State Implementation Plan 

# PLAN TO IMPROVE AIR QUALITY IN THE WASHINGTON, DC-MD-VA REGION

May 23, 2007

State Implementation Plan (SIP) for 8-Hour Ozone Standard Prepared for: District of Columbia Department of Environment Maryland Department of the Environment Virginia Department of Environmental Quality on behalf of the Metropolitan Washington Air Quality Committee

METROPOLITAN WASHINGTON COUNCIL OF GOVERNMENTS Photos courtesy of EPAAlterna tive f o rm ats of this public atio n can be

m a de available for persons with disabilities. Phone: 202.962.3300 or 202-962.3213 (TDD) Em ail: acco mmodations@m wcog.or g

. For deta ils : www. mwco g.org

. For Virginia: Phone: (804) 698-4070 Em ail: abbanks@deq.virginia.govTABLE OF CONTENTS

1. EXECUTIVE SUMMARY

.............................................................................................. 1-1 1.1 Background

................................................................................................................ .. 1-3 1.2 The Ozone Problem

..................................................................................................... 1-4 1.3 The SIP Process

........................................................................................................... 1-5 1.4 Rate of Progress Demonstrated in Previous One-Hour Ozone SIPs

............................ 1-5 1.5 Base Year 2002 Em ission Inventor ies and Future Year 2008 and 2009.................1-6 1.6 2002-2008 Reasonable Further Progress Plan

............................................................. 1-7 1.7 Establishm ent of a Budget for Transportation Mobile E m issions

............................... 1-7 1.8 Attainm e nt Dem onstration

......................................................................................... 1-9 1.9 Analysis of Reasonably Availa ble Control Measures (RACM)

.................................. 1-9 1.10 Contingency Measures

................................................................................. ........ 1-10 1.11 Docum e nt Conte n ts

.................................................................................................. 1-10

2.0 INTRO DUCTION AND OVERVIEW

.......................................................................... 2-1 2.1 Clean Air Act Background........................................................................................... 2-1 2.2 8-hour Ozone Standard

................................................................................................ 2-2 2.3 SIP Requirem e nts for Modera te Nonattainm e nt Areas

............................................... 2-2 2.4 Rate of Progress Demonstr ated in Previous S I Ps

........................................................ 2-3 2.5 Com p arability of 8-hour Inventories to Previous State Implem entation Plans

........... 2-3 2.6 Sources of Ozone in the Metropolitan W a shington Region

........................................ 2-5 2.7 The Effects of Ozone

................................................................................................ 2-10 2.8 Frequency of Violation of Federal Health S t andard for Ozone

................................. 2-11 2.9 The Metropolitan W a shington A i r Quality C o mm ittee (MW A QC)

.......................... 2-12 2.10 Interstate Air Quality Council

.................................................................................. 2-13 2.11 State Comm it m e nt/Im p le m e nt ation Assurances

...................................................... 2-14 2.12 Subm ittal of the Plans

.............................................................................................. 2-14 2.13 Sanctions

................................................................................................................ .. 2-14 2.14 Reasonable Further Progress Requirem e nts

............................................................ 2-14 2.15 2009 Attainm e nt De m onstration

.............................................................................. 2-15 2.16 Analysis of Reasonably Availa ble Control Measures (R ACM)

.............................. 2-16 2.17 Contingency Measures

............................................................................................. 2-16

3.0 THE 2002 BASE-YEAR I NVENTORY

......................................................................... 3-1 3.1 Background and requirem e nts

..................................................................................... 3-1 3.2 Total E m issions by Source........................................................................................... 3-4 3.2.1 Point

................................................................................................................. ....... 3-4 3.2.2 Area

.................................................................................................................. ....... 3-4 3.2.3 Mobile

................................................................................................................ ..... 3-5 3.2.4 Nonroad...............................................................................................................

.... 3-6 3.2.5 Biogenic

.............................................................................................................. .... 3-7 3.3 Annual Inventories

........................................................................................................ 3 -7

4.0 THE 2008 AND 20 09 PROJECTED INVENTORIES

................................................. 4-1 4.1 Growth Projection Methodology

................................................................................. 4-2

ii4.1.1 Growth Projection Methodo logy for Point Sources: EGAS

................................... 4-2 4.1.2 Growth Projection Methodology: Area S ources

..................................................... 4-2 4.1.3 Growth Projection Met hodology: Nonroad Sources............................................... 4-5 4.1.4 Growth Projection Methodology: Onroad Sources................................................. 4-8 4.1.5 Biogenic Em ission Projections

............................................................................... 4-8 4.2 Offset Provisions and Point Source Growth

................................................................ 4-8 4.3 Actual vs. Allowable Em issions in Deve lopm ent of the 2008 and 2009 Projected Em issions Inventories....................................................................................................................

....... 4-9 4.4 Projection Inventory Results

........................................................................................ 4-9 4.5 Em ission Reductions from Control Measures

........................................................... 4-12 4.6 2008 Controlled E m issions for Reasonable Further Progress

................................... 4-14 4.7 2009 Controlled Em issions for Attainm e nt

................................................................ 4-15

5.0 2008 REASONABLE FURTH E R PROG RESS REQ U IREMENTS

.......................... 5-1 5.1 Introduction

.............................................................................................................. .... 5-1 5.1.1 Rate of Progress De m onstrated in Previous State Im plem entation Plans

................ 5-1 5.2 Guidance for Calculating Reasonable Further Progress (RFP) Em ission Target Levels

......................................................................................................................... ......... 5-2 5.2.1 2008 VOC and NOx Target L e vels

......................................................................... 5-3 5.2.2 Calculation of 2008 Target Levels

........................................................................... 5-3 5.3 Com p liance with 2008 Reasonable Further Progress Requirem e nts

........................... 5-6 5.4 Reasonable Further Progress Continge ncy E m ission Reduction Requirem ent

........... 5-7

6. CONTROL MEASURES

.................................................................................................. 6-1 6.1 Point Source Controls

................................................................................................... 6-2 6.2 Area Source Controls

.................................................................................................. 6-12 6.3 Nonroad Source Controls

............................................................................................ 6-39 6.4 On-road Source Controls

............................................................................................ 6-48 6.5 Voluntary Bundle

........................................................................................................ 6-5 7

7. REASO NABLY AVAILABLE CONTRO L MEASURES ( R ACM) ANALYSIS

....... 7-1 7.1 RACM Analysis

........................................................................................................... 7- 1 7.1.1 Analysis Overview and Criteria

............................................................................... 7-1 7.1.2 Im plem entation Date

................................................................................................ 7-2 7.1.3 Enforceability

......................................................................................................... .. 7-2 7.1.4 Technological Feasibility

......................................................................................... 7-2 7.1.5 Econom i c Feasibility and Cost Effectiveness

.......................................................... 7-3 7.1.6 Substantial and Widespread Adverse Im pacts

......................................................... 7-3 7.1.7 De Minim i s Threshold

............................................................................................. 7-3 7.1.8 Advancing Achievem ent of 84 ppb Standard

.......................................................... 7-4 7.1.9 Intensive and Costly Effort

...................................................................................... 7-4 7.2 RACM Measure Analysis

............................................................................................. 7-4 7.2.1 Analysis Methodology

............................................................................................. 7-4 7.2.2 Analysis Results

....................................................................................................... 7-5 7.3 RACM Determ ination

.................................................................................................. 7-5

iii8. MOBILE SOURCE CONFORMITY

.............................................................................. 8-1 8.1 Mobile Em issions Budget and the W a shington Area Transportation Confor mity Process

.................................................................................... 8-2 8.2 Budget Level for On-Road Mobile Source E m issions

............................................... 8-2 8.2.1 RFP Year Mobile Budgets

...................................................................................... 8-3 8.2.2 Attainm e nt Year Mobile Budgets

........................................................................... 8-3 8.2.3 Contingency Year Mobile Budgets

......................................................................... 8-4 8.3 Transportation Control Measures (TCMs) and TERMs

.............................................. 8-4 8.4 Trends in Mobile E m issions

........................................................................................ 8-5

9.0 MODERATE AREA PL AN COMMITMENTS

........................................................... 9-1 9.1 Schedules of Adopted Control Measures

..................................................................... 9-1 9.2 Stationary Source T h reshold Revisions

..................................................................... 9-12 9.3 New RACT Rules Applicability

................................................................................ 9-13 9.4 Revision of New Source Re view (NSR) Regulations

................................................ 9-14

10.0 ATTAINMENT DEMONSTRATION AND WEIGHT OF EVIDENCE

.............. 10-1 10.1 Modeling Study Overview: Background and Objectives

........................................ 10-1 10.1.1 Relationship to Regi onal Modeling Protocols

.................................................... 10-2 10.1.2 Conceptual Description

....................................................................................... 10-3 10.2 Dom a in and Database Issues

.................................................................................... 10-3 10.2.1 Episode Selection

................................................................................................ 10-3 10.2.2 Size of the Modeling Domain

............................................................................. 10-4 10.2.3 Horizontal Grid Size

........................................................................................... 10-4 10.2.4 Vertical Resolution

............................................................................................. 10-4 10.2.5 Initial and Boundary Conditions

......................................................................... 10-4 10.2.6 Meteorological Model Se lection and Configuration........................................... 10-5 10.2.7 Emissions Model Sele ction and Configuration................................................... 10-5 10.2.8 Air Quality Mo del Selectio n and Configuration

................................................. 10-6 10.2.9 Quality Assurance

.............................................................................................. 10-6 10.3 Model Perform a nce Evaluation

............................................................................... 10-6 10.3.1 Diagnostic and Oper ational Evaluation

.............................................................. 10-7 10.3.2 Summary of M odel Perform a nce

...................................................................... 10-10 10.4 Attainm e nt De monstration

..................................................................................... 10-10 10.4.1 Modeling Attainm e nt Test

................................................................................ 10-11 10.4.2 Unmonitored A r ea Analysis

............................................................................. 10-12 10.4.3 Emissions Inventories

....................................................................................... 10-12 10.4.4 Attainm e nt Modeling Results

........................................................................... 10-13 10.5 W e ight of Evidence Analysis................................................................................. 10-13 10.5.1 Trend in 8-Hour Ozone Design Value

.............................................................. 10-14 10.5.2 Trend in Exceedance Count Across All Monitors

............................................ 10-15 10.5.3 Trend in Nitrogen Dioxide Levels

.................................................................... 10-16 10.5.4 Trend in Carbon Monoxide Levels

.................................................................... 10-17 10.5.5 Trend in VOC a nd NOx Em i ssions

.................................................................. 10-18 10.5.6 Spatial Extent of NAAQS Violations

............................................................... 10-19 10.5.7 Trend in 8-Hour Ozone Exceedan ce Days and High Tem p erature Days

......... 10-20

iv10.5.8 Trend in Meteorology Ad justed Ozone Levels

................................................. 10-22 10.5.9 Alternative Design Value C a lculation T echniques

........................................... 10-24 10.5.10 Uncertainty in CMAQ Modeling

.................................................................... 10-28 10.5.11 Local Governm e nt Voluntary Initiatives

........................................................ 10-31 10.6 Summary and Conclusions of Attainm e nt De m onstration

................................... 10-32 10.7 Procedural Requirem e nts

....................................................................................... 10-31 10.7.1 Reporting........................................................................................................... 1 0-31 10.7.2 Data Archival and Tran sfer of Modeling Files

................................................. 10-31

11.0 Contingency Plan

.......................................................................................................... 11-1 11.1 Contingency Measures for the 2008 RFP Dem onstration

....................................... 11-1 11.1.1 Background

......................................................................................................... 11 -1 11.1.2 Required Reductions

........................................................................................... 11-1 11.1.3 Identified Contingency Measures

....................................................................... 11-2 11.1.4 Portable Fuel Containers Rule: Phase I and Phase II

......................................... 11-2 11.1.5 Regional NOx Transport Requirem e nts.............................................................. 11-4 11.2 Contingency Measures for the Attainm e nt De m onstration

...................................... 11-5 11.2.1 Background

......................................................................................................... 11 -5 11.2.2 Required Reductions

........................................................................................... 11-5 11.2.3 Identified Contingency Measures

....................................................................... 11-6 11.2.4 Tier 2 Motor V e hicle Em ission Regulations

...................................................... 11-8 11.2.5 Phase I and Phase II Em issions Standards for Gasoline-Powered Non-Road Utility Engines

................................................................................................................ .. 11-9 11.2.6 Emissions S t an dards for Diesel-P owered Non-Road Utility Engines of 50 or More Horsepower

....................................................................................................... 11-10 11.2.7 Emissions S t andards for Sp ark Ignition Marine Engines

................................. 11-11 11.2.8 Emissions S t an dards for Large Spark Ig nition Eng i n e s

................................... 11-12 11.2.9 Portable Fuel Containers Rule: Phase I and Phase II

....................................... 11-13

List of Appendices

A. Mem b ership Rosters for MW AQC, TAC and AQPAC B. Base Year 2002 Inventory and Docum e ntation C. Point Source Inventories and Projections D1. Round 7.0 Cooperative F o recast Projection s & Area and Nonroad S ource Inventories and Projections D2. Nonroad Model Outputs_Unc.Cnt.2008.09 E1. MOB6.2.03 Inventories and Docum e ntation E2. Mob6 Input_Output_Files_Adj2002.08_Unc.Cnt.2008.09 F. Transportation Control Measures G. Attainm e nt Modeling D e m onstration and Docum e ntation H. Voluntary C o mm it m e nt Letters and other Docum e ntation I. RACM Doc u m e ntation J. Public Hearing Notices and Public C o mm ents and Responses

vList of Tables

Table A Summary of Control Strategies

....................................................................................... 1 -2

2-1 Top Ten Sources of VOC

................................................................................................... .... 2-8 2-2 Top Ten Sources of NOx

.................................................................................................... ..... 2-9

3-1 2002 Base Year Ozone Season VOC Inventory

...................................................................... 3-1 3-2 2002 Base Year Ozone S eason NOx Inventory ....................................................................... 3-2 3-3 2002 Base Year Ozone Season CO Inventory

.......................................................................... 3-2 3-4 2002 Base Year Annual VOC Inventory

................................................................................. 3-3 3-5 2002 Base Year Annua l NOx Inventory .................................................................................. 3-3 3-6 2002 Base Year Annual CO Inventory

.................................................................................... 3-4

4-1 2002-2008 Growth Factors

.................................................................................................. .... 4-2 4-2 2002-2009 Growth Factors

.................................................................................................. .... 4-3 4-3 Nonroad Model Common Inputs

............................................................................................. 4- 6 4-4 Nonroad Model State Specific Inputs

...................................................................................... 4 -7 4-5 2008 Projected Uncontrolled V O C Em issions

...................................................................... 4-10 4-6 2008 Projected Uncontrolled N O x Em issions

....................................................................... 4-10 4-7 2009 Projected Uncontrolled V O C Em issions

...................................................................... 4-11 4-8 2009 Projected Uncontrolled N O x Em issions

....................................................................... 4-11 4-9 2008 Projected Controll ed VOC Em issions

.......................................................................... 4-14 4-10 2008 Projected Controlled NOx Em issions

......................................................................... 4-15 4-11 2009 Projected Controlled VOC Em issions

........................................................................ 4-16 4-12 2009 Projected Controlled NOx Em issions

......................................................................... 4-16

5-1 2002 Reasonable Further P r ogre ss Base Year Inventory

........................................................ 5-4 5-2 2002 Reasonable Further P r ogress Adjusted-Year Inventory

................................................. 5-5 5-3 2008 RFP Adjusted Year Inventory

........................................................................................ 5- 5 5-4 Calculation of Non-Credita ble E m issions Reductions

............................................................ 5-6 5-5 Calculation of VOC Target Level for 2008

............................................................................. 5-6 5-6 Com p arison of 2008 Controlled and Target Inventories

......................................................... 5-7 5-7 Calculation of VOC and NOx Re ductions for RFP Contingency

........................................... 5-8

Table A Summary of Control Strategies

....................................................................................... 6 -1 6-1 2008 NOx Point Source Reductions for Maryland

.................................................................. 6-7 6-2 2009 NOx Point Source Reductions for Maryland

.................................................................. 6-7

6-3 2008 NOx Point Source Reductions for Virginia

.................................................................... 6-8 6-4 2009 NOx Point Source Reductions for Virginia

.................................................................... 6-8 6-5 2008 NOx Point Source Reductions for District

..................................................................... 6-9 6-6 2009 NOx Point Source Reductions for District

..................................................................... 6-9 6-7 Point Source NOx Reductions Summ ary, 2008, 2009

.......................................................... 6-10 6-8 Summary of Em ission Reductions for Voluntary Bundle

..................................................... 6-60 6-9 Summary of Benefits EERE Program s

.................................................................................. 6-61

vi6-10 Summary of Benefits of Regi onal W i nd Power Purchase

................................................... 6-64 6-11 Projected Annual Generation and Avoided Em issions from DC RPS Tier 1 Sources

........ 6-70 6-12 Summary of Voluntary Measures Initial Survey Responses

............................................... 6-72 6-13 Projected Annual Reductions from Energy Efficiency Program s

....................................... 6-79

7-1 Potential RACM Measures

................................................................................................... ... 7-6

9-1 District Schedule of A dopted Control Measures

...................................................................... 9-1 9-2 Maryland Schedule of Adopt ed Control Measures

................................................................. 9-5 9-3 Maryland Non-CTG RACT

..................................................................................................... 9-8 9-4 Virginia Schedule of A dopted Control Measures..................................................................... 9-9 9-5 Schedule of Stationary Source R e visions

............................................................................... 9-12 9-6 New RACT Rules Applicability

............................................................................................ 9- 13 9-7 Schedule for Revision of NSR Regulations

.......................................................................... 9-14

10-1 W a shi ngton Designations fo r 8-hour Ozone Standard

........................................................ 10-2 10-2 W a shi ngton, DC-MD-VA Statis tics for 8-hour Ozone

....................................................... 10-8 10-3 Individual Site Statistics for 8-hour Ozone (40 ppb cutoff)

................................................ 10-8 10-4 Individual Site Statistics for 8-hour Ozone (60 ppb cutoff)

................................................ 10-8 10-5 Modeling Attainm e nt Test Usin g EPA Prefe rred Methodology

....................................... 10-11 10-6 Tem p e r ature and 8-hour Ozone Exceedances

................................................................... 10-21 10-7 Methodologies for Calculati ng Baseline Design Values

................................................... 10-25 10-8 Methodologies for Calculati ng Relative Response Factors

............................................... 10-27 10-9 Future Design Value Ranges

............................................................................................. 10 -28

11-1 Calculation of Contingenc y Measure Requirem e nts

........................................................... 11-1 11-2 Contingency Measures for 2008 Reasonable Further P r ogress

........................................... 11-2 11-3 Calculation of 2009 Continge ncy Measure Requirem e nt

.................................................... 11-6 11-4 Contingency Measures for A ttainm e nt De monstration

....................................................... 11-7

viiList of Figu res

1-1 VOC Em issions by Source

................................................................................................... ... 1-6 1-2 NOx Em issions by Source

................................................................................................... .... 1-7 1-3 8-hour Ozone Design Value Trend, 1988-2006.......................................................1-9

2-1 W a shington, DC-MD-VA 8-Hr Oz one Nonattainm e nt Region

.............................................. 2-4 2-1 Conditio ns for Ozone Form ation

............................................................................................ . 2

- 5 2-3 Gradual Build-up of Ozone Levels

.......................................................................................... 2-6 2-4 Estim ates of Population At Risk

........................................................................................... . 2 -11 2-5 Ozone Exceedance Days, 1997-2006

.................................................................................... 2-13

10-1 Location of Ozone Monitors in the W a shington Region

..................................................... 10-9 10-2 Trend in 8-Hour Oz one Design Values

............................................................................. 10-14 10-3 Trend in Monitored Exceedances

...................................................................................... 10-15 10-4 Trend in NOx Annual Average Concentrations

................................................................ 10-16 10-5 Trend in 2 nd High 1-Hour CO Concentrations ................................................................... 10-17 10-6 VOC Em issions by Source

................................................................................................ 10 -18 10-7 NOx Em issions by Source

................................................................................................. 1 0-19 10-8 Co m p arison of Nonattainm e nt Area (NAA) Zones, 1990-2006

....................................... 10-20 10-9 8-Hour Ozone Exceedances and / High Tem p eratu r e Days

............................................... 10-22 10-10 Meteorology Adjusted Ozone Season Averages

............................................................. 10-23

viii1.0 EXECUTIVE SUMMARY

The W a shington m e tropolitan area plans to m eet federal requirem e nts for reducing ground-level ozone, a principal com ponent of sm og, by 2009. The Clean Air Act Am endm ents of 1990 (CAAA or Act) represent an unprecedented com m itm ent to protecting public health and the environm ent. Title I of the Act classifies areas that exceed national health-based air quality standards based upon the severity of their pollution problem (m arginal, m oderate, serious, severe, and extrem e) and, accordingly, prescribes increasingly stringent m easures that m u st be im plem ented and sets new deadlines for achieving the standards. The Act also establishes specific em issions reduction requirem e nts to ensure that continual progress toward attainm e nt is

m a de.

High levels of ozone are a health problem . W h en it is breathed into the lungs, ozone reacts with lung tissue. It can harm breathing passages, decrease the lungs’ working ability and cause coughing and chest pains; eye and throat irr itation; breathing difficulties even for healthy individuals, but especially for those with respiratory problem s such as allergies, asthm a , bronchitis and em physem a; and greater susceptibility to respiratory infection.

In 1997 EPA issued a revised ozone health standard based on an 8-hour m easurem ent to protect against longer exposure periods. Since the late 1980’s m o re than 3,000 published health studies indicated that health effects occur at levels lower than the previous standard and that exposure tim es longer than one hour are of concern. EPA established an 8-hour standard at 0.08 parts per

m illion (ppm ) and def i ned the new standard as a “concentration-based” f o rm , specif i cally the 3- year average of the 4 th highest daily m a xim u m 8-hour ozone concentrations.

EPA designated the m e tropolitan W a shington region as m oderate nonattainm e nt for the 8-hour ozone standard in April 2004. The region has a deadline of June 15, 2010, to m eet the 8-hour ozone standard. 1 The geographic scope of the region includes the Metropolitan W a shington Region defined as follows: Montgom ery, Prince Ge orge’s, Frederick, Charles, Calvert Counties in Maryland; Fairfax County, Arlington County, City of Alexandria, City of Falls Church, City of Fairfax, Prince W illiam County, Loudoun County, City of Manassas and City of Manassas Park in Virginia; and the District of Colum b ia.

This docum ent, the 8-Hour Ozone Attainm e nt Plan for the Metropolitan W a shington, DC-MDVA Nonattainm e nt Area, is a plan to im prove air quality in the W a shington region to m e et the National Am bient Air Quality Standard (NAAQS) for ozone. The Plan consists of a Reasonable Further Progress Plan, 2002-2008; an attainm e nt plan; an analysis of reasonably available control m easures; an attainm e nt dem onstration; contingency plans for RFP and attainm e nt; and

m obile budgets for 2008, 2009, and 2010. The plan presents a Base-Year Inventory for 2002 and projected inventories for 2008 and 2009.

The 8-Hour Ozone Attainm e nt Plan is intended to show the progress being m a de to im prove air quality in the W a shington nonattainm e nt area and the efforts underway to assure that all necessary steps are taken to reach the federal health standard for ground-level ozone by 2009. The plan has been prepared by the Metropolitan W a shington Air Quality Com m ittee (MW AQC)

1 Federal Register, Vol.69, no. 84, April 30, 2004, 23951-24000

.

MW AQC Ozone SIP 1-1 May 23, 2007to com p ly with the Clean Air Act Am endm ents of 1990 and with EPA requirem e nts for the W a shington region as stated in EPA’s 2004 recla ssification of the W a shington region, and Phase 1 and Phase 2 of EPA’s 8-Hour Im plem entation Guidance, issued in April 2004 and Novem b er 2005.

Ref No. C ontrol M e a s ur e 2008 b 2 009 c 2008 b 200 9 c

MEASURES INCLUDED I N THE FUTURE CO NTRO LLED SCENARIO

6. 1.2 State NOx RACT and Regional NOx Tr anspor t Requirement (RA C T
, NO x SI P Call, CAI R
, HAA) 0.00 0.00 12.65 128. 7 6

SUBTOT A L 0.00 0.00 12.65 128. 7 6

6. 2.11 M o b ile Equipm ent Repair and Ref i n i s h ing Rule 3.49 3.59 0 0 6. 2.12 Port able F u el Container s Rule: P h ase I 7.34 9.30 0 0 6. 2.13 Ar chitectur al and I ndu s t rial Maintenance Coatings Rule 10.62 10.82 0 0
6. 2.14 Ref o rm ulated Consum er Products R u le: Phase I 6.23 0.76 0 0 6. 2.15 Solvent Cleaning Operations Rule 2.91 2.99 0 0 6. 2.16 I ndustrial Adhesives and Sealants Rule - 2

. 4 2 0 6. 2.17 Port able F u el Container s Rule: P h ase I I - 0

. 7 5 0 6. 2.18 Ref o rm ulated Consum er Products R u le: Phase I I 0.39 6.34 0 0 SUBTOT A L 30.98 36.97 0 0

6. 3.1 E PA Non- Road Gasoline E ngines Rule 42.44 11.68 14. 7 6 6. 3.2 E P A Non- Road Diesel E ngines Rule 6. 3.3 Em issions standards for s p a r k ignition m a r i n e engines 6. 3.4 E m i ssions standards for lar g e spar k ignition engines 6. 3.5 R ef orm u lated Gas o line (of f

- r oad) 6. 3.6 S tandards for L o com o tive 0.05 0.06 2.54 2. 7 4

SUBTOT A L 36.96 42.50 14.22 17. 5 0

6. 4.2 H igh-T ech I n spection/Main tenance (up d ated cu tpoints) 6. 4.4 N ational Low Em ission Vehicle Pr o g r a m 6. 4.5 T ier 2 Motor Vehicle Em iss i on Standar d s 6. 4.6 H eavy

- Duty Diesel Engine Rule

6. 4.7 T r anspor tation Contr o l Meas ures and Vehicle T echnology

, Fuel, or Maintena nce Measures 0.19 0.18 0.49 0. 4 5

SUBTOT A L 6.38 7.35 30.16 38. 0 8

6. 5 V oluntary Bundle 0.19 0.19 0.28 0. 3 0 TOTAL REDUCTIONS 74.51 87.01 57.31 184. 6 4 Notes: 0 0

b Red u ctions included in th e 2008 Reasonable Fur t her Pr ogr ess dem onstration, occu rr ing between 2002 and 2008.

c Redu ctions in cluded in the attainm e nt dem onstration, occurr in g between 2002 and 2009. a The Ar ea Source r e ductions do not include the Dis t r i ct of Columbia. T h e Di s t rict's OT C VO C rules on all the applicable area source categories are or will be fully adopted, subm itted to EP A, and federally enforceab le m e asures. However, the em ission r e ductions of 3.38 tpd VOC in 2008 and 3.80 tpd VOC in 2009 ar ising f r om th es e m easur es in th e District ar e not applied to the em issions inventor i e s pre s ent e d in this RFP/at tainm e nt m o d e ling/contingency dem o n s tration of the Washington DC- M D-VA r e gional SI P. T h e Distr i ct of Columbia' s m e asur es are expected to pr ovide additional enhancem ents to the air quality im pr ovem e nt in the r e gion

. TABLE A SUMM ARY OF C O NTROL S T RATEGIES VOC an d NOx Benef i ts of Cont rol Meas u r es (2002- 200 9) VOC Red u ct ions NOx Reduc tion s

36.91 to n s /d a y to n s /d a y

VOLU NTARY MEASU R ES (Mu l tip l e S o urce Sect ors) ON- R OAD MEASUR ES

6.19 7.17 29.67 37. 6 3 NON

- ROAD MEASU R ES POINT S O URC E MEAS URES

AREA SOURCE MEASUR ES ( a )

MW AQC Ozone SIP 1-2 May 23, 20071.1 Background

In April 2004 EPA designated the W a shington area as a “m oderate” nonattainm e nt area for the 8-hour ozone standard under Subpart 2 of part D, Title I. The boundaries of the W a shington nonattainm e nt areas are defined in the Federal Register, Vol. 69, No. 84, 4/30/04. The W a shington nonattainm e nt area includes the Dist rict of Colum b ia, Arlington, Fairfax, Loudoun, Prince W illiam counties, and the cities of Alexandria, Falls Church, Fairfax, Manassas, and Manassas Park in Virginia; as well as Calvert, Charles, Frederick, Montgom ery, and Prince George’s counties and the Cities of Bowie, College Park, Gaithersburg, Greenbelt, Frederick, Rockville, and Takom a Park in Maryland. A m a p of the nonattainm e nt area is shown in Chapter 2.

To m eet the federal 8-hour standard for ozone, nonattainm e nt areas are required to develop regional plans, state im plem entation plans or “SIP,” to reduce ozone-causing em issions of volatile organic com pounds (VOCs) or Nitrogen Oxides (NOx) by at least 15 percent between 2002-2008, and to reduce all ozone precursor em issions to a level sufficient to attain the federal 8-hour standard by June 15, 2010. However, the region is required to dem onstrate attainm e nt of the standard by the end of the last ozone season before that date, which is Septem ber 2009. The actual attainm e nt date for planning purposes is 2009; the photochem i cal m odeling to dem onstrate attainm e nt and the inventories used to determ ine reduction benefits use 2009 as the attainm e nt date.

The 8-Hour Ozone Attainm e nt Plan for the W a shington nonattainm e nt areas has been developed by the Metropolitan W a shington Air Quality Com m ittee (MW AQC) in cooperation with Maryland, Virginia and the District of Colum b ia. Table A identifies the W a shington region’s control m easures to achieve a 15 percent em issions reduction by 2008 and attainm e nt by 2009. EPA’s ozone guidance calls f o r dem onstration of steady progress in im proving air quality by 2009.

Overall, the 2009 attainm e nt plan for the Metropolitan W a shington region includes total reductions by 2009 of 87.10 tons per day of VOC and 184.64 tons per day of nitrogen oxides (NOx). The plan m a y be sum m a rized as follows:

• 128.76 tons per day of NOx reductions thr ough the regulation of point sources of pollution, such as factories and power plants;

• 36.97 tons per day of VOC reductions from regulating area sources of pollution such as architectural coatings, portable fuel containers, autom obile repair, and consum er products;

• 42.50 tons per day of VOC reductions and 17.50 tons per day of NOx reductions from non-road sources such as nonroad gasoline and nonroad diesel rules, em issions standards for large spark ignition engines, reform ulated gasoline, and m a rine engines;

• 7.35 tons per day of VOC reductions and 38.08 tons per day of NOx reductions from initiatives relating to cars and trucks, the “on-road” or “m obile” sources of pollution; and

• 0.19 tons per day of VOC reductions and 0.30 tons per day of NOx reductions from voluntary m easures spanning m u ltiple source sectors.

MW AQC Ozone SIP 1-3 May 23, 20071.2 The Oz one Problem

Of the six m a jor air pollutants f o r which am bient air quality standards have been established under the Clean Air Act, the pollutant that has posed the m o st prevalent and perplexing problem for the W a shington m e tropolitan area is ozone, a principal com ponent of “sm og.”

W hy has the ozone problem been so difficult to solve? First, ozone is not discharged directly. It is form ed in, and downwind of, urban areas when sunlight and high tem p eratures cause com p lex photochem i cal reactions to occur between em issions of VOCs and NOx. A num ber of diverse

sources em it these ozone precursors. Major sources of VOC em issions include, but are not lim ited to, gasoline storage f acilities, bakeries, gasoline ref u eling stations, printing f acilities,

m o tor vehicles, lawnm o wers, consum er products, and boats. In addition, m a ny species of plants

em it VOCs. Principal sources of NOx, which is produced by com bustion and industrial processes, include m o tor vehicles, construction equipm ent, fossil fuel-fired power plants, and open burning.

Second, the ozone problem is further com p licated by the fact that weather conditions play a

m a jor role in the form ation of ozone and in the severity of the problem . Solar energy drives the reactions that create ozone. W h en a warm air m a ss stays in one spot, and winds are calm

, sm og

m a y rem a in for several days at a tim e, creating severe ozone conditions. W h ile it is not always possible to predict weather conditions that create severe ozone problem s, the m o re severe and prolonged episodes can be forecast.

Third, scientists are only beginning to understand how weather conditions, topography, and ozone precursors interact to create ozone. Originally, ozone control strategies focused on reducing VOCs. However, new evidence shows that NOx control is also necessary and, in fact, achieving attainm e nt of the standards m a y be im possible without it. The com p lexity of the reactions that cause ozone requires reliance upon com puter m odels of ozone form ation to guide the region to the correct m i x of VOC and NOx controls. For the m o st recent scientific findings about ozone, see Appendix G Attachm e nt 1, “The Conceptual Model.”

Fourth, given that sm og travels across county a nd state lines, the ozone problem is regional. Therefore, solving the problem requires considerable coordination and consensus building on the part of local and state governm e nts to develop re gional em ission control strategies. On the East Coast, governm e nts from Maine to W a shington, D.C. and Virginia are required under the Act to form the Ozone Transport Com m i ssion (OTC) in order to develop ozone control strategies on a regional basis. The OTC has developed VOC and NOx controls that are intended to reduce ozone levels from Virginia to Maine.

The Ozone Transport Assessm ent Group (OTAG) worked to quantify and reduce the am ount of ozone and its precursors, which m ove from one state to the next within the 37 Eastern states. The work of OTAG led EPA to issue the NOx SIP call in 1998. EPA prom ulgated the Clean Air Interstate Rule (CAIR) in 2005 as a regional transport rule to help the states towards m eeting the 8-hour ozone and PM 2. 5 standards. Both the NOx SIP call and CAIR apply to the Midwestern states as well as eastern states and require them to reduce em issions from stationary sources and were intended to reduce pollution transported aloft.

MW AQC Ozone SIP 1-4 May 23, 20071.3 SIP Process

The Act requires states to develop and im plem ent ozone reduction strategies in the form of a SIP. The SIP is the state's "m aster plan" for attaining and m a intaining the NAAQS.

Once the adm i nistrator of the EPA approves a state plan, the plan is enforceable as a state law and as federal law under Section 113 of the Act. If EPA finds the SIP inadequate to attain the NAAQS in all or any regions of the state, and if the state fails to m a ke the requisite am endm ents, the EPA adm i nistrator m a y issue binding am endm ents under Section 110(c)(1).

EPA is required to im pose severe sanctions on the states under three circum stances: the state' s failure to subm it a SIP revision; on the finding of the inadequacy of the SIP to m eet prescribed air quality requirem e nts; and the state' s f a ilure to enf o rce the control strategies that are contained in the SIP.

Sanctions include the withholding of federal funds for highway projects -- other than those for saf e ty, m a ss transit, or transportation im provem e nt projects related to air quality im provem e nt or

m a intenance -- beginning 24 m onths after EPA announcem ent. No federal agency or departm e nt will be able to award a transportation grant or fund, license, or perm it any other transportation project that does not conform to the m o st recently approved SIP.

1.4 Rate of Progress Demonstrated in Previous 1-Hour Oz one SIPs

The Clean Air Act requires that serious nonattainm e nt areas ensure progress toward the attainm e nt goal by achieving a 15 percent reduction in volatile organic chem icals (VOCs) by 1996, and an additional 9 percent by 1999. To dem onstrate attainm e nt, the Act requires the region to dem onstrate, through the use of photochem i cal air quality com puter m odels, that ozone will reach the level of the standard. The W a shington region was classified as a serious nonattainm e nt area for the 1-hour ozone standard in 1992, the standard in place at the tim e. EPA now uses a different m easurem ent for the 8-hour ozone standard. In 2003 EPA reclassified the

m e tropolitan W a shington region as severe nonattainm e nt for ozone when the region did not m e et the attainm e nt deadline for serious nonattainm e nt areas by Novem b er 1999. In March 2004 MW AQC approved a SIP to m eet the requirem e nts for a severe nonattainm e nt area. The “Severe Area SIP” dem onstrated rate of progress of 9 percent from 1999-2002, and 9 percent from 2002- 2005. EPA approved the states’ SIPs and Rate of Progress (RFP) plans in 2005. 2

2 Approval and Promulgation of Air Quality Implementation Plans, District of Columbia, Maryland, Virginia, 1- Hour Attainment Plans, Rate-of-Progress Plans, Conti ngency Measures, Transportation Control Measures, VMT Offset, and 1990 Base Year Inventory, Federal Regi ster, Vol. 70, No. 92, May 13, 2005, pp. 25688-25716 and Approval and Promulgation of Air Quality Implementati on Plans; Maryland; Metropolitan Washington, DC 1-Hour Ozone Attainment Plan, Lifting of Earlier Rules Resu lting in Removal of Sanctions and Federal Implementation Clocks, Federal Register, Vol.70, No. 220, November 16, 2005, pp.69440-69443.

MW AQC Ozone SIP 1-5 May 23, 20071.5 Base Year 2002 Emission Inventorie s and Future Year 2008 and 2009 Emissions Inventories

A com p arison of future year inventories 2008 and 2009 to the base year inventory 2002 dem onstrate dram atic reductions in em issions. Between the base year 2002 and the attainm e nt year 2009, volatile organic com pound em issions (VOC) will decrease by 22.2 percent and

em issions of nitrogen oxide (NOx) will decrease by 39.4 percent. The 8-hour ozone SIP presents revisions to the 2002 base year i nventory using MOBILE 6.2.03, Travel Dem a nd Model version 2.1d#50, including corrections to nonroad, area and stationary source em issions. A description of the 2002 Base Year inventory is included in Chapter 3 and com p lete docum entation for the Base Year 2002 inventory is in Appendix B. Future year projected inventories for 2008 and 2009 were developed using MOBILE6.2.03 and Travel Dem a nd Model Version 2.1d#50. The future year inventories are discussed in SIP Chapter 4.

Figure 1-1. VOC Emissions by Source, 2002-2009



### V O C E m i ssi ons by S our ce ( 2 002 V s

. 2009) W ashi ngt on, D C N onat t a i n m e nt A r ea

12.

91 192 . 64 125. 79 448. 28

1

16.

94 3 48.

74

8

8.

66 66. 68 179. 10

14.

31

0 100 200 300 400 500



### P o i n t A r ea N on- r o a d O n - r oa d Tot alEmissions (tpd)
2002 2009

Figure 1-2.

MW AQC Ozone SIP 1-6 May 23, 2007NOx Emissions by Source, 2002-2009



### N O x E m i ssi on s b y S o ur ce ( 2 002 V s

. 2009) W ash i n gt o n , D C N o n a t t a i n ment A r ea

2

20

.6

0

8 5

. 7 2 26 6.

65 5 97.

2

2

24

.2

5 7 5.

10 27 . 4

8 1

1 3.

03 1 46.

53 36 2.

0 5

0 100 200 300 400 500 600 700

Poi n t A r ea N on- r o ad O n - r oad T o t a lEmissions (tpd)

2002 2009

1.6 2002-2008 Reasonable Further Progress Plan

EPA’s Final Rule To Implement the 8-Hour Ozone National Ambient Air Quality Standard – Phase II m a ndates that to m eet the Reasonable Further Progress (RFP) requirem e nt, the W a shington, DC-MD-VA 8-hour ozone nonattainm e nt area needs to reduce its em issions by 15 percent between 2002 and 2008 using either reduction in VOC or NOx or any com b ination of the two. This SIP explains that the W a shington region is able to dem onstrate reasonable further progress for the period 2002-2008 using a 15 per cent VOC reduction. The W a shington region’s controlled VOC em issions in 2008 of 358.84 tons per day (tpd) VOC are below the target level of VOC reductions of 370.45 tpd VOC, dem onstrating that the region m eets its 15 percent Reasonable Further Progress (RFP) requirem e nt.

1.7 Establishment of a Budget for Transportation Mobile Emissions

As part of the developm ent of the plan, MW AQC in consultation with the Transportation Planning Board (TPB) will establish m obile source em issions budgets or m a xim u m allowable levels of VOC and NOx. These budgets will be the benchm ark used to determ ine if the region’s long range transportation plan, known as the Cons trained Long-Range Plan, (CLRP) and six year transportation im provem e nts program (TIP) conform with the CAAA of 1990. Under EPA regulations the projected m obile source em issions for 2008 and 2009 -- m i nus the Transportation Control Measures (TCM) and vehicle technology, fuel, or m a intenance-based m easures -- becom e the m obile em issions budgets for the region unless MW AQC takes actions to set another

MW AQC Ozone SIP 1-7 May 23, 2007budget level. The m obile em issions budgets were developed using com puter m odels MOBILE6.2.03 and Travel Dem a nd Model version 2.1d#50.

Reasonable Further Progress Mobile Budgets The m obile em issions budgets for the 2008 Reasonable Further Progress are based on the projected 2008 m obile source em issions accounting for all the m obile control m easures, including TCMs and vehicle technology, fuel, or m a intenance-based m easures. The m obile

em issions budgets for the 2008 Reasonable Further Progress are 70.8 tons/day VOC and 159.8 tons/day NOx.

2008 Mobile Budgets:

VOC = 70.8 tons/day NOx = 159.8 tons/day

Attainment Year Mobile Budgets

The m obile em issions budgets for the 2009 attainm e nt year are based on the projected 2009

m obile source em issions accounting for all the m obile control m easures, including TCMs and vehicle technology, fuel, or m a intenance-based m easures. The m obile em issions budgets for the 2009 Attainm e nt Year are 66.5 tons/day VOC and 146.1 tons/day NOx.

2009 Mobile Budgets:

VOC = 66.5 tons/day NOx = 146.1 tons/day

The m obile em issions budgets for the 2010 year are based on the projected 2009 m obile source

em issions accounting for all the m obile control m easures, including TCMs and vehicle technology, fuel, or m a intenance-based m easures, m i nus the reductions required for the contingency plan discussed in Chapter 11. The m obile em issions budgets for the 2009 Attainm e nt Year are 66.5 tons/day VOC and 146.1 tons/day NOx. The required reduction

am ount to satisfy the contingency plan is 1.8 tpd NOx.

The Mobile Em issions Budget for 2010, based upon the projected 2009 m obile source em issions accounting for all the m obile control

m easures, including the Transportation Control Measures and vehicle technology, fuel, or m a intenance-based m easures, less the contingency requirem e nt: VOC = 66.5 tons/day NOx = 144.3 tons/day

MW AQC Ozone SIP 1-8 May 23, 20071.8 Attainment Demonstration

The 8-Hour Ozone Attainm e nt Plan analyzes the potential of the W a shington m e tropolitan area to achieve attainm e nt of the 8-hour ozone standard. The dem onstration of achieving the 8-hour ozone standard is based on results f r om the Com m unity Multiscale Air Quality Model (CMAQ) and supporting W e ight of Evidence analysis. The 8- hour ozone design value is the fourth highest

m a xim u m ozone concentration at a m onitoring site averaged over a continuous three-year period. Values of 85 parts per billion (ppb) and above are exceeding the 8-hour ozone health standard. CMAQ results show only two of the 18 m onitoring stations in the W a shington m e tropolitan area having a future design value at and above 85 ppb; all other m onitors fall well below 85 ppb.

Air quality trends continue to im prove, em issions are decreasing (Fig.1-3), and in the past three years the region has less than one Code Red Day for every day over 90 o F. The im pact of air quality im provem e nt is dem onstrated in the reduced spatial extent of the attainm e nt zone in 2005. Voluntary program s in the W a shington area offer further potential for reducing ozone during the sum m e r. Episodic program s such as teleworking and reducing electricity dem a nd on high electric dem a nd days m a y provide additional ozone reductions on the worst days of

s u mme r

. The photochem i cal m odeling com b ined with supporting W e ight of Evidence analysis provide strong evidence the region will attain the 8-hour ozone standard by 2009.

Figure 1-3: 8-hour Oz one Design Value, 1988-2006.

8- ho u r O z o n e D esi g n V a l u e W ash i n g t on , D

. C

. R e gi on , 1988- 2006

0.

11

5

0 . 1 07

0 . 1 0 0 0 . 1 0 0 0 . 1 0 1

0 . 0 9 6 0. 09

8

0. 09

4 0 . 1 0 0 0 . 1 0 1 0 . 1 0 6

0 . 1 01

0 . 0 97 0 . 0 97 0 . 0 9 9

0 . 0 9 6

0 . 0 9 1 0

. 0 91 0.

11

6

0. 07 5 0. 08 5 0. 09 5 0. 10 5 0. 11 5 0. 12 5

1 9 8 8 19 8 9 19 90 1 9 9 1 1 9 9 2 1 9 9 3 1 9 9 4 1 9 9 5 19 96 1 9 9 7 1 9 9 8 1 9 9 9 20 00 2 0 0 1 2 0 0 2 2 0 0 3 2 0 0 4 2 0 0 5 20 0 6

Ye arDesign Value (ppm)

8- h our O z one NAAQS

MW AQC Ozone SIP 1-9 May 23, 20071.9 Analysis of Reasonably Available Control Measures (RACM)

An extensive list of potential control m easures was analyzed and evaluated against criteria used f

o r potential RACM m easures. Individual m easures m u st m eet the f o llowing criteria: 1) W ill reduce em issions by the beginning of the W a shington region’s 2008 ozone season (May 1, 2008); 2) Enforceable; 3) Technically feasible; 4) Econom ically feasible (proposed as a cost of $3,500-$5,000 per ton or less); 5) W ould not create substantial or widespread adverse im pacts within the region; and 6) Em issions from the source being controlled exceed a de minimis threshold, proposed as 0.1 tons per day.

If im plem ented collectively, any group of potential RACM m e asures would need to provide reductions of 20-40 tons per day of NOx and/ or VOC by the 2008 ozone season. The region has reviewed all of the potential control m easures to determ ine if collectively they could m eet these criteria. Several m a ndatory program s are available that can provide m oderate levels of em ission reductions, however, none of these m easures can provide benefits by the 2008 ozone season, and the total overall reduction that could be provided by these m easures is below 20-40 tons per day. W h ile there are potential voluntary m easures that can be im plem ented before 2008, together these voluntary m easures will not provide suf f i cient creditable em ission reductions to advance the attainm e nt date by one year. Therefore, there are no RACM appropriate for the W a shington region’s m oderate area SIP.

1.10 Contingency Measures

In the event that the reductions anticipated in the 2008 RFP or 2009 attainm e nt dem onstration are not realized within the tim efram e s specified, contingency m easures m u st be im plem ented. EPA issued guidance says that contingency m easures m u st provide for a 3 percent reduction in baseline em issions. The contingency m easures for the 2008 RFP and attainm e nt dem onstrations

m u st total 3 percent of the 2002 adjusted base year inventory.

To satisfy the contingency requirem e nt for the 2008 RFP, the SIP includes a 3 percent reduction, attributed to states’ Clean Air Interstate Rule (C AIR) and Portable Fuel Container Rule benefits from 2008-2010. These m easures deliver benefit in excess of 1.31 tpd VOC and 15.27 tpd NOx, thereby m eeting the RFP contingency m easure requirem e nt.
The contingency m easures for the attainm e nt dem onstration m u st also total 3 percent of the 2002 Adjusted Base Year Inventory. The contingency m easures identified by the District of Colum b ia, Maryland and Virginia f o r the attainm e nt dem onstration deliver total benef its in excess of the required contingency em issions reductions; theref ore these m easures f u lf ill the region’s attainm e nt contingency requirem e nt.

MW AQC Ozone SIP 1-10 May 23, 20071.11 Document Contents

Chapter 2 presents a detailed overview of the Clean Air Act, the region’s reclassification to m oderate nonattainm e nt area, the requirem e nts for

m oderate nonattainm e nt areas, additional com m itm ents by the states to EPA, the region’s air quality planning process, the role of the states and the proposed plan.

Chapter 3 presents revisions to the 2002 base year inventory using MOBILE 6.2.03, Travel Dem a nd Model version 2.1d#50 including corrections to nonroad, area and stationary source em issions.

Chapter 4 presents the 2008 and 2009 proj ected inventories using MOBILE 6.2.03 and Travel Dem a nd Model Version 2.1d#50 to revise 2008 and 2009 projected and a discussion of the growth projection m e thodology.

Chapter 5 presents 2008 RFP requirem e nts. These are MW AQC’s calculations of how m a ny tons per day of em issions m u st be reduced in the W a shington region in order to m eet the reasonable further progress target level of reductions and also describes the control strategy and associated target

em issions levels for the 15 percent reduction requirem e nt.

Chapter 6 Outlines the control strategies that the states will im plem ent to achieve the reductions in VOC and NOx.

Chapter 7 discusses the analysis of Reasonably Available Control Measures (RACM).

Chapter 8 discusses m obile source conform ity issues and establishes 2008 and 2009

m obile em issions budgets for the Metropolitan W a shington region.

Chapter 9 presents the states’ schedules and adoption of regulations to m e et requirem e nts for severe nonattainm e nt areas and presents the states’

com m itm ents to EPA.

Chapter 10 presents the Metropolitan W a shington region’s dem onstration of attainm e nt based on CMAQ m odeling and weight of evidence.

Chapter 11 presents contingency m easures for the 2008 Reasonable Further Progress and for the 2009 attainm e nt dem onstration.

MW AQC Ozone SIP 1-11 May 23, 2007MWAQC Ozone SIP 2-1 May 23, 2007 2.0 INTRODUCTION AND OVERVIEW

This document presents the regional air quality plan for attainment of the federal 8-hour standard for ground-level ozone being considered by the Metropolitan Washington Air Quality Committee (MWAQC) for the Washington, D.C. multi-jurisdictional nonattainment area. MWAQC was established, by the governors of Maryland and Virginia and the mayor of the District of Columbia to prepare a regionally coordinated air quality plan to comply with the requirements of the 1990 Clean Air Act Amendments (CAAA or Act). MWAQC was established in accordance with Section 174 of the Clean Air Act.

2.1 Clean Air Act Background

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 (NAAQS). The CAAA established a process for evaluating air quality in each region and identifying and classifying nonattainment areas according to the severity of its air pollution problem. The CAAA defines ground-level ozone as a criteria pollutant. In 1979 EPA promulgated the 0.12 ppm, 1-hour ozone standard. In 1997 EPA issued a revised ozone standard of 0.08 parts per million (ppm) or 84 parts per billion (ppb) measured over an 8-hour period. The1-hour ozone standard was revoked on June 15, 2005. The Metropolitan Washington, DC-MDVA nonattainment area met the 1-hour ozone standard by the November 15, 2005 deadline. The CAAA also sets National Ambient Air Quality Standards (NAAQS) for five other criteria pollutants, carbon monoxide, particulate matter, lead, sulfur dioxide and nitrogen dioxide.

In April 2004 EPA designated the Washington area as a “moderate” nonattainment area for the 8-hour ozone standard under Subpart 2 of part D, Title I . The boundaries of the Washington nonattainment areas are defined in the Federal Register, Vol.; 69, No. 84, 4/30/04). The Washington nonattainment area includes the Dist rict of Columbia, Arlington, Fairfax, Loudoun, Prince William counties, and the cities of Alexandria, Falls Church, Fairfax, Manassas, and Manassas Park in Virginia; as well as Calvert, Charles, Frederick, Montgomery, and Prince George’s counties and the Cities of Bowie, College Park, Gaithersburg, Greenbelt, Frederick, Rockville, and Takoma Park in Maryland. A map of the nonattainment area is shown in Figure 2-1.

To meet the federal 8-hour standard for ozone, nonattainment areas are required to develop regional plans, state implementation plans or “SIP,” to reduce ozone-causing emissions of volatile organic compounds (VOCs) by at least 15 % between 2002-2008, and to reduce all ozone precursor emissions to a level sufficient to attain the federal 8-hour standard by June 15, 2010. However, the region is required to demonstrate attainment of the standard by the end of the last ozone season before that date, which is September 2009. The actual attainment date for planning purposes is 2009; the photochemical modeling to demonstrate attainment and the inventories used to determine reduction benefits use 2009 as the attainment date.MWAQC Ozone SIP 2-2 May 23, 2007 2.2 8-hour Ozone Standard

In 1997 EPA issued a revised ozone health standard based on an 8-hour measurement to protect against longer exposure periods. Since the late 1980’s more than 3,000 published health studies indicated that health effects occur at levels lower than the previous standard and that exposure times longer than one hour are of concern. EPA established an 8-hour standard at 0.084 parts per million (ppm) and defined the new standard as a “concentration-based” form, specifically the 3- year average of the 4 th highest daily maximum 8-hour ozone concentrations.

EPA changed the form of the standard to a concentration-based form because it more directly relates to ozone concentrations associated with health effects. Based on recent studies, the 8-hour ozone standard was designed to reduce exposure to ambient ozone concentrations that have been linked to increased hospital admissions for respiratory ailments such as asthma. 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.

2.3 SIP Requirements for Moderate Nonattainment Areas

The Clean Air Act Section 182 (b) and EPA’s im plementation rule, 40 CFR Part 51, Subpart X, requires moderate nonattainment areas to submit revisi ons to the state implemen tation plan that meet the following planning requirements:

• Reasonable Further Progress (RFP): 15% VOC re duction from baseline within 6 years of
enactment

• Attainment demonstration: Due 3 years after designation (6/15/07)

• New Source Review (NSR) and Reasonably Av ailable Control Technology (RACT) major source applicability: 100 TPY for NOx and 50 tpy for VOC (CAAA Section 184)

• NSR offsets: 1.15 to 1

• NSR permits: required for new or modified major stationary sources

• NOx control for RACT: requirement for major st ationary VOC sources also applies to major NOx sources

• RACM/RACT: RACT required for all CTG sources and all other major sources

• Basic Inspection and Maintenance (I/M): for vehicles

• Stage II vapor recovery: required for gas stati ons with a throughput of at least 10,000 gallons per month.

• Contingency measures: required for failure to meet RFP milestones or attain

Before designation as a moderate nonattainment area for the 8-hour standard, the Washington, DC-MD-VA region was classified as a “severe” nonattainment area for the 1-hour ozone standard. The Clean Air Act Section 182 (d) requirements for severe nonattainment areas include a number of planning requirements that are more stringent than those required for a moderate nonattainment area. The more stringent lower permitting thresholds remain in force in Maryland and the District of Columbia.MWAQC Ozone SIP 2-3 May 23, 2007 The more stringent regulations remaining in for ce in Maryland and the District are the following:

• Lower permit threshold for point sources to 25 tpy

• Lower NSR threshold for definition of “Major” source requiring controls to 25 tpy

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

2.4 Rate of Progress Demonstrated in Previous SIPs

For the previous 1-hour ozone health standard, MWAQC approved several SIPs to meet Rate of Progress requirements (ROP) for serious nonattainment areas. The Act required that serious nonattainment areas ensure progress toward the attainment goal by achieving a 15% reduction in VOCs by 1996, and an additional 9% by 1999. MWAQC approved the “15% Plan” in January 1994. 1 MWAQC approved the Phase I Attainment Plan, which includes the 9% ROP requirements, in October 1997 and revised it in April 1999. 2 The plan outlined how the region would reduce pollutants by the additional 9% requirement from 1996–1999 and discussed efforts to identify attainment requirements.

MWAQC approved the Attainment Plan (Phase II) in April 1998 and revised it in January 2000. 3 The Phase II plan summarized the results of photochemical air quality modeling and provided information on trends in actual measured ozone levels. The plan predicted that the Washington metropolitan region would attain the federal 1-hour standard for ozone in 2005. The monitoring data demonstrates that the region attained the 1-hour ozone standard as predicted.

In 2003, EPA reclassified the metropolitan Washington region as severe nonattainment for ozone when the region did not meet the attainment deadline for serious nonattainment areas by November 1999. In March 2004, MWAQC approved a State Implementation Plan to meet the requirements for a severe nonattainment area. The “Severe Area SIP” demonstrated rate of progress of 9% from 1999-2002, and 9% from 2002- 2005. The states submitted the plan to EPA, which approved the states’ SIPs and ROP plans in 2005. 4

2.5 Comparability of 8-hour Inventories to Previous State Implementation Plans

In 1997 EPA issued a revised ozone standard of 0.080 parts per million (ppm) or 84 parts per billion (ppb) measured over an 8-hour period. Th e 1-hour ozone standard was revoked on June 15, 2005. EPA designated the metropolitan Washington region as moderate nonattainment for the 8-hour ozone standard in January 2004.The ar ea source and point source inventories in the 8- hour ozone SIP are comparable to the previous 1-hour ozone SIP and are generally consistent with the methodologies used for those inventories, although the most recent version of the models were used. The 8-hour ozone SIP’s mobile source inventory was estimated using MOBILE6.2.03 and Travel Demand Model version 2.1d#50. Both models are newer, revised versions of the models used for the Severe Area SIP.Figure 2-1. Washington, DC-MD-VA 8-Hour Oz one Nonattainment Region

Additionally, the Reasonable Further Progress and attainm e nt dem onstration for 8-hour ozone standard uses a new m odel, EPA’s Nonroad Model, to calculate em issions from the nonroad sector. In previous SIPs the nonroad em issions were calculated using a spreadsheet-based

MW AQC Ozone SIP 2-4 May 23, 2007projection of an inventory developed by EPA. Changes in the estim ating techniques for nonroad

em issions have changed, so it is not possible to com p are them with previous calculations.

2.6 Sources of Oz one in the Metropolitan Washington Region

Ozone (O 3 ) is form ed through a com p lex series of chem ical reactions when oxygen m o lecules and atom s (O 2 + O) are com b ined. The process occurs when reactive volatile organic com pounds interact with nitrogen oxides in the presence of sunlight during hot, stagnant, sum m e r days. VOCs are chem ical com pounds contained in gasoline, furniture polish, cleaning fluids, paint, inks, and other household and industrial produc ts. VOCs also are a by-produce of com bustion. Principal sources of NOx, which is produced by com bustion and industrial processes, include

m o tor vehicles, fossil fuel-fired power plants , and open burning. Ozone form ation is favored under certain weather conditions, including high tem p erature, bright sunshine, and light winds. See Figure 2-2.

Figure 2-2. Conditions for Ozone Formation

MW AQC Ozone SIP 2-5 May 23, 2007Typically, ozone levels escalate rapidly before noon tim e, peak in the afternoon, and taper off when
t h e s un goes down. Figure 2-3 shows hourly ozone con centrations for a typical 24-hour period in our region.

Figure 2-3. Gradual build-up of ozone levels on a typical summer day. Ozone peak s in the afternoon, then tapers off to lower levels in the evening.

Outer suburban and rural areas share this regional problem . W i nds can m ove a cloud of ozonecontaining sm og for long distances. Regional data i ndicate that violations of the ozone standard can occur in either rural, inner suburban, outer suburban, or urban areas or com b inations thereof.

W h ile ozone within the region is caused m o stly by em issions generated within the region, it also is carried into the m e tropolitan area by winds from elsewhere. Research conducted through the Ozone Transport Com m i ssion (OTC), and the Ozone Transport Assessm ent Group (OTAG) provides evidence that ozone form ed in other parts of the country m a y drift into and affect air quality in the W a shington region.

A num ber of diverse sources em it the ozone precursors VOC and NOx. Major sources of VOC

em issions include, but are not lim ited to, gasoline storage f acilities, bakeries, gasoline ref u eling stations, printing facilities, m o tor vehicles, lawnm o wers, consum er products, and boats. Principal sources of NOx, which is produced by com bustion, include m o tor vehicles (cars, trucks and buses), fossil fuel-fired power plants, and construction equipm ent.

In general the anthropogenic (m an-m ade) sources of ozone precursors are grouped into four source categories: point (stationary), area, non-road, and m obile sources.

Point sources are stationary sources that em it m o re than 10 tpy of em issions. These sources are individually inventoried. Actual em issions m easur em ents are available for som e sources from

MW AQC Ozone SIP 2-6 May 23, 2007MWAQC Ozone SIP 2-7 May 23, 2007 the states and the District of Columbia. Emi ssions from other sources are estimated using emission factors.

Area source emissions include small industries, such as: bakeries and printers; off-highway mobile equipment; and commercial/consumer products and activities. Emissions are not measured directly but are estimated from engineering calculations and estimates of activity levels.

Non-road sources include construction and farming equipment, commercial and residential lawn and garden activities, and recreational boating.

On-road or "mobile source" emissions from transportation sources are estimated from regional transportation models, which provide estimates of the number of vehicle trips, and the distance, location and speed of the trips, combined with a detailed EPA-approved model of per-vehicle emission factors.

A fifth category, "biogenic" emissions, includes all naturally occurring sources of VOC emissions from trees, crops and other forms of vegetation.

The following tables list the top ten sources of VOCs and NOx in the Washington nonattainment area in 2002 and in 2009.MWAQC Ozone SIP 2-8 May 23, 2007 Table 2-1 TOP TEN SOURCES OF MAN-MADE VOLA TILE ORGANIC COMPOUNDS (VOCs) IN THE WASHINGTON AREA IN 2002 and 2009 EMISSIONS LEVELS

# SOURCE CATEGORY SOURCE VOCs * TONS/ DAY

2002 2009

1 On-Road Mobile CARS, BUSES, TRUCKS 116.9 66.7

2 Non-Road LAWN & GARDEN EQUIPMENT 81.6 52.2

3 Area SURFACE COATING 62.7 57.5

4 Area COMMERCIAL CONSUMER SOLVENT USE 58.5 57.3

5 Area PORTABLE FUEL CONTAINERS 25.6 17.9

6 Nonroad PLEASURE CRAFT 20.7 15.0

7 Area GASOLINE STORAGE 13.7 15.0

8 Stationary UTILITIES AND OTHER SOURCES 12.9 14.3

9 Area PESTICIDES 11.8 9.7

10 Area SURFACE CLEANING 11.6 10.3

* The emissions estimates above are rounded to the neares t whole number, listed in order for 2002 emissions. They are MWAQC’s best estimates. Total VOC emissions in the Washington area were 448.28 tons per day in 2002 and 348.74 tons per day in 2009. Biogenic emissions account for 314.74 tons/day of VOC emissions in the Washington region. The 2009 inventories include the final attainment control strategy.MWAQC Ozone SIP 2-9 May 23, 2007 Table 2-2 TOP TEN SOURCES OF NITROGEN OXIDES (NOx) IN THE WASHINGTON AREA IN 2002 and 2009 EMISSIONS LEVELS

# SOURCE CATEGORY SOURCE NOx * TONS/ DAY

2002 2009

1. On-Road Mobile ALL VEHICLES 266.7 146.5

2. Stationary UTILITIES AND OTHER SOURCES 220.6 113.0

3. Non-Road CONSTRUCTION AND MINING 45.8 38.3

4. Non-Road LAWN AND GARDEN EQUIPMENT (RES) 12.6 10.6

5. Area INDUSTRIAL FUEL COMBUSTION 9.3 11.1

6. Non-Road RAILROAD LOCOMOTIVES 7.2 5.7

7. Non-Road INDUSTRIAL EQUIPMENT 6.7 4.6

8. Area COMMERCIAL/INSTITUTIONAL FUEL COMBUSTION 6.4 7.1

9. Area RESIDENTIAL FUEL COMBUSTION 4.8 5.3

10. Area AIRCRAFT EMISSIONS 3.8 5.9

* The emissions estimates above are rounded to the nearest whol e number. They are MWAQC's best estimates. The total emission of NOx in the Washington area was 597.22 tons per day in 2002 and 362.05 tons per day in 2009. The 2009 inventories include the final attainment control strategy.MWAQC Ozone SIP 2-10 May 23, 2007 2.7 The Effects of Ozone

Specific groups that are most likely to feel adverse effects from ozone are people with respiratory problems, asthmatic children and the elderly. Healthy individuals who engage in moderate to heavy exercise during the summer when ambient ozone concentrations are high may also be affected. EPA cites the following health effects:
When inhaled, even at very low levels, ozone can cause acute respiratory problems; aggravate asthma; cause significant temporary decreases in lung capacity of 15 to over 20 percent in some healthy adults; cause inflammation of lung tissue; lead to hospitaladmissions and emergency room visits [10 to 20 percent of all summertime respiratoryrelated hospital visits in the northeastern U.S. are associated with ozone pollution]; and impair the body's immune system defenses, making people more susceptible to respiratory illnesses, including bronchitis and pneumonia. 5

But some people will feel symptoms at lower leve ls of exposure (even levels below the federal health standard), or experience more adverse eff ects at high levels. According to the American Lung Association, 2004, populations at increased risk in the Washington metropolitan region include

• 1,143,573 children 18 years of age and younger;

• 369,633 asthmatics, including 94,721 childre n with asthma and 277,912 adults;

• 191,510 residents with other chronic or pers istent respiratory diseases, such as chronic bronchitis and emphysema;

• 423,373 residents over the age of 65

Figure 2-4 shows a breakdown of some of the categories of sensitive populations by sub-region.ES T I M A T E S O F P O PUL A T I O N S

- A T

- R I S K EX PO S E D
T O ADV E R S E H E AL T H CO NS E Q U E NC E S F R O M O Z O N E

W A

SH I N G T O N D C

- M D

- VA M S A

0 100 200 300 400 500 T hou s ands

D i s t ri c t of C o l u m b i a S ubur ban M a ry l a n d N o r t h e r n V i r g i n i a ES T I M A T E S O F P O PUL A T I O N S

- A T

- R I S K EX PO S E D
T O ADV E R S E H E AL T H CO NS E Q U E NC E S F R O M O Z O N E

W A

SH I N G T O N D C

- M D

- VA M S A

0 100 200 300 400 500 T hou s ands

D i s t ri c t of C o l u m b i a S ubur ban M a ry l a n d N o r t h e r n V i r g i n i a

Figure 2-4. Approxim a tely one-third of the residents of Metropolitan W a s h i n g t o n a r e a a r e : c h i l d re n ; asthm a tics over 65; have chronic respiratory diseases; and/or are especially sensitive to ozone. These individuals are

m o re vulnerable to ill effects from air pollution. Source: Am erican Lung Association 6

As m e ntioned earlier, ozone poses a threat not only to hum an health, but also to the health of natural ecosystem s. Scientific evidence suggest s that air pollution weakens the im m une system s of m a ny types of vegetation and can cause significant crop dam a ge. In addition, rain and snow wash air pollution deposited on vegetation and architectural surfaces into the stream s and rivers of the region and finally into the Chesapeake Bay.

