is required to establish target levels that reduce VOC and NOx emissions by 3 percent per year (or 9% total) over the 2008 to 2011 period. For the RFP period 2008-2011, the target levels of emissions are the maximum quantity of anthropogenic emissi ons permissible during the 2011 milestone year. This section describes the methodology used to establish the regional ta rget inventories and controlled inventories for 2011. Because the expected NOx and VOC emissions will be less than the target levels, the Baltimore region will meet th e RFP requirements by the January 1, 2012 deadline.



### 6.2 GUIDANCE FOR CALCULATIN G REASONABLE FURTHER PROGRESS (RFP) EMISSION TARGET LEVELS

The guidance and methods used to calculate the 2011 target levels are the same as for the 2008 target levels; however, the starting point is the 2008 target levels instead of the 2002 Base Year Inventory.



### 6.2.1 2011 VOC and NOx Target Levels

EPA’s Final Rule To Implement the 8-Hour Oz one National Ambient Air Quality Standard – Phase II mandates that to meet the reasonable further progress requirement, the Baltimore ozone

nonattainment area needs to reduce its emi ssions by 9% between 2008 and 2011 using either reduction in VOC or NOx or any combination of the two. The Baltimore region is able to demonstrate reasonable further progress for the period 2008-2011.

The target levels for 2011 reasonable further pr ogress plans are calculated according to the EPA’s

final rule mentioned above. The general formula for calculation of 2011 target levels is as follows:

Equation 6-1

Target

Level 2011 = Target Level

2008 ‐ Reductions Required to

meet the RFP (2008

– 2011) ‐ non

‐ creditable

emissions reduction

between 2008 and 2011

Equation 6-1, above, gives the general formula for calculating 2011 target leve ls. S ince the region

has chosen to demonstrate the 2008 reasonable further progress using a 6% VOC reduction, the 2011 VOC target level is as shown in Equation 6-2:

Baltimore Serious Area 8-Hour Ozone SIP Page 48Equation 6-2

2011 VOC Target

Level = 2008 VOC
Target Level ‐ 6.0% VOC

Reduction ‐ non

‐ creditable

emissions reduction

between 2008 and 2011

Equation 6-3

2011 NOx Target

Level = 2008 NOX
Target Level ‐ 3.0% NOx

Reduction ‐ non

‐ creditable

emissions reduction

between 2008 and 2011



### Step 1: Develop 2008 Target Levels for VOC and NOx

The 2008 target levels were developed in accord ance with EPA protocols and the methods were presented in Chapter 5.



### Step 2: Non-creditable Emissions Reductions

The non-creditable emissions reductions that occu r in the absence of an y post-1990 CAA measures during a reasonable further progress period can be determined by ta king the difference between the RFP adjusted-year inventories for the relevant milestone years. For VOC and NOx, the relevant milestone years are 2008 and 2011. Note: The non- creditable emissions reductions between two RFP years cannot be negative.

Equation 6-4

Non

‐ creditable

Emissions Reductions = 2008 RFP Adjusted

Year Inventory ‐ 2011 RFP Adjusted

Year Inventory

Table 6-1:

Calculation of Non-credita ble Emissions Reductions (Ozo ne Season tons per day)

Description VOC NOx

Non-creditable Emissions Reduction (2008 – 2011) 0.29 0.00



### Step 3: Calculation of 2011 Target Levels

Following Equations 6-2, 6-3 and 6-4, the VOC a nd NOx target levels fo r 2011 are calculated in

Table 6-2 below:

Baltimore Serious Area 8-Hour Ozone SIP Page 49Table 6-2:

Calculation of VOC and NO x Target Levels for 2011 (Ozone Season tons per day)

Description Formula VOC NOx

A 2008 Target Level 238.00 343.81

B FMVCP/RVP Reductions Between 2008 and 2011 0.29 0.00

C 2002 Adjusted Base Year Inventory Ca lculated Relative to 2011 A - B 237.71 343.81

D Reduction Ratio 0.0600 0.0300

E Emissions Reductions Required Between 2008 and 2011 C * D 14.28 10.31

F Target Level for 2011 [TL (2011) ] A - B - E 223.72 333.49



### 6.3 COMPLIANCE WITH 2011 REASON ABLE FURTHER PROGRESS REQUIREMENTS

In order to demonstrate reasonable further progr ess for the period 2008-2011, the Baltimore region must show that expected emissions in 2011 are equal to or less than the 2011 target levels presented

in Table 6-2.

The 2011 controlled inventories are inventories of all anthropogenic VOC and NOx emissions expected to occur in the Baltimore Nonatta inment Area during 2011. The inventories were developed as described in Chapter 4 and are disp layed in Table 4-6. As summarized in Table 6-3,

the 2011 controlled VOC and NOx inventories are le ss than the 2011 target inventories. Table 6-3 demonstrates that the Baltimore region fulf ills the 2008-2011 reasonable further progress requirements.

Table 6-3:

Baltimore Nonattainment Area Comparison of 2011 Controlled and Target Inventories Ozone Season Daily Emissions (tons per day)

Description VOC NOx

2011 Target Levels 223.72 333.49

2011 Controlled Emissions 205.65 246.48

Baltimore Serious Area 8-Hour Ozone SIP Page 50

## 7.0 2012 REASONABLE FURTHER PROGRESS REQUIREMENTS

7.1 INTRODUCTION

In addition to the 2008-2011 reasonable further progr ess (RFP) demonstration contained in Chapter 6, the Baltimore region must also demonstrate reasonable further progress for the period 2011-2012. In order to demonstrate reasonable further progress, a region must show that its expected emissions, termed “controlled inventories,” of NOx and VOC will be less than or equal to the target levels set for the end of the reasonable further progress peri od, or “milestone year”. By re-classifying as a “serious” ozone nonattainment area, the Baltimore region is required to establish target levels that reduce VOC and NOx emissions by 3 percent per year (or 3% total) over the 2011 to 2012 period. For the reasonable further progr ess period 2011-2012, the target le vels of emissions are the maximum quantity of anthropogenic emissions pe rmissible during the 2012 milestone year. This section describes the methodology used to establish the regional target in ventories and controlled inventories for 2012. Because the expected NOx a nd VOC emissions will be less than the target levels, the Baltimore region will meet the reasona ble further progress requirements by the January 1, 2013 deadline.



### 7.2 GUIDANCE FOR CALCULATIN G REASONABLE FURTHER PROGRESS (RFP) EMISSION TARGET LEVELS

The guidance and methods used to calculate the 2012 target levels are the same as the 2008 and 2011 target levels, however the starting point is the 2011 target level.



### 7.2.1 2012 VOC and NOx Target Levels

EPA’s Final Rule To Implement the 8-Hour Oz one National Ambient Air Quality Standard – Phase II mandates that to meet the reasonable further progress requirement, the Baltimore ozone

nonattainment area needs to reduce its emissi ons by 3 between 2011 and 2012 using reductions in either VOC or NOx or any combination of the tw o. The Baltimore region is able to demonstrate reasonable further progress for the period 2011-2012.

The target levels for 2012 reasonable further pr ogress plans are calculated according to the EPA’s

final rule mentioned above. The general formula for calculation of 2012 target levels is as shown in Equation 7-1:

Equation 7-1

Target

Level 2012 = Target Level

2011 ‐ Reductions Required to

meet the RFP (2011

– 2012) ‐ non

‐ creditable

emissions reduction

between 2011 and 2012

Equation 7-1, above, gives the general formula for calculating 2012 target leve ls. S ince the region

has chosen to demonstrate the 2012 reasonable further progress using a 1.5% VOC reduction, the 2012 VOC target level is as shown in Equation 7-2.

Baltimore Serious Area 8-Hour Ozone SIP Page 51Equation 7-2

2012 VOC Target

Level = 2011 VOC
Target Level ‐ 1.5% VOC

Reduction ‐ non

‐ creditable

emissions reduction

between 2011 and 2012

Equation 7-3

2012 NOx Target

Level = 2011 NOX
Target Level ‐ 1.5% NOx

Reduction ‐ non

‐ creditable

emissions reduction

between 2011 and 2012



### Step 1: Develop 2011 Target Levels for VOC and NOx

The 2011 target levels were developed in accord ance with EPA protocols and the methods were presented in Chapter 6.



### Step 2: Non-creditable Emissions Reductions

The non-creditable emissions reductions that oc cur in absence of any post-1990 CAA measures during a reasonable further progress period can be determined by ta king the difference between the RFP adjusted-year inventories for the relevant milestone years. For VOC and NOx, the relevant milestone years are 2011 and 201 2. The non-creditable emissions reductions between two RFP years cannot be negative.

Equation 7-4

Non

‐ creditable

Emissions Reductions = 2011 RFP Adjusted

Year Inventory ‐ 2012 RFP Adjusted

Year Inventory

Table 7-1:

Calculation of Non-credita ble Emissions Reductions (Ozo ne Season tons per day)

Description VOC NOx

Non-creditable Emissions Reduction (2008 – 2011) 0.00 0.18



### Step 3: Calculation of 2012 Target Levels

Following Equations 7-2, 7-3 and 7-4, the VOC a nd NOx target levels fo r 2012 are calculated in

Table 7-2 below:

Baltimore Serious Area 8-Hour Ozone SIP Page 52Table 7-2:

Calculation of VOC and NO x Target Levels for 2012 (Ozone Season tons per day)

Description Formula VOC NOx

A 2011 Target Level 223.73 333.49

B FMVCP/RVP Reductions Between 2011 and 2012 0.00 0.18

C 2002 Adjusted Base Year Inventory Ca lculated Relative to 2012 B - A 223.73 333.32

D Reduction Ratio 0.0150 0.0150

E Emissions Reductions Required Between 2011 and 2012 C * D 3.36 5.00

F Target Level for 2012 [TL (2012) ] A - B - E 220.38 328.49



### 7.3 COMPLIANCE WITH 2012 REASON ABLE FURTHER PROGRESS REQUIREMENTS

In order to demonstrate reasonable further progr ess for the period 2011-2012, the Baltimore region must show that expected emissions in 2012 are equal to or less than the 2012 target levels presented

in Table 7-2.

The 2012 controlled inventories are inventories of all anthropogenic VOC and NOx emissions expected to occur in the Baltimore Nonatta inment Area during 2012. The inventories were developed as described in Chapter 4 and are disp layed in Table 4-7. As summarized in Table 7-3,

the 2012 controlled VOC and NOx inventories are le ss than the 2012 target inventories. Table 7-3 demonstrates that the Baltimore region fulf ills the 2011-2012 reasonable further progress requirements.

Table 7-3:

Baltimore Nonattainment Area Comparison of 2012 Controlled and Target Inventories Ozone Season Daily Emissions (tons per day)

Description VOC NOx

2012 Target Levels 220.38 328.49

2012 Controlled Emissions 199.90 232.88

Baltimore Serious Area 8-Hour Ozone SIP Page 53

## 8.0 CONTROL MEASURES

This chapter is divided into three sections. Secti on 8.1 identifies the control measures that were part

of the 1-Hour Ozone SIP for the Baltimore N onattainment Area. These regulations/control

measures continue to be in existence and contin ue to reduce emissions in the region. All of the

emission reductions from the measures identified in Section 8.1 were part of the baseline emissions inventory for the Baltimore Nonattainment Area.

Section 8.2 of this chapter identif ies measures implemented after 2002 that were not part of the baseline inventory and are gi ving specific emission reductions to the region’s 8-hour Ozone reasonable further progress demonstration.

Section 8.3 identified vol untary/innovative measures that the Maryland is not taking formal credit

for in the SIP. These measures are not comm itments to programs but present information on programs that are directionally correct and could provide ozone benefits.



### 8.1 1-HOUR OZONE CONTROL MEASURES

8.1.1 On-Road Mobile Measures

Enhanced Vehicle Inspection an d M a intenance (Enhanced I/M)

The Clean Air Act (CAA or “the Act”) requir es enhanced motor vehicle inspection and maintenance (I/M) programs in serious, seve re, and extreme ozone nonattainment areas and Metropolitan Statistical Area (MSA)/Consolidated Metropolitan Statistical Area (CMSA) portions of the OTR with urbanized populat ions over 200,000. In Maryland, th is required an enhanced I/M program in the eight jurisdictions operating a basic I/M program as well as six new jurisdictions, for a total of 14 of the 23 jurisdictions in the state. Tailpipe emissions are measured over a transient driving cycle conducted on a dynamometer, which pr ovides a much better indication of actual onroad vehicle performance th an the existing idle test.



### Tier I Vehicle Emission Standards and Ne w Federal Evaporative Test Procedures

The Act requires a new and cleaner set of federal motor vehicle emissions standards (Tier I standards) beginning with model year 1994. The Act also requires a uniform level of evaporative

Baltimore Serious Area 8-Hour Ozone SIP Page 54emission controls which are more st ringent than most evaporative cont rols used in existing vehicles. These federally implemented programs a ffect light duty vehicles and trucks.



### Reformulated Gasoline in On-road Vehicles

All gasoline-powered vehicles are affected by this control measure. Vehicle refueling emissions at

service stations are also reduce d. In addition, emissions from gasoline powered nonroad vehicles and equipment are reduced by this control strate gy. Since January 1995, only gasoline that the EPA has certified as reformulated may be sold to cons umers in the nine worst ozone nonattainment areas with populations exceeding 250,000.



### Tier 2 Vehicle Emission Standards

On December 21, 1999, the EPA announced new regula tions affecting tailpipe emissions standards for the production of new cars and light trucks weighing up to 8,500 pounds. Commonly referred to as “Tier 2,” these standards take effect beginning in 2004. The emi ssions reduction benefits of this Tier 2 program for the Maryland region are be si gnificant, including passe nger cars that are 77 percent cleaner than those on the road today. Li ght-duty trucks, such as Sport Utility Vehicles (SUVs), which are subject to standards that are less protective than those for cars, would be as much as 95 percent cleaner under the new standards. In effect, the rule forces SUVs and light trucks to meet the same tailpipe emission standards as cars.

As part of the new tailpipe sta ndard, the EPA also announced standard s for lower sulfur in gasoline. The lower sulfur standards are necessary to enab le passenger vehicles to meet Tier 2 emission

standards.



### National Low Emission Vehicle Program

The National Low Emission Vehicle Program (N ational LEV) program is a vehicle technology program resulting in the production of light duty vehicles and light -duty trucks with significantly lower tailpipe emissions. The National LEV program is applicable to 1999 and later model-year vehicles sold in the Ozone Transport Region (O TR) and 2001 and later model-year vehicles sold throughout the United States. The Nationa l LEV program was developed through an unprecedented, cooperative, voluntary effort by th e northeastern states, auto manufacturers, environmentalists, fuel providers, U. S. EPA and other interested par ties. National LEV vehicles are 70 percent cleaner than 1998 models. The National LEV program results in substantial reductions in volatile organic compounds (VOCs) and oxides of nitrogen (NOx), which contribute to unhealthy levels of smog in many areas across the country.

Baltimore Serious Area 8-Hour Ozone SIP Page 55

### Federal Heavy-Duty Diesel Engine Rule

EPA’s heavy-duty diesel engine (HDDE) rule addresses diesel ve hicles weighing more than 8,500 pounds. These standards take effect in 2007 and re duce emissions from new HDDEs by 95%. In order to achieve the new standards, ultra-low sulfur diesel fuel will also be needed.



### Stage II and New Vehicle On-Boa rd Vapor Recovery Systems

These measures required the following: (1) inst allation of Stage II vapor recovery nozzles at gasoline pumps and (2) the instal lation of onboard refueling emissions (onboard refueling vapor recovery, or “ORVR”) controls for new passenger cars and light trucks be ginning in the 1998 model year. Maryland adopted Stage II vapor recovery regulations for the Baltimore and Washington nonattainment areas and Cecil County in January of 1993, earlier than required of the Ozone Transport Region (OTR). The Stage II vapor re covery regulation requires that the gasoline dispensing system be equipped with nozzles that are designed to re turn the vapors, through a vapor line, into the gasoline tank.



### 8.1.2 Area Source Measures

VOC Controls in Maryland 22

 Automotive and Light-Duty Truck Coating

 Can Coating

 Coil Coating

 Large Appliance Coating

 Paper, Fabric, Vinyl, and Other Plastic Parts Coating

 Control of VOC Emissions from Solid Resin Decorative Surface Manufacturing

 Metal Furniture Coating

 Control of VOC Emissions from Cold and Vapor Degreasing

 Flexographic and Rotogravure Printing

 Lithographic Printing

 Dry Cleaning Installations

 Miscellaneous Metal Coating

 Aerospace Coating Operations

 Brake Shoe Coating Operations

 Control of Volatile Organic Compounds fr om Structural Steel Coating Operations

 Manufacture of Synthesized Pharmaceutical Products

 Paint, Resin and Adhesive Manufact uring and Adhesive Application

 Control of VOC Equipment Leaks

 Control of Volatile Organic Compound ( VOC) Emissions from Yeast Manufacturing

 Control of Volatile Organic Compound Emission s from Screen Printing and Digital Imaging

22 See the Code of Maryland Regulations (COMAR) 26.11.10, 26.11.14, and 26.11.19.

Baltimore Serious Area 8-Hour Ozone SIP Page 56 Control of Volatile Organic Compounds ( VOC) Emissions from Expandable Polystyrene Operations

 Control of Landfill Gas Emissions from Municipal Solid Waste Landfills

 Control of Volatile Organic Compounds (VOC ) Emissions from Commercial Bakery Ovens

 Control of Volatile Organic Compou nds (VOC) from Vinegar Generators

 Control of VOC Emissions from Vehicle Refinishing

 Control of VOC Emissions from Leather Coating

 Control of Volatile Organic Compounds fr om Explosives and Propellant Manufacturing

 Control of Volatile Organic Compound Emissions from Reinforced Plastic Manufacturing

 Control of Volatile Organic Compounds fr om Marine Vessel Coating Operations

 Control of Volatile Organic Compounds fr om Bread and Snack Food Drying Operations

 Control of Volatile Organic Com pounds from Distilled Facilities

 Control of Volatile Organic Compou nds from Organic Chemical Production

 Iron and Steel Produc tion Installations

 Control of Kraft Pulp Mill Emissions



### Municipal Landfills

A municipal solid waste landfill is a disposal facility where household waste is placed and periodically covered with inert material. Landf ill gases are produced from the decomposition and

chemical reactions of the refuse in the landfill. They consist primarily of methane and carbon dioxide, with volatile organic compounds making up less than one percent of the total emissions. The control strategy for this source ca tegory is based upon federal rules.



### Burning Ban

Open burning is primarily used for the disposal of brush, trees, and yard waste and as a method of la nd clearing by both developers and

individual citizens. Emissions from open burning include oxides of nitrogen, hydrocarbons , carbon dioxide (CO 2 ), carbon monoxide (CO) and other toxic compounds. Emissions levels from open burning are high due to the ineffici ent and uncontrolled manner in which the material is burned. The Department adopted a regulation that prohibits open burning during the peak ozone period (June to August). Th ere are exemptions for agricultural burning, fire training and recreati onal activities.



### Surface Cleaning/Degreasing

Cold degreasing is an operation th at uses solvents and other materi als to remove oils and grease from metal parts including automo tive parts, machined products and fabricated metal components. MDE adopted regulations in 1995 to require small degreasing operations such as gasoline stations, autobody paint shops and machine shops to use le ss polluting degreasing solvents in serious and

Baltimore Serious Area 8-Hour Ozone SIP Page 57severe ozone nonattainment areas. Also, solvent ba ths and rags soaked with solvents must be covered under this regulation.



### Architectural and Industrial Maintenance Coatings

Architectural and industrial main tenance coatings are field-app lied coatings used by industry, contractors, and homeowners to coat houses, build ings, highway surfaces, and industrial equipment for decorative or protective purposes. VOC emissions result from the evaporation of solvents from the coatings during applicati on and drying. A federal measur e requires reformulation of architectural and industrial maintenance coatings . The users of these coatings are small and widespread, making the use of add-on control devi ces technically and econo mically infeasible.



### Commercial and Consumer Products

Consumer and commercial products are items sold to retail customers for household, personal or automotive use, along with the products marketed by wholesale distributors for use in institutional or commercial settings such as beauty shops, sch ools, and hospitals. VOC emissions result from the evaporation of solvent contents in the products or solvents used as propellants. This measure requires the reformulation of certain consumer products to reduce their VOC content. Product reformulation can be accomplished by substituting water, other non-VOC ingredients, or low-VOC solvents for VOCs in the product.



