dep 

west virginia department of environmental protection 

Executive Office 

601 57th ST SE 

Charleston, WV 24304 

Mr. Shawn M. Garvin (3RAOO) 

Regional Administrator 

US EPA Region 3 

1650 Arch Street 

Philadelphia, PA 19103-2029 

August 5, 2013 

Earl Ray Tomblin, Governor 

Randy C. Huffman, Cabinet Secretary 

www .dep. wv .gov 

Re: Redesignation Request and Maintenance Plan for the West Virginia Portion ofthe 

Martinsburg-Hagerstown, WV-MD 1997 PM2.s Nonattainment Area 

Dear Administrator Garvin: 

The State of West Virginia is requesting that the EPA redesignate the West Virginia portion of the 

Martinsburg-Hagerstown, WV-MD 1997 PM25 Nonattainment Area to attainment pursuant to the 

provisions of the Clean Air Act, section 107. The State is also requesting that EPA concurrently 

approve the associated maintenance plan as a revision to the State Implementation Plan (SIP), 

meeting the requirements of Clean Air Act, section 175A, which demonstrates that the area will 

continue to meet the 1997 PM25 air quality standards for at least ten more years. The State of West 

Virginia is additionally requesting approval of the 2007 base year inventory as meeting the 

requirements under Clean Air Act Section 172(c)(3). 

The requests are detailed in the enclosed hardcopy: Redesignation Request and Maintenance Plan for 

the West Virginia Portion of the Martinsburg-Hagerstown, WV-MD 1997 PM2.5 Nonattainment Area 

and the supporting documentation is provided in electronic format, on the enclosed compact discs. 

We certify that the electronic copies include exact duplicates of the hard copy. The electronic copies 

also furnish additional information which has not been presented in hardcopy form. We certify that 

the opportunity for a public hearing required by 40 CFR §51.1 02(a) was offered in accordance with 

the applicable state laws and the requirements of 40 CFR §51.102(d). EPA and the state ofMaryland 

were notified at the beginning of the public comment period. Please contact John Benedict, Director, 

Division of Air Quality at (304) 926-0462, if you have any questions or need additional information. 

Enclosures 

cc: Diana Esher (3APOO) 

John Benedict 

Cabinet Secretary 

~ 

Promoting a healthy environment. 
 

west virginia department of environmental protection

REDESIGNATION REQUEST

AND

MAINTENANCE PLAN

FOR THE

WEST VIRGINIA PORTION

 OF THE

MARTINSBURG-HAGERSTOWN, WV-MD

1997 2.5 PM NONATTAINMENT AREA

FINAL

August 2013

Promoting a healthy environment.
Page intentionally left blank.

Page ii
Table of Contents

I. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1

A. Request.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1

B. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1

C. Geographic Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 2

II. REDESIGNATION CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3

A. The Mar 2.5 tinsburg Area has attained the 1997 PM Standard. . . . . . . . . . . . . . . . . . Page 3

B. The Martinsburg Area has a Fully Approved SIP Under Section 110(k) of the CAA

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 8

C. The Martinsburg Area’s Air Quality Improvement is Due to Permanent and Enforceable

Emissions Reductions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

D. The State has Developed a Maintenance Plan for the Martinsburg Area Which Ensures

Attainment of the 1997 PM2.5 Standard for at least 10 Years. . . . . . . . . . . . . . . . . . Page 9

E. The Martinsburg Area Has Met All Relevant Requirements under CAA Section 110 and

Part D. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

1. Section 110(a) requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

2. Section 172(c) requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

3. Conformity.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

III. MAINTENANCE PLAN.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11

A. PM2.5 Emissions Demonstrations.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15

B. NOx Emissions Demonstrations.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16

C. SO2 Emissions Demonstrations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17

D. NH3 Emissions Demonstrations.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18

E. VOC Emissions Demonstrations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

F. Summary 2.5 x 2 3 of PM , NO , SO , NH and VOC Emission Reductions.. . . . . . . . . . . Page 20

G. Air Quality Improvement is Based on Permanent and Enforceable Emission Reductions

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21

H. Emissions Tracking. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 22

IV. TRANSPORTATION ANALYSIS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23

A. Onroad Emission Estimations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23

1. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23

2. Highway Emissions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23

3. Analysis Methodology and Data Inputs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 24

B. Description of Input Data.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 26

1. Roadway Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27

2. Other Supporting Traffic Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 29

3. Vehicle Class Data.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 30

4. Vehicle Ages. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 31

5. Vehicle Population Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 31

Page iii M 2.5 artinsburg, WV 1997 PM Redesignation and Maintenance Plan
6. Environmental and Fuel Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 31

7. Other Vehicle Technology and Control Strategy Data. . . . . . . . . . . . . . . . . . . Page 31

C. Analysis Methodology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 32

1. VMT Preparation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 32

2. Speed Estimation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 35

3. MOVES Runs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 37

D. Motor Vehicle Emission Budgets (MVEBs). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 40

1. NOx MVEBs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 41

2. Direc 2.5 t PM MVEBs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 42

3. Summary of Adopted MVEBs.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 43

V. CONTROL MEASURES AND REGULATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 44

A. Reasonably Available Control Measures (RACM) and Reasonably Available Control

Technology (RACT). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 44

B. Inventory of Actual Emissions.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 45

C. Evidence 2.5 that control measures required in past PM SIP revisions have been fully

implemented.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 45

1. NOx SIP Call, CAIR and CSAPR. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 45

2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards. . . . . Page 46

3. Heavy-Duty Diesel Engines.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 47

4. Clean Air Non-road Diesel Rule. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 47

5. MACT Regulations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 47

D. Assurance that existing control measures will remain in effect.. . . . . . . . . . . . . . . Page 49

VI. SUPPLEMENTAL MODELING ANALYSES.. . . . . . . . . . . . . . . . . . . . . . . . . . . Page 50

A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule). . . . Page 50

B. EPA Modeling for Proposed Transport Rule 2010. . . . . . . . . . . . . . . . . . . . . . . . . Page 52

C. VISTAS/AS 2.5 IP Emissions and Air Quality Modeling to Support PM and 8-hour Ozone

State Implementation Plans. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 53

VII. CONTINGENCY MEASURES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 55

A. Maintenance Plan Review. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 55

B. Corrective Actions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 55

1. Warning Level Response. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 55

2. Action Level Response. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 55

3. Control Measure Selection and Implementation. . . . . . . . . . . . . . . . . . . . . . . . Page 56

C. Potential Contingency Measures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 56

D. PM2.5 2 x, SO , and NO sources potentially subject to future additional control requirements.

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 56

VIII. PUBLIC PARTICIPATION.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 57

IX. CONCLUSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 57

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page iv
List of Tables

Table 1: Mar 2.5 tinsburg Nonattainment Area Design Values for the 1997 Annual and 24-hr PM

NAAQS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 4

Table 2: SO2 x and NO EGU Emissions 2002 through 2011. . . . . . . . . . . . . . . . . . . . . . . . Page 12

Table 3: Berke 2.5 ley County, WV PM Emission Inventory Totals for 2005, 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15

Table 4: Washing 2.5 ton County, MD PM Emission Inventory Totals for 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15

Table 5: Mar 2.5 tinsburg Nonattainment Area PM Emission Inventory Totals for 2007, 2017 and

2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16

Table 6: Berke xley County, WV NO Emission Inventory Totals for 2005, 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16

Table 7: Washing xton County, MD NO Emission Inventory Totals for 2007, 2017 and 2025 (tpy)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16

Table 8: Mar xtinsburg Nonattainment Area NO Emission Inventory Totals for 2007, 2017 and

2025 (tpy).. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17

Table 9: Berke 2ley County, WV SO Emission Inventory Totals for 2005, 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17

Table 10: Washing 2ton County, MD SO Emission Inventory Totals for 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17

Table 11: Mar 2tinsburg Nonattainment Area SO Emission Inventory Totals for 2007, 2015 and

2025 (tpy).. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18

Table 12: Berke 3ley County, WV NH Emission Inventory Totals for 2005, 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18

Table 13: Washing 3ton County, MD NH Emission Inventory Totals for 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18

Table 14: Mar 3tinsburg Nonattainment Area NH Emission Inventory Totals for 2007, 2017 and

2025 (tpy).. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

Table 15: Berkeley County, WV VOC Emission Inventory Totals for 2005, 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

Table 16: Washington County, MD VOC Emission Inventory Totals for 2007, 2017 and 2025

(tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

Table 17: Martinsburg Nonattainment Area VOC Emission Inventory Totals for 2007, 2017 and

2025 (tpy).. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 20

Table 18: West Virginia Portion of the Martinsburg Area Comparison of 2007 attainment year

and 2017 and 2025 projected emission estimates (tpy). . . . . . . . . . . . . . . . . . . . . . . . . Page 20

Table 19: Maryland Portion of the Martinsburg Area Comparison of 2007 attainment year and

2017 and 2025 projected emission estimates (tpy). . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 20

Table 20: Martinsburg Area Comparison of 2007 attainment year and 2017 and 2025 projected

emission estimates (tpy).. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21

Table 21: Summary of Highway Emissions Inventory. . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 24

Table 22: Demographic Growth Assumptions to the Travel Model. . . . . . . . . . . . . . . . . . Page 29

Table 23: MOVES Source Types and HPMS Vehicle Groups. . . . . . . . . . . . . . . . . . . . . . Page 30

Table 24: MOVES Run Data Checklist.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 38

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page v
Table 25: Percentage of Charleston Emissions Attributable to Mobile Sources in 2007, 2017 and

2025. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 39

Table 26: Berke xley County (WV) NO Emission Inventory Totals, Onroad (Highway) Emissions

and Original Safety Margins for 2017 and 2025 (tpy). . . . . . . . . . . . . . . . . . . . . . . . . . Page 41

Table 27: Berke xley County (WV) NO MVEBs and Remaining Safety Margins

x

 After Reallocation from the Original Safety Margins into the NO MVEBs. . . . . . . . Page 41

Table 28: Berke 2.5 ley County (WV) PM Emission Inventory Totals, Onroad (Highway)

Emissions and Original Safety Margins for 2018 and 2025 (tpy). . . . . . . . . . . . . . . . . Page 42

Table 29: Berke 2.5 ley County (WV) PM MVEBs and Remaining Safety Margins

After 2.5 Reallocation from the Original Safety Margins into the PM MVEBs.. . . . . . . Page 42

Table 30: CSAPR Annual PM2.5 Design Values (μg/m3).. . . . . . . . . . . . . . . . . . . . . . . . . Page 51

Table 31: Proposed Transport Rule Modeling Results from EPA - 2010. . . . . . . . . . . . . . Page 52

Table 32: VISTAS/ASIP 2009, 2012 and 2018 Modeling Results (with CAIR). . . . . . . . Page 54

Page vi M 2.5 artinsburg, WV 1997 PM Redesignation and Maintenance Plan
List of Figures

Figure 1: Map of the Martinsburg-Hagerstown, WV-MD nonattainment area and monitor

locations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 4

Figure 2: West Virg 2.5 inia PM Annual Design Values, 1999-2001 through 2009-2011.. . . Page 6

Figure 3: Mary 2.5 land PM Annual Design Values, 1999-2001 through 2007-2009.. . . . . . . Page 7

Figure 4: PM2.5 Annual Mean National Trends.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 8

Figure 5. Local Data Inputs Used for Emissions Inventory. . . . . . . . . . . . . . . . . . . . . . . . . Page 25

Figure 6. Emission Calculation Process.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 26

Figure 7. Examples of Key MOVES Input Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27

Figure 8. HEP Regional Travel Demand Model. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 28

Figure 9. PPSUITE Speed/Emission Estimation Procedure. . . . . . . . . . . . . . . . . . . . . . . . Page 34

Figure 10. Emission Factor vs. Speed Variances (NOx). . . . . . . . . . . . . . . . . . . . . . . . . . . Page 35

Page vii M 2.5 artinsburg, WV 1997 PM Redesignation and Maintenance Plan
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Page viii M 2.5 artinsburg, WV 1997 PM Redesignation and Maintenance Plan
List of Appendices

Appendix A: Air Monitoring Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page A - 1

Appendix B: Berkeley County, West Virginia Emissions Inventory. . . . . . . . . . . . . . Page B - 1

Appendix C: Berkeley County, West Virginia On-Road Mobile Emissions Inventory

Documentation.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page C - 1

Appendix D: Washington County, Maryland Emissions Inventory. . . . . . . . . . . . . . . Page D - 1

Appendix E: MARAMA Documentation for Washington County, MD Inventory. . . Page E - 1

Appendix F: Washington County, Maryland On-Road Mobile Emissions Inventory

Documentation.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page F - 1

Appendix G: Public Participation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page G - 1

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page ix
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Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page x
REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST

VIRGINIA PORTION OF THE MARTINSBURG-HAGERSTOWN, WV-MD 

1997 PM2.5 NONATTAINMENT AREA

I. INTRODUCTION

The Martinsburg 2.5 -Hagerstown, WV-MD PM nonattainment area is amulti-state nonattainment area,

comprising Berkeley County in West Virginia, and Washington County in Maryland. The area

monitored attainment of 2.5 the 1997 PM standard with a design value for 2006-2008 of 14.9 μg/m , 

3

2007-2009 of 14.0 μg/m , 2008-2010 of 12.9 μg/m , 2009-2011 of 11.8 μg/m , and 2010-2012 of 3 3 3

11.6 μg/m . The State of West Virginia herein requests redesignation by the United States 3

Environmental Protection Agency of Be 2.5 rkeley to attainment relative to the 1997 PM National

Ambient Air Quality Standard. The State of Maryland also plans to request redesignation of

Washington County 2.5 , Maryland to attainment relative to the 1997 PM National Ambient Air Quality

Standard.

A. Request

The State of West Virginia is requesting that the EPA redesignate the West Virginia portion of the

Martinsbu 2.5 rg-Hagerstown, WV-MD 1997 PM Nonattainment Area to attainment pursuant to the

provisions of the Clean Air Act, section 107. The State is also requesting that EPA concurrently

approve the associated maintenance plan as a revision to the State Implementation Plan (SIP),

meeting the requirements of Clean Air Act, section 175A, which demonstrates that the area will

continue to meet the current PM2.5 air quality standards for at least ten more years.

The State of West Virginia is also requesting approval of the 2007 base year inventory as meeting the

requirements under Clean Air Act Section 172(c)(3).

B. Background

The Clean Air Act (CAA) requires areas failing to meet a National Ambient Air Quality Standard

(NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the

standard. The EPA revised the NAAQS for particulate matter in July 1997. It replaced the existing

PM10 2.5 10standard with a health based PM standard and retained the PM standard as a “coarse”

2.5 standard protecting welfare. The 1997 PM standards include an annual standard set at 15.0

microg 2.5 rams per cubic meter (μg/m3), based on the 3-year average of annual mean PM

concentrations and a 24-hour standard of 65 μg/m , based on the 3-year average of the 98 percentile 3 th

of 24-hour concentrations.

The revised NAAQS were legally challenged in the U.S. Court of Appeals for the District of

Columbia Circuit (D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the

standard back to EPA. The remand did not question the level at which EPA set the standards but

rather the constitutionality of the CAA provision that authorizes EPA to set national air quality

standards. EPA requested a rehearing which the D.C. Circuit denied. Therefore, in December 1999,

EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued

a decision on February27, 2001 that unanimouslyaffirmed the constitutionalityof the CAA provision

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 1
but did remand several other issues back to the D.C. Circuit, including the issue of whetherEPA acted

arbitrarily and capriciously in establishing the specific levels of the standards.