2.8 Frequency of Violation of Federal Health Standard for Oz one

The W a shington area has exceeded the federal 8-hour health standard for ozone since the standard was introduced in 1997. The num ber of ozone exceedance days in a season ranged from a low of 8 to a high of 48. In an average sum m e r from 1997 - 2006, there were 25 days when W a shington' s air exceeded the ozone standard.

The federal standard is 0.08 ppm (84 ppb) of oz one averaged over eight hours. Figure 2-5 shows the num ber of days that the W a shington region has violated the ozone standard since 1997. Violations are related to the weather (hot sta gnant sum m e rs are favorable for ozone form ation) and the levels of ozone precursors present in the am bient air.

The Metropolitan W a shington Council of Governm e nts (COG) issues an air quality forecast prepared by a regional team of m e teorologists each day during the sum m e r. The daily forecast and air quality index (AQI) advise the public of the air quality conditions for the next 24 hours,

MW AQC Ozone SIP 2-11 May 23, 2007MW AQC Ozone SIP 2-12 May 23, 2007so that those at risk can take adequate precautions and everyone can take action to reduce ozonecausing em issions.

Figure 2-5. Ozone Exceedance Days in the Metropolitan Washington area

E x c eed an c es o f 8- h o u r O z o n e S t an d a r d

W a s h i n gt o n, D

. C

. R e gi o n, 1 9 9 7

- 2 0 0 6

30 48

40

11 22 38

8 8 20 21

5 30 55

19 97 1 9 9 8 1 9 9 9 20 00 2 0 0 1 2 0 0 2 20 03 2 0 0 4 2 0 0 5 20 06

Yea rNumberofExceedanceDays N o t e : H e a l t h St anda r d f o r 8

- hour O z one i s 0

. 0 8 ppm

. D a t a show n a r e t h e nu m b e r o f da ys i n
e a c h ye a r w h e n a t l e a s t one m oni t o r i n t h e r e gi on r e c o r d ed gr ound- l e v e l oz o n e conc e n t r at i ons
a bove t h e 8

- h our he al t h s t a nda r d

.

2.9 The Metropolitan Washington Air Quality Committee (MWAQC)

Under Section 174 of the Clean Air Act Am endm ents, the governors of Maryland and Virginia and the m a yor of the District of Colum b ia certif ied the Metropolitan W a shington Air Quality Com m ittee (MW AQC) to develop specif i c recom m e ndations f o r a regional air quality plan in the W a shington, DC-MD-VA nonattainm e nt area. The agreem ent was renewed in 2004.

Mem b ers of MW AQC include elected of f i cials f r om the Cities of Bowie, College Park, Frederick, Gaithersburg, Greenbelt, Rockville, and Takom a Park in Maryland, and Alexandria, Fairfax and Falls Church, Manassas and City of Manassas Park in Virginia; the Montgom ery and Prince George' s county councils; the Montgom ery and Prince George' s county executives; the

m a yor of the District of Colum b ia and representa tives of the Council of the District of Colum b ia; and representatives of Calvert, Charles, and Frederick counties in Maryland, and Arlington, Fairfax, Loudoun, and Prince W illiam counties in Virginia.

Representatives of the general assem b lies of Maryland and Virginia, the state air m a nagem e nt directors, and the state transportation directors, and the chairm an of the National Capital Region Transportation Planning Board also are m e m b ers of MW AQC. The m e m b ership roster is contained in Appendix A.MWAQC Ozone SIP 2-13 May 23, 2007 The Metropolitan Washington Council of Governments, in close cooperation with state air quality and transportation agencies provides technical support to the Metropolitan Washington Air Quality Committee. Additional technical staff support is provided by county and city technical staffs.

MWAQC also has established a public advisory committee to provide recommendations regarding public participation in the development of the air quality plans. The Air Quality Public Advisory Committee (AQPAC) works closely with staff and submits formal recommendations to MWAQC. AQPAC members represent academic, business, civic, and environmental groups. AQPAC members are listed in Appendix A.

Representatives of the following state air management agencies are members of MWAQC: District of Columbia Department of Environment, Air Quality Division; Air and Radiation Management Administration of the State of Maryland's Department of the Environment (MDE); and the Commonwealth of Virginia's Department of Environmental Quality (VDEQ). Representatives of the following state transportation agencies are members of MWAQC: District Department of Transportation (DDOT), Maryla nd Department of Transportation (MDOT), and the Virginia Department of Transportation (VDOT).

Since the Washington metropolitan nonattainment area crosses state boundaries, the states and the District of Columbia established MWAQC to prepare a regional control plan. MWAQC's recommendations are forwarded to the Interstate Air Quality Council (IAQC) (see Section 2.10) and to the three state air agencies. In turn, each state will submit a SIP revision to EPA. In Maryland, the submittal is made by the governor or a designee; in the District of Columbia, by the mayor or a designee; and in Virginia by th e Director of the Virginia Department of Environmental Quality on behalf of the governor.

2.10 Interstate Air Quality Council

The Interstate Air Quality Council (IAQC) is a cabinet-level collaboration between the District of Columbia, the State of Maryland and the Commonwealth of Virginia, comprised of the secretaries of the environment and transportation. The purpose of the IAQC is to address issues of interstate transport of air pollutants and to provide a sound process for improving regional air quality. IAQC transmits air quality planning proposals and materials to MWAQC for review and consideration. MWAQC transmits proposed plans and reports to the IAQC for submittal by the Governors and the Mayor to EPA.MWAQC Ozone SIP 2-14 May 23, 2007 2.11 State Commitment/Implementation Assurances

The measures in the SIP must be supported by any necessary legislative authority adopted by the states and the District of Columbia and adopted by the applicable governmental body responsible for their implementation.

Section 110 of the 1990 CAAA specifies the conditions under which EPA approves SIP submissions. These requirements are being follo wed by MWAQC and the states in developing this air quality plan or SIP. In order to develop effective control strategies, EPA has identified four fundamental principles 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 fundamental principles are: a) Emissions reductions ascribed to the control measure must be quantifiable and measurable; b) The control measures must be enforceable, in that the state must show that they have adopted legal means for ensuring that sources are in compliance with the control
measure; c) Measures are replicable; and d) The control strategy be accountable 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.

2.12 Submittal of the Plans

The governors and the mayor (or their designees) are required to submit to the EPA air quality SIPs to meet the requirements of the CAAA. After MWAQC approves the SIP and the Interstate Air Quality Council approves, each of the states and the District of Columbia will submit the document, along with specific commitments, schedules for adoption as appropriate, to EPA’s Region III Office in Philadelphia.

2.13 Sanctions

EPA must impose various sanctions if the states or the District of Columbia do not submit a plan; or submit a plan that the EPA does not approve; or fail to implement the plan. These include: withholding federal highway funding; withholding air quality planning grants ; and imposing a federal plan (“federal implementation plan”). Failure to submit or implement a plan will have significant consequences for compliance with conformity requirements.

2.14 Reasonable Further Progress (RFP) Requirements

The Washington region is required to demonstrat e continued reductions of 15% in VOC or VOC with NOx substitution from 2002 and 2008. This SIP explains that the Washington region is able to demonstrate reasonable further progress for the period 2002-2008 using a 15% VOC reductionMWAQC Ozone SIP 2-15 May 23, 2007 (see chapters 5 and 11 for detail). MWAQC has taken the following steps in development of the regional air quality plan:

• Recalculation of 2002 base-year emissions inventory

The recalculated 2002 base year inventory of man-made pollution sources is 448.28 tons per day VOC and 597.22 tons per day of NOx. Chapter 3 provides complete documentation of the revised 2002 base year inventory.

• Recalculation of adjusted base-year inventories for 2002, and 2008 with MOBILE6.2

The 1990 CAAA does not allow states to take credit for emissions reduction measures implemented before the Act's passage on November 15, 1990. Consequently, it is necessary toadjust the 2002 base-year inventory to eliminate reductions that would occur in 2008 due to pre1990 rules and regulations. The RFP adjusted base-year 2002 inventory is 497.89 tons per day VOC and 638.81 tons per day NOx. The RFP adjusted year 2008 inventory is 485.44 tons per day VOC and 607.20 tons per day NOx.

• Recalculation of 2008 VOC emission target level and actual 2008 inventory

Difference of RFP adjusted years 2002 and 2008 VOC inventories is the non-creditable VOC emission reduction that would occur during the period 2002 through 2008. Non-creditable VOC emission reduction was estimated to be 12.45 tpd and is subtracted from the base-year 2002 inventory to develop adjusted base-year 2002 inventory, which is the basis for calculating the RFP target level. 15% VOC (or 65.38 tpd) emission reduction during the period 2002 though 2008 was required from the adjusted base-year 2002 inventory to meet the RFP requirement. Actual VOC target level is the difference of adjusted base-year 2002 inventory (435.83 tpd) and emission reduction required (65.35 tpd) and theref ore was estimated to be 370.45 tpd. Since the actual estimated 2008 inventory was 358.84 tpd of VOC, which is well below the target level, RFP requirement was met.

2.15 2009 Attainment Demonstration

The objective of the photochemical modeling study is to enable the air agencies to analyze the efficacy of various control strategies, and to demonstrate that the measures adopted as part of the State Implementation Plan will result in attainment of the ozone standard by 2009. The modeling exercise predicts future 2009 air quality conditions based on the entire ozone season in the base year 2002, and applies control measures to demonstrate the effectiveness of new measures in reducing air pollution.

The attainment modeling project was directed by the MWAQC’s Technical Advisory Committee (TAC) and the Metropolitan Washington Air Quality Committee, a policy committee. EPA’s Models-3/Community Multiscale Air Quality (CMAQ) is the model used for the attainment demonstration. Virginia Department of Environm ental Quality (DEQ) in consultation with the Maryland Department of the Environment (MDE), DC Department of the Environment (DDOE),MWAQC Ozone SIP 2-16 May 23, 2007 and the Metropolitan Washington Council of Governments (MWCOG), was responsible for conducting CMAQ runs for the Washington, DC-MD-VA nonattainment area and surrounding counties (i.e., the Washington region domain). Vi rginia DEQ’s modeling runs were done in coordination with the Ozone Transport Commission’s (OTC) modeling for the 12-state Ozone Transport Region (OTR), and with Visibility Improvement State and Tribal Association of the Southeast (VISTAS) Association for Southeastern Integrated Planning (ASIP) modeling, done for the southeastern states. Modeling centers in cluded New York State Dept. of Environmental Conservation (NYS DEC), University of Maryla nd, Northeast States for Coordinated Air Use Management (NESCAUM) and Virginia DEQ. Modeling inventories were developed, updated and shared among the regional modeling centers and provided by the MidAtlantic Visibility Union (MANE-VU) and VISTAS.

In addition to CMAQ model runs, the WOE consists of statistical analyses and additional modeling exercises that give further evidence of the region’s progress towards attainment. The photochemical modeling combined with supporting Weight of Evidence analysis provide strong evidence the region will attain the 8-hour ozone standard by 2009.

2.16 Analysis of Reasonably Available Control Measures (RACM)

An extensive list of potential control measures was analyzed and evaluated against criteria used for potential RACM measures. Individual measures must meet the following criteria: will reduce emissions by the beginning of the Washington region’s 2008 ozone season (May 1, 2008); are enforceable; are technically feasible; are economically feasible, defined as a cost of $3,500 to $5,000 per ton or less; would not create substantial or widespread adverse impacts within the region; and do the emissions from the source being controlled exceed a de minimus threshold, defined as 0.1 tons per day. A final short list of RACM measures that met most of the criteria was evaluated against two remaining criteria, the ability to reduce the region’s ozone levels to 84 parts per billion by 2008 and the potential for intensive and costly implementation.

2.17 Contingency Measures

In the event that the reductions anticipated in the 2008 RFP demonstrations or the 2009 attainment demonstration are not realized within the timeframes specified, there must be contingency measures ready for implementation. EPA issued guidance says that contingency measures must provide for a 3% reduction in adjusted 2002 base year inventory for both Reasonable Further Progress and attainment. A minimum of 0.3 % VOC must be included. The total reductions required for the RFP and attainment contingencies are 1.3 tons/day VOC and 15.3 tons/day NOx, with reductions achieved by 2010 and 2011 respectively. Emissions reduction requirements for both RFP and attainme nt contingencies are met using different measures. These proposed contingency measures are listed in Chapter 11. Chapter 11 contains detail on these measures, how they would be implemented, enforced, and the amount of reduction benefit expected.MWAQC Ozone SIP 2-17 May 23, 2007 Sources

1 Plan to Achieve a Fifteen Percent Reduction in Volatile Organic Compound Emissions for the Washington, DCMD-VA Nonattainment Area, MWAQC, January 14, 1994.

2 Revised State Implementation Plan (SIP) Revision, Phase I Attainment Plan, for the Washington DC-MD-VA Nonattainment Area , MWAQC, April 16, 1999.

3 State Implementation Plan (SIP) Revision Phase II Attainment Plan, for the Washington, DC-MD-VA Nonattainment Area , MWAQC, February 3, 2000 and Revision to State Implementation Plan (SIP) Revision, Phase II Attainment Plan, for the Washington DC-MD-VA Nonattain ment Area, Establishing Out-Year Mobile Emissions Budgets for Transportation Conformity , MWAQC, January 19, 2000.

4 Approval and Promulgation of Air Quality Implementati on Plans, District of Columbia, Maryland, Virginia, 1-Hour Attainment Plans, Rate-of-Progress Plans, Con tingency Measures, Transporta tion Control Measures, VMT Offset, and 1990 Base Year Inventory,”, Federal Re gister, Vol 70, No. 92, May 13, 2005, pp. 25688-25716 and Approval and Promulgation of Air Quality Implementation Plans; Maryland; Metropolitan Washington, DC 1-Hour Ozone Attainment Plan, Lifting of Earlier Rules Resu lting in Removal of Sanctions and Federal Implementation Clocks, Federal Register, Vol.70, No.220, November 16, 2005, pp.69440-69443.

5 http://www.epa.gov/ttn/oarpg/naaqsfin/o3health

6 American Lung Association, State of the Air Report, 2006, www.lungusa.orgMWAQC Ozone SIP May 23, 2007 3-1 3.0 THE 2002 BASE-YEAR INVENTORY

3.1 Background and requirements

The 2002 Base-Year Inventory is p ublished in a separate document, "2002 Base Year Emissions Inventory of Ozone Precursor Emissions for th e Washington, DC-MD-VA Nonattainment Area," (June 15, 2006). This document was prepared for the District of Columbia, Maryland and Virginia by COG under the auspices of MWAQC. It is available fo r inspection at the offices of the Council of Governments a nd the District of Columbia , Maryland, and Virginia air management agencies in addi tion to COG Web site (http://s harepoint.mwcog.org/airquality).

The emissions inventory covers the Washington DC-MD-VA nona ttainment area, Figure 2-1, which is classified as a mode rate nonattainment area for ozone by the U.S. Environmental Protection Agency (EPA). The 2002 emissions invent ory is the starting poin t for calculating the emissions reduction requirement needed to meet the 15% VOC emissions (for man-made sources of emissions) reduction goal by 2008 to meet r easonable further progress requirements (RFP) prescribed for moderate nonattainment areas by the Clean Air Act Amendments and EPA.

This separately published document addresses em issions of volatile orga nic compounds (VOCs), oxides of nitrogen (NOx), and carbon monoxide (CO) on a typical summer ozone season day and annual basis. Included in the inventory are stationary anthropogenic (man-made), biogenic (naturally occurring), and non -road and on-road mobile sour ces of ozone precursors.

The 2002 base-year ozone season inventories for VOC and NOx can be seen in Tables 3-1 and 3-2.

Table 3-1 2002 Base-Year Ozone Season VOC Inventory (Tons/Day)

District of Columbia Maryland Virginia Total

Point 0.24 4.60 8.07 12.91
Area 16.81 92.49 83.35 192.64
Non-Road 8.91 63.82 53.06 125.79
On-Road 13.09 56.13 47.71 116.94 Biogenics 13.63 166.70 134.41 314.74
Total 52.68 383.74 326.60 763.02 * Small discrepancies may result due to roundingMWAQC Ozone SIP May 23, 2007 3-2 Table 3-2 2002 Base-Year Ozone Season NOx Inventory (Tons/Day)

District of Columbia Maryland Virginia Total

Point 4.89 155.78 59.93 220.60
Area 2.16 6.77 15.32 24.25
Non-Road 10.54 34.21 40.97 85.72
On-Road 23.70 132.27 110.68 266.65 Biogenics 0.10 1.75 1.22 3.07
Total 41.39 330.78 228.12 600.29 * Small discrepancies may result due to rounding

Table 3-3 2002 Base-Year Ozone Season CO Inventory (Tons/Day)

District of Columbia Maryland Virginia Total

Point 1.01 77.72 9.77 88.50
Area 2.12 23.09 16.46 41.68
Non-Road 73.47 656.47 671.82 1401.76
On-Road 139.38 774.98 642.61 1556.97 Biogenics 1.13 16.08 12.38 29.59
Total 217.11 1548.34 1353.04 3118.50 * Small discrepancies may result due to roundingMWAQC Ozone SIP May 23, 2007 3-3 Table 3-4 2002 Base-Year Annual VOC Inventory (Tons/Year)

District of Columbia Maryland Virginia Total

Point 421.97 1169.50 701.93 2293.40
Area 6433.31 42671.04 34395.80 83500.16
Non-Road 2042.84 15341.7 14177.81 31562.36
On-Road 4582.50 19405.47 16920.67 40908.64 Biogenics 2519.63 31126.70 24906.38 58552.71
Total 16000.25 109714.41 91102.59 216817.27 * Small discrepancies may result due to rounding

Table 3-5 2002 Base-Year Annual NOx Inventory (Tons/Year)

District of Columbia Maryland Virginia Total

Point 3177.81 45920.04 14479.17 63577.02
Area 1694.70 5401.14 7091.38 14187.22
Non-Road 3535.64 10580.61 13680.71 27796.96
On-Road 8762.85 49018.07 41163.68 98944.60 Biogenics 25.91 430.75 301.22 757.88
Total 17196.91 111350.61 76716.16 205263.68 * Small discrepancies may result due to roundingMWAQC Ozone SIP May 23, 2007 3-4 Table 3-6 2002 Base-Year Annual CO Inventory (Tons/Year)

District of Columbia Maryland Virginia Total

Point 158.73 26419.14 1805.09 28382.96
Area 2328.39 54261.98 23697.04 80287.40
Non-Road 18753.14 161173.48 168615.54 348542.16
On-Road 64181.72 336517.27 288150.48 688849.47 Biogenics 226.51 3241.41 2481.13 5949.05
Total 85648.49 581613.28 484749.28 1152011.04 * Small discrepancies may result due to rounding

3.2 Total Emissions by Source

3.2.1 Point Sources

For emissions inventory purposes, point sources are defined as stati onary, commercial, or industrial operations that emit more than 10 tons per year (tpy) of VOCs or 25 tpy or more of NOx or CO. Prior to being reclassified to a se vere area, the threshold was 100 tons/year of NOx. The point source inventory consists of actual emissions for the base-year 2002 and includes sources within the geographica l area of the Washington DC-M D-VA nonattainment area. The states of Maryland and Virginia and the District of Columbia are responsible for compiling and submitting point source emission estimates.

In 2002, the State of Maryland also included all types of Andrews Air Force Base emissions in their point source emissions. These sources are called quasi-point source emissions.

3.2.2 Area Sources

Area sources are sources of emissions too sma ll to be inventoried individually and which collectively contribute significant emissions. Area sources incl ude smaller stationary point sources not included in the states' point source in ventories such as prin ting 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 collective activity for each source category at the county (or county-equivalent) level. An activity level is any parameter asso ciated with the activity of a source, such as production rate or fuel consumpti on 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 oflanding and takeoff cycles (LTOs) by an EPAapproved emission factor per LTO cycle for each specific aircraft type.MWAQC Ozone SIP May 23, 2007 3-5 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) factor s. For example, solvent evaporation from consumer and commercial products such as waxe s, aerosol products, and window cleaners cannot be routinely determined for many local sources. The per capit a emission factor assumes that emissions in a given area can be reasonably associated with population. This assumption is valid over broad areas for certain activities such as dry cleaning and small degreasing operations. For some other sources an employment based factor is more appropriate as an activity surrogate.

3.2.3 Mobile Sources

Emissions from mobile sources were derived from the use of the National Capital Region Transportation Planning Board (TPB) travel de mand forecasting procedure, which simulates vehicle travel across the region' s transportation system. Travel was simulated on all highways in the region, including both volume and speed of travel for each hour of the day. An EPA emissions model, MOBILE 6.2.03, was used to dete rmine the emissions characteristics of the vehicle fleet in place in the year 2002. Input fo r this emissions model in cludes locally specific information such as age distribut ion of registered vehicles, eva poration characteristics of motor fuel, and temperature data. The general equa tion for the estimation of mobile sources is:

(Travel Component) x (Emission Factor) = Emissions Emissions accounted for in the mo bile source inventory include:

Origin: Emissions include "cold st art" and "hot start" emissions occurring during the first few minutes of vehicle operation. Running: Emissions occurring on lo cal streets and on the region's network of arterial streets, freeways and non-ramp freeways. Running Loss: Emissions due to the heating of fuel and fuel lines. Crankcase: Emissions due to blow-by. Destination: Evaporative or "hot soak" emissions occurring at the conclusion of a vehicle trip afte r the engine is turned off. Diurnal: Evaporative emissions occurri ng when the vehicle is at rest due to temperature fluctuations. Resting Loss: Emissions due to the permeation of fuel through hoses and fittings. Auto Access: Emissions attributable to au to trips to Metrorail stations or to park-and-ride lots. Bus: Bus emissions, i.e., Metrobus, Ride-on, etc.MWAQC Ozone SIP May 23, 2007 3-6 3.2.4 Nonroad Sources

Emissions for all nonroad vehicles and engi nes except airport (aircraft, ground support equipment (GSE) and, auxiliary power units (APU), locomotives, and diesel marine vessels were calculated using EPA’s NONROAD2005 model vers ion 2005a (February 8, 2006) except for locomotives, marine diesel vessels, and aircrafts. This model was run with its associated graphic user interface NONROAD2005.0.0 (December 2, 2005), reporting utility ve rsion. 2005c (March 21, 2006), and all geographical allocation data files updated until February 1, 2006.

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

• Recreational vehicles, such as all-terra in 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 equipment, such as leaf and snow blowers. • Aircraft ground support equipment.

The nonroad model estimates emissions for each specific 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 deterior ation and/or new standards.

The emissions are then temporally and geograp hically allocated using appropriate allocation factors.

Aircraft (military, commercial, general aviation, and air taxi) and auxili ary power units (APU) operated at airports along with locomotives a nd diesel marine vessels are also considered nonroad sources and are include d in the nonroad category.

Metropolitan Washington Airports Authority (MWAA) provided a ll types of airport emissions for Dulles (Fairfax & Loudoun) and Reagan National (Arlington) airports, which are documented in Air Pollution Emission Inventories for Washington Dulles International Airport and Ronald Reagan Washington National Airport for Calendar Years 2002, 2008, 2009 1 (see Appendix B4 of the 2002 base year inventor y document). Nonroad model-generated ground support equipment emissions for Loudoun and Arlington counties were replaced by emissions

1 Metropolitan Washington Airports Authority, Air Pollution Emission Inventories for Washington Dulles International Airport and Ronald Reagan Washington National Airport for Calendar Years 2002, 2008, 2009, prepared by URS Corporation, Washington, D.C. March 2006.MWAQC Ozone SIP May 23, 2007 3-7 provided by MWAA. While MWAA GSE emissions for Dulles airport were equally divided between Fairfax and Loudoun counties, Reagan National emissions were put into Arlington County. Aircraft and APU emissions for other co unties were provided by th e respective states. Emissions from locomotives and commercial dies el marine vessels were also provided by the
states.

3.2.5 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 throughout the day. Biogenic emissions of NOx include lightning and forest fires. EPA used a biogenic computer model (BEIS3.12) to estimate biogenic emissions for each county in the country for all twelve months of the year 2002. Emissions data fo r Washington, DC ozone non-attainment area counties were acquired from the EPA web-site (ftp://ftp.epa.gov/EmisInventory/ 2002finalnei/biogenic_sector _data/). EPA has recommended that states use these emissions in case they do not have their own estim ated biogenic emissions. The Washington, DC-MD-VA ozone non-attainment area decided to use the inventories provided by the EPA.

3.3 Annual Inventories

The 2002 base-year inventories for VOC, NOx and CO in Tables 3-1 through 3-3 are for the typical ozone season day and in Tables 3-4 thro ugh 3-6 for the annual emissions. A summary of both the ozone season day and the annual invent ories for VOC, NOx and CO is also found in Table 1-1 of Appendix B.4.0 The 2008 and 2009 Projected Inventories

Part II of EPA’s rule to implem e nt the 8-hour NAAQS requires the W a shington, DCMD-VA ozone nonattainm ent region to ach ieve a 15 % reduction between 2002 and 2008 using reductions in either VOC or NOx e m i ssions or with any com b ination of the two. 1 Also an inventory for the attainm e nt y ear 2009 is required for the region. The 15 % reduction must be calculated from the anthr opogenic em issions levels reported in the 2002 base year em issions inventory after t hose levels have been adjusted for noncreditable em issions reduction occurr ing between 2002 and 2008. The 2002 Base-Year Inventory is described in Chapter 3. T h is chapter presents the 2008 and 2009 projection invento r ies, the es tim ation of the lev e ls of em issions to be expected in those years before the consideration of em issions controls.

The 2008 and 2009 projected inventories were derived by applying the appropriate growth factors to the 2002 base year em i ssions inventory. EP A guidance describes four typical indicators of growth. In order of priority, these are product output, value added, earnings, and em ploym e nt. Su rrogate indicators of ac tivity, for exam ple population growth, are also acceptable m e thods.

Round 7.0 Cooperative F o recasts (po pulation, ho usehold and em ploym e nt projections) and Vehicle Miles T r aveled (VMT) projecti ons for 2008 and 2009 were used to project

area sou r ces em issions. Round 7.0 Cooperative F o recasts were prepared b y the Metropolitan W a shington C ouncil of Governm e nts (MW C OG) staff and officially adopted by its Board of Directors on October 12, 2005, prior to the Base Realignm ent and Closure (BRAC) announcem ents. Vehicle M i les Traveled (VMT) projection s were developed by COG Departm e nt of Transportation Planning st aff as part of the report on 2005 Constrained Long Range Plan (CLRP) & 2006-2011 Transportation Im prove m e nt Program (TIP) f o r the Nationa l Capital Region T r ansportation Planning Board. Projections f o r onroad em issions were developed using MOBILE6.2 (January 2003) model and the Travel D e m a nd Model ver. 2.1d #50 developed by the National Capitol Region Transportation Planning Board. The tr avel dem a nd modeling process also used Round 7.0 Cooperative F o recasts.

EPA’s nonroad m odel, NONROAD2005, was used for developing both 2008 and 2009 nonroad inventories. The Econom ic Growth An alysis System (EGAS) m o del was used by all three jur i sdictions to projec t grow th in point source em issions.

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M W AQ C O z on e SI P May 23

, 20 07 4- 14.1 Grow th Pr ojection Methodology

The following sections describe the m e t hods followed to determ ine the projected inventories f o r 2008 and 2009 for point, ar ea, nonroad, and onroad sources.

4.1.1 Grow th Pr ojection Methodology for Point Sources: EGA S The growth in point source em issions is pr ojected using EGAS version 5.0. Point source

em issions for 2002 are provided from the state da ta sources and the m ode l is run with the following options selected: Source Classificatio n Code; the Bureau of Labor Statistics national eco nom i c forecast; and the baseline reg i onal econo m i c forecast. Point source

em ission projections using EGAS for 2008 and 2009 are contained in Appendix C.

4.1.2 Grow th Pr ojection Methodology: Area Sources

Base year 2002 area source em issions were calculated using the year 2002 population, household, and em ployment data. Growth factors for the periods 2002 through 2008 and 2002 through 2009 were derived by divi ding Cooperative R ound 7.0 population, household, and em ployment forecasts and Vehi cle Miles T r aveled (VMT) d a ta prov ided by COG Departm e nt of Transportation Planning for 2008 and 2009 by the year 2002 population, household, employm e nt, and VMT data for the region respectively. Cooperativ e Round 7.0 Forecasts an d VMT data are prov ided in Appendix D1 and E1 respectively. Projected ar ea source inventories for 2008 and 2009 are contained in Appendix D1. Growth factors used for th e 2008 and 2009 projection years are presented in Tables 4-1 and 4-2.

Table 4-1 2002-2008 Grow th Factors

Jurisdiction Employment a Population a Household a VMT b

District o f Col u m b ia 1. 03 2 1

. 03 8 1. 04 1 1. 03 3

Calv ert Coun ty 1. 23 8 1

. 12 6 1. 12 7 1. 15 1

Ch arles C o un t y 1. 26 4 1

. 12 7 1. 14 2 1. 14 0

Fr ed er ick Coun ty 1. 25 9 1

. 14 0 1. 14 3 1. 14 6

M ont gom ery C o u n t y 1. 08 8 1

. 08 4 1. 08 2 1. 04 8

Pri n ce Ge or ge' s C o unt y 1. 09 0 1

. 04 7 1. 06 7 1. 04 5

City o f Alex and r ia 1. 15 0 1

. 07 1 1. 08 6 1. 04 5

Arling t on C o un ty 1. 11 3 1

. 06 8 1. 08 6 1. 01 9

Fairfa x C o u n ty 1. 10 9 1

. 09 8 1. 10 1 1. 05 8

Fairfax City 1. 05 2 1

. 05 8 1. 05 7 1. 05 8

M W AQ C O z on e SI P May 23

, 20 07 4- 2Falls Ch urch C ity 1. 14 5 1

. 10 9 1. 13 2 1. 05 8

Lou dou n Cou n ty 1. 36 7 1

. 44 4 1. 44 7 1. 29 2

Prin ce W illia m Cou n t y 1. 20 1 1

. 26 3 1. 26 7 1. 16 3
Manassas City 1. 05 5 1

. 05 8 1. 07 9 1. 16 3

Manassas Park City 1. 38 3 1

. 24 9 1. 27 9 1. 16 3

a Growth factors base d on COG Round 7.0 C o ope r ative Forecasts.
b G r ow th f actor s b a sed o n VMT esti m a tes f r o m 2 005 CLR P & 20 06- 2011 TI P pr ov id ed b y COG Depa rt m e nt of Tran sp ort a t i o n Pl anni ng

.

Table 4-2 2002-2009 Grow th Factors

Jurisdiction Employment a Population a Household a VMT b

District o f Col u m b ia 1. 04 3 1

. 04 9 1. 05 1 1. 03 8

Calv ert Coun ty 1. 26 6 1

. 14 7 1. 14 7 1. 16 1

Ch arles C o un t y 1. 29 1 1

. 14 1 1. 16 0 1. 15 9

Fr ed er ick Coun ty 1. 29 7 1

. 16 2 1. 16 5 1. 17 5

M ont gom ery C o u n t y 1. 10 6 1

. 09 7 1. 09 5 1. 05 7

Pri n ce Ge or ge' s C o unt y 1. 10 8 1

. 05 2 1. 07 6 1. 06 2

City o f Alex and r ia 1. 16 6 1

. 08 3 1. 10 1 1. 08 3

Arling t on C o un ty 1. 13 7 1

. 08 2 1. 10 2 1. 02 3

Fairfa x C o u n ty 1. 13 8 1

. 11 7 1. 12 0 1. 07 4

Fairfax City 1. 06 6 1

. 07 1 1. 06 7 1. 07 4

Falls Ch urch C ity 1. 09 4 1

. 14 1 1. 17 2 1. 07 4

Lou dou n Cou n ty 1. 42 7 1

. 51 5 1. 51 7 1. 33 1

Prin ce W illia m Cou n t y 1. 23 5 1

. 30 4 1. 31 2 1. 18 9
Manassas City 1. 06 7 1

. 06 4 1. 08 9 1. 18 9

Manassas Park City 1. 48 9 1

. 28 6 1. 32 2 1. 18 9

a Growth factors base d on COG Fi nal Round 7.0 C o ope rative Forecasts.
b G r ow th f actor s b a sed o n VMT esti m a tes f r o m 2 005 CLR P & 20 06- 2011 TI P pr ov id ed b y COG Depa rt m e nt of Tran sp ort a t i o n Pl anni ng

.

2008 and 2009 em issions for area so urces were calculated by multiply ing the 2002 bas e

year area em issions by the above growth factors for 2008 and 2009 for each jurisdiction. Each area so urce category was m a tched to an appropriate growth surrogate based on the

M W AQ C O z on e SI P May 23

, 20 07 4- 3activ ity us ed to gener a te the base -yea r em ission e s tim ates. Surrogates were chosen as f

o llows:
Surface Coating – Depending on whether em ission f actors were based on em ployment or population, the surrogate chosen varied wi th individual sub-categories. For exam ple, the autom obile refinishing category was grow n using em ploym ent, as the em ission factor was based on it, but population was chosen fo r growing traffic m a rkings as its em ission factor was based on population.

Commerc ia l/Consumer Solvent Use - Population was chosen as the growth surrogate since 2002 em issions are based on per capita em ission factors.

Residential Fuel Combustion - Household was chosen as the growth surrogate.

Industrial/Commercial/Instituti onal Fuel Combustion - Population was chosen as the growth surr ogate exc e pt f o r the comm ercial/ins t itution a l coa l com bustion catego r y, where no growth was assum e d.

Vehicle Fueling (Stage II) a nd Underground Tank Breathing - All gas o line m a rketing catego r ies w e re bas e d on vehicle m iles trav el ed (VMT) data since VMT is an appropriate surrogate for gasoline sales. Em ission factor s for these categories are based on gasoline sales.

Open Burning - Population was chosen as the grow th surrogate as yard wastes, land debris, etc. increas e with population.

Structural Fires, Mo to r Vehicle Fires – Population was chosen as the growth surrogate.

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

Dry Cleaning - Em ploym ent was chosen as the surrogate.

Graphic Arts - Population was used to estim a te growth since em issions are based on per capita em ission factors.

Surface Cleaning - Em ploym ent growth was used as the surrogate.

Tank Truck Unloadin g – Growth in VMT was applied to this category since base-year

em issions are calculated using gasoline sales.

Municipal Landfills - Base-year em issions are estim at ed using data on total refuse deposited. Population was chosen as a surrogate since deposited waste is from the general population rather than industrial facilities.

Asphalt Paving - Population was chosen as the surr ogate since base-year em issions are calculated using per capita em ission factors.

M W AQ C O z on e SI P May 23

, 20 07 4- 4Bakeries, Brew eries - P opulation was chosen as the surrogate.

Soil/Groundw a ter Remediation - Zero growth was applied to this category. The number of re m e diations during the ozone season, used to generate base-year em issions, does not directly correlate to population, households, or employm e nt growth.

Portable Fu el Container Emissions - Em issions for the District of Columbia and Maryland from residential and com m e rcial s ectors were grown based on household and

em ploym e nt respectively. Em issions for Virg inia were grown using the fuel usage by SCCs associated with th e refueling o f porta ble fu el containers . These fuel usage data were derived from the NONROAD2005 m odel by MACTEC as part of the em issions developm ent efforts for the Visibility Im prove m e nt State and Tribal Association of the Southeast (VISTAS) modeling process.

Commerc ia l Cooking - Em ploym e nt growth wa s used as the surrogate.

Compostin g – Zero growth was applied to this category.

Forest Fires, Slash Burning, Prescribed Burning – Zero growth was applied to this catego r y.
Accidental Oil Spills - Zero growth was applied to this category.

Incineratio n – Zero growth was applied to this category.

Pestic ide Application - Zero growth was applied to this category.

Aircraft Refueling Emissions - Em issions from refueling of aircrafts was projected based on employm ent.

4.1.3 Grow th Pr ojection Methodology: Nonroad Sources

The 2008 and 2009 nonroad source inventories we re created through the use of EPA’ s NONROAD2005 m odel version 2005a (Febru ary 8, 2006), except for locom o tives,

m a rine diesel vessels, and aircrafts. This m odel was run with its associated graphic user interface NONROAD2005.1.0 (June 12, 2006), repor ting utility version. 2005c (March 21, 2006), and all geog raphical allocation data files updated u n til Feb r uary 1, 2006. The base year 2002 nonroad source inventory was also created using the sam e model, reporting utility and geo g raphic a l a l location d a ta f

iles, but with a dif f

e rent graphic us e r interface version NONROAD2005.0 .0 (Decem be r 2, 2005).

Nonroad m o del runs were m a de for t h e m e tropolitan W a shington region for average ozone season day. The ozone season extends from May through September. However, the NONROAD2005 m odel used in these runs did no t have the option to run the m odel for the ozone season period. Instead, it provide d an option for a summ er season (June – August) run. In order to get average ozone season day em issions, the m o del was run for

M W AQ C O z on e SI P May 23

, 20 07 4- 5the entire summer season (June-August) wh ile us ing average ozone seaso n fuel
param e ters. Then tota l e m issions calculated th is way were divided by the total num be r of days in the summ er season (92) to get aver age ozone season day em issions. Monthly fuel data obtained from the states were averaged for the period May through Septem ber to get fuel param e ters reflecting the ozone season pe riod. Three different se ts of average o z o n e season fuel param e ters were develo ped each fo r the District of Colum b ia, Virginia, and Maryland.

Methodology to prepare inputs for ozone season day runs is provided below.

Tem p erature Tem p erature data were acquired from the Natio nal Clim atic Data Center (NCDC). Hourly average tem p erature data were coll ec ted f o r Dulles (I AD) and Reagan Nation a l (DCA) weather stations for the top ten 8- hour maxim u m ozone days during the period 2002-2004. Then the tw o hourly datasets were averaged together to get one hourly dataset. Then m i nim u m, m a xim u m, and averag e tem p eratures were com p uted from this hourly tem p erature dataset.

Fuel inputs Month specific data for fuel RVP and oxygen weight percent were provided by the state air ag encies of Maryland a nd Virginia. These data were averaged for the period May through Septem ber to get ozone season average inputs. The District of Colum b ia decided to use year and ozone season specific Mobile6 model default values for these param e ters. Nonroad m o del defaults were used for sulfur content in gas, diesel, m a rine diesel, and CNG/LPG. Model default (Zero %) Stage II controls were assum e d for the m odel runs.

Model inputs (tem perature, fuel, and other parameters) for both 2008 and 2009 are listed below f o r ea ch jur i sdic tion: Table 4-3 NONROAD Model - Common Inputs

Parameters V a l u e s Min. Tem p erature 69.8 M a x. Tem p era t ure 92 .5 Avg. Tem p erature 81.4 Gas S u l f ur

( % ) 0. 00 3 D i esel Su lf ur (%) 0

. 0 348 M a ri ne Di esel Sul f ur (% ) 0. 04 0 8 C NG/ LP G Sul f u r (%) 0. 00 3 Oxy g en W e i g h t (%) 2. 1 Stage II C o ntr o l (% ) 0

M W AQ C O z on e SI P May 23

, 20 07 4- 6Table 4-4 NONROAD Model – State-Specific Inputs

S t a t e R V P Di st ri ct o f C o l u m b i a 6. 8 M a ry l a n d 6

. 9 Virg in i a 6

. 8

Since the nonroad m odel does not generate em issions for aircraft, APU, locom o tives, and commercial diesel m a rine vessels, these were either projected from the base year

em issions using the Coo p erative Forecast 7.0 o r acquired from M W AA. Below are th e details for projecting em issions for the above m e ntioned individual nonroad categories.

Aircraft em issions (comm e rcial, m ilitary, gen e ral aviation, air taxi) Metropolitan W a shington Air ports A u thority (MWAA) provi ded all types of airport

em issions for Dulles and Reagan Nationa l airports, which are docum ented in Air Pollution Emission Inventories for Washingt on Dulles International A i rport and Ronald Reagan Washington National Airport for Calendar Years 2002, 2008, 2009 2 (see Appendix B4 of the base year 2002 inventory docum e nt). Since Dulles airport is spread across Fairfax and Loudoun counties, M W AA e m i ssion from Dulles airport were divided equally between Fairfax and Loudoun counties. Em issions from Reagan National airport were put into Arlington County.

Milita ry airc raft em issions for Maryland fo r future years were provided by MDE. No growth was assum e d f o r Virginia m ilita ry aircraf t em issions.

General aviation and air taxi em issions for Maryland were provided by MDE. For Virginia, these em issions were grown from the base year using population as the surrogate.

Auxilia ry po wer unit em issions These em issions were only available fo r Dulles (Fairfax & L oudoun) and Reagan National (Arlington) airports and were provided by the MW AA. Details on the developm ent of these em issions are provide d in the MW AA airpor t em issions document referred abo v e.
Ground support equipment em issions The NONROAD2005 model generated th ese em issions for Arlington, Loudoun, Manassas city, Fredrick, Montgom ery, and Prince Georges’ counties. However,

em issions for Arlington, Fa irfax, and Loudoun counties we re taken from the MWAA docum ent referred above. M W AA GSE e m issions were generated using the EDMS model, which calculated em issions based on actu al aircraft operations and used data from

a recen t surv ey perform e d in February 2004 on GSE fleet, fuel types, and operating

2 Metrop o litan Wash ing t on Airpo r ts Au tho r it y, Air P o llution E m ission Inv e ntories f o r W a shi n gton Dull es I n tern a tiona l Airp o r t an d Ro na ld Reaga n Wa sh i n g t on Na ti o n a l Airp ort for Ca lenda r Yea rs 20 02 , 200 8, 2 009

, p r epa r ed by UR S C o r p orat i o n, W a s h i ngt on , D.C

. M a rch 2 0 0 6

.

M W AQ C O z on e SI P May 23

, 20 07 4- 7tim es. Nonroad m odel calculated em issi ons are based on GSE population only and therefore emissions generated this way were considered less ac curate than the one generated by the EDMS m odel. MWAA also provided em issions from m o bile lounges for Dulles airport separately, which were com b ined with GSE em issions. W h ile MW AA GSE e m ission from Dul l es airport were divided equally between Fairfax and Loudoun counties, those from Reagan National ai rport were put into Arlington county.

Comm ercial Diesel Marine Vessels Base year em issions from co mm ercial diesel m a rine vesse ls were provided by MDE and were grown to future years using em ploym ent as the surrogate.

Railroad Railroad or locom o tive em issions were provide d by all three states and were grown using

em ploym e nt as the surrogate.

Projected nonroad source i nventories for 2008 and 2009 are contained in Appendix D1. Detailed NONROAD200 5 m odel output files are be ing provided separately in electronic for m at as Appendix D2 of this docum ent.

4.1.4 Grow th Pr ojection Methodology: Onroad Sources

The 2008 and 2009 m obile source inventor ies were created through the use of transportation and em issions m odeling t echniques. This involved use of the MOBILE6.2.03 em issions factor m o del and the Version 2.1d #50 Travel De m a nd Model with 2008 and 2009 planned highway network. Fu ll docum entation of the developm ent of the 2008 and 2009 m obile inventories is in cluded in Appendix E1. Detailed Mob6.2.03 model input, output, and external output files are being provided separately in electronic for m at as Appendix E2 of this docum ent. Appropriate population, household, and

em ploym e nt growth are input through the R ound 7.0 Cooperative Forecasting techniques.

4.1.5 Biogenic Emission Projections

2002 base year em issions were estimate d by EPA using BEIS3.12 m odel. Biogenic

em ission inventories for 2009 are the sam e as those used for the 2002 base year for Washington, DC-VA-M D ozone nonattainm e nt region. Year specific biogenic inventories f o r 2009 were not estim ated. No 2008 biogenic inventories were prepared as they are not used to determ in e reasonable further progress.

4.2 Offset Provisions and Point Source Grow th

The Act requires that em ission growth from major stationary s ources in nonattainment areas be offs et by reductions that would not otherwise be achieved by other m a ndated controls. The offset requirem ent applies to all n e w m a jor stationary sou r c e s and exis ting

m a jor stationary sources that have undergone major m odifications. Increases in em issions from existing sources resulting from increases in capacity utilization are not subject to the

M W AQ C O z on e SI P May 23

, 20 07 4- 8offset requirem e nt. For the purposes of the o ffset requirem e nt, m a jor stationary sources include all stationary sou r ces ex ceeding an applicable size cu toff. The Wa shington, D C region is designated as moderate nonattainm e nt for the 8-hour ozone standard. Under the
current m o derate designation, the NSR th resholds are 50 tpy VOC and 100 tpy NOx.

The New Source Review perm it regulations in Virginia are structured so that the pertinent req u irem ents su ch as m a jor source threshold and offset ratio are selfim ple m enting depending upon changes to the non attainm e nt area classification. The N S R threshold will rem a in at 25 tpy for both VOC and NOx for Maryland and the District. NSR offset ratio of 1.15 to 1.00 appli cable for m o derate area was used.

4.3 Actual vs. Allow a ble Emissions in Development of the 2008 and 2009 Projected Emissions In ventories

For the purposes of calculating 2008 and 2009 projection em issions inventories, EPA guidance sp ecifically ou tlin es the circum stances under which em issions projections are to be based on actual or allowable em issions. For so urces or sou r ce categories that are subject to a pre-1990 regulation and the state do es not anticipate subjecting the source to additional regulation, emissions projections should be based on actual em issions levels. Actual em issions levels should also be used to project for sources or source categories that were unregulated as of 1990. For sources that are expected to be subject to post-1990 regulation, projections should be ba sed on new allowable em issions.

To sim p lify com p arisons between the base-y ear and the projected year, E P A guidance states that com p arison should be m a de only be tween like em issions: actual to actual, or allowable to allowable, not actu a l to allowable. Therefore, all bas e year and all projection
year em issio n s estim ates are bas e d on actual em issions.

The term "actual em issions" m eans the average rate, in tons per year , at which a source discharged a pollutant during a one year period, which preceded the date or other specified date, and which is representative of norm a l source operation. Actual em issions are calculated using the source' s operating hou rs, production rates, and types of m a terial processed, stored, or com busted dur ing the selected tim e period.

"Allowable em issions" are defined as the m a xi m u m e m issions a source o r insta lla tion is capable of discharging after consideration of any physical , operations, or em issions lim itations required by s t ate regulations or by federally enforceab le cond itions, wh ic h restrict operations and which are included in an a pplicab le a i r quality per m it to constr uct or perm it to operate, secretarial order, plan for co mpliance, co nsent agreem ent, court order, or applicable federal requirem e nt.

4.4 Projection Inventory Results

The 2008 and 2009 VOC and NOx projection-year em ission inventory results with no control m e a s ures applied summarized by com p onent of the invent ory in Tables 4-3 though 4-6 below.

M W AQ C O z on e SI P May 23

, 20 07 4- 9Table 4-5 2008 Projected Uncontrolled VO C Emissions (tons/day)

Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b

Point 5

. 3 4 8

. 4 0 0

. 2 6 1 3

. 9 9

Area 1 0 1

. 6 2 9 3

. 5 5 1 7

. 4 0 2 1 2

. 5 6

Non-road 6 5

. 2 7 5 5

. 6 1 8

. 5 6 1 2 9

. 4 4

Mobile 3 6

. 5 6 3 2

. 6 2 7

. 9 9 7 7

. 1 7

Total b 2 0 8

. 7 8 1 9 0

. 1 8 3 4

. 2 1 4 3 3

. 1 7
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 0

. 9 8 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s Ai r Force Base (AFB).
b Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

.

Table 4-6 2008 Projected Uncontrolled NO x Emissions (tons/day) Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b

Point 1 7 6

. 9 1 5 6

. 9 8 8

. 1 2 2 4 2

. 0 1

Area 7

. 1 1 1 7

. 5 8 2

. 2 4 2 6

. 9 3

Non-road 3 6

. 1 4 4 4

. 2 8 1 0

. 7 1 9 1

. 1 3

Mobile 9 2

. 5 1 8 0

. 1 0 1 7

. 3 6 1 8 9

. 9 7

Total b 3 1 2

. 6 7 1 9 8

. 9 3 3 8

. 4 3 5 5 0

. 0 3
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 2

. 2 1 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s AFB

. b Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

.

M W AQ C O z on e SI P May 23

, 20 07 4- 1 0Table 4-7 2009 Projected Uncontrolled VO C Emissions (tons/day)

Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b

Point 5

. 3 3 8

. 8 1 0

. 2 6 1 4

. 4 0

Area 1 0 3

. 0 6 9 5

. 4 4 1 7

. 5 7 2 1 6

. 0 7

Non-road 6 6

. 0 0 5 6

. 5 8 8

. 5 8 1 3 1

. 1 6

Mobile 3 4

. 9 7 3 1

. 3 6 7

. 5 2 7 3

. 8 5

Total b 2 0 9

. 3 5 1 9 2

. 1 9 3 3

. 9 3 4 3 5

. 4 8
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 0

. 9 8 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s AFB

. b Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

.

Table 4-8 2009 Projected Uncontrolled NO x Emissions (tons/day) Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b

Point 1 7 6

. 8 5 5 7

. 4 0 7

. 5 4 2 4 1

. 7 9

Area 7

. 1 7 1 7

. 9 6 2

. 2 6 2 7

. 3 9

Non-road 3 6

. 6 6 4 5

. 1 2 1 0

. 8 2 9 2

. 6

Mobile 8 9

. 7 4 7 7

. 5 3 1 6

. 8 9 1 8 4

. 1 6

Total b 3 1 0

. 4 1 1 9 8

. 0 2 3 7

. 5 2 5 4 5

. 9 5
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 2

. 2 1 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s AFB

. b Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

.

M W AQ C O z on e SI P May 23

, 20 07 4- 1 14.5 Emission R e ductions from Control Measures

Chapter 6 of this SIP describes the control m easures that have either alread y been im ple m ented or will b e implem e nted by 2008 and 2009 that will reduce em issions in the two years. Most control m eas ures are required by federa l or state regulations. Local
governm e nts and state agencies h a v e voluntarily comm itted to other m easures, as described in Section 6.5. Projected contro lled inventories for 2008 and 2009 assum e a

num b er of control m easures to be in place by these years.

Tables 4-9 through 4-12 present the projecte d controlled em issions for the 2008 rate-ofprogress and 2009 attainm e nt years resulti ng from i m ple m entation of the control

m easures. Below is a list of the m eas ur es im plemented by the year 2002 in the Washington region. Chapter 6 presents detail ed infor m ation on the m easures and the projected reductions from each.

Point Non-CTG VOC RACT t o 50 tpy NOx OTC Phase II Budget Rules (DC only) Expanded Non-CTG VOC RACT and State Po int Source Regulations to 25 tons/yr NOx SIP Ca ll (MD)

Area Stage II Vap o r Recovery Phase II Volatility Contr o ls of Ref u eling Em issions Refor m ulated Surface Coatings Refor m ulated Consum er Products – National Rule Refor m ulated Industrial Cleani ng Solvents – National Rule National S t andards for Locom o tive Engines Surface Cleaning/Degreasing for Machinery / Autom o tive Repair Landf ill Reg u lations Seasonal Open Burning Restrictions Stage I Expansion (Tank Truck Unloading) Graphic Arts Controls Auto body Refinishing

Nonroad 1994 EPA Non-Road Diesel Engines Rule 1995 EPA Non-Road Small Gasoline Engines Rule, Phase 1 and Phase 2 (handheld and non handheld) 1996 EPA Em issions standards for s p ark ign itio n m a rine en gines 2002 EPA Em issions standards for large spark ig nition engin e s Refor m ulated Gasoline (off-road)

Onroad High-Tech Inspection/M a inten a nce (I&M) Refor m ulated Gasoline (on-road)

M W AQ C O z on e SI P May 23

, 20 07 4- 1 2Federal “Tier I” Vehicle Standards and New Car Evaporative Standards National Low Em ission Vehicle Program

Below is a list of the m e asures with pha sed-in implem e ntations between 2002 and 2009 in the W a shington region. Note that the Dist rict' s OTC VOC r u les on all the applicable

area sou r ce catego r ies ar e or will be f u lly adop ted

, subm itted to EPA, and f e derally enforceable m easures. However, the em issi on red u ctions of 3. 38 tpd VOC in 2008 and 3.80 tpd VOC in 2009 arising from these m easures in the District ar e not applied to the

em issions inventories pres ented in th is RFP/attain m e nt m ode ling/contingency dem onstration of the Washington D C -MD-VA re gional S I P. The District of Colum b i a ' s

m easures ar e expected to provide ad dition a l enh a ncem ents to the air qua lity im provem e nt in the region.

Point Clean Air In ters tate Rule (CAIR) (VA and DC) Maryland H ealthy Air Act (MD)

Area Additional phase-in of reductions f r o m National Locom o tives Rule OTC Mobile Equipm ent Repair a nd Refinishing (VA and DC) Rule OTC AIM Coatings Rule OTC Solvent Cleaning R u le for VA and DC OTC Consum er Products Rule - Phase I & II OTC Portable Fuel Container Rule - Phase I & II OTC Industrial Adhesives Rule On-Board Refueling/Vapor Recovery Rule for LD Trucks (2004)

Nonroad 2004 Nonroad Heavy Duty Diesel Rule (negligible benefits by 2009) Additional phase-in of technol ogy rules im ple m ented by 2002.

Onroad Heavy-Duty Diesel Engine Rule (2004) Heavy-Duty Diesel Engine Rule (2007) Tier 2 Motor Vehicle Em ission Standards I&M Program with Final Cutpoints Transportation Control Measures (T CMs) Vehicle Technology, Maintenance, or Fuel-Based Measures

M W AQ C O z on e SI P May 23

, 20 07 4- 1 34.6 2008 Controlled Emissions for Reasonable Further Progress

The projection of 2008 controlled em issions is simply the 2008 uncontrolled em issions

m i nus the em ission reductions achieved from the federal co ntrol m easures and the reasonable further progress control m easures implem ented by states for the 8-hour ozone plan. This infor m ation is pr esented in Table 4-7 and Tabl e 4-8. Controlled point source inventories are contained in Appendix C, c ontrolled area and nonroad source inventories in Appendix D1, and controlled m obile source inve ntories in Appendix E1. Maryland point source em issions include quasi- poi nt source (nonroad and onroad mobile)

em issions from Andrews Air Force Base, whic h are described in de tail in the 2002 Base Year em issions inventory docum ent.

Table 4-9 2008 Projected Controlled VOC Emissions (tons/day) Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b,d

Point 5

. 3 4 8

. 4 0 0

. 2 4 1 3

. 9 8

Area c 8 7

. 6 3 7 6

. 5 5 1 7

. 4 0 1 8 1

. 5 9

Non-road 4 7

. 5 0 3 7

. 9 2 7

. 0 6 9 2

. 4 8

Mobile 3 3

. 8 6 2 9

. 6 5 7

. 4 7 7 0

. 9 8

Total d 1 7 4

. 3 3 1 5 2

. 5 2 3 2

. 1 8 3 5 8

. 8 4
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 0

. 9 8 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s AFB

. b Reg i on al to tal in clu d e s a r e du ctio n of 0

. 19 t p d VO C f r o m V o l u n t ar y Measu r es Bund le.

c The controlled a r ea s o urce e m issions for the Distri ct do not include re duc t i ons fr om t h e OTC V O C

measu r es. Th e District's OTC VOC ru les o n all th e ap p licable area so urce categ ories are o r will b e fu lly ado p t e d

, s u bm it t e d t o E P A

, a n d fede ral l y enf o rcea bl e m easures

. Ho we ver , t h e em i ssi on r e duct i o ns o f 3. 38
t pd V O C i n 2 0 0 8 an d 3. 8 0 t p d VOC i n 2 0 0 9 ari s i n g fr om these m easures in the Dist rict are not a p plied to t h e em i ssi ons i nve nt o r i e s pres ent e d i n t h i s R FP/ at t a i n m e nt m odel i ng/ co nt i nge ncy dem onst r at i on o f t h e Was h in gto n D C -M D- V A re g i onal S I P

. T h e District o f Col u m b ia ' s m easures a r e e xpecte d to provi de ad d ition a l en h a n cem en ts to the air q u a lity i m p r ov em en t in th e reg i o n

. d Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

M W AQ C O z on e SI P May 23

, 20 07 4- 1 4Table 4-10 2008 Projected Controlled NOx Emissions (tons/day) Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b,c

Point 1 7 6

. 9 1 4 9

. 3 4 3

. 1 1 2 2 9

. 3 6

Area 7

. 1 1 1 7

. 5 8 2

. 2 4 2 6

. 9 3

Non-road 3 0

. 1 3 3 7

. 6 8 9

. 0 9 7 6

. 9 1

Mobile 7 7

. 8 5 6 7

. 2 0 1 5

. 2 5 1 6 0

. 3 0

Total c 2 9 2

. 0 1 1 7 1

. 8 0 2 9

. 6 9 4 9 3

. 2 2
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 2

. 2 1 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s AFB

. b Reg i on al to tal in clu d e s a r e du ctio n of 0

. 28 t p d NOx fro m V o l u n t ar y Measu r es Bund le.

c Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

4.7 2009 Controlled Emissions for Attainment

The projection of 2009 controlled em issions is simply the 2009 uncontrolled em issions

m i nus the em ission reductions achieved from th e federal co ntrol m easures and the rateof-progress control m e a s ures and other attainm e nt strategies im ple m ented by states for the 8-hour ozone plan. T h is inform ation is presented in Table 4-9 and Table 4-10. Maryland point source em issions include quasi - point source em issions from Andrews Air Force B a se, which are described in detail in the 2002 BY em issions inventory docum ent.

M W AQ C O z on e SI P May 23

, 20 07 4- 1 5Table 4-11 2009 Projected Controlled VOC Emissions (tons/day) Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b,d

Point 5

. 3 3 8

. 7 2 0

. 2 5 1 4

. 3 1

Area c 8 6

. 0 1 7 5

. 5 2 1 7

. 5 7 1 7 9

. 1 0

Non-road 4 5

. 4 7 3 6

. 3 9 6

. 8 0 8 8

. 6 6

Mobile 3 1

. 6 4 2 8

. 1 5 6

. 8 8 6 6

. 6 8

Total d 1 6 8

. 4 5 1 4 8

. 7 8 3 1

. 5 1 3 4 8

. 5 6
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 1

. 0 0 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s AFB

. b Reg i o n a l t o tal in clu d e s a r e du ctio n of 0

. 19 t p d fr o m V o l u ntar y Measu r es Bu nd le.

c The c ont rolle d a r ea s o urce e m issions for the District do no t in clud e red u ctio n s fro m th e OTC VOC

measu r es. Th e District's OTC VOC ru les o n all th e ap p licable area so urce categ ories are o r will b e fu lly ado p t e d

, s u bm it t e d t o E P A

, a n d fede ral l y enf o rcea bl e m easures

. Ho we ver , t h e em i ssi on r e duct i o ns o f 3. 38
t pd V O C i n 2 0 0 8 an d 3. 8 0 t p d VOC i n 2 0 0 9 ari s i n g fr om these m easures in the Dist rict are not a p plied to t h e em i ssi ons i nve nt o r i e s pres ent e d i n t h i s R FP/ at t a i n m e nt m odel i ng/ co nt i nge ncy dem onst r at i on o f t h e Was h in gto n D C -M D- V A re g i onal S I P

. T h e District o f Col u m b ia ' s m easures a r e e xpecte d to provi de ad d ition a l en h a n cem en ts to the air q u a lity i m p r ov em en t in th e reg i o n

. d Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

Table 4-12 2009 Projected Controlled NOx Emissions (tons/day) Washington, DC-MD-VA O z one Nonattainment Area

Emission Source Maryland a Virginia District of Columbia Total b,c

Point 7 2

. 1 8 3 8

. 4 2 2

. 4 3 1 1 3

. 0 3

Area 7

. 1 7 1 7

. 9 6 2

. 2 6 2 7

. 3 9

Non-road 2 9

. 2 8 3 7

. 0 3 8

. 7 9 7 5

. 1 0

Mobile 7 0

. 9 4 6 1

. 4 4 1 4

. 1 6 1 4 6

. 5 3

Total c 1 7 9

. 5 6 1 5 4

. 8 5 2 7

. 6 4 3 6 1

. 7 5
Notes:

a M a ry l a nd poi nt s o u r ce em i s si ons i n cl u d e 2

. 2 5 t p d o f quas i - p o i n t s o urce em i ssi ons f r o m A n d r ew s AFB

. b Reg i o n a l t o tal in clu d e s a r e du ctio n of 0.3 tp d fr o m V o l u ntar y Measu r es Bu nd le.

c Sm al l d i screpan c ies m a y resu lt du e to rou n d i ng

M W AQ C O z on e SI P May 23

, 20 07 4- 1 6MWAQC Ozone SIP May 23, 2007 5-1 5.0 2008 REASONABLE FURTHER PROGRESS (RFP) REQUIREMENTS

5.1 Introduction

In June 2004 EPA revoked the 1-hour ozone standard and published implementation guidance for the 8-hour ozone standar d. The Metropolitan Wa shington, DC-MD-VA re gion was classified as moderate nonattainment of the 8-hour ozone standard under Subpart 2, Section 182, Part b.

EPA’s implementation guidance requires that a moderate 8-hour ozone nonattainment area that has an attainment date beyond 5 years after its 8-hour designation and ha s previously met its 15% emission reduction requirements under the 1-hour standard will only be subject to subpart 1 RFP requirements. These requirements will be satisfied with a plan to demonstrate 15 % emissions reductions (which may be either VOC or NOx or a combination of both) from 2002 to 2008. 1 The Metropolitan Washington region is current ly a moderate 8-hour ozone nonattainment area and has an attainment date (June 15, 2010) , which is beyond 5 years after its 8-hour designation (June 15, 2004). The region is also a former 1-hour ozone nonattainment area with an approved 15% VOC reduction plan. Therefore, it is required by EPA to demonstrate RFP by reducing 15% emissions during the period 2002- 2008. This chapter contains the Washington region’s RFP demonstration for the period 2002-2008. The region will need to fulfill this RFP requirement by January 1, 2009.

In order to demonstrate RFP, a region must show that its expected emissions, termed controlled inventories, of NOx and VOC will be less than or e qual to the target levels set for the end of the RFP period, or “milestone year”. For the R FP period 2002-2008, the “target inventories” of emissions are the maximum quantity of anth ropogenic 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 expect ed NOx and VOC emissions will be less than or equal to the target levels, the Washington region will meet the RFP requirements for 2008.

5.1.1 Rate of Progress Demonstrated in Previous State Implementation Plans

Since 1990, the Clean Air Act has required ozone nonattainment areas to demonstrate progress towards attaining the ozone sta ndard. This requirement is gene rically referred to as the RFP requirement, and, was also called rate-of-pr ogress (ROP). But under 40 CFR 51.900, “rate-ofprogress” refers to the progress required towa rds attaining the 1-hour ozone standard, and “reasonable further progress (RFP) ” progress required towards atta ining the current 8-hour ozone standard. During the period 1990-1996, areas in nonattainment for the 1-hour ozone standard were required to reduce VOC emissions by 15% . After 1996, these areas were required to demonstrate a 9% rate of progr ess every three years until their attainment date. The percent reductions for these ROP plans were computed relative to 1990 base line emissions.

The Clean Air Act Amendments (CAAA) included rest rictions on the use of control measures to meet the 15% requirements. Reductions in ozone pr ecursors resulting from four types of federalMWAQC Ozone SIP May 23, 2007 5-2 and state regulations could not be used to meet rate of progress. These four types of programs

are: (1) Federal Motor Vehicle Control Program (FMV CP) tailpipe and evaporative standards applicable as of January 1, 1990, (2) Federal regulations limiting the Reid Vapor Pressure (RVP) of gasoline in ozone nonattainment areas applicable as of June 15, 1990; (3) State regulations correcting deficiencies in reasonably available control technology (RACT) rules (4) State regulations establishing or correcti ng inspection and maintenance (I/M) programs for on-road vehicles.

