GOVERNMENT OF THE DISTRICT OF COLUMBIA 

District Department of the Environment 

*** 

Air Quality Division 

MEMORANDUM 

TO: Keith A. Anderson ~f) Ff 

Director, District Department of the Environment 

FROM: Cecily Beall &JP 4-ftrll t-f 

Associate Director, Air Quality Division, DDOE 

DATE: May 12, 2014 

SUBJECT: Hearing Officer's Certification for the Public Hearing on the Washington 

DC-MD-V A Base Year Emissions Inventory to Meet 2008 8-Hour Ozone 

NAAQS Requirements 

This is to certify that a public hearing was held at approximately 5:30p.m. on May 12, 2014, to 

give the public the opportunity to comment on the Washington DC-MD-VA base year emissions 

inventory to meet requirements ofthe 2008 8-hour ozone national ambient air quality standards 

(NAAQS), which will be submitted to the U.S. Environmental Protection Agency (EPA) as a SIP 

revision. Notice ofthe public hearing was posted in the D.C. Register on April11, 2014 (61 

DCR 16: 003782, Notice ID 4842548). 

Cecily Beall ofthe District Department of the Environment, Air Quality Division, represented 

the District. No one attended the public hearing. 

DISTRICT 

DEPARTMENT 

OF THE 

ENVIRONMENT 

g"enfo.-ward * 1200 First St. NE, 5th Floor, Washington, DC 200021 tel: 202.535.2600 I web:ddoe.dc.gov 
511312014 Notice ID 4842548: Em.ironment, District Department of the- Notice of Public Hearing and Public Corrment Period on Air Quality Issues- State lfTlllemen ... 

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Notice 10: 4842548 

Environment, District Department of the - Notice of Public Hearing and Public Comment Period on Air Quality 

Issues - State Implementation Plan Revision - 40 CFR Part 52, Subpart J 

Register Category: Public Hearing 

Agency Name: Environment, District Department of the 

Notice Files: 

Register Issue: 4/11/2014 Vol 61/16 

Publish Date: 4/11/2014 

How to Link to this Notice: http://www.dcregs.org/Gateway/NoticeHome.aspx?NoticeiD=4842548 

Telephone Directory by Topic • Agencies • DC Council • Search • Elected Officials • Feedback • Accessibility • Privacy & Security • Terms & Conditions 

DCdocuments@dc.gov 

http://WNW.dcregs.org/Gatewa}fNoticeHorne.aspx?NoticeiD=4842548 1/1 
DISTRICT OF COLUMBIA VOL. 61- NO. 16 APRIL 11, 2014 

DISTRICT DEPARTMENT OF THE ENVIRONMENT 

NOTICE OF PUBLIC HEARING AND PUBLIC COMMENT PERIOD 

ON AIR QUALITY ISSUES 

State Implementation Plan Revision- 40 C.F.R. Part 52, Subpart J 

Notice is hereby given that a public hearing will be held on Monday, May 12, 2014, at 5:45p.m. 

in Room 555 at 1200 First Street NE, 5th Floor, in Washington, D.C. 20002. This hearing 

provides interested parties an opportunity to comment on the proposed revision to the District of 

Columbia's (District) State Implementation Plan (SIP), found at 40 C.F.R. Part 52 Subpart J. 

The District was designated by the U.S. Environmental Protection Agency (EPA) as being in 

marginal nonattainment of the 2008 8-hour ozone national ambient air quality standard 

(NAAQS), effective on July 20, 2012 (77 Fed. Reg. 30088, May 21, 2012). To meet 

requirements of Clean Air Act § 172( c )(3) for marginal areas, a base year emissions inventory 

must be submitted to EPA as a SIP revision no later than two years after designation (42 U.S. 

Code§ 7511a(a)(l)). Once the District has completed its procedures, the inventory and 

supporting documents will be submitted to EPA as a SIP revision. 

Copies of the proposed SIP revision are available for public review during normal business hours 

at the offices of the District Department of the Environment (DDOE), 1200 First Street NE, 5th 

Floor, Washington, DC 20002, and on-line at http://ddoe.dc.gov/. 