### Automobile Refinishing

Automobile refinishing is the re painting of worn or damaged auto mobiles, light trucks and other vehicles. Volatile organic compound emissions resu lt from the evaporation of solvents from the coatings during application, drying and clean up tec hniques. This measure, based in state regulation, requires large and small autobody refinishing operations to use low VOC content materials in the refinishing process and cleanup, a nd to use efficient spray guns to control application. The Department adopted regulations in 1995 requi ring the use of reformulated coatings.



### Screen Printing

A screen-printing process is used to apply printing or an image to virtually any substrate. In the screen-printing operation, ink is distributed through a porous screen mesh to which a stencil may have been applied to define an image to be prin ted on a substrate. VOC emissions result from the evaporation of ink solvents and from the use of solvents for cleaning. The major source of VOC emissions is the printing process. This measure re quires smaller printers to use water based and/or

low VOC materials to reduce VOC emissions. Because the users of these coatings are relatively small, requiring the use of add-on control device s is technically and ec onomically infeasible. Reductions in VOC emissions were obtained through the use of ink reformulation, process printing modification, and material substitution for cleani ng operations. This regulation became effective on June 5, 1995.

Baltimore Serious Area 8-Hour Ozone SIP Page 58

### Graphic Arts – Lithographic Printing

This source category consists of numerous sma ll sheet-fed printers that perform non-continuous printing, and web printers that print on a continuous web or roll. Heat-set web printers use drying ovens to force dry the printed matter. Web printing sources pe rform high volume printing on paper or paperboard. VOC emissions are caused by ev aporation of the ink so lvents, alcohol in the fountain or dampening solution, a nd equipment wash solvents. These VOC discharges may also cause visible emissions and nuisance odors. MDE adopt ed a regulation in 1995 to require printers to

use control devices and/or low VOC materials to reduce VOC emissions.



### Graphic Arts – Flexographi c and Rotogravure Printing

This source category consists of numerous small fl exographic or rotogravure printers that perform non-continuous sheet fed printi ng and continuous web or roll printing. MDE adopted a printing regulation in 1987 that requi res smaller printers to use control devices and/or low VOC materials to reduce VOC emissions. VOC emissions are caused almost entirely by evaporation of the ink solvents. Although several control devices were evaluated over the years for rotogravure and flexographic web printers, a catalyt ic oxidizer has proven to be most successful. A typical oxidizer yields 96-98 percent destruction of VOC. Most sources were in compliance with all requirements by early 1992.



### 8.1.3 Non-Road Measures

Nonroad Small Gasoline Engines

This measure requires small gasoline-powered engine equipment, such as lawn and garden equipment, manufactured after August 1, 1996 to meet federal emi ssions standards. Small gasolinepowered engine equipment includes, for example, lawn mowers, trimmers, generators, and compressors. These measures apply to equipment with engines of less than 25 horsepower. VOC

emissions result from combustion and evaporation of ga soline used to power this equipment.



### Non-Road Diesel Engines Tier I and Tier II

This measure takes credit for NOx emissions reduc tions from emissions standards promulgated by the EPA for non-road, compression-i gnition (i.e., diesel-powered) ut ility engines. The measure affects diesel-powered (or other compression-ign ition) heavy-duty farm, construction equipment, industrial equipment, etc., rated at or above 37 kilowatts (37 kilowatt s is approximately equal to 50 horsepower). Heavy-duty farm and construction equipment includes asphalt pavers, rollers, scrapers, rubber-tired dozers, agricultural tractors, combines, balers, and harvesters. This measure applies to all compression-ignition engines excep t engines used in aircraft, marine vessels,

Baltimore Serious Area 8-Hour Ozone SIP Page 59locomotives and underground mining activity. NOx em issions result from combustion of diesel fuel used to power this equipment.



### Marine Engine Standards

Of the nonroad sources studied by EPA, gasoline mari ne engines were found to be one of the largest contributors of hydrocarbon (HC) emissions, 30% of the nationwide nonroad total. This measure controls exhaust emissions from new spark-i gnition (SI) gasoline mari ne engines, including outboard engines, personal watercraft engines, and jet boat engines.



### Emissions standards for la rge spark ignition engines

This EPA measure controls VOC and NOx emissions from several groups of previously unregulated nonroad engines, including large indu strial spark-ignition engines, re creational vehicles, and diesel marine engines. The emission stan dards apply to all new engines so ld in the United States and any imported engines manufactured after these standa rds begin. Controls on the category of large industrial spark-ignition engines ar e first required in 2004. Large industrial spark-ignition engines are those rated over 19 kW used in a variety of commercial applications; most use liquefied petroleum gas, with others opera ting on gasoline or natural gas. Controls on the other engine categories are required begi nning in years after 2005.



### Reformulated gasoline use in non-ro ad motor vehicles and equipment

This federally mandated measure requires the use of lower polluting "reformulated" gasoline in the

Baltimore Nonattainment Area. The measure i nvolves taking credit fo r emissions reductions resulting from the use of the federally reform ulated gasoline in non-road mobile sources.

Nonattainment areas classified as severe were re quired to opt in on the delivery of reformulated gasoline. This measure affects the various non-roa d mobile sources that burn gasoline, such as small gasoline-powered engine equipment incl uding lawn mowers, trimmers, generators, and compressors. VOC emissions result from combusti on and evaporation of ga soline used to power this equipment.



### Railroad Engine Standards

This measure establishes emission standard s for oxides of nitrogen, hydrocarbons, carbon monoxide, particulate matter, and smoke for ne wly manufactured and re manufactured dieselpowered locomotives and locomotive engines, which were previously unregul ated. This regulation

took effect in 2000 and affects railroad manufactur ers and locomotive re-manuf acturers. It involves adoption of three separate sets of emission standard s with the applicability dependent on the date a

locomotive is first manufactured.

Baltimore Serious Area 8-Hour Ozone SIP Page 60

### 8.1.4 Point Source Measures

Expandable Polystyrene Products

These sources use expandable polystyrene beads that contain pentane, a VOC, to manufacture foam products such as foam cups, board insulation, a nd custom shapes. VOC emissions typically occur during storage and pre-expansion of the beads, during manufacturing, and during "aging" when the blowing agent (pentane) slowly diffuses from th e foam before shipping. This control measure requires Reasonably Available Control Technologies (RACT) to be installe d at operations that manufacture foam cups, foam in sulation and other foam products. The regulation became effective in July 1995.



### Yeast Manufacturing

Yeast is produced using an aerated fermentati on process under controlled conditions. In June 1995, MDE required RACT to be installed at two y east-manufacturing operati ons in the Baltimore Nonattainment Area. The regulation results in an overall emission reduction of approximately 60 to 70 percent from the 1990 baseline by requiring aff ected sources to meet specific VOC emission

standards.



### Commercial Bakery Ovens

This measure requires commercial bakeries using yeas t to leaven bread and bread products to install RACT. Commercial bakeries gene rate VOC emissions from the fermentation and baking processes used to produce yeast-raised baked goods. Thes e emissions are primarily ethanol. The regulation requires control equipment dependent upon thresholds th at are based on cost effectiveness criteria.



### Federal Air Toxics

This measure covers sources that are required to comply with federal air toxics requirements. The Department has delegation to implement federal ai r toxics rules that will achieve VOC emissions reductions. Federal rules that may achieve su ch reductions include the following: federal NESHAPs for vinyl chloride produ ction plants, benzene emissions from equipment leaks, benzene storage vessels, coke by-product recovery plants, benz ene transfer operations , and benzene waste operations; and the EPA Maximum Achievab le Control Technology (MACT) program.



### Enhanced Rule Compliance

Enhanced Rule Compliance or rule effectiveness (RE) improvement refers to an improvement in the implementation of and compliance with a regulati on. These RE improvements may take several forms, ranging from more frequent and in-depth tr aining of inspectors to larger fines for sources that do not comply with a given rule.

Baltimore Serious Area 8-Hour Ozone SIP Page 61

### State Air Toxics

This measure addresses stationary sources that are covered by Maryland's air toxics regulations that have achieved VOC reductions above and beyond curre nt federally enforceable limits. In general, Maryland's air toxics regulations cover any source required to obtain a permit to construct or annually renewed state permit to operate. The Depa rtment adopted the air toxics regulations in

1988.



### NOx RACT -- Reasonably Available Control Technology

This measure requires control of nitrogen oxi des (NOx) emissions by installing RACT. NOx RACT will apply to utility, industrial and comm ercial fuel burning equipment and combustion installations. The regulation established cost-effectiv e controls on all installations located at major NOx sources. This first phase of stationary source NOx reductions resulted in an approximate 22%

reduction in NOx emissions.



### NOx Phase II/Phase III Ozone Transport Comm ission (OTC)/NOx Bu dget Rule (Phase II) and NOx SIP Call (Phase III)

In 1994, the OTC member states signed a major agreement to reduce NOx emissions from power plants and other major stationary sources of po llution throughout the Northeast and Mid-Atlantic states. The agreement recognized th at further reductions in NOx emi ssions are needed to enable the entire Ozone Transport Region (OTR) to meet the NAAQS. The Department adopted a “NOx Budget” rule to require a second phase of stationary source NOx reductions as part of this regulatory initiative. This regula tion requires large stationary sources to reduce summertime NOx emissions by approximately 65% from 1990 levels . The regulation also includes provisions allowing sources to comply by trad ing “allowances.” This regulation requires affected sources to have met these requirements by May 2000.

In late 1998, the U.S. EPA adopted its “NOx SIP Call” to reduce ozone tr ansport in the Eastern United States. This regional NOx reduction pr ogram requires 22 states, including Maryland, to submit regulations and a revision to State Implem entation Plans (SIPs) to further reduce NOx emissions. Maryland’s Phase III regulations achie ve approximately 23% a dditional reductions from large stationary sources such as power plants, cement kilns and large industrial boilers. The regulations require affected sources to add specific control equipmen t, reduce emissions, or trade to meet the allowable amount ("cap" ) of seasonal NOx emissions by 2003.



### 8.2 8-HOUR OZONE CONTROL MEASURES

The following measures have been implemented in Maryland since 2002, the baseline emissions inventory year for 8-Hour Ozone. These measures were not part of the baseline emissions inventory for the 8-Hour Ozone SIP, and emission reductions from these measures were forecasted for 2008, 2011, and 2012 (reasonable further progress ca lculation) and 2012 (attainment inventory) for use in the reasonable further progress calculations for the Baltimore Nonattainment Area as well

as the attainment modeli ng for the region. A summary of the cont rol measures and their benefits is

Baltimore Serious Area 8-Hour Ozone SIP Page 62presented in Table 8-1 below. The benefits below summarize the emission credits available from the

listed measures based on the difference between a controlled and uncontrolled inventory, each year, for each pollutant.

Table 8-1: Summary of Emissions C redits Available from Control Measures

2008 2011 2012

Control Measure VOC NOx VOC NOx VOC NOx

Total Mobile (Includes Enhanced I/M, Tier I,

Reform Gas, LEV, and HDDE) 52.86 158.43 62.23 181.35 66.59 192.33

Stage II/Refuel 0.00 0.00 0.00 0.00 0.00 0.00

OTC ‐ Consumer Products Phase 1 3.70 0.00 3.77 0.00 3.79 0.00

OTC ‐ Consumer Products Phase 2 0.00 0.00 0.46 0.00 0.46 0.00

OTC

– AIM 6.03 0.00 6.19 0.00 6.19 0.00

OTC ‐ PFC Phase 1 6.71 0.00 8.31 0.00 8.35 0.00

OTC ‐ PFC Phase 2 0.00 0.00 0.60 0.00 0.60 0.00

OTC ‐ Industrial Adhesives 0.00 0.00 2.63 0.00 2.64 0.00
Open Burning 0.00 0.00 0.00 0.00 0.00 0.00

Nonroad Model 17.85 8.12 26.33 14.55 29.83 17.30

Railroads (Tier 2) 0.00 1.18 0.00 1.58 0.00 1.67
Healthy Air Act (HAA) 0.00 0.00 0.00 31.86 0.00 37.18

Total 87.14 167.73 110.51 229.35 118.45 248.48



### 8.2.1 The Maryland Healthy Air Act (HAA)

In April of 2006, the Maryland General Assembly enacted the Maryland Healthy Air Act. The Maryland General Assembly record related to the HAA and the final ve rsion of the Act itself can be

found at:

http://mlis.state.md.us/2006rs/billfile/SB0154.htm

The MDE Regulations (Code of Maryland Regulations) can be found at:

http://www.mde.state.md.us/assets/document/CPR_12-26- 06_Emergency_and_Permanent_HAA_Regs_for_AELR.pdf

The HAA requires reductions in nitrogen oxides (NO

x ), sulfur dioxide (SO 2 ) and mercury emissions from large coal burning power plants. The Healthy Air Act also requires that Maryland become involved in the Regional Greenhouse Gas Initiative (RGGI) which is aimed at reducing greenhouse gas emissions.

The Maryland Department of the Environment has been charged with implementing the HAA through regulations. As enacted, these regulations constitute the most sweeping air pollution emission reduction measure proposed in Maryland history.

Baltimore Serious Area 8-Hour Ozone SIP Page 63Affected Sources

The Healthy Air Act NOx reduction requirements affect the fossil fuel fired electric generating units below. Note that only the Ravens Power Hold ings, LLC plants are located in the Baltimore

Nonattainment Area.

Ravens Power Holdings, Brandon Shores 1 & 2, Anne Arundel County H. A. Wagner 2 & 3, Anne Arundel County C. P. Crane 1 & 2, Baltimore County

Mirant System Chalk Point 1 & 2, Prince George’s County Dickerson 1, 2, & 3, Montgomery County Morgantown 1 & 2, Charles County

Allegheny Energy Washington County R. Paul Smith, 3 & 4

Overview of Expected Emission Reductions

Over ninety-five percent of the air pollution emitted from Maryland’ s power plants comes from the largest and oldest coal burning plants. The emi ssion reductions from the Healthy Air Act come in two phases. The first phase re quires reductions in the 2009/ 2010 timeframe, and compared to a 2002 emissions baseline, reduce NO

x emissions by almost 70%, SO 2 emissions by 80% and mercury emissions by 80%.

The second phase of emission control occurs in the 2012/2013 timeframe. At full implementation

the HAA will reduce NO

x emissions by approximately 75 percent from 2002 levels, SO 2 emissions will be reduced by approximately 85 percent from 2002 levels, and mercury emissions will be reduced by 90 percent.

Table 8-2: Annual Maryland Healthy Ai r Act NOx Emissions Reductions (TPY):

Unit 2002

Emissions Uncontrolled

2009

Emissions 2009

HAA Caps 2009 HAA

Emission

Reductions 2009 HAA

Emission

Reduction % 2012

HAA Caps 2009

Uncontrolled

Emissions - 2012 HAA Cap 2012 HAA

Emission

Reduction %

Brandon

Shores 1 6329 7558 2927 4631 61.27 2414 5144 68.06

Brandon

Shores 2 6034 7206 3055 4151 57.60 2519 4687 65.04

Wagner 2 2232 2666 673 1993 74.76 555 2111 79.18

Wagner 3 1718 2052 1352 700 34.11 1115 937 45.66

Crane 1 6245 7458 832 6626 88.84 686 6772 90.80

Crane 2 4285 5117 894 4223 82.53 737 4380 85.60

TOTALS 26843 32057 9733 22324 69.64 8026 24031 74.96

Baltimore Serious Area 8-Hour Ozone SIP Page 64Table 8-3: Ozone Season Maryland Heal thy Air Act NOx Emissions Reductions*

Unit (a) 2002

Emissions (Ozone

Season Day) (b) 2002

Emissions (Ozone

Season = 153 Days) (c)

Uncontrolled

2009

Emissions (Ozone Season Day) (d)

Uncontrolled

2009

Emissions (Ozone

Season = 153 Days) (e) 2009

HAA Caps (Ozone

Season = 153 Days) (f) 2009

HAA

Emission

Reductions (Ozone Season) (g) 2009

HAA

Reductions (Ozone Season Day) (h) 2012 HAA Caps (Ozone

Season = 153 Days) (i) 2009

Uncontrolled

Emissions -

2012 HAA Cap (Ozone Season) (j) 2009

Uncontrolled

Emissions -

2012 HAA Cap (Tons

Per Ozone Season day)

Brandon

Shores 1 9.68 1481.04 11.56 1768.68 1363 405.68 2.65 1124 644.68 4.21

Brandon

Shores 2 7.60 1162.80 9.08 1389.24 1449 -59.76 -0.39 1195 194.24 1.27
Wagner 2 6.88 1052.64 8.21 1256.13 278 978.13 6.39 229 1027.13 6.71
Wagner 3 3.28 501.84 3.91 598.23 583 15.23 0.10 481 117.23 0.77

Crane 1 11.86 1814.58 14.16 2166.48 345 1821.48 11.91 284 1882.48 12.30

Crane 2 10.56 1615.68 12.61 1929.33 385 1544.33 10.09 317 1612.33 10.54

TOTALS 49.86 7628.58 59.53 9108.09 4403 4705 30.75 3630 5478 36

*All emissions are meas ured in short tons.



### 8.2.2 Portable Fuel Containe rs Rule: Phase I

This measure introduces performance standards for portable fuel containers and spouts. The

standards are intended to reduce emissions from stor age, transport and refueling activities. The rule

also included administrative and labeling requirements. Compliant containers must have the following: only one opening for both pouring and filli ng, an automatic shut-off to prevent overfill, an automatic sealing mechanism when not dispensing fuel, specified fuel flow rates, and permeation

rates and warranties.



### Source Type Affected

This measures affects any person or entity se lling, supplying or manu facturing portable fuel containers, except containers with a capacity of less than or equal to one quart, rapid refueling devices with capacities greater than or equal to four gallons, safe ty cans and portable marine fuel tanks operating with outboard motors, and product s resulting in cumulative VOC emissions below those of a representative container or spout.



### Control Strategy

Maryland adopted phase I of the Ozone Transpor t Commission (OTC) Model Rule for Portable Fuel Containers in January 2002. The rule appl ies to all counties in the nonattainment area. Reductions from this rule increase annually beginn ing with implementation in the State of Maryland on January 1, 2004.

Baltimore Serious Area 8-Hour Ozone SIP Page 65

### Projected Reductions

VOC Emission Reductions for 2008 (TPD): 6.71 VOC Emission Reductions for 2011 (TPD): 8.31 VOC Emission Reductions for 2012 (TPD): 8.35



### Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 75% after full implementation after 10 years. Implementation began in 2004.



### References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport Commission Model Rules”, March 31, 2001.



### 8.2.3 Architectural and Industrial Mainte nance Coat ings Rule

This rule requires manufacturers to reformulate various types of coatings to meet VOC content limits. Affected products include architectural coatings, traffic markings, high-performance maintenance coatings and other special-purpose coa tings. It uses more stringent VOC content limits than the existing federal consumer products rule.



### Source Type Affected

The measure affects all manufact urers of affected coatings.



### Control Strategy

Maryland adopted this ru le on March 29, 2004. The rule applies to all counties in the nonattainment area. Compliance with this rule was required as of January 1, 2004.

The VOC content limits in this rule are based on a Suggested Control Measure (SCM) adopted by the California Air Resources Board (CARB) and a National Association of Clean Air Agencies (NACAA) model rule or OTC coatings. Manufacturers are expected to comply with this rule using primarily EPA Test Method 24.



### Projected Reductions

VOC Emission Reductions for 2008 (TPD): 6.03

Baltimore Serious Area 8-Hour Ozone SIP Page 66VOC Emission Reductions for 2011 (TPD): 6.19 VOC Emission Reductions for 2012 (TPD): 6.19



### Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 31 percent, based on Pechan (2001).



### References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport Commission Model Rules”, March 31, 2001.



### 8.2.4 Consumer Products Rule: Phase 1

Phase I of the Consumer Products Rule required reformulation of approximately 80 types of consumer products to reduce their VOC content. It uses more stringent VOC content limits than the existing federal consumer products rule. The rule also contains requirements for labeling and reporting.



### Source Type Affected

Manufacturers of various specialty chemicals named in the rule, such as aerosol adhesives, floor wax strippers, dry cleaning fluids and general purpose cleaners



### Control Strategy

Phase I of the Ozone Transport Commission Mode l Rule for Reformulated Consumer Products

became effective in the State of Maryland on August 18, 2003.

Manufacturers are expected to demonstrate complian ce with the rule primarily through a California Air Resources Board test method. If complying with the VOC contents becomes difficult, flexibility options are provided.



### Projected Reductions

VOC Emission Reductions for 2008 (TPD): 3.70 VOC Emission Reductions for 2011 (TPD): 3.77 VOC Emission Reductions for 2012 (TPD): 3.79

Baltimore Serious Area 8-Hour Ozone SIP Page 67

### Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 14.2 percent, based on Pechan (2001).