The basic procedures of devel oping target levels for the 15% Plan are describe in EPA’s guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15% Rate of Progress Plans . For the purposes of the 8-hour RFP requirements this guidance was updated by EPA in November 2005 and August 2006. 2 ,6

In 2003 EPA reclassified the Metropolitan Wash ington region as severe non-attainment for the 1-hour ozone standard when the region did not meet the attainment deadline for serious nonattainment areas by November 1999. In Marc h 2004 MWAQC approved a State Implementation Plan to meet the requirements for a severe nonattainment area. The “Severe Area SIP” demonstrated rate of progress of 15% fr om 1999-2002, and 15% from 2002-2005. The states submitted the plan to EPA, and EPA approved the states’ SIPs and Rate of Progress plans in 2005. 3

5.2 Guidance for Calculating Reasonable Fu rther Progress (RFP) Emission Target Levels

The Clean Air Act Amendments of 1990 provide the primary guidance for calculating the VOC and NOx target levels used in a region’s ROP plans. In November 2005 as part of its final implementation rule for the 8-hour ozone standard, EPA issued guidance to assist the states in their RFP plan development.

As discussed above, the guidance that applies sp ecifically to the Metropolitan Washington region is described in the EPA’s 8-hour oz one implementation guidance document. 1 Methodology specific to the Metropolitan Wash ington region, for calculating emi ssions target levels for the purpose of demonstrating RFP, is described in de tails in the EPA document’s Appendix A to the preamble of the final implem entation rule, under Method 2. 2

Method 2 of the EPA’s guidance document states that the target level of VOC and NOx emissions in 2008 needed to meet the 2008 RFP requirement is any combination of VOC and NOx reductions from the adjusted base year 2002 inventories (base year 2002 emissions less non-creditable emissions reduction occurring between 2002 and 2008) that total 15 %. For example, the target level of VOC emissions in 2008 could be a 10 % reduction from the adjusted base year 2002 VOC inventory and a 5 percent reduction from the adjusted NOx inventory. The actual projected 2008 VOC and NOx inventories for all sources with all control measures in place and including projected 2008 growth in activity must be at or lower than the target levelsMWAQC Ozone SIP May 23, 2007 5-3 of VOC and NOx emissions. Washington region ha s not chosen to substitute NOx for VOC reductions for complying with its reasonable furt her progress requirement s and therefore all its required 15% emissions reductions during the period 2002-2008 come from VOC reductions only. 4

This section summarizes the requirements and procedures for calculating the target emission levels required for a RFP demonstration. RFP demonstrations build upon each other, starting from the base year of 2002.

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 fu rther progress requirement, the Washington, DC-MD-VA 8-hour ozone nonattainment area need s to reduce its emissions by 15% between 2002 and 2008 using either reduction in VOC or NOx or any combination of the two. The Washington region is able to demonstrate reas onable further progress for the period 2002-2008 using 15% VOC reduction.

The target levels for 2008 reasonable further progress plans are calculated according to the EPA’s final rule mentioned above. The general formula for calculation of 2008 target levels is as follows:

Target Level = (RFP base year emissions - non-creditable emissions reduction between 2002 and 2008) * (Reductions required to meet the reasonable further progress requirement) [Eq. 5-1]

5.2.2 Calculation of 2008 Target Levels

Equation 5-1 gives the general formula for calcu lating 2008 target levels. Since the region has chosen to demonstrate the 2008 reasonable fu rther progress using 15% VOC reduction, the 2008 VOC target level becomes:

2008 VOC Target level = (2002 RFP Base-Year VOC emissions – non-creditable emissions reduction between 2002 and 2008) * (15% VOC reduction) [Eq. 5-2]
Step 1 Develop 2002 Base Year Inventories and 2002 Reasonable Further Progress Base Year Inventories

The 2002 base year inventory is an invent ory of actual anthropoge nic and biogenic VOC emissions on a typical weekday during peak oz one season. The inventory was calculated as described in Chapter 3 and is presented in Ta ble 3-1. The reasonable further progress base-year inventory includes only anthr opogenic emissions generated with in the Metropolitan Washington nonattainment area. As the 2002 base-year invent ory included no emissions generated outside the Metropolitan Washington area, the only differe nce between the base year inventory and the reasonable further progress base year inventor y is the removal of biogenic emissions. The reasonable further progress base year VOC inventory is presented in Table 5-1.MWAQC Ozone SIP May 23, 2007 5-4 Table 5-1 2002 Reasonable Further Progress Base-Year Inventory (Ozone Season tons per day) Source VOC NOx Point 12.91 220.60

Area 192.64 24.25

Non-Road 125.79 85.72

On-Road 116.94 266.65

TOTAL 448.28 597.22
Note: Small discrepancies may result due to rounding

Step 2 Develop 2002 and 2008 RFP Adjusted Year Inventories

According to the 1990 CAAA, reductions necessary to meet the reasonable further progress requirement must be calculated from an emissi on baseline that excludes the effects of the noncreditable Federal Motor Vehicle Control Prog ram (FMVCP) and Reid Vapor Pressure (RVP) programs described in Section 5.1.2. Therefore the 2002 baseline must be adjusted by subtracting the VOC and NOx reductions that will result from these two programs during the period 2002- 2008. The resulting inventory is referred to as the 2002 Adjusted Base Year Inventory.

In order to calculate the non-creditable emi ssions reductions, which occur during the period 2002-2008, the following two mobile inventories are needed:

1) 2002 Reasonable Further Progres s Adjusted-Year Inventory 2) 2008 Reasonable Further Progres s Adjusted-Year Inventory Both of these mobile inventories were created us ing the same inputs (liste d below), with the only difference between them being the model year (inventory #1 and #2 were created for model years 2002 and 2008 respectively). a) 1990 I/M Program b) RVP = 7.8 psi (RVP required accordi ng to June 1990 fuel RVP regulations) 5 c) No Post-1990 Clean Air Act Measures d) 2002 Vehicle Activity Inputs e) 2002 Vehicle Miles Traveled (VMT)

The MOBILE6 input files are in cluded in Appendix D2. Table 5- 2 & 5-3 show RFP adjustedyear inventories for 2002 and 2008 respectively.MWAQC Ozone SIP May 23, 2007 5-5 Table 5-2 2002 Reasonable Further Progress Adjusted-Year Inventory (Ozone Season tons per day) Source VOC NOx Point 12.91 220.60

Area 192.64 24.25

Non-Road 125.79 85.72

On-Road 166.55 308.24

TOTAL 497.89 638.81
Note: Small discrepancies may result due to rounding

Table 5-3 2008 Reasonable Further Progress Adjusted-Year Inventory (Ozone Season tons per day) Source VOC NOx Point 12.91 220.60

Area 192.64 24.25

Non-Road 125.79 85.72

On-Road 154.10 276.63

TOTAL 485.44 607.20
Note: Small discrepancies may result due to rounding

Step 3 Non-creditable Emissions Reductions

The non-creditable emissions reductions that oc cur in absence of any post-1990 CAA measures during a reasonable further progres s period can be determined by taking the difference between the RFP adjusted-year inventories for the rele vant milestone years. For VOC and NOx, the relevant milestone years are 2002 and 2008.

Non-creditable Emissions Reductions = 2002 RFP Adjusted Year Inventory – 2008 RFP Adjusted Year Inventory [Eq. 5-3]

Calculation of non-creditable emissions re ductions is shown in Table 5-4 below:MWAQC Ozone SIP May 23, 2007 5-6 Table 5-4 Calculation of Non-credita ble Emissions Reductions (Ozone Season tons per day) Description VOC NOx 2002 RFP Adjusted Year Inventory (a) 497.89 638.81 2008 RFP Adjusted Year Inventory (b) 485.44 607.20
Non-creditable Emissions Reduction (a-b) 12.45 31.61

Step 4 Calculation of 2008 Target Levels

Following Equation 5-2, the VOC target level fo r 2008 is calculated in Table 5-5 below:

Table 5-5 Calculation of VOC Target Level for 2008 (Ozone Season tons per day) Description VOC 2002 RFP Base-Year Inventory (a) 448.28
Non-creditable Emissions Reduction (b) 12.45 2002 Adjusted Base-Year Inventory (c) = (a-b) 435.83 Reduction Required for Reasonable Further Progress (d) = 15% VOC reduction from (c) 65.38

2008 Target Levels for Reasonable Further Progress (e) = (c-d) 370.45

5.3 Compliance with 2008 Reasonable Further Progress Requirements

In order to demonstrate reasonable further progress for the period 2002-2008, the Washington 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 Washington nonattain ment area during 2008. The inventories were developed as described in Chapter 4 and are disp layed in Tables 4-7 and 4-8. As summarized in Table 5-6, the 2008 controlled VOC inventory is less than the 2008 target VOC inventory. Table 5-6 demonstrates that the Wash ington region fulfills the 2002- 2008 reasonable further progress requirement using 15% VOC reduction during this period.MWAQC Ozone SIP May 23, 2007 5-7 Table 5-6 Washington Nonattainment Area Comparison of 2008 Controlled and Target Inventories Ozone Season Daily Emissions (tons per day) Description VOC 2008 Reasonable Further Progress Target Level 370.45

2008 Controlled Emissions a,b 358.84

Notes:

a Regional total includes a reduction of 0.19 tpd VOC from Voluntary Measures Bundle. b The controlled area source emissions for the District do not includ e reductions from the OTC VOC measures. The District's OTC VOC rules on all th e applicable area source categories are or will be fully adopted, submitted to EPA, and federally enforceable measures. However, the emission reductions of 3.38 tpd VOC in 2008 and 3.80 tpd VOC in 2009 arising from these measures in the District are not applied to the emissions inventories presented in this RFP/attainment modeling/contingency demonstration of the Washington DC-MD-VA regional SIP. The District of Columbia's measures are expected to provide add itional enhancements to the air quality improvement in the region.

5.4 Reasonable Further Progress Continge ncy Emissions Reduction Requirements

This section briefly discusses the procedures for calculating th e emission reduction required to meet the RFP contingency requirements, which have been discussed in detail in the chapter 11. A total of 3% reduction using a combination of VOC and NOx reductions are needed to comply with the RFP contingency emissions reduction requirements; however, a minimum of 0.3% VOC is required. Therefore, minimum re duction requirements are as follows:

VOC Reduction Required = (2002 RFP Base-Year VOC emissions – non-creditable emissions reduction between 2002 and 2008)* (0.3% VOC reduction) [Eq. 5-4]

NOx Reduction Required = (2002 RFP Base-Year NOx emissions – non-creditable emissions reduction between 2002 and 2008)* (2.7% NOx reduction) [Eq. 5-5]

Following Equations 5-4 and 5-5, the mi nimum VOC and maxi mum NOx reductions requirement for RFP contingency are calculated in Table 5-7 below:MWAQC Ozone SIP May 23, 2007 5-8 Table 5-7 Calculation of VOC and NOx Redu ctions for RFP Further Progress Contingency (Ozone Season tons per day) Description VOC NOx 2002 RFP Base-Year Inventory (a) 448.28 597.22
Non-creditable Emissions Reduction (b) 12.45 31.61 Adjusted Base-Year Inventory (c) = (a-b) 435.83 565.61 0.3% VOC Reduction Required for RFP Contingency (d) = (0.3/100) * (c) 1.31

2.7% NOx Reduction Required for RFP Contingency (e) = (2.7/100) * (c) 15.27

References

U.S. EPA, “Guidance on the Adjusted Base Y ear 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 15, 1993.

1 40 CFR 51.910(a); 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.

2 “

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, pp. 71696

.

3 Approval and Promulgation of Air Quality Implementation Plans; District of Columbia, Maryland, Virginia; 1Hour Ozone Attainment Plans, Rate-of-Progress Plans, Contingency Measures, Transportation Control Measures, VMT Offset, and 1990 Base Year Inventory, Federal Register, vol 70, No. 92,May 13, 2005, pp.25688-25719.

4 If a region chooses to substitute reductions in NOx for reductions in VOC, the substitution must be made in accordance with EPA’s NOx Substitution Guidance. This guidance states the use of NOx emission reductions must be consistent with the photochemical modeling used in the region’s attainment demonstration. As photochemical attainment modeling performed for the Metropolitan Washington region shows that NOx reductions significantly reduce ozone formation, the region can substitute NOx redu ctions for VOC reductions. Based on this modeling, the Washington region can substitute NOx reductions for some or all (0-15%) of the required VOC reductions for the 2008 reasonable further progr ess (App. F – Severe SIP).

5 The 1990 Phase II regulations specify 7.8 psi as the maximum RVP of gasoline being sold in the Washington, DCMD-VA ozone nonattainment area in 1992.

6 Memorandum, “8-hour Ozone National Ambient Air Quality Standard (NAAQS) Implementation – Reasonable Further Progress (RFP),” from William T. Harnett, date d August 15, 2006.6.0 CONTROL MEASURES

This section is divided into five sections: Point Source Measures; Area Source Measures; Nonroad Source Measures; Mobile Measures; and Voluntary Measures.

Reductions from the control m easures presented in this Chapter are sum m a rized in Table A.

Ref No

. C ontrol Measure 200 8 b 200 9 c 20 08 b 2 009 c

M E ASURES INCLUD ED IN THE F U TURE CONTROLLED SCENARIO

6. 1.2 S t ate NOx R A C T and R e gion al NOx Tran spor t Req u iremen t (RACT

, NOx SI P Call, CAI R , HAA) 0.0 0 0

. 00 12. 65 1 28. 76

SUBT OT AL 0.0 0 0

. 00 12. 65 1 28. 76

6. 2.1 1 M obile E quip m en t Repair and R e finishing R u le 3

. 49 3. 5 9 0 0 6. 2.1 2 P o rtable Fu el C ontain e rs R u le: P h a s e I 7

. 34 9. 3 0 0 0 6. 2.1 3 Ar chitectu r al an d I ndu str i al Mainten a nc e C o ating s R u le 10

. 6 2 1 0. 8 2 0 0
6. 2.1 4 Reform ulated Consum er Prod ucts Rule: Ph as e I 6

. 23 6. 3 4 0 0 6. 2.1 5 S o lv ent C l ean ing Op era t io ns R u le 2

. 91 2. 9 9 0 0 6. 2.1 6 I ndu str i al Adh e siv e s and S ealan ts R u le - 2

. 4 2 0 6. 2.1 7 P o rtable Fu el C ontain e rs R u le: P h a s e II - 0

. 7 5 0 6. 2.1 8 Reform ulated Consum er Prod ucts Rule: Ph as e II 0

. 39 0. 7 6 0 0 SU BT O T A L 30

. 9 8 3 6. 9 7 0 0

6. 3.1 E PA Non-Ro ad G a s o line E ngines Ru l e 42 .44 11. 68 14. 76 6. 3.2 EP A N on-R o a d Di es el Engi ne s Rule 6. 3.3 Em i s s i o n s s t a n da r d s f o r s p a r k i g ni t i o n m a r i ne e n gi n e s 6. 3.4 E m i ssions stand a rd s for larg e spark ign i t i o n en gines 6. 3.5 R ef ormulated Gasoline (o ff-r oad ) 6. 3.6 S tan d ard s for Locom o tive 0.0 5 0

. 06 2. 54 2. 74

SUBT OT AL 3 6 .9 6 4 2

. 50 14. 22 17. 50

6. 4.2 H ig h-T ech I n spec tio n /Main t e n an ce (u pda te d cu tpoin t s) 6. 4.4 N ati o nal L o w Em issi o n Vehicle Pro g ram 6. 4.5 T ier 2 Motor Veh i cl e Em is sion Stand a rds 6. 4.6 H eavy -Duty Diesel E ngin e Rule

6. 4.7 T r ansp ortation C ontr o l Measu r es and Veh i cle T echn o log y , Fuel, or M a intenance Measures 0.1 9 0

. 18 0. 49 0. 45

SUBT OT AL 6.3 8 7

. 35 30. 16 38. 08

6. 5 V o l untary Bund le 0.1 9 0

. 19 0. 28 0. 30 TOTAL RED UCTIONS 7 4 .5 1 8 7

. 01 57. 31 1 84. 64 No t e s : 0 0

b Red u ction s in cluded in the 2 008 Reasonab l e Furth e r Pr ogres s d e m onstrat io n, o ccurring between 2 002 and 20 08.

c Redu ctions in cluded in th e attainm e n t dem o n s t r ation, occu rrin g b e tween 200 2 an d 2 009

. NON-ROAD MEASURES POINT SOURCE MEASURES

AREA SOUR CE M E ASU R ES ( a )

6.1 9 7

. 17 29. 67 37. 63 36

. 9 1 tons/d ay t o ns/d ay

VOLUNTARY M E ASURES ( M ultiple Source Se ctor s ) ON-ROAD MEASURES

a Th e Area Source redu ctions d o no t includ e the Dis t rict of C o lum b ia. The Dis t ri ct ' s OTC VOC rules on all the
app licable area s o urce categ orie s are or will be fully adop t e d, sub m i tted to E P A, and fed e rally enfo rceable m easures. However, the em ission redu ctions o f 3. 38 t p d VOC in 200 8 an d 3

. 80 tpd V O C in 20 09 arising from th es e m easures in th e Dist rict are not applied to th e em iss i o n s inventor i e s presen ted in this R FP/attainm e n t m o deling / contin gen c y dem o n s t r ation of t h e W a shing t o n DC-MD

- VA region al SIP. Th e District of C o lumbia's measur es are expe cted to
pr ovide add i tio n al e nhan cements to the air qu ality im p r ov ement in the r e gion

. TABL E A SUM M AR Y OF CONTROL STRATEGI E S VOC an d NOx Be ne f i ts of Cont r o l Me as ur es ( 20 02 -20 0 9 ) VOC Reduc t ions NOx Reductions

MW AQC Ozone SIP May 23, 2007 6-16.1 POINT SOURCE MEASURES

6.1.1 Non-CTG VOC RACT (federal and state regulation)

This m easure involves extending em ission standards to point sources with the potential to em it in excess of 25 tons per year (tpy) of VOCs.

Control Strategy

The W a shington, D.C. m e tropolitan area, when designated as severe nonattainm e nt for the 1-hour ozone standard, was obligated under the CAAA to im plem ent RACT for m a jor sources (25 tpy) not covered by EPA' s Control Technique Guidance (CTG) docum ents. Under the 15% VOC Reduction Plan, Virginia, Maryland, and th e District of Colum b ia developed and im plem ented new regulations for point sources with the potential to em it between 25 and 50 tpy not already regulated or required to be regulat ed under the previous m a jor source definition (50 tpy). This control m easure included two part s: extension of non-CTG RACT rules to point

sources em itting over 25 tpy, and extension of other state regulations applicable to m a jor sources. The latter reductions were found only in Maryland.

As a m oderate nonattainm e nt area for the 8-hour ozone standard, "reasonably available" control technologies m u st be determ ined and im plem ented for industry sources with the potential to em it greater than 50 tpy.

RACT consists of a variety of control techniques that are generally available and cost-effective. Usually the EPA will issue a CTG, which docum ents the cost per ton of the control m e thod and the size of the source that can best benefit from the control based on cost and technological f

easibility. A CTG can include add-on equipm ent as well as em issions lim its. If a CTG is not issued for a category that contains a m a jor sour ce, the state m u st develop a RACT regulation for that category.

Maryland’s RACT im plem entation involved three type s of standards: 1) identification of m a jor source categories and establishm ent of RACT for both m a jor and non m a jor sources in those categories; 2) RACT for categories that did not have m a jor sources but together with all sm all sources were above m a jor source threshold; and 3) specific RACT for sources that em itted m o re than 20 lbs of VOC per day.

Source Type Affected

This m easure affects point sources with the potential to em it 25 tpy or m o re of VOCs. In Maryland, it affects both m a jor and non m a jor sources that together constitute em issions above 25 tons per day, sm all sources that together em it greater than 25 tons and point sources that em it

m o re than 20 lbs of VOCs per day.

MW AQC Ozone SIP May 23, 2007 6-2Control Strategy

Point sources are regulated through a state perm it process in Maryland, Virginia and D.C. The states were required to develop and im plem en t new RACT regulations for all non-CTG point

sources em itting m o re than 25 tpy, which had not been previously regulated. All three states have subm itted or will subm it to EPA a separate SIP revision addressing RACT SIP requirem e nts. All three states recertified RACT for the point sources em itting m o re than 50 tpy in the region.

Implementation

District of Colum b ia – Departm e nt of Environm ent Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality

Projected Reductions and Emi ssion Benefit Calculations

The benefits of requiring RACT to point sources with potential to em it greater than 25 tpy is already reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. States recertified that the existing levels of controls at sources subject to the regulations com p ly with RACT requirem e nts. As such, there ar e no em ission benefits of RACT recertification

.

References

Staff engineers at the Virginia Departm e nt of Environm ental Quality, the Maryland Departm e nt of the Environm ent, and the District of Colum b ia Departm e nt of Environm ent supplied reduction potential estim ates.

MW AQC Ozone SIP May 23, 2007 6-36.1.2 NOx RACT and Regional NOx Transport Re quiremen ts (fed eral an d state regulation )

This section docum ents credit for NOx em issions reductions attributable to federal and regional NOx requirem e nts on point sources. These credits include:

• Reasonably Available Control Technology ("RACT"), as required under 42 U.S.C. § 7511a (f) (read in conjunction with §§ 7511a (b)(2) and (c));

• “NOx Budget” rules that required a second phase of stationary source NOx reductions as part of a coordinated regulatory initiative by the Ozone Transport Region (OTR) states to further reduce NOx em issions in the Northeast;

• the “NOx SIP Call” to reduce ozone transport in the Eastern United States;

• EPA' s Clean Air Interstate Rule (CAIR); and

• Maryland' s Healthy Air Act.

Control Strategy

RACT Major point sources of NOx are subject to RA CT requirem e nts created by D.C., Maryland and Virginia in response to §7511a (f). In the W a shington DC region, NOx reduction controls m u st be applied to sources that have the potential to em it 25 tons per year or m o re of NOx.

Maryland, Virginia, and the District of Colum b ia com p leted the requirem e nts of RACT under the 1-hour ozone standard in the late 1990’s. EP A required that the states review and recertify RACT under the 8-hour ozone standard. In this process, each state reviewed existing RACT rules, existing sources and potentially new source categories to ensure RACT requirem e nts are being m e t. All three states have subm itted or will subm it to EPA a separate SIP revision addressing RACT SIP requirem e nts. All three states recertified RACT for all applicable sources.

NOx OTC Phase II Budget Rules In the late 1990’s Maryland and the District adopted “NOx Budget” rules to require a second phase of stationary source NOx reductions as part of a coordinated regulatory initiative by the OTR states to further reduce NOx em issions in the Northeast. The rules required large stationary sources to reduce sum m e rtim e NOx em issions by approxim a tely 65 percent from 1990 levels. The regulation also included provisions allowing sources to com p ly by trading “allowances.” This regulation required affected sources to reduce their em issions to m eet these requirem e nts by May 2001.

NOx SIP Call In late 1998, the U.S. EPA adopted a rule called the “NOx SIP Call” to reduce ozone transport in the Eastern United States. This regional NOx reduction program required 22 states, including Maryland and Virginia, and the District of Colum b ia, to further reduce large point source NOx

em issions to EPA identified state em ission budget levels by 2007. State regulation adoption tim elines notwithstanding the m a jority of the 22 SIP call states had these regulations in place by 2003/2004.

MW AQC Ozone SIP May 23, 2007 6-4Clean Air Interstate Rule (CAIR) On May 12, 2005, the U.S. EPA prom ulgated the Clean Air Interstate Rule, which requires reductions in em issions of NOx and SO2 from la rge fossil fuel-fired electric generating units. The rule is set up in several phases with the first phase of NOx reductions to com e by 2009. The rule sets up both an annual em issions budget and an ozone season em issions budget. The rule requires that units with nam e plate capacity greater than 25 m e gawatts em it no m o re NOx than their allocations determ ined by the state either through em ission controls or banking and trading.

Virginia CAIR Virginia has adopted state regulations codifying the requirem e nts of the Clean Air Interstate Rule. Virginia' s rules create an em issions cap based on the allowances allocated to the f acility. The rules do not allow trading as a m e thod of com p lying with the em issions cap.

Maryland Healthy Air Act In April of 2006 the Maryland General Assem b ly and Governor Ehrlich adopted the Healthy Air Act (HAA), a law that requires reductions in NOx, SO2, and Mercury em issions from Maryland’s largest and oldest coal fired power plants. Maryland im plem ents the HAA through regulation. The regulation requires reductions in NOx em issions from coal-fired electric generating units (excluding fluidized bed com bustion units) starting in 2009. By 2009 Maryland expects an approxim a te 70 percent reduction in NOx em issions from these regulations when

com p ared to 2002 em issions. To m eet the requirem e nts of Maryland’s regulations a com p any’s “system ” (covered units owned by the sam e com p any) m u st m e et a system -wide cap by 2009. Com p liance cannot be achieved through the purchase of allowances under the HAA.

District of Colum b ia CAIR The District of Colum b ia is currently draf ting its Clean Air Interstate Rule (CAIR). Its CAIR regulations do not allow trading of NOx allowances f o r achieving the reductions f o r the f a cilities within its jurisdiction.

S u mma r y The point source NOx controls are a phased appro ach to controlling em issions of NOx from power plants and other large fuel com bus tion sources. The program s resulting in em ission reductions from point sources in the region include:

• The NOx SIP Call rule

• EPA' s Clean Air Interstate Rule

• Maryland' s Healthy Air Act

NOx reductions resulting from these controls are presented by source for Maryland in Tables 6-1 and 6-2, for Virginia in Tables 6-3 and 6-4, and fo r the District in Tables 6-5 and 6-6. Table 6-7

sum m a rizes em ission reductions by jurisdiction and for the region for each of the NOx point source controls listed in Tables 6-1 through 6-6.

In Maryland, the expected em ission reductions for 2008 and 2009 were calculated using the

em issions estim ates consistent with annual allocations under the Healthy Air Act im plem enting regulation. The program does not allow trading of NOx allowances. The expected em issions

MW AQC Ozone SIP May 23, 2007 6-5reductions are listed in Tables 6-4 and 6-5.

In Virginia, the expected em ission reductions for 2008 and 2009 from electric generating utilities were calculated using knowledge of historical NOx em ission rates, adjusted by the expected control efficiencies achieved from various control devices that have been installed, or by estim ating the am ount of allowances the facility would receive under the Virginia CAIR rule. The expected em issions reductions are listed in Tables 6-3 and 6-4.

In the District of Colum b ia, the expected em ission reductions for 2008 and 2009 were calculated using the listed allowances within the Clean Air Interstate Rule. The expected em issions reductions are listed in Tables 6-5 and 6-6.

See Appendix C for further point source docum entation.

MW AQC Ozone SIP May 23, 2007 6-6Table 6-1 2008 NOx Point Source Reductions for Maryland (tons per day) R e d u c t i o n s

Facility 2008 Uncontrolled

Em i s s i o n s R A C T NOx SIP Call Healthy Air Act Total Em ission Red.
D i c k e r s o n 2 5

. 6 1 3 0 0 0 0

C h a l k P o i n t 5 0

. 5 8 6 0 0 0 0
M o r g a n t o w n 7 8

. 5 1 2 0 0 0 0
Total 2008 R e d u c t i o n s 0 0 0 0

Table 6-2 2009 NOx Point Source Reductions for Maryland (tons per day) R e d u c t i o n s

Facility 2009 Uncontrolled

Em i s s i o n s R A C T NOx SIP Call Healthy Air Act a Total Em ission Red.
D i c k e r s o n 2 5

. 9 0 2 0 0 1 8

. 8 1 3 1 8

. 8 1 3

Chalk Point 50.525 0 0 34.836 34.836
M o r g a n t o w n 7 8

. 2 0 7 0 0 5 1

. 0 2 5 5 1

. 0 2 5
Total 2009 R e d u c t i o n s 1 5 4

. 6 3 4 0 0 1 0 4

. 6 7 4 1 0 4

. 6 7 4

a Healthy Air Act em ission reduction estim ates based on a regulation that imposes ozone s eas on lim its on the affected s ources

.

MW AQC Ozone SIP May 23, 2007 6-7Table 6-3 2008 NOx Point Source Reductions for Virginia (tons per day)

Reductions

Tons/day Facility ID Facility Name 2008 Baseline Emissions Tons/day N S R R A C T NOx SIP Call Total Emission Reductions

Tons/day 2008 Estimated Emissions Tons/day

51-153-0002 70225 Dom i nion Possum Point Power Station 1 6

. 2 1 7 3

. 4 3 5 a 3

. 4 3 5 1 2

. 7 8 2

51-510-0003 70228 MirantPotom ac River Power Plant 2 0

. 1 5 8 4

. 1 9 4 4

. 1 9 4 1 5

. 9 6 4

51-153-0139 72340 Prince W illiam County Departm e nt of Public Wo r k s 0

. 1 1 5 0

. 0 1 0

. 0 1 0

. 1 0 5

7

. 6 3 9 2 8

. 8 5 1
Notes:

a 70225 went through a PSD netting exercise resulting in a perm it th at required em ission reductions of NOx. See perm it dated 10/5/01.

Table 6-4 2009 NOx Point Source Reductions for Virginia (tons per day)
Reductions

Tons/day Facility ID Facility Name 2009 Baseline Emissions Tons/day N S R R A C T NOx SIP Call CAIR Total Emission Reduced Tons/day 2009 Estimated Emissions Tons/day

51-153-0002 70225 Dom i nion Possum Point Power Station 1 6

. 2 4 0 3

. 4 3 5 0.937 a 4.372 (1) 11.868

51-510-0003 70228 MirantPotom ac River Power Plant 2 0

. 4 1 5 4

. 1 9 4 10.402 a 1 4

. 5 9 6 5

. 8 1 9 (1)

51-153-0139 72340 Prince W illiam County Departm e nt of Public Wo r k s 0

. 1 1 5 0

. 0 1 0

. 0 1 0

. 1 0 5

1 8

. 9 7 8 1 7

. 7 9 2
Notes:

a Actual CAIR allocations have not y e t been calculated by VA st aff. These reductions and emi s s i on rates are es tim ates bas e d on past heat input rates and the draft CAIR allocation analy s is.

MW AQC Ozone SIP May 23, 2007 6-8Table 6-5 2008 NOx Point Source Reductions for the District of Columbia (tpd) R e d u c t i o n s

Facility 2008 Uncontrolled

Em i s s i o n s R A C T NOx SIP C a l l C A I R Total Em ission Red. Pepco - Benning 4.04 - 2.61 N/A 2.61 Pepco - Buzzard 2.82 - 2.31 N/A 2.31
Capitol Power Plant 0.51 - 0 0 0
GSA W e st & Central H e a t i n g 0

. 2 6

- 0

. 1 0 0 0

. 1 0 Georgetown Univ. Power Plant 0.08 - 0 0 0
U.S. Soldiers Hom e 0.03 - 0 0 0
Total 2008 R e d u c t i o n s 0 5

. 0 2 0 5

. 0 2

Table 6-6 2009 NOx Point Source Reductions for the District of Columbia (tpd) R e d u c t i o n s

Facility 2009 Uncontrolled

Em i s s i o n s R A C T NOx SIP C a l l C A I R Total Em ission Red.
Pepco - Benning 3.69 - 0 2.95 2.95
Pepco - Buzzard 2.58 - 2.07 0 2.07
Capitol Power Plant 0.51 - 0 0 0
GSA W e st & Central H e a t i n g 0

. 2 7

- 0

. 1 1 0 0

. 1 1 Georgetown Univ. Power Plant 0.08 - 0 0 0
U.S. Soldiers Hom e 0.03 - 0 0 0
Total 2009 Reductions 0 2.18 2.95 5.13

The CAIR reductions reflect the allotte d allowances for the District of Co lumbia (85% of 112 tons per season).

MW AQC Ozone SIP May 23, 2007 6-9Table 6-7 Point Source NOx Reductions Summary (tons per day)

Control District of Colum b i a M a r y l a n d V i r g i n i a T o t a l

2008
N S R 0 0 3

. 4 3 5 3

. 4 3 5
NOx RACT 0 0 0.01 0.01

NOx SIP Call 5.02 0 4.194 9.214
C A I R 0 0 0 0 Healthy Air Act 0 0 0 0
Total 2008 Reductions 5

. 0 2 0 7

. 6 3 9 1 2

. 6 5
2009
N S R 0 0 3

. 4 3 5 3.435 NOx RACT 0 0 0.01 0.01

NOx SIP Call 2.18 0 4.194 6.374 C A I R 2

. 9 5 0 1 1

. 3 6 14.31 Healthy Air Act 0 104.674 0 104.674 Total 2009 Reductions 5

. 1 3 1 0 4

. 6 7 4 1 8

. 9 7 8 1 2 8

. 7 6

MW AQC Ozone SIP May 23, 2007 6-10Implementation

District Departm e nt of the Environm ent Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality

Projected Reductions

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 NOx Reductions 5.02 0 7.639 12.65

2009 NOx Reductions 5.13 104.674 18.978 128.76

Emission Benefit Calculations

The em ission reductions associated with the state NOx requirem e nts on point sources were supplied by the staffs of the Maryland Air and Radiation Managem e nt Adm i nistration, the District Departm e nt of the Environm ent, and th e Virginia Departm e nt of Environm ental Quality Air Division.

References

1990 Clean Air Act Am endm ents, 42 U.S.C. §§7511a (f), (b)(2), and (c).

Federal Register Vol. 70, No. 91, May 12, 2005, p. 25162.

MW AQC Ozone SIP May 23, 2007 6-116.2 AREA SOURCE MEASURES

6.2.1 Reformulated Surface Coatings (federal rule)

This m easure involved adopting the federal rule resulting from the National Regulatory Negotiation for Architectural and Industrial Maintenance (AIM) Coatings, which restricts the VOC content of architectural, industrial m a intena nce, special industrial, and highway m a rkings surface coatings sold and used in the W a shington, D.C. ozone nonattainm e nt area. This rule was adopted on Septem ber 11, 1998 (63 FR 48819), corrected on June 30, 1999 (64 FR 34997) and

am ended on February 16, 2000 (65 FR 7736). Com p liance was required by Septem ber 13, 1999, or March 10, 2000.

Source Type Affected

This m easure affects m a kers of architectural, industrial m a intenance, special industrial, and highway m a rkings surface coatings.

Control Strategy

The m easure is based on the national regulatory negotiation for AIM coatings. According to EPA guidance, the final rule yields a 20 percen t reduction in VOC em issions from AIM coating sources. This estim ate includes consideration of rule effectiveness and rule penetration.

Reductions for AIM coatings are achievable through product reform ulations, product substitution, and consum er education. Reform ulations include altering the com ponents of thecoating to achieve a lower VOC content, replacing VOC solvents with water or alternative nonVOC solvents, and increasing the solids content of the coating thereby reducing the volum e applied. Product substitution is accom p lished by replacing higher-VOC coatings with currently available lower-VOC coatings. Consum er education will provide inf o rm ation on the relative cost of lower-VOC coatings and encourage careful, efficient use of such products.

Implementation

This program is im plem ented by the EPA under 42 U.S.C. §7511 (b).

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References

National Volatile Organic Com pound Em ission Sta ndards for Architectural, Pream ble Section IV.A.1 (63 FR 48819), Septem ber 11, 1998.

MW AQC Ozone SIP May 23, 2007 6-12U.S. Environm ental Protection Agency, "Credit for the 15% rate-of-progress Plans for Reductions from Architectural and Industrial Maintenance Coating Rule ", Mem o randum from John S. Seitz, Director, to directors of Air Divisions of EPA Regional Offices, March 22, 1995.

U.S. Environm ental Protection Agency, "Credit for the 15% rate-of-progress Plans for Reductions from Architectural and Industria l Maintenance Coating Rule and the Autobody Refinishing Rule", Mem o randum from John S. Se itz, Director, to directors of Air Divisions of EPA Regional Offices, Novem b er 21, 1994.

Meeting the 15-Percent Rate-of-Progress Requirement Under the Clean Air Act: A Menu of Options , STAPPA/ALAPCO, Septem ber 1993.

MW AQC Ozone SIP May 23, 2007 6-136.2.2 Reformulated Consumer Products (federal rule)

This m easure required that certain consum er products sold in the W a shington, D.C. ozone nonattainm e nt area be reform ulated to reduce their VOC content. The m easure is based upon regulations that EPA was required to publish by Novem b er 15, 1995 under 42 U.S.C. 7511b(e)(3). The final regulation was adopted on Septem ber 11, 1998 (63 FR 48848).

Source Type Affected

The m easure affects m a nufacturers of the various specialty chem icals that EPA selected, after conducting a study consistent with 42 U.S.C. 7511b(e)(2).

Control Strategy

The m easure relies upon federal im plem entation of a rule m a ndating reform ulation of certain "consum er or com m e rcial products" (as that term is defined under 42 U.S.C. 7511b(e)(1)(B)). Under §7511b(e)(3), EPA was required to create by Novem b er 15, 1995, regulations to require reform ulation of one-fourth of the "consum er or com m e rcial products" that are responsible for at least 80 percent of photochem i cally reactive VOC em issions from such products.

EPA guidance from John Seitz specifies a 10 percent total reduction of em issions from a regulated subset of consum er products. EPA estim ated the regulated subset to be approxim a tely 3.9 pounds per capita annually. Consequently, a total of 10 percent of the "com m e rcial or

consum er products" were expected to be subject to reform ulation requirem e nts by Novem b er 15, 1999. EPA guidance also allows states to retain em ission reduction estim ates for consum er and

com m e rcial product reform ulations in their 15% Plans.

Implementation

This m easure was federally im plem ented under a federal regulatory calendar initially issued in 60 Federal Register 15264 , finalized in 63 Federal Register 48791 and am ended in 64 Fe deral Register 13422 (March 18, 1999)

. This program is im plem ented by the EPA under 42 U.S.C. §7511 (b).

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References

National Volatile Organic Com pound Em ission St andards for Consum er Products, Pream ble Section III.A. (63 FR 48848), Septem ber 11, 1998.

1990 Clean Air Act Am endm ents, 42 U.S.C. 7511b(e).

U.S. Environm ental Protection Agency, "Regul atory Schedule for Consum er and Com m e rcial

MW AQC Ozone SIP May 23, 2007 6-14Products under Section 183 (e) of the Clean Air Act", Mem o randum from John S. Seitz, Director, to directors of Air Divi sions of EPA Regional Offices, June 21, 1995.

Com m e rcial and Consum er Products: Schedule for Regulation (64 FR 13422), March 18, 1999.

MW AQC Ozone SIP May 23, 2007 6-156.2.3 Reformulation of Industrial Cleaning Solvents (federal rule)

This m easure required that certain industrial cleaning solvents sold in the W a shington, D.C. ozone nonattainm e nt area be reform ulated to reduce their VOC content. The m easure is based upon regulations that, under 42 U.S.C. 7511b(e)(3), EPA was required to publish by Novem b er 15, 1995. The industrial cleaning solvent standards were adopted in 2001.

Source Type Affected The m easure af f

ects m a nuf acturers of the various specialty chem icals that EPA will select, af ter conducting a study consistent with 42 U.S.C. § 7511b(e)(2).

Control Strategy

The m easure relies upon federal im plem entation of a rule m a ndating reform ulation of certain "consum er or com m e rcial products" (as that term is defined under 42 U.S.C. § 7511b(e)(1)(B)). Under § 7511b(e)(3), EPA m u st create by Novem b er 15, 1995, regulations to require reform ulation of one-fourth of the "consum er or com m e rcial products" that are responsible for at least 80 percent of photochem i cally reactive VOC em issions from such products.

EPA guidance from John Seitz specifies a 10 percent total reduction of em issions from a regulated subset of consum er products. This is used as a benchm ark for estim ating reductions in industrial cleaning solvents.

Implementation This program was im plem ented by the EPA in 2001 under a schedule adopted on March 18, 1999. The program is im plem ented under 42 U.S.C. §7511 (b).

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References

1990 Clean Air Act Am endm ents, 42 U.S.C. 7511b(e).

U.S. Environm ental Protection Agency, "Regul atory Schedule for Consum er and Com m e rcial Products under Section 183 (e) of the Clean Air Act", Mem o randum from John S. Seitz, Director, to directors of Air Divi sions of EPA Regional Offices, June 21, 1995.

Federal Register Vol. 64 No. 52, Thursd ay, March 18, 1999 (AD FLR-6311-9) p. 13422 - 13424.

MW AQC Ozone SIP May 23, 2007 6-166.2.4 Surface Cleaning and Degreasing for Machinery and Automobiles Repair (state rule)

This m easure am ended regulations for surface cleaning (often called "cold cleaning and degreasing") devices and operations, to require m o re stringent em issions control techniques, and to require, where possible, the use of low- or no-VOC solvents.

Source Type Affected

All cold cleaning and degreasing equipm ent and operations.

Control Strategy

Maryland has regulations on cold cleaning and degreasing equipm ent and operations (COMAR 26.11.19.09). The regulations require a decrease in vapor pressure of degreasing m a terial for cold degreasers, installation of a condenser or air pollution control device, and good operating practices to m i nim i ze VOC losses.

The District of Colum b ia and Virginia have a dopted regulations on cold cleaning and degreasing equipm ent and operations. Credit is taken for two types of control m easures. (1) The first

m easure proposes the following equipm ent controls: solvent tank evaporation controls, carry-out

em ission controls, and enclosure/add-on controls; and the following operational controls: proper equipm ent use, and reduced disturbance of solv ent-air interface. (2) The second m e asure will require the use, where feasible, of alternative solvents.

Implementation

District of Colum b ia - Departm e nt of Environm ent Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

MW AQC Ozone SIP May 23, 2007 6-176.2.5 Landfill Regulations (state rule)

Landf ills em it gases as a result of decom position of m a terials buried in them . W h ile m o st of these gases are m e thane, which is not photochem i cally reactive, landfills do contribute to VOC

em issions, and, thus, ozone form ation. A federal rule for the control of new landfills and guidelines for existing landfills was proposed under Section 111 of the Clean Air Act Am endm ents.

Source Type Affected Municipal landfills are those that receive prim arily household and/or com m e rcial waste.

Control Strategy

The 15% VOC Reduction Plan required adoption of the f e deral guidelines f o r m unicipal landf ills (see 56 Federal Register 24468). The proposed guidelines require installation of gas collection system s followed by flares, to either destroy the VOCs or burn them for fuel. The rule requires capture and control system s to capture at least 80 percent of the VOC em issions and route them to a 98% destruction efficiency control device.

Implementation

Federal standards for existing landfills were prom ulgated under Section 111 of the Clean Air Act Am endm ents. The following state agencies will have to independently adopt regulations consistent with the federal standards:

Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References

U.S. Environm ental Protection Agency, Standards of Performance for New Stationary Sources and Guidelines for Existing Sources: Municipal Solid Waste Landfills , 56 Federal Register 24468, May 30, 1991.

U.S. Environm ental Protection Agency, Air Emissions from Municipal Solid Waste Landfills - Background Information for Proposed Standards and Guidelines , EPA-450/3-90-011a, March 1991.

MW AQC Ozone SIP May 23, 2007 6-186.2.6 Seasonal Open Burning Restrictions (state rule)

This m easure involves am ending and/or adopting state regulations to ban the open burning of such item s as trees, shrubs, and brush from land clearing, trim m i ngs from landscaping, and household or business trash, during the peak ozone season. The m easure is authorized by state regulations, but is enforced by the local governm e nts.

Source Type Affected

The m easure affects all citizens and businesses that burn solid waste.

Control Strategy

Under the 15% VOC Reduction Plan, Maryland a nd Virginia adopted state regulations to prohibit open burning during peak ozone season in the W a shington, D.C. ozone nonattainm e nt area. The em issions benefits will rem a in constant through 2009.

Implementation

District of Colum b ia - Departm e nt of Environm ent. Maryland - Air and Radiation Managem e nt Adm i nistration; local governm e nt enforcem ent. Virginia - Departm e nt of Environm ental Quality; local governm e nt enforcem ent.

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References

“Open Burning in Residential Areas, Em issions Inventory Developm ent Report,” E.H. Pechan & Associates, Inc., January 31, 2003. Prepared for the Mid-Atlantic/Northeast Visibility Union.

“Northern Virginia Open Burning Rule Effectiveness Evaluation,” E.H. Pechan & Associates, Inc., Decem ber 8, 2003. Prepared for the County of Fairfax.

MW AQC Ozone SIP May 23, 2007 6-196.2.7 Stage I Vapor Recovery System Expansion (state rule)

This m easure involves applying the federal Control Technique Guideline' s "balanced subm erged" underground storage tank refilling m e thod at gas stations located in newly designated nonattainm e nt counties.

Source Type Affected

All filling of underground storage tanks not controlled were affected.

Control Strategy

In the 15% VOC Reduction Plan, balanced subm erged f ill requirem e nts were extended to Calvert, Charles and Frederick counties in Maryland and Stafford counties in Virginia. All other counties in the nonattainm e nt area already were required to use balanced subm erged fills. Note that Stafford County is not part of the W a shington, DC-MD-VA 8-hour ozone nonattainm e nt

area.

Implementation

Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References Maryland Departm e nt of the Environm ent, Air Managem e nt Adm i nistration, Stage I Vapor Recovery Inspection Program , (Beth Murray, Septem ber 30, 1991).

MW AQC Ozone SIP May 23, 2007 6-206.2.8 Stage II Vapor Recovery (federal law )

As a serious ozone nonattainm e nt area, W a shington was required, under 42 U.S.C. § 7511a(b)(3) and 7511a(c), to install stage II vapor recovery system s at gasoline pum ps.

Source Type Affected

This m easure affects gasoline service stations with a throughput of at least 10,000 gallons per

m onth and reduces vehicle refueling em issions. Refueling em issions are attributed to the evaporation of gasoline-rich vapors displaced from the storage tank during refueling. The system is com posed of a nozzle covering the f ill-pipe and a vapor line returning f r om the fillpipe to the storage tank. The stage II system captures the fuel rich vapors fromthe vehicle fillpipe and returns them to the storage tank. Returning saturated vapors to the storage tank reduces

em issions by m a intaining liquid/vapor equilibrium in the storage tank, thereby decreasing the evaporation potential. Recovered vapors are then collected by tanker trucks and returned to the
term inal for recovery or destruction.

Control Strategy

Stage II nozzles have been in place in the District of Colum b ia since 1977. Im plem entation of stage II is required in the W a shington nonattainm e nt regions of Maryland and Virginia by operation of the Clean Air Act Am endm ents of 1990, 42 U.S.C. § 7511a(b)(3) and 7511a(c). Those sections require adherence to a schedule of im plem entation, and set forth a standard for applicability (i.e., to stations of what size or what am ount of gasoline sold per m onth). Maryland and Virginia adopted stage II regulations as a part of their Novem b er 15, 1992 SIP revisions.

Projected Reductions

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

Emission Benefit Calculations

Not applicable.

References

U.S. Environm ental Protection Agency, Technical Guidance -- Stage II Vapor Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline Dispersing Facilities , Volum e 1, EPA450/3-91-022a, Novem b er 1991.

1990 Base Year Em issions Inventory for Stationa ry, Anthropogenic, Biogenic Sources and Highway Vehicle Em issions of Ozone Precursors in the W a shington, DC-MD-VA Metropolitan Statistical Nonattainm e nt Area, Prepared for The District of Colum b ia, Maryland, and Virginia by the Metropolitan W a shington Council of Governm e nts, Septem ber 22, 1993.

MW AQC Ozone SIP May 23, 2007 6-216.2.9 Graphic Arts Controls (state rule/CTG)

Controls for offset lithography have been adopted as a new CTG. These controls apply to sm all printers and sources. VOCs are em itted from the inks used for printing, fountain solutions, and from the solvents used to clean the printing equipm ent.

Source Type Affected

This regulation affects sm all printers not currently regulated under RACT m easures. Lithographic printing facilities include heatset web, non-heatset web, non-heatset sheet-fed, and newspaper non-heatset web sources.

Control Strategy

The 15% VOC Reduction Plan contained m easures based on the draft CTG, which included the f

o llowing controls:

E m i s s i o n S o u r c e R e c o m m e n d e d C o n t r o l

I n k s 9 0 % c o n t r o l ( c o n d e n s e r f i l t e r s ) f o r h e a t s e t p l a n t s Fountain Solution 1.6% isopropyl alcohol (IPA) for heatset plants (90% reduction) alcohol substitution for non-heatset (99 % reduction) 5 % I P A f o r s h e e t

- f e d ( 5 0 % r e d u c t i o n ) Cleaning Solutions 30% VOC content lim it (70% reduction)

Implementation

District of Colum b ia - Departm e nt of Environm ent Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References

U.S. Environm ental Protection Agency , Control Techniques Guideline for Offset Lithographic Printing , Draft, Decem ber 14, 1992.

MW AQC Ozone SIP May 23, 2007 6-226.2.10 Auto Body Refinishing (state rule/CTG)

EPA has crafted a national rule for em issions from auto body refinishing. The rule requires reform ulated auto body coatings. This source category was originally targeted as a new Control Technique Guideline (CTG), and a draft CTG is available for use in creating a state rule.

Source Type Affected

EPA expects all auto body refinishing facilities to be affected. This category includes the application of base coats, prim er coats, finish coats, and sealer/clear coats.

Control Strategy

The 15% VOC Reduction Plan contained a m easure that required reduced-solvent coatings for precoats, prim er surfaces, prim er sealers, and topcoats. The m easure also required the use of spray gun cleaners that recycle solvents, and the use of high-volum e, low- pressure application equipm ent.

Implementation

EPA adopted a National Rule for Autobody Refinishing on August 14, 1998. Maryland - Air and Radiation Managem e nt Adm i nistration

Projected Reductions and Emission Benefit

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

References

U.S. Environm ental Protection Agency, Chem icals and Pet r ol eum Branch, Research Triangle Park, North Carolina , Automobile Refinishing Control Techniques Guideline , Final

EPA Reference Docket Num b er A-95-18

Maryland Departm e nt of the Environm ent, Ai r and Radiation Managem e nt Adm i nistration, Baltim ore, Maryland, Summary and Economic Impact of New Regulation .23 under COMAR 26.11.19, Control of VOC Emissions from Vehicle Refinishing (October 18, 1994)

MW AQC Ozone SIP May 23, 2007 6-236.2.11 Mobile Repair and Refinishing Rule (state rule/OTC model rule)

This rule establishes VOC lim its for paints using in m obile repair and refinishing. The VOC lim its are consistent with f e deral lim its f o r m obile equipm ent ref i nishing m a terials. The rule also requires im proved transfer efficiency applica tion equipm ent, enclosed spray gun cleaning, and

m i nim a l training.

Source Type Affected

All m a nufacturers of paints used in m obile repair and refinishing and operators of m obile repair and ref i nishing f acilities.

Control Strategy

Virginia adopted the Ozone Transport Com m i ssion (OTC) Model Rule for Mobile Repair and Refinishing in Novem b er 2003. This rule becam e effective in the District of Colum b ia in February 2004. The rule applies to all counties in the nonattainm e nt area. The State of Maryland had rules in place by 1996 that contain lim its com p arable to the OTC m odel rule.

Implementation

District of Colum b ia - Departm e nt of Environm ent Virginia - Departm e nt of Environm ental Quality

Projected Reductions

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 0.13 - 3.49 3.61

2009 VOC Reductions 0.13 - 3.59 3.72

Emission Benefit Calculations

Projected reductions are based on an em ission re duction factor of 38 percent, based on Pechan (2001).

References

E.H. Pechan, “Control Measure Developm ent Support Analysis for the Ozone Transport Com m i ssion Model Rules”, March 31, 2001.

MW AQC Ozone SIP May 23, 2007 6-246.2.12 Portable Fuel Containers Rule: Phase I (state rule/OTC model rule)

This m easure introduces perform a nce standards for portable fuel containers and spouts. The standards are intended to reduce em issions f r om storage, transport and ref u eling activities. The rule also included adm i nistrative and labeling requirem e nts. Com p liant containers m u st have: only one opening for both pouring and filling, an autom a tic shut-off to prevent overfill, an
autom a tic sealing m echanism when not dispensing fu el and specified fuel flow rates, perm eation rates and warranties.

Source Type Affected

Any person or entity selling, supplying or m a nuf acturing 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 f our gallons, saf e ty cans and portable m a rine f u el tanks operating with outboard m o tors, and products resulting in cum u lative VOC em issions below those of a representative container or spout.

Control Strategy

Maryland adopted phase I of the Ozone Transport Com m i ssion (OTC) Model Rule for Portable Fuel Containers in January 2002.

Virginia adopted phase I of the Ozone Transport Com m i ssion (OTC) Model Rule for Portable Fuel Containers on Novem b er 2003.

The rule was adopted in the District of Colum b ia in April 2004.

The rule applies to all counties in the nonattainm e nt area.

Reductions from this rule increase annually beginning with im plem entation in the State of Maryland on January 1, 2004.

The District of Colum b ia and the Com m onwealth of Virginia required com p liance with this rule as of January 1, 2005.

Implementation

Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality District of Colum b ia - Departm e nt of Environm ent

MW AQC Ozone SIP May 23, 2007 6-25Projected Reductions

Reductions are shown under phase II of the Portable Fuel Container Rule.

Emission Benefit Calculations

Projected reductions are based on an em ission reduction factor of 75 percent after full im plem entation after 10 years. Im plem entation began in 2004 in Maryland and 2005 in the District and Virginia. In 2008, the em ission reduction factor is 25 -32.5 percent. In 2009, the

em ission reduction factor is 32.5 - 40 percent.

References

E.H. Pechan, “Control Measure Developm ent Support Analysis for the Ozone Transport Com m i ssion Model Rules”, March 31, 2001.

MW AQC Ozone SIP May 23, 2007 6-266.2.13 Architectural and Industrial Maintenance C oatings Rule (state rule/OTC model rule)

This rule requires m a nufacturers to reform ulate va rious types of coatings to m eet VOC content lim its. Affected products include architectural coatings, traffic m a rkings, high-perform a nce

m a intenance coatings and other special-purpose coatings. It uses m o re stringent VOC content lim its than the existing Federal consum er products rule.

Source Type Affected

The m easure affects all m a nufacturers of affected coatings.

Control Strategy

Virginia adopted the Ozone Transport Com m i ssion (OTC) Model Rule for Architectural and Industrial Maintenance Coatings in Novem b er 2003.

Maryland adopted this rule on March 29, 2004.

The rule becam e effective in the District of Colum b ia in April 2004.

The rule will apply to all counties in the nonattainm e nt area.

The VOC content lim its in this rule are based on a Suggested Control Measure (SCM) adopted by the California Air Resources Board (CARB) a nd a State and Territorial Air Pollution Program Adm i nistrators/Association of Local Air Polluti on Officials (STAPPA/ALAPCO) m odel rule or OTC coatings. Manufacturers are expected to com p ly with this rule using prim arily EPA Test Method 24.

Implementation

District of Colum b ia - Departm e nt of Environm ent Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality

MW AQC Ozone SIP May 23, 2007 6-27Projected Reductions

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 1.45 50.22 5.4 12.07

2009 VOC Reductions 1.46 5.29 5.53 12.28

Note: The District' s OTC VOC rules on all the applicab le area source categories are or will be fully adopted, subm itted to EP A, and federally enforceable m easures . However, the em ission reductions arising from these

m eas ures in the Dis t rict are not applied to the em i ssions inventories presented in this RFP/attainm e nt modeling/contingency demonstration of the Washington DC-MD-VA regional SI P

. The Dis t rict of Colum b ia's

m easures are expected to provide additional enhan cem ents to the air quality im provem e nt in the region.

Emission Benefit Calculations

Projected reductions are based on an em ission re duction factor of 31 percent, based on Pechan (2001).

References

E.H. Pechan, “Control Measure Developm ent Support Analysis for the Ozone Transport Com m i ssion Model Rules”, March 31, 2001.

MW AQC Ozone SIP May 23, 2007 6-286.2.14 Consumer Products Rule: Phase I (sta te rule/Oz one Transport Commission (OTC) model rule)

Phase I of the Consum er Products Rule require d reform ulation of approxim a tely 80 types of

consum er products to reduce their VOC content. It uses m o re stringent VOC content lim its than the existing Federal consum er products rule. The rule also contains requirem e nts for labeling and reporting.

Source Type Affected

Manufacturers of various specialty chem icals nam e d 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 Com m i ssion (OTC) Model Rule for Reform ulated Consum er Products becam e effective in the District of Colum b ia in April 2004.

The State of Maryland adopted phase I of the Ozone Transport Com m i ssion (OTC) Model Rule for Reform ulated Consum er Products on August 18, 2003.

The Com m onwealth of Virginia adopted phase I of the Ozone Transport Com m i ssion (OTC) Model Rule for Reform ulated Consum er Products on March 9, 2005.

Manufacturers are expected to dem onstrate com p liance with the rule prim arily through a California Air Resources Board (CARB) test m e thod. If com p lying with the VOC contents becom e s dif f i cult, f l exibility options are provided.

Implementation

Maryland - Air and Radiation Managem e nt Adm i nistration District of Colum b ia - Departm e nt of Environm ent Virginia - Departm e nt of Environm ental Quality

MW AQC Ozone SIP May 23, 2007 6-29Projected Reductions

Reductions are shown under phase II of the Consum er Products Rule.

Emission Benefit Calculations

Projected reductions are based on an em ission re duction factor of 14.2 percent, based on Pechan (2001).

References

E.H. Pechan, “Control Measure Developm ent Support Analysis for the Ozone Transport Com m i ssion Model Rules”, March 31, 2001.

MW AQC Ozone SIP May 23, 2007 6-306.2.15 Solvent Cleaning Operations Rule (state rule/ Oz one Transport Commission (OTC) model rule)

This rule establishes hardware and operating requirem e nts and alternative com p liance options for vapor cleaning m achines used to clean m e tal parts. These m achines are used in

m a nufacturing operations to clean grease, wax, oil and other contam inants from parts when a high level or cleanliness is necessary. The rule also affects cold cleaners, which are used in
autom obile and m a intenance facilities and industrial m a intenance shops.

Source Type Affected

Manufacturers and operators of vapor cleaning or cold cleaning m achines

Control Strategy

Virginia adopted the Ozone Transport Com m i ssion (OTC) Model Rule for Solvent Cleaning Operations in Novem b er 2003. The rule applies to all counties in the nonattainm e nt area.

The rule becam e effective in the District of Colum b ia in April 2004.

The State of Maryland had rules in place by 1996 that contain lim its com p arable to the OTC

m odel rule. Therefore the OTC m odel rule was not needed in Maryland as a state rule was already in place.

Standards for vapor cleaning m achines are based on Federal Maxim u m Available Control Technology (MACT) standards for chlorinated solvent vapor degreasers. Cold cleaner solvent volatility provisions are based on regulatory program s in place in several states, prim arily Maryland and Illinois.

Implementation

District of Colum b ia - Departm e nt of Environm ent Virginia - Departm e nt of Environm ental Quality

Projected Reductions

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 0.21 0 2.91 3.13

2009 VOC Reductions 0.22 0 2.99 3.20

Note: The District' s OTC VOC rules on all the applicab le area source categories are or will be fully adopted, subm itted to EP A, and federally enforceable m easures . However, the em ission reductions arising from these

MW AQC Ozone SIP May 23, 2007 6-31m eas ures in the Dis t rict are not applied to the em i ssions inventories presented in this RFP/attainm e nt modeling/contingency demonstration of the Washington DC-MD-VA regional SI P

. The Dis t rict of Colum b ia's

m easures are expected to provide additional enhan cem ents to the air quality im provem e nt in the region.

Emission Benefit Calculations

Projected reductions are based on an em ission re duction factor of 66 percent, based on Pechan (2001).

References

E.H. Pechan, “Control Measure Developm ent Support Analysis for the Ozone Transport Com m i ssion Model Rules”, March 31, 2001.

MW AQC Ozone SIP May 23, 2007 6-326.2.16 Industrial Adhesives and Sealants Rule (state rule/ Oz one Transport Commission (OTC) model rule)

This rule establishes VOC content lim itations for industrial and com m e rcial application of solvent-based adhesives and sealants. Controls will cover adhesives, sealants, adhesive prim ers, sealer prim ers, adhesive application to substrates, and aerosol adhesives. VOC content lim its are sim ilar to those contained in the CARB Reas onably Available Control Technology (RACT) or Best Available Control Technology (BACT) docum en t for adhesives and sealants (Dec. 1998).

Source Type Affected

Manufacturers and distributors of industrial adhesives and sealants.

Control Strategy

All jurisdictions plan to adopt the OTC Model Rule for Industrial Adhesives and Sealants in 2007. The rule will be effective in Maryland and the District of Colum b ia no later than May 1, 2008 and for Virginia no later than May 1, 2009.

Implementation

District of Colum b ia - Departm e nt of Environm ent Virginia - Departm e nt of Environm ental Quality Maryland - Air and Radiation Managem e nt Adm i nistration

Projected Reductions

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 0 0 0 0

2009 VOC Reductions 0.16 1.19 1.23 2.58

Note: The District' s OTC VOC rules on all the applicab le area source categories are or will be fully adopted, subm itted to EP A, and federally enforceable m easures . However, the em ission reductions arising from these

m eas ures in the Dis t rict are not applied to the em i ssions inventories presented in this RFP/attainm e nt modeling/contingency demonstration of the Washington DC-MD-VA regional SI P

. The Dis t rict of Colum b ia's

m easures are expected to provide additional enhan cem ents to the air quality im provem e nt in the region.

MW AQC Ozone SIP May 23, 2007 6-33Emission Benefit Calculations

Em ission reductions are based on a 64 percent reduction in em issions of VOC from the baseline. Further details are available from OTC (2007).

References

OTC 2007. Identification and Evaluation of Candidate C ontrol Measures: Fi nal Technical Support Document. Pr e p a r e d by MACTEC Federal Program s, Inc., Herndon, Virginia for the Ozone Transport Com m i ssion. February 28, 2007.

MW AQC Ozone SIP May 23, 2007 6-346.2.17 Portable Fuel Containers Rule: Phase II (state rule/ Oz one Transport Commission (OTC) model rule)

This m easure expands existing perform a nce standards for portable gasoline containers and spouts to kerosene containers. The standards are intended to reduce em issions from storage, transport and ref u eling activities. The rule also included adm i nistrative and labeling requirem e nts. Com p liant containers m u st have : only one opening for both pouring and filling, an
autom a tic shut-of f to prevent overf ill, an autom a tic sealing m echanism when not dispensing f u el and specified fuel flow rates, perm eation rates and warranties.

Source Type Affected

Any person or entity selling, supplying or m a nuf acturing 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 f our gallons, saf e ty cans and portable m a rine f u el tanks operating with outboard m o tors, and products resulting in cum u lative VOC em issions below those of a representative container or spout.

Control Strategy

All jurisdictions plan to adopt the Phase II OTC Model Rule for Portable Fuel Containers in 2007. The rule will be effective in all jurisdictions no later than May 1, 2008. The rule will apply to all counties in the nonattainm e nt area.

Implementation

Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm ental Quality District of Colum b ia - Departm e nt of Environm ent

Projected Reductions

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total 2008 VOC Reductions (Phase I rule only) 0.75 5.17 2.17 8.09

2009 VOC Reductions 0.99 6.95 3.11 11.05

I n cludes r e ductions fr om Phase I and Phase I I

. Note: The District' s OTC VOC rules on all the applicab le area source categories are or will be fully adopted, subm itted to EP A, and federally enforceable m easures . However, the em ission reductions arising from these

m eas ures in the Dis t rict are not applied to the em i ssions inventories presented in this RFP/attainm e nt modeling/contingency demonstration of the Washington DC-MD-VA regional SI P

. The Dis t rict of Colum b ia's

m easures are expected to provide additional enhan cem ents to the air quality im provem e nt in the region.

MW AQC Ozone SIP May 23, 2007 6-35Emission Benefit Calculations

Phase I: Projected reductions are based on an em ission reduction factor of 75 percent after full im plem entation after 10 years. Im plem entation began in 2004 in Maryland and 2005 in the District and Virginia. In 2008, the em ission reduction factor is 25 -32.5 percent. In 2009, the

em ission reduction factor is 32.5 - 40 percent.

Phase II: Em ission reductions are based on a 4 percent reduction in em issions of VOC. Further details are available from OTC (2007).

References

OTC 2007. Identification and Evaluation of Candidate C ontrol Measures: Fi nal Technical Support Document. Pr e p a r e d by MACTEC Federal Program s, Inc., Herndon, Virginia for the Ozone Transport Com m i ssion. February 28, 2007.

MW AQC Ozone SIP May 23, 2007 6-366.2.18 Consumer Products Rule: Phase II (state rule/ Oz one Transport Commission (OTC) model rule)

Phase II of the Consum er Products Rule involves adopting the CARB 7/20/05 Am endm ents which sets new or revises existing lim its on 13 consum er product categories. It uses m o re stringent VOC content lim its than the existing federal consum er products rule. The rule also contains requirem e nts for labeling and reporting.

Source Type Affected

Manufacturers of various specialty chem icals nam e d in the rule, such as aerosol adhesives, floor wax strippers, dry cleaning fluids and general purpose cleaners.

Control Strategy

All jurisdictions plan to adopt phase II of the OTC Model Rule for Reform ulated Consum er Products in 2007. The rule will be effective in Maryland and the District of Colum b ia no later than May 1, 2008 and for Virginia no later than May 1, 2009.