The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its decision

on March 26, 2002. The court rejected the claims that the EPA had acted arbitrarily and capriciously

in setting the levels of the standards. 

On December 17, 2004, EPA promulgated 2.5 the initial PM nonattainment areas designations for the

PM2.5 standards across the country. Modifications to those designations were made and an effective

date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 1990 which defined five

ozone nonattainment classifications for the areas that exceed the NAAQS based on the severity of the

ozone 2.5levels, PM nonattainment designations are simply labeled “nonattainment.” The CAA

Amendments 2.5 require states with PM nonattainment areas to submit a plan within three years of the

effective date of 2.5 the designations (April 5, 2008) detailing how the PM standards would be attained

by April 5, 2010.

On November 20, 2009 [74 FR60199] EPA determined that the Martinsburg-Hagerstown, WV-MD

area had attained 2.5 the 1997 PM NAAQS (Clean Data Determination). This determination was based

on complete, quality-assured and certified ambient air monitoring data for the three year period, 

2006-2008. This determination suspended the state’s requirement to submit an attainment

demonstration, Reasonably Available Control Measures (RACM), including Reasonably Available

Control Technology (RACT), Reasonable Further Progress (RFP) plan, contingency measures, and

other planning SIP 2.5 revisions related to attainment of the 1997 PM NAAQS for so long as the area

continues to attain the 1997 PM2.5 NAAQS.

On January 10, 2012 [77 FR 1411] EPA also determined that the Martinsburg-Hagerstown, WV-MD

area had attained 2.5 the 1997 annual PM NAAQS by the applicable attainment date of April 5, 2010.

This determination was based upon complete, quality-assured, and certified ambient air monitoring

data for the 2007-2009 monitoring period. 

C. Geographic Description

The Martinsburg 2.5 -Hagerstown, WV-MD PM nonattainment area (Martinsburg area) is a multi-state

nonattainment area, comprising Berkeley County in West Virginia, and Washington County in

Maryland. This area is shown in Figure 1 under Section II.A. The Martinsburg area has not previously

been subject to nonattainment area rulemakings for fine particles. 

Although EPA designated the Martinsburg area nonattainment for the 15.0 μg/m annual standard, 3

as a result of the Clean Data Determination West Virginia DEP was not required to develop a plan

to demonstrate that the area would meet the federal annual air quality standard by April 5, 2010. 

This document is intended to support West Virginia’s request that the West Virginia portion of the

Martinsburg area be 2.5 redesignated from nonattainment to attainment for the 1997 PM standard. In

addition, the State of Maryland also plans to submit a request for their portion of the Martinsburg

area. 

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 2
II. REDESIGNATION CRITERIA

Pursuant to Section 107(d)(3)(E) of the CAA states must sufficiently address five issues to obtain

redesignation of a nonattainment area to attainment: 

A. determinate that the area has attained the applicable NAAQS;

B. have a fully approved implementation plan under CAA section 110(k);

C. show that the improvement in air quality is due to permanent and enforceable emission

reductions;

D. submit an EPA approvable maintenance plan which ensures attainment of the NAAQS for at

least ten years beyond redesignation; and

E. show that the area has met the applicable requirements of CAA section 110 and part D. 

The State of West Virginia herein affirmatively completes all five of the required elements as detailed

below.

A. The Martinsburg Area has attained the 1997 PM2.5 Standard

[See Appedix A]

The following information is taken from EPA’s “Guideline on Data Handling Conventions for the

PM NAAQS,” U.S. EPA-454/R-99-008, April 1999.

In accordance with the CAA Amendments, three complete years of monitoring data are required to

demonstrate attainment at a monitoring 2.5 site. The annual PM primary and secondary ambient air

quality standards are met at an ambient air quality monitoring site when the three-year average of the

annual average is less than 15.0 μg/m . While calculating design values, three significant digits must 3

be carried in the computations, with final values rounded to the nearest 0.1 μg/m . Decimals 0.05 or 3

greater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m is the largest 3

concentration that is less than, or equal to 15.0 μg/m . Values at or below 15.0 μg/m meet the 3 3

standard; values equal to or greater than 15.1 μg/m exceed the standard. An area is in compliance 3

with 2.5 the annual PM NAAQS only if every monitoring site in the area meets the NAAQS. An

individual site’s 3-year average of the annual average concentrations is also called the site’s design

value. The air quality design value for the area is the highest design value among all sites in the area. 

There are 2.5 two (2) monitors measuring PM concentrations in the Martinsburg, WV-MD

nonattainment area. One (1) monitor is located in West Virginia and operated by the West Virginia

Division of Air Quality (DAQ). One (1) monitor is located in Maryland and operated by the Maryland

Department of the Environment (MDE). The location of the monitoring sites for this nonattainment

area are shown in Figure 1. A listing of the design values based on the three-year average of the

annual mean concentrations from 2001-2003 through 2009-2011 for the monitors is shown in Table

1. The data for the two monitors is located in Appendix A.

The data in Appendix A has been quality assured, up through 2011 in accordance with 40 CFR 58.10

and all other federal requirements. The data has been recorded in the AQS database and, therefore,

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 3
the data are available to the public. Table 1 shows the monitoring data for 2001-2012 that were

retrieved from the EPA AQS.

Figure 1: Map of the Martinsburg-Hagerstown, WV-MD nonattainment area and monitor locations 

Table 1: Martinsburg Nonattainment Area Design Values for the 1997 Annual and 24-hr PM2.5 NAAQS

1997 NAAQS 24 hr 3 yr 98% = 65 1997 Annual NAAQS = 15

FRM

Site

02

-

04

03

-

05

04

-

06

05

-

07

06

-

08

07

-

09

08

-

10

09

-

11

10

-

12

02

-

04

03

-

05

04

-

06

05

-

07

06

-

08

07

-

09

08

-

10

09

-

11

 10 

 - 

12

54-

003-

0003

37 36 34 33 31 29 31 30 31 16.1 16.2 15.8 15.8 14.9 14.0 12.9 11.8 11.6

24-

043-

0009

39 36 34 31 30 27 28 27 28 14.1 14.1 13.8 13.2 12.2 11.5 11.0 10.9 11.0

Source: EPA Air Quality System (AQS); http://www.epa.gov/airtrends/values. html

Notes: Green shading indicates meeting the standard, all monitors in the area monitor attainment.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 4
The design values calculated 2.5 for the Martinsburg area demonstrate that the 1997 PM NAAQS has

been attained. The area’s design values have trended downward as emissions have declined due to

such factors as cleaner automobiles and fuels, and controls for EGUs, at the national, regional and

local level. 

National monitoring 2.5 for PM began in 1999. There has been a clear downward trend in design

values for all monitors in West Virginia and Maryland, as shown in Figures 2 and 3. Design values

have also trended downward nationally, as shown in Figure 4.

On November 20, 2009 [74 FR 60199] EPA determined that the Martinsburg-Hagerstown, WV-MD

area had attained 2.5 the 1997 PM NAAQS [Clean Data Determination]. This determination was based

upon complete, quality assured, quality controlled, and certified ambient air monitoring data that

2.5 showed that the area monitored attainment of the 1997 PM NAAQS during the 2006-2008

monitoring period. On January 10, 2012 [77 FR 1411] EPA also determined that the MartinsburgHagerstown, WV-MD area had attained 2.5 the 1997 annual PM NAAQS by the applicable attainment

date of April 5, 2010. This determination was based upon complete, quality-assured, and certified

ambient air monitoring data for the 2007-2009 monitoring period.

PM2.5 ambient air quality monitoring data for the recent three (3) year period 2009 through 2011,

demonstrate 2.5 that the air quality continues to meet the NAAQS for annual PM in this nonattainment

area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter

Four, support a redesignation to attainment for the Martinsburg area based on the requirements in

Section 107(d)(3)(E) of the CAA.

DAQ commits 2.5 to continue monitoring PM levels at the West Virginia sites indicated in Figure 1

and Table 1. DAQ will consult with EPA Region III prior to making changes to the existing

monitoring network, should changes become necessary in the future. DAQ will continue to quality

assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. 

Connection to a central station and updates to the DAQ web site will provide real time availability

of the data and knowledge of any exceedances. DAQ will enter all data into AQS on a timely basis

in accordance with federal guidelines. 

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 5
Figure 2: West Virginia PM2.5 Annual Design Values, 1999-2001 through 2009-2011.

Data Source: http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25_DesignValues_2009201

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan 
Figure 3: Maryland PM2.5 Annual Design Values, 1999-2001 through 2007-2009.

Data Source: http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25_DesignValues_2009201

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan 
Figure 4: PM2.5 Annual Mean National Trends

Source: http://www.epa.gov/airtrends/pm.html

B. The Martinsburg Area has a Fully Approved SIP Under Section 110(k) of the CAA

On December 17, 2004, EPA promulgated the initial PM2.5 nonattainment areas designations for the

PM2.5 standards across the country, including the Martinsburg-Hagerstown, WV-MD area. 

Modifications to those designations were made and an effective date was set at April 5, 2005. On

November 20, 2009 [74 FR60199] EPA determined that the Martinsburg-Hagerstown, WV-MD area 

had attained the 1997 PM2.5 NAAQS (Clean Data Determination). This determination was based on

complete, quality-assured and certified ambient air monitoring data for the three year period, 2006-

2008. This determination suspended the state’s requirement to submit an attainment demonstration,

Reasonably Available Control Measures (RACM), including Reasonably Available Control

Technology (RACT), Reasonable Further Progress (RFP) plan, contingency measures, and other

planning SIP revisions related to attainment of the 1997 PM2.5 NAAQS for so long as the area

continues to attain the 1997 PM2.5 NAAQS.

On January 10, 2012 [77 FR 1411] EPA also determined that the Martinsburg-Hagerstown, WV-MD

area had attained the 1997 annual PM2.5 NAAQS by the applicable attainment date of April 5, 2010.

This determination was based upon complete, quality-assured, and certified ambient air monitoring

data for the 2007-2009 monitoring period. The DEP believes that all applicable requirements under

CAA section 110(k) have been met.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 8
C. The Martinsburg Area’s Air Quality Improvement is Due to Permanent and

Enforceable Emissions Reductions

Several federally enforceable control measures have been implemented during the past decade which

contribute to the air quality improvement, and will continue to reduce emissions in the future,

including:

x

• NO SIP Call and the Clean Air Interstate Rule (CAIR);

• Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards [65FR6698,

10FEB2000];

• Heavy-Duty Diesel Engines [65FR59896, 06OCT2000];

• Clean Air Non-road Diesel Rule [69FR38958, 29JUN2004]; and

• Various MACT regulations.

These are discussed in detail in Section V - Control Measures and Regulations.

D. The State has Developed a Maintenance Plan for the Martinsburg Area Which Ensures

Attainment of the 1997 PM2.5 Standard for at least 10 Years

Section 107(d)(3)(E) of the CAAA stipulates that for an area to be redesignated to attainment EPA

must approve a maintenance plan that meets the requirements of Section 175A. A state may submit

both the redesignation request and maintenance plan at the same time, and the plan adoption process,

including rule-making or public hearing proceedings, may proceed on a parallel track. West Virginia

is herein submitting a request to redesignate the Martinsburg area to attainment and is also requesting

that EPA concurrently process this request and the accompanying maintenance plan.

E. The Martinsburg AreaHas MetAll Relevant Requirements under CAA Section 110 and

Part D

For purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were

applicable prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated

nonattainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific

10

requirements applicable to particulate matter (specifically to address PM ).

1. Section 110(a) requirements

Section 110(a) of Title I of the CAA contains the general requirements for a SIP. As EPA has

stated in previous rulemaking , only the section 110 and part D requirements that are linked with 1

a particular area’s designation are the relevant measures which we may consider in evaluating a

redesignation request. Further, we believe that the other section 110 elements that are not

connected with nonattainment plan submissions and not linked with an area’s attainment status

See EPA’s proposed approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland

1

non 2.5 attainment area for the 1997 PM NAAQS. (76 FR 79593)

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 9
are also not applicable requirements for purposes of redesignation. A state remains subject to

these requirements after an area is redesignated to attainment.

The 2.5 requirements of section 110(a)(2) are statewide requirements that are not linked to the PM

nonattainment status of a nonattainment area. Therefore these SIP elements are not applicable

2.5 requirements for purposes of review of the state’s PM redesignation request.

2. Section 172(c) requirements

Section 172(c) contains general requirements for nonattainment plans. The requirements for

reasonable further progress, identification of certain emissions increases, and other measures

needed for attainment will not apply for redesignations because they only have meaning for areas

not attaining the standard. The requirements for an emission inventory will be satisfied by the

inventory requirements of the maintenance plan. Sections III and V discuss these requirements

in more detail.

3. Conformity

The state must work with EPA to show that its SIP provisions are consistent with the Section

176(c)(4) conformity requirements. The redesignation request should include conformity

procedures, if the state already has these procedures in place. If a state does not have conformity

procedures in place at the time that it submits a redesignation request, the state must commit to

follow EPA’s conformity regulation upon issuance, as applicable. EPA approved West Virginia’s

Transportation Conformity SIP detailing conformity procedures effective June 2, 2008 [73 FR

24175].Section IV discusses this requirement in more detail.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 10
III. MAINTENANCE PLAN

(CAA Section 107(d)(3)(E)(iv))

Section 107(d)(3)(E) stipulates that for an area to be redesignated, EPA must fully approve a

maintenance plan that meets the requirements of Section 175(A). The maintenance plan will

constitute a SIP revision and must provide for maintenance of the relevant NAAQS in the area for

at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such

additional measures, if any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures as the Administrator

deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the

contingency measures must include a requirement that the state will implement all measures

contained in the nonattainment SIP prior to redesignation.

West Virginia DAQ, in consultation with EPA and MDE, selected the year 2007 as the attainment

year, 2017 as the interim year and 2025 as the end year of the maintenance plan for this redesignation

request. This document contains actual emissions summaries for 2005 and 2007, and projected

emissions summaries for 2017 and 2025. Thus, the pertinent inventory years for West Virginia are:

2005 (nonattainment year), 2007 (attainment year and maintenance plan base year), 2017 (interim

year) and 2025 (maintenance plan end year). Detailed, SIP quality emissions inventories for all

pertinent years are contained in Appendix B. [The State of Maryland is requesting redesignation of

Washington County in a separate action.] Three specific emissions inventory demonstrations should

be made for Berkeley County:

1. The attainment year(2007) emissions must each be less than the corresponding emissions

in the nonattainment year (2005). The reductions must be attributable to federally

enforceable emission reductions (as discussed in Section III.E and Section V).

2. The interim year (2015) emissions should be less than the maintenance plan base year

(2007).

3. The end year (2025) emissions of each of the pollutants should be less than the

maintenance plan base year (2007).

