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 EPA
Alternative formats of this publication can be 

made available for persons with disabilities. 

Phone: 202.962.3300 or 202-962.3213 

(TDD) 

Email: accommodations@mwcog.org. 

 For details: www.mwcog.org. 

For Virginia: Phone: (804) 698-4070 

 Email: abbanks@deq.virginia.gov 
TABLE 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 Emission Inventories and Future Year 2008 and 2009.................1-6 

1.6 2002-2008 Reasonable Further Progress Plan ............................................................. 1-7 

1.7 Establishment of a Budget for Transportation Mobile Emissions............................... 1-7 

1.8 Attainment Demonstration ......................................................................................... 1-9 

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

1.10 Contingency Measures......................................................................................... 1-10 

1.11 Document Contents.................................................................................................. 1-10 

2.0 INTRODUCTION AND OVERVIEW .......................................................................... 2-1 

2.1 Clean Air Act Background........................................................................................... 2-1 

2.2 8-hour Ozone Standard ................................................................................................ 2-2 

2.3 SIP Requirements for Moderate Nonattainment Areas ............................................... 2-2 

2.4 Rate of Progress Demonstrated in Previous SIPs........................................................ 2-3 

2.5 Comparability of 8-hour Inventories to Previous State Implementation Plans ........... 2-3 

2.6 Sources of Ozone in the Metropolitan Washington Region ........................................ 2-5 

2.7 The Effects of Ozone ................................................................................................ 2-10 

2.8 Frequency of Violation of Federal Health Standard for Ozone................................. 2-11 

2.9 The Metropolitan Washington Air Quality Committee (MWAQC).......................... 2-12 

2.10 Interstate Air Quality Council.................................................................................. 2-13 

2.11 State Commitment/Implementation Assurances...................................................... 2-14 

2.12 Submittal of the Plans.............................................................................................. 2-14 

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

2.14 Reasonable Further Progress Requirements ............................................................ 2-14 

2.15 2009 Attainment Demonstration.............................................................................. 2-15 

2.16 Analysis of Reasonably Available Control Measures (RACM).............................. 2-16 

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

3.0 THE 2002 BASE-YEAR INVENTORY......................................................................... 3-1 

3.1 Background and requirements ..................................................................................... 3-1 

3.2 Total Emissions 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 2009 PROJECTED INVENTORIES ................................................. 4-1 

4.1 Growth Projection Methodology ................................................................................. 4-2 

ii
 4.1.1 Growth Projection Methodology for Point Sources: EGAS................................... 4-2 

 4.1.2 Growth Projection Methodology: Area Sources..................................................... 4-2 

 4.1.3 Growth Projection Methodology: Nonroad Sources............................................... 4-5 

 4.1.4 Growth Projection Methodology: Onroad Sources................................................. 4-8 

 4.1.5 Biogenic Emission Projections............................................................................... 4-8 

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

4.3 Actual vs. Allowable Emissions in Development of the 2008 and 2009 Projected Emissions 

Inventories........................................................................................................................... 4-9 

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

4.5 Emission Reductions from Control Measures ........................................................... 4-12 

4.6 2008 Controlled Emissions for Reasonable Further Progress ................................... 4-14 

4.7 2009 Controlled Emissions for Attainment ................................................................ 4-15 

5.0 2008 REASONABLE FURTHER PROGRESS REQUIREMENTS.......................... 5-1 

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

 5.1.1 Rate of Progress Demonstrated in Previous State Implementation Plans................ 5-1 

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

Levels.................................................................................................................................. 5-2 

 5.2.1 2008 VOC and NOx Target Levels ......................................................................... 5-3 

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

5.3 Compliance with 2008 Reasonable Further Progress Requirements........................... 5-6 

5.4 Reasonable Further Progress Contingency Emission Reduction Requirement ........... 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........................................................................................................ 6-57 

7. REASONABLY AVAILABLE CONTROL MEASURES (RACM) ANALYSIS ....... 7-1 

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

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

 7.1.2 Implementation Date................................................................................................ 7-2 

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

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

 7.1.5 Economic Feasibility and Cost Effectiveness.......................................................... 7-3 

 7.1.6 Substantial and Widespread Adverse Impacts......................................................... 7-3 

 7.1.7 De Minimis Threshold ............................................................................................. 7-3 

 7.1.8 Advancing Achievement 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 Determination.................................................................................................. 7-5 

iii
8. MOBILE SOURCE CONFORMITY .............................................................................. 8-1 

8.1 Mobile Emissions Budget and the Washington Area 

Transportation Conformity Process.................................................................................... 8-2 

8.2 Budget Level for On-Road Mobile Source Emissions ............................................... 8-2 

 8.2.1 RFP Year Mobile Budgets...................................................................................... 8-3 

 8.2.2 Attainment 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 Emissions ........................................................................................ 8-5 

9.0 MODERATE AREA PLAN COMMITMENTS........................................................... 9-1 

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

9.2 Stationary Source Threshold Revisions..................................................................... 9-12 

9.3 New RACT Rules Applicability ................................................................................ 9-13 

9.4 Revision of New Source Review (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 Regional Modeling Protocols.................................................... 10-2 

 10.1.2 Conceptual Description....................................................................................... 10-3 

10.2 Domain 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 Selection and Configuration........................................... 10-5 

 10.2.7 Emissions Model Selection and Configuration................................................... 10-5 

 10.2.8 Air Quality Model Selection and Configuration................................................. 10-6 

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

10.3 Model Performance Evaluation ............................................................................... 10-6 

 10.3.1 Diagnostic and Operational Evaluation .............................................................. 10-7 

 10.3.2 Summary of Model Performance...................................................................... 10-10 

10.4 Attainment Demonstration..................................................................................... 10-10 

 10.4.1 Modeling Attainment Test................................................................................ 10-11 

 10.4.2 Unmonitored Area Analysis ............................................................................. 10-12 

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

 10.4.4 Attainment Modeling Results........................................................................... 10-13 

10.5 Weight 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 and NOx Emissions .................................................................. 10-18 

 10.5.6 Spatial Extent of NAAQS Violations............................................................... 10-19 

 10.5.7 Trend in 8-Hour Ozone Exceedance Days and High Temperature Days......... 10-20 

iv
 10.5.8 Trend in Meteorology Adjusted Ozone Levels................................................. 10-22 

 10.5.9 Alternative Design Value Calculation Techniques........................................... 10-24 

 10.5.10 Uncertainty in CMAQ Modeling.................................................................... 10-28 

 10.5.11 Local Government Voluntary Initiatives........................................................ 10-31 

10.6 Summary and Conclusions of Attainment Demonstration ................................... 10-32 

10.7 Procedural Requirements....................................................................................... 10-31 

 10.7.1 Reporting........................................................................................................... 10-31 

 10.7.2 Data Archival and Transfer of Modeling Files................................................. 10-31 

11.0 Contingency Plan .......................................................................................................... 11-1 

11.1 Contingency Measures for the 2008 RFP Demonstration ....................................... 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 Requirements.............................................................. 11-4 

11.2 Contingency Measures for the Attainment Demonstration ...................................... 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 Vehicle Emission Regulations ...................................................... 11-8 

 11.2.5 Phase I and Phase II Emissions Standards for Gasoline-Powered Non-Road 

Utility Engines.................................................................................................................. 11-9 

 11.2.6 Emissions Standards for Diesel-Powered Non-Road Utility Engines of 50 

or More Horsepower....................................................................................................... 11-10 

 11.2.7 Emissions Standards for Spark Ignition Marine Engines................................. 11-11 

 11.2.8 Emissions Standards for Large Spark Ignition Engines ................................... 11-12 

 11.2.9 Portable Fuel Containers Rule: Phase I and Phase II....................................... 11-13 

 

List of Appendices 

A. Membership Rosters for MWAQC, TAC and AQPAC 

B. Base Year 2002 Inventory and Documentation 

C. Point Source Inventories and Projections 

D1. Round 7.0 Cooperative Forecast Projections & 

 Area and Nonroad Source Inventories and Projections 

D2. Nonroad Model Outputs_Unc.Cnt.2008.09 

E1. MOB6.2.03 Inventories and Documentation 

E2. Mob6 Input_Output_Files_Adj2002.08_Unc.Cnt.2008.09 

F. Transportation Control Measures 

G. Attainment Modeling Demonstration and Documentation 

H. Voluntary Commitment Letters and other Documentation 

I. RACM Documentation 

J. Public Hearing Notices and Public Comments and Responses 

v
List 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 Season 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 Annual 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 VOC Emissions ...................................................................... 4-10 

4-6 2008 Projected Uncontrolled NOx Emissions ....................................................................... 4-10 

4-7 2009 Projected Uncontrolled VOC Emissions ...................................................................... 4-11 

4-8 2009 Projected Uncontrolled NOx Emissions ....................................................................... 4-11 

4-9 2008 Projected Controlled VOC Emissions .......................................................................... 4-14 

4-10 2008 Projected Controlled NOx Emissions ......................................................................... 4-15 

4-11 2009 Projected Controlled VOC Emissions ........................................................................ 4-16 

4-12 2009 Projected Controlled NOx Emissions ......................................................................... 4-16 

5-1 2002 Reasonable Further Progress Base Year Inventory ........................................................ 5-4 

5-2 2002 Reasonable Further Progress Adjusted-Year Inventory ................................................. 5-5 

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

5-4 Calculation of Non-Creditable Emissions Reductions ............................................................ 5-6 

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

5-6 Comparison of 2008 Controlled and Target Inventories ......................................................... 5-7 

5-7 Calculation of VOC and NOx Reductions 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 Summary, 2008, 2009 .......................................................... 6-10 

6-8 Summary of Emission Reductions for Voluntary Bundle ..................................................... 6-60 

6-9 Summary of Benefits EERE Programs .................................................................................. 6-61

vi
6-10 Summary of Benefits of Regional Wind Power Purchase ................................................... 6-64 

6-11 Projected Annual Generation and Avoided Emissions 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 Programs ....................................... 6-79 

7-1 Potential RACM Measures ...................................................................................................... 7-6 

9-1 District Schedule of Adopted Control Measures...................................................................... 9-1 

9-2 Maryland Schedule of Adopted Control Measures ................................................................. 9-5 

9-3 Maryland Non-CTG RACT ..................................................................................................... 9-8 

9-4 Virginia Schedule of Adopted Control Measures..................................................................... 9-9 

9-5 Schedule of Stationary Source Revisions............................................................................... 9-12 

9-6 New RACT Rules Applicability ............................................................................................ 9-13 

9-7 Schedule for Revision of NSR Regulations .......................................................................... 9-14 

10-1 Washington Designations for 8-hour Ozone Standard ........................................................ 10-2 

10-2 Washington, DC-MD-VA Statistics 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 Attainment Test Using EPA Preferred Methodology ....................................... 10-11 

10-6 Temperature and 8-hour Ozone Exceedances ................................................................... 10-21 

10-7 Methodologies for Calculating Baseline Design Values ................................................... 10-25 

10-8 Methodologies for Calculating Relative Response Factors ............................................... 10-27 

10-9 Future Design Value Ranges ............................................................................................. 10-28 

11-1 Calculation of Contingency Measure Requirements ........................................................... 11-1 

11-2 Contingency Measures for 2008 Reasonable Further Progress ........................................... 11-2 

11-3 Calculation of 2009 Contingency Measure Requirement .................................................... 11-6 

11-4 Contingency Measures for Attainment Demonstration ....................................................... 11-7 

vii
List of Figures 

1-1 VOC Emissions by Source ...................................................................................................... 1-6 

1-2 NOx Emissions by Source ....................................................................................................... 1-7 

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

2-1 Washington, DC-MD-VA 8-Hr Ozone Nonattainment Region .............................................. 2-4 

2-1 Conditions for Ozone Formation ............................................................................................. 2-5

2-3 Gradual Build-up of Ozone Levels .......................................................................................... 2-6 

2-4 Estimates of Population At Risk ............................................................................................ 2-11 

2-5 Ozone Exceedance Days, 1997-2006 .................................................................................... 2-13 

10-1 Location of Ozone Monitors in the Washington Region ..................................................... 10-9 

10-2 Trend in 8-Hour Ozone 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 2nd High 1-Hour CO Concentrations ................................................................... 10-17 

10-6 VOC Emissions by Source ................................................................................................ 10-18 

10-7 NOx Emissions by Source ................................................................................................. 10-19 

10-8 Comparison of Nonattainment Area (NAA) Zones, 1990-2006 ....................................... 10-20 

10-9 8-Hour Ozone Exceedances and/ High Temperature Days ............................................... 10-22 

10-10 Meteorology Adjusted Ozone Season Averages ............................................................. 10-23 

viii
1.0 EXECUTIVE SUMMARY 

The Washington metropolitan area plans to meet federal requirements for reducing ground-level 

ozone, a principal component of smog, by 2009. The Clean Air Act Amendments of 1990 

(CAAA or Act) represent an unprecedented commitment to protecting public health and the 

environment. Title I of the Act classifies areas that exceed national health-based air quality 

standards based upon the severity of their pollution problem (marginal, moderate, serious, 

severe, and extreme) and, accordingly, prescribes increasingly stringent measures that must be 

implemented and sets new deadlines for achieving the standards. The Act also establishes 

specific emissions reduction requirements to ensure that continual progress toward attainment is 

made. 

High levels of ozone are a health problem. When 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 irritation; breathing difficulties even for healthy 

individuals, but especially for those with respiratory problems such as allergies, asthma, 

bronchitis and emphysema; and greater susceptibility to respiratory infection. 

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 0.08 parts per 

million (ppm) and defined the new standard as a “concentration-based” form, specifically the 3-

year average of the 4th highest daily maximum 8-hour ozone concentrations. 

EPA designated the metropolitan Washington region as moderate nonattainment for the 8-hour 

ozone standard in April 2004. The region has a deadline of June 15, 2010, to meet the 8-hour 

ozone standard.1

 The geographic scope of the region includes the Metropolitan Washington 

Region defined as follows: Montgomery, Prince George’s, Frederick, Charles, Calvert Counties 

in Maryland; Fairfax County, Arlington County, City of Alexandria, City of Falls Church, City 

of Fairfax, Prince William County, Loudoun County, City of Manassas and City of Manassas 

Park in Virginia; and the District of Columbia. 

This document, the 8-Hour Ozone Attainment Plan for the Metropolitan Washington, DC-MDVA Nonattainment Area, is a plan to improve air quality in the Washington region to meet the 

National Ambient Air Quality Standard (NAAQS) for ozone. The Plan consists of a Reasonable 

Further Progress Plan, 2002-2008; an attainment plan; an analysis of reasonably available 

control measures; an attainment demonstration; contingency plans for RFP and attainment; and 

mobile 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 Attainment Plan is intended to show the progress being made to improve air 

quality in the Washington nonattainment 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 Washington Air Quality Committee (MWAQC) 

 

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

MWAQC Ozone SIP 1-1 May 23, 2007 
to comply with the Clean Air Act Amendments of 1990 and with EPA requirements for the 

Washington region as stated in EPA’s 2004 reclassification of the Washington region, and Phase 

1 and Phase 2 of EPA’s 8-Hour Implementation Guidance, issued in April 2004 and November 

2005. 

Ref No. Control Measure 2008 b 2009 c 2008 b 2009 c

MEASURES INCLUDED IN THE FUTURE CONTROLLED SCENARIO

6.1.2

State NOx RACT and Regional NOx Transport 

Requirement (RACT, NOx SIP Call, CAIR, HAA)

0.00 0.00 12.65 128.76

SUBTOTAL 0.00 0.00 12.65 128.76

6.2.11 Mobile Equipment Repair and Refinishing Rule 3.49 3.59 0 0

6.2.12 Portable Fuel Containers Rule: Phase I 7.34 9.30 0 0

6.2.13 Architectural and Industrial Maintenance Coatings Rule 10.62 10.82 0 0

6.2.14 Reformulated Consumer Products Rule: Phase I 6.23 0.76 0 0

6.2.15 Solvent Cleaning Operations Rule 2.91 2.99 0 0

6.2.16 Industrial Adhesives and Sealants Rule - 2.42 0

6.2.17 Portable Fuel Containers Rule: Phase II - 0.75 0

6.2.18 Reformulated Consumer Products Rule: Phase II 0.39 6.34 0 0

SUBTOTAL 30.98 36.97 0 0

6.3.1 EPA Non-Road Gasoline Engines Rule 42.44 11.68 14.76

6.3.2 EPA Non-Road Diesel Engines Rule

6.3.3 Emissions standards for spark ignition marine engines

6.3.4 Emissions standards for large spark ignition engines

6.3.5 Reformulated Gasoline (off-road)

6.3.6 Standards for Locomotive 0.05 0.06 2.54 2.74

SUBTOTAL 36.96 42.50 14.22 17.50

6.4.2 High-Tech Inspection/Maintenance (updated cutpoints)

6.4.4 National Low Emission Vehicle Program

6.4.5 Tier 2 Motor Vehicle Emission Standards

6.4.6 Heavy-Duty Diesel Engine Rule

6.4.7

Transportation Control Measures and Vehicle 

Technology, Fuel, or Maintenance Measures 0.19 0.18 0.49 0.45

SUBTOTAL 6.38 7.35 30.16 38.08

6.5 Voluntary Bundle 0.19 0.19 0.28 0.30

TOTAL REDUCTIONS 74.51 87.01 57.31 184.64

Notes:

0

0

b

 Reductions included in the 2008 Reasonable Further Progress demonstration, occurring between 2002 and 2008. c

 Reductions included in the attainment demonstration, occurring between 2002 and 2009.

a The Area Source reductions do not include the District of Columbia. The District's OTC VOC rules on all the 

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 additional enhancements to the air quality improvement in the region.

TABLE A

SUMMARY OF CONTROL STRATEGIES

VOC and NOx Benefits of Control Measures

(2002-2009)

VOC Reductions NOx Reductions

36.91

tons/day tons/day

VOLUNTARY MEASURES (Multiple Source Sectors)

ON-ROAD MEASURES

6.19 7.17 29.67 37.63

NON-ROAD MEASURES

POINT SOURCE MEASURES

AREA SOURCE MEASURES(a)

MWAQC Ozone SIP 1-2 May 23, 2007 
1.1 Background 

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 District 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 

Chapter 2. 

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) or Nitrogen Oxides (NOx) by at least 15 percent 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. 

The 8-Hour Ozone Attainment Plan for the Washington nonattainment areas has been developed 

by the Metropolitan Washington Air Quality Committee (MWAQC) in cooperation with 

Maryland, Virginia and the District of Columbia. Table A identifies the Washington region’s 

control measures to achieve a 15 percent emissions reduction by 2008 and attainment by 2009. 

EPA’s ozone guidance calls for demonstration of steady progress in improving air quality by 

2009. 

Overall, the 2009 attainment plan for the Metropolitan Washington 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 may be summarized as follows: 

• 128.76 tons per day of NOx reductions through 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, automobile repair, and consumer 

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, emissions standards 

for large spark ignition engines, reformulated gasoline, and marine 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 “mobile” sources of pollution; and 

• 0.19 tons per day of VOC reductions and 0.30 tons per day of NOx reductions from

voluntary measures spanning multiple source sectors. 

MWAQC Ozone SIP 1-3 May 23, 2007 
1.2 The Ozone Problem

Of the six major air pollutants for which ambient air quality standards have been established 

under the Clean Air Act, the pollutant that has posed the most prevalent and perplexing problem

for the Washington metropolitan area is ozone, a principal component of “smog.” 

Why has the ozone problem been so difficult to solve? First, ozone is not discharged directly. It 

is formed in, and downwind of, urban areas when sunlight and high temperatures cause complex 

photochemical reactions to occur between emissions of VOCs and NOx. A number of diverse 

sources emit these ozone precursors. Major sources of VOC emissions include, but are not 

limited to, gasoline storage facilities, bakeries, gasoline refueling stations, printing facilities, 

motor vehicles, lawnmowers, consumer products, and boats. In addition, many species of plants 

emit VOCs. Principal sources of NOx, which is produced by combustion and industrial 

processes, include motor vehicles, construction equipment, fossil fuel-fired power plants, and 

open burning. 

Second, the ozone problem is further complicated by the fact that weather conditions play a 

major role in the formation of ozone and in the severity of the problem. Solar energy drives the 

reactions that create ozone. When a warm air mass stays in one spot, and winds are calm, smog 

may remain for several days at a time, creating severe ozone conditions. While it is not always 

possible to predict weather conditions that create severe ozone problems, the more 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 attainment of the standards may be impossible without it. The complexity of the 

reactions that cause ozone requires reliance upon computer models of ozone formation to guide 

the region to the correct mix of VOC and NOx controls. For the most recent scientific findings 

about ozone, see Appendix G Attachment 1, “The Conceptual Model.” 

Fourth, given that smog travels across county and state lines, the ozone problem is regional. 

Therefore, solving the problem requires considerable coordination and consensus building on the 

part of local and state governments to develop regional emission control strategies. On the East 

Coast, governments from Maine to Washington, D.C. and Virginia are required under the Act to 

form the Ozone Transport Commission (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 Assessment Group (OTAG) worked to quantify and reduce the amount of 

ozone and its precursors, which move 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 promulgated the Clean Air 

Interstate Rule (CAIR) in 2005 as a regional transport rule to help the states towards meeting the 

8-hour ozone and PM2.5 standards. Both the NOx SIP call and CAIR apply to the Midwestern 

states as well as eastern states and require them to reduce emissions from stationary sources and 

were intended to reduce pollution transported aloft. 

MWAQC Ozone SIP 1-4 May 23, 2007 
1.3 SIP Process 

The Act requires states to develop and implement ozone reduction strategies in the form of a SIP. 

The SIP is the state's "master plan" for attaining and maintaining the NAAQS. 

Once the administrator 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 make the requisite amendments, 

the EPA administrator may issue binding amendments under Section 110(c)(1). 

EPA is required to impose severe sanctions on the states under three circumstances: the state's 

failure to submit a SIP revision; on the finding of the inadequacy of the SIP to meet prescribed 

air quality requirements; and the state's failure to enforce the control strategies that are contained 

in the SIP. 

Sanctions include the withholding of federal funds for highway projects -- other than those for 

safety, mass transit, or transportation improvement projects related to air quality improvement or 

maintenance -- beginning 24 months after EPA announcement. No federal agency or department 

will be able to award a transportation grant or fund, license, or permit any other transportation 

project that does not conform to the most recently approved SIP.

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

The Clean Air Act requires that serious nonattainment areas ensure progress toward the 

attainment goal by achieving a 15 percent reduction in volatile organic chemicals (VOCs) by 

1996, and an additional 9 percent by 1999. To demonstrate attainment, the Act requires the 

region to demonstrate, through the use of photochemical air quality computer models, that ozone 

will reach the level of the standard. The Washington region was classified as a serious 

nonattainment area for the 1-hour ozone standard in 1992, the standard in place at the time. EPA 

now uses a different measurement for the 8-hour ozone standard. 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 SIP to meet the requirements for a severe nonattainment area. The “Severe 

Area SIP” demonstrated 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, Contingency Measures, Transportation Control Measures, VMT 

Offset, and 1990 Base Year Inventory, Federal Register, 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 Resulting in Removal of Sanctions and Federal Implementation 

Clocks, Federal Register, Vol.70, No. 220, November 16, 2005, pp.69440-69443. 

MWAQC Ozone SIP 1-5 May 23, 2007 
1.5 Base Year 2002 Emission Inventories and Future Year 2008 and 2009 Emissions 

Inventories 

A comparison of future year inventories 2008 and 2009 to the base year inventory 2002 

demonstrate dramatic reductions in emissions. Between the base year 2002 and the attainment 

year 2009, volatile organic compound emissions (VOC) will decrease by 22.2 percent and 

emissions of nitrogen oxide (NOx) will decrease by 39.4 percent. The 8-hour ozone SIP 

presents revisions to the 2002 base year inventory using MOBILE 6.2.03, Travel Demand Model 

version 2.1d#50, including corrections to nonroad, area and stationary source emissions. A 

description of the 2002 Base Year inventory is included in Chapter 3 and complete 

documentation 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 Demand Model 

Version 2.1d#50. The future year inventories are discussed in SIP Chapter 4.

Figure 1-1. 

VOC Emissions by Source, 2002-2009 

VOC Emissions by Source (2002 Vs. 2009)

Washington, DC Nonattainment Area

12.91

192.64

125.79

448.28

116.94

348.74

88.66

66.68

179.10

14.31

0

100

200

300

400

500

Point Area Non-road On-road Total

E

mis

sions (tpd)

2002

2009

Figure 1-2. 

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

NOx Emissions by Source (2002 Vs. 2009)

Washington, DC Nonattainment Area

220.60

85.72

266.65

597.22

24.25

75.10

27.48

113.03

146.53

362.05

0

100

200

300

400

500

600

700

Point Area Non-road On-road Total

E

missions (tp

d)

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 mandates that to meet the Reasonable Further Progress (RFP) requirement, the 

Washington, DC-MD-VA 8-hour ozone nonattainment area needs to reduce its emissions by 15 

percent between 2002 and 2008 using either reduction in VOC or NOx or any combination of the 

two. This SIP explains that the Washington region is able to demonstrate reasonable further 

progress for the period 2002-2008 using a 15 percent VOC reduction. The Washington region’s 

controlled VOC emissions in 2008 of 358.84 tons per day (tpd) VOC are below the target level 

of VOC reductions of 370.45 tpd VOC, demonstrating that the region meets its 15 percent 

Reasonable Further Progress (RFP) requirement. 

1.7 Establishment of a Budget for Transportation Mobile Emissions 

As part of the development of the plan, MWAQC in consultation with the Transportation 

Planning Board (TPB) will establish mobile source emissions budgets or maximum allowable 

levels of VOC and NOx. These budgets will be the benchmark used to determine if the region’s 

long range transportation plan, known as the Constrained Long-Range Plan, (CLRP) and six year 

transportation improvements program (TIP) conform with the CAAA of 1990. Under EPA 

regulations the projected mobile source emissions for 2008 and 2009 -- minus the Transportation 

Control Measures (TCM) and vehicle technology, fuel, or maintenance-based measures -- 

become the mobile emissions budgets for the region unless MWAQC takes actions to set another 

MWAQC Ozone SIP 1-7 May 23, 2007 
budget level. The mobile emissions budgets were developed using computer models 

MOBILE6.2.03 and Travel Demand Model version 2.1d#50. 

 

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 TCMs 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. 

2008 Mobile Budgets: 

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

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 TCMs and 

vehicle technology, 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. 

2009 Mobile Budgets: 

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

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 TCMs 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 

MWAQC Ozone SIP 1-8 May 23, 2007 
1.8 Attainment Demonstration 

The 8-Hour Ozone Attainment Plan analyzes the potential of the Washington metropolitan area 

to achieve attainment of the 8-hour ozone standard. The demonstration of achieving the 8-hour 

ozone standard is based on results from the Community Multiscale Air Quality Model (CMAQ) 

and supporting Weight of Evidence analysis. The 8-hour ozone design value is the fourth highest 

maximum ozone concentration at a monitoring 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 monitoring stations in the Washington metropolitan area 

having a future design value at and above 85 ppb; all other monitors fall well below 85 ppb. 

Air quality trends continue to improve, emissions are decreasing (Fig.1-3), and in the past three 

years the region has less than one Code Red Day for every day over 90o

F. The impact of air 

quality improvement is demonstrated in the reduced spatial extent of the attainment zone in 

2005. Voluntary programs in the Washington area offer further potential for reducing ozone 

during the summer. Episodic programs such as teleworking and reducing electricity demand on 

high electric demand days may provide additional ozone reductions on the worst days of 

summer.

The photochemical modeling combined with supporting Weight of Evidence analysis provide 

strong evidence the region will attain the 8-hour ozone standard by 2009. 

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

8-hour Ozone Design Value

Washington, D.C. Region, 1988-2006

0.115

0.107

0.100

0.100

0.101

0.096

0.098

0.094

0.100

0.101

0.106

0.101

0.097

0.097

0.099

0.096

0.091

0.091

0.116

0.075

0.085

0.095

0.105

0.115

0.125

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Year

Design Value (ppm)

8-hour Ozone NAAQS

MWAQC Ozone SIP 1-9 May 23, 2007 
1.9 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: 1) Will 

reduce emissions by the beginning of the Washington region’s 2008 ozone season (May 1, 

2008); 2) Enforceable; 3) Technically feasible; 4) Economically feasible (proposed as a cost of 

$3,500-$5,000 per ton or less); 5) Would not create substantial or widespread adverse impacts 

within the region; and 6) Emissions from the source being controlled exceed a de minimis

threshold, proposed as 0.1 tons per day. 

If implemented collectively, any group of potential RACM measures 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 measures to determine if collectively they could meet these 

criteria. Several mandatory programs are available that can provide moderate levels of emission 

reductions, however, none of these measures can provide benefits by the 2008 ozone season, and 

the total overall reduction that could be provided by these measures is below 20-40 tons per day. 

While there are potential voluntary measures that can be implemented before 2008, together 

these voluntary measures will not provide sufficient creditable emission reductions to advance 

the attainment date by one year. Therefore, there are no RACM appropriate for the Washington 

region’s moderate area SIP. 

1.10 Contingency Measures 

In the event that the reductions anticipated in the 2008 RFP or 2009 attainment demonstration 

are not realized within the timeframes specified, contingency measures must be implemented. 

EPA issued guidance says that contingency measures must provide for a 3 percent reduction in 

baseline emissions. The contingency measures for the 2008 RFP and attainment demonstrations 

must total 3 percent of the 2002 adjusted base year inventory. 

To satisfy the contingency requirement for the 2008 RFP, the SIP includes a 3 percent reduction, 

attributed to states’ Clean Air Interstate Rule (CAIR) and Portable Fuel Container Rule benefits 

from 2008-2010. These measures deliver benefit in excess of 1.31 tpd VOC and 15.27 tpd NOx, 

thereby meeting the RFP contingency measure requirement. 

The contingency measures for the attainment demonstration must also total 3 percent of the 2002 

Adjusted Base Year Inventory. The contingency measures identified by the District of Columbia, 

Maryland and Virginia for the attainment demonstration deliver total benefits in excess of the 

required contingency emissions reductions; therefore these measures fulfill the region’s 

attainment contingency requirement. 

MWAQC Ozone SIP 1-10 May 23, 2007 
1.11 Document Contents 

Chapter 2 presents a detailed overview of the Clean Air Act, the region’s 

reclassification to moderate nonattainment area, the requirements for 

moderate nonattainment areas, additional commitments 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 Demand Model version 2.1d#50 including corrections to nonroad, 

area and stationary source emissions. 

Chapter 4 presents the 2008 and 2009 projected inventories using MOBILE 6.2.03 and 

Travel Demand Model Version 2.1d#50 to revise 2008 and 2009 projected 

and a discussion of the growth projection methodology. 

Chapter 5 presents 2008 RFP requirements. These are MWAQC’s calculations of 

how many tons per day of emissions must be reduced in the Washington 

region in order to meet the reasonable further progress target level of 

reductions and also describes the control strategy and associated target 

emissions levels for the 15 percent reduction requirement. 

Chapter 6 Outlines the control strategies that the states will implement to achieve the 

reductions in VOC and NOx. 

Chapter 7 discusses the analysis of Reasonably Available Control Measures 

(RACM). 

Chapter 8 discusses mobile source conformity issues and establishes 2008 and 2009 

mobile emissions budgets for the Metropolitan Washington region. 

Chapter 9 presents the states’ schedules and adoption of regulations to meet 

requirements for severe nonattainment areas and presents the states’ 

commitments to EPA. 

Chapter 10 presents the Metropolitan Washington region’s demonstration of

attainment based on CMAQ modeling and weight of evidence. 

Chapter 11 presents contingency measures for the 2008 Reasonable Further Progress 

and for the 2009 attainment demonstration. 

 

MWAQC Ozone SIP 1-11 May 23, 2007 
MWAQC 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. The 

1-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 District 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 4th 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 implementation rule, 40 CFR Part 51, Subpart X, 

requires moderate nonattainment areas to submit revisions to the state implementation plan that meet 

the following planning requirements: 

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

enactment 

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

• New Source Review (NSR) and Reasonably Available 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 stationary 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 stations 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 force 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. The 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 area 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 Ozone Nonattainment Region

Additionally, the Reasonable Further Progress and attainment demonstration for 8-hour ozone 

standard uses a new model, EPA’s Nonroad Model, to calculate emissions from the nonroad 

sector. In previous SIPs the nonroad emissions were calculated using a spreadsheet-based 

MWAQC Ozone SIP 2-4 May 23, 2007 
projection of an inventory developed by EPA. Changes in the estimating techniques for nonroad 

emissions have changed, so it is not possible to compare them with previous calculations. 

2.6 Sources of Ozone in the Metropolitan Washington Region 

Ozone (O3) is formed through a complex series of chemical reactions when oxygen molecules 

and atoms (O2 + O) are combined. The process occurs when reactive volatile organic compounds 

interact with nitrogen oxides in the presence of sunlight during hot, stagnant, summer days. 

VOCs are chemical compounds contained in gasoline, furniture polish, cleaning fluids, paint, 

inks, and other household and industrial products. VOCs also are a by-produce of combustion. 

Principal sources of NOx, which is produced by combustion and industrial processes, include 

motor vehicles, fossil fuel-fired power plants, and open burning. Ozone formation is favored 

under certain weather conditions, including high temperature, bright sunshine, and light winds. 

See Figure 2-2. 

Figure 2-2. Conditions for Ozone Formation 

MWAQC Ozone SIP 2-5 May 23, 2007 
Typically, ozone levels escalate rapidly before noontime, peak in the afternoon, and taper off when 

the sun goes down. Figure 2-3 shows hourly ozone concentrations for a typical 24-hour period in our 

region. 

Figure 2-3. Gradual build-up of ozone levels on a typical summer day. Ozone peaks in 

the afternoon, then tapers off to lower levels in the evening. 

Outer suburban and rural areas share this regional problem. Winds can move a cloud of ozonecontaining smog for long distances. Regional data indicate that violations of the ozone standard 

can occur in either rural, inner suburban, outer suburban, or urban areas or combinations thereof. 

While ozone within the region is caused mostly by emissions generated within the region, it also 

is carried into the metropolitan area by winds from elsewhere. Research conducted through the 

Ozone Transport Commission (OTC), and the Ozone Transport Assessment Group (OTAG) 

provides evidence that ozone formed in other parts of the country may drift into and affect air 

quality in the Washington region. 

A number of diverse sources emit the ozone precursors VOC and NOx. Major sources of VOC 

emissions include, but are not limited to, gasoline storage facilities, bakeries, gasoline refueling 

stations, printing facilities, motor vehicles, lawnmowers, consumer products, and boats. Principal 

sources of NOx, which is produced by combustion, include motor vehicles (cars, trucks and 

buses), fossil fuel-fired power plants, and construction equipment. 

In general the anthropogenic (man-made) sources of ozone precursors are grouped into four 

source categories: point (stationary), area, non-road, and mobile sources. 

Point sources are stationary sources that emit more than 10 tpy of emissions. These sources are 

individually inventoried. Actual emissions measurements are available for some sources from

MWAQC Ozone SIP 2-6 May 23, 2007 
MWAQC Ozone SIP 2-7 May 23, 2007 

the states and the District of Columbia. Emissions 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 VOLATILE 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 nearest 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 whole 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 hospital 

admissions 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 levels of exposure (even levels below the federal 

health standard), or experience more adverse effects 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 children with asthma and 277,912 adults; 

• 191,510 residents with other chronic or persistent 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. 
ESTIMATES OF POPULATIONS-AT-RISK EXPOSED

TO ADVERSE HEALTH CONSEQUENCES FROM OZONE

WASHINGTON DC-MD-VA MSA

0

100

200

300

400

500

Thousands

District of Columbia Suburban Maryland Northern Virginia

ESTIMATES OF POPULATIONS-AT-RISK EXPOSED

TO ADVERSE HEALTH CONSEQUENCES FROM OZONE

WASHINGTON DC-MD-VA MSA

0

100

200

300

400

500

Thousands

District of Columbia Suburban Maryland Northern Virginia

Figure 2-4. Approximately one-third of the residents of Metropolitan 

Washington area are: children; asthmatics over 65; have chronic respiratory 

diseases; and/or are especially sensitive to ozone. These individuals are 

more vulnerable to ill effects from air pollution. Source: American Lung 

Association 6

As mentioned earlier, ozone poses a threat not only to human health, but also to the health of 

natural ecosystems. Scientific evidence suggests that air pollution weakens the immune systems 

of many types of vegetation and can cause significant crop damage. In addition, rain and snow 

wash air pollution deposited on vegetation and architectural surfaces into the streams and rivers 

of the region and finally into the Chesapeake Bay.

2.8 Frequency of Violation of Federal Health Standard for Ozone

The Washington area has exceeded the federal 8-hour health standard for ozone since the 

standard was introduced in 1997. The number of ozone exceedance days in a season ranged from

a low of 8 to a high of 48. In an average summer from 1997 - 2006, there were 25 days when 

Washington's air exceeded the ozone standard. 

The federal standard is 0.08 ppm (84 ppb) of ozone averaged over eight hours. Figure 2-5 shows 

the number of days that the Washington region has violated the ozone standard since 1997. 

Violations are related to the weather (hot stagnant summers are favorable for ozone formation) 

and the levels of ozone precursors present in the ambient air. 

The Metropolitan Washington Council of Governments (COG) issues an air quality forecast 

prepared by a regional team of meteorologists each day during the summer. The daily forecast 

and air quality index (AQI) advise the public of the air quality conditions for the next 24 hours, 

MWAQC Ozone SIP 2-11 May 23, 2007 
MWAQC Ozone SIP 2-12 May 23, 2007 

so that those at risk can take adequate precautions and everyone can take action to reduce ozonecausing emissions. 

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

Exceedances of 8-hour Ozone Standard

Washington, D.C. Region, 1997-2006

30

48

40

11

22

38

8 8

20 21

5

30

55

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Year

Number of Exceedance Days

Note: Health Standard for 8-hour Ozone is 0.08 ppm. Data shown are the number of days in

each year when at least one monitor in the region recorded ground-level ozone concentrations

above the 8-hour health standard.

2.9 The Metropolitan Washington Air Quality Committee (MWAQC) 

Under Section 174 of the Clean Air Act Amendments, the governors of Maryland and Virginia 

and the mayor of the District of Columbia certified the Metropolitan Washington Air Quality 

Committee (MWAQC) to develop specific recommendations for a regional air quality plan in the 

Washington, DC-MD-VA nonattainment area. The agreement was renewed in 2004. 

Members of MWAQC include elected officials from the Cities of Bowie, College Park, 

Frederick, Gaithersburg, Greenbelt, Rockville, and Takoma Park in Maryland, and Alexandria, 

Fairfax and Falls Church, Manassas and City of Manassas Park in Virginia; the Montgomery and 

Prince George's county councils; the Montgomery and Prince George's county executives; the 

mayor of the District of Columbia and representatives of the Council of the District of Columbia; 

and representatives of Calvert, Charles, and Frederick counties in Maryland, and Arlington, 

Fairfax, Loudoun, and Prince William counties in Virginia. 