Manufacturers are expected to dem onstrate com p liance with the rule prim arily through a California Air Resources Board (CARB) test m e thod. If com p lying with the VOC contents becom e s dif f i cult, f l exibility options are provided.

Implementation

Maryland - Air and Radiation Managem e nt Adm i nistration District of Colum b ia - Departm e nt of Environm ent Virginia - Departm e nt of Environm ental Quality

Projected Reductions

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 0.84 3.59 3.03 7.46

2009 VOC Reductions 0.85 3.63 3.47 7.95

Note: The District' s OTC VOC rules on all the applicab le area source categories are or will be fully adopted, subm itted to EP A, and federally enforceable m easures . However, the em ission reductions arising from these

m eas ures in the Dis t rict are not applied to the em i ssions inventories presented in this RFP/attainm e nt modeling/contingency demonstration of the Washington DC-MD-VA regional SI P

. The Dis t rict of Colum b ia's

m easures are expected to provide additional enhan cem ents to the air quality im provem e nt in the region.

MW AQC Ozone SIP May 23, 2007 6-37Emission Benefit Calculations

Phase I: Projected reductions are based on an em ission reduction factor of 14.2 percent, based on Pechan (2001).

Phase II: Em ission reductions are based on a 2 percent reduction in em issions of VOC. Further details are available from OTC (2007).

References

OTC 2007. Identification and Evaluation of Candidate C ontrol Measures: Fi nal Technical Support Document. Pr e p a r e d by MACTEC Federal Program s, Inc., Herndon, Virginia for the Ozone Transport Com m i ssion. February 28, 2007.

E.H. Pechan, “Control Measure Developm ent Support Analysis for the Ozone Transport Com m i ssion Model Rules”, March 31, 2001.

MW AQC Ozone SIP May 23, 2007 6-386.3 NON-ROAD MEASURES

The following non-road em ission reduction m easures that are discussed in this section are calculated using the NONROAD2005 em ission factor m odel:

• EPA Non-road Gasoline Engines Rule, 6.3.1

• EPA Non-road Diesel Engines Rule, 6.3.2

• Em issions Standards For Spark Ignition Marine Engines, 6.3.3

• Em issions Standards for Large Spark Ignition Engines, 6.3.4

• Reform ulated Gasoline for Off-Road Applications, 6.3.5

• Em ission Standards for Locom o tives, 6.3.6, are calculated using the Area Source spreadsheet but em ission benefits are included in the nonroad sector totals.

Projected Reductions and Emi ssion Benefit Calculations

Past SIP docum ents for the W a shington region ha ve presented the em ission reductions from each of the above m easures individually, and then sum m e d the reductions to create a controlled on road inventory for each m ilestone year. NONROAD2005, the current non-road em issions

m odel approved for use by the EPA, is not designed to calculate the benefits of each of the above control m easures individually. As a result, this and f u ture SIP revisions will not enum erate the benefits of individual non-road control m easures. The table below sum m a rizes the com b ined benefits from the above control m easures by jurisdiction.

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 1.50 17.77 17.69 36.96

2009 VOC Reductions 1.78 20.53 20.19 42.50

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 NOx Reductions 1.62 6.01 6.60 14.23

2009 NOx Reductions 2.03 7.38 8.09 17.50

MW AQC Ozone SIP May 23, 2007 6-396.3.1 Phase I and Phase II Emissions Standard s for Gasoline-Pow e red Non-Road Utility Engines (federal rule)

This m easure takes credit for VOC em issions reductions attributable to em issions standards
prom ulgated by the EPA f o r sm all non-road, spark-ignition (i.e., gasoline-powered) utility engines, as authorized under 42 U.S.C. §7547. The m easure affects gasoline-powered (or other spark-ignition) lawn and garden equipm ent, cons truction equipm .ent, chain saws, and other such utility equipm ent as chippers and stum p grinders, wood splitters, etc., rated at or below 19 kilowatts (an equivalent of 25 or fewer horsepower). Phase 2 of the rule applied further controls on handheld and non-handheld outdoor equipm ent.

Control Strategy

Federal em issions standards prom ulgated under §7547 (a) apply to spark-ignition non-road utility engines. The EPA' s Phase 1 Spark Ignition Nonroad f i nal rule on such em issions standards was published in 60 Federal Register 34581 (July 3, 1995), and was effective beginning August 2, 1995. Com p liance was required by the 1997 m odel year. The Phase 2 final rule for handheld nonroad equipm ent was published in 65 Federal Register 24267 (April 25, 2000). The Phase 2 final rule for non-handheld equipm ent was published in 64 Federal Register 15207 (March 30, 1999).

Implementation

This program is im plem ented by the EPA, under 42 U.S.C. §7547 (a).

MW AQC Ozone SIP May 23, 2007 6-40References

EPA Guidance Mem o randum , "Future Nonroad Em ission Reduction Credits for Court-Ordered Nonroad Standards" from Em ission Planning and Strategies Division, Mem o randum from Phil Lorang, Director, Em ission Planning a nd Strategies Division, Novem b er 28, 1994.

U.S. Environm ental Protection Agency, "Em i ssi on Standards for New Nonroad Spark-Ignition Engines at or Below 19 Kilowatts", Final Rule, 60 Federal Register 34581 (July 3, 1995).

U.S. Environm ental Protection Agency, “Phase 2 Em ission Standards for New Nonroad SparkIgnition Nonhandheld Engines At or Below 19 Kilowatts”, Final Rule, 64 Federal Register 15207, (March 30, 1999); correction published 64 Federal Register 36423 (July 6, 1999)

U.S. Environm ental Protection Agency, “Phase 2 Em ission Standards for New Nonroad SparkIgnition Handheld Engines at or Below 19 Kilo watts”, Final Rule, 65 Federal Register 24267 (April 25, 2000)

1990 Clean Air Act Am endm ents, 42 U.S.C. §7547 (a).

MW AQC Ozone SIP May 23, 2007 6-416.3.2 Emissions Standards for Diesel-Pow ered Non-Road Utility Engines of 50 or More Horsepow er (federal rule)

This m easure takes credit for NOx em issions reductions attributable to em issions standards
prom ulgated by the EPA f o r non-road, com p ression-ignition (i.e., diesel-powered) utility engines, as authorized under 42 U.S.C. § 7547. The m easure affects diesel-powered (or other

com p ression-ignition) construction equipm ent, indus trial equipm ent, etc., rated at or above 37 kilowatts (37 kilowatts is approxim a tely equal to 50 horsepower).

Control Strategy

Federal em issions standards applicable to com p ression-ignition non-road utility engines are
prom ulgated under §7547 (a).

EPA' s first rule on such em issions standards was published in 59 Federal Register 31306 (June 17, 1994), and was effective on July 18, 1994.

Tier 2 and Tier 3 Em ission Standards were prom ulgated in 1998. This program includes the first set of standards for nonroad diesel engines less than 37 kW (phasing in between 1999 and 2000), including m a rine engines in this size range. It also phases in m o re stringent "Tier 2" em ission standards from 2001 to 2006 for all engine sizes and adds yet m o re stringent "Tier 3" standards for engines between 37 and 560 kW (50 and 750 hp) from 2006 to 2008.

EPA adopted a com p rehensive national program to greatly reduce em issions from future nonroad diesel engines by integrating engine and f u el controls as a system to gain the greatest air quality benefits. This rule was published June 29, 2004. The requirem e nt to reduce sulfur levels in nonroad diesel fuel by m o re than 99 percent will allow for the first tim e advanced em ission control system s to be used on the engines used in construction, agricultural, industrial, and airport service equipm ent.

Implementation

This program is im plem ented by the EPA under 42 U.S.C. § 7547 (a).

References

1990 Clean Air Act Am endm ents, 42 U.S.C. §7547 (a).

U.S. Environm ental Protection Agency, "Control of Em issions of Air Pollution from Nonroad Diesel Engines; Final Rule." 63 Federal Register 56967, October 23, 1998.

U.S. Environm ental Protection Agency, "Control of Em issions of Air Pollution from Nonroad Diesel Engines and Fuel; Final Ru le." 69 Federal Register Vol. 69, No. 124, June 29, 2004

MW AQC Ozone SIP May 23, 2007 6-42EPA Guidance Mem o randum , "Future Nonroad Em ission Reduction Credits for Court-Ordered Nonroad Standards" from Em ission Planning and Strategies Division, Mem o randum from Phil Lorang, Director, Em ission Planning a nd Strategies Division, Novem b er 28, 1994.

U.S. Environm ental Protection Agency," Determ in ation of Significance for Nonroad Sources and Em ission Standards for New Nonroad Com p ression-Ignition Engines at or Above 37 Kilowatts", Final Rule, 59 Federal Register 31306 (June 17, 1994).

MW AQC Ozone SIP May 23, 2007 6-436.3.3 Emissions Standards for Spark Ignition (SI) Marine Engines (federal rule)

This EPA m easure controls exhaust VOC em issions from new spark-ignition (SI) gasoline

m a rine engines, including outboard engines, persona l watercraft engines, and jet boat engines. Of nonroad sources studied by EPA, gasoline m a rine engines were found to be one of the largest contributors of hydrocarbon (HC) em issions ( 30 percent of the nationwide nonroad total).

Control Strategy

EPA is im posing em ission standards for 2 – str oke technology, outboard and personal watercraft engines. This will involve increasingly stringent HC control over the course of a 9-year phase-in period beginning in m odel year 1998. By the end of the phase-in, each m a nufacturer m u st m eet an HC and NOx em ission standard that represents a 75 percent reduction in HC com p ared to unregulated levels. These standards do not apply to any currently owned engines or boats.

Implementation

This program is im plem ented by the EPA under 42 U.S.C. § 7547 (a).

References

1990 Clean Air Act Am endm ents, 42 U.S.C. §7547 (a).

U.S. Environm ental Protection Agency, "Control of Air Pollution; Final Rule f o r New Gasoline Spark-Ignition Marine Engines; Exem ptions fo r New Nonroad Com p ression-Ignition Engines at or Above 37 Kilowatts and New Nonroad Spark-I gnition Engines at or Below 19 Kilowatts", 61 Federal Register 52087, October 4, 1996.

Regulatory Im pact Analysis "Control of Air Polluti on Em ission Standards for New Nonroad Spark-Ignition Marine Engines", U.S. EPA, June 1996

MW AQC Ozone SIP May 23, 2007 6-446.3.4 Emissions Standards for Large Spark Ignition Engines (federal rule)

This EPA m easure controls VOC and NOx em issions from several groups of previously unregulated nonroad engines, including large industrial spark-ignition engines.

Control Strategy

The EPA requirem e nts vary depending upon the type of engine or vehicle, taking into account environm ental im pacts, usage rates, the need for high perform a nce m odels, costs and other factors. The em ission standards apply to all new engines sold in the United States and any im ported engines m a nufactured after these standards began.

Controls on the category of large industrial spark-ignition engines were first required in 2004.Controls on the other engine categories began in years after 2005. Large industrial sparkignition engines are those rated over 19 kW used in a variety of com m e rcial applications; m o st use liquefied petroleum gas, with others operating on gasoline or natural gas.

EPA adopted two tiers of em ission standards for Large SI engines. The first tier of standards, which started in 2004, are based on a sim p le laboratory m easurem ent using steady-state procedures. The Tier 1 standards are the sam e as those adopted earlier by the California Air Resources Board for engines used in California. Tier 2 standards becam e effective in 2007.

Implementation

This program is im plem ented by the EPA under 42 U.S.C. § 7547 (a).

References

1990 Clean Air Act Am endm ents, 42 U.S.C. §7547 (a).

U.S. Environm ental Protection Agency, "Contro l of Em issions fromNonroad Large SparkIgnition Engines, and Recreational Engines (Marine and Land-Based)," Final Rule, 67 Federal Register 68241 (Novem b er 8, 2002).

U.S. Environm ental Protection Agency, Final Regulatory Support Docum e nt: Control of Em issions from Unregulated Nonroad Engines,” EPA420-R-02-022, Septem ber 2002.

MW AQC Ozone SIP May 23, 2007 6-456.3.5 Reformulated Gasoline Use in Non-Road Motor Vehicles and Equipment (state optin to federal rule)

This m easure involves taking credit for reductions due to the use of federally reform ulated gasoline in non-road m obile sources. Reform ulated gasoline is available as a result of Virginia' s , Maryland' s, and the District of Colum b ia' s "opting-in" on delivery of reform ulated gasoline in the W a shington, D.C. ozone nonattainm e nt area. Ar eas that opted-in on delivery of reform ulated gasoline began receiving such gasoline beginning in 1995.

Source Types Affected

This m easure affects the various non-road m obile sources that burn gasoline.

Control Strategy

Federal reform ulated gasoline has been sold in the W a shington, DC-MD-VA ozone nonattainm e nt area since January 1, 1995.

Implementation

District of Colum b ia - Im plem ented by EPA via m a yor' s form al request to opt-in to federal
program

. Maryland - Im plem ented by EPA via governor' s form al request to opt-in to federal program

. Virginia - Im plem ented by EPA via governor' s form al request to opt-in to federal program

.

References

U.S. Environm ental Protection Agency, "Regulati on of Fuels and Fuel Additives: Standards f o r Reform ulated Gasoline", Proposed Rule, 58 Federal Register 11722, February 26, 1993.

"VOC Em ission Benefits for Non-Road Equipm ent with the Use of Federal Phase I Reform ulated Gasoline", m e m o randum from Phil Lorang, U.S. EPA Office of Mobile S ources to A i r D i rectors, EPA Regions 1-10, August 18, 1993.

MW AQC Ozone SIP May 23, 2007 6-466.3.6 Standards for Locomotives (federal rule)

This sets NOx standards for locom o tive engines rem a nufactured and m a nufactured after 2001.

Source Type Affected

This program includes all locom o tives originally m a nufactured from 2002 through 2004. It also applies to the rem a nufacture of all engines built since 1973. Regulation of the rem a nufacturing process is critical because locom o tives are generally rem a nufactured 5 to 10 tim es during their total service lives, which are typically 40 years or m o re.

Control Strategy

Three separate sets of em issions standards have been adopted, with the applicability of the standards dependent on the date a locom o tive is first m a nufactured. The first set of standards (Tier 0) applies to locom o tives and locom o tive engines originally m a nufactured from 1973 through 2001, any tim e they are m a nufactured or rem a nufactured. The second set of standards (Tier 1) apply to locom o tives and locom o tive engines originally m a nufactured from 2002 through 2004. These locom o tives are required to m eet the Tier 1 standards at the tim e of

m a nufacture and at each subsequent rem a nufacture. The final set of standards (Tier 2) apply to locom o tives and locom o tive engines originally m a nufactured in 2005 and later. Electric locom o tives, historic steam -powered locom o tives and locom o tives m a nufactured before 1973 do not significantly contribute to the em issions pr oblem and, therefore, are not included in the regulation.

Implementation

This program is im plem ented by the EPA under the Final Emissions Standards for Locomotives (EPA420-F-97-048) published in Decem ber 1997.

MW AQC Ozone SIP May 23, 2007 6-47Projected Reductions

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 NOx Reductions 0.26 1.02 1.26 2.54

2009 NOx Reductions 0.27 1.09 1.37 2.73

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 0.01 0.02 0.02 0.05

2009 VOC Reductions 0.01 0.03 0.02 0.06 Note: NOx and VOC values are generated using the Ar ea Source spreasheet but are presented in the overall nonroad sector totals.

Emission Benefit Calculations

Em ission benefits are based on EPA guidance on em ission factors for locom o tives. In 2008, the reductions are 10.3 percent for VOC and 30.7 percent for NOx. In 2009, the reductions are 13.5 percent for VOC and 32.35 percent for NOx.

References

Regulatory Update, EPA’s Nonroad Engine Emissions Control Programs, EPA, Air and Radiation, EPA420-F-99-001, January 1999.

Final Emissions Standards for Locomotives, EPA420-F-97-048, Decem ber 1997.

Emission Factors for Locomotives , EPA420-F-97-051, Decem ber 1997, Table 9.

MW AQC Ozone SIP May 23, 2007 6-486.4 ON-ROAD MEASURES

The following onroad em ission reduction m easures that are discussed in this section are calculated using the MOBILE6 em ission factor m odel:

• Controls on Refueling Em issions and Reform ulated Gasoline for On-road Applications, 6.4.1

• Enhanced I/M, 6.4.2

• Federal Tier 1 Vehicle Standards, 6.4.3

• National Low Em ission Vehicle Standards, 6.4.4

• Federal Tier 2 Vehicle Standards, 6.4.5

• Heavy Duty Diesel Engine Rule, 6.4.6

Projected Reductions and Emi ssion Benefit Calculations

Past SIP docum ents for the W a shington region ha ve presented the em ission reductions from each of the above m easures individually, and then sum m e d the reductions to create a controlled on road inventory for each m ilestone year. MOBILE5b, the m obile em issions m odel used in previous SIPs, was designed to calculate the benefits of each of the above control m easures individually. In the update to MOBILE6, changes were m a de to the m odel, creating synergistic effects between the six m obile control m easures listed above. These effects do not lend them selves to isolating credit from one control program , and m a ke it very difficult to calculate increm ental benefits from im plem entation of individual control m easures. As a result, this and f u ture SIP revisions will not enum erate the benef its of individual m obile control m easures, with the exception of the transportation control m eas ures (TCMs) and vehicle technology, fuel, and

m a intenance-based m easures, which are quantified outside of the MOBILE6 m odel. The table below sum m a rizes the com b ined benefits from the above control m e asures by jurisdiction. See Appendix E1 for docum entation of the MOBILE 6 m odeling process.

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 VOC Reductions 0.52 2.70 2.97 6.19

2009 VOC Reductions 0.64 3.33 3.21 7.18

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

2008 NOx Reductions 2.11 14.66 12.90 29.67

2009 NOx Reductions 2.73 18.80 16.09 37.62

MW AQC Ozone SIP May 23, 2007 6-496.4.1 Phase II Volatility Controls of Refueling Emissions and Reformulated Gasoline Use in On-road Vehicles (federal regulation)

This m easure takes credit for lower refueling em issions resulting from the effects of federally

m a ndated reductions in gasoline volatility, as required under 42 U.S.C. §§7545 (h) and (k). The

m easure affects em issions from all gasoline vehicles. In 2005, the m easure requires the use of federal reform ulated gasoline in the W a shington nonattainm e nt area. This is accom p lished through an opt-in to the federal program , which subsequently becam e m a ndatory as a result of designation as severe ozone nonattainm e nt.

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

Source Type Affected

All gasoline-powered vehicles (non-road source benefits are docum ented under Section 6.4.2) are affected by this m easure. Vehicle refueling em issions at service stations are also reduced.

Control Strategy

Federal reform ulated gasoline has been sold in the W a shington, DC-MD-VA ozone nonattainm e nt area since January 1, 1995. The volatility reductions under §7545 (h) becam e effective in sum m e r 1992. Further volatility reductions required under §7545 (k) are associated with the reform ulated gasoline that began selling in the W a shington nonattainm e nt area on January 1, 1995.

Implementation

The volatility controls of refueling em issions program was im plem ented by the EPA under 42 U.S.C. §§7545 (h) and (k). Im plem entation of the RFG program occurs through a state "opt-in" process. The governors of Maryland and Virginia and the m a yor of the District of Colum b ia have "opted in" for, and EPA has approved, delivery of reform ulated gasoline in their respective portions of the W a shington, DC-MD-VA ozone nonattainm e nt area. Under Phase I of the RFG
program , all gasoline sold in the nonattainm e nt area on or after January 1, 1995, m u st be reform ulated gasoline. Phase II of the RFG program becam e effective after January 1, 2000. The program becam e m a ndatory for the W a shington region one year after designation as Severe nonattainm e nt, which occurred on March 23, 2004.

References

1990 Clean Air Act Am endm ents, 42 U.S.C. §§7545 (h) and (k).

U.S. Environm ental Protection Agency, Office of Mobile Sources , User's Guide to MOBILE6.0

, Chapter 2, January 2002.

MW AQC Ozone SIP May 23, 2007 6-506.4.2 Enhanced Vehicle Emissions Inspection and Maintenance (Enhanced I/M) (federal regulation)

This m easure involves requiring a regional vehicle em issions inspection and m a intenance (I/M)
program with requirem e nts stricter than "basic" program s, as required under 42 U.S.C. § 7511a(c)(3) and 7521. Before 1994, "basic" autom obile em issions testing checked only tailpipe

em issions while idling and som e tim es at 2,500 rpm

. The new procedures include a dynam o m e ter (treadm ill) test that checks the car' s em issions under driving conditions. In addition, evaporative em issions and the on-board diagnostic com puter are checked.

Source Type Affected

This m easure affects light-duty gasoline and diesel vehicles and trucks.

Control Strategy

Maryland, the District of Colum b ia, and Virginia com m itted to EPA Perform a nce Standard Enhanced I/M program s in the 15% VOC Em issions Reduction Plan. Each affected vehicle in the region is given a high-tech em issions test ever y two years. In Maryland and the District of Colum b ia, em issions tests are perform e d at test-only stations. Virginia tests vehicles in stations that m a y also perform repairs using a decentralized program

. Implementation

District of Colum b ia - Departm e nt of Public W o rks, Dept. of Consum er and Regulatory Affairs Maryland - Motor Vehicles Adm i nistration Virginia - Departm e nt of Environm ental Quality

Appendix E1 contains detailed inform ation regarding im plem entation of I/M program s in the District, Maryland, and Virginia.

References

U.S. Environm ental Protection Agency, "Inspec tion/ Maintenance Program Requirem e nts," Final Rule, 57 Federal Register 52950 (Novem b er 5, 1992).

U.S. Environm ental Protection Agency, "I/M Costs, Benefits, and Im pacts Analysis," Draft, February 1992.

MW AQC Ozone SIP May 23, 2007 6-516.4.3 Federal "Tier I" New Vehicle Emission and New Federal Evaporative Emissions Standards (federal regulation)

Under 42 U.S.C. §7521, EPA issued a new and cleaner set of federal m o tor vehicle em ission standards (Tier I standards), which were phased in beginning with m odel year 1994.

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof.

Source Type Affected

These federally im plem ented program s affected li ght-duty vehicles and light-duty trucks (LDT).

Control Strategy

The Federal Motor Vehicle Control Program requires m o re stringent exhaust em ission standards as well as a uniform level of evaporative em ission controls, dem onstrated through the new federal evaporative test procedures. Under 42 U.S.C. §7521(g), all post-1995 m odel year cars

m u st achieve the Tier I (or Phase I) exhaust standards, which are as follows. Em issions are in
gram s per m ile, and are related to durability tim efram e s of 5 yrs/50,000 m iles and 10 yrs/100,000 m iles.

Vehicle Type 5 yrs/50,000 mi 10 yrs/100,000 mi V O C s C O N O x V O C s C O N O x Light-duty vehicles; light-duty trucks (loaded weight 3,750 lbs) 0

. 2 5 3

. 4 0

. 4 * 0

. 3 1 4

. 2 0

. 6 *

Light-duty trucks (loaded weight of 3,751 to 5,750 lbs) 0

. 3 2 4

. 4 0

. 7 * * 0

. 4 0 5

. 5 0

. 9 7

*For diesel-fueled light-duty vehicles and for LDTs at 3,750 lbs, before m odel year 2004, the applicable NOx standards shall be 1.0 at 5 yrs/50,000 m i and 1.25 at 10 yrs/100,000. **This NOx standard does not apply to di esel-fueled trucks of 3,751 to 5,750 lbs.

Implementation This program is im plem ented by the EPA under 42 U.S.C. §7521.

References

U.S. Environm ental Protection Agency, Office of Mobile Sources, User's Guide to MOBILE5

, Chapter 2, March 1993.

MW AQC Ozone SIP May 23, 2007 6-526.4.4 National Low Emission Vehicle Program (federal regulation)

Under the National Low-Em ission Vehicle (LEV) program , auto m a nufacturers have agreed to

com p ly with tailpipe standards that are m o re stringent than EPA can m a ndate prior to m odel year (MY) 2004. Once m a nufacturers com m itted to the program , the standards becam e enforceable in the sam e m a nner that other federal m o tor vehicle em issions control requirem e nts are enforceable. The program went into effect throughout the Ozone Transport Region (OTR), including Maryland, Virginia, and the District of Colum b ia, in m odel year 1999 and was in place nationwide in m odel year 2001.

The benefits of this program are reflected in the 2002 baseline inventory and the 2008 and 2009 projections thereof. No additional reductions are calculated.

Source Type Affected

These federally im plem ented program s affect light-duty vehicles and trucks.

Control Strategy

The National Low Em ission Vehicle Program requires m o re stringent exhaust em ission standards than the Federal Motor Vehicle Control Program Tier I (or Phase I) exhaust standards.

Implementation

This program is im plem ented by the EPA, under 40 CFR Part 86 Subpart R. Nine states within the OTR, including the MW AQC states, have opted-in to the program as have all the auto

m a nufacturers. EPA found the program to be in effect on March 2, 1998.

References

U.S. Environm ental Protection Ag ency, Office of Mobile Sources, User's Guide to MOBILE5

, Chapter 2, March 1993.

MW AQC Ozone SIP May 23, 2007 6-536.4.5 Tier 2 Motor Vehicle Emission Regulations (federal regulation)

The U.S. EPA prom ulgated a rule on February 10, 2000 requiring m o re stringent tailpipe

em issions standards f o r all passenger vehicles, including sport utility vehicles (SUVs), m i nivans, vans and pick-up trucks. These regulations also require lower levels of sulfur in gasoline, which will ensure the effectiveness of low em ission-control technologies in vehicles and reduce harm ful air pollution.

Source Type Affected

These federally im plem ented program s affect light-duty vehicles and trucks.

Control Strategy

The new tailpipe and sulfur standards require passenger vehicles to be 77 to 95 percent cleaner than those built bef o re the rule was prom ulgated and will reduce the sulf ur content of gasoline by up to 90 percent. The new tailpipe standards are set at an average standard of 0.07 gram s per

m ile for NOx for all classes of passenger vehicl es beginning in 2004. This includes all light-dutytrucks, as well as the largest SUVs. Vehicles weighing less than 6000 pounds are being phasedin to this standard between 2004 and 2007.

Beginning in 2004, the refiners and im porters of gasoline have the flexibility to m a nufacture gasoline with a range of sulfur levels as long as all of their production is capped at 300 parts per

m illion (ppm ) and their annual corporate average sulfur levels are 120 ppm . In 2005, the refinery average was set at 30 ppm , with a corporate average of 90 ppm and a cap of 300 ppm . Finally, in 2006, refiners m e t a 30 ppm average sulfur level with a m a xim u m cap of 80 ppm

.
As newer, cleaner cars enter the national f l eet, the new tailpipe standards will signif i cantly reduce em issions of nitrogen oxides from vehicles by about 74 percent by 2030.

Implementation EPA im plem ents this program under 40 CFR Parts 80, 85, and 86.

References

U.S. Environm ental Protection Ag e n c y , “Control of Air Pollution from New Motor Vehicles: Tier 2 Motor Vehicle Em issions Standards and Gasolin e Sul f ur

Control Requirem e nts,” Final Rule, 65 Federal Register 6697, February 10, 2000.

MW AQC Ozone SIP May 23, 2007 6-546.4.6 Heavy-Duty Diesel Engine Rule (federal regulation)

Under the Heavy-Duty Diesel Engine Rule, truck m a nufacturers m u st com p ly with m o re stringent tailpipe standards by 2004 and 2007. The standards are enforceable in the sam e

m a nner that other federal m o tor vehicle em issions control requirem e nts are enforceable.

Source Type Affected

These federally im plem ented program s affect heavy-duty diesel engines used in trucks.

Control Strategy

The Heavy-Duty Diesel Engine Rule requires m o re stringent exhaust em ission standards.

Implementation

This program is im plem ented by the EPA, under 40 CFR Parts 9 and 86 Control of Em issions of Air Pollution From Highway Heavy-Duty Engines; Final Rule.

References

U.S. Environm ental Protection Agency, Office of Mobile Sources, User's Guide to MOBILE5

, Chapter 2, March 1993.

40 CFR Parts 9 and 86 Control of Em issions of Air Pollution from Highway Heavy-Duty Engines; Final Rule (62 FR 54694), October 21, 1997.

MW AQC Ozone SIP May 23, 2007 6-556.4.7 Transportation Control Measures (TCMs) and Vehicle Technology, Fuel, and Maintenance-based Measures (state and local program)

Section 108(f) of the Clean Air Act Am endm ents provides exam ples of TCMs that can be im plem ented to reduce em issions from m obile sources. Most TCMs are designed to reduce vehicle m iles traveled or vehicle trips or im prove the flow of traffic.

In conjunction with state departm e nts of transportation and local transit authorities, state air agencies have identif ied a num ber of projects designed to reduce vehicle travel and m itigate traffic congestion in the Metropolitan W a shington nonattainm e nt area. These m easures include purchase of alternative-f u eled vehicles, im provem e nts to bicycle and pedestrian f acilities, and im provem e nts to transit services and access to transit facilities. All responsible agencies have

com m itted to im plem enting these projects by January 1, 2005.

Additional inform ation on TCMs is contained in Appendix F.

Source Type Affected Transportation-related activities in the Metropolitan W a shington nonattainm e nt area

Implementation District of Colum b ia – Departm e nt of Transportation Maryland - Departm e nt of Transportation Virginia - Departm e nt of Transportation W a shington Metropolitan Area Transit Authority Northern Virginia Local Governm e nts

MW AQC Ozone SIP May 23, 2007 6-56Projected Reductions Transportation Control Measures:

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total*

2008 VOC Reductions 0.0025 0.0429 0.0624 0.1124

2009 VOC Reductions 0.0022 0.0395 0.0576 0.1037

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total*

2008 NOx Reductions 0.0025 0.1 0.1385 0.2490

2009 NOx Reductions 0.0023 0.0896 0.1238 0.2229

Vehicle Technology, Maintenance, or Fuel-Based Measures:

VOC Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total*

2008 VOC Reductions 0 0.0064 0.0165 0.0829

2009 VOC Reductions 0 0.0059 0.0152 0.0812

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total*

2008 NOx Reductions 0.0022 0.0154 0.0595 0.2365

2009 NOx Reductions 0.0022 0.0138 0.0552 0.2306

Note: Totals also include TCMs and Vehicle Tec hnology, Maintenance, and Fuel-based Measures for the W a shington Metropolitan Area Transit Adm i nistration (W MATA). Em ission reduction estim ates were supplied by the District of Colum b ia Departm e nt of Transportation, the Maryland Departm e nt of Transportation, the Virginia Departm e nt of Transportation. See Appendix F for details.

MW AQC Ozone SIP May 23, 2007 6-576.5 Voluntary Bundle

In Septem ber 2004, EPA issued its policy on “Inc orporating Em erging and Voluntary Measures in a State Im plem entation Plan (SIP).” 1 This policy establishes criteria for EPA to approve credit under a SIP for em ission reductions from voluntary and em erging m easures. This policy
perm its states to develop and im plem ent innovative program s that partner with local jurisdictions, businesses and private citizens to im plem ent em ission-reducing m e asures at the local level.

In August 2005, EPA issued a second guidance docum ent to facilitate innovative control

m easures. This docum ent was entitled “Guidance on Incorporating Bundled Measures in a State Im plem entation Plan.” 2 The guidance supports the developm ent of innovative m easures by describing how States can develop individual voluntary and em erging m easures and “bundle” them into a single SIP subm ission. The em issions reductions for each m easure in the bundle are quantified but it is the perform a nce of the entire bundle (the sum of the em ission reductions from all the m easures in the bundle) that is m easured by EPA for SIP com p liance purposes. The bundled m easures policy takes into account the fact that som e m easures m a y perform less effectively than projected by allowing the State to average these m easures with others that perform better than expected. Agencies m u st im plem ent each voluntary control m e asure, and
states m u st m onitor each m easure for effectiveness and report the findings to EPA. If the estim ated reductions are not achieved, states com m it to take corrective action by either m a king changes to the existing program or developing m o re effective control m easures.
This SIP proposes a set of m easures for the voluntary bundle that includes em ission reductions

m easures included in the bundle for the 1-hour ozone SIP and several new program s proposed herein. All of the voluntary m easures have been im plem ented after the 2002 SIP base year. The 1-hour ozone SIP bundle com m itm ents were m odifie d. Diesel retrofit and low-em ission vehicle purchases are no longer included in the bundle and are being used for weight of evidence or as Transportation Em ission Reduction Measures (TERMs). In addition, one of the program s included in the SIP voluntary bundle for the 1- hour ozone standard (Low-VOC Consum er Products in Virginia) has been adopted as a m a ndatory m easure and therefore, it is no longer included as part of the voluntary bundle.

The bundled m easures will reduce em issions daily through the ozone season in May through Septem ber. The m easures will be im plem ented by county, city and state agencies in consultation with the District of Colum b ia, the State of Maryland or the Com m onwealth of Virginia. The

em ission reductions credited in this plan are below EPA' s presum ptive lim its for voluntary initiatives.

Som e of the program s identified in the voluntary m easures package for Reasonable Further Progress (RFP) will be fully im plem ented by May 1, 2008 – the beginning of the 2008 ozone season – even though m o st reductions will occur by January 2008, the date on which the region will achieve rate of progress. Full im plem entation of all other m easures will begin in 2009.

1 See http://www.epa.gov/cleanenergy/stateandlocal/guidance.htm
2 Ibid

.

MW AQC Ozone SIP May 23, 2007 6-58Som e of the program s identified in the voluntary m easures package for Reasonable Further Progress (RFP) will be fully im plem ented by May 1, 2008 – the beginning of the 2008 ozone season – even though m o st reductions will occur by January 2008, the date on which the region will achieve rate of progress. Full im plem entation of all other m easures will begin in 2009.

This voluntary m easures package m a y be expanded in future SIPs as additional voluntary

m easures are developed and im plem ented. Many state agencies and local governm e nts are currently developing program s that could, in the future, qualify as voluntary m e asures.
This section contains descriptions of the voluntary m easures that are included in this SIP subm ission. A detailed estim ate of the benefits resulting from each m easure is contained in Appendix H. The inform ation below sum m a rizes the em ission reductions for the entire voluntary bundle. Individual m easures contai ned in the bundle are described on succeeding
pages.

Source Type Affected

This bundle reflects com m itm ents by owners, operators, purchasers or users of the following types of em issions-related item s /equipm ent in the Metropolitan W a shington area: com m e rcial power generation, portable fuel containers, m unici pal buildings, urban forest trees, locom o tives, solvents, and paints.

Implementation

Arlington County, Virginia Calvert County, Maryland City of Alexandria, Virginia City of Falls Church, Virginia City of Greenbelt, Maryland Fairf a x City, Virginia Fairfax County, Virginia Loudoun County, Virginia Maryland Departm e nt of Transportation Maryland National Capital Parks and Planning Com m i ssion Montgom ery County, Maryland Prince George’s County, Maryland Prince W illiam County, Virginia Virginia Departm e nt of Environm ental Quality W a shington Surburban Sanitary Com m i ssion, Maryland

Monitoring and Enforcement

The District of Colum b ia, the State of Maryla nd, and the Com m onwealth of Virginia com m it to

m onitoring, evaluation and reporting of the em issions effects of the program s com p rising the voluntary m easures. All governm e nts and agencies that have com m itted to im plem enting

MW AQC Ozone SIP May 23, 2007 6-59voluntary m easures have been inform ed of the m onitoring and evaluation requirem e nt and have agreed to provide m onitoring inform ation to the state air agencies.

The District of Colum b ia, Maryland, and Virginia will evaluate the em ission benefits from this voluntary m easures package through a “true-up” analysis to be conducted at least every three calendar years. As agreed in the 1-hour ozone SIP, the first true-up is scheduled for March 2007. The next true-up will be com p leted by June 2010, three years from the subm ittal of this SIP revision. Should the evaluation program determ ine that the m easures listed in this section have not delivered the estim ated reductions, the states com m it to rem e dy the resulting deficiency within one year if rulem a king is not required, or within two years if rulem a king is required. If the June 2010 true-up shows em issions benefits lower than expected, the states will rem e dy the deficiency by June 2011 if the rem e dy does not require rulem a king, or by June 2012 if rulem a king is required.

Projected Reductions

The District of Colum b ia, the State of Maryland, and the Com m onwealth of Virginia have used available m e thods to create their best estim ate of the em ission benefits created from the bundle of voluntary m easures. These estim ates have been agreed upon by the im plem enting agencies and are conservative in nature. The sum m a ry of the estim ates and the m e thodology follows below. More detailed inform ation about the m e thodologies is provided in Appendix H.

T a bl e 6- 8. Summary of Emi ssi on Reducti ons f o r Vol u nt ary Bundl e C o mmi t m ent s ( 2002- 2009)

Jur i sdi c t i on Emi ssi on Redu cti o n for 2008 ( t p d VOC) Emi ssi on Redu ction fo r 20 09 ( t p d VO C) Emi ssi on Redu ct i o n f o r 2008 ( t p d NO x) Emi ssi on Redu ction fo r 2009 ( t p d N O x) Regi onal W i nd Pow e r Purchase Progr a m 0 0 0

. 1 3 0

. 1 5 Ren e w a ble Po r t folio Standards 0 0

- - LED T r af f i c Si gnal Retr of i t s 0 0 0. 02 0. 02 V R E Idli n g R e du c t ion 0. 01 0. 01 0. 13 0. 13 Lo w - VO C Pai n t 0. 17 0. 17 0 0 G as Can R e pl ac eme n t 0. 01 0. 01 0 0

TO TA L 0. 19 0. 19 0. 28 0. 30

N o t e : I n c l u d e s cu mu la ti v e i m p a ct s o f c o mm it me nt s ma de i n t h e 1-ho ur an d 8-h our oz o n e SI P s

.

MW AQC Ozone SIP May 23, 2007 6-60Point Source Strategies

Renew a ble Energy and Energy Efficiency

The following energy efficiency and renewable energy m easures are included as innovative voluntary control m easures in the SIP.

• Renewable Energy Program s

- Regional W i nd Power Purchase Program

- Clean Energy Rewards Program

- Renewable Portfolio Standards

• Energy Efficiency Program s

- LED Traffic Signal Retrofit Program

- Building Energy Efficiency Program s

• Green Building Program s

Emission Reduction Calculatio ns and Projected Reductions

In recent years, substantial progress has been m a de in the developm ent of m e thodologies to quantify em ission reduction benefits from ener gy efficiency and renewable energy (EERE)

m easures. Several m e thods have been used to calculate the benefits resulting from the displacem ent of fossil fuel generation in the dispatch order. The m e thodology outlined below was developed by Resource System s Group, Inc. (RSG) in cooperation with Environm ental Resources Trust (ERT).

The State of Maryland relied on an initial version of the RSG/ERT m e thodology in its regional wind purchase subm ission as part of the bundle of voluntary m easures subm itted to EPA in its 1- hour ozone SIP. This SIP control m easure was subsequently cited with approval by the EPA in its August 2004 “Guidance on State Im plem entation Plan (SIP) Credits for Em ission Reductions from Electric-sector Energy Efficien cy and Renewable Energy Measures.” 3 EPA also approved the wind purchase as the first-ever renewable energy m easure to receive NOx em issions reduction credit in a State Im plem entation Plan. 4

Udated versions of the RSG m e thodology have been subsequently used in three separate projects to estim ate the displacem ent of em issions at fossil-fueled power plants resulting from EERE

m easures in New Jersey, Connecticut, and Virginia. Most of this work has been supported by the U.S. Departm e nt of Energy. 5 The New Jersey work was conducted in cooperation with the U.S. Environm ental Protection Agency a nd the National Renewable Energy Laboratory.

3 See http://www.epa.gov/cleanenergy/stateandlocal/guidance.htm
4 70 Fed. Reg. 24988 (May 12, 2005).
5 U.S Departm e nt of Energy, Final Report on the Clean Energy/Air Quality Integration Initiative for the MidAtlantic Region , August 2006. See http://www.eere.energy.gov/wip/clean_energy_initiative.htm l ; Resource System s Group, Estimation of Avoided Emission Rates for Nitroge n Oxide Resulting from Renewable Electric Power Generation in the New England, New York and PJ M Interconnection Power Market Areas, 2006, Prepared under grant funding from the U.S. Departm e nt of Energy and unde r subcontract to Environm ental Resources Trust and Connecticut Sm art Power; Resource System s Group, Avoided Emissions at Three Proposed Wind Power Projects in Virginia, 2006, Prepared under grant funding from the U.S. DOE’s Cl ean Energy/Air Quality Integration Initiative.

MW AQC Ozone SIP May 23, 2007 6-61Each state is including provisions in their NOx Ozone Season em issions trading program that will set aside a portion of the state’s ozone season NOx allowance budget to support renewable energy and energy ef f i ciency projects. Each state will assure that NOx allowances are retired in

an am ount com m e nsurate with the size of the six EERE m easures cited below to ensure surplus

em ission reductions.

The SIP m easures will be structured to take into account the differences in the NOx em issions trading regulations of Maryland, the District of Colum b ia, and Virginia. Maryland’s NOx SIP Call regulations authorize the allocation of NOx allowances to support EERE projects and purchases but the NOx SIP Call regulations for th e District of Colum b ia and Virginia do not provide such authority. Thus, em ission reducti ons f r om EERE projects will not be claim e d f o r Virginia governm e nt entities in 2007 and 2008.

However, in 2009, NOx em issions trading for electric generating units in all three states will be governed by the Clean Air Interstate Rule (CAIR), and all three governm e nts are including provisions in their CAIR setting aside a portion of allowances in their sum m e r ozone season trading budget to support EERE projects and purchases. The Virginia Air Pollution Control Board approved the VA CAIR on Decem ber 6, 2006, and Maryland and the District of Colum b ia plan to adopt their regulations to im plem ent CAIR in 2007. As a result, surplus em ission reductions from all three jurisdictions can be claim e d for 2009.

Table 6-9. Summary of Benefits EERE Programs

Measure Daily kWh Generation /Savings 2009 NOx Emission Reduction (tpd) Renewable Energy Program s Regional W i nd Power Purchase Program 123,000,000 0.15 Clean Energy Rewards Program up to 31,900,000 - Renewable Portfolio Standard (RPS) 22,500,000 - Energy Efficiency Program s LED Traffic Signal Retrofit Program 26,905,556 0.02 Building Energy Efficiency Program s ~15,000,000 - Green Building Program s - - T O T A L

~ 1 5 0

, 0 0 0

, 0 0 0 0

. 1 7 Note: Total does not include the Clean Energy Rewards, RPS, or the Building Energy Efficiency Program s.

MW AQC Ozone SIP May 23, 2007 6-62Regional Wind Pow er Purchase Program

Under this m easure, local and State governm e nt entities in the nonattainm e nt area have

com m itted to purchase a specific num ber of kilowatt-hours (kW h ) of power during the sum m e r ozone season from wind turbines. The governm e nt agencies will purchase the wind energy directly from an electricity supplier or purchase renewable energy certificates (RECs) 6 that assure that such wind energy is placed on the el ectric grid. This zero-em ission wind power will displace em issions from fossil-fueled power pl ants that would norm a lly supply power to the Metropolitan W a shington region. The air agencies in Maryland, the District of Colum b ia, and Virginia will retire NOx allowances in an am ount com m e nsurate with the am ount of em issions displaced.

Source Type Affected

The m easure affects certain local and State governm e nt entities within the Metropolitan W a shington nonattainm e nt area. The region is im plem enting this m easure to reduce electric power generation from coal, oil, and/or gas-fi red sources, thereby reducing NOx em issions from these sources.

Control Strategy

This m easure is envisioned as a region-wide m easure encom p assing purchases of wind power or wind energy RECs by state and local governm e nt entities within the Metropolitan W a shington nonattainm e nt area.

This program was initiated on a pilot basis in the 1-hour ozone SIP and has been expanded here. To m eet the existing com m itm ents from the 1-hour ozone SIP, local governm e nts signed m u ltiyear com m itm ents with wind power suppliers to assure that a f i xed quantity of wind energy would be placed on the electric grid in upwind or continguous States. These purchases have displaced fossil fuel generated power, thus reducing the NOx em itted from those plants.

Implementation

Arlington County, Virginia Fairfax County, Virginia Prince W illiam County, Virginia Montgom ery County, Maryland Mem b ers of the Montgom ery County buying group (see list below) Prince George' s County W a shington Suburban Sanitary Com m i ssion (W SSC) District of Colum b ia

6 Renewable energy certificates represent the unique a nd exclusive proof that 1 Megawatt-hour of energy was generated from a renewable energy source and placed on the electric grid.

MW AQC Ozone SIP May 23, 2007 6-63In Fiscal Years (FY) 2005 and 2006, a buying group led by Montgom ery County, Maryland purchased 40,845,139 kilowatt-hours (kW h ) of wind energy RECs per fiscal year. The purchase represented 5% of the total annual electricity consum ption of each purchasing group participant. Montgom ery County executed a contract am endm ent on Septem ber 18, 2006 to purchase additional kW hs of clean, renewable energy in com p liance with SIP requirem e nts (RECs for energy were generated at the Mountaineer W i nd Energy Center in W e st Virginia) for FY07 and FY08 (July 1, 2006 to June 30, 2008). In the new contract, the County, and m a ny other m e m b ers of the buying group opted to increase their wind energy purchase to 10% of their total annual electricity consum ption, for a total of 51,809,091 kW h of clean energy purchased by the group in FY07, and 57,481,122 kW h in FY08. Credit for 28,000,000 kW H per year was taken in the onehour ozone SIP, leaving 23,809,091 kW h in FY07 and 29,481,122 kW h in FY08 available for credit in the 8-hour SIP. The purchase will cover the period from July 1, 2006 to June 30, 2008

The f o llowing other counties, cities, and state agencies will participate in the Montgom ery County buying group:

Montgom ery County Public Schools (MCPS) Montgom ery County Governm e nt Maryland National Capital Park and Planning Com m i ssions (M-NCPPC) Montgom ery College Housing Opportunities Com m i ssion (HOC) City of Rockville Gaithersburg Takom a Park College Park Rockville Housing Enterprise Town of Kensington Chevy Chase Village Som e rset Glenn Echo Chevy Chase Sect. 5 Town of Laytonsville

In addition, the Virginia Energy Purchasing Gove rnm e ntal Association (VEPGA) issued an RFP in March 2007 to select a supplier of wind energy RECs in the am ount of at least 11,230,000 kW h/year. The RFP will cover the period April 2007 to March 2010. The following counties, cities, and state agencies will participate in this buying group: Fairfax County, Arlington County, and Prince W illiam County.

The District of Colum b ia plans to purchas e 16,500 kW h/year from wind energy or wind energy RECs. There is the possibility that this purchase can be used by utilities to m eet RPS requirem e nts so is not analyzed further here.

All three RFPs will include:

MW AQC Ozone SIP May 23, 2007 6-64• A reporting requirem e nt indicating the actual am ount of wind energy in kW h purchased during the ozone season and per year. In addition, the request for proposal issued for the Virginia m unicipalities will contain a requirem e nt that the purchase of wind energy RECs be m a de from wind plants in the PJM Interconnection grid in one or m o re of the following States: Maryland, Virginia, Pennsylvania, W e st Virginia, or Ohio. Based on EPA’s analysis of ozone transport data set forth in the pream ble to the EPA’s CAIR (70 Fed. Reg. 25249-50), these five States are considered upwind of one or m o re counties in the DC-MD-VA nonattainm e nt area. The RFPs for the MD jurisdictions will require that the purchase of wind energy RECs be m a de from wind plants in States contiguous to Maryland.

• A reporting requirem e nt indicating actual am ount of wind energy in kW h purchased during the ozone season and per year.

Monitoring and Enforcement

Each State will provide evidence that it has assu red the retirem ent of the designated am ount of NOx allowances from future use under a NOx em issions trading program . In addition, all jurisdictions and agencies participating in the regional wind power purchase program have

com m itted to m a intain copies of signed contracts and energy bills to verify the am ount of wind energy or wind energy RECs purchased. They also will purchase wind energy or wind energy RECs from a certified supplier who can provide independent certification that the wind energy purchased is placed on the electric grid. This evidence will help to validate the em ission reduction credit included in the SIP.

Projected Reductions

The renewable energy purchase program is expected to involve purchase 104,000 MW h of power or wind energy RECs annually, reduci ng 0.15 tpd NOx during the 2009 ozone season. Further inform ation on the projected reductions is included in Appendix H.

T a ble 6-10. Wi nd P u rchase C o mm it men t s f o r the 8

- ho ur Ozone SIP Voluntary Bu ndle (all i n kWh/y ear)

Jurisdi c t i on 1-ho ur Ozone SIP C o mmi tment for 20 05 8- h our Ozone SIP Commi tment for 2008 8-hou r O z o n e SI P Co m m i t m e nt f o r 200 9 2005 Emi s si on R e duc t i on C redi t ed i n 1- hour O z on e S I P

( t pd NOx) 2008 E m i ssion A

v o i de d (tpd NOx) 2009 Emi ssion A

v oi d e d ( t pd NOx)
M o n t g o mery C ounty
, M D Purchasi n g Group (ex i st i n g ) 2 8

, 0 0 0

, 000 28,000,000 28

, 000,000 M o n t g o mery C ounty
, M D Purchasi n g Group (new ) 14,740,561 P r i n ce G eorg e 's Coun t y , M D 8, 42 3, 095 8

, 423,095 W a shin g t on Subu r ban Sa nitary C o mm i ssion (W SS C) 70, 00 0, 000 70

, 000,000 A r l i n g t on Cou n t y , V A 2, 34 0, 000 4, 70 0, 000 4

, 700,000 F a irf a x C ount y , VA 5, 80 0, 000 11

, 600,000 P r i n ce W i l l i a m C ounty
, VA 75 0, 000 750,000 To ta l 1 04, 41 3, 65 6 123

, 473,095 0.05 0. 1 3 0. 15
Notes : All em iss i on re duc t i ons a r e f o r ozone s eas on on ly and a r e es t i m a t e d usin g t h e em iss i ons ca lcula t o r in App end ix H

. M o n t go m e ry Coun t y FY 2008 n e w co m m i t m en t s only t h r ough J u n e 3 0

, 2 008

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MW AQC Ozone SIP May 23, 2007 6-65Clean Energy Rew a rds Program

Under this m easure, Montgom ery County Governm e nt will provide rewards (incentives) to residents, sm all businesses, and com m unity organizations purchasing clean energy products certified by the Departm e nt of Environm ental Protection (DEP). The authority for this program is granted in the Montgom ery County Code Section 18A-11, as am ended, and Executive Regulation No. 2-06AM. Based on the program ’s funding of $361,000 for FY 2007, Montgom ery County has estim ated that its Clean Energy Rewards Program will provide incentives for 31,900 MW h of clean energy.

Source Type Affected

The m easure affects Montgom ery County residents, sm all businesses, congregations, and nonprofits, and is supported by Montgom ery County Governm e nt, within the Metropolitan W a shington nonattainm e nt area. Montgom ery County is im plem enting this m easure to reduce

consum ption of electric power generated from co al, oil, and/or natural gas fired sources by

consum ers, thereby reducing NOx em issions from these sources.

Control Strategy

Clean Energy Rewards is a unique program de veloped by Montgom ery County to encourage

consum ers to switch to clean energy. Consum ers m u st purchase at least 50 percent of their annual energy consum ption from a clean energy product certified by the Departm e nt of Environm ental Protection (DEP) to be eligible for rewards.

Under the program , eligible clean energy products m u st be generated within the PJM Regional Transm ission Organization (RTO) from solar, wi nd, and/or Tier 1 biom ass as defined by the Maryland Code, Public Utility Com p any Article, 7-703 (Maryland’s RPS). However, current products for FY 2007 are lim ited to energy generated from wind and solar sources, and Montgom ery County believes that the m ajority of certified clean energy products will be windbased in 2007.

Participating suppliers m u st provide docum entation to DEP’s Director verifying that all products

m a rketed through Clean Energy Rewards m eet the program ’s criteria. These steps ensure the clean energy is generated within the PJM region and is not used to m eet the requirem e nts of the Maryland Renewable Energy Portfolio Standard or is otherwise double counted. Only purchases of

wind energy or solar will be reported f o r purposes of the SIP.

MW AQC Ozone SIP May 23, 2007 6-66Implementation

Montgomery County Government. The Departm e nt of Environm ental Protection solicited support from several energy suppliers and REC m a rketers for this program . Potential suppliers are required to subm it product inform ation labels or other generation data about each product to be m a rketed through the program , and sign a Mem o randum of Understanding with the County agreeing to deliver the rewards to consum ers either as a credit on their bill, or as a product discount. Montgom ery County residents will receive 1 cent/kW h up to 20,000 kW h per year. Non-residential end-users (sm a ll business, congregations, and non-profits) will receive 1.5 cents/kW h up to 100,000 kW h per year.

DEP is the m a in m a rketing arm of the Clean Energy Rewards Program . However, program suppliers also are encouraged to m a rket the product and the program to Montgom ery County

consum ers with DEP guidance to insure consistency. DEP has developed a web site and educational m a terials to inform consum ers about the program and the benefits of clean energy. The County is running an advertising cam paign in Montgom ery County Metro stations and in the Montgomery County Extra section of The Washington Post ; and is m eeting with and prom oting the program through com m unity organizations and other Montgom ery County support structures. DEP anticipates that these m a rketing m easures will reach thousands of Montgom ery County electric consum ers.

Consum ers can sign-up for clean energy products through DEP’s web site starting Novem b er 15, 2006, and will begin receiving the products and accruing rewards starting January 1, 2007.

Monitoring and Enforcement

DEP is requiring suppliers to subm it reports identifying the consum ers participating in the Clean Energy Rewards Program , the am ount of eligible clean energy consum ed through the program by resource type, and additional product verification data. Custom er lists and energy

consum ption will be subm itted to DEP on a quarterly basis. This inf o rm ation will be used to determ ine the funds to reim burse energy suppliers for rewards paid.

By March of 2008 and each following year, DEP will receive reports from energy suppliers verifying the energy reserved for the program and the generation sources. Participating suppliers

m u st provide docum entation to DEP’s Director verifying that all products m a rketed through Clean Energy Rewards m eet the program ’s criteria. Additionally, suppliers are required to reserve electricity in an account under the PJM Generation Attribute Tracking System (GATS) using the identifier “(ENV)” and designate it as “Montgom ery County Clean Energy Rewards.” Once electricity is reserved in this account, it cannot be used to m eet RPS requirem e nts or otherwise sold. These steps ensure that the clean energy is generated within the regional airshed and is not used to m eet the RPS requirem e nts or is otherwise double counted. The details of these subm issions will allow Montgom ery County to verify the am ount of zero-em ission NOx clean energy generated within Maryland and adjacent states on an annual basis.

Since this is a new program , it is im possible to estim ate with certainty the exact volum e of clean energy that will be purchased by Montgom ery County consum ers. However, given the funding

MW AQC Ozone SIP May 23, 2007 6-67appropriated, the County Council’s support, and the Clean Energy Products Certified in FY2007 this program is likely to be well subscribed. Moreover, under the EERE set-aside in the Maryland NOx em ission trading regulations, in the f u ture NOx allowances also will be retired

com m e nsurate with the am ount of avoided em issions.

MW AQC Ozone SIP May 23, 2007 6-68Renew a ble Portfolio Standards

This m easure will f o cus on NOx em ission reductions resulting f r om the displacem e nt of power generation from coal, oil, and/or gas-fired s ources by zero-em ission renewable energy sources. The District of Colum b ia Departm e nt of the Environm ent will retire NOx allowances in an

am ount com m e nsurate with the am ount of em issions displaced.

Source Type Affected

The m easure af f

ects the District of Colum b ia within the Metropolitan W a shington nonattainm e nt area. According to the DC Renewable Energy Portfolio Standard (RPS) Act of 2004, a m a jor purpose of the Act is to “ensure that the benefits of electricity from renewable energy sources, including long-term reduced em issions...accrue to the public at large.”

Control Strategy

Under the DC RPS Act, retail electricity suppliers are required to m eet their regulatory requirem e nts by supplying renewable energy that is located: (A) in the PJM Interconnection region or in a state that is adjacent to the PJM Interconnection region; or (B) outside the area described in (A) but in a control area that is adjacent to the PJM Interconnection region, if the electricity is delivered into the PJM Interconnection region.

The increased supply of renewable energy will displace fossil fuel generated power in the PJM Interconnection area, thus reducing the NOx em itted f r om these plants.

The District of Colum b ia plans to include pr ovisions in its NOx Ozone Season Trading Program under the Clean Air Interstate Rule setting aside a portion of the District’s total NOx allowance budget to support renewable energy and energy efficien cy projects. The District will assure that NOx allowances will be retired in an am ount com m e nsurate with the NOx em issions reduced as a result of the tier one zero-em ission renewable energy purchases. This retirem ent of allowances will ensure that surplus em ission reductions will be provided. Since the CAIR program f

o r electric generating units is not effective until 2009, credit for NOx em ission reductions will not be claim e d until 2009.

Implementation

District of Columbia. Under the DC RPS Act, retail electricity suppliers serving custom ers in the District of Colum b ia are required to provi de 2.5% of their supply from tier one renewable energy sources in 2009. In addition, retail electric suppliers are required to provide 0.019% from solar energy or solar REC purchases. This renewable energy percentage increases each year toa level of 11% in 2022 and later. Tier 1 renewable sources are defined to include: (1) zeroem ission renewable energy sources, including solar energy, wind energy, geotherm al energy, and ocean energy; and (2) low-em ission renewable energy, including qualifying biom ass, qualified m e thane from anaerobic decom position, and fuel cells.

MW AQC Ozone SIP May 23, 2007 6-69Monitoring and Enforcement

The District of Colum b ia will provide evidence that it has assured the retirem ent of the designated am ount of NOx allowances from future use under its renewable energy set-aside. In addition, the District of Colum b ia Departm e nt of the Environm ent has com m itted to obtain inform ation from the DC Public Service Com m i ssion confirm i ng that electricity suppliers have

m a de purchases of renewable energy consistent with the com m itm ents incorporated in this control m easure.

Calculation of Emission Reduction Benefits

The calculation of NOx em ission reductions for 2009 involves the following steps:

(1) Estim ate total retail sales of electricity in DC for the sum m e r ozone season in 2009; (2) Estim ate the am ount of Megawatt-hours supplied from zero-em ission Tier 1 renewable resources in the sum m e r ozone season for 2009 (based on the requirem e nts of the DC RPS Act and estim ates by the DC Departm e nt of the Environm ent); (3) Calculate avoided NOx em issions in lbs/MW h during the sum m e r ozone season based on an estim ate of actual avoided NOx em issions and the calculation of NOx allowances retired; and (4) Calculate avoided NOx em issions in tons/day during the sum m e r ozone season.

The total annual consum ption of electricity in the District of Colum b ia is 12,354,981.11 MW h. In estim ating the portion of the Tier 1 renewable energy purchases com p rised of wind energy or associated RECs, MW COG relied on the expertise of one of the Com m i ssioners of the DC Public Service Com m i ssion (PSC). Since the DC RPS has not yet been operational, the PSC Com m i ssioner suggested that DC review the expe rience of another Mid-Atlantic State with a sim ilar Tier 1 category in its RPS – one that included both landfill gas and wind energy. New Jersey f it that category, and the NJ Board of Public Utilities provided inf o rm ation indicating the following allocation of purchases am ong landfill gas, wind and solar in its Tier 1 category during the m o st recent year: (1) 92.27% landfill gas; (2) 6.48% wind energy; and (3) 1.2% solar.

Based on this NJ estim ate and the different treatm e nt of solar in the DC RPS, we have extrapolated to the DC RPS and calculated that wind energy will represent an estim ated 6.56% of the Tier 1 requirem e nt in 2009. Solar energy m u st provide 0.019% of total electricity

consum ption. Electricity generated from landfill gas is not considered in the analysis. The

em issions calculator described in Appendix H was used to estim ate the avoided NOx em issions.

The District of Colum b ia is claim i ng zero credit from this m e asure.

MW AQC Ozone SIP May 23, 2007 6-70Table 6-11 Projected Annual Generation and Avoided Emissions from the DC RPS Tier 1 Sources

DC RPS Tier 1 Category MWh Annual Generation NOx Emissions Avoided (tpd) W i n d 2 0

, 2 6 2 0

. 0 2 5 Solar PV 2,347 0.007

MW AQC Ozone SIP May 23, 2007 6-71Green Building Programs Under this program , local governm e nts in the nonattainm e nt area have com m itted to reducing energy dem a nd associated with operation of existing and new buildings by im plem enting Green Building Program s. Depending on the energy effi ciency and renewable energy com ponents of these program s, they will decrease dem a nd for electricity and displace power generation from coal, oil, and/or gas-fired sources that would norm a lly supply power to the Metropolitan W a shington region, thereby reducing NOx em issions from those sources.

Source Type Affected The m easure affects state and local governm e nts within the Metropolitan W a shington nonattainm e nt area.

Control Strategy This m easure is envisioned as a region-wide m easure encom p assing green building program s by state and local governm e nts within the Metropolitan W a shington nonattainm e nt area. These
program s are in the early stages of developm ent and affect several local jurisdictions in the nonattainm e nt area. Local governm e nts have begun to im plem ent a variety of Green Building Program s that m a y reduce dem a nd f o r electricity. The reduction in energy dem a nd will displace f

o ssil f u el generated power, thus reducing the NOx em itted f r om those plants.

Green Building Program s can include a num ber of initiatives such as certification under the Leadership in Environm ental and Energy Design (LEED) Program , labeling under the ENERGY STAR® program , Green Globes rating, and green build ing codes. In order to provide air quality benefits, any program m u st include as a key com ponent a requirem e nt that retrofitted or new buildings achieve a reduction in energy dem a nd com p ared to an established baseline.

Each state in the nonattainm e nt area is including provisions in its NOx Ozone Season em issions trading regulations that set aside a percentage of the state’s total NOx allowance budget to support energy efficiency and renewable energy (EERE) projects.

Implementation This section identif ies the current status of Green Building Program s listed f o r the SIP, exam ines what uses or adaptations of m a jor green building rating system s could be m a de to quantify

em issions effects in a SIP context, and sum m a rizes m a jor green buildings efforts to date within the nonattainm e nt area.

Current Status of Green Building Programs for the SIP The following table lists the initial survey responses for Green Building program s in the nonattainm e nt area that the jurisdictions indicated they would like to include as voluntary

m easures, for SIP purposes. None of the jurisdictions intend to quantify the listed Green Buildings program elem ents for 2009 em ission reductions for the 8-hour Ozone SIP.

MW AQC Ozone SIP May 23, 2007 6-72Table 6-12. Summary of Voluntary Measures Initial Survey Responses Regarding Green Building Programs (2002-2009)

J u r i s d i c t i o n P r o g r a m E l e m e n t Fairfax County LEED goal for recreation center Arlington County LEED scorecard for projects; developer incentives Montgom ery County Green Building ordinance District of Colum b ia Planning for LEED requirem e nts for all govt buildings City of Alexandria LEED silver goal for all govt buildings City of Alexandria Require plan for voluntary LEED for private sector City of Greenbelt LEED silver for public works building

Additional green building activities of the local governm e nts in the nonattainm e nt area are f u rther described in the section below on “Green Building Activities in the Nonattainm e nt Area.”

For these green building program s to produce quantifiable electric load and em ission reduction results, m o re specific program requirem e nts will be necessary. Green building program rating system s are a good fram ework for discussing how these specific program requirem e nts could be designed.

Green Building Program Rating Systems Popular green building program rating syst em s are LEED certification, ENERGY STAR® Building label, and Green Globes.

LEED. LEED® is a nationally accepted benchm ark for the design, construction, and operation of high perform a nce green buildings established by the U.S. Green Building Council (USGBC). LEED prom otes a whole-building approach to su stainability by recognizing perform a nce in five key areas of hum an and environm ental health: sustainable site developm ent, water savings, energy efficiency, m a terials selection, and indoor environm ental quality. Specific LEED
program s include:

• New Com m e rcial Construction and Major Renovation projects (known as LEED-NC and is the m o st widely applied)

• Existing Building Operations and Maintenance (known as LEED-EB)

• Com m e rcial Interiors projects

• Core and Shell Developm ent projects

• Hom e s (pilot program )

• Neighborhood Developm ent (pre-pilot program )

• Guidelines for Multiple and On-Cam pus Building Projects; Schools; Retail for New Construction and Com m e rcial Interiors; Healthcare; and Laboratories.

To earn LEED certification, a building project m u st m eet certain prerequisites and perform a nce benchm arks or "credits" within each category. Projects are awarded Certified, Silver, Gold, or Platinum certification depending on the num ber of credits they achieve.

As the docum entation required for LEED certification is substantial, it is com m on for organizations to require “LEED-equivalent” building perform a nce levels to avoid the

MW AQC Ozone SIP May 23, 2007 6-73adm i nistrative cost of certification. However, without the certification docum entation, perform a nce can be difficult to verify.

LEED-NC has 14 out of a total of 69 credits that im pact building energy and corresponding power generation em issions. Several buildings have successfully certified for LEED Silver without earning any of those building energy cred its. Therefore, it is im portant to design MW COG Green Buildings program s to require a reduction in energy consum ption in addition to the LEED certification level.