As can be seen in Table 2 below, West Virginia and Maryland have seen a significant state-wide

decline 2 xin the emissions of SO and NO emitted by EGUs since 2002. In 2007 through 2011,

facilities began preparing for and implementing control programs to address CAIR and consent

decrees. Significant reductions occurred regionally and nationally. Data available for 2011, show the

SO2 x and NO reductions which were implemented under CAIR and consent decrees.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 11
Table 2: SO2 x

 and NO EGU Emissions 2002 through 2011

SO2

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

WV 507,110 539,858 473,760 467,082 454,158 371,996 301,574 174,583 106,088 92,609

MD 255,360 268,991 281,684 281,753 276,271 272,879 227,198 198,254 28,670 30,541

US

10,196,210 10,594,972 10,259,212 10,222,639 9,392,502 8,933,517 7,616,449 5,724,185 5,120,381 4,503,028

NOx

WV 225,371 203,142 172,339 159,481 151,673 150,849 97,331 36,120 51,393 53,415

MD 71,457 68,062 60,305 60,235 53,698 50,121 35,902 16,946 18,572 17,184

US

4,474,647 4,169,671 3,763,583 3,633,354 3,409,279 3,283,723 2,996,594 1,984,454 2,061,510 1,936,310

Source: Clean Air Markets, Air Markets Program Data, Acid Rain Program Emissions

Further, Tables 3- 20 clearly show total emissions have decreased in the period from 2005 to 2007

in Berkeley County, and emission projections through 2025 do not predict any increase in the total

emissions for Berkeley County or the Martinsburg area. As outlined below, the reductions are

enforceable and should continue in the future.

On March 10, 2004, EPA promulgated the CAIR. Beginning in 2009, EPA’s CAIR rule required

EGUs xin 28 eastern states and the District of Columbia to significantly reduce emissions of NO and

SO2 x. CAIR replaced the NO SIP Call for EGUs. The intent of the CAIR program was for national

NOx emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3

million tons in 2018 in 28 states. States were required to submit a CAIR SIP as part of this effort. 

West Virginia DEP submitted a CAIR SIP to EPA on June 1, 2006. Revisions to the CAIR SIP were

submitted on April 22, 2008. The revised CAIR SIP was approved on August 4, 2009 (74 FR 38536). 

As a xresult of CAIR, EPA projected that in 2009 emissions of NO would decrease from a baseline

of 179,000 2tons per yearto 63,000 tons per year while in 2010 emissions of SO would decrease from

a baseline of 582,000 tons per year to 250,000 tons per year, within West Virginia. And by 2015,

EPA projec x 2ted emissions of NO would decrease to 44,000 tons per year while emissions of SO

would decrease to 118,000 tons per year, within West Virginia. 

On December 23, 2008, EPA’s CAIR program was remanded without vacatur by the D.C. Circuit

Court.

The following was reported by EPA’s Clean Markets Division:

“Based on emissions monitoring data, EPA has observed substantial reductions in emissions

from 2005 to 2010 as companies installed more controls, electric demand declined, and low

natural gas prices made combined-cycle gas-fired units more competitive in several parts of

the country. Thus, even after CAIR’s vacatur and subsequent remand in late 2008, the controls

in place generally have continued to operate, helping to drive continued progress in reducing

em 2issions. However, allowance prices of SO have been relatively low since 2008, raising

concerns that coal-fired units could burn dirtier fuels, operate scrubbers at reduced efficiency,

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 12
or even bypass scrubbers altogether, instead relying on banked allowances (because there is

not an exist x xing large bank of NO allowances, NO allowance prices have not been affected

as 2 xsignificantly). For these reasons, EPA is tracking SO and NO emissions closely each

quarter to evaluate further progress and assess whether backsliding may be occurring and, if

so, where it may be taking place.” [http://www.epa.gov/airmarkets/background.htm] 

On July 6, 2010, EPA proposed a replacement to the CAIR program, the Transport Rule [75 FR

45210]. On July 6, 2011, EPA finalized the Transport Rule, now commonly referred to as the CrossState Air Pollution Rule (CSAPR) [76 FR 48208, 08 AUG 2011] in time for reductions to begin in

2012. As finalized, the CSAPR would have preserved the initial reductions achieved under CAIR

and provide more x 2reductions in NO and SO emissions in 2012 and 2014, ahead of the 2015 CAIR

Phase 2.

West Virginia DAQ is in agreement with the analysis by U.S. EPA that the CAIR program provided

2.5 real reductions. We believe these reductions have assisted with PM attainment in this nonattainment

area and throughout West Virginia. It is also the DAQ’s belief that the CSAPR will continue to

provide the necessary reductions, and likely even greater reductions, that will be necessary for

maintenance of 2.5 the annual PM standard to continue. As stated byEPA regarding the final Transport

Rule or CSAPR: 

This rule will prohibit all significant contribution to nonattainment and interference with

2.5 respect to the annual and 24-hour PM . In addition, it will resolve air quality issues at most

nonattainment and maintenance receptors identified by EPA. EPA projects that unresolved

nonattainment and maintenance issues will remain in only a few downwind states after

promulgation and 2.5 implementation of the Transport Rule. For the annual PM standard, EPA

projects that this rule will help assure that all areas in the east fully resolve their

nonattainment and maintenance concerns. This rule will also help a number of areas achieve

the standard earlier than they may have otherwise. [76 FR 48247] 

However, on December 30, 2011 the United States Court of Appeals for the District of Columbia

stayed the implementation of CSAPR, indefinitely reinstating CAIR.

Although there are no electric generating units in the West Virginia portion of the MartinsburgHagerstown, WV-MD area, the DAQ believes that CAIR, or any likely replacement for CAIR, will

constrain nearbyEGU NOx and SO2 emissions sufficientlyto ensure that maintenance level emissions

are not exceeded during the maintenance period.

As shown in Section VI - Supplemental Modeling Analyses, recent modeling -- CAIR, proposed

Transport Rule, CSAPR (Final Transport Rule), including base cases where CAIR and CSAPR were

not considered to be applicable requirements, and the VISTAS/ASIP modeling (which includes

CAIR) -- all show that the Martinsburg-Hagerstown, WV-MD area will continue to maintain the

1997 PM2.5 NAAQS. 

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 13
The base year, attainment year and projection years emissions inventory development discussion

contained in Appendix B identifies procedures used bythe Division of Air Quality (DAQ) to develop

emissions estimates for BerkeleyCounty, the West Virginia portion of the Martinsburg-Hagerstown,

WV-MD nonattainment area. The Maryland Department of the Environment (MDE) provided the

emission estimates (contained in Appendix D) for the Maryland portion of the area, based on growth

and control files for Point, Area, and Nonroad categories developed by MARAMA. Appendix E

contains MARAMA’s technical support document detailing the analysis used to project emissions. 

Baker performed Onroad mobile source emission projections using the EPA MOVES model. The

analysis is described in more detail in Appendix C for Berkeley County, WV and Appendix F for

Washington County, MD. All projections were made using federally approved interagency

consultation procedures.

Sectors included for West Virginia in the following tables are: Point, including Airports; Other Area

(Area); Locomotive and Marine (LM); Non-road Mobile (Nonroad); Fire; and Onroad Mobile

(Onroad). Since no Electric Generating Units (EGUs) are located in Berkeley County, there was no

need to include a sector for EGUs. The Point Source sector in Berkeley County is equivalent to the

Non-EGU sector in Washington County, MD.

Sectors for Maryland included in the following tables are: Electric Generating Units (EGUs); NonElectric Generating Units (Non-EGUs); Area; Marine, Aircraft and Rail (MAR); Non-road Mobile

(Nonroad); and Onroad Mobile (Onroad).

While the two states have slightly different subcategories for some emissions, the totals for the

individual pollutants and precursors demonstrate maintenance for the entire interstate nonattainment

area.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 14
A. PM2.5 Emissions Demonstrations

The 2005 and 2007 actua 2.5 2.5 l PM EGU and NonEGU emissions data below reflect PM -primary

emissions.

Table 3: Berkeley County, WV PM2.5 Emission Inventory Totals for 2005, 2007, 2017 and

2025 (tpy)

Sector 2005

(Base)

2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Point 361 227 222 5 239 -12

Area 1,430 677 694 -17 707 -30

LM 25 32 19 13 14 17

Nonroad 45 41 24 17 14 27

Fire 0.00 0.22 0.07 0.15 0.07 0.15

Onroad 199 176 66 111 40 137

TOTAL 2,059 1,154 1,025 129 1,015 139

*

Note: Numbers may not total exactly due to rounding. *

Table 4: Washington Coun 2.5 ty, MD PM Emission Inventory Totals for 2007, 2017 and

2025 (tpy)

Sector 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

EGU 310 277 33 299 11

NonEGU 188 188 0 188 0

Area 501 522 -20 538 -37

MAR 10 5 5 3 7

Nonroad 74 47 27 33 41

Onroad 218 125 93 78 140

TOTAL 1,301 1,163 138 1,139 162

*

Note: Numbers may not total exactly due to rounding. *

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 15
Table 5: Martinsburg Nonattainment Area PM2.5 Emission Inventory Totals for 2007,

2017 and 2025 (tpy) 

County 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Berkeley, WV 1,154 1,025 129 1,015 139

Washington, MD 1,301 1,163 138 1,139 162

Ma 2.5 rtinsburg PM Total 2,455 2,188 267 2,154 301

*

Note: Numbers may not total exactly due to rounding.

*

B. NOx Emissions Demonstrations

Table 6: Berkeley County, WV NOx Emission Inventory Totals for 2005, 2007, 2017 and

2025 (tpy)

Sector 2005

(Base)

2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Point 3,402 1,967 1,913 54 2,070 -103

Area 636 121 110 11 107 14

LM 849 943 584 359 424 519

Nonroad 469 437 230 208 149 289

Fire 0.00 0.07 0.02 0.04 0.02 0.04

Onroad 5,520 5,005 2,016 2,989 1,277 3,728

TOTAL 10,875 8,473 4,853 3,620 4,026 4,447

*

Note: Numbers may not total exactly due to rounding. *

Table 7: Washington Coun xty, MD NO Emission Inventory Totals for 2007, 2017 and

2025 (tpy)

Sector 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

EGU 1,398 1,390 8 1,390 8

NonEGU 1,982 1,516 466 1,518 465

Area 296 317 -22 339 -43

MAR 289 196 93 144 145

Nonroad 793 433 360 301 492

Onroad 6,022 3,361 2,641 2,312 3,710

TOTAL 10,781 7,233 3,548 6,004 4,777

*

Note: Numbers may not total exactly due to rounding. *

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 16
Table 8: Martinsburg Nonattainment Area NOx

 Emission Inventory Totals for 2007, 2017

and 2025 (tpy)

County 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Berkeley, WV 8,473 4,853 3,620 4,026 4,447

Washington, MD 10,781 7,233 3,548 6,004 4,777

Ma xrtinsburg NO Total 19,254 12,086 7,168 10,030 9,224

*

Note: Numbers may not total exactly due to rounding. *

C. SO2 Emissions Demonstrations

Table 9: Berkeley County, WV SO2 Emission Inventory Totals for 2005, 2007, 2017 and

2025 (tpy)

Sector 2005

(Base)

2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Point 1,978 1,444 1,405 39 1,521 -77

Area 575 300 249 50 241 59

LM 51 34 3 31 3 31

Nonroad 49 26 1 25 1 25

Fire 0.00 0.02 0.01 0.01 0.01 0.01

Onroad 109 30 10 20 10 20

TOTAL 2,462 1,833 1,667 166 1,776 57

*

Note: Numbers may not total exactly due to rounding. *

Table 10: Washington Coun 2ty, MD SO Emission Inventory Totals for 2007, 2017 and

2025 (tpy)

Sector 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

EGU 5,536 4,590 946 4,590 946

NonEGU 1,277 1,271 6 1,271 6

Area 274 80 195 83 191

MAR 5 2 4 2 4

Nonroad 45 1 44 1 44

Onroad 45 19 26 21 25

TOTAL 7,183 5,962 1,221 5,967 1,216

*

Note: Numbers may not total exactly due to rounding. *

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 17
Table 11: Martinsburg Nonattainment Area SO2

 Emission Inventory Totals for 2007,

2015 and 2025 (tpy)

County 2007

Attainment

2015

Interim

2015 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Berkeley, WV 1,833 1,667 166 1,776 57

Washington, MD 7,183 5,962 1,221 5,967 1,216

Ma 2rtinsburg SO Total 9,016 7,629 1,387 7,743 1,273

*

Note: Numbers may not total exactly due to rounding. *

D. NH3 Emissions Demonstrations

Table 12: Berkeley County, WV NH3 Emission Inventory Totals for 2005, 2007, 2017 and

2025 (tpy)

Sector 2005

(Base)

2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Point 67 91 93 -2 97 -7

Area 198 173 172 1 173 0

LM 0.35 0.42 0.45 -0.03 0.51 -0.09

Nonroad 0.39 0.41 0.49 -0.09 0.58 -0.17

Fire 0.00 0.01 0.00 0.01 0.00 0.01

Onroad 52 52 36 16 36 16

TOTAL 318 317 302 15 308 9

*

Note: Numbers may not total exactly due to rounding. *

Table 13: Washington Coun 3ty, MD NH Emission Inventory Totals for 2007, 2017 and

2025 (tpy)

Sector 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

EGU 0.00 0.00 0.00 0.00 0.00

NonEGU 0.00 0.00 0.00 0.00 0.00

Area 1,113 1,115 -2 1,116 -3

MAR 0.00 0.00 0.00 0.00 0.00

Nonroad 0.79 0.95 -0.16 1.07 -0.28

Onroad 92 68 24 74 17

TOTAL 1,206 1,184 22 1,192 14

*

Note: Numbers may not total exactly due to rounding. *

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 18
Table 14: Martinsburg Nonattainment Area NH3

 Emission Inventory Totals for 2007,

2017 and 2025 (tpy)

County 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Berkeley, WV 317 302 15 308 9

Washington, MD 1,206 1,184 22 1,192 14

Ma 2rtinsburg SO Total 1,522 1,485 37 1,500 23

*

Note: Numbers may not total exactly due to rounding. *

E. VOC Emissions Demonstrations

Table 15: Berkeley County, WV VOC Emission Inventory Totals for 2005, 2007, 2017 and

2025 (tpy)

Sector 2005

(Base)

2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Point 298 231 191 40 204 24

Area 2,505 1,386 1,042 343 1,089 296

LM 52 63 41 22 34 29

Nonroad 404 389 249 140 214 175

Fire 0.00 0.13 0.04 0.09 0.04 0.09

Onroad 1,473 1,378 673 705 498 880

TOTAL 4,732 3,447 2,197 1,250 2,042 1,405

*

Note: Numbers may not total exactly due to rounding. *

Table 16: Washington County, MD VOC Emission Inventory Totals for 2007, 2017 and

2025 (tpy)

Sector 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

EGU 10 9 1 9 0

NonEGU 354 353 0 353 0

Area 1,711 1,581 130 1,664 46

MAR 54 48 6 46 8

Nonroad 877 534 344 467 410

Onroad 1,657 948 709 725 931

TOTAL 4,662 3,472 1,191 3,266 1,397

*

Note: Numbers may not total exactly due to rounding. *

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 19
Table 17: Martinsburg Nonattainment Area VOC Emission Inventory Totals for 2007,

2017 and 2025 (tpy)

County 2007

Attainment

2017

Interim

2017 Safety

Margin

2025

Maintenance

2025 Safety

Margin

Berkeley, WV 3,447 2,197 1,250 2,042 1,405

Washington, MD 4,662 3,472 1,191 3,266 1,397

Ma 2rtinsburg SO Total 8,109 5,668 2,441 5,308 2,802

*

Note: Numbers may not total exactly due to rounding. *

F 2.5 x 2 3. Summary of PM , NO , SO , NH and VOC Emission Reductions

Table 18: West Virginia Portion of the Martinsburg Area Comparison of 2007 attainment

year and 2017 and 2025 projected emission estimates (tpy)