Interested parties wishing to testify at this hearing must submit in writing their names, addresses, 

telephone numbers and affiliation, if any, to Mr. William Bolden at the DDOE address above or 

at william.bolden@dc.gov by 4:00p.m. on May 12, 2014. Interested parties may also submit 

written comments to Ms. Jessica Daniels, Monitoring and Assessment Branch, Air Quality 

Division, DDOE, at the same address or by email at jessica.daniels@dc.gov. Questions about 

this SIP revision should be directed to Mr. Rama S. Tangirala by phone at 202-535-2989 or 

email at rama.tangirala@dc.gov, or Ms. Daniels at 202-741-0862 or jessica.daniels@dc.gov. No 

comments will be accepted after May 12, 2014. 

003782 
Page 1 of2 

311 Online Distric1 

* * * 

District Department of the Environment 

DDOE Home I Services I Environmental Protection I EnergySmart DC I Resources I Regulatic 

~~List~n 

Notice of Public Hearing and Comment Period on Air Quality Issues - 2008 8-1 

Emissions Inventory 

Last Date: Monday, May 12, 2014- 5:45pm to 6:45pm 

Building: DDOE Headquarters 

Room: 555 

Details: 

Notice is hereby given that a public hearing will be held on Monday, May 12, 2014, at 5:45p.m. in Room 555 at 120! 

20002. This hearing provides interested parties an opportunity to comment on the proposed revision to the District o· 

(SIP}, found at 40 C.F.R. Part 52 Subpart J. 

The District was designated by the U.S. Environmental Protection Agency (EPA) as being in marginal nonattainmen1 

quality standard (NAAQS), effective on July 20, 2012 (77 Fed. Reg. 30088, May 21, 2012). To meet requirements o 

year emissions inventory must be submitted to EPA as a SIP revision no later than two years after designation (42 U 

completed its procedures, the inventory and supporting documents will be submitted to EPA as a SIP revision. 

Copies of the proposed SIP revision are attached below and are available for public review during normal business t 

Environment (DDOE}, 1200 First Street NE, 5th Floor, Washington, DC 20002. 

Interested parties wishing to testify at this hearing must submit in writing their names, addresses, telephone numben 

DDOE address above or at william.bolden@dc.gov by 4:00 p.m. on May 12, 2013. Interested parties may also subm 

Monitoring and Assessment Branch, Air Quality Division, DDOE, at the same address or by email at jessica. daniels~ 

directed to Mr. Rama S. Tangirala by phone at 202-535-2989 or email at rama.tangirala@dc.gov, or Ms. Daniels at~ 

comments will be accepted after May 12, 2013. 

• Appendices (MWCOG.org) 

Attachment(s): 

Base Year 2011 Inventory for the DC-MD-VA Ozone Nonattainment Area 

http:/ /ddoe.dc.gov /node/815212 5/13/2014 
Page 2 of2 

Related Content: 

• Notice of Public Hearing and Comment Period on Air Quality Issues- Ozone Infrastructure SIP 

• Public Notices & Hearings 

http://ddoe.dc.gov/node/815212 5/13/2014 
MAY 12,2014 

Please sign below: 

NAME 

1. 

2. 

3. 

4. 

5. 

GOVERNMENT OF THE DISTRICT OF COLUMBIA 

Department of the Environment 

Environmental Protection Administration 

Air Quality Division 

PUBLIC HEARING ON THE DISTRICT/ND I VA 

2008 8-HOUR OZONE NAAQS BASE YEAR INVENTORY 

FOR SUBMITTAL AS A STATE IMPLEMENTATION PLAN REVISION 

AlT<E JJ o 'f.£ 51 spe_A ~e...cf.-S 

AFFILIATION (if any) ADDRESS 
Appendix E

Public Hearing Notices, Comments, and Responses
DDOE Notice

DISTRICT DEPARTMENT OF THE ENVIRONMENT

NOTICE OF PUBLIC HEARING AND PUBLIC COMMENT PERIOD

ON AIR QUALITY ISSUES

State Implementation Plan Revision - 40 C.F.R. Part 52, Subpart J

Notice is hereby given that a public hearing will be held on Monday, May 12, 2014, at 5:45 

p.m. in Room 555 at 1200 First Street NE, 5th Floor, in Washington, D.C. 20002. This hearing 

provides interested parties an opportunity to comment on the proposed revision to the District of 

Columbia’s (District) State Implementation Plan (SIP), found at 40 C.F.R. Part 52 Subpart J. 

