MDE 

MARYLAND DEPARTMENT OF THE ENVIRONMENT 

1800 Washington Boulevard. Baltimore MD 21230 

410-537-3000. 1-800-633-6101 

Martin O'Malley 

Governor 

Anthony G. Brown 

Lieutenant Governor 

Linda C. Janey, J.D., Manager 

Clearinghouse Review Unit 

Maryland State Clearinghouse for 

Intergovernmental Assistance 

Maryland Office of Planning 

301 West Preston Street 

Baltimore MD 21201 

Dear Ms. Janey: 

APR 19 axl7 

Shari T. Wilson 

Secretary 

Robert M. Summers, Ph.D. 

Deputy Secretary 

I am enclosing a copy of the Executive Summary of the Baltimore Nonattainment Area 8-Hour 

Ozone State Implementation Plan and Base Year Inventory. These documents provide information 

required to show why the Baltimore region will reduce pollution and meet the federal ozone standard by 

June 15, 2010, which is the designated attainment date for the Baltimore region. 

Based on the large size of the printed document, the entire document may be viewed at the website 

link below: 

http://www.mde.state.md.uslPrograms/ AirPrograms/air planning/index. asp 

A public hearing on the document will be held on May 22, 2007. The official close of the 

comment period occurs at the end of business hours on May 22, 2007. 

The hearing will be held as required by federal law (Clean Air Act at 42 U.S.C .. 7410 (a) and. 40 

CFR 51.102). If you have any comments related to this document, please call me at (410) 537-3240. 

Enclosure 

~ Recycled Paper 

Sincerely, 

Brian J. Hug, Deputy Program Manager 

Air Quality Planning Program 

Air and Radiation Management Administration 

www.mde.state.md.us TTY Users 1·800·735·2258 

Via Maryland Relay Service 
MARYLAND DEPARTMENT OF THE ENVIRONMENT 

MDE 

Martin O'Malley 

Governor 

Anthony Brown 

Lt. Governor 

1800 Washington Boulevard. Baltimore MD 21230 

410-537-3000 • 1-800-633-6101 

Baltimore Nonattainment Area 

8-Hour Ozone 

State Implementation Plan 

and Base Year Inventory 

SIP Number: 07-04 

June 15,2007 

Prepared for: 

U .8. Environmental Protection Agency 

Prepared by: 

Maryland Department of the Environment 

MDE 

Page 1 

Shari T. Wilson 

Secretary 

Robert M. Summers, Ph.D. 

Deputy Secretary 
1.0 Executive Summary 

Introduction 

Ground level ozone is considered a significant health based pollutant and the US 

Environmental Protection Agency (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 under the federal Clean Air Act. Areas of the county 

that monitor air pollution above the federal standard are designated "non attainment" 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 meets the federal standards. 

The Baltimore region, which comprises Baltimore City 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 explains the 

process by which the region will reduce pollution and meet the federal ozone standard by 

June 15,2010, which is the designated attainment date for the Baltimore region. 

This is a substantial good news story regarding Maryland's improving air quality. The 

Maryland Department of the Environment (MDE) is very proud of this SIP document as 

it shows, based on significant analysis, that the region will indeed attain the ozone 

standard. 

Emissions 

A significant portion of this document is related to emissions. Nitrogen Oxides (NOx) 

and Volatile Organic Compounds (VOC) emissions create ozone under heat and sunlight. 

Reductions in these precursor emissions are a necessity to reduce ozone pollution. The 

MDE is responsible for creating an emissions inventory for NOx and VOC that estimates 

the actual emissions created by all the different emission sources in our state. Emissions 

come from a variety of sources including mobile sources like cars and trucks, point 

sources like power plants, area sources like lawnmowers, and non-road sources like 

construction equipment and all terrain vehicles. 

This document details the current emission inventory for NOx and VOC and predicted 

emissions for the future. It is important to predict emissions in the future to track 

progress from emission reduction programs and for incorporation into attainment 

analyses that predict whether a region will meet the air quality standard or not. 

The good news exhibited by this document is that NOx and VOC emissions are going 

down in the Baltimore region. Control programs aimed at reducing emissions have been 

developed and implemented and the reductions required by these programs are 

significant. Population growth, economic growth, and the public need tend to tax the 

emission reductions that come from control programs. Despite these obstacles, the 

overall trend in ozone forming emissions is downward and MDE predicts that with 

additional reductions will come even cleaner air. 