Also, LEED-NC energy perform a nce is based on the sim u lated design of the building, which once constructed and occupied m a y or m a y not operationally achieve the certified energy perform a nce levels as predicted. The building design sim u lation is typically conducted on an hourly calculation basis, and these calculation m odels and results could be used to derive ozone season energy savings. The intention of the USGBC is that building projects certified under the LEED-NC rating system subsequently re-certify under LEED-EB with actual building energy perform a nce data.

ENERGY STAR®

. ENERGY STAR® Label for Buildings is provided by the U. S. Environm ental Protection Agency (EPA) to benchm ark the energy perform a nce of com m e rcial buildings. A building with perform a nce scored am ong the nation' s top 25 percent – equal to an energy perform a nce score of 75 or greater on a 1 to 100 scale – and that m a intains a healthy and productive indoor environm ent can qualify as an ENERGY STAR® building. The score accounts for the m o st significant drivers of energy intensity such as weather (based on location inform ation) and building characteristics (such as size). Currently there are twelve eligible building space types. The score is based on annual energy intensity, norm a lized in units of kBtu/f t2-yr, and 12-m onths of operation with energy utility bills are required. The Statem ent of Energy Perform a nce autom a tically includes a calculation of power generation CO 2 em issions (as determ ined by the EPA) based on the annual site energy use in that location.

The LEED-EB rating system awards energy perform a nce credits based on the ENERGY STAR® rating score.

As achieving the ENERGY STAR® building label m a y require im provem e nts to the building to reduce annual energy usage (and increase the score), the corresponding power generation

em ission reductions could be quantified and c ounted. The ENERGY STAR® rating tool already
autom a tically calculates annual CO 2 em issions reductions corresponding to the energy

consum ption reduction. However, m o re detailed inform ation would have to be recorded to account for the seasonal, daily or hourly em ission reductions occurring during the nonattainm e nt period.

Green Globes. Another green building rating program has been developed by the Green Building InitiativeTM and is known as The Green GlobesTM environm ental assessm ent and rating system . Green Globes is questionnaire-driven for new building construction projects. At each stage of the design process, users go through a sequence of questions that provide guidance for integrating im portant elem ents of sustainability. The construction docum ents questionnaire is the basis for the rating and seven areas are addressed: Project Managem e nt – Policies and

MW AQC Ozone SIP May 23, 2007 6-74Practices; Site; Energy; W a ter; Resources, Building Materials and Solid W a ste; Em issions and Effluents; and Indoor Environm ent. The bu ilding energy points are awarded based on the ENERGY STAR® rating score as determ ined by th e Target Finder tool. The em issions points address fossil-fuel heating equipm ent and operation. Once an assessm ent is verified by a third party, building properties achieving a score of 35% or m o re receive a Green Globes rating (one to four globes) based on the percentage of total points (up to 1000) achieved.

Green Building Activities in the Nonattainment Area This section identifies green buildings activities in the jurisdictions, LEED-certified buildings in the nonattainm e nt area, and discusses Federal green buildings.

Jurisdiction Activities. Many of the jurisdictions are undertaking green buildings activities. These have not been included in this SIP subm ission. NREL com p iled this inform ation from the Internet and personal com m unications.

Metropolitan Washington Council of Governments (COG). In June 2006, COG Board Chair Jay Fisette announced a goal of prom oting Green Building policies and practices in the W a shington region. This effort supports the COG Board' s focus on growth and developm ent, and provides environm ental and energy friendly m e thods for supporting sustainable developm ent in the region, consistent with COG' s Strategic Ener gy Plan. On Septem ber 29th, COG' s "Regional Leadership Conference on Green Building" was held with over 300 attendees from the public and private sectors. The conference focused on a review of local and national Green Building best m a nagem e nt practices, policies, regulations and legislation. In addition, several COG

m e m b ers have adopted or will soon adopt legisl ation encouraging or requiring Green Building practices for governm e nt and/or private sector construction. The COG Board adopted resolution R55-06 at the Novem b er 8, 2006 COG Board Meeting, which supports the developm ent of regional Green Building policies and best practice guidelines, establishes a special ad hoc elected official advisory com m ittee, and adopt s the existing Intergovernm e ntal Green Building Group (IGBG) as a COG technical com m ittee.

The 2006 Regional Energy Strategic Plan - “Power ed by Energy Efficiency – Fueled by Energy Conservation," outlines an energy vision and m i ssion for the National Capital Region and expands existing regional energy and environm ental goals. The Energy Strategic Plan also identif ies potential initiatives to address the region’s diversity of energy sources, help m a nage energy dem a nd, m itigate the effects of energy disruption and enhance overall environm ental quality. Developm ent of the Plan was identified by the COG Board of Directors as a 2006 priority. In addition, the Plan is consistent with and com p lem e nts the proposed Green Building Program . The Plan was subm itted to m e m b er governm e nts in June 2006 for a 90-day com m e nt period. The COG Board approved the revised vers ion of the Energy Strategic Plan by adopting resolution R56-06 at the COG Board Meeting on Novem b er 8, 2006.

Washington, D.C. In Decem ber 2006, the District of Colum b ia Council enacted green building legislation applicable to private developm ent. The legislation, which is expected to be approved by the U.S. Congress, would m a ke W a shington the first m a jor city to require private developers to adhere to the standards of the USGBC. Even before the legislation, that jurisdiction was already on track to open the nation's first LEED-certified stadium

.

MW AQC Ozone SIP May 23, 2007 6-75The bill requires all com m e rcial developm ent of 50,000 square feet or m o re to m eet the building council' s standards starting in 2012. The requirem e nt applies to both new construction and significant renovations of old buildings.

All city-owned com m e rcial projects funded in 2008 or later would have to attain certification, and District of Colum b ia-funded housing proj ects would be required to follow sim ilar environm ental standards. The bill also orders the m a yor to adopt separate standards for schools, which the USGBC is now developing.

Montgomery County. On Novem b er 28, 2006, the Montgom ery County Council unanim ously enacted “Green Building” requirem e nts for future public and private construction in Montgom ery County -- the strongest “Green Building” requirem e nts in the region.

The legislation requires that County-built or funded non-residential buildings achieve a LEED Silver rating and requires private non-residential or m u lti-f a m ily residential buildings to achieve a LEED Certified rating.

Buildings covered by the law include any newly constructed or extensively m odified nonresidential or m u lti-fam ily residential building with at least 10,000 square feet of gross floor area. The law would take effect for private buildings one year after the County im plem enting regulations are finalized, but not later than Septem ber 1, 2008. Follow up regulations will address m a ny of the details on the rating system (LEED NC, EB), and such regulations are expected to be developed by July 2007.

The current legislation does not have a define d m a ndatory energy-efficiency com ponent beyond the prerequisites of the LEED rating system . The Montgom ery County energy code is IECC 2003 (IECC 2006 is expected to be adopted in the spring of 2007) which is m o re aggressive than

m o st of the neighboring jurisdictions.

Arlington County. Arlington County’s green building program is a leading m unicipal program in the region and has been developed in the context of the County’s com m itm ent to sm art growth and com m unity sustainability. County policy encourages all large com m e rcial and m u lti-fam ily residential projects to incorporate LEED com ponent s of 25 or m o re credits on a voluntary basis. Arlington’s Green Building Incentive Program allows developers to apply for bonus density in exchange for official LEED certification. Proj ects m a y apply for a bonus density of 0.15 to 0.35 additional floor-to-area ratio (FAR). Developers who choose to participate in the density bonus and com m it to LEED certification post a bond that is released when the building is certified. Site plan projects that do not receive official LEED certification from the USGBC are asked to contribute $0.03 per square foot to the County’s Green Building Fund. This m oney is used to fund green building education and workshops.

A few buildings have gone through the County’s green building incentive program , including the new Navy League building, the National Rural Electric Cooperative Association building, and a private m u ltifam ily building currently under construction. Exam ples of the County’s own green buildings include Langston Brown School and the W a lter Reed Com m unity Center.

MW AQC Ozone SIP May 23, 2007 6-76Fairfax County. Fairfax County is expanding activities in support of environm entally sustainable developm ent, which include incorporating m o re sustainable building practices. The County has focused its green building efforts in two areas: the greening of public buildings, and policy for private developm ent. Of 20 m unicipal buildings recently built in the County, 18 have LEED elem ents, with m a ny m oving toward certification. The County is in the process of reviewing the Com p rehensive Plan, its key guidance docum ent, and is developing broad language supporting green building.

City of Alexandria. The City of Alexandria initiated a green building policy f our years ago and adopted a LEED standard for all public buildi ngs in 2003-4. Project staff review the LEED checklist to determ ine actions within their existing budgets, and then m a ke the decision whether to fully certify. They currently target a 3.5 percent prem ium for projects in order to m eet the LEED silver standard. One percent is reserved for green construction costs. Alexandria also enacted legislation in July 2006 to allow a design-build process for projects. Green building will be integrated into that process.

LEED Certified and Registered Buildings. At least 46 building projects in the nonattainm e nt area jurisdictions are registered for LEED, and one LEED certified building is currently listed on the USGBC website:

Langston-Brown High School Continuation & Com m unity Center LEED® Project # 0172 LEED Version 2 Certification Level: SILVER Septem ber 3, 2003 Arlington Public Schools, Arlington County Arlington, VA http://www.usgbc.org/ShowFile.aspx? Docum e ntID=425 This project was awarded 1 credit for 15% reduction in the energy cost budget.

ENERGY STAR® Buildings Label. There are over 300 ENERGY STAR® labeled buildings in Maryland, Virginia and W a shington, D.C., but none are owned by the MW COG governm e nt organizations. Many of the jurisdictions have signed-up as ENERGY STAR® Partners

com m itted to im proving their energy efficiency. These local governm e nt partners currently include:

Alexandria Public Schools Arlington County Com m onwealth of Virginia Fairfax County Governm e nt Fairfax County Public Schools (Special Recognition in 2004) Loudon County Public Schools Prince W illiam County City of W a shington, DC (and DC Energy Office) W a shington DC Public Schools Charles County Public Schools

MW AQC Ozone SIP May 23, 2007 6-77City of Takom a Park Montgom ery County

Federal Green Buildings. Legislation and federal m a ndates provide an exam ple of setting guidelines for sustainable buildings generally and energy efficiency specifically. The Energy Policy Act of 2005 and Executive Order 13423 of January 2007 require all new federal buildings to achieve a 30 percent im provem e nt in energy cost to ASHRAE Standard 90.1-2004. This ASHRAE Standard is the sam e baseline applied in LEED-NC version 2.2. The Executive Order also requires federal agencies to follow the guidelines of the Mem o randum of Understanding for Federal Leadership in High Perform a nce and Sustainable Buildings. Federal agencies are also required to m eet progressive energy use intensity reduction targets for their entire building stock. These goals are stated in term s of reduced energy consum ption. There are a num ber federal buildings located in the MW COG region with case study inform ation available.

Monitoring and Enforcement All jurisdictions and agencies claim i ng em issions reductions f r om green buildings program s will

com m it to m a intain records of the projects undertaken to verify the reduction in electricity dem a nd. The factors that m u st be recorded include the baseline and proposed design or operationally achieved annual energy usage values by fuel type. The corresponding energy savings values have to be further tracked on an hourly or seasonal basis to correspond to the nonattainm e nt period.

Projected Reductions and Emissions Benefit Calculations Annual electricity consum ption reductions can be calculated from reporting the LEED Energy Perform a nce, On-Site Renewable Energy, and Green Power certified credits and the baseline and proposed/achieved building energy usage num bers by fuel type. LEED certification energy perform a nce values are reported on an annual cost basis, although an hourly sim u lation program is usually utilized for building energy m odeling. W ith additional guidance, seasonal or daily

num bers could be available from the process.

Co-benefits of Green Building program s include reduction in energy dem a nd and associated

em issions from building heating appliance fuels; reducing the heat island effect (with vegetative shading and high-albedo m a terials); reduction in VOCs associated with built environm ent treatm e nts (adhesives and sealants, paints and coatings, carpet, and com posite wood); and reduction in transportation em issions (by encouraging the use of m a ss transit and alternative fuel vehicles).

Because of the uncertainty surrounding the am ount of creditable reductions available from this
program , Maryland and Virginia are claim i ng zero credit from this m easure.

MW AQC Ozone SIP May 23, 2007 6-78Building Energy Efficiency Programs

Energy Efficiency Programs Under this program , the local governm e nts in the nonattainm e nt area have undertaken m easures to im prove the energy perform a nce of governm e nt facilities. This section describes the estim ation of the electricity reductions (m easured in kilowatt-hours, kW h) achieved by those

m easures. An overview is given here, and the details of each local governm e nt program are provided in Appendix H.

Source Type Affected These program s im prove the energy efficiency of buildings and building equipm ent owned and operated by the local governm e nts in the Metropolitan W a shington area.

Control Strategy This m easure is envisioned as a region-wide m easure encom p assing energy perform a nce contracts and other structured energy savings program s by state and local governm e nts within the Metropolitan W a shington nonattainm e nt area. This program is at varying stages of developm ent, and com m itm ents received involve several local jurisdictions in the nonattainm e nt area. State and local governm e nts have signed contracts with energy service com p anies (ESCOs) to retrofit existing facilities to reduce the dem a nd for electricity and have undertaken other energy ef f i ciency m easures in their f acilities. The reduction in electricity dem a nd will displace fossil fueled power generation, thus reducing the NOx em itted from those plants.

Each state in the nonattainm e nt area is including provisions in its NOx Ozone Season em issions trading regulations that set aside a percentage of the state’s total NOx allowance budget to support energy efficiency and renewable energy (EERE) projects.

Implementation Arlington County, Virginia. The Arlington County governm e nt has instituted a variety of

m easures since 2002 to im prove energy efficien cy of operations. In addition, Arlington has allocated funds for additional efficiency investm e nts that will increase the energy savings between now and 2010.

Fairfax County, Virginia. Fairfax County governm e nt has im plem ented several large energy efficiency projects in 2005 and 2006. These project s involve variable speed drives, lighting and heating, ventilation and air conditioning (HVAC) upgr ades, and other efficiency investm e nts.

Montgomery County, Maryland. Montgom ery County departm e nts undertake their own energy efficiency investm e nts, as detailed in each of their Resource Conservation Plans. (See http://www.m ontgom erycountym d.gov/content/dep/Energy/2007rcp.pdf ). These investm e nts cover a wide range of m easures during the period 2003 to 2008.

Calvert County, Maryland. Calvert County has a num ber of energy efficiency initiatives being undertaken to im prove air quality, including lighting upgrades, program m a ble therm o stats, and appliance replacem ent with ENERGY STAR®.

MW AQC Ozone SIP May 23, 2007 6-79Monitoring and Enforcement All jurisdictions and agencies reporting em issi on reductions from energy efficiency program s will com m it to m a intain copies of signed energy service perf orm a nce contracts and energy bills and other docum entation to verify the reduction in electricity dem a nd. 7

Projected Reductions and Emissions Benefit Calculations The estim ates below were developed in collaboration with local jurisdictions. These estim ates quantify the reductions in energy consum ption resulting from the energy service perform a nce contracts and other efficiency m easures undertaken by each jurisdiction. The m e thods used to develop these estim ates are described in Appendix H, which also explains how electricity savings are divided into three categories.

Table 6-13. Projected Annual Reductions from Energy Efficiency Programs

Annual kWh Reductions by Year and Ty pe of Measure, MWH Arlington County Y e a r A / C L i g h t i n g O t h e r 2 0 0 8 2 7 7 7 5 3 1 2 2 0 0 9 3 1 8 2 0 6 0 7 Fairfax County Y e a r A / C L i g h t i n g O t h e r 2 0 0 8

- 9 8 4

, 2 3 2 2 0 0 9

- 8 4 3

, 5 9 7 Montgomery County Y e a r A / C L i g h t i n g O t h e r 2 0 0 8 4

, 8 5 5 1 3

, 7 8 8 8

, 3 6 7 2 0 0 9 4

, 1 2 7 1 1

, 7 2 0 7
, 1 1 2

Because of the uncertainty surrounding the am ount of creditable reductions available from this
program , Maryland and Virginia are claim i ng zero credit from this m easure.

7 Currently, not enough is known about the m e thods used to develop kW h reduction estim ates to be able to define the docum entation necessary to establish their validity. Ju risdictions are considering establishing a baseline based on docum ented energy code requirem e nts for energy efficiency.

MW AQC Ozone SIP May 23, 2007 6-80LED Traffic Signal Retrofit Program

Under this program , state and local governm e nts in the nonattainm e nt area have com m itted to replace existing traffic signals with m o re energy efficient Light Em itting Diode (LED) technology. This will decrease dem a nd for electricity and subsequent power generation from coal, oil, and/or gas-fired sources that would norm a lly supply power to the Metropolitan W a shington region, thereby reducing NOx em issions from those sources.

Source Type Affected

The m easure affects state and local governm e nts within the Metropolitan W a shington nonattainm e nt

area.

Control Strategy

This m easure is envisioned as a region-wide m easure encom p assing LED traffic signal retrofits by state and local governm e nts within the Metropolitan W a shington nonattainm e nt area. This
program is in the early stages of developm ent, and com m itm ents received at this point affect several state and local jurisdictions in the nonattainm e nt area. Transportation agencies have begun to retrofit existing traffic signals to LED technology to reduce the dem a nd for electricity. The reduction in energy dem a nd will displace fossil fuel generated power, thus reducing the NOx em itted f r om those plants.

Each state in the nonattainm e nt area are including a provision in their regulatory program that sets aside a portion of the state’s total NOx allowance budget for clean air projects. The state will retire NOx set-aside allowances in an am ount com m e nsurate with the size of the energy dem a nd reduction to ensure reductions of ozone season em issions allowed under the state regulatory program

. Implementation

Maryland Departm e nt of Transportation (MDOT) Virginia Departm e nt of Transportation (VDOT) District Departm e nt of Transportation (DDOT) Montgom ery County, Maryland Arlington County, Virginia City of Alexandria, Virginia City of Falls Church, Virginia

Under this program , jurisdictions are com m itting to replace older incandescent traffic signals with m o re energy-efficient LED signals. All of the identified replacem ents will be in place by May 1, 2009.

MW AQC Ozone SIP May 23, 2007 6-81The following table sum m a rizes the LED signal replacem ent com m itm ents:

LED Traffic Signal Replacment Number of LED Signal Units W a shington, DC 69,140 V D O T 6
, 8 9 4 M D O T 1 5 * Montgom ery County, MD 250* Arlington County, Virginia 92*

City of Alexandria, Virginia 25*

City of Falls Church, Virginia 92

* Data reported is number of intersecti ons with LED signal units installed.

Monitoring and Enforcement

All jurisdictions and agencies participating in the LED Traffic Signal Retrofit program have

com m itted to m a intain records of the traf f i c signals being replaced and energy bills to verif y the reduction in energy dem a nd.

Projected Reductions and Emissions Benefit Calculations

LED Traffic Signal Replacment Number of LED Signal Units Oz one Season NOx Reduction (tpd) a W a shington, DC 69,140 0.02 V i r g i n i a 6
, 8 9 4 0.004 Note: Only DDOT and VDOT commitments are included in the emission benefit calculation at this tim e.

a The em is s i on factors us ed for this an aly s is are discussed in Appendix H.

MW AQC Ozone SIP May 23, 2007 6-82Mobile Source Strategies

The following m obile source strategies are included in the voluntary bundle:

• Rem o te Sensing Program

There were two program s included in the 1-hour ozone SIP which are now being withdrawn, and as such, will not be included in the 8-hour oz one SIP voluntary bundle: diesel retrofit and alternative fuel vehicle/low-em ission vehicle purchase program

.

• Diesel Retrofit Program. Under this program , local governm e nts and transit agencies identify high-em itting, high-m ileage diesel vehicles, such as older school buses and transit buses for retrofit. These vehicles are retrofitted usi ng any of a variety of technologies certified under EPA’s Voluntary Diesel Retrofit Program . Com m only considered technologies include oxidation catalysts and particulate f ilters.

• Alternative Fuel Vehicle/Low

- em ission Vehicle Purchase Program. Under this
program , local governm e nts and transit agencies purchase low-em ission vehicles instead of conventional gasoline powered vehicles.

Local governm e nts com m itted to these two initiatives in the 1-hour ozone SIP voluntary bundle, and no em ission reduction credits were applied. Annual reporting for the evaluation report indicates that these com m itm ents were m e t. Local governm e nts are now reserving any em ission reduction credits that these program s m a y generate for potential future use in m eeting transportation conform ity or as weight of evidence. As such, they are no longer included in the local voluntary bundle in the 8-hour ozone SIP. The 8-hour ozone SIP dem onstrates RFP and attainm e nt without m odeling of any reductions from these m easures, therefore rem oval of these

com m itm ents from the voluntary bundle does not interfere with air quality planning requirem e nts.

MW AQC Ozone SIP May 23, 2007 6-83Remote Sensing Device Program

The Com m onwealth of Virginia has im plem ented a rem o te sensing program throughout the Northern Virginia portion of the W a shington nonattainm e nt area. This program reduces the

num ber of high-em itting vehicles in the Virginia portion of the W a shington region by requiring vehicles identified as high em itting to undergo out-of-cycle testing.

Source Type Affected

The m easure affects Virginia m o torists drivi ng through the Virginia portion of the W a shington nonattainm e nt area.

Control Strategy

Under this m easure, cars em itting in excess of the state em ission lim it are identif ied via a rem o te sensing program as they drive throughout th e region. Owners of high-em itting vehicles are

m a iled a notice requiring out-of-cycle testing and repair for the vehicle’s em ission system . Highem itting Virginia vehicles not registered within the inspection and m a intenance (I/M) program area but driving through the W a shington region on a re gular basis are also be required to repair their em issions control system s. This will reduce the num ber of high-em itting vehicles in the W a shington nonattainm e nt area.

Implementation

Virginia – Departm e nt of Environm ental Quality

Monitoring and Enforcement

VDEQ has developed a rule that will backstop this program and provide clear penalties f o r

noncom pliance. Penalties are based on the level of the em issions exceedences and vary from $450 to $225, adjusted from the base year of 1990 by the consum er price index. See 9 VAC 5- 91-750. The entire rule m a y be found at h ttp://www.deq.virginia.gov/air/pdf/airregs/C091.pdf.

Projected Reductions and Emi ssion Benefit Calculations

Because of the uncertainty surrounding the am ount of creditable reductions available from this
program and also due to the problem atic nature of relating m obile source concentrations to

em ission rates, Virginia is claim i ng zero credit from this m easure.

MW AQC Ozone SIP May 23, 2007 6-84Auxiliary Pow er Units (APU) on Locomotives

Diesel locom o tives produce large quantities of NOx and particulate m a tter. Because it is tim e

consum ing to start up and shut down locom o tives engines, m a ny locom o tive operators leave engines running when the locom o tives are not in use. This is especially true of locom o tives used in switchyards, which m u st operate frequently at irregular intervals. As a result, operators often tolerate idling so as to have the switcher ready when needed. This program encouraged

com m u ter, freight and com m e rcial passenger railroads to install electric-powered APUs on locom o tives operating in the W a shington nonattainm e nt area. An APU offers a low-em ission alternative to constantly idling the locom o tive engine.

Source Type Affected

Locom o tives operating within the Metropolitan W a shington nonattainm e nt area.

Control Strategy

This m easure was envisioned as a region-wide m easure encouraging a variety of locom o tive owners and operators within the Metropolitan W a shington nonattainm e nt area to purchase and install APUs to reduce locom o tive idling.

This program was included in the 1-hour ozone SIP and is not being expanded at this tim e. Only

one com m itm ent has been received. Virginia Railway Express (VRE), a local com m u ter railroad, has com m itted to install 13 APUs on locom o tives operating within the Metropolitan W a shington region. These APUs are used when locom o tives would norm a lly idle in the rail yards, reducing fuel usage and locom o tive em issions.

There are no new com m itm ents beyond those m a de in the 1-hour ozone SIP.

Implementation

Virginia Railway Express

VRE has com p leted their APU installation progr am , and the units are functioning properly. VRE has budgeted funds for the electricity charges, and for routine m a intenance on the units.

Monitoring and Enforcement

VRE has com m itted to m a intain copies of signed contracts and invoices to verify the num ber and type of APUs purchased. VRE has also pledged to track the average hours the APUs are operated. These records will be provided to the appropriate state air agency on an annual basis and will be used to provide docum entation f o r the region’s periodic evaluation report.

MW AQC Ozone SIP May 23, 2007 6-85Projected Reductions

VRE is operating 13 APUs at a projected reduction of 0.13 tpd NOx per year.

Emissions Benefits Calculations

Em ission benef its are calculated as f o llows:

avoided tpd 7 2000 avoided emissions n consumptio fuel avoided avoided idling units of #

=

× × × ×

week days

ton lb gal lb
hour gal
week hours

MW AQC Ozone SIP May 23, 2007 6-86VOC Reduction Strategies

The following program s are included in the voluntary bundle to reduce em issions of VOCs in the region:

• Low-VOC Paints Program

• Gasoline Container Replacem ent Program

• Solvent Parts W a sher Replacem ent Program

Low

- VOC Paints Program

Interior and exterior paint is applied to a variety of surfaces, including buildings and roads. Though the Architectural and Industrial Maintenance Coatings rule, requires a lower VOC content for m a ny paints, m a ny m a nufacturers sell no-VOC paint, or paint with VOC content

m u ch lower than the AIM rule standard. Use of no- or very low-VOC paint further reduces VOC

em issions in the W a shington nonattainm e nt area.

Source Type Affected

The m easure affects state and local governm e nts and their contractors involved in som e interior and exterior painting and traf f i c m a rking activities.

Control Strategy

This m easure is envisioned as a region-wide m easure encouraging use of very low or zero-VOC paint by public citizens, private industry and state and local governm e nts within the Metropolitan W a shington nonattainm e nt area.

This program was included in the 1-hour ozone SI P and is being expanded here. State agencies and local governm e nts have com m itted to using paint and traffic m a rking m a terials with very low or zero VOC content. The lower-VOC paint is to be purchased and applied daily throughout the ozone season, and often year-round. It is hoped that continuing outreach efforts will expand this program to include participation from additional governm e nt entities and the private sector.

Implementation

Arlington County, Virginia Calvert County, Maryland City of Alexandria, Virginia City of Greenbelt, Maryland Fairfax County, Virginia Maryland Departm e nt of Transportation Maryland National Capital Parks and Planning Com m i ssion (M-NCPPC), Prince George’s County Prince George’s County, Maryland

MW AQC Ozone SIP May 23, 2007 6-87All participating jurisdictions plan to purchase and use paints with VOC content below the allowable levels under the existing regulatory program s for architectural, industrial, and

m a intenance coatings. See Appendix H for m o re details.

Monitoring and Enforcement

All jurisdictions and agencies participating in the low-VOC paint program have com m itted to

m a intain records of the num ber of gallons of paint used and the paint’s VOC content. VOC content will be determ ined either by using the VOC level certification found on the paint can label or through laboratory testing, at the discretion of the participant. These records will be provided to the appropriate state air agency on an annual basis and will be used to provide docum entation for the region’s periodic evaluation reports.

Projected Reductions

Including the com m itm ents m a de in the 1-hour ozone SIP, this m easure affects 566 gallons of paint per day and is anticipated to reduce 0.17 tpd VOC. Further inform ation on com m itm ents and projected reductions is included in Appendix H.

Emissions Benefits Calculations

Benefits from this program are calculated by determ ining em issions reduced over and above those required by the OTC AIM rule. They are calculated as follows:

⎟ ⎠ ⎞ ⎜ ⎝ ⎛

− ∗

× ×

= s commitment in cap rule AIM under cap 2000 39

. 453 7854

. 3 (tpd) Reduced VOC liter g liter

g

ton lb
lb g gallon liters day gallons

MW AQC Ozone SIP May 23, 2007 6-88Solvent Parts Washer Replacement Program

Under this program , local governm e nts voluntarily replace solvent-based parts cleaners with

zero-em itting technology. This program reduces VOC em issions in the W a shington nonattainm e nt area.

Source Type Affected

The m easure affects local governm e nts within the Metropolitan W a shington nonattainm e nt area.

Control Strategy

This m easure is envisioned as a region-wide m easure encouraging replacem ent of solvent-based parts cleaners with zero-em itting technology in pr ivate industry and state and local governm e nts within the Metropolitan W a shington nonattainm e nt area.

This program is in the early stages of developm ent, and com m itm ents received at this point affects only one local jurisdiction in the nonattainm e nt area. Montgom ery County has begun to replace county-owned solvent-based parts clean ers with zero-em itting technology. The program elim inates VOC em issions from those units.

Implementation

Montgom ery County, Maryland

Montgom ery County has replaced solvent-based parts washers with m i crobial/aqueous washers at county-owned vehicle service facilities. The county is also conducting a pilot program that will offer rebates to private autom o tive shops to purchase m i crobial/aqueous parts washers in place of solvent- based parts washers. The County hopes to expand the rebate programCountywide. Montgom ery County is also working to im plem ent an Environm ental Partners Program across a wide range of businesses, including the general public, which will prom ote environm entally f r iendly practices that include air quality benef its.

Monitoring and Enforcement

All jurisdictions and agencies participating in the Solvent Parts W a sher Replacem ent program have com m itted to m a intain records of the num ber of units replaced, the annual quantity of solvent use that was displaced, and the VOC conten t of the displaced solvent. These records will be provided to the appropriate state air agency on an annual basis and will be used to provide docum entation for the region’s periodic evaluation reports.

MW AQC Ozone SIP May 23, 2007 6-89Projected Reductions and Emissions Benefit Calculations

VOC em ission reductions can vary based on the am ount of solvent previously used by the f

acility bef o re the switch to a solvent f r ee system . Based on prelim inary estim ates provided by staff, replacing a typical unit m a y reduce VOC em issions by 0.1 to 2 tons/year/unit. Maryland is claim i ng zero SIP credit for this m easure.

MW AQC Ozone SIP May 23, 2007 6-90Gas Can Replacement Program

Portable gas cans are a significant source of daily VOC em issions. Em issions from gas cans occur f r om evaporation and due to spillage f o r overf illing of power equipm ent f u el tanks. In transporting and storing cans, em issions are al so released through secondary vent holes and
perm eation. By using newer gas cans with features such as shut off valves, harm ful gasoline fum e s can be reduced by 75 percent.

Source Type Affected

Owners of portable fuel containers, except containers with a capacity of less than or equal to one quart, rapid ref u eling devices with capacities greater than or equal to f our gallons, saf e ty cans and portable m a rine fuel tanks operating with outboard m o tors, and products resulting in

cum u lative VOC em issions below those of a representative container or spout.

Control Strategy

This program was adopted as part of the vol untary bundle developed for the 1-hour ozone SIP. Com m itm ents included local jurisdictions, state agencies, and their contractors operating in the nonattainm e nt area. Jurisdictions pledged to collect functional cans that were not already scheduled for replacem ent, and replace those in-use, functional cans with redesigned cans

m eeting the new Portable Fuel Containers standard. Old cans were destroyed in accordance with requirem e nts for disposal of hazardous waste.

There are no new com m itm ents beyond those m a de in the 1-hour ozone SIP.

Implementation

Arlington County, Virginia Fairfax County, Virginia City of Fairf a x, Virginia Maryland National Capital Parks & Planning Com m i ssion, Prince George’s County Montgom ery County, Maryland Prince George’s County, Maryland Prince W illiam County, Maryland

Monitoring and Enforcement

All jurisdictions and agencies participating in the fuel container replacem ent program com m itted
to m a intain records of the num ber of fuel containers replaced and the m e thod of disposal. These records are provided to the appropriate state air agency on an annual basis and are used to provide docum entation for the region’s program evaluation report.

MW AQC Ozone SIP May 23, 2007 6-91Projected Reductions

This program was expected to replace 1,478 gas cans, resulting in a benefit of 0.01 tpd VOC.

Emissions Benefits Calculations

Calculation of em ission benefits was based on estim ates prepared by EH Pechan for use by the Ozone Transport Com m i ssion (Reference 2). In the report, Pechan estim ates that 2.28 m illion gas cans are sold annually in the OTC Region. Table IV-6 in the Pechan docum ent shows that for the 2.5 year period from January 1, 2003 through July 1, 2005, em issions in the OTC region will be reduced by 48 tpd VOC. Over this tim e period, the expected benefit in the Metropolitan W a shington region would be 4.3 tpd, assum i ng a January 1, 2003 im plem entation date. The estim ated annual benefit from the m easure in the W a shington region is 4.3/48=8.96% of the total benefit.

Assum i ng that em ission reductions are linearly related to gas can turnover, the W a shington region accounts for 8.96 percent of the 2.28 m illion cans sold in the region per year, or 204,000 cans. Annual regional reductions from the m easure are estim ated at 1.88 tpd. Therefore, replacem ent of one can will, on average, deliver a benefit of 1.88/204,000 = 0.00000922 tpd VOC.

MW AQC Ozone SIP May 23, 2007 6-92Urban Heat Island Mitigation/Tree Planti ng/Canopy Conservation and Management

Strategic tree planting and tree canopy conserva tion and m a nagem e nt are innovative voluntary

m easures that will achieve area-wide im provem e nt of the tree canopy, providing air quality benefits including reductions in ground-level ozone in the W a shington DC Metro nonattainm e nt area. Air quality benef its associated with trees and their shade result f r om lowering sum m e rtim e air tem p eratures and from actual pollutant absorption and contact rem oval from the trees them selves.

One of the m o st dram atic im provem e nts achievable from area-wide com p rehensive tree canopy conservation and planting is reducing the negative effects of urban heat islands (the rise in
tem p eratures due to an increased num ber of buildings and im perm eable surface areas retaining heat). Strategic placem ent of trees around hom es, buildings, streets, and parking lots, increases shade and evapotranspiration, thereby lowering sum m e rtim e air tem p eratures and surface
tem p eratures of asphalt, concrete, and other im pervious areas. Lowering air sum m e rtim e tem p eratures helps reduce ground-level ozone in several ways:

 slow the tem p erature-dependent reaction that form s ground-level ozone;

 reduce evaporative em issions, prim arily VOCs (precursors to ground-level ozone) from sources such as vehicles; and

 reduce the am ount of electricity generated for cooling, thereby reducing air pollutant

em issions including ground-level ozone precursors, from power plants.

In addition, through up-take and contact rem oval, trees rem ove ground-level ozone, nitrogen oxides, sulf ur oxides, and other ozone precursors f r om the air. Other air quality benef its f r om trees include rem oval of carbon m onoxide and fine particulate m a tter less than 10 m i crons. Carbon dioxide is rem oved and stored by trees, dust is intercepted, and oxygen is released.

Source Type Affected

The m easure affects state and local governm e nts within the W a shington DC Metro nonattainm e nt area.

Control Strategy

To achieve reductions in ground-level ozone, gove rnm e nt agencies, volunteer organizations, and private landowners m u st m a ke long-term com m itm ents to conserving existing canopy and planting significant num bers of trees in strategic locations. Under this m easure, local
governm e nts in the m e tropolitan nonattainm e nt area will com m it to:

1. Measure Existing Resources and Track Changes – Initiate and/or enhance ef f

o rts to

m easure, track, and enhance existing urban tree canopy and canopy expansion efforts.

2. Program s to Enhance and Increase Benefits from Trees – Im plem ent urban forestry
program s to enhance canopy coverage to reduce sum m e rtim e air and surface
tem p eratures. Program s include planting trees in strategic locations to cool targeted

MW AQC Ozone SIP May 23, 2007 6-93surfaces and provisions for long-term m a intenance. Priority planting sites include locations where buildings, streets, driveways, and parking lots will be shaded by the new plantings.

3. Public Outreach – The region com m its to undertake a public outreach program designed to prom ote tree and canopy conservation and planting. Local governm e nts, counties, states, and COG will work with volunteer tree planting organizations, school children, property owners, and stakeholder groups of businesses to support tree conservation and planting, conduct educational outreach regarding the benefits of trees and canopy, species selection, tree planting and establishm ent, and long-term tree m a intenance. Efforts will be m a de to docum ent all conservation and planting efforts including voluntary program s.

4. Regional Canopy Managem e nt Plan – Local governm e nts will work to develop a long range plan to enhance tree conservation and planting, and to establish goals for increasingtree canopy coverage between 2010 and 2030 that could lead to lower levels of groundlevel ozone pollution. Issues to address include coordination of efforts, tracking progress in centralized databases, continuation and increases of resources from state and federal sources, involvem e nt of private landowners a nd businesses, and periodic evaluations and reports.
5. Species Selection – During photosynthesis, trees release secondary m e tabolic products. Som e of these include biogenic volatile organic com pounds (VOCs), precursors to the f

o rm ation of ozone. In m o st instances, the im provem e nts in air quality gained f r om trees outweigh the concerns over additional biogenic VOC em issions. Additionally, large trees are considerably m o re benef i cial f o r air quality than sm all trees. Theref ore, when planting trees, species should be selected for large-size and long-term survival based on specif i c site conditions and adjusted, when possible, f o r low-VOC em itters.

6. Monitoring Program s – Monitor these activities and report periodically.

Current Programs

Many program s that support, encourage, or require the tree and forest conservation and planting exist within the local jurisdictions, counties, and states in the W a shington DC Metro nonattainm e nt area. Special attention will be paid coordinating these program s to enhance tree protection, canopy conservation and expansion to enhance regional air quality.

Implementation

Fairfax County tree canopy requirem e nt for new developm ent. Fairfax County parking lot canopy ordinance. Fairfax County governm e nt land planting program

. Fairfax County countywide nonprofit tree planting program

. Arlington County Urban Forest Master Plan. Arlington County plant 1,280 trees annually. Arlington County Chesapeake Bay Preservati on Ordinance/Landscape Conservation Plan.

MW AQC Ozone SIP May 23, 2007 6-94City of Alexandria Urban Forestry Plan under developm ent. City of Alexandria 12,000 square feet of vegetative roof installed on city buildings. City of Alexandria Reflective roofs standard for governm e nt buildings. City of Greenbelt Tree planting program . Shade tree im provem e nt initiative. Montgom ery County street tree planting program . 1,200 trees per year. Montgom ery County "Shade to Save" pilot program

. Montgom ery County is developing a residential tree planting program

. Montgom ery County is developing urban tree legislation. Montgom ery County Stream Restoration Projects pl ant native trees and shrubs to enhance and establish forests near stream project sites. Montgom ery County Rainscapes Program

. Montgom ery County Forest Conservation Law Am endm ents to the Forest Conservation Law to adjust for changes in developm ent patterns are being developed. Montgom ery County Forest Banking Program Montgom ery County Legacy Open Space program Montgom ery County Rural Legacy Program Montgom ery County Developm ent Rights Program Prince George' s County Releaf Grant Program Prince George' s County Tree Replacem ent Program Prince George' s County Gorgeous Prince George' s Day MNCPPC Montgom ery County Parks Departm e nt actively m a intains and plants shade trees in developed areas of parks. MNCPPC Montgom ery County Parks Departm e nt establishes forested areas on open land within the park system

. Calvert County Reflective roof system s on 6 county buildings.

Monitoring and Enforcement

The state and local governm e nts will m a intain records of program activity and public outreach

cam paigns designed to prom ote tree and canopy conservation and planting or enhancem ent. The jurisdictions will also provide evidence of educational outreach ef f

o rts regarding docum enting and reporting voluntary planting and m a intenance program s. Results of all initiatives will be quantified and reported consistent with other SIP requirem e nts to the public and EPA.

Projected Reductions and Emi ssions Benefits Calculations

This program is expected to lead to reductions in ground-level ozone throughout the W a shington DC Metro nonattainm e nt area. Methods to quantify benefits from trees and tree canopy are evolving. Several m e thods have been used to cal culate benefits resulting from canopy expansion. Currently, the Air Pollution Rem oval Calculator developed by the United States Forest Service will be used to estim ate pollution rem oval and value for urban trees based on basic user inputs. This program draws on data collected and analyzed for various cites in the region by the USFS for the Urban Forest Effects (UFORE) m odel.

Maryland, Virginia, and the District of Colum b ia are claim i ng zero credit for this m easure.

MW AQC Ozone SIP May 23, 2007 6-95References

US EPA. 2007. Heat Island Effect: Vegetation & Air Quality. Most recent update Jan 16, 2007. http://epa.gov/heatisland/strategies/level3_vegairquality.htm l . Trees and Our Air, January 1999, Galveston-Houston Association for Sm og Prevention.

MW AQC Ozone SIP May 23, 2007 6-967.0 REASONABLY AVAI LAB LE CO NTROL MEASURE (RACM) ANALYSIS

7.1 RACM Analysis

Section 172(c)(1) of the Clean Air Act requ ire s state im pl em e n tation plans (SIPs) to include an analysis of reasonably available con t rol m easures (RACM). This analysis is designed to ensure that the W a shington regi on is im ple m enting all RACM in order to dem onstrate attainm e nt with the 1-hour ozone standard on the earliest date possible. T h is chapter presents a summary of analyses conduc ted to determ ine whether the SIP includes all such m e a s ures. Full details of th e analysis are included in Appendix I

. The Metropolitan W a shington C ouncil of Governm e nts (MW C OG) conducted this RACM evaluation in coordination with the District of Colum b ia De partm e nt of Environm ent (DC-DOE), Maryland D e partm e nt of the Environm ent (MDE) and the Virginia Departm e nt of Environmental Quality (VA DEQ).

7.1.1 Analysis Overview and Criteria

The RACM requirem e nt is rooted in Sec tion 172(c)(1) of the Clean Air Act, which directs states to “provide for im plem entation of all reasonably availa ble control m e a s ures as expeditiously as practicab le”. In its 1992 General Pream b le for im ple m entation of the 1990 Clean Air Act Amendm ents (57 FR 13498) EP A explains that it interprets Section 172(c)(1) as a requirem e nt that states incor porate in a SIP all RACM that would advance a region’s attainm e nt date. However, regions are obligated to adopt only those m easures that are reas onably available for im plem entati on in light of local circum stances. In the Pream ble, EPA laid out guidelines to help states determ ine which m eas ures should be considered reasonably available:

If it can be shown that one or mo re measures are unreasonable because emissions from the sources affected are insignificant (i.e. de minimis) , those measures may be excluded from fu rther consideration...the resulting available control measures should th en 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 cons ider the im pact of the reasonableness of the measures on the m unicipal or ot her 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, including th e consideration of

econom ic and technological feas ibility, ability to cause subs tantial widespread and longterm advers e im pacts, collec tive ability of th e m easures to a dvance a r e g i on’s a tta in m e nt date, and whether an intensiv e or costly effort will be required to im ple m ent the

m easures. Consistent with EPA guidance and the U. S. District Court’s opinion, the region

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, 2 007has develop e d specific criteria for ev aluati on of potential RACM m easures. Individual

m easures must m eet the following criteria:

• W ill reduce em issions by the beg i nning of the W a shingto n region ’s 2 008 ozone season (May 1, 2008) 1

• Enforceable

• Technically feasible

• Econom ically feasible (proposed as a cost of $3,500-$5,000 per ton or less)

• Would not create substantial or widespr ead adv e rse im pacts within th e region

• Em issions from the source being contro lled exceed a de minimis threshold, proposed as 0.1 tons per day

An explanation of these criteria is given in succeeding sections.

7.1.2 Implementation Date

EPA has tra d ition a lly in struc t ed r e gions to ev a l u a te RACM m easures on their ability to advance the region’s attainm e nt date. This m eans that im ple m entation of a m e asure or a group of m e asures m u st enable the region to reduce ozone levels to the 84 ppb required to attain the 8-hour ozone standard at least one year earlier than expected. A s the Washington region currently expects to reduce ozone le vels to 84 ppb during the 2009 ozone season, any RACM m u st enable the re gion to m eet the 84 ppb standard by May 1, 2008, the beginning of the 2008 ozone season.

7.1.3 Enforceability

When a control m easure is added to a SIP, the m e asure becomes legally binding, as are any specific perform a nce targets asso ciated with the m easure. If the state o r local
governm e nt does not hav e the au thority necessary to im ple m ent or enforce a m easure, the

m easure is not creditable in the SIP and therefore cannot be declared a RACM. A

m easure is considered en forceable w h en all state or local gov ernm ent agencies responsible for funding, im ple m entation and en forcem ent of the m easure have comm i tted in writing to its im plem entation and enf o rcem ent.

In addition to theoretical enforceability, a m easur e m u st also be practically enforceable. If

a m easure cannot practically be enforced beca use the sources are unidentifiable or cannot be loca ted, o r becaus e it is otherwis e impossibl e to ensure th at the sourc e s will im plement the control m easure, the m easure cannot be declared a RACM. One exception is voluntary measures, such as those imple m e nted under EPA’s Voluntary Measures Guidance.

7.1.4 Technological Feasib ility

All technology-based control m eas ures m u st include technologies that have been verified by EPA. The region cannot take S I P credit for technologies that do not produce EPAverified reductions.

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, 2 0077.1.5 Economic F e asibility and Cost Effectiveness

EPA guidance states that regions should cons ider both econom i c feasibility and cost of
contro l when evaluating potential R A CM . Therefore, the W a shington region has specif i ed a c o st-ef f

ectiv e n ess thr e sho l d f o r all po s s ible RACM. Measure s f o r which the cost of compliance exceeds this thre shold will not be considered RACM.

In setting this threshold, the region took into consideration two m a jor factors. First, E P A has issued guidance regarding the relations hip between RACT and RACM. In its RACM analysis for the Dallas/F orth W o rth nonattainm e nt area, EPA states:

“RACT is defined by EPA as the lowest em ission rate achievable considering econom i c and technical feasibility. RACT level contro l is generally considered RACM for m a jor sources.”

In the W a shington region, installation of Reasonably Available Control Technology (RACT) costs are as low as approxim a tely $3,500 per ton of e m issions reduced. Therefore, it seem s reasonable to ado p t this cost effectiveness for area, non road and mobile sources in addition to stationa ry. Secondly, the National Capital Region Transportation Planning Board (TPB) fre quently adopts Transportation E m issions Reduction Measures (T ERMs) to offset m obile em issions for the purpose of conform ity. The m a jority of TERMs adopted by TPB in th e past ten years for the express purpose of reducing m obile em issions have cost less than $10,000 per ton. 1

The region proposes a threshold of $3,500-$5,000 fo r cost effectiveness. All m easures costing und er $5,000 per ton NOx or VOC reduced will be ev aluated against the

rem a ining cr ite ria to dete rm ine whether they m eet the requ ire m ents f o r a RACM.

7.1.6 Substantial and Widespread Adverse Impacts

Som e candidate RACM have the potential to cause substantial and widespread adverse im pacts to a particular social group or s ector of the econom y. Due to environm ental justice conc erns, m easures tha t cause substa ntia l or widespre ad advers e impacts will not be considered RACM.

7.1.7 De Minimis Threshold

In the General Pream ble, EPA allows regi ons to exclude from the RACM analysis

m easures that control em issions from insi gnificant sources and m easures that would im pose an undue adm i nistrative burden. Under moderate area RACT requirem e nts, the

sm allest m a jor source subject to RACT e m its 25 tpy, or approxim a tely 0.1 tpd. Following

1 Though se ve ral expe nsi v e T E RMS ha ve be en a d opted in recent years, these m easures were desi gne d for

co ng estion m i t i g a tio n or o t h e r tran sp ortatio n pu rpo s es. Em i ssio n redu ctio ns were cred ited as an an cillary bene fit, a n d the projects woul d have proceeded e v en if no e m ission cre d its we re gene rate d.

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, 2 007these requirem e nts and the preced ent set by th e San Francis c o RACM analysis, the reg i on will not con s ider con t ro l m easures af fecti ng source categories that p r odu ce less that 0.1 tpd NOx or VOC e m issions.

7.1.8 Advancing Achievement of 84 ppb Standard

In order for m easures to be collectively d eclared RACM, i m plem entation of the m easures must enable the region to dem onstrate attain m e nt of the 84 ppb ozone standard one full ozone season earlier than currently exp ected. As discussed in Section 7.1.1, the Washington region currently e xpects to dem onstrate attain m e nt in 2009. Therefore, any RACM would need to enable the region to m eet the 84 ppb standard during the 2008

ozone season.

Photochem i cal m odeling perform e d as part of the W a shington region’s attainm e nt dem onstration has not yet been com p leted. It is impossible to determ ine how m a ny additional tons the region would need to reduce in order to en sure tha t a tta inm e nt is met in 2008. Prelim inary m o deling results indi cate that any RACM would need to collectively reduce m o re than 20-40 per day (t pd) of NOx and/or VOC em ission in order to advance the attainm e nt date by one year.

7.1.9 Intensive and Costly Effort

When considered together, the im plem entati on requirem e nts of any RACM cannot be so great as to preclude effective im plem enta tion and adm i nistration given the budget and staff resources available to the W a shington region.

7.2 RACM Me asure Analysis

7.2.1 Analysis Methodology

Over the last decade, th e Metropo lita n W a shingto n Air Quality Comm ittee (MW A QC) has com p iled an extensive list of poten tial contro l m easures. MW COG has also

resea r ched m easures used as air qua lity contro l s t ra tegie s in other m e tro politan reg i o n s. These lists o f control m easures were com p iled in to a m a ster list of candidate m easures for the RACM analysis. Th e sources of strateg i es an alyzed for the Me tropolitan W a shington region include the following:

• Clean Air Act Section 1 08(f) m easures (Transportation Control Measures)

• Transportation Em issions Reduction M easures (T ERMs) listed in recent Transportation Im prove m e nt Program s (TIP s) for the Metropolitan W a shington region

• Measures identified in 1993 and 2003 M W AQC review of Air Pollution Control Measures

• Measure s co nsidered in Baltim ore, Atlanta and Houston RACM analyse s

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, 2 007M WAQC Ozone SIP 7-5 May 23, 2007 These measures were then evaluated against the criteria discusse d in Section 7.1 as documented in Appendix I.

7.2.2 Analysis Results

Table 7-1 provides lists, orga nized by source sector, of potential measures evaluated against the RACM criteria. The table shows which measures were determined to meet the individual measure criteria described in Sections 7.1.1 through 7.1.6. For each measure, the table lists whether the measure is cons idered RACM, and provides a rationale for each individual determination.

7.3 RACM Determination

If implemented collectively, any group of potential RACM would need to provide reductions of 20-4 tpd of NOx and/or VOC by the 2008 ozone season. The region has reviewed all of the potential c ontrol measures to determine if collectively they could meet these criteria. Several mandatory programs are available that can provi de moderate levels of emission reductions, however, none of these measures can provide benefits by the 2008 ozone season, and the total overall re duction that could be provided by these measures is below 20-40 tpd. While there ar e potential voluntary m easures that can be implemented before 2008, together these voluntary measures will not provide sufficient creditable emission reductions to advance th e attainment date by one year. Therefore, there are no reasonably (RACM) appropriate for the Washi ngton region’s moderate area SIP.

Though the measures listed in Table 7-1 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 SIPs prepared for the Washington region.Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

Stationary Sources

S 1 Reductions from EGUs: OTC Model Rule Adopt OTC Multipollutant Model Rule for EGUs. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

S 2 Reductions from EGUsPlant RACT/TechnologyBased Approach Identify and Require Additional Power Plant-Specific Emission Reduction Technologies. - Yes Yes - - Yes No No creditable emission reductions

S 3 OTC Model Rule: Distributed Generation Rule Adopt OTC Model Rule to Require Additional Controls on Distributed Generation Sources. No Yes Yes - No Yes No Will not provide reductions by

May 2008

S 4 OTC Model Rule: Peaking Unit Rule Adopt OTC Model Rule to Require Additional Controls on EGU Peaking Units. No Yes - - No Yes No Will not provide reductions by

May 2008

S 5 OTC Model Rule: ICI Boiler Standards Adopt OTC Model Rule on Standards for Industrial, Commercial, and Institutional Boilers. No Yes Yes Yes No Yes No Will not provide reductions by

May 2008

S 6 Control Asphalt and Concrete Facilities Require NOx emission limits on asphaltic concrete production facilities. No Yes Yes No No Yes No Will not provide reductions by

May 2008

S 7 Control Portland Cement Facilities Adopt OTC Model Rule on RACT Update for Portland Cement Facilities. No Yes Yes Yes No Yes No Will not provide reductions by

May 2008

S 8 Mineral Products Industry Controls: Glass and Fiberglass Control Glass and Fiberglass Facility Emissions. No Yes Yes Yes Yes No No Will not provide reductions by

May 2008

S 9 Controls on Municipal Solid Waste Incinerators Adopt OTC Model Rule on RACT Update for MSW Incineration Facilities. No Yes Yes - Yes Yes No Will not provide reductions by

May 2008

S 10 Control VOC Emissions from Chemical Manufacturing Chemical Manufacturing: More stringent standards on the manufacture of polystyrene, formica, polyester resin, wood and paper, other polymers, pharmaceuticals, paints, varnishes, soaps, detergents, inks, solvents, fuel additives, acids, fertilizers, and resins. No Yes Yes - No No No Will not provide reductions by

May 2008

S 11 Local Cap and Trade Program Implement cap and trade program for VOC sources in region. Consider California RECLAIM program. No Yes Yes - No Yes No Will not provide reductions by

May 2008

S 12 Statewide Emission Registration Program Require a mandatory statewide registration program for all NOx and VOC emission sources. No Yes Yes No No Yes No Not economically feasible

S 13 Clear Skies Act Implement Clear Skies Legislation. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

S 14 State Multipollutant Legislation Adopt State Multipollutant Legislation. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

Page 1 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

S 15 Emission Reduction Credit Retirement Program Establish program to retire emission reduction credits for stationary sources. No Yes Yes Yes - Yes No Will not provide reductions by

May 2008

S 16 Episodic Mandatory Facility Reductions Require mandatory facility reductions on Air Quality Action Days. Require Curtailment Plan. No Yes Yes - No No No No creditable emission reductions

S 17 Enhanced Enforcement/Rule Compliance at Existing Stationary Sources Step up enforcement of and compliance with existing rules for emissions control by stationary

sources. Yes Yes Yes No Yes No No No creditable emission reductions

S 18 Low NOx Fuel Oil for Stationary Sources Require oil-burning stationary sources to burn ThermaNOx, a low-NOx No. 2 fuel oil emulsion, during ozone season. No - Yes - Yes - No Will not provide reductions by

May 2008

S 19 Energy Efficiency Programs Increase Adoption of Energy Efficient Technology by Government and the Private Sector with Commensurate Retirement of EGU NOx Allowances. - Yes Yes - Yes - No Will not advance attainment date

S 20 Energy Efficiency: Energy Efficiency Standards Establish requirements for minimum energy efficiency, with Commensurate Retirement of EGU NOx Allowances. - Yes Yes - Yes - No Will not advance attainment date

S 21 Renewable Energy: Renewable Portfolio Standards Increase Purchases of Renewable Energy by Government and the Private Sector, with Commensurate Retirement of EGU NOx Allowances. - Yes Yes - Yes - No Will not advance attainment date

S 22 Renewable Energy: Solar Photovoltaic Programs Increase Purchases and Installation of Renewable Energy sources by Government and the Private Sector, with Commensurate Retirement of EGU NOx Allowances. Consider Incentive Programs. - Yes Yes - Yes - No Will not advance attainment date

S 23 Renewable Energy: Wind Energy Purchases Increase Purchases of Renewable Energy by Government and the Private Sector, with Commensurate Retirement of EGU NOx Allowances. - Yes Yes No Yes - No Will not advance attainment date

S 24 Renewable Energy: Solar Hot Water Heating Increase Use of Solar Hot Water Heating by Government and the Private Sector, with Commensurate Retirement of EGU NOx Allowances. - Yes Yes - Yes - No Will not advance attainment date

Page 2 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

S 25 Energy Efficiency: Energy Performance Contracting Program Increase Use of Energy Performance Contracts in the Public and/or Private sector to Reduce Energy Consumption, with Commensurate Retirement of EGU NOx Allowances. - Yes Yes - Yes - No Will not advance attainment date

S 26 Energy Efficiency Programs: LED Traffic Signal Retrofit Program Increase Use Energy Efficient LED Traffic Signals. - Yes Yes Yes Yes - No Will not advance attainment date

S 27 Energy Efficiency: Green Building Code Program Establish energy efficiency standards for building codes, with Commensurate Retirement of EGU NOx Allowances. - Yes Yes - Yes - No Will not advance attainment date

S 28 Energy Efficiency: Ground Source Heat Pump Initiative Increase Purchases and Installation of Ground Source Heat Pumps in the Public and/or Private Sector, with Commensurate Retirement of EGU NOx Allowances. - Yes Yes - Yes - No Will not advance attainment date

S 29 Energy Efficiency Programs: LED Street Light Retrofit Program Increase Use of Energy Efficient LED Street Lights. - Yes - - Yes - No Will not advance attainment date

S 30 Energy Efficiency: Energy Star Exit Signs Increase market penetration of Energy Efficient Lighting (EXIT Signs). - Yes Yes - Yes - No Will not advance attainment date

S 31 Chemical Industry Controls Reduce upwind NOx emissions limits in the manufacture of chemicals. No Yes - - - - No Will not provide reductions by

May 2008

S 32 Upwind NOx Controls: Expand NOx RACT to Upwind Counties Expand NOx RACT Requirements. No Yes - Yes Yes Yes No Will not provide reductions by

May 2008

S 33 Metallurgical Industry Controls: Iron and Steel Control Upwind Iron and Steel Production Emissions. No Yes - - - - No Will not provide reductions by

May 2008

S 34 Metallurgical Industry Controls: Lead Control Upwind Lead Smelter Emissions. No Yes - - - - No Will not provide reductions by

May 2008

S 35 Metallurgical Industry Controls: Aluminum Control Upwind Aluminum Production Emissions. No Yes - - - - No Will not provide reductions by

May 2008

S 36 Metallurgical Industry Controls: Zinc/Copper Control Upwind Zinc/Copper Smelter Emissions. No Yes - - - - No Will not provide reductions by

May 2008

S 37 Mineral Products Industry Controls: Lime Control Upwind Lime Facility Emissions. No Yes - - - - No Will not provide reductions by

May 2008

S 38 Mineral Products Industry Controls: Phosphate Control Upwind Phosphate Rock Plant Emissions. No Yes - - - - No Will not provide reductions by

May 2008

S 39 Forest Product Industry Controls Control Upwind Wood, Paper and Pulp Production Emissions. No Yes - - - - No Will not provide reductions by

May 2008

Page 3 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

S 40 Upwind VOC Controls: Plant-by-Plant BACT Controls Identify and Require Additional Facility-Specific Emission Reduction Technologies. No Yes - - - Yes No Will not provide reductions by

May 2008

S 41 Upwind VOC Controls: Expand VOC RACT to Upwind Counties Expand VOC RACT Requirements. No Yes - Yes Yes Yes No Will not provide reductions by

May 2008

S 42 Upwind NOx Controls: Plant-by-Plant BACT Controls Identify and Require Additional Facility-Specific Emission Reduction Technologies. No Yes - - - Yes No Will not provide reductions by

May 2008

S 43 Upwind RACT Update: Refineries Update RACTs for Refineries in Upwind Contributing Areas. No Yes - - Yes Yes No Will not provide reductions by

May 2008 Area Sources

A 1 Control VOC Content of Adhesives and Sealants Adopt OTC Model Rule. Reduce VOC limits for adhesives and sealants. No Yes Yes - - Yes No Will not provide reductions by

May 2008

A 2 Low-Emission Asphalt Adopt SCAQMD Rules 1108: Cutback Asphalt (less than 0.5% VOC evaporating at 260F) and 1108.1: Emulsified Asphalt (less than 3% VOC evaporating at 260F). No Yes - - Yes No No De minimis

A 3 Expand Coverage of OTC Consumer Products Rule (Phase II) Expand Number of Products Covered by OTC Consumer Product Rule. Require Lower VOC Content of Products Already Covered. No Yes - - - Yes No Will not provide reductions by

May 2008

A 4 Expand Coverage of OTC AIMs Rule (Phase II) Expand Number of Products Covered by OTC AIMs Rule. Require Lower VOC Content of Products Already Covered. No Yes - - - Yes No Will not provide reductions by

May 2008

A 5 Green Procurement Policy Establish procurement policies that foster emission reduction (paints, solvents, coatings, asphalt, roofs, building materials, AFVs, EE office equipment, ULSD). Yes No Yes - Yes - No No creditable emission reduction

A 6 Control Growth and Development: Land Use Restrictions Implement land use restrictions to control residential, commercial, and industrial development in the nonattainment area. - No Yes - No - No No creditable reductions

A 7 Control Growth and Development: Mitigate New Development Mitigate emissions from new development. - No Yes - No - No No creditable reductions

A 8 Implement Programs to Reduce the Urban Heat Island Effect: Forestry. Increase Urban Tree Canopy No No Yes - Yes No No No creditable emission reduction

A 9 Implement Programs to Reduce the Urban Heat Island Effect: Roofs. Increase Green and Cool Roof Market Penetration No No Yes - Yes No No No creditable emission reduction

Page 4 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

A 10 Implement Programs to Reduce the Urban Heat Island Effect: Pavement. Increase Cool Pavement Market Penetration No No Yes - Yes No No No creditable emission reduction

A 11 Expand Stage I Vapor Recovery Expand Requirements for Stage I Vapor Recovery to Upwind Counties. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 12 Expand Stage II Vapor Recovery Expand requirements for Stage II Vapor Recovery to Upwind Counties. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 13 Upwind Fuels Controls Expand Use of Reformulated Gasoline to Upwind Counties. Consider OTC Regional Fuels Initiative. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 14 Expand OTC Consumer Products Rule Expand OTC Consumer Product Rule to Upwind Counties. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 15 Expand OTC Mobile Equipment Repair and Refinishing Rule Expand OTC Mobile Equipment Repair and Refinishing Rule to Upwind Counties. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 16 Expand OTC Portable Fuel Containers Rule Expand OTC Portable Fuel Containers Rule to Upwind Counties. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 17 Expand OTC Solvent Cleaning Rule Expand OTC Solvent Cleaning Rule to Upwind Counties. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 18 Expand OTC AIMs Rule Expand OTC AIMs Rule to Upwind Counties. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 19 Control Upwind Port Emissions Pursue approaches to reduce land based port emissions. No Yes Yes Yes Yes Yes No Will not provide reductions by

May 2008

A 20 Control Drycleaning Facilities Ban transfer systems in Petroleum Dry Cleaning. No Yes Yes - No Yes No Will not provide reductions by

May 2008

A 21 Expand Seasonal Open Burning Restrictions Expand prohibitions on seasonal open burning. No Yes Yes Yes Yes No No No creditable reductions

A 22 Enhanced Enforcement: Environmental Partnerships/Pollution Prevention Initiatives Voluntary compliance audits, encourage low emitting technology (swap out solvent machines) Yes No Yes - Yes No No No creditable emission reductions

A 23 Control Agricultural Sources Encourage agricultural best practices, including those that reduce pesticide use. Yes No Yes - No Yes No No creditable emission reduction

A 24 RACT Update: Control Industrial Incineration Implement programs to reduce emissions from industrial incineration. No Yes - - - - No Will not provide reductions by

May 2008

A 25 Home Heating Oil Standards Adopt OTC model rule on standards for home heating oils. No Yes Yes - No - No Will not provide reductions by

May 2008

A 26 Control Fermentation Sources (wineries/breweries) Reduce evaporative VOC emissions from the fermentation process at wineries and/or breweries. No Yes Yes - No - No Will not provide reductions by

May 2008

Page 5 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

A 27 Control Landfills and Wastewater Facilities Reduce the NOx and VOC emission limits for flares. No Yes Yes No Yes No No De minimis

A 28 Control Wastewater Treatment Facilities Require capture and control of VOC emissions from facilities treating industrial wastewater and domestic sewage. Adopt SCAQMD Rule 1176: Sumps and Wastewater Separators. No Yes - - No - No Will not provide reductions by

May 2008

A 29 Control VOC Emissions from Fuel Facilities Reduce the VOC emission limits for bulk plants/terminal, including storage tanks. Adopt SCAQMD Rule 1178: Further Reductions of VOC Emissions from Storage Tanks at Petroleum Facilities. No Yes - - No Yes No Will not provide reductions by

May 2008

A 30 Control VOC Emissions from Construction and Maintenance Reduce VOC emissions from roofing kettles. No Yes No No No - No Will not provide reductions by

May 2008

A 31 Control Residential Wood Burning Implement voluntary program toreduce emissions from woodburning fireplaces and wood stoves. Yes No Yes - Yes No No No creditable emission reduction

A 32 Low-Emission Natural Gas Water Heaters Adopt SCAQMD Rule 1121: Control of NOx from Residential Type Natural Gas Fired Water Heaters. No No Yes Yes No No No De minimis

A 33 Low-Emission Natural Gas Furnaces Adopt SCAQMD Rule 1111: NOx Emissions from Natural Gas Fired, Fan-Type Central Furnaces (no more than 40 nanograms of NOx per joule of useful heat). No No Yes Yes No No No De minimis

A 34 Control Restaurant Sources Implement programs to reduce emissions from restaurants, including charbroil operations and deep fat fryers. No No Yes No No No No Will not provide reductions by