### References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport Commission Model Rules”, March 31, 2001.



### 8.2.5 Industrial Adhesives and Sealants Rule

This rule establishes VOC content limitations for industrial and commercial application of solventbased adhesives and sealants. Controls will cover adhesives, sealants, adhesive primers, sealer primers, adhesive application to substrates, and aerosol adhesives. VOC content limits are similar to those contained in the CARB Reasonably Av ailable Control Technol ogy (RACT) or Best Available Control Technology (BACT) document fo r adhesives and sealants (Dec. 1998).



### Source Type Affected

Manufacturers and distributors of indu strial adhesives and sealants



### Control Strategy

The State of Maryland will adopt the Ozone Transport Commission (OTC) Model Rule for

Industrial Adhesives and Sealants in time such that the effective date of emissions reductions occurs no later than May 1, 2009.



### Projected Reductions

VOC Emission Reductions for 2008 (TPD): 0.00 VOC Emission Reductions for 2011 (TPD): 2.63 VOC Emission Reductions for 2012 (TPD): 2.64



### Emission Benefit Calculations

Emission benefits are based on a 64 percent reduction in emissions of VOC from the baseline. Further details are available in OTC (2006).

Baltimore Serious Area 8-Hour Ozone SIP Page 68

### References

OTC 2006. Identification and Evaluation of Candidat e Control Measures: Draft Technical Support Document. Prepared by MACTEC Federal Program s, Inc., Herndon, Virginia for the Ozone Transport Commission. August 4, 2006.



### 8.2.6 Portable Fuel Containe rs Rule: Phase II

This measure expands existing performance standards for portable gasoline containers and spouts to

kerosene containers. The standards are intended to reduce emi ssions from storage, transport and refueling activities. The rule also includes ad ministrative and labeling requirements. Compliant containers must have the following: only one op ening for both pouring and filling; an automatic shut-off to prevent overfill; an automatic s ealing mechanism when not dispensing fuel; and specified fuel flow rates, pe rmeation rates and warranties.



### Source Type Affected

This measure affects any person or entity selling, supplying or manufacturing portable fuel containers, except containers with a capacity of less than or equal to one quart, rapid refueling devices with capacities greater than or equal to four gallons, safe ty cans and portable marine fuel tanks operating with outboard motors, and product s resulting in cumulative VOC emissions below those of a representative container or spout.



### Control Strategy

The State of Maryland has adopted the Ozone Transport Commission (OTC) Model Rule for

Portable Fuel Containers Phase II in time such that the effective date of emi ssions reductions occurs no later than May 1, 2008.



### Projected Reductions

VOC Emission Reductions for 2008 (TPD): 0.00 VOC Emission Reductions for 2011 (TPD): 0.60 VOC Emission Reductions for 2012 (TPD): 0.60



### Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 58% after full implementation after 10 years. Implementation began in 2004. In 2008, the emission reduction factor is 0.00%. In 2009, the emission reduction factor is 5.8%. Further details are available in OTC Technical Support Document (2006).

Baltimore Serious Area 8-Hour Ozone SIP Page 69

### References

[OTC 2006. Identification and Evaluation of Candidate Control Measures: Draft Technical Support Document. Prepared by MACTEC Federal Program s, Inc., Herndon, Virginia for the Ozone Transport Commission. August 4, 2006]



### 8.2.7 Consumer Products Rule: Phase II

Phase II of the Consumer Products Rule involv es adopting the CARB 7/20/05 Amendments which set new or revise existing limits on 13 consumer product categories. It uses more stringent VOC content limits than the existing fe deral consumer products rule. The rule also contains requirements for labeling and reporting.



### Source Type Affected

Manufacturers of various specialty chemicals named in the rule, such as aerosol adhesives, floor wax strippers, dry cleaning fluids and general purpose cleaners



### Control Strategy

The State of Maryland will adopt the Ozone Transport Commission (OTC) Model Rule for

Consumer Products Phase II in time such that the effective date of emissions reductions occurs no later than May 1, 2008.



### Projected Reductions

VOC Emission Reductions for 2008 (TPD): 0.00 VOC Emission Reductions for 2011 (TPD): 0.46 VOC Emission Reductions for 2012 (TPD): 0.46



### Emission Benefit Calculations

Emission reductions are based on an additional 2 percent reduction in emissions of VOC from the

baseline. Further details are available in OTC Technical Support Document (2006).



### References

[OTC 2006. Identification and Evaluation of Candidate Control Measures: Draft Technical Support Document. Prepared by MACTEC Federal Program s, Inc., Herndon, Virginia for the Ozone Transport Commission. August 4, 2006]

Baltimore Serious Area 8-Hour Ozone SIP Page 70

### Rule Phase In

The following rules have a phase in period for the Baltimore Nonattainment Area and give the region phased-in emissions benefits:

Area Sources:

 Additional phase in of reductions from Federal Locomotives Rule

 Federal Rule related to On-Board Refueli ng/Vapor Recovery for LD Trucks (2004)

Nonroad Sources:

 Federal 2004 Nonroad Heavy Duty Diesel Rule (negligible benefits by 2009)



### 8.3 VOLUNTARY AND INNOVATIVE MEASURES

EPA’s voluntary measures policy, “Guidance on In corporating Voluntary Mobile Source Emission Reduction Programs in State Implementation Plan s,” establishes criter ia under which emission reductions from voluntary programs are creditable in a SIP. This pol icy permits states to develop and implement innovative programs that partner with lo cal jurisdictions, bus inesses and private citizens to implement emission-reducing behaviors at the local level.

Inclusion of the programs below in the “Control Measures” portion of this attainment plan is not intended to create an enforceable commitment by MDE or the State of Maryland to implement the programs or to achieve any specific emission reducti ons projected as a result of implementation of the programs, and neither MDE nor the State makes any such commitment. In addition, MDE does not rely on any emission reductions projected as a result of impl ementation of these programs to

demonstrate attainment. While the emission reducti ons from these programs could be substantial and could lead to significant regi onal air quality benefits , actual air quality be nefits are uncertain. Consequently, projected emission re ductions from these programs are not included in the emission inventory, the attainment modeling, the reasonable further progress calculati on or any other area of the SIP where specific projected emission reductions are identified.



### 8.3.1 Regional Forest Canopy Program: Co nservation, Restoration, and Expansion

Expanded tree canopy cover is an innovative voluntary measure proposed to improve the air quality in the Baltimore region. Trees reduce ground-level ozone concentrations by the following means:

1) Reducing air temperatures and reducing energy used for cooling, and 2) Directly removing ozone and NOx from the air.

Modeling has clearly shown that trees reduce ozone levels. In addition, trees in an urban setting have far-reaching water quality habits (e.g. decreasi ng storm water runoff) and societal benefits. To

Baltimore Serious Area 8-Hour Ozone SIP Page 71achieve a reduction in ground-level ozone under a tree canopy program, it is necessary to preserve the current canopy and plant and maintain a significant number of new trees.

The current Baltimore region tree canopy is com posed of mixed native hardwoods and urban plantings. On average these species require 30 years to mature, so the short-te rm benefits of a tree program are not substantial yet the long-term benef its are still significant. To achieve area-wide canopy expansion requires long-term commitment by the state and loca l agencies, volunteer organizations, and private landowners.

Achieving maximum benefits from this type of program requires th e following types of

commitments:

1) Initiate and/or enhance effort s to support, monitor, evaluate, a nd report preservation of existing urban tree canopy and canopy expansion efforts.

2) Implement urban forestry programs to affect air temperature, surface temperature, and wind speed and reduce VOC emissions. Programs include sustained tree planting, reduced mowing, and lawn maintenance. Also included are tree plan ting initiatives for streets, parking lots, and government-owned facilities.

3) Provide assistance and outreach to landowners and businesses to encour age tree conservation, planting and maintenance.

4) Initiate development of a comprehensive plan that establishes a detail ed regional baseline and outline strategies to preserve, enhance, increase, protect, measure, and track overall forest canopy change in the region over the next 20 years.

5) Monitor these activities and report annually.

Current Programs

While Maryland has over 40 state programs that suppor t, encourage or require the planting of trees, five of these tools are of special importa nce for implementation at the local level:

 Forest Conservation Act

 Critical Areas Act

 Mitigation Requirements

 Comprehensive Plans Requirements

 Urban and Community Forestry Programs

Special attention will be paid to how these programs can be coordi nated with new local ordinances

and initiatives to enhance their use in tree protection, canopy preser vation and expansion to achieve regional air quality (SIP) goals.

Baltimore Serious Area 8-Hour Ozone SIP Page 72Control Strategy

Coordination

This type of measure requires coll aboration among the various state a nd local agencies that support, encourage, and require tree pl anting. Currently, numerous agen cies bear responsibility for implementing and tracking tree planting related activ ities, but there is no ce ntralized repository for this information. The state can be encouraged to commit to create a new program to coordinate tree-planting programs. This program would be housed within the Department of Natural Resources’ Maryland Forest Service and would be charged with management of a tree planting database and promoting outreach efforts to la ndowners and stakeholder groups. This database would be used to compile baseline data, includi ng maps and descriptive information about each nonattainment county in the planni ng area; information about tr ee plantings, including new and replacement trees; and canopy change.

Canopy Preservation

The state coordinating office will work with local governments to fully implement key programs. Particular attention will be give n to those who set conservation, tree planting and canopy goals and

reforestation standards for local authorities to track during the devel opment process. Local authorities will be encouraged to do the following:

1) Track efforts aimed at pr eserving existing canopy,

2) Provide the resource agency with data re garding preservation efforts including new ordinances and development tools, and

3) Work with federal, state and private landowners to identify development mitigation areas.

The effectiveness of canopy preservation effort s could then be periodically evaluated.

Public Outreach

The region would need to commit to undertake a pub lic outreach program de signed to promote tree planting. This need could be addressed build ing upon the Chesapeake Bay Agreement Forestry Directive and local land use gui delines. Past initiatives under Maryland programs have included financial incentives to private landowners for planting trees. The Baltimore Metropolitan Council, state government agencies, and local government s could work with vol unteer tree planting organizations, landowners, and stakeholder groups to support tree planting and conduct educational outreach regarding documenting and reporting vol untary planting and maintenance programs.

Canopy Goals

Each jurisdiction in the nonattainment area could be encouraged to adopt a tree canopy goal. Local and state governments could evaluate refore station of public lands to meet canopy goals. Governments could collaborate with privat e citizens to address canopy goals.

Baltimore Serious Area 8-Hour Ozone SIP Page 73Strategic Tree Planting

Biogenic volatile organic compounds (BVOCs), an ozone precursor, are emitted by some tree species as a natural process. Expanding the canopy primarily w ith trees whose BVOC emissions are lower will have a significant impact on overa ll emissions; planting lower BVOC trees is a key approach to reducing BVOCs. A right tree – right place strategy wi ll need to be encouraged to garner the maximum benefits from this type of program.



### 8.3.2 Clean Air Teleworking Initiative

The State of Maryland, on occasion experiences unh ealthful levels of the air pollutants, groundlevel ozone and fine particles. Wh en air quality elevates to unhea lthful levels, it poses significant health and economic impacts on Maryland resident s. Since 1990, when the modern-day Clean Air Act was passed, to address air pollution concerns and requirements Maryland has implemented over 100 pollution control programs aff ecting industries, small businesses, mobile sources, and the general public. These programs have prevented n early 800 tons of ozone-forming pollutants from entering the air each day. In order to inform the public abou t daily air pollution levels, the Maryland Department of the Environment has been accurately forecasting and reporting air quality

information since 1993.

Traffic congestion is a major problem in Maryla nd’s metropolitan areas where individuals waste hundreds of hours every year stuck in traffic due to congested roadways. Numerous studies have demonstrated that telework (or “telecommuting” ) programs are advantageous in addressing major environmental, transportation, productivity, quality of life, and employment issues.

Reducing the number of road miles traveled by commuters decreases air polluting vehicle emissions, gasoline consumption, traffic congesti on, and highway maintenance costs for Maryland residents. Telework provides economic and or ganizational benefits to employers, resulting in increased employee productivity, enhanced empl oyee morale, improved employee recruitment and retention, reduced office space and parking needs, reduced stress, increased job satisfaction, decreased absenteeism costs, an expanded labor pool, and increased fl exibility in meeting the needs of state residents. Maryland, as a major employer, has recognized its leadersh ip role in developing substantive programs, such as teleworking, to reduce commuter road miles traveled by state employees and enhance productivity.

Objective

The objectives of the Clean Air Telework initiative are as follows: to 1) in crease the number of employees who telework in the Baltimore/Washi ngton metropolitan area and, 2) increase the frequency of employees who telework by linki ng teleworking with air quality; specifically, encouraging employees to telework on days when air quality is at its worst.

The decision to encourage teleworking on bad air days will be guided by the Air Quality Index (AQI) , a nationwide, color-coded scale used by the U.S. Environmental Protection Agency to communicate air quality to the public . “Code Orange” is considered unhealthy for sensitive groups (children, the elderly, an d those with heart or lung conditi ons) and “Code Red” is considered

Baltimore Serious Area 8-Hour Ozone SIP Page 74unhealthy for everyone . “Code Purple,” which occurs very infr equently in the regi on, is considered very unhealthy for everyone . Clean Air Partners, a nonprofit organization that encourages voluntary action to improve air qual ity, provides a three-day air quality forecast to local employers through its Air Quality Action Da y (AQAD) program. A copy of Cl ean Air Partners’ Air Quality Action Guide, which incorporated the AQI, is show n in Figure 8-1. Teleworking is encouraged at Code Orange and above.

Figure 8-1: Air Quality Action Guide

Baltimore Serious Area 8-Hour Ozone SIP Page 75Approach

Encouraging employees to telework on poor air qu ality days may result in numerous employees and managers working at home for several consecutive days. This will require advanced preparation by employees, managers, and office coworkers to ensu re transparency and a consistent level of productivity. While this may initi ally seem challenging from a management perspective, the added benefit is that employees and managers will b ecome adept at teleworki ng concurrently, thereby increasing the organization’s busine ss continuity capabilities in the event of an actual emergency.

Implementation

The following steps are recommended to help bu sinesses successfully la unch their “Clean Air Teleworking” initiative:

Get Input from Managers – Businesses should get input fr om several managers to identify potential barriers and solutions to the “Clean Air Teleworking” initiative. This could be accomplished by conducting one-on-one interviews with 4-5 managers or a small discussion group. The input from the managers could then be used to shape the development and implementation of the program, starting with a small pilot involving a couple of managers supportive of teleworking

and the “Clean Air Teleworking” initiative.

Become an AQAD Participant – Businesses should become Air Quality Action Days participants so they can receive the Clean Ai r Partners’ three-day air quality forecast, which can then be distributed by email to employees when a poor air quality day (Code Orange, Code Red, or Code Purple) is forecasted.

Conduct Pilot – Businesses should select managers and em ployees who will be participating in the “Clean Air Teleworking” pilot and launch th e program over the summer of 2007. Conduct an orientation/training session for pa rticipants prior to implementation and follow up with brief phone interviews after a multi-day episode to determine if there were any problems. Prepare a summary report at the end of the pilot and sh are with management and employees.

Implement Tracking System – Ask participants to track thei r participation using a Web-based system that tracks reductions in vehicle em issions, particularly NOx, VOC, CO, and CO 2 , resulting from teleworking. An example is of such a Web-based system is TeleTrips ( https://www.secureteletrips.com/ ). The information collected can be repor ted at the individual, department/team, and organizational level and provides continuous feedback on how the program and participants are improving air quality. Furthermore, businesses should consider recogni zing individuals or teams/departments with the highest level of participation and emissions reductions.

Communicate – Businesses should send out several ema il communications to all their employees; including, prior to the launch of the “Clean Air Teleworking” pilot, during implementation, and at the conclusion of the pilot. The emails should explain pilot program objectives and keep employees informed. Furthermore, employees not participati ng in the pilot should also receive the air quality forecast for Code Orange, Code Red, and Code Pu rple days and be encouraged to take other voluntary measures at work and at home (e.g., carpooling, eating in th e cafeteria rath er than going out for lunch, refueling after dusk, and postponing mowing lawns.)

Baltimore Serious Area 8-Hour Ozone SIP Page 76Expand Program – Businesses should share the results of the pilot with all staff and encourage additional managers and employees to participat e in the program in future years. Repeat orientation/training for new part icipants prior to implementati on, conduct phone or on-line survey with participants during implementation, track par ticipation and results fo r all participants, and recognize or reward individuals, teams, and departme nts with the highest leve l of participation and

emissions reductions.

An initial pilot program will be initiated throughout the Maryland Department of the Environment (MDE). It will encourage telecommuting opportuni ties for qualified personnel when air quality is forecasted to be in the Code Orange (Unhealt hy for Sensitive Groups) range or above. The MDE pilot program will launch in May 2007.

Additional strategies will be employed to enco urage a wider participation in the Clean Air Teleworking Initiative. Examples include these:

 Promote participation among a ll Maryland State agencies;

 Collaborate with the Baltimore Metropolitan Council and the Metr opolitan Washington Council of Governments to promote the initiat ive throughout the local jurisdictions; Clean

Air Partners will serve as the wo rk group to implement the program;

 Develop a strategic plan for local governments and federal agencies;

 Encourage participation within the private sector;

 Develop a merit-based recognition/awar d system for participation; and

 Promote program throughout the Ozone Transport Commission.

A timeline of the implementation steps is shown in Table 8-4.

Table 8-4: Clean Air Teleworking Time Line

Task/Step Apr-07 May-07 Jun-07 Jul-07 Aug-07 Sep-07 Oct-07 Nov-07 Dec-07

1.0 Telework Toolkit

1.1 Research materials x

1.2 Compile toolkit X

1.3 Integrate with Clean Air Partners web site x

2.0 Clean Air Teleworking Pilot

2.1 Recruit organization(s) x x

2.2 Develop/implement communications plan x x

2.3 Conduct interviews/focus groups with managers x x

2.4 Identify participants (e.g., specific units/departments) x x

2.5 Conduct orientation x

2.6 Launch and conduct pilot x x X x

2.6 Conduct "spot" phone interviews/email surveys x x X x

2.7 Implement tracking system x x x X x

2.8 Track and report results x x x X x x x

2.9 Expand program x x

Baltimore Serious Area 8-Hour Ozone SIP Page 77The Clean Air Teleworking Initiative will be deve loped in close coordination with other entities who have a role in telework implementati on: Commuter Connections, Maryland Telework Partnership with Employers, Telework!Va, and the newly created Office of Telework Promotion

and Broadband Assistance in VA.

Supporting Material

Clean Air Partners will compile and customize a telework tool kit that would be posted on the organization’s Web site. The tool kit would provide on-line resources to he lp employers start or expand a telework program, including the use of “episodic” teleworking on poor air quality days.

University of Maryland Study of Ai r Quality Benefits of Teleworking

To simulate the effects of a very aggressive telework initiative, the University of Maryland modeled the air quality change that would re sult if 40% of all light duty vehicles were taken off the road in

the nonattainment areas of Baltimor e, Philadelphia, and Washington, D.C. on 38 high ozone days in the summer of 2002. Changes in emissions were im plemented as a flat 40% reduction in vehicle miles traveled in each county of th e three nonattainment areas. The effects of implementing such a program were modeled using version 4.4 of the CMAQ model. The model results showed that across the three nonattainment areas, an aggres sive telework program has the potential for considerable benefit to air qualit y, with fairly uniform benefits acr oss all three areas. The highest monitors in the Philadelphia and Washington, D.C. areas would see the largest benefits from this program, suggesting it is reaching the most tr oublesome monitors on the worst ozone days. Benefits in all three nonattainment areas averaged more than 2 ppbv ozone.



### 8.3.3 High Electricity Demand Day (HEDD) Initiative

Emissions from Electric Generating Units (E GUs) are higher on high electric demand days (HEDD), resulting in poorer air qua lity. High electrical demand da y operation of EGUs generally

has not been addressed under ex isting air quality control requirements, and the HEDD units are called into service on the very hot days of summe r and on very cold days of winter when air pollution levels typically reach their peaks. HE DD units include gasoline and diesel combustion turbines as well as residual oil burning units.

The Ozone Transport Commission (OTC) has been meeting with state environmental and utility regulators, EPA staff, EGU owners and operators and the independe nt regional systems operators. The purpose of these meetings has been to asse ss emissions associated with HEDD during the

ozone season and to address excess NOx emi ssions on HEDDs. The OTC has found that NOx emissions are much higher on a high electrical demand day than on a typical summer day. The potential exists to reduce HEDD emissions by appr oximately 25 percent in the short term through the application of known control technologies.