2007

Attainment

2017

Interim

2017

Projected

Decrease

2025

Maintenance

2025

Projected

Decrease

PM2.5 1,154 1,025 129 1,015 139

NOx 8,473 4,853 3,620 4,026 4,447

SO2 1,833 1,667 166 1,776 57

NH3 317 302 15 308 9

VOC 3,447 2,197 1,250 2,042 1,405

Note: Numbers may not total exactly due to rounding. *

Table 19: Maryland Portion of the Martinsburg Area Comparison of 2007 attainment

year and 2017 and 2025 projected emission estimates (tpy)

2007

Attainment

2017

Interim

2017

Projected

Decrease

2025

Maintenance

2025

Projected

Decrease

PM2.5 1,301 1,163 138 1,139 162

NOx 10,781 7,233 3,548 6,004 4,777

SO2 7,183 5,962 1,221 5,967 1,216

NH3 1,206 1,184 22 1,192 14

VOC 4,662 3,472 1,191 3,266 1,397

Note: Numbers may not total exactly due to rounding. *

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 20
Table 20: Martinsburg Area Comparison of 2007 attainment year and 2017 and 2025

projected emission estimates (tpy)

2007

Attainment

2017

Interim

2017

Projected

Decrease

2025

Maintenance

2025

Projected

Decrease

PM2.5 2,455 2,188 267 2,154 301

NOx 19,254 12,086 7,168 10,030 9,224

SO2 9,016 7,629 1,387 7,743 1,273

NH3 1,522 1,485 37 1,500 23

VOC 8,109 5,668 2,441 5,308 2,802

Note: Numbers may not total exactly due to rounding. *

As shown in the table above (Table 20), PM2.5 emissions in the nonattainment area are projected to

decrease xfrom the maintenance plan base year by 267 tons in 2017 and 301 tons in 2025. NO

emissions in the nonattainment area are projected to decrease by 7,168 tons in 2017 and 9,224 tons

2

in 2025. SO emissions in the nonattainment area are projected to decline by 1,387 tons in 2017 and

1,273 3tons in 2025. NH emissions in the nonattainment area are projected to decrease by 37 tons in

2017 and 23 tons in 2025. VOC emissions in the nonattainment area are projected to decrease by

2,441 tons in 2017 and 2,802 tons in 2025.

The Martinsburg area 2.5 x 2 3shows projected net reductions in PM , NO , SO , NH and VOC emissions.

Cleaner vehicles and fuels are expected to be in place in 2017 and 2025, and CAIR remains in place

until a CAIR Replacement Rule is finalized, these programs should cause an overall drop in the

emissions of all five pollutants. Decreases from EPA rules covering Tier 2 Motor Vehicle Emissions

Standards andGasolineSulfurControl Requirements [65FR6698,10FEB2000],HighwayHeavy-Duty

Engine Rule [62FR54694, 21OCT1997], and the Non-Road Diesel Engine Rule [63FR56968,

23OCT1998] are factored into the changes. 

G. Air Quality Improvement is Based on Permanent and Enforceable Emission Reductions

A demonstration that improvement in air quality between the year violations occurred and the year

attainment was achieved is based on permanent and enforceable emission reductions and not on

temporary adverse economic conditions or unusually favorable meteorology.

Ambient air quality data 2.5 from all monitoring sites indicate that air quality met the NAAQS for PM

in 2007-2009, 2008-2010 and in 2009-2011. EPA’s redesignation guidance (PolicyMemo from John

Calcagni, Director, Air Quality Management Division to Regional Air Directors: Air Procedures for

Processing Requests to Redesignate Areas to Attainment), dated September 4, 1992 (p. 9) states: “A

state may generally demonstrate maintenance of the NAAQS by either showing that future emissions

of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling

to show that the future mix of sources and emissions rates will not cause a violation of the NAAQS.”

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 21
Permanent and enforceable reductions of PM2.5 x 2

, NO , SO and VOC emissions have contributed to

2.5 the attainment of the annual PM standard. Some of these reductions were realized due to the

application of tighter federal standards on highway heavy-duty engines (Control of Emissions of Air

Pollution from Highway Heavy Duty Engines) and Nonroad diesel engines (Control of Emissions of

Air Pollution from Nonroad Diesel Engines), the application of tighter federal standards on new

vehicles (Control of Air Pollution from New Motor Vehicles: Tier 2 Motor Vehicle Emission

Standards and Gasoline Sulfur Control Requirements), Title xIV of the CAA, the NO SIP Call, CAIR, 

CSAPR, and the implementation of both major source and area source MACT standards. Reductions

achieved are discussed in greater detail under Section V.

H. Emissions Tracking

Provisions for future annual updates of the inventory to enable tracking of the emission levels,

including an annual emission statement from major sources.

In West Virginia, major point sources in all counties are required to submit air emissions information

annually 2.5 . West Virginia DAQ prepares a new periodic inventory for all PM precursor emission

sectors every three years in accordance with EPA’s Air Emissions ReportingRequirements (AERR). 

These PM2.5 precursor inventories will be prepared for future years as necessary to comply with the

inventory reporting requirements established in the CFR. Emissions information will be compared

to the 2005 base year and the 2025 projected maintenance year inventories to assess emission trends,

as necessary 2.5 , and to assure continued compliance with the annual PM standard.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 22
IV. TRANSPORTATION ANALYSIS

A. Onroad Emission Estimations

This section provides a summary of the on-road (highway) mobile source emissions inventory for the

BerkeleyCounty,West Virginia portion oftheMartinsburg-Hagerstown, WV-MD nonattainment area

under 2.5 the 1997 annual PM National Ambient Air Quality Standards (NAAQS). The estimations;

methodology; and conclusions have been reviewed through the Inter-Agency-Consultation process

detailed in West Virginia’sSIP-approvedMemorandum ofUnderstanding (MOU)[73 FR 24175].The

inventory was developed using EPA’s Motor Vehicle Emission Simulator (MOVES) model. The

section includes a summary of the methodology and data assumptions used for the analysis. 

1. Background

BerkeleyCounty (West Virginia) and Washington County(Maryland), two of the countyjurisdictions

in theHagerstownEastern PanhandleMetropolitanPlanningOrganization (HEPMPO), are designated

nonattainment 2.5 for the 1997 annual PM NAAQS. Based on recent monitor readings showing

compliance with the standard, a redesignation request and ten-year maintenance SIP has been

prepared for the area. This highway inventory supports the SIP by providing estimated highway

emissions for the 2005, 2007, 2017 and 2025 analysis years for the Berkeley County, West Virginia

portion of the nonattainment area. One or more of the analysis years in the projected inventory may

be designated as motor vehicle emission budgets (MVEBs) in support of future regional

transportation conformity analyses. The transportation plans and programs for the region must be in

conformance with all the provisions in the SIP and demonstrate that forecasted regional vehicle

emissions do not exceed the established MVEBs. 

The inventory is based on the latest planning assumptions including the use of regional planning tools

maintained by the HEPMPO, which is the responsible Metropolitan Planning Organization (MPO)

for the area. The highway emissions inventory has been estimated using MOVES, EPA's current

state-of-the-art tool for estimating emissions from highway vehicles. Compared to previous tools,

MOVES incorporates the latest emissions data, more sophisticated calculation algorithms, increased

user flexibility, new software design, and additional capabilities. EPA announced the release of

MOVES2010 in March 2010 (75 FR 9411), and released a minor revision as MOVES2010a in

September 2010. In April 2012, EPA released MOVES2010b to allow users to benefit from several

improvements to general model performance. MOVES2010b does not affect the criteria pollutant

emissions results of MOVES2010a and therefore is not a new model. Based on the timing of the

analysis, this highway emissions inventory utilizes the MOVES2010a model.

2. Highway Emissions

Table 21 summarizes the annual highway emissions inventory for the BerkeleyCounty portion of the

PM2.5 nonattainment area. The 2.5 inventory includes direct PM (from tailpipe, brake wear and tire

wear) ox x 2 3ides of nitrogen (NO ) and sulfur dioxide (SO ), ammonia (NH ) and Volatile Organic

Compounds (VOC). The emission estimates have been developed using the MOVES2010a emission

model and latest planning assumptions. In addition to the required analysis years, test runs were also

conducted for the current HEPMPO Long Range Transportation Plan (LRTP) 2040 horizon year. 

Available data on projects and land use were used to prepare this forecast. The 2040 analysis year

has been 2.5 included to illustrate the potential trends in PM emissions due to the limited impacts of

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 23
vehicle turnover and technology in that timeframe. These emission trends are considered in the

development of final MVEBs and safety margins.

Table 21: Summary of Highway Emissions Inventory

Pollutants

Emissions 

(Short Tons/Year)

2005 2007 2017 2025 2040

PM2.5 199.2 176.5 65.6 39.7 36.9

NOx 5,520 5,005 2,016 1,277 1,142

SO2 108.8 30.0 9.8 9.9 11.2

NH3 52.2 51.8 35.8 35.7 40.0

VOC 1472.9 1378.4 673.4 498.1 442.4

3. Analysis Methodology and Data Inputs

The analysis methodologyand data inputs were developed through interagencyconsultation and using

available EPA guidance documents including: 

• Policy Guidance on the Use of MOVES2010 and Subsequent Minor Revisions for SIP

Development, Transportation Conformity, and Other Purposes, US EPA Office of Air and

Radiation, EPA-420-B-12-010, April 2012.

• Using MOVES to prepare Emission Inventories in State Implementation Plans and

Transportation Conformity: Technical Guidance for MOVES2010, 2010a and 2010b. US

EPA Office of Air and Radiation, and Office of Transportation and Air Quality,

EPA-420-B-12-028, April 2012.

• Motor Vehicle Emission Simulator, User Guide for MOVES2010a, EPA-420-B-10-036,

August 2010.

The methodologies used to produce the emission data conform to the recommendations provided in

EPA’s technical guidance. A mix of local and national default (internal to MOVES2010a) data has

been used for this submission. As illustrated in Figure 5, local data has been used for the primary data

items that have a significant impact on emissions including vehicle miles of travel, vehicle

population, congested speeds, vehicle type mix and environmental and fuel assumptions. Local data

inputs to the analysis process reflect the latest available planning assumptions using information

obtained from the WVDOT, DEP, HEPMPO and other local/national sources. 

The analysis methodology used for this inventory is consistent with that planned for future HEPMPO

transportation conformity analyses including the latest LRTP. This includes the use of the regional

travel demand model outputs and custom post-processing software (PPSUITE) to calculate hourly

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 24
 speeds and prepare key traffic input files to the MOVES2010a emission model. PPSUITE consists

of a set of programs that perform the following functions:

• Analyzes highway operating conditions.

• Calculates highway speeds. 

• Compiles vehicle miles of travel (VMT) and vehicle type mix data.

• Prepares MOVES runs and processes MOVES outputs.

Figure 5. Local Data Inputs Used for Emissions Inventory

PPSUITE is a widely used and accepted tool for estimating speeds and processing emissions rates. 

It is has been used for past SIP highway inventories in Maryland, Pennsylvania, and New Jersey. The

software is based upon accepted transportation engineering methodologies. For example, PPSUITE

utilizes speed and delay estimation procedures based on planning methods provided in the Highway

Capacity Manual, a report prepared by the Transportation Research Board (TRB) summarizing

current knowledge and analysis techniques for capacity and level-of-service analyses of the

transportation system. 

The PPSUITE process is integral to producing traffic-related input files to the MOVES emission

model. Exhibit 4 summarizes the key functions of PPSUITE within the emission calculation process. 

Other MOVES input files are prepared external to the PPSUITE software. These include vehicle

population, vehicle age, environmental, and fuel input files.

Local Data

Assumptions

VMT

(HEPMPO

Model)

Speeds

(Calculated)

Vehicle Mixes

(WVDOT

Counts)

Vehicle

Population and

Age (DEP &

WVDMV)

Seasonal /

Hourly Factors

(WVDOT)

Environmental

and Fuel Data

(DEP)

Control

Strategies

(DEP)

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 25
Figure 6. Emission Calculation Process

The following subsections provide additional detail on the input planning assumptions and analysis

methodology including a description of data sources, the role of MOVES default parameters and

additional details on the role of PPSUITE in developing the traffic input data files to MOVES.

B. Description of Input Data

A large number of inputs to MOVES are needed to fully account for the numerous vehicle and

environmental parameters that affect emissions. These include traffic flow characteristics, vehicle

descriptions, fuel parameters, inspection/maintenance program parameters, and environmental

variables as shown in Figure 7. 

MOVES includes a default national database of meteorology, vehicle fleet, vehicle activity, fuel, and

emission control program data for every county; but EPA cannot certify that the default data is the

most current or best available information for any specific area. As a result, local data is

recommended for use in SIP analyses, where available. 

A mix of local and default data is used for this inventory. Local data sources are used for all inputs

that have a significant impact on calculated emission rates. These data items are discussed in the

following subsections.

Expand 

Volumes to 24 

Hours

HEP Travel 

Demand 

Model

% Pattern 

Distributions

Apply VMT 

Adjustments

Adjust 

Volumes

for Peak 

Spreading

V/C 

thresholds for

spreading

Disaggregate

to 

Vehicle Types

Vehicle 

Mapping File

Calculate Link 

Mid-block 

Speed and 

Approach 

Delays

Roadway 

attributes 

(Lanes, FC, 

AT, other)

Lookup Table

Apply Post

Speed VMT 

Adjustments

Prepare 

MOVES 

CDM Files

VHT by 

Speed Bin

Annual VMT

Road Type 

Fractions

Source Type 

Population 

Per VMT 

<Optional>

Hourly 

Fractions

Ramp 

Fractions

<Optional>

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 26
Figure 7. Examples of Key MOVES Input Data

1. Roadway Data

The roadway data input to emissions calculations for this inventory is based on information from the

HEPMPO regional travel demand model as used for the region’s LRTP, Direction 2035. The travel

model, as illustrated in Figure 8, estimates roadway volumes based on input demographic forecasts

and expected changes to the transportation roadway network.

The HEPMPO travel demand model follows the basic “four-step” travel demand forecasting process

and utilizes the TransCAD software platform. Given the small portion of daily travel carried by the

bus system in the Hagerstown and Martinsburg regions, a separate mode choice or transit model is

not included. Auto-occupancy factors are used to convert person trips into vehicle trips. 

The model is driven by socio-economic and transportation network data. These data include items

such as zonal population, households, income, school enrollment, and employment by type for 494

zones defined in the region. Transportation network data includes facility type, length, and speed

limit for each of the highway links defined in the region. The highway network database contains

attributes for each individual line in the line layer and includes all attributes needed to perform a

traffic assignment. The travel model and associated land use inputs used for this inventory were

based on the assumptions used for the 2035 LRTP submitted in June 2010. 

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 27
Figure 8. HEP Regional Travel Demand Model

The travel model network and assigned traffic volumes are processed by the PPSUITE post processor

to prepare the traffic inputs needed to the MOVES emission model. The following information is

extracted from the model for emission calculations:

• lanes

• roadway capacity

• distance

• weekday traffic volume

• area type code

• facility class code

The volumes and distances are used in calculating highway VMT totals for each county. Forecast

traffic volumes from the regional travel model are based on the input demographics. Table 22

summarizes the demographics used for the Direction 2035 LRTP and for this emissions inventory. 