Representatives of the general assemblies of Maryland and Virginia, the state air management 

directors, and the state transportation directors, and the chairman of the National Capital Region 

Transportation Planning Board also are members of MWAQC. The membership 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), Maryland 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 the 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 followed 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 strategies 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 demonstrate 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 reduction 
MWAQC 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 to 

adjust 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 therefore 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 Environmental 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). Virginia 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 included New York State Dept. of Environmental 

Conservation (NYS DEC), University of Maryland, 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 attainment 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 Nonattainment Area, Establishing Out-Year Mobile Emissions 

Budgets for Transportation Conformity, MWAQC, January 19, 2000. 4

Approval and Promulgation of Air Quality Implementation Plans, District of Columbia, Maryland, Virginia, 

 1-Hour 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. 25688-25716 and 

Approval and Promulgation of Air Quality Implementation Plans; Maryland; Metropolitan Washington, DC 1-Hour 

Ozone Attainment Plan, Lifting of Earlier Rules Resulting 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.org
MWAQC 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 published in a separate document, "2002 Base Year Emissions 

Inventory of Ozone Precursor Emissions for the 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 for inspection at the offices of 

the Council of Governments and the District of Columbia, Maryland, and Virginia air 

management agencies in addition to COG Web site (http://sharepoint.mwcog.org/airquality). 

The emissions inventory covers the Washington DC-MD-VA nonattainment area, Figure 2-1, 

which is classified as a moderate nonattainment area for ozone by the U.S. Environmental 

Protection Agency (EPA). The 2002 emissions inventory is the starting point 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 reasonable further progress requirements (RFP) 

prescribed for moderate nonattainment areas by the Clean Air Act Amendments and EPA. 

This separately published document addresses emissions of volatile organic 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 sources 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 rounding 
MWAQC 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 rounding 
MWAQC 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 rounding 
MWAQC 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 stationary, 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 severe 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 geographical area of the Washington DC-MD-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 small to be inventoried individually and which 

collectively contribute significant emissions. Area sources include smaller stationary point 

sources not included in the states' point source inventories such as printing establishments, dry 

cleaners, and auto refinishing companies, as well as non-stationary sources. 

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

indicator of collective activity for each source category at the county (or county-equivalent) 

level. An activity level is any parameter associated with the activity of a source, such as 

production rate or fuel consumption that may be correlated with the air pollutant emissions from 

that source. For example, the total amount of VOC emissions emitted by commercial aircraft 

can be calculated by multiplying the number of landing and takeoff 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) factors. For example, solvent evaporation from consumer and 

commercial products such as waxes, aerosol products, and window cleaners cannot be routinely 

determined for many local sources. The per capita emission factor assumes that emissions in a 

given area can be reasonably associated with population. This 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 demand 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 determine the emissions characteristics of the 

vehicle fleet in place in the year 2002. Input for this emissions model includes locally specific 

information such as age distribution of registered vehicles, evaporation characteristics of motor 

fuel, and temperature data. The general equation for the estimation of mobile sources is: 

(Travel Component) x (Emission Factor) = Emissions 

Emissions accounted for in the mobile source inventory include: 

Origin: Emissions include "cold start" and "hot start" emissions 

occurring during the first few minutes of vehicle operation. 

Running: Emissions occurring on local 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 after the engine is turned off. 

Diurnal: Evaporative emissions occurring 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 auto 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 engines except airport (aircraft, ground support 

equipment (GSE) and, auxiliary power units (APU), locomotives, and diesel marine vessels were 

calculated using EPA’s NONROAD2005 model version 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 version. 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-terrain vehicles and off-road motorcycles; 

• Logging equipment, such as chain saws; 

• Agricultural equipment, such as tractors; 

• Construction equipment, such as graders and back hoes; 

• Industrial equipment, such as fork lifts and sweepers; 

• Residential and commercial lawn and garden 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, fuel 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 deterioration and/or new standards. 

The emissions are then temporally and geographically allocated using appropriate allocation 

factors. 

Aircraft (military, commercial, general aviation, and air taxi) and auxiliary power units (APU) 

operated at airports along with locomotives and diesel marine vessels are also considered 

nonroad sources and are included in the nonroad category. 

Metropolitan Washington Airports Authority (MWAA) provided all 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, 20091

 (see 

Appendix B4 of the 2002 base year inventory 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 counties were provided by the respective states. 

Emissions from locomotives and commercial diesel marine vessels were also provided by the 

states. 

3.2.5 Biogenic Emissions 

An important component of the inventory is biogenic emissions. Biogenic emissions are those 

resulting from natural sources. Biogenic emissions 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 for 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 estimated 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 through 3-6 for the annual emissions. A summary of 

both the ozone season day and the annual inventories 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 implement the 8-hour NAAQS requires the Washington, DCMD-VA ozone nonattainment region to achieve a 15 % reduction between 2002 and 2008 

using reductions in either VOC or NOx emissions or with any combination of the two.1

Also an inventory for the attainment year 2009 is required for the region. The 15 % 

reduction must be calculated from the anthropogenic emissions levels reported in the 

2002 base year emissions inventory after those levels have been adjusted for noncreditable emissions reduction occurring between 2002 and 2008. The 2002 Base-Year 

Inventory is described in Chapter 3. This chapter presents the 2008 and 2009 projection 

inventories, the estimation of the levels of emissions to be expected in those years before 

the consideration of emissions controls. 

The 2008 and 2009 projected inventories were derived by applying the appropriate 

growth factors to the 2002 base year emissions inventory. EPA guidance describes four 

typical indicators of growth. In order of priority, these are product output, value added, 

earnings, and employment. Surrogate indicators of activity, for example population 

growth, are also acceptable methods. 

Round 7.0 Cooperative Forecasts (population, household and employment projections) 

and Vehicle Miles Traveled (VMT) projections for 2008 and 2009 were used to project 

area sources emissions. Round 7.0 Cooperative Forecasts were prepared by the 

Metropolitan Washington Council of Governments (MWCOG) staff and officially 

adopted by its Board of Directors on October 12, 2005, prior to the Base Realignment 

and Closure (BRAC) announcements. Vehicle Miles Traveled (VMT) projections were 

developed by COG Department of Transportation Planning staff as part of the report on 

2005 Constrained Long Range Plan (CLRP) & 2006-2011 Transportation Improvement 

Program (TIP) for the National Capital Region Transportation Planning Board. 

Projections for onroad emissions were developed using MOBILE6.2 (January 2003) 

model and the Travel Demand Model ver. 2.1d #50 developed by the National Capitol 

Region Transportation Planning Board. The travel demand modeling process also used 

Round 7.0 Cooperative Forecasts. 

EPA’s nonroad model, NONROAD2005, was used for developing both 2008 and 2009 

nonroad inventories. The Economic Growth Analysis System (EGAS) model was used by 

all three jurisdictions to project growth in point source emissions. 

 1

 40 CFR 51.910(a), Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality StandardPhase 2; Federal Register. Final Rule To Implement Certain Aspects of the 1990 Amendments Relating to

New Source Review and Prevention of Significant Deterioration as They Apply in Carbon Monoxide, 

Particulate Matter and Ozone NAAQS; Final Rule for Reformulated Gasoline, Federal Register. Vol.70,

No. 228, Nov. 29, 2005, pp.71612-71705. 

MWAQC Ozone SIP 4-1 May 23, 2007 
4.1 Growth Projection Methodology 

The following sections describe the methods followed to determine the projected 

inventories for 2008 and 2009 for point, area, nonroad, and onroad sources. 

4.1.1 Growth Projection Methodology for Point Sources: EGAS

The growth in point source emissions is projected using EGAS version 5.0. Point source 

emissions for 2002 are provided from the state data sources and the model is run with the 

following options selected: Source Classification Code; the Bureau of Labor Statistics 

national economic forecast; and the baseline regional economic forecast. Point source 

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

4.1.2 Growth Projection Methodology: Area Sources

Base year 2002 area source emissions were calculated using the year 2002 population, 

household, and employment data. Growth factors for the periods 2002 through 2008 and 

2002 through 2009 were derived by dividing Cooperative Round 7.0 population, 

household, and employment forecasts and Vehicle Miles Traveled (VMT) data provided

by COG Department of Transportation Planning for 2008 and 2009 by the year 2002 

population, household, employment, and VMT data for the region respectively. 

Cooperative Round 7.0 Forecasts and VMT data are provided in Appendix D1 and E1 

respectively. Projected area source inventories for 2008 and 2009 are contained in 

Appendix D1. Growth factors used for the 2008 and 2009 projection years are presented 

in Tables 4-1 and 4-2. 

Table 4-1 

2002-2008 Growth Factors 

Jurisdiction Employmenta Populationa Householda VMTb

District of Columbia 1.032 1.038 1.041 1.033

Calvert County 1.238 1.126 1.127 1.151

Charles County 1.264 1.127 1.142 1.140

Frederick County 1.259 1.140 1.143 1.146

Montgomery County 1.088 1.084 1.082 1.048

Prince George's County 1.090 1.047 1.067 1.045

City of Alexandria 1.150 1.071 1.086 1.045

Arlington County 1.113 1.068 1.086 1.019

Fairfax County 1.109 1.098 1.101 1.058

Fairfax City 1.052 1.058 1.057 1.058

MWAQC Ozone SIP 4-2 May 23, 2007 
Falls Church City 1.145 1.109 1.132 1.058

Loudoun County 1.367 1.444 1.447 1.292

Prince William County 1.201 1.263 1.267 1.163

Manassas City 1.055 1.058 1.079 1.163

Manassas Park City 1.383 1.249 1.279 1.163

a Growth factors based on COG Round 7.0 Cooperative Forecasts. b

 Growth factors based on VMT estimates from 2005 CLRP & 2006-2011 TIP provided by COG

Department of Transportation Planning. 

Table 4-2 

2002-2009 Growth Factors 

Jurisdiction Employmenta Populationa Householda VMTb

District of Columbia 1.043 1.049 1.051 1.038

Calvert County 1.266 1.147 1.147 1.161

Charles County 1.291 1.141 1.160 1.159

Frederick County 1.297 1.162 1.165 1.175

Montgomery County 1.106 1.097 1.095 1.057

Prince George's County 1.108 1.052 1.076 1.062

City of Alexandria 1.166 1.083 1.101 1.083

Arlington County 1.137 1.082 1.102 1.023

Fairfax County 1.138 1.117 1.120 1.074

Fairfax City 1.066 1.071 1.067 1.074

Falls Church City 1.094 1.141 1.172 1.074

Loudoun County 1.427 1.515 1.517 1.331

Prince William County 1.235 1.304 1.312 1.189

Manassas City 1.067 1.064 1.089 1.189

Manassas Park City 1.489 1.286 1.322 1.189

a Growth factors based on COG Final Round 7.0 Cooperative Forecasts. b

 Growth factors based on VMT estimates from 2005 CLRP & 2006-2011 TIP provided by COG

Department of Transportation Planning. 

2008 and 2009 emissions for area sources were calculated by multiplying the 2002 baseyear area emissions by the above growth factors for 2008 and 2009 for each jurisdiction. 

Each area source category was matched to an appropriate growth surrogate based on the 

MWAQC Ozone SIP 4-3 May 23, 2007 
activity used to generate the base-year emission estimates. Surrogates were chosen as 

follows:

Surface Coating – Depending on whether emission factors were based on employment 

or population, the surrogate chosen varied with individual sub-categories. For example, 

the automobile refinishing category was grown using employment, as the emission factor 

was based on it, but population was chosen for growing traffic markings as its emission 

factor was based on population. 

Commercial/Consumer Solvent Use - Population was chosen as the growth surrogate 

since 2002 emissions are based on per capita emission factors. 

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

Industrial/Commercial/Institutional Fuel Combustion - Population was chosen as the 

growth surrogate except for the commercial/institutional coal combustion category, 

where no growth was assumed. 

Vehicle Fueling (Stage II) and Underground Tank Breathing - All gasoline marketing 

categories were based on vehicle miles traveled (VMT) data since VMT is an appropriate 

surrogate for gasoline sales. Emission factors for these categories are based on gasoline 

sales. 

Open Burning - Population was chosen as the growth surrogate as yard wastes, land 

debris, etc. increase with population. 

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

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

surrogate. 

Dry Cleaning - Employment was chosen as the surrogate.

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

capita emission factors. 

Surface Cleaning - Employment growth was used as the surrogate. 

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

emissions are calculated using gasoline sales. 

Municipal Landfills - Base-year emissions are estimated 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 surrogate since base-year emissions are 

calculated using per capita emission factors. 

MWAQC Ozone SIP 4-4 May 23, 2007 
Bakeries, Breweries - Population was chosen as the surrogate. 

Soil/Groundwater Remediation - Zero growth was applied to this category. The number 

of remediations during the ozone season, used to generate base-year emissions, does not 

directly correlate to population, households, or employment growth. 

Portable Fuel Container Emissions - Emissions for the District of Columbia and 

Maryland from residential and commercial sectors were grown based on household and 

employment respectively. Emissions for Virginia were grown using the fuel usage by 

SCCs associated with the refueling of portable fuel containers. These fuel usage data 

were derived from the NONROAD2005 model by MACTEC as part of the emissions 

development efforts for the Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) modeling process. 

Commercial Cooking - Employment growth was used as the surrogate. 

Composting – Zero growth was applied to this category. 

Forest Fires, Slash Burning, Prescribed Burning – Zero growth was applied to this 

category. 

Accidental Oil Spills - Zero growth was applied to this category. 

Incineration– Zero growth was applied to this category.

Pesticide Application - Zero growth was applied to this category.

Aircraft Refueling Emissions - Emissions from refueling of aircrafts was projected 

based on employment. 

4.1.3 Growth Projection Methodology: Nonroad Sources 

The 2008 and 2009 nonroad source inventories were created through the use of EPA’s 

NONROAD2005 model version 2005a (February 8, 2006), except for locomotives, 

marine diesel vessels, and aircrafts. This model was run with its associated graphic user 

interface NONROAD2005.1.0 (June 12, 2006), reporting utility version. 2005c (March 

21, 2006), and all geographical allocation data files updated until February 1, 2006. The 

base year 2002 nonroad source inventory was also created using the same model, 

reporting utility and geographical allocation data files, but with a different graphic user

interface version NONROAD2005.0.0 (December 2, 2005). 

Nonroad model runs were made for the metropolitan Washington region for average 

ozone season day. The ozone season extends from May through September. However, the 

NONROAD2005 model used in these runs did not have the option to run the model for 

the ozone season period. Instead, it provided an option for a summer season (June – 

August) run. In order to get average ozone season day emissions, the model was run for 

MWAQC Ozone SIP 4-5 May 23, 2007 
the entire summer season (June-August) while using average ozone season fuel 

parameters. Then total emissions calculated this way were divided by the total number of 

days in the summer season (92) to get average ozone season day emissions. Monthly fuel 

data obtained from the states were averaged for the period May through September to get 

fuel parameters reflecting the ozone season period. Three different sets of average ozone 

season fuel parameters were developed each for the District of Columbia, Virginia, and 

Maryland. 

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

Temperature

Temperature data were acquired from the National Climatic Data Center (NCDC). 

Hourly average temperature data were collected for Dulles (IAD) and Reagan National 

(DCA) weather stations for the top ten 8-hour maximum ozone days during the period 

2002-2004. Then the two hourly datasets were averaged together to get one hourly 

dataset. Then minimum, maximum, and average temperatures were computed from this 

hourly temperature dataset. 

Fuel inputs

Month specific data for fuel RVP and oxygen weight percent were provided by the state 

air agencies of Maryland and Virginia. These data were averaged for the period May 

through September to get ozone season average inputs. The District of Columbia decided 

to use year and ozone season specific Mobile6 model default values for these parameters. 

Nonroad model defaults were used for sulfur content in gas, diesel, marine diesel, and 

CNG/LPG. Model default (Zero %) Stage II controls were assumed for the model runs. 

 

Model inputs (temperature, fuel, and other parameters) for both 2008 and 2009 are listed 

below for each jurisdiction: 

Table 4-3 

NONROAD Model - Common Inputs 

Parameters Values

Min. Temperature 69.8 

Max. Temperature 92.5 

Avg. Temperature 81.4 

Gas Sulfur (%) 0.003 

Diesel Sulfur (%) 0.0348

Marine Diesel Sulfur (%) 0.0408

CNG/LPG Sulfur (%) 0.003 

Oxygen Weight (%) 2.1 

Stage II Control (%) 0 

MWAQC Ozone SIP 4-6 May 23, 2007 
Table 4-4 

NONROAD Model – State-Specific Inputs 

State RVP

District of Columbia 6.8 

Maryland 6.9

Virginia 6.8

Since the nonroad model does not generate emissions for aircraft, APU, locomotives, and 

commercial diesel marine vessels, these were either projected from the base year 

emissions using the Cooperative Forecast 7.0 or acquired from MWAA. Below are the 

details for projecting emissions for the above mentioned individual nonroad categories. 

Aircraft emissions (commercial, military, general aviation, air taxi)

Metropolitan Washington Airports Authority (MWAA) provided all types of airport 

emissions for Dulles and Reagan National 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, 20092

 (see 

Appendix B4 of the base year 2002 inventory document). Since Dulles airport is spread 

across Fairfax and Loudoun counties, MWAA emission from Dulles airport were divided 

equally between Fairfax and Loudoun counties. Emissions from Reagan National airport 

were put into Arlington County. 

Military aircraft emissions for Maryland for future years were provided by MDE. No 

growth was assumed for Virginia military aircraft emissions. 

General aviation and air taxi emissions for Maryland were provided by MDE. For 

Virginia, these emissions were grown from the base year using population as the 

surrogate. 

Auxiliary power unit emissions 

These emissions were only available for Dulles (Fairfax & Loudoun) and Reagan 

National (Arlington) airports and were provided by the MWAA. Details on the 

development of these emissions are provided in the MWAA airport emissions document 

referred above. 

Ground support equipment emissions 

The NONROAD2005 model generated these emissions for Arlington, Loudoun, 

Manassas city, Fredrick, Montgomery, and Prince Georges’ counties. However, 

emissions for Arlington, Fairfax, and Loudoun counties were taken from the MWAA 

document referred above. MWAA GSE emissions were generated using the EDMS 

model, which calculated emissions based on actual aircraft operations and used data from

a recent survey performed in February 2004 on GSE fleet, fuel types, and operating 

 2 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 4-7 May 23, 2007 
times. Nonroad model calculated emissions are based on GSE population only and 

therefore emissions generated this way were considered less accurate than the one 

generated by the EDMS model. MWAA also provided emissions from mobile lounges 

for Dulles airport separately, which were combined with GSE emissions. While MWAA 

GSE emission from Dulles airport were divided equally between Fairfax and Loudoun 

counties, those from Reagan National airport were put into Arlington county. 

Commercial Diesel Marine Vessels

Base year emissions from commercial diesel marine vessels were provided by MDE and 

were grown to future years using employment as the surrogate. 

Railroad

Railroad or locomotive emissions were provided by all three states and were grown using 

employment as the surrogate. 

Projected nonroad source inventories for 2008 and 2009 are contained in Appendix D1. 

Detailed NONROAD2005 model output files are being provided separately in electronic 

format as Appendix D2 of this document.

4.1.4 Growth Projection Methodology: Onroad Sources 

The 2008 and 2009 mobile source inventories were created through the use of 

transportation and emissions modeling techniques. This involved use of the 

MOBILE6.2.03 emissions factor model and the Version 2.1d #50 Travel Demand Model 

with 2008 and 2009 planned highway network. Full documentation of the development of 

the 2008 and 2009 mobile inventories is included in Appendix E1. Detailed Mob6.2.03 

model input, output, and external output files are being provided separately in electronic 

format as Appendix E2 of this document. Appropriate population, household, and 

employment growth are input through the Round 7.0 Cooperative Forecasting techniques. 

4.1.5 Biogenic Emission Projections 

2002 base year emissions were estimated by EPA using BEIS3.12 model. Biogenic 

emission inventories for 2009 are the same as those used for the 2002 base year for 

Washington, DC-VA-MD ozone nonattainment region. Year specific biogenic 

inventories for 2009 were not estimated. No 2008 biogenic inventories were prepared as 

they are not used to determine reasonable further progress. 

4.2 Offset Provisions and Point Source Growth 

The Act requires that emission growth from major stationary sources in nonattainment 

areas be offset by reductions that would not otherwise be achieved by other mandated 

controls. The offset requirement applies to all new major stationary sources and existing 

major stationary sources that have undergone major modifications. Increases in emissions 

from existing sources resulting from increases in capacity utilization are not subject to the 

MWAQC Ozone SIP 4-8 May 23, 2007 
offset requirement. For the purposes of the offset requirement, major stationary sources 

include all stationary sources exceeding an applicable size cutoff. The Washington, DC

region is designated as moderate nonattainment for the 8-hour ozone standard. Under the 

current moderate designation, the NSR thresholds are 50 tpy VOC and 100 tpy NOx. 

The New Source Review permit regulations in Virginia are structured so that the 

pertinent requirements such as major source threshold and offset ratio are selfimplementing depending upon changes to the nonattainment area classification. The NSR 

threshold will remain at 25 tpy for both VOC and NOx for Maryland and the District. 

NSR offset ratio of 1.15 to 1.00 applicable for moderate area was used. 

4.3 Actual vs. Allowable Emissions in Development of the 2008 and 2009 

Projected Emissions Inventories 

For the purposes of calculating 2008 and 2009 projection emissions inventories, EPA 

guidance specifically outlines the circumstances under which emissions projections are to 

be based on actual or allowable emissions. For sources or source categories that are 

subject to a pre-1990 regulation and the state does not anticipate subjecting the source to 

additional regulation, emissions projections should be based on actual emissions levels. 

Actual emissions 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 based on new allowable emissions. 

To simplify comparisons between the base-year and the projected year, EPA guidance 

states that comparison should be made only between like emissions: actual to actual, or 

allowable to allowable, not actual to allowable. Therefore, all base year and all projection 

year emissions estimates are based on actual emissions. 

The term "actual emissions" means 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 normal source operation. Actual emissions 

are calculated using the source's operating hours, production rates, and types of material 

processed, stored, or combusted during the selected time period. 

"Allowable emissions" are defined as the maximum emissions a source or installation is 

capable of discharging after consideration of any physical, operations, or emissions 

limitations required by state regulations or by federally enforceable conditions, which 

restrict operations and which are included in an applicable air quality permit to construct 

or permit to operate, secretarial order, plan for compliance, consent agreement, court 

order, or applicable federal requirement. 

4.4 Projection Inventory Results 

The 2008 and 2009 VOC and NOx projection-year emission inventory results with no 

control measures applied summarized by component of the inventory in Tables 4-3 

though 4-6 below. 

MWAQC Ozone SIP 4-9 May 23, 2007 
Table 4-5 

2008 Projected Uncontrolled VOC Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb

Point 5.34 8.40 0.26 13.99

Area 101.62 93.55 17.40 212.56

Non-road 65.27 55.61 8.56 129.44

Mobile 36.56 32.62 7.99 77.17

Totalb

208.78 190.18 34.21 433.17

Notes: 

a Maryland point source emissions include 0.98 tpd of quasi- point source emissions from Andrews Air 

Force Base (AFB). b

 Small discrepancies may result due to rounding. 

Table 4-6 

2008 Projected Uncontrolled NOx Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb

Point 176.91 56.98 8.12 242.01

Area 7.11 17.58 2.24 26.93

Non-road 36.14 44.28 10.71 91.13

Mobile 92.51 80.10 17.36 189.97

Totalb

312.67 198.93 38.43 550.03

Notes: 

a Maryland point source emissions include 2.21 tpd of quasi- point source emissions from Andrews AFB. b

 Small discrepancies may result due to rounding. 

MWAQC Ozone SIP 4-10 May 23, 2007 
Table 4-7 

2009 Projected Uncontrolled VOC Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb

Point 5.33 8.81 0.26 14.40

Area 103.06 95.44 17.57 216.07

Non-road 66.00 56.58 8.58 131.16

Mobile 34.97 31.36 7.52 73.85

Totalb

209.35 192.19 33.93 435.48

Notes: 

a Maryland point source emissions include 0.98 tpd of quasi- point source emissions from Andrews AFB. b

 Small discrepancies may result due to rounding. 

Table 4-8 

2009 Projected Uncontrolled NOx Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb

Point 176.85 57.40 7.54 241.79

Area 7.17 17.96 2.26 27.39

Non-road 36.66 45.12 10.82 92.6

Mobile 89.74 77.53 16.89 184.16

Totalb

310.41 198.02 37.52 545.95

Notes: 

a Maryland point source emissions include 2.21 tpd of quasi- point source emissions from Andrews AFB. b

 Small discrepancies may result due to rounding. 

MWAQC Ozone SIP 4-11 May 23, 2007 
4.5 Emission Reductions from Control Measures

Chapter 6 of this SIP describes the control measures that have either already been 

implemented or will be implemented by 2008 and 2009 that will reduce emissions in the 

two years. Most control measures are required by federal or state regulations. Local 

governments and state agencies have voluntarily committed to other measures, as 

described in Section 6.5. Projected controlled inventories for 2008 and 2009 assume a 

number of control measures to be in place by these years. 

Tables 4-9 through 4-12 present the projected controlled emissions for the 2008 rate-ofprogress and 2009 attainment years resulting from implementation of the control 

measures. Below is a list of the measures implemented by the year 2002 in the 

Washington region. Chapter 6 presents detailed information on the measures and the 

projected reductions from each. 

Point

Non-CTG VOC RACT to 50 tpy 

NOx OTC Phase II Budget Rules (DC only) 

Expanded Non-CTG VOC RACT and State Point Source Regulations to 25 tons/yr 

NOx SIP Call (MD) 

Area

Stage II Vapor Recovery

Phase II Volatility Controls of Refueling Emissions 

Reformulated Surface Coatings 

Reformulated Consumer Products – National Rule 

Reformulated Industrial Cleaning Solvents – National Rule 

National Standards for Locomotive Engines 

Surface Cleaning/Degreasing for Machinery/Automotive Repair 

Landfill Regulations 

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 Emissions standards for spark ignition marine engines 

2002 EPA Emissions standards for large spark ignition engines 

Reformulated Gasoline (off-road) 

Onroad

High-Tech Inspection/Maintenance (I&M) 

Reformulated Gasoline (on-road) 

MWAQC Ozone SIP 4-12 May 23, 2007 
Federal “Tier I” Vehicle Standards and New Car Evaporative Standards 

National Low Emission Vehicle Program

Below is a list of the measures with phased-in implementations between 2002 and 2009 

in the Washington region. Note that the District's OTC VOC rules on all the 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 additional enhancements to the air quality improvement 

in the region. 

Point

Clean Air Interstate Rule (CAIR) (VA and DC) 

Maryland Healthy Air Act (MD) 

Area

Additional phase-in of reductions from National Locomotives Rule 

OTC Mobile Equipment Repair and Refinishing (VA and DC) Rule 

OTC AIM Coatings Rule 

OTC Solvent Cleaning Rule for VA and DC 

OTC Consumer 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 technology rules implemented by 2002. 

Onroad

Heavy-Duty Diesel Engine Rule (2004) 

Heavy-Duty Diesel Engine Rule (2007) 

Tier 2 Motor Vehicle Emission Standards 

I&M Program with Final Cutpoints 

Transportation Control Measures (TCMs) 

Vehicle Technology, Maintenance, or Fuel-Based Measures 

MWAQC Ozone SIP 4-13 May 23, 2007 
4.6 2008 Controlled Emissions for Reasonable Further Progress

The projection of 2008 controlled emissions is simply the 2008 uncontrolled emissions 

minus the emission reductions achieved from the federal control measures and the 

reasonable further progress control measures implemented by states for the 8-hour ozone 

plan. This information is presented in Table 4-7 and Table 4-8. Controlled point source 

inventories are contained in Appendix C, controlled area and nonroad source inventories 

in Appendix D1, and controlled mobile source inventories in Appendix E1. Maryland 

point source emissions include quasi- point source (nonroad and onroad mobile) 

emissions from Andrews Air Force Base, which are described in detail in the 2002 Base 

Year emissions inventory document. 

Table 4-9 

2008 Projected Controlled VOC Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb,d

Point 5.34 8.40 0.24 13.98

Areac

87.63 76.55 17.40 181.59

Non-road 47.50 37.92 7.06 92.48

Mobile 33.86 29.65 7.47 70.98

Totald

174.33 152.52 32.18 358.84

Notes: 

a Maryland point source emissions include 0.98 tpd of quasi- point source emissions from Andrews AFB. b

 Regional total includes a reduction of 0.19 tpd VOC from Voluntary Measures Bundle. c

 The controlled area source emissions for the District do not include reductions from the OTC VOC

measures. The District's OTC VOC rules on all the 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 

additional enhancements to the air quality improvement in the region. d

 Small discrepancies may result due to rounding

MWAQC Ozone SIP 4-14 May 23, 2007 
Table 4-10 

2008 Projected Controlled NOx Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb,c

Point 176.91 49.34 3.11 229.36

Area 7.11 17.58 2.24 26.93

Non-road 30.13 37.68 9.09 76.91

Mobile 77.85 67.20 15.25 160.30

Totalc

292.01 171.80 29.69 493.22

Notes: 

a Maryland point source emissions include 2.21 tpd of quasi- point source emissions from Andrews AFB. b

 Regional total includes a reduction of 0.28 tpd NOx from Voluntary Measures Bundle. c

 Small discrepancies may result due to rounding

4.7 2009 Controlled Emissions for Attainment

The projection of 2009 controlled emissions is simply the 2009 uncontrolled emissions 

minus the emission reductions achieved from the federal control measures and the rateof-progress control measures and other attainment strategies implemented by states for 

the 8-hour ozone plan. This information is presented in Table 4-9 and Table 4-10. 

Maryland point source emissions include quasi- point source emissions from Andrews 

Air Force Base, which are described in detail in the 2002 BY emissions inventory 

document. 

MWAQC Ozone SIP 4-15 May 23, 2007 
Table 4-11 

2009 Projected Controlled VOC Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb,d

Point 5.33 8.72 0.25 14.31

Areac

86.01 75.52 17.57 179.10

Non-road 45.47 36.39 6.80 88.66

Mobile 31.64 28.15 6.88 66.68

Totald

168.45 148.78 31.51 348.56

Notes: 

a Maryland point source emissions include 1.00 tpd of quasi- point source emissions from Andrews AFB. b

 Regional total includes a reduction of 0.19 tpd from Voluntary Measures Bundle. c The controlled area source emissions for the District do not include reductions from the OTC VOC 

measures. The District's OTC VOC rules on all the 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 

additional enhancements to the air quality improvement in the region. d

 Small discrepancies may result due to rounding

Table 4-12 

2009 Projected Controlled NOx Emissions (tons/day) 

Washington, DC-MD-VA Ozone Nonattainment Area 

Emission 

Source 

Marylanda Virginia District of 

Columbia 

Totalb,c

Point 72.18 38.42 2.43 113.03

Area 7.17 17.96 2.26 27.39

Non-road 29.28 37.03 8.79 75.10

Mobile 70.94 61.44 14.16 146.53

Totalc

179.56 154.85 27.64 361.75

Notes: 

a Maryland point source emissions include 2.25 tpd of quasi- point source emissions from Andrews AFB. b

 Regional total includes a reduction of 0.3 tpd from Voluntary Measures Bundle. c

 Small discrepancies may result due to rounding

MWAQC Ozone SIP 4-16 May 23, 2007 
MWAQC 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 standard. The Metropolitan Washington, DC-MD-VA region 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 has 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 currently 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 equal to the target levels set for the end of the 

RFP period, or “milestone year”. For the RFP period 2002-2008, the “target inventories” of 

emissions are the maximum quantity of anthropogenic emissions permissible during the 2008 

milestone year. 

This section describes the methodology used to establish the regional target inventories and 

controlled inventories for 2008. Because the expected 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 standard. This requirement is generically referred to as the RFP 

requirement, and, was also called rate-of-progress (ROP). But under 40 CFR 51.900, “rate-ofprogress” refers to the progress required towards attaining the 1-hour ozone standard, and 

“reasonable further progress (RFP)” progress required towards attaining 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 progress 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 restrictions on the use of control measures to 

meet the 15% requirements. Reductions in ozone precursors resulting from four types of federal 
MWAQC 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 (FMVCP) 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 correcting inspection and maintenance (I/M) programs 

for on-road vehicles. 

The basic procedures of developing 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 Washington 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 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 15% from 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 Further 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 specifically to the Metropolitan Washington region 

is described in the EPA’s 8-hour ozone implementation guidance document.1

 Methodology 

specific to the Metropolitan Washington region, for calculating emissions target levels for the 

purpose of demonstrating RFP, is described in details in the EPA document’s Appendix A to the 

preamble of the final implementation 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 levels 
MWAQC Ozone SIP May 23, 2007 

 

5-3

of VOC and NOx emissions. Washington region has not chosen to substitute NOx for VOC 

reductions for complying with its reasonable further progress requirements 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 Ozone National Ambient Air Quality Standard – 

Phase II mandates that to meet the reasonable further progress requirement, the Washington, 

DC-MD-VA 8-hour ozone nonattainment area needs 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 reasonable 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 calculating 2008 target levels. Since the region has 

chosen to demonstrate the 2008 reasonable further 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 inventory of actual anthropogenic and biogenic VOC 

emissions on a typical weekday during peak ozone season. The inventory was calculated as 

described in Chapter 3 and is presented in Table 3-1. The reasonable further progress base-year 

inventory includes only anthropogenic emissions generated within the Metropolitan Washington 

nonattainment area. As the 2002 base-year inventory included no emissions generated outside 

the Metropolitan Washington area, the only difference between the base year inventory and the 

reasonable further progress base year inventory 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 emission baseline that excludes the effects of the noncreditable Federal Motor Vehicle Control Program (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 emissions reductions, which occur during the period 

2002-2008, the following two mobile inventories are needed: 

1) 2002 Reasonable Further Progress Adjusted-Year Inventory 

2) 2008 Reasonable Further Progress Adjusted-Year Inventory 

Both of these mobile inventories were created using the same inputs (listed 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 according 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 included 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 occur in absence of any post-1990 CAA measures 

during a reasonable further progress period can be determined by taking the difference between 

the RFP adjusted-year inventories for the relevant milestone years. For VOC and NOx, the 

relevant milestone years are 2002 and 2008. 

Non-creditable Emissions Reductions = 2002 RFP Adjusted Year Inventory – 2008 RFP Adjusted Year Inventory 

[Eq. 5-3] 

Calculation of non-creditable emissions reductions is shown in Table 5-4 below: 
MWAQC Ozone SIP May 23, 2007 

 

5-6

Table 5-4 

Calculation of Non-creditable 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 for 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 nonattainment area during 2008. The inventories were 

developed as described in Chapter 4 and are displayed 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 Washington 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 Emissionsa,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 include reductions from the OTC VOC 

measures. The District's OTC VOC rules on all the 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 additional enhancements to the air quality improvement 

in the region. 

5.4 Reasonable Further Progress Contingency Emissions Reduction Requirements 

This section briefly discusses the procedures for calculating the 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 reduction 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 minimum VOC and maximum 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 Reductions 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 Year Emissions Inventory and the 1996 Target for 

the 15% Rate of Progress Plans” 

U.S. EPA, “Guidance on the Post-1996 Reasonable 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 reductions 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 progress (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, dated 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 measures presented in this Chapter are summarized in Table A. 

Ref No. Control Measure 2008 b 2009 c 2008 b 2009 c

MEASURES INCLUDED IN THE FUTURE CONTROLLED SCENARIO

6.1.2

State NOx RACT and Regional NOx Transport 

Requirement (RACT, NOx SIP Call, CAIR, HAA)

0.00 0.00 12.65 128.76

SUBTOTAL 0.00 0.00 12.65 128.76

6.2.11 Mobile Equipment Repair and Refinishing Rule 3.49 3.59 0 0

6.2.12 Portable Fuel Containers Rule: Phase I 7.34 9.30 0 0

6.2.13 Architectural and Industrial Maintenance Coatings Rule 10.62 10.82 0 0

6.2.14 Reformulated Consumer Products Rule: Phase I 6.23 6.34 0 0

6.2.15 Solvent Cleaning Operations Rule 2.91 2.99 0 0

6.2.16 Industrial Adhesives and Sealants Rule - 2.42 0

6.2.17 Portable Fuel Containers Rule: Phase II - 0.75 0

6.2.18 Reformulated Consumer Products Rule: Phase II 0.39 0.76 0 0

SUBTOTAL 30.98 36.97 0 0

6.3.1 EPA Non-Road Gasoline Engines Rule 42.44 11.68 14.76

6.3.2 EPA Non-Road Diesel Engines Rule

6.3.3 Emissions standards for spark ignition marine engines

6.3.4 Emissions standards for large spark ignition engines

6.3.5 Reformulated Gasoline (off-road)

6.3.6 Standards for Locomotive 0.05 0.06 2.54 2.74

SUBTOTAL 36.96 42.50 14.22 17.50

6.4.2 High-Tech Inspection/Maintenance (updated cutpoints)

6.4.4 National Low Emission Vehicle Program

6.4.5 Tier 2 Motor Vehicle Emission Standards

6.4.6 Heavy-Duty Diesel Engine Rule

6.4.7

Transportation Control Measures and Vehicle 

Technology, Fuel, or Maintenance Measures 0.19 0.18 0.49 0.45

SUBTOTAL 6.38 7.35 30.16 38.08

6.5 Voluntary Bundle 0.19 0.19 0.28 0.30

TOTAL REDUCTIONS 74.51 87.01 57.31 184.64

Notes:

0

0

b

 Reductions included in the 2008 Reasonable Further Progress demonstration, occurring between 2002 and 2008. c

 Reductions included in the attainment demonstration, occurring between 2002 and 2009.

NON-ROAD MEASURES

POINT SOURCE MEASURES

AREA SOURCE MEASURES(a)

6.19 7.17 29.67 37.63

36.91

tons/day tons/day

VOLUNTARY MEASURES (Multiple Source Sectors)

ON-ROAD MEASURES

a

 The Area Source reductions do not include the District of Columbia. The District's OTC VOC rules on all the 

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 additional enhancements to the air quality improvement in the region.

TABLE A

SUMMARY OF CONTROL STRATEGIES

VOC and NOx Benefits of Control Measures

(2002-2009)

VOC Reductions NOx Reductions

MWAQC Ozone SIP May 6-1 23, 2007 
6.1 POINT SOURCE MEASURES

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

This measure involves extending emission standards to point sources with the potential to emit in 

excess of 25 tons per year (tpy) of VOCs. 

Control Strategy

The Washington, D.C. metropolitan area, when designated as severe nonattainment for the 

1-hour ozone standard, was obligated under the CAAA to implement RACT for major sources 

(25 tpy) not covered by EPA's Control Technique Guidance (CTG) documents. Under the 15% 

VOC Reduction Plan, Virginia, Maryland, and the District of Columbia developed and 

implemented new regulations for point sources with the potential to emit between 25 and 50 tpy 

not already regulated or required to be regulated under the previous major source definition (50 

tpy). This control measure included two parts: extension of non-CTG RACT rules to point 

sources emitting over 25 tpy, and extension of other state regulations applicable to major 

sources. The latter reductions were found only in Maryland. 

As a moderate nonattainment area for the 8-hour ozone standard, "reasonably available" control 

technologies must be determined and implemented for industry sources with the potential to emit 

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 documents the cost per ton of the control method and 

the size of the source that can best benefit from the control based on cost and technological 

feasibility. A CTG can include add-on equipment as well as emissions limits. If a CTG is not 

issued for a category that contains a major source, the state must develop a RACT regulation for 

that category. 

Maryland’s RACT implementation involved three types of standards: 1) identification of major 

source categories and establishment of RACT for both major and non major sources in those 

categories; 2) RACT for categories that did not have major sources but together with all small 

sources were above major source threshold; and 3) specific RACT for sources that emitted more 

than 20 lbs of VOC per day. 