May 2008

A 35 "Cash for Clunkers" Gasoline Containers Replacement Program Accelerate the Replacement of Older Gasoline Cans with CARB Compliant Containers. Offer incentives for consumers to turn in old gas cans and obtain new

ones. Yes No Yes - Yes No No No creditable emission reduction

A 36 Enhanced Enforcement of Area Source Regs: Open Burning Enhance enforcement of seasonal open burning restrictions. Yes Yes Yes - Yes No No No creditable emission reductions

A 37 Enhanced Enforcement of Area Source Regs: Solvent Cleaning Enhance enforcement of surface cleaning rules. Yes Yes Yes - Yes No No No creditable emission reductions

A 38 Mitigation Fees: Preempted Sources Charge emission mitigation fee to federally preempted sources. No - Yes - Yes - No Will not provide reductions by

May 2008

Page 6 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

A 39 Pesticide Application: Best Practices Establish best practices for pesticide application. Yes - Yes - No - No No creditable emission reduction

A 40 Control Bakeries Adopt SCAQMD Rule 1153: Commercial Bakery Ovens. Reduce exemption level and set standards for unregulated bakeries. No Yes Yes No No No No Will not provide reductions by

May 2008

A 41 Government Actions (Air Quality Action day similar to snow day) Implement a liberal leave policy for local, state and federal employees on Air Quality Action Days, permitting employees to work from home or take unscheduled leave. Yes No Yes Yes Yes Yes No No creditable emission reduction

A 42 Clean Air Partners: Public Outreach and Education Implement Strategic Communication Campaigns to Increase Public Awareness (target lawnmowers, paints, refueling). Yes No Yes Yes Yes Yes No No creditable emission reduction

A 43 Local Government Education Campaign Encourage local governments to adopt Air Quality Action Day policies (target lawnmowers, paints, refueling). Yes No Yes Yes Yes Yes No No creditable emission reduction

A 44 Mass Marketing Campaign Marketing effort involving business-to-business advertising campaign in print media and on world wide web. Yes No Yes Yes Yes Yes No No creditable emission reduction

A 45 Public Outreach and Education: Fueling Educate to improve fueling practices. Yes No Yes Yes Yes Yes No No creditable emission reduction

A 46 Public Outreach and Education: Sources Public Education on NOx and ROG sources in Schools and Small Businesses. Yes No Yes Yes Yes Yes No No creditable emission reduction

A 47 Episodic limits on asphalt paving and traffic marking activities Prohibit road paving and traffic marking on Air Quality Action days. Yes Yes Yes Yes Yes - No No creditable emission reduction

A 48 No Fuel Policy on Air Quality Action Days Voluntary reduction in fueling activities on Air Quality Action Days. Yes No Yes Yes No - No No creditable emission reduction

A 49 Episodic Pesticide Application Ban Ban pesticide application on Code Red Air Quality Action Days. Yes - Yes - No - No Adverse impacts

A 50 Episodic Voluntary Pesticide Application Reduction Encourage voluntary restrictions on pesticide application on Code Red Air Quality Action Days. Yes - Yes - No - No Adverse impacts

A 51 Clean Air Partners: Air Quality Action Days Take a variety of actions on Air Quality Action Days to reduce emissions and improve air quality (target lawnmowers, paints, refueling). Yes No Yes Yes Yes Yes No No creditable emission reduction

Non-road Sources

Page 7 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

N 1 Clean Air Construction Initiative: Road Construction Projects Develop alternative programs for state and local governments (public entities) to reduce on-road and off-road construction and maintenance related emissions. Episodic: no work or idling restrictions. Non-episodic: Control retrofits. Yes No Yes - - Yes No No creditable emission reduction

N 2 Clean Air Construction Initiative: Off-Road Construction Projects Develop alternative programs for state and local governments (public entities) to reduce on-road and off-road construction and maintenance related emissions. Episodic: no work or idling restrictions. Non-episodic: Control retrofits. Yes No Yes - - Yes No No creditable emission reduction

N 3 Clean Air Maintenance Initiative: Road Maintenance Contracts Develop alternative programs for state and local governments (public entities) to reduce on-road and off-road construction and maintenance related emissions. Episodic: no work or idling restrictions. Non-episodic: Control retrofits. Yes No Yes - - Yes No No creditable emission reduction

N 4 Clean Air Construction Initiative: Preference for Low-emissions Industrial Equipment In bids for government contracts, award extra points to bidders using low-emission industrial equipment. Yes No Yes - - Yes No No creditable emission reduction

N 5 Control Construction Emissions Limitations and Fleet Rules for Construction Equipment. No Yes - No No Yes No Not economically feasible

N 6 Non-Road Diesel Engine Retrofit Program: Voluntary Develop voluntary program encouraging retrofit of non-road diesel equipment in public and/or private fleets. Yes No Yes - Yes Yes No No creditable emission reduction

N 7 Non-Road Diesel Engine Retrofit Program: Mandatory Develop mandatory program requiring retrofit of non-road diesel equipment in public and/or private fleets. No Yes Yes - - Yes No Will not provide reductions by

May 2008

N 8 Retrofit/Repower Locomotives Provide financial incentives to retrofit or repower locomotives operating in the nonattainment area for cleaner burning diesel or alternative fuels. Yes No - - Yes - No No creditable emission reduction

N 9 Locomotive Idling Reduction Support Installation of Idling Reduction Technologies on Locomotives. Yes No Yes - Yes - No No creditable emission reduction

N 10 Control Off-Road Diesel Engines (smoke test) Implement mandatory smoke testing program for heavy-duty (>50 hp) off-road diesel engines. No Yes Yes No Yes - No Will not provide reductions by

May 2008

Page 8 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

N 11 Airport Emission Cap Establish Agreement with Airports Authority to Cap or Reduce Emissions. Yes No - - Yes Yes No No creditable emission reduction

N 12 Airport Emissions Cap in Upwind Counties Voluntary Agreement to Cap Airport Emissions Outside the Nonattainment Area. Yes No - - Yes Yes No No creditable emission reduction
N 13 Airport Electric GSE Subsidize adoption of electric ground service equipment. Yes Yes Yes Yes Yes Yes No Will not advance attainment date
N 14 Airport GSE Retrofits Subsidize the retrofit of airport ground service equipment. Yes Yes Yes Yes Yes Yes No Will not advance attainment date

N 15 Airport GSE Idling Controls Develop voluntary program to encourage operators to limit idling of airport ground service equipment. Yes Yes Yes Yes Yes Yes No Will not advance attainment date

N 16 Airport APU Initiatives Seek voluntary agreement to reduce use of aircraft APUs through use of gate-provided services or other strategies Yes Yes Yes Yes Yes Yes No Will not advance attainment date

N 17 Locomotive Engine Standards Encourage new federal locomotive engine emission standards (EPA 2012) No - - - Yes Yes No Will not provide reductions by

May 2008

N 18 Marine Diesel Engine Standards Encourage new federal marine engine emission standards (EPA 2012). No - - - Yes Yes No Will not provide reductions by

May 2008

N 19 Control Off-Road Diesel Engines (Blue Sky) Encourage the use of engines that are included in EPA’s voluntary “Blue Sky Series” engine program. Yes No Yes - Yes - No No creditable emission reductions

N 20 Control Spark Ignition Engines Retrofit controls and 3-way catalyst for spark ignition engines. - Yes - - Yes - No No creditable emission reductions

N 21 Industrial Equipment Replacement Subsidize replacement of fossilfuel fired industrial equipment with electric industrial equipment. Yes No - - No - No No creditable emission reductions

N 22 Light Commercial Equipment Retrofits Require light commercial equipment to be retrofitted with emissions controls. No No - No - - No Not economically feasible

N 23 Control Light Commercial Equipment Retrofit portable engines and generators. No No - No Yes - No Not economically feasible

N 24 Recreational Equipment Retrofits Require recreational equipment to be retrofitted with particulate fitlers and/or oxidation catalysts. No Yes - - - - No Not economically feasible

N 25 Control Recreational Marine Emissions Provide incentives for newer boats and engines. Yes No Yes No Yes - No No creditable emission reductions

N 26 Idling Restrictions for Lawn & Garden Equipment Limit idling by commercial lawn & garden equipment. No No Yes No - - No Not enforceable

Page 9 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

N 27 Agricultural Equipment Retrofits Require agricultural equipment to be retrofitted with emissions controls. No Yes - - - - No Will not provide reductions by

May 2008

N 28 Agricultural Equipment Use Restrictions Ban use of agricultural equipment on Air Quality Action Days. Yes No Yes No No - No Not feasible

N 29 Low-emissions Agricultural Equipment Require sale of low-emissions agricultural equipment in region. No Yes - No No - No Will not provide reductions by

May 2008

N 30 Industrial Equipment Retrofits Require industrial equipment to be retrofitted with emissions controls. No Yes - - No - No Will not provide reductions by

May 2008

N 31 Low-emissions Commercial and Industrial Equipment Require sale of low-emissions commercial and industrial equipment in region. No Yes - - - Yes No Will not provide reductions by

May 2008

N 32 Idling Restrictions for Commercial and Industrial Equipment Limit idling by commercial and industrial equipment. No No Yes No Yes Yes No Not economically feasible

N 33 Control Light Commercial Equipment Require zero emission forklifts where feasible. No No - No Yes No No Not economically feasible

N 34 Control Commercial Marine Sources Tug/Push Boat Activity Reductions. No Yes Yes No No - No Potential adverse impacts

N 35 Biodiesel for Off-Road Equipment Increase use of biodiesel in offroad diesel equipment during

ozone season. Yes No - - - - No No creditable emission reduction

N 36 High Cetane Fuel Require High Cetane Diesel Fuel for Off-road Vehicles. No Yes Yes No Yes - No Will not provide reductions by

May 2008

N 37 Require low-NOx fuel for recreational equipment Require recreational equipment to use low-NOx fuel additives during

ozone season. Yes Yes Yes Yes - - No Will not advance attainment date

N 38 Low-NOx Fuel for Lawn & Garden Equipment Require diesel-fired lawn & garden equipment to use low-NOx fuel additives during ozone

season. No No - No Yes - No No creditable emission reduction

N 39 Low-NOx Fuel for Recreational Marine Equipment Require diesel-fired recreational marine equipment to use low-NOx fuel additives during ozone

season. Yes Yes Yes Yes Yes - No No creditable emission reduction

N 40 Require Low-NOx Fuel for Airport GSE Require airport GSE to use lowNOx fuel additives during ozone

season. Yes Yes Yes Yes Yes - No No creditable emission reduction

N 41 Require Low-NOx Fuel for Industrial Equipment Require industrial equipment to use low-NOx fuel additives during

ozone season. Yes Yes Yes Yes Yes - No No creditable emission reduction

N 42 Require Low-NOx Fuel for Light Commercial Equipment Require light commercial equipment to use low-NOx fuel during ozone season, if applicable. Yes Yes Yes Yes Yes - No No creditable emission reduction

Page 10 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

N 43 Episodic Low-NOx Fuel for Construction Equipment Require diesel-fired construction equipment operating in region to use low-NOx fuel additives during

ozone season. Yes Yes Yes Yes Yes - No No creditable emission reduction

N 44 Episodic Low-NOx Fuel for Construction Equipment Require diesel-fired construction equipment operating on state or local government contracts to use low-NOx fuel additives during

ozone season. Yes Yes Yes Yes Yes - No No creditable emission reduction

N 45 Episodic Low-NOx Fuel for Construction Equipment Voluntary use of low-NOx fuel additives by diesel-fired construction equipment during

ozone season. Yes Yes Yes Yes Yes - No No creditable emission reduction

N 46 Control Recreational Equipment Emissions Increase registration fee on recreational vehicles (dedicate fee to clean air fund). No Yes Yes No Yes - No Not economically feasible

N 47 Control Upwind Port Emissions Emission Fee Program for PortRelated Mobile Sources No Yes Yes - Yes - No No creditable emission reductions

N 48 Graduated registration fees for recreational boats Levee additional registration fee for registration of boats with old, high-emission engines. No Yes Yes No - - No Will not provide reductions by

May 2008

N 49 Airport Congestion Pricing Charge higher aircraft landing fees during busy times of day to reduce airport delays and congestion. No Yes Yes No Yes Yes No Not economically feasible

N 50 Gas Tax Increase Implement a fuel tax on off-road gasoline. No Yes Yes No - - No Not economically feasible

N 51 Diesel Tax Increase Implement a fuel tax on off-road diesel. No Yes Yes No - - No Not economically feasible

N 52 Episodic Restrictions on Lawn & Garden Equipment (mandatory) Restrict use of lawn and garden equipment during Air Quality Action days. No - Yes - No Yes No No creditable emission reduction

N 53 Episodic Restrictions on Recreational Equipment Use (mandatory) Restrict use of recreational equipment during Air Quality Action days. No - Yes - No Yes No No creditable emission reduction

N 54 Episodic Restrictions on Use of Commercial and Industrial Equipment (mandatory) Restrict use of commercial and industrial equipment during Air Quality Action Days. No - Yes - No Yes No No creditable emission reduction

N 55 Episodic Commercial Lawn & Garden Equipment Use Restrictions (voluntary) Encourage restricted use of commercial lawn and garden equipment on Air Quality Action Days. Yes No Yes - Yes Yes No No creditable emission reduction

N 56 Episodic Residential Lawn & Garden Equipment Use Restrictions (voluntary) Encourage restricted use of residential lawn & garden equipment on Air Quality Action Days. Yes No Yes - Yes Yes No No creditable emission reduction

Page 11 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

N 57 Episodic Commercial and Industrial Equipment Use Restrictions (voluntary) Encourage restricted use of commercial and industrial equipment during Air Quality Action Days. Yes No Yes - Yes Yes No No creditable emission reduction

N 58 Episodic No Mow Policy on Code Red Days (voluntary) Voluntary reduction in mowing on Code Red Days. Yes No Yes - Yes Yes No No creditable emission reduction

N 59 Episodic Recreational Marine Equipment Use Restrictions (mandatory) Ban use of recreational marine equipment on Code Red Air Quality Action Days. Yes Yes Yes No No - No Potential adverse impacts

N 60 Episodic Recreational Marine Equipment Use Restrictions (voluntary) Encourage restricted use of all recreational marine equipment on Air Quality Action Days. Yes No Yes Yes Yes - No Will not advance attainment date

N 61 Episodic Recreational Marine Idling Restrictions (mandatory) Ban idling by recreational marine equipment on Code Red Air Quality Action Days. Yes Yes Yes No Yes - No Will not advance attainment date

N 62 Episodic Recreational Marine Idling Restrictions (voluntary) Encourage reduced idling by recreational marine equipment on Air Quality Action Days. No No Yes No Yes - No No creditable emission reductions

N 63 Episodic Recreational Marine Idling Restrictions (mandatory) Ban idling by recreational marine equipment during ozone season. Yes Yes Yes No Yes - No Will not advance attainment date

N 64 Recreational Marine Idling Restrictions Ban idling by recreational marine equipment year-round. Yes Yes Yes No Yes - No Will not advance attainment date

N 65 "Cash for Clunkers" 2-cycle Engines Implement a 2-cycle Engine Replacement Program. Yes No Yes No Yes - No No creditable emission reductions

N 66 "Cash for Clunkers" Lawn & Garden Equipment Offer cash for consumers to turn in lawnmowers or lawn tractors and purchase electric or push

mowers. Yes No Yes No Yes - No No creditable emission reductions

N 67 "Cash for Clunkers" Outboard Motors Offer cash for consumers to turn in old outboard motors and purchase new ones. Yes No Yes No Yes - No No creditable emission reductions

N 68 "Cash for Clunkers" Recreational Equipment Program Offer small cash reward forowners to turn in old, highemission recreational equipment. Yes No Yes No Yes - No No creditable emission reductions

N 69 Control Emissions from Lawn and Garden Equipment (xeriscaping) Adopt measures to reduce lawn area and mower usage. Xeriscaping. Yes No Yes Yes Yes - No No creditable emission reductions

N 70 Agricultural Equipment Use Restrictions (voluntary) Voluntary moratorium on use of agricultural equipment on Air Quality Action Days. Yes No Yes No Yes - No No creditable emission reductions

N 71 Low Maintenance Landscape Initiative "Lawn Care for Cleaner Air": increase use of low maintenance landscapes. Yes No Yes Yes Yes - No No creditable emission reduction Mobile Sources

M 1 Voluntary Diesel Retrofit Program: Local Vehicles Retrofit diesel local vehicles. Yes No Yes - Yes - No No creditable emission reduction

Page 12 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 2 Voluntary Diesel Retrofit Program: Commercial Vehicles Retrofit diesel commercial vehicles. Yes No Yes - Yes - No No creditable emission reduction

M 3 Low-emission Vehicle Purchase Program: Buses Accelerate adoption of lowemission vehicles. Consider hydrid and CNG buses. Yes No Yes - Yes - No No creditable emission reduction

M 4 Low-emission Vehicle Purchase Program: Refuse Haulers Accelerate Adoption of Lowemission Vehicles. Consider CNG refuse haulers instead of new diesel. Yes No Yes - Yes - No No creditable emission reduction

M 5 Voluntary Diesel Retrofit Program: School Buses Retrofit diesel school buses. Yes No Yes - Yes - No No creditable emission reduction

M 6 Voluntary Diesel Retrofit Program: State Vehicles Retrofit diesel state vehicles. Yes No Yes - Yes - No No creditable emission reduction

M 7 Voluntary Diesel Retrofit Program: International Green Diesel Retrofit Fit transit buses running on ultralow sulfur diesel with a quadcatalytic filter. Yes No Yes - Yes - No No creditable emission reduction

M 8 Low-emission Vehicle Purchase Program: State and Local Fleets Accelerate adoption of lowemission vehicles, including hybrids. Focus on state and local fleets. Yes No Yes Yes Yes - No Not enforceable

M 9 Low-emission Vehicle Purchase Program: Private Owners Fleet Accelerate adoption of lowemission vehicles. Consider use of tax incentives. Yes No Yes - Yes - No Not enforceable

M 10 Electric Vehicle Tax Incentives Establish incentives to purchase electric vehicles. Yes No Yes - Yes - No Not enforceable

M 11 Low-emission Vehicle Purchase Program: Rental Cars Accelerate Adoption of Lowemission Vehicles. Target rental car fleets. Yes No Yes - Yes - No No creditable emission reduction

M 12 Low-emission Vehicle Purchase Program: Taxicabs Accelerate Adoption of Lowemission Vehicles. Target taxicab fleets. Yes No Yes - Yes - No No creditable emission reduction

M 13 OTC Corridor Strategy Implement truck stopelectrification projects and HeavyDuty Engine Engine Control Module (ECM) Recalibration (chip reflash) along the I-95 corridor. Yes No Yes - Yes - No No creditable emission reduction

M 14 Truck Idling Reduction: Truck Stop Electrification (TSE) Implement projects to electrify truck stops. Yes No Yes - Yes - No No creditable emission reduction

M 15 Truck Idling Reduction: Auxilliary Power Units (APU) Increase market penetration of APUs to reduce truck idling. Yes No Yes Yes Yes - No No creditable emission reduction

M 16 Control Bus Emissions Provide electrified parking spaces or APUs for tour buses. Yes No - - Yes - No No creditable emission reductions

Page 13 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 17 Smart Growth and Infill Development Programs Encourage development/redevelopment of land in designated growth areas, encouraging local governments to place greater emphasis on land development near transit stations. Yes No Yes - Yes No No No creditable emission reductions

M 18 Incentives for Mixed Use at Transit Centers Include incentives for mixed-use development at transit centers to reduce sprawl and VMT. No Yes Yes - Yes Yes No Will not provide reductions by

May 2008

M 19 Infill Development Implement an infill development program throughout the Washington region. No No Yes - Yes - No Will not provide reductions by

May 2008

M 20 Convenience Commercial Centers in Residential Areas Change zoning ordinances to allow neigborhood-serving retail establishments in residential

areas. No Yes Yes - No - No Will not provide reductions by

May 2008

M 21 Control Growth and Development Encourage mixed-use development. Yes No Yes - Yes Yes No No creditable emission reductions

M 22 Proximity Commute: Job Swap Encourage employees of the same firm to swap jobs, permitting each to work at a location closer to home. Yes No Yes - Yes - No No creditable emission reductions

M 23 Proximity Commute: Live Near Your Work Provides financial incentives to homebuyers moving to designated neighborhoods near their workplaces. Yes No Yes - Yes - No No creditable emission reductions

M 24 Telecommuting Centers and Telework Program Telecommuting centers, including marketing activity, consultant support, commuter and employer information and assistance. Yes No Yes - Yes - No No creditable emission reductions

M 25 Telecourses at Local Colleges and Universities Encourage local colleges and universities to offer telecourses to reduce vehicle trips. Yes No Yes - Yes - No No creditable emission reductions

M 26 Safe Routes to School Program Implement a safe pedestrian and bicycle routes to school program to reduce VMT. - No Yes - Yes No No No creditable emission reduction

M 27 Commuter Operations Center Provides commuter assistance services, including carpool and vanpool ridematching. Yes No Yes - Yes - No No creditable emission reductions

M 28 Guaranteed Ride Home Provides free rides home in event of unexpected emergency or unscheduled overtime to commuters using public transport. Yes No Yes - Yes - No No creditable emission reductions

M 29 Access to Jobs Program Identifies gaps in transit service between places of residence and places of work for low wage workers. - No Yes - Yes No No No creditable emission reduction

Page 14 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 30 Integrated Rideshare Provides transit, park & ride, and telecenter information to all commuters on a matchlist. Yes No Yes - Yes - No No creditable emission reductions

M 31 Interactive Rideshare Kiosks Transportation Information Kiosks in Maryland, Virginia and the District of Columbia. Yes No Yes - Yes - No No creditable emission reductions

M 32 Vanpool Programs Create programs and incentives designed to increase the number of vanpools in the region. Yes - Yes - Yes Yes No No creditable emission reduction

M 33 Free Parking for Carpools/Vanpools Provide free reserved parking spaces for all carpools or vanpools. Yes No Yes No Yes - No No creditable emission reductions

M 34 Employer Metro Shuttle Bus Services Provide incentives for businesses to provide employee shuttle service to the nearest rail or transit stop. Yes No Yes - Yes - No No creditable emission reduction

M 35 Improvements to Bicycle and Pedestrian Access Provide incentives to developments that speed improvements to bicycle/pedestrian access. This includes improvements to sidewalks, curb ramps, crosswalks, lighting, etc. - No Yes - Yes No No No creditable emission reduction

M 36 Bicycle Racks in DC Install bicycle racks at various locations throughout the region. Yes No Yes - Yes No No No creditable emission reductions

M 37 Bike Lockers at Metro Stations, Park & Ride Lots, Other Locations Expand existing bike lockers at Metrorail stations, install bicycle storage spaces in parking lots. Yes No Yes - Yes No No No creditable emission reduction

M 38 Bike Racks on Transit Buses Provide external bike racks on WMATA and other local transit buses. Yes No Yes - Yes No No No creditable emission reduction

M 39 Bike to Work Day Conduct a one-day bike to work event. Provide outreach activities, education on the bike-to-work option, and assistance in trying bike-to-work. Yes No Yes - Yes No No No creditable emission reduction

M 40 Bike/Pedestrian Paths Fund construction of additional bicycle/pedestrian paths in the region. No No Yes - Yes No No No creditable emission reduction

M 41 Employers Provide Free Bicycles for Midday Use Require employers to provide onebicycle per 50 employees for midday business or personal use. Yes No Yes - Yes No No No creditable emission reduction

M 42 Car Sharing Program Fund incentives for new car sharing customers (i.e., Flexcar or Zipcar services). Yes No Yes - Yes No No No creditable emission reduction

M 43 Vehicle Share Programs: Transit Stations Develop a transit station car/low emission vehicle share program. Yes No Yes - Yes No No No creditable emission reduction

Page 15 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 44 Vehicle Share Programs: Neighborhoods Implement a neighborhood electri c vehicle share program. Yes No Yes - Yes No No No creditable emission reduction

M 45 Clean Commute/Try Transit Week Promotes use of alternative transportation, including transit, by daily commuters for one week per year. Yes No Yes - Yes - No No creditable emission reductions

M 46 Student & staff based college & university rideshare programs Create rideshare program focused on students and staff at regional universities. Yes No Yes - Yes No No No creditable emission reduction

M 47 Establish Restricted Zones in Downtown Areas and Transit Centers Restrict private vehicle use in certain areas during business hours, encouraging pedestrian, bicycle, and transit use. No Yes Yes - No Yes No Will not provide reductions by

May 2008

M 48 4 Day Work Week/Flexible Work Schedules Encourage employers to adopt a shorter work week, with employees working 4 10-hour days. Yes No Yes - Yes - No No creditable emission reductions

M 49 Expand Peak Period Metrorail Service Extend peak-period service on Metrorail so trains run more frequently between 6-11 am and 3

- 8 pm. No No - - Yes - No Will not provide reductions by

May 2008

M 50 Expand VRE Train Service Expand VRE train service to include additional departures. No No - - Yes - No Will not provide reductions by

May 2008

M 51 Support Rail to Dulles and BWI Airports Provide funding to expand metro rail services to Dulles and BWI airports. No No Yes - Yes - No Will not provide reductions by

May 2008

M 52 Increase Commuter Rail Frequency Increase frequency of MARC service to every 15 minutes on Penn and Camden lines and every 10 min on the Brunswich line. Increase VRE frequency to every 15 minutes. No No - - Yes - No Will not provide reductions by

May 2008

M 53 Provide Additional Transit Service to Core Increase funding for transit services to expand core service. No No - - Yes - No Will not provide reductions by

May 2008

M 54 Provide Additional Transit Service Access Increase funding for enhancing access to transit services. Yes No Yes - Yes No No No creditable emission reductions

M 55 Regional Bus Service Expansion Expansion of Metrobus and other regional bus services. No No Yes - Yes - No Will not provide reductions by

May 2008

M 56 Express Buses From Outyling Areas Implement direct bus service from outlying Park & Ride lots and far suburbs to major work centers. Yes No Yes - Yes - No No creditable emission reductions

M 57 Express Reverse Commuter Buses Implement reverse commute express buses from the District to major outlying work centers. Yes No Yes - Yes - No No creditable emission reductions

M 58 New Surface Parking at Transit Centers Add new parking spaces at transit centers (bus, Metrorail, MARC, VRE) parking lots. No No Yes - Yes No No No creditable emission reductions

Page 16 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 59 Build Park & Ride Lots at Major Intersections of Commuter Highways Construct new park & ride commuter lots along HOV facilities. Yes Yes Yes - Yes - No No creditable emission reductions

M 60 Shorter Distance from Buildings to Bus Stops For existing buildings, re-route traffic to allow buses to come closer to the building. For new buildings, alter setback requirements to allow closer bus

access. No No - - Yes - No No creditable emission reductions

M 61 New MARC Coaches Purchase additional coaches for MARC to accommodate increased ridership. No No Yes - Yes - No Will not provide reductions by

May 2008

M 62 Additional Transit Stores Establish additional stationary transit stores in the region. Yes No Yes - Yes No No No creditable emission reductions

M 63 ATM Machines Installed at Metro Stations Install ATMs near metro stations for rider convenience. Yes No Yes - Yes - No No creditable emission reductions

M 64 Traffic Signal Optimization Regularly optimize traffic signals to reduce idling and low-speed emissions. Yes Yes Yes - Yes - No No creditable emission reductions

M 65 Transit Prioritization -- Queue Jumps Provide queue jumps for buses at over-capacity signalized intersections throughout the region. Queue jumps allow buses to use a shoulder or other designated lane to bypass intersection queues and move forward towards the stop line. Yes No Yes - Yes No No No creditable emission reductions

M 66 Manage Roadway Usage: Traffic Incident Management Regional Travel Information System/Driver Assistance. Enhance real time traffic information to allow drivers to make better decisions about when and where to travel. - No - - Yes - No No creditable emission reductions

M 67 Replace Traffic Signals with Lesser Controls Install roundabouts in place of signals at low volume intersections. No Yes Yes - Yes - No Will not provide reductions by

May 2008

M 68 Signals to Flashing Yellow 12am-5am From midnight until 5am, set intersection signals to flashing yellow in predominant direction and flashing red in minor direction for all low volume intersections where safety permits. Yes Yes Yes - Yes - No No creditable emission reductions

M 69 Extend Ramp Metering Install signals to control flow of vehicles at selected freeway ramp entrances to maintain level of service. Yes Yes Yes - - No No No creditable emission reductions

M 70 Expand HOV Network on the Freeway System Construct additional HOV lanes on regional freeways. No - Yes - Yes - No Will not provide reductions by

May 2008

Page 17 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 71 Manage Roadway Usage: Dedicated Bus Lanes Dedicate roadway lanes for use by buses. No Yes Yes - No - No Potential adverse impacts

M 72 Value Pricing (HOT lanes) Implement value pricing strategies on busy freeways during rush hour. No Yes Yes - - - No Will not provide reductions by

May 2008

M 73 Green Curb Initiative Restricted Access/ “Green Curb”. Differential fees and access permits applied during periods of high congestion. Target delivery/loading zones and carpool/vanpool pickup areas. No Yes Yes - - No No Will not provide reductions by

May 2008

M 74 Congestion Pricing on Low Occupancy Vehicles Impose a fee on vehicles containing two or fewer persons that use designated roadways, tunnels, and bridges during the peak AM periods. No Yes Yes - - - No Will not provide reductions by

May 2008

M 75 Establish Clean Air Fund Sell Clean Air License Plates to fund air quality programs (similar to “Save the Bay” tags). No Yes Yes Yes Yes - No Will not provide reductions by

May 2008

M 76 Electronic Tolling Expand interoperability of electronic tolling systems. Yes Yes Yes - Yes - No No creditable emission reductions

M 77 Annual Gasoline Vehicle Pollution Fee Levy an annual fee on petroleumpowered vehicles based on mileage driven and emission rates (odometer tax). No Yes - - - - No Will not provide reductions by

May 2008

M 78 VMT-Based Car Tax Charge VMT fee for all vehicles registered or garaged in the region. No Yes - - - - No Will not provide reductions by

May 2008

M 79 Graduated Car Tax: Additional Vehicles Charge higher car tax on each additional vehicle registered by a household. No Yes Yes - - - No Will not provide reductions by

May 2008

M 80 Graduated Car Tax: Miles Per Gallon Charge graduated car taxes based on a vehicle's EPA miles per gallon rating. No - - - - - No Will not provide reductions by

May 2008

M 81 Graduated Car Tax: Petroleum-Based Vehicles only Implement region-wide car tax for petroleum-fueled vehicles. No Yes Yes - - - No Will not provide reductions by

May 2008

M 82 Graduated Vehicle Registration Fee Based on Number of Vehicles Assess graduated vehicle registration fee/car tax on every privately owned vehicle in the region. Households with multiple vehicles pay higher tax on each additional vehicle. No Yes - - - - No Will not provide reductions by

May 2008

M 83 Pay-as-you-drive auto insurance ($/gal) Offer auto insurance rates linked to number of gallons of fuel consumed by vehicle. No Yes - - - - No Will not provide reductions by

May 2008

Page 18 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 84 Mobile Source Mitigation Fees: Vehicle Garage Collect a fee from each homeowner with a vehicle garage. No Yes - - - - No Will not provide reductions by

May 2008

M 85 Mobile Source Mitigation Fees: Ozone Season VMT Surcharge Require a surcharge to be paid by drivers during the summer season based on the number of driving miles. No Yes - - - - No Will not provide reductions by

May 2008

M 86 Area Pricing: Entry Fees Collect fees from drivers to enter a pre-defined area. No Yes Yes - - - No Will not provide reductions by

May 2008

M 87 Gas Tax Increase Implement a fuel tax on on-road gasoline. No Yes Yes - No - No Will not provide reductions by

May 2008

M 88 Diesel Tax Increase Implement a fuel tax on on-road diesel. No Yes Yes - No - No Will not provide reductions by

May 2008

M 89 Commuter Parking Tax: Employees Implement daily tax on employees using commuter parking spaces. No No Yes No No - No Will not provide reductions by

May 2008

M 90 Commuter Parking Tax: Employers with No Discounted Commuter Parking Spaces Implement daily tax on employers providing free or discounted commuter parking spaces. No No Yes No No - No Will not provide reductions by

May 2008

M 91 Commuter Parking Tax: Employers with No Transit Benefits Implement daily tax on employers who do not provide transit benefits to employees. No Yes Yes No No - No Potential adverse impacts

M 92 Market Based Parking Charge at Federal Facilities Negotiate agreement with federal government to charge market rate for daily parking for all employees. No No Yes - Yes - No Will not provide reductions by

May 2008

M 93 Parking Impact Fee: All Parking Levy annual impact fee on every parking space in nonattainment

area. No No Yes - No - No Will not provide reductions by

May 2008

M 94 Parking Impact Fee: Commuter Parking Levy an annual fee on every commuter parking space in the Washington nonattainment area. No No Yes No No - No Will not provide reductions by

May 2008

M 95 Tax Parking Spaces Above Code Minimum Discourage developers from providing parking in excess of code minimum by imposing a graduated tax on excess spaces. No No Yes No No - No Will not provide reductions by

May 2008

M 96 Episodic Parking Fee Increases Increase fees for parking garages and meter during episodes. No No Yes No No - No Will not provide reductions by

May 2008

M 97 Universal Transportation Access SmarTrip card will allow users to pay fares on all rail and bus systems in the region (including parking in Metrorail lots) using one electronic card. - No - - Yes - No Will not provide reductions by

May 2008

M 98 Commuter Choice - State & Local Government Employees Provide the region's local, state and municipal employees with transit benefits. Yes No Yes - Yes - No No creditable emission reductions

Page 19 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 99 Reduce Parking Fees at Facilities Outside the Beltway Adjacent to Metro Reduce parking fees at Metro parking facilities or county/city managed facilities outside of the Beltway that are located near Metro stations. Yes No Yes No Yes No No No creditable emission reductions

M 100 Metrorail Feeder Bus Service & Fare Buydown Improve Metrorail feeder bus service at underutilized park & ride lots, implement fare buydown program. Yes No Yes - Yes No No No creditable emission reduction

M 101 Flat Fare For All Transit Trips Single price all public transit services with free transfers all day, 7 days per week. - No - - Yes - No Will not provide reductions by

May 2008
M 102 Subsidize Transit Usage Expand MetroChek to all public sector employees Yes No Yes - Yes - No Will not advance attainment date

M 103 Free Bus Service Off-Peak Institute free off-peak bus service from 10-2 on weekdays and all day on weekends. - No Yes - Yes - No Will not provide reductions by

May 2008

M 104 Free bus-to-rail / rail-to-bus transfers Institute free bus-to-rail transfer similar to free rail-to-bus transfer currently in place. - No Yes - Yes - No Will not provide reductions by

May 2008

M 105 Free Rail Use 10-3 Free Metrorail trips for all riders from 10AM-3PM on weekdays. - No Yes - Yes - No Will not provide reductions by

May 2008

M 106 Employer Parking CashOut: Voluntary Implement voluntary program encouraging employers to provide the value of subsidized parking to employees who use alternative commute strategies. Yes No Yes - No - No No creditable emission reductions

M 107 Free Transit Passes to Students Free transit passes for high school and college students, subsidized by schools or through student registration fee. - No Yes - Yes - No Will not provide reductions by

May 2008

M 108 Half Price Fares on Feeder Bus Service All metro bus and local bus services to Metrorail and commuter rail stations reduce fares by half. - No Yes - Yes - No Will not provide reductions by

May 2008

M 109 College 33 Pass System Expand Baltimore college bus fare program to DC area. Program allows students to receive reduced fares near 19 participating schools in the region. Yes No Yes - Yes - No Will not advance attainment date

M 110 Discount Multi-Trip Bus Fares Introduce discount programs reducing cost of multiple bus rides through purchase of pass books (e.g. 10-trip tickets). Yes No Yes - Yes - No Will not advance attainment date

M 111 Vanpool Insurance Establish a special risk pool to underwrite the cost of vanpool insurance. Yes No Yes - Yes - No No creditable emission reduction

Page 20 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 112 Commuter Choice Tax Credit Employers subsidize employees' monthly transit or vanpool costs and receive a tax credit for incurred expenses. Yes No Yes - Yes - No No creditable emission reductions

M 113 Rebate for Purchase of Hybrid Vehicles Issue rebate for purchase and registration of hybrid vehicles. Yes No Yes - Yes - No No creditable emission reduction

M 114 Real-Time Bus Schedule Information Expand trials of real-time bus schedule information to local transit providers. Yes No Yes - Yes No No No creditable emission reductions

M 115 Automatic Bus Locator System System would provide bus location information to transit dispatchers. This would decrease wait time and improve on-time arrival/departure. Yes No Yes - Yes - No No creditable emission reductions

M 116 WMATA Bus Information Displays with Maps Install additional information boxes with maps and schedule information. Would include schedules in languages other than English in neighborhoods where most residents speak another language. Yes No Yes - Yes No No No creditable emission reductions

M 117 CAL LEV II Standards Adopt CAL LEV II Standards, which will require increased zero emission vehicles with marginal VOC and CO2 reductions in 2010. No Yes Yes - Yes - No Will not provide reductions by

May 2008

M 118 Expand Remote Sensing Program Expand the Adoption of a Remote Sensing Program to Maryland and the District of Columbia. No Yes Yes - Yes - No Will not provide reductions by

May 2008

M 119 Control Heavy Duty Diesel Engines Heavy-duty engine Engine Control Module (ECM) recalibration (chip reflash). Yes No Yes - Yes - No No creditable emission reduction

M 120 Zero I/M waivers and exemptions Eliminate all waivers and exemptions in the I/M program. No Yes Yes - - - No Will not provide reductions by

May 2008

M 121 Motorcycle I/M Program End the motorcycle smog check exemption. No Yes Yes - Yes - No Will not provide reductions by

May 2008

M 122 Diesel I/M Program Perform community-based inspections of trucks and buses. Yes No Yes No Yes - No No creditable emission reduction

M 123 Expand I/M Requirements to Upwind Counties Expand Inspection and Maintenance Requirements. No Yes Yes - Yes Yes No Will not provide reductions by

May 2008

M 124 Mandatory Diesel Retrofit Program: Public Fleets Require retrofit of on-road diesel vehicles in public fleets. No Yes Yes - Yes Yes No Will not provide reductions by

May 2008

M 125 Mandatory Diesel Retrofit Program: Private Fleets Require retrofit of on-road diesel vehicles in private fleets. No Yes Yes - Yes Yes No Will not provide reductions by

May 2008

Page 21 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 126 On-road Heavy-Duty Diesel Smoke Testing and I/M Program Implement a smoke testing and/or Inspection/Maintenance Program for on-road heavy-duty diesel engines. No Yes Yes - Yes No No Will not provide reductions by

May 2008

M 127 Clean Fuels Program: CNG Fueling Stations for DC Metro Region Build new modular CNG fueling stations. Yes No Yes - Yes - No No creditable emission reduction

M 128 Biodiesel Fuel Expand use of biodiesel fuel for on-road vehicles. Yes No Yes - Yes - No No creditable emission reduction

M 129 High Cetane Fuel Require high-Cetane diesel fuel for on-road vehicles. No Yes Yes No Yes - No Will not provide reductions by

May 2008

M 130 Low-NOx Diesel Fuel Require regional use of low-NOx fuel additives for on-road diesel vehicles No No - No Yes - No Will not provide reductions by

May 2008

M 131 Low-NOx On-Road Diesel Fuel in Ozone Season Require use of low-NOx additive in on-road diesel fuel during

ozone season. No No - No Yes - No Will not provide reductions by

May 2008

M 132 Low-NOx On-Road Diesel Fuel in Ozone Season Require use of low-NOx additive by state or local diesel vehicles during ozone season. No No - No Yes - No Will not provide reductions by

May 2008

M 133 Fuel Additives to Reduce Emissions Use emulsified diesel fuel in diesel burning heavy duty vehicles. Yes No - No Yes - No Not enforceable

M 134 CARB Diesel Fuel Implement CARB diesel fuel standards. No Yes Yes No Yes - No Will not provide reductions by

May 2008

M 135 Enhanced Enforcement: Bus and Truck Idling Step-up enforcement of existing regulations to prevent extended bus and truck idling. Yes No Yes - Yes No No No creditable emission reduction

M 136 Enhanced Enforcement: On

road Idling Increase enforcement of regional idling restrictions for on-road vehicles. Yes No Yes - Yes No No No creditable emission reduction

M 137 Enhanced Enforcement of Mobile Source Regulations Increase smoking vehicle enforcement. Yes No Yes - Yes No No No creditable emission reduction

M 138 Enhanced Enforcement: Speed Limits Increase speed limit enforcement so that more vehicles are traveling at or below the posted limit. Yes No Yes - Yes No No No creditable emission reduction

M 139 Control Vehicle Idling No Idling Rule – Restriction. Limits idling to 5 minutes for all non-commercial, consumer operated vehicles within the Washington NAA. Establish exemptions where required. No Yes Yes - Yes No No Will not provide reductions by

May 2008

M 140 Permit Right Turn on Red Reduce vehicle idling time by permitting right turn on red, where safety allows. Yes Yes Yes - Yes No No No creditable emission reductions

Page 22 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 141 Control Vehicle Speeds: Automated Enforcement Automate speed enforcement and lower the speed limit to 55 mph for heavy duty vehicles. No Yes Yes - Yes - No Will not provide reductions by

May 2008

M 142 Control Vehicle Speeds: Lower Limits Speed Limit Restriction: Regional speed limit of 55 mph on all roads which previously had posted speeds of greater than 55 mph. No Yes Yes - Yes Yes No Will not provide reductions by

May 2008

M 143 Clean Air Partners: Air Quality Action Days Take a variety of actions on Air Quality Action Days to reduce emissions and improve air quality (free transit, telework, carpool). Yes No Yes - Yes - No No creditable emission reductions

M 144 Government Actions (air quality action day similar to snow day) Implement a liberal leave policy for local, state and federal employees on Air Quality Action Days, permitting employees to work from home or take unscheduled leave. Yes No Yes - Yes - No No creditable emission reductions

M 145 Clean Air Partners: Public Outreach and Education Implement Strategic Communication Campaigns to Increase Public Awareness (reduce vehicle use). Yes No Yes - Yes - No No creditable emission reductions

M 146 Local Government Education Campaign Implement Strategic Communication Campaigns to Increase Local Government Air Quality Improvement Efforts (reduce vehicle use). Yes No Yes - Yes - No No creditable emission reductions

M 147 Mass Marketing Campaign Marketing effort involving business-to-business advertising campaign in print media and on world wide web. Yes No Yes - Yes - No No creditable emission reductions

M 148 "Cash for Clunkers" OnRoad Vehicles Fund voluntary program paying car owners to turn in old vehicles for scrappage. Target pre-1980 vehicles with minimal/no emissions control. Yes No Yes No Yes - No Not economically feasible

M 149 "Cash for Clunkers" Early Bus Engine Replacement Replaces high-polluting diesel engines in WMATA buses with new diesel engines. Yes No Yes No Yes - No Not economically feasible

M 150 "Cash for Clunkers" Taxicab Replacement - Conventional Vehicles Replace taxicabs with new "conventional" LDGVs. Yes No Yes No Yes - No Not economically feasible

M 151 "Cash for Clunkers" Gas Caps Program Provide free replacement gas caps to light- and medium-duty vehicle owners. Yes No Yes - Yes - No No creditable emission reduction

M 152 Control Delivery Truck Emissions Establish voluntary emission reduction program with delivery fleets. Yes No Yes - Yes - No No creditable emission reduction

M 153 Rush Hour Shift Shift Metrorail AM and PM rush hours to start 30 min earlier and end 30 min later. Yes No - - Yes - No No creditable emission reduction

Page 23 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 154 Mandatory Employee Commute Reduction Mandatory employer trip reduction to reduce employee vehicle trips. No No Yes No No - No Potential adverse impacts

M 155 Manage Roadway Usage: No Drive Days Odd/Even License Plate no Drive Days. Prohibit drivers from traveling during certain periods, based on vehicle tags or other easily identifiable criteria. Can be a permanent or episodic control. No Yes - - No Yes No Will not provide reductions by

May 2008

M 156 Transportation Funding Initiatives Require that Congestion Mitigation Air Quality (CMAQ) funds be used only for projects that improve air quality. No No Yes No Yes - No Will not provide reductions by

May 2008

M 157 Restrict Parking at Schools Restrict high school students from driving to and parking at high schools when bus service is available. Yes No Yes No No No No No creditable emission reduction

M 158 Restrict Construction of New Parking Restrict construction of new parking at employment centers based on distance from transit and urban core. No Yes Yes - No - No No creditable emission reduction

M 159 Eliminate or Restrict Airport Parking Eliminate airport parking and replace with alternative fuel shuttle buses. No No Yes - No - No Will not provide reductions by

May 2008

M 160 Employer Parking CashOut: Mandatory Implement program requiring employers to provide the value of subsidized parking to employees who use alternative commute strategies. No Yes Yes - No - No No creditable emission reductions

M 161 Remove Trash Trucks From Area Streets Reduce use of trash trucks through transport of trash by barge. - No - - Yes - No No creditable emission reductions

M 162 Increase Intermodal Transport Increase use of intermodal options for transporting goods. Yes No Yes Yes Yes - No No creditable emission reduction

M 163 Fleet ILEV for light-duty gasoline vehicles Require fleets operating in nonattainment area to be comprised of a percentage of Inherently Low Emission Vehicles (ILEV). No Yes Yes No No - No Will not provide reductions by

May 2008

M 164 Control Vehicle Technology Install systems on gasoline vehicles to reduce emissions (e.g., Bose high-speed centrifugal separation system). No - - - Yes - No Will not provide reductions by

May 2008

M 165 Control VOC Content of Automotive Products Windshield Wiper Fluid – lower VOC. Establish evaporative standards that are lower thanthose set by the EPA – 35 weightpercent VOC. No - - - Yes - No Will not provide reductions by

May 2008

Page 24 5/10/2007Table 7-1. Potential RACM MeasuresList # Measure DescriptionRACM: Implementation by May 2008?RACM: Enforceable?RACM: Technologically Feasible?RACM: Economically Feasible?RACM: No Adverse Impacts?RACM: Reductions >0.1tpd?RACM: Yes/No?RACM: Explanation

M 166 Gasoline Engine Retrofit Program Retrofit with 3-way catalysts on gasoline-burning heavy duty trucks that currently have 2-way catalysts or no catalysts. Yes No - - Yes No No No creditable emission reduction

M 167 Improve Truck Fleet Fuel Economy Encourage adoption of technologies that increase truck fleet fuel economy. Yes No - Yes Yes - No No creditable emission reduction Note: * Under discussion at IAQC.

Page 25 5/10/2007References

US EPA, “State Im plementation Pla n s; Gene ra l Pream ble f o r the Im ple m entation of Title I of the Clean Air Act Am endments of 1990”, (57 FR 13498), April 16, 1992.

US EPA Re gion VI, “Reasonably A v ailable Cont rol Measures (RACM) Analysis for the Dallas/Fort Worth Ozone Nona ttain m e nt Area”, Decem ber 2000.

Bay Area Air Quality Managem e nt District , Metropolitan Trans portation Comm ission and Association of Bay Area Governm e nts, “Bay Area 2001 Ozone Attainm e nt Plan,” October 24, 2001, Appendix C.

1 See d i scu s sion in “Approv al an d Pro m u l g a tio n of Air Qu ality Im p l e m en tat i o n Plan s; District o f Co lu m b ia, Marylan d

, Virg in ia; Po st 19 96 Rat e -of- Pr og ress Pl ans a n d One

- Ho ur Oz o n e A t t a i n m e nt D e m o n s tr atio ns; Fin a l Ru le (A pr il 17 , 200 3, 68 FR 191 06 ).

M W AQ C O z on e SI P 7

- 31 May 2 3

, 2 007MWAQC Ozone SIP May 23, 2007 8-1 8.0 MOBILE SOURCE CONFORMITY

In order to balance growth in metropolitan nonattainment regions and their expanding transportation systems with improving air quality, the Clean Air Act requires that transportation modifications in a nonattainment area must not impair progress made in air quality improvements. 1 EPA issued rules for transportation conformity in its Transportation Conformity rule on November 24, 1993 in the Federal Register. 2 The Transportation Conformity rule has been amended several times, in recent years to incorporate changes resulting from transportation legislation passed in 2005, and EPA guidance for implementing the 8-hour ozone and PM 2.5 national air quality standards. The rule provides guidance for performing a conformity determination, to assure that transportation modifications "conform" to air quality planning goals established in air quality SIP documents. With the exception of mobile source budgets identified for specific years, the summary of federal conformity requirements as included in the SIP is provided for information only and does not constitute a control measure or program. The requirements are subject to change and may be amended in future updates to federal, state and/or local regulations.

In general, to be found in "conformity" with ai r quality plans before the attainment plan is approved by EPA, the VOC, NOx, and carbon monoxide , and fine particle emissions generated by mobile sources when a transportation plan is implemented must meet certain emission tests:

• When a mobile source emissions budget SIP has been submitted and found adequate, mobile source emissions must not exceed the mobile emissions budgets established in the SIP;

• In 8-hour ozone areas that have approved 1-hour ozone SIPs, prior to adequate or approved 8-hour SIP budgets, the 1-hour budgets must be used for 8-hour conformity. 3

In 2005 federal transportation legislation, SAFETEA-LU 3 , established new transportation conformity requirements. Conformity for plans and TIPs are required a minimum of every fouryears. Conformity for plans and Transportation Improvement Programs (TIPs) must be redetermined not later than two years after new emissions budgets are found adequate. Metropolitan Planning Organizations (MPOs) are required to demonstrate conformity for the year the mobile budgets are established, for the final year of the transportation plan, and for appropriate interim years to ensure that anyalysis years are no more than ten years apart. Transportation Control Measures (TCMs) can be substituted in approved SIPs with the concurrence of the MPO, the air agencies and EPA. A conformity lapse will not occur until 12 months after an applicable deadline has passed.

The 2005 legislation requires MPOs to consult with agencies responsible for land use management, natural resources, environmental protection, and conservation and historic

1 CAA § 176(c), 42 USC §§7401-7671(q)
2 40 CFR Parts 51 and 93.
3 SAFETEA-LU, Public Law 109-56, August 10, 2005. Safe, Accountable, Flexible and Efficient Transportation Equity Act—A Legacy for Users.MWAQC Ozone SIP May 23, 2007 8-2 preservation. In addition a public participation plan is required for approval of a transportation plan. Public comment is required before the conformity determination and transportation plans can be approved.

The Clean Air Act provides penalties for MPOs in nonattainment areas that do not demonstrate conformity. SAFETEA-LU requires MPOs to perfor m a conformity determination at least every four years. A conformity lapse occurs when the conformity determination for a transportation plan or TIP has expired. During a conformity lapse, only Transportation Control Measures (TCMs), exempt projects and non-federal regi onally significant projects may advance.

Highway sanctions may result if the SIP is not submitted, if EPA finds the SIP incomplete or disapproves the control strategy. In the event of a SIP disapproval without a protective finding for the mobile budgets, a conformity freeze occurs immediately upon notification of the disapproval. In a conformity freeze, no new projects may proceed. As for a conformity lapse, a conformity freeze has some exceptions, similar to those in a conformity lapse. Those exceptions are listed in the Transportation Conformity Rule and amendments.

8.1 Mobile Emissions Budget and the Washington Area Transportation Conformity Process

In the metropolitan Washington region, regional growth requires that the Transportation Improvement Program (TIP) and the Constrained Long Range Plan (CLRP) be updated and revised and approved on an annual basis. The TIP includes transportation modifications and improvements on a six-year program cycle. Mobile source emissions in the CLRP and six-year TIP cannot exceed the mobile emissions budgets established in the SIP for the short-term TIP years, as well as for the 20-year forecast period of the long-range plan. The regional emissions analysis of the transportation plan must include all projects to be initiated in the Transportation Improvement Program’s timeframe.

Modifications to the existing regional transportation network are advanced through the Transportation Planning Board (TPB) by state, regional and local transportation agencies. Pursuant to the conformity regulations, the CLRP and TIP must contain analyses of the motor vehicle emissions estimates for the region resulting from the transportation improvements. These analyses must show that the transportation improvements in the TIP and the plan do not result in a deterioration of air quality goals established in the SIP. The conformity rule requires interagency consultation between the environmental body preparing the air quality plan and the MPO.

8.2 Budget Level for On-Road Mobile Source Emissions

In developing the SIP, MWAQC consults with the Transportation Planning Board (TPB), to establish mobile source emissions budgets. These budgets will be the benchmark used to determine if the region's constrained long range transportation plan (CLRP) and six year transportation improvements program (TIP) conform with the Clean Air Act Amendments of 1990. For the 8-hour ozone standard, the projected mobile source emissions for 2008MWAQC Ozone SIP May 23, 2007 8-3 (Reasonable Further Progress) and 2009 (attainment) less Transportation Control Measures and other and vehicle technology, fuel, or maintenance-based measures become the mobile emissions budgets for the region unless MWAQC takes actions to set other budget levels.

The 2008 and 2009 mobile emissions inventories reflect the most recent models available, EPA’s MOBILE6.2.03 and the Travel Demand Model Version 2.1d#50, used by COG’s Transportation Planning Department, along with the most recent data available, namely 2005 vehicle registration data. The methodology used to project the 2009 attainment year mobile inventory and to recalculate mobile inventories for milestone years is discussed in Section 3.2.3 and Section 4.1.4. See the appendices for detailed input parameters used in modeling the inventories.

The mobile emissions budgets for 2008 Reasonable Further Progress and 2009 attainment are based on the projected 2008 and 2009 mobile source emissions accounting for all the mobile control measures, including Transportation Control Measures, vehicle technology, fuel, or maintenance-based measures, and projected regional growth.

8.2.1 Reasonable Further Progress Mobile Budgets The mobile emissions budgets for the 2008 Reasonable Further Progress are based on the projected 2008 mobile source emissions accounting for all the mobile control measures, including Transportation Control Measures and vehicle technology, fuel, or maintenance-based measures. The mobile emissions budgets for the 2008 Reasonable Further Progress are 70.8 tons/day VOC and 159.8 tons/day NOx.

The Mobile Emissions Budget for 2008 Reasonable Further Progress, based upon the projected 2008 mobile source emissions accounting for all the mobile control measures, including the Transportation Control Measures and vehicle technology, fuel, or maintenance-based

measures:
VOC = 70.8 tons/day NOx = 159.8 tons/day

8.2.2 Attainment Year Mobile Budgets

The mobile emissions budgets for the 2009 attainment year are based on the projected 2009 mobile source emissions accounting for all the mobile control measures, including Transportation Control Measures and vehicle t echnology, fuel, or maintenance-based measures. The mobile emissions budgets for the 2009 Attainment Year are 66.5 tons/day VOC and 146.1 tons/day NOx.MWAQC Ozone SIP May 23, 2007 8-4 The Mobile Emissions Budget for 2009 attainment year, based upon the projected 2009 mobile source emissions accounting for all the mobile control measures, including the Transportation Control Measures and vehicle technology, fuel, or maintenance-based

measures:
VOC = 66.5 tons/day NOx = 146.1 tons/day

8.2.3 Contingency Budget

The mobile emissions budgets for the 2010 year are based on the projected 2009 mobile source emissions accounting for all the mobile control measures, including Transportation Control Measures and vehicle technology, fuel, or maintenance-based measures, minus the reductions required for the contingency plan discussed in Chapter 11. The mobile emissions budgets for the 2009 Attainment Year are 66.5 tons/day VOC and 146.1 tons/day NOx. The required reduction amount to satisfy the contingency plan is 1.8 tpd NOx.

The Mobile Emissions Budget for 2010, based upon the projected 2009 mobile source emissions accounting for all the mobile control measures, including the Transportation Control Measures and vehicle technology, fuel, or maintenance-based measures, less the contingency requirement:

VOC = 66.5 tons/day NOx = 144.3 tons/day

8.3 Transportation Control Measures (TCMs) and TERMs

Each time the Constrained Long Range Transportation Plan (CLRP) or the six-year Transportation Improvement Plan (TIP) is amended, the TPB will estimate the emissions from the regional transportation network and compare the expected emissions against the mobile emissions budget set in this SIP. This determination will take into account the projects included in the region’s transportation plans and the TCMs shown in Table A, which amount to 0.11 tpd VOC and 0.25 tpd NOx in 2008 and 0.10 tpd VOC and 0.22 tpd NOx in 2009. In addition, Vehicle technology, fuel or maintenance-based measures are also credited in the mobile budgets. Vehicle technology, fuel or maintenance-base d measures account for 0.08 tpd VOC and 0.24 tpd NOx in 2008 and 0.08 tpd VOC and 0.23 tpd NOx in 2009. Further information on TCMs and Vehicle technology, fuel or maintenance-based measures can be found in Section 6.4 and in Appendix F.

TERMS, or Transportation Emissions Reduction Measures, are used to mitigate mobile emissions if the conformity analysis demonstrates that mobile emissions will exceed the mobile budgets established in the SIP. In anticipation of possible mobile emissions mitigation needsMWAQC Ozone SIP May 23, 2007 8-5 associated with TPB plans and programs, the TPB Technical Committee Travel Management Subcommittee has analyzed a wide range of transportation emissions reduction measures (TERMs). The TERMS are used as needed in the event of a TIP and CLRP that exceed the mobile emissions limits set by the air quality plan. TERMs are used for conformity; TCMs are SIP measures and, as such, are permanent.

8.4 Trends in Mobile Emissions

The mobile emissions budgets for 2008 and 2009 for Volatile Organic Compounds (VOCs) and Nitrogen Oxides (NOx) reflect a continuation of a downward trend in mobile emissions over time. The VOC and NOx emission levels for mobile sources provided in Section 8.2 reflect declines of 39.3 percent and 40 percent for VOC and NOx, respectively, over the period from 2002 to 2008; and declines of 43 percent and 45 percent of VOC and NOx respectively from 2002 to 2009.

The steady reductions in mobile emissions are attributable largely to a series of increasingly stringent federal regulations requiring cleaner ve hicles and fuels, including the federal Tier II regulations for motor vehicles. The decline in mobile source emissions is also attributable in part to transportation policies that have resulted in large and continuing investments in mass transit facilities and services. Related efforts to promote transit-oriented development are helping to encourage use of transit rather than private vehicles. The Rosslyn-Ballston corridor in Arlington County, Virginia is a nationally recognized model of long-range planning which has resulted in the location of high-density commercial and residential development within close proximity of Metrorail stations and accompanying high levels of transit use. Similar success stories can be found in the District of Columbia and suburban Maryland.

In addition to continuing investments in major transit facilities, ongoing programs to encourage alternatives to the private automobile have helped keep levels of ridesharing and transit use in the Washington region among the highest in the country. The rapidly increasing use of the Washington Metro’s SmarTrip cards is permitting the direct provision of MetroChek subsidies for many transit riders at farecard machines, and the expansion of this technology to commuter rail and buses will provide for seamless transfers for transit riders within the next few years.

The region’s Transportation Improvement Program (TIP) includes substantial ongoing funding commitments to promoting ridesharing, telecommuting, and transit use as well as vehicle replacement and retrofit measures and bicycle and pedestrian programs. These commitments provide additional reductions in emissions, which are being reflected in conformity determinations. While not included in the SIP, these ongoing commitments are reducing emissions from mobile sources and are an important part of the contribution of the transportation sector to cleaner air.

Trends toward reduced mobile emissions are occurring despite a steady increase in population, employment and vehicle miles traveled (VMT) within the Washington region. Between 2002 and 2009, regional household population is expected to show a 12 percent increase, while daily VMT estimates show a 9 percent increase. The emission increases from this additional travel haveMWAQC Ozone SIP May 23, 2007 8-6been further exacerbated by a shift toward the use of higher-emitting, less fuel-efficient lightduty trucks, such as SUVs, instead of passenger vehicles.

Trends toward increasing population, employment and VMT are expected to remain strong well beyond 2009. The regional cooperative forecasting process predicts that from 2002 to 2020, regional population will grow by 31 percent and employment will grow by 31 percent. Regional VMT is predicted to increase by 31 percent over this time. However, these trends will not reverse the expected decline in regional mobile emissions resulting from cleaner fuels and improved vehicle technology. The recent Tier II passenger vehicle standards and regulations on emissions from heavy-duty diesel vehicles and fuels are expected to produce further dramatic reductions in VOC and NOx emissions as vehicles are replaced and retrofitted over the next 20 years. Projections contained in the Nationa l Capital Region Transportation Planning Board (TPB)’s Constrained Long Range Plan (CLRP) 4 indicate that for both pollutants, mobile emission reductions in excess of 50 percent will occur during this period.

4 Draft Air Quality Conformity Determination of the 2006 Constrained Long-Range Plan (CLRP) and FY 2007-2012 Transportation Improvement Program (TIP) for the Metropolitan Washington Region. Metropolitan Washington Council of Governments, National Capital Region Transportation Planning Board, Washington, DC.9.0 MODERATE AREA PLAN COMMITMENTS

Achieving the results shown in this Plan requires a com m itm ent to im plem ent the regulatory

m easures upon which the plan is based. The locally adopted m easures included in the analysis are those included in Table A. Chapter 6 provides docum entation of the reductions achieved by those m easures. The States and the District are also taking action to im plem ent regional

m easures to reduce ozone transport. Tables 9-1, 9-2, 9-3 and 9-4 provide inform ation on the im plem entation of each m easure by Maryland, Virginia and the District of Colum b ia.

Com m itm ents for regulations required by the CAAA Section 182 (b) for m oderate nonattainm e nt areas are shown in Tables 9-5, 9-6, and 9-7.

9.1 Schedules of Adopted Control Measures

Table 9-1 District of Columbia Schedule of Adopted Control Measures Washington Nonattainment Area

No. Control Measure Mandate Regulation Number Effective Date
Point Source Controls
6.1.1 Non-CTG VOC RACT Federal Regulation 20 DCMR Sec 715 10/2/98

6.1.2 State NOx RACT Requirem e nts and Regional Transport NOx Reductions Federal Regulation 20 DCMR Sec. 805

20 DCMR Ch. 10

20 DCMR Chapter 11 11/19/93

1/20/2000

No later than Jan. 1, 2009
Area Source Controls
6.2.1 Reform ulated Surface Coatings Federal Regulation 63 FR 48849 64 FR 34997 65 FR 7736 9/11/98 6/30/99 2/16/00
6.2.2 Reform ulated Consum er Products Federal Regulation 63 FR 48848 9/11/98

6.2.3 Reform ulated Industrial Cleaning Solvents Federal Regulation 20 DCMR Sec 708 10/2/98

MW AQC Ozone SIP 9-1 May 23, 2007No. Control Measure Mandate Regulation Number Effective Date
6.2.4 Surface Cleaning/Degreasing for Machinery/Autom obile Repair State Regulation 20 DCMR Sec. 743-745 5/1/99

6

. 2

. 5 L a n d f i l l R e g u l a t i o n s N / A N / A N / A
6.2.6 Seasonal Open Burning Restrictions State Regulation 20 DCMR Sec. 604 2/1/85

6.2.7 Stage I Expansion N/A N/A N/A
6.2.8 Stage II Vapor Recovery Nozzle Federal Regulation 20 DCMR Sec. 705 2/1/85

6.2.9 Graphic Arts Controls State Regulation 20 DCMR Sec. 716 5/1/99

6.2.10 Auto and Light Duty Truck Coating Operations Federal Regulation 8 / 1 4 / 9 8

6.2.11 Mobile Equipm ent Repair and Refinishing Rule State Regulation/OTC Model Rule 20 DCMR Sec. 718 4/04

6.2.12 Portable Fuel Containers Rule: Phase I State Regulation/OTC Model Rule 20 DCMR Sec. 735-741 4/04

6.2.13 Architectural and Industrial Maintenance Coatings Rule State Regulation/OTC Model Rule 20 DCMR Sec. 749-754 4/04

6.2.14 Reform ulated Consum er Products Rule: Phase I State Regulation/OTC Model Rule 20 DCMR Sec. 719-734 4/04

6.2.15 Solvent Cleaning Operations Rule State Regulation/OTC Model Rule 20 DCMR Sec. 742-748 4/04

6.2.16 Industrial Adhesives and Sealants Rule State Regulation/OTC Model Rule 20 DCMR 738-743 No later than May 1, 2008
6.2.17 Portable Fuel Containers Rule: Phase II State Regulation/`OTC Model Rule 20 DCMR Sec. 744-752 No later than May 1, 2008
6.2.18 Reform ulated Consum er Products Rule: Phase II State Regulation/OTC Model Rule 20 DCMR Sec. 719-737 No later than May 1, 2008
Nonroad Source Controls

MW AQC Ozone SIP 9-2 May 23, 2007No. Control Measure Mandate Regulation Number Effective Date
6.3.1 EPA Non-Road Gasoline Engines Rule Federal Regulation 40 CFR parts 90 and 91 12/3/96

6.3.2 EPA Non-Road Diesel Engines Rule Federal Regulation 40 CFR Part 9 et al. Model Year 2000-2008 depending on engine size
6.3.3 EPA Nonroad Spark Ignition Marine Engine Rule Federal Regulation 40 CFR Parts 89, 90, 91 1998 Model Year
6.3.4 EPA Large Spark Ignition Engines Rule Federal Regulation 40 CFR Parts 89, 90, 91, 94, 1048, 1051, 1065, and 1068 11/8/2002

6.3.5 Reform ulated Gasoline (off-road) Federal Regulation with State Opt-in CAA Section 211 (k) 1/1/95

6.3.6 Em issions Controls for Locom o tives Federal Regulation 63 FR 18998 6/15/98

On-road Measures
6.4.1 Phase II Volatility Controls of Refueling Em issions Federal Regulation with State Opt-in 42 U.S.C. 7545 1992

6.4.1 Reform ulated Gasoline Phase I and II (on-road) Federal Regulation with State Opt-in 42 U.S.C. 7545 1/1/95

6.4.2 High Tech Inspections & Maintenance Federal Regulation 18 DCMR** Chapters 4, 6, 7, 10, 11; 26 DCMR Chapter 26 4/30/99

6.4.3 Federal Tier I Vehicle Standards and new Car Evaporative Standards Federal Regulation 40 CFR part 86 Model Year 1994-1996; Evap Stds. 1996
6.4.4 National Low Em issions Vehicle Program Federal Regulation 20 DCMR, Sec 915 1/20/2000

MW AQC Ozone SIP 9-3 May 23, 2007No. Control Measure Mandate Regulation Number Effective Date
6.4.5 Tier 2 Motor Vehicle Em ission Standards Federal Regulation 65 FR 6698 2/10/2000

6.4.6 Heavy-Duty Diesel Engine Rule Federal Regulation 62 FR 54694 12/22/97

* This inform ation was obtained from the District Departm e nt of the Environm ent. **District of Colum b ia Municipal Regulations. *** For m easures not yet adopted, an anticipated schedule for adoption is provided.