As discussed in the next subsection, adjustments are needed to convert the traffic volumes (and

VMT) to average daily conditions in each month. Additional forecast year demographics needed for

this inventory, including 2017 and 2025, were determined through interpolation. 

The lane values, capacities, area type, and facility class are important inputs for determining the

congestion and speeds for individual highway segments. The PPSUITE processing software allows

for many additional variables other than those available in the regional travel model. Using these

variables improves the calculation of congested speeds. Such variables include information regarding

free-flow speeds, traffic signal and control parameters, and volume-delay functions. This data is

determined from lookup tables based on the model link’s area type and facility class. Much of the

lookup table data was developed from information contained in the Highway Capacity Manual.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 28
Table 22: Demographic Growth Assumptions to the Travel Model

County Year Population Households Employment

Washington

2008 146,337 57,277 82,377

2035 199,253 79,913 106,048

Annual Growth 1.1% 1.2% 0.9%

Berkeley

2008 101,125 41,208 42,702

2035 140,905 61,808 61,349

Annual Growth 1.2% 1.5% 1.4%

Jefferson

2008 51,806 20,908 21,489

2035 79,053 35,624 32,687

Annual Growth 1.6% 2.0% 1.6%

Region

2008 299,268 119,393 146,568

2035 419,211 177,345 200,084

Annual Growth 1.3% 1.5% 1.2%

2. Other Supporting Traffic Data

Other traffic data is used to adjust and disaggregate traffic volumes. Key sources used in these

processes include the following:

• HPMS VMT: According to EPA guidance, baseline inventory VMT computed from the

regional model must be adjusted to be consistent with HPMS VMT totals. Although it has

some limitations, the HPMS system is currently in use in all 50 states and is being improved

under FHWA direction. Adjustment factors are calculatedwhich adjust the travel model VMT

to be consistent with the reported HPMS totals for that year. These factors are applied to all

county and facility group combinations within the region. These adjustments are important

for accounting for missing local roadway VMT that is not represented within the regional

travel model. For historic analysis years (e.g. 2005 and 2007), VMT has been reconciled to

match the reported VMT for each of those years.

• Seasonal Factors: The travel model produces traffic volumes representing an average

weekday. To support the annual emission calculation process, the model travel volumes are

adjusted to reflect average annual daily traffic (AADT), an average of all days in the year

including weekends and holidays. Seasonal adjustment factors were obtained from the

WVDOT. The factors are based on data processing of West Virginia’s permanent traffic

count stations. The seasonal factors are also used to develop the MOVES daily and monthly

VMT fraction files, allowing MOVES to determine the portion of annual VMT that occurs

in each month of the year.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 29
• Hourly Patterns: Speeds and emissions vary considerably depending on the time of day. 

Therefore, it is important to estimate the pattern by which roadway volume varies by hour of

the day. Pattern data is in the form of a percentage of the daily volumes for each hour. 

Distributions are provided for all the counties within the region and by each facility type

grouping. This data was not directly available from WVDOT but was determined through an

assessment of available data in other states. The same factors are also used to develop the

MOVES hourly fraction file.

3. Vehicle Class Data

Emission rates within MOVES vary significantly by the type of vehicle. The MOVES model

produces emissions and rates by thirteen MOVES vehicle source types. However, VMT is input to

MOVES by six HPMS vehicle groups. Table 23 summarizes the distinction between each

classification scheme.

Table 23: MOVES Source Types and HPMS Vehicle Groups

SOURCE TYPES HPMS Class Groups

11 Motorcycle 10 Motorcycle

21 Passenger Car 20 Passenger Car

31 Passenger Truck 30 Passenger/Light Truck

32 Light Commercial Truck 40 Buses

41 Intercity Bus 50 Single Unit Trucks

42 Transit Bus 60 Combination Trucks

43 School bus

51 Refuse Truck

52 Single Unit Short-haul Truck

53 Single Unit Long-haul Truck

54 Motor Home

61 Combination Short-haul Truck

62 Combination Long-haul Truck

For this regional inventory, vehicle type pattern data was developed for each county and facility class

combination based on WVDOT classification counts and internal MOVES defaults. As the first step,

WVDOT truck count data was used to develop percentage splits of the total volume to the following

vehicle groups:

• autos

• heavy trucks and buses

MOVES default 2008 VMT by HPMS vehicle type (for Berkeley county) were then used to split the

above vehicle groups (autos and trucks) into the 6 HPMS vehicle classes needed by MOVES.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 30
The vehicle type percentages are also provided to the capacity analysis section of PPSUITE to adjust

the speeds in response to trucks. That is, a given number of larger trucks take up more roadway space

than a given number of cars, and this is accounted for in the speed estimation process by adjusting

capacity using information from the Highway Capacity Manual. 

4. Vehicle Ages

Vehicle age distributions are input to MOVES for each county by the thirteen source types. The

distributions reflect the percentage of vehicles in the fleet up to 31 years old. The vehicle age

distributions were prepared by DEP based on information obtained from West Virginia Division of

Motor Vehicle (WVDMV) 2010 registration data. MOVES default values byanalysis yearwere used

for source types 41, 42, 43, 51, 52, 53, 61, and 62, which includes all heavy trucks and buses.

5. Vehicle Population Data

The information on the vehicle fleet including the number and age of vehicles impacts forecasted start

and evaporative emissions within MOVES. Similar to vehicle ages, MOVES requires the population

of vehicles by the thirteen source type categories. The MOVES national default values for calendar

year 2010 provided the data for source types 51, 52, 53, 61 and 62. All other light-duty vehicles,

buses and motor homes were developed based on WVDMV registration data. This data was

processed by DEP based on 2010 registration data. 

For the preparation of source type population for other years, the 2010 values were adjusted using

growth factors based on historic and forecast population and employment for the region from the

Woods and Poole 2012 State Profile. For light-duty vehicles, growth rates were developed based on

the population growth in Berkeley County. For heavy trucks, growth rates were determined by

selecting the maximum of the population and employment growth for that county.

6. Environmental and Fuel Data

Information on environmental, fuel, vehicle technology and other control strategy assumptions were

determined based on a review of MOVES2010a default information and other available local data. 

 

Average monthlyminimum and maximum temperatures were obtained from the South East Regional

Climate Center (SERCC). EPA’s MOBILE6.2-MOVES meteorological data convertor spreadsheet

(available from http://www.epa.gov/oms/models/moves/tools.htm) was used to prepare the hourly

temperature inputs needed for the MOVES model based on the available data. MOVES default

humidity values were used for the county.

MOVES default fuel assumptions were updated with the following local data assumptions by season:

• Summer (months 5-10): RVP=10 for E10 fuel; RVP=9 for conventional gasoline

• Winter (months 1,2,12): RVP=14

• Other (months 3,4,11): Uses MOVES default RVP that varies by year

The MOVES defaults included a 29% market share of E10 fuel in 2007 and a 100% market share of

E10 fuel in future analysis years.

7. Other Vehicle Technology and Control Strategy Data

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 31
West Virginia does not have a vehicle inspection maintenance program and there are no state vehicle

technologystrategies included in the highwayemissions inventory. Current federal vehicle emissions

control and fuel programs are incorporated into the MOVES2010a software. These include the

National Program standards covering model year vehicles through 2016. Modifications of default

emission rates are required to reflect the early implementation of the National Low Emission Vehicle

Program (NLEV) program in West Virginia. To reflect these impacts, EPA has released instructions

and input files that can be used to model these impacts. This inventory utilized the August 2010

version of the files (http://www.epa.gov/oms/models/moves/tools.htm). 

C. Analysis Methodology

The previous subsections have summarized the input data used for computing speeds and emission

rates for this highway emissions inventory. This subsection explains how PPSUITE and MOVES

uses that input data to produce emission estimates. Figure 9 provides a more detailed overview of

the PPSUITE analysis procedure using the available traffic data information described in the previous

subsection. 

1. VMT Preparation

Producing an emissions inventory with PPSUITE requires a process of disaggregation and

aggregation. Data is available and used on a very small scale - individual travel model roadway

segments for each of the 24 hours of the day. This data needs to be processed individually to

determine the distribution of vehicle hours of travel (VHT) by speed and then aggregated by vehicle

class to determine the input VMT to the MOVES emission model. Key steps in the preparation of

VMT include:

• Assemble Travel Model Link VMT - The HEPMPO regional travel model contains the

roadway links, distances and travel volumes needed to estimate VMT. The PPSUITE

software processes each link bysimplymultiplying the assigned travel volume bythe distance

to obtain VMT. Highway networks for analysis years not available from the past conformity

runs are calculated by interpolating VMT from existing networks. 

• Apply Seasonal Adjustments- PPSUITE takes the travel model average weekdayvolumes and

adjusts the volume to reflect average annual conditions (AADT). The AADT volumes are

used in the speed processing routines to determine an average set of congested speeds by hour

of the day. The link AADT volumes are assembled by PPSUITE and extrapolated to produce

the annual VMT file input to MOVES.

• Disaggregate to Hours - After adjusting the link volume to represent AADT, the volume is

split to each hour of the day. This allows for more accurate speed calculations (effects of

congested hours) and allows PPSUITE to prepare the hourly VMT and speeds for input to the

MOVES model.

• Peak Spreading - After dividing the daily volumes to each hour of the day, PPSUITE

identifies hours that are unreasonably congested. For those hours, PPSUITE then spreads a

portion of the volume to other hours within the same peak period, thereby approximating the

“peak spreading” that normally occurs in such over-capacity conditions. This process also

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 32
helps prevent hours with unreasonably congested speeds that may impact emission

calculations.

• Disaggregation to Vehicle Types - EPA requires VMT estimates to be prepared by source

type, reflecting specific local characteristics. The hourly volumes are disaggregated to the six

HPMS MOVES vehicle grouping based on WVDOT vehicle classification count data in

combination with MOVES defaults as described in the previous subsection.

• Apply HPMS VMT Adjustments - Volumes must also be adjusted to account for differences

with the HPMS VMT totals, as described previously. VMT adjustment factors are provided

as input to PPSUITE, and are applied to each of the roadway segment volumes. These factors

were developed from reported HPMS VMT totals for years 2005, 2007 and 2008. The 2008

factors are applied to future yearruns. The VMT added or subtracted to the travel model links

assume the speeds calculated using the original volumes for each roadway segment for each

hour of the day.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 33
Figure 9. PPSUITE Speed/Emission Estimation Procedure

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 34
2. Speed Estimation 

Emissions for many pollutants (including both VOC and NOx) vary significantly with travel speed. 

While VOCs generally decrease as speed increases, NOx decreases at the low speed range and

increases at higher speeds, as illustrated in Figure 10.

Figure 10. Emission Factor vs. Speed Variances (NOx)

Source: Figure 3 from Implications of the MOVES2010 Model on Mobile Source

Emission Estimates, Air & Waste Management Association, July 2010

EPA recognizes that the estimation of vehicle speeds is a difficult and complex process. Because

emissions are so sensitive to speeds, it recommends special attention be given to developing

reasonable and consistent speed estimates; it also recommends that VMT be disaggregated into

subsets that have roughly equal speed, with separate emission factors for each subset. At a minimum,

speeds should be estimated separately by road type. 

The computational framework used for this analysis meets and exceeds that recommendation. Speeds

are individually calculated for each roadway segment and hour and include the estimated delays

encountered at signals. Rather than accumulating the roadway segments into a particular road type

and calculating an average speed, each individual link hourly speed is represented in the MOVES

vehicle hours of travel (VHT) by speed bin file. This MOVES input file allows the specification of

a distribution of hourly speeds. For example, if 5% of a county's arterial VHT operates at 5 mph

during the AM peak hour and the remaining 95% operates at 65 mph, this can be represented in the

MOVES speed input file. For the highway emissions inventory, distributions of speeds are input to

MOVES by road type and source type by each hour of the day.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 35
To calculate speeds, PPSUITE first obtains initial capacities (how much volume the roadway can

serve before heavy congestion) and free-flow speeds (speeds assuming no congestion) from the

speed/capacity lookup data. As described in previous subsections, this data contains default roadway

information indexed by the area and facility type codes. For areas with known characteristics, values

can be directly coded to the database and the speed/capacity data can be overridden. However, for

most areas where known information is not available, the speed/capacity lookups provide valuable

default information regarding speeds, capacities, signal characteristics, and other capacityadjustment

information used for calculating congested delays and speeds. The result of this process is an

estimated average travel time for each hour of the day for each highway segment. The average time

multiplied by the volume produces vehicle hours of travel (VHT).

Developing the MOVES Traffic Input Files: 

The PPSUITE software is responsible for producing the following MOVES input files during any

analysis run:

• VMT by HPMS vehicle class

• VHT by speed bin

• road type distributions

• ramp fractions (Use MOVES defaults)

These files are text formatted files with a *.csv extension. The files are provided as inputs within the

MOVES County Data Manager (CDM) and are described below:

• VMT Input File: VMT is the primary traffic input that affects emission results. The roadway

segment distances and traffic volumes are used to prepare estimates of VMT. PPSUITE

performs these calculations and outputs the MOVES annual VMT input file to the County

Data Manager (CDM). The annual VMT is computed by multiplying the travel model

adjusted AADT by 365 days in a year.

• VHT by Speed Bin File: As described in the previous subsection, the PPSUITE software

prepares the MOVES VHT by speed bin file which summarizes the distribution of speeds

across all links into each of 16 MOVES speed bins for each hour of the day by road type. 

This robust process ensures that MOVES emission rates are used to the fullest extent and is

consistent with the methods and recommendations provided in EPA’s technical guidance.

• Road Type Distributions: InMOVES, typical drive cycles and associated operating conditions

vary by the type of roadway. MOVES defines five different road types as follows:

1 Off-Network

2 Rural Restricted Access

3 Rural Unrestricted Access

4 Urban Restricted Access

5 Urban Unrestricted Access

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 36
For this inventory, the MOVES road type distribution file is automatically generated by PPSUITE

using defined equivalencies. The off-network road type includes emissions from vehicle starts,

extended idle activity, and evaporative emissions. Off-network activity in MOVES is primarily

determined by the Source Type Population input. The remaining distribution among road types is

determined by equating the model facility types with each MOVES road type as follows:

• MOVES Road Type (2) = Rural travel model interstate and ramps

• MOVES Road Type (3) = All remaining Rural travel model facility types

• MOVES Road Type (4) = Urban travel model interstate and ramps

• MOVES Road Type (5) = All remaining Urban travel model facility types

• Ramp Fractions: MOVES default Ramp Fraction file (assuming 8% of ramp VMT fraction for

both urban and rural links) is used as inputs to MOVES. 

3. MOVES Runs

After computing speeds and aggregating VMT and VHT, PPSUITE prepares traffic-related inputs

needed to run EPA’s MOVES2010a software. Additional required MOVES inputs are prepared

external to the processing software and include temperatures, I/M program parameters, fuel

characteristics, vehicle fleet age distributions and source type population.

The MOVES county importer is run in batch mode. This program converts all data files into the

MYSQL formats used by the MOVES model. At that point a MOVES run specification file (*.mrs)

is created which specifies options and key data locations for the run. MOVES is then executed in

batch mode. 