Source Type Affected 

This measure affects point sources with the potential to emit 25 tpy or more of VOCs. In 

Maryland, it affects both major and non major sources that together constitute emissions above 

25 tons per day, small sources that together emit greater than 25 tons and point sources that emit 

more than 20 lbs of VOCs per day. 

MWAQC Ozone SIP May 6-2 23, 2007 
Control Strategy

Point sources are regulated through a state permit process in Maryland, Virginia and D.C. The 

states were required to develop and implement new RACT regulations for all non-CTG point 

sources emitting more than 25 tpy, which had not been previously regulated. All three states 

have submitted or will submit to EPA a separate SIP revision addressing RACT SIP 

requirements. All three states recertified RACT for the point sources emitting more than 50 tpy 

in the region. 

Implementation

District of Columbia – Department of Environment 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental Quality 

Projected Reductions and Emission Benefit Calculations 

The benefits of requiring RACT to point sources with potential to emit 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 comply 

with RACT requirements. As such, there are no emission benefits of RACT recertification.

References

Staff engineers at the Virginia Department of Environmental Quality, the Maryland Department 

of the Environment, and the District of Columbia Department of Environment supplied reduction 

potential estimates. 

MWAQC Ozone SIP May 6-3 23, 2007 
6.1.2 NOx RACT and Regional NOx Transport Requirements (federal and state regulation)

This section documents credit for NOx emissions reductions attributable to federal and regional 

NOx requirements 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 emissions 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 RACT requirements created by D.C., Maryland and 

Virginia in response to §7511a (f). In the Washington DC region, NOx reduction controls must 

be applied to sources that have the potential to emit 25 tons per year or more of NOx. 

Maryland, Virginia, and the District of Columbia completed the requirements of RACT under 

the 1-hour ozone standard in the late 1990’s. EPA 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 requirements are 

being met. All three states have submitted or will submit to EPA a separate SIP revision 

addressing RACT SIP requirements. 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 emissions in the Northeast. The rules required large stationary 

sources to reduce summertime NOx emissions by approximately 65 percent from 1990 levels. 

The regulation also included provisions allowing sources to comply by trading “allowances.” 

This regulation required affected sources to reduce their emissions to meet these requirements 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 Columbia, to further reduce large point source NOx 

emissions to EPA identified state emission budget levels by 2007. State regulation adoption 

timelines notwithstanding the majority of the 22 SIP call states had these regulations in place by 

2003/2004. 

MWAQC Ozone SIP May 6-4 23, 2007 
Clean Air Interstate Rule (CAIR)

On May 12, 2005, the U.S. EPA promulgated the Clean Air Interstate Rule, which requires 

reductions in emissions of NOx and SO2 from large fossil fuel-fired electric generating units. 

The rule is set up in several phases with the first phase of NOx reductions to come by 2009. The 

rule sets up both an annual emissions budget and an ozone season emissions budget. The rule 

requires that units with nameplate capacity greater than 25 megawatts emit no more NOx than 

their allocations determined by the state either through emission controls or banking and trading. 

 

Virginia CAIR

Virginia has adopted state regulations codifying the requirements of the Clean Air Interstate 

Rule. Virginia's rules create an emissions cap based on the allowances allocated to the facility. 

The rules do not allow trading as a method of complying with the emissions cap. 

Maryland Healthy Air Act

In April of 2006 the Maryland General Assembly and Governor Ehrlich adopted the Healthy Air 

Act (HAA), a law that requires reductions in NOx, SO2, and Mercury emissions from

Maryland’s largest and oldest coal fired power plants. Maryland implements the HAA through 

regulation. The regulation requires reductions in NOx emissions from coal-fired electric 

generating units (excluding fluidized bed combustion units) starting in 2009. By 2009 Maryland 

expects an approximate 70 percent reduction in NOx emissions from these regulations when 

compared to 2002 emissions. To meet the requirements of Maryland’s regulations a company’s 

“system” (covered units owned by the same company) must meet a system-wide cap by 2009. 

Compliance cannot be achieved through the purchase of allowances under the HAA. 

District of Columbia CAIR

The District of Columbia is currently drafting its Clean Air Interstate Rule (CAIR). Its CAIR 

regulations do not allow trading of NOx allowances for achieving the reductions for the facilities 

within its jurisdiction. 

Summary

The point source NOx controls are a phased approach to controlling emissions of NOx from power 

plants and other large fuel combustion sources. The programs resulting in emission 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 for the District in Tables 6-5 and 6-6. Table 6-7 

summarizes emission 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 emission reductions for 2008 and 2009 were calculated using the 

emissions estimates consistent with annual allocations under the Healthy Air Act implementing 

regulation. The program does not allow trading of NOx allowances. The expected emissions 

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

In Virginia, the expected emission reductions for 2008 and 2009 from electric generating utilities 

were calculated using knowledge of historical NOx emission rates, adjusted by the expected 

control efficiencies achieved from various control devices that have been installed, or by 

estimating the amount of allowances the facility would receive under the Virginia CAIR rule. 

The expected emissions reductions are listed in Tables 6-3 and 6-4. 

In the District of Columbia, the expected emission reductions for 2008 and 2009 were calculated 

using the listed allowances within the Clean Air Interstate Rule. The expected emissions 

reductions are listed in Tables 6-5 and 6-6. 

See Appendix C for further point source documentation.

MWAQC Ozone SIP May 6-6 23, 2007 
Table 6-1 

2008 NOx Point Source Reductions for Maryland (tons per day) 

Reductions

Facility 

2008 

Uncontrolled 

Emissions RACT

NOx SIP 

Call 

Healthy 

Air Act 

Total 

Emission 

Red. 

Dickerson 25.613 0 0 0 0

Chalk Point 50.586 0 0 0 0

Morgantown 78.512 0 0 0 0

Total 2008 

Reductions 0 0 0 0

Table 6-2 

2009 NOx Point Source Reductions for Maryland (tons per day) 

Reductions

Facility 

2009 

Uncontrolled 

Emissions RACT

NOx SIP 

Call 

Healthy 

Air Acta

Total 

Emission 

Red. 

Dickerson 25.902 0 0 18.813 18.813

Chalk Point 50.525 0 0 34.836 34.836 

Morgantown 78.207 0 0 51.025 51.025

Total 2009 

Reductions 154.634 0 0 104.674 104.674 a

Healthy Air Act emission reduction estimates based on a regulation that imposes ozone season limits on the affected sources.

MWAQC Ozone SIP May 6-7 23, 2007 
Table 6-3 

2008 NOx Point Source Reductions for Virginia (tons per day) 

Reductions 

Tons/day 

Facility ID Facility 

Name 

2008 

Baseline 

Emissions

Tons/day NSR RACT

NOx 

SIP 

Call 

Total 

Emission 

Reductions 

Tons/day 

2008 

Estimated 

Emissions 

Tons/day 

51-153-0002 

70225 

Dominion 

Possum

Point Power 

Station 

16.217 3.435a 3.435 12.782

51-510-0003 

70228 

MirantPotomac 

River Power 

Plant 

20.158 4.194 4.194 15.964

51-153-0139 

72340 

Prince 

William

County 

Department 

of Public 

Works

0.115 0.01 0.01 0.105

7.639 28.851

Notes: 

a

70225 went through a PSD netting exercise resulting in a permit that required emission reductions of NOx. See permit 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 NSR RACT

NOx 

SIP 

Call 

CAIR 

Total 

Emission 

Reduced 

Tons/day 

2009 

Estimated 

Emissions

Tons/day 

51-153-0002 

70225 

Dominion 

Possum

Point Power 

Station 

16.240 3.435 0.937a 4.372(1) 11.868 

51-510-0003 

70228 

MirantPotomac 

River Power 

Plant 

20.415 4.194 10.402a 14.596 5.819(1)

51-153-0139 

72340 

Prince 

William

County 

Department 

of Public 

Works

0.115 0.01 0.01 0.105

18.978 17.792

Notes: 

a

Actual CAIR allocations have not yet been calculated by VA staff. These reductions and emission rates are estimates based on 

past heat input rates and the draft CAIR allocation analysis. 

MWAQC Ozone SIP May 6-8 23, 2007 
Table 6-5 

2008 NOx Point Source Reductions for the District of Columbia (tpd) 

Reductions

Facility 

2008 

Uncontrolled 

Emissions RACT

NOx SIP 

Call CAIR

Total 

Emission 

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 West & Central 

Heating 0.26 - 0.10 0 0.10

Georgetown Univ. 

Power Plant 0.08 - 0 0 0 

U.S. Soldiers Home 0.03 - 0 0 0 

Total 2008 

Reductions 0 5.02 0 5.02

Table 6-6 

2009 NOx Point Source Reductions for the District of Columbia (tpd) 

Reductions

Facility 

2009 

Uncontrolled 

Emissions RACT

NOx SIP 

Call CAIR

Total 

Emission 

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 West & Central 

Heating 0.27 - 0.11 0 0.11

Georgetown Univ. 

Power Plant 0.08 - 0 0 0 

U.S. Soldiers Home 0.03 - 0 0 0 

Total 2009 Reductions 0 2.18 2.95 5.13 

The CAIR reductions reflect the allotted allowances for the District of Columbia (85% of 112 tons per season). 

MWAQC Ozone SIP May 6-9 23, 2007 
 

Table 6-7 

Point Source NOx Reductions Summary (tons per day) 

Control 

District of 

Columbia Maryland Virginia Total

2008 

NSR 0 0 3.435 3.435

NOx RACT 0 0 0.01 0.01 

NOx SIP Call 5.02 0 4.194 9.214 

CAIR 0 0 0 0

Healthy Air Act 0 0 0 0 

Total 2008 Reductions 5.02 0 7.639 12.65

2009 

NSR 0 0 3.435 3.435 

NOx RACT 0 0 0.01 0.01 

NOx SIP Call 2.18 0 4.194 6.374 

CAIR 2.95 0 11.36 14.31 

Healthy Air Act 0 104.674 0 104.674 

Total 2009 Reductions 5.13 104.674 18.978 128.76

MWAQC Ozone SIP May 6-10 23, 2007 
Implementation 

District Department of the Environment 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental 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 emission reductions associated with the state NOx requirements on point sources were 

supplied by the staffs of the Maryland Air and Radiation Management Administration, the 

District Department of the Environment, and the Virginia Department of Environmental Quality 

Air Division. 

References

1990 Clean Air Act Amendments, 42 U.S.C. §§7511a (f), (b)(2), and (c). 

Federal Register Vol. 70, No. 91, May 12, 2005, p. 25162. 

MWAQC Ozone SIP May 6-11 23, 2007 
6.2 AREA SOURCE MEASURES 

6.2.1 Reformulated Surface Coatings (federal rule)

This measure 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 maintenance, special industrial, and highway markings 

surface coatings sold and used in the Washington, D.C. ozone nonattainment area. This rule was 

adopted on September 11, 1998 (63 FR 48819), corrected on June 30, 1999 (64 FR 34997) and 

amended on February 16, 2000 (65 FR 7736). Compliance was required by September 13, 1999, 

or March 10, 2000. 

Source Type Affected

This measure affects makers of architectural, industrial maintenance, special industrial, and 

highway markings surface coatings. 

Control Strategy

The measure is based on the national regulatory negotiation for AIM coatings. According to 

EPA guidance, the final rule yields a 20 percent reduction in VOC emissions from AIM coating 

sources. This estimate includes consideration of rule effectiveness and rule penetration. 

Reductions for AIM coatings are achievable through product reformulations, product 

substitution, and consumer education. Reformulations include altering the components of the 

coating 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 volume 

applied. Product substitution is accomplished by replacing higher-VOC coatings with currently 

available lower-VOC coatings. Consumer education will provide information on the relative 

cost of lower-VOC coatings and encourage careful, efficient use of such products. 

 

Implementation

This program is implemented 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 Compound Emission Standards for Architectural, Preamble Section 

IV.A.1 (63 FR 48819), September 11, 1998. 

MWAQC Ozone SIP May 6-12 23, 2007 
U.S. Environmental Protection Agency, "Credit for the 15% rate-of-progress Plans for 

Reductions from Architectural and Industrial Maintenance Coating Rule ", Memorandum

from John S. Seitz, Director, to directors of Air Divisions of EPA Regional Offices, March 

22, 1995. 

U.S. Environmental Protection Agency, "Credit for the 15% rate-of-progress Plans for 

Reductions from Architectural and Industrial Maintenance Coating Rule and the Autobody 

Refinishing Rule", Memorandum from John S. Seitz, Director, to directors of Air Divisions 

of EPA Regional Offices, November 21, 1994. 

Meeting the 15-Percent Rate-of-Progress Requirement Under the Clean Air Act: A Menu of 

Options, STAPPA/ALAPCO, September 1993. 

MWAQC Ozone SIP May 6-13 23, 2007 
6.2.2 Reformulated Consumer Products (federal rule) 

This measure required that certain consumer products sold in the Washington, D.C. ozone 

nonattainment area be reformulated to reduce their VOC content. The measure is based upon 

regulations that EPA was required to publish by November 15, 1995 under 42 U.S.C. 

7511b(e)(3). The final regulation was adopted on September 11, 1998 (63 FR 48848). 

Source Type Affected

The measure affects manufacturers of the various specialty chemicals that EPA selected, after 

conducting a study consistent with 42 U.S.C. 7511b(e)(2). 

Control Strategy

The measure relies upon federal implementation of a rule mandating reformulation of certain 

"consumer or commercial 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 November 15, 1995, regulations to require 

reformulation of one-fourth of the "consumer or commercial products" that are responsible for at 

least 80 percent of photochemically reactive VOC emissions from such products. 

EPA guidance from John Seitz specifies a 10 percent total reduction of emissions from a 

regulated subset of consumer products. EPA estimated the regulated subset to be approximately 

3.9 pounds per capita annually. Consequently, a total of 10 percent of the "commercial or 

consumer products" were expected to be subject to reformulation requirements by November 15, 

1999. EPA guidance also allows states to retain emission reduction estimates for consumer and 

commercial product reformulations in their 15% Plans. 

Implementation

This measure was federally implemented under a federal regulatory calendar initially issued in 60 

Federal Register 15264, finalized in 63 Federal Register 48791 and amended in 64 Federal Register 

13422 (March 18, 1999). This program is implemented 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 Compound Emission Standards for Consumer Products, Preamble 

Section III.A. (63 FR 48848), September 11, 1998. 

1990 Clean Air Act Amendments, 42 U.S.C. 7511b(e). 

U.S. Environmental Protection Agency, "Regulatory Schedule for Consumer and Commercial 

MWAQC Ozone SIP May 6-14 23, 2007 
 Products under Section 183 (e) of the Clean Air Act", Memorandum from John S. Seitz, 

 Director, to directors of Air Divisions of EPA Regional Offices, June 21, 1995. 

Commercial and Consumer Products: Schedule for Regulation (64 FR 13422), March 18, 1999. 

MWAQC Ozone SIP May 6-15 23, 2007 
6.2.3 Reformulation of Industrial Cleaning Solvents (federal rule) 

This measure required that certain industrial cleaning solvents sold in the Washington, D.C. 

ozone nonattainment area be reformulated to reduce their VOC content. The measure is based 

upon regulations that, under 42 U.S.C. 7511b(e)(3), EPA was required to publish by November 

15, 1995. The industrial cleaning solvent standards were adopted in 2001. 

Source Type Affected

The measure affects manufacturers of the various specialty chemicals that EPA will select, after 

conducting a study consistent with 42 U.S.C. § 7511b(e)(2). 

Control Strategy

The measure relies upon federal implementation of a rule mandating reformulation of certain 

"consumer or commercial products" (as that term is defined under 42 U.S.C. § 7511b(e)(1)(B)). 

Under § 7511b(e)(3), EPA must create by November 15, 1995, regulations to require 

reformulation of one-fourth of the "consumer or commercial products" that are responsible for at 

least 80 percent of photochemically reactive VOC emissions from such products. 

EPA guidance from John Seitz specifies a 10 percent total reduction of emissions from a 

regulated subset of consumer products. This is used as a benchmark for estimating reductions in 

industrial cleaning solvents. 

Implementation 

This program was implemented by the EPA in 2001 under a schedule adopted on March 18, 

1999. The program is implemented 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 Amendments, 42 U.S.C. 7511b(e). 

U.S. Environmental Protection Agency, "Regulatory Schedule for Consumer and Commercial 

 Products under Section 183 (e) of the Clean Air Act", Memorandum from John S. Seitz, 

 Director, to directors of Air Divisions of EPA Regional Offices, June 21, 1995. 

 

Federal Register Vol. 64 No. 52, Thursday, March 18, 1999 (AD FLR-6311-9) p. 13422 - 13424. 

MWAQC Ozone SIP May 6-16 23, 2007 
6.2.4 Surface Cleaning and Degreasing for Machinery and Automobiles Repair (state 

rule)

This measure amended regulations for surface cleaning (often called "cold cleaning and 

degreasing") devices and operations, to require more stringent emissions control techniques, and 

to require, where possible, the use of low- or no-VOC solvents. 

Source Type Affected

All cold cleaning and degreasing equipment and operations. 

Control Strategy

Maryland has regulations on cold cleaning and degreasing equipment and operations (COMAR 

26.11.19.09). The regulations require a decrease in vapor pressure of degreasing material for 

cold degreasers, installation of a condenser or air pollution control device, and good operating 

practices to minimize VOC losses. 

The District of Columbia and Virginia have adopted regulations on cold cleaning and degreasing 

equipment and operations. Credit is taken for two types of control measures. (1) The first 

measure proposes the following equipment controls: solvent tank evaporation controls, carry-out 

emission controls, and enclosure/add-on controls; and the following operational controls: proper 

equipment use, and reduced disturbance of solvent-air interface. (2) The second measure will 

require the use, where feasible, of alternative solvents. 

Implementation

District of Columbia - Department of Environment 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental 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. 

MWAQC Ozone SIP May 6-17 23, 2007 
6.2.5 Landfill Regulations (state rule)

Landfills emit gases as a result of decomposition of materials buried in them. While most of

these gases are methane, which is not photochemically reactive, landfills do contribute to VOC 

emissions, and, thus, ozone formation. A federal rule for the control of new landfills and 

guidelines for existing landfills was proposed under Section 111 of the Clean Air Act 

Amendments. 

Source Type Affected

Municipal landfills are those that receive primarily household and/or commercial waste. 

Control Strategy 

The 15% VOC Reduction Plan required adoption of the federal guidelines for municipal landfills 

(see 56 Federal Register 24468). The proposed guidelines require installation of gas collection 

systems followed by flares, to either destroy the VOCs or burn them for fuel. The rule requires 

capture and control systems to capture at least 80 percent of the VOC emissions and route them

to a 98% destruction efficiency control device. 

Implementation 

Federal standards for existing landfills were promulgated under Section 111 of the Clean Air Act 

Amendments. The following state agencies will have to independently adopt regulations 

consistent with the federal standards: 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental 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. Environmental 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. Environmental Protection Agency, Air Emissions from Municipal Solid Waste Landfills -

Background Information for Proposed Standards and Guidelines, EPA-450/3-90-011a, 

March 1991.

MWAQC Ozone SIP May 6-18 23, 2007 
 6.2.6 Seasonal Open Burning Restrictions (state rule)

This measure involves amending and/or adopting state regulations to ban the open burning of 

such items as trees, shrubs, and brush from land clearing, trimmings from landscaping, and 

household or business trash, during the peak ozone season. The measure is authorized by state 

regulations, but is enforced by the local governments. 

Source Type Affected

The measure affects all citizens and businesses that burn solid waste. 

Control Strategy

Under the 15% VOC Reduction Plan, Maryland and Virginia adopted state regulations to 

prohibit open burning during peak ozone season in the Washington, D.C. ozone nonattainment 

area. The emissions benefits will remain constant through 2009. 

Implementation

District of Columbia - Department of Environment. 

Maryland - Air and Radiation Management Administration; local government enforcement. 

Virginia - Department of Environmental Quality; local government enforcement. 

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, Emissions Inventory Development 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., December 8, 2003. Prepared for the County of Fairfax. 

MWAQC Ozone SIP May 6-19 23, 2007 
6.2.7 Stage I Vapor Recovery System Expansion (state rule)

This measure involves applying the federal Control Technique Guideline's "balanced 

submerged" underground storage tank refilling method at gas stations located in newly 

designated nonattainment counties. 

Source Type Affected

All filling of underground storage tanks not controlled were affected. 

Control Strategy

In the 15% VOC Reduction Plan, balanced submerged fill requirements were extended to 

Calvert, Charles and Frederick counties in Maryland and Stafford counties in Virginia. All other 

counties in the nonattainment area already were required to use balanced submerged fills. Note 

that Stafford County is not part of the Washington, DC-MD-VA 8-hour ozone nonattainment 

area. 

Implementation

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental 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 Department of the Environment, Air Management Administration, Stage I Vapor 

Recovery Inspection Program, (Beth Murray, September 30, 1991).

MWAQC Ozone SIP May 6-20 23, 2007 
6.2.8 Stage II Vapor Recovery (federal law)

As a serious ozone nonattainment area, Washington was required, under 42 U.S.C. § 7511a(b)(3) 

 and 7511a(c), to install stage II vapor recovery systems at gasoline pumps. 

Source Type Affected

This measure affects gasoline service stations with a throughput of at least 10,000 gallons per 

month and reduces vehicle refueling emissions. Refueling emissions are attributed to the 

evaporation of gasoline-rich vapors displaced from the storage tank during refueling. The 

system is composed of a nozzle covering the fill-pipe and a vapor line returning from the fillpipe to the storage tank. The stage II system captures the fuel rich vapors from the vehicle fillpipe and returns them to the storage tank. Returning saturated vapors to the storage tank reduces 

emissions by maintaining liquid/vapor equilibrium in the storage tank, thereby decreasing the 

evaporation potential. Recovered vapors are then collected by tanker trucks and returned to the 

terminal for recovery or destruction. 

Control Strategy

Stage II nozzles have been in place in the District of Columbia since 1977. Implementation of 

stage II is required in the Washington nonattainment regions of Maryland and Virginia by 

operation of the Clean Air Act Amendments of 1990, 42 U.S.C. § 7511a(b)(3) and 7511a(c). 

Those sections require adherence to a schedule of implementation, and set forth a standard for 

applicability (i.e., to stations of what size or what amount of gasoline sold per month). Maryland 

and Virginia adopted stage II regulations as a part of their November 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. Environmental Protection Agency, Technical Guidance -- Stage II Vapor Recovery Systems for 

Control of Vehicle Refueling Emissions at Gasoline Dispersing Facilities, Volume 1, EPA450/3-91-022a, November 1991. 

1990 Base Year Emissions Inventory for Stationary, Anthropogenic, Biogenic Sources and Highway 

Vehicle Emissions of Ozone Precursors in the Washington, DC-MD-VA Metropolitan 

Statistical Nonattainment Area, Prepared for The District of Columbia, Maryland, and 

Virginia by the Metropolitan Washington Council of Governments, September 22, 1993. 

MWAQC Ozone SIP May 6-21 23, 2007 
6.2.9 Graphic Arts Controls (state rule/CTG)

Controls for offset lithography have been adopted as a new CTG. These controls apply to small 

printers and sources. VOCs are emitted from the inks used for printing, fountain solutions, and 

from the solvents used to clean the printing equipment. 

Source Type Affected

This regulation affects small printers not currently regulated under RACT measures. 

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 measures based on the draft CTG, which included the 

following controls: 

Emission Source Recommended Control

Inks 90% control (condenser filters) for heatset plants

Fountain Solution 1.6% isopropyl alcohol (IPA) for heatset plants (90% 

reduction) 

alcohol substitution for non-heatset (99 % reduction) 

5% IPA for sheet-fed (50% reduction)

Cleaning Solutions 30% VOC content limit (70% reduction) 

Implementation

District of Columbia - Department of Environment 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental 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. Environmental Protection Agency, Control Techniques Guideline for Offset Lithographic 

Printing, Draft, December 14, 1992.

MWAQC Ozone SIP May 6-22 23, 2007 
6.2.10 Auto Body Refinishing (state rule/CTG)

EPA has crafted a national rule for emissions from auto body refinishing. The rule requires 

reformulated 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, primer coats, finish coats, and sealer/clear coats. 

Control Strategy

The 15% VOC Reduction Plan contained a measure that required reduced-solvent coatings for 

precoats, primer surfaces, primer sealers, and topcoats. The measure also required the use of 

spray gun cleaners that recycle solvents, and the use of high-volume, low- pressure application 

equipment. 

Implementation

EPA adopted a National Rule for Autobody Refinishing on August 14, 1998. 

Maryland - Air and Radiation Management Administration 

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. Environmental Protection Agency, Chemicals and Petroleum Branch, Research Triangle Park, 

North Carolina, Automobile Refinishing Control Techniques Guideline, Final 

EPA Reference Docket Number A-95-18 

Maryland Department of the Environment, Air and Radiation Management Administration, 

Baltimore, Maryland, Summary and Economic Impact of New Regulation .23 under COMAR 

26.11.19, Control of VOC Emissions from Vehicle Refinishing (October 18, 1994)

MWAQC Ozone SIP May 6-23 23, 2007 
6.2.11 Mobile Repair and Refinishing Rule (state rule/OTC model rule) 

This rule establishes VOC limits for paints using in mobile repair and refinishing. The VOC 

limits are consistent with federal limits for mobile equipment refinishing materials. The rule also 

requires improved transfer efficiency application equipment, enclosed spray gun cleaning, and 

minimal training. 

Source Type Affected

All manufacturers of paints used in mobile repair and refinishing and operators of mobile repair 

and refinishing facilities. 

Control Strategy

Virginia adopted the Ozone Transport Commission (OTC) Model Rule for Mobile Repair and 

Refinishing in November 2003. This rule became effective in the District of Columbia in 

February 2004. The rule applies to all counties in the nonattainment area. The State of Maryland 

had rules in place by 1996 that contain limits comparable to the OTC model rule. 

Implementation

District of Columbia - Department of Environment 

Virginia - Department of Environmental 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 emission reduction factor of 38 percent, based on Pechan 

(2001). 

References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport 

Commission Model Rules”, March 31, 2001.

MWAQC Ozone SIP May 6-24 23, 2007 
6.2.12 Portable Fuel Containers Rule: Phase I (state rule/OTC model rule) 

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

standards are intended to reduce emissions from storage, transport and refueling activities. The 

rule also included administrative and labeling requirements. Compliant containers must have: 

only one opening for both pouring and filling, an automatic shut-off to prevent overfill, an 

automatic sealing mechanism when not dispensing fuel and specified fuel flow rates, permeation 

rates and warranties. 

Source Type Affected

Any person or entity selling, supplying or manufacturing portable fuel containers, except 

containers with a capacity of less than or equal to one quart, rapid refueling devices with 

capacities greater than or equal to four gallons, safety cans and portable marine fuel tanks 

operating with outboard motors, and products resulting in cumulative VOC emissions below 

those of a representative container or spout. 

Control Strategy 

Maryland adopted phase I of the Ozone Transport Commission (OTC) Model Rule for Portable 

Fuel Containers in January 2002. 

Virginia adopted phase I of the Ozone Transport Commission (OTC) Model Rule for Portable 

Fuel Containers on November 2003. 

The rule was adopted in the District of Columbia in April 2004. 

The rule applies to all counties in the nonattainment area. 

Reductions from this rule increase annually beginning with implementation in the State of 

Maryland on January 1, 2004. 

The District of Columbia and the Commonwealth of Virginia required compliance with this rule 

as of January 1, 2005. 

Implementation 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental Quality 

District of Columbia - Department of Environment 

MWAQC Ozone SIP May 6-25 23, 2007 
Projected Reductions

Reductions are shown under phase II of the Portable Fuel Container Rule. 

Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 75 percent after full 

implementation after 10 years. Implementation began in 2004 in Maryland and 2005 in the 

District and Virginia. In 2008, the emission reduction factor is 25 -32.5 percent. In 2009, the 

emission reduction factor is 32.5 - 40 percent. 

References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport 

Commission Model Rules”, March 31, 2001. 

MWAQC Ozone SIP May 6-26 23, 2007 
6.2.13 Architectural and Industrial Maintenance Coatings Rule (state rule/OTC model rule) 

This rule requires manufacturers to reformulate various types of coatings to meet VOC content 

limits. Affected products include architectural coatings, traffic markings, high-performance 

maintenance coatings and other special-purpose coatings. It uses more stringent VOC content 

limits than the existing Federal consumer products rule. 

Source Type Affected

The measure affects all manufacturers of affected coatings. 

Control Strategy

Virginia adopted the Ozone Transport Commission (OTC) Model Rule for Architectural and 

Industrial Maintenance Coatings in November 2003. 

Maryland adopted this rule on March 29, 2004. 

The rule became effective in the District of Columbia in April 2004. 

The rule will apply to all counties in the nonattainment area. 

The VOC content limits in this rule are based on a Suggested Control Measure (SCM) adopted 

by the California Air Resources Board (CARB) and a State and Territorial Air Pollution Program

Administrators/Association of Local Air Pollution Officials (STAPPA/ALAPCO) model rule or 

OTC coatings. Manufacturers are expected to comply with this rule using primarily EPA Test 

Method 24. 

Implementation

District of Columbia - Department of Environment 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental Quality 

MWAQC Ozone SIP May 6-27 23, 2007 
Projected 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 applicable area source categories are or will be fully adopted, 

submitted to EPA, and federally enforceable measures. However, the emission reductions 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 additional enhancements to the air quality improvement in the region.

Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 31 percent, based on Pechan 

(2001). 

References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport 

Commission Model Rules”, March 31, 2001.

MWAQC Ozone SIP May 6-28 23, 2007 
6.2.14 Consumer Products Rule: Phase I (state rule/Ozone Transport Commission (OTC) 

model rule) 

 

Phase I of the Consumer Products Rule required reformulation of approximately 80 types of 

consumer products to reduce their VOC content. It uses more stringent VOC content limits than 

the existing Federal consumer products rule. The rule also contains requirements for labeling and 

reporting. 

Source Type Affected

Manufacturers of various specialty chemicals named in the rule, such as aerosol adhesives, floor 

wax strippers, dry cleaning fluids and general purpose cleaners. 

Control Strategy

Phase I of the Ozone Transport Commission (OTC) Model Rule for Reformulated Consumer 

Products became effective in the District of Columbia in April 2004. 

The State of Maryland adopted phase I of the Ozone Transport Commission (OTC) Model Rule 

for Reformulated Consumer Products on August 18, 2003. 

The Commonwealth of Virginia adopted phase I of the Ozone Transport Commission (OTC) 

Model Rule for Reformulated Consumer Products on March 9, 2005. 

Manufacturers are expected to demonstrate compliance with the rule primarily through a 

California Air Resources Board (CARB) test method. If complying with the VOC contents 

becomes difficult, flexibility options are provided. 

Implementation

Maryland - Air and Radiation Management Administration 

District of Columbia - Department of Environment 

Virginia - Department of Environmental Quality 

MWAQC Ozone SIP May 6-29 23, 2007 
Projected Reductions 

Reductions are shown under phase II of the Consumer Products Rule. 

Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 14.2 percent, based on Pechan 

(2001). 

References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport 

Commission Model Rules”, March 31, 2001.

MWAQC Ozone SIP May 6-30 23, 2007 
6.2.15 Solvent Cleaning Operations Rule (state rule/ Ozone Transport Commission (OTC) 

model rule) 

This rule establishes hardware and operating requirements and alternative compliance options 

for vapor cleaning machines used to clean metal parts. These machines are used in 

manufacturing operations to clean grease, wax, oil and other contaminants from parts when a 

high level or cleanliness is necessary. The rule also affects cold cleaners, which are used in 

automobile and maintenance facilities and industrial maintenance shops. 

Source Type Affected

Manufacturers and operators of vapor cleaning or cold cleaning machines 

Control Strategy

Virginia adopted the Ozone Transport Commission (OTC) Model Rule for Solvent Cleaning 

Operations in November 2003. The rule applies to all counties in the nonattainment area. 

The rule became effective in the District of Columbia in April 2004. 

The State of Maryland had rules in place by 1996 that contain limits comparable to the OTC 

model rule. Therefore the OTC model rule was not needed in Maryland as a state rule was 

already in place. 

Standards for vapor cleaning machines are based on Federal Maximum Available Control 

Technology (MACT) standards for chlorinated solvent vapor degreasers. Cold cleaner solvent 

volatility provisions are based on regulatory programs in place in several states, primarily 

Maryland and Illinois. 

Implementation

District of Columbia - Department of Environment 

Virginia - Department of Environmental 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 applicable area source categories are or will be fully adopted, 

submitted to EPA, and federally enforceable measures. However, the emission reductions arising from these 

MWAQC Ozone SIP May 6-31 23, 2007 
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 additional enhancements to the air quality improvement in the region.

Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 66 percent, based on Pechan 

(2001). 

References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport 

Commission Model Rules”, March 31, 2001.

MWAQC Ozone SIP May 6-32 23, 2007 
6.2.16 Industrial Adhesives and Sealants Rule (state rule/ Ozone Transport Commission 

(OTC) model rule) 

This rule establishes VOC content limitations for industrial and commercial application of 

solvent-based adhesives and sealants. Controls will cover adhesives, sealants, adhesive primers, 

sealer primers, adhesive application to substrates, and aerosol adhesives. VOC content limits are 

similar to those contained in the CARB Reasonably Available Control Technology (RACT) or 

Best Available Control Technology (BACT) document 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 Columbia no later than May 1, 

2008 and for Virginia no later than May 1, 2009. 

Implementation

District of Columbia - Department of Environment 

Virginia - Department of Environmental Quality 

Maryland - Air and Radiation Management Administration 

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 applicable area source categories are or will be fully adopted, 

submitted to EPA, and federally enforceable measures. However, the emission reductions 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 additional enhancements to the air quality improvement in the region.

MWAQC Ozone SIP May 6-33 23, 2007 
Emission Benefit Calculations

Emission reductions are based on a 64 percent reduction in emissions of VOC from the baseline. 

Further details are available from OTC (2007). 

References

OTC 2007. Identification and Evaluation of Candidate Control Measures: Final Technical Support 

Document. Prepared by MACTEC Federal Programs, Inc., Herndon, Virginia for the Ozone 

Transport Commission. February 28, 2007. 

MWAQC Ozone SIP May 6-34 23, 2007 
6.2.17 Portable Fuel Containers Rule: Phase II (state rule/ Ozone Transport Commission 

(OTC) model rule) 

This measure expands existing performance standards for portable gasoline containers and 

spouts to kerosene containers. The standards are intended to reduce emissions from storage, 

transport and refueling activities. The rule also included administrative and labeling 

requirements. Compliant containers must have: only one opening for both pouring and filling, an 

automatic shut-off to prevent overfill, an automatic sealing mechanism when not dispensing fuel 

and specified fuel flow rates, permeation rates and warranties. 

Source Type Affected

Any person or entity selling, supplying or manufacturing portable fuel containers, except 

containers with a capacity of less than or equal to one quart, rapid refueling devices with 

capacities greater than or equal to four gallons, safety cans and portable marine fuel tanks 

operating with outboard motors, and products resulting in cumulative VOC emissions 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 nonattainment area. 

Implementation 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental Quality 

District of Columbia - Department of Environment 

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 

Includes reductions from Phase I and Phase II.

Note: The District's OTC VOC rules on all the applicable area source categories are or will be fully adopted, 

submitted to EPA, and federally enforceable measures. However, the emission reductions 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 additional enhancements to the air quality improvement in the region.

MWAQC Ozone SIP May 6-35 23, 2007 
Emission Benefit Calculations

Phase I: Projected reductions are based on an emission reduction factor of 75 percent after full 

implementation after 10 years. Implementation began in 2004 in Maryland and 2005 in the 

District and Virginia. In 2008, the emission reduction factor is 25 -32.5 percent. In 2009, the 

emission reduction factor is 32.5 - 40 percent. 

Phase II: Emission reductions are based on a 4 percent reduction in emissions of VOC. Further 

details are available from OTC (2007). 

References

OTC 2007. Identification and Evaluation of Candidate Control Measures: Final Technical Support 

Document. Prepared by MACTEC Federal Programs, Inc., Herndon, Virginia for the Ozone 

Transport Commission. February 28, 2007. 

MWAQC Ozone SIP May 6-36 23, 2007 
6.2.18 Consumer Products Rule: Phase II (state rule/ Ozone Transport Commission (OTC) 

model rule) 

Phase II of the Consumer Products Rule involves adopting the CARB 7/20/05 Amendments 

which sets new or revises existing limits on 13 consumer product categories. It uses more 

stringent VOC content limits than the existing federal consumer products rule. The rule also 

contains requirements for labeling and reporting. 

Source Type Affected

Manufacturers of various specialty chemicals named in the rule, such as aerosol adhesives, floor 

wax strippers, dry cleaning fluids and general purpose cleaners. 

Control Strategy

All jurisdictions plan to adopt phase II of the OTC Model Rule for Reformulated Consumer 

Products in 2007. The rule will be effective in Maryland and the District of Columbia no later 

than May 1, 2008 and for Virginia no later than May 1, 2009. 

Manufacturers are expected to demonstrate compliance with the rule primarily through a 

California Air Resources Board (CARB) test method. If complying with the VOC contents 

becomes difficult, flexibility options are provided. 

Implementation

Maryland - Air and Radiation Management Administration 

District of Columbia - Department of Environment 

Virginia - Department of Environmental 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 applicable area source categories are or will be fully adopted, 

submitted to EPA, and federally enforceable measures. However, the emission reductions 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 additional enhancements to the air quality improvement in the region.

MWAQC Ozone SIP May 6-37 23, 2007 
Emission Benefit Calculations

Phase I: Projected reductions are based on an emission reduction factor of 14.2 percent, based 

on Pechan (2001). 

Phase II: Emission reductions are based on a 2 percent reduction in emissions of VOC. Further 

details are available from OTC (2007). 

References

OTC 2007. Identification and Evaluation of Candidate Control Measures: Final Technical Support 

Document. Prepared by MACTEC Federal Programs, Inc., Herndon, Virginia for the Ozone 

Transport Commission. February 28, 2007. 

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport 

Commission Model Rules”, March 31, 2001.

MWAQC Ozone SIP May 6-38 23, 2007 
6.3 NON-ROAD MEASURES 

The following non-road emission reduction measures that are discussed in this section are 

calculated using the NONROAD2005 emission factor model: 

• EPA Non-road Gasoline Engines Rule, 6.3.1 

• EPA Non-road Diesel Engines Rule, 6.3.2 

• Emissions Standards For Spark Ignition Marine Engines, 6.3.3 

• Emissions Standards for Large Spark Ignition Engines, 6.3.4 

• Reformulated Gasoline for Off-Road Applications, 6.3.5 

• Emission Standards for Locomotives, 6.3.6, are calculated using the Area Source 

spreadsheet but emission benefits are included in the nonroad sector totals. 

Projected Reductions and Emission Benefit Calculations

Past SIP documents for the Washington region have presented the emission reductions from each 

of the above measures individually, and then summed the reductions to create a controlled on 

road inventory for each milestone year. NONROAD2005, the current non-road emissions 

model approved for use by the EPA, is not designed to calculate the benefits of each of the above 

control measures individually. As a result, this and future SIP revisions will not enumerate the 

benefits of individual non-road control measures. The table below summarizes the combined 

benefits from the above control measures 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 

MWAQC Ozone SIP May 6-39 23, 2007 
6.3.1 Phase I and Phase II Emissions Standards for Gasoline-Powered Non-Road Utility 

Engines (federal rule) 

This measure takes credit for VOC emissions reductions attributable to emissions standards 

promulgated by the EPA for small non-road, spark-ignition (i.e., gasoline-powered) utility 

engines, as authorized under 42 U.S.C. §7547. The measure affects gasoline-powered (or other 

spark-ignition) lawn and garden equipment, construction equipm.ent, chain saws, and other such 

utility equipment as chippers and stump 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 equipment. 