MW AQC Ozone SIP 9-4 May 23, 2007Table 9-2 Maryland Schedule of Adopted Control Measures Washington Nonattainment Area

No. Control Measure Mandate Regulation Number Effective Date
Point Source Controls
6

. 1

. 1 N o n

- C T G R A C T F e d e r a l Regulation See Table 9-3 -

6.1.1 Expanded Point Source Regulations to 25 tpy Federal Regulation 2 6

. 1 1

. 1 9

. 0 1 B ( 4 ) 5 / 8 / 9 5

6.1.2 NOx Phase II Controls Federal Regulation 26.11.27 & .28
26.11.29 & 30 10/18/99

6.1.2 State NOx RACT Requirem e nts Federal Regulation 26.11.29.08

26.11.27 5/10/93

No later than Jan.1, 2009
Area Source Controls
6.2.1 Reform ulated Surface Coatings Federal Regulation 63 FR 48849 64 FR 34997 65 FR 7736 9/11/98 6/30/99 2/16/00
6.2.2 National Volatile Organic Com pound Em ission Standards for Consum er Products Federal Regulation 63 FR 48848 9/11/98

6.2.3 Reform ulated Industrial Cleaning Solvents Federal Regulation 42 U.S.C. 7511 2001

6.2.4 Surface Cleaning/Degreasing for Machinery/Autom obile Repair State Regulation 26.11.19.09 6/5/95

6

. 2

. 5 L a n d f i l l R e g u l a t i o n s F e d e r a l Regulation 2 6

. 1 1

. 1 9

. 2 0 3 / 9 / 9 8

6.2.6 Seasonal Open Burning Restrictions State Regulation 26.11.07 5/22/95

6.2.7 Stage I Expansion Federal Regulation 2 6

. 1 1

. 1 3

. 0 4 C 4 / 2 6 / 9 3

6.2.8 Stage II Vapor Recovery Nozzle Federal Regulation 2 6

. 1 1

. 2 4 2 / 1 5 / 9 3

6.2.9 Graphic Arts Controls State Regulation/CTG 26.11.19.11 & .18 6/5/95 & 11/7/94
6.2.10 Auto and Light Duty Truck Coating Operations State Regulation 26.11.19.23 5/22/95

MW AQC Ozone SIP 9-5 May 23, 2007No. Control Measure Mandate Regulation Number Effective Date
6.2.11 Control of VOC Em issions from Vehicle Refinishing State Regulation 26.11.19.23 5/22/95

6.2.12 Portable Fuel Containers Rule: Phase I State Regulation/OTC Model Rule 2 6

. 1 1

. 1 3

. 0 7 1 / 2 1 / 0 2

6.2.13 Architectural and Industrial Maintenance Coatings Rule State Regulation/OTC Model Rule 2 6

. 1 1

. 3 3 3 / 2 9 / 0 4

6

. 2

. 1 4 R e f o r m ulated Consum e r Products Rule: Phase I State Regulation/OTC Model Rule 2 6

. 1 1

. 3 2 8 / 1 8 / 0 3

6.2.15 Control of VOC Em issions from Cold and Vapor Degreasing State Regulation/OTC Model Rule 2 6

. 1 1

. 1 9

. 0 9 6 / 5 / 1 9 9 5

6.2.16 Industrial Adhesives and Sealants Rule** State Regulation/OTC Model Rule [Regulation Num b er Pending] 5/1/2008

6.2.17 Portable Fuel Containers Rule: Phase II** State Regulation/OTC Model Rule 2 1

. 1 1

. 1 3

. 0 7 5 / 1 / 2 0 0 8

6

. 2

. 1 8 R e f o r m ulated Consum e r Products Rule: Phase II** State Regulation/OTC Model Rule 2 6

. 1 1

. 3 2 5 / 1 / 2 0 0 8

Non-road Source Controls
6.3.1 EPA Non-Road Gasoline Engines Rule Federal Regulation 40 CFR parts 90 and 91 12/3/96

6.3.2 EPA Non-Road Diesel Engines Rule Federal Regulation 40 CFR Part 9 et al. Model Year 2000-2008 depending on engine size
6.3.3 EPA Nonroad Spark Ignition Marine Engine Rule Federal Regulation 40 CFR Parts 89, 90, 91 1998 Model Year
6.3.4 EPA Large Spark Ignition Engines Rule Federal Regulation 40 CFR Parts 89, 90, 91, 94, 1048, 1051, 1065, and 1068 11/8/2002

6.3.5 Reform ulated Gasoline (off-road) F ederal Regulation with State Opt-in CAA Section 211 (k) 1/1/95

MW AQC Ozone SIP 9-6 May 23, 2007No. Control Measure Mandate Regulation Number Effective Date
6.3.6 Em issions Controls for Locom o tives Federal Regulation 63 FR 18998 6/15/98

On-road Source Controls
6.4.1 Phase II Volatility Controls of Refueling Em issions Federal Regulation with State Opt-in 0 3

. 0 3

. 0 3

. 0 5 1 0 / 2 6 / 9 2

6.4.1 Reform ulated Gasoline Phase I and Phase II (on-road) Federal Regulation with State Opt-in 42 U.S.C. 7545 1/1/95 & 1/1/2000

6.4.2 High Tech Inspections & Maintenance Federal Regulation 1 1

. 1 4

. 0 8 1 / 2 / 9 5 & 1/1/2000
6.4.3 Federal Tier I Vehicle Standards and new Car Evaporative Standards Federal Regulation 40 CFR part 86 Model Year 1994-1996; Evap Stds. 1996
6.4.4 National Low Em issions Vehicle Program Federal Regulation 2 6

. 1 1

. 2 0

. 0 4 3 / 2 2 / 9 9

6.4.5 Tier 2 Motor Vehicle Em ission Standards Federal Regulation 65 FR 6698 2/10/2000

6.4.6 Heavy-Duty Diesel Engine Rule Federal Regulation 63 FR 54694 12/22/97

*This inform ation was obtained from the Maryland Departm e nt of the Environm ent. ** For m easures not yet adopted, an anticipated schedule for adoption is provided.

MW AQC Ozone SIP 9-7 May 23, 2007Table 9-3 Maryland Non-CTG RACT Washington Nonattainment Area

Overall requirement in COMAR 26.11.19.02G effective 4-26-93 (20: Md. R 726) The following case-by-case RACT regulations have been adopted to ensure consistency.

RACT Regulation Regulation Number Effective Date MD Register

Definition of Gasoline to include JP-4 26.11.13.01 8-11-97 24:16 Md R. 1161
Plastic Parts Coating 26.11.19.07E 6-5-95 22:11 Md R 823
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

Com m e rcial 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
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

MW AQC Ozone SIP 9-8 May 23, 2007Table 9-4 Virginia Schedule of Adopted Control Measures Washington Nonattainment Area

No. Control Measure Mandate Regulation Number Effective Date

Point Source Controls 6.1.1 Non-CTG RACT - VOC Federal Regulation 9 VAC 5-40-5220 1/1/93

6.1.1 Expanded Point Source Regulations to 25 tpy - VOC Federal Regulation 9 VAC 5-40-300 4/1/96

6.1.2 State NOx RACT Requirem e nts Federal Regulation 9 VAC 5-40-310; 9 VAC 5-40-311 1/1/93

6.1.2 Regional Transport NOx Reduction Controls Federal Regulation By perm it or

com p liance
agreem ent

9 VAC 5 Chapter 130 6/25/98

No later than Jan.1, 2009
Area Source Controls
6

. 2

. 1 R e f o r m ulated S u r f a c e Coatings Federal Regulation 63 FR 48849 64 FR 34997 65 FR 7736 9/11/98 6/30/99 2/16/00
6

. 2

. 2 R e f o r m ulated Consum e r Products Federal Regulation 63 FR 48848 9/11/98

6

. 2

. 3 R e f o r m ulated I n d u s t r i a l Cleaning Solvents Federal Regulation 42 U.S.C. 7511 2001

6

. 2

. 4 S u r f a c e C l e a n i n g / D e g r e a s i n g f

o r Machinery/Autom obile Repair State Regulation 9 VAC 5-40-3260 et. seq. 4/1/96

6

. 2

. 5 L a n d f i l l R e g u l a t i o n s F e d e r a l Regulation 9 VAC 5-40-5800 et. seq. 4/1/96

6.2.6 Seasonal Open Burning Restrictions State Regulation 9 VAC 5-40-5630 4/1/96

6.2.7 Stage I Expansion Federal Regulation 9 VAC 5-40- 5200 1/1/99

6.2.8 Stage II Vapor Recovery Nozzle Federal Regulation 9 VAC 5–40-5220 1/1/93

MW AQC Ozone SIP 9-9 May 23, 2007No. Control Measure Mandate Regulation Number Effective Date

6.2.9 Graphic Arts Controls State Regulation/CTG 9 VAC 5-40-7800 et. seq. 4/1/96

6.2.10 Auto and Light Duty Truck Coating Operations State Regulation 9 VAC 5 40-3860 et. seq. 7/1/91

6.2.11 Mobile Equipm ent Repair and Refinishing Rule State Regulation 9 VAC 5-40-6970 et. seq. 3/24/04

6.2.12 Portable Fuel Containers Rule: Phase I State Regulation/OTC Model Rule 9 VAC 5-40-5700 et. seq. 3/24/04

6.2.13 Architectural and Industrial Maintenance Coatings Rule State Regulation/OTC Model Rule 9 VAC 5-40-7120 et. seq. 3/24/04

6

. 2

. 1 4 R e f o r m ulated Consum e r Products Rule: Phase I State Regulation/OTC Model Rule 9 VAC 5-40-7240 et. seq. 3/9/05

6.2.15 Solvent Cleaning Operations Rule State Regulation/OTC Model Rule 9 VAC 5-40-6820 et. seq. 3/24/04

6.2.16 Industrial Adhesives and Sealants Rule** State Regulation/OTC Model Rule 9 VAC 5 Chapter 40 5/1/2009

6.2.17 Portable Fuel Containers Rule: Phase II** State Regulation/OTC Model Rule 9 VAC 5 Chapter 40 5/1/2009

6

. 2

. 1 8 R e f o r m ulated Consum e r Products Rule: Phase II** State Regulation/OTC Model Rule 9 VAC 5 Chapter 40 5/1/2009

Non-road Source Controls
6.3.1 EPA Non-Road Gasoline Engines Rule Federal Regulation 40 CFR parts 90 and 91 12/3/96

6.3.2 EPA Non-Road Diesel Engines Rule Federal Regulation 40 CFR part 9 et al. Model Year 2000-2008 depending on engine size
6.3.3 EPA Nonroad Spark Ignition Marine Engine Rule Federal Regulation 40 CFR Parts 89, 90, 91 1998 Model Year
6.3.4 EPA Large Spark Ignition Engines Rule Federal Regulation 40 CFR Parts 89, 90, 91, 94, 1048, 1051, 1065, and 11/8/2002

MW AQC Ozone SIP 9-10 May 23, 2007No. Control Measure Mandate Regulation Number Effective Date

1068 6.3.5 Reform ulated Gasoline Phase I and Phase II (non-road) Federal Regulation with State Opt-in CAA Section 211 (k) 1/1/95

6.3.6 Em issions Controls for Locom o tives Federal Regulation 63 FR 18998 6/15/98

On-road Measures
6.4.1 Phase II Volatility Controls of Refueling Em issions Federal Regulation with State Opt-in 2 VAC 5 420-10 7/28/93

6.4.1 Reform ulated Gasoline Phase I and Phase II (on-road) Federal Regulation with State Opt-in 42 U.S.C. 7545 1/1/95 & 1/1/2000

6.4.2 High Tech Inspection & Maintenance Federal Regulation 9 VAC 5 Chapter 91 4/2/97

6.4.3 Federal Tier I Vehicle Standards and new Car Evaporative Standards Federal Regulation 40 CFR part 86 Model Year 1994-1996; Evap Stds. 1996
6.4.4 National Low Em issions Vehicle Program Federal Regulation 9 VAC 5-200 4/14/99

6.4.5 Tier 2 Motor Vehicle Em ission Standards Federal Regulation 65 FR 6698 2/10/2000

6.4.6 Heavy-Duty Diesel Engine Rule Federal Regulation 63 FR 54694 12/22/97

*This inform ation was obtained from the Virginia Departm e nt of Environm ental Quality. ** For m easures not yet adopted, an anticipated schedule for adoption is provided.

MW AQC Ozone SIP 9-11 May 23, 20079.2 Stationary Source Threshold Revisions

The Clean Air Act Am endm ents, Section 182 (d) required the states in severe nonattainm e nt areas to adopt lower perm it thresholds for point sources from 50 tons per year to 25 tons per year. Maryland, Virginia and the District of Colum b ia adopted these m easures, listed in Table 9- 5, on the schedule shown.

Under the m oderate designation for the 8-hour ozone standard, the perm it threshold is 50 tons per year VOC and 100 tons per year NOx. Virginia will adopt the thresholds corresponding to the m oderate designation. Maryland and the District are com m itted to m a intaining the perm it threshold at 25 tons per year for both VOC and NOx.

Table 9-5 Schedule of Stationary Source Revisions Washington Nonattainment Area N o . S t a t e Control M e a s u r e R e g u l a t i o n Number Effective Date

Maryland Control of NOx Em issions for Major Stationary Sources COMAR 09.08 Adoption: 10/03

Virginia Control of NOx Em issions for Major Stationary Sources 9 VAC 5-20-204 9 VAC 5-80- 2000 Adopted: 4/7/03 Effective: 6/4/03 D i s t r i c t o f Colum b ia Major Source Thresholds 20 DCMR Sections 715.2,715.3,715.4 (VOC RACT) 8/29/03

MW AQC Ozone SIP 9-12 May 23, 20079.3 New RACT Rules Applicability

W h en the W a shington, DC region was designated as severe nonattainm e nt for ozone, Virginia, Maryland and the District adopted additional reasonably available control technology (RACT) rules for sources subject to the lower m a jor source applicability size threshold of 25 tpy. The requirem e nts for VOCs have been in the regulations for som e tim e due to earlier regulatory actions. The RACT threshold will rem a in at 25 tpy f o r Virginia, Maryland and the District. The states are also recertifying RACT for facilities that have the potential to em it m o re than 50 tpy VOC or 100 tpy NOx.

Table 9-6 New RACT Rules Applicability Washington Nonattainment Area N o . S t a t e Control M e a s u r e R e g u l a t i o n Number Date

Virginia Non-CTG RACT 9 VAC 5-40-240 of Part II of 9 VAC 5 Ch.40, specifically 9 VAC 5-40-300 (VOCs), 9 VAC 5-40-310 (NOx) Adopted: 4/7/03 Effective: 6/4/03

Maryland Control of NOx Em issions COMAR 9.08 10/03

D i s t r i c t o f Colum b ia Major Source Thresholds 20 DCMR sections 805.1,805.6,805.7 (NOx RACT) 8/29/03

MW AQC Ozone SIP 9-13 May 23, 20079.4 Revision of New Source Review (NSR) Regulations

W h en designated as severe nonattainm e nt of the ozone standard, the states were required to lower the thresholds f o r def i ning “Major” sources to require controls f o r f acilities with the potential to em it m o re than 25 tons per year (from 50 tons per year) and to revise New Source Review (NSR) regulations to apply the 1:1.3 offset requirem e nt to m a jor stationary sources of VOC and NOx.

The W a shington, DC region is designated as m oderate nonattainm e nt for the 8-hour ozone standard. Under the current m oderate designa tion, the NSR thresholds are 50 tpy VOC and 100 tpy NOx. The 1:1.15 offset requirem e nt would apply.

The New Source Review perm it regulations in Virginia are structured so that the pertinent requirem e nts such as m a jor source threshold and offset ratio are self-im p lem e nting depending upon changes to the nonattainm e nt area classification. The NSR threshold will rem a in at 25 tpy for both VOC and NOx for Maryland and the Dist rict and the 1:1.3 offset requirem e nt will apply.

Table 9-7 Schedule for Revision of NSR Regulations Washington Nonattainment Area State Control Measure Regulation Number Effective Date M a r y l a n d R e q u i r e m e nts f o r Major New Sources and Modifications: Definitions and General Conditions COMAR 17.01 and COMAR 17. 03 Adoption: 10/03

Virginia Perm its f o r Major Stationary Sources and Major Modifications Locating in Nonattainm e nt Areas 9 VAC 5-80-2000 of Part II of 9 VAC 5 Chapter 80 Adopted: 6/31/81 Effective: 12/1/04

V i r g i n i a N o n a t t a i n m e n t Areas (NSR perm it regulations) 9 VAC 5-20-204 Effective: 5/4/2005

District of Colum b ia Nonattainm e nt Areas (NSR Perm it Regulations) 20 DCMR section 204 8/29/03

MW AQC Ozone SIP 9-14 May 23, 200710.0 Attainment Demonstration

The 8-Hour Ozone Standard Attainm e nt Plan analyzes the potential of the W a shington

m e tropolitan area to achieve attainm e nt of the 8-hour ozone standard. The dem onstration of achieving the 8-hour ozone standard is based on both the Com m unity Multiscale Air Quality Model (CMAQ) and W e ight of Evidence (W OE) analysis supporting the attainm e nt m odeling results. Photochem i cal m odeling and the W O E analyses provide strong evidence that the region will attain the 8-hour ozone standard by 2009. Details of both the CMAQ m odel and the W O E tests are being provided below.

10.1 Modeling Study Overview : Background and Objectives
On June 15, 2005, EPA revoked the 1-hour ozone standard and re-designated the W a shington D.C. MSA as a “Moderate” ozone non-attainm e nt area for the new 8-hour ozone standard. Moderate ozone non-attainm e nt areas are required to dem onstrate attainm e nt of the new 8-hour ozone standard using photochem i cal m odeling and W O E analyses. The objective of the photochem i cal m odeling study is to enable the air agencies to analyze the efficacy of various control strategies, and to dem onstrate that the m easures adopted as part of the State Im plem entation Plan will result in attainm e nt of the ozone standard by June 2010. The

m odeling exercise predicts future 2009 air quality conditions based on the worst episodes in the base year 2002, and applies control m easures to dem onstrate the effectiveness of new m easures in reducing air pollution.

For the reason m e ntioned above, a photochem i cal m odeling study was undertaken by Virginia Departm e nt of Environm ental Quality (VADEQ) on behalf of the W a shington m e tropolitan area to dem onstrate attainm e nt of the 8-hour oz one NAAQS. The attainm e nt m odeling project was directed by the Technical Advisory Com m ittee (TAC) and the Metropolitan W a shington Air Quality Com m ittee (MW AQC), a policy com m ittee. EPA’s Com m unity Multi-scale Air Quality (CMAQ) was the m odel used for the attainm e nt dem onstration. Table 10-1 identifies all jurisdictions that EPA has designated as non-attainm e nt within the W a shington MSA.

MW AQC Ozone SIP 10-1 May 23, 2007Table 10-1. Washington MSA Designations for 8-hour Oz one Standard

Jurisdiction Counties Classification Maximum Attainment Date (from June 15, 2004) District of Colum b ia District of Colum b ia

Maryland Calvert Charles Frederick Montgom ery Prince George' s

Virginia Alexandria City Arlington Fairfax City

Fairfax Falls Church City Loudoun Manassas City Manassas Park City

Prince W illiam Moderate June 15, 2010

The m odeling analyses set forth in this report have been conducted in accordance with the EPA (2006). 1

10.1.1 Relationship to Regional Modeling Protocols

The state m e m b ers of the com m ittees for this study are also m e m b ers of the OTC and ASIP

m odeling com m ittees. This m e m b ership has allowed them to coordinate the analyses perform e d for W a shington, D.C. with the regional m odeling analyses conducted by OTC and ASIP. VADEQ, in consultation with the MDE, DCDOE, and MW COG, was responsible for conducting CMAQ runs for the W a shington, D.C. dom ain. VADEQ’s m odeling runs were done in coordination with the Ozone Transport Com m i ssion’s (OTC) m odeling for the 12-state Ozone Transport Region (OTR) and with the ASIP m odeling, done for the southeastern states. Modeling centers for OTC included the New York State Departm e nt of Environm ental Conservation (NYSDEC), the University of Maryland, NESCAUM and VADEQ. Technical support docum ents for the OTC m odeling perform e d for the OTR are included in Appendix G. Modeling inventories were developed, updated and shared am ong the regional m odeling centers and provided by MARAMA, MANE-VU and VISTAS.

Installation of the m odels at VADEQ and all participating m odeling centers was com p leted and diagnostic procedures were run successfully. The m odel has been benchm arked against other

m odeling platform s across the region to ensure accurate results. The Policy Com m ittee and the TAC oversaw the m odeling work and m a de appropriate reports to the full MW AQC through regular briefings and offe red other inform ation in cases where specific technical decisions had policy im plications. The Technical Com m ittee m e m b ers and m e m b ers of

1 Guidance on the Use of Models and Other Analyses for De m onstrating Attainm e nt of Air Quality Goals for Ozone, PM2.5, and Regional Haze (Draft 3.2- Septem ber 2006).

MW AQC Ozone SIP 10-2 May 23, 2007other com m ittees involved in the project who are also m e m b ers of OTC and ASIP m a de sure to the extent practicable that there was consistency between the regional and urban m odeling effort s.

10.1.2 Conceptual Description

EPA recom m e nds that a conceptual description of the area’s ozone problem be developed prior to the initiation of any air quality m odeling study. A “conceptual description” is a qualitative way of characterizing the nature of an area’s non-attainm e nt problem . W ithin the conceptual description of a particular m odeling exercise, it is recom m e nded that the specific m e teorological
param e ters that inf l uence air quality be identif ied and qualitatively ranked in im portance.

The conceptual m odel for this study was prepared by the Northeast States for Coordinated Air Use Managem e nt (NESCAUM) for use by the OTC m e m b er States. The conceptual m odel docum ent, The Nature of the Ozone Air Quality Problem in the Ozone Transport Region: A Conceptual Description (NESCAUM, October 2006) , is provided in Appendix G. This docum ent provides the conceptual description of the ozone problem in the OTR states, consistent with the EPA’s guidance.

10.2 Domain and Database Issues

10.2.1. Episode Selection
The procedures for selecting 8-hr ozone m odeling episodes seek to achieve a balance between good science and regulatory needs and constraints. Modeling episodes, once selected, influence technical and policy decisions for m a ny years. Cl early, both the direct and im plicit procedures used in selecting episodes warrant full consideration.

The rationale for the selection of 2002 m e teorology as input to the air quality sim u lations includes a qualitative analysis (Ryan and Piety 2002) 2 and a quantitative analysis (Environ 2005) 3 . These docum ents are provided in Appendix G Attachm e nt 2.

Recent research has shown that m odel perform a nce evaluations and the response to em issions controls need to consider m odeling results from long tim e periods, in particular full synoptic cycles or even full ozone seasons. Based on this factor the entire ozone season was sim u lated for the 2002 and 2009 State Im plem entation Plan (SIP) m odeling runs (May 1 to Septem ber 30). As a result, the total num ber of days exam ined for the com p lete ozone season far exceeds EPA

recom m e ndations, and provides for better assessm ent of the sim u lated pollutant fields.

2 Ryan, W

. F., Piety, C. 2002. Sum m a ry of 2002 Pollution Episodes in the Mid-Atlantic . The Pennsylvania State University Departm e nt of Meteorology, State College, Penns ylvania and the University of Maryland Departm e nt of Meteorology, College Park, Maryland.

3 Environ. 2005. Ozone Episode Classification Project for Ozone Transport Com m i ssion (Task 2b), Stoeckenius, T., Kem b all-Cook, S, ENVIRON Internationa l Corporation, Novato, California.

MW AQC Ozone SIP 10-3 May 23, 200710.2.2. Siz e of the Modeling Domain In defining the m odeling dom ain, one m u st consider 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 m e teorological and air quality data. The dom ain or spatial extent to be m odeled includes as its core the non-attainm e nt area. Beyond this, the dom ain includes enough of the surrounding area such that m a jor upwind sources fall within the dom ain and em issions produced in the non-attainm e nt area rem a in within the dom ain throughout the day.

The boundaries of the m odeling dom ain are provided in Appendix G Attachm e nt 3. This dom ain covers the Northeast region including northeastern, central and southeastern US as well as Southeastern Canada. The final SIP m odeling analysis utilized the m odeling dom ain boundaries established by OTC.

10.2.3 Horiz o ntal Grid Siz e The OTC platform used for the W a shington, D.C. m odeling analysis utilized a coarse grid continental United States (US) dom ain with a 36-km horizontal grid resolution. The CMAQ dom ain is nested in the MM5 dom ain. A larger MM5 dom ain was selected for both MM5 sim u lations to provide a buffer of several grid cells around each boundary of the CMAQ 36 km dom ain. This was designed to elim inate any errors in the m e teorology from boundary effects in the MM5 sim u lation at the interface of the MM5 m odel. A 12-km inner dom ain was selected to better characterize air quality in OTC and su rrounding Regional Planning Organization (RPO) regions. Appendix G Attachm e nt 4 contains the horizontal grid definitions for the MM5 and CMAQ m odeling dom ains.

10.2.4 Vertical Resolution The CMAQ vertical structure is prim arily defined by the vertical grid used in the MM5

m odeling. The MM5 m odel em ployed a terrain following coordinate system defined by pressure. The layer averaging schem e adopted for CMAQ is designed to reduce the com putational cost of the CMAQ sim u lations. The effects of layer averaging have a relatively m i nor effect on the

m odel perform a nce m e trics when com p ared to am bient m onitoring data. Appendix G Attachm e nt 5 contains the verti cal layer definitions for the MM5 and CMAQ

m odeling dom ains.

10.2.5 Initial and Boundary Conditions The objective of a photochem i cal grid m odel is to estim ate the air quality given a set of

m e teorological and em issions conditions. W h en initializing a m odeling sim u lation, the exact concentration fields are unknown in every grid cell for the start tim e. Therefore, typically photochem i cal grid m odels are started with clean conditions within the dom ain and allowed to stabilize before the period of interest is sim u lated. In practice this is accom p lished by starting the

m odel several days prior to the period of interest.

The winds m ove pollutants into, out of, and within the dom ain. The m odel handles the

m ovem e nt of pollutants within the dom ain and out of the dom ain. An estim ate of the quantity of pollutants m oving into the dom ain is needed. These are called boundary conditions. To estim ate the boundary conditions for the m odeling study, three-hourly boundary conditions for the outer 36-km dom ain were derived from an annual m odel run perform e d by researchers at Harvard

MW AQC Ozone SIP 10-4 May 23, 2007University using the GEOS-CHEM global chem istry transport m odel. The influence of boundary conditions was m i nim i zed by using a 15-day ramp -up period which is sufficient to establish pollutant levels that are encountered in the beginning of the ozone episode.

10.2.6 Meteorological Model Selection and Configuration The Pennsylvania State University/National Ce nter for Atm o spheric Research (PSU/NCAR) Mesoscale Meteorological Model (MM5) was selected for application in the W a shington, D.C. non-attainm e nt m odeling analysis. MM5 is a non-hydrostatic, prognostic m e teorological m odel routinely used for urban- and regional-s cale photochem i cal regulatory m odeling studies.

Based on m odel validation and sensitivity testing, the MM5 configurations provided in Appendix G Attachm e nt 6 were selected. Results of the University of Maryland’s detailed perform a nce evaluation of the MM5 m odeling used in conjunction with the OTC platform are provided in Appendix G Attachm e nt 7.

10.2.7 Emissions Model Selection and Configuration Significant coordination efforts took place between MANE-VU and VISTAS in the developm ent of the em issions inventories used in the m odeling study. All analyses conducted in support of the W a shington, D.C. m odeling analysis were coordinated between the Technical and Policy Com m ittees along with TAC.

These inventories include a base case (2002) whic h serves as the “parent” inventory off which all future year inventories (i.e., 2009) are based. The future year inventories include em issions growth due to any projected increase in econom ic activity as well as the im plem entation of control m easures. Detailed descriptions of both base case 2002 and attainm e nt year 2009 inventories are provided in Attachm e nt 12 and Attachm e nt 13 respectively of the Appendix G.

The Sparse Matrix Operator Kernel Em issi ons (SMOKE) Em issions Processing System was selected for application in the W a shington, D.C. non-attainm e nt area m odeling analysis. SMOKE (Version 2.1) was used for the W a shington DC attainm e nt m odeling dem onstration. 2002 base case and 2009 future base case em issions data files were provided by OTC and ASIP. W h erever possible, the m obile source em ission inventories (in VMT form at) were replaced with SCC-specific county level em issions to m o re accu rately reflect actual em issions for typical ozone season day. A detailed description of all SMOKE input files such as area, m obile, fire, point and biogenic

em issions files is provided in Appendix G Att achm e nt 8. The SMOKE m odel configuration is also provided.

MW AQC Ozone SIP 10-5 May 23, 200710.2.8 Air Quality Model Selection and Configuration EPA’s Models-3/Com m unity Multi-scale Air Quality (CMAQ) m odeling system was selected for the attainm e nt dem onstration prim arily because it is a “one-atm osphere” photochem i cal grid

m odel capable of addressing ozone at regional scale and is considered one of the preferred

m odels for regulatory m odeling applications. The m odel is also recom m e nded by the Guidance on the Use of Models and Other Analyses f o r Dem onstrating Attainm e nt of Air Quality Goals for Ozone, PM2.5, and Regional Haze (Draft 3.2- Septem ber 2006)

. The CMAQ configuration is provided in Appendix G Attachm e nt 9.

10.2.9 Quality Assurance All air quality, em issions, and m e teorological data were reviewed to ensure com p leteness, accuracy, and consistency before proceeding with m odeling. Any errors, m i ssing data or inconsistencies, were addressed using appropriate m e thods that are consistent with standard practices. All m odeling was benchm arked through the duplication of a set of standard m odeling results.

Quality Assurance (QA) activities were carried out f o r the various em issions, m e teorological, and photochem i cal m odeling com ponents of the m odeling study. Em issions inventories obtained from the Regional Planning Organizations (RPO) were exam ined to check for errors in the

em issions estim ates. W h en such errors were discovered, the problem s in the input data files were corrected.

The MM5 m e teorological and CMAQ air quality m odel inputs and outputs were plotted and

exam ined to ensure accurate representation of the observed data in the m odel-ready fields, and
tem poral and spatial consistency and reasonableness. Both MM5 and CMAQ underwent operational and scientif ic evaluations in order to f acilitate the quality assurance review of the

m e teorological and air quality m odeling procedures and are discussed in greater detail throughout this docum ent.

10.3 Model Performance Evaluation

There are m a ny aspects of m odel perform a nce. This section will focus prim arily on the m e thods and techniques recom m e nded by EPA f o r evaluating the perf orm a nce of the air quality m odel. It should be noted that the other parts of the m odeling process, the em issions and m e teorology, also undergo an evaluation. It is with this knowledge and the desire to keep the report concise, that the air quality m odel becam e the prim ary focus of this section.

The f i rst step in the m odeling process is to verif y the m odel’s perf orm a nce in term s of its ability to predict the ozone in the right locations and at the right levels. To do this, the m odel predictions for the base year sim u lation are com p ared to the am bient data observed in the historical episode. This verification is a com b ina tion of statistical and graphical evaluations. If the m odel appears to be producing ozone in the right locations for the right reasons, then the

m odel can be used as a predictive tool to evaluate various control strategies and their effects on

MW AQC Ozone SIP 10-6 May 23, 2007ozone. The purpose of the m odel perform a nce evaluation is to assess how accurately the m odel predicts ozone levels observed in the historical episode.

The results of a m odel perform a nce evaluation were evaluated prior to using m odeling to support the attainm e nt dem onstration. The perform a nce of CMAQ was evaluated using both operational and diagnostic m e thods. Operational evaluation refers to the m odel’s ability to replicate observed concentrations of ozone and/or precu rsors (surface and aloft), whereas diagnostic evaluation assesses the m odel’s accuracy with respect to characterizing the sensitivity of ozone to changes in em issions (i.e., relative response factors).
The New York State DEC, Division of Air Re sources, conducted a perform a nce evaluation of the 2002 base case CMAQ sim u lation (May 15-Septem ber 30) on behalf of the OTC m e m b er States. Appendix G Attachm e nt 10 provides com p rehensive operational and diagnostic evaluation results, including spreadsheets containing the assum p tions m a de to com pute statistics. Highlights of this evaluation are provided in the following sections.

10.3.1 Diagnostic and Operational Evaluation

The issue of m odel perform a nce goals for ozone is an area of ongoing research and debate. To evaluate m odel perform a nce, EPA recom m e nds that several statistical m e trics be developed for air quality m odeling. Two of the com m on m e trics that are m o st often used to assess perform a nce are the m ean norm a lized gross error and the m ean norm a lized bias. The m ean norm a lized gross
error param e ter provides an overall assessm ent of m odel perform a nce and can be interpreted as precision, and the m ean norm a lized bias param e ter m easures a m odel' s ability to reproduce observed spatial and tem poral patterns and can be interpreted as accuracy. EPA suggests the following criteria: a m ean norm a lized bias (MNB) of < ±15%, and a m ean norm a lized gross error (MNGE) of < 35% above a threshold of 40-60 ppb. These results are presented in Table 10- 2 below for the local non-attainm e nt area and in Tables 10-3 and 10-4 on a m onitor-by-m onitor basis averaged over all days for the 40 ppb and 60 ppb thresholds. Figure 10-1 shows the location of the m onitors.

MW AQC Ozone SIP 10-7 May 23, 2007Table 10-2. Washington, D.C. MSA Statistics for 8-hour Oz one

Location Ozone Cutoff Threshold (ppb) Mean Normaliz ed Gross Error (MNGE) (%) Mean Normaliz ed Bias (MNB)

(%) W a s h i n g t o n , 4 0 1 3

. 3 4

- 0

. 4 3

Table 10-3. Individual Site Statistics for 8-hour Oz one using 40 ppb Cutoff

AIRS ID Site Name Jurisdiction State MNGE (%) MNB (%)
1 1

- 0 0 1

- 0 0 2 5 T a k o m a District of Colum b ia --- 1 2

. 7 7 6

. 8 5 1 1

- 0 0 1

- 0 0 4 1 R i v e r T e r r a c e District of Colum b ia --- 1 2

. 0 8

- 3

. 1 3 1 1

- 0 0 1

- 0 0 4 3 M c M i l l a n District of Colum b ia --- 1 4

. 8 5

- 1 2

. 0 4 2 4

- 0 0 9

- 0 0 1 0 C a l v e r t C a l v e r t M D N A N A 2 4

- 0 1 7

- 0 0 1 0 S o u t h e r n M D C h a r l e s M D 1 2

. 3 0

. 5 5 24-021-0037 Frederick Municipal Airport F r e d e r i c k M D 1 2

. 2 9

- 0

. 2 2 2 4

- 0 3 1

- 3 0 0 1 R o c k v i l l e Montgom e r y M D 1 3

. 5 7 7

. 6 2 4

- 0 3 3

- 0 0 0 2 G r e e n b e l t Prince George' s MD 1 2

. 8 2 1

. 5 4 24-033-8003 PG Equestrian Center Prince George' s MD 13.48 3.38 5 1

- 0 1 3

- 0 0 2 0 A u r o r a H i l l s Arlington County VA 1 2

. 7 3

- 6

. 3 3 5 1

- 0 5 9

- 0 0 0 5 C h a n t i l l y Fairfax County VA 1 3

. 2 3

- 8

. 3 1 5 1

- 0 5 9

- 0 0 1 8 M o u n t V e r n o n Fairfax County VA 1 4

. 6 3 4

. 9 3 5 1

- 0 5 9

- 0 0 3 0 F r a n c o n i a Fairfax County VA 1 2

. 5 7

- 3

. 5 7 5 1

- 0 5 9

- 1 0 0 5 A n n a n d a l e Fairfax County VA 1 2

. 0 1

- 2

. 9 4 5 1

- 0 5 9

- 5 0 0 1 M c L e a n Fairfax County VA 1 7

. 8 7 1 1

. 9 9 5 1

- 1 0 7

- 1 0 0 5 A s h b u r n Loudoun County VA 1 3

. 1 8

- 8

. 5 4 5 1

- 1 5 3

- 0 0 0 9 L o n g P a r k Prince W illiam County VA 1 2

. 5 5

- 4

. 2 3 5 1

- 5 1 0

- 0 0 0 9 A l e x a n d r i a A l e x a n d r i a C i t y V A 1 4

. 1 4 9

. 2 Table 10-4. Individual Site Statistics for 8-hr Oz one using 60 ppb Cutoff

AIRS ID Site Name Jurisdiction State MNGE (%) MNB (%)
1 1

- 0 0 1

- 0 0 2 5 T a k o m a District of Colum b ia --- 9

. 3 7 2

. 8 1 1

- 0 0 1

- 0 0 4 1 R i v e r T e r r a c e District of Colum b ia --- 1 1

. 2 8

- 7

. 5 7 1 1

- 0 0 1

- 0 0 4 3 M c M i l l a n District of Colum b ia --- 1 5

. 6 1

- 1 3

. 6 6 2 4

- 0 0 9

- 0 0 1 0 C a l v e r t C a l v e r t M D N A N A 2 4

- 0 1 7

- 0 0 1 0 S o u t h e r n M D C h a r l e s M D 1 1

. 2 2

- 5

. 6 2 24-021-0037 Frederick Municipal Airport F r e d e r i c k M D 1 0

. 9

- 4

. 2 7 2 4

- 0 3 1

- 3 0 0 1 R o c k v i l l e Montgom e r y M D 1 1

. 3 3

. 2 4 2 4

- 0 3 3

- 0 0 0 2 G r e e n b e l t Prince George' s MD 1 1

. 4 2

- 2

. 6 24-033-8003 PG Equestrian Center Prince George' s MD 11.46 -3.87 5 1

- 0 1 3

- 0 0 2 0 A u r o r a H i l l s Arlington County VA 1 3

. 3 6

- 9

. 7 9 5 1

- 0 5 9

- 0 0 0 5 C h a n t i l l y Fairfax County VA 1 3

. 7 1

- 1 2

. 5 7 5 1

- 0 5 9

- 0 0 1 8 M o u n t V e r n o n Fairfax County VA 1 1

. 0 2

- 2

. 6 3 5 1

- 0 5 9

- 0 0 3 0 F r a n c o n i a Fairfax County VA 1 1

. 9 9

- 7

. 4 2 5 1

- 0 5 9

- 1 0 0 5 A n n a n d a l e Fairfax County VA 1 1

. 8 8

- 7

. 5 5 1

- 0 5 9

- 5 0 0 1 M c L e a n Fairfax County VA 1 3

. 5 4 5

. 5 9 5 1

- 1 0 7

- 1 0 0 5 A s h b u r n Loudoun County VA 1 4

. 1 8

- 1 2

. 8 4 5 1

- 1 5 3

- 0 0 0 9 L o n g P a r k Prince W illiam County VA 1 2

. 6

- 1 1

. 7

MW AQC Ozone SIP 10-8 May 23, 2007Figure 10-1. Location of Oz one Monitors in the Washington, D.C. Area

The following statistics for the OTC dom ain have also been provided in Appendix G Attachm e nt 11.

1. Archive file containing tim e series of 8-hour average observed and predicted ozone organized by state.

2. Observed and predicted com posite diurnal variations of selected species, including but not lim ited to ozone at SLAMS/NAMS sites, ozone at CASTNet and other sites, VOC species such as ethene, isoprene, form aldehyde and gas phase com pounds such as CO, NO and NO 2
. 3. Statistical evaluation of daily m a xim u m 8-hour ozone at SLAMS/NAMS sites and CASTNet/other sites; statistics are com puted using two different thresholds for observed daily m a xim u m ozone - 40 and 60 ppb; statistics are com puted by date (all sites on a given day) and by site (one site over all days).

4. Statistical evaluation of daily m a xim u m 8-hour ozone at SLAMS/NAMS sites that fall within non-attainm e nt counties; statistics are com puted by non-attainm e nt area.
5. Statistical evaluation of daily average CO, NO, NO 2 , and SO 2 at SLAMS/NAMS and other sites; statistics are com puted by date and by site.

6. Statistical evaluation of daily average ethene, isoprene, and form aldehyde at SLAMS/NAMS and other sites; statistics are com puted by date and by site.

MW AQC Ozone SIP 10-9 May 23, 20077. Plots of com posite tim e series for daily m a x 8-hour ozone, root m ean square error and

m ean bias f o r illustrative purposes.

8. Daily tile plots of daily 8-hour m a xim u m predicted ozone across the m odeling dom ain

com p ared with actual observations.

10.3.2 Summary of Model Performance
CMAQ was em ployed to sim u late ozone for the 2002 season (May 15 through Septem ber 30). A

com p arison of the tem poral and spatial distributions of ozone and its precursors was conducted for the study dom ain with additional focus placed on perform a nce in the W a shington D.C. area. The CMAQ m odel perform a nce for surface ozone is quite good with low bias and error. Model perform a nce is generally consistent from day to day. The results the 2002 ozone season show that the m odeling system tends to over-predict m i nim u mconcentrations and slightly underpredict peak concentrations. The over-prediction of m i nim u m concentrations is not of great regulatory concern since attainm e nt tests are based on the application of relative response factors to daily peak concentrations. It is still im portant to appropriately m odel the over-night ozone

rem oval processes and regional transport to accurately estim ate peak concentrations.

The m odel perform a nce for the W a shington D.C. area averaged over all stations and all days

m eet the guidelines suggested by EPA. The criteria for acceptable m odel perform a nce are m e t on

m o st individual days as well. No significant differences in m odel perform a nce for ozone and its precursors were encountered across the OTC. W h ile there are som e differences between the spatial data between sub-regions, there is nothing to suggest a tendency for the m odel to respond in a system atically different

m a nner between regions. Exam ination of the statistical m e trics by sub-region confirm s the absence of significant perform a nce problem s aris ing in one area but not in another, building confidence that the CMAQ m odeling system is operating consistently across the full OTC dom ain.

The m odeling system is doing a good job of appropriately estim ating 8-hour average surface ozone throughout the OTC and in the W a shington D.C. area. This confidence in the m odeling results allows for the m odeling system to be used to support the developm ent of em issions control scenarios and State Im plem entation Plan to m eet the 8-hour ozone NAAQS.

10.4 Attainment Demonstration

The W a shington region’s dem onstration of achievi ng the 8-hour ozone standard is based on two bodies of evidence: (1) the Com m unity Multi-scale Air Quality Model (CMAQ) and (2) a

num ber of W O E tests supporting the attainm e nt m odeling results. Details of both the CMAQ

m odel and the W O E tests are provided below.

MW AQC Ozone SIP 10-10 May 23, 200710.4.1 Modeling Attainment Test

The m odeled attainm e nt test applied at each m onitor was perform e d using the following equation:

(DVF) I = (RRF) I (DVB) I

W h ere:

(DVB) I = the baseline concentration m onitored at site I, in ppb (RRF) I = the relative response factor (RRF), calculated near site I (DVF) I = the estim ated future design value for the tim e attainm e nt is required, in ppb.

Table 10-5. Modeling Attainment Test Using EPA Preferred Methodology

AIRS ID Site Name Jurisdiction State DVB RRF DVF 11-001-0025 Takom a District of Colum b ia --- 8 8

. 7 0

. 8 9 2 79 11-001-0041 River Terrace District of Colum b ia --- 8 9

. 0 0

. 8 8 3 78 11-001-0043 McMillan District of Colum b ia --- 9 2

. 7 0

. 8 8 3 81 2 4

- 0 0 9

- 0 0 1 0 C a l v e r t C a l v e r t M D N A 0

. 8 3 6 N A 2 4

- 0 1 7

- 0 0 1 0 S o u t h e r n M D C h a r l e s M D 9 3

. 0 0

. 8 0 8 75

24-021-0037 Frederick Municipal Airport F r e d e r i c k M D 8 7

. 3 0

. 8 4 6 73

2 4

- 0 3 1

- 3 0 0 1 R o c k v i l l e Montgom ery M D 8 6

. 7 0

. 8 8 1 76 2 4

- 0 3 3

- 0 0 0 2 G r e e n b e l t P r i n c e George' s M D 9 4

. 0 0

. 8 6 9 81 24-033-8003 PG Equestrian Center Prince George' s MD 9 4

. 0 0

. 8 6 5 81 51-013-0020 Aurora Hills Arlington County VA 9 6

. 7 0

. 8 9 1 86 5 1

- 0 5 9

- 0 0 0 5 C h a n t i l l y F a i r f a x County V A 8 7

. 0 0

. 8 6 7 75 51-059-0018 Mount Vernon Fairfax County VA 9 6

. 7 0

. 8 8 3 85 5 1

- 0 5 9

- 0 0 3 0 F r a n c o n i a F a i r f a x County V A 9 5

. 0 0

. 8 8 83 5 1

- 0 5 9

- 1 0 0 5 A n n a n d a l e F a i r f a x County V A 9 4

. 0 0

. 8 8 82 5 1

- 0 5 9

- 5 0 0 1 M c L e a n F a i r f a x County V A 8 8

. 0 0

. 8 8 3 77 5 1

- 1 0 7

- 1 0 0 5 A s h b u r n L o u d o u n County V A 9 0

. 0 0

. 8 6 9 78

5 1

- 1 5 3

- 0 0 0 9 L o n g P a r k Prince William County VA 8 5

. 0 0

. 8 7 1 74

5 1

- 5 1 0

- 0 0 0 9 A l e x a n d r i a A l e x a n d r i a City V A 9 0

. 0 0

. 8 8 3 79

Current design values were calculated using the EPA m e thod of averaging the three design value periods which include the baseline inventory year. Specifically, the average design value was calculated using the 2000-2002, 2001-2003, and 2002-2004 periods. In the event that there was less than five years of available data at a m onitoring site the f o llowing procedure was used:

1. 3 years of data - The current design value was based on a single design value.

2. 4 years of data - The current design value was based on an average of two design value periods.

MW AQC Ozone SIP 10-11 May 23, 20073. Less than 3 years of data – The site was not used in the attainm e nt test. A 3x3 array of grid cells surrounding each m onitor was used in the m odeled attainm e nt test as

recom m e nded by EPA for 12-km grid resolution m odeling to calculate RRFs. The predicted 8-hour daily m a xim u m concentrations from each m odeled day were used in the

m odeled attainm e nt test with the nearby grid cell with the highest predicted 8-hour daily

m a xim u m concentration with baseline em issions for each day considered in the test, and the grid cell with the highest predicted 8-hour daily m a xim u m concentration with the future em issions for each day in the test.

The RRFs used in the m odeled attainm e nt test were com puted by taking the ratio of the m e an of the 8-hour daily m a xim u m predictions in the future to the m ean of the 8-hour daily m a xim u m predictions with baseline em issions, over all relevant days. The following rules shall were applied to determ ine the num ber of days and the m i nim u m threshold at each ozone m onitor:

1. If there were 10 or m o re days with daily m a xim u m 8-hour average m odeled ozone > 85 ppb an 85 ppb threshold was used.
2. If there was less than 10 days with daily m a xim u m 8-hour average m odeled ozone > 85 ppb the threshold was reduced to as low as 70 ppb until there was 10 days in the m ean RRF calculation.
3. If there was less than 10 days with daily m a xim u m 8-hour average m odeled ozone > 70 ppb then all days > 70 ppb were used.
4. No RRF calculations shall be perform e d for sites with less than 5 days > 70 ppb.

10.4.2 Unmonitored Area Analysis

An “unm onitored area analysis” using m odel adjusted spatial fields was perform e d. The basic steps of this process were as follows:

1. Interpolated am bient ozone design value data to create a set of spatial fields. 2. Adjusted the spatial fields using gridded m odel output gradients (base year values). 3. Applied gridded m odel RRFs to the m odel adjusted spatial fields. 4. Determ ined if any unm onitored areas are predicted to exceed the NAAQS in the future.

Recom m e nded EPA guidance was utilized in the “unm onitored area analysis”.

10.4.3 Emissions Inventories

For areas with an attainm e nt date of no later than June 15, 2010, the em ission reductions need to be im plem ented no later than the beginning of the 2009 ozone season. A determ ination of attainm e nt will likely be based on air quality m onitoring data collected in 2007, 2008, and 2009. Therefore, the year to project future em issions should be no later than the last year of the three
year m onitoring period; in this case 2009.

MW AQC Ozone SIP 10-12 May 23, 2007The 2002 base year em issions inventory were projected to 2009 using standard em issions projection techniques. Future year 2009 invent ories were provided by two Regional Planning Organizations (RPO’s), the MidAtlantic Visibility Union (MANE-VU) and the Visibility Im provem e nt State and Tribal Association of the Southeast (VISTAS) were used in the attainm e nt dem onstration.

Em ission inventory guidance docum ents were followed for developing projection year inventories for point, area, m obile, and bioge nic em issions. These procedures addressed projections of spatial, tem poral, and chem ical com position change between the base year and projection year. The alternative control strategies for evaluation in the attainm e nt dem onstration were selected by MW AQC. These were selected from groups of strategies developed by the technical subcom m ittees responsible for identifying and developing the regulations and/or control

m easures. Consideration was given to m a intaining consistency with control m easures likely to be im plem ented by other m odeling dom ains. Also, technology-based em ission reduction requirem e nts m a ndated by the Clean Air Act were included in the future year m odel runs.

10.4.4 Attainment Modeling Results Applying EPA’s preferred m e thodology to CMAQ m odel results, the future design values for 2009 shown in Table 10-5 indicate only two m onitors will be at or slightly above 84 parts per billion (ppb). All other m onitors (sixteen) will be below 85 ppb. These results place the W a shington, DC-MD-VA region well within EPA’s range, 82-87 ppb, where W O E will contribute significantly to the region’s attainm e nt dem onstration. 4

10.5 Weight of Evidence (WOE) Analysis All photochem i cal m odels including the CMAQ m odel has inherent uncertainties. Over or under prediction m a y result from uncertainties associated with em ission inventories, m e teorological data, and representation of ozone photochem i stry in the m odel. Therefore, EPA photochem i cal

m odeling guidance docum ent provides for other evidence (W eight of Evidence) to address these

m odel uncertainties so that proper assessm ent of the probability to attain eight-hour ozone standard can be m a de.

There were num ber of W O E tests em ployed to test the potential of W a shington, D.C. area to attain the eight-hour standard in 2009. Details of each of these tests are being provided below.

4 Guidance on the Use of Models and Other Analyses in Attainm e nt Dem onstrations for the 8-hour Ozone NAAQS, EPA-454/R-05-002, October 2005, “Table 2-1: Guidance for W e ight of Evidence Determ inations,” p. 9.

MW AQC Ozone SIP 10-13 May 23, 200710.5.1 Trend in 8-hour Oz one Design Value

Trend in the 8-hour ozone design values between 1988 and 2006 is shown in Figure 10-2. It is clear that the design value has significantly decreased during this period from 0.116 ppm in 1988 to 0.091 ppm in 2006.

Figure 10-2. Trend in 8-Hour Oz one Design Value in the Washington, DC-MD-VA Nonattainment Area

8- ho u r O z o n e D esi g n V a l u e W ash i n g t on , D

. C

. R e gi on , 1988- 2006

0.

11

5

0. 10

7

0. 1 0 0 0 . 1 0 0 0. 10

1

0. 09

6 0 . 0 9 8

0. 09

4 0. 10

0 0. 10

1 0 . 1 0 6

0 . 1 0 1

0. 09

7 0. 0 9 7 0 .0

9 9

0. 09

6

0 . 0 9 1 0

. 0 9 1 0

. 1 1 6

0. 07 5 0. 08 5 0. 09 5 0. 10 5 0. 11 5 0. 12 5

1 9 8 8 19 8 9 19 90 1 9 9 1 1 9 9 2 1 9 9 3 1 9 9 4 1 9 9 5 19 96 1 9 9 7 1 9 9 8 1 9 9 9 20 00 2 0 0 1 2 0 0 2 2 0 0 3 2 0 0 4 2 0 0 5 20 0 6

Ye arDesign Value (ppm)

8- h our O z one NAAQS

MW AQC Ozone SIP 10-14 May 23, 200710.5.2 Trend in Exceedance Count across All Monitors

The trend in the total num ber of exceedances across all m onitors between 1997 and 2006 is shown in Figure 10-3. Monitor exceedances occur whenever a m onitor’s 8-hour ozone concentration is greater than or equal to 0.08 ppm . Though the num ber of m onitors in the W a shington, DC-MD-VA 8-hour nonattainm e nt area has actually increased by 20 percent (15 in 1997 to 18 in 2006), the num ber of exceedances decreased by 30 percent (30 in 1997 to 21 in 2006).

Figure 10-3. Trend in Monitored Exceedances across All Monitors in the Washington, DC-MD-VA Nonattainment Area

E xceed an ces of 8- h o u r O z o n e S t an d a r d

W ash i n g t on , D

. C

. R e g i o n , 1997- 2006

30 48

40

11 22 38

8 8 20 21

5 30 55

19 9 7 19 98 19 99 20 00 20 01 20 02 2 0 03 2 0 0 4 2 0 0 5 2 0 0 6

Yea rNumberofExceedance Days N o t e : H e a l t h S t a n d a r d f o r 8

- hour O z o n e i s 0

. 0 8 ppm

. D a t a s h ow n a r e t h e num be r of d a y s i n
ea ch year w h en at l east one m oni t o r i n t h e r e g i on r ecor d ed g r ound

- l e vel oz on e concent r at i ons
a bov e t h e 8

- hour he a l t h s t a nda r d

.

MW AQC Ozone SIP 10-15 May 23, 200710.5.3 Trend in Nitrogen Dioxide Levels

The trend in nitrogen dioxide levels between 1988 and 2006 is shown in Figure 10-4. It is clear from the figure that the levels overall have been declining between 1988 and 2006. A significant (0.011 ppm ) decrease is apparent between the two years (1988-2006). Im plem entation of NOx SIP call has brought down significantly the nitroge n dioxide em issions in power plants in upwind areas after 2003. As a result, nitrogen dioxide concentration levels have also been reduced, which is clearly seen after 2003 in the figure below. The NAAQS for NO 2 (Annual Mean Concentration) is 0.053 ppm and therefore the region is well below the standard. As NO 2 is a very im portant factor in ozone form ation, its decline over the years has been the one of the

m a in reasons behind the reduction in ozone levels in the region.

Figure 10-4. Trend in Nitrogen Dioxide Annual Average Concentration in the Washington, DC-MD-VA Nonattainment Area

A n nua l A v er a g e N i t r oge n D i ox i d e C o nc e n t r a t i o ns W ash i n g t o n , D C N o n a t a i n ment A r ea, 198 8- 20 06

0.

0 3 0 0. 0 3 0

0. 0 28 0 . 02

9 0 .0

3 0

0. 026 0 . 0 26 0. 0 2 6 0 . 02

7

0 .0

2 5

0. 02

3 0. 0 24 0 .0

2 5 0 .0

2 6

0 . 02

4 0. 02

4 0 .0

3 1

0 . 01

9 0.

03

0

0. 01 5 0. 02 0 0. 02 5 0. 03 0 0. 03 5

1 9 88 1 9 89 1 99

0 1 9 91 1 9 92 1 99

3 1 9 94 1 9 95 1 9 96 1 9 97 1 99

8 1 9 99 2 0 00 2 0 01 2 0 02 2 0 03 2 0 04 2 0 05 2 00

6

Y earConcentration (ppm)

MW AQC Ozone SIP 10-16 May 23, 200710.5.4 Trend in Carbon Monoxide Levels

The trend in carbon m onoxide levels between 1988 and 2006 is shown in Figure 10-5. It is clear from the figure that the levels have been declining between 1988 and 2006. A significant (9.4
ppm ) decrease is apparent between the two years (1988-2006). Though not very significant, carbon m onoxide does play a role in ozone form ation and so its decline over the years has certainly helped reduce ozone levels in the region.

Figure 10-5. Trend in 2 nd High 1-Hour Carbon Monoxide Concentration in the Washington, DC-MD-VA Nonattainment Area

2 nd H i g h 1- ho ur C a r b o n M o no x i de C o n c en t r at i o ns W a s h i n gt on , D C N o n a t t ai nme n t A r ea, 19 88- 2 006

1 3.

7 13 . 7 13 . 6

9 . 7 11 . 4

9. 8 1 0.

2

8 . 1 8. 9

7. 3 7 .5

6 .6 6. 3 7 .5 8. 3

4 . 0 3. 8 4 . 0 1 3 .4

2 4 6 8 10 12 14 16

19

88 19 8 9 1 9 90 19 91 19 92 19 93 19 94 19 95 19 96 19 97 19 98 19 99 20 00 20 01 20 02 20 03 20 04 20 05 20 06

Y earConcentration (ppm)

MW AQC Ozone SIP 10-17 May 23, 200710.5.5 Trend in VOC and NOx Emissions

Com p arison of VOC and NOx em issions in the years 2002, 2008, and 2009 are shown in Figures 10-6 and 10-7 respectively.

It is clear from Figure 10-6 that total VOC em i ssions are projected to decrease significantly in 2008 and 2009 from 2002 levels. VOC em issions are projected to decrease between 2002 and 2009 for area, nonroad and onroad sources. Point source VOC em ission will be increasing a

sm all am ount bit in 2008 and 2009.

Figure 10-7 shows that total NOx em issions are projected to decrease significantly in 2008 and 2009 from 2002 levels. NOx em issions are projected to decrease between 2002 and 2009 for point, nonroad and onroad sources. Area source NOx em ission will be increasing a sm all am ount in 2008 and 2009.

Figure 10-6. VOC Emissions in the Washi ngton, DC-MD-VA Nonattainment Area



### V O C E m i s si ons by S our c e W ashi ngt on, D C N onat t a i n m e nt A r ea

12.

91 192 . 64 125. 79 448. 28

116. 94 359. 03

92.

48 70. 98 181 . 59

13.

98 348. 74

8

8.

66 66. 68 179. 10

14.

31

0 100 200 300 400 500



### P o i n t A r ea N on- r o a d O n - r oa d Tot alEmissions (tpd) 2002 2008 2009

MW AQC Ozone SIP 10-18 May 23, 2007Figure 10-7. NOx Emissions in the Washi ngton, DC-MD-VA Nonattainment Area



### N O x E m i s s i ons by S o ur c e W a s h i ngt on, D C N ona t t a i n m e nt A r ea

2

20.

60

8 5.

72 26 6

. 6 5 5 97 . 2

2

24.

25

2

7.

01 2

29.

36

1 6

0.

30 49 3.

49

7

6

. 9

1

7 5.

10 27 . 4

8 113 . 0

3 14 6

. 5

3 3 6 2.

05

0 100 200 300 400 500 600 700

P o i n t A r ea N on- road O n - r oad T o t a lEmissions (tpd)

200 2 200 8 200 9

10.5.6 Spatial Extent of NAAQS Violations

The W a shington, DC-MD-VA nonattainm e nt area’s ge ographical extent of violation has been decreasing in size since 1990. Figure 10-8 shows a decrease in the spatial extent of the nonattainm e nt zone within the W a shington, DC-MD-VA nonattainm e nt region between 1990 and 2006. The actual nonattainm e nt geographical area exceeding 8-hour ozone design value of 0.08 ppm (84 ppb) has been shown in red color in the figure. It is clear that alm o st entire W a shington, DC m e tropolitan region was in nonattainm e nt during 1988-1990. The 2004-2006 data show that the geographical extent of this ar ea has reduced in size to portions of the District of Colum b ia, the city of Alexandria, and Arlington, Fairfax, Prince W illiam s , Charles, Calvert, and Prince George' s counties. Ozone levels observed in these areas are not only the product of local em issions but are also im pacted a great deal by the transport of ozone and its precursors from upwind areas. Not only the nonattainm e nt zone in 2006 has been reduced to less than half in size com p ared to 1990, but also the design value has also been reduced by about 16 percent from 108 ppb to 91 ppb.

MW AQC Ozone SIP 10-19 May 23, 2007Figure 10-8. Comparison of Nonattainment Z o nes w i thin Washington, DC-MD-VA Nonattainment Area (1990 – 2006)

10.5.7 Trend in 8-Hour Oz one Exceedance Days and High Temperature Days

Ozone concentrations are quite dependent on m e teorological conditions especially tem p erature. High tem p eratures help drive ozone production. Correlations can be m a de between ozone concentrations and m e teorological variables such as the num ber of 90oF days. Hot dry sum m e rs can produce long periods of elevated ozone c oncentrations while ozone production can be lim ited during cool and wet sum m e rs.

Tem p erature data from the Dulles International Airport were reviewed during years considered

warm er than norm a l to determ ine any trends between 8-hour ozone values and high tem p erature days. The years analyzed were 1998, 2002, 2005, and 2006. During these years, there were m o re than 30 days when tem p eratures equaled or exceeded 90oF. Table 10-6 lists the num ber of 8-hour ozone exceedance days and the days with tem p eratures ≥ 90oF in each of the four years

m e ntioned above in the W a shington, DC-MD-VA nonattainm e nt area. In com p aring these years to 1998, there has been a decline of 21% (2002), 58% (2005) and 56% (2006) in the num ber of 8-hour ozone exceedance days. The ratio of 8-hour exceedance days and days with m a xim u m tem p erature ≥ 90oF (fraction of the days with tem p eratures over 90oF that had exceedances) is also declining through these years.

MW AQC Ozone SIP 10-20 May 23, 2007Table 10-6. Temperature and 8-Hour Oz one Exceedances in the Washington, DC-MD-VA Oz one Nonattainment Area

Y e a r 8

- H o u r O z o n e Exceedance Day s Day s w i th Max. Temp ≥ 90oF Ratio of 8-Hour Exceedance Day s and day s w i th Max. Temp ≥ 90oF 1 9 9 8 4 8 3 7 1

. 3 0 2 0 0 2 3 8 4 1 0

. 9 2 2 0 0 5 2 0 3 3 0

. 6 0 2 0 0 6 2 1 3 7 0

. 5 7

Trend in the num ber of 8-hour ozone exceedance days and the num ber of days with m a xim u m tem p erature ≥ 90oF is shown in Figure 10-9. A close l ook at the Figure 10-9 reveals the num ber of ozone exceedance days on decline since 1998 even though the num ber of high tem p erature days has rem a ined high and at m o re or less the sam e level in the four analysis years. The reason behind fewer ozone exceedance days after 1998 can be attributed to lower em ission levels. W h ile during 1998 tem p eratures below 90oF were able to cause an exceedance, beginning 1999 exceedances occurred only when tem p erature reached m o re than 90oF due to lower em ission levels.

It is clear that the em ission levels have been decreasing over the years and since 1999 they have been reduced to a level that the tem p erature m u st be m o re than 90oF in order to exceed. A

num ber of federal control m easures such as, Acid Rain Program (Phase 1 – 1996 & Phase 2 – 2000) and NOx SIP Call (2004) were im plem ente d during 1996-2004 to control em issions level. Also a wide range of local and regional control m easures were im plem ented by Maryland, Virginia, and the District of Colum b ia beginning 1996, full benefits of which began in 1998. Em issions reductions from all the above m e ntioned m easures com b ined resulted in the decrease in the num ber of ozone exceedance days since 1998.