MOVES can be executed using either the inventory or rate-based approaches. For this highway

emissions inventory, MOVES is applied using the inventory-based approach. Under this method,

actual VMT and population are provided as inputs to the model; MOVES is responsible for producing

the total emissions for the region. Under the rate-based approach, MOVES would produce emission

factors, after which PPSUITE would apply the emission factors to the link data and calculate total

regional emissions.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 37
Table 24: MOVES Run Data Checklist

Note: Because of regulatory requirements after the checklist was developed, the precursors ammonia

and Volatile Organic Compounds (VOC) were later added to the emission estimates.

Data Item Inputs Assumptions

MOVES RunSpec

Scale/Calulation Type County Scale Inventory Run

Seasonal Analysis Annual - 12 months including weekdays and weekend (using AADT approach)

Analysis Years 2005, 2007, 2017, 2025, 2040 (for outyear evaluation - optional to evaluate safety margin)

Pollutants PM2.5, NOx, SO2

Stage II Refueling Emissions Not Applicable

Fuel Types Gasoline, Diesel, CNG

Traffic Data

Base networks are those used for past HEPMPO LRTP analyses and conformity

Years not available are calculated by interpolating VMT from existing networks

Seasonal/Daily Adjustments Factors to develop MOVES daily and monthly VMT fraction files as inputs. Seasonal adjustment factors received 

from WVDOT.

County HPMS VMT Adjustments Calculate AADT HPMS adjustments for 2005, 2007 and 2008 (Ensure VMT for past years is consisitent with 

reported HPMS); HPMS VMT obtained from WVDOT website.

Vehicle Mixes

MOVES VMT required by 6 HPMS vehicle classes. Obtain WVDOT truck count data to determine average

truck percentages by functional class; Split model traffic volumes into auto and trucks using these

percentages and then use MOVES default VMT distributions for the Charleston region to divide the two

vehicle groups (auto and trucks) into MOVES 13 source types, which are recombined to the 6 HPMS vehicle

classes.

MOVES Inputs

Annual VMT Calculated by PPSUITE from Model network database / seasonal factors / vehicle mapping

Avg. Hourly Speed Distribution Calculated by PPSUITE (Minimum Speed = 2.5 mph); Based on Model volumes and speed post processing by 

hour of day. 

Road Type Distribution Calculated by PPSUITE; a RoadType field must be added to the Model network based on FC.

Ramp Fraction MOVES defaults

Month VMT Fractions Factors to convert AADT to an average day in each month (Local data or MOVES default). Calculated based

on seasonal adjustment factors.

Day VMT Fractions Based on AADT assumption (i.e. 5/7 & 2/7)

Hour VMT Fractions Factors to disaggregate daily traffic volumes by hour for different roadway functional classes. Borrow hourly

distributions from Washington County, MD.

Source Type Population

2010 Inputs provided by WVDEP --> Adjust/grow to 2005, 2007 and future years by applying factors developed 

from Woods & Poole population/employment forecast data. (For non-trucks: use population growth. For trucks: 

maximum of population & employment growth)

Vehicle Age Distribution Source Types 11, 21, 31, 32 & 54: based on 2010 WV DMV Registration Data;

Source Types 41, 42, 43, 51, 52, 53, 61 & 62: use MOVES National Defaults.

Fuel Parameters

(Gasoline/Diesel/CNG) 

Use MOVES defaults with the following updates to RVP:

1. Summer (months 5 - 10): RVP = 10 for E10 and RVP = 9 for conventional gasoline

2. Winter (months 1, 2, 12): RVP = 14

3. Months 3, 4 & 11: Use MOVES default RVP which varies by year - 10.783 in 2005, 11.339 in 2007, and

12.729 in future years.

(Note: MOVES defaults include 29% market share of E10 in 2007 and 100% market share of E10 in future

years)

 I/M Parameters No I/M programs

Temperatures/Humidity

Temperatures: Use monthly average Max/Mins provided by WVDEP as inputs to EPA's Mobile6-MOVES

converter to develop inputs in MOVES format.

Humidity: MOVES defaults

Control Programs

Early NLEV / CALLEVII Include EPA provided MOVES override database for early NLEV implementation

California ZEV Program Not Included

Highway Network

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 38
The following table shows the emissions totals by sector, for each county in the nonattainment area. For a mor

Appendices B, C, D and F.Table 25: Percentage of Charleston Emissions Attributable to Mobile Sources in 2007, 2017 and 2025

2007 2017 2025 2007 2017 2025 2007 2017 2025 2007 2017 2025 

Berkeley Co., WV Point 227 222 239 1,967 1,913 2,070 1,444 1,405 1,521 91 93 

Berkeley Co., WV Area 677 694 707 121 110 107 300 249 241 173 172 1Berkeley Co., WV LM 32 19 14 943 584 424 34 3 3 0.42 0.45 0.Berkeley Co., WV NonRoad 41 24 14 437 230 149 26 1 1 0.41 0.49 0.Berkeley Co., WV Fire 0 0.07 0.07 0.07 0.02 0.02 0.02 0.01 0.01 0.01 0.00 0.Berkeley Co., WV OnRoad 176 66 40 5,005 2,016 1,277 30 10 10 52 36 

Berkeley Co., WV SubTotal 1,154 1,025 1,015 8,473 4,853 4,026 1,833 1,667 1,776 317 302 3

Berkeley Co., WV Onroad Percentage 15.3% 6.4% 3.9% 59.1% 41.5% 31.7% 1.6% 0.6% 0.6% 16.3% 11.9% 11.6Washington Co., MD EGU 310 277 299 1,398 1,390 1,390 5,536 4,590 4,590 0.00 0.00 0.Washington Co., MD nonEGU 188 188 188 1,982 1,516 1,518 1,277 1,271 1,271 0.00 0.00 0.Washington Co., MD Area 501 522 538 296 317 339 274 80 83 1,113 1,115 1,1Washington Co., MD MAR 10 5 3 289 196 144 5 2 2 0.00 0.00 0.Washington Co., MD NonRoad 74 47 33 793 433 301 45 1 1 0.79 0.95 1.Washington Co., MD OnRoad 218 125 78 6,022 3,381 2,312 45 19 21 92 68 

Washington Co., MD Subtotal 1,301 1,163 1,139 10,781 7,233 6,004 7,183 5,962 5,967 1,206 1,184 1,1Washington Co., MD Onroad Percentage 16.7% 10.7% 6.8% 55.9% 46.7% 38.5% 0.6% 0.3% 0.3% 7.6% 5.7% 6.2

394 190 117 11,027 5,397 3,589 75 29 31 144 104 1

2,455 2,188 2,154 19,254 12,086 10,030 9,016 7,629 7,743 1,522 1,485 1,5

16.1% 8.7% 5.5% 57.3% 44.7% 35.8% 0.8% 0.4% 0.4% 9.4% 7.0% 7.3

SO2 NH3 

County Sector

Martinsburg, WV‐MDOnroad Total

Martinsburg, WV‐MDOnroad Percentage

Martinsburg, WV‐MD Total

PM2.5 NOx

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan 
D. Motor Vehicle Emission Budgets (MVEBs)

In order to ensure that transportation plans can accommodate some measure of unexpected growth, 

WVDEP proposed to establish MVEB’s that are higher than the initial projected onroad (highway)

emission estimates. The MVEBs are herein being adopted and will become effective after EPA

approval or a formal adequacyfinding. The Transportation ConformityRule (40 CFR 93.101) defines

Safety margin as:

“the amount by which the total projected emissions from all sources of a given pollutant are

less than the total emissions that would satisfy the applicable requirement for reasonable

further progress, attainment, or maintenance” (emphasis added). 

Thus, in the context of the maintenance plan, there may be safety margins associated with the 2017

interim year and separate safety margins associated with the 2025 end year. These safety margins are

calculated bysubtracting the 2017 total emissions (for a given pollutant) and the 2025 total emissions

(for a given pollutant), respectively, from the 2007 attainment year total emissions (for a given 

pollutant). We may refer to the results for a given pollutant/precursor as the 2017 safety margin and

the 2025 safety margin, respectively.

Portions of the original safetymargins may be reallocated to the MVEBs as long as adequate margins

remain to ensure maintenance. It is important to consider that transportation planning organizations

typically develop a twenty year Long Range Transportation Plan (LRTP) while the initial air quality

maintenance plan only lasts for ten years. Under the conformity rule, the last year of the LRTP must

be tested against the MVEBs established for the last year of the maintenance plan. Therefore, future

transportation conformity determinations will not only be made for the specific years contained in the

maintenance plans but also for horizon years contained in the LRTP, which now may extend to the

year 2040.

That is, the future expected highway emissions, including growth, in 2040 will be compared against

the 2025 MVEBs. It is also veryimportant to recognize DAQ has little prior experience with MOVES

in SIP development and must take prudent steps to ensure positive conformity determinations in the

case where our agency’s inexperience with, or misapplication of, MOVES leads to significant

underestimation of future highway emissions. Therefore, it is DAQ’s firm position that liberal

amounts of the safety margins should be reallocated to the MVEBs to provide certainty in the

transportation planning process.

With respect to the precursor emissions of ammonia and VOC, no MVEBs are required due to the

provisions of the Transportation ConformityRule section 40 CFR § 93.102(b)(2)(v) and the fact that

neither the Administrator of EPA nor the State of West Virginia has made a finding that

transportation-related emissions of these two precursors within the nonattainment area are a

2.5 significant contributor to the PM nonattainment problem.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 40
1. NOx

 MVEBs

NOxis a precursor pollutant and contributes to fine particulate concentrations through the formation

of nitrates. Only a xfraction of the NO emissions is actually converted. Therefore, WVDEP believes

x

that relatively higher NO emissions (as a percent of onroad emissions) may be incorporated in the

MVEBs without endangeringmaintenance. In this case, WVDEP is adding 30% to the initial highway

emission estimates to set the NOx MVEBs for 2017 and 2025, respectively.

Tab xle 26: Berkeley County (WV) NO Emission Inventory Totals, Onroad (Highway) Emissions and

Original Safety Margins for 2017 and 2025 (tpy)

2007

Attainment

2017

Interim

2017

Original

Safety

Margin

2025

Maintenance

2025

Original

Safety

Margin

B xerkeley County NO Total 8,473 4,853 3,620 4,026 4,447

Onroad Subtotal 5,005 2,016 na 1,277 na

Totals may not sum exactly due to rounding.

Thus, x xthe original NO 2017 safety margin is 3,620 tons per year and the original NO 2025 safety

marg xin is 4,447 tons per year. The DAQ is reallocating an additional 30% to the original onroad NO

estimates xfrom the respective safety margins to the NO MVEBs. That is, 605 tpy is subtracted from

the 2017 safety margin and added to the highway emission estimate yielding a 2017 MVEB of 2,621

tpy, leaving a remainder of 3,015 tpy in the final 2017 safety margin. Similarly, 383 tpy is subtracted

from the 2025 safety margin and added to the 2025 highway emission estimate, yielding a 2025

MVEB of 1,660 tpy, leaving a remainder of 4,064 tpy in the final 2025 safety margin.

Tab xle 27: Berkeley County (WV) NO MVEBs and Remaining Safety Margins

A xfter Reallocation from the Original Safety Margins into the NO MVEBs

2007

Attainment

2017

Original

Safety

Margin

OnRoad

Amount

Reallocated

to 2017

MVEB

2017

Remaining

Safety

Margin and

Final

MVEB

2025

Original

Safety

Margin

OnRoad

Amount

Reallocated

to 2025

MVEB

2025

Remaining

Safety

Margin

and Final

MVEB

Berkeley

NOx Total

8,473 3,620 -605 3,015 4,447 -383 4,064

Onroad

NOx MVEB

5,005 2,016 +605 2,621 1,277 +383 1,660

Totals may not sum exactly due to rounding.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 41
2. Direc 2.5 t PM MVEBs

Direc 2.5 t PM emissions(filterable and condensable) affect fine particulate concentrations more quickly

and more significantly than precursor pollutants, on a mass emissions basis. Therefore, WVDEP is

adopting 2.5 a lower onroad emissions augmentation of 25% for direct PM .

Tab 2.5 le 28: Berkeley County (WV) PM Emission Inventory Totals, Onroad (Highway) Emissions and

Original Safety Margins for 2018 and 2025 (tpy)

2007

Attainment

2017

Interim

2017

Original

Safety

Margin

2025

Maintenance

2025

Original

Safety

Margin

Berke xley County NO Total 1,154 1,025 129 1,015 139

Onroad Subtotal 176 66 na 40 na

Totals may not sum exactly due to rounding.

Thus, 2.5 2.5 the original PM 2017 safety margin is 129 tons per year and the original PM 2025 safety

marg 2.5 in is 139 tons per year. The DAQ is reallocating an additional 25% to the original onroad PM

estimates 2.5 from the respective safety margins to the PM MVEBs. That is, 17 tpy is subtracted from

the 2017 safetymargin and added to the highway emission estimate yielding a 2017 MVEBof 83 tpy, 

leaving a remainder of 112 tpy in the final 2017 safety margin. Similarly, 10 tpy is subtracted from

the 2025 safety margin and added to the 2025 highway emission estimate, yielding a 2025 MVEB of

50 tpy, leaving a remainder of 129 tpy in the final 2025 safety margin.

Tab 2.5 le 29: Berkeley County (WV) PM MVEBs and Remaining Safety Margins

A 2.5 fter Reallocation from the Original Safety Margins into the PM MVEBs

2007

Attainment

2017

Original

Safety

Margin

OnRoad

Amount

Reallocated

to 2017

MVEB

2017

Remaining

Safety

Margin and

Final

MVEB

2025

Original

Safety

Margin

OnRoad

Amount

Reallocated

to 2025

MVEB

2025

Remaining

Safety

Margin

and Final

MVEB

Berkeley

County

PM2.5 Total

1,154 129 -17 112 139 -10 129

Onroad

PM2.5

MVEB

176 66 +17 83 40 +10 50

Totals may not sum exactly due to rounding.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 42
3. Summary of Adopted MVEBs

2017 NOx MVEB: 2,621 TPY 2025 NOx 2.5 MVEB: 1,660 TPY

2017 PM2.5 2.5 MVEB: 83 TPY 2025 PM MVEB: 50 TPY

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 43
V. CONTROL MEASURES AND REGULATIONS

CAA Section107 (d)(3)(E)(ii), 107(d)(3)(iv), and 107(d)(3)(E)(v)

A. Reasonably Available Control Measures (RACM) and Reasonably Available Control

Technology (RACT)

Section 172(c)(1) of the 1990 Clean Air Act Amendments (CAA) requires states with nonattainment

areas to implement reasonably available control measures (RACM) and reasonably available control

technology(RACT). Stateswith nonattainment areas must submit a SIP providing for implementation

of allreasonablyavailable control measures as expeditiouslyas practicable (including such reductions

in emissions from existing sources in the area as may be obtained through the adoption, at a

minimum, of reasonable available control technology).