Control Strategy

Federal emissions standards promulgated under §7547 (a) apply to spark-ignition non-road 

utility engines. The EPA's Phase 1 Spark Ignition Nonroad final rule on such emissions 

standards was published in 60 Federal Register 34581 (July 3, 1995), and was effective 

beginning August 2, 1995. Compliance was required by the 1997 model year. The Phase 2 final 

rule for handheld nonroad equipment was published in 65 Federal Register 24267 (April 25, 

2000). The Phase 2 final rule for non-handheld equipment was published in 64 Federal Register

15207 (March 30, 1999). 

Implementation

This program is implemented by the EPA, under 42 U.S.C. §7547 (a). 

MWAQC Ozone SIP May 6-40 23, 2007 
References

EPA Guidance Memorandum, "Future Nonroad Emission Reduction Credits for Court-Ordered 

Nonroad Standards" from Emission Planning and Strategies Division, Memorandum from

Phil Lorang, Director, Emission Planning and Strategies Division, November 28, 1994. 

U.S. Environmental Protection Agency, "Emission Standards for New Nonroad Spark-Ignition 

 Engines at or Below 19 Kilowatts", Final Rule, 60 Federal Register 34581 (July 3, 1995). 

U.S. Environmental Protection Agency, “Phase 2 Emission 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. Environmental Protection Agency, “Phase 2 Emission Standards for New Nonroad SparkIgnition Handheld Engines at or Below 19 Kilowatts”, Final Rule, 65 Federal Register 24267 

(April 25, 2000) 

1990 Clean Air Act Amendments, 42 U.S.C. §7547 (a). 

MWAQC Ozone SIP May 6-41 23, 2007 
6.3.2 Emissions Standards for Diesel-Powered Non-Road Utility Engines of 50 or More 

Horsepower (federal rule) 

This measure takes credit for NOx emissions reductions attributable to emissions standards 

promulgated by the EPA for non-road, compression-ignition (i.e., diesel-powered) utility 

engines, as authorized under 42 U.S.C. § 7547. The measure affects diesel-powered (or other 

compression-ignition) construction equipment, industrial equipment, etc., rated at or above 37 

kilowatts (37 kilowatts is approximately equal to 50 horsepower). 

Control Strategy 

Federal emissions standards applicable to compression-ignition non-road utility engines are 

promulgated under §7547 (a). 

EPA's first rule on such emissions standards was published in 59 Federal Register 31306 (June 

17, 1994), and was effective on July 18, 1994. 

Tier 2 and Tier 3 Emission 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 marine engines in this size range. It also phases in more stringent "Tier 2" emission 

standards from 2001 to 2006 for all engine sizes and adds yet more stringent "Tier 3" standards 

for engines between 37 and 560 kW (50 and 750 hp) from 2006 to 2008. 

EPA adopted a comprehensive national program to greatly reduce emissions from future nonroad 

diesel engines by integrating engine and fuel controls as a system to gain the greatest air quality 

benefits. This rule was published June 29, 2004. The requirement to reduce sulfur levels in 

nonroad diesel fuel by more than 99 percent will allow for the first time advanced emission 

control systems to be used on the engines used in construction, agricultural, industrial, and 

airport service equipment. 

Implementation

This program is implemented by the EPA under 42 U.S.C. § 7547 (a). 

References

1990 Clean Air Act Amendments, 42 U.S.C. §7547 (a). 

U.S. Environmental Protection Agency, "Control of Emissions of Air Pollution from Nonroad 

Diesel Engines; Final Rule." 63 Federal Register 56967, October 23, 1998. 

U.S. Environmental Protection Agency, "Control of Emissions of Air Pollution 

from Nonroad Diesel Engines and Fuel; Final Rule." 69 Federal Register Vol. 69, No. 124, June 

29, 2004 

MWAQC Ozone SIP May 6-42 23, 2007 
EPA Guidance Memorandum, "Future Nonroad Emission Reduction Credits for Court-Ordered 

Nonroad Standards" from Emission Planning and Strategies Division, Memorandum from

Phil Lorang, Director, Emission Planning and Strategies Division, November 28, 1994. 

U.S. Environmental Protection Agency," Determination of Significance for Nonroad Sources and 

Emission Standards for New Nonroad Compression-Ignition Engines at or Above 37 

Kilowatts", Final Rule, 59 Federal Register 31306 (June 17, 1994). 

MWAQC Ozone SIP May 6-43 23, 2007 
6.3.3 Emissions Standards for Spark Ignition (SI) Marine Engines (federal rule) 

This EPA measure controls exhaust VOC emissions from new spark-ignition (SI) gasoline 

marine engines, including outboard engines, personal watercraft engines, and jet boat engines. 

Of nonroad sources studied by EPA, gasoline marine engines were found to be one of the largest 

contributors of hydrocarbon (HC) emissions (30 percent of the nationwide nonroad total). 

Control Strategy 

EPA is imposing emission standards for 2 – stroke 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 model year 1998. By the end of the phase-in, each manufacturer must meet 

an HC and NOx emission standard that represents a 75 percent reduction in HC compared to 

unregulated levels. These standards do not apply to any currently owned engines or boats. 

Implementation

This program is implemented by the EPA under 42 U.S.C. § 7547 (a). 

References

1990 Clean Air Act Amendments, 42 U.S.C. §7547 (a). 

U.S. Environmental Protection Agency, "Control of Air Pollution; Final Rule for New Gasoline 

Spark-Ignition Marine Engines; Exemptions for New Nonroad Compression-Ignition Engines at 

or Above 37 Kilowatts and New Nonroad Spark-Ignition Engines at or Below 19 Kilowatts", 61 

Federal Register 52087, October 4, 1996.

Regulatory Impact Analysis "Control of Air Pollution Emission Standards for New Nonroad 

 Spark-Ignition Marine Engines", U.S. EPA, June 1996 

MWAQC Ozone SIP May 6-44 23, 2007 
6.3.4 Emissions Standards for Large Spark Ignition Engines (federal rule) 

This EPA measure controls VOC and NOx emissions from several groups of previously 

unregulated nonroad engines, including large industrial spark-ignition engines. 

Control Strategy 

The EPA requirements vary depending upon the type of engine or vehicle, taking into account 

environmental impacts, usage rates, the need for high performance models, costs and other 

factors. The emission standards apply to all new engines sold in the United States and any 

imported engines manufactured 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 commercial applications; most 

use liquefied petroleum gas, with others operating on gasoline or natural gas. 

EPA adopted two tiers of emission standards for Large SI engines. The first tier of standards, 

which started in 2004, are based on a simple laboratory measurement using steady-state 

procedures. The Tier 1 standards are the same as those adopted earlier by the California Air 

Resources Board for engines used in California. Tier 2 standards became effective in 2007.

Implementation

This program is implemented by the EPA under 42 U.S.C. § 7547 (a). 

References

1990 Clean Air Act Amendments, 42 U.S.C. §7547 (a). 

U.S. Environmental Protection Agency, "Control of Emissions from Nonroad Large SparkIgnition Engines, and Recreational Engines (Marine and Land-Based)," Final Rule, 67 

Federal Register 68241 (November 8, 2002). 

U.S. Environmental Protection Agency, Final Regulatory Support Document: Control of 

Emissions from Unregulated Nonroad Engines,” EPA420-R-02-022, September 2002. 

MWAQC Ozone SIP May 6-45 23, 2007 
6.3.5 Reformulated Gasoline Use in Non-Road Motor Vehicles and Equipment (state optin to federal rule)

This measure involves taking credit for reductions due to the use of federally reformulated 

gasoline in non-road mobile sources. Reformulated gasoline is available as a result of Virginia's, 

Maryland's, and the District of Columbia's "opting-in" on delivery of reformulated gasoline in 

the Washington, D.C. ozone nonattainment area. Areas that opted-in on delivery of reformulated 

gasoline began receiving such gasoline beginning in 1995. 

Source Types Affected

This measure affects the various non-road mobile sources that burn gasoline. 

Control Strategy 

Federal reformulated gasoline has been sold in the Washington, DC-MD-VA ozone 

nonattainment area since January 1, 1995. 

Implementation

District of Columbia - Implemented by EPA via mayor's formal request to opt-in to federal 

program. 

Maryland - Implemented by EPA via governor's formal request to opt-in to federal program. 

Virginia - Implemented by EPA via governor's formal request to opt-in to federal program. 

References

U.S. Environmental Protection Agency, "Regulation of Fuels and Fuel Additives: Standards for 

Reformulated Gasoline", Proposed Rule, 58 Federal Register 11722, February 26, 1993. 

"VOC Emission Benefits for Non-Road Equipment with the Use of Federal Phase I Reformulated 

Gasoline", memorandum from Phil Lorang, U.S. EPA Office of Mobile Sources to Air Directors, 

EPA Regions 1-10, August 18, 1993. 

MWAQC Ozone SIP May 6-46 23, 2007 
6.3.6 Standards for Locomotives (federal rule) 

This sets NOx standards for locomotive engines remanufactured and manufactured after 2001. 

Source Type Affected

This program includes all locomotives originally manufactured from 2002 through 2004. It also 

applies to the remanufacture of all engines built since 1973. Regulation of the remanufacturing 

process is critical because locomotives are generally remanufactured 5 to 10 times during their 

total service lives, which are typically 40 years or more. 

Control Strategy

Three separate sets of emissions standards have been adopted, with the applicability of the 

standards dependent on the date a locomotive is first manufactured. The first set of standards 

(Tier 0) applies to locomotives and locomotive engines originally manufactured from 1973 

through 2001, any time they are manufactured or remanufactured. The second set of standards 

(Tier 1) apply to locomotives and locomotive engines originally manufactured from 2002 

through 2004. These locomotives are required to meet the Tier 1 standards at the time of 

manufacture and at each subsequent remanufacture. The final set of standards (Tier 2) apply to 

locomotives and locomotive engines originally manufactured in 2005 and later. Electric 

locomotives, historic steam-powered locomotives and locomotives manufactured before 1973 do 

not significantly contribute to the emissions problem and, therefore, are not included in the 

regulation. 

Implementation

This program is implemented by the EPA under the Final Emissions Standards for Locomotives 

(EPA420-F-97-048) published in December 1997. 

MWAQC Ozone SIP May 6-47 23, 2007 
Projected 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 Area Source spreasheet but are presented in the overall 

nonroad sector totals. 

Emission Benefit Calculations

Emission benefits are based on EPA guidance on emission factors for locomotives. 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, December 1997. 

Emission Factors for Locomotives, EPA420-F-97-051, December 1997, Table 9. 

MWAQC Ozone SIP May 6-48 23, 2007 
6.4 ON-ROAD MEASURES 

The following onroad emission reduction measures that are discussed in this section are calculated 

using the MOBILE6 emission factor model: 

• Controls on Refueling Emissions and Reformulated Gasoline for On-road Applications, 

6.4.1 

• Enhanced I/M, 6.4.2 

• Federal Tier 1 Vehicle Standards, 6.4.3 

• National Low Emission Vehicle Standards, 6.4.4 

• Federal Tier 2 Vehicle Standards, 6.4.5 

• Heavy Duty Diesel Engine Rule, 6.4.6

Projected Reductions and Emission Benefit Calculations

Past SIP documents for the Washington region have presented the emission reductions from each 

of the above measures individually, and then summed the reductions to create a controlled on 

road inventory for each milestone year. MOBILE5b, the mobile emissions model used in 

previous SIPs, was designed to calculate the benefits of each of the above control measures 

individually. In the update to MOBILE6, changes were made to the model, creating synergistic 

effects between the six mobile control measures listed above. These effects do not lend 

themselves to isolating credit from one control program, and make it very difficult to calculate 

incremental benefits from implementation of individual control measures. As a result, this and 

future SIP revisions will not enumerate the benefits of individual mobile control measures, with 

the exception of the transportation control measures (TCMs) and vehicle technology, fuel, and 

maintenance-based measures, which are quantified outside of the MOBILE6 model. The table 

below summarizes the combined benefits from the above control measures by jurisdiction. See 

Appendix E1 for documentation of the MOBILE 6 modeling 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 

MWAQC Ozone SIP May 6-49 23, 2007 
6.4.1 Phase II Volatility Controls of Refueling Emissions and Reformulated Gasoline Use 

in On-road Vehicles (federal regulation)

This measure takes credit for lower refueling emissions resulting from the effects of federally 

mandated reductions in gasoline volatility, as required under 42 U.S.C. §§7545 (h) and (k). The 

measure affects emissions from all gasoline vehicles. In 2005, the measure requires the use of 

federal reformulated gasoline in the Washington nonattainment area. This is accomplished 

through an opt-in to the federal program, which subsequently became mandatory as a result of 

designation as severe ozone nonattainment. 

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 documented under Section 6.4.2) 

are affected by this measure. Vehicle refueling emissions at service stations are also reduced. 

Control Strategy

Federal reformulated gasoline has been sold in the Washington, DC-MD-VA ozone 

nonattainment area since January 1, 1995. The volatility reductions under §7545 (h) became 

effective in summer 1992. Further volatility reductions required under §7545 (k) are associated 

with the reformulated gasoline that began selling in the Washington nonattainment area on 

January 1, 1995. 

Implementation

The volatility controls of refueling emissions program was implemented by the EPA under 42 

U.S.C. §§7545 (h) and (k). Implementation of the RFG program occurs through a state "opt-in" 

process. The governors of Maryland and Virginia and the mayor of the District of Columbia 

have "opted in" for, and EPA has approved, delivery of reformulated gasoline in their respective 

portions of the Washington, DC-MD-VA ozone nonattainment area. Under Phase I of the RFG 

program, all gasoline sold in the nonattainment area on or after January 1, 1995, must be 

reformulated gasoline. Phase II of the RFG program became effective after January 1, 2000. 

The program became mandatory for the Washington region one year after designation as Severe 

nonattainment, which occurred on March 23, 2004. 

References

1990 Clean Air Act Amendments, 42 U.S.C. §§7545 (h) and (k). 

U.S. Environmental Protection Agency, Office of Mobile Sources, User's Guide to MOBILE6.0, 

Chapter 2, January 2002.

MWAQC Ozone SIP May 6-50 23, 2007 
6.4.2 Enhanced Vehicle Emissions Inspection and Maintenance (Enhanced I/M) (federal 

regulation)

This measure involves requiring a regional vehicle emissions inspection and maintenance (I/M) 

program with requirements stricter than "basic" programs, as required under 42 U.S.C. § 

7511a(c)(3) and 7521. Before 1994, "basic" automobile emissions testing checked only tailpipe 

emissions while idling and sometimes at 2,500 rpm. The new procedures include a 

dynamometer (treadmill) test that checks the car's emissions under driving conditions. In 

addition, evaporative emissions and the on-board diagnostic computer are checked. 

Source Type Affected

This measure affects light-duty gasoline and diesel vehicles and trucks. 

Control Strategy

Maryland, the District of Columbia, and Virginia committed to EPA Performance Standard 

Enhanced I/M programs in the 15% VOC Emissions Reduction Plan. Each affected vehicle in 

the region is given a high-tech emissions test every two years. In Maryland and the District of 

Columbia, emissions tests are performed at test-only stations. Virginia tests vehicles in stations 

that may also perform repairs using a decentralized program. 

Implementation

District of Columbia - Department of Public Works, Dept. of Consumer and Regulatory Affairs 

Maryland - Motor Vehicles Administration 

Virginia - Department of Environmental Quality 

Appendix E1 contains detailed information regarding implementation of I/M programs in the 

District, Maryland, and Virginia.

References

U.S. Environmental Protection Agency, "Inspection/ Maintenance Program Requirements," Final 

 Rule, 57 Federal Register 52950 (November 5, 1992). 

U.S. Environmental Protection Agency, "I/M Costs, Benefits, and Impacts Analysis," Draft, 

 February 1992. 

MWAQC Ozone SIP May 6-51 23, 2007 
6.4.3 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 motor vehicle emission 

standards (Tier I standards), which were phased in beginning with model 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 implemented programs affected light-duty vehicles and light-duty trucks (LDT). 

Control Strategy

The Federal Motor Vehicle Control Program requires more stringent exhaust emission standards 

as well as a uniform level of evaporative emission controls, demonstrated through the new 

federal evaporative test procedures. Under 42 U.S.C. §7521(g), all post-1995 model year cars 

must achieve the Tier I (or Phase I) exhaust standards, which are as follows. Emissions are in 

grams per mile, and are related to durability timeframes of 5 yrs/50,000 miles and 10 

yrs/100,000 miles. 

Vehicle Type 5 yrs/50,000 mi 10 yrs/100,000 mi

VOCs CO NOx VOCs CO NOx

Light-duty vehicles; 

light-duty trucks (loaded weight 3,750 lbs) 

0.25 3.4 0.4* 0.31 4.2 0.6*

Light-duty trucks 

(loaded weight of 3,751 to 5,750 lbs) 

0.32 4.4 0.7** 0.40 5.5 0.97

*For diesel-fueled light-duty vehicles and for LDTs at 3,750 lbs, before model year 2004, the applicable NOx standards 

shall be 1.0 at 5 yrs/50,000 mi and 1.25 at 10 yrs/100,000. 

**This NOx standard does not apply to diesel-fueled trucks of 3,751 to 5,750 lbs.

Implementation

This program is implemented by the EPA under 42 U.S.C. §7521. 

References

U.S. Environmental Protection Agency, Office of Mobile Sources, User's Guide to MOBILE5, 

Chapter 2, March 1993. 

MWAQC Ozone SIP May 6-52 23, 2007 
6.4.4 National Low Emission Vehicle Program (federal regulation) 

Under the National Low-Emission Vehicle (LEV) program, auto manufacturers have agreed to 

comply with tailpipe standards that are more stringent than EPA can mandate prior to model year 

(MY) 2004. Once manufacturers committed to the program, the standards became enforceable in 

the same manner that other federal motor vehicle emissions control requirements are 

enforceable. The program went into effect throughout the Ozone Transport Region (OTR), 

including Maryland, Virginia, and the District of Columbia, in model year 1999 and was in place 

nationwide in model 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 implemented programs affect light-duty vehicles and trucks. 

Control Strategy

The National Low Emission Vehicle Program requires more stringent exhaust emission 

standards than the Federal Motor Vehicle Control Program Tier I (or Phase I) exhaust standards. 

Implementation

This program is implemented by the EPA, under 40 CFR Part 86 Subpart R. Nine states within 

the OTR, including the MWAQC states, have opted-in to the program as have all the auto 

manufacturers. EPA found the program to be in effect on March 2, 1998. 

References

U.S. Environmental Protection Agency, Office of Mobile Sources, User's Guide to MOBILE5, 

Chapter 2, March 1993. 

MWAQC Ozone SIP May 6-53 23, 2007 
6.4.5 Tier 2 Motor Vehicle Emission Regulations (federal regulation) 

The U.S. EPA promulgated a rule on February 10, 2000 requiring more stringent tailpipe 

emissions standards for all passenger vehicles, including sport utility vehicles (SUVs), minivans, 

vans and pick-up trucks. These regulations also require lower levels of sulfur in gasoline, which 

will ensure the effectiveness of low emission-control technologies in vehicles and reduce 

harmful air pollution. 

Source Type Affected 

These federally implemented programs 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 before the rule was promulgated and will reduce the sulfur content of gasoline by 

up to 90 percent. The new tailpipe standards are set at an average standard of 0.07 grams per 

mile 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 less than 6000 pounds are being phasedin to this standard between 2004 and 2007. 

Beginning in 2004, the refiners and importers of gasoline have the flexibility to manufacture 

gasoline with a range of sulfur levels as long as all of their production is capped at 300 parts per 

million (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 met a 30 ppm average sulfur level with a maximum cap of 80 ppm. 

As newer, cleaner cars enter the national fleet, the new tailpipe standards will significantly 

reduce emissions of nitrogen oxides from vehicles by about 74 percent by 2030. 

Implementation 

EPA implements this program under 40 CFR Parts 80, 85, and 86. 

References 

U.S. Environmental Protection Agency, “Control of Air Pollution from New Motor Vehicles: Tier 2 

Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements,” Final Rule, 

65 Federal Register 6697, February 10, 2000. 

MWAQC Ozone SIP May 6-54 23, 2007 
6.4.6 Heavy-Duty Diesel Engine Rule (federal regulation) 

Under the Heavy-Duty Diesel Engine Rule, truck manufacturers must comply with more 

stringent tailpipe standards by 2004 and 2007. The standards are enforceable in the same

manner that other federal motor vehicle emissions control requirements are enforceable. 

Source Type Affected

These federally implemented programs affect heavy-duty diesel engines used in trucks. 

Control Strategy

The Heavy-Duty Diesel Engine Rule requires more stringent exhaust emission standards. 

Implementation

This program is implemented by the EPA, under 40 CFR Parts 9 and 86 Control of Emissions of 

Air Pollution From Highway Heavy-Duty Engines; Final Rule. 

References

U.S. Environmental Protection Agency, Office of Mobile Sources, User's Guide to MOBILE5, 

Chapter 2, March 1993. 

40 CFR Parts 9 and 86 Control of Emissions of Air Pollution from Highway Heavy-Duty 

Engines; Final Rule (62 FR 54694), October 21, 1997. 

 

MWAQC Ozone SIP May 6-55 23, 2007 
6.4.7 Transportation Control Measures (TCMs) and Vehicle Technology, 

Fuel, and Maintenance-based Measures (state and local program)

Section 108(f) of the Clean Air Act Amendments provides examples of TCMs that can be 

implemented to reduce emissions from mobile sources. Most TCMs are designed to reduce 

vehicle miles traveled or vehicle trips or improve the flow of traffic. 

In conjunction with state departments of transportation and local transit authorities, state air 

agencies have identified a number of projects designed to reduce vehicle travel and mitigate 

traffic congestion in the Metropolitan Washington nonattainment area. These measures include 

purchase of alternative-fueled vehicles, improvements to bicycle and pedestrian facilities, and 

improvements to transit services and access to transit facilities. All responsible agencies have 

committed to implementing these projects by January 1, 2005. 

Additional information on TCMs is contained in Appendix F. 

Source Type Affected

Transportation-related activities in the Metropolitan Washington nonattainment area

Implementation

District of Columbia – Department of Transportation 

Maryland - Department of Transportation 

Virginia - Department of Transportation 

Washington Metropolitan Area Transit Authority 

Northern Virginia Local Governments 

MWAQC Ozone SIP May 6-56 23, 2007 
Projected 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 Technology, Maintenance, and Fuel-based Measures for 

the Washington Metropolitan Area Transit Administration (WMATA). Emission reduction estimates 

were supplied by the District of Columbia Department of Transportation, the Maryland Department of 

Transportation, the Virginia Department of Transportation. See Appendix F for details. 

MWAQC Ozone SIP May 6-57 23, 2007 
6.5 Voluntary Bundle 

In September 2004, EPA issued its policy on “Incorporating Emerging and Voluntary Measures 

in a State Implementation Plan (SIP).”1

 This policy establishes criteria for EPA to approve 

credit under a SIP for emission reductions from voluntary and emerging measures. This policy 

permits states to develop and implement innovative programs that partner with local 

jurisdictions, businesses and private citizens to implement emission-reducing measures at the 

local level. 

In August 2005, EPA issued a second guidance document to facilitate innovative control 

measures. This document was entitled “Guidance on Incorporating Bundled Measures in a State 

Implementation Plan.”2

 The guidance supports the development of innovative measures by 

describing how States can develop individual voluntary and emerging measures and “bundle” 

them into a single SIP submission. The emissions reductions for each measure in the bundle are 

quantified but it is the performance of the entire bundle (the sum of the emission reductions from

all the measures in the bundle) that is measured by EPA for SIP compliance purposes. The 

bundled measures policy takes into account the fact that some measures may perform less 

effectively than projected by allowing the State to average these measures with others that 

perform better than expected. Agencies must implement each voluntary control measure, and 

states must monitor each measure for effectiveness and report the findings to EPA. If the 

estimated reductions are not achieved, states commit to take corrective action by either making 

changes to the existing program or developing more effective control measures. 

 

This SIP proposes a set of measures for the voluntary bundle that includes emission reductions 

measures included in the bundle for the 1-hour ozone SIP and several new programs proposed 

herein. All of the voluntary measures have been implemented after the 2002 SIP base year. The 

1-hour ozone SIP bundle commitments were modified. Diesel retrofit and low-emission vehicle 

purchases are no longer included in the bundle and are being used for weight of evidence or as 

Transportation Emission Reduction Measures (TERMs). In addition, one of the programs 

included in the SIP voluntary bundle for the 1-hour ozone standard (Low-VOC Consumer 

Products in Virginia) has been adopted as a mandatory measure and therefore, it is no longer 

included as part of the voluntary bundle. 

 

The bundled measures will reduce emissions daily through the ozone season in May through 

September. The measures will be implemented by county, city and state agencies in consultation 

with the District of Columbia, the State of Maryland or the Commonwealth of Virginia. The 

emission reductions credited in this plan are below EPA's presumptive limits for voluntary 

initiatives. 

 

Some of the programs identified in the voluntary measures package for Reasonable Further 

Progress (RFP) will be fully implemented by May 1, 2008 – the beginning of the 2008 ozone 

season – even though most reductions will occur by January 2008, the date on which the region 

will achieve rate of progress. Full implementation of all other measures will begin in 2009. 

 

1 See http://www.epa.gov/cleanenergy/stateandlocal/guidance.htm 2

 Ibid. 

MWAQC Ozone SIP May 6-58 23, 2007 
Some of the programs identified in the voluntary measures package for Reasonable Further 

Progress (RFP) will be fully implemented by May 1, 2008 – the beginning of the 2008 ozone 

season – even though most reductions will occur by January 2008, the date on which the region 

will achieve rate of progress. Full implementation of all other measures will begin in 2009. 

This voluntary measures package may be expanded in future SIPs as additional voluntary 

measures are developed and implemented. Many state agencies and local governments are 

currently developing programs that could, in the future, qualify as voluntary measures. 

This section contains descriptions of the voluntary measures that are included in this SIP 

submission. A detailed estimate of the benefits resulting from each measure is contained in 

Appendix H. The information below summarizes the emission reductions for the entire 

voluntary bundle. Individual measures contained in the bundle are described on succeeding 

pages. 

Source Type Affected

This bundle reflects commitments by owners, operators, purchasers or users of the following 

types of emissions-related items/equipment in the Metropolitan Washington area: commercial 

power generation, portable fuel containers, municipal buildings, urban forest trees, locomotives, 

solvents, and paints. 

Implementation

Arlington County, Virginia 

Calvert County, Maryland 

City of Alexandria, Virginia 

City of Falls Church, Virginia 

City of Greenbelt, Maryland 

Fairfax City, Virginia 

Fairfax County, Virginia 

Loudoun County, Virginia 

Maryland Department of Transportation 

Maryland National Capital Parks and Planning Commission 

Montgomery County, Maryland 

Prince George’s County, Maryland 

Prince William County, Virginia 

Virginia Department of Environmental Quality 

Washington Surburban Sanitary Commission, Maryland 

Monitoring and Enforcement 

The District of Columbia, the State of Maryland, and the Commonwealth of Virginia commit to 

monitoring, evaluation and reporting of the emissions effects of the programs comprising the 

voluntary measures. All governments and agencies that have committed to implementing 

MWAQC Ozone SIP May 6-59 23, 2007 
voluntary measures have been informed of the monitoring and evaluation requirement and have 

agreed to provide monitoring information to the state air agencies. 

The District of Columbia, Maryland, and Virginia will evaluate the emission benefits from this 

voluntary measures 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 completed by June 2010, three years from the submittal of this SIP 

revision. Should the evaluation program determine that the measures listed in this section have 

not delivered the estimated reductions, the states commit to remedy the resulting deficiency 

within one year if rulemaking is not required, or within two years if rulemaking is required. If 

the June 2010 true-up shows emissions benefits lower than expected, the states will remedy the 

deficiency by June 2011 if the remedy does not require rulemaking, or by June 2012 if 

rulemaking is required. 

Projected Reductions 

The District of Columbia, the State of Maryland, and the Commonwealth of Virginia have used 

available methods to create their best estimate of the emission benefits created from the bundle 

of voluntary measures. These estimates have been agreed upon by the implementing agencies 

and are conservative in nature. The summary of the estimates and the methodology follows 

below. More detailed information about the methodologies is provided in Appendix H. 

Table 6-8. Summary of Emission Reductions for Voluntary Bundle Commitments (2002-2009)

Jurisdiction

Emission 

Reduction for 

2008 (tpd VOC)

Emission 

Reduction for

2009 (tpd VOC)

Emission 

Reduction for

2008 (tpd NOx)

Emission 

Reduction for

2009 (tpd NOx)

Regional Wind Power Purchase Program 0 0 0.13 0.15

Renewable Portfolio Standards 0 0 - -

LED Traffic Signal Retrofits 0 0 0.02 0.02

VRE Idling Reduction 0.01 0.01 0.13 0.13

Low-VOC Paint 0.17 0.17 0 0

Gas Can Replacement 0.01 0.01 0 0

TOTAL 0.19 0.19 0.28 0.30

Note: Includes cumulative impacts of commitments made in the 1-hour and 8-hour ozone SIPs.

MWAQC Ozone SIP May 6-60 23, 2007 
Point Source Strategies 

Renewable Energy and Energy Efficiency 

The following energy efficiency and renewable energy measures are included as innovative 

voluntary control measures in the SIP. 

• Renewable Energy Programs 

- Regional Wind Power Purchase Program

- Clean Energy Rewards Program

- Renewable Portfolio Standards 

• Energy Efficiency Programs 

- LED Traffic Signal Retrofit Program

- Building Energy Efficiency Programs 

• Green Building Programs 

Emission Reduction Calculations and Projected Reductions 

In recent years, substantial progress has been made in the development of methodologies to 

quantify emission reduction benefits from energy efficiency and renewable energy (EERE) 

measures. Several methods have been used to calculate the benefits resulting from the 

displacement of fossil fuel generation in the dispatch order. The methodology outlined below 

was developed by Resource Systems Group, Inc. (RSG) in cooperation with Environmental 

Resources Trust (ERT). 

The State of Maryland relied on an initial version of the RSG/ERT methodology in its regional 

wind purchase submission as part of the bundle of voluntary measures submitted to EPA in its 1-

hour ozone SIP. This SIP control measure was subsequently cited with approval by the EPA in 

its August 2004 “Guidance on State Implementation Plan (SIP) Credits for Emission Reductions 

from Electric-sector Energy Efficiency and Renewable Energy Measures.”3

 EPA also approved 

the wind purchase as the first-ever renewable energy measure to receive NOx emissions 

reduction credit in a State Implementation Plan.4

 

Udated versions of the RSG methodology have been subsequently used in three separate projects 

to estimate the displacement of emissions at fossil-fueled power plants resulting from EERE 

measures in New Jersey, Connecticut, and Virginia. Most of this work has been supported by 

the U.S. Department of Energy.5

 The New Jersey work was conducted in cooperation with the 

U.S. Environmental Protection Agency and 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 Department 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.html; Resource Systems 

Group, Estimation of Avoided Emission Rates for Nitrogen Oxide Resulting from Renewable Electric Power 

Generation in the New England, New York and PJM Interconnection Power Market Areas, 2006, Prepared under 

grant funding from the U.S. Department of Energy and under subcontract to Environmental Resources Trust and 

Connecticut Smart Power; Resource Systems Group, Avoided Emissions at Three Proposed Wind Power Projects in 

Virginia, 2006, Prepared under grant funding from the U.S. DOE’s Clean Energy/Air Quality Integration Initiative. 

MWAQC Ozone SIP May 6-61 23, 2007 
Each state is including provisions in their NOx Ozone Season emissions trading program that 

will set aside a portion of the state’s ozone season NOx allowance budget to support renewable 

energy and energy efficiency projects. Each state will assure that NOx allowances are retired in 

an amount commensurate with the size of the six EERE measures cited below to ensure surplus 

emission reductions. 

The SIP measures will be structured to take into account the differences in the NOx emissions 

trading regulations of Maryland, the District of Columbia, 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 the District of Columbia and Virginia do not 

provide such authority. Thus, emission reductions from EERE projects will not be claimed for 

Virginia government entities in 2007 and 2008. 

However, in 2009, NOx emissions trading for electric generating units in all three states will be 

governed by the Clean Air Interstate Rule (CAIR), and all three governments are including 

provisions in their CAIR setting aside a portion of allowances in their summer ozone season 

trading budget to support EERE projects and purchases. The Virginia Air Pollution Control 

Board approved the VA CAIR on December 6, 2006, and Maryland and the District of Columbia 

plan to adopt their regulations to implement CAIR in 2007. As a result, surplus emission 

reductions from all three jurisdictions can be claimed for 2009. 

 

Table 6-9. Summary of Benefits EERE Programs 

Measure Daily kWh Generation 

/Savings 

2009 NOx 

Emission 

Reduction (tpd) 

Renewable Energy Programs 

 Regional Wind 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 Programs 

 LED Traffic Signal Retrofit Program 26,905,556 0.02 

 Building Energy Efficiency Programs ~15,000,000 - 

Green Building Programs - - 

TOTAL ~150,000,000 0.17

Note: Total does not include the Clean Energy Rewards, RPS, or the Building Energy Efficiency Programs. 

MWAQC Ozone SIP May 6-62 23, 2007 
Regional Wind Power Purchase Program 

Under this measure, local and State government entities in the nonattainment area have 

committed to purchase a specific number of kilowatt-hours (kWh) of power during the summer 

ozone season from wind turbines. The government 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 electric grid. This zero-emission wind power will 

displace emissions from fossil-fueled power plants that would normally supply power to the 

Metropolitan Washington region. The air agencies in Maryland, the District of Columbia, and 

Virginia will retire NOx allowances in an amount commensurate with the amount of emissions 

displaced. 

Source Type Affected 

The measure affects certain local and State government entities within the Metropolitan 

Washington nonattainment area. The region is implementing this measure to reduce electric 

power generation from coal, oil, and/or gas-fired sources, thereby reducing NOx emissions from

these sources. 

Control Strategy 

This measure is envisioned as a region-wide measure encompassing purchases of wind power or 

wind energy RECs by state and local government entities within the Metropolitan Washington 

nonattainment area. 

This program was initiated on a pilot basis in the 1-hour ozone SIP and has been expanded here. 

To meet the existing commitments from the 1-hour ozone SIP, local governments signed multiyear commitments with wind power suppliers to assure that a fixed 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 emitted from those plants. 

Implementation 

Arlington County, Virginia 

Fairfax County, Virginia 

Prince William County, Virginia 

Montgomery County, Maryland 

Members of the Montgomery County buying group (see list below) 

Prince George's County 

Washington Suburban Sanitary Commission (WSSC) 

District of Columbia 

 

6 Renewable energy certificates represent the unique and exclusive proof that 1 Megawatt-hour of energy was 

generated from a renewable energy source and placed on the electric grid. 

MWAQC Ozone SIP May 6-63 23, 2007 
In Fiscal Years (FY) 2005 and 2006, a buying group led by Montgomery County, Maryland 

purchased 40,845,139 kilowatt-hours (kWh) of wind energy RECs per fiscal year. The purchase 

represented 5% of the total annual electricity consumption of each purchasing group participant. 

 Montgomery County executed a contract amendment on September 18, 2006 to purchase 

additional kWhs of clean, renewable energy in compliance with SIP requirements (RECs for 

energy were generated at the Mountaineer Wind Energy Center in West Virginia) for FY07 and 

FY08 (July 1, 2006 to June 30, 2008). In the new contract, the County, and many other members 

of the buying group opted to increase their wind energy purchase to 10% of their total annual 

electricity consumption, for a total of 51,809,091 kWh of clean energy purchased by the group in 

FY07, and 57,481,122 kWh in FY08. Credit for 28,000,000 kWH per year was taken in the onehour ozone SIP, leaving 23,809,091 kWh in FY07 and 29,481,122 kWh 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 following other counties, cities, and state agencies will participate in the Montgomery 

County buying group: 

Montgomery County Public Schools (MCPS) 

Montgomery County Government 

Maryland National Capital Park and Planning Commissions (M-NCPPC) 

Montgomery College 

Housing Opportunities Commission (HOC) 

City of Rockville 

Gaithersburg 

Takoma Park 

College Park 

Rockville Housing Enterprise 

Town of Kensington 

Chevy Chase Village 

Somerset 

Glenn Echo 

Chevy Chase Sect. 5 

Town of Laytonsville 

In addition, the Virginia Energy Purchasing Governmental Association (VEPGA) issued an RFP 

in March 2007 to select a supplier of wind energy RECs in the amount of at least 11,230,000 

kWh/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 William County. 

The District of Columbia plans to purchase 16,500 kWh/year from wind energy or wind energy 

RECs. There is the possibility that this purchase can be used by utilities to meet RPS 

requirements so is not analyzed further here. 

All three RFPs will include: 

 

MWAQC Ozone SIP May 6-64 23, 2007 
• A reporting requirement indicating the actual amount of wind energy in kWh purchased 

during the ozone season and per year. In addition, the request for proposal issued for the 

Virginia municipalities will contain a requirement that the purchase of wind energy RECs 

be made from wind plants in the PJM Interconnection grid in one or more of the following 

States: Maryland, Virginia, Pennsylvania, West Virginia, or Ohio. Based on EPA’s 

analysis of ozone transport data set forth in the preamble to the EPA’s CAIR (70 Fed. 

Reg. 25249-50), these five States are considered upwind of one or more counties in the 

DC-MD-VA nonattainment area. The RFPs for the MD jurisdictions will require that the 

purchase of wind energy RECs be made from wind plants in States contiguous to 

Maryland. 

• A reporting requirement indicating actual amount of wind energy in kWh purchased 

during the ozone season and per year. 

Monitoring and Enforcement 

Each State will provide evidence that it has assured the retirement of the designated amount of 

NOx allowances from future use under a NOx emissions trading program. In addition, all 

jurisdictions and agencies participating in the regional wind power purchase program have 

committed to maintain copies of signed contracts and energy bills to verify the amount 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 emission 

reduction credit included in the SIP. 

Projected Reductions 

The renewable energy purchase program is expected to involve purchase 104,000 MWh of 

power or wind energy RECs annually, reducing 0.15 tpd NOx during the 2009 ozone season. 

Further information on the projected reductions is included in Appendix H. 

 

Table 6-10. Wind Purchase Commitments for the 8-hour Ozone SIP Voluntary Bundle (all in kWh/year)

Jurisdiction

1-hour Ozone SIP 

Commitment for 

2005 

8-hour Ozone SIP 

Commitment for 

2008

8-hour Ozone SIP

Commitment for

2009

2005 Emission

Reduction 

Credited in 1-

hour Ozone SIP

(tpd NOx)

2008 

Emission 

Avoided 

(tpd NOx)

2009 

Emission 

Avoided 

(tpd NOx)

Montgomery County, MD Purchasing Group (existing) 28,000,000 28,000,000 28,000,000

Montgomery County, MD Purchasing Group (new) 14,740,561

Prince George's County, MD 8,423,095 8,423,095

Washington Suburban Sanitary Commission (WSSC) 70,000,000 70,000,000

Arlington County, VA 2,340,000 4,700,000 4,700,000

Fairfax County, VA 5,800,000 11,600,000

Prince William County, VA 750,000 750,000

Total 104,413,656 123,473,095 0.05 0.13 0.15

Notes:

All emission reductions are for ozone season only and are estimated using the emissions calculator in Appendix H.