On March 2, 2007, the OTC states and the District of Columbia agreed to a Memorandum of Understanding (MOU) committing to reductions fr om the HEDD source sector. The MOU includes specific targets for a group of six states to achie ve reductions in NOx emissions associated with HEDD units on high electrical demand days during th e ozone season. These states agreed to achieve these reductions beginning with the 2009 ozone season or as soon as feasible thereafter, but no later

Baltimore Serious Area 8-Hour Ozone SIP Page 78than 2012. The OTC states not included in the MOU, including Virginia and the District of Columbia, agreed to continue to review the HEDD program and seek reductions where possible, but they do not have a formal emissions reduction target in the MOU. The OTC MOU is included in Appendix C.



### 8.3.4 Emission Reductions from Transportation Measures

Substantial funding commitments have come from State and local agencies and private employers for promotion of strategies to reduce mobile emissions. Examples of these measures include idling reduction, ridesharing, teleworking, transit use, vehicle replacement and retrofit measures, and bicycle and pedestrian programs. These fundi ng commitments produce reductions in emissions, some of which are being reflect ed in transportation plans.

Although these programs are workin g to reduce emissions from mobile sources and play an important role in the transportati on sector’s contribution to cleaner air, neither MDE, nor the State

intends their inclusion in this SIP to constitu te enforceable commitments to implement these programs or to achieve any emission reductions projected as a result of implementing these programs, and neither MDE, nor the State makes a ny such commitment. These directionally correct programs will continue to be used outside of the SIP for transportation planning purposes as needed.

The following are descriptions of selected emissi on reduction strategies in the Baltimore region.

Clean and Efficient Strategies With the support of both state and federal funds, MDE has worked with several local governments to introduce new technologies designed to reduce emissions of their in -use fleets. The MDE worked successfully with Baltimore City to retr ofit 108 trash haulers, 23 du mp trucks and 49 firetrucks with diesel oxidation catal ysts (DOCs) and closed crankcas e ventilation filtration systems (CCVFSs). These systems help reduce PM emissions from both the exhaust systems and from the engine. MDE is also supporting the installati on of two “Quick Charge” recharging units in Baltimore City. These chargers allow the city to r echarge its fleet of electr ic vehicles in under an hour, compared with the previous time of 6 hours. This will encour age the City to purchase more

electric vehicles for its downtown fleet. MDE is also working with Johns Hopkins University to

retrofit its fleet of 10 diesel ve hicles with DOCs and CCVFSs as we ll as install a “Quick Charger” unit at its main campus. MDE has worked with Ho ward County to successfully retrofit 25 of their transit buses with DOCs, CCVFSs, a nd International Clean diesel kits . This project is reducing both particulate matter and NOx emissions. MDE has also worked with Anne Arundel County Public Schools to retrofit their fleet of 51 diesel-power ed school buses with DOCs and CCVFSs. Finally, MDE is in the process of retrofitting 10 fire trucks for the City of Annapolis. These vehicles will be

retrofitted with DOCs and CCVFSs.

Traffic Flow Improvements (CHART) The Coordinated Highways Action Response Team (CHART) program, operated by MDOT and Maryland State Police, focuses its operations on non-recurring congestion such as backups caused by accidents. The Statewide Operations Center, and the three satellite Operations Centers in the region, survey the state’s roadways to quickly identify incidents through the use of Intelligent Transportation System (ITS) technology. CHART also includes traffic patrols, which have been operating during peak periods on many of the stat e highways in the region since the early 1990s.

Baltimore Serious Area 8-Hour Ozone SIP Page 79Based on 2005 data, it has been estimated that CHART operations saved 37.3 million vehicle hours of delay statewide including 21.3 million in the Ba ltimore region; saved 6.3 million gallons of fuel;

and reduced overall mobile source emissions.

Truck Stop Electrification (TSE) Truck Stop Electrification allows tr uckers to shut down their engine and obtain elec tric power and

“creature comforts” while resting. TSEs reduce diesel emissions and reduce noise and wear and tear on the truck engine. IdleAire tr uck stops provide electricity (1 10V AC), cab heating/cooling, television and movies, telephone a nd Internet access. IdleAire ha s over 100 locations nationally, including three in Maryland. The Maryland sites are located in Baltimore and Jessup, both in the Baltimore region. An additional TSE has been pu t in place in Cecil C ounty at I-95 and MD 279.

Electronic Toll Collection The Maryland Transportation Authority (MDTA) commenced operation of its electronic toll collection system, M-TAG, at th e authority’s th ree harbor crossing faci lities in 1999. By fall 2001, all toll facilities in the region were equipped wi th electronic toll collect ion equipment. As of January 2004, 45 percent of vehicles using MDTA f acilities used electronic toll tags. MDTA is a member of the E-Z Pass InterAgency Group, a coal ition of Northeast Toll Authorities. MDTA established reciprocity with the E-Z Pass system in 2001, enabling travelers in Maryland, as well as at most toll facilities in New York, New Jerse y, Delaware, Pennsylvania, Massachusetts, Virginia, and West Virginia to pay tolls using one electronic device.

Traffic Signal System Retiming SHA has instituted a program to review and retime its 1,200 traffic signals in the Baltimore region. The timing of each traffic signal system is revi ewed and updated every three years. In addition, systems in high profile corridors or corridors s ubject to significant traffic pattern change are evaluated on a more frequent schedule. This prog ram results in smoother traffic flow as well as reduced emissions resulting from idling vehicles. Synchro software is used to develop new timing plans and to calculate benefits from the new timing plans. This progr am has resulted in the following average annual benefits for the Balt imore region: 11.8 percen t reduction in network delay; 8.5 percent reduction in arterial delay; 8.7 percent reduction in arterial stops; and 1.9 percent reduction in fuel consumption.

Ride Share The Baltimore region’s original rideshare program began in 1974 as a joint effort of Baltimore City, the Regional Planning Council (now the Baltimor e Metropolitan Council), and MDOT. Efforts to encourage ridesharing were expanded to cove r the entire state in 1978 when the Maryland Ridesharing Office of the Maryland Transit Admi nistration (MTA) was established. Since it was formed, the MTA has enhanced and expanded its ac tivities to include both commuters and their employers. A continuing program administered by the MTA provides fu nding support to local

rideshare coordinators in order to strengthen ride matching and ri deshare-support services at the jurisdictional level. The BMC provi des ridesharing coordination serv ices for Baltimore and Carroll Counties. Local rideshare coordinators have provided ridesharing information that has helped in the development of more effective regional emission reduction strategies. They have also assisted employers and employees in identifying opportun ities for other Emission Reduction Strategies (ERSs) such as transit, flexib le work hours, and telecommuting.

Baltimore Serious Area 8-Hour Ozone SIP Page 80Maryland Commuter Tax Credit In January 2000, a tax credit went into effect stat ewide that allows employe rs to claim a 50% state tax credit, up to $52.50 per month, for providing tran sit benefits in the form of a subsidy to an employee. An employer may provide this benef it to an employee withou t tax consequences under the federal tax law. It is expected that the state tax credit will be even more attractive to employers as a benefit to offer employees than is the federa l law; the state benefit is a direct tax credit as opposed to an allowable business expense, the case of the federal program. This feature of the Maryland law also has the potential to encourage increased transit use by low and moderate-income employees. Under provisions of both the 1999 and 2000 Maryland laws, private non-profit organizations will also be able to participate in the program. Employers will be able to claim tax credits for providing transit passes and vouchers , guaranteed ride home, and parking cash-out programs. Similar to the IRS benefits, the Ma ryland Commuter Tax Benefit program does not provide financial assistance to carpoolers. Inform ation is also provided online and employers are able to register over the Internet to participate in the program.

Clean Commute Month The Baltimore Regional Transportation Board (BRTB) has teamed with state transportation and air quality agencies as well as private organizati ons to promote Clean Commute Week. The program was expanded in 2003 and is now known as Clean Commute Month (CCM). During CCM, residents of the Baltimore region ar e asked to try an alternative to driving alone for at least one day during May. Clean Commute Month 2006 promotion began in late April, with a number of outreach events throughout the region. Even ts continued through May, and in cluded a Bike to Work Day. Participation in Bike to Work Day has increased substantially in recent years, and many local businesses and organizations donate prizes for registered participan ts. Bike to Work Day, a true region-wide initiative, fe atures rallies in Annapol is; Baltimore City; and Baltimore, Carroll, Harford and Howard Counties. With a grant from MDE, CCM 2006 also included Clean Car Clinics, where certified technicians provided free car inspections to the public.

Telework Partnership with Employers BMC and MWCOG participate in a bi-regional program to assist large and small employers to establish home-based telecommuting programs for their employees. This program, known as the “Telework Partnership with Employers,” or “TPE,” is funded by MDOT. In addition to the traffic and emission reduction benefits of the TPE pr ogram, the TPE program assists in perfecting marketing, outreach procedures, and administrative methods that may be used in other alternate commute programs. Since its kickoff in Octobe r 1999, over 25 large and small private sector employers as well as two nonprofit organizations ha ve been recruited to participate in the biregional TPE program. In the Baltimore region, eight employers have taken advantage of the TPE and several others are currently considering the program. Employe rs are recruited through outreach events. Employers that have signed up to particip ate in year-long pilot programs choose from a list of qualified regional and national telecommuting consultants whose se rvices are paid for by MDOT.

Transit Oriented Development The transit oriented development (TOD) in Owings Mills in Baltimore County is an example of long-range planning which has resulted in the loca tion of high-density co mmercial and residential development within close proximity of the Baltimo re subway system’s Owings Mills station and the transit bus stop. Similar developments are planne d or underway in other parts of the Baltimore region.

Baltimore Serious Area 8-Hour Ozone SIP Page 81Bicycle/Pedestrian Enhancements Bicycle commuting can provide an a lternate travel mode to shorter car trips which pollute more per mile than longer trips. Both bicycle and pedestrian modes of travel to work, when used alone or in combination with transit, can help to reduce traffic congestion by ta king cars off the road. Bicycling and walking lend themselves to smart growth land uses such as transit oriented and mixed use developments. They also work well with travel demand management and “live near your work” programs. The physical activity invo lved in cycling and walking also provide health benefits of exercise which is important considering the cu rrent problem of obesity in the United States.

Through MDOT, the Maryland State Highway Admini stration (SHA) has worked to engineer and implement new and improved bicycle and pedestrian facilities, and SHA has implemented programs to encourage walking. SHA has a stated goal of providing 200 miles of marked bicycle lanes throughout Maryland by December 31, 2006. In addition, SHA has developed the Maryland SHA Bicycle and Pedestrian Guidelines to provide general guidance on de sign. The state has a policy of considering sidewalks to reinforce pedestrian safety and promote pedestrian access adjacent to roadways under construction or reconstruction. Special e fforts are made to fa cilitate pedestrian

travel near schools.

In addition, bicycle safety and bi cycle travel in general are bei ng improved through the construction of wider shoulders and/or curb lanes to separate motor vehicles from the cyclists. In regard to bicycle or pedestrian travel in controlled access roadway corridors, a separation almost always exists between the bike or pedest rian travel and the motor vehicles . It is only along roadways where the vehicle speeds or mix of the travel modes coul d result in serious accidents that sidewalks and bicycle travel not promoted.

Beginning in 2005 improvements to existing sidewa lks or new sidewalk construction has taken place along many roadways in the Baltimore re gion. These roads include MD 2, MD 435, MD 26, MD 134, MD 140, MD 7, MD 150, MD 542 and MD 648. In addition, since 2005, separate bike or pedestrian paths have been constructed to faci litate recreation, pede strian shopping, or schoolrelated travel. In the Baltimore region these in clude the Maryland and Pennsylvania Heritage trail extension, Broken Land Parkway Path way, Centennial Access Trail, Wakefield Community Trail,

Broadneck Peninsula Trail and the South Shore Trail.

Other recent bike/pedestrian en hancements include the following :

 Bike to Work Day expansion in the Baltimore region

 Quantification of benefits of bi cycling as far as reductions in air pollutants (per Appendix G:

“Recreation and Reduced Auto Use Benefits ,” of the National Cooperative Highway Research Program (NCHRP) report Guidelines for Analysis of Investments in Bicycle

Facilities )

 Status of regional efforts such as BMC’s Action Plan 2001 and statewide efforts such as

MDOT’s Twenty Year Bicycle and Pede strian Access Master Plan

.

 Street Smart campaign- MDOT

 Safe Routes to School- MD SHA

 MDOT’s “Safe Bicycling in Maryland”

 Complete Streets program

 Free water taxi service around Baltimore Harbor

 BMC’s “Bicycle Commuter Resourc e Guide for the Baltimore Region”

Baltimore Serious Area 8-Hour Ozone SIP Page 82MARC Station Parking Enhancements MARC commuter rail services have been enhanced through construc tion of additional parking at stations throughout the Baltimore region. A feasibil ity study is underway for structured parking (garage or parking deck) at Odenton Stati on for 2,500 spaces on the MTA owned property. In addition the Odenton MARC parking facilities were expanded by over 700 spaces; the facilities were opened in 2006. There are a total of 2,000 spaces at the location. Expansion of the Halethorpe MARC Station park-and-ride lot Phase I, is comple te with 428 parking spaces added. The scope of the work includes high level platforms, new sh elters, improved accessibility for persons with disabilities, lighting, and streetsc aping. Phase II, which includes a pedestrian bridge and high level platforms is in the project initiation stage. In September 2005, construction began on a parking lot expansion at the Martin State Ai rport MARC station, located on the Penn Line. It was completed in 2006. This expansion increased the number of parking spaces from 171 to 321.

Refurbishing MARC and other rail vehicles In order to insure the reliability, safety and comfort of MARC equipment, the rolling stock is periodically overhauled. These include 26 MARC car s that have been or are scheduled to be

refurbished between FY2005 and FY 2008. In additi on, 23 locomotives are in the process of being overhauled and retrofitted to meet cleaner, federa lly required TIER standa rds. This is an ongoing

effort that started in FY 2005 and is not expected to be completed until at least 2012.

MTA Bus Purchases The Maryland Transit Administration (MTA) makes annual purchases of buses to replace, expand or upgrade the fleet. Buses over 12 years old are replaced. This pur chase is made to prevent high

out-of-service rates and reduce break down and re pair problems. Bus replacements include new clean diesel as well as hybrid electric vehicles. The newer buses are much cleaner than the buses being replaced. In 2005, 125 buses were replaced ; in 2006, 105 buses were replaced; and in 2007, 100 buses were replaced.

Locally Operated Transit Systems (LOTS) MTA provides funding to small jurisdictions and rural area systems including Anne Arundel, Baltimore, Carroll, Harford and Howard C ounties. Regular small system buses and handicapped/senior ride vehicles are replaced, repaired, or expanded. The ridesharing program provides citizens with commute options. Funds are also used for outreach to companies in the counties to provide them with information on commuting options.

Smart Card Implementation Imple mentation of Smart Card technology and fare collection equipment for the Baltimore Metro, bus, light rail, commuter bus and lots is being pursued by MTA. Smart card allows for quicker and seamless travel between different transit systems. Passengers are able to pay for travel throughout the state with the swipe of a card. This makes tr ansit and high occupancy vehicle (HOV) travel

more convenient for the traveler.

Light Rail double tracking

Installation of the double track was opened between North Avenue and Hunt Valley in 2006. The double track will enhance operational flexibility by eliminating delays and improve headways and

service. The double track will make the service mo re attractive and thus increase HOV ridership.

Baltimore Serious Area 8-Hour Ozone SIP Page 83Port of Baltimore Initiatives In 2006, the Maryland Port Authority (MPA) partnere d with Port stakeholde rs to oversee various physical and operational improvements to terminal gates. The purpose of the improvements was to expedite inbound and outbound vehicle traffic. A net benefit of these projects was overall reductions in idling time for heavy-duty diesel trucks and othe r vehicles visiting the terminals, resulting in reduced emissions. Since November 2006, MPA uses Ultra Low Sulfur Diesel Fuel

blended with bio-diesel in all of its on -road as well as off-road diesel engines. This includes vehicles such as its cranes, fleet vehicles, stat ionary generators, fire pumps, and cargo handlingequipment. In the fall of 2006, MPA applied for an EPA grant to retrofit at least one ship-to-shore

crane and several RTG cranes with Diesel Oxid ation Catalysts. MPA understands that EPA will officially announce by the end of March 2007 that th ey will be awarded the grant. MPA annually

exceeds EPA's 75% fleet vehicle alternative fu el purchasing requirements. To do so, MPA purchases bi-fuel (ethanol/gas) fl eet vehicles. In addition, MPA pur chased a hybrid (electric/gas) fleet vehicle in 2006. MPA performs outreach to empl oyees on "ozone alert days" in order to reduce activities, such as vehicle fueling and combus tion engine usage, which contribute to ozone pollution.

Park and Ride Lots

The SHA and MdTA have built 43 lots in the Baltim ore region since the 1970's. This does not include Baltimore City, which builds its own pr ojects. The SHA has made substantial space additions to three Park and Ride lots in the Baltimore region and has built a 56-space new lot on Maryland Route 7. Other Park and Ride lots have been expanded or improved in the attainment areas adjacent to the Baltimore region as well as the Washington Metropolitan area. These lots serve to accommodate carpool based work trips into the Baltimore region. The benefits of the reduction in VMT and vehicle trips (VT) in th e Baltimore region provides for a reduction in regional congestion and vehicular emissions.

Landscaping and Reforestation Landscaping and reforestation can have a positive effect on wate r and air quality. In the Baltimore region reforestation and/or landscaping efforts have been m ade adjacent to the following roadway facilities since 2005: MD 2, MD 468, MD 665, MD 216, MD 100, US 40, I-695, I-83, and the MD

43 extension.

Additional Clean and Efficient Strategies Enacted or Under Development Charm City Circulator http://www.charmcitycirculator.com/

The Circulator consists of four routes that run seven days a week using hybrid buses. Service is free. Air quality benefit calcu lations from this service started in 2009. The Transit Vehicle Purchases Project most recently added hybrid-electric buses to the Charm City Circulator to extend service to Fort McHenry Nationa l Monument and Historic Shrine.

Hunt Valley Shuttle The Baltimore County Chamber of Commerce a nd the Hunt Valley Business Community are working to establish a bus shuttle between Hunt Valley and southern York County, PA, including the City of York.

Baltimore Serious Area 8-Hour Ozone SIP Page 84Kent Street Transit Plaza

The Kent Street Transit Plaza and Pedestrian Corr idor Project will expand bus ridership and safe access to the existing light rail system through design and construction of the Kent Street Plaza and Pedestrian Corridor from the Westport Li ght Rail Station to Annapolis Road.

MARC East Baltimore Station A new station is planned for east Baltimore City in 2015. There is a potential tie-in with Baltimore City’s proposed Greektown pedestrian and transit project.

Emergency Ride Home Program - proposed; the BRTB recommends moving forward with a program for the Baltimore region. (Note that th e Washington, DC area already has Guaranteed Ride Home (GRH) as part of Commuter Connections.)

Baltimore Collegetown Network (BCN) BCN operates a free bus service available to st udents registered at Goucher College, Towson University, Notre Dame of Maryland Universi ty, Loyola University Maryland, Johns Hopkins University, Maryland Institute College of Art, and Morgan State University. The Collegetown Shuttle, as it is known, is paid for by those institutions.

BWI Airport Low Emission Vehicles The Maryland Aviation Administration’s (MAA’s) fleet of ground vehicles is extensive and

consumes much fuel. To reduce the emissions asso ciated with its vehicle fleet, MAA was a pioneer in encouraging the use of Compressed Natural Gas (CNG) vehicles. CNG vehicles offer air quality benefits, because they produce fewer emi ssions than gasoline-powered engines.

U.S. Department of Housing and Urban Deve lopment (HUD) Sustainable Communities and Clean Fuels Program Grants Four federal grant programs were announced in August 2011: (1) clean fuel buses, (2) the Federal Transit Administration’s (FTA ) Transit Investments for Greenhouse Gas and Energy Reduction (TIGGER) III program; (3) the U.S. Department of Transportation’s (USDOT) Transportation Investment Generating Economic Recovery Program (TIGER) III program; and (4) the HUD/EPA/USDOT Sustainability Grant Program. BMC will support grant applicants in the Baltimore region. These grant program projects are expected to help reduce emissions from on-road

mobile sources.

US 40 Carbon Neutral Corridor MDOT and Cambridge Systematics consultants are developing a comp rehensive corridor vision that results in attaining smart growt h, conservation and climate change goals where the net emissions from the corridor are significantly reduced. The corridor study area goes from Baltimore City to

Aberdeen in Baltimore and Harford Counties.

Clean Technology and Commute Alternatives http://www.baltometro.org/trans portation-planning/transporta tion-improvement-program-2011-

2014 A variety of projects have been implemented in the Baltimore region since 2007. Examples include hybrid fleet vehicles; hybrid replacement buses; hybrid taxis; and retrofits of fire trucks, medics, and shuttle buses. The projects have been implem ented by private business, universities, and state and local governments.