MW AQC Ozone SIP 10-21 May 23, 2007Figure 10-9. 8-Hour Oz one Exceedance Days and High Temperature Days ( ≥ 90oF) in the Washington, DC-MD-VA Nonattainment Area

15 20 25 30 35 40 45 50

199 8 199 9 200 2 200 5 200 6

Ye a rNumberofDays 

### 8- H o u r O z on e Ex ceeda n c e D a y s 

### 90 D egr ee Da y s

10.5.8 Trend in Meteorology-Adjusted Oz one Levels

Cox and Chu developed an advanced statisti cal technique, which allows the effects of

m e teorology (tem perature, hum idity, etc.) to be separated from the 8-hour ozone levels. EPA applied this technique at a num ber of m onitors across the country to develop m e teorology adjusted 8-hour daily m a xim u m ozone levels and com p ared them to the observed 8-hour daily

m a xim u m ozone levels. This analysis was published in the EPA’s ozone trend report titled “Weather Makes a Difference: 8-hour Ozone Trends for 1997-2005” in August 2006 and is available at http://www.epa.gov/air/airtrends/weather.htm l

. EPA perform e d this analysis for W a shington, DC and Beltsville (Maryland) in W a shington, DCMD-VA ozone non-attainm e nt area. Figure 10-10 shows the results for these two sites. It is quite clear from the two figures that a consistently declining trend is observed in ozone levels in response to consistently declining VOC and NOx em issions levels once the effect of

m e teorology has been rem oved. W ith em issions further projected to decline in 2009, ozone levels will also decline in the attainm e nt year.

MW AQC Ozone SIP 10-22 May 23, 2007Figure 10-10. Meteorology Adjusted Oz one Season Average 8-Hour Daily Maximum Oz one Trend (1997-2005)

Source: Cox, W illiam M. and Shao-Hang Chu. (1996). “Assessm ent of Interannual Ozone Variation in Urban Areas from a Clim atological Perspective.” Atmospheric Environment , 30.14, 2615-2625.

MW AQC Ozone SIP 10-23 May 23, 200710.5.9 Alternative Design Value Calculation Techniques

10.5.9.1 Methodologies for Calculating Baseline Design Values

The baseline m easured concentrations at each m onitoring site is the anchor point for future year projected concentrations. The baseline design values are projected to the future using RRFs. In practice, the choice of the baseline design value can be critical to the determ ination of the estim ated future year design values. Therefore, careful consideration should be given to the calculation of baseline values.

EPA guidance also states that there are several possible m e thodologies to calculate baseline design values. Although EPA recom m e nds using the average of the three design value periods which include the baseline inventory year, there is a high degree of uncertainty that this approach best represents baseline concentrations. Specifically, there is concern that weighting the 2002 concentrations three tim es in the calculation arbitrarily places too m u ch weight on an individual year of m e teorology and does not accurately reflect clim ate variability which has a significant im pact on future design value projections. Ideally, a statistical m odel that analyzes the inter-annual variability of pollutant concentrations due solely to m e teorology fluctuations 5

, 6 should be used to predict the probability of future violation of the NAAQS at any m onitoring site. In the absence of this statistical m odeling analysis, a series of baseline design value calculations were perform e d in order to assess the effect on future design value projections. Th e following three calculation techniques were perform e d:

1. EPA Recom m e nded Method - Baseline design values were calculated using the weighted average approach, using the three design value periods which include the baseline inventory year. Specifically, the average design values were calculated using the 2000- 2002, 2001-2003, and 2002-2004 periods as described in Section 10.4.1.

2. 2001-2003 Design Value - Baseline design values were calculated using the design value period which straddles the 2002 baseline inventory year. This approach is an alternative approach in the EPA guidance. Sites that did not have adequate data available to calculate a design value for this period were excluded.

3. 2000-2004 Straight Average Design Value - Baseline design values were calculated using a straight average of the 5 year period centered on the 2002 baseline inventory year. Sites with less than 5 years of data were averaged over the num ber of availableyears of data. This approach provides a reasonable period of record to assess the interannual variability of m e teorology without arbitrarily placing em phasis on any one year of

m e teorology.

5 Cox, W illiam M. and Shao-Hang Chu. 1993. Meteorologically Adjusted Ozone Trends in Urban Areas: A Probabilistic Approach. Atm o spheric Environm ent: Part B: Urban Atm o sphere (ATMOS. ENVIRON., PART B). Vol. 27B, no. 4, pp. 425-434. 1993.
6 Cox, W illiam M. and Shao-Hang Chu. 1996. Assessment of Interannual Ozone Variation in Urban Areas from a Climatological Perspective. Atm o spheric Environm ent: 30.14, 2615-2625.

MW AQC Ozone SIP 10-24 May 23, 2007Table 10-7. Methodologies for Calculating Baseline Design Values

AIRS ID Site Name Jurisdiction State EPA Method

DVB 2001- 2003 DVB 2000-2004 Straight Average

DVB 1 1

- 0 0 1

- 0 0 2 5 T a k o m a District of Colum b ia --- 88.7 88 87.6
1 1

- 0 0 1

- 0 0 4 1 R i v e r T e r r a c e District of Colum b ia --- 89.0 92 85.2
1 1

- 0 0 1

- 0 0 4 3 M c M i l l a n District of Colum b ia --- 92.7 94 89.6
2 4

- 0 0 9

- 0 0 1 0 C a l v e r t C a l v e r t M D N A N A N A
2 4

- 0 1 7

- 0 0 1 0 S o u t h e r n M D C h a r l e s M D 9 3

. 0 9 4 9 1

. 6 24-021-0037 Frederick Municipal Airport F r e d e r i c k M D 8 7

. 3 8 8 8 5

. 8
2 4

- 0 3 1

- 3 0 0 1 R o c k v i l l e Montgom e r y M D 8 6

. 7 8 8 8 5

. 2
2 4

- 0 3 3

- 0 0 0 2 G r e e n b e l t Prince George' s MD 94.0 93 92.5 24-033-8003 PG Equestrian Center Prince George' s MD 94.0 NA 94.7 5 1

- 0 1 3

- 0 0 2 0 A u r o r a H i l l s Arlington County VA 96.7 99 92.8 5 1

- 0 5 9

- 0 0 0 5 C h a n t i l l y Fairfax County VA 87.0 89 85.2 5 1

- 0 5 9

- 0 0 1 8 M o u n t V e r n o n Fairfax County VA 96.7 97 95.4 5 1

- 0 5 9

- 0 0 3 0 F r a n c o n i a Fairfax County VA 95.0 97 91.8 5 1

- 0 5 9

- 1 0 0 5 A n n a n d a l e Fairfax County VA 94.0 NA 94.0 5 1

- 0 5 9

- 5 0 0 1 M c L e a n Fairfax County VA 88.0 88 86.0 5 1

- 1 0 7

- 1 0 0 5 A s h b u r n Loudoun County VA 90.0 92 87.0 5 1

- 1 5 3

- 0 0 0 9 L o n g P a r k Prince W illiam County VA 85.0 87 83.6
5 1

- 5 1 0

- 0 0 0 9 A l e x a n d r i a Alexandria City VA 90.0 92 86.8

10.5.9.2 Methodologies for Calculating Relative Response Factors
In addition to the variability associated with base design value calculations, there is also uncertainty in the calculation of relative response factors (RRFs). As a result, three techniques were used to calculate the RRFs to assess the im pact on future design value projections. RRF calculations for each of the following techniques are provided in Table 10-8.

1. EPA Recom m e nded Method – Utilizes the def a ult recom m e ndations f o r “nearby” grid cells, with a 3x3 grid cell array for 12-km resolution m odeling. The relative response factor (RRF) used in the m odeled attainm e nt test is com puted by taking the ratio of the

m ean of the 8-hour daily m a xim u m predictions in the future to the m ean of the 8-hour daily m a xim u m predictions with baseline em issions, over all relevant days.

EPA recom m e nds this approach because of the following three reasons:

a. Consequence of a control strategy m a y be “m igration” of a predicted peak. If a State were to confine its attention only to the cell containing a m onitor, it m i ght underestim ate the RRF (i.e., overestim ate the effects of a control strategy).

b. Uncertainty in the form ulation of the m odel and the m odel inputs is consistent with recognizing som e leeway in the precision of the predicted location of daily m a xim u m ozone concentrations.

MW AQC Ozone SIP 10-25 May 23, 2007c. Standard practice in defining a gridded m odeling dom ain is to start in the southwest corner of the dom ain, and determ ine grid cell location from there. Considering several cells “near” a m onitor rather than the single cell containing the m onitor dim i nishes the likelihood of inappropriate results which m a y occur from the geom etry of the superim posed grid system

. 2. Grid Cell Average Technique – Utilizes the def a ult recom m e ndations f o r “nearby” grid cells, with a 3x3 grid cell array for 12-km resolution m odeling. The relative response factor (RRF) used in the m odeled attainm e nt test is com puted by taking the ratio of the

m ean of the 8-hour daily m a xim u m predictions averaged across the 3x3 grid cell array surrounding the m onitor in the future to the m ean of the 8-hour daily m a xim u m predictions averaged across the 3x3 grid cell array surrounding the m onitor with baseline

em issions, over all relevant days. The following rules shall were applied to determ ine the num ber of days and the m i nim u m threshold at each ozone m onitor:

a. If there were 10 or m o re days with daily m a xim u m 8-hour average m odeled ozone > 85 ppb, averaged over the 3x3 grid cell array, an 85 ppb threshold was used.

b. If there was less than 10 days with daily m a xim u m 8-hour average m odeled ozone > 85 ppb, averaged over the 3x3 grid cell array, the threshold was reduced to as low as 70 ppb until there was 10 days in the m ean RRF calculation.

c. If there was less than 10 days with daily m a xim u m 8-hour average m odeled ozone > 70 ppb, averaged over the 3x3 grid cell array, then all days > 70 ppb was used.

d. No RRF calculations shall be perform e d for sites with less than 5 days > 70 ppb, averaged over the 3x3 grid cell array. This technique is effective in that it only looks at days where the average 8-hour ozone

m a xim u m surrounding the m onitor exceeds 85 ppb and excludes the evaluation of days that have an isolated peak or a tight concentration gradient in the vicinity of the m onitor that can be difficult to m odel.

3. Grid Cell Only Technique – Utilizes the grid cell where the m onitor is located and does
not em ploy an array of grid cells surrounding the m onitor. The relative response factor (RRF) used in the m odeled attainm e nt test is com puted by taking the ratio of the m e an of the 8-hour daily m a xim u m predictions in the future to the m ean of the 8-hour daily

m a xim u m predictions with baseline em issions, over all relevant days. There are a few reasons why it m i ght be appropriate to use this technique:

a. There are occasions where the use of unm onitored grid cells nearby a m onitor m a y not adequately characterize what is happening at the m onitor.

b. Model perform a nce evaluations (MPE) are only conducted for the grid cells containing m onitors; therefore, it m a y be beneficial to have the m odel attainm e nt test

rem a in consistent with the MPE and only use these grid cells.

MW AQC Ozone SIP 10-26 May 23, 2007c. Calculating RRFs based on nearby cells that change locations between the baseline sim u lation and future sim u lation (not paired in space) m a y lead to erroneous and

m i sleading conclusions.

Table 10-8. Methodologies for Calculating Relative Response Factors

AIRS ID Site Name Jurisdiction State EPA Method 9-Cell Average Method Grid Cell Only Method 1 1

- 0 0 1

- 0 0 2 5 T a k o m a District of Colum b ia --- 0

. 8 9 2 0

. 8 7 4 0

. 8 8 6 1 1

- 0 0 1

- 0 0 4 1 R i v e r T e r r a c e District of Colum b ia --- 0

. 8 8 3 0

. 8 7 2 0

. 9 0 9 1 1

- 0 0 1

- 0 0 4 3 M c M i l l a n District of Colum b ia --- 0

. 8 8 3 0

. 8 7 2 0

. 9 0 9 2 4

- 0 0 9

- 0 0 1 0 C a l v e r t C a l v e r t M D 0

. 8 3 6 0

. 8 1 5 0

. 8 1 2 4

- 0 1 7

- 0 0 1 0 S o u t h e r n M D C h a r l e s M D 0

. 8 0 8 0

. 8 0 6 0

. 7 9 4 24-021-0037 Frederick Municipal Airport F r e d e r i c k M D 0

. 8 4 6 0

. 8 3 3 0

. 8 4 4 2 4

- 0 3 1

- 3 0 0 1 R o c k v i l l e Montgom e r y M D 0

. 8 8 1 0

. 8 6 1 0

. 8 6 2 4

- 0 3 3

- 0 0 0 2 G r e e n b e l t Prince George' s MD 0

. 8 6 9 0

. 8 5 7 0

. 8 5 7 24-033-8003 PG Equestrian Center Prince George' s MD 0

. 8 6 5 0

. 8 3 8 0

. 8 3 7 5 1

- 0 1 3

- 0 0 2 0 A u r o r a H i l l s Arlington County VA 0

. 8 9 1 0

. 8 7 5 0

. 8 9 3 5 1

- 0 5 9

- 0 0 0 5 C h a n t i l l y Fairfax County VA 0

. 8 6 7 0

. 8 5 8 0

. 8 8 8 5 1

- 0 5 9

- 0 0 1 8 M o u n t V e r n o n Fairfax County VA 0

. 8 8 3 0

. 8 7 2 0

. 8 6 8 5 1

- 0 5 9

- 0 0 3 0 F r a n c o n i a Fairfax County VA 0

. 8 8 0

. 8 7 3 0

. 8 7 7 5 1

- 0 5 9

- 1 0 0 5 A n n a n d a l e Fairfax County VA 0

. 8 8 0

. 8 7 3 0

. 8 7 7 5 1

- 0 5 9

- 5 0 0 1 M c L e a n Fairfax County VA 0

. 8 8 3 0

. 8 6 9 0

. 8 6 4 5 1

- 1 0 7

- 1 0 0 5 A s h b u r n Loudoun County VA 0

. 8 6 9 0

. 8 7 2 0

. 8 7 4 5 1

- 1 5 3

- 0 0 0 9 L o n g P a r k Prince W illiam County VA 0

. 8 7 1 0

. 8 6 5 0

. 8 6 6 5 1

- 5 1 0

- 0 0 0 9 A l e x a n d r i a Alexandria City VA 0

. 8 8 3 0

. 8 7 2 0

. 8 6 8

10.5.9.3 Future Design Value Ranges
In order to assess the sensitivity of the f u ture design value calculations, a m a trix using relative response factor and base design values. This results in 9 com b inations of future design values for each m onitor, except where m i ssing data is noted. A sum m a ry of the m i nim u m and m a xim u m DVFs for each m onitor is provided in Table 10-9.

The m i nim u m DVFs for all m onitors fall below the 85 ppb attainm e nt threshold. It is also im portant to note that there is a high degree of sensitivity in the DVF calculations f o r the Arlington County m onitor, where the range is from 81 ppb to 88 ppb. Detailed calculations are provided in Appendix G Attachm e nt 11 for all runs conducted by the OTC, ASIP, and VADEQ.

MW AQC Ozone SIP 10-27 May 23, 2007Table 10-9. Future Design Value Ranges (BOTW +VA CAIR Modeling Run)

AIRS ID Site Name Jurisdiction State Minimum DVF Maximum DVF 1 1

- 0 0 1

- 0 0 2 5 T a k o m a District of Colum b ia --- 76 79 1 1

- 0 0 1

- 0 0 4 1 R i v e r T e r r a c e District of Colum b ia --- 74 83
1 1

- 0 0 1

- 0 0 4 3 M c M i l l a n District of Colum b ia --- 78 84
2 4

- 0 0 9

- 0 0 1 0 C a l v e r t C a l v e r t M D N A N A
2 4

- 0 1 7

- 0 0 1 0 S o u t h e r n M D C h a r l e s M D 72 75 24-021-0037 Frederick Municipal Airport F r e d e r i c k M D 71 74
2 4

- 0 3 1

- 3 0 0 1 R o c k v i l l e Montgom e r y M D 73 77 2 4

- 0 3 3

- 0 0 0 2 G r e e n b e l t Prince George' s MD 79 81 24-033-8003 PG Equestrian Center Prince George' s MD 78 81 5 1

- 0 1 3

- 0 0 2 0 A u r o r a H i l l s Arlington County VA 81 88 5 1

- 0 5 9

- 0 0 0 5 C h a n t i l l y Fairfax County VA 73 79 5 1

- 0 5 9

- 0 0 1 8 M o u n t V e r n o n Fairfax County VA 82 85 5 1

- 0 5 9

- 0 0 3 0 F r a n c o n i a Fairfax County VA 80 85 5 1

- 0 5 9

- 1 0 0 5 A n n a n d a l e Fairfax County VA 82 82 5 1

- 0 5 9

- 5 0 0 1 M c L e a n Fairfax County VA 74 77 5 1

- 1 0 7

- 1 0 0 5 A s h b u r n Loudoun County VA 75 80 5 1

- 1 5 3

- 0 0 0 9 L o n g P a r k Prince W illiam County VA 72 75
5 1

- 5 1 0

- 0 0 0 9 A l e x a n d r i a Alexandria City VA 75 81

10.5.10 Uncertainty in CMAQ Modeling

10.5.10.1 Background

CMAQ is a state-of -the-art air quality m odeling tool used to predict f u ture ozone concentrations for use in attainm e nt dem onstrations. The University of Maryland assessed the m odel’s perform a nce and exam ined the im plications for the attainm e nt dem onstration and weight of evidence. The University of Maryland’s research com p lem e nts the m odel perform a nce evaluation conducted by the Virginia Dept. of Environm ental Quality and described in Section 10.3. The University of Maryland Departm e nt of Meteorology’s research is sum m a rized below. Details of this research are in Appendix G Attachm e nt 15.

10.5.10.2 Analysis of Model Performance

The University of Maryland found that CMAQ does an excellent job of capturing the m e an distribution of surface layer ozone during the ozone season. However, their research identified several characteristics of the m odel that could im pact the conclusions of the attainm e nt m odeling results. The University of Maryland analyses involved com p arisons of surface and aircraft

ozone m easurem ents and CMAQ ozone sim u lations. As described in m o re detail in Appendix G, the results of these analyses indicate the following:

• CMAQ underestim ates ozone concentrations in upwind areas

• CMAQ underestim ates ozone concentrations aloft

• CMAQ overestim ates ozone form ation in urban areas

MW AQC Ozone SIP 10-28 May 23, 2007• CMAQ biases in upwind areas are larger when air quality is poor

• CMAQ underestim ates the contribution of transported pollution on concentrations within the nonattainm e nt area

• CMAQ underestim ates the im portance of NOx controls in upwind areas.

CMAQ Underestimates Ozone Concentrations in Upwind Areas. CMAQ exhibits its best perform a nce in urban areas (sm a ll bias), less success in suburban areas (underestim ates ozone, a larger negative bias), and its worst perform a nce in rural areas (underestim ates ozone m o re, larger negative bias). The m odel’s perform a nce is at its worst in upwind, rural areas. In particular, research indicates that the ozone in Virginia and the Ohio River Valley is under-predicted.

CMAQ may Underestimate Ozone Aloft. In com p arison to aircraft observations, the base-case

m odel run underestim ates the rate of photochem i cal sm og production above about 500 m and overestim ates it below this altitude.

CMAQ Overpredicts Ozone Formation in Urban Areas. The CMAQ m odel tends to overestim ate the rate of form ation and concentration of ozone, especially in VOC-rich urban plum es. The overall chem istry m a y therefore be m o re NO x -lim ited than CMAQ would suggest. It is believed that the CB4 m echanism used in the version of CMAQ run for this SIP is sim p lified and m i ssing reactions that were thought to be inconsequential, but are now known or in som e instances suspected to play a larger role than previously thought. Altogether, these reactions could sequester at least 1.5 ppbv NOx.

CMAQ Biases are Larger when Air Quality is Poor. Biases between CMAQ-calculated and

m easured 8-hour ozone concentrations are m i nim a l (1-2 ppbv) when averaged over the sum m e r but there is a large negative bias in rural upwind areas (7-8 ppbv) on days when air quality is
poor.
CMAQ Underestimates the Contribution of Transported Pollution on Ozone Concentrations in the Nonattainment Area. The transport of ozone into and within the State of Maryland above the nocturnal boundary layer was exam ined using a com b ination of aircraft and ground-based

m easurem ents. These aircraft observations indicate that CMAQ underestim ates transport. The research indicates that when upwind pollution source regions lay over the Ohio River Valley (~59% of aircraft profiles), transport account ed for 69-82 percent of the afternoon boundary layer ozone.5 W h en winds were weak (~27% of aircraft profiles), transport only accounted for 58 percent of the afternoon boundary layer ozone.

The ground level ozone data obtained from MDE m onitoring stations has also been exam ined for evidence of downward m i xing. On days when the transported ozone is low, peak ozone occurs at about 15:00 EST. However when the transported ozone is large, an earlier peak occurs at about 10:00 EST, corresponding to the breakdown of the nocturnal boundary layer. The rate of increase of ozone within this peak is about four tim es greater than that due to pure photochem i stry.

MW AQC Ozone SIP 10-29 May 23, 2007CMAQ Underestimates the Importance of Reducing Upwind NOx Emissions and Overestimates the Significance of Local Sources. Several studies suggest that CMAQ, and likely photochem i cal m odels in general, under-predict the change in ozone concentrations that result from a change in NO x em issions, particularly those from upwind power plants (and large industrial sources). CMAQ shows that although m odel sim u lated NO x reductions result in ozone reductions, the percentage reductions in ozone were sm aller than the percentage reductions in NO x .

Even when com p ared to results from within the 2002 ozone season, CMAQ under- predicts daily ozone variability, and shows im portant m odel perf orm a nce issues in areas just upwind of Maryland on high ozone days, nam e ly in the Ohio River Valley and central Virginia. A study of the 2003 Northeast Blackout [Marufu et al., 2004] shows that the blackout caused a drop of at least 7 ppbv ozone (partly attributable to decreases in power plant em issions), and likely considerably m o re, while a m odeling study of the sam e event [Hu et al., 2006] used CMAQ to predict only a 2.2 ppbv change.

Analysis of ozone trends before and after the NO x SIP Call reveals that Maryland’s ozone im proved significantly after the NO x SIP Call. Ozone values were binned according to peak
tem p erature to rem ove m o st of the effects of m e teorology from the analysis, revealing a consistent 12 percent downward trend in ozone after the SIP Call. An ongoing study by EPA reveals that the NO x SIP call likely produced double the benefit that CMAQ predicted.

10.5.10.3 Implications of CMAQ Performance on Attainment Demonstration

Dem onstrated issues with CMAQ’s perform a nce, particularly with respect to extrem e values and transport, im ply that CMAQ predicted future ozone concentrations are overestim ated for the W a shington, DC-MD-VA non-attainm e nt area. The results im ply that the W a shington, DC-MDVA region m a y be m o re likely to com p ly with the ozone standard than the m odel indicates.

The transport of pollutants from areas outside the region has an extrem ely im portant im pact on the attainm e nt of the 8-hour ozone standard. Th e evidence from both the aircraft and the station ozone data clearly points to the im portance of transport in the overall quality of the air in the W a shington region. 7 Upwind power plant em ission sources of NO x and SO 2 from W e st Virginia, Ohio, and Pennsylvania along the Ohio River Valley play a crucial role in the am ount of ozone and aerosol m easured in the lower troposphere in the Mid-Atlantic region. Due to the higher stack heights of power plants these em issions are m o re likely to be transporter large distances. The effect of the transported ozone is to add ozone early in the day and hence to expand the tim e interval over which the ozone levels m a y exceed 85 ppbv.

In som e instances, em issions in the rural/suburban areas upwind of the W a shington region are dom inated by power-plant em issions. The analysis indicates that ozone after the NO x SIP Call im proved significantly, suggesting that future control program s sim ilar to those im plem ented

7 The study of the relative contribution of transported and local photochem i stry to the ozone data for six exceedance days in August 2002 suggests that if local photochem i stry were the only source of ozone, none of the 6 days

exam ined would have exceeded the 8-hour ozone standard.

MW AQC Ozone SIP 10-30 May 23, 2007over this tim e period should be highly effective as well. This suggests that NO x controls, and especially power plant controls are likely to be sim ilarly effective in controlling ozone in the future.

The research also suggests that regional control program s should be m o re effective than predicted by CMAQ and local program s som e what less effective. Since the bulk of the control
program s in the SIP are regional (e.g. fleet tur nover, heavy duty diesels, and the Clean Air Interstate Rule), greater changes in surface ozone can be expected than those predicted by CMAQ, especially given CMAQ’s lack of response to changes in em issions.

10.5.11 Local Government Voluntary Initiatives

In addition to participating in Clean Air Partners program s (described in the following sections), the local governm e nts and state agencies in the W a shington region have taken a coordinated, proactive approach to reducing em issions attributable to their organizations on an episodic basis. These actions reduce VOC and NOx em issions fr om a variety of source sectors. Program s include:

• Local jurisdictions have com m itted to purchasing low-em ission vehicles reducing

em issions from on-road sources.

• Shutdowns of county waste-to-energy facilities reduce stationary source em issions.

• Reducing em issions from peaking units that generate electricity can reduce NOx

em issions during periods of poor air quality.

• State agencies and county governm e nts ban refu eling of non-em ergency fleet vehicles and application of traffic paint and pesticides, elim inating area source em issions.

• Many of these organizations also ban operation of lawn and garden equipm ent to reduce non-road em issions.

• Mobile em issions are reduced through liberal leave policies and support for teleworking on Code Red Days.

• Tree planting program s are being developed by the local jurisdictions in the region as a long term strategy to im prove air quality. Local jurisdictions in the W a shington region are m a king program com m itm ents reflected in the Voluntary Bundle (Chapter 6) or, in the case of low-em ission vehicle purchases, are reserving

em ission reduction credits that the purchases m a y generate for potential future use in m e eting transportation conform ity. The City of Alexandria has specifically requested that a variety of
program s being im plem ented by the city, includi ng low-em ission vehicle purchases, use of lowVOC paints, Green Building and energy efficiency program s, and episodic program s, be applied in the SIP as weight of evidence. Though the benefits of episodic program s are not reflected in the region’s 2009 controlled inventory, the program s are an im portant part of the region’s attainm e nt strategy and provide additional evidence that the region will attain the ozone standard in 2009.

MW AQC Ozone SIP 10-31 May 23, 200710.5.11.1 Voluntary Action Campaign: Clean Air Partners
Clean Air Partners is a bi-regional public-private partnership in the Baltim ore W a shington region created to develop and im plem ent voluntary action program s to reduce em issions on the days when ozone levels are expected to be high.

The partnership was created in 1994 by the Metropolitan W a shington Air Quality Com m ittee (MW AQC), the Transportation Planning Board of the National Capitol Region (TPB) and the Baltim ore Metropolitan Council (BMC). The partnership, originally known as ENDZONE Partners, has conducted an air quality public education cam paign in the W a shington and Baltim ore m e tropolitan areas since 1995. The purposes of the cam paign are to raise public awareness of air quality issues and to prom ote voluntary actions to im prove air quality. The

cam paign is funded by public funds from Maryland, Virginia, the and District of Colum b ia, and receives staff support from the state air m a nagem e nt agencies. In 1997 the partnership form ed a new form al public-private partnership, hired a m a naging director, and in 1999 changed its nam e to Clean Air Partners.

The Ozone Action Days em ployer program was established in 1995 in the Baltim ore/W a shington region. This program encourages em ployers and their em ployees to take voluntary actions to reduce ozone pollution causing em issions. W h en the Environm ental Protection Agency (EPA) designated both Baltim ore and W a shington, DC m e tropolitan regions as nonattainm e nt for fine particles, Clean Air Pa rtners’ Board of Directors changed the nam e of the program from Ozone Action Days to Air Quality Action Days (AQAD).

The AQAD program is designed to educate em ploye rs and em ployees to take voluntary actions, specifically on Code Red days. It was argued that voluntary actions taken on the worst days of

sum m e r would “shave the peaks,” or reduce the high ozone levels on the worst days. Clean Air Partners provides resources and inform ation to a network of AQAD participants. Clean Air Partners assists em ployers in establishing on-site program s designed to reduce em ployee travel on bad air days; and encourages voluntary actions by business, industry, governm e nt, and individuals to restrict activities that contribute to the f o rm ation and risks of bad air. Approxim a tely 600 em ployers and individuals ar e registered as AQAD participants and have

com m itted to take voluntary actions to reduce em issions on Code Red days.

Clean Air Partners runs an extensive education cam paign throughout the ozone season, May to Septem ber, to educate the public about the effects of ground-level ozone and fine particles. The

m e ssages tell people what they can do to protect their health and im prove air quality. Air quality forecasts are distributed daily by fax and em ail to the m e dia and Air Quality Action Days participants. The air quality forecast is color-coded for ease of com m unication, following EPA’s regulation f o r the Air Quality Index (AQI).

During the ozone season, in addition to com m unicating daily with television and radio

m e teorologists in the regions, Clean Air Partners places radio and television ads to advise about the health risks and to prom ote less polluting behaviors on unhealthy air days. The ad m e ssages target individual em ission reduction actions for be havior m odification and the heath effects of poor air quality.

MW AQC Ozone SIP 10-32 May 23, 2007Evaluation of Voluntary Action Campaign

Despite im provem e nts in the region’s air quality, new challenges lie ahead for the AQAD

em ployer program . Prior to 2006, Clean Air Partners asked its participants to take voluntary actions on Code Red days, which was associated with the 1-hour ozone standard. W h en EPA set the 8-hour ozone standard to coincide with the Code Orange Air Quality Index it resulted in approxim a tely 20 or m o re days per year that exceed the standard.

Typically Clean Air Partners conducts surveys to determ ine the effectiveness and reach of its

m e ssage. Two types of surveys are conducted, an “end of season” survey and an “episodic survey,” taken on the evening of a forecasted Code Red Day. Surveys have been conducted by the partnership since 1995.

The end-of-season survey, conducted eight tim es since 1995, is used to estim ate the potential for behavior change and to help target the right m e ssages. Episodic surveys began in the sum m e r of 1999. The objective of the episodic survey is to determ ine if the Clean Air Partners’ m e ssage is being heard and if the potential for behavior cha nge is being realized. A study looking at trends in results of surveys taken over eight years indicates that the episodic survey, conducted on the evening of a forecasted Code Red Day, provides the m o st reliable m easure of behavior in response to the cam paign. Survey results show a steady increase in the public’s “willingness to act,” with 76 percent of the respondents indicating a belief that the individual can m a ke a difference.

Trends in Survey Results

Data from the two types of surveys indicate that general knowledge levels about air quality and its m easurem ent system s increased substantially in both m e tropolitan areas during the f i ve years studied, 1996-2001. Knowledge that Code Red indi cates unhealthy air when activity should be lim ited increased significantly during the period. A 2002 survey showed over 90 percent surveyed knew that today was a “Code Red/Bad Air Day,” and 67 percent said the phrase Code Red m eans “air is unhealthy.”

The end-of -season survey results f o r the W a shington m e tropolitan region show the percentage of residents willing to act grew from 35 percent to 44 percent over a six-year period. The percentage of people reporting changing their behavior in response to the Code Red m e ssage grew to 66 percent, an increase of 23 percent from 1996. The findings from the surveys show:

• Increase in knowledge about ground-level ozone and color-code rating system

• Steady increase in “willingness to act” from 35 percent in 1996 to 44 percent in 2001.

• Behavior change in response to bad air days is com m on Avoidance of health risk is m o st com m on reason for behavior change (66%); second reason is to reduce em issions (17 percent). 8

8 “An Analysis of Air Pollution-Related Knowledge, Attit udes, and Behaviors Across Tim e : The End of Season and Episodic Surveys,” Fox, J. Clifford and Mousum i Sa rkar, Virginia Com m onwealth University, Decem ber 2002, prepared for Clean Air Partners.

MW AQC Ozone SIP 10-33 May 23, 200710.5.11.2 Code Red/Code Orange Telew o rk Program

Clean Air Partners is adopting a new program to increase teleworking as an episodic strategy. Beginning in the sum m e r of 2007, Clean Air Partners will prom ote teleworking throughout
governm e nt and businesses when air quality is forecasted to be in the unhealthy for sensitive groups range, Code Orange or above. The decision to initiate Clean Air telework days will be guided by forecasts issued using the Air Quality Index (AQI). Three-day forecasts are issued by the Maryland Departm e nt of the Environm ent and the Metropolitan Council of Governm e nts for the W a shington region.

Clean Air Partners will develop a toolkit that w ill assist organizations in prom oting, establishing and tracking a telework program and provide resources for keeping abreast of forecasted and current air quality levels in the region. Participants will be asked to track their participation using a web-based system that tracks auto em ission reductions resulting from teleworking (NOx, VOC, CO, and CO 2 ).

The University of Maryland (UM) will evaluate the telework program through photochem i cal

m odeling by using different assum p tions regard ing the program s effectiveness at reducing Vehicle Miles Traveled (VMT). Prelim inary UM m odeling indicates that a strengthened telework program has the potential to reduce VMT and thereby leads to a m easurable ozone reduction on the worst days of sum m e r (see Appendix G Attachm e nt 14)

10.5.11.3 High Electrical Demand Day Emission Reduction Strategies

Em issions from Electric Generating Units (E GUs) are higher on high electric dem a nd days, resulting in poorer air quality. High electrical de m a nd day (HEDD) operation of EGUs generally have not been addressed under existing air quality control requirem e nts, and these units are called into service on the very hot days of sum m e r and on very cold days of winter when air pollution levels typically reach their peaks.

The Ozone Transport Com m i ssion (OTC) has been m eeting with state environm ental and utility regulators, EPA staff, EGU owners and opera tors and the independent regional system s operators to assess em issions associated with HEDD during the ozone season and to address excess NOx em issions on HEDDs. The OTC has found that NOx em issions are m u ch higher on a high electrical dem a nd day than on a typical sum m e r day and there is the potential to reduce HEDD em issions by approxim a tely 25 percent in the short term through the application of known control technologies. HEDD units consists of gasoline and diesel com bustion turbines,coal and residual oil burning units. A group of six OTC states has agreed to pursue nonregulatory strategies with the EGUs to achieve reductions in NOx em issions associated with HEDD units on high electrical dem a nd days during the ozone season. The six states agreed to achieve these additional reductions beginning with the 2009 ozone season or as soon as feasible thereafter, but no later than 2012.

MW AQC Ozone SIP 10-34 May 23, 2007On March 2, 2007, the OTC states and the District of Colum b ia agreed to a Mem o randum of Understanding (MOU) com m itting to reductions f r om the HEDD source sector. The MOU includes specific targets for a group of six states to achieve reductions in NOx em issions associated with HEDD units on high electrical dem a nd days during the ozone season. These states agreed to achieve these reductions beginning with the 2009 ozone season or as soon as feasible thereafter, but no later than 2012. The rem a ining OTC states including Virginia and the District of Colum b ia agreed to continue to review the HEDD program and seek reductions where possible but they do not have a form al em issions reduction target in the MOU.

Through the HEDD MOU com m itm ents, significant NOx reductions are anticipated in the W a shington DC-MD-VA ozone nonattainm e nt area from the program Maryland expects to develop with EGUs. Maryland has agreed to a specific NOx em ission reduction target in the MOU of a state-wide reduction of NOx em issi ons from HEDD units by 32 percent, or an estim ated 23.5 tons per day. The OTC MOU is included in Appendix G.

10.5.11.4 Tree Canopy Programs

Large-scale tree-planting program s offer a m e thod to im prove air quality across the W a shington, DC-MD-VA ozone non-attainm e nt area. Tree cover in urban areas plays an im portant role in the

com p lex system of ground level ozone production. Results from analysis conducted by the University of Maryland suggest that decreases in ground level ozone concentrations on the order of 1-3 ppbv could be realized with an increase in urban tree cover ranging from 20-40 percent. Corresponding changes in wind speed will occur in m odified areas as well. These changes are the result of the lessening of the urban “heat island” ef f

ect. Heat islands f o rm as cities replace natural land cover with pavem e nt, buildings, and other infrastructure. The heat in a heat island is the result of the dif f

e rent radiative properties (i.e. the ability of objects to absorb and/or ref l ect the sun’s energy) between urban and rural areas. Urban areas are m o re efficient at absorbing sunlight than rural areas. The excess energy absorbed by urban areas is eventually reradiated back to the atm o sphere in the form of heat (aka infrared radiation). W eakening of the heat island effect results in a transfer of energy from th e urban areas to downwind areas which causes som e locations to observe a slight increase in surface tem p eratures (1-2 ° C) and in wind speeds (1-2

ms -1 ).

The general consensus from the studies m e ntioned above suggests that increased tree cover has a beneficial effect on local air quality by reducing ozone in and around urban areas. As discussed in Appendix G, the m odeled tem p erature changes are accom p anied by changes in ground level ozone concentrations. Owing to the com p lexity of the system , changes in ozone, like
tem p erature, are not confined to locations wher e trees are planted. Different locations downwind of m odified areas observed either increased or decreased ozone levels depending on a variety of factors. The reduction of surface tem p erature (specifically, cooling in urban areas) obtained from the num erical m odeling studies was used as the basis for predicting changes in daily m ean peak 8-hour ozone levels derived from a m u ltiple linear regression m odel for the Baltim ore NonAttainm e nt Area.

A large-scale tree-planting program m a y lead to im proved air quality. Given the slow growth rate of trees, large scale tree planting is a long term solution. It is believed that the genera of

MW AQC Ozone SIP 10-35 May 23, 2007trees used to reforest is im portant, but what species of tree offers the m o st benefit is not clear and

m a y differ from locale to locale. Other signifi cant, logistical questions also need to be considered when planning a large-scale tree planting program . In the near term , this analysis points to the im portance of program s to m a intain tree cover and prevent increases in ozone due to loss of tree cover.

10.6 Summary and Conclusions of Attainment Demonstration The photochem i cal m odeling com b ined with supporting weight-of-evidence analysis provide strong evidence the region will attain the 8-hour ozone standard by 2009.

10.7 Procedural Requirements

10.7.1 Reporting

Docum e nts, technical m e m o randum s, and data bases developed in this study are available for distribution as appropriate. This report contains the essential m e thods and results of the conceptual m odel, episode selection, m odeling protocol, base case m odel developm ent and perform a nce testing, future year and control strategy m odeling, quality assurance, W O E analyses, and calculation of 8-hr ozone attain m e nt via EPA’s relative response factor (RRF)

m e thodology.

10.7.2 Data Archival and Transfer of Modeling Files
All relevant data sets, m odel codes, scripts, and related software required by any project participant necessary to corroborate the study findings (e.g., perform a nce evaluations, control strategy runs) will be provided in an electronic f o rm at approved by the Technical Com m ittee within the fram ework of MW AQC. The Technical Com m ittee has archived all m odeling data relevant to this project. Transfer of data m a y be facilitated through the com b ination of a project website and the transf er of large databases via overnight m a il. Database transf ers will be

accom p lished using an ftp protocol for sm aller datasets, and the use of IDE and Firewire disk drives for larger data sets.

MW AQC Ozone SIP 10-36 May 23, 200711.0 CONTING E NCY PL AN

The General Pream ble and EPA guidance define s the requ ir e m ents f o r identif ica tion of contingency m easures for rate-of-progress a nd attainm e nt demonstrations. For post-1996 rate-of-progress and attainm e nt de monstr ations, contingency m easures may reduce

em issions of either VOC or NOx. Contingenc y m easures are required for each m ilestone year. Air quality plans must include sufficien t contingency m easures to account for up to 3% of the base-year invent ory ad justed to the ap pr opriate m ilestone year.

11.1 Contingency Measures for the 2008 (R FP) Further Progress Demonstration

11.1.1 Background

EPA requires the W a shington region to incl ude a contingency plan containing adopted

m easures that qualify as contingency m easures for the 2002-2008 Reasonable Further Progress (RFP). This se ction f u lf ills th e requirem ent for the RFP contingency.

11.1.2 Required Reductions

The contingency m easures for the 2008 RFP a nd attainm e nt dem onstrations m u st total 3% of the 2002 adjusted base year invent ory. A m i ni m u m of 0.3 percent VOC must be included. The inventory is calculated as desc ribed in Sections 4 and 5. Table 11-1 shows the calculation of the necessary reductions.

Table 11-1 Calculation of VOC and NOx Red u ctions for RFP Further Progress Contingency (Oz o ne Sea s on tons per day) D e s c r i p t i o n V O C N O x 2002 RFP Base-Year Inventory (a) 448.28 597.22

Non-creditable Em issions Reduction (b) 12.45 31.61 Adjusted Base-Year Inventory (c) = (a-b) 435.83 565.61

0.3% VOC Reduction R e quired for RFP Contingency (d) = (0.3 /10 0 ) * (c) 1

. 3 1

2.7% NOx Reduction R e quired for RFP Contingency (e) = (2.7/100) * (c) 1 5

. 2 7

Contingency reductions must occur on a tim etable tha t is d i r ectly related to the RFP SIP schedule. S t ates have no m o re than one year af te r notif ica tion by EP A of a n RFP failure to achieve the contingency plan reductions . For a potential RF P failure, notification would be received in 2009, therefore the c ontingency reductions m u st be achieved no later than 2010.

MW A Q C O z o n e SI P May 2 3

, 2 007 11

- 111.1.3 Identified Contingency Measures

Table 11-2 lists the contingency m e a s ure identified by the District of Colum b ia, Maryland and Virginia for the 2008 RFP de m o nstration. This m easure delivers a total benefit of 1.3 tons per day (tpd) VO C and 15.3 tpd NOx. The com b ined reduction equals 3% of the Adjusted Base Year Inventory, therefore m eeting the contingency m easure requirem e nt calculated in Table 11-1.

Table 11-2 Contingency Measures for 2008 Reas onable Further Progress (RFP) (Oz o ne Sea s on tons per day) Ref. No. Contingency Measure VOC (tons/day) NOx (tons/day) 6.2.12 6.2.17 Ozone Transport Commission Portable Fuel Containers Rule 1

. 3 1 0

6.1.2 Regional Transport NOx Reductions (Clean Air Inter s ta te R u le, Healthy Air Act) 0 1 5

. 3

TOTAL REDUCTIONS 1.31 15.3

In acco rdan ce with EPA’s guidance encourag ing early im plem entation of contingen c y

m easures to guard against failure to either m eet a m ilestone or attain, the District of Colum b ia, Maryland an d Virginia will im plem en t the con ting e ncy m easures iden tif ied in Table 11-3 according to the tim etable indica ted in Chapters 6 and 9. EPA’s guidance on early im plem entation of control m e a s ures is as follows:

The EPA encourages the early impl ementation of required control measures and of contingency measures as a means of guarding against failur e s to meet a miles t one or to at tain. Any im plemented measures (that are not need ed for the ra te-o f-progre ss requ irem ents or for the atta inme nt requirements) would need to be back filled only to the extent they a r e us e d to meet a milestone.

The reductions from the designated contingenc y m easures are surplus v i s

- à-vis the R FP dem onstration contain e d in this S I P. They will n o t be used to m eet that m iles t one requir e m e nt. As a result, the states will not b e req u ired to bac k f ill any con tingency

m easures that they choose to im plem ent in advance of the requirem e nt.

11.1.4 Portable Fu el Containers Rule: Phase I and Phase II

This m easure introduces perform a nce standard s for portable fuel containers and spouts. The standards are in tend ed to redu ce em issi ons from storage, transport and refueling activ ities. T h e rule also included ad m i nist rative and labeling requirem e nts. Com p liant contain e rs must have: o n ly one opening fo r both pouring an d filling, an autom a tic sh utof

f to prevent overf ill, a n autom a tic seal ing m e c h anism whe n not dispensing fuel and specified fuel flow rates, pe rm eation rates and warran tie s.

MW A Q C O z o n e SI P May 2 3

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- 2Source Type Affected

Any person or entity selling, supplying or m a nu facturing portable fuel containers, except containers w ith a capacity of less than or e qual to one quart, rapid refueling devices with capacities greater than or equal to four gallons , safety cans and portable marine fuel tanks operating with outboard motors, and products res u lting in cu mulative V O C e m issions below those of a representative container or spout.

Control Strategy

Maryland, the District, and Virgin ia all adopted Phase I and ar e in the process of adopting Phase II of the OTC Model Rule fo r Portable Fuel Containers.

Implementation

Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm e n tal Quality District of Colum b ia - Departm e nt of Environm e n t

Projected Reductions

VO C Emissio n Re ducti ons (t ons per d a y)

District of

C o l u mbi a Mar y land Virg inia To ta l

VOC Re d u ctio ns 0 0. 83 0. 48 1. 31

Emission B e nefit Calculations

Projected reductions are based on an em i ssion reduction factor of 75% after full im ple m entation after 10 years. Im plem entation began in 2005. In 2008, the em ission reduction factor is 30%. In 2009, the em i ssion reduction factor is 37.5%. P h ase II reductions are based on an additional 4 percent reduction in em issions of VOC.

Note that th e Distr i ct' s OTC VOC rules on a ll the applicable area source catego r ies are or will be fully adopted, su bm itted to E P A, and federally enforceable m easures. However, the em ission reductions arising from these m eas ures in th e Dis t rict are not applied to the

em issions inventories pres ented in th is RFP/attain m e nt m ode ling/contingency dem onstration of the Washington D C -MD-VA re gional S I P. The District of Colum b i a ' s

m easures ar e expected to provide ad dition a l enh a ncem ents to the air qua lity im provem e nt in the region.

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- 311.1.5 Regional NOx Transport Requirements

This section docum ents contingency credit fo r NOx e m issions reducti ons attributable to federal and regional NOx requirem e nts on poin t sources. These cred its in clude:

• EPA' s Clean Air Inte rstate Rule (CAIR); and

• Maryland' s Healthy Air Act.

Control Strategy

Clean Air In ters tate Rule (CAIR) In 2004, the U.S. EPA pr om ulgated the Clean Air Interstate R u le, which requires reductions in em issions of NOx and SO2 from large f o ssil f u el-f ir ed ele c tric gen e ra tin g units. The rule is set up in seve ra l ph ases with th e f i rst phas e of NOx reductions to com e by 2009. The rule sets up both an annual em issions budget and an ozone season

em issions budget. The rule requires that units with nam e plate capacity greater than 25

m e gawatts e m it no m o re NOx than their a lloc a tions determ ined by the s t ate e ithe r through em ission controls or banking and trading.

Virginia CAIR Virginia has adopted state regulations c odifying the requirements of the C l ean Air Inter s ta te R u le. Virg inia ' s rules crea te an em issions cap based on the allo wances allo cated to the facility. The rules do not allow tr ading as a m e thod of c o m p lying with the

em issions cap.

Maryland H ealthy Air Act In April of 2006 the Maryland General Asse m b ly and Governor Ehrlich adopted the Healthy Air Act (HAA), a law that requires reductions in NOx, SO 2 , and Mercury

em issions from Maryland’s largest and ol dest coal fired pow er plants. Maryland im ple m ents the HAA through regulation. The re gulation requires reductions in NOx

em issions from coal-fired electric generati ng units (excluding fluidized bed com bustion units) starting in 2009. By 2009 Maryland expe cts an approxim a te 70 percent reduction in NOx e m issions from t h ese regulations when compared to 2002 em issions. To m e et the requirem e nts of Maryland’s regulations a co m p any’s “system” (covered units owned by the sam e company) m u s t m eet a system -wide cap by 2009. Com p liance cannot be achieved through the purchase of allowances under the HAA.

District of Colum b ia CAIR The Distr i ct of Colum b ia is currently drafting its Clean Air In ters tate Rule (CAIR). The District of Colum b ia' s CAIR regulations do not allow trading of NOx allowances for achieving the reductions for the f acilities within its jurisdic tio n.

Su mm ary The point source NOx controls are a phased approach to co ntrolling em issions of NOx from power plants and other large fuel co m bustion sources. T h e program s resulting in

em ission reductions applied for contingency from point sources in the region include: EPA' s Clean Air Inte rstate Rule and Maryland' s Healthy Air Act

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- 4Implementation

District Departm e nt of the Environm ent Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm e n tal Quality

Projected Reductions

NOx Emission Reductions (tons per day)

District of Columbia Maryland Virginia Total

NOx Reductions 0.66 12.19 2.45 15.3

Emission B e nefit Calculations

The em ission reductions associated with th e state NOx requirem e nts on point sources were supplied by the staffs of the Ma ryland Air and Radiation Management Adm i nistration, the District Department of th e E nvironm ent, and the Virginia Departm e nt of Environmental Quality Air Division.

References

1990 Clean Air Act Amendm ents, 42 U.S. C. §§7511a (f), (b)(2), and (c).

11.2 Contingency Measures for the Atta inment De monstratio n
11.2.1 Background

EPA requires the W a shington region to incl ude a contingency plan containing adopted

m easures that qualify as contingency m easur es for the 2009 attainm e nt dem onstration. This section fulfills the requirem e nt for the 2009 attainm e nt dem onstratio n.

11.2.2 Required Reductions

The W a shington region must also identify cont ingency m e asures to be implem e nted in the event that the region doe s not attain the 8-hour oz one standard in 2009. The contingency m easures for the attainment dem ons tration m u st provide reductions of either VOC or NOx that total 3% of the 2002 Adjust ed Base Year Invent ory. A m i ni m u m of 0.3 percent VOC m u st be included. The adjusted inventory is calculated as described in Chapters 4 and 5. Table 11-3 shows the calcula tion of the necessary reductions, based on the m i ni m u m VOC reduction required.

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- 5Table 11-3 Calculation of VOC and NOx Reductions for Attainment Contingency (Oz o ne Sea s on tons per day) D e s c r i p t i o n V O C N O x 2002 Base-Year Inventory (a) 448.28 597.22

Non-creditable Em issions Reduction (b) 12.45 31.61 Adjusted Base-Year Inventory (c) = (a-b) 435.83 565.61

0.3% VOC Reduction R e quired for Attainm e nt Contingency (d) = (0.3/100) * (c) 1

. 3 1

2.7% NOx Reduction R e quired for Attainm e nt Contingency (e) = (2.7/100) * (c) 1 5

. 2 7

Contingency reductions must occur on a tim et able tha t is d i r ectly related to the attainm e nt SIP schedule. States have no m o re than one year after notification by EPA of an attainm e nt f a ilur e to achieve the con tingency plan reductions. For a potential attainm e nt failu re in 200 9, notificatio n would be received in 2 010, therefo r e the contingency reductions must be achieved no later than 2011.

11.2.3 Identified Contingency Measures

Table 11-4 lists the contingency m e a s ures identified by the D i strict of Colum b ia, Maryland and Virginia for the attainm e nt de m o nstration. Th ese m easures deliver total benefits of 8.46 tpd VOC and 6.05 tpd NOx. Th e com b ined reduction equals 3% of the Adjusted Base Year Inventory, m eeting the contingency m e a s ure requirem ent calculated in Table 11

- 3 ; the r ef ore this m easure f u lf ills the r e gion’s con t ingency m easure requirem e nt. All of these control m e a s ures will be effective by 2011.

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- 6Table 11-4 Contingency Measures for Attainment Demonstration (Oz o ne Sea s on tons per day) Ref. No. Contingency Measure VOC (tons/day) NOx (tons/day) 6.4.5 Tier 2 Motor Vehicle Em ission Standards 0 1.77 6.3.1 Phase I and Phase II Emissions S t andards for Gasoline-Po wered Non-Road Utility Engines 1

. 4 9 0

. 0 4

6.3.2 Em issions Standards for Diesel-Powered Non-Road Utility Engines of 50 or More Horse power 0

. 3 9 3

. 2 8

6.3.3 Em issions Standards for Spark Ignition Marine Engine 1

. 4 2 0

6.3.4 Em issions Standards for Large Spark Ignition Engines 0

. 5 4 0

. 9 6

6.2.12 6.2.17 Ozone Transport Commission Portable Fuel Containers Rule 4

. 6 2 0

TOTAL REDUCTIONS 8.46 6.05

The contingency reduction from the on-road source is substantia ted by a 2010 Mobile Em issions Budget, as specified in C h apter 8. Reductions for the Tier 2 motor vehicle

em ission standards occur between 2009 a nd 2010. Reductions for the other identified

m easures occur between 2009 and 2011.

In acco rdan ce with EPA’s guidance encourag ing early im plem entation of contingen c y

m easures to guard against failure to either m eet a m ilestone or attain, the District of Colum b ia, Maryland an d Virginia will im plem en t the con ting e ncy m easures iden tif ied in Table 11-4 according to the tim etable indica ted in Chapters 6 and 9. EPA’s guidance on early im plem entation of control m e a s ures is as follows:

The EPA encourages the early impl ementation of required control measures and of contingency measures as a means of guarding against failur e s to meet a miles t one or to at tain. Any im plemented measures (that are not need ed for the ra te-o f-progre ss requ irem ents or for the atta inme nt requirements) would need to be back filled only to the extent they a r e us e d to meet a milestone.

The reductions from the designated continge ncy m easures are surplus vis-à-vis the
atta inm e nt dem onstratio n contain e d in this S I P. They will no t be used to m eet that

m ilestone re quirem e nt. As a result, the sta t es will not be requ ired to backf ill any contingency m easures that they choose to im plem ent in advance of the requirem e nt.

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- 711.2.4 Tier 2 Motor Vehicle Emission R e gulations

The U.S. EPA prom ulgated a rule on Februa ry 10, 2000 requiring m o re stringent tailpipe

em issions standards for all passenger vehicles , including sport utility vehicles (SUVs),

m i nivans, vans and pick-up trucks. T h ese regula tions also require lower levels of sulfur in gasoline, which will ensure the effectiv en ess o f low e m ission-contro l technologies in vehicles and reduce harmful air pollution.

Source Type Affected

These federally im ple m ented program s a ffect light-duty vehicles and trucks.

Control Strategy

The new tailpipe and sulfur standards requi re passenger vehicles to be 77% to 95% cleane r than those built b e f o re the ru le was prom ulgated and will reduce th e sulf ur content of gasoline by up to 90 %. T h e new tailp i pe standard s are set at an average standard of 0.07 gram s per m ile for NOx for all classes of passenger vehicles beginning in 2004. This includes all light-duty trucks , as well as the largest SUVs. Vehicles weighing les s than 6000 pounds will be phased- in to this stand a rd between 2004 and 2007.

Beginning in 2004, the refiners and importers of gasoline have the flexibility to

m a nufacture gasoline with a range of sulfur levels as long as all of their production is capped at 30 0 parts per m illion (pp m ) and their annual co rp orate averag e sulfur lev e ls are 120 ppm

. In 2005, the ref i nery average was set at 30 ppm

, with a co rporate average of 90
ppm and a cap of 300 ppm. Finally, in 2006, refi ners m e t a 30 ppm average sulfur level with a m a ximum cap of 80 ppm

.
As newer, cleaner c a rs e n ter the nationa l f l eet, th e new tailpipe standa rds will significantly reduce em issions of nitrogen oxides from vehicles by about 74 % by 2030.

Implementation
EPA i m plem ents this program under 40 CFR Pa rts 80, 85, and 86.

Projected Reductions

This m easure provides 1.8 tpd NOx reduction applied for contingency purposes. This contingency m easure will be im plemented vi a a 2010 m obile source budget as discussed in Chapter 8

.

Emission B e nefit Calculations

The contingency reductions are based on Tier 2 m o tor vehicle em ission standards, for reductions occurring between 2009 and 2010.

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- 811.2.5 Phase I and Ph ase II Emissions St and a rds for Gasoline-Pow e red Non-Road Utility Engines

This m easure takes cred it for VOC em issi ons reductions attribut able to e m issions standards prom ulgated by the EPA for sm a ll non-road, spark-ignition (i.e., gasolinepowered) utility engines, as authorized under 42 U.S.C. §7547. The m e asure affects gasolin e-po wered (or o t her spark

- ig nition ) lawn and garden e quipm ent, construc tion equipm ent, chain saws, and other su ch utility eq uipm ent as chippers and stum p grinders, wood splitters, etc., ra ted at or below 19 kilowatts (an equivalent of 25 or fewer horsepower). Phase 2 of the rule applied further controls on handheld and non-handheld outdoor equipm ent.

Control Strategy

Federal em i ssions standards prom ulgated under §7547 (a) apply to spark-ignition nonroad utility engines. The EPA' s Phase 1 Spark Ignition Nonroad final rule on such

em issions standards was published in 60 Federal Register 34581 (July 3, 1995), and was effective beginning August 2, 1995. Com p lian ce was required by the 1997 m odel year. The Phase 2 final rule for handheld nonroad equipm ent was published in 65 Federal Register 24267 (April 25, 2000). The Phase 2 final rule for non-handheld equipm ent was published in 64 Federal Register 15207 (March 30, 1999).

Implementation

This program is im ple m ented by the EPA, under 42 U.S.C. §7547 (a).

Projected Reductions

VO C Emissio n Re ducti ons (t ons per d a y)

District of

C o l u mbi a Mar y land Virg inia To ta l

VOC Re d u ctio ns 0. 08 0. 68 0. 73 1. 49

NO x R e du ct i o ns 0. 01 0. 02 0. 02 0. 04

Emission B e nefit Calculations

The contingency reductions are estim a ted using EPA' s NONROAD model for reductions occurring between 2009 and 2011.

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- 911.2.6 Emissions Stan dards for Diesel-Pow ered Non-Road Utility En gines of 50 or More Hors epow er

This m easure takes cred it for NOx em issi ons reductions attribut able to e m issions standards prom ulgated by the EPA for non -road, com p ression-ignition (i.e., dieselpowered) utility engines, as authorized under 42 U.S.C. § 7547. The m e asure affects diesel-powered (or other com p ression-igni tion) construction equipm ent, industrial equipm ent, etc., rated at or above 37 kilowa tts (37 kilowatts is approxim a tely equal to 50 horsepower).

Control Strategy

Federal em i ssions standards applicable to com p ression-ignition non-road utility engines
are prom ulgated under §7547 (a).

EPA' s first rule on such em issions standard s was published in 59 Fe deral Register 31306 (June 17, 1994), and was effective on July 18, 1994.

Tier 2 and T i er 3 Em ission Standards were promulgated in 1998. This program includes the first set of standards for nonroad diesel engines less than 37 kW (phasing in between 1999 and 2000), including m a rine engines in th is size range. It also phases in m o re stringent "T ier 2" em ission standards from 2001 to 2006 for all engine sizes and adds yet more stringent "Tier 3" standards for e ngines between 37 and 560 kW (50 and 750 hp) from 2006 to 2008.

EPA adopted a com p rehensive national program to greatly reduce em issions from fut u re nonroad diesel engines by integrating engine an d fuel controls as a system to gain the greatest air quality benefits. This rule was published June 29, 2004. The requirem e nt to reduce su lf ur leve ls in n onroad dies e l f u el by m o re than 99 % will a llow f o r the f i rs t tim e advanced em ission control system s to be us ed on the engines used in construction, agricultural, industr ial, and airport service equipm ent.

Implementation

This program is im ple m ented by the EPA under 42 U.S.C. § 7547 (a).

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- 1 0Projected Reductions

Emission Red u ctions (tons per d a y)

District of

C o l u mbi a Mar y land Virg inia To ta l

VOC Re d u ctio ns 0. 07 0. 19 0. 13 0. 39

NO x R e du ct i o ns 0. 57 1. 34 1. 37 3. 28

Emission B e nefit Calculations

The contingency reductions are estim a ted using EPA' s NONROAD model for reductions occurring between 2009 and 2011.

11.2.7 Emissions Stan dards for Spark Ignition (SI) Marine Engines

This EPA measure controls exhaust VOC e m issions from new spark-ignition (SI) gasoline m a rine engines, including outboard en gines, personal watercraft engines, and jet boat engines. Of nonroad sources studied by EP A, gasoline marine engines were found to be one of the largest contribu tors of hydrocarbon (HC) em i ssions (30% of the nationwide nonroad total).

Control Strategy

EPA is im posing em ission standards for 2 – stroke technology, outboard and personal
waterc raf t e ngines. This will inv o lv e incr eas ing l y string ent HC control over the cou r se of a nine-year phase-in period beginning in m odel year 1998. By the end of the phase-in, each m a nufacturer m u st m eet an HC and NOx emission s t and a rd that rep r esents a 75 % reduction in HC com p ared to unregulated le vels. These standards do not apply to any currently ow ned engines or boats.

Implementation

This program is im ple m ented by the EPA under 42 U.S.C. § 7547 (a).

Projected Reductions

Emission Red u ctions (tons per d a y)

District Of Co lumbia Mar y land Virg inia To ta l

VOC Re d u ctio ns 0. 19 1. 07 0. 15 1. 42

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- 1 1Emission B e nefit Calculations

The contingency reductions are estim a ted using EPA' s NONROAD model for reductions occurring between 2009 and 2011.

11.2.8 Emissions Stan dards for Larg e Spark Ignition (SI) Engines

This EPA measure con t rols VOC and NOx em is sions from s e veral groups of previously unregulated nonroad engines, including large industrial SI engines.

Control Strategy

The EPA requirem e nts vary depending upon the t ype of engine or vehicle, taking into account environm ental impacts, usage rates, th e need for high perform a nce m odels, costs and other factors. The em ission standards a pply to all new engines sold in the United States and any im ported engines m a nuf actured after thes e stan dards began.

Controls on the category of large industrial SI engines were f i rst required in 2004. Controls on the other engine categories began in years af ter 2005. Large industrial SI engines are those rated over 19 kW used in a variety of commercial app lic ations ; m o st use liquefied petroleum gas, with others operating on gasoline or natural gas.

EPA adopted two tiers of e m ission standards for Large SI engines. The first tier of standards, which started in 2004, are based on a sim p le laboratory m easurem ent using steady-state procedures. The Tier 1 s t andards are the sam e as those adopted earlier by the California A i r Resources Board for engines used in California. Tier 2 standards became effective in 2007.

Implementation

This program is im ple m ented by the EPA under 42 U.S.C. § 7547 (a).

Projected Reductions

Emission Red u ctions (tons per d a y)

District of

C o l u mbi a Mar y land Virg inia To ta l

VOC Re d u ctio ns 0. 04 0. 30 0. 21 0. 54

NO x R e du ct i o ns 0. 08 0. 48 0. 40 0. 96

Emission B e nefit Calculations

The contingency reductions are estim a ted using EPA' s NONROAD model for reductions occurring between 2009 and 2011.

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- 1 211.2.9 Portable Fuel Containers R u le: Phase I and Phase II

This m easure introduces perform a nce standard s for portable fuel containers and spouts. The standards are in tend ed to redu ce em issi ons from storage, transport and refueling activ ities. T h e rule also included ad m i nist rative and labeling requirem e nts. Com p liant contain e rs must have: o n ly one opening fo r both pouring an d filling, an autom a tic sh utof

f to prevent overf ill, a n autom a tic seal ing m e c h anism whe n not dispensing fuel and specified fuel flow rates, pe rm eation rates and warran tie s.
Source Type Affected

Any person or entity selling, supplying or m a nu facturing portable fuel containers, except containers w ith a capacity of less than or e qual to one quart, rapid refueling devices with capacities greater than or equal to four gallons , safety cans and portable marine fuel tanks operating with outboard motors, and products res u lting in cu mulative V O C em issions below those of a representative container or spout.

Control Strategy

Maryland, the District, and Virgin ia all adopted Phase I and ar e in the process of adopting Phase II of the OTC Model Rule fo r Portable Fuel Containers.

Implementation

Maryland - Air and Radiation Managem e nt Adm i nistration Virginia - Departm e nt of Environm e n tal Quality District of Colum b ia - Departm e nt of Environm e n t

Projected Reductions

VO C Emissio n Re ducti ons (t ons per d a y)

District of

C o l u mbi a Mar y land Virg inia To ta l

VOC Re d u ctio ns -0 .0 6 2. 98 1. 71 4. 62

Emission B e nefit Calculations

Projected reductions are based on an em i ssion reduction factor of 75% after full im ple m entation after 10 years. Im plem entation began in 2005. In 2008, the em ission reduction factor is 30%. In 2009, the em i ssion reduction factor is 37.5%. P h ase II reductions are based on an additional 4 percent reduction in em issions of VOC.

Note that th e Distr i ct' s OTC VOC rules on a ll the applicable area source catego r ies are or will be fully adopted, su bm itted to E P A, and federally enforceable m easures. However,

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- 1 3the em ission reductions arising from these m eas ures in th e Dis t rict are not applied to the

em issions inventories pres ented in th is RFP/attain m e nt m ode ling/contingency dem onstration of the Washington D C -MD-VA re gional S I P. The District of Colum b i a ' s

m easures ar e expected to provide ad dition a l enh a ncem ents to the air qua lity im provem e nt in the region.

The contingency reductions are for reductions occurring betw een 2009 and 2011.

References

E.H. Pechan, “Control Measure Developm ent Support Analysis for the Ozone Transport Comm ission Model Rules”, March 31, 2001.

U. S. EPA, “ S tate Im plem entation Plans; General Pream ble for the Im plem entation of Title I of the Clean Air Act Am endm ents of 1990”

, Proposed Rule, 57 Federal Register 13498 (April 16, 1992).

U.S. EPA, “ G uidance on the Post-1996 Rate-of-Progress Plan and the Attainm e nt De m onstration,” Corrected Version as of February 18, 1994, p. 50.

OTC 2007. Identification and Evaluation of C andidate Control Measures: Final Technical Support Document. Prepared by MACTEC Fede ral Programs, Inc., Herndon, Virginia for the Ozone T r ansport Commission. February 28, 2007.

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- 1 4