Montgomery County FY 2008 new commitments only through June 30, 2008. Commitment does not extend to 2009.

Because NOx SIP Call regulations in Virginia don't have NOx allowance retirement provisions for 2008, the 2008 NOx Emission Avoided do not include 0.1 tpd from Virginia commitments.

MWAQC Ozone SIP May 6-65 23, 2007 
Clean Energy Rewards Program 

Under this measure, Montgomery County Government will provide rewards (incentives) to 

residents, small businesses, and community organizations purchasing clean energy products 

certified by the Department of Environmental Protection (DEP). The authority for this program

is granted in the Montgomery County Code Section 18A-11, as amended, and Executive 

Regulation No. 2-06AM. Based on the program’s funding of $361,000 for FY 2007, 

Montgomery County has estimated that its Clean Energy Rewards Program will provide 

incentives for 31,900 MWh of clean energy. 

Source Type Affected 

The measure affects Montgomery County residents, small businesses, congregations, and nonprofits, and is supported by Montgomery County Government, within the Metropolitan 

Washington nonattainment area. Montgomery County is implementing this measure to reduce 

consumption of electric power generated from coal, oil, and/or natural gas fired sources by 

consumers, thereby reducing NOx emissions from these sources. 

Control Strategy 

Clean Energy Rewards is a unique program developed by Montgomery County to encourage 

consumers to switch to clean energy. Consumers must purchase at least 50 percent of their 

annual energy consumption from a clean energy product certified by the Department of 

Environmental Protection (DEP) to be eligible for rewards. 

Under the program, eligible clean energy products must be generated within the PJM Regional 

Transmission Organization (RTO) from solar, wind, and/or Tier 1 biomass as defined by the 

Maryland Code, Public Utility Company Article, 7-703 (Maryland’s RPS). However, current 

products for FY 2007 are limited to energy generated from wind and solar sources, and 

Montgomery County believes that the majority of certified clean energy products will be windbased in 2007. 

Participating suppliers must provide documentation to DEP’s Director verifying that all products 

marketed through Clean Energy Rewards meet the program’s criteria. These steps ensure the 

clean energy is generated within the PJM region and is not used to meet the requirements of the 

Maryland Renewable Energy Portfolio Standard or is otherwise double counted. Only purchases 

of wind energy or solar will be reported for purposes of the SIP. 

MWAQC Ozone SIP May 6-66 23, 2007 
Implementation 

Montgomery County Government. The Department of Environmental Protection solicited 

support from several energy suppliers and REC marketers for this program. Potential suppliers 

are required to submit product information labels or other generation data about each product to 

be marketed through the program, and sign a Memorandum of Understanding with the County 

agreeing to deliver the rewards to consumers either as a credit on their bill, or as a product 

discount. Montgomery County residents will receive 1 cent/kWh up to 20,000 kWh per year. 

Non-residential end-users (small business, congregations, and non-profits) will receive 1.5 

cents/kWh up to 100,000 kWh per year. 

DEP is the main marketing arm of the Clean Energy Rewards Program. However, program

suppliers also are encouraged to market the product and the program to Montgomery County 

consumers with DEP guidance to insure consistency. DEP has developed a web site and 

educational materials to inform consumers about the program and the benefits of clean energy. 

The County is running an advertising campaign in Montgomery County Metro stations and in the 

Montgomery County Extra section of The Washington Post; and is meeting with and promoting 

the program through community organizations and other Montgomery County support structures. 

DEP anticipates that these marketing measures will reach thousands of Montgomery County 

electric consumers. 

 

Consumers can sign-up for clean energy products through DEP’s web site starting November 15, 

2006, and will begin receiving the products and accruing rewards starting January 1, 2007. 

Monitoring and Enforcement 

DEP is requiring suppliers to submit reports identifying the consumers participating in the Clean 

Energy Rewards Program, the amount of eligible clean energy consumed through the program

by resource type, and additional product verification data. Customer lists and energy 

consumption will be submitted to DEP on a quarterly basis. This information will be used to 

determine the funds to reimburse 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 

must provide documentation to DEP’s Director verifying that all products marketed through 

Clean Energy Rewards meet 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 “Montgomery County Clean Energy Rewards.” 

Once electricity is reserved in this account, it cannot be used to meet RPS requirements or 

otherwise sold. These steps ensure that the clean energy is generated within the regional airshed 

and is not used to meet the RPS requirements or is otherwise double counted. The details of 

these submissions will allow Montgomery County to verify the amount of zero-emission NOx 

clean energy generated within Maryland and adjacent states on an annual basis. 

Since this is a new program, it is impossible to estimate with certainty the exact volume of clean 

energy that will be purchased by Montgomery County consumers. However, given the funding 

MWAQC Ozone SIP May 6-67 23, 2007 
appropriated, 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 emission trading regulations, in the future NOx allowances also will be retired 

commensurate with the amount of avoided emissions. 

MWAQC Ozone SIP May 6-68 23, 2007 
Renewable Portfolio Standards 

 

This measure will focus on NOx emission reductions resulting from the displacement of power 

generation from coal, oil, and/or gas-fired sources by zero-emission renewable energy sources. 

The District of Columbia Department of the Environment will retire NOx allowances in an 

amount commensurate with the amount of emissions displaced. 

 

Source Type Affected 

 

The measure affects the District of Columbia within the Metropolitan Washington 

nonattainment area. According to the DC Renewable Energy Portfolio Standard (RPS) Act of 

2004, a major purpose of the Act is to “ensure that the benefits of electricity from renewable 

energy sources, including long-term reduced emissions...accrue to the public at large.” 

 

Control Strategy 

 

Under the DC RPS Act, retail electricity suppliers are required to meet their regulatory 

requirements 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 emitted from these plants. 

 

The District of Columbia plans to include provisions 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 efficiency projects. The District will assure that 

NOx allowances will be retired in an amount commensurate with the NOx emissions reduced as 

a result of the tier one zero-emission renewable energy purchases. This retirement of allowances 

will ensure that surplus emission reductions will be provided. Since the CAIR program for 

electric generating units is not effective until 2009, credit for NOx emission reductions will not 

be claimed until 2009. 

Implementation 

District of Columbia. Under the DC RPS Act, retail electricity suppliers serving customers in 

the District of Columbia are required to provide 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 to 

a level of 11% in 2022 and later. Tier 1 renewable sources are defined to include: (1) zeroemission renewable energy sources, including solar energy, wind energy, geothermal energy, 

and ocean energy; and (2) low-emission renewable energy, including qualifying biomass, 

qualified methane from anaerobic decomposition, and fuel cells. 

MWAQC Ozone SIP May 6-69 23, 2007 
Monitoring and Enforcement 

 

The District of Columbia will provide evidence that it has assured the retirement of the 

designated amount of NOx allowances from future use under its renewable energy set-aside. In 

addition, the District of Columbia Department of the Environment has committed to obtain 

information from the DC Public Service Commission confirming that electricity suppliers have 

made purchases of renewable energy consistent with the commitments incorporated in this 

control measure.

Calculation of Emission Reduction Benefits 

The calculation of NOx emission reductions for 2009 involves the following steps: 

(1) Estimate total retail sales of electricity in DC for the summer ozone season in 2009; 

(2) Estimate the amount of Megawatt-hours supplied from zero-emission Tier 1 renewable 

resources in the summer ozone season for 2009 (based on the requirements of the DC 

RPS Act and estimates by the DC Department of the Environment); 

(3) Calculate avoided NOx emissions in lbs/MWh during the summer ozone season based on 

an estimate of actual avoided NOx emissions and the calculation of NOx allowances 

retired; and 

(4) Calculate avoided NOx emissions in tons/day during the summer ozone season. 

The total annual consumption of electricity in the District of Columbia is 12,354,981.11 MWh. 

In estimating the portion of the Tier 1 renewable energy purchases comprised of wind energy or 

associated RECs, MWCOG relied on the expertise of one of the Commissioners of the DC 

Public Service Commission (PSC). Since the DC RPS has not yet been operational, the PSC 

Commissioner suggested that DC review the experience of another Mid-Atlantic State with a 

similar Tier 1 category in its RPS – one that included both landfill gas and wind energy. New 

Jersey fit that category, and the NJ Board of Public Utilities provided information indicating the 

following allocation of purchases among landfill gas, wind and solar in its Tier 1 category 

during the most recent year: (1) 92.27% landfill gas; (2) 6.48% wind energy; and (3) 1.2% solar. 

Based on this NJ estimate and the different treatment of solar in the DC RPS, we have 

extrapolated to the DC RPS and calculated that wind energy will represent an estimated 6.56% 

of the Tier 1 requirement in 2009. Solar energy must provide 0.019% of total electricity 

consumption. Electricity generated from landfill gas is not considered in the analysis. The 

emissions calculator described in Appendix H was used to estimate the avoided NOx emissions. 

The District of Columbia is claiming zero credit from this measure. 

MWAQC Ozone SIP May 6-70 23, 2007 
Table 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) 

Wind 20,262 0.025

Solar PV 2,347 0.007 

MWAQC Ozone SIP May 6-71 23, 2007 
Green Building Programs 

Under this program, local governments in the nonattainment area have committed to reducing 

energy demand associated with operation of existing and new buildings by implementing Green 

Building Programs. Depending on the energy efficiency and renewable energy components of 

these programs, they will decrease demand for electricity and displace power generation from

coal, oil, and/or gas-fired sources that would normally supply power to the Metropolitan 

Washington region, thereby reducing NOx emissions from those sources. 

Source Type Affected 

The measure affects state and local governments within the Metropolitan Washington 

nonattainment area.

Control Strategy 

This measure is envisioned as a region-wide measure encompassing green building programs by 

state and local governments within the Metropolitan Washington nonattainment area. These 

programs are in the early stages of development and affect several local jurisdictions in the 

nonattainment area. Local governments have begun to implement a variety of Green Building 

Programs that may reduce demand for electricity. The reduction in energy demand will displace 

fossil fuel generated power, thus reducing the NOx emitted from those plants. 

Green Building Programs can include a number of initiatives such as certification under the 

Leadership in Environmental and Energy Design (LEED) Program, labeling under the ENERGY 

STAR® program, Green Globes rating, and green building codes. In order to provide air quality 

benefits, any program must include as a key component a requirement that retrofitted or new 

buildings achieve a reduction in energy demand compared to an established baseline. 

Each state in the nonattainment area is including provisions in its NOx Ozone Season emissions 

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 identifies the current status of Green Building Programs listed for the SIP, examines 

what uses or adaptations of major green building rating systems could be made to quantify 

emissions effects in a SIP context, and summarizes major green buildings efforts to date within 

the nonattainment area. 

Current Status of Green Building Programs for the SIP 

The following table lists the initial survey responses for Green Building programs in the 

nonattainment area that the jurisdictions indicated they would like to include as voluntary 

measures, for SIP purposes. None of the jurisdictions intend to quantify the listed Green 

Buildings program elements for 2009 emission reductions for the 8-hour Ozone SIP. 

MWAQC Ozone SIP May 6-72 23, 2007 
Table 6-12. Summary of Voluntary Measures Initial Survey Responses 

Regarding Green Building Programs (2002-2009) 

Jurisdiction Program Element

Fairfax County LEED goal for recreation center 

Arlington County LEED scorecard for projects; developer incentives 

Montgomery County Green Building ordinance 

District of Columbia Planning for LEED requirements 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 governments in the nonattainment area are 

further described in the section below on “Green Building Activities in the Nonattainment Area.” 

For these green building programs to produce quantifiable electric load and emission reduction 

results, more specific program requirements will be necessary. Green building program rating 

systems are a good framework for discussing how these specific program requirements could be 

designed. 

Green Building Program Rating Systems 

Popular green building program rating systems are LEED certification, ENERGY STAR® 

Building label, and Green Globes. 

LEED. LEED® is a nationally accepted benchmark for the design, construction, and operation 

of high performance green buildings established by the U.S. Green Building Council (USGBC). 

LEED promotes a whole-building approach to sustainability by recognizing performance in five 

key areas of human and environmental health: sustainable site development, water savings, 

energy efficiency, materials selection, and indoor environmental quality. Specific LEED 

programs include: 

• New Commercial Construction and Major Renovation projects (known as LEED-NC and 

is the most widely applied) 

• Existing Building Operations and Maintenance (known as LEED-EB) 

• Commercial Interiors projects 

• Core and Shell Development projects 

• Homes (pilot program) 

• Neighborhood Development (pre-pilot program) 

• Guidelines for Multiple and On-Campus Building Projects; Schools; Retail for New 

Construction and Commercial Interiors; Healthcare; and Laboratories. 

To earn LEED certification, a building project must meet certain prerequisites and performance 

benchmarks or "credits" within each category. Projects are awarded Certified, Silver, Gold, or 

Platinum certification depending on the number of credits they achieve. 

As the documentation required for LEED certification is substantial, it is common for 

organizations to require “LEED-equivalent” building performance levels to avoid the 

MWAQC Ozone SIP May 6-73 23, 2007 
administrative cost of certification. However, without the certification documentation, 

performance can be difficult to verify. 

LEED-NC has 14 out of a total of 69 credits that impact building energy and corresponding 

power generation emissions. Several buildings have successfully certified for LEED Silver 

without earning any of those building energy credits. Therefore, it is important to design 

MWCOG Green Buildings programs to require a reduction in energy consumption in addition to 

the LEED certification level. 

Also, LEED-NC energy performance is based on the simulated design of the building, which 

once constructed and occupied may or may not operationally achieve the certified energy 

performance levels as predicted. The building design simulation is typically conducted on an 

hourly calculation basis, and these calculation models 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 

performance data. 

ENERGY STAR®. ENERGY STAR® Label for Buildings is provided by the U. S. 

Environmental Protection Agency (EPA) to benchmark the energy performance of commercial 

buildings. A building with performance scored among the nation's top 25 percent – equal to an 

energy performance score of 75 or greater on a 1 to 100 scale – and that maintains a healthy and 

productive indoor environment can qualify as an ENERGY STAR® building. The score 

accounts for the most significant drivers of energy intensity such as weather (based on location 

information) and building characteristics (such as size). Currently there are twelve eligible 

building space types. The score is based on annual energy intensity, normalized in units of 

kBtu/ft2-yr, and 12-months of operation with energy utility bills are required. The Statement of

Energy Performance automatically includes a calculation of power generation CO2 emissions (as 

determined by the EPA) based on the annual site energy use in that location. 

The LEED-EB rating system awards energy performance credits based on the ENERGY STAR® 

rating score. 

As achieving the ENERGY STAR® building label may require improvements to the building to 

reduce annual energy usage (and increase the score), the corresponding power generation 

emission reductions could be quantified and counted. The ENERGY STAR® rating tool already 

automatically calculates annual CO2 emissions reductions corresponding to the energy 

consumption reduction. However, more detailed information would have to be recorded to 

account for the seasonal, daily or hourly emission reductions occurring during the nonattainment 

period. 

Green Globes. Another green building rating program has been developed by the Green 

Building InitiativeTM and is known as The Green GlobesTM environmental assessment 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 important elements of sustainability. The construction documents questionnaire is 

the basis for the rating and seven areas are addressed: Project Management – Policies and 

MWAQC Ozone SIP May 6-74 23, 2007 
Practices; Site; Energy; Water; Resources, Building Materials and Solid Waste; Emissions and 

Effluents; and Indoor Environment. The building energy points are awarded based on the 

ENERGY STAR® rating score as determined by the Target Finder tool. The emissions points 

address fossil-fuel heating equipment and operation. Once an assessment is verified by a third 

party, building properties achieving a score of 35% or more 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 nonattainment 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 submission. NREL compiled this information from the 

Internet and personal communications. 

Metropolitan Washington Council of Governments (COG). In June 2006, COG Board Chair Jay 

Fisette announced a goal of promoting Green Building policies and practices in the Washington 

region. This effort supports the COG Board's focus on growth and development, and provides 

environmental and energy friendly methods for supporting sustainable development in the 

region, consistent with COG's Strategic Energy Plan. On September 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 management practices, policies, regulations and legislation. In addition, several COG 

members have adopted or will soon adopt legislation encouraging or requiring Green Building 

practices for government and/or private sector construction. The COG Board adopted resolution 

R55-06 at the November 8, 2006 COG Board Meeting, which supports the development of 

regional Green Building policies and best practice guidelines, establishes a special ad hoc 

elected official advisory committee, and adopts the existing Intergovernmental Green Building 

Group (IGBG) as a COG technical committee. 

The 2006 Regional Energy Strategic Plan - “Powered by Energy Efficiency – Fueled by Energy 

Conservation," outlines an energy vision and mission for the National Capital Region and 

expands existing regional energy and environmental goals. The Energy Strategic Plan also 

identifies potential initiatives to address the region’s diversity of energy sources, help manage 

energy demand, mitigate the effects of energy disruption and enhance overall environmental 

quality. Development of the Plan was identified by the COG Board of Directors as a 2006 

priority. In addition, the Plan is consistent with and complements the proposed Green Building 

Program. The Plan was submitted to member governments in June 2006 for a 90-day comment 

period. The COG Board approved the revised version of the Energy Strategic Plan by adopting 

resolution R56-06 at the COG Board Meeting on November 8, 2006. 

Washington, D.C. In December 2006, the District of Columbia Council enacted green building 

legislation applicable to private development. The legislation, which is expected to be approved 

by the U.S. Congress, would make Washington the first major 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.

MWAQC Ozone SIP May 6-75 23, 2007 
The bill requires all commercial development of 50,000 square feet or more to meet the building 

council's standards starting in 2012. The requirement applies to both new construction and 

significant renovations of old buildings. 

All city-owned commercial projects funded in 2008 or later would have to attain certification, 

and District of Columbia-funded housing projects would be required to follow similar 

environmental standards. The bill also orders the mayor to adopt separate standards for schools, 

which the USGBC is now developing. 

Montgomery County. On November 28, 2006, the Montgomery County Council unanimously 

enacted “Green Building” requirements for future public and private construction in 

Montgomery County -- the strongest “Green Building” requirements 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 multi-family residential buildings to achieve 

a LEED Certified rating. 

Buildings covered by the law include any newly constructed or extensively modified nonresidential or multi-family 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 implementing 

regulations are finalized, but not later than September 1, 2008. Follow up regulations will 

address many 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 defined mandatory energy-efficiency component beyond 

the prerequisites of the LEED rating system. The Montgomery County energy code is IECC 

2003 (IECC 2006 is expected to be adopted in the spring of 2007) which is more aggressive than 

most of the neighboring jurisdictions. 

Arlington County. Arlington County’s green building program is a leading municipal program in 

the region and has been developed in the context of the County’s commitment to smart growth 

and community sustainability. County policy encourages all large commercial and multi-family 

residential projects to incorporate LEED components of 25 or more credits on a voluntary basis. 

 Arlington’s Green Building Incentive Program allows developers to apply for bonus density in 

exchange for official LEED certification. Projects may 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 commit 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 money 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 multifamily building currently under construction. Examples of the County’s own green 

buildings include Langston Brown School and the Walter Reed Community Center. 

MWAQC Ozone SIP May 6-76 23, 2007 
Fairfax County. Fairfax County is expanding activities in support of environmentally sustainable 

development, which include incorporating more sustainable building practices. The County has 

focused its green building efforts in two areas: the greening of public buildings, and policy for 

private development. Of 20 municipal buildings recently built in the County, 18 have LEED 

elements, with many moving toward certification. The County is in the process of reviewing the 

Comprehensive Plan, its key guidance document, and is developing broad language supporting 

green building. 

City of Alexandria. The City of Alexandria initiated a green building policy four years ago and 

adopted a LEED standard for all public buildings in 2003-4. Project staff review the LEED 

checklist to determine actions within their existing budgets, and then make the decision whether 

to fully certify. They currently target a 3.5 percent premium for projects in order to meet 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 nonattainment area 

jurisdictions are registered for LEED, and one LEED certified building is currently listed on the 

USGBC website: 

Langston-Brown High School Continuation & Community Center 

LEED® Project # 0172 

LEED Version 2 Certification Level: SILVER 

September 3, 2003 

Arlington Public Schools, Arlington County 

Arlington, VA 

http://www.usgbc.org/ShowFile.aspx?DocumentID=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 Washington, D.C., but none are owned by the MWCOG government 

organizations. Many of the jurisdictions have signed-up as ENERGY STAR® Partners 

committed to improving their energy efficiency. These local government partners currently 

include: 

Alexandria Public Schools 

Arlington County 

Commonwealth of Virginia 

Fairfax County Government 

Fairfax County Public Schools (Special Recognition in 2004) 

Loudon County Public Schools 

Prince William County 

City of Washington, DC (and DC Energy Office) 

Washington DC Public Schools 

Charles County Public Schools 

MWAQC Ozone SIP May 6-77 23, 2007 
City of Takoma Park 

Montgomery County 

Federal Green Buildings. Legislation and federal mandates provide an example 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 improvement in energy cost to ASHRAE Standard 90.1-2004. This 

ASHRAE Standard is the same baseline applied in LEED-NC version 2.2. The Executive Order 

also requires federal agencies to follow the guidelines of the Memorandum of Understanding for 

Federal Leadership in High Performance and Sustainable Buildings. Federal agencies are also 

required to meet progressive energy use intensity reduction targets for their entire building stock. 

These goals are stated in terms of reduced energy consumption. There are a number federal 

buildings located in the MWCOG region with case study information available. 

Monitoring and Enforcement 

All jurisdictions and agencies claiming emissions reductions from green buildings programs will 

commit to maintain records of the projects undertaken to verify the reduction in electricity 

demand. The factors that must 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 

nonattainment period. 

Projected Reductions and Emissions Benefit Calculations 

Annual electricity consumption reductions can be calculated from reporting the LEED Energy 

Performance, On-Site Renewable Energy, and Green Power certified credits and the baseline and 

proposed/achieved building energy usage numbers by fuel type. LEED certification energy 

performance values are reported on an annual cost basis, although an hourly simulation program

is usually utilized for building energy modeling. With additional guidance, seasonal or daily 

numbers could be available from the process. 

Co-benefits of Green Building programs include reduction in energy demand and associated 

emissions from building heating appliance fuels; reducing the heat island effect (with vegetative 

shading and high-albedo materials); reduction in VOCs associated with built environment 

treatments (adhesives and sealants, paints and coatings, carpet, and composite wood); and 

reduction in transportation emissions (by encouraging the use of mass transit and alternative fuel 

vehicles). 

Because of the uncertainty surrounding the amount of creditable reductions available from this 

program, Maryland and Virginia are claiming zero credit from this measure. 

MWAQC Ozone SIP May 6-78 23, 2007 
Building Energy Efficiency Programs 

Energy Efficiency Programs 

Under this program, the local governments in the nonattainment area have undertaken measures 

to improve the energy performance of government facilities. This section describes the 

estimation of the electricity reductions (measured in kilowatt-hours, kWh) achieved by those 

measures. An overview is given here, and the details of each local government program are 

provided in Appendix H. 

 

Source Type Affected 

These programs improve the energy efficiency of buildings and building equipment owned and 

operated by the local governments in the Metropolitan Washington area. 

Control Strategy 

This measure is envisioned as a region-wide measure encompassing energy performance 

contracts and other structured energy savings programs by state and local governments within 

the Metropolitan Washington nonattainment area. This program is at varying stages of 

development, and commitments received involve several local jurisdictions in the nonattainment 

area. State and local governments have signed contracts with energy service companies 

(ESCOs) to retrofit existing facilities to reduce the demand for electricity and have undertaken 

other energy efficiency measures in their facilities. The reduction in electricity demand will 

displace fossil fueled power generation, thus reducing the NOx emitted from those plants. 

Each state in the nonattainment area is including provisions in its NOx Ozone Season emissions 

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 government has instituted a variety of 

measures since 2002 to improve energy efficiency of operations. In addition, Arlington has 

allocated funds for additional efficiency investments that will increase the energy savings 

between now and 2010. 

Fairfax County, Virginia. Fairfax County government has implemented several large energy 

efficiency projects in 2005 and 2006. These projects involve variable speed drives, lighting and 

heating, ventilation and air conditioning (HVAC) upgrades, and other efficiency investments. 

Montgomery County, Maryland. Montgomery County departments undertake their own energy 

efficiency investments, as detailed in each of their Resource Conservation Plans. (See 

http://www.montgomerycountymd.gov/content/dep/Energy/2007rcp.pdf). These investments 

cover a wide range of measures during the period 2003 to 2008. 

Calvert County, Maryland. Calvert County has a number of energy efficiency initiatives being 

undertaken to improve air quality, including lighting upgrades, programmable thermostats, and 

appliance replacement with ENERGY STAR®. 

MWAQC Ozone SIP May 6-79 23, 2007 
Monitoring and Enforcement 

All jurisdictions and agencies reporting emission reductions from energy efficiency programs 

will commit to maintain copies of signed energy service performance contracts and energy bills 

and other documentation to verify the reduction in electricity demand.7 

Projected Reductions and Emissions Benefit Calculations 

The estimates below were developed in collaboration with local jurisdictions. These estimates 

quantify the reductions in energy consumption resulting from the energy service performance 

contracts and other efficiency measures undertaken by each jurisdiction. The methods used to 

develop these estimates 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 Type of Measure, 

MWH 

Arlington County

Year A/C Lighting Other

2008 27 775 312

2009 31 820 607

Fairfax County

Year A/C Lighting Other

2008 - 98 4,232

2009 - 84 3,597

Montgomery County

Year A/C Lighting Other

2008 4,855 13,788 8,367

2009 4,127 11,720 7,112

Because of the uncertainty surrounding the amount of creditable reductions available from this 

program, Maryland and Virginia are claiming zero credit from this measure. 

 

7 Currently, not enough is known about the methods used to develop kWh reduction estimates to be able to define 

the documentation necessary to establish their validity. Jurisdictions are considering establishing a baseline based 

on documented energy code requirements for energy efficiency. 

MWAQC Ozone SIP May 6-80 23, 2007 
LED Traffic Signal Retrofit Program 

Under this program, state and local governments in the nonattainment area have committed to 

replace existing traffic signals with more energy efficient Light Emitting Diode (LED) 

technology. This will decrease demand for electricity and subsequent power generation from

coal, oil, and/or gas-fired sources that would normally supply power to the Metropolitan 

Washington region, thereby reducing NOx emissions from those sources. 

Source Type Affected 

The measure affects state and local governments within the Metropolitan Washington nonattainment 

area. 

Control Strategy 

This measure is envisioned as a region-wide measure encompassing LED traffic signal retrofits 

by state and local governments within the Metropolitan Washington nonattainment area. This 

program is in the early stages of development, and commitments received at this point affect 

several state and local jurisdictions in the nonattainment area. Transportation agencies have 

begun to retrofit existing traffic signals to LED technology to reduce the demand for electricity. 

The reduction in energy demand will displace fossil fuel generated power, thus reducing the 

NOx emitted from those plants. 

Each state in the nonattainment 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 amount commensurate with the size of the energy 

demand reduction to ensure reductions of ozone season emissions allowed under the state 

regulatory program. 

Implementation 

Maryland Department of Transportation (MDOT) 

Virginia Department of Transportation (VDOT) 

District Department of Transportation (DDOT) 

Montgomery County, Maryland 

Arlington County, Virginia 

City of Alexandria, Virginia 

City of Falls Church, Virginia 

Under this program, jurisdictions are committing to replace older incandescent traffic signals 

with more energy-efficient LED signals. All of the identified replacements will be in place by 

May 1, 2009. 

MWAQC Ozone SIP May 6-81 23, 2007 
The following table summarizes the LED signal replacement commitments: 

LED Traffic Signal Replacment Number of LED Signal Units 

Washington, DC 69,140 

VDOT 6,894

MDOT 15*

Montgomery County, MD 250* 

Arlington County, Virginia 92* 

City of Alexandria, Virginia 25* 

City of Falls Church, Virginia 92 

* Data reported is number of intersections with LED signal units installed. 

Monitoring and Enforcement 

All jurisdictions and agencies participating in the LED Traffic Signal Retrofit program have 

committed to maintain records of the traffic signals being replaced and energy bills to verify the 

reduction in energy demand. 

Projected Reductions and Emissions Benefit Calculations 

LED Traffic Signal 

Replacment 

Number of LED 

Signal Units 

Ozone Season 

NOx Reduction

(tpd)a

Washington, DC 69,140 0.02

Virginia 6,894 0.004

Note: Only DDOT and VDOT commitments are included in the emission benefit 

calculation at this time. a

The emission factors used for this analysis are discussed in Appendix H.

MWAQC Ozone SIP May 6-82 23, 2007 
Mobile Source Strategies 

The following mobile source strategies are included in the voluntary bundle: 

• Remote Sensing Program

There were two programs included in the 1-hour ozone SIP which are now being withdrawn, and 

as such, will not be included in the 8-hour ozone SIP voluntary bundle: diesel retrofit and 

alternative fuel vehicle/low-emission vehicle purchase program. 

• Diesel Retrofit Program. Under this program, local governments and transit agencies 

identify high-emitting, high-mileage diesel vehicles, such as older school buses and transit buses 

for retrofit. These vehicles are retrofitted using any of a variety of technologies certified under 

EPA’s Voluntary Diesel Retrofit Program. Commonly considered technologies include oxidation 

catalysts and particulate filters. 

• Alternative Fuel Vehicle/Low-emission Vehicle Purchase Program. Under this 

program, local governments and transit agencies purchase low-emission vehicles instead of 

conventional gasoline powered vehicles. 

Local governments committed to these two initiatives in the 1-hour ozone SIP voluntary bundle, 

and no emission reduction credits were applied. Annual reporting for the evaluation report 

indicates that these commitments were met. Local governments are now reserving any emission 

reduction credits that these programs may generate for potential future use in meeting 

transportation conformity 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 demonstrates RFP and 

attainment without modeling of any reductions from these measures, therefore removal of these 

commitments from the voluntary bundle does not interfere with air quality planning 

requirements. 

MWAQC Ozone SIP May 6-83 23, 2007 
Remote Sensing Device Program 

The Commonwealth of Virginia has implemented a remote sensing program throughout the 

Northern Virginia portion of the Washington nonattainment area. This program reduces the 

number of high-emitting vehicles in the Virginia portion of the Washington region by requiring 

vehicles identified as high emitting to undergo out-of-cycle testing. 

Source Type Affected 

The measure affects Virginia motorists driving through the Virginia portion of the Washington 

nonattainment area. 

Control Strategy 

Under this measure, cars emitting in excess of the state emission limit are identified via a remote 

sensing program as they drive throughout the region. Owners of high-emitting vehicles are 

mailed a notice requiring out-of-cycle testing and repair for the vehicle’s emission system. Highemitting Virginia vehicles not registered within the inspection and maintenance (I/M) program

area but driving through the Washington region on a regular basis are also be required to repair 

their emissions control systems. This will reduce the number of high-emitting vehicles in the 

Washington nonattainment area. 

Implementation 

Virginia – Department of Environmental Quality 

Monitoring and Enforcement 

VDEQ has developed a rule that will backstop this program and provide clear penalties for 

noncompliance. Penalties are based on the level of the emissions exceedences and vary from

$450 to $225, adjusted from the base year of 1990 by the consumer price index. See 9 VAC 5-

91-750. The entire rule may be found at http://www.deq.virginia.gov/air/pdf/airregs/C091.pdf. 

Projected Reductions and Emission Benefit Calculations 

Because of the uncertainty surrounding the amount of creditable reductions available from this 

program and also due to the problematic nature of relating mobile source concentrations to 

emission rates, Virginia is claiming zero credit from this measure. 

MWAQC Ozone SIP May 6-84 23, 2007 
Auxiliary Power Units (APU) on Locomotives 

Diesel locomotives produce large quantities of NOx and particulate matter. Because it is time 

consuming to start up and shut down locomotives engines, many locomotive operators leave 

engines running when the locomotives are not in use. This is especially true of locomotives used 

in switchyards, which must operate frequently at irregular intervals. As a result, operators often 

tolerate idling so as to have the switcher ready when needed. This program encouraged 

commuter, freight and commercial passenger railroads to install electric-powered APUs on 

locomotives operating in the Washington nonattainment area. An APU offers a low-emission 

alternative to constantly idling the locomotive engine. 

Source Type Affected 

Locomotives operating within the Metropolitan Washington nonattainment area. 

Control Strategy 

This measure was envisioned as a region-wide measure encouraging a variety of locomotive 

owners and operators within the Metropolitan Washington nonattainment area to purchase and 

install APUs to reduce locomotive idling. 

This program was included in the 1-hour ozone SIP and is not being expanded at this time. Only 

one commitment has been received. Virginia Railway Express (VRE), a local commuter railroad, 

has committed to install 13 APUs on locomotives operating within the Metropolitan Washington 

region. These APUs are used when locomotives would normally idle in the rail yards, reducing 

fuel usage and locomotive emissions. 

There are no new commitments beyond those made in the 1-hour ozone SIP. 

Implementation 

Virginia Railway Express 

VRE has completed their APU installation program, and the units are functioning properly. VRE 

has budgeted funds for the electricity charges, and for routine maintenance on the units. 

Monitoring and Enforcement 

VRE has committed to maintain copies of signed contracts and invoices to verify the number 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 documentation for the region’s periodic evaluation report. 

MWAQC Ozone SIP May 6-85 23, 2007 
Projected Reductions 

VRE is operating 13 APUs at a projected reduction of 0.13 tpd NOx per year. 

Emissions Benefits Calculations 

Emission benefits are calculated as follows: 

tpd avoided

2000 7

# of units idling avoided avoided fuel consumption emissions avoided

=

×

× × ×

week

days

ton

lb

gal

lb

hour

gal

week

hours

MWAQC Ozone SIP May 6-86 23, 2007 
VOC Reduction Strategies 

The following programs are included in the voluntary bundle to reduce emissions of VOCs in the 

region: 

• Low-VOC Paints Program

• Gasoline Container Replacement Program

• Solvent Parts Washer Replacement 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 many paints, many manufacturers sell no-VOC paint, or paint with VOC content 

much lower than the AIM rule standard. Use of no- or very low-VOC paint further reduces VOC 

emissions in the Washington nonattainment area. 

Source Type Affected 

The measure affects state and local governments and their contractors involved in some interior and 

exterior painting and traffic marking activities. 

Control Strategy 

This measure is envisioned as a region-wide measure encouraging use of very low or zero-VOC 

paint by public citizens, private industry and state and local governments within the 

Metropolitan Washington nonattainment area. 

This program was included in the 1-hour ozone SIP and is being expanded here. State agencies 

and local governments have committed to using paint and traffic marking materials 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 government entities and the private sector. 

Implementation 

Arlington County, Virginia 

Calvert County, Maryland 

City of Alexandria, Virginia 

City of Greenbelt, Maryland 

 Fairfax County, Virginia 

Maryland Department of Transportation 

Maryland National Capital Parks and Planning Commission (M-NCPPC), Prince George’s 

County 

Prince George’s County, Maryland 

MWAQC Ozone SIP May 6-87 23, 2007 
All participating jurisdictions plan to purchase and use paints with VOC content below the 

allowable levels under the existing regulatory programs for architectural, industrial, and 

maintenance coatings. See Appendix H for more details. 

Monitoring and Enforcement 

All jurisdictions and agencies participating in the low-VOC paint program have committed to 

maintain records of the number of gallons of paint used and the paint’s VOC content. VOC 

content will be determined 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 

documentation for the region’s periodic evaluation reports. 

Projected Reductions 

Including the commitments made in the 1-hour ozone SIP, this measure affects 566 gallons of 

paint per day and is anticipated to reduce 0.17 tpd VOC. Further information on commitments 

and projected reductions is included in Appendix H. 

Emissions Benefits Calculations 

Benefits from this program are calculated by determining emissions reduced over and above 

those required by the OTC AIM rule. They are calculated as follows: 

⎟

⎠

⎞ ⎜

⎝

⎛ ∗ −

×

×

= cap under AIM rule cap in commitments

453.39 2000

3.7854

VOC Reduced (tpd) liter

g

liter

g

ton

lb

lb

g

gallon

liters

day

gallons

MWAQC Ozone SIP May 6-88 23, 2007 
Solvent Parts Washer Replacement Program 

Under this program, local governments voluntarily replace solvent-based parts cleaners with 

zero-emitting technology. This program reduces VOC emissions in the Washington 

nonattainment area. 

Source Type Affected 

The measure affects local governments within the Metropolitan Washington nonattainment area. 

Control Strategy 

This measure is envisioned as a region-wide measure encouraging replacement of solvent-based 

parts cleaners with zero-emitting technology in private industry and state and local governments 

within the Metropolitan Washington nonattainment area. 

This program is in the early stages of development, and commitments received at this point 

affects only one local jurisdiction in the nonattainment area. Montgomery County has begun to 

replace county-owned solvent-based parts cleaners with zero-emitting technology. The program

eliminates VOC emissions from those units. 

Implementation 

Montgomery County, Maryland 

Montgomery County has replaced solvent-based parts washers with microbial/aqueous washers 

at county-owned vehicle service facilities. The county is also conducting a pilot program that 

will offer rebates to private automotive shops to purchase microbial/aqueous parts washers in 

place of solvent- based parts washers. The County hopes to expand the rebate program Countywide. Montgomery County is also working to implement an Environmental Partners Program

across a wide range of businesses, including the general public, which will promote 

environmentally friendly practices that include air quality benefits. 

Monitoring and Enforcement 

All jurisdictions and agencies participating in the Solvent Parts Washer Replacement program

have committed to maintain records of the number of units replaced, the annual quantity of 

solvent use that was displaced, and the VOC content 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 

documentation for the region’s periodic evaluation reports. 

MWAQC Ozone SIP May 6-89 23, 2007 
Projected Reductions and Emissions Benefit Calculations 

VOC emission reductions can vary based on the amount of solvent previously used by the 

facility before the switch to a solvent free system. Based on preliminary estimates provided by 

staff, replacing a typical unit may reduce VOC emissions by 0.1 to 2 tons/year/unit. Maryland is 

claiming zero SIP credit for this measure. 

MWAQC Ozone SIP May 6-90 23, 2007 
Gas Can Replacement Program 

Portable gas cans are a significant source of daily VOC emissions. Emissions from gas cans 

occur from evaporation and due to spillage for overfilling of power equipment fuel tanks. In 

transporting and storing cans, emissions are also released through secondary vent holes and 

permeation. By using newer gas cans with features such as shut off valves, harmful gasoline 

fumes 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 refueling devices with capacities greater than or equal to four gallons, safety cans 

and portable marine fuel tanks operating with outboard motors, and products resulting in 

cumulative VOC emissions below those of a representative container or spout. 

Control Strategy 

This program was adopted as part of the voluntary bundle developed for the 1-hour ozone SIP. 

Commitments included local jurisdictions, state agencies, and their contractors operating in the 

nonattainment area. Jurisdictions pledged to collect functional cans that were not already 

scheduled for replacement, and replace those in-use, functional cans with redesigned cans 

meeting the new Portable Fuel Containers standard. Old cans were destroyed in accordance with 

requirements for disposal of hazardous waste. 

There are no new commitments beyond those made in the 1-hour ozone SIP. 