Baltimore Serious Area 8-Hour Ozone SIP Page 85

## 9.0 REASONABLY AVAILABLE CONTROL MEASURE (RACM)

ANALYSIS

Section 172(c)(1) of the Clean Air Act requires state implementati on plans (SIPs) to include an analysis of Reasonably Available Control Measures (RACM). This an alysis is designed to ensure

that the Baltimore 8-hour Ozone Nonattainment Area is implementing all reasonably available

control measures in order to demonstrate attainment with the 8-hour ozone st andard on the earliest date possible. This chapter pres ents a summary of analyses conduc ted to determine whether the SIP includes all reasonably available control measures . Full details of the analysis are included in Appendix D.

The Maryland Department of the Environment (MDE ) has prepared this RACM analysis using two independently developed lists of potential control measures. The fi rst list consists of the RACM analysis performed for the Washington, DC Regi on’s 8-hour ozone SIP. The MDE worked very closely with all the DC region’ s jurisdictions in the developm ent of the DC Region’s RACM analysis. Understanding that the adjacent Wash ington, DC non-attainment region is both extremely similar to the metropolitan Baltimore region and wa s also undertaking their RACM analysis, MDE incorporated the Washington, DC RACM criteri a and analysis into this Baltimore SIP.

The Washington, DC RACM analysis included a seri es of regional calls ove r several months to review over 200 suggested measures from numerous s ources to create a master listing of measures. Each of over 200 measures was individually eval uated against establishe d RACM criteria (the criteria are explained below).

In addition to a careful review of the Washington, DC Region’s RA CM analysis, during the fall of 2006, the MDE also worked closely with the Bal timore Metropolitan Counc il (BMC) in developing a small list of potential transportation emission reducti on measures. This analysis yielded a list of 24 specific measures that could be implemented in the Baltimore Nonattainment Area for emission reduction purposes. Based on the criteria used fo r RACM, none of these 24 measures is to be considered RACM but these measures shall be kept on a short list of measures if the region needs

additional reductions.

At the completion of the RACM analysis it was determined that no measures met the criteria.



### 9.1 ANALYSIS OVERVIEW AND CRITERIA

The RACM requirement is rooted in Section 172(c)(1 ) of the Clean Air Act, which directs states to “provide for implementation of all reasonably av ailable control measures as expeditiously as practicable”. In its 1992 Gene ral Preamble for implementation of the 1990 Clean Air Act Amendments (57 FR 13498) EPA explains that it inte rprets Section 172(c)(1) as a requirement that states incorporate in a SIP all r easonably available control measures that would advance a region’s attainment date. However, regions are obligated to adopt only those measur es that are reasonably available for implementation in light of local circumstances. In the Preamble, EPA laid out guidelines to help states determine which measur es should be considered reasonably available:

Baltimore Serious Area 8-Hour Ozone SIP Page 86If it can be shown that one or more measur es are unreasonable because emissions from the sources affected are insignificant (i.e. de minimis ), those measures may be excluded from further consideration...the resulting available c ontrol measures should then be evaluated for reasonableness, considering their technological feasibility and the cost of control in the area to which the SIP applies...In the case of public sector sources and control measures, this evaluation should consider the impact of the reasonableness of the measures on the municipal or other government entity that must bear the responsibility for their implementation.

In its opinion on Sierra Club v. EPA, decided July 2, 2002, the U.S. Court of Appeals for the DC Circuit upheld EPA’s definition of RACM, in cluding the consideration of economic and technological feasibility, potential of the measures to cause subs tantial widespread and long-term adverse impacts, collective ability of the measures to advance a region’s attainment date, and whether an intensive or costly effort will be re quired to implement the measures. Consistent with EPA guidance and the U.S. District Court’ s opinion, both the Baltimore and Washington DC regions have developed specific criteria for ev aluation of potential RACM measures. Individual measures must meet the following criteria:

 Will reduce emissions by the beginning of the 2008 ozone season (April 1, 2008)

 Enforceable

 Technically feasible

 Economically feasible (proposed as a cost of $3,500-$5,000 per ton or less)

 Would not create substantial or widespr ead adverse impacts within the region

 Emissions from the source being controlled exceed a de minimis threshold, proposed as 0.1 tons per day

An explanation of these criteria is given in succeeding sections.



### 9.1.1 Implementation Date

EPA has traditionally instructed regions to evaluate RACM measures on their ability to advance the region’s attainment date. This means that implemen tation of a measure or a group of measures must enable the region to reduce ozone levels to th e 84 ppb required to attain the eight-hour ozone standard at least one year earlier than expected. As the Baltimore region currently expects to reduce ozone levels to 84 ppb during the 2009 ozone season, any RACM measures must enable the region to meet the 84 ppb standard by April 1, 2008, the beginning of the 2008 ozone season.



### 9.1.2 Enforceability

When a control measure is added to a SIP, the me asure becomes legally binding, as are any specific performance targets associated with the measure. If the state or local gove rnment does not have the authority necessary to implement or enforce a meas ure, the measure is not creditable in the SIP and

therefore cannot be declared a RACM. A measure is considered enforceable when all state or local government agencies responsible for funding, implem entation and enforcement of the measure have committed in writing to its implementation and enforcement.

Baltimore Serious Area 8-Hour Ozone SIP Page 87In addition to theoretical enforceability, a measur e must also be practically enforceable. If a measure cannot practically be enfo rced because the sources are unide ntifiable or cannot be located, or because it is otherwise impossible to ensure th at the sources will implem ent the control measure,

the measure cannot be declared a RACM. One ex ception is voluntary measures, such as those implemented under EPA’s Voluntary Measures Guidance.



### 9.1.3 Technological Feasibility

All technology-based control measures must include technologies th at have been verified by EPA. The region cannot take SIP credit for technologies that do not produce EPA-verified reductions.



### 9.1.4 Economic Feasibility a nd Cost Effect iveness

EPA guidance states that regions should consider both economic feasibility and cost of control when evaluating potential RACM measures. Therefore, the Baltimore region has specified a costeffectiveness threshold for all possible RACM measures. Measures fo r which the cost of compliance exceeds this threshold will not be considered RACM.

In setting this threshold, the regi on took into considerati on two major factors. First, EPA has issued guidance regarding the relationship between Re asonably Available Cont rol Technology (RACT) and RACM. In its RACM analysis for the Dallas/Forth Worth nonattainment area, EPA states this:

RACT is defined by EPA as the lowest emi ssion rate achievable c onsidering economic and technical feasibility. RACT level control is generally considered RACM for major sources.

In the Baltimore region, RACT installation cost s are as low as approxi mately $3,500 per ton. The region proposes a threshold of $3,500- $5,000 for cost effectiveness.



### 9.1.5 Substantial and Widespread Adverse Impacts

Some candidate RACM measures have the potentia l to cause substantial and widespread adverse impacts to a particular social group or sector of the economy. Due to environmental justice concerns, measures that cause substantial or wi despread adverse impacts will not be considered

RACM.



### 9.1.6 De Minimis Threshold

In the General Preamble, EPA allows regions to exclude from the RACM analysis measures that control emissions from insignificant sources and measures that would impose an undue

administrative burden. Under moderate area RACT re quirements, the smallest major source subject to RACT emits 25 tpy, or approximately 0.1 tpd.

Baltimore Serious Area 8-Hour Ozone SIP Page 88Following these requirements and the precedent set by the San Francisco RACM analysis, the region will not consider control measures affectin g source categories that produce less that 0.1 tpd

NOx or VOC emissions.



### 9.1.7 Advancing Achievement of 0. 08 ppm (84 ppb) Standard

In order for measures to be collectively declar ed RACM, implementation of the measures must enable the region to demonstrate attainment of the 0.08 ppm ozone standard one full ozone season earlier than currently expected.



### 9.1.8 Intensive and Costly Effort

When considered together, the implementation re quirements of any RACM measure cannot be so great as to preclude effective implementati on and administration given the budget and staff resources available to the Baltimore region.



### 9.2 RACM MEASURE ANALYSIS

9.2.1 Analysis Methodology

The sources of strategies analyzed for th e Baltimore region include the following:

 Clean Air Act Section 108(f) measures (Transportation Control Measures)

 Transportation Emissions Reduction Measures (TERMs) listed in recent Transportation Improvement Programs (TIPs) for the Metropo litan Baltimore and Washington DC regions

 Measures identified through a revi ew of the emission reduction st rategies report prepared for the Baltimore Metropolitan Council

 Measures considered in Washington, Atlanta and Houston RACM analyses

These measures were then evaluated against the criteria discussed earlier in this chapter and documented in Appendix D.



### 9.2.2 Analysis Results

Appendix D provides lists (in tabu lar form) organized by source sector, of potential measures evaluated against the RACM criteria. Each specific RACM criterion was reviewed for each

individual measure identified on the lists.

Based on this analysis, none of the measures re viewed were identified as RACM for the Baltimore

8-hour Ozone Nonattainment Area.

Baltimore Serious Area 8-Hour Ozone SIP Page 89

### 9.3 RACM DETERMINATION

Though the measures listed in Appendix D did not meet the criteria for RACM, many of the

measures are worthwhile measures that reduce emissions. These measures will be considered potential control measures for future SI Ps prepared for the Baltimore region.

References

US EPA, “State Implementation Plans; General Pr eamble for the Implementation of Title I of the Clean Air Act Amendments of 1990”, (57 FR 13498), April 16, 1992.

US EPA Region VI, “Reasonably Available Cont rol Measures (RACM) Analysis for the

Dallas/Fort Worth Ozone Nonatta inment Area”, December 2000.

Bay Area Air Quality Management District, Metropolitan Transportation Commission and Association of Bay Area Governments, “Bay Area 2001 Ozone Attainment Plan,” October 24, 2001, Appendix C.

E.H. Pechan & Associates, Inc., “ Revi ew of Emission Reduc tions Strategies”, December 8, 2006.

Baltimore Serious Area 8-Hour Ozone SIP Page 90

## 10.0 MOBILE SOURCE CONFORMITY

Transportation conformity ("conformity") is a pr ovision of the Clean Air Act that ensures that Federal funding and approval goes to those transportation activities that are consistent with air quality goals. Conformity applies to transportation plans and proj ects funded or approved by the Federal Highway Administration (FHW A) or the Federal Transit Administration (FTA) in areas that do not meet or previously have not met air quality standards for ozone, carbon monoxide, particulate matter, or nitrogen dioxide.

In order to balance growing metropolitan regions and expanding transportation systems with the need to improve air quality, EPA established regu lations ensuring that enhancements to existing transportation networks will not impair progress to wards air quality goals. Under the Clean Air Act Conformity Regulations, transportation modificati ons in a nonattainment area must not impair progress made in air quality improvements. Thes e regulations, published in EPA's Transportation Conformity rule on November 24, 1993 in the Federa l Register and amended in a final rule signed on July 31, 1997, require that transp ortation modifications "conform" to air quality planning goals established in air quality SIP documents. The 1997 amendments were followed by further amendments in 2002, 2004, and more recent years since.

In essence, this SIP submission includes mobile emissions budgets for nitrogen oxides (NOx) and volatile organic compounds (VOCs). These budgets, once found adequate by EPA, shall be used in all conformity documents for the Baltimore Nonattain ment Area. In order for a transportation plan to “conform,” the estimated emissions from the transportation plan can not exceed the emissions budgets set via this SIP submission. If the estima ted emissions are shown to exceed the budget then mitigation measures must be taken to ensure emissions will not exceed the emission budgets.

Responsibility for Making a Conformity Determination

The policy board of a Metropolitan Planning Or ganization (MPO), in consultation with the Maryland Department of Transportation (MDOT) a nd MDE, is responsible for formally making a conformity determination on the MPO’s transp ortation plans and transportation improvement programs (TIPs) prior to submittal to the FHWA and FTA for review. The EPA also may review and comment on proposed conformity determinations.

If a particular transportation pl an’s projected emissi ons exceed the mobile emissions budget, the MPO has a variety of mitigation options for reducing emissions. These may include but are not limited to specific transportation emission reducti on measures such as High Occupancy Vehicle (HOV) lanes, transit enhancements, bicycle la nes, diesel retrofits , and idling reductions.

The Safe, Accountable, Flexible, Efficient Tran sportation Equity Act: A Legacy for Users (SAFETEA-LU) was enacted on August 10, 2005. Unde r this act, amendments were made to the transportation conformity rules (Section 6011 of the Act), which required states that have nonattainment areas like Maryland to revise their existing tran sportation conformity SIPs. Maryland submitted a revised transportation confor mity SIP to USEPA in February of 2007.

Baltimore Serious Area 8-Hour Ozone SIP Page 91Because of changes mandated by SAFETEA-LU, conf ormity determinations have to be done at least every four years instead of the previous three years.

When a positive conformity determination is not made according to the required frequency, or in the event that emission mitigation can’t be ag reed upon, a nonattainment area is in conformity “lapse”. This means that federal transportation fu nds allocated to the state, which contains the lapsed nonattainment area, can only be used for the following ki nds of projects:

1. TCMs in Approved SIPs;

2. Non-Regionally Significant Non-Federal Projects;

3. Regionally Significant Non-Fede ral Projects - only if th e project was approved by all necessary non-federal entities before the laps e. (See Approval of a Regionally Significant Non-Federal Project by a Non-Federal Entity later in this chapter.)

4. Project phases (i.e., design, right-of-way acquis ition, or construction) that received funding commitments or an equivalent approval or au thorization prior to the conformity lapse.

5. Exempt Projects - identified unde r 40 CFR §93.126and 40 CFR §93.127; and,

6. Traffic Synchronization Projects - however, these projects must be included in subsequent regional conformity analysis of MPO's transportation plan/TIP under 40 CFR §93.128.

The amount of federal funding a state receives is not reduced but such funds are restricted until the area can again demonstrate conformity.



### 10.1 MOBILE EMISSIONS BUDGET & THE BALTIMORE REGION

TRANSPORTATION CONF ORMITY PROCESS

Mobile source emissions in the long-range tran sportation plan known as the Baltimore Regional Transportation Plan (BRTP), and the shorter te rm Transportation Improvement Program cannot exceed the mobile emissions budget. The transporta tion plans are required to conform to the mobile budget established in the SIP for the short-term TIP years, as well as for the forecast period of the long-range plan, which must be at least twenty years.

In the Baltimore region, modifications to the ex isting transportation netw ork are advanced through the Baltimore Regional Transportation Board (BRTB) by state, regional and local transportation agencies through periodic updates to the BRTP a nd TIP. The TIP is updated annually for the Baltimore region and includes transportation modifications and improvements on a four-year program cycle. Pursuant to the conformity regula tions, the TIP must contain analyses of the motor vehicle emissions estimates for the region resultin g from the transportation improvements. These analyses must show that the transportation improv ements in the TIP and the plan do not result in a deterioration of (“conform to”) the air quality goals established in the SIP.



### 10.2 BUDGET LEVEL FOR ON-ROAD MOBILE SOURCE EMISSIONS

As part of the development of the SIP, MDE, in consultation with the Baltimore Regional Transportation Board, establishes a mobile sour ce emissions budget. This budget will be the benchmark used to determine if the region's long -range transportation plan (BRTP) and four-year transportation improvements prog ram (TIP) conform to the SIP. Under EPA regulations, the

Baltimore Serious Area 8-Hour Ozone SIP Page 92projected mobile source emissions for 2012 (the region’ s attainment ozone season) become the mobile emissions budgets for the region unless MD E takes actions to set other budget levels.

Modeling and Data

The 2012 mobile emissions inventories are calculated using the following m odels and tools: EPA’s MOVES and the Highway Performance Monitoring Sy stem (HPMS) model. A detailed explanation of the model and the emission estimating methodology can be found in Appendix E.

Attainment Year Mobile Budgets

The mobile emissions budgets for the 2012 attainment year are based on the projected 2012 mobile source emissions accounting for all mobile control measures. The mobile emissions budgets for the 2012 attainment year, based upon the projected 2012 mobile source emissions, accounting for all the mobile control measures, are as follows:

Table 10-1: 2012 Attainment Year Mobile Bu dgets for the Baltimore Nonattainment Area

VOC (TPD) 40.2

NOx (TPD) 93.5



### 10.3 TRENDS IN MOBILE EMISSIONS

The mobile emissions budgets for 2012 for VOCs and NOx reflect a con tinuation of a downward

trend in mobile emissions over time.

Baltimore Serious Area 8-Hour Ozone SIP Page 93Mobile Emissions Trends

0.0 50.0 100.0 150.0 200.0 250.0

2002 2008 2011 2012

YearEmissions (tons/day)

VOC

NOx

The steady reductions in mobile emissions are attr ibutable largely to a series of increasingly stringent federal regulations requi ring cleaner vehicles and fuels, including the federal Tier II regulations for motor vehicles. Trends toward re duced mobile emissions are occurring despite the negative effects of a shift toward the use of higher-emitting, less fuel -efficient sport utility vehicles instead of passenger cars and a steady increa se in population, employme nt and vehicle miles traveled (VMT) within the Baltimore region.

The trends of increasing populat ion, employment, and VMT are e xpected to remain strong well beyond 2009. The regional cooperative forecasti ng process (from the 2004 Baltimore Regional Transportation Plan) predicts that from 2000 to 2030, the regional population will grow by 14% and employment will grow by 22%. Regional VMT is pred icted to still outpace these increases over the same time period with a projec ted growth of 37% on an averag e weekday. These trends, however, will not reverse the expected decline in regional m obile emissions resulting from cleaner fuels and improved vehicle technology. The Tier II passenger vehicle standards and re gulations on emissions from heavy-duty diesel vehicles and fuels are exp ected to produce further dramatic reductions in VOC and NOx emissions as vehicles are replaced and retrofitted over the next 20 years. It is important to keep in mind, however, that despit e cleaner fuels and impr oved vehicle technology, the relationship between land use planning, transportati on, and air quality is important for long-term air quality goals.

Baltimore Serious Area 8-Hour Ozone SIP Page 94

## 11.0 SERIOUS AREA PLAN COMMITMENTS

Achieving the results shown in this Plan requ ires a commitment to implement the regulatory measures upon which the plan is based. Maryland is taking action to implement regional and local measures to effectively reduce ozone tran sport throughout the Baltimore and Washington Nonattainment Areas. Tables 11-1 and 11-2 provide information on the implementation of each

measure.



### 11.1 SCHEDULES OF ADOPTED CONTROL ME ASURES

Table 11-1: Maryland Schedule of Adopted Control Measures Baltimore, Washington DC, and C ecil County Nonattainment Areas

Control Measure Regulation Number Effective Date

Federally Mandated Measures

High Tech Inspections &

Maintenance 11.14.08 1/2/1995

Stage II Vapor Recovery Nozzle 26.11.24 2/15/1993

Federal Tier I Vehicle Standards and new Car Evaporative Standards 40 CFR part 86 Model Year 1994-1996; Evap

Stds. 1996

Tier 2 Motor Vehicle Emission

Standards 65 FR 6698 2/10/2000

Non-CTG RACT See Table 11-2

- Phase II Gasoline Volatility Controls 03.03.03.05 10/26/1992

EPA Non-Road Gasoline Engines

Rule 40 CFR parts 90 and 91 12/3/1996

EPA Non-Road Diesel Engines Ru le 40 CFR Part 9 et al. Model Year 2000-2008 depending on engine size

State NOx RACT Requirements 26.11.29.08 5/10/1993

EPA Nonroad Spark Ignition Marine Engine Rule 40 CFR Parts 89, 90, 91 1998 Model Year

EPA Large Spark Ignition Engines

Rule 40 CFR Parts 89, 90, 91, 94, 1048, 1051, 1065, and

1068 11/8/2002

Federal Programs

Baltimore Serious Area 8-Hour Ozone SIP Page 95Control Measure Regulation Number Effective Date

Reformulated Surface Coatings 63 FR 48849, 64 FR 34997, 65 FR 7736 9/11/1998, 6/30/1999,

2/16/2000

National Volatile Organic Compound Emission Standards for

Consumer Products 63 FR 48819 9/11/1998

National Low Emissions Vehicle Program 26.11.20.04 3/22/1999

Emissions Controls for Locomotives 63 FR 18998 6/15/1998

Heavy-Duty Diesel Engine Rule 63 FR 54694 12/22/1997

State and Local Measures

Reformulated Gasoline (on-road) Federal - local opt-in 1/1/1995

Reformulated Gasoline (off-road) Federal - local opt-in 1/1/1995

Surface Cleaning/Degreasing for Machinery/Automobile Repair 26.11.19.09 6/5/1995

Landfill Regulations 26.11.19.20 3/9/1998

Seasonal Open Burning Restrictions 26.11.07 5/22/1995

Stage I Expansion 26.11.13.04C 4/26/1993

Expanded Point Source Regulations to 25 tpy 26.11.19.01B(4) 5/8/1995

Graphic Arts Controls 26.11.19.11 & .18 6/5/1995 & 11/7/1994

Auto and Light Duty Truck Coating Operations 26.11.19.23 5/22/1995

Control of VOC Emissions from Vehicle Refinishing 26.11.19.23 5/22/1995

Portable Fuel Containers Rule:

Phase I 26.11.13.07 1/21/2002

Architectural and Industrial Maintenance Coatings Rule 26.11.33 3/29/2004

Reformulated Consumer Products

Rule: Phase I 26.11.32 8/18/2003

Control of VOC Emissions from Cold and Vapor Degreasing 26.11.19.09 6/5/1995

Maryland Healthy Air Act 26.11.27 Emergency Regulations

effective 1/18/2007 - Permanent Regulations

effective 7/16/2007

Industrial Adhesives and Sealants

Rule* 26.11.35 4/21/2008, and amendment (permanent regulations)

effective 6/1/2009

Baltimore Serious Area 8-Hour Ozone SIP Page 96Control Measure Regulation Number Effective Date

Portable Fuel Containers Rule:

Phase II* 26.11.13.07 6/18/2007

Reformulated Consumer Products

Rule: Phase II* 26.11.32 6/18/2007

Regional Control Measures

NOx Phase II Controls 26.11.27 & .28

26.11.29 & 30 10/18/1999

Table 11-2: Maryland Non-CTG RACT Baltimore and Washington Nonattainment Areas

Overall requirement in COMAR 26.11.19.02G effective 4-26-93 (20: Md. R 726) The following case-by-case RACT regulations ha ve been adopted to ensure consistency.