EPA states on their website regarding RACM, RACT, and the Clean Data Policy

[www.epa.gov/airquality/urbanair/sipstatus/policy_details.html]: 

Under EPA’s Clean Data Policy and the regulations that embody it, 40 CFR 51.918 (1997

8-hour ozone) and 51.1004(c) (PM-2.5), an EPA rulemaking determination that an area is

attaining the relevant standard suspends the area’s obligations to submit an attainment

demonstration, reasonable available control measures (RACM), reasonable further progress,

contingencymeasures and other planning requirements related to attainment for as long as the

area continues to attain. EPA’s statutory interpretation of the Clean Data Policy is described

in the “Final Rule to Implement the 8-hour Ozone National Ambient Air Quality

Standard—Phase 2" (Phase 2 Final Rule). 70 FR 71612, 71644-46 (Nov. 29, 2005) (ozone);

See also 72 FR 20585, 20665 (Apr. 25, 2007) (PM-2.5). EPA believes that the legal bases set

forth in detail in our Phase 2 Final rule, our May 10, 1995 memorandum from John S. Seitz,

entitled “Reasonable Further Progress, Attainment Demonstration, andRelated Requirements

for Ozone Nonattainment Areas Meeting the Ozone National Ambient Air QualityStandard,”

and our December 14, 2004 memorandum from Stephen D. Page entitled “Clean Data Policy

for the Fine Particle National Ambient Air Quality Standards” are equally pertinent to all

NAAQS. EPA has codified the Clean Data Policy for 1997 8-hour ozone and PM-2.5, and has

also applied it in individual rulemakings for 1-hour ozone and PM-10.

Under the Clean Data Policy, EPA may issue a determination of attainment (known

informally as a Clean Data Determination) after notice and comment rulemaking determining

that a specific area is attaining the relevant standard. Forsuch areas the requirement to submit

to EPA those SIP elements related to attaining the NAAQS is suspended for so long as the

area continues to attain the standard. These planning elements include reasonable further

progress(RFP) requirements, attainment demonstrations, RACM, contingencymeasures, and

other state planning requirements related to attainment of the NAAQS. The determination of

attainment is not equivalent to a redesignation, and the state must still meet the statutory

requirements for redesignation in order to be redesignated to attainment. A determination of

attainment for purposes of the Clean Data Policy/regulations is also not linked to any

particular attainment deadline, and is not necessarilyequivalent to a determination that an area

has attained the standard by its applicable attainment deadline, e.g., under section 181(b).

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 44
On November 20, 2009 [74 FR60199] EPA determined that the Martinsburg-Hagerstown, WV-MD

area had attained 2.5 the 1997 PM NAAQS (Clean Data Determination). This determination was based

on complete, quality-assured and certified ambient air monitoring data for the three year period, 

2006-2008. This determination suspended the state’s requirement to submit an attainment

demonstration, Reasonably Available Control Measures (RACM), including Reasonably Available

Control Technology (RACT), Reasonable Further Progress (RFP) plan, contingency measures, and

other planning SIP 2.5 revisions related to attainment of the 1997 PM NAAQS for so long as the area

continues to attain the 1997 PM2.5 NAAQS.

On January 10, 2012 [77 FR 1411] EPA also determined that the Martinsburg-Hagerstown, WV-MD

area had attained 2.5 the 1997 annual PM NAAQS by the applicable attainment date of April 5, 2010.

This determination was based upon complete, quality-assured, and certified ambient air monitoring

data for the 2007-2009 monitoring period. 

Complete quality 2.5 -assured PM ambient air quality data for the most recent three (3) years, 2009

2.5 through 2011, demonstrate that the air quality continues to meet the NAAQS for annual PM in this

nonattainment area. Therefore, RACM, including RACT, no longer applies.

B. Inventory of Actual Emissions

CAA Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in

the area, including the requirement for periodic revisions as determined necessary. 40 CFR 51.1008

requires such inventory to be submitted within three years of designation and requires a baseline

emission inventory for calendar year 2002 or other suitable year to be used for attainment planning.

West Virginia is herein submitting the 2007 comprehensive inventory for the West Virginia portion

of the Martinsburg nonattainment area to meet the requirements of CAA Section 172(c)(3).

West Virginia will continue to provide updates to future inventories in accordance with EPA’s AERR

rule. As discussed in Section III.F, West Virginia DAQ submits, and commits to continue

submissions of emission inventories every three years. 

C. Evidence 2.5 that control measures required in past PM SIP revisions have been fully

implemented.

1. NOx SIP Call, CAIR and CSAPR

The EPA NOx SIP Call required 22 states to pass rules that would result in significant emission

reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States.

West Virg xinia passed this rule in 2002. NO SIP Call requirements are incorporated into permits

along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. 

West Virginia DAQ also has an active enforcement program to address violations discovered by

field office staff. Compliance is tracked through the Clean Air Markets data monitoring program.

In West Virginia, this rule accounted for a reduction from 2003 levels of approximately 57

percent of NOx emissions by 2008 from sources subject to the rule. The other 21 states also

adopted these rules. 

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 45
On March 10, 2004, the EPA promulgated the CAIR. Beginning in 2009, EPA’s CAIR rule

required EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions

of NOx and SO2 x x. CAIR replaced the NO SIP Call for EGUs. National NO emissions were

expected to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3

million tons in 2018 in 28 states. States were required to submit a CAIR SIP as part of this effort. 

West Virginia submitted an initial CAIR SIP on June 1, 2006. Subsequently, WV submitted an

abbreviated CAIR SIP on June 8, 2007, which requested authority to allocate CAIR allowances.

Final revisions to the CAIR SIP were submitted on April 22, 2008. The revised CAIR SIP was

approved in a direct final action on August 2, 2009 (74FR38536 ). 

On July 6, 2010, EPA proposed a replacement to the CAIR program, the Transport Rule [75 FR

45210]. On July 6, 2011, EPA finalized the Transport Rule, now commonly referred to as the

Cross-State Air Pollution Rule (CSAPR) [76FR48208, 08AUG2011] in time for reductions to

begin in 2012. As finalized, the CSAPR would have preserved the initial reductions achieved

under CAIR and provided more x 2 reductions in NO and SO emissions in 2012 and 2014, ahead

of the 2015 CAIR Phase 2.

EPA states on their Cross-State Air Pollution Rule homepage: “By 2014, power plants in states

common 2to both the Cross-State Air Pollution Rule and CAIR will achieve annual SO emissions

around 1.8 million xtons lower and annual NO emissions around 76,000 tons lower than what

would have been achieved at that time under CAIR.” (www.epa.gov/airtransport/basic.html) 

Control xs for EGUs under the NO SIP Call formally commenced May 31, 2004. Emissions

covered by this program have been generally trending downward since 1998 with larger

reductions occurring in 2002 and 2003. Data taken from the EPA Clean Air Markets web site,

quantify the gradual NOx reductions that have occurred in West Virginia as a result of Title IV

of xthe 1990 CAA Amendments and the beginning of the NO SIP Call Rule. West Virginia

developed xthe NO Budget Trading Program rules in 45CSR 1 and 26 in response to the SIP Call.

45CSR1 regulated EGUs and 45CSR26 regulated certain non-EGUs under a cap and trade

prog xram based on an 77 percent reduction of NO emissions from EGUs and a 60 percent

x

reduction of NO emissions from non-EGUs, compared to historical levels. This cap was in place

through 2008, at which time the CAIR program superseded it as discussed above. Section III

above discussed the reductions West Virginia has seen as a result of CAIR.

On April 21, 2004, EPA published Phase xII of the NO SIP Call that established a budget for large

(greater than 1 ton per day emissions) stationary internal combustion engines. 45CSR1 addresses

stationary internal combustion engines, all used in natural gas pipeline transmission. EPA

approved xthis revision to the SIP on November 27, 2006. An 82 percent NO reduction from 1995

levels was anticipated. Approval of the compliance plans occurred by August 4, 2006, and March

1, 2007 and the compliance demonstration began May 1, 2007.

2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards

[65FR6698, 10FEB2000]

In February 2000, EPA published a federal rule to significantly reduce emissions from cars and

light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be

required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. 

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 46
This rule applies nationwide. The federal rules phased in between 2004 and 2009. EPA

estimated xthat NO emission reductions will be approximately 77 percent for passenger cars, 86

percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger

SUVs, vans, and heavier trucks. The sulfur content of gasoline is estimated to be reduced by up

to 90 percent. VOC emission reductions will be approximately 12 percent for passenger cars, 18

percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and

heavier trucks. 

3. Heavy-Duty Diesel Engines 

[65FR59896, 06OCT2000]

In October 2000, EPA published a final rule for Highway Heavy Duty Engines, a program which

includes low-sulfur diesel fuel standards, which were phased in from 2004 through 2007. This

rule applies to heavy-duty gasoline and diesel trucks and buses. This rule resulted in a 40 percent

x x

reduction in NO from diesel trucks and buses, a large sector of the mobile sources NO inventory.

It also estimated the level of sulfur in highway diesel fuel would be reduced by 97 percent by

mid-2006.

4. Clean Air Non-road Diesel Rule 

[69FR38958, 29JUN2004]

In June 2004, EPA published the Clean Air Non-road Diesel Rule. This rule applies to diesel

engines used in industries such as construction, agriculture, and mining. It also contains a cleaner

fuel standard similar to the highway diesel program. The new standards will cut emissions from

non-road diesel engines bymore than 90 percent. Non-road diesel equipment, as described in this

x

rule, currently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NO

from mobile sources nationwide. Sulfur levels will be reduced in non-road diesel fuel by 99

percent from 2004 levels, from approximately 3,000 parts per million (ppm) to 15 ppm in 2009. 

New engine standards took effect, based on engine horsepower, starting in 2008. Together, these

2.5 rules will substantially reduce local and regional sources of PM precursors.

5. MACT Regulations

The Clean Air Act requires EPA to regulate emissions of toxic air pollutants from a published list

of industrial sources referred to as “source categories.” As required under the Act, EPA has

developed Maximum Achievable Control Technology Standards, or MACT standards, for a list

of source categories that must meet control technology requirements to reduce the emission of

toxic air pollutants.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 47
MACT Source Categories with Compliance Dates On or After 2005

MACT Source Category 40CFR63

Subpart

Date

Promulgated

Existing

Source

Compliance

Date

Pollutants

Affected

Publicly Owned Treatment Works (POTW) VVV 10/26/99 10/26/02 VOC

Coke Ovens L 10/27/03 Phased from

1995-2010

VOC

Coke Ovens: Pushing, Quenching, and Battery

Stacks

CCCCC 4/14/03 4/14/06 VOC

Asphalt Roofing Manufacturing and Asphalt

Processing (two source categories)

LLLLL 4/29/03 5/1/06 VOC

Metal Furniture (Surface Coating) RRRR 5/23/03 5/23/06 VOC

Printing, Coating, and Dyeing of Fabrics OOOO 5/29/03 5/29/06 VOC

Wood Building Products (Surface Coating) QQQQ 5/28/03 5/28/06 VOC

L 2ime Manufacturing AAAAA 1/5/04 1/5/07 PM, SO

Site Remediation GGGGG 10/8/03 10/8/06 VOC

Iron & Steel Foundries EEEEE 4/22/04 04/23/07

04/22/05 work

practice std.

VOC

T 2aconite Iron Ore Processing RRRRR 10/30/03 10/30/06 PM, SO

Miscellaneous Coating Manufacturing HHHHH 12/11/03 12/11/06 VOC

Metal Can (Surface Coating) KKKK 11/13/03 11/13/06 VOC

Plastic Parts and Products (Surface Coating) PPPP 4/19/04 4/19/07 VOC

Miscellaneous Metal Parts and Products

(Surface Coating) (includes Asphalt/Coal Tar

Application to Metal Pipes)

MMMM 1/2/04 1/2/07 VOC

Industrial Boilers, Institutional/ Commercial

Boilers and Process Heaters

DDDDD 9 2/13/04 9/13/07 PM, SO

Plywood and Composite Wood Products DDDD 7/30/04 10/1/07 VOC

R xeciprocating Internal Combustion Engines ZZZZ 6/15/04 6/15/07 NO , VOC

Auto and Light-Duty Truck (Surface Coating) IIII 4/26/04 4/26/07 VOC

Wet Formed Fiberglass Mat Production HHHH 4/11/04 4/11/05 VOC

Metal Coil (Surface Coating) SSSS 6/10/02 6/10/05 VOC

Paper and Other Web Coating (Surface

Coating)

JJJJ 12/4/02 12/4/05 VOC

Miscellaneous Organic Chemical Production

(MON)

FFFF 11/10/03 5/10/08 VOC

Electric Arc Furnace Steelmaking Facilities

(Area Sources)

YYYYY 12/28/07 6/30/08 PM

Fabric Printing, Coating & Dyeing OOOO 5/29/03 5/29/06 VOC

Gasoline Dispensing Facilities (Area Sources) CCCCCC 1/10/08 1/10/11 VOC

Gasoline Distribution Bulk Terminals, Bulk

Plants, and Pipeline Facilities (Area Sources)

BBBBBB 1/10/08 1/10/11 VOC

ICI Boilers & Process Heaters- Major Sources DDDDD 12/21/12 2016/2017 PM

ICI Boilers & Process Heaters- Area Sources JJJJJJ 12/21/12 3/21/14 PM

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 48
D. Assurance that existing control measures will remain in effect

West Virginia commits to maintaining the aforementioned control measures afterredesignation. West

Virginia hereby commits that any changes to its rules or emission limits required for maintenance of

2.5 the annual PM standard in the Martinsburg area, will be submitted to EPA for approval as a SIP

revision. 

West Virginia, through the Division of Environmental Protection, DAQ, has the legal authority and

necessary resources to actively enforce any violations of its rules or permit provisions. After

2.5 redesignation, it intends to continue enforcing all rules that relate to the emission of PM precursors

in the Martinsburg Area.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 49
VI. SUPPLEMENTAL MODELING ANALYSES

Although EPA’s Redesignation Guidance does not require modeling nonattainment areas seeking

redesignation, extensive modeling has been performed covering the Martinsburg-Hagerstown, WVMD area 2.5 to determine the effect of national emission control strategies on PM concentrations. These

modeling analyses determined that the Martinsburg-Hagerstown, WV-MD area is significantly

2.5 2 x

impacted by regional transport of PM and its precursors, and that regional SO and NO reductions

are an effective way 2.5 to attain the annual standards for PM in this area. Future year modeled annual

PM2.5 concentrations are expected to be reduced by6% to 25% from baseline design values. Examples

of these modeling analyses are described below.

A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule)

EPA performed modeling to support the emission reductions associated with the Final Transport Rule

or the Cross State Air Pollution Rule (CSAPR), as it is currently called. EPA used the Comprehensive

Air QualityModel with Extension (CAMx) version 5.3 applied to the 2005 meteorology as processed

by 2 xthe Mesoscale Model (MM5), Version 3.7.4. Emissions input into the CAMx included SO , NO ,

VOC, NH3 and direc 2.5 t PM for 2005. The modeling was based on the annual fine particle design

values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year

modeling was conducted, and the future year design values for 2012 and 2014 were evaluated for

attainment of 2.5 the annual NAAQS for PM of 15 μg/m , as shown in Table 24. The BerkeleyCounty 3

monitor (54-003-0003) represents the Martinsburg area.

As indicated in the Air Quality Modeling Technical Support Document (TSD) for the CSAPR, air

quality modeling was performed for several emissions cases: a 2005 base year, a 2012 “no CAIR”

base case, a 2014 “no CAIR” base case, and the 2014 remedy case.