Implementation 

Arlington County, Virginia 

Fairfax County, Virginia 

City of Fairfax, Virginia 

Maryland National Capital Parks & Planning Commission, Prince George’s County 

Montgomery County, Maryland 

Prince George’s County, Maryland 

Prince William County, Maryland 

Monitoring and Enforcement 

All jurisdictions and agencies participating in the fuel container replacement program committed 

to maintain records of the number of fuel containers replaced and the method of disposal. These 

records are provided to the appropriate state air agency on an annual basis and are used to 

provide documentation for the region’s program evaluation report. 

MWAQC Ozone SIP May 6-91 23, 2007 
Projected 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 emission benefits was based on estimates prepared by EH Pechan for use by the 

Ozone Transport Commission (Reference 2). In the report, Pechan estimates that 2.28 million 

gas cans are sold annually in the OTC Region. Table IV-6 in the Pechan document shows that 

for the 2.5 year period from January 1, 2003 through July 1, 2005, emissions in the OTC region 

will be reduced by 48 tpd VOC. Over this time period, the expected benefit in the Metropolitan 

Washington region would be 4.3 tpd, assuming a January 1, 2003 implementation date. The 

estimated annual benefit from the measure in the Washington region is 4.3/48=8.96% of the total 

benefit. 

Assuming that emission reductions are linearly related to gas can turnover, the Washington 

region accounts for 8.96 percent of the 2.28 million cans sold in the region per year, or 204,000 

cans. Annual regional reductions from the measure are estimated at 1.88 tpd. Therefore, 

replacement of one can will, on average, deliver a benefit of 1.88/204,000 = 0.00000922 tpd 

VOC. 

MWAQC Ozone SIP May 6-92 23, 2007 
Urban Heat Island Mitigation/Tree Planting/Canopy Conservation and Management 

Strategic tree planting and tree canopy conservation and management are innovative voluntary 

measures that will achieve area-wide improvement of the tree canopy, providing air quality 

benefits including reductions in ground-level ozone in the Washington DC Metro nonattainment 

area. Air quality benefits associated with trees and their shade result from lowering summertime 

air temperatures and from actual pollutant absorption and contact removal from the trees 

themselves. 

One of the most dramatic improvements achievable from area-wide comprehensive tree canopy 

conservation and planting is reducing the negative effects of urban heat islands (the rise in 

temperatures due to an increased number of buildings and impermeable surface areas retaining 

heat). Strategic placement of trees around homes, buildings, streets, and parking lots, increases 

shade and evapotranspiration, thereby lowering summertime air temperatures and surface 

temperatures of asphalt, concrete, and other impervious areas. Lowering air summertime 

temperatures helps reduce ground-level ozone in several ways: 

 slow the temperature-dependent reaction that forms ground-level ozone; 

 reduce evaporative emissions, primarily VOCs (precursors to ground-level ozone) from

sources such as vehicles; and 

 reduce the amount of electricity generated for cooling, thereby reducing air pollutant 

emissions including ground-level ozone precursors, from power plants. 

 

In addition, through up-take and contact removal, trees remove ground-level ozone, nitrogen 

oxides, sulfur oxides, and other ozone precursors from the air. Other air quality benefits from

trees include removal of carbon monoxide and fine particulate matter less than 10 microns. 

Carbon dioxide is removed and stored by trees, dust is intercepted, and oxygen is released. 

Source Type Affected 

The measure affects state and local governments within the Washington DC Metro 

nonattainment area. 

Control Strategy 

To achieve reductions in ground-level ozone, government agencies, volunteer organizations, and 

private landowners must make long-term commitments to conserving existing canopy and 

planting significant numbers of trees in strategic locations. Under this measure, local 

governments in the metropolitan nonattainment area will commit to: 

1. Measure Existing Resources and Track Changes – Initiate and/or enhance efforts to 

measure, track, and enhance existing urban tree canopy and canopy expansion efforts. 

2. Programs to Enhance and Increase Benefits from Trees – Implement urban forestry 

programs to enhance canopy coverage to reduce summertime air and surface 

temperatures. Programs include planting trees in strategic locations to cool targeted 

MWAQC Ozone SIP May 6-93 23, 2007 
surfaces and provisions for long-term maintenance. Priority planting sites include 

locations where buildings, streets, driveways, and parking lots will be shaded by the new 

plantings. 

3. Public Outreach – The region commits to undertake a public outreach program designed 

to promote tree and canopy conservation and planting. Local governments, 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 establishment, and long-term tree maintenance. Efforts will 

be made to document all conservation and planting efforts including voluntary programs. 

4. Regional Canopy Management Plan – Local governments will work to develop a long 

range plan to enhance tree conservation and planting, and to establish goals for increasing 

tree 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, involvement of private landowners and businesses, and periodic evaluations and 

reports. 

5. Species Selection – During photosynthesis, trees release secondary metabolic products. 

Some of these include biogenic volatile organic compounds (VOCs), precursors to the 

formation of ozone. In most instances, the improvements in air quality gained from trees 

outweigh the concerns over additional biogenic VOC emissions. Additionally, large trees 

are considerably more beneficial for air quality than small trees. Therefore, when 

planting trees, species should be selected for large-size and long-term survival based on 

specific site conditions and adjusted, when possible, for low-VOC emitters. 

6. Monitoring Programs – Monitor these activities and report periodically. 

Current Programs 

Many programs that support, encourage, or require the tree and forest conservation and planting 

exist within the local jurisdictions, counties, and states in the Washington DC Metro 

nonattainment area. Special attention will be paid coordinating these programs to enhance tree 

protection, canopy conservation and expansion to enhance regional air quality. 

Implementation 

Fairfax County tree canopy requirement for new development. 

Fairfax County parking lot canopy ordinance. 

Fairfax County government 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 Preservation Ordinance/Landscape Conservation Plan. 

MWAQC Ozone SIP May 6-94 23, 2007 
City of Alexandria Urban Forestry Plan under development. 

City of Alexandria 12,000 square feet of vegetative roof installed on city buildings. 

City of Alexandria Reflective roofs standard for government buildings. 

City of Greenbelt Tree planting program. Shade tree improvement initiative. 

Montgomery County street tree planting program. 1,200 trees per year. 

Montgomery County "Shade to Save" pilot program. 

Montgomery County is developing a residential tree planting program. 

Montgomery County is developing urban tree legislation. 

Montgomery County Stream Restoration Projects plant native trees and shrubs to enhance and 

establish forests near stream project sites. 

Montgomery County Rainscapes Program. 

Montgomery County Forest Conservation Law 

Amendments to the Forest Conservation Law to adjust for changes in development patterns are 

being developed. 

Montgomery County Forest Banking Program

Montgomery County Legacy Open Space program

Montgomery County Rural Legacy Program

Montgomery County Development Rights Program

Prince George's County Releaf Grant Program

Prince George's County Tree Replacement Program

Prince George's County Gorgeous Prince George's Day 

MNCPPC Montgomery County Parks Department actively maintains and plants shade trees in 

developed areas of parks. 

MNCPPC Montgomery County Parks Department establishes forested areas on open land within 

the park system. 

Calvert County Reflective roof systems on 6 county buildings. 

Monitoring and Enforcement 

The state and local governments will maintain records of program activity and public outreach 

campaigns designed to promote tree and canopy conservation and planting or enhancement. The 

jurisdictions will also provide evidence of educational outreach efforts regarding documenting 

and reporting voluntary planting and maintenance programs. Results of all initiatives will be 

quantified and reported consistent with other SIP requirements to the public and EPA. 

Projected Reductions and Emissions Benefits Calculations 

This program is expected to lead to reductions in ground-level ozone throughout the Washington 

DC Metro nonattainment area. Methods to quantify benefits from trees and tree canopy are 

evolving. Several methods have been used to calculate benefits resulting from canopy expansion. 

Currently, the Air Pollution Removal Calculator developed by the United States Forest Service 

will be used to estimate pollution removal 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) model. 

Maryland, Virginia, and the District of Columbia are claiming zero credit for this measure. 

MWAQC Ozone SIP May 6-95 23, 2007 
References 

US EPA. 2007. Heat Island Effect: Vegetation & Air Quality. Most recent update Jan 16, 2007. 

http://epa.gov/heatisland/strategies/level3_vegairquality.html. Trees and Our Air, January 1999, 

Galveston-Houston Association for Smog Prevention. 

MWAQC Ozone SIP May 6-96 23, 2007 
7.0 REASONABLY AVAILABLE CONTROL MEASURE (RACM) 

ANALYSIS

7.1 RACM Analysis 

Section 172(c)(1) of the Clean Air Act requires state implementation plans (SIPs) to 

include an analysis of reasonably available control measures (RACM). This analysis is 

designed to ensure that the Washington region is implementing all RACM in order to 

demonstrate attainment with the 1-hour ozone standard on the earliest date possible. This 

chapter presents a summary of analyses conducted to determine whether the SIP includes 

all such measures. Full details of the analysis are included in Appendix I. The 

Metropolitan Washington Council of Governments (MWCOG) conducted this RACM 

evaluation in coordination with the District of Columbia Department of Environment 

(DC-DOE), Maryland Department of the Environment (MDE) and the Virginia 

Department of Environmental Quality (VA DEQ). 

7.1.1 Analysis Overview and Criteria 

The RACM requirement is rooted in Section 172(c)(1) of the Clean Air Act, which 

directs states to “provide for implementation of all reasonably available control measures 

as expeditiously as practicable”. In its 1992 General Preamble for implementation of the 

1990 Clean Air Act Amendments (57 FR 13498) EPA explains that it interprets Section 

172(c)(1) as a requirement that states incorporate in a SIP all RACM that would advance 

a region’s attainment date. However, regions are obligated to adopt only those measures 

that are reasonably available for implementation in light of local circumstances. In the 

Preamble, EPA laid out guidelines to help states determine which measures should be 

considered reasonably available: 

If it can be shown that one or more measures are unreasonable because 

emissions from the sources affected are insignificant (i.e. de minimis), those 

measures may be excluded from further consideration...the resulting 

available control measures should then be evaluated for reasonableness, 

considering their technological feasibility and the cost of control in the area 

to which the SIP applies...In the case of public sector sources and control 

measures, this evaluation should consider the impact of the reasonableness 

of the measures on the municipal or other government entity that must bear 

the responsibility for their implementation. 

In its opinion on Sierra Club v. EPA, decided July 2, 2002, the U.S. Court of Appeals for 

the DC Circuit upheld EPA’s definition of RACM, including the consideration of 

economic and technological feasibility, ability to cause substantial widespread and longterm adverse impacts, collective ability of the measures to advance a region’s attainment 

date, and whether an intensive or costly effort will be required to implement the 

measures. Consistent with EPA guidance and the U.S. District Court’s opinion, the region 

MWAQC Ozone SIP 7-1 May 23, 2007
has developed specific criteria for evaluation of 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) 1

• Enforceable 

• Technically feasible 

• Economically feasible (proposed as a cost of $3,500-$5,000 per ton or less) 

• Would not create substantial or widespread adverse impacts within the region 

• Emissions from the source being controlled exceed a de minimis threshold, 

proposed as 0.1 tons per day 

An explanation of these criteria is given in succeeding sections. 

7.1.2 Implementation Date 

EPA has traditionally instructed regions to evaluate RACM measures on their ability to 

advance the region’s attainment date. This means that implementation of a measure or a 

group of measures must 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. As the 

Washington region currently expects to reduce ozone levels to 84 ppb during the 2009 

ozone season, any RACM must enable the region to meet the 84 ppb standard by May 1, 

2008, the beginning of the 2008 ozone season. 

7.1.3 Enforceability 

When a control measure is added to a SIP, the measure becomes legally binding, as are 

any specific performance targets associated with the measure. If the state or local 

government does not have the authority necessary to implement or enforce a measure, the 

measure is not creditable in the SIP and therefore cannot be declared a RACM. A 

measure is considered enforceable when all state or local government agencies 

responsible for funding, implementation and enforcement of the measure have committed 

in writing to its implementation and enforcement. 

In addition to theoretical enforceability, a measure must also be practically enforceable. If 

a measure cannot practically be enforced because the sources are unidentifiable or cannot 

be located, or because it is otherwise impossible to ensure that the sources will implement 

the control measure, the measure cannot be declared a RACM. One exception is 

voluntary measures, such as those implemented under EPA’s Voluntary Measures 

Guidance. 

7.1.4 Technological Feasibility 

All technology-based control measures must include technologies that have been verified 

by EPA. The region cannot take SIP credit for technologies that do not produce EPAverified reductions. 

MWAQC Ozone SIP 7-2 May 23, 2007
 

7.1.5 Economic Feasibility and Cost Effectiveness 

EPA guidance states that regions should consider both economic feasibility and cost of 

control when evaluating potential RACM. Therefore, the Washington region has 

specified a cost-effectiveness threshold for all possible RACM. Measures for which the

cost of compliance exceeds this threshold will not be considered RACM. 

In setting this threshold, the region took into consideration two major factors. First, EPA 

has issued guidance regarding the relationship between RACT and RACM. In its RACM 

analysis for the Dallas/Forth Worth nonattainment area, EPA states: 

“RACT is defined by EPA as the lowest emission rate achievable considering economic 

and technical feasibility. RACT level control is generally considered RACM for major 

sources.” 

In the Washington region, installation of Reasonably Available Control Technology 

(RACT) costs are as low as approximately $3,500 per ton of emissions reduced. 

Therefore, it seems reasonable to adopt this cost effectiveness for area, nonroad and 

mobile sources in addition to stationary. Secondly, the National Capital Region 

Transportation Planning Board (TPB) frequently adopts Transportation Emissions 

Reduction Measures (TERMs) to offset mobile emissions for the purpose of conformity. 

The majority of TERMs adopted by TPB in the past ten years for the express purpose of 

reducing mobile emissions have cost less than $10,000 per ton.1

The region proposes a threshold of $3,500-$5,000 for cost effectiveness. All measures 

costing under $5,000 per ton NOx or VOC reduced will be evaluated against the 

remaining criteria to determine whether they meet the requirements for a RACM. 

7.1.6 Substantial and Widespread Adverse Impacts 

Some candidate RACM have the potential to cause substantial and widespread adverse 

impacts to a particular social group or sector of the economy. Due to environmental 

justice concerns, measures that cause substantial or widespread adverse impacts will not 

be considered RACM. 

7.1.7 De Minimis Threshold 

In the General Preamble, EPA allows regions to exclude from the RACM analysis 

measures that control emissions from insignificant sources and measures that would

impose an undue administrative burden. Under moderate area RACT requirements, the 

smallest major source subject to RACT emits 25 tpy, or approximately 0.1 tpd. Following 

1

 Though several expensive TERMS have been adopted in recent years, these measures were designed for 

congestion mitigation or other transportation purposes. Emission reductions were credited as an ancillary 

benefit, and the projects would have proceeded even if no emission credits were generated. 

MWAQC Ozone SIP 7-3 May 23, 2007
these requirements and the precedent set by the San Francisco RACM analysis, the region 

will not consider control measures affecting source categories that produce less that 0.1 

tpd NOx or VOC emissions. 

7.1.8 Advancing Achievement of 84 ppb Standard 

In order for measures to be collectively declared RACM, implementation of the measures 

must enable the region to demonstrate attainment of the 84 ppb ozone standard one full 

ozone season earlier than currently expected. As discussed in Section 7.1.1, the 

Washington region currently expects to demonstrate attainment in 2009. Therefore, any 

RACM would need to enable the region to meet the 84 ppb standard during the 2008 

ozone season. 

Photochemical modeling performed as part of the Washington region’s attainment 

demonstration has not yet been completed. It is impossible to determine how many 

additional tons the region would need to reduce in order to ensure that attainment is met 

in 2008. Preliminary modeling results indicate that any RACM would need to 

collectively reduce more than 20-40 per day (tpd) of NOx and/or VOC emission in order 

to advance the attainment date by one year. 

7.1.9 Intensive and Costly Effort 

When considered together, the implementation requirements of any RACM cannot be so 

great as to preclude effective implementation and administration given the budget and 

staff resources available to the Washington region. 

7.2 RACM Measure Analysis 

7.2.1 Analysis Methodology 

Over the last decade, the Metropolitan Washington Air Quality Committee (MWAQC) 

has compiled an extensive list of potential control measures. MWCOG has also 

researched measures used as air quality control strategies in other metropolitan regions. 

These lists of control measures were compiled into a master list of candidate measures for 

the RACM analysis. The sources of strategies analyzed for the Metropolitan Washington 

region include the following: 

• Clean Air Act Section 108(f) measures (Transportation Control Measures) 

• Transportation Emissions Reduction Measures (TERMs) listed in recent 

Transportation Improvement Programs (TIPs) for the Metropolitan Washington 

region 

• Measures identified in 1993 and 2003 MWAQC review of Air Pollution Control 

Measures 

• Measures considered in Baltimore, Atlanta and Houston RACM analyses

MWAQC Ozone SIP 7-4 May 23, 2007
MWAQC Ozone SIP 7-5 May 23, 2007 

These measures were then evaluated against the criteria discussed in Section 7.1 as 

documented in Appendix I. 

7.2.2 Analysis Results 

Table 7-1 provides lists, organized 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 considered 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 control measures to determine if collectively they could meet 

these criteria. Several mandatory programs are available that can provide moderate levels 

of emission reductions, however, none of these measures can provide benefits by the 

2008 ozone season, and the total overall reduction that could be provided by these 

measures is below 20-40 tpd. While there are potential voluntary measures that can be 

implemented before 2008, together these voluntary measures will not provide sufficient 

creditable emission reductions to advance the attainment date by one year. Therefore, 

there are no reasonably (RACM) appropriate for the Washington 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 Measures

List #

Measure Description

RACM: 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 EGUs 

Plant 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

MWAQC Ozone SIP Page 1 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 2 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 3 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 4 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 5 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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 to 

reduce 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

MWAQC Ozone SIP Page 6 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 7 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 8 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 9 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 10 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 11 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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 for 

owners 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

MWAQC Ozone SIP Page 12 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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 ultra 

low 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 stop 

electrification 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

MWAQC Ozone SIP Page 13 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 14 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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 one 

bicycle 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

MWAQC Ozone SIP Page 15 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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 electric

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

MWAQC Ozone SIP Page 16 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 17 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 18 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 19 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 20 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 21 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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: Onroad 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

MWAQC Ozone SIP Page 22 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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

MWAQC Ozone SIP Page 23 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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 than 

those set by the EPA – 35 weightpercent VOC.

No - - - Yes - No

Will not provide 

reductions by 

May 2008

MWAQC Ozone SIP Page 24 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
Table 7-1. Potential RACM Measures

List #

Measure Description

RACM: 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.

MWAQC Ozone SIP Page 25 Table 7-1: Pages 7-6 to 7-30 May 23, 2007 5/10/2007
 

References

US EPA, “State Implementation Plans; General Preamble for the Implementation of Title 

I of the Clean Air Act Amendments of 1990”, (57 FR 13498), April 16, 1992. 

US EPA Region VI, “Reasonably Available Control Measures (RACM) Analysis for the 

Dallas/Fort Worth Ozone Nonattainment Area”, December 2000. 

Bay Area Air Quality Management District, Metropolitan Transportation Commission 

and Association of Bay Area Governments, “Bay Area 2001 Ozone Attainment 

Plan,” October 24, 2001, Appendix C. 

1

 See discussion in “Approval and Promulgation of Air Quality Implementation Plans; District of

Columbia, Maryland, Virginia; Post 1996 Rate-of-Progress Plans and One-Hour Ozone Attainment

Demonstrations; Final Rule (April 17, 2003, 68 FR 19106). 

MWAQC Ozone SIP 7-31 May 23, 2007
MWAQC 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 PM2.5

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 air 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 four 

years. 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 perform 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 regionally 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 2008 
MWAQC 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 technology, 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-based 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 needs 
MWAQC 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 vehicles 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 have 
MWAQC Ozone SIP May 23, 2007 8-6

 

been 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 National 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 commitment to implement the regulatory 

measures upon which the plan is based. The locally adopted measures included in the analysis 

are those included in Table A. Chapter 6 provides documentation of the reductions achieved by 

those measures. The States and the District are also taking action to implement regional 

measures to reduce ozone transport. Tables 9-1, 9-2, 9-3 and 9-4 provide information on the 

implementation of each measure by Maryland, Virginia and the District of Columbia. 

Commitments for regulations required by the CAAA Section 182 (b) for moderate nonattainment 

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 Requirements 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 Reformulated 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 Reformulated Consumer Products Federal 

Regulation 63 FR 48848 9/11/98 

6.2.3 Reformulated Industrial Cleaning 

Solvents 

Federal 

Regulation 

20 DCMR 

Sec 708 

10/2/98 

MWAQC Ozone SIP 9-1 May 23, 2007 

 
No. Control Measure Mandate Regulation 

Number 

Effective 

Date 

6.2.4 Surface Cleaning/Degreasing for 

Machinery/Automobile Repair 

State Regulation 20 DCMR 

Sec. 743-745 

5/1/99 

6.2.5 Landfill Regulations 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 

8/14/98

6.2.11 Mobile Equipment 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 Reformulated Consumer 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 Reformulated Consumer Products 

Rule: Phase II 

State 

Regulation/OTC 

Model Rule 

20 DCMR 

Sec. 719-737 

No later 

than May 1, 

2008 

Nonroad Source Controls 

MWAQC Ozone SIP 9-2 May 23, 2007 

 
No. 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 Reformulated Gasoline (off-road) Federal 

Regulation with 

State Opt-in 

CAA Section 

211 (k) 

1/1/95 

6.3.6 Emissions Controls for Locomotives Federal 

Regulation 

63 FR 18998 6/15/98 

On-road Measures 

6.4.1 Phase II Volatility Controls of 

Refueling Emissions 

Federal 

Regulation with 

State Opt-in 

42 U.S.C. 

7545 

1992 

6.4.1 Reformulated 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 Emissions Vehicle 

Program

Federal 

Regulation 

20 DCMR, 

Sec 915 

1/20/2000 

MWAQC Ozone SIP 9-3 May 23, 2007 

 
No. Control Measure Mandate Regulation 

Number 

Effective 

Date 

6.4.5 Tier 2 Motor Vehicle Emission 

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 information was obtained from the District Department of the Environment. 

**District of Columbia Municipal Regulations. 

*** For measures not yet adopted, an anticipated schedule for adoption is provided.

MWAQC Ozone SIP 9-4 May 23, 2007 

 
Table 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 Non-CTG RACT Federal

Regulation 

See Table 9-3 - 

6.1.1 Expanded Point Source 

Regulations to 25 tpy 

Federal 

Regulation 

26.11.19.01B(4) 5/8/95

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 Requirements Federal 

Regulation 

26.11.29.08 

26.11.27 

5/10/93 

No later than 

Jan.1, 2009 

Area Source Controls

6.2.1 Reformulated 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 

Compound Emission Standards 

for Consumer Products 

Federal 

Regulation 

63 FR 48848 9/11/98 

6.2.3 Reformulated Industrial Cleaning 

Solvents 

Federal 

Regulation 

42 U.S.C. 7511 2001 

6.2.4 Surface Cleaning/Degreasing for 

Machinery/Automobile Repair 

State Regulation 26.11.19.09 6/5/95 

6.2.5 Landfill Regulations Federal

Regulation 

26.11.19.20 3/9/98

6.2.6 Seasonal Open Burning 

Restrictions 

State Regulation 26.11.07 5/22/95 

6.2.7 Stage I Expansion Federal 

Regulation 

26.11.13.04C 4/26/93

6.2.8 Stage II Vapor Recovery Nozzle Federal 

Regulation 

26.11.24 2/15/93

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 

MWAQC Ozone SIP 9-5 May 23, 2007 

 
No. Control Measure Mandate Regulation 

Number 

Effective 

Date 

6.2.11 Control of VOC Emissions 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 

26.11.13.07 1/21/02

6.2.13 Architectural and Industrial 

Maintenance Coatings Rule 

State 

Regulation/OTC 

Model Rule 

26.11.33 3/29/04

6.2.14 Reformulated Consumer

Products Rule: Phase I 

State 

Regulation/OTC 

Model Rule 

26.11.32 8/18/03

6.2.15 Control of VOC Emissions from

Cold and Vapor Degreasing 

State 

Regulation/OTC 

Model Rule 

26.11.19.09 6/5/1995

6.2.16 Industrial Adhesives and 

Sealants Rule** 

State 

Regulation/OTC 

Model Rule 

[Regulation 

Number 

Pending] 

5/1/2008 

6.2.17 Portable Fuel Containers Rule: 

Phase II** 

State 

Regulation/OTC 

Model Rule 

21.11.13.07 5/1/2008

6.2.18 Reformulated Consumer

Products Rule: Phase II** 

State 

Regulation/OTC 

Model Rule 

26.11.32 5/1/2008

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 Reformulated Gasoline (off-road) Federal 

Regulation with 

State Opt-in 

CAA Section 

211 (k) 

1/1/95 

MWAQC Ozone SIP 9-6 May 23, 2007 

 
No. Control Measure Mandate Regulation 

Number 

Effective 

Date 

6.3.6 Emissions Controls for 

Locomotives 

Federal 

Regulation 

63 FR 18998 6/15/98 

On-road Source Controls 

6.4.1 Phase II Volatility Controls of 

Refueling Emissions 

Federal 

Regulation with 

State Opt-in 

03.03.03.05 10/26/92

6.4.1 Reformulated 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 

11.14.08 1/2/95 &

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 Emissions Vehicle 

Program

Federal 

Regulation 

26.11.20.04 3/22/99

6.4.5 Tier 2 Motor Vehicle Emission 

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 information was obtained from the Maryland Department of the Environment. 

** For measures not yet adopted, an anticipated schedule for adoption is provided.

 

MWAQC Ozone SIP 9-7 May 23, 2007 

 
Table 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 

Commercial Bakery Ovens 26.11.19.21 7-3-95 22:13 Md R 970 

Vinegar Generators 26.11.19.22 8-11-97 24:16 Md R 1161 

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 

MWAQC Ozone SIP 9-8 May 23, 2007 

 
Table 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 

Requirements 

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 permit or 

compliance 

agreement 

9 VAC 5 Chapter 

130 

6/25/98 

No later than 

Jan.1, 2009 

Area Source Controls

6.2.1 Reformulated 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 Reformulated Consumer

Products 

Federal 

Regulation 

63 FR 48848 9/11/98 

6.2.3 Reformulated Industrial

Cleaning Solvents 

Federal 

Regulation 

42 U.S.C. 7511 2001 

6.2.4 Surface Cleaning/Degreasing

for Machinery/Automobile 

Repair 

State Regulation 9 VAC 5-40-3260 

et. seq. 

4/1/96 

6.2.5 Landfill Regulations Federal

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 

MWAQC Ozone SIP 9-9 May 23, 2007 

 
No. 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 Equipment 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 

6.2.14 Reformulated Consumer

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 

6.2.18 Reformulated Consumer

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 

MWAQC Ozone SIP 9-10 May 23, 2007 

 
No. Control Measure Mandate Regulation 

Number Effective Date 

1068 

6.3.5 Reformulated Gasoline Phase I 

and Phase II (non-road) 

Federal 

Regulation with 

State Opt-in 

CAA Section 211 

(k) 

1/1/95 

6.3.6 Emissions Controls for 

Locomotives 

Federal 

Regulation 

63 FR 18998 6/15/98 

On-road Measures 

6.4.1 Phase II Volatility Controls of 

Refueling Emissions 

Federal 

Regulation with 

State Opt-in 

2 VAC 5 420-10 7/28/93 

6.4.1 Reformulated 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 Emissions 

Vehicle Program

Federal 

Regulation 

 9 VAC 5-200 4/14/99 

6.4.5 Tier 2 Motor Vehicle 

Emission 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 information was obtained from the Virginia Department of Environmental Quality. 

** For measures not yet adopted, an anticipated schedule for adoption is provided.

MWAQC Ozone SIP 9-11 May 23, 2007 

 
9.2 Stationary Source Threshold Revisions 

The Clean Air Act Amendments, Section 182 (d) required the states in severe nonattainment 

areas to adopt lower permit thresholds for point sources from 50 tons per year to 25 tons per 

year. Maryland, Virginia and the District of Columbia adopted these measures, listed in Table 9-

5, on the schedule shown. 

Under the moderate designation for the 8-hour ozone standard, the permit threshold is 50 tons 

per year VOC and 100 tons per year NOx. Virginia will adopt the thresholds corresponding to 

the moderate designation. Maryland and the District are committed to maintaining the permit 

threshold at 25 tons per year for both VOC and NOx. 

Table 9-5 

Schedule of Stationary Source Revisions 

Washington Nonattainment Area 

No. State Control Measure Regulation

Number 

Effective Date 

Maryland Control of NOx Emissions 

for Major Stationary 

Sources 

COMAR 09.08 Adoption: 

10/03 

Virginia Control of NOx Emissions 

for Major Stationary 

Sources 

9 VAC 5-20-204 

9 VAC 5-80-

2000 

Adopted: 

4/7/03 

Effective: 

6/4/03 

District of

Columbia 

Major Source Thresholds 20 DCMR 

Sections 

715.2,715.3,715.4 

(VOC RACT) 

8/29/03 

MWAQC Ozone SIP 9-12 May 23, 2007 

 
9.3 New RACT Rules Applicability 

When the Washington, DC region was designated as severe nonattainment for ozone, Virginia, 

Maryland and the District adopted additional reasonably available control technology (RACT) 

rules for sources subject to the lower major source applicability size threshold of 25 tpy. The 

requirements for VOCs have been in the regulations for some time due to earlier regulatory 

actions. The RACT threshold will remain at 25 tpy for Virginia, Maryland and the District. The 

states are also recertifying RACT for facilities that have the potential to emit more than 50 tpy 

VOC or 100 tpy NOx. 

Table 9-6 

New RACT Rules Applicability 

Washington Nonattainment Area 

No. State Control Measure Regulation

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 

Emissions 

COMAR 9.08 10/03 

District of

Columbia 

Major Source 

Thresholds 

20 DCMR 

sections 

805.1,805.6,805.7 

(NOx RACT) 

8/29/03 

MWAQC Ozone SIP 9-13 May 23, 2007 

 
9.4 Revision of New Source Review (NSR) Regulations 

When designated as severe nonattainment of the ozone standard, the states were required to 

lower the thresholds for defining “Major” sources to require controls for facilities with the 

potential to emit more 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 requirement to major stationary sources of 

VOC and NOx. 

The Washington, DC region is designated as moderate nonattainment for the 8-hour ozone 

standard. Under the current moderate designation, the NSR thresholds are 50 tpy VOC and 100 

tpy NOx. The 1:1.15 offset requirement would apply. 

The New Source Review permit regulations in Virginia are structured so that the pertinent 

requirements such as major source threshold and offset ratio are self-implementing depending 

upon changes to the nonattainment area classification. The NSR threshold will remain at 25 tpy 

for both VOC and NOx for Maryland and the District and the 1:1.3 offset requirement will 

apply. 

Table 9-7 

Schedule for Revision of NSR Regulations 

Washington Nonattainment Area 

State Control Measure Regulation Number Effective Date 

Maryland Requirements for

Major New Sources 

and Modifications: 

Definitions and 

General Conditions 

COMAR 17.01 and COMAR 17. 03 Adoption: 10/03 

Virginia Permits for Major 

Stationary Sources 

and Major 

Modifications 

Locating in 

Nonattainment 

Areas 

9 VAC 5-80-2000 of Part II of 9 VAC 

5 Chapter 80 

Adopted: 6/31/81 

Effective: 12/1/04

Virginia Nonattainment

Areas (NSR permit 

regulations) 

9 VAC 5-20-204 Effective: 

5/4/2005 

District of 

Columbia 

Nonattainment 

Areas (NSR Permit 

Regulations) 

20 DCMR section 204 8/29/03 

MWAQC Ozone SIP 9-14 May 23, 2007 

 
10.0 Attainment Demonstration 

The 8-Hour Ozone Standard Attainment Plan analyzes the potential of the Washington 

metropolitan area to achieve attainment of the 8-hour ozone standard. The demonstration of 

achieving the 8-hour ozone standard is based on both the Community Multiscale Air Quality 

Model (CMAQ) and Weight of Evidence (WOE) analysis supporting the attainment modeling 

results. Photochemical modeling and the WOE analyses provide strong evidence that the region 

will attain the 8-hour ozone standard by 2009. Details of both the CMAQ model and the WOE 

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 Washington 

D.C. MSA as a “Moderate” ozone non-attainment area for the new 8-hour ozone standard. 

Moderate ozone non-attainment areas are required to demonstrate attainment of the new 8-hour 

ozone standard using photochemical modeling and WOE analyses. 

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 June 2010. The 

modeling exercise predicts future 2009 air quality conditions based on the worst episodes in the 

base year 2002, and applies control measures to demonstrate the effectiveness of new measures 

in reducing air pollution. 

For the reason mentioned above, a photochemical modeling study was undertaken by Virginia 

Department of Environmental Quality (VADEQ) on behalf of the Washington metropolitan area 

to demonstrate attainment of the 8-hour ozone NAAQS. The attainment modeling project was 

directed by the Technical Advisory Committee (TAC) and the Metropolitan Washington Air 

Quality Committee (MWAQC), a policy committee. EPA’s Community Multi-scale Air Quality 

(CMAQ) was the model used for the attainment demonstration. 

Table 10-1 identifies all jurisdictions that EPA has designated as non-attainment within the 

Washington MSA. 

MWAQC Ozone SIP 10-1 May 23, 2007 
Table 10-1. Washington MSA Designations for 8-hour Ozone Standard 

Jurisdiction Counties Classification

Maximum 

Attainment Date

(from June 15, 2004)

District of Columbia District of Columbia 

Maryland 

Calvert 

Charles 

Frederick 

Montgomery 

Prince George's

Virginia 

Alexandria City 

Arlington 

Fairfax City 

Fairfax 

Falls Church City 

Loudoun 

Manassas City 

Manassas Park City

Prince William

Moderate June 15, 2010 

The modeling 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 members of the committees for this study are also members of the OTC and ASIP 

modeling committees. This membership has allowed them to coordinate the analyses performed 

for Washington, D.C. with the regional modeling analyses conducted by OTC and ASIP. 

VADEQ, in consultation with the MDE, DCDOE, and MWCOG, was responsible for conducting 

CMAQ runs for the Washington, D.C. domain. VADEQ’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 the ASIP modeling, done for the southeastern states. 

Modeling centers for OTC included the New York State Department of Environmental 

Conservation (NYSDEC), the University of Maryland, NESCAUM and VADEQ. Technical 

support documents for the OTC modeling performed for the OTR are included in Appendix G. 

Modeling inventories were developed, updated and shared among the regional modeling centers 

and provided by MARAMA, MANE-VU and VISTAS. 

Installation of the models at VADEQ and all participating modeling centers was completed and 

diagnostic procedures were run successfully. The model has been benchmarked against other 

modeling platforms across the region to ensure accurate results. 

The Policy Committee and the TAC oversaw the modeling work and made appropriate reports to 

the full MWAQC through regular briefings and offered other information in cases where specific 

technical decisions had policy implications. The Technical Committee members and members of 

 

1

 Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, 

PM2.5, and Regional Haze (Draft 3.2- September 2006). 

MWAQC Ozone SIP 10-2 May 23, 2007 
other committees involved in the project who are also members of OTC and ASIP made sure to 

the extent practicable that there was consistency between the regional and urban modeling 

efforts. 

10.1.2 Conceptual Description 

EPA recommends that a conceptual description of the area’s ozone problem be developed prior 

to the initiation of any air quality modeling study. A “conceptual description” is a qualitative 

way of characterizing the nature of an area’s non-attainment problem. Within the conceptual 

description of a particular modeling exercise, it is recommended that the specific meteorological 

parameters that influence air quality be identified and qualitatively ranked in importance. 

The conceptual model for this study was prepared by the Northeast States for Coordinated Air 

Use Management (NESCAUM) for use by the OTC member States. The conceptual model 

document, 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 document 

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 modeling episodes seek to achieve a balance between 

good science and regulatory needs and constraints. Modeling episodes, once selected, influence 

technical and policy decisions for many years. Clearly, both the direct and implicit procedures 

used in selecting episodes warrant full consideration. 

The rationale for the selection of 2002 meteorology as input to the air quality simulations 

includes a qualitative analysis (Ryan and Piety 2002)2 and a quantitative analysis (Environ 

2005)3

. These documents are provided in Appendix G Attachment 2. 

Recent research has shown that model performance evaluations and the response to emissions 

controls need to consider modeling results from long time periods, in particular full synoptic 

cycles or even full ozone seasons. Based on this factor the entire ozone season was simulated for 

the 2002 and 2009 State Implementation Plan (SIP) modeling runs (May 1 to September 30). As 

a result, the total number of days examined for the complete ozone season far exceeds EPA 

recommendations, and provides for better assessment of the simulated pollutant fields. 

 

2 Ryan, W.F., Piety, C. 2002. Summary of 2002 Pollution Episodes in the Mid-Atlantic. The Pennsylvania State 

University Department of Meteorology, State College, Pennsylvania and the University of Maryland Department of 

Meteorology, College Park, Maryland. 

3

 Environ. 2005. Ozone Episode Classification Project for Ozone Transport Commission (Task 2b), Stoeckenius, T., 

Kemball-Cook, S, ENVIRON International Corporation, Novato, California. 

MWAQC Ozone SIP 10-3 May 23, 2007 
10.2.2. Size of the Modeling Domain 

In defining the modeling domain, one must consider the location of the local urban area, the 

downwind extent of the elevated ozone levels, the location of large emission sources, and the 

availability of meteorological and air quality data. The domain or spatial extent to be modeled 

includes as its core the non-attainment area. Beyond this, the domain includes enough of the 

surrounding area such that major upwind sources fall within the domain and emissions produced 

in the non-attainment area remain within the domain throughout the day. 

The boundaries of the modeling domain are provided in Appendix G Attachment 3. This domain 

covers the Northeast region including northeastern, central and southeastern US as well as 

Southeastern Canada. The final SIP modeling analysis utilized the modeling domain boundaries 

established by OTC. 

10.2.3 Horizontal Grid Size

The OTC platform used for the Washington, D.C. modeling analysis utilized a coarse grid 

continental United States (US) domain with a 36-km horizontal grid resolution. The CMAQ 

domain is nested in the MM5 domain. A larger MM5 domain was selected for both MM5 

simulations to provide a buffer of several grid cells around each boundary of the CMAQ 36 km

domain. This was designed to eliminate any errors in the meteorology from boundary effects in 

the MM5 simulation at the interface of the MM5 model. A 12-km inner domain was selected to 

better characterize air quality in OTC and surrounding Regional Planning Organization (RPO) 

regions. Appendix G Attachment 4 contains the horizontal grid definitions for the MM5 and 

CMAQ modeling domains. 

10.2.4 Vertical Resolution 

The CMAQ vertical structure is primarily defined by the vertical grid used in the MM5 

modeling. The MM5 model employed a terrain following coordinate system defined by pressure. 

The layer averaging scheme adopted for CMAQ is designed to reduce the computational cost of 

the CMAQ simulations. The effects of layer averaging have a relatively minor effect on the 

model performance metrics when compared to ambient monitoring data. 

Appendix G Attachment 5 contains the vertical layer definitions for the MM5 and CMAQ 

modeling domains. 