RACT Regulation Regulation

Number Effective

Date MD Register

Plastic Parts Coating 26.11.19.07E 6-5-95 22:11 Md R 823

Definition of Gasoline to include JP-4 26.11.13.01 8-11-97 24:16 Md R.

1161

Printing on Plastic 26.11.19.07F 9-8-97 24:18 Md R

1298

Aerospace Coating Operations 26.11.19.13-1 9-22-97 24:19 Md R

1344

Yeast Manufacturing 26.11.19.17 11-7-94 21:22 Md R

1879

Expandable Polystyrene Operations 26.11.19.19 7-3-95 22:13 Md R 970

Commercial Bakery Ovens 26.11.19.21 7-3-95 22:13 Md R 970

Vinegar Generators 26.11.19.22 8-11-97 24:16 Md R

1161

Baltimore Serious Area 8-Hour Ozone SIP Page 97RACT Regulation Regulation

Number Effective

Date MD Register

Leather Coating 26.11.19.24 8-11-97 24:16 Md R

1161

Explosives and Propellant Manufacturing 26.11.19.25 8-11-97 24:16 Md R

1161

Reinforced Plastic Manufacturing 26.11.19.26 8-11-97 24:16 Md R

1162

Marine Vessel Coating Operations 26.11.19.27 10-20-97 24:21 Md R

1453



### 11.2 STATIONARY SOURCE THRESHOLDS

Under the “moderate” classification for the 8-hour ozone standard, the permit threshold is 50 tons per year VOC and 100 tons per year NOx. In order to prevent backsliding Maryland is required to maintain the Baltimore NAA permit threshold at 25 tons per year for both VOC and NOx.

Baltimore Serious Area 8-Hour Ozone SIP Page 98

## 12.0 CONTINGENCY MEASURES

12.1 PURPOSE OF CHAPTER

This chapter demonstrates that the Baltimore Nonattainment Area meets the requirements for SIP contingency measures related to both Reasonable Further Progress (R FP) and to the attainment of the ozone standard. If implemented, the contingency measures discussed in th is chapter would result in reductions in addition to those required to de monstrate RFP (discussed in Chapter 5) and in

addition to those that have been taken into acco unt in the attainment demonstration (discussed in Chapters 5-7). Contingency measur es ensure that if the Baltimo re Nonattainment Area fails to achieve the required RFP reductions by the RFP milestone year, or fails to attain the ozone standard by the attainment year, additional reductions will occur without further state or federal action.



### 12.2 CONTINGENCY REQUIREMENTS

Section 172(c)(9) of the CAA and EPA’s Phase 2 Rule require that nonattainment areas include contingency measures in their RFP and attainment SIPs. If a state receives a notification from EPA

that a nonattainment area within its borders has failed to achieve th e level of reductions demonstrated in the RFP SIP by the milestone year , or has failed to atta in the standard by the attainment date, the area must be able to impl ement contingency measures within one year after

EPA’s notice.

The RFP contingency and the attainment continge ncy must each provide for reductions equivalent to at least 3% of the 2002 RFP Adjusted Base Year VOC emissions inventory. 23 The contingency

reductions are in addition to th e reductions required to demonstr ate RFP and in addition to the

reductions taken into account in the attainment demonstration.



### 12.3 RFP CONTINGENCY

As discussed in Chapters 5-7, MDE is meeting the RFP requirement to reduce emissions by 27 percent for the years 2002 to 2012 (15 percent RFP for the years 2002 to 2008, 9 percent RFP for the years 2008 to 2011, 3 percent RFP for the years 2011 to 2012) through a combination of

reductions of NOx and VOCs.

To satisfy the contingency requirement, MDE must be able to demonstrate that if the Baltimore area fails to achieve the required RFP reductions, without further state or fede ral action, an additional

3% reduction could be achieved from control meas ures not already taken in account in calculation

of the 27% RFP reduction.

According to EPA’s interpretation of this re quirement, the RFP contingency may be met by showing reductions in the 2012 RFP milestone ye ar of at least 30% by 2012 (27% RFP + 3% RFP

23 The RFP Adjusted Base Year Inventory is based on the MD 2002 Base Year Inventory adjusted for RFP purposes, as discussed in detail in Chapters 5-7.

Baltimore Serious Area 8-Hour Ozone SIP Page 99contingency). 24 As demonstrated in Chapter 7, Ta ble 7-3 and reproduced with additional information in Table 12-1 below, the Baltimore area has demonstrated reductions significantly greater than the 27% reductions needed to meet RFP requirements and the additional 3% reductions needed to meet the contingency requirements. Therefore, the Baltimore Nonattainment Area has met the RFP contingency requirement.

Table 12-1:

Baltimore Nonattainment Area Comparison of 2012 Target Inventory plus 3% Contingency and 2012 Controlled Inventories

Description VOC NOx

(a) 2012 Target Levels 220.38 328.49

(b) RFP 3% Contingency Reductions
(1.5% of VOC & NOx 2012 Target Levels in (a)) 3.31 4.93

(c) 2012 Target Levels with Additional RFP Contingency (a)-(b) 217.07 323.56

(d) 2012 Controlled Emissions 199.90 232.88



### 12.4 ATTAINMENT CONTINGENCY

EPA will assess whether the Baltimore Nonattainmen t Area has attained the standard, presumably based on monitored ozone readings for 2010 - 2012. If the area is not mee ting the standard based on readings for the 3-year period, EPA may issue a no tification of failure to attain. The notification will trigger a requirement for MDE to implement contingency reductions within one year of the notification. For purposes of this contingency analysis, MDE is a ssuming that EPA would issue the notice in June 2013, and that the contingency meas ures would need to be in place by June 2014. Therefore, to meet the attainment contingency requirement, MDE must id entify control measures that will achieve additional reductions in emissions after 2012 and by June 2014 from control measures that will be effective without any further state or federal action. One year from the date of notification, the iden tified contingency measures must be fully implemented. This means that the contingency measures must pr ovide emission reductions in the 2014 timeframe to meet the contingency requirements.

The amount of additional reductions that must be achieved in order to meet the attainment contingency requirement is 3% of the 2002 RFP Adjusted Base Y ear VOC emissions. The amount

of reductions is shown below.

Table 12-2: Required Attainment Contingency

2002 RFP Adjusted Base Year Inventory (TPD) 3% of 2002 VOCs = Required Contingency Reduction

VOC NOx

BNAA 258.69 369.69 7.76

24 U.S. EPA Memorandum from Michael H. Shapiro to Region 1 through 10 Air Directors, Guidance on Issues Related to 15% Rate-of-Progress Plans, August 23, 1993.

Baltimore Serious Area 8-Hour Ozone SIP Page 100While the required reductions (3%) are calculated as a percentage of the 2002 VOC emissions, NOx

reductions can be used as a direct substitute for up to 90% of the required reductions. Therefore, only 0.3% of the reductions achieved by the continge ncy measures must be VOCs; this equates to

0.78 TPD in the BNAA.

Table 12-3: Minimum VOC Reductions Required for Attainment Contingency

Pollutant Total Reductions Needed for Contingency Pollutant Percentage Contingency Amount per Pollutant (tpd)

VOC 7.76 10% 0.78

NOx 7.76 90% 6.98

MDE will meet this attainment contingency requ irement by taking credit for emission reductions that will be achieved from the existing federal on-road mobile source control measures such as Fuel Standards and Heavy-Duty Engine Standards, and from the Maryland Low-Emission Vehicle (LEV) Program. These measures will continue to provide substantial VOC and NOx emission reductions through 2012 (and beyond) as newer, le ss-polluting vehicles replace the older fleet.

In addition some emission control strategies list ed to meet the 2012 target level are expected to

result in more emission reductions than are needed to meet the requirements. If other measures fail to meet expected reductions, the excess from the following measures will be used to make up the

difference:

 On-road mobile

 Nonroad Mobile

 Ozone Transport Commission (OTC) - Portable Fuel Container Phase 1 and Phase 2

 OTC - Architectural Surface Coatings

 OTC – Commercial and Consumer Products

 Railroad Locomotives Tier 2



### 12.5 CONCLUSIONS

As shown in Table 12-4 below, which is a comb ination of Tables 5-5, 6-2, and 7-2 with RFP contingency information added, the Baltimore Nonattainment Area has met the RFP contingency by demonstrating that the reductions of VOC and NO x projected by 2012 are signi ficantly greater than the 30% reduction that is require d (27% for RFP and 3% for RFP c ontingency). For the attainment contingency, the reductions of VOC and NOx that will be achieved from the on-road mobile source control measures already in effect are significantly grea ter than reductions needed to meet the 3% attainment contingency requirement.

Baltimore Serious Area 8-Hour Ozone SIP Page 101Table 12-4: Contingenc y Measure Calculations



### VOC Target Level for 2012 Milestone

Baltimore Nonattainment Area

Emissions in Tons per Day

Formula

A 2002 Base Year Inventory 485.97

B Biogenic Emissions 223.20

C 2002 Rate-of Progress Base Year Inventory A - B 262.77

D FMVCP/RVP Reductions Between 2002 and 2008 4.08

E 2002 Adjusted Base Year Inventory Calculated Relative to 2008 C - D 258.69

F Reduction Ratio 0.0800

G Emissions Reductions Required Between 2002 and 2008 E * F 20.70

H Target Level for 2008 [TL (2008) ] C - D - G 238.00
Reclassification / Bump Up

I FMVCP/RVP Reductions Between 2008 and 2011 0.29

J 2002 Adjusted Base Year Inventory Calculated Relative to 2011 I - J 237.71

K Reduction Ratio 0.0600

L Emissions Reductions Required Between 2008 and 2011 J * K 14.26

M Target Level for 2011 [TL (2011) ] J - L 223.73

N FMVCP/RVP Reductions Between 2011 and 2012 0.00

O 2002 Adjusted Base Year Inventory Calculated Relative to 2012 M - N 223.73

P Reduction Ratio 0.0150

Q Emissions Reductions Required Between 2011 and 2012 P * O 3.36

R Target Level for 2012 [TL (2012) ] O - Q 220.38

S RFP Contingency (3% Total: 1.5% VOC/1.5% Nox) 3.31

T Attainment Contingency Target Level with minimum VOC reductions 0.78

U Contingency Target Level R-(S + T) 216.30

Emission Level Obtained 2012 199.90

Baltimore Serious Area 8-Hour Ozone SIP Page 102

### NOx Target Level for 2012 Milestone

Baltimore Nonattainment Area

Emissions in Tons per Day

Formula

A 2002 Base Year Inventory 371.47

B Biogenic Emissions 0.00

C 2002 Rate-of Progress Base Year Inventory A – B 371.47

D FMVCP/RVP Reductions Between 2002 and 2008 1.78

E 2002 Adjusted Base Year Inventory Calculated Relative to 2008 C – D 369.69

F Reduction Ratio 0.0700

G Emissions Reductions Required Between 2002 and 2008 E * F 25.88

H Target Level for 2008 [TL (2008) ] C - D - G 343.81
Reclassification / Bump Up

I FMVCP/RVP Reductions Between 2008 and 2011 0.00

J 2002 Adjusted Base Year Inventory Calculated Relative to 2011 I – J 343.81

K Reduction Ratio 0.0300

L Emissions Reductions Required Between 2008 and 2011 J * K 10.31

M Target Level for 2011 [TL (2011) ] J – L 333.49

N FMVCP/RVP Reductions Between 2011 and 2012 0.18

O 2002 Adjusted Base Year Inventory Calculated Relative to 2012 M – N 333.32

P Reduction Ratio 0.0150

Q Emissions Reductions Required Between 2011 and 2012 P * O 5.00

R Target Level for 2012 [TL (2012) ] O - Q 328.49

S RFP Contingency (3% Total: 1.5% VOC/1.5% Nox) 4.93

T Attainment Contingency Target Level with minimum VOC reductions 6.98

U Contingency Target Level R-(S + T) 316.58

Emission Level Obtained 2012 232.88

Baltimore Serious Area 8-Hour Ozone SIP Page 103

## 13.0 ATTAINMENT MODELING DEMONSTRATION

The 8-hour Ozone Standard Attainment Modeling Demonstration analyzes the potential of the

Baltimore NAA to achieve attainment of the 8-hour ozone standard by June 15, 2013. The attainment modeling demonstr ation is comprised of the following five sections:

13.1 – Modeling Study Overview

13.2 – Domain and Data Base Issues

13.3 – Model Performance Evaluation

13.4 – Attainment Demonstration 13.5 – Procedural Requirements



### 13.1 MODELING STUDY OVERVIEW

13.1.1 Background and Objectives

Since the Baltimore 8-Hour Ozone Nonattainment Area (NAA) did not attain the 1997 8-hour ozone standard by its 2009 attainment date, EPA reclassified the Baltimore NAA from a “moderate” to a “serious” NAA. Baltimore is accordingly requ ired to demonstrate a ttainment of the 8-hour ozone standard by 2012 using photochemical modeli ng and weight-of-evidence analyses. Chapter 14 contains all the weight-of-ev idence analyses supporting the Ba ltimore NAA’s attainment of the

8-hour ozone standard.

The objective of the photochemical modeling study is to enable the MDE to analyze the efficacy of various control strategies, and to demonstrate that the measures adopted as part of the State Implementation Plan (SIP) will result in attainme nt of the 8-hour ozone standard by June 15, 2013. The modeling exercise predicts future year 2012 air quality conditions based on the worst episodes in the base year 2002, and applies control measures to demonstrate the effectiveness of new control measures in reducing air pollution.

For the reason previously mentioned, the Ozone Transport Commission (OTC), on behalf of the Ozone Transport Region (OTR) member states , including Maryland, und ertook a photochemical modeling study to demonstrate compliance with the 8-hour ozone NAAQS. The 8-hour ozone attainment modeling study was directed by the OT C Modeling Committee, which consisted of the following workgroups: OTC Photochemical Workgroup, OTC Meteor ological Modeling Workgroup, OTC Emissions Inventory Developm ent Workgroup, and the OTC Control Strategy Workgroup.

The OTC Air Directors served on the OTC Oversi ght Committee and provided oversight of the

process.

Table 13-1 identifies all jurisd ictions within the 8-hour oz one Baltimore NAA and Figure 13-1 provides a graphical representation of the 8-hour ozone Baltimore NAA.

Baltimore Serious Area 8-Hour Ozone SIP Page 104Table 13-1: Jurisdictions within the 8-Hour Ozone Baltimore NAA

Area Maryland

Counties Classification Attainment

Date

Baltimore NonAttainment Area Anne Arundel

Baltimore Baltimore City

Carroll

Harford

Howard Serious June 2013

Baltimore, MD

Non-Attainment Area

Figure 13-1: 8-Hour Ozone Baltimore NAA

The photochemi cal model selected for the atta inment modeling demonstration was the EPA Models-3/Community Multi-scale Air Quality (CMAQ) modeling system , which is a “OneAtmosphere” photochemical grid model capable of addressing ozone at a regional scale and is considered one of the preferred models for regulatory modeling applications. The modeling analyses set forth in this report have been conducted in accordance with the Guidance on the Use of Models and Other Analyses for Demonstrating A ttainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze (Draft 3.2- September 2006)

.

Baltimore Serious Area 8-Hour Ozone SIP Page 105

### 13.1.2 Relationship to Regional Modeling Protocols

The state of Maryland is a member of the OTC a nd, along with other member OTC states, was able to coordinate the modeling analyses performed for the Baltimore NAA with the regional modeling analysis conducted by th e OTC Modeling Committee.

The lead agency for coordinating the running of the CMAQ model and performing the modeling runs for the OTC was the New York State Departme nt of Environmental C onservation (NYSDEC). Modeling centers for the OTC included the NYSDEC, the University of Maryland at College Park (UMD), the Northeast States for Coordinated Ai r Use Management (NESCAUM), the New Jersey Department of Environmental Protection (NJDEP) and the Virginia Department of Environmental Quality (VADEQ). The lead modeling agency for coordinating the running of the CMAQ model for the OTC and performing the modeling runs was the NYSDEC, but member states of the OTC, within the frame-work of the OTC, managed th e modeling project collect ively. All OTC modeling inventories were provided by the Mid-Atlantic Regional Air Mana gement Association (MARAMA) and developed, updated, and shared among the OTC states’ modeling centers.

Installation of the CMAQ model at all participating modeling centers was completed and diagnostic procedures were run successfully. The CMAQ model was benchmarked against other modeling platforms across the OTR to ensure accurate results. The OTC Modeling Committee oversaw the modeling effort and reported to the OTC Ov ersight Committee through regular briefings and presentations, and offered additional information in cases where specific technical decisions had policy implications. MDE was a member of th e various OTC committees to ensure that the Maryland ozone modeling protocol followed the sa me analyses being conducted by the OTC. Provided in Appendix F-1 is the Ba ltimore NAA ozone m odeling protocol.



### 13.1.3 Conceptual Description

EPA recommends that a conceptual description of an area’s ozone problem be developed prior to the initiation of any air quality modeling study. A “conceptual description” is a qualitative way of characterizing the nature of an area’s non-attainment problem. Within the conceptual description of a particular modeling exercise, it is recommended that the specifi c meteorological parameters that influence air quality be identified and ranked in importance based on qualitative information.

NESCAUM prepared the conceptual description for this study for the OTR member states’ use. The conceptual description document, The Nature of the Ozone Air Quality Problem in the Ozone Transport Region: A Conceptual Description (NESCAUM, October 2006), is provided in Appendix F-2. This document provides the conceptual desc ription of the ozone problem in the OTR states, consistent with the EPA’s guidance.



### 13.2 DOMAIN AND DATA BASE ISSUES

13.2.1 Episode Selection

Baltimore Serious Area 8-Hour Ozone SIP Page 106The procedures for selecting 8-hour ozone modeling episodes seek to achiev e a balance between the science and regulatory needs and co nstraints. Modeling episodes, on ce selected, influence technical and policy decisions for many years. Both the dir ect and implicit procedures used in selecting episodes warrant full consideration.

The rationale for the selection of 2002 meteorology as input to the air quality simulations includes a qualitative analysis (Ryan a nd Piety 2002) and a quantitative analysis (Environ 2005). These documents are provided in Appendix F-3.

Recent research has shown that model performa nce evaluations and the response to emissions controls need to consider modeling results over l ong time periods; in particular, full synoptic cycles or even full ozone seasons. Based on this factor, the entire ozone season was simulated for the 2012 SIP modeling runs (May 1 to September 30). As a result, the total number of days examined for the complete ozone season far exceeds EPA recomme ndations, and provides fo r better assessment of the simulated pollutant fields.



### 13.2.2 Size of the Modeling Domain

In defining the modeling domain, one must consid er the location of the local urban area, the downwind extent of the elevated ozone levels, the location of large em ission sources, and the availability of meteorological a nd air quality data. The domain or spatial extent to be modeled includes as its core the NAA. Beyond this, th e domain includes enough of the surrounding area such that major upwind sources fall within the domain and emissions produced in the NAA remain within the domain throughout the day.

