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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, Maryland.

The Hearing and Comment Period: The public hearing allowed public comment on a 

document prepared for the U.S. Environmental Protection Agency pertaining to the ozone (O3) 

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.

Statement: 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. Mary Jane Rutkowski served as the hearing officer.

Comments and Responses: The Department received oral comments at the hearing and one set 

of written comments in more than 1,170 emails, from the Sierra Club. The comments and 

responses are summarized below. A copy of the comment email and materials submitted at the 

hearing are included in this 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 

vehicular emissions and to establish health-protective emission limits for the 

Baltimore-area coal plants.

Response: MDE thanks the commenter(s) for expressing their concern for air quality issues 

within the Baltimore area. MDE agrees with the commenter(s) on the need for 

healthy air for the citizens of Maryland. 
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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 measures implemented to continue progress 

and achieve the 0.08 ppm 8-hour ozone standard in the Baltimore nonattainment 

area. This SIP addresses the requirements imposed on the Baltimore 

Nonattainment Area by the U.S. EPA in 76 FR 54412 when the area was 

reclassified to a serious ozone nonattainment area. As such, it fully conforms to 

all current EPA guidance and regulatory requirements.

Maryland, by law, is prohibited from establishing motor vehicle standards and 

fuel standards under 42 U.S.C.A. 7543. Maryland is one of fifteen states to 

proactively adopt the California Clean Car Standard, pursuant to CAA section 177 

(42 U.S.C.A 7507), which establishes a limited exemption to the preemption of 

state mobile source regulations. The California Clean Car Standard is a state-ofthe-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 technologies 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.