SUBJECT: 

FROM: 

TO: 

THRU: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Maryland 19103 

Technical Support Document (TSD)- Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the 1997 Fine Particulate Matter (PM2.s) National Ambient 

Air Quality Standard (NAAQS) Maintenance Plan for the Baltimore, Maryland 

(MD) 1997 PM2.s Nonattainment Area 

Gregory Becoat ~ <\:w H 

Office of Air Program Planning (3AP30) ) 

c/1 _1]_,;_/):1 1 /) /)A ~/1-t-- 1~ AsrahKhadr 

Office of Air Program 

LY~Planning (3AP30) ~ 

Administrative Record for the Adequacy Findings for the Motor Vehicle 

Emissions Budgets in the 1997 Fine Particulate Matter (PM2.s) National Ambient 

Air Quality Standard (NAAQS) Maintenance Plan for the Baltimore, MD 1997 

PM2.s Nonattainment Area 

/2-.. £ S):wj,~ Cristina Fernandez s ociate Director 

Office of Air Program Planning (3AP30) 

I. Background 

On January 5, 2005 (70 FR 944, 1014), the Environmental Protection Agency (EPA) published 

air quality area designations for the 1997 PM2.s NAAQS. In that rulemaking action, EPA 

designated Baltimore, MD (the Area), which consists of Anne Arundel County, Baltimore 

County, Carroll County, Harford County, Howard County, and Baltimore City, nonattainment for 

the 1997 annual PM2.s standard. On May 22, 2012 (77 FR 30208), EPA determined that the Area 

had attained the 1997 PM2.s NAAQS based on quality-assured, quality-controlled and certified 

ambient air monitoring data that show the Area has monitored attainment based on 2008 through 

2010 data. 

II. Transportation Conformity Requirements 

Transportation conformity is required under section 176(c) of the Clean Air Act (CAA) to ensure 

that federally supported highway, transit projects, and other activities are consistent with 
(conform to) the purpose of the State Implementation Plan (SIP). The CAA requires federal 

actions in nonattainment and maintenance areas to "conform to" the goals of SIP. This means 

that such actions will not cause or contribute to violations of a NAAQS; worsen the severity of 

an existing violation; or delay timely attainment of any NAAQS or any interim milestone. 

Actions involving Federal Highway Administration (FHWA) or Federal Transit Administration 

(FTA) funding or approval are subject to the Transportation Conformity Rule (40 CFR part 93, 

subpart A). Under this rule, metropolitan planning organizations (MPOs) in nonattainment and 

maintenance areas coordinate with state air quality and transportation agencies, EPA, FHW A, 

and FT A to demonstrate that their metropolitan transportation plans and transportation 

improvement plans (TIPs) conform to applicable SIPs. This is typically determined by showing 

that estimated emissions from existing and planned highway and transit systems are less than or 

equal to the MVEBs contained in a SIP. 

For MVEBs to be approvable, they must meet, at a minimum, EPA's adequacy criteria found at 

40 CFR 93.118(e)(4). EPA's adequacy criteria are: (1) the submitted control strategy 

implementation plan was endorsed by the Governor or designee and was subject to a State public 

hearing; (2) consultation among Federal, State, and local agencies occurred; full implementation 

plan documentation was provided to EPA; and EPA's stated concerns, if any, were addressed 

before the control strategy implementation plan was submitted; (3) the MVEBs are clearly 

identified and precisely quantified; (4) the MVEBs, when considered together with all other 

emissions sources, are consistent with applicable requirements for maintenance; (5) the MVEBs 

are consistent with and clearly related to the emissions inventory and the control measures in the 

submitted control strategy implementation plan; and (6) revisions to previously submitted 

maintenance plans explain and document any changes to previously submitted budgets and 

control measures; impacts on point and area source emissions; any changes to established safety 

margins; and reasons for the changes (including the basis for any changes related to emission 

factors or estimates of vehicle miles traveled). 

