1 MARYLAND DEPARTMENT OF THE ENVIRONMENT

RESPONSE TO COMMENTS

for the

PUBLIC HEARING and SUBMISSIONS

Regarding:

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 for the Baltimore MD Nonattainment Area

Dates and Locations: A public hearing was held on July 19, 2013 at MDE Headquarters, 1800 Washington Boulevard, in Baltimore, Maryla nd.

The Hearing and Comment Period: The public hearing allowed public comment on a document prepared for the U.S. Environmental Prote ction Agency pertaining to the o zone (O 3 )

Serious Area Attainment Plan SIP for the 1997, 0.08 ppm , ozone National Ambient Air Quality Standard (NAAQS, or “ standard ”) . This SIP was released for public comment and review on June 20, 2013 . Prior to the hearing, the public was urged to express their concerns via the standard U.S. Postal Service mail or by email submission.

St atement: At the hearing, the Department’s statement was read into the record by Molly Berger

, Natural Resources Planner , who represented the Air Quality Planning Program of the Air and Radiation Management Administration. M ary Jane Rutkowski served as th e hearing officer.

Comments and Responses: The Department receive d oral comments at the hearing and one set
of written comments in more than 1,170 emails , from the S ierra Club

. The comments and responses are summarized below. A copy of the comment email and materials submitted at the hearing are included in th is section of this SIP. The transcript of the hearing is also included.

1. Comment: While the Maryland Healthy Air Act was an important step for cleaning up our air, as the Maryland Department of the Environment has recognized, the Act does not go far enough. In particular, additional emission reductions are needed from motor vehicles as well as from two of the state's largest sources of ozone

- causing pollution: the Crane and Wagner coal plants . The coal plants still lack the most

state

- of

- the

- art emission controls for ozone

- causing pollutants.

To protect my health, and the health of other members of the Baltimore community, I call on the Maryland Department of the Environment to address

vehicu lar emissions and to establish health

- protective emission limits for the

Baltimore

- area coal plants.

Response: MDE thanks the commenter(s) for expressing their concern for air quality issues within the Baltimore area. MDE agrees with the commenter(s) on the need for healthy air for the citizens of Maryland.2 As part of this SIP submission, Maryland has presented the control measures used to improve ozone levels substantially since passage of the Clean Air Act

Amendments as well as the additional measure s implemented to continue progress and achieve the 0.08 ppm 8

- hour ozone standard in the Baltimore nonattainment area. This SIP addresses the requirements imposed on the Baltimore Nonattainment Area by the U.S. EPA in 76 FR 54412 when the area was

reclas sified to a serious ozone nonattainment area. As such, it fully conforms to all current EPA guidance and regulatory requirements.

Maryland, by law, is prohibited from establishing motor vehicle standards and fuel standards under 42 U.S.C.A. 7543. Maryla nd is one of fifteen states to proactively adopt the California Clean Car Standard, pursuant to CAA section 177 (42 U.S.C.A 7507), which establishes a limited exemption to the preemption of state mobile source regulations. The California Clean Car Standar d is a state

- of

the

- art program that increases automobile fuel efficiency and cuts pollution from our cars and light trucks. The program has the backing and support of the

Environmental Defense Fund as well as the Sierra Club. The State has also adopted California Low Emission Vehicle (Cal LEV) standards, which are more stringent than federal regulations.

All of the coal

- fired electric generating units within the Baltimore Nonattainment Area are equipped with NOX controls. A variety of control techno logies can be employed to control NOX emissions from coal

- fired units. These include (ranging from least effective to most effective): uncontrolled, boiler tuning and maintenance, combustion modifications (over

- fired air, low NOX burners),

selective auto

- catalytic reduction (SACR), selective non

- catalytic reduction (SNCR), and selective catalytic reduction (SCR). All of the coal

- fired electric generating units within the Baltimore Nonattainment Area utilize a combination of controls and are equipped with a minimum of a SNCR level of control.

MDE has been designated as a moderate nonattainment area under the 75 ppb 8

- hour ozone and continues to implement additional control programs and regulations that will be needed for the area to attain this new, more stringent standard. MDE will consider all sources, including electric generating units and vehicular emissions, when developing these strategies.