The boundaries of the OTC modeling domain are pr ovided in Appendix F-4. This domain covers the Northeast region, including the northeastern, central and so utheastern U.S. as well as

southeastern Canada. The final SIP modeli ng analysis utilized this modeling domain.



### 13.2.3 Horizontal Grid Size

The OTC platform provided the basic platform for the Baltimore NAA modeling analysis and utilized a coarse grid co ntinental United States do main with a 36 km horizontal grid resolution. The CMAQ domain is nested in the Pennsylvania St ate University/National Center for Atmospheric Research (PSU/NCAR) Mesoscale Meteorological Model (MM5) domain. A larger MM5 domain was selected for the MM5 simulations to provi de a buffer of several grid cells around each boundary of the CMAQ 36 km domain. This was designed to eliminate any errors in the meteorology from boundary effects in the MM5 simu lation at the interface of the MM5 model. A

12 km inner domain was selected to better ch aracterize air quality in OTR and surrounding Regional Planning Organization (RPO) regions. Appendix F-5 contains the horizontal grid definitions for the MM5 and CMAQ modeling domains.

Baltimore Serious Area 8-Hour Ozone SIP Page 107

### 13.2.4 Vertical Resolution

The vertical grid used in the CMAQ modeling was primarily defined by the MM5 vertical structure. The MM5 model employed a terrain following coordi nate system defined by pressure. The layer averaging scheme adopted for CMAQ is designed to reduce the computational cost of the CMAQ simulations. Only the uppermost layers of the CMAQ domain were coalesced. All layers in the planetary boundary layer were le ft undisturbed in moving from the MM5 to the CMAQ simulation.

This ensures that the near-sur face processes that affect air pollution the most are faithfully represented in CMAQ, while the meteorological sy stems that are driven by upper-level winds are allowed to develop properly in MM5. The effects of layer averaging have a relatively minor effect on the model performance metrics when compared to ambient monitoring data.

Appendix F-6 contains the vertical layer defini tions for the MM5 and CMAQ modeling domains.



### 13.2.5 Initial and Boundary Conditions

The objective of a photochemical grid model is to estimate the air qual ity, given a set of meteorological and emissions conditions. When initializing a modeling simulation, the exact

concentration fields are not known in every grid cell for the star t time. Therefore, typically photochemical grid models are started with clea n conditions within the domain and allowed to stabilize before the period of interest is simulate d. In practice, this is accomplished by starting the model several days, called spin-up ti me, prior to the period of interest.

The winds move pollutants into, out of, and within the domain. The model handles the movement of pollutants within the domain and out of the domain. An estimate of the concentration of pollutants at the edge of the domain and therefore the quantit y of pollutants moving into the domain is needed. These are called boundary conditions. The 12 km gr id boundary conditions were extracted from the 36 km CMAQ simulation. To estimate the boundar y conditions for the modeling study, boundary

conditions for the outer 36 km domain were deri ved every three hours from an annual model run performed by researchers at Harvard University using the GEOS-CHEM global chemical transport model (Moon and Byun 2004, Baker 2005). The influence of boundary conditions was minimized by using a 15-day spin-up period, which is suffici ent to establish pollutant levels that are

encountered in the eastern U.S. Additional info rmation on the extraction of boundary conditions is provided in Appendix F-7.



### 13.2.6 Meteorological Model Selection and Configuration

The Pennsylvania State University/National Ce nter for Atmospheric Research (PSU/NCAR) Mesoscale Meteorological Model (MM5) versi on 3.6 was used to generate the annual 2002 meteorology for the OTC modeling analysis. The MM5 model is a non- hydrostatic, prognostic meteorological model routinely used for urban- and regional-scale photo chemical regulatory modeling studies. Professor Da-Lin Zhang (UMD) performed the MM5 modeling in consultation

with the NYSDEC and MDE staff.

Baltimore Serious Area 8-Hour Ozone SIP Page 108A more detailed description and performance eval uation of the MM5 modeli ng results are provided in Appendix F-8. Based on model validation and sensitivity testing, the MM5 configurations provided in Appendix F- 9 were selected.



### 13.2.7 Emissions Model Selection and Configuration

The Sparse Matrix Operator Kernel Emissi ons (SMOKE) Emissions Processing System was selected for the OTC modeling analysis. SMOKE is principally an emissions processing system, and not a true emissions inventory preparation sy stem in which emissions estimates are simulated from ‘first principles’. This means that, with the exception of mobile and biogenic sources, its purpose is to provide an efficien t, modern tool for converting em issions inventory data into the formatted, hourly, mapped emissions files requ ired for a photochemical air quality model.

Inside the OTR, the emissions inventories prep ared for the modeling analyses were developed through a coordinated effort between the OTR stat es and the Mid-Atlantic Northeast Visibility Union (MANE-VU) Regional Plan ning Organization (RPO).

The 2002 emissions were first generated by the indivi dual OTR states. These inventories were then assembled and processed through the MANE-VU RPO. The 2002 emissions for non-OTR areas within the modeling domain were obtained from other RPOs for their corresponding areas.

These RPOs included the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), the Midwest Regional Planning Organization (MRPO) and the Central Regional Air Planning Association (CENRAP). These emissions were then processed by the NYSDEC using the SMOKE (Version 2.1) processor to provide inputs for the photochemi cal model. Wherever possible, the mobile source emission inventories (in vehicle miles traveled, or “VMT” format) were replaced

with Source Classification Code (SCC)-specific county level emissi ons to more accurately reflect actual emissions for a typical ozone season day.

The emissions inventories included a base case ( 2002), which serves as the “parent” inventory off which all future year inventories (i.e., 2012) are based. The future year emissions inventories include emissions growth due to projected increases in economic activity as well as emissions reductions due to implementation of control measures.

A detailed description of all SMOKE input files, such as area, mobile, fire, point and biogenic emissions files, and the SMOKE model conf iguration are provided in Appendix F-10.



### 13.2.8 Air Quality Model Select ion a nd Configuration

EPA’s Models-3/Community Multi-scale Air Qual ity (CMAQ) modeling system was selected for the attainment demonstration primarily because it is a “one-atmosphere” photochemical grid model capable of addressing ozone on a re gional scale and is considered one of the preferred models for regulatory modeling applications. Th e model is also recommended by the Guidance on the Use of Models and Other Analyses for Demonstrating A ttainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (Draft 3.2- September 2006).

Baltimore Serious Area 8-Hour Ozone SIP Page 109Baltimore Serious Area 8-Hour Ozone SIP Page 110 The CMAQ configuration is provided in Appendix F-11.



### 13.2.9 Quality Assurance

All air quality, emissions, and meteorological data were reviewed to ensure completeness, accuracy, and consistency before proceeding with modeling. Any errors, missing data or inconsistencies, were addressed using appropriate methods that are consistent with standard practices. All modeling was benchmarked through the duplic ation of a set of st andard modeling results across different modeling centers.

Quality Assurance (QA) activities were carried out for the various emissions, meteorological, and photochemical modeling components of the modeling study. Emissions inve ntories obtained from

the RPOs were examined to check for errors in the emissions estimates. When such errors were discovered, the problems in the input data files were corrected and the models were run again.

The MM5 meteorological model and CMAQ air quali ty model inputs and outputs were plotted and examined to ensure sufficiently accurate represen tation of the observed data in the model-ready fields, and temporal and spatial consistency a nd reasonableness. Both MM5 and CMAQ underwent operational and scientific evaluatio ns in order to facilitate the quality assurance review of the meteorological and air quality modeling procedures, and these evaluations ar e discussed in greater detail in other sections of this SIP and the appendices.



### 13.3 MODEL PERFORMANCE EVALUATION

13.3.1 Overview

There are many aspects of model performance. This section will focus primarily on the methods and techniques recommended by EPA for evaluating the performance of the air quality model. It should be noted that other parts of the modeling proces s, the emissions and meteorology, also undergo an

evaluation. In the intere st of keeping this sect ion concise, though, the ai r quality model is the primary focus.

The first step in the modeling process is to verify the model’s performance in terms of its ability to predict ozone in the right locations and at the right levels. To do this, model predictions for the base year simulation are compared to the ambient da ta observed in the historical episode. This

verification is a combination of statistical and graphical evaluati ons. If the model appears to be predicting ozone in the right locations for the ri ght reasons, then the model can be used as a predictive tool to evaluate vari ous control strategies and their effects on ozone. The purpose of the model performance evaluation is to assess the accuracy with which the model predicts ozone levels observed in the historical episode. Then CMAQ’s pr edictions of future year air quality are put in the appropriate context when CMAQ performance a nd predictions are used to inform future policy

decisions.The results of a model performa nce evaluation were examined pr ior to using CMAQ’s results to support the attainment demonstr ation. The performance of CMAQ was evaluated using both operational and diagnostic methods. Operational evaluation refers to the model’s ability to replicate observed concentrations of ozone and/or precur sors (surface and aloft), whereas diagnostic

evaluation assesses the mode l’s accuracy with respect to characterizing the se nsitivity of ozone to changes in emissions (i.e., relative response factors).

The NYSDEC conducted a performance evaluation of the 2002 base case CMAQ simulation (May 15-September 30) on behalf of the OTR member states. Appendix F-12 provides comprehensive operational and diagnostic evaluati on results, including spreadsh eets containing the assumptions made to compute statistics. Highlights of this evaluation are provided in the following sections.



### 13.3.2 Diagnostic and Operational Evaluation

The issue of model performance goals for ozone is an area of ongoing research and debate. To evaluate model performance, EPA recommends that several statistical metrics be calculated for air quality modeling. Two of the comm on metrics that are most often used to assess performance are the mean normalized gross error and the mean normalized bias. The mean normalized gross error parameter provides an overall asse ssment of model performance and can be interprete d as precision, and the mean normalized bias parameter measures a model's ability to reproduce observed spatial and temporal patterns and can be interpreted as accuracy. EPA suggests the following criteria: a mean normalized gross error (MNGE) of < 35%, a nd a mean normalized bias (MNB) of < ±15% above a threshold of 40-60 ppb. These results ar e presented in Table 13-2 for the Baltimore NAA and in Tables 13-3 and 13-4 on a monitor-by-mon itor basis averaged over all days for the 40 ppb and 60 ppb thresholds. Figure 13-2 shows the locati on of the monitors in the Baltimore NAA.

Table 13-2: Baltimore NAA Statistics for 8-hour Ozone

Location Ozone Cutoff

Threshold (ppb) Mean

Normalized

Gross Error

(MNGE) (%) Mean

Normalized Bias (MNB)

(%)

40 12.94 -0.99 Baltimore, MD NAA 60 12.49 -4.41

Table 13-3: Individual Site Statistics for 8-hour Ozone Using 40 ppb Cutoff

AIRS ID Site Name County State MNGE (%) MNB (%)

240030014 Davidsonville Anne Arundel MD 12.49 -5.11

240051007 Padonia Baltimore MD 11.60 -1.34

240053001 Essex Baltimore MD 14.60 3.62

240130001 South Carroll Carroll MD 12.31 1.33

Baltimore Serious Area 8-Hour Ozone SIP Page 111AIRS ID Site Name County State MNGE (%) MNB (%)

240251001 Edgewood Harford MD 13.63 -2.50

240259001 Aldino Harford MD 12.35 -4.29

Table 13-4: Individual Site Statistics for 8-hr Ozone Using 60 ppb Cutoff

AIRS ID Site Name Jurisdiction State MNGE (%) MNB (%)

240030014 Davidsonville Anne Arundel MD 12.31 -9.14

240051007 Padonia Baltimore MD 10.11 -5.38

240053001 Essex Baltimore MD 15.80 1.39

240130001 South Carroll Carroll MD 10.02 -2.50

240251001 Edgewood Harford MD 14.06 -5.35

240259001 Aldino Harford MD 12.36 -7.12

Baltimore, MD

Non-Attainment Area Ozone Monitor

Figure 13-2: Locations of Ozon e Monitors in the Baltimore NAA

Baltimore Serious Area 8-Hour Ozone SIP Page 112The following statistics for the OTR domain have also been provi ded in Appendix F-12.

1. Archive file containing 8-hour average observed and predicte d ozone organized by state.

2. Observed and predicted composite diurnal variat ions of selected spec ies, including but not limited to ozone at SLAMS/NAMS sites; ozone at CASTNet and other sites; VOC species such as ethene, isoprene, and formaldehyde; and gas phase compounds such as CO, NO and

NO 2

.

3. Statistical evaluation of daily maximu m 8-hour ozone at SLAMS/NAMS sites and CASTNet/other sites; statistics are computed using two different thresholds for observed daily maximum ozone of 40 and 60 ppb. Statistics are computed by date (all sites on a given day) and by site (one site over all days).

4. Statistical evaluation of daily maximum 8- hour ozone at SLAMS/NAMS sites that fall

within non-attainment countie s; statistics are computed by non-attainment area.

5. Statistical evaluation of daily average CO, NO, NO 2 , and SO 2 at SLAMS/NAMS and other sites; statistics are comp uted by date and by site.

6. Statistical evaluation of daily average ethene, isoprene, and formaldehyde at SLAMS/NAMS and other sites; statistic s are computed by date and by site.

7. Plots of composite time series for daily max 8-hour ozone, root mean square error and mean bias for illustrative purposes.

8. Maps of daily 8-hour maximum predicted ozone across the modeling domain, compared

with actual observations.



### 13.3.3 Summary of Model Performance

The CMAQ model was employed to simulate ozone for the 2002 season (May through September). 25 A comparison of the temporal and spatia l distributions of ozone and its precursors was conducted for the study domain, with additiona l focus placed on performance in the Baltimore

NAA.

The CMAQ model performance for surface ozone is quite good with low bias and error. Model performance is generally consistent from day to day. The results of the 2002 ozone season show that the modeling system tends to over-predict mi nimum concentrations and slightly under-predict peak concentrations. Th e over-prediction of minimum concentr ations is not of great regulatory concern since attainment tests are based on the app lication of relative respons e factors to daily peak

concentrations. Prediction of minimum concentrations, though, is still important to appropriately model regional transport and nighttime ozone rem oval processes in order to accurately estimate peak concentrations.

The model performance for the Baltimore NAA averag ed over all stations and all days meets the guidelines suggested by EPA. Appl ying those criteria to individual days is a much more stringent

25 Note that the Maryland ozone season changed to April through October, in 2004; see 40 CFR 58, Appendix D, Table

D-3.

Baltimore Serious Area 8-Hour Ozone SIP Page 113test that is not required by EPA. If, however, those long-term average stan dards are applied to daily performance, those criteria for acceptable model pe rformance are met on most individual days as

well.

No significant differences in model performance for ozone and its precursors were encountered

across different areas of the OTR. While there ar e some differences in the spatial data among subregions, there is nothing to suggest a tendency for the model to res pond in a systematically different manner between regions. Examination of the statistical metrics by sub-region confirms the absence of significant performance problems arising in one area but not in an other, building confidence that the CMAQ modeling system is operating co nsistently across the full OTR domain.

The evaluations discussed above show that the modeling system is doing a good job of appropriately estimating 8-hour average surface ozone throughout the OTR and in the Baltimore NAA. This confidence in the modeling results allows the modeling system to be used to support the development of emissions control scenarios a nd, more generally, the Ba ltimore NAA 8-hour Ozone

SIP.

Also, as stated previously, the model performance for the 2002 ozone season meets all EPA guidelines and thus demonstrates that the modeling platform is a ppropriate for modeling emissions

controls scenarios for the Baltimore NAA SIP. At the same time it must be remembered that CMAQ has been evaluated by using measures that re flect its ability to repr esent average conditions instead of its ability to respond to changes in emissions. Thus it is likely that although CMAQ has met the traditional performance m easures as stated in EPA guidan ce, it may in fact under-predict the magnitude of ozone changes resulting from the modeling of various control measures. This means future year (i.e., 2012) mode ling results should be viewed not in the traditional sense as being exact, but should be s een as an upper limit.



### 13.4 ATTAINMENT DEMONSTRATION

13.4.1 Overview

The 8-hour ozone standard attainment demonstra tion analyzes the potent ial of the Baltimore NAA

to achieve attainment of the 8-hour ozone standard. The demonstration of the achievement of the 8-

hour ozone standard is based on both the CMAQ modeling results and a number of weight-ofevidence analyses (provided in Chapter 14) that support the attainment mode ling results. Details of the CMAQ modeling are provided in the following sections.



### 13.4.2 Modeling Attainment Test

The modeled attainment test applied at each mon itor was performed using the following equation:

(DVF) I = (RRF) I (DVB) I

Baltimore Serious Area 8-Hour Ozone SIP Page 114Where:

(DVB) I = the baseline concentration monitored at site I, in ppb (RRF) I = the relative response factor , calculated near site I (DVF) I = the estimated future design value, in ppb, for the time attainment is required.

The future design value for each monitor in the Ba ltimore NAA is provided in Table 13-5 and in Figure 13-3.

Table 13-5: Modeling Attainment Test Us ing EPA Preferred Methodology

AIRS ID Site Name County State DVB RRF DVF

240030014 Davidsonville Anne Arundel MD 98.0 0.797 78

240051007 Padonia Baltimore MD 88.7 0.816 72

240053001 Essex Baltimore MD 91.3 0.838 76

240130001 South Carroll Carroll MD 88.7 0.816 72

240251001 Edgewood Harford MD 100.3 0.804 80

240259001 Aldino Harford MD 97.0 0.793 76

Baltimore Serious Area 8-Hour Ozone SIP Page 115Figure 13-3: Baltimore NAA 8-Hour Ozo ne Base Year (2002) and Future Year (2012) Design

Values

Current design values were calculated using the EPA approved method of averaging the three design value periods that include the baseline inventory year. Sp ecifically, the average design value was calculated using the 2000- 2002, 2001-2003, and 2002-2004 periods.

In the event that there were less than five years of available data at a monitoring site the following procedure was used:

1. 3 years of data - The current design value was ba sed on a single design value.

2. 4 years of data - The current design value was based on an average of two design value periods.

3. Less than 3 years of data – The site was not used in the attainment test.

A 3x3 array of grid cells surrounding each monitor wa s used in the modeled attainment test as recommended by EPA for 12 km grid reso lution modeling to calculate RRFs.

Baltimore Serious Area 8-Hour Ozone SIP Page 116The predicted 8-hour daily maximum ozone concentr ations from each modeled day were used in the modeled attainment test, with the nearby grid cel l with the highest predic ted 8-hour daily maximum

ozone concentration with baseline emissions for each day considered in the test, and the grid cell with the highest predicted 8-hour daily maximum oz one concentration with the future emissions for each day in the test.

The RRFs used in the modeled attainment test were computed by taking the ratio of the mean of the 8-hour daily maximum predictions in the future , to the mean of the 8-hour daily maximum predictions with baseline em issions, over all relevant days, as defined below.

The following rules were applied to determine th e number of days and the minimum threshold at

each ozone monitor:

1. If there were 10 or more days with daily maximum 8-hour average modeled ozone > 85 ppb, an 85 ppb threshold was used.

2. If there were less than 10 days with da ily maximum 8-hour average modeled ozone > 85 ppb, the threshold was reduced in 1 ppb increm ents to as low as 70 ppb, until there were 10 days in the mean RRF calculation.

3. If there were less than 10 days but more th an 5 days with daily maximum 8-hour average modeled ozone > 70 ppb, then all days > 70 ppb were used.

4. No RRF calculations were performed fo r sites with less than 5 days > 70 ppb.

Provided in Appendix F-13 is additional information on the RRF and the modeled attainment test.



### 13.4.3 Unmonitored Area Analysis

An “unmonitored area analysis” using model adjusted spatial fields was perf ormed. The basic steps of this process were as follows:

1. Interpolated ambient ozone design value da ta to create a set of spatial fields.

2. Adjusted the spatial fields using gridded m odel output gradients (base year values).

3. Applied gridded model RRFs to th e model adjusted spatial fields.

4. Determined if any unmonitored areas are predicted to exceed the NAAQS in the

future.

Recommended EPA guidance was utilized in the unmonitored area analysis.

Provided in Figure 13-4 is a map showing the spatia lly interpolated extent of 8-hour ozone above the NAAQS in the Baltimore NAA based on a future case (2012) modeling simulation.

Baltimore Serious Area 8-Hour Ozone SIP Page 1172012 Predicted 8-Hour Ozone Desi g n Value (pp b )

Figure 13-4: Spatially Interpolated Extent of the 8-Hour Ozo ne in the Baltimore NAA Using Predicted 2012 Design Values

In Figure 13-4 the clear areas wi thin the Baltimore NAA indicate th e areas that will be below the 8- hour NAAQS of 85 ppb. Figure 13-4 clearly demonstrat es that all areas with in the Baltimore NAA are predicted to be in attainment of the 8-hour ozone NAAQS by 2012.