III. Review of the Submitted Modeling Utilizing the Motor Vehicle Emission Simulator 

(MOVES2010) 

Maryland Department ofthe Environment (MDE) utilized MOVES2010a to produce MVEBs for 

years 2017 and 2025. To utilize the MOVES2010a model, several different models were used to 

provide the necessary inputs into MOVES2010a. One ofthe models, PPSUITE, was utilized to 

provide inputs as well as to post-process the output files from MOVES201 Oa. 

The appropriate traffic related inputs which were processed by PPSUITE were input into 

MOVES2010a. Additional traffic related inputs as well as non-traffic related inputs were 

provided as well. The data was input into MOVES2010a via the county data manager. The 

county data manager is a function of the MOVES2010b model which allows county specific data 

inputs to be converted into a usable form by MOVES20 1 Ob. At that point a RunSpecification 

(RunSpec), which is a function ofMOVES2010b that allows the user to input necessary 

parameters into the model, was created and run in batch mode. The outputs were provided as an 

inventory because vehicle miles traveled (VMT) and vehicle population were provided to 

MOVES2010b. 

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EPA reviewed the modeling methodology utilized by MDE and all modeling related information 

to produce the MVEBs for years 2017 and 2025. EPA found that all necessary and required 

modeling procedures were followed in the production of the 2017 and 2025 MVEBs which were 

produced using MOVES2010a. 

IV. Administrative Requirements for Making Adequacy Findings 

EPA followed the process for determining the adequacy of the submitted SIP MVEBs in 

accordance with the procedures listed in the January 2008 Conformity Regulations contained in 

40 CFR part 93, 118(f) "Adequacy review process for implementation plan submissions." EPA 

will be issuing a notice of proposed rulemaking (NPR) for a 30-day public comment period 

soliciting public comment for the approvability of the State of Maryland's SIP submission. The 

NPR also proposes approval of the MVEBs for milestone year 2017 and the out-year 2025 for the 

Baltimore, MD 1997 PM2.s N onattainment Area for PM2.s and nitrogen oxides (NOx). 

On April 30, 2014, a notice was posted on EPA's web site located at: 

http://www.epa.gov/otaq/stateresources/transconf/currsips.htm, for the purpose of opening EPA's 

30-day public comment period on the adequacy/approvability of the budgets in the Maintenance 

Plan for the Baltimore, MD 1997 PM2.s Nonattainment Area. The purpose of the notice is to 

inform the public of the availability of the Baltimore Maintenance Plan on its own website. 

EPA's website notice provides a link where interested members of the public could access the 

SIP revision. Following EPA's public comment period, responses to any comments received on 

the proposed mobile budgets will be addressed in an amendment to this TSD. 

This TSD will be an enclosure to the letter from EPA to MDE informing ofEPA's findings on 

the MVEBs within the Baltimore Maintenance Plan. EPA will publish a Federal Register notice 

announcing the adequacy findings. The effective date of the adequacy findings will be 15 days 

after the publication date ofthat notice. Once EPA has published the Federal Register notice, the 

letter sent to MDE and this TSD will also be posted at the EPA website. 

Shown in Table 1 are the budgets from the Baltimore Maintenance Plan. The MVEBs in Table 1 

for milestone year 2017 and the out-year 2025 for PM2.s and NOx will be applied to all future 

transportation conformity determinations and analyses for the 1997 annual PM2.s NAAQS. 

Table 1. On-Road MVEBs Contained in the Baltimore, MD 1997 PM2.s Nonattainment 

Area Maintenance Plan for the 1997 PM2.s NAAQS 

Year Motor Vehicle Emissions Mobile Vehicle Emissions 

Budget for PM2.s On-Road Budget forNOx On-Road 

Emissions (tons per year) Emissions (tons per year) 

2017 1,218.60 29,892.01 

2025 1,051.39 21,594.96 

V. Evaluation of the Adequacy of the MVEBs in the Baltimore Maintenance Plan for the 

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1997 PM2.s NAAQS 

In this TSD, we are evaluating the MVEBs associated with the Baltimore Maintenance Plan for 

conformity purposes. We are using the evaluation criteria detailed in the Transportation 

Conformity Rule, 40 CFRpart 93.102(b)(2)(v), 93.102(b)(2)(v), 93.102(b)(3), and part 93, 

93.118(e)4 through 93.118(e)5. The evaluation is presented in Table 2, below. 