The District was designated by the U.S. Environmental Protection Agency (EPA) as being in 

marginal nonattainment of the 2008 8-hour ozone national ambient air quality standard 

(NAAQS), effective on July 20, 2012 (77 Fed. Reg. 30088, May 21, 2012). To meet 

requirements of Clean Air Act § 172(c)(3) for marginal areas, a base year emissions inventory 

must be submitted to EPA as a SIP revision no later than two years after designation (42 U.S. 

Code § 7511a(a)(1)). Once the District has completed its procedures, the inventory and 

supporting documents will be submitted to EPA as a SIP revision. 

Copies of the proposed SIP revision are available for public review during normal business 

hours at the offices of the District Department of the Environment (DDOE), 1200 First Street 

NE, 5th Floor, Washington, DC 20002, and on-line at http://ddoe.dc.gov/. 

Interested parties wishing to testify at this hearing must submit in writing their names, 

addresses, telephone numbers and affiliation, if any, to Mr. William Bolden at the DDOE 

address above or at william.bolden@dc.gov by 4:00 p.m. on May 12, 2014. Interested parties 

may also submit written comments to Ms. Jessica Daniels, Monitoring and Assessment Branch, 

Air Quality Division, DDOE, at the same address or by email at jessica.daniels@dc.gov. 

Questions about this SIP revision should be directed to Mr. Rama S. Tangirala by phone at 202-

535-2989 or email at rama.tangirala@dc.gov, or Ms. Daniels at 202-741-0862 or 

jessica.daniels@dc.gov. No comments will be accepted after May 12, 2014. 
VDEQ Notice

DEPARTMENT OF ENVIRONMENTAL QUALITY

Public Notice – Air Quality Plan

Notice of action: The Department of Environmental Quality (DEQ) is seeking 

comments and announcing a public hearing on a proposed 2011 base year inventory 

for precursors to the pollutant ozone, which are carbon monoxide (CO), nitrogen 

oxides (NOX), and volatile organic compounds (VOC) in the Metropolitan Washington, 

DC-MD-VA 2008 Ozone Nonattainment Area. The Commonwealth intends to submit 

the inventory as a revision to the Commonwealth of Virginia State Implementation Plan 

(SIP) in accordance with the federal Clean Air Act. The SIP is the plan developed by 

the Commonwealth in order to fulfill its responsibilities under the Act to attain and 

maintain the ambient air quality standards promulgated by the U.S. Environmental 

Protection Agency (EPA).

Purpose of notice: DEQ is seeking comments on the overall 2011 inventory for the 

Northern Virginia portion of the Metropolitan Washington, DC-MD-VA 2008 Ozone 

Nonattainment Area, which consists of the counties of Arlington, Fairfax, Loudoun, and 

Prince William and the cities of Alexandria, Fairfax, Falls Church, Manassas, and 

Manassas Park. 

Public comment period: March 24 to April 23, 2014.

Public hearing: A public hearing will be conducted in Conference Room 2, DEQ 

Northern Region Office, 13901 Crown Court, Woodbridge, Virginia, at 10:00 am on 

April 22, 2014. A map and directions maybe found at 

http://www.deq.virginia.gov/Locations/NorthernRegionalOffice.aspx.

Description of proposal: The proposed 2011 base year inventory was prepared by 

the Metropolitan Washington Air Quality Committee (MWAQC), which consists of 

elected officials from the affected localities and representatives of state transportation 

and air quality planning agencies. 

The proposal consists of a comprehensive inventory of actual emissions from all 

sources of relevant pollutants for the base year 2011. This inventory, once finalized, 

will be the basis for any future planning exercises that have as a goal compliance with 

the 2008 ozone national ambient air quality standard (NAAQS).

Federal information: This notice is being given to satisfy the public participation 

requirements of federal regulations (40 CFR 51.102). The proposed inventory and 

supporting technical documents will be submitted as a revision to the Commonwealth 

of Virginia SIP under § 110(a) of the federal Clean Air Act in accordance with 40 CFR 

51.104.
How to comment: DEQ accepts written comments by email, fax, and postal mail. In 

order to be considered, comments must include the full name, address, and telephone 

number of the person commenting and be received by DEQ no later than the last day 

of the comment period. Both oral and written comments are accepted at the public 

hearing. DEQ prefers that comments be provided in writing, along with any supporting 

documents or exhibits. Comments must be submitted to Doris A. McLeod, Air Quality 

Planner, Department of Environmental Quality, 629 E. Main St, PO Box 1105, 

Richmond, Virginia 23218 (phone 804-698-4197, fax 804-698-4510, email 

doris.mcleod@deq.virginia.gov). All materials received are part of the public record.