10.2.5 Initial and Boundary Conditions 

The objective of a photochemical grid model is to estimate the air quality given a set of 

meteorological and emissions conditions. When initializing a modeling simulation, the exact 

concentration fields are unknown in every grid cell for the start time. Therefore, typically 

photochemical grid models are started with clean conditions within the domain and allowed to 

stabilize before the period of interest is simulated. In practice this is accomplished by starting the 

model several days prior to the period of interest. 

The winds move pollutants into, out of, and within the domain. The model handles the 

movement of pollutants within the domain and out of the domain. An estimate of the quantity of

pollutants moving into the domain is needed. These are called boundary conditions. To estimate 

the boundary conditions for the modeling study, three-hourly boundary conditions for the outer 

36-km domain were derived from an annual model run performed by researchers at Harvard 

MWAQC Ozone SIP 10-4 May 23, 2007 
University using the GEOS-CHEM global chemistry transport model. The influence of boundary 

conditions was minimized 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 Center for Atmospheric Research (PSU/NCAR) 

Mesoscale Meteorological Model (MM5) was selected for application in the Washington, D.C. 

non-attainment modeling analysis. MM5 is a non-hydrostatic, prognostic meteorological model 

routinely used for urban- and regional-scale photochemical regulatory modeling studies. 

Based on model validation and sensitivity testing, the MM5 configurations provided in 

Appendix G Attachment 6 were selected. Results of the University of Maryland’s detailed 

performance evaluation of the MM5 modeling used in conjunction with the OTC platform are 

provided in Appendix G Attachment 7. 

10.2.7 Emissions Model Selection and Configuration

Significant coordination efforts took place between MANE-VU and VISTAS in the development 

of the emissions inventories used in the modeling study. All analyses conducted in support of the 

Washington, D.C. modeling analysis were coordinated between the Technical and Policy 

Committees along with TAC. 

These inventories include a base case (2002) which serves as the “parent” inventory off which 

all future year inventories (i.e., 2009) are based. The future year inventories include emissions 

growth due to any projected increase in economic activity as well as the implementation of 

control measures. Detailed descriptions of both base case 2002 and attainment year 2009 

inventories are provided in Attachment 12 and Attachment 13 respectively of the Appendix G. 

The Sparse Matrix Operator Kernel Emissions (SMOKE) Emissions Processing System was 

selected for application in the Washington, D.C. non-attainment area modeling analysis. 

SMOKE (Version 2.1) was used for the Washington DC attainment modeling demonstration. 

2002 base case and 2009 future base case emissions data files were provided by OTC and ASIP. 

Wherever possible, the mobile source emission inventories (in VMT format) were replaced with 

SCC-specific county level emissions to more accurately reflect actual emissions for typical 

ozone season day. 

A detailed description of all SMOKE input files such as area, mobile, fire, point and biogenic 

emissions files is provided in Appendix G Attachment 8. The SMOKE model configuration is 

also provided. 

MWAQC Ozone SIP 10-5 May 23, 2007 
10.2.8 Air Quality Model Selection and Configuration 

EPA’s Models-3/Community Multi-scale Air Quality (CMAQ) modeling system was selected 

for the attainment demonstration primarily because it is a “one-atmosphere” photochemical grid 

model capable of addressing ozone at regional scale and is considered one of the preferred 

models for regulatory modeling applications. The model is also recommended by the Guidance 

on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals 

for Ozone, PM2.5, and Regional Haze (Draft 3.2- September 2006). 

The CMAQ configuration is provided in Appendix G Attachment 9. 

10.2.9 Quality Assurance 

All air quality, emissions, and meteorological data were reviewed to ensure completeness, 

accuracy, and consistency before proceeding with modeling. Any errors, missing data or 

inconsistencies, were addressed using appropriate methods that are consistent with standard 

practices. All modeling was benchmarked through the duplication of a set of standard modeling 

results. 

Quality Assurance (QA) activities were carried out for the various emissions, meteorological, 

and photochemical modeling components of the modeling study. Emissions inventories obtained 

from the Regional Planning Organizations (RPO) were examined to check for errors in the 

emissions estimates. When such errors were discovered, the problems in the input data files were 

corrected. 

 

The MM5 meteorological and CMAQ air quality model inputs and outputs were plotted and 

examined to ensure accurate representation of the observed data in the model-ready fields, and 

temporal and spatial consistency and reasonableness. Both MM5 and CMAQ underwent 

operational and scientific evaluations in order to facilitate the quality assurance review of the 

meteorological and air quality modeling procedures and are discussed in greater detail 

throughout this document. 

10.3 Model Performance Evaluation 

There are many aspects of model performance. This section will focus primarily on the methods 

and techniques recommended by EPA for evaluating the performance of the air quality model. It 

should be noted that the other parts of the modeling process, the emissions and meteorology, also 

undergo an evaluation. It is with this knowledge and the desire to keep the report concise, that 

the air quality model became the primary focus of this section. 

The first step in the modeling process is to verify the model’s performance in terms of its ability 

to predict the ozone in the right locations and at the right levels. To do this, the model 

predictions for the base year simulation are compared to the ambient data observed in the 

historical episode. This verification is a combination of statistical and graphical evaluations. If 

the model appears to be producing ozone in the right locations for the right reasons, then the 

model can be used as a predictive tool to evaluate various control strategies and their effects on 

MWAQC Ozone SIP 10-6 May 23, 2007 
ozone. The purpose of the model performance evaluation is to assess how accurately the model 

predicts ozone levels observed in the historical episode. 

The results of a model performance evaluation were evaluated prior to using modeling to support 

the attainment demonstration. The performance of CMAQ was evaluated using both operational 

and diagnostic methods. Operational evaluation refers to the model’s ability to replicate 

observed concentrations of ozone and/or precursors (surface and aloft), whereas diagnostic 

evaluation assesses the model’s accuracy with respect to characterizing the sensitivity of ozone 

to changes in emissions (i.e., relative response factors). 

The New York State DEC, Division of Air Resources, conducted a performance evaluation of 

the 2002 base case CMAQ simulation (May 15-September 30) on behalf of the OTC member 

States. Appendix G Attachment 10 provides comprehensive operational and diagnostic 

evaluation results, including spreadsheets containing the assumptions made to compute statistics. 

Highlights of this evaluation are provided in the following sections. 

10.3.1 Diagnostic and Operational Evaluation 

The issue of model performance goals for ozone is an area of ongoing research and debate. To 

evaluate model performance, EPA recommends that several statistical metrics be developed for 

air quality modeling. Two of the common metrics that are most often used to assess performance 

are the mean normalized gross error and the mean normalized bias. The mean normalized gross 

error parameter provides an overall assessment of model performance and can be interpreted as 

precision, and the mean normalized bias parameter measures a model's ability to reproduce 

observed spatial and temporal patterns and can be interpreted as accuracy. EPA suggests the 

following criteria: a mean normalized bias (MNB) of < ±15%, and a mean normalized 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-attainment area and in Tables 10-3 and 10-4 on a monitor-by-monitor 

basis averaged over all days for the 40 ppb and 60 ppb thresholds. Figure 10-1 shows the 

location of the monitors. 

MWAQC Ozone SIP 10-7 May 23, 2007 
Table 10-2. Washington, D.C. MSA Statistics for 8-hour Ozone

Location 

Ozone Cutoff 

Threshold 

(ppb) 

Mean Normalized Gross Error 

(MNGE) 

(%) 

Mean Normalized Bias 

(MNB) 

(%) 

Washington, 40 13.34 -0.43

Table 10-3. Individual Site Statistics for 8-hour Ozone using 40 ppb Cutoff

AIRS ID Site Name Jurisdiction State MNGE 

(%) 

MNB 

(%) 

11-001-0025 Takoma District of Columbia --- 12.77 6.85

11-001-0041 River Terrace District of Columbia --- 12.08 -3.13

11-001-0043 McMillan District of Columbia --- 14.85 -12.04

24-009-0010 Calvert Calvert MD NA NA

24-017-0010 Southern MD Charles MD 12.3 0.55

24-021-0037 Frederick Municipal Airport Frederick MD 12.29 -0.22

24-031-3001 Rockville Montgomery MD 13.57 7.6

24-033-0002 Greenbelt Prince George's MD 12.82 1.54

24-033-8003 PG Equestrian Center Prince George's MD 13.48 3.38 

51-013-0020 Aurora Hills Arlington County VA 12.73 -6.33

51-059-0005 Chantilly Fairfax County VA 13.23 -8.31

51-059-0018 Mount Vernon Fairfax County VA 14.63 4.93

51-059-0030 Franconia Fairfax County VA 12.57 -3.57

51-059-1005 Annandale Fairfax County VA 12.01 -2.94

51-059-5001 McLean Fairfax County VA 17.87 11.99

51-107-1005 Ashburn Loudoun County VA 13.18 -8.54

51-153-0009 Long Park Prince William County VA 12.55 -4.23

51-510-0009 Alexandria Alexandria City VA 14.14 9.2

Table 10-4. Individual Site Statistics for 8-hr Ozone using 60 ppb Cutoff 

AIRS ID Site Name Jurisdiction State MNGE 

(%) 

MNB 

(%) 

11-001-0025 Takoma District of Columbia --- 9.37 2.8

11-001-0041 River Terrace District of Columbia --- 11.28 -7.57

11-001-0043 McMillan District of Columbia --- 15.61 -13.66

24-009-0010 Calvert Calvert MD NA NA

24-017-0010 Southern MD Charles MD 11.22 -5.62

24-021-0037 Frederick Municipal Airport Frederick MD 10.9 -4.27

24-031-3001 Rockville Montgomery MD 11.3 3.24

24-033-0002 Greenbelt Prince George's MD 11.42 -2.6

24-033-8003 PG Equestrian Center Prince George's MD 11.46 -3.87 

51-013-0020 Aurora Hills Arlington County VA 13.36 -9.79

51-059-0005 Chantilly Fairfax County VA 13.71 -12.57

51-059-0018 Mount Vernon Fairfax County VA 11.02 -2.63

51-059-0030 Franconia Fairfax County VA 11.99 -7.42

51-059-1005 Annandale Fairfax County VA 11.88 -7.5

51-059-5001 McLean Fairfax County VA 13.54 5.59

51-107-1005 Ashburn Loudoun County VA 14.18 -12.84

51-153-0009 Long Park Prince William County VA 12.6 -11.7

MWAQC Ozone SIP 10-8 May 23, 2007 
Figure 10-1. Location of Ozone Monitors in the Washington, D.C. Area 

The following statistics for the OTC domain have also been provided in Appendix G 

Attachment 11. 

1. Archive file containing time series of 8-hour average observed and predicted ozone 

organized by state. 

2. Observed and predicted composite diurnal variations of selected species, including but 

not limited to ozone at SLAMS/NAMS sites, ozone at CASTNet and other sites, VOC 

species such as ethene, isoprene, formaldehyde and gas phase compounds such as CO, 

NO and NO2. 

3. Statistical evaluation of daily maximum 8-hour ozone at SLAMS/NAMS sites and 

CASTNet/other sites; statistics are computed using two different thresholds for observed 

daily maximum ozone - 40 and 60 ppb; statistics are computed by date (all sites on a 

given day) and by site (one site over all days). 

4. Statistical evaluation of daily maximum 8-hour ozone at SLAMS/NAMS sites that fall 

within non-attainment counties; statistics are computed by non-attainment area. 

5. Statistical evaluation of daily average CO, NO, NO2, and SO2 at SLAMS/NAMS and 

other sites; statistics are computed by date and by site. 

6. Statistical evaluation of daily average ethene, isoprene, and formaldehyde at 

SLAMS/NAMS and other sites; statistics are computed by date and by site. 

MWAQC Ozone SIP 10-9 May 23, 2007 
7. Plots of composite time series for daily max 8-hour ozone, root mean square error and 

mean bias for illustrative purposes. 

8. Daily tile plots of daily 8-hour maximum predicted ozone across the modeling domain 

compared with actual observations. 

10.3.2 Summary of Model Performance 

CMAQ was employed to simulate ozone for the 2002 season (May 15 through September 30). A 

comparison of the temporal and spatial distributions of ozone and its precursors was conducted 

for the study domain with additional focus placed on performance in the Washington D.C. area. 

The CMAQ model performance for surface ozone is quite good with low bias and error. Model 

performance is generally consistent from day to day. The results the 2002 ozone season show 

that the modeling system tends to over-predict minimum concentrations and slightly underpredict peak concentrations. The over-prediction of minimum concentrations is not of great 

regulatory concern since attainment tests are based on the application of relative response factors 

to daily peak concentrations. It is still important to appropriately model the over-night ozone 

removal processes and regional transport to accurately estimate peak concentrations. 

The model performance for the Washington D.C. area averaged over all stations and all days 

meet the guidelines suggested by EPA. The criteria for acceptable model performance are met on 

most individual days as well. 

No significant differences in model performance for ozone and its precursors were encountered 

across the OTC. While there are some differences between the spatial data between sub-regions, 

there is nothing to suggest a tendency for the model to respond in a systematically different 

manner between regions. Examination of the statistical metrics by sub-region confirms the 

absence of significant performance problems arising in one area but not in another, building 

confidence that the CMAQ modeling system is operating consistently across the full OTC 

domain. 

The modeling system is doing a good job of appropriately estimating 8-hour average surface 

ozone throughout the OTC and in the Washington D.C. area. This confidence in the modeling 

results allows for the modeling system to be used to support the development of emissions 

control scenarios and State Implementation Plan to meet the 8-hour ozone NAAQS. 

10.4 Attainment Demonstration 

The Washington region’s demonstration of achieving the 8-hour ozone standard is based on two 

bodies of evidence: (1) the Community Multi-scale Air Quality Model (CMAQ) and (2) a 

number of WOE tests supporting the attainment modeling results. Details of both the CMAQ 

model and the WOE tests are provided below. 

MWAQC Ozone SIP 10-10 May 23, 2007 
10.4.1 Modeling Attainment Test 

The modeled attainment test applied at each monitor was performed using the following 

equation: 

(DVF)I = (RRF)I (DVB)I 

Where: 

(DVB)I = the baseline concentration monitored at site I, in ppb 

(RRF)I = the relative response factor (RRF), calculated near site I 

(DVF)I = the estimated future design value for the time attainment 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 Takoma District of Columbia --- 88.7 0.892 79 

11-001-0041 River Terrace District of Columbia --- 89.0 0.883 78 

11-001-0043 McMillan District of Columbia --- 92.7 0.883 81 

24-009-0010 Calvert Calvert MD NA 0.836 NA

24-017-0010 Southern MD Charles MD 93.0 0.808 75 

24-021-0037 Frederick Municipal 

Airport 

Frederick MD 87.3 0.846 73 

24-031-3001 Rockville Montgomery MD 86.7 0.881 76 

24-033-0002 Greenbelt Prince George's MD 94.0 0.869 81 

24-033-8003 PG Equestrian Center Prince George's MD 94.0 0.865 81 

51-013-0020 Aurora Hills Arlington County VA 96.7 0.891 86 

51-059-0005 Chantilly Fairfax County VA 87.0 0.867 75 

51-059-0018 Mount Vernon Fairfax County VA 96.7 0.883 85 

51-059-0030 Franconia Fairfax County VA 95.0 0.88 83 

51-059-1005 Annandale Fairfax County VA 94.0 0.88 82 

51-059-5001 McLean Fairfax County VA 88.0 0.883 77 

51-107-1005 Ashburn Loudoun County VA 90.0 0.869 78 

51-153-0009 Long Park Prince William

County

VA 85.0 0.871 74 

51-510-0009 Alexandria Alexandria City VA 90.0 0.883 79 

Current design values were calculated using the EPA method 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 monitoring site the following 

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. 

MWAQC Ozone SIP 10-11 May 23, 2007 
3. Less than 3 years of data – The site was not used in the attainment test. 

A 3x3 array of grid cells surrounding each monitor was used in the modeled attainment test as 

recommended by EPA for 12-km grid resolution modeling to calculate RRFs. 

The predicted 8-hour daily maximum concentrations from each modeled day were used in the 

modeled attainment test with the nearby grid cell with the highest predicted 8-hour daily 

maximum concentration with baseline emissions for each day considered in the test, and the grid 

cell with the highest predicted 8-hour daily maximum concentration with the future emissions for 

each day in the test. 

The RRFs used in the modeled attainment test were computed by taking the ratio of the mean of 

the 8-hour daily maximum predictions in the future to the mean of the 8-hour daily maximum

predictions with baseline emissions, over all relevant days. 

The following rules shall were applied to determine the number of days and the minimum

threshold at each ozone monitor: 

1. If there were 10 or more days with daily maximum 8-hour average modeled ozone > 85 ppb 

an 85 ppb threshold was used. 

2. If there was less than 10 days with daily maximum 8-hour average modeled ozone > 85 ppb 

the threshold was reduced to as low as 70 ppb until there was 10 days in the mean RRF 

calculation. 

3. If there was less than 10 days with daily maximum 8-hour average modeled ozone > 70 ppb 

then all days > 70 ppb were used. 

4. No RRF calculations shall be performed for sites with less than 5 days > 70 ppb. 

10.4.2 Unmonitored Area Analysis 

An “unmonitored area analysis” using model adjusted spatial fields was performed. The basic steps 

of this process were as follows: 

1. Interpolated ambient ozone design value data to create a set of spatial fields. 

2. Adjusted the spatial fields using gridded model output gradients (base year values). 

3. Applied gridded model RRFs to the model adjusted spatial fields. 

4. Determined if any unmonitored areas are predicted to exceed the NAAQS in the future. 

Recommended EPA guidance was utilized in the “unmonitored area analysis”. 

10.4.3 Emissions Inventories 

For areas with an attainment date of no later than June 15, 2010, the emission reductions need to 

be implemented no later than the beginning of the 2009 ozone season. A determination of 

attainment will likely be based on air quality monitoring data collected in 2007, 2008, and 2009. 

Therefore, the year to project future emissions should be no later than the last year of the three 

year monitoring period; in this case 2009. 

MWAQC Ozone SIP 10-12 May 23, 2007 
The 2002 base year emissions inventory were projected to 2009 using standard emissions 

projection techniques. Future year 2009 inventories were provided by two Regional Planning 

Organizations (RPO’s), the MidAtlantic Visibility Union (MANE-VU) and the Visibility 

Improvement State and Tribal Association of the Southeast (VISTAS) were used in the 

attainment demonstration. 

Emission inventory guidance documents were followed for developing projection year 

inventories for point, area, mobile, and biogenic emissions. These procedures addressed 

projections of spatial, temporal, and chemical composition change between the base year and 

projection year. 

The alternative control strategies for evaluation in the attainment demonstration were selected by 

MWAQC. These were selected from groups of strategies developed by the technical 

subcommittees responsible for identifying and developing the regulations and/or control 

measures. 

Consideration was given to maintaining consistency with control measures likely to be 

implemented by other modeling domains. Also, technology-based emission reduction 

requirements mandated by the Clean Air Act were included in the future year model runs. 

10.4.4 Attainment Modeling Results 

Applying EPA’s preferred methodology to CMAQ model results, the future design values for 

2009 shown in Table 10-5 indicate only two monitors will be at or slightly above 84 parts per 

billion (ppb). All other monitors (sixteen) will be below 85 ppb. These results place the 

Washington, DC-MD-VA region well within EPA’s range, 82-87 ppb, where WOE will 

contribute significantly to the region’s attainment demonstration.4

10.5 Weight of Evidence (WOE) Analysis 

All photochemical models including the CMAQ model has inherent uncertainties. Over or under 

prediction may result from uncertainties associated with emission inventories, meteorological 

data, and representation of ozone photochemistry in the model. Therefore, EPA photochemical 

modeling guidance document provides for other evidence (Weight of Evidence) to address these 

model uncertainties so that proper assessment of the probability to attain eight-hour ozone 

standard can be made. 

There were number of WOE tests employed to test the potential of Washington, 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 Attainment Demonstrations for the 8-hour Ozone NAAQS, 

EPA-454/R-05-002, October 2005, “Table 2-1: Guidance for Weight of Evidence Determinations,” p. 9. 

MWAQC Ozone SIP 10-13 May 23, 2007 
10.5.1 Trend in 8-hour Ozone 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 Ozone Design Value in the 

Washington, DC-MD-VA Nonattainment Area 

8-hour Ozone Design Value

Washington, D.C. Region, 1988-2006

0.115

0.107

0.100

0.100

0.101

0.096

0.098

0.094

0.100

0.101

0.106

0.101

0.097

0.097

0.099

0.096

0.091

0.091

0.116

0.075

0.085

0.095

0.105

0.115

0.125

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Year

Design Value (ppm)

8-hour Ozone NAAQS

MWAQC Ozone SIP 10-14 May 23, 2007 
10.5.2 Trend in Exceedance Count across All Monitors 

The trend in the total number of exceedances across all monitors between 1997 and 2006 is 

shown in Figure 10-3. Monitor exceedances occur whenever a monitor’s 8-hour ozone 

concentration is greater than or equal to 0.08 ppm. Though the number of monitors in the 

Washington, DC-MD-VA 8-hour nonattainment area has actually increased by 20 percent (15 in 

1997 to 18 in 2006), the number 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 

Exceedances of 8-hour Ozone Standard

Washington, D.C. Region, 1997-2006

30

48

40

11

22

38

8 8

20 21

5

30

55

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Year

Number of Exceedance Days

Note: Health Standard for 8-hour Ozone is 0.08 ppm. Data shown are the number of days in

each year when at least one monitor in the region recorded ground-level ozone concentrations 

above the 8-hour health standard.

MWAQC Ozone SIP 10-15 May 23, 2007 
10.5.3 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). Implementation of NOx 

SIP call has brought down significantly the nitrogen dioxide emissions 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 NO2 (Annual 

Mean Concentration) is 0.053 ppm and therefore the region is well below the standard. As NO2

is a very important factor in ozone formation, its decline over the years has been the one of the 

main 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 

Annual Average Nitrogen Dioxide Concentrations

Washington, DC Nonatainment Area, 1988-2006

0.030

0.030

0.028

0.029

0.030

0.026

0.026

0.026 0.027

0.025

0.023 0.024

0.025 0.026

0.024

0.024

0.031

0.019

0.030

0.015

0.020

0.025

0.030

0.035

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Year

Concentration (ppm)

MWAQC Ozone SIP 10-16 May 23, 2007 
10.5.4 Trend in Carbon Monoxide Levels 

The trend in carbon monoxide 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 monoxide does play a role in ozone formation and so its decline over the years has 

certainly helped reduce ozone levels in the region. 

Figure 10-5. Trend in 2nd High 1-Hour Carbon Monoxide Concentration in the 

Washington, DC-MD-VA Nonattainment Area 

2nd High 1-hour Carbon Monoxide Concentrations

Washington, DC Nonattainment Area, 1988-2006

13.7

13.7

13.6

9.7

11.4

9.8

10.2

8.1

8.9

7.3

7.5

6.6

6.3

7.5

8.3

4.0

3.8

4.0

13.4

2

4

6

8

10

12

14

16

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Year

Concentration (ppm)

MWAQC Ozone SIP 10-17 May 23, 2007 
10.5.5 Trend in VOC and NOx Emissions 

Comparison of VOC and NOx emissions 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 emissions are projected to decrease significantly in 

2008 and 2009 from 2002 levels. VOC emissions are projected to decrease between 2002 and 

2009 for area, nonroad and onroad sources. Point source VOC emission will be increasing a 

small amount bit in 2008 and 2009. 

Figure 10-7 shows that total NOx emissions are projected to decrease significantly in 2008 and 

2009 from 2002 levels. NOx emissions are projected to decrease between 2002 and 2009 for 

point, nonroad and onroad sources. Area source NOx emission will be increasing a small amount 

in 2008 and 2009. 

Figure 10-6. VOC Emissions in the Washington, DC-MD-VA Nonattainment Area 

VOC Emissions by Source

Washington, DC Nonattainment Area

12.91

192.64

125.79

448.28

116.94

359.03

92.48

70.98

181.59

13.98

348.74

88.66

66.68

179.10

14.31

0

100

200

300

400

500

Point Area Non-road On-road Total

E

mis

sions (tpd)

2002

2008

2009

MWAQC Ozone SIP 10-18 May 23, 2007 
Figure 10-7. NOx Emissions in the Washington, DC-MD-VA Nonattainment Area 

NOx Emissions by Source

Washington, DC Nonattainment Area

220.60

85.72

266.65

597.22

24.25

27.01

229.36

160.30

493.49

76.91

75.10

27.48

113.03

146.53

362.05

0

100

200

300

400

500

600

700

Point Area Non-road On-road Total

Emissions (tpd)

2002

2008

2009

10.5.6 Spatial Extent of NAAQS Violations 

The Washington, DC-MD-VA nonattainment area’s geographical extent of violation has been 

decreasing in size since 1990. Figure 10-8 shows a decrease in the spatial extent of the 

nonattainment zone within the Washington, DC-MD-VA nonattainment region between 1990 

and 2006. The actual nonattainment 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 almost entire 

Washington, DC metropolitan region was in nonattainment during 1988-1990. The 2004-2006 

data show that the geographical extent of this area has reduced in size to portions of the District 

of Columbia, the city of Alexandria, and Arlington, Fairfax, Prince Williams, Charles, Calvert, 

and Prince George's counties. Ozone levels observed in these areas are not only the product of 

local emissions but are also impacted a great deal by the transport of ozone and its precursors 

from upwind areas. Not only the nonattainment zone in 2006 has been reduced to less than half 

in size compared to 1990, but also the design value has also been reduced by about 16 percent 

from 108 ppb to 91 ppb. 

MWAQC Ozone SIP 10-19 May 23, 2007 
Figure 10-8. Comparison of Nonattainment Zones within 

Washington, DC-MD-VA Nonattainment Area (1990 – 2006) 

10.5.7 Trend in 8-Hour Ozone Exceedance Days and High Temperature Days

Ozone concentrations are quite dependent on meteorological conditions especially temperature. 

High temperatures help drive ozone production. Correlations can be made between ozone 

concentrations and meteorological variables such as the number of 90oF days. Hot dry summers 

can produce long periods of elevated ozone concentrations while ozone production can be 

limited during cool and wet summers. 

Temperature data from the Dulles International Airport were reviewed during years considered 

warmer than normal to determine any trends between 8-hour ozone values and high temperature 

days. The years analyzed were 1998, 2002, 2005, and 2006. During these years, there were more 

than 30 days when temperatures equaled or exceeded 90oF. Table 10-6 lists the number of 8-hour 

ozone exceedance days and the days with temperatures ≥ 90oF in each of the four years 

mentioned above in the Washington, DC-MD-VA nonattainment area. In comparing these years 

to 1998, there has been a decline of 21% (2002), 58% (2005) and 56% (2006) in the number of 

8-hour ozone exceedance days. The ratio of 8-hour exceedance days and days with maximum

temperature ≥ 90oF (fraction of the days with temperatures over 90oF that had exceedances) is 

also declining through these years. 

MWAQC Ozone SIP 10-20 May 23, 2007 
Table 10-6. Temperature and 8-Hour Ozone Exceedances in the 

Washington, DC-MD-VA Ozone Nonattainment Area 

Year 8-Hour Ozone

Exceedance Days

Days with Max. 

Temp ≥ 90oF 

Ratio of 8-Hour Exceedance Days

and days with Max. Temp ≥ 90oF 

1998 48 37 1.30

2002 38 41 0.92

2005 20 33 0.60

2006 21 37 0.57

Trend in the number of 8-hour ozone exceedance days and the number of days with maximum

temperature ≥ 90oF is shown in Figure 10-9. A close look at the Figure 10-9 reveals the number 

of ozone exceedance days on decline since 1998 even though the number of high temperature 

days has remained high and at more or less the same level in the four analysis years. The reason 

behind fewer ozone exceedance days after 1998 can be attributed to lower emission levels. While 

during 1998 temperatures below 90oF were able to cause an exceedance, beginning 1999 

exceedances occurred only when temperature reached more than 90oF due to lower emission 

levels. 

It is clear that the emission levels have been decreasing over the years and since 1999 they have 

been reduced to a level that the temperature must be more than 90oF in order to exceed. A 

number of federal control measures such as, Acid Rain Program (Phase 1 – 1996 & Phase 2 – 

2000) and NOx SIP Call (2004) were implemented during 1996-2004 to control emissions level. 

Also a wide range of local and regional control measures were implemented by Maryland, 

Virginia, and the District of Columbia beginning 1996, full benefits of which began in 1998. 

Emissions reductions from all the above mentioned measures combined resulted in the decrease 

in the number of ozone exceedance days since 1998. 

MWAQC Ozone SIP 10-21 May 23, 2007 
Figure 10-9. 8-Hour Ozone Exceedance Days and High Temperature Days (≥ 90oF) 

in the Washington, DC-MD-VA Nonattainment Area 

15

20

25

30

35

40

45

50

1998 1999 2002 2005 2006

Year

Nu

m

b

er of D

a

y

s

8-Hour Ozone Exceedance Days

90 Degree Days

10.5.8 Trend in Meteorology-Adjusted Ozone Levels 

Cox and Chu developed an advanced statistical technique, which allows the effects of 

meteorology (temperature, humidity, etc.) to be separated from the 8-hour ozone levels. EPA 

applied this technique at a number of monitors across the country to develop meteorology 

adjusted 8-hour daily maximum ozone levels and compared them to the observed 8-hour daily 

maximum 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.html. 

EPA performed this analysis for Washington, DC and Beltsville (Maryland) in Washington, DCMD-VA ozone non-attainment 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 emissions levels once the effect of 

meteorology has been removed. With emissions further projected to decline in 2009, ozone 

levels will also decline in the attainment year. 

MWAQC Ozone SIP 10-22 May 23, 2007 
Figure 10-10. Meteorology Adjusted Ozone Season Average 

8-Hour Daily Maximum Ozone Trend (1997-2005) 

Source: Cox, William M. and Shao-Hang Chu. (1996). “Assessment 

of Interannual Ozone Variation in Urban Areas from a 

Climatological Perspective.” Atmospheric Environment, 30.14, 

2615-2625. 

MWAQC Ozone SIP 10-23 May 23, 2007 
10.5.9 Alternative Design Value Calculation Techniques 

10.5.9.1 Methodologies for Calculating Baseline Design Values 

The baseline measured concentrations at each monitoring 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 determination of the 

estimated 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 methodologies to calculate baseline 

design values. Although EPA recommends 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 times in the calculation arbitrarily places too much weight on an 

individual year of meteorology and does not accurately reflect climate variability which has a 

significant impact on future design value projections. 

Ideally, a statistical model that analyzes the inter-annual variability of pollutant concentrations 

due solely to meteorology fluctuations5,6

should be used to predict the probability of future 

violation of the NAAQS at any monitoring site. In the absence of this statistical modeling 

analysis, a series of baseline design value calculations were performed in order to assess the 

effect on future design value projections. The following three calculation techniques were 

performed: 

1. EPA Recommended 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 number of available 

years of data. This approach provides a reasonable period of record to assess the interannual variability of meteorology without arbitrarily placing emphasis on any one year of 

meteorology. 

 

5

 Cox, William M. and Shao-Hang Chu. 1993. Meteorologically Adjusted Ozone Trends in Urban Areas: A 

Probabilistic Approach. Atmospheric Environment: Part B: Urban Atmosphere (ATMOS. ENVIRON., PART B). 

Vol. 27B, no. 4, pp. 425-434. 1993. 

6 Cox, William M. and Shao-Hang Chu. 1996. Assessment of Interannual Ozone Variation in Urban Areas from a 

Climatological Perspective. Atmospheric Environment: 30.14, 2615-2625. 

MWAQC Ozone SIP 10-24 May 23, 2007 
Table 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 

11-001-0025 Takoma District of Columbia --- 88.7 88 87.6 

11-001-0041 River Terrace District of Columbia --- 89.0 92 85.2 

11-001-0043 McMillan District of Columbia --- 92.7 94 89.6 

24-009-0010 Calvert Calvert MD NA NA NA

24-017-0010 Southern MD Charles MD 93.0 94 91.6

24-021-0037 Frederick Municipal Airport Frederick MD 87.3 88 85.8

24-031-3001 Rockville Montgomery MD 86.7 88 85.2

24-033-0002 Greenbelt Prince George's MD 94.0 93 92.5 

24-033-8003 PG Equestrian Center Prince George's MD 94.0 NA 94.7 

51-013-0020 Aurora Hills Arlington County VA 96.7 99 92.8 

51-059-0005 Chantilly Fairfax County VA 87.0 89 85.2 

51-059-0018 Mount Vernon Fairfax County VA 96.7 97 95.4 

51-059-0030 Franconia Fairfax County VA 95.0 97 91.8 

51-059-1005 Annandale Fairfax County VA 94.0 NA 94.0 

51-059-5001 McLean Fairfax County VA 88.0 88 86.0 

51-107-1005 Ashburn Loudoun County VA 90.0 92 87.0 

51-153-0009 Long Park Prince William County VA 85.0 87 83.6 

51-510-0009 Alexandria 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 impact on future design value projections. RRF 

calculations for each of the following techniques are provided in Table 10-8. 

1. EPA Recommended Method – Utilizes the default recommendations for “nearby” grid 

cells, with a 3x3 grid cell array for 12-km resolution modeling. The relative response 

factor (RRF) used in the modeled attainment test is computed by taking the ratio of the 

mean of the 8-hour daily maximum predictions in the future to the mean of the 8-hour 

daily maximum predictions with baseline emissions, over all relevant days. 

EPA recommends this approach because of the following three reasons: 

a. Consequence of a control strategy may be “migration” of a predicted peak. If a State 

were to confine its attention only to the cell containing a monitor, it might 

underestimate the RRF (i.e., overestimate the effects of a control strategy). 

b. Uncertainty in the formulation of the model and the model inputs is consistent with 

recognizing some leeway in the precision of the predicted location of daily maximum

ozone concentrations. 

MWAQC Ozone SIP 10-25 May 23, 2007 
c. Standard practice in defining a gridded modeling domain is to start in the southwest 

corner of the domain, and determine grid cell location from there. Considering 

several cells “near” a monitor rather than the single cell containing the monitor 

diminishes the likelihood of inappropriate results which may occur from the geometry 

of the superimposed grid system. 

2. Grid Cell Average Technique – Utilizes the default recommendations for “nearby” grid 

cells, with a 3x3 grid cell array for 12-km resolution modeling. The relative response 

factor (RRF) used in the modeled attainment test is computed by taking the ratio of the 

mean of the 8-hour daily maximum predictions averaged across the 3x3 grid cell array 

surrounding the monitor in the future to the mean of the 8-hour daily maximum

predictions averaged across the 3x3 grid cell array surrounding the monitor with baseline 

emissions, over all relevant days. 

The following rules shall were applied to determine the number of days and the minimum

threshold at each ozone monitor: 

a. If there were 10 or more days with daily maximum 8-hour average modeled 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 maximum 8-hour average modeled 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 mean RRF calculation. 

c. If there was less than 10 days with daily maximum 8-hour average modeled ozone > 

70 ppb, averaged over the 3x3 grid cell array, then all days > 70 ppb was used. 

d. No RRF calculations shall be performed 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 

maximum surrounding the monitor exceeds 85 ppb and excludes the evaluation of days 

that have an isolated peak or a tight concentration gradient in the vicinity of the monitor 

that can be difficult to model. 

3. Grid Cell Only Technique – Utilizes the grid cell where the monitor is located and does 

not employ an array of grid cells surrounding the monitor. The relative response factor 

(RRF) used in the modeled attainment test is computed by taking the ratio of the mean of 

the 8-hour daily maximum predictions in the future to the mean of the 8-hour daily 

maximum predictions with baseline emissions, over all relevant days. 

There are a few reasons why it might be appropriate to use this technique: 

a. There are occasions where the use of unmonitored grid cells nearby a monitor may 

not adequately characterize what is happening at the monitor. 

b. Model performance evaluations (MPE) are only conducted for the grid cells 

containing monitors; therefore, it may be beneficial to have the model attainment test 

remain consistent with the MPE and only use these grid cells. 

MWAQC Ozone SIP 10-26 May 23, 2007 
c. Calculating RRFs based on nearby cells that change locations between the baseline 

simulation and future simulation (not paired in space) may lead to erroneous and 

misleading 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 

11-001-0025 Takoma District of Columbia --- 0.892 0.874 0.886

11-001-0041 River Terrace District of Columbia --- 0.883 0.872 0.909

11-001-0043 McMillan District of Columbia --- 0.883 0.872 0.909

24-009-0010 Calvert Calvert MD 0.836 0.815 0.81

24-017-0010 Southern MD Charles MD 0.808 0.806 0.794

24-021-0037 Frederick Municipal Airport Frederick MD 0.846 0.833 0.844

24-031-3001 Rockville Montgomery MD 0.881 0.861 0.86

24-033-0002 Greenbelt Prince George's MD 0.869 0.857 0.857

24-033-8003 PG Equestrian Center Prince George's MD 0.865 0.838 0.837

51-013-0020 Aurora Hills Arlington County VA 0.891 0.875 0.893

51-059-0005 Chantilly Fairfax County VA 0.867 0.858 0.888

51-059-0018 Mount Vernon Fairfax County VA 0.883 0.872 0.868

51-059-0030 Franconia Fairfax County VA 0.88 0.873 0.877

51-059-1005 Annandale Fairfax County VA 0.88 0.873 0.877

51-059-5001 McLean Fairfax County VA 0.883 0.869 0.864

51-107-1005 Ashburn Loudoun County VA 0.869 0.872 0.874

51-153-0009 Long Park Prince William County VA 0.871 0.865 0.866

51-510-0009 Alexandria Alexandria City VA 0.883 0.872 0.868

10.5.9.3 Future Design Value Ranges 

In order to assess the sensitivity of the future design value calculations, a matrix using relative 

response factor and base design values. This results in 9 combinations of future design values for 

each monitor, except where missing data is noted. A summary of the minimum and maximum

DVFs for each monitor is provided in Table 10-9. 

The minimum DVFs for all monitors fall below the 85 ppb attainment threshold. It is also 

important to note that there is a high degree of sensitivity in the DVF calculations for the 

Arlington County monitor, where the range is from 81 ppb to 88 ppb. Detailed calculations are 

provided in Appendix G Attachment 11 for all runs conducted by the OTC, ASIP, and VADEQ. 

MWAQC Ozone SIP 10-27 May 23, 2007 
Table 10-9. Future Design Value Ranges (BOTW +VA CAIR Modeling Run) 

AIRS ID Site Name Jurisdiction State Minimum 

DVF 

Maximum 

DVF 

11-001-0025 Takoma District of Columbia --- 76 79 

11-001-0041 River Terrace District of Columbia --- 74 83 

11-001-0043 McMillan District of Columbia --- 78 84 

24-009-0010 Calvert Calvert MD NA NA

24-017-0010 Southern MD Charles MD 72 75 

24-021-0037 Frederick Municipal Airport Frederick MD 71 74 

24-031-3001 Rockville Montgomery MD 73 77 

24-033-0002 Greenbelt Prince George's MD 79 81 

24-033-8003 PG Equestrian Center Prince George's MD 78 81 

51-013-0020 Aurora Hills Arlington County VA 81 88 

51-059-0005 Chantilly Fairfax County VA 73 79 

51-059-0018 Mount Vernon Fairfax County VA 82 85 

51-059-0030 Franconia Fairfax County VA 80 85 

51-059-1005 Annandale Fairfax County VA 82 82 

51-059-5001 McLean Fairfax County VA 74 77 

51-107-1005 Ashburn Loudoun County VA 75 80 

51-153-0009 Long Park Prince William County VA 72 75 

51-510-0009 Alexandria 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 modeling tool used to predict future ozone concentrations 

for use in attainment demonstrations. The University of Maryland assessed the model’s 

performance and examined the implications for the attainment demonstration and weight of 

evidence. The University of Maryland’s research complements the model performance 

evaluation conducted by the Virginia Dept. of Environmental Quality and described in Section 

10.3. The University of Maryland Department of Meteorology’s research is summarized below. 

Details of this research are in Appendix G Attachment 15. 