Table 2. Adequacy of the MVEBs Contained in the Baltimore Maintenance Plan for the 

1997 PM2.s NAAQS 

Transportation Confomtity 

Rule 

40 CFR Part 93 93.118 

93.1 02(b )(2)(iv) 

93.102(b)(2)(v) 

93.1 02(b )(3) 

Sec. 93.118(e)(4)(i) 

Review Criteria 

Have EPA and the State 

made a finding that N Ox is 

an insignificant contributor 

to the direct mobile PM 

emissions? 

Has EPA or State made a 

finding that VOCs, Sulfur 

Oxides (SOx) or Ammonia 

(NH3) as precursors to be a 

significant contributor to the 

mobile PMz.s emissions? 

Has the EPA or the State 

made a finding that reentrained road dust is a 

significant contributor to the 

PM mobile emissions? 

Was the submitted revised 

plan endorsed by the 

Governor (or his or her 

designee) and subject to a 

State public hearing? 

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Was the Criterion atistied? 

lfYes How was this Criteria 

Satisfied? 

Neither EPA nor the State 

have made such a finding. 

Neither EPA nor the State 

have made any findings that 

VOCs, SOx, or NH3 are 

significant contributors to the 

PMz.s mobile emissions, and 

therefore, they have not been 

included in the SIP. 

Neither EPA nor the State 

have made such a finding. 

Yes. The Baltimore 

Maintenance Plan was 

endorsed and submitted as a 

SIP revision by the 

Governor's designee, the 

Secretary ofMaryland 

Department of the 

Environment, Robert M. 

Summers. A public hearing 

on the SIP proposal was held 

on October 7, 2013. 
Sec. 93.118(e)(4)(ii) Before the maintenance plan Yes. Consultation has 

was submitted to EPA, did occurred among all required 

consultation between federal, federal, state and local 

State and local agencies agencies. 

occur; was full 

implementation plan 

documentation provided to 

EPA, and was EPA's stated 

concerns, if any, addressed? 

Sec. 93.118(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly 

emissions budget( s) clearly identified on pages 20-21 of 

identified and precisely the Baltimore Maintenance 

quantified? Plan prepared by the 

Maryland Department of the 

Environment. 

Sec. 93.118(e)(4)(iv) Is the motor vehicle EPA believes the budgets can 

emissions budget(s), when be declared adequate because 

considered together with all in conjunction with the other 

other emission reductions, emission reductions, they 

consistent with applicable demonstrate continued 

requirements for maintenance for years 2017 

maintenance? and 2025. 

Sec. 93.118(e)(4)(v) Is the motor vehicle EPA believes that the budgets 

emissions budget(s) are clearly related to the 

consistent with and clearly emissions inventory and'the 

related to the emissions control measures in the SIP 

inventory and the control submittal. 

measures in the Plan? 

Sec. 93.118(e)(4)(vi) Revisions to previously Yes, the Baltimore 

submitted attainment Maintenance Plan provides 

demonstrations: explain and new MVEBs for years 2017 

document any changes to and 2025 for PM2.s and NOx. 

previously submitted budgets The addition of safety 

and control measures; margins to the MVEBs is 

impacts on point and area consistent with continued 

source emissions; any attainment. 

changes to established safety 

margins (see Sec. 93.1 01 for 

definition); and reasons for 

the changes (including the 

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basis for any changes related 

to emission factors or 

estimates of vehicle miles 

traveled). 

Sec. 93.118(e)(5) Did they provide and we Yes 

review public comments and 

the State's responses to those 

comments with the submitted 

control strategy SIP? 

VI. Findings 

Based upon our review and evaluation of the MVEBs contained in the Maintenance Plan for the 

Baltimore, MD 1997 PMz.s NAAQS N onattainment Area, EPA finds the MVEBs adequate for 

conformity purposes and recommends that the MVEBs be SIP approved. 

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