To review the proposal: The proposal and any supporting documents are available 

on the DEQ Air Public Notices for Plans web site 

(http://www.deq.state.va.us/Programs/Air/PublicNotices/airplansandprograms.aspx). 

The documents may also be obtained by contacting the DEQ representative named 

above. The public may review the documents between 8:30 am and 4:30 pm of each 

business day until the close of the public comment period at the following DEQ 

locations: 1) Main Street Office, 8th Floor, 629 E. Main St, Richmond, VA, 804-698-

4070 and 2) Northern Regional Office, 13901 Crown Court, Woodbridge, VA, 703-583-

3800.

SIP\NONATTN PLANS\2014\NVA-INV-SIP-notice
MDE Notice

NEW A public hearing regarding the “Base Year 2011 Emissions Inventory (Washington 

DC-MD-VA 2008 Ozone NAAQS Nonattainment Area)” will be held on Thursday, June 

12, 2014 at the Montgomery County Planning Department, Regional Office at 8787 

Georgia Avenue, Silver Spring, MD 20910 -- First Floor Media Room -- 10:00 A.M.

Copies of the document can be viewed at the links following this notice and at the offices of the 

Maryland Department of the Environment, Air and Radiation Management Administration, 

1800 Washington Boulevard, Suite 730, Baltimore, Maryland. For more information, contact 

Molly Berger at (410) 537-3234.

Comments may be sent to Molly Berger, Maryland Department of the Environment, Air and 

Radiation Management Administration, 1800 Washington Boulevard, Suite 730, Baltimore, 

MD, 21230; emailed Molly.Berger@Maryland.gov.

For more information, contact Molly Berger at (410) 537-3234 (Toll free in Maryland call 1-

(800) 633-6101 ext. 3234), or via email at Molly.Berger@Maryland.gov; 

NEW Document Available for Public Comment: Base Year 2011 Emissions Inventory 

(Washington DC-MD-VA 2008 Ozone NAAQS Nonattainment Area)

 Full Inventory Document without Appendices

 Appendices ZIP File. This file contains all the appendices in a 176 MB ZIP file. 

o A. Point Source Inventory Files 

o B1. Area and Nonroad (Marine Vessels, Airport, Railroad Locomotives) 

Source Inventory Development Document (Maryland) 

o B2. Area and Nonroad (Marine Vessels, Airport, Railroad Locomotives) 

Source Inventory Development Document (Virginia) 

o B3. Area and Nonroad (Marine Vessels, Airport, Railroad Locomotives) 

Source Inventory Development Document (District of Columbia) 

o B4. Area and Nonroad (Marine Vessels, Airport, Railroad Locomotives) 

Source Inventory Files 

o C. NMIM2008 (NONROAD Model) Input and Output Files 

o D1. Onroad Mobile Source Development Document 

o D2. MOVES 2010a (Onroad Mobile Model) Input and Output Files
Public Comments & Responses

Public Comments

No public comments were received by the District Department of the Environment and the

Virginia Department of Environmental Quality on the base year 2011 emissions inventory 

document. Maryland Department of the Environment received a comment letter from US

EPA dated June 12, 2014. EPA sent a revised version of this comment letter dated June 27, 

2014. As required by 40 C.F.R. § 51.102(e), a complete record of these comments is located 

at the Air Division of the Maryland Department of the Environment. The department contact

to access this information is:

Director, Air and Radiation Management Administration, Maryland Department of the 

Environment

As required by § 2.1(h) of Appendix V of 40 C.F.R. Part 51, below is a summary of the 

comments received and responses thereto. Included is a brief statement of the subject, the 

identification of the commenter, the summary of the comment and the response (analysis and 

action taken). 

1. Subject: Use of IM240 program in Base Year 2011 onroad source emissions 

inventory development

Commenter: United States Environmental Protection Agency (EPA), Region III

Original Text (Comment letter dated June 12, 2014): With regards to the Onroad portion of 

the emissions inventory, specifically the vehicle inspection and maintenance coverage inputs 

for MOVES, Maryland cannot use the IM240 emissions test standards as part of the State's 

emissions inspection and maintenance (I/M) program. In August 2009, Maryland removed 

the IM240 test from the State's I/M program. This has been confirmed each year when the 

state submits to EPA a data analysis report for its I/M program as required by 40 CFR 

51.366. As such, Maryland cannot rely on the additional emission benefits received from an 

emissions inspection test that is not currently implemented within the State.