10.5.10.2 Analysis of Model Performance 

The University of Maryland found that CMAQ does an excellent job of capturing the mean 

distribution of surface layer ozone during the ozone season. However, their research identified 

several characteristics of the model that could impact the conclusions of the attainment modeling 

results. The University of Maryland analyses involved comparisons of surface and aircraft 

ozone measurements and CMAQ ozone simulations. As described in more detail in Appendix G, 

the results of these analyses indicate the following: 

• CMAQ underestimates ozone concentrations in upwind areas 

• CMAQ underestimates ozone concentrations aloft 

• CMAQ overestimates ozone formation in urban areas 

MWAQC Ozone SIP 10-28 May 23, 2007 
• CMAQ biases in upwind areas are larger when air quality is poor 

• CMAQ underestimates the contribution of transported pollution on concentrations within 

the nonattainment area 

• CMAQ underestimates the importance of NOx controls in upwind areas. 

CMAQ Underestimates Ozone Concentrations in Upwind Areas. CMAQ exhibits its best 

performance in urban areas (small bias), less success in suburban areas (underestimates ozone, a 

larger negative bias), and its worst performance in rural areas (underestimates ozone more, larger 

negative bias). The model’s performance 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 comparison to aircraft observations, the base-case 

model run underestimates the rate of photochemical smog production above about 500 m and 

overestimates it below this altitude. 

CMAQ Overpredicts Ozone Formation in Urban Areas. The CMAQ model tends to 

overestimate the rate of formation and concentration of ozone, especially in VOC-rich urban 

plumes. The overall chemistry may therefore be more NOx-limited than CMAQ would suggest. It 

is believed that the CB4 mechanism used in the version of CMAQ run for this SIP is simplified 

and missing reactions that were thought to be inconsequential, but are now known or in some

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 

measured 8-hour ozone concentrations are minimal (1-2 ppbv) when averaged over the summer 

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 examined using a combination of aircraft and ground-based 

measurements. These aircraft observations indicate that CMAQ underestimates transport. The 

research indicates that when upwind pollution source regions lay over the Ohio River Valley 

(~59% of aircraft profiles), transport accounted for 69-82 percent of the afternoon boundary 

layer ozone.5 When 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 monitoring stations has also been examined for 

evidence of downward mixing. 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 times greater than that due to pure 

photochemistry. 

MWAQC Ozone SIP 10-29 May 23, 2007 
CMAQ Underestimates the Importance of Reducing Upwind NOx Emissions and 

Overestimates the Significance of Local Sources. Several studies suggest that CMAQ, and 

likely photochemical models in general, under-predict the change in ozone concentrations that 

result from a change in NOx emissions, particularly those from upwind power plants (and large 

industrial sources). CMAQ shows that although model simulated NOx reductions result in ozone 

reductions, the percentage reductions in ozone were smaller than the percentage reductions in 

NOx. 

Even when compared to results from within the 2002 ozone season, CMAQ under- predicts daily 

ozone variability, and shows important model performance issues in areas just upwind of

Maryland on high ozone days, namely 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 emissions), and likely 

considerably more, while a modeling study of the same event [Hu et al., 2006] used CMAQ to 

predict only a 2.2 ppbv change. 

Analysis of ozone trends before and after the NOx SIP Call reveals that Maryland’s ozone 

improved significantly after the NOx SIP Call. Ozone values were binned according to peak 

temperature to remove most of the effects of meteorology from the analysis, revealing a 

consistent 12 percent downward trend in ozone after the SIP Call. An ongoing study by EPA 

reveals that the NOx SIP call likely produced double the benefit that CMAQ predicted. 

10.5.10.3 Implications of CMAQ Performance on Attainment Demonstration 

Demonstrated issues with CMAQ’s performance, particularly with respect to extreme values and 

transport, imply that CMAQ predicted future ozone concentrations are overestimated for the 

Washington, DC-MD-VA non-attainment area. The results imply that the Washington, DC-MDVA region may be more likely to comply with the ozone standard than the model indicates. 

The transport of pollutants from areas outside the region has an extremely important impact on 

the attainment of the 8-hour ozone standard. The evidence from both the aircraft and the station 

ozone data clearly points to the importance of transport in the overall quality of the air in the 

Washington region.7 Upwind power plant emission sources of NOx and SO2 from West Virginia, 

Ohio, and Pennsylvania along the Ohio River Valley play a crucial role in the amount of ozone 

and aerosol measured in the lower troposphere in the Mid-Atlantic region. Due to the higher 

stack heights of power plants these emissions are more 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 time 

interval over which the ozone levels may exceed 85 ppbv. 

In some instances, emissions in the rural/suburban areas upwind of the Washington region are 

dominated by power-plant emissions. The analysis indicates that ozone after the NOx SIP Call 

improved significantly, suggesting that future control programs similar to those implemented 

 

7

 The study of the relative contribution of transported and local photochemistry to the ozone data for six exceedance 

days in August 2002 suggests that if local photochemistry were the only source of ozone, none of the 6 days 

examined would have exceeded the 8-hour ozone standard. 

MWAQC Ozone SIP 10-30 May 23, 2007 
over this time period should be highly effective as well. This suggests that NOx controls, and 

especially power plant controls are likely to be similarly effective in controlling ozone in the 

future. 

The research also suggests that regional control programs should be more effective than 

predicted by CMAQ and local programs somewhat less effective. Since the bulk of the control 

programs in the SIP are regional (e.g. fleet turnover, 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 emissions. 

10.5.11 Local Government Voluntary Initiatives 

In addition to participating in Clean Air Partners programs (described in the following sections), 

the local governments and state agencies in the Washington region have taken a coordinated, 

proactive approach to reducing emissions attributable to their organizations on an episodic basis. 

These actions reduce VOC and NOx emissions from a variety of source sectors. Programs 

include: 

• Local jurisdictions have committed to purchasing low-emission vehicles reducing 

emissions from on-road sources. 

• Shutdowns of county waste-to-energy facilities reduce stationary source emissions. 

• Reducing emissions from peaking units that generate electricity can reduce NOx 

emissions during periods of poor air quality. 

• State agencies and county governments ban refueling of non-emergency fleet vehicles and 

application of traffic paint and pesticides, eliminating area source emissions. 

• Many of these organizations also ban operation of lawn and garden equipment to reduce 

non-road emissions. 

• Mobile emissions are reduced through liberal leave policies and support for teleworking 

on Code Red Days. 

• Tree planting programs are being developed by the local jurisdictions in the region as a 

long term strategy to improve air quality. 

Local jurisdictions in the Washington region are making program commitments reflected in the 

Voluntary Bundle (Chapter 6) or, in the case of low-emission vehicle purchases, are reserving 

emission reduction credits that the purchases may generate for potential future use in meeting 

transportation conformity. The City of Alexandria has specifically requested that a variety of 

programs being implemented by the city, including low-emission vehicle purchases, use of lowVOC paints, Green Building and energy efficiency programs, and episodic programs, be applied 

in the SIP as weight of evidence. 

Though the benefits of episodic programs are not reflected in the region’s 2009 controlled 

inventory, the programs are an important part of the region’s attainment strategy and provide 

additional evidence that the region will attain the ozone standard in 2009. 

MWAQC Ozone SIP 10-31 May 23, 2007 
10.5.11.1 Voluntary Action Campaign: Clean Air Partners 

Clean Air Partners is a bi-regional public-private partnership in the Baltimore Washington region 

created to develop and implement voluntary action programs to reduce emissions on the days 

when ozone levels are expected to be high. 

The partnership was created in 1994 by the Metropolitan Washington Air Quality Committee 

(MWAQC), the Transportation Planning Board of the National Capitol Region (TPB) and the 

Baltimore Metropolitan Council (BMC). The partnership, originally known as ENDZONE 

Partners, has conducted an air quality public education campaign in the Washington and 

Baltimore metropolitan areas since 1995. The purposes of the campaign are to raise public 

awareness of air quality issues and to promote voluntary actions to improve air quality. The 

campaign is funded by public funds from Maryland, Virginia, the and District of Columbia, and 

receives staff support from the state air management agencies. In 1997 the partnership formed a 

new formal public-private partnership, hired a managing director, and in 1999 changed its name

to Clean Air Partners. 

The Ozone Action Days employer program was established in 1995 in the 

Baltimore/Washington region. This program encourages employers and their employees to take 

voluntary actions to reduce ozone pollution causing emissions. When the Environmental 

Protection Agency (EPA) designated both Baltimore and Washington, DC metropolitan regions 

as nonattainment for fine particles, Clean Air Partners’ Board of Directors changed the name of 

the program from Ozone Action Days to Air Quality Action Days (AQAD). 

The AQAD program is designed to educate employers and employees to take voluntary actions, 

specifically on Code Red days. It was argued that voluntary actions taken on the worst days of 

summer would “shave the peaks,” or reduce the high ozone levels on the worst days. Clean Air 

Partners provides resources and information to a network of AQAD participants. Clean Air 

Partners assists employers in establishing on-site programs designed to reduce employee travel 

on bad air days; and encourages voluntary actions by business, industry, government, and 

individuals to restrict activities that contribute to the formation and risks of bad air. 

Approximately 600 employers and individuals are registered as AQAD participants and have 

committed to take voluntary actions to reduce emissions on Code Red days. 

Clean Air Partners runs an extensive education campaign throughout the ozone season, May to 

September, to educate the public about the effects of ground-level ozone and fine particles. The 

messages tell people what they can do to protect their health and improve air quality. Air quality 

forecasts are distributed daily by fax and email to the media and Air Quality Action Days 

participants. The air quality forecast is color-coded for ease of communication, following EPA’s 

regulation for the Air Quality Index (AQI). 

During the ozone season, in addition to communicating daily with television and radio 

meteorologists in the regions, Clean Air Partners places radio and television ads to advise about 

the health risks and to promote less polluting behaviors on unhealthy air days. The ad messages 

target individual emission reduction actions for behavior modification and the heath effects of 

poor air quality. 

MWAQC Ozone SIP 10-32 May 23, 2007 
Evaluation of Voluntary Action Campaign 

Despite improvements in the region’s air quality, new challenges lie ahead for the AQAD 

employer 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. When EPA set 

the 8-hour ozone standard to coincide with the Code Orange Air Quality Index it resulted in 

approximately 20 or more days per year that exceed the standard. 

Typically Clean Air Partners conducts surveys to determine the effectiveness and reach of its 

message. 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 times since 1995, is used to estimate the potential for 

behavior change and to help target the right messages. Episodic surveys began in the summer of 

1999. The objective of the episodic survey is to determine if the Clean Air Partners’ message is 

being heard and if the potential for behavior change 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 most reliable measure of behavior in 

response to the campaign. 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 make a 

difference. 

Trends in Survey Results 

Data from the two types of surveys indicate that general knowledge levels about air quality and 

its measurement systems increased substantially in both metropolitan areas during the five years 

studied, 1996-2001. Knowledge that Code Red indicates unhealthy air when activity should be 

limited 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 means “air is unhealthy.” 

The end-of-season survey results for the Washington metropolitan 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 message 

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 common 

Avoidance of health risk is most common reason for behavior change (66%); second reason is to 

reduce emissions (17 percent).8

 

8 “An Analysis of Air Pollution-Related Knowledge, Attitudes, and Behaviors Across Time: The End of Season and 

Episodic Surveys,” Fox, J. Clifford and Mousumi Sarkar, Virginia Commonwealth University, December 2002, 

prepared for Clean Air Partners. 

MWAQC Ozone SIP 10-33 May 23, 2007 
10.5.11.2 Code Red/Code Orange Telework Program 

Clean Air Partners is adopting a new program to increase teleworking as an episodic strategy. 

Beginning in the summer of 2007, Clean Air Partners will promote teleworking throughout 

government 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 Department of the Environment and the Metropolitan Council of Governments for 

the Washington region. 

Clean Air Partners will develop a toolkit that will assist organizations in promoting, 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 emission reductions resulting from teleworking (NOx, VOC, 

CO, and CO2). 

The University of Maryland (UM) will evaluate the telework program through photochemical 

modeling by using different assumptions regarding the programs effectiveness at reducing 

Vehicle Miles Traveled (VMT). Preliminary UM modeling indicates that a strengthened 

telework program has the potential to reduce VMT and thereby leads to a measurable ozone 

reduction on the worst days of summer (see Appendix G Attachment 14) 

10.5.11.3 High Electrical Demand Day Emission Reduction Strategies 

Emissions from Electric Generating Units (EGUs) are higher on high electric demand days, 

resulting in poorer air quality. High electrical demand day (HEDD) operation of EGUs generally 

have not been addressed under existing air quality control requirements, and these units are 

called into service on the very hot days of summer and on very cold days of winter when air 

pollution levels typically reach their peaks. 

The Ozone Transport Commission (OTC) has been meeting with state environmental and utility 

regulators, EPA staff, EGU owners and operators and the independent regional systems 

operators to assess emissions associated with HEDD during the ozone season and to address 

excess NOx emissions on HEDDs. The OTC has found that NOx emissions are much higher on a 

high electrical demand day than on a typical summer day and there is the potential to reduce 

HEDD emissions by approximately 25 percent in the short term through the application of 

known control technologies. HEDD units consists of gasoline and diesel combustion 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 emissions associated with 

HEDD units on high electrical demand 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. 

 

MWAQC Ozone SIP 10-34 May 23, 2007 
On March 2, 2007, the OTC states and the District of Columbia agreed to a Memorandum of 

Understanding (MOU) committing to reductions from the HEDD source sector. The MOU 

includes specific targets for a group of six states to achieve reductions in NOx emissions 

associated with HEDD units on high electrical demand 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 remaining OTC states including Virginia and the 

District of Columbia agreed to continue to review the HEDD program and seek reductions where 

possible but they do not have a formal emissions reduction target in the MOU. 

Through the HEDD MOU commitments, significant NOx reductions are anticipated in the 

Washington DC-MD-VA ozone nonattainment area from the program Maryland expects to 

develop with EGUs. Maryland has agreed to a specific NOx emission reduction target in the 

MOU of a state-wide reduction of NOx emissions from HEDD units by 32 percent, or an 

estimated 23.5 tons per day. The OTC MOU is included in Appendix G. 

10.5.11.4 Tree Canopy Programs 

Large-scale tree-planting programs offer a method to improve air quality across the Washington, 

DC-MD-VA ozone non-attainment area. Tree cover in urban areas plays an important role in the 

complex 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 modified areas as well. These changes are 

the result of the lessening of the urban “heat island” effect. Heat islands form as cities replace 

natural land cover with pavement, buildings, and other infrastructure. The heat in a heat island is 

the result of the different radiative properties (i.e. the ability of objects to absorb and/or reflect 

the sun’s energy) between urban and rural areas. Urban areas are more efficient at absorbing 

sunlight than rural areas. The excess energy absorbed by urban areas is eventually reradiated 

back to the atmosphere in the form of heat (aka infrared radiation). Weakening of the heat island 

effect results in a transfer of energy from the urban areas to downwind areas which causes some

locations to observe a slight increase in surface temperatures (1-2 °C) and in wind speeds (1-2 

ms-1). 

The general consensus from the studies mentioned 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 modeled temperature changes are accompanied by changes in ground level 

ozone concentrations. Owing to the complexity of the system, changes in ozone, like 

temperature, are not confined to locations where trees are planted. Different locations downwind 

of modified areas observed either increased or decreased ozone levels depending on a variety of 

factors. The reduction of surface temperature (specifically, cooling in urban areas) obtained 

from the numerical modeling studies was used as the basis for predicting changes in daily mean 

peak 8-hour ozone levels derived from a multiple linear regression model for the Baltimore NonAttainment Area. 

A large-scale tree-planting program may lead to improved 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 

MWAQC Ozone SIP 10-35 May 23, 2007 
trees used to reforest is important, but what species of tree offers the most benefit is not clear and 

may differ from locale to locale. Other significant, logistical questions also need to be 

considered when planning a large-scale tree planting program. In the near term, this analysis 

points to the importance of programs to maintain tree cover and prevent increases in ozone due 

to loss of tree cover. 

10.6 Summary and Conclusions of Attainment Demonstration 

The photochemical modeling combined 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 

Documents, technical memorandums, and data bases developed in this study are available for 

distribution as appropriate. This report contains the essential methods and results of the 

conceptual model, episode selection, modeling protocol, base case model development and 

performance testing, future year and control strategy modeling, quality assurance, WOE 

analyses, and calculation of 8-hr ozone attainment via EPA’s relative response factor (RRF) 

methodology. 

10.7.2 Data Archival and Transfer of Modeling Files 

All relevant data sets, model codes, scripts, and related software required by any project 

participant necessary to corroborate the study findings (e.g., performance evaluations, control 

strategy runs) will be provided in an electronic format approved by the Technical Committee 

within the framework of MWAQC. The Technical Committee has archived all modeling data 

relevant to this project. Transfer of data may be facilitated through the combination of a project 

website and the transfer of large databases via overnight mail. Database transfers will be 

accomplished using an ftp protocol for smaller datasets, and the use of IDE and Firewire disk 

drives for larger data sets. 

MWAQC Ozone SIP 10-36 May 23, 2007 
11.0 CONTINGENCY PLAN 

The General Preamble and EPA guidance defines the requirements for identification of

contingency measures for rate-of-progress and attainment demonstrations. For post-1996 

rate-of-progress and attainment demonstrations, contingency measures may reduce 

emissions of either VOC or NOx. Contingency measures are required for each milestone 

year. Air quality plans must include sufficient contingency measures to account for up to 

3% of the base-year inventory adjusted to the appropriate milestone year. 

11.1 Contingency Measures for the 2008 (RFP) Further Progress Demonstration 

11.1.1 Background 

EPA requires the Washington region to include a contingency plan containing adopted 

measures that qualify as contingency measures for the 2002-2008 Reasonable Further 

Progress (RFP). This section fulfills the requirement for the RFP contingency. 

11.1.2 Required Reductions 

The contingency measures for the 2008 RFP and attainment demonstrations must total 

3% of the 2002 adjusted base year inventory. A minimum of 0.3 percent VOC must be 

included. The inventory is calculated as described in Sections 4 and 5. Table 11-1 shows 

the calculation of the necessary reductions. 

Table 11-1 

Calculation of VOC and NOx Reductions 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

Contingency reductions must occur on a timetable that is directly related to the RFP SIP 

schedule. States have no more than one year after notification by EPA of an RFP failure 

to achieve the contingency plan reductions. For a potential RFP failure, notification 

would be received in 2009, therefore the contingency reductions must be achieved no 

later than 2010. 

MWAQC Ozone SIP 11-1 May 23, 2007
11.1.3 Identified Contingency Measures

Table 11-2 lists the contingency measure identified by the District of Columbia, 

Maryland and Virginia for the 2008 RFP demonstration. This measure delivers a total 

benefit of 1.3 tons per day (tpd) VOC and 15.3 tpd NOx. The combined reduction equals 

3% of the Adjusted Base Year Inventory, therefore meeting the contingency measure 

requirement calculated in Table 11-1. 

Table 11-2 

Contingency Measures for 2008 Reasonable Further Progress (RFP) 

(Ozone Season 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 

1.31 0

6.1.2 Regional Transport NOx Reductions (Clean Air 

Interstate Rule, Healthy Air Act) 

0 15.3

TOTAL REDUCTIONS 1.31 15.3

In accordance with EPA’s guidance encouraging early implementation of contingency 

measures to guard against failure to either meet a milestone or attain, the District of 

Columbia, Maryland and Virginia will implement the contingency measures identified in 

Table 11-3 according to the timetable indicated in Chapters 6 and 9. EPA’s guidance on 

early implementation of control measures is as follows: 

The EPA encourages the early implementation of required control 

measures and of contingency measures as a means of guarding against 

failures to meet a milestone or to attain. Any implemented measures (that 

are not needed for the rate-of-progress requirements or for the attainment 

requirements) would need to be backfilled only to the extent they are used

to meet a milestone. 

The reductions from the designated contingency measures are surplus vis-à-vis the RFP 

demonstration contained in this SIP. They will not be used to meet that milestone 

requirement. As a result, the states will not be required to backfill any contingency 

measures that they choose to implement in advance of the requirement. 

11.1.4 Portable Fuel Containers Rule: Phase I and Phase II 

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

The standards are intended to reduce emissions from storage, transport and refueling 

activities. The rule also included administrative and labeling requirements. Compliant 

containers must have: only one opening for both pouring and filling, an automatic shutoff to prevent overfill, an automatic sealing mechanism when not dispensing fuel and 

specified fuel flow rates, permeation rates and warranties. 

MWAQC Ozone SIP 11-2 May 23, 2007
Source Type Affected

Any person or entity selling, supplying or manufacturing portable fuel containers, except 

containers with a capacity of less than or equal to one quart, rapid refueling devices with 

capacities greater than or equal to four gallons, safety cans and portable marine fuel tanks 

operating with outboard motors, and products resulting in cumulative VOC emissions 

below those of a representative container or spout. 

Control Strategy 

Maryland, the District, and Virginia all adopted Phase I and are in the process of adopting 

Phase II of the OTC Model Rule for Portable Fuel Containers. 

Implementation 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental Quality 

District of Columbia - Department of Environment 

Projected Reductions

VOC Emission Reductions (tons per day)

District 

of Columbia Maryland Virginia Total 

VOC Reductions 0 0.83 0.48 1.31 

Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 75% after full 

implementation after 10 years. Implementation began in 2005. In 2008, the emission 

reduction factor is 30%. In 2009, the emission reduction factor is 37.5%. Phase II 

reductions are based on an additional 4 percent reduction in emissions of VOC. 

Note that the District's OTC VOC rules on all the applicable area source categories are or 

will be fully adopted, submitted to EPA, and federally enforceable measures. However, 

the emission reductions 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 additional enhancements to the air quality improvement 

in the region. 

MWAQC Ozone SIP 11-3 May 23, 2007
11.1.5 Regional NOx Transport Requirements 

This section documents contingency credit for NOx emissions reductions attributable to 

federal and regional NOx requirements on point sources. These credits include: 

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

• Maryland's Healthy Air Act. 

Control Strategy

Clean Air Interstate Rule (CAIR)

In 2004, the U.S. EPA promulgated the Clean Air Interstate Rule, which requires 

reductions in emissions of NOx and SO2 from large fossil fuel-fired electric generating 

units. The rule is set up in several phases with the first phase of NOx reductions to come

by 2009. The rule sets up both an annual emissions budget and an ozone season 

emissions budget. The rule requires that units with nameplate capacity greater than 25 

megawatts emit no more NOx than their allocations determined by the state either

through emission controls or banking and trading. 

Virginia CAIR

Virginia has adopted state regulations codifying the requirements of the Clean Air 

Interstate Rule. Virginia's rules create an emissions cap based on the allowances allocated 

to the facility. The rules do not allow trading as a method of complying with the 

emissions cap. 

Maryland Healthy Air Act

In April of 2006 the Maryland General Assembly and Governor Ehrlich adopted the 

Healthy Air Act (HAA), a law that requires reductions in NOx, SO2, and Mercury 

emissions from Maryland’s largest and oldest coal fired power plants. Maryland 

implements the HAA through regulation. The regulation requires reductions in NOx 

emissions from coal-fired electric generating units (excluding fluidized bed combustion 

units) starting in 2009. By 2009 Maryland expects an approximate 70 percent reduction 

in NOx emissions from these regulations when compared to 2002 emissions. To meet the 

requirements of Maryland’s regulations a company’s “system” (covered units owned by 

the same company) must meet a system-wide cap by 2009. Compliance cannot be 

achieved through the purchase of allowances under the HAA. 

District of Columbia CAIR

The District of Columbia is currently drafting its Clean Air Interstate Rule (CAIR). The 

District of Columbia's CAIR regulations do not allow trading of NOx allowances for 

achieving the reductions for the facilities within its jurisdiction. 

Summary

The point source NOx controls are a phased approach to controlling emissions of NOx 

from power plants and other large fuel combustion sources. The programs resulting in 

emission reductions applied for contingency from point sources in the region include: 

EPA's Clean Air Interstate Rule and Maryland's Healthy Air Act 

MWAQC Ozone SIP 11-4 May 23, 2007
Implementation 

District Department of the Environment 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental 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 Benefit Calculations

The emission reductions associated with the state NOx requirements on point sources 

were supplied by the staffs of the Maryland Air and Radiation Management 

Administration, the District Department of the Environment, and the Virginia Department 

of Environmental Quality Air Division. 

References

1990 Clean Air Act Amendments, 42 U.S.C. §§7511a (f), (b)(2), and (c). 

11.2 Contingency Measures for the Attainment Demonstration 

11.2.1 Background 

EPA requires the Washington region to include a contingency plan containing adopted 

measures that qualify as contingency measures for the 2009 attainment demonstration. 

This section fulfills the requirement for the 2009 attainment demonstration. 

11.2.2 Required Reductions 

The Washington region must also identify contingency measures to be implemented in 

the event that the region does not attain the 8-hour ozone standard in 2009. The 

contingency measures for the attainment demonstration must provide reductions of either 

VOC or NOx that total 3% of the 2002 Adjusted Base Year Inventory. A minimum of 0.3 

percent VOC must be included. The adjusted inventory is calculated as described in 

Chapters 4 and 5. Table 11-3 shows the calculation of the necessary reductions, based on 

the minimum VOC reduction required. 

MWAQC Ozone SIP 11-5 May 23, 2007
Table 11-3 

Calculation of VOC and NOx Reductions for Attainment Contingency 

(Ozone Season tons per day)

Description VOC NOx

2002 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 Attainment 

Contingency (d) = (0.3/100) * (c) 

1.31

2.7% NOx Reduction Required for Attainment 

Contingency (e) = (2.7/100) * (c) 

15.27

Contingency reductions must occur on a timetable that is directly related to the 

attainment SIP schedule. States have no more than one year after notification by EPA of 

an attainment failure to achieve the contingency plan reductions. For a potential 

attainment failure in 2009, notification would be received in 2010, therefore the 

contingency reductions must be achieved no later than 2011. 

11.2.3 Identified Contingency Measures

Table 11-4 lists the contingency measures identified by the District of Columbia, 

Maryland and Virginia for the attainment demonstration. These measures deliver total 

benefits of 8.46 tpd VOC and 6.05 tpd NOx. The combined reduction equals 3% of the 

Adjusted Base Year Inventory, meeting the contingency measure requirement calculated 

in Table 11-3; therefore this measure fulfills the region’s contingency measure 

requirement. All of these control measures will be effective by 2011. 

MWAQC Ozone SIP 11-6 May 23, 2007
Table 11-4 

Contingency Measures for Attainment Demonstration 

(Ozone Season tons per day)

Ref. 

No. 

Contingency Measure VOC 

(tons/day) 

NOx 

(tons/day)

6.4.5 Tier 2 Motor Vehicle Emission Standards 0 1.77 

6.3.1 Phase I and Phase II Emissions Standards for 

Gasoline-Powered Non-Road Utility Engines 1.49 0.04

6.3.2 Emissions Standards for Diesel-Powered Non-Road 

Utility Engines of 50 or More Horsepower 

0.39 3.28

6.3.3 Emissions Standards for Spark Ignition Marine 

Engine 1.42 0

6.3.4 Emissions Standards for Large Spark Ignition 

Engines 0.54 0.96

6.2.12 

6.2.17 

Ozone Transport Commission Portable Fuel 

Containers Rule 4.62 0

TOTAL REDUCTIONS 8.46 6.05 

The contingency reduction from the on-road source is substantiated by a 2010 Mobile 

Emissions Budget, as specified in Chapter 8. Reductions for the Tier 2 motor vehicle 

emission standards occur between 2009 and 2010. Reductions for the other identified 

measures occur between 2009 and 2011. 

In accordance with EPA’s guidance encouraging early implementation of contingency 

measures to guard against failure to either meet a milestone or attain, the District of 

Columbia, Maryland and Virginia will implement the contingency measures identified in 

Table 11-4 according to the timetable indicated in Chapters 6 and 9. EPA’s guidance on 

early implementation of control measures is as follows: 

The EPA encourages the early implementation of required control 

measures and of contingency measures as a means of guarding against 

failures to meet a milestone or to attain. Any implemented measures (that 

are not needed for the rate-of-progress requirements or for the attainment 

requirements) would need to be backfilled only to the extent they are used

to meet a milestone. 

The reductions from the designated contingency measures are surplus vis-à-vis the 

attainment demonstration contained in this SIP. They will not be used to meet that 

milestone requirement. As a result, the states will not be required to backfill any 

contingency measures that they choose to implement in advance of the requirement. 

MWAQC Ozone SIP 11-7 May 23, 2007
11.2.4 Tier 2 Motor Vehicle Emission Regulations 

The U.S. EPA promulgated a rule on February 10, 2000 requiring more stringent tailpipe 

emissions standards for all passenger vehicles, including sport utility vehicles (SUVs), 

minivans, vans and pick-up trucks. These regulations also require lower levels of sulfur 

in gasoline, which will ensure the effectiveness of low emission-control technologies in 

vehicles and reduce harmful air pollution. 

Source Type Affected 

These federally implemented programs affect light-duty vehicles and trucks. 

Control Strategy 

The new tailpipe and sulfur standards require passenger vehicles to be 77% to 95% 

cleaner than those built before the rule was promulgated and will reduce the sulfur 

content of gasoline by up to 90 %. The new tailpipe standards are set at an average 

standard of 0.07 grams per mile 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 less than 6000 pounds will be phased-in to this standard between 2004 and 

2007. 

Beginning in 2004, the refiners and importers of gasoline have the flexibility to 

manufacture gasoline with a range of sulfur levels as long as all of their production is 

capped at 300 parts per million (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 met a 30 ppm average sulfur level 

with a maximum cap of 80 ppm.

As newer, cleaner cars enter the national fleet, the new tailpipe standards will 

significantly reduce emissions of nitrogen oxides from vehicles by about 74 % by 2030. 

Implementation 

EPA implements this program under 40 CFR Parts 80, 85, and 86. 

Projected Reductions

This measure provides 1.8 tpd NOx reduction applied for contingency purposes. This 

contingency measure will be implemented via a 2010 mobile source budget as discussed 

in Chapter 8.

Emission Benefit Calculations

The contingency reductions are based on Tier 2 motor vehicle emission standards, for

reductions occurring between 2009 and 2010. 

MWAQC Ozone SIP 11-8 May 23, 2007
11.2.5 Phase I and Phase II Emissions Standards for Gasoline-Powered Non-Road 

Utility Engines 

This measure takes credit for VOC emissions reductions attributable to emissions 

standards promulgated by the EPA for small non-road, spark-ignition (i.e., gasolinepowered) utility engines, as authorized under 42 U.S.C. §7547. The measure affects 

gasoline-powered (or other spark-ignition) lawn and garden equipment, construction 

equipment, chain saws, and other such utility equipment as chippers and stump 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 equipment. 

Control Strategy

Federal emissions standards promulgated under §7547 (a) apply to spark-ignition nonroad utility engines. The EPA's Phase 1 Spark Ignition Nonroad final rule on such 

emissions standards was published in 60 Federal Register 34581 (July 3, 1995), and was 

effective beginning August 2, 1995. Compliance was required by the 1997 model year. 

The Phase 2 final rule for handheld nonroad equipment was published in 65 Federal 

Register 24267 (April 25, 2000). The Phase 2 final rule for non-handheld equipment was 

published in 64 Federal Register 15207 (March 30, 1999). 

Implementation

This program is implemented by the EPA, under 42 U.S.C. §7547 (a). 

Projected Reductions

VOC Emission Reductions (tons per day)

District 

of Columbia Maryland Virginia Total 

VOC Reductions 0.08 0.68 0.73 1.49 

NOx Reductions 0.01 0.02 0.02 0.04 

Emission Benefit Calculations

The contingency reductions are estimated using EPA's NONROAD model for reductions 

occurring between 2009 and 2011. 

MWAQC Ozone SIP 11-9 May 23, 2007
11.2.6 Emissions Standards for Diesel-Powered Non-Road Utility Engines of 50 or 

More Horsepower 

This measure takes credit for NOx emissions reductions attributable to emissions 

standards promulgated by the EPA for non-road, compression-ignition (i.e., dieselpowered) utility engines, as authorized under 42 U.S.C. § 7547. The measure affects 

diesel-powered (or other compression-ignition) construction equipment, industrial 

equipment, etc., rated at or above 37 kilowatts (37 kilowatts is approximately equal to 50 

horsepower). 

Control Strategy 

Federal emissions standards applicable to compression-ignition non-road utility engines 

are promulgated under §7547 (a). 

EPA's first rule on such emissions standards was published in 59 Federal Register 31306 

(June 17, 1994), and was effective on July 18, 1994. 

Tier 2 and Tier 3 Emission 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 marine engines in this size range. It also phases in more 

stringent "Tier 2" emission standards from 2001 to 2006 for all engine sizes and adds yet 

more stringent "Tier 3" standards for engines between 37 and 560 kW (50 and 750 hp) 

from 2006 to 2008. 

EPA adopted a comprehensive national program to greatly reduce emissions from future 

nonroad diesel engines by integrating engine and fuel controls as a system to gain the 

greatest air quality benefits. This rule was published June 29, 2004. The requirement to 

reduce sulfur levels in nonroad diesel fuel by more than 99 % will allow for the first time 

advanced emission control systems to be used on the engines used in construction, 

agricultural, industrial, and airport service equipment. 

Implementation

This program is implemented by the EPA under 42 U.S.C. § 7547 (a). 

MWAQC Ozone SIP 11-10 May 23, 2007
Projected Reductions

Emission Reductions (tons per day) 

District 

of Columbia Maryland Virginia Total 

VOC Reductions 0.07 0.19 0.13 0.39 

NOx Reductions 0.57 1.34 1.37 3.28 

Emission Benefit Calculations

The contingency reductions are estimated using EPA's NONROAD model for reductions 

occurring between 2009 and 2011. 

11.2.7 Emissions Standards for Spark Ignition (SI) Marine Engines 

This EPA measure controls exhaust VOC emissions from new spark-ignition (SI) 

gasoline marine engines, including outboard engines, personal watercraft engines, and jet 

boat engines. Of nonroad sources studied by EPA, gasoline marine engines were found to 

be one of the largest contributors of hydrocarbon (HC) emissions (30% of the nationwide 

nonroad total). 

Control Strategy 

EPA is imposing emission standards for 2 – stroke technology, outboard and personal 

watercraft engines. This will involve increasingly stringent HC control over the course of

a nine-year phase-in period beginning in model year 1998. By the end of the phase-in, 

each manufacturer must meet an HC and NOx emission standard that represents a 75% 

reduction in HC compared to unregulated levels. These standards do not apply to any 

currently owned engines or boats. 

Implementation

This program is implemented by the EPA under 42 U.S.C. § 7547 (a). 

Projected Reductions

Emission Reductions (tons per day) 

District 

Of Columbia Maryland Virginia Total 

VOC Reductions 0.19 1.07 0.15 1.42 

MWAQC Ozone SIP 11-11 May 23, 2007
Emission Benefit Calculations

The contingency reductions are estimated using EPA's NONROAD model for reductions 

occurring between 2009 and 2011. 

11.2.8 Emissions Standards for Large Spark Ignition (SI) Engines 

This EPA measure controls VOC and NOx emissions from several groups of previously 

unregulated nonroad engines, including large industrial SI engines. 

Control Strategy 

The EPA requirements vary depending upon the type of engine or vehicle, taking into 

account environmental impacts, usage rates, the need for high performance models, costs 

and other factors. The emission standards apply to all new engines sold in the United 

States and any imported engines manufactured after these standards began.

Controls on the category of large industrial SI engines were first required in 2004. 

Controls on the other engine categories began in years after 2005. Large industrial SI 

engines are those rated over 19 kW used in a variety of commercial applications; most 

use liquefied petroleum gas, with others operating on gasoline or natural gas. 

EPA adopted two tiers of emission standards for Large SI engines. The first tier of 

standards, which started in 2004, are based on a simple laboratory measurement using 

steady-state procedures. The Tier 1 standards are the same as those adopted earlier by the 

California Air Resources Board for engines used in California. Tier 2 standards became 

effective in 2007.

Implementation

This program is implemented by the EPA under 42 U.S.C. § 7547 (a). 

Projected Reductions

Emission Reductions (tons per day) 

District 

of Columbia Maryland Virginia Total 

VOC Reductions 0.04 0.30 0.21 0.54 

NOx Reductions 0.08 0.48 0.40 0.96 

Emission Benefit Calculations

The contingency reductions are estimated using EPA's NONROAD model for reductions 

occurring between 2009 and 2011. 

MWAQC Ozone SIP 11-12 May 23, 2007
11.2.9 Portable Fuel Containers Rule: Phase I and Phase II 

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

The standards are intended to reduce emissions from storage, transport and refueling 

activities. The rule also included administrative and labeling requirements. Compliant 

containers must have: only one opening for both pouring and filling, an automatic shutoff to prevent overfill, an automatic sealing mechanism when not dispensing fuel and 

specified fuel flow rates, permeation rates and warranties. 

Source Type Affected

Any person or entity selling, supplying or manufacturing portable fuel containers, except 

containers with a capacity of less than or equal to one quart, rapid refueling devices with 

capacities greater than or equal to four gallons, safety cans and portable marine fuel tanks 

operating with outboard motors, and products resulting in cumulative VOC emissions 

below those of a representative container or spout. 

Control Strategy 

Maryland, the District, and Virginia all adopted Phase I and are in the process of adopting 

Phase II of the OTC Model Rule for Portable Fuel Containers. 

Implementation 

Maryland - Air and Radiation Management Administration 

Virginia - Department of Environmental Quality 

District of Columbia - Department of Environment 

Projected Reductions

VOC Emission Reductions (tons per day)

District 

of Columbia Maryland Virginia Total 

VOC Reductions -0.06 2.98 1.71 4.62 

Emission Benefit Calculations

Projected reductions are based on an emission reduction factor of 75% after full 

implementation after 10 years. Implementation began in 2005. In 2008, the emission 

reduction factor is 30%. In 2009, the emission reduction factor is 37.5%. Phase II 

reductions are based on an additional 4 percent reduction in emissions of VOC. 

Note that the District's OTC VOC rules on all the applicable area source categories are or 

will be fully adopted, submitted to EPA, and federally enforceable measures. However, 

MWAQC Ozone SIP 11-13 May 23, 2007
the emission reductions 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 additional enhancements to the air quality improvement 

in the region. 

The contingency reductions are for reductions occurring between 2009 and 2011. 

References

E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport 

Commission Model Rules”, March 31, 2001. 

U. S. EPA, “State Implementation Plans; General Preamble for the Implementation of 

Title I of the Clean Air Act Amendments of 1990”, Proposed Rule, 57 Federal Register

13498 (April 16, 1992). 

U.S. EPA, “Guidance on the Post-1996 Rate-of-Progress Plan and the Attainment 

Demonstration,” Corrected Version as of February 18, 1994, p. 50. 

OTC 2007. Identification and Evaluation of Candidate Control Measures: Final 

Technical Support Document. Prepared by MACTEC Federal Programs, Inc., Herndon, 

Virginia for the Ozone Transport Commission. February 28, 2007. 

MWAQC Ozone SIP 11-14 May 23, 2007