### 13.4.4 Emissions Inventories

For areas with an attainment date of no later th an June 15, 2013, the emission reductions need to be implemented no later than the beginning of the 2012 ozone season. A determination of attainment will likely be based on air quality monitoring data collected in 2010, 2011, and 2012. Therefore, the year to project future emissions should be no late r than the last year of the three-year monitoring period; in this case, 2012.

Baltimore Serious Area 8-Hour Ozone SIP Page 118The 2002 base year emissions inventory was project ed to 2012 using standa rd emissions projection techniques discussed previous ly and in Appendix F-14. Th e 2012 inventories developed by

MANE-VU were used in the attainment demonstration.

Emission inventory guidance documen ts were followed for developi ng projection year inventories for point, area, mobile, and biogenic emissions. Thes e procedures addressed pr ojections of spatial, temporal, and chemical composition change be tween the base year and projection year.

The OTC selected several control strategies for ev aluation in the attainment demonstration. These were selected from groups of strategies devel oped by the technical subco mmittees responsible for identifying and developing the regula tions and/or control measures.

Consideration was given to maintaining consistency with control measures likely to be implemented in other RPOs. Technology-based emission reduc tion requirements mandated by the Clean Air Act were also included in project ing future year emissions.

Provided in Appendix F-14 is additional information on the emissions used in future year modeling.



### 13.4.5 Summary and Conclusions of Attainment Demonstration

The results of the future year (2012) modeling simulation indicate that the maximum 8-hour ozone design value for the Baltimore NAA will be in th e range of 80 ppb at the Edgewood, MD ozone

monitor. This translates into an 8-hour ozone design value re duction of approximately 20 ppb from 2002 to 2012. The significance of 80 ppb is that it falls below 82 ppb; according to EPA guidance, this means that only a basic supplemental analyses should be completed to confirm the outcome of

the modeled attainment test that the future year (2012) design va lue will be less than the 8-hour ozone NAAQS.

The weight-of-evidence demonstrati on (Chapter 14) is meant to be a basic supplemental analysis that when combined with the modeling demonstrati on, presents significant evidence that the future year (2012) design value for the Baltimore NAA will be well below th e 8-hour ozone NAAQS.

Presented in Figures 13-5 and 13-6 are two ma ps of the Baltimore NAA 8-hour ozone design values, for 2002 (the base year), and the predicte d 8-hour ozone design values for the future year 2012, respectively. In each map of the Baltimore NAA, clear areas have 8-hour ozone design values below the NAAQS and the colored areas have design values that are equal to or exceed the 8-hour ozone NAAQS. These two design value maps clearly demonstrate the trend of improved air quality through 2012 and attainment of the 8-hour ozone NAAQS for the Baltimore region.

Presented in Figure 13-7 are the 2002 8-hour ozone design values and the predicted 8-hour ozone design values for future year 2012 for each ozone monitor in the Baltimore NAA. These design values demonstrate that the trend of improved air quality continues into 2012 and attainment of the 8-hour ozone NAAQS.

Baltimore Serious Area 8-Hour Ozone SIP Page 119Based on a combination of the future year ( 2012) modeling simulation results and the basic supplemental weight-of-evidence (Chapter 14) analyses there is over whelming evidence to

demonstrate that the Baltimore NAA will attain the 8-hour ozone NAAQS by June 15, 2013.

Figure 13-5: Spatially Interpolated Extent of the 8-Hour Ozo ne Within the Baltimore NAA Using 2002 Base Year Design Values

Baltimore Serious Area 8-Hour Ozone SIP Page 120Figure 13-6: Spatially Interpolated Extent of the 8-Hour Ozone Within the Baltimore NAA Using 2012 Predicted Future Year Design Values

Baltimore Serious Area 8-Hour Ozone SIP Page 121Figure 13-7: Baltimore NAA 8-Hour Ozone Base Year (2002) and Predicted Future Year (2012) Design Values

Baltimore Serious Area 8-Hour Ozone SIP Page 122

### 13.5 PROCEDURAL REQUIREMENTS

13.5.1 Reporting

Documents, technical memorandums, and data base s developed in this st udy are available for distribution as appropriate. This report contains the essential met hods and results of the conceptual model, episode selection, m odeling protocol, base case model development and performance testing, future year and control strategy modeling, quality assurance, weight of evidence analyses (Chapter 14), and calculation of 8-hr ozone attainment via EPA’ s relative response factor (RRF) methodology.



### 13.5.2 Data Archival and Tran sfer of Modeling Files

All relevant data sets, model code s, scripts, and related software required by any project participant necessary to corroborate the study findings (e.g., performance evalua tions and control strategy runs) will be provided in an electronic format a pproved by the OTC Modeling Committee within the framework of the OTC. The OTC Modeling Committ ee has archived all modeling data relevant to this project. Transfer of data may be facilitated through the comb ination of a project website and the transfer of large databases via overnight mail. Database transfers will be accomplished using an ftp protocol for smaller datasets, a nd the use of IDE and Firewire disk drives for larger data sets.

Baltimore Serious Area 8-Hour Ozone SIP Page 123GENERAL REFERENCES

Ryan, W.F., Piety, C. (2002) Summary of 2002 Pollution Episodes in the Mid-Atlantic . The Pennsylvania State University Department of Meteorology, State College, Pennsylvania and the University of Maryland Department of Meteorology, College Park, Maryland.

Stoeckenius, T., Kemball-Cook, S. (2005) Ozone Episode Classification Project for Ozone Transport Commission (Task 2b), ENVIRON International Corporation, Novato, California.

Moo, N. and D. Byun (2004) A Simple User’s Guide For “geos2cmaq” Code: Linking CMAQ with

GEOS-CHEM. Version 1.0. Institute for Mu ltidimensional Air Quality Studies (IMAQS)

. University of Houston, Houston, Texas.

Baker, K. (2005) http://www.ladco.org/tech /photo/present/ozone.pdf

EPA GUIDANCE DOCUMENTS

Guidance on the Use of Models and Other Analyses for Demonstrating Attainm ent of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (Draft 3.2- September 2006) . U.S. Environmental Protection Agency, Research Triangle Park, North Carolina.

Baltimore Serious Area 8-Hour Ozone SIP Page 124

## 14.0 WEIGHT OF EVIDENCE ATTAINMENT DEMONSTRATION

The approach that MDE has taken to Maryland’s weight of evidence attain ment demonstration is that of supplemental data analys is and modeling. These technique s provide a favorable indication that the Baltimore NAA will successfully attain the 8-hour ozone NAAQS in 2012.



### 14.1 AMBIENT AIR MONITORING ME ASUREMENTS AND TRENDS

Measurements from surface monitoring stations pr ovide the most fundament al indication of air quality improvement in the Baltimore NAA. Basic tr ends of ozone from the network of monitors show continuously improving air quality in Mary land and the Baltimore NAA with respect to multiyear design values, annual exce edance day counts, 24-hour daily pe ak concentrations, single-hour concentrations, warm weather days when ozone is usually highest, and finally ozone precursor

trends.



### 14.1.1 The Ambient Monitoring Network

MDE operates a relatively dense network of oz one monitoring stations, which has enabled the collection of high resolution ozone data on various scales of time and space. Figure 14-1 shows maps of the ambient ozone monitoring network fo r Maryland, the Mid-Atlantic, and the Eastern U.S. Comparing the spatial dens ity of monitoring sites on a wi der domain of the Mid-Atlantic region shows that Maryland has no large expanses w ithout monitors, like Vi rginia, West Virginia, and Pennsylvania. An even larger perspective over the entire eastern U.S. reveals that Maryland is covered by one of the more dense monitoring networ ks due to the required monitoring associated with the cluster of large metr opolitan areas extending from Richmond, VA through New York, NY.

The Code of Federal Regulations requires four ozone sites for a metr opolitan statistical area of greater than 10 million people for an 8-hour oz one non-attainment area (40 CFR 58 Appendix D §4.1). MDE currently has seven ozone sites deploy ed in the Baltimore NAA, which is currently classified by EPA to be in “moderate” non-attainment . Due to logistical reasons, slight changes are made in the deployment of sites over the years, such as the unavoidable relocation of the Fort Meade monitoring site due to the U.S. military’s need for additional space on the grounds of the Fort Meade military post. MDE was fortunate to find a new location for the site at Beltsville, where interagency collaborations and oppor tunities for long-term studies ar e more viable. In addition, a site was located in Baltimore City at the Furley Elementary School Recreational Center in August 2006. On the whole, the number of site s has remained relatively constant.

Baltimore Serious Area 8-Hour Ozone SIP Page 125Panel A – Maryland Ozone Network

Panel B – Mid-Atlantic Oz one Network Panel C – East ern U.S. Ozone Network

Figure 14-1: Maps of the 2012 Ozone Monitoring Sites

There are 17 ozone monitoring sites in the state of Maryland, a dense network for a relatively small

state.

Baltimore Serious Area 8-Hour Ozone SIP Page 126

### 14.1.2 Ozone Trends

Ozone concentrations exhibit an improving air quali ty trend on multiple temporal scales. Perhaps the simplest regulatory measure of improving air quality is the downward trend in 8-hour ozone design values for the sites in Maryland. Design values offer the benefit of a multi-year metric,

which removes the statistical bias of single high values by taking th e fourth highest value of three consecutive years and averaging those values togeth er. Figure 14-2 displays the decreasing trend of 8-hour ozone design values in Maryland. The trend is a good fit to the data with an R 2 of ~0.6 and a slope of -0.8 ppb / year. The decrease in ozone design values between 2003 and 2004 reflects the disproportionate benefit of the NO

x SIP Call, as this is when the majority of regional NOx controls were put in place on electric generating units (E GU’s). This trend of decreasing ozone design values is expected to conti nue through 2012, as the Maryland Healthy Air Act (HAA), the first phase of which started in 2009, will significantly reduce Maryland EGU NO

x and SO 2 emissions.

112
109 113113 112 114

109 119 132

125

115

107 105 110
107 110
107 106 104 103

95

91 93 94

91

87 106 107

103 104 y = -0.8492x + 119.93

R

2 = 0.5728

85 95 105 115 125 1351980198219841986198819901992199419961998200020022004200620088-Hour Ozone Design Value (ppb)

Figure 14-2: Trend in 8-hour Ozone Design Values per Year for all Maryland Sites

The downward trend in 8-hour ozone concentrations on an annual basis is highlighted in Figure 14- 3 by showing the number of 8-hour ozone exceedance da ys per year. This tr end is also a good fit

with an R 2 of ~0.5 and a steeper declining slope of –1.4 days/year. Since 2002, an average of approximately 16 days per year, or approximate ly 2 weeks, have experienced 8-hour ozone

concentrations  85ppb; this is a sharp contrast to the 2 months’ worth of exceedance days which

existed in the 1980s.

Baltimore Serious Area 8-Hour Ozone SIP Page 1274646 67

41 54 52 55 59

30 33 54

25 55

43 42

33 35 54

45

20 29 41

11 10 28

20 26

15

3

y = -1.4355x + 59.933

R 2 = 0.5532

0 10 20 30 40 50 60 70 8019821984198619881990199219941996199820002002200420062008Number of Days

Figure 14-3: Trend in 8-hour Ozone Exceedance Days per Year for all Maryland Sites

The declining trend is an indi cator of improving air quality.

The temporal scale trend next reviewed is the da ily scale. Average daily peak 8-hour ozone is shown in Figure 14-4. In order to show a clearer picture of the trends without the noise of shortterm fluctuations, the data are grouped in four-year bins. Th e methodology of choosing bins is carried out in reverse chronological order, beginning with the first four-year bin, 2006-2009. The

scientific consensus is that ozone concentrations in the eastern U.S., outside of large urban areas,

are NO

x -limited. 26 As a result, reductions in region-wide NO

x emissions (NO

x SIP Call) should reduce the overall background ozone concentrations. Local emissions and photochemistry will still lead to short-term spikes in ozone, often  85 ppb, but these spikes will occur on top of a lower base-level of ozone. The magnitude of each indi vidual ozone spike should also have a reduced amplitude from the base-level. Such a change in the base-level of ozone was created by the NO

x SIP Call and is demonstrated in Figure 14-4.

26 Ryan, W.F., “Local Ozone Forecasting and the NOx SIP Call Rule”, EPA Nationa l Air Quality Conference, Orlando, FL, 2007.

Baltimore Serious Area 8-Hour Ozone SIP Page 1280 20 40 60 80 100 120

Feb Mar Apr May Jun Jul Aug Sep Oct Nov8-hour Ozone (ppb).

1990-1993 1994-1997 1998-2001

2002-2005 2006-2009

Figure 14-4: Trends in Average Daily Peak 8-hour Ozone for all Maryland Sites Binned by Four-year Periods

The red arrow indicates improving air quality sh own by the decreasing trend of average daily peak 8-hour ozone. The solid lines are monthly averages.

Continuing in reverse chronological or der, each of the prior bins also consisted of a four-year period for the sake of consistency. The most important feature of Figure 14-4 is the steady decline in the trend of each bin, indicated by the red arrow. The part of the summer when peak ozone concentrations occur (June-August) is exactly when the greatest benefit is seen with reductions in the daily peak 8-hour ozone. The improving tr end in 1998-2001 is partially due to meteorology

because the summers of 2000 and 2001 were not conducive to photochemical formation. Temperatures were cooler than normal, precipit ation was more prevalent, and the synoptic scale systems rarely created long-lived high pressure ce nters over the southeaste rn U.S. which typically plays a large role in high ozone episodes. Th e improving trend in 2002-2005 shows another marked decrease in ozone values, a sign of the valuable impact of the NO

x SIP Call.

Not only have ozone concentrations been steadily declining during the pa rt of the summer when ozone production is greatest, but ozone concentrati ons have also been stead ily declining during the part of each day when ozone production is greate st. Being a photochemical pollutant, ambient ozone reaches its peak concentrations during the afternoon when the s un angle is high and temperatures are at their warmest. Figure 14-5 shows the diurnal trend in ozone from 1993 to 2009. The years are binned by 3-year rolling averages in order to eliminate the noise of hourly fluctuations present in the raw data. The stea dy progression from each rolling average to the next shows an improvement of air quality. The red arro w indicates the decline of ozone concentrations.

Baltimore Serious Area 8-Hour Ozone SIP Page 129The last three rolling averages experienced a distin ct decline in magnitude of hourly ozone after the

NO

x SIP Call.

The red arrow indicates improving air quality sh own by the decreasing trend of peak mid-day hourly concentrations.

Figure 14-5: Trend in Diurnal Ozone by 3-year Rolling Averages for All Maryland Sites from the Summers (April 1 – October 31) of 1993 through 2009

The approach to trends thus far has focused enti rely on the ozone concentrations themselves. A more comprehensive look at ozone trends must al so consider meteorology a nd precursors. Ozone is a photochemical pollutant and as such, it is high ly dependent upon meteorol ogical conditions.



### 14.1.3 Temperature Adjusted Ozone Trend

The data shown in Figure 14-6 provide insight into the trend of 8-hour ozone with respect to

temperature.

Baltimore Serious Area 8-Hour Ozone SIP Page 130y = -1.3389x + 28.63

R 2 = 0.6955

0 10 20 30 40 50 60 7019821984198619881990199219941996199820002002200420062008Number of Days.

-30 -20 -10 0 10 20 30 40Difference.

Number of Days greater than or equal to 90 Degrees F at BWI

Number of 8-hour Ozone Exceedence Days in Maryland

Difference (Number of Exceedence Days - Number of 90 Degree Days)

Linear Trend of Difference y = -1.3389x + 28.63

R 2 = 0.6955

0 10 20 30 40 50 60 7019821984198619881990199219941996199820002002200420062008Number of Days.

-30 -20 -10 0 10 20 30 40Difference.

Number of Days greater than or equal to 90 Degrees F at BWI

Number of 8-hour Ozone Exceedence Days in Maryland

Difference (Number of Exceedence Days - Number of 90 Degree Days)

Linear Trend of Difference

Figure 14-6: Maryland Air Quality: Days above 90  F and Ozone Exceedances, 1982-2008

Improving air quality in Maryland is shown by th e downward linear trend (black line) of the difference between (blue line) the number of 8-hour ozone exceedance days per year (green bars) and the number of days with a daily maximum temperature > 90°F per year at BWI (red bars). The time period is 1981-2009.

Temperature is the single strongest environmental predictor of ozone concentrations; as such there has historically been a strong co rrelation between the number of 8-hour ozone exceedance days per year and the number of days w ith a daily maximum temperature > 90  F per year at BWI. In fact, in the early 1980’s the number of ozone exceedance days was typically double the number of 90  F days. This statistic has steadily changed, though, so that in 2006 the ra tio was the exact opposite

with the number of 90  F days double the number of exceedance days. The trend in the difference between the two counts (black line) has an R 2 of approximately 0.7 and a downward slope of –1.3. Despite stable numbers of 90  F days, ambient ozone concentrations continue to experience a downward trend reflecting impr ovements in air quality.

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### 14.1.4 Ambient Ozone Precursor Trend

As described in Chapter 2, the precursors to ozone formation include VOCs and NO

x . VOCs are somewhat difficult to depict in term s of simple trends because the li st of VOCs is very large. MDE collects 56 species of VOCs as part of the P hotochemical Assessment Monitoring Sites (PAMS) network and a separate list (with some overlap ) of 61 Toxic VOCs. VOC measurements have uniformly experienced declines in concentrations since 1994 due to the reformulated gasoline rule and hydrocarbon reductions for ozone. They have al so received some asso ciated benefits from restrictions on CFC (chlorofluoroc arbon) emissions since the 1990s. NO

x on the other hand, is more simply analyzed and it is widely av ailable. A given percent reduction of NO

x should result in an equal percent reduction of ozone. NO

x is measured by the same trace gas instrumentation used to simultaneously measure ambient NO and NO 2 . NO 2 is commonly measured to show compliance

with the NO 2 NAAQS. Figure 14-7 displays the decreasing trend of NOx for the Baltimore NAA

since 1993.

0 10 20 30 40 50 60 70 80

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23



## Hour (EST)NOx (ppb)

1993-1995 1994-1996 1995-1997 1996-1998 1997-1999 1998-2000 1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 2005-2007 2006-2008 2007-2009

Figure 14-7: Trend in Diurnal NOx by 3-ye ar Rolling Averages for All Sites in Maryland during the Summers (April 1 – October 31) of 1993 through 2009

Instrument calibration occurs during the data gap at 2:00 AM Eastern Standard Time (EST).

Baltimore Serious Area 8-Hour Ozone SIP Page 132

### 14.1.5 Supplemental Modeling

On July 6, 2011, the EPA released the final version of the Transport Rule, also know as the CrossState Air Pollution Rule (CSAPR). The CAMx air quality model runs for the rule were documented

in the Air Quality Modeling Final Rule Technical Support Document (June 2011), and can be found

here: http://www.epa.gov/airtransport/pdfs/AQModeling.pdf

.

The CSAPR modeling was performed for several emissions cases:

1. 2005 base year,

2. 2012 “no CAIR” case,

3. 2014 “no CAIR or CSAPR” case, and

4. 2014 “with CSAPR” case.

The 2005 average design value (Avg DV) was calcula ted by using a five-year weighted average of the three 3-year averages (2003–2005, 2004–2006, and 2005–2007) and was used to determine

whether a monitor was in nonattainment for the CSAPR.

Based on the 2012 and 2014 modeling results, all mon itors within the Baltimore NAA demonstrated compliance with the 1997 8-hour ozone NAAQS. Th e CSAPR modeling results are shown in Table

14-1.

Table 14-1 CSAPR Average Design Value M odeling Results for Baltimore NAA Monitors

Monitor ID 2012

“without CAIR” (ppb) 2014

“without CAIR or

CSAPR”

(ppb) 2014

“with

CSAPR”

(ppb) Edgewood 240251001 84.4 82.5 82.3

Davidsonville 240030014 78.6 77.6 77.3

Essex 240053001 78.7 77.3 77.1

South Carroll 240130001 74.2 72.2 72.0

Aldino 240259001 80.0 76.4 76.2

Padonia 240051007 70.0 68.3 68.2

Note: The Furley Elementary School Recreational Center (ID # 245100054) monitoring station was

established in 2006 and thus did not have enough data to calcula te an average 2005 ozone design

value and for that reason was not in cluded in this modeling analysis.

Based on the attainme nt demonstration modeling (see Chapter 13), the weight of evidence data analysis, and the supplemental mo deling that was completed, MDE is confident that the Baltimore

NAA will attain the 8-hour ozone NAAQS standard by June 15, 2013.

Baltimore Serious Area 8-Hour Ozone SIP Page 133