Revised Text (Comment letter dated June 27, 2014): EPA withdrew its comments regarding 

using emissions benfits from the I/M240 program in the base year 2011 onroad mobile 

emission inventory. The text in the revised comment letter is as follows – “In August 2009, 

Maryland removed the IM240 test from the State's I/M program. This has been confirmed

each year when the state submits to EPA a data analysis report for its I/M program as 

required by 40 CFR 51.366.”

Response: Maryland has worked with EPA to fix the technical comments identified in 

EPA's review of the SIP with relation to the IM240 program. MDE obtained a copy of the 

I/M input file that generated the EPA comment from Joseph Schulingkamp at EPA and 

compared it with the I/M input file that was part of the draft SIP submittal. MDE's 

comparison determined that the two files were inconsistent and the comment wasn't 

accurate. MDE discussed this inconsistency with Mr. Schulingkamp on June 20, 2014 

during which he verbally agreed that the I/M input file from MDE was correct and that he 

considered the issue resolved. MDE sent an email confirming resolution of this MOVES 
I/M input issue to Mr. Schulingkamp on July 1, 2014. Subsequently, EPA sent a revised 

comment letter dated June 27, 2014 conforming this.

2. Subject:

Commenter: United States Environmental Protection Agency (EPA), Region III

Text (Comment letters dated June 12, 2014 & June 27, 2014): As required by 40 CFR 

51.104, whenever a program is substantially revised at the state level, the state should then 

revise its State Implementation Plan (SIP) to reflect those changes. In general, when SIP 

approved emission reduction programs are revised at the state level, the state must perform 

an anti-backsliding analysis as required by Clean Air Act (CAA) section 110(1) and submit 

that demonstration as part of the SIP revision to remove or amend the relevant SIP measure. 

This analysis should demonstrate that the revised emission control program will not 

negatively impact the state's ability of attaining or maintaining the relevant NAAQS. Also, 

EPA's I/M requirements rule adds an additional requirement specific to I/M programs, that 

the revised program meet the applicable I/M program performance standard test set out in 40

CFR 51, Subpart S (using the current emissions factor mobile source model, MOVES).

Upon submittal of an I/M SIP revision by Maryland, along with the accompanying 

performance standard analysis and noninterfence demonstration, EPA would review the 

revision to ensure that the revised I/M program will continue to meet Federal requirements 

of both 40 CFR 51, Subpart S and the CAA.

Response: With respect to the comment regarding 40 CFR 51.104 and the revision of the 

IM SIP/ anti-backsliding analysis, MDE commits to working with EPA to resolve this 

comment/ submit any necessary SIP revisions or analysis before June 1, 2015.

Technical Corrections

1. Commenter: Virginia Department of Environmental Quality

Date received: April 23, 2014

Recipient: MWCOG

Comment: The VDEQ would like to request that the following revision be incorporated:

The Virginia Department of Environmental Quality would like submit revised 2011 commuter 

rail emission inventory estimates for northern Virginia for incorporation into the final 2011 

emission inventory to be submitted to the EPA as part of the Base Year 2011 emissions 

inventory (Washington DC-MD-VA 2008 Ozone NAAQS Nonattainment Area submittal). The 

commuter rail emission estimates for northern Virginia jurisdictions that were included in the

revision of the 2011 inventory that were sent out for public review were based on an ERTAC 

commuter rail study that was grown to CY 2011. Since that time, VDEQ has obtained actual 

CY 2011 commuter rail activity data and fuel consumption data from the VRE, along with 

equipment specific engine emission factors and has developed CY 2011 commuter rail emission 

estimates for northern Virginia which we feel more accurately represent the emissions 

associated with this source category. 
SCC Code FIPS Code Pollutant Code Annual Emissions 

(TPY)

Daily Emissions 

(TPD)