Modeling results for the Martinsburg area (Berkeley County monitor, 54-003-0003) show a 1.84

μg/m 2.5 (11.6%) decrease in the average PM concentration for 2012 and a 2.23 μg/m (14.0%) 3 3

decrease in the average concentration for 2014, without accounting for CAIR or reductions required

by the Transport Rule or CSAPR. A reduction of 3.94 μg/m (24.7%) from the 2003-2007 baseline 3

is expected for 2014 with the implementation of the CSAPR. It should also be noted that the base year

design value used by EPA in their modeling was taken from 2003 through 2007 and is higher than

the current 2009 through 2011 design value of 11.8 μg/m in the area. Furthermore, the monitored 3

design values for 2008-2010 and 2009-2011 of 12.9 and 11.8 μg/m , respectively, are less than the 3

modeled base case design vales for 2012 and 2014. Figures 2 and 3 (in Section II) show the

downward 2.5 trend of the design values from 1999 through 2010 for the PM monitors in West Virginia

and Maryland.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 50
Table 30: CSAPR Annual 2.5 PM Design Values (μg/m3)

Site ID County 2003-

2007

Average

Ambient

Value

2003-2007

Maximum

Ambient

Values

2012 Base

Case

Average

Values

2012 Base

Case

Maximum

Values

2014 Base

Case

Average

Values

2014 Base

Case

Maximum

Values

2014

Remedy

Average

Values

2014

Remedy

Maximum

Values

54-003-0003 Berkeley 15.93 16.19 14.09 14.32 13.70 13.92 11.81 11.99

54-009-0005 Brooke 16.52 16.80 14.33 14.58 13.84 14.09 11.34 11.55

54-009-0011 Brooke 16.04 16.37 13.87 14.15 13.39 13.66 10.89 11.13

54-011-0006 Cabell 16.30 16.57 14.71 14.94 14.05 14.28 11.57 11.75

54-029-1004 Hancock 15.76 16.64 13.73 14.51 13.28 14.03 10.81 11.44

54-033-0003 Harrison 13.99 14.19 13.17 13.36 12.71 12.90 9.36 9.49

54-039-0010 Kanawha 15.15 15.38 13.40 13.60 12.78 12.97 10.13 10.28

54-039-0011 Kanawha 13.17 13.17 11.67 11.67 11.13 11.13 8.67 8.67

54-039-1005 Kanawha 16.52 16.59 14.65 14.71 14.01 14.06 11.30 11.35

54-049-0006 Marion 15.03 15.25 14.22 14.43 13.76 13.95 10.16 10.30

54-051-1002 Marshall 15.19 15.33 13.25 13.38 12.75 12.87 10.07 10.17

54-061-0003 Monongalia 14.35 14.47 12.89 13.01 12.41 12.53 9.28 9.40

54-069-0010 Ohio 14.58 14.58 12.53 12.53 12.05 12.05 9.51 9.51

54-081-0002 Raleigh 12.90 13.03 11.22 11.33 10.70 10.80 8.39 8.47

54-107-1002 Wood 15.40 15.44 13.74 13.77 13.16 13.20 10.84 10.87

Source: Air Quality Modeling Final Technical Support Document for the Final Cross-State Air Pollution Rule , pages B-61 - B-62. (www.epa.gov/airtransport/techinfo.html) 

M 2.5 artinsburg, WV 1997 PM Redesignation and Maintenance Plan Page 51
B. EPA Modeling for Proposed Transport Rule 2010

EPA performed modeling to support the emission reductions associated with the Proposed Transport

Rule. EPA used the Comprehensive Air Quality Model with Extension (CAMx Version 5), applied

to the 2005 meteorology as processed by the Mesoscale Model (MM5), Version 3.7.4. Emissions

2 x 3 2.5 input into the CAMx included SO , NO , VOC, NH and direct PM for 2005. The modeling was

based on the annual fine particle design values calculated from 2003 through 2005, 2004 through

2006, and 2005 through 2007. Future year modeling was conducted, and the future year design values

2.5 for 2012 and 2014 were evaluated for attainment of the annual NAAQS for PM of 15 μg/m , as 3

shown in Table 31. The Berkeley County monitor (54-003-0003) represents the Weirton area.

Table 31: Proposed Transport Rule Modeling Results from EPA - 2010

Monitor ID County Design

Value 

2003-2007

(μg/m )

3

Future

Design Value

2012 Base

(μg/m )

3

Future

Design Value

2014 Base

(μg/m )

3

Future

Design Value

2014 Remedy

(μg/m )

3

54-003-0003 Berkeley 15.93 14.95 14.64 12.44

54-009-0005 Brooke 16.52 14.95 14.51 12.02

54-009-0011 Brooke 16.04 14.49 14.05 11.56

54-011-0006 Cabell 16.30 15.25 14.65 12.09

54-029-1004 Hancock 15.76 14.34 13.93 11.48

54-033-0003 Harrison 13.99 13.82 13.30 9.94

54-039-0010 Kanawha 15.15 14.01 13.45 10.77

54-039-0011 Kanawha 13.17 12.23 11.74 9.24

54-039-1005 Kanawha 16.52 15.28 14.69 11.97

54-049-0006 Marion 15.03 14.96 14.41 10.79

54-051-1002 Marshall 15.19 13.96 13.44 10.74

54-061-1003 Monongalia 14.35 13.72 13.14 10.01

54-069-0010 Ohio 14.58 13.18 12.72 10.15

54-081-0002 Raleigh 12.90 11.88 11.40 9.01

54-107-1002 Wood 15.40 14.31 13.77 11.40

Source: Technical Support Document for the Proposed Transport Rule, pages B-52 - B-53.

(www.epa.gov/airquality/transport/pdfs/TR_AQModeling_TSD.pdf)

EPA stated in the preamble to the proposed Transport Rule that the “baseline analysis takes into

account emissions reductions associated with the implementation of all federal rules promulgated by

December 2008 and assumes that CAIR is not in effect.” [75FR 45233, 02AUG2010]

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 52
Modeling results for the Martinsburg area (Berkeley County monitor, 54-003-0003) show a 0.98

μg/m 2.5 (6.2%) decrease in the PM concentration for 2012 and a 1.29 μg/m (8.1%) decrease in the 3 3

concentration for 2014, without accounting for CAIR or reductions required by the Transport Rule.

A reduction of 3.49 μg/m (21.9%) from the 2003-2007 baseline is expected for 2014 with the 3

implementation of the Transport Rule. It should also be noted that the base year design value used

by EPA in their modeling was taken from 2003 through 2007 and is higher than the current 2009

through 2011 design value of 11.8 μg/m in the area. Furthermore, the monitored design values for 3

2006-2008, 2007-2009, 2008-2010 and 2009-2011 of 14.9, 14.0, 12.9 and 11.8 μg/m , respectively,

3

are less than the modeled base case design vales for 2012 and 2014. Figures 2 and 3 (in Section II)

2.5 show the downward trend of the design values from 1999 through 2010 for the PM monitors in

West Virginia and Maryland.

C. VISTAS/ASIP Em 2.5 issions and Air Quality Modeling to Support PM and 8-hour Ozone

State Implementation Plans 

VISTAS/ASIP conducted modeling to determine the impact of CAIR and other control programs in

the southeast, including West Virginia. The VISTAS/ASIP modeling used Version 4.51 of the

Community Multi-scale Air Quality (CMAQ) modeling system with enhanced secondary organic

aerosol (SOA) module (SOAmods) applied to the year 2002 meteorology, as processed by MM5.

Emissions 2 x 3 2.5 input into CMAQ included SO , NO , VOC, NH and direct PM for 2002. The modeling

was based on 2000 through 2004 design values. Future year modeling for 2009, 2012 and 2018 was

conducted and the future year design values were determined with the emission reductions associated

with CAIR, as shown in Table 32. The Transport Rule is expected to provide reductions above and

beyond CAIR. The Berkeley County monitor (54-003-0003) represents the Martinsburg area.

The VISTAS/ASIP modeling results for the Martinsburg area (Berkeley County monitor, 54-003-

0003) predic 2.5 ted a 2.7 μg/m (16.7%) decrease in the projected PM concentration for 2009 from the 3

2002 design value. As shown in Table 1, the actual monitored design value for 2007-2009 was 14.0

μg/m , a 2.2 μg/m (13.6%) improvement, slightly less than predicted. The modeling results show 3 3

a continued 2.5 improvement in the area, with a PM concentration of 12.3 μg/m3by 2018, a 24.1%

reduction from the 2002 design value. The current 2009-2011 design value for the area is 11.8 μg/m ,

3

which is lower than the predicted design values for 2012 and 2014.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 53
Table 32: VISTAS/ASIP 2009, 2012 and 2018 Modeling Results (with CAIR)

Monitor ID County 2002 Annual

DVC

Annual DVF

2009 2012 2018

54-003-0003 Berkeley 16.2 13.5 12.9 12.3

54-009-0005 Brooke 16.7 13.6 13.3 12.6

54-011-0006 Cabell 16.5 14.4 13.7 13.3

54-029-0011 Hancock 16.0 13.0 12.6 11.9

54-026-1004 Hancock 17.3 14.0 13.7 13.0

54-033-0003 Harrison 14.0 11.6 10.7 10.4

54-039-0010 Kanawha 15.4 13.1 12.2 11.7

54-039-1005 Kanawha 17.1 14.7 13.7 13.2

54-049-0006 Marion 15.3 12.9 12.0 11.6

54-051-1002 Marshall 15.6 13.2 12.7 12.1

54-055-0002 Mercer 12.7 10.6 9.7 9.1

54-061-0003 Monongalia 14.8 12.3 11.5 11.0

54-069-0008 Ohio 15.1 12.6 12.1 11.5

54-081-0002 Raleigh 13.1 11.0 10.1 9.5

54-089-0001 Summers 10.1 8.3 7.6 7.1

54-107-1002 Wood 16.1 13.8 13.4 12.6

Source: Technical Support Document for the Association for Southeastern Integrated Planning (ASIP) Emissions and Air

Qu 2.5 ality Modeling to Support PM and 8-Hour Ozone State Implementation Plans, March 24, 2008.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 54
VII. CONTINGENCY MEASURES

CAA Section 107(d)(3)(E)(v)

A. Maintenance Plan Review

As required by Section 175(A) of the CAA, West Virginia hereby commits to submit an additional

maintenance plan as a SIP revision covering the ten year period after the expiration of the

maintenance plan currently under review.

B. Corrective Actions

West Virginia hereby commits to adopt and expeditiously implement necessary corrective actions in

the following circumstances:

1. Warning Level Response

A warning 2.5 level response shall be prompted whenever the PM average of the weighted annual

mean of 15.5 μg/m occurs in a single calendar year within the maintenance area or when 3

emissions in the maintenance area increase by more than 10% above the levels in the 2007

attainment year inventory. A warning level response will consist of a study to determine whether

2.5 2.5 the PM value indicates a trend toward higher PM values or whether emissions appear to be

increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the

control measures necessary to reverse the trend taking into consideration ease and timing for

implementation as well as economic and social considerations. Implementation of necessary

controls in response to a warning level response trigger will take place as expeditiously as

possible, but in no event later than 12 months from the conclusion of the most recent calendar

year. 

Should it be determined through the warning level study that action is necessary to reverse the

noted trend, the procedures for control selection and implementation outlined under “action level

response” shall be followed.

2. Action Level Response

An action level response shall be prompted whenever a two-year average of the weighted annual

means of 15.0 μg/m or greater occurs within the maintenance area. A violation of the standard 3

(three-year average of the weighted annual means of 15.0 μg/m or greater) shall also prompt an 3

action level response. In the event that the action level is triggered and is not found to be due to

an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement,

West Virginia DAQ in conjunction with the metropolitan planning organization or regional

council of governments, will determine additional control measures needed to assure future

attainment of 2.5 the 1997 PM NAAQS. In this case, measures that can be implemented in a short

time will be selected in order to be in place within 18 months from the close of the calendar year

that prompted the action level. West Virginia DAQ will also consider the timing of an action

level trigger and determine if additional, significant new regulations not currently included as part

of the maintenance provisions will be implemented in a timely manner and will constitute our

response.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 55
3. Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal

process. This process will include publication of notices, an opportunity for public hearing, and

other measures required by West Virginia law for rulemaking. 

If a new measure/control is already promulgated and scheduled to be implemented at the federal

or State level, and that measure/control is determined to be sufficient to address the upward trend

in air quality, additional local measures may be unnecessary. Furthermore, West Virginia DAQ

will submit to EPA an analysis to demonstrate the proposed measures are adequate to return the

area to attainment. 

C. Potential Contingency Measures

Contingency measures to be considered will be selected from a comprehensive list of measures

deemed appropriate and effective at the time the selection is made. The selection of measures will

be based on cost-effectiveness, emission reduction potential, economic and social considerations or

other factors that West Virginia DAQ deems appropriate. West Virginia DAQ will solicit input from

all interested and affected persons in the maintenance area prior to selecting appropriate contingency

measures. Because it is not possible at this time to determine what control measures will be

appropriate at an unspecified time in the future, the list of contingency measures outlined below is

not exhaustive.

1) Diesel reduction emission strategies.

2) Alternative fuel (e.g., liquid propane and compressed natural gas) and diesel retrofit programs

for fleet vehicle operations.

3) Tighter PM2.5 2 x, SO , and NO emissions offsets for new and modified major sources.

4) Concrete manufacturing - upgrade wet suppression.

5) Additional NOx RACT statewide.

No contingency measure shall be implemented without providing the opportunity for full public

participation during which the relative costs and benefits of individual measures, at the time they are

under consideration, can be fully evaluated.

D. PM2.5 2 x, SO , and NO sources potentially subject to future additional control requirements.

The following 2.5 2 x is a list of PM , SO , and NO sources potentially subject to future controls.

2 x

• ICI Boilers - SO and NO controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• Fleet vehicles;

• Concrete manufacturers;

• Aggregate processing plants.

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 56
VIII. PUBLIC PARTICIPATION

West Virginia published an announcement of the opportunity for a public hearing and solicited public

comment concerning the draft redesignation petition and maintenance plan in the State Register, the

Charleston Gazette and the Martinsburg Journal on June 14, 2013. 

A public hearing to receive comments on the redesignation request was tentativelyscheduled for 6:00

p.m. on Tuesday, July 23, 2013, at the West Virginia Division of Environmental Protection

Headquarters located at 601 57 Street, SE, Charleston, WV. However, no person requested a public th

hearing, therefore the hearing was cancelled. The public comment period closed on July 15, 2013.

Appendix G includes a copy of the public notice, and a copy of the notice of public hearing

cancellation, a copy of the comments received and the response to comments.

IX. CONCLUSIONS

The Martinsburg PM2.5 nonattainment area has attained the 1997 annual and 24-hour NAAQS for

PM2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regarding

2.5 redesignations of PM nonattainment areas. Documentation to that effect is contained herein. West

Virginia DAQ has prepared a redesignation request and maintenance plan that meet the requirements

of Section 110 (a)(1) of the 1990 CAA. 

Ba 2.5 sed on this presentation, the West Virginia portion of the Martinsburg PM nonattainment area 

meets the requirements for redesignation under the CAA and EPA guidance. West Virginia has

performed an analyses showing the air quality improvements are due to permanent and enforceable

measures. Furthermore, because this area is subject to significant transport of pollutants, significant

2 x

regional SO and NO reductions will ensure continued compliance (maintenance) with the standard

with an increasing margin of safety.

The State of West Virg 2.5 inia hereby requests that the Martinsburg 1997 PM nonattainment area be

redesignated to attainment simultaneouslywith EPA approval of the CAA section 175A maintenance

plan provisions contained herein. 

The State of West Virginia is also requesting approval of the 2007 base year inventory as meeting the

requirements under Clean Air Act Section 172(c)(3).

Martinsburg, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 57