Page 8 
Control Programs 

Over the past several decades the MDE has adopted and implemented numerous control 

programs (laws, regulations, voluntary measures) that reduce NOx and VOC emissions in 

Maryland. In addition, several new control measures are being adopted specifically to 

help Maryland attain the federal ozone standard. The 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 significantly reduces NOx from Maryland older coal burning power plants. The 

HAA is more stringent that the parallel federal rule called the Clean Air Interstate Rule 

and is the most substantial emission control program ever adopted in Maryland. The 

HAA is the most aggressive power plant control program on the east coast. Overall, the 

HAA will reduce Maryland power plant NOx emissions by 70% (compared to 2002 

levels) in 2009 and by 75% by 2012. The 2009 reductions are a significant part of the 

attainment scheme developed by the MDE to meet the federal ozone standard. 

Addition control programs being implemented to help Maryland meet the federal ozone 

standard include several VOC rules targeted at adhesives and sealants, lower VOC 

portable fuel containers, and lower VOC consumer products. Other non-traditional 

measures include an aggressive telework program 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. 

Control Measures Summary* 

2009 

VOC NOx 

Control Measure (tpd) (tpd) 

On-road Mobile Measures 44.32 67.82 

Consumer Products Phase 1 3.72 0.00 

Consumer Products Phase 2 0.45 0.00 

Low VOC Paints (Architectural and Maintenance 

Coatings - AIM) 6.09 0.00 

Portable Fuel Containers Phase 1 8.20 0.00 

Portable Fuel Containers Phase 2 0.59 0.00 

Industrial Adhesives Rule 2.57 0.00 

Nonroad Measures 20.89 8.47 

Railroads (Tier 2 Engine Standards) 0.00 1.16 

Maryland Healthy Air Act (HAA) 0.00 30.75 

Total 86.84 108.20 ., All control level totals are rounded 

Page 9 
Modeling 

A significant part of the attainment demonstration for Maryland consists of air quality 

modeling analysis. Required by the CAA, air quality models are run to examine what 

future air quality conditions will be and whether a region will attain the standard or not 

by their designated attainment date. The models are not relied upon as the only 

attainment test but are an important part of the attainment demonstration for Mary land. 

The air quality modeling analysis completed for this SIP shows the Baltimore 

N onattainment area attaining the 8-hour Ozone standard during the ozone season of 2009. 

All of the air quality monitors located in the nonattainment area are predicted to be at 

levels consistent with attainment (using a weight of evidence approach). 

Weight of Evidence 

As mentioned above air quality models are not the only tool available that can be used to 

predict attainment of the federal ozone standard. A weight of evidence approach can be 

used to further analyze air quality data, trends, meteorology, model performance and 

model chemistry. The MDE has developed a significant weight of evidence that the 

Baltimore Nonattainment area will indeed meet the federal ozone standard during the 

ozone season of 2009. 

Some of the weight of evidence analyses utilized for the Baltimore Nonattainment area 

includes: 

• an analysis of the chemistry component of the CMAQ air quality model 

• an analysis to the ozone sensitivity to NOx emission reductions 

• the effect of land-sea interactions on ozone at the Edgewood air quality monitor 

• an analysis of the regional nature of ozone transport 

• an analysis of the potential benefits of an aggressive telecommuting strategy 

• an analysis of the uncertainty in the CMAQ air quality model and the overprediction of ozone design values 

• an analysis of the effects of urban tree canopy cover on temperatures and ozone 

levels 

Based on all of the above analysis and the air quality modeling performed for the 

Baltimore Nonattainment area there is a dramatic weight of evidence available that shows 

the region will meet the 8-hour ozone standard during the 2009 ozone season. The chart 

below shows a summary of the ozone monitor design value ranges expected in the region 

based on the modeling/ weight of evidence analysis. All of the air quality monitors in the 

region are predicted to be well below the 85ppb 8-hour ozone standard. 

Page 10 
.c -

Q. 90 

Q. 

-II) 85 All sites attain the 85ppb NAAQS for 8-Hour Ozone 

::s 

~ 80 

c 

CJ 75 

'in 

70 II) 

Q I 

Monitoring Location 

I Range of 2009 8-Hour Ozone Design Values from Weight of Evidence 

Page 11