2285002009 51013 VOC 1.3186 0.0036

2285002009 51059 VOC 8.9597 0.0245

2285002009 51153 VOC 3.2008 0.0088

2285002009 51510 VOC 4.1131 0.0113

2285002009 51013 SO2 0.2256 0.0006

2285002009 51059 SO2 1.5329 0.0042

2285002009 51153 SO2 0.5476 0.0015

2285002009 51510 SO2 0.7037 0.0019

2285002009 51013 PM25-PRI 0.4246 0.0012

2285002009 51059 PM25-PRI 2.8854 0.0079

2285002009 51153 PM25-PRI 1.0308 0.0028

2285002009 51510 PM25-PRI 1.3246 0.0036

2285002009 51013 PM10-PRI 0.4379 0.0012

2285002009 51059 PM10-PRI 2.9756 0.0082

2285002009 51153 PM10-PRI 1.0630 0.0029

2285002009 51510 PM10-PRI 1.3660 0.0037

2285002009 51013 Nox 15.2126 0.0417

2285002009 51059 Nox 103.3689 0.2832

2285002009 51153 Nox 36.9282 0.1012

2285002009 51510 Nox 47.4536 0.1300

2285002009 51013 CO 6.5920 0.0181

2285002009 51059 CO 44.7926 0.1227

2285002009 51153 CO 16.0020 0.0438

2285002009 51510 CO 20.5630 0.0563

Response: MWAQC and the states agree. The changes will be reflected in the final 

document.

2. Commenter: Virginia Department of Environmental Quality

Date received: June 30, 2014

Recipient: MWCOG

The Virginia Department of Environmental Quality requested to submit a minor revision to the 

2011 point source NOx emission inventory estimate for the Prince William county. This 

revision decreased the average ozone season day NOx emission for the county and the northern 

Virginia from 13.38 tons per day to 12.96 tons per day. 

Response: MWAQC and the states agree. The changes will be reflected in the final 

document.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 191 03-2029 

George Abum, Director 

Air & Radiation Management Administration 

Maryland Department of the Environment 

1800 Washington Boulevard 

Baltimore, Maryland 21230 

Dear Mr. Abum: 

JUN 1 ·2 2014 

Thank you for giving the U.S. Environmental Protection Agency (EPA) the opportunity to 

review the proposed 2011 Base Year Emissions Inventory for the Washington, DC-MD-VA 

nonattainment area for the 2008 ozone national ambient air quality standards (NAAQS). EPA has 

reviewed the proposed base year inventory and our comments are enclosed. 

Please enter these comments into the public record. We look forward to working with you to 

resolve these comments. Should you have any questions pertaining to EPA's review, please do not 

hesitate to contact me. If members of your staff have questions, they may direct them to Mr. Brian 

Rehn, Office of Air Program Planning, at (215) 814-2176. 

Enclosures 

Sincerely, 

~ Diana Esher, Director 

Air Protection Division 

cc: Molly Berger, Maryland Department of the Environment 

0 Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process. chlorine free. 

Customer Service Hotline: 1-800-438-2474 
EPA Comments on Maryland's Proposed 2011 Base Year Emissions Inventorv for the 

Washington, DC-MD-VA 2008 Ozone NAAQS Nonattainment Area 

With regards to the Onroad portion of the emissions inventory, specifically the vehicle inspection 

and maintenance coverage inputs for MOVES, Maryland cannot use the IM240 emissions test 

standards as part of the State's emissions inspection and maintenance (1/M) program. In August 

2009, Maryland removed the IM240 test from the State's liM program. This has been confirmed 

each year when the state submits to EPA a data analysis report for its 1/M program as required by 

40 CFR 51.366. As such, Maryland cannot rely on the additional emission benefits received 

from an emissions inspection test that is not currently implemented within the State. 

Additionally, as required by 40 CFR 51.104, whenever a program is substantially revised at the 

state level, the state should then revise its State Implementation Plan (SIP) to reflect those 

changes. In general, when SIP approved emission reduction programs are revised at the state 

level, the state must perform an anti-backsliding analysis as required by Clean Air Act (CAA) 

section 110(1) and submit that demonstration as part ofthe SIP revision to remove or amend the 

relevant SIP measure. This analysis should demonstrate that the revised emission control 

program will not negatively impact the state's ability of attaining or maintaining the relevant 

NAAQS. Also, EPA's liM requirements rule adds an additional requirement specific to 1/M 

programs, that the revised program meet the applicable liM program performance standard test 

set out in 40 CFR 51, SubpartS (using the current emissions factor mobile source model, 

MOVES). 

Upon submittal of an 1/M SIP revision by Maryland, along with the accompanying performance 

standard analysis and noninterfence demonstration, EPA would review the revision to ensure that 

the revised 1/M program will continue to meet Federal requirements of both 40 CFR 51, Subpart 

S and the CAA. 

(.)rinted on I 00% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. 

Customer Service Hotline: 1-800-438-2474 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

George Abum, Director 

Air & Radiation Management Administration 

Maryland Department of the Environment 

1800 Washington Boulevard 

Baltimore, Maryland 21230 

JUN 2 7 2014 

ARMA 

JUl 0 8 2014 

Dear Mr. Abum: 

DIRECTOR'S OFFICE 

On June 12, 2014, EPA submitted public comments regarding the proposed 2011 Base 

Year Emissions Inventory for the Washington, DC-MD-VA nonattainment area for the 2008 

ozone national ambient air quality standards (NAAQS). In that letter EPA commented, 

" ... Maryland cannot rely on the additional emission benefits received from an emissions 

inspection test [the IM240 test] that is not currently implemented within the State.'' After 

discussions with the Maryland Department of the Environment, EPA has concluded that the 

Onroad portion of the emissions inventory does not rely on emission benefits from the IM240 

test. 

Therefore, EPA's comments regarding the Onroad portion of the emissions inventory 

have been resolved; however, the remaining comments regarding changes to any approved 

program that is part of the State Implementation Plan (SIP) and the requirement to update the SIP 

and perform applicable analyses still stand. Please enter these revised comments into the public 

record. We look forward to working with you to resolve these comments. Should you have any 

questions pertaining to EPA's review, please do not hesitate to contact me. If members of your 

staff have questions, they may direct them to Mr. Brian Rehn, Office of Air Program Planning, at 

(215) 814-2176. 

Enclosures 

Sincerely, 

-::!)i cu--D.. e.'o!l 

Diana Esher, Director 

Air Protection Division 

cc: Molly Berger, Maryland Department of the Environment 

Printed on I 00% recycled/recyclable paper wit II I 00% post-c01rsumer fiber tmd proces.'J clrlori11e free. 

Customer Service Hotli11e: 1-80()..438-2474 
EPA Comments on Maryland's Proposed 2011 Base Year Emissions Inventory for the 

Washington, DC-MD-VA 2008 Ozone NAAQS Nonattainment Area 

With regaftis te the 0Rreatl f3eFtieR efthe efftissieRs iRveRte~·. Sf3eeiileally the vehiele iRsf3eetieR 

ootl maiRteRanee eeverage iRf3Uts for MOV6S, MarylaRd earmet use the IM24Q efRissieRs test 

stooEIEH'tis as 13aFt efthe State's efRissieRs iRSf!eetieR anti fRaiRteRaRee (liM) ~:~regram. In August 

2009, Maryland removed the IM240 test from the State's 1/M program. This has been confirmed 

each year when the state submits to EPA a data analysis report for its 1/M program as required by 

40 CFR 51.366. As sueh, Marylana ear.Bet rely 98 the aeaitioRal efRissieR eeReilts reeeivetl 

from aR efRissieRs iRsf3eetioR test that is Ret eun:eRtly ifRfJlefReRtea withiR the State. 

AaditieRally, As required by 40 CFR 51.104, whenever a program is substantially revised at the 

state level, the state should then revise its State Implementation Plan (SIP) to reflect those 

changes. In general, when SIP approved emission reduction programs are revised at the state 

level, the state must perform an anti-backsliding analysis as required by Clean Air Act (CAA) 

section 11 0(1) and submit that demonstration as part of the SIP revision to remove or amend the 

relevant SIP measure. This analysis should demonstrate that the revised emission control 

program will not negatively impact the state's ability of attaining or maintaining the relevant 

NAAQS. Also, EPA's liM requirements rule adds an additional requirement specific to 1/M 

programs, that the revised program meet the applicable 1/M program performance standard test 

set out in 40 CFR 51, Subpart S (using the current emissions factor mobile source model, 

MOVES). 

Upon submittal of an 1/M SIP revision by Maryland, along with the accompanying performance 

standard analysis and noninterfence demonstration, EPA would review the revision to ensure that 

the revised 1/M program will continue to meet Federal requirements of both 40 CFR 51, Subpart 

S and the CAA. 

Prlllled 011 I 00% recycled/recyclable paper wltll I 00% post-COIISIImer fiber a11d process clllor/